ML20202G038
| ML20202G038 | |
| Person / Time | |
|---|---|
| Issue date: | 09/28/1977 |
| From: | Minogue R NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | |
| References | |
| SECY-77-515, SECY-77-515-01, SECY-77-515-1, SECY-77-515-R, NUDOCS 9902040252 | |
| Download: ML20202G038 (85) | |
Text
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SECY-77-515 Septembet- 28, 1977
! UNITED STATES NUCLEAR REGULATORY COMMISslON l
CONSENT CALENDAR ITEM For: The Commissioners From: Robert B. Minogue, Director ,
Office of Standards Development l
/ xecutive Director for Operations 6 Thru: E f Y ,- ., - ;
Subject:
NATURAL RESOURCES DEFENSE COUNCIL PETITION TO REDUCE OCCUPA- m .. !
TIONAL RADIATION EXPOSURE LIMITS (PRM-20-6) G l' 3 -.4
Purpose:
To obtain a decision on the subject petition.
Category: This paper covers a minor but possibly controversial policy question.
Issue: Should the NRC approve or deny Petition PRM-20-6 by the Natural Resources Defense Council (NRDC) to reduce the occupa- )
tional radiation exposure limits.
Decision Criteria: 1. The relative magnitudes of the hazards of occupational radiation exposure and other occupational hazards.
- 2. Potential reduction of individual radiation doses and of resultant risks.
- 3. The effects of efforts to keep radiation exposure "as l low as reasonably achievable" (ALARA).
- 4. Increase in cumulative radiation doses.and resultant risks of both radiation workers and the general public.
- 5. Increase in costs of many activities involving radiation, including radiographic and medical procedures.
- 6. Critical shortage of skilled workers for special operations such as reactor maintenance.
l 7. Increase in public safety hazards due to reduction or I elimination of important radiographic processes.
- 8. Discrimination on the basis of age in radiation work.
Contact:
Charles A. Willis 25 59M
"-M ai 443-6920 se:cjj iudus %M. twet * %xtroj N I i4 04 20 M. I 20 2 770928 '
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, l Th2 Commissioners 4 accidents. The relative risk model predicts an average age at death of about 60 for people dying of cancer caused by occupational radiation exposure at the limit. The absolute '
model predicts fewer cancer deaths but the deaths would occur at a somewhat younger age. Both models predict risks from the actual exposures received by radiation workers that are well below the actual average risk to all workers of i fatal on-the-job accidents.
Fatal work accidents are not directly comparable to radia-tion induced cancer deaths for several reasons. For example, many accidents that shorten life as much as would a radiation induced cancer are not considered fatal accidents. Work accidents cause 30 times as many disabling injuries as fatalities.3 Still, a comparison of fatal work accident rates with (theoretical) radiation cancer risks may be of some interest.
Accident rates usually are expressed in terms of accidents ,
per year per 100,000 workers. Expressed as latent cancer I produced per 100,000 workers per year, the effects of radia- I tion exposure for a working lifetime are:
- a. Exposure at the limit, 5 Rems /yr: 51 to 130 (BEIR), 25 l l
(ICRP). l
- b. Actual average exposure, 0.4 Rem /yr: 4 to 10 (BEIR), 2 (ICRP).
The "ICRP" values are obtained using the risk values in the new ICRP report.1 For comparison, the fatal accident rates i in the major industrial groups used by the National Safety j Council range from 7 (in " trade") to 117 (in " mining, quarry- 1 ing"), with an average of 17 for all industries.3 Fatal l accident rates are much higher in certain occupations such l as jet bomber pilot (300), steeplejack (500), farm machinery operator (800), and jet fighter pilot (2000).4 Thus, under the present limits, radiation workers' latent cancer risks are lower than the average worker's risk of f atal work 3" Accident Facts," National Safety Council, Chicago, 1974.
4C. A. Willis, " Safety Criteria for Nuclear Power in Space," Radiation Protection i Standards, Quo Vadis, Health Physics Society, Richland, Washington, 1972. j 1
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, w The Commissioners 5 accidents. Even'for the small fraction ( %) of radiation workers being exposed at the limit, the latent cancer risks are comparable to the average fatal accident risks of workers in major groups of industries; these maximum radiation risks are well below the fatal accident risks in high risk occupations. ;
1 Comparison of radiation risks to the risks from other toxic substances is virtually impossible. A host of substances have been identified.as carcinogenic. These substances !
range from the commonplace, such as sun light and wood dust, I to exotic chemicals. Rate and risk data, however, are unavailable. l Epidemiological studies have not demonstrated any ill effect of radiation exposure at occupational exposure levels.
- 2. Reduction of Individual Doses i
The reduction of the doses of individual workers would result from adopting the NRDC-proposed dose limits. On the order of 15% of radiation workers exceed the NRDC proposed limit each year. These doses would be reduced and in some i instances the reduction would be by a factor of 10 or more. i Other doses also would be reduced because the uncertainties !
in dose estimation and measurement compel operating organiza-tions to keep doses substantially below the limit. This ;
reduced dose to individual workers must be counted a' potential l benefit of the proposed limit, but only to the extent that :
workers are not transferred to more hazardous or less reward- :
ing work to control their radiation exposure.
An analysis was performed by the staff assuming that lowering the dose limit by a factor of 2 would not increase total exposure (or total risk) for reactor workers. The analysis l indicated that this small (50%) reduction in the limit would
! not affect the average worker but would lower the exposure (and risk) of about 6% of the reactor workers. If the reduction in dose were proportional to the reduction in the j
limit, the effect might be a decrease of less than 1.2 l latent cancer deaths annually. This small decrease was not l
deemed sufficient to justify the impact of a limit reduction l (Enclosure "J"). Of course, these 1.2 latent cancer deaths would not be prevented by the limit reduction; they would be ;
shifted from the high exposure group to the rest of the wnrker population.
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l The Commissioners 6 I
- 3. Effects of ALARA l The NRC is committed not only to keeping radiation exposures below the limits but also to keeping exposures "as low as reasonably achievable" (ALARA). The ALARA efforts are directed to the total exposure of the population as well as I individual exposures. This effort is much more effective in reducing risks than a simple reduction of the limits would be and it does not have the adverse impact that a limit reduction would have.
- 4. Increase in Cumulative Oose of the Worker Population The NRDC proposed limit reduction would be expected to actually increase the total (man-rem) dose of the worker population. This would result from the need to rotate workers between radiation work and other jobs to meet the new low limits. This would mean that less well prepared people would be doing much radiation work. Also it would be necessary to utilize several workers to do a job now being i
done by one; this would increase the exposure received while entering, leaving and preparing to do the job. One detailed analysis predicted a 450% annual increase in cumulative dose to the workers at the plant analyzed.
- 5. Cost Increases The costs of many activities would be significantly increased by the proposed lower limits. The increased cost of medical care would have the most immediate impact on the public; these cost increases would result from the need to use more ,
people.to do the work. The majority of radiation workers I are medical workers. The cost increase would be quite !
general through increased energy costs, increased radiography !
costs,.etc. A dramatic reduction in the occupational radia- ,
tion exposure limits could have a major impact on society, )
even though there are only about a million radiation workers I I
in the USA.
l 6. Skilled Worker Shortage for Special Activities Critical shortages of skilled workers for special operations would be a significant impact of reducing the limits. The current limits have required the use of 1500 people to do I the work that, in the absence of radiation, could have been j done by perhaps 15 people. Limits 10 times more restrictive would have dramatically increased the number. It is not clear that the needed people could be found.
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Tha Commissioners 7 i
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- 7. Increase in Pubiic Safety Hazards Radiography would be severely impacted by a reduction of the dose limits. Costs would be increased, much additional :
manpower would be needed and many important procedures would !
become impracticable. This could be expected to result in less use of radiography. Curtailment of radiography would increase the hazards associated with ships, bridges, pipe-lines, etc. ]
- 8. Age Discrimination The NRDC petition calls for one limit for workers less than 45 years of age and another (higher) limit for older workers.
This age discrimination was objected to in many of the :
comments received.
- 9. EPA Denial The EPA has the authority and responsibility to provide guidance on general radiation criteria, such as the occupa- :
tional radiation exposure limit. The EPA guidance is the present limit. The EPA has considered and formally rejected the limit change sought by the NRDC. The reasons given by the EPA for denying the petition are consistent with the results of the independent analysis by the NRC staff.
For these reasons it is concluded that approval of the petition would have serious adverse impacts without commensurate benefits, that current data do not justify any reduction in the occupational dose limits and that the petition should be denied.
Recommendation: That the Commission:
(a) Approve
- 1. publication of the Denial of Petition for Rule Making set out in Enclosure "G".
- 2. transmittal of a letter such as Enclosure "H" to the NRCD.
! (b) Note I- The. Subcommittee on. Nuclear _ Regulation.of the _
Senate Committee on Environment l
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! j The Commissioners 8 l
and Public Works, the Subcommittee on Energy and the Environ-ment of the House Committee on Interior and Insular Affairs will be informed of this action by letter such as in Enclosure "I".
- 2. In accordance with 10 CFR 50.5(d)(3), an environmental impact statement,. negative declaration, or environmental impact appraisal need not be prepared in connection with the proposed action since the proposed action is nonsubstantive end insignificant from the standpoint of environmental
'impiet in that there would be no change in the environment.
- 3. No public announcement will be issued.
4 General Accounting Office review is not required because the proposed action involves no new record-keeping requirements. j Coordination: This response has been concurred in by the Offices of Nucle.ar Reactor Regulation, Nuclear Material Safety and Safeguards, Inspection and Enforcement and Public Affairs. The Office of the Executive Legal Director has no legal objections to this response.
Schedulino: For affirmation at an eapry open olicy sion. Anticipated scheduling the week of 4,ctober 19 6 . .
Robert . Minogue, Director !
OTfice of Standards Development
Enclosures:
"A" - NRDC Petition and Supporting Document "B" - EPA Denial "C" - List of Commenters "D" - Staff Analysis of Comments j "E" - BEIRCAN Report "F" - Value/ Impact Analysis 1 "G" - Denial of Petition for Rule Making I "H" - Draft Letter to NRDC "I" - Draft Letter to Congressional i Committees .
"J" - Analysis of the Effect of Dose ,
Limit-Reduction l
! i I
l NOTE: Request staff forward technical questions to R. Alexander prior to October 19 in order to take advantage of the author's background knowledge. After that date he will not be available.
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9 Commissioners' comments or consent should be provided directly to the Office of the Secretary by Wednesday, October 12, 1977.
Comission staff office coments, if. any, should be submitted to the Comissioners NLT October 6,1977, with an information copy to the Office of the-Secretary. If the paper is of such a nature that it requires additional time for' analytical review and comment, the Commissioners and the Secretariat should.be apprised of when coments may be expected.
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Enc 10:ed please find fi/:s ccpice of the Matural P.c sourc00 Defonne Ccu:.cil's Petition to 11. nd 10 CF2 20.101, Experure cef I .dic/iduals te .ncdiatics in Restricte d
'I. recs, tc~at'.er with ccpies cf the supporting report
" Radio. tion Stanf ardn for Occupational Yhole Sody Exposure , '
dated Septe:ter 25, 19'T5, which .re herewi d file with the Cc=1 sien . .
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BEFORC THE hUCLEAR REGULATORY COCIISSIO(.h eg.. g,*; Sif,*f,"
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In The Matter Of )
) NRC Dochet No. ;
l Rh,DIATICN PROTCCTIO:1 STJJ:DARDS }
FOR CCNTROL OF OCCUPATIC::AL ENPOCUP.E )
i PETITION TO AME:*D 10 CFR 20.101 Exposure of Individuals to Radiation in Restricted Areas The NATUh.L RESCURCCS D2rENSC COUNCIL, I:!C . , ("NRDC " ) , on its own behalf c ' en behalf of its =c=bers, hereby petitions the Nuc1 car l
Regulatory C;.nission ( " N RC " ) to amend its rarl.i nt.ipnn, rotection I
standards as they app:cf to the naximum permissible whole body dose equivalent fer cccupational expesure as tera fully described in i the rcport, R: diction Standards for Cccurational Ynole Sedv En Ostre, ,
I by Thc=cs B. Cochran, Ph.D., and Arthur R. Tamplin, Ph.D., subnitted herewith. Thim atendment vould have the same effect maasured by the reduction in genetic and somatic radi5 tion injury as wculd be achieved by reducing the current maximum permissibic whole bcd?
dose equivalent for occupational exposurc by a factor of ten fer genctic injury and six for somatic injury. This request is filed pursuant to 5 U.S.C. S 553 (c) and 10 CPR S 2.802.
Enclosure "A"
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! Identification of Petitioner J l
. 1 Petitioner NATURAL RESCURCES DEFENSE COUNCIL, INC., ("N RDC" ) , i 4
is a non-profit, membership corporation organi:cd under the laws l I
of the St' ate of New York, NRDC is a charitable organization exc pt from taxation under Section 501(c) (3) of the Internal Revenue Code.
NRDC's principal office and place of business is located at 15 West 44th Strcot, New York, New York. It maintains other offices at 917 15th Street, N.W., Washingtcn, D.C., and at 664 Hamilton Avenue, !
Palo Alto, California. NRDC has a nationwide ne=bership of persons dedicated to the defense and preservation of the human environment and ,
the natural rescurces of the United States. GLher persens support 1
NRDC's objectivos by financial contributions and personal ef forts.
The objectives of URDC include:
(a) to =sintain and enhance the quality of the huren '.
environr.cnt; (b) to ronitor federal departments and regulatory agencies to ensure that environtental values are fully consilerod in decision =aking, and, in particular, to ensure that federal I statutes designed to protect and enhance the enviren=cnt are fully and properly implemented; (c) to improve federal agency decisienmaking which affects
- the environment by cor.manting, furnishing information, and initiating and participating in administrativo prcceedings; i
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l (d) to Ocicct and undertche environmental 1:wsuite which i
l have a potential for establiching widaly applicabic procedenc Enclosure "A"
. . . __. . . . . _ _ __. _ m __ _
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for caving, reclaiming, or protecting t;me important aspect of our national endowment, including the health and safety of the public; and (e) to provide a1 central, national focus for scientists, t lawyers, and educators, and cencerned citizens in an effort to make our ccurts and adminis'trative agencies effective instruments of environmental protection. j l
In pursuit of its objectives, NRDC has been involved in many i l
proceedings involving the Atc'mic Energy Commission and now the Nuclear Regulatory Commission.
Petitioner's Interest in the Proceedinc NRDC's basic interest in the captioned proceeding is twofold:
(1) to protect present and future ::RDC members, their progeny, and the public by ensuring the public is'adecuately protected frem genetic insults resulting frem werher'whole body exposure.to radiation, and (2) to protect.present and future NRDC menbers, their progeny, and the public where they are en occasien euployed by NRC licensees in rectricted areas by ensuring that radiation workers are adecuately protected from cxposure to whole body radiation, by establishing adcquato radiation standards gevorning n:aximum permissible occupa-tional whole bcdy expecure to radiation.
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_Supenrtinn Statreent httached to this Petitien is a Report prepared by Thomac B.
Enclosure "A" 1
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l Cochran, Ph.D., and Arthur R. Tamplin, Ph.D., entitled, Radiation l
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Standards for Cccupational Wholc Body E::posure, dated September 25, .
i 1975. This Report and the documents rcforenced therein provide the f, 1
l principal support for and elaboration of .this Petition. ,
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Proposed Action I The NRC regulations governing permissible' occupational exposure icvels to radiation are set out in,the Code of Federal Regulations l at 10 CFR 20.101. At present these 10 CFR 20.101 regulations li=it l the whole body dose to 1-1/4 rem per calendar quarter (5 rem / year), .
except a licensee may permit an individual to receive up to 3 re=/
l quarter whole bcdy dose as long as the dose to the whole body, when i added to the accumulated occupatio$al dose to the whole body, shall ecuals the individual's age in years. l not e::ceed 5 (3-19) rem .there "N" .
- The objective of the proposed action is to reduce the genetic risk associated with radiation e::posure at the current cccupational t
i enposure icvel by a facter of 10 and reduce the somatic risk by a factor of 6. To meet this cbjective it is requested that tna c"rrent l
regulntions $e amended as follows:
- 1. For individuals under the age of M, where M is not less than 45, the whole body radiation exposure 1imit shall not exceed 0.5 rce l ,
in any calendar year and 0.3 rem in any calendar quarter.
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- 2. For individuals equal to er greater than M years of age, n licen co may permit an individual to receive up to 3 ren/ quarter whole body docc as 1cng as the do::o to the wnole body shall not "A"
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cxeced (0. 5) (:*-18) + X (N-M) rem,-where N equals the individual's age in years, a.kd X is calculated to reduce the cunulative somatic risks by a factor of G below the cumulative risks associated with exposure at 5 rem / year from age 13. It is proposed that the value l
L of X be calculated using the relative risk model as describe.d more -
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j fully in the BEIR Report. :It'is further requested that:
- 3. The NRC institute hearit.gs to determine the "as lou as prac-l ticabic" extent to which the' exposures can be maintained bel _ the proposed new' regulations.
' Time for Acticn We believe that ma$ters of importance to human health and .
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safety recuire prcmot-action. The matters ue raise here are based on data generally knoun and available for sc:e time. . Allowing a
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reasont.ble period for public cc==ent, we reccamend that the standards requested be set within six cenths.
Conclusicin i
The requested action represents minimum steps which must be taken to protect radiation workers and the public frem the dangers 9
_/. Naticnal Academy' of Sciences', National Research Council, "The ;
Effects on Populations of Exposure to Lcw Levels of Icnizing Radiation," ;
Report of the Advisory Committee on_the Siclogical Effcets of Ionizing j Radiations, Nove.nter, 1972, p. 171. It is proposed that the plateau regicn, i.e., the-interval following the latest period-during which the risk remains clevated, for cancers ether than leukemia be taken !
ac tho' lifetime of the individual. The relative rish model uit.h L
the lifc:tico p3ntcau assumptien gives the upper limit estimate of
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- _ tho.rish.
Enclosure "A" i
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of radiation. Further actions consistent with and in furtherance of the Report submitted herewith, including the adoption cf addi-tional standards and guidelines, should be considered by the NRC i
to assure that workers and the public are provided the full pro-tcction to which they are entitled.
Ecepectfully submitted, f'
J. Gustave Speth NATURAL RISCU?.CES OEFENSE CCU CIL, I;;C:
917 Fifteenth Street, N . h' .
Ifa shington , D.C. 20005 (202) 737-5000 Attorney for Fetitioner t .
Datad: Septerior 25, 1975 .
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Enclosure "A" G
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P i . 1 Natural Resources Defense Council,Inc. -
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1 RADIATION STIJ!DAP.DS FOR OCCUPATIONAL WIiOLE EODY E:GOSURE : I J
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I September 25, 1975
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1 Thomas B. Cochran Arthur R. Tamplin ;
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' Enclosure "A" a
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I. Introduction ,
This Report is written in support of a petition by the Natural-Resources Defense Council (URDC) to the Nuc1 car Regulatory Commission (NRC) requesting a reduction in the ma.Mimum permissible occupational whole body radiation exposure.
The present standards for occupational exposure are based on i still current recommendations.of the National Council on Radiation Protection and Meast ements (MCRP) and the Inter-national Commission on Radiological Protection (ICRP) adopted in 1958 and 1959, respectively. The NRDC petition and this !
Report were prompted by consideration of the latest infor-mation on thn biological effcets of radiation. This infor- l J
cation indicates that the bioldgical effects are greater than 1 was assumed in 1958 and 1959 when the existing standards were recommen6cd.
- The latest data have been revicwed by a committco of the ICRP u.;d by the BDIR Commit' tee of the U.S. Nationaa 1,2/
Academy of Sciences (NAS) . The BEIR Committee was prin-
. . I cipally concerned with the exposure of the general Sopulation 1/ ICRP Publication 14, Radiosensitivitv and Spatial Distri-bution of Doac, Reports Prepared by Two Task Groups of Con'mittee 1 of the International Commission on Radiological Protection, Pergamon Press, Oxford, 1969. .
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2/ NAS-DEIR Report, National Academy of Sciences, The Ef fectq on Poualations of ihuncure to Low Levnis of Ionininc Radiatinn. --
Report of the Advinory Cornutttee on the Biological Ef fcets of Ionizing Radiation (CCIR Report) , Washington, D. C., November, 1972.
Enclosure "A"
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- 2-l and, in'this regard, indicated that the existing exposure '
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i standard was" unnecessarily:high. The ICRP Committee, l
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whilo declining to mako any. rocommendations, presented a calculation to demonstrate how the new . data on the biological ja ef fects of radiation could be used to lower the existing .
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whole body exposure standards by.a factor of ten. 'The :
=l reduction requested in this Report corresponds closely to 1
this f actor of ten in the ICRP Committee analysis.
In January, 1971, while not:rocommending an overall l
change, the NCRP reccamended that the_ occupational exposure ,.
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of. pregnant women .be limited to one . tenth the present exposure 5/ -
The reduction requested in this Report would also limit. ,
l fulfill this NCRP recommendatic,n. ,
1 In the following section of this Report, we shall '
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-present an analysis of the risk of sematic.and genetic in]ury j
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at the current maximum permissible c::posure limit and comparc this' risk with those encountered in other occupations, This l l
i analysis will serve to indicate'that tho' exposure limit is too high. In Section III, uc shall present our requested modifi- ,
i 3/ Ibid.,.p.2. ,
- i 4,/ ICRP - Publication 14, o_n_. cit. , Ac. c. endix IV. ,
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[ 5/ NCRP Report No.39, Basic Radiatien Protection Criteria, ;
i' Natl.!nal' Council on Radiation Protection and :casurement, i l Washington, D. C., 1971,'pp.'92-93. .
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Enclosure "A" 6
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1 cations of the exposure limits and an analysis of the reduced ,
In the final section, risk ascocia'ted with these new limits.
we shall indicate how these requested reductions relate to the recommendation and suggestions of the ICRP, NCRP, and I
the UAS Cc=mittcc on the Genetic Effects of Atomic Radiation.
l II. Radiation Induced Risk at the Existina Occupational Whole Dody Doso Limit The latest and most comprehensive revicu of the biological effects of radiation on man is the NAS's 1972 SCIR Rcport. The DEIR Ccamittee reviewed both the somatic and i genetic rish associated with exposure to low levcis of ionizing ,
radiation. We shall discuss first the sematic and then the acnctic effect!;.
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I A. Sematic Effects i i
Tabic 1 summarizes the EEIR Report estimate of the excess l
! annus] cancer and leukemia deaths per million people assuming
, tihole body e::posura to 5 rem /ycar (the ' current occupational 1/
standard) . .
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6/ tlAS-BEIR neport, oo. cit., p.170.
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Enclosure "A" f
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l Table 1 Calculation of the excess annual number of cancer deaths for individuals exposed from 20 to 65 years of age ,
ABSOLUTE RISK MODEL RELATIVE RISK MODEL Exposure Conditions Excess Deaths Due to: Excess Deaths Due to: )
All Other All Other Leukemia Cancer Leukemia Cancer 10' people: 5 rem /yr. 81 (a) 300 181 (a) 601 (b) 336 (b) 740 l
l (a) 30 year plateau .
l (b) lifetime plateau i
(Plateau region = interval following latest period ,
j during uhich the risk remr. ins estimated) . j
. Source: NAS-SEIR Report, p.170. .
O The rich esti=ates in Tabic 1 incorporate the assumptien that the million people have an ago and sex distribution identical to that of individuals 20 years and older in the.U.S. populatica (1967 statistics) . These figures do not, represent a 20 year old individual's chance of eventually dying of radiation induced cancer (assuming exposure at the 5 rem /ycar limit) . This chance can, he.tever, be calcula ted by using the overall This v mortality rate for individuals over 20 years of ago.
death rate in 1973 was 1500 deaths per 100,000 populaticn.
llence, if this rate in divided into the frequoney of cancer 1
deat.hn given in Table 1, the chance of a worker, exposed at
, Enclosure "A"
t 5 rem / year frc,m age 20, dying from radiation induced cancer ,
e :
is calculate'd to be from 1 in 16 to 1 in 40. We believe .. l this 3 cvc1 of risk is c::cessive. 4 i
A means of illustrating the excessiveness of the l radiation rish to workers exposed at the maximum permissible i
dose rate is to ecmpare tnis rist, witn ene fatality rate ,
associated with other occupations. .This comparison is given in Table 2. .
i Table 2 .
ratality Rate by Occupation Occuentien Yearly Fatality Rcte Rodistion I.orker - exposed :
at the cc.rrent maximr:a permiesible dose rate a
. (from Tcble 1) 1 in 1000 to 1 in 2600 United States (1973)
.c .
1 in 6000 -I ,
All Industries "C . ' ' e- . (
. ,e Mining and Quarrying r 1 in 900 England and Wales c All Occupations (males) 1 in 5000 to 1 in 10,000 l
l l a Duc to cancer : nduced by occupational whole body e>:posure (at 5 rem /yr.) enly. ;
b National Safet.y Council,. Accident Pactr., 1974 edition, 1974, p.23.
c D.scann ia! f:n"H i r.*r. t for ".nnland and % 1 09 'h c i nt r .r Genera.1'c 1".;9-19 M. Occupational :lartality. Part III, i Vol.2. !!".N London (29:0) an referenced in'ICn? Pubiication 8, p.60* Enclosure "A" l
i l-
m
.o_
In making the above comparison, we believe that the upper limit of the radiation induced risk should be used.
The BEIR Committee cautioned that its esticate may be too 7/
high or too low.
One reason for cuggesting that it is too lcw is that the lincar hypothesis is used as a basis for :
extrapolating from high dose-high dose rate data to lou J dose-lcu rate situations. Pecent evidence suggests that 1 j
the linear hypothesis may underestimate the ef fect of lcv J dose-lou dose rate irradiation. The late =t information has been summarized by Dr. Karl Z. Morgan who concluded:
Frequently in the litarature it is stated : hat the linear hype hesis .
is a very conservative assurptien.
During the past f e .? years, he.tever, many studios have indicated that this probably is 1.ot true in general and that at icw doses and dose ratas somatic damage per rad (and espacially that from c-irradiation) prcbably is usually greater than veuld be assumed on the l.inear h.ro:hasis. 3/
Thus, there is littla justification for relying on j
the lo.ter estimate of the radiation indu:ed risk and prudent health practice would indicato that the upper limit should be used. When thi~s is donc ,11:spection of Table 2 indicates that ;
1 l
7/ Ibid., p.90.
1 C/ Morgan, Karl Z., Suggented Reduction of Permissible Exposure to Plutonium and Other Trancuranium 01, rents, Journal of American Industrjal W/gicnc, Augu'st, 1975.
Enclosure "A" l l
1
. i i
+= me.
1 l
. -7.- \
. l the estimated radiction exposure risk corresponds to that j l
associated w'ith mining and cuarrying, a risk that is acknowl- l l
I cdged to be far too high. The radiction exposure risk exceeds the average occupational risk by six fold. In this report, we are proposing a reduction in the risk of radiation indiced cancor at the maximum allevable- whole bcdy exposure by a factor of 6 together with the recuest th'at the exposures be
~
kept as far below the proposcd neu limits as is practicable.
In making the above compcrison and proposing this reduction, we do not mean to imply that all radiation workers are l l
exposed to the maximum level of the current standards. We only maan to imply that the current expcsure standard is an inapprcpriate guideline agai'ned uhich to a," ply-the as-low- ,
as-practicable rule.
)
I It could be argued that it is not appropriate to set the maximum exposure limit at a level that corresponds to the average occupational fatality reto because the limit applies in practice only to the most exposed individuals.
But it is precisely these e st exposed workers about whcm we must be conderned, and we see no reason why the nuclear industry should subject its workers-to an above-average risk, certainly not when that rick is comparabic to that in the mining and quarrying inductsy. Morcover, we believe tlyis approach in appropriate becaurc radir. tion werkers are alno Enclosure "A"
- - -U- ,.
l subject to normal n>n-radiological occupational hazards, ,.
and hence the avercyc risk in the industry will still be
~
above the average for all occupations even with the adoption of our proposed changes. Thus, it would even be reasonable to argue that the risk of radiation induced cancer should I
be further reduced. Consequently, uc see no justification i i
for a higher rish, particularly since the above estimete of the cancer and leukemia rish does not include the additional risk associated with radiation induced genetic damage. l l,
B. Genetic Effects The BEIR Report estimated that .the total incidence of all identified serious genetic diseases due to 5 rem per generation to a population of 1 million would be between 300 9/
to 7,500 per ycar at equilibricm. In addition, the BEIR Report estir.ated that this same exposure at equilibrium would eventually lead to an increase of between 0.5% and 5% in the ill health of the population.
The approach for estimating the genetically sigt.ificant done (GSD) is to use that exposure accumulated r-by age 30. The existing exposurc lipit wculd allow a iorker
. exposed at 5 rem / year from age 18 to accumulste a dose of 60 rem by age 30. !!cnce, based on the BEIR Report estimatos en
- e 9_/ S.13-UUIn nepnrt, g.1. cit., p.51.
Enclosure "A" ,
e e
$$9 99$' 69 Oh
1
/ '
l I
P above, if one million workers were exposed from age 19 f
at the current 5 rem /ycar limit, between 3,600 and 90,000 l
\
i identified serious genetic disease and a significant increase of ill-hcalth would show up in the progeny of I
these workers, assuming an average of 2 children per worker. j The increased incidence in ill-health wculd be equivalent to between 65 and 600 of the incidence in a' population of 1 million, e.g., the first generation. This genetic risk can be compared with the se:natic risk to the workers themselves.
Thus, an individual vorher c:: posed at 5 rem / year from 18 to ,
I l
65 years of age vould incur an additional risk of fatal cancer between 1 in 16 and 1 in 40, and an additional risk of between 1 in 10 and 1 in 300 that one of his progeny will incur a serious genetic defect. In terms of the raw numbers, the .
-sematic and genetic risks overlap quantitatively. This simple comparison of the senatic and genetic ricks associated with !
a singic worker's lifetime c::posure assunes equal weighting of ,
j the hurt or suffering associated with the somatic and genetic damage. -
The genetic rish is different in that the offect is l suffered not by the workers but by their offspring and by future generations. As a consequence , one can argue that dic genetic risk should bc 9,iven more weight because it is not accumed by the worker but involuntarily by their offspring l l
and by futurc genurations. McVerthclass, the biological dnta ;
Enclosure "A" l
~
l
s - - l. u -
i i
indicates that the rish of ' genetic. damage is. comparable to the leukemin and cancer risk and, therefore, is also too high regardless of :ny speci.a1 weighting that it deserves.
Again, we strongly suggest that the upper limit estimate of the genetic risk be used in this comparison. j The BEIR Co:nmittee suggested caution in the use of these l cstimates and began its Discussion section by stating:
A major con-corn of the Subcommittee is the possible e::istence of a class of radiation-ir.duced genetic damage that has been left out of the estimates.
By relying so heavily on c::perimental '
data in the mouse we may have overlooked important effee:s that are not readily detected in mice, er the mouse may r.ot i be a prcper laboratory model for the study of man.10/
l As if to reemphaci:c thic, tha 'C :a.ituse concluded this section by stating:
We remind all who =ny.use our estimrates as a basis for policy
' decisions that those estimatos are an attempt to take into account i only known ter.-i'ble ef f ects of ;
i radiation, an.d that there may wcll be intangible effects in addition whose cumulative impact may be appreciabic, although not novel.ll/
There is reason to suggest that the BEIR Ccmmittee should have implied an even more cat ticus approach to their I
i l
l 10/ Ibid., p.57. -
11_/ lbid.
Enclosure "A"
-e er e age e i
= .
cst ites. In the experinc. hts of Dr. William L. Russell at the vak Ridgc National Laboratory, it uns observed that the induced mutation frequency at low dose rates was about 1/3 i
that observed at high dose rates. The factor of 1/3 was used by the EEIR Committee. !!owever , Dr. Mary F. Lyon, et al., have analyzed the Russell data along with additional' data from -
12/
. experiments at low dose rates. Their analysis shows that as the doso rate drops below some 0.01 r./ min. , the induced mutation frequency begins to increase. They conclude:
In future estimatas of the genetic hazards of environmental radiation, therefore, it would be prudent to increase this last figure to a value above that seen in mice at 0.01 r./ min.,
for which the maximum likelihood estimate givqn by the data considered here is 10 N'10-8.13/ l l
The value adopted in the BCIR Report *.:as 2.5 X 10-' mutations per locus per rem or a factor of 4 lower. l i
Thus, once again thare is little justification fer relying on the lower limit estinate and prudent health practices indicate that the upper limit estimato should be empaoyed in establishing radiation protection standards.
The upper estimato of the genetic rish (1/10) is comparable l 12/ Lyon, Mary F., D. G. Pap >..' orth and Rita J. S. Phillips, l
"Docc-rate and !!utation Frcquency af ter Irradiation of !!ouse l Spermatoc:onia ," Mature ::ow nieleav , Vol.238, July 26, 1972,
'pp.101-104.
13/ Ibid., p.104. .
, Enclosure "A" -
w- .* -
i l
l
- 12- i I
.~
to the upper limit estimate of the somatic rish of 1/16, and i
Olis genetic' risk, lihc thc. somatic rish, is excessive. When l somatic rink and genetic rish are cc=bined (on an equal' weight basis) , the combination suggests that the existing exposurc standard is at least 10 times too high. In this Report wc are proposing a factor of 10 reduction in the genetic risk and a factor. of 6 reduction in the somatic risk with the additional I
request as stated previously that the exposures be kept as far below the proposed new limits as is practicable. )
1 l
l III. Procosed Action -
i
! l l
i i I i l The .1UU: regulations governing permissible occupational l
exposure levcis to radiation arc embodied-in the Ccdc cf Fcdcral a
Regulations at 10 CFR 2,1,101. At present these 10 CFR 21.101 I
, regulations limit the whole bcdy dcse to 1-1/4 rem per calendar quarter (5 rem / year), encept a licensee ray permit an individua' .
i to receive up to 3 rem / quarter whole body dose as long as the dose to the whole body when added to the accumulated cecepaticnal dose to the wholc, body, shall not exceed 5 (N-18) rem where.
! "N" cquals the individual's ago in years, i
The objective of the proposed action.is to reduce the genetic rish associated with radiation' exposure at the current occupational enposure icyc1 by a factor of 10 and reduce the somatic risk by a factor of G. To meet the objectivo r'clative to the genetic rink, it in proposed that the current regulations
- be amended an follcun
Enclosure "A"
- . _13 ,
- 1. For individuals under the age of M, where M is not less than 45, the whole bcdy radiation ;
i exposurc limit shall not exceed 0.'5 rem in any calendar year and 0.3 rem in any calendar quarter.
To meet the objective relative to the somatic risk, it is proposed, in addition to the above, that:
- 2. For individuals equal to or greater than M years of age, a licensec may permit an individual to receive up to 3 rem / quarter uhole body dose as long as the dose to the whole Lcdy shall not .
cxeced'0.5 (M-18) + X (N-M) rcm, ahere N 9 equals the individual':s age in years,'and X is calculated to reduce t'he cumulative somatic risk by a factor of 6 below the cumulative somatic risk associated with exposure at 5 rem / year from age 18. It is proposed that the value of X be calculated using the relativo risk medel as described l more fully in the DEIR Report.
14/ ins-CUIR Raport, og. cit., p.171. It is proposed that the platcau region, i.c., the interval following the latest period during which the risk remains clevated, for cancers other than leukemia bc :hken as the lifetiac of the individual.
The relative ri.sh model with the lif etime plateau assumption given the uppe:: limit estimate of the rick.
Enclosure "A"
It is further requested that:
- 3. The UnC institEtc hearings to determine the "as icw as' practicabic" cxtent to uhich E the exposure can be maintained below the proposed new regulations. l The effect of these pr$ posed changes will be to
- reduce the genetic risk from occupational radiation exposurc f at the limiting value by a factor.of 10 to about 1 in 100 -
and reduce the risk associated with the induction of fatal .
cancers to about the same level. Again, it should be recognized that the ordinary cccupaticnal risks and the risk assccinted with other than whole bcdy irradiation must be cdded to these whole bcdy radiation risks. Never- ,
tholess, the whole body radiation risk is still quito large and therefore, it is essential to maintcin che actual )
exposures as far below these proposed new limits as is practicabic.
IV. Additional Justification l The DEIR Cc=mittee of the MAS reviewed the more recent data on the biological effects of radiation. They l
l ucro concerned mainly with the expostrre of the general public.
l In this respect the Coinittee concluded that the current 15/
' Radiation l'rotection Guide wan unnecessarily hich, a conclusion
- NA:1-1EIlt actor C on. cit.,.p.2.
3 5./ --
Enclosure "A"
i -
~
which in our judgment shou 1d be equally applicable to occupational cxposure standards.
A Commi':tce of the ICRP in 1969 reviewed the same material that formed the basis for the DEIR Report and indicated that the somatic effects of radiation were 5 to 6 times worse than was estimated previously. The ICRP made no r" commendations relative to the exposure standards; rather, it stated:
The choice between no change and a partial and tentative revision will
)
depend, so it seems to us, not only j on a scientific assessment of evidence, j but also on practical considerations, l such as the general desirability of .
stability in the reccmmendaticas over a period of years. The balance between practical co4siderations and inccmplets scientific evidance is a matter for judgement outside 'the Task Group's frame of reference. Neverthclcss, it seemed useful to give an example in Appendi:: IV of how our conclusions
. about relative tissue sensitivity to cancer induction by radiation might be used as a basis for cetting dose limits for individual tissues and organs and perhaps for the whole body.16/ l i
1
, _1_6/ ICRP - Publication 14, on. cit., p.33.
l
- Enclosure "A" i
l .
j i
4
-lb- ,
In Aplandix IV, the Committee ar.alynis indicated that, uhen the somatic and genetic effects are ccebined, the whole body exposure limit should be reduced by'a factor of 10. Thus, the changes proposed here are in accord with this ICRP Committee analysis.
Both the ICRP and McRP have, recommended that special l
consideration should be given to pregnant and fertile females.
In fact, in Januarv, 1971, the NCRP recommended:
During the entire gostation period the maximum permissible dose ecuivalent to the fetus from occupational exposure of the expectant mother sneuld not exceed 0.5 rem.17/
The changes proposed in this Report v.ould in ef fect accomcdate this rccc=mendation of the NCRP.
The AEC, while achnc'.:1cdging tha greater.sencititity l
of the fetus, did not amend the dose limiting sections of the l l
Ccamission's regulaticns (10 CFR 20). So far as pregnant or l 1
I fertile uomen are concerned, the AEC noted difficulties in sex dircrimination, right-to-work and right-to-privacy as 18/
reasons for not changing the limits. The change proposed here, since it applies to both men and women below the ago j of 45 climinates these dif ficulties.
In further justification for not changing the dose limits for pregnant and fertile ucmen, the AEC stated in its l
L j 17/ NCRP Repor t :.'o. 39, oo. cit., p.92.
18/ Fi :le ra l Reai.;ter, Vol.40, No.2, ?riday, January 3, 1975, ,
pp.709-000.
Enclosi:re "A" l
ew ' ee
17 1
. 1 Federal Encister notico:
Reduction of the dose limits for ,
all radiation workors in order to avoid discrimination against women does not appear practicable. Such j a reduction in the dose limits would cost the nuclear industry large sums of money in the application of design and engincering changes and, in some cases, the emplof m nt of additional '
workers in order to accomplish essential work within the reduced individual dose i 1
limits. The latter could even result in ;
a net increase in total man-rens of exposure. l I
Reduction 'of the doso limit for all workers would aggravate an existing shortage of availabic manpower in certain key occupa-tions, e.g., radiographers, welders, and pipefitters, that may involve relatively ;
high radiatien exposure.- 19/ j Uhile we disagree with the philosophy for setting
. I radiation star.dards implicit :$ the reference to the largo sums of money it vould cost the industry, we note that the i
changes proposed here do not cause all workers to be limited to 0.5 rem / year. ' Fur the rmor e , the 3 rem / quarter limit is retairad for older workers. Hence, the preposed changes should not place a large burden on the industry. For exampic, the AEC stated in the Federal Reci' ster noticc:
}
~
19/ Ibid., p.799..
\ -
l Enclosure "A" I
1
I-t
_1g_ !
, j Data on c.Sults of personnel monitoring reportad to the ,
Commission pursuant to 320.407.
~
10 Crn Part 20, for calendar year 1973, indicate that 67,8G2 individuals were monitored, 29,169 -
roccived measurable exposures ;
averaging 0.73 rom for the year, -
and.3,425 individuals (11.8 per- ,
cent of those receiving measurable
~
exposurcs) had estimated exposures - !
, in excess of 2 rems.20/ ,
4 If M in the proposed regulations were set at 55 years i
! i and X at 3 rem / year, the necessary reduction in cancer fatalities ; l I
would be achieved. If the werk force has the same distribution I
as the population, then some 161 would be ever 55 years old I l and the above quotation indicates that only 12% are presently '
exposed above 2 rem / year. If M were set ct 45 and X at 1.5 rem / year, the cancer reduction vould be achieved, and'sene 37%
of the ork force could be expected to be above 45. In this ,.
latter case, by limiting the exposure of workers over 45 to 0.5 ren for 2 years, these same workers (12% of th.e work force in any one year) could roccive 3.5 tem in the third year. ,
Morcover, t
since there is good reason to believe that the present P l
exposures are not as low as practicable, the industry should ;
not have great difficulty in confor.ging to these proposed :
. regulations.
20/ Ibid., p.799.
Enclosure "A" I -
l 9
% mw9
_19 l..
In conclusion, we note diat our proposal for limiting the exposure of younger workers while alloyring a i
higher exposure to older workers is not ncw. It is, in fact, similar to a 195G roccmmendation of the NAS Committee en the Genctic Eff ccts of Atomic Radiation in' the DEAR Report:
F) That overy effort be made to '
assign to tasks involving higher ra-diation exposures individuals who, for age or other reasons, are unlikely there-after to have additional effspring. Again it is recognized that such a procedure will introduce complications and difficultics, but this committee is convinced that society should begin to modify its procedures to meet inevitable new conditions.21/
We submit that this recommendation is even more appropriate today. Its justifiyation en genctic grcunds is undiminished while, at the same time, the cancer inducing potential of radiation is now recognized to be much greater and the high radioscasitivity of the develeping embryo and fetus is a2so nou recog.ti:cd. In the presence of an ,
expanding nuclear industry, the.cime to implement this recommendation has arrived.
21/ NAS BEAR Report, National Academy of Scicaces, The niolocical offecta. of Atomic Rndiation, Summary Reports, Report of tho l Committcc on Gcnctic Effects of Atomic Radiation, Mathington, D. C.,
l 1956, p.29. ,
Enclosure "A" E
l l
l -
k
. s 7 '. l 4
l 4
rick of genetic effcet uculd ducrease from 6 percent to betvecn 6.025 cnd 6.50 percent. These conctic rick estimates cannot hc teken as ebsolute predictions, nd are most likely overestie:tes; hevcVer, even under cuch ascu ptions, the risk for preconceptucl exposure at the RPG '
is very low cc pared to the ncr=al incidence of genetically induced l disease. We do not belicyc reducing the RPG as suggested would n:cessarily result in loverint; pcten tal genetic ef fects to the progeny cf those occupationally expcsed :: rcdiation. Wherecc the evercge individual exposure may be reduced by appro;ricte controls in ccnc circunstcnces, it is likely in =cny situations thct the person recs of cxpecure vould not decrocse and =ay vell increcsc.
Current Federal guides for occupational exposure constitute a totc1 '
system with tuo principle cdtonitiens: 1) no exposure without "the ,,
a-. - expcetation of benefit," and 2) maintencnce of actual expecurcs "as icv as [rcasenchly achievcble]." The avorcge annuci RPG tust be recognized net es a per=issibic exposure year after year, but one uhcrcin cn Othervice, i' individual can be expeced if a circunstance justifies it.
the exposure is to be at the levest rescene.ble level. This interralated system of guides has produced, for the occupatienclly exposed verk force, an cvercge cr.nual doce of about 0.2 rem per year to those monitored. Although it is technically possible for an individual to cccumulate doses et f rces per ycc: fer a verking lifetite, in a l
practical cense it would be most difficult. We believe that futurc ,
guidance for occupational rcdicticn e:posure and its adninistration 1 should be such that the average enpesure is censiderably below the RPG
- es has been the experience to da:c. ;
. ,4 On the bcsis of the abcvc cencider:tions, the Agency is not l persuaded that the RPG should be icvered to the level petiticned, and therefore, vc are denying the petition. k'e hsyc nc: yet dcccrained what ;
value vc will rccc==end for the whole body RPG; thus, we vill keep in !
mind the concerns ce.precsed by NRDC as we continue our program to revisa c:
the current Federal guidance on occupaticnal expcsures to icnizing l4
.;.i . radiation. That effort has, with the cssistcnce of a Federal l Interagency Ccenittee, progressed to the point where uc hope to provide
.317 We vculd relec=c
'd" our conclusion within the next several conths.
'./
continuing interest by,NRDC in this effort.
lC Sincorcly yours,.
'Q
- < } h ,
\
e *[
W. D. Ecre, Ph.D.
j' -
Deputy Assic cnt Ad inistrater for Radistien Progrcms (AW-458) e Enciosure "B" l
l*
l i
I
a ,
i ENCLOSURE C LIST OF COMMENTERS
- 1. Margaret Liss, M.S., Wausau Hospitals, Inc., Wausau, Wisconsin l 54401 11/21/75
- 2. Lionel Lewis, Certified Health Physicist, Charlotte, N.C. 12/10/75
- 3. Ronald V. Scheele, Radiation Physicist & RSO, St. Vincent Hospital, Green Bay, Wisconsin 54305 12/10/75
- 4. C. Eiche1dinger, Manager, Nuclear Safety, Westinghouse s N
Electric Corporation, Pittsburgh, Pennsylvania 15230 12/16/75
- 5. Dr. Alan L. Orvis, RSO & CHP, Mayo Clinic, Rochester, Minn.
55901 12/16/75 l
- 6. W. F. Heer, Manager, Materials Plants, Babcock & Wilcox Apollo, Pennsylvania 15613 12/19/75 I
- 7. Daniel C. Kasperski, CHP, Council on Energy Independence, -
Chicago, Illinois 60690 12/23/75 B. A. N. Tschaeche, General Electric, San Jose, California 95125 12/23/75
- 9. R. L. Bolger, Assist. Vice President, Commonwealth Edison, Chicago, Illinois 60690 12/29/75 l
- 10. Anthony Mazzocchi, Oil, Chemical, and Atomic Workers International Union, Washington, D.C. 20036 12/29/75
- 11. Jene N. Vance, Bechtel . Power Corporation, San Francisco, Calif. 94119 12/30/75
! 12. Dr. Joyce C. Lashof. Director of Public Health, State of Illinois, Springfield, Illinois 62761 1/ 8/76 l
- 13. William L. Porter, Duke Power Company, Charlotte, N.C. 28242 1/16/76
- 15. John M. Arras, Defense Nuclear Agency, Bethesda, Maryland 20014 ,
1/28/76
- 16. Dr. Lauriston S. Taylor, NCRP, Washington, D.C. 20014 1/29/76
- 17. J. E. Gilleland, Tennessee Valley Authority, Chattanooga, Tenn. 37401 1/30/76 Enclosure "C"
i, I
- 18. Carl M. Modes, President, Universal Technical Testing Laboratories, Inc., Collingsdale, Pa. 19203 2/ 5/76 Norman W. Curtis, Vice President, Pennsylvania Power & Light.
19.. Allentown, Pa. 18101 2/ 5/76 20...Dr. Keith J. Schiager, Professor cr e ,lth Physics, Graduate
. School of Public. Health, University of Pittsburgh, Pittsburgh, Pa. 15261 2/ 5/76
- 21. Ken Nicolas, American College 'of Nuclear Physicians, 1730 Pennsylvania Ave., Washington, D.C. 20006 2/ 9/76
- 22. Fred W. Rohde Industrial Radiographic Service ' Association, Burbank, California 91507 2/10/76
- 23. John J. Munro, III, Tech / Ops, Burlington, Mass. 01803 2/10/76
- 24. Walter P. Peeples, Jr., President, Nuclear Environmental i Engineering, Inc., Houston, Texas 77058 2/10/76
- 25. W. J. Shelley, Kerr-McGee Nuclear Corporation, Oklahoma City,
.Okla. 73125 2/10/76 .
- 26. J. Lee 'Ballard, Sr. Vice President, Consolidated X-Ray Service Corporation, Woodbridge, New Jersey 07095 2/11/76
- 27. Roland A. Finston, Acting Director, Health Physics and Occupational Health, Stanford University, Stanford, California 94305 2/11/76
- 28. W. C. Plumstead, Vice President, United States Testing Company, Inc., Reading, Pa. 19601 2/11/76
- 29. Howard J. Larson, Atomic Industrial Forum, Inc. , Washington, D.C. 20014 2/12/76 C. Eiche1dinger, Manager, Muclear Safety, Westinghouse Electric 30.
Corporation, Pittsburgh, Pa.15230 2/12f76
- 31. Otha W. Linton, Director of Governmental Relations, American College of Radiology,' Chevy Chase, Maryland 20015 2/12/76
- 32. Paul L. Ziemar, President, Health Physics Society, Purdue University, West Lafayette, Indiana 47907 2/12/76
- . 33. Joan Kurjian, Abbott Laboratories, North Chicago, Illinois 60064 2/12/76 l
4 i
2 Enclosure "C" L
i
, - . - - - -_ . - -- .l
- i
- 34. Helmut Thielsch Vice President, ITT Grinnel Corporation, Providence, Rhode Island 02901 2/16/76
- 35. John B. McCormack, Assistant Radiation Protection Officer, Chicago Bridge & Iron Company, Houston, Texas 77040 2/19/76
- 36. John J. Munro, III, Health Physicist, Tech / Ops. , Burlington, Mass. 01803 2/27/76
- 37. M. S. Mullikin, Universal Testing, Inc., Salt Lake City, Utah 84115 3/22/76
- 38. M. E. Remley, Rockwell International, Atomic Interantional
- Division, Canoga Park, California 91304 3/29/76
- 39. Walter P. Peeples, Jr., President, Nuclear Engironmental Engineering, Inc., Houston, Texas 77058 4/ 1/76
- 40. Jerri L. Jeffers, Executive Vice President, Testmaster Inspection Company, Perrysburg, Ohio 43551 4/ 2/76
- 41. Frank A. Malek, Jr., Training Department, Nuclear Environmental Engineering, Inc., Houston, Texas 77058 4/ 2/76
- 42. W. A. Christnensen, President. X-Ray Products Corporation, Pico Rivera, California 90660 4/ 2/76
- 43. Arthur W. Irwin B & M Welding and Testing Co. , Inc.,
St. Louis, Missouri 63110 4/ 5/76
- 44. H. W. Rogers, President, H. R. Inspection Service, Shawnee Mission, Kansas 66203 4/ 5/76
- 45. Tom W. Cuthbertson, Radiation Safety Officer, Peabody Testing /
X-Ray Engineering Company, City, California 94404 4/ 7/76
- 46. George Pardee, President, Transpacific Laboratories, Honolulu, Hawaii 96819 4/ 7/76
- 47. Otis Gamble, Conam Inspection Division, Nuclear Energy Services, Inc., Houston, Texas 77036 4/13/76
- 48. R. F. Dicharry, President, Source Production & Equipment Company, Inc., Kenner, Louisiana 70062 4/13/76
- 49. Elizabeth Dowey & John Abbotts, Public Interest Research i Group, 2000 P Street, N.W., Washington, D.C. 20036 4/16/76 l
3 Enclosure "C"
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- 50. Walter W. Offner, President, X-Ray Engineering International, San Francisco, California 94104 4/20/76
- 51. Darrell W. James, President, Non-Destructive Testing Co. , -
Grand Prairie, Texas 75050 4/29/76 ;
- 52. W. Donham Ciawford, President, Edison Electric Institute, 90 Park Avenue, New York, New York 10016 5/18/76
- 54. Jack K. Goodrich, M.D., Eugene L. Saenger, M.D., American l College of Nuclear Physicians,1730 Pennsylvania Ave., N.W., l Washington, D.C. 20006 3/15/76 j
- 55. Walter W. Offner, P.E., San Francisco, California 94104 5/17/76
- 56. Sol Burstein, Executive Vice President Wisconsin Electric Power Company, Milwaukee, Wisconsin 53201 5/19/76 l
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4 Enclosure "C" I
STAFF EVALUATION OF PUBLIC C0lWENTS ON NRDC PETITION PRM-20-6 .
Supporting Comments Three letters supporting the NRDC petition were received.
The first letter generally expre: sed agreement with the NRDC position and emphasized the idea that the general reduction in limits proposed I
by the NRDC would satisfy the recommendations of the NCRP for lower
' limits for fertile women. However, the staff concludes that while a general reduction of the exposure limits might seem to fulfill the NCRP ,
.. recommendation without discriminating against women, in actuality, it would not do so. The NRDC recommendations are predicated on the con-i tention that the present limits are "too high" for adults. The NCRP
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recommendation was based on the. idea that the embryo and fetus are more ,
radiosensitive than adults and thus should have their exposare constrained ;
by lower limits. If follows that if the limits for adults should be reduced, the limits for unborn children (and thus for fertile women) should be lowered proportionately.
F The second supporting letter stated that the writer "...can find no flaw
.in their (NRDC),line of argument...." Also it is. reported that'at least i
one. major university is already operating within the NRDC proposed limits t
I National Council'on Radiation Protection and Measurement, " Basic f I Radiation Protection Criteria," NC.TP-39, 1971.
-1 Enclosure "D"
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with_certain exceptions. The exceptions are personnel in diagnostic radiology. These exceptions could be eliminated if the NRDC proposed limits were redefined to apply only to the whole body, trunk, and ,
gonadal doses; that is, if higher doses to the head and arms were per-mitted. The fact that this radiation protection professional agrees with ;
the-NRDC argument is duly noted. The bases for the staff's disagreement are explained elsewhere. The reported ability to meet the proposed limits (with exceptions), however, is less significant because experi-ence indicates that measured exposures generally are low at universities.
The third supporting letter expresses union support for the NRDC proposal.
It also contends that the data showing some 84% of occupational exposures ,
to be less than 0.5 rem annually shows that the 0.5 rem /yr limit is well within licensee capabilities. The staff questions this interpretation of i
the observation that most radiation workers receive less than 0.5 rem annually; this could be the result of measuring exposures of people who rarely work with radiation or it could indicate that some ALARA efforts
- are effective. In any event it does not counter the arguments of many i
organizations that the proposed limits would be a real hardship.
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Alternate Proposal This letter did not agree or disagree with the idea that the limits should
- be lowered. Rather, it suggests a different set of reduced limits that 2 Enclosure "D" i
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i seem to largely achieve the NRDC objectives with less impact. This )
suggestion would retain the present limit of 3 rems per quarter but would limit total dose to 1(N-18) rems, where N is age in years. Pro-visions would be made to avoid penalizing those occupationally exposed before the new limits became effective and a 0.25 rem quarterly limit would apply where the records were incomplete or where the total dose limit was exceeded. The staff believes that this proposal would have less impact than would the NRDC proposal while achieving much the same l results, viz. , placing special constraints on the exposure of individual younger workers and generally reducing exposure limits. Still, the impact of this proposed dose limit reduction would be severe and does not seem justified by substantive benefits. ,
COMMENTS OPPOSING THE NRDC PROPOSAL l
l Fifty-two of the 56 comments received opposed the NRDC-proposed limit l l
reduction. The comments range from a simple statement that the proposed I limits were " unrealistic," through detailed rebuttal of the NRDC arguments, j to vitrolic denunciation of the MRDC petition.
Comments opposing the NRDC petition were received from:
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- NCRP Professional Societies (4)
. Industrial Organizations (3) i i
3 Enclosure "D"
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- 'GovernmentAgencies(3)
- Major Co.porations (8)
. Utility Companies (5)- ;
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- Hospitals.(3) l
- 'Radiopharmaceutical Companies (2) l i
Individual Professionals (2)
Universities (2) ,
- Radiography, Testing and Source Fabrication Companies (19) ,
The principal bases for opposing the NRCC petition mentioned in the letters i are as follows:
l.- The proposed limit reduction, while possibly reducing individual' risks, would increase the radiation risk of the whole population; one analysis concludes that at their facility the limit reduction would increase the workers' cumulative dose risk by a factor of 4.5.
- 2. The NRDC arguments are not scientifically sound in that the NRDC has misused and misinterpreted statements of the NCRP and the BEIR Committee in developing the NRDC position; clearly the NRDC petition differs markedly from the recommendations of the NCRP and the BEIR Committee.
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l l-i 4 Enclosure "D"
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- 3. Excessive financial costs (both to particular industries such as l medicine and industrial radiography, and to society in general) l would result from the proposed limit. reduction.
- 4. The NRDC petition would constitute discrimination against younger workers; many found this feature particularly objectionable. j i
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.5. The proposed dose limit reduction could necessitate job rotation and the use of less skilled personnel in certain medical operations .
thereby seriously increasing the doses received by patients. This !
is important because almost all the exposure to man-made radiation is received in medical procedures. ,
- 6. The proposed dose limit reduction'could increase radiography costs to prohibitive levels and thereby reduce the overall quality of con- ]
1 structions. Reduced radiography would reduce the reliability and safety of a host of facilities including bridges, pipelines, ships I
and aircraft.
'7. The proposed low dose limits could create serious personnel problems
! in nuclear reactor maintenance, radiography, medicine, etc., neces-sitating the use of inexperienced people and affecting the job
( security of some workers.
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5 Enclosure "D" ;
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- 8. The NRDC arguments incorrectly compare maximum risks of radiation exposure with average risks of. industrial accidents; the use of average doses would dramatically reduce the calculated risks.
- 9. The proposed low dose limits would have a devastating impact on special maintenance operations in nuclear power plants. Jobs requiring 1500 skilled workers to meet present exposure limits have been experienced. Were the limits one tenth their present values, the number of workers needed ccild be expected to exceed the supply.
- 10. Far-reaching rule changes should not be based on a single, unrefereed paper; such chant:ss should be made only if found necessary as a ,
result of careful study by a broadly based group of recognized experts.
I Summary
.The public comments provided little support for the NRDC petition. Public comments opposing the petition were broadly based and, in many instances, detailed and convincing.
While many substantitive points were made in these comments, the most i i
! important'seem to be that the NRDC proposed limit reduction would: !
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i 6 Enclosure "D" ,
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- 1. increase the total radiation hazard,
- 2. increase other hazards through reduced use of radiography,
- 3. result.in an unjustified general financial burden, and
- 4. create very serious problems in many industries, from oil well loggicq ,
i to medicine.
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4-. .
ENCLOSURE E
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BEIRCAN, A Computer Program For
- Calculating the Effects ~of Exposure to Ionizing Radiation.
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l Charles A. Willis Occupational Health and Safety Branch Jivision of Siting,' Health and Safeguards Standards Office'of Standards Development i Enclosure "E"
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! CONTENTS l
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! 1. Introduction
- 2. Assumptions and Limitations
- 3. Method of Calculation l 4. Use of BEIRCAN
- 5. Example Results from BEIRCAN l
- 6. Implications for Occupational Radiation Exposure Limits l
l Appendix: BEIRCAN LISTING l
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Enclosure "E" L
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ABSTRACT- !
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l This report explains.and tells how to use the _BEIRCAN-(Biological Effects f i
of' Ionizing Radiation, Cancer) computer program. -The program uses the -
models from_ the BEIR Report. -The user may select (1) either the relative risk or the absolute risk'model, (2) either 30 years or " remainder of life" i for the plateau duration for cancer other than leukemia, (3) the exposure period and (4);the exposure rate. Output includes average life shortening (by radiation induced cancer), percent of deaths caused by radiation and j average life span ~ reduction per person-rem. '
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i l CONTENTS
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- 1. Introduction
- 2. Assumptions and Limitations
- 3. Method of Calculation
- 4. Use of BEIRCAN
- 5. Example Results from BEIRCAN Appendix: BEIRCAN LISTING t
Enclosure "E"
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- 1. Introduction The National Academy of Sciences' Advisory Committee on the Bio'.ogical Effects of Ionizing Radiation has developed models for calculating the probability that an " average" person will develop cancer as a consequence of exposure to ionizing radiation.U) In the BEIR Report the models were applied in a retrospective manner. That is, the analyses show what number of radiation deaths would be expected in a year if a specified popula- :
tion had already received a specified exposure. This approach simplified i
the calculations by avoiding the problem of competing risks.
i In many instances there is a need to know what the effects would be 1 if a specified group were exposed in the same manner for a period of years.
Also, it is interesting to compare the effectiveness of a particular popula-tion dose delivered at various rates and at various ages. The BEIRCAN j code was developed to perform these calculations.
- 2. Assumptions and Limitations _
The principal assumptions are those of the BEIR Report, including the BEIR Report data fcr the " natural" cancer rate for the relative risk model calculations.
The main assumption incorporated in the code itself is the " natural" risk values. These are taken directly from the 1967 mortality data for the entire U.S. These data are extrapolated exponentially to a maximum risk value of 0.5. There would be little change in the results if more recent data were used. However, significant changes would result if race IAdvisory Comittee on the Biological Effects of Ionizing Radiations, "The Effects on Populations of Exposure to Low Levels of Ionizing Radiation,"
National Academy of Sciences--National Research Council, Washington, D.C.,
November 1972.
l 1 Enclosure "E" l
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l l I and sex specific data were used. It would not be appropriate, however, to use race and sex specific mortality data for "naturald risks unlass l race and sex specific parameter values for cancer induction by radiation were used (these values are not in the BEIR Report).
! The smallest time interval considered is one year except for in utero exposure which is 0.75 yr. There.seems no justification for the considera-l tion of smaller time intervals. ,
i Calculations end at age 120. The number of people living longer is !
not significant for these calculations.
BEIRCAN does not account for radiation effects other than cancer.
I Acute effects of radiation, for example, are omitted along with nonspecific life shortening, etc. The crission should be recognized, especially in ,
use of the results for very large annual doses (100 rems /yr or more).
The risk values are handled as probabilities; the total risk is not .
J allowed to exceed 1 in any year. This handling of the risk parameters I
! is a factor only for the very old and where the doses are very large.
l Method of Calculation
- 3. 1 The calculational begins with 2 groups of people, an " exposed" group and a " control" group. Each group contains 1000 people at birth and each j is reduced in number, year-by-year, according to age-specific risk values.
For the control group, the age-specific risk values correspond to the 1967 mortality data for the U.S. population. The exposed group also experiences these " natural" risks to which the radiation risks are added. i For example, during the 10th year of life the risk (individual probability of death) from natural causes is taken as .00027 so the control group is 2 Enclosure "E"
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I Table 10 also shows the results for cases where exposure starts at various ages. Here, however, exposure continues for a fixed period (5 years in this example) so exposure stops at various ages. l Table '.1 is a special case where the individual annual doses are L These doses are displayed in the " input dat' I
specified by the user.
section of the table. Exposure starts as stated in the input but ( mosure ends when each of the supplied annual dose, has been used once. Any _ase j value can be used but a value must be given for each year, even if the l
value is zero. i
- 6. Implications for Occupational Exposure Limits The Natural Resources Defense Council, Inc. (NRDC) petitioned the NRC and the EPA to reduce the occupational radiatiori exposure limits because theoretical' risks from exposure at the present limits were (in NRDC's i judgement) too high. BEIRCAN results were used in evaluating the NRDC i petition. l The relative magnitudes of radiation risks and other occupational hazards determine the need for and the potential benefit from reducing the exposure limits. The NRDC postulated that the maximum radiation hazard ,
(from exposure at the limit) should not exceed the average risk of a fatal l l
work accident. The NRDC calculates the radiation hazard with the most pessimistic of the BEIR models and concludes that the dose limit should be l reduced by a factor of 6. The NRDC also recommended that the limits be lowered by a factor of 10 to reduce genetic risk; the staff and most ,
experts in this field feel that genetic risk is a function of the total dose to the population and does not constitute a valid basis for changing 17 Enclosure "E"
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' Comparison of radiation' risks to the risks from other toxic substances is virtually impossible. -A host of substances have been identified as t carcinogenic. These substances range from the commonplace, such as sun light and wood dust to exotic chemicals. ' Rate and risk data, however, are unavailable.
Epidemiological studies have not demonstrated any ill effect of occupational radiation exposure. This is not evidence that low levels of )
radiation are harmless but it does indicate that radiation protection
- practices over.the past 35 years have been reasonably successful and that there is ne urgent need for drastic change.
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21 Enclosure "E" l
4 ENCLOSURE F VALUE/ IMPACT ASSESSMENT OF DENIAL OF THE l.
NRDC PETITION (PRM'20-6) ON DOSE LIMIT REDUCTION 1 r
I. The Proposed Action A. Description :
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.The Natural Resources Defense Council, Inc. (NRDC) filed a petition on September 26,'1975 requesting that the Nuclear Regulatory. .
Commission (NRC) reduce the occupational radiation exposure limits so
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l the associated risks are lowered by a factor of 10 for genetic effects and a factor of 6 for somatic effects.
The NRC docketed the petition (PRM 20-6) and published it in [
the Federal-Register (Vol. 40, No. 209, October 29,1975). Comments ,
were requested and received. '
The Environmental Protection Agency (EPA) received a similar petition from the NRDC. On August 10, 1976 the EPA denied the petition.
The EPA denial was based largely on the following considerations:
- 1. ; Risk is (assumed) proportional to the actual dose ,
received. not the dose limit. $
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- 11. Average doses have beer far below the limit.
- Enclosure "F"
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iii. Efforts to keep exposures "as low as reasonably achievable"
< (ALARA) will keep doses well below the limit.
iv. Lowering the limits would likely increase the total (man-rem) dose to the population and thereby increase the risk.
The staff has evaluated the issue taking into account both the comments received and the EPA denial. The staff concludes the NRC should deny the petition because the proposed reduction of the limits would have ;
serious delaterious impact without commensurate benefits. j B. Need for the Proposed Action l
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The NRC must formally respond to the petition, documenting the i j
- decision and its bases, C. Value/ Impact of the Proposed Action
- 1. Nuclear Regulatory Comission (NRC)
A formal response to the petition is needed to satisfy the conditions of 10 CFR Part 2, Paragraph 2.803.
The principal advantage to the NRC of denying the petition is that such action would be consistent with the responsibility to act in 2
Enclosure "F"
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l the public interest based on the preponderance of the evidence. The
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principal disadvantage to the NRC is that 'a denial can be expected to l i
precipitate further criticism of the NRC by special interest groups. ;
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Secondary advantages of denying the petition are:
- a. A denial avoids disagreement with the Environmental Protection Agency (EPA).
- b. A denial obviates the need to reevaluate all approved designs,
- c. A denial avoids the need to revise many of the regu-lations and guides.
- 2. Other Government Agencies l
The proposed denial of the petition would have no impact on other agencies except through avoidance of the impact that would result from acting in accordance with the petition.
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l~ --lhe impact of reducing the occupational dose limits as proposed by the petition would be substantial on all agencies using or having contractors use radioactive material under NRC or agreement 3 Enclosure "F"
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state license. The proposed limit reduction would require reevaluation of many regulations and contracts. It would delay programs, increase costs and probably make some programs impracticable. The most severely l
impacted probably would be agencies involve'd in medical treatment or research (i.e., NIH, Social Security), energy production or research j l
(TVA, ERDA), sophisticated equipment development involving radiography (D00), or agricultural research (DOA).
- 3. Industry The proposed denial of the petition would have no impact on industry except through avoidance of the impact that would result l from acting in accordance with the petition.
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, The impact avoided by denying the petition is substantial.
Nearly all of the over 8600 NRC licensees and the over 10,800 Agreement State licensees would be affected directly. Indirectly, the effects would be felt by the many other industries to which the licensees provide l products and services such as radiation-based gauges and radiography. )
Impacts would include license revisions, reevaluation of designs, modi--
fication of facilities and increased manpower requirements.
l 4. Radiation Workers l
The proposed denial of the petition would not affect radia-tion workers except through avoidance of change.
4 Enclosure "F" l I i-l
Radiation workers are now permitted to receive an upper limit of 250 rems in a 50-year working lifetime. According to the staff calculations based on the BEIR Committee models, this exposure might result in an average life span reduction of between 0.45 and 0.75 years.
In practice, exposures are rarely at or near the limits; probably 85% of the annual occupational doses are less than 10% of the limit. Thus, the proposed limit change would result in little actual dose reduction and, therefore, little benefit.
The proposed limit reduction would have a discernible impact on radiation workers. The most serious of these would be a loss of job stability because of the need to rotate workers between jobs to control exposures.
- 5. Public A dental would affect the public only through avoidance of change.
The public would receive no benefit from the reduction of
. the-limits' but could experience significant impact. The most important l impacts probably would be the increased cost of medical care and certain products such as electricity. The public also could experience an increase i in safety hazards as a result of reduced use of radiography to ensure the 5 Enclosure "F"
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l safety of ships, planes, pipelines, etc. Clearly the reduced limits would increase radiography costs and would make some radiographic pro-cedures impracticable. l l
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D. Decision on the Proposed Action The petition should be denied because lowering the exposure limits as requested by the NRDC would have serious deleterious impact without comensurate benefits. -l II. Technical Approach
! l The issue raised by the NRDC has been evaluated by the staff, taking into account the actions of the EPA on a similar petition and the exten- ;
sive comments received from the public. The staff utilized an internally developed computer program based on the BEIR Committee models to evaluate radiation risks. Other related technical works which initially seemed l to support the NRDC position were evaluated with the support of con-sul tants. Alternative changes in the radiation exposure limits were considered. Finally, it was concluded that the best course of action is to deny the petition.
A. Technical Alternatives l
The alternatives in' handling this petition involve the depth of the evaluation. The choices were to:
6 Enclosure "F" 1
- i. Accept or deny the petition without careful evaluation.
ii. Base a decision on careful evaluation by the staff, 1
utilizing consultant support as needed and taking account of public comments and the actions of the EPA.
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l iii. Evaluate the issue through a major study as might be done by contract personnel and a committee of the National Academy of Sciences.
B. Discussion of the Technical Alternatives The proposed dose limit reduction obviously would have a very serious impact. Consequently, it could not be adopted cavalierly. The i question of the adequacy of the limits for the protection of individual workers is of such importance that the petition could not be casually dismissed. Thus, the possible alternative of handling the petition without careful evaluation was rejceted.
A major study of the bases for the occupational dose lim'i<
was considered. This would have involved the use of contractors and I could have involved a special connittee of the National Academy of Sciences. Several considerations led the staff to conclude that such an effort is not warranted at this time. These considerations include 7 Enclosure "F"
the fact that the NRDC petition-is_ not based on any new theory or data.
l Also the dose'1imit issue is under continuing scrutiny by the staffs of the EPA and of the NRC. The International Commission of Radiological Protection (ICRP) and the NCRP continue to be active and have considered ,
l all the information presented by the- NRDC in support of its petition. l l
Thus, a major study did not appear justified at this time. i i
The approach chosen was a careful. evaluation of the occupa-tional exposure limit is' sue by the NRC staff.
III. Procedural Approach A. Procedural Alternatives Three ways of handling the NRDC petition were considered:
- i. Change the limits in accordance with the petition.
ii. Change the limits some other way to meet the petition's f I
objectives.
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- f. 8 Enclosure "F" 1-
B. Value/ Impact of Alternatives Changing the limits in accordance with the petition would have severe impacts without commensurate benefits, as discussed in I.C.
Changing the limits to meet the general objectives of the petition, but using new limits different from those proposed by the NRDC ;
was carefully considered. Technically, risks from occupational radiation :
exposure could be reduced by using older people for radiation work. Post-poning radiation exposure until after age 45 would largely aliminate the genetic risk and reduce cancer risks. See Tables'1 and 2. A person-rem of radiation received between the ages of 20 and 25 may reduce life i expectancy 13 times as much as the same dose received between the ages of 60 and 65. Thus, various schemes to reduce radiation risks are possible.
However, all these approaches have very serious drawbacks including' age discrimination. Excluding young people from radiation work would have a ,
major impact on research, teaching and industry as well as limiting the !
job opportunities of those being " protected." Furth'er, the protection i provided might not be real; those excluded from radiation work would then be involved in other work which well might be even more hazardous. No ;
acceptable alternate lower limits were found.
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! C. Decision on procedural Approach (
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9 Enclosure "F" ;
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Ind'& l l CuMS3C0"NCES OF uhDIAT10N 3XPOSDRE !
lEtCM VA31G3S AJ13 F02 5. Yn Pfh10DS AT 5.000 LZMS/YR ]
J STM4r /eecn,/ Y25 LOST LEATHS Pha DAYS LOST YR3 LOST I Ase _
Oc4645 M3GA-M A:1-Rd5 ?3R M AN-233 PE3 DEATH ]
- 0. G.33? 0.20 15 143.3 3.1429 59.86
- 5. 0.191 0.0896 78.2 1.3452 47.10
- 10. 0.351 0.1312 148.3 1.9697 36.37
- 15. 0.335 0.1251 162.6 1.So40 31.67
'20. 0.392 0.1u 59 156.5 1.6039 27.71
- 25. 0.3o4 0.0374 151.9 1.3341 24.04
- 30. 0.339 0.0701 142.5 1.0773 20.70
- 33. 0.305 0.0542 129.o 0.6408 17.74
- 40. 0.264 0.0401 114.0 0.6311 15.16
- 45. 0.215 0.0232 95.9 0.4532 12.96
- 50. 0.109 0.0167 76.6 0.3097 11.07
- 55. C.122 0.0115 53.1 0.2002 9.43 i
- 30. 0.061 0.0065 41.5 0.1215 8.01 c a. 0.048 0.0033 27.S 0.0688 o.82
- 79. 0.025 0.0015 17.0 0.0366 5.37
- 73. 0.C11 0.0006 9.9 0.018b 5.12
- 50. G.002 0.0002 5.7 0.0092 4.41
- 35. 0.001 0.0001 3.4 0.0046 3.62
- 30. 0.000 0.0000 2.1 0.0021 2.82 9 f. . 0.000 0.0000 1.1 0.0009 2.20 10 3. 0.000 0.0000 0.6 0.0000 2.00 A3eOLUTE RIs1 30 DEL 30.9 YEAR ?LAT3AD, Cc:iC2R 0:3 21: IHAN LdUKEMIA 1
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I 10 Enclosure "F" :
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CONSEQUENCES OF RADIATION EXPO'EURE l FROM VARIOUS AGES FOR 5. YR PEh!ODS AT 5.000 REMS /YR Srnn T PEnceu r YRS LOST DEATHS PER DAYS LOST YRS LOST l A4s 0640f t - 5EGA-MAN-EEM PER MAN-REM PER DEATH
- 0. 5.885 0.9261 2513.5 14.4470 15.74 i
~5. 7.082 1.0137 2905.3 15.189u 14.31 !
10, 2.076- 0.2951 853.4 4.4301 14.21 j 15.- 0.761 0.1102 313.7 1.6592 14.48
- 20. 0.760 0.1081 315.3 1.6377 14.22
- 25. 0.756 0.1047 315.7 1.5970 13.85 ;
- 30. 0.754 0.1016 317.5 1.5626 13.48 <
1.488u 12.89 )
- 35. 0.744 0.0959 316.0
- 40. 0.734 0.0897 316.0 1.4109 12.22 i
- 45. 0.687 0.076u 302.4 1.2284 11.12 i 50 . 0.633 0.0637 287.7 1.0563 10.05 l
- 55. 0.536 0.0472 255.7 0.8231 8.81 '
1 60 . 0.433 0.0337 222.2 0.6313 7.78
- 65. 0.306- 0.0208 175.7 0.4363 6.80
- 70. 0.198 0.0119 134.0 0.2928 5.98 3
- 75. 0.107 0.0057 94.0 0.1810 5.27
- 80. 0.051 0.0023 66.2 0.1076 4.uS i
- 85. 0.020 0.0007 45.1 0.0615 3.65 :
- 90. 0.005 0.0001 28.0 0.0289 2.82
- 95. 0.001 0.0000 15.3 0.0123 2.20 100. 0.000 0.0000 7.7 0.0056 2.00 l BELATIVE RISK MODEL LIFETIME PLATEAU, C ANCER OTHER TH AN LE3KEMIA l
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11 Enclosure "F" I
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SA IV. NRC Authority A. .The Commission's Authority for the proposed action is pursuant to the-Atomic Energy Act of 1954, as amended, and the Energy Reorganiza-tion Act of 1974, as amended. In particular, 5 2.803 of 10 CFR Part 2 calls for formal responses to petitions.
- 8. Need for NEPA Assessment No NEPA assessment is needed for this action as there will be no environmental impact.
V. Relationship to Other Existing or Proposed Regulations or Policies The proposed action will not be in conflict with any existing or proposed regulation or policy.
VI. Summary and Conclusions The NRDC_ has petitioned to have the occupational radiation exposure limits reduced so the individual worker receiving maximum permissible l
- doses would experience lower risks; genetic risks were to be lowered by a factor of 10 and somatic risks were to be lowered by a factor of 6.
The staff reviewed the issue and concluded that the proposed limit
!~
i-12 Enclosure "F" L
reduction would have severe deleterious impacts without compensating benefits. The impacts would include increasing total risks from occupa-tional exposure to radiation. It is concluded that the petition should be denied.
References None.
1 l
1 1
I l
l l
13 Enclosure "F"
(
[:. .
l is ;
(Docket No. PRM-20-6)
NATURAL RESOURCES DEFENSE COUNCIL, INC. l l
Denial of Petition for Rule Making i
Notice is hereby given that the Nuclear Regulatory Commission has denied a petition for rule making submitted by letter dated September 26, )
\
1975, by the Natural Resources Defen;a Council, Inc., 917 15th Street, 1 l
N.W.,. Washington, D.C. A notice of filing of petition, Docket No. PRM-20-6, i was puolished in the Federal Register on October 29, 1975 (40 FR 50327).
Interested persons were invited to comment on the petition. The response 1
consisted of 3 letters supporting the petition, 1 letter suggesting a less severe change in the regulations, and 52 letters opposing the petition.
The Natural Resources Defense Council, Inc. (NRDC) petitioned the Nuclear Regulatory Commission (NRC), requesting that the whole body occupa-tional exposure' limits be lowered so that (1) the associated somatic risk is reduced by a factor of 6 and (2) the genetic risk is lowered by a ]
factor of.10. Specifically, the NRDC requested that the regulations (10 CFR Part 20 Paragraph 20.101) be amended as follows:
- 1. For individuals under the age of M, where M is not less than 45, the whole body radiation exposure limit shall not exceed 0.5 rem in any calendar year and 0.3 rem in any calendar quarter.
4
'2. For individuals equal to or greater than M years of age, a licensee may permit an individual to receive up to 3 rem / quarter whole bod., dose as long as the dose to the whole body shall not exceed (0.5) l 1 Enclosure "G"
a 9=
(M-18) + X(N-M) rems, where N equals the individual's age in years, and X is calculated to reduce the cumulative somatic risks by a factor of 6 below the cumulative risks associated with, exposure at 5 rems / year from age 18.
i The NRDC also proposed that the value of "x" (above) be calculated l using the relative risk model with a lifetime plateau as described in the l
BEIR Report.I The NRDC further requested that the NRC institute hearings to determine the "as low as practicable" extent to which the exposures can be maintained below the proposed new regulations. This request is denied because the limits are not being changed. However, a public meeting has been held, and others are planned, on specific aspects of the NRC program for keeping radiation exposures "as low as reasonably achievable" (ALARA). Broad scope hearings on occupational ALARA are not likely to be productive because an ALARA program should be specific to the operation; for example, good practice in oil well logging might be quite different from good i
l practice in nuclear medicine.
A. Supporting Document The basis for the NRDC petition was provided by a technical report entitled, " Radiation Standards for Occupational Whole Body Exposure," by T. B. Cochran and A. R. Tamplin.
National Academy of Sciences, National Research Council, "The Effects on Populations of Exposure to Low Levels of Ionizing Radiation," Report of the Advisory Committee on the Biological Effects of Ionizing Radiations, November, 1972, p. 171.
. 2 Enclosure "G" i
l i
.\
~
- . . l s
i The somatic risk from occupational exposure is assessed by Cochran I and Tamplin by noting that the BEIR Report (Page 170) gives the theoretical number of radiation induced cancer deaths annually from 5 rems per year 1
from age 18 to age 65 as 381, 417, 782 or 917 per million people. The I values are different for the different models and assumptions used. These !
estimated cancer risk values are compared to the actual fatal occupational accident rate in the USA. In 1973, work accidents took the lives of 170 out of each million workers; in minir.g and quarrying, there were 1170 ;
fatal accidents per million workers.2 The NRDC contends that the cancer death risk from occupational exposure to radiation at the limit, calculated with the most pessimistic BEIR model, should not exceed the average risk of a fatal work accident. On this basis, the NRDC concludes that the limit should be reduced by a factor of 6.
The genetic risk is estimated by noting that the BEIR Report (page 57) estimates that an average population dose of 5 rems per generation might produce 300 to 7500 genetic effects per million live births at equilibrium (a 0.5 to 5 percent increase). The NRDC then estimates that the 60 rems permitted radiation workers by age 30 might produce 3,600 to 90,000 effects in the progeny of a million radiation workers; this includes the effects in all future generations. The NRDC argues that the upper bound estimates should be used and states that the resulting risk is too high.
They recommend that the risk be reduced by a factor of 10.
In justifying its recommendations the NRDC first refers to the Inter-national Commission on Radiological Protection's (ICRP) Publication 14 2
National Safety Council, Accident Facts, 1974 Edition, 1974.
3 Enclosure "G"
(*
l (1969) to conclude that the whole body occupational exposure limit should be lowered by a ' actor of 10. The NRDC then refers to the National Council on Radiation Protection and Measurements' (NCRP) recommendation that the dose to the fetus not exceed 0.5 res,3 . noting that the NRDC-i proposed limits would meet the NCRP recommendation without sex discrimina-tion or violation of privacy. Next, the NRDC contends that its proposed reduction of the Ifnits would not place a large economic burden on industry L because older workers (for whom the limits would not be so drastically 4
lowered) could be used. Finally, the NRDC cites the BEAR report recom-mendation that "every effort be made to assign tasks involving higher l
l radiation exposures to individuals who, for age or other reasons, are unlikely to have additional offspring."
- 8. Related Report: The Mancuso-Stewart-Kneale Study Another report issued recently alleged that low levels of radiation might be much more carcinogenic than the BEIR Committee reported. While l
this report was not submitted by the NRDC in support of its petition, the 1
report was deemed relevant and was reviewed by the staff in this context.
I All other information available to the NRC was in agreement with the BEIR Report.
This report is generally referred to as the Mancuso Report.5 g,,cy,,, l L
Stewart and Kneale studied the death and exposure records of deceased 1
I 3 National Council on Radiation Protection and Measurements, " Basic Radiation Protection Criteria," NCRP-39, 1971.
" Committee on Genetic Effects of Atomic Radiation, "The Biological Effects of
( Atos.ic Radiation, Summary Reports," National Academy of Sciences,1956.
S l T. F. Mancuso, A. Stewart & G. Knea'e, " Radiation Exposures of Hanford l
Workers Dying From Cancer and Othe- Causes," to be published in the Trans-I actions of-the Tenth Midyear Symposium of the Health Physics Society.
4 Enclosure "G"
- i. '
. e: .
- . i
- s. j
[
former workers at the Hanford Atomic Project. Some of these people had died of cancer and some had been exposed to measurable amounts of radiation l l
at work. The question considered was whether the occupational exposure !
l l l had caused some of the cancer. The cancer incidence was slightly higher ;
1 in the occupationally exposed group but the difference was not statistically i L
significant at the 90% confidence level. !
When data for males are separated from data for females, again the ,
differences in the cancer incidence in the occupationally exposed (OE) groups are not significantly different from incidence in the not-occupationally-L <
exposed (N0E) groups. Further, among males the OE group had the higher
- cancer incidence while among females the NOE group had the higher incidence.
The mean lifetime occupational dose of the exposed workers was only
- 1.72 rads. This is less than the variation in exposures between individuals '
L l that_is expected from non-occupational exposure and the non-occupational l t l exposure was not measured. The average non occupational exposure of US citizens is about 7.5 rems by age fifty. This exposure is from natural l and medical sources. The range is from about 4 rems to hundreds of rems.
l l- For the deceased former Hanford employees, the occupational exposure wes
-less than 20% of the probable total exposure.
,, comparing the average doses of those who died of cancer with the average doses of those who died of other causes, Mancuso et al., estimated that 5.8% of the cancers were caused by occupational radiation exposure and'that doses as low as 0.8 rad might double the likelihood of certain
! kinds of cancers.
5 Enclosure "G" l-I l~
i l-
.s , . . , - . . . - - . , -
7 .._ . . , , . . , .
'. i 4
If valid, the findings of Mancuso et al., would have significant implications for public health and safety, not only in NRC-licensed activities but also in activities involving exposure from other sources, particularly medical radiation and natural background radiation.
Drs. Marks and Gilbert, Battelle-Pacific Northwest Laboratories, analyzed the Mancuso Report data and arrived at entirely different conclu-sions;6 this analysis was reported at the same meeting in the fall of 1976 as the Mancuso Report. Dr. Bair, in his analysis for the Atomic Industrial Forum, was generally in agreement with Marks and Gilbert.7 More recently an analysis of the Mancuso Report data was conducted at the request of the Energy Research and Development Agency by Ors. Land of the National Cancer Institute, Hutchinson and MacMahen of the Harvard School of Epidemiology, and Jablon of the National Academy of Sciences.
I This study also disagreed with the Mancuso Report; it did seem to indicate an increased incidence of cancer of the pancreas and multiple myeloma, but emphasizes that these indications may be statistical flukes. The differences between the Mancuso Report and the other analyses are reported to be
" attributable to the improper use of statistical methodologies."O The NRC solicited an Environmental Protection Agency (EPA) evaluation 9
of the Mancuso Report and was advised that the EPA policy is to rely on 6
- 5. Marks & E. Gilbert, " Comments on the Paper by Mancuso, tewart and Kneale," to be published in the Proceedings of the Tenth Midyear Symposium
! of the Health Physics Society.
W. J. Bair " Press Response to the New York Times Article by David Burnham, i October 25, 1976." Battelle, Pacific Northwest Laboratories, Richland, Washington, October '4976.
8 W. H. Weyzen, ERDA, Letter 1.o Michael Parsont, NRC, April 5, 1977.
9W. A. Mills (EPA), t.etter to R. B. Minogue (NRC), May 10, 1977.
6 Enclosure "G" i
v., , ,
l .
L i l 1 i the considered judgment of experts oa biological effects of radiation and, in practice, the EPA has relied heavily on the National Academy of Sciences l BEIR Committee. In some cases, where the results have been submitted for peer review and are unequivocal, the EPA'may directly utilize the results of new studies. More often, and in the case of the Mancuso Report, the
- EPA finds that the results of radiation health studies require extensive scientific evaluation. In such cases the EPA will forego the use of recent studies until they have had a thorough review by scientific experts, usually the NAS-BEIR Committee. At EPA's request the BEIR Committee is now reviewing various new studies, including the Mancuso Report.
10 The NRC staff independently analyzed the Mancuso Report and also retained a consultant to evaluate the statistical methods of the report.II Both of.these analyses concluded that the Mancuso Report conclusions could not be supported by.the information presented in the report a.nd that no' .
immediate NRC action need be taken.
The NRC has concluded that the Mancuso Report does not support the NRDC position.
C. Environmental Protection Agency Denial _
By letter dated October 7, 1975, the Natural Resources Defense Council, I
l Inc., also petitioned the EPA to reduce current occupational Radiation Protection Guides for whole body exposure (25 FR 4402).
10 Report of the Staff Committee to Study the Pap'er, " Radiation Exposures i of Hanford Workers Dying From Various Causes, USNRC, November 16, 1976.
11 j 0. L'. Kleitman, " Critique of Mancuso, Stewart and Kneale Paper," February 3, 2 1977.
7 Enclosure "G"
This was virtually the same petition, with the same supporting document, that was submitted to the NRC. The EPA denied the petition on August 10, 1976.12 The bases for the EPA denial were (1) risk. is proportional to the actual dose, not the dose limit; (2) average doses have been kept far below the limit; (3) efforts to keep exposures "as low as reasonably achievable" (ALARA) will keep doses far below the limit; and (4) lowering the individual dose limits would be likely to increase the cumulative (man-rem) dose and thereby increase the overall risk.
The EPA disagreed with the NRDC argument that the maximum radiation risk should be comparable to the average risk of fatal accidents. The EPA concluded that one average value should be compared to another average value. The average occupational exposure was estimated to be about 0.2 rem annually, which corresponds to from 3 to 37 lethal cancers annually per million radiation workers. This is well below the 170 fatal accidents 4
per million workers experienced in 1973.
The EPA also cited a major difference between fatal accidents and radiogenic car >cer. Because radiation dose builds up slowly over the years and because there is a significant latent period between dose and effect, a radiation fatality shortens life much less than a fatal accident. The EPA concluded that the best basis for comparing radiation risks with accident risks'was years of life lost. On this basis, the EPA concluded that the risk from 5 rems / year is just below the accidental risk of death experienced by agricultural workers in recent years.
N.D.Rowe(EPA),LettertoJ.G.Speth(NRDC),Augus 10, 76.
i.
8 Enclosure "G"
u .
~
)
The EPA noted that combining the risk from S rems per year with the accident risks for their profession brought the risks of the group of radiation workers at highest risk (industrial radiographers) to near the accident risk of construction workers.
Workers are exposed to carcinogens other than radiation. These i
include sun-light, wood-dust, heavy metals, etc. Data are not available to permit quantification of the risk, but the EPA noted that consideration j of other carcinogens would tend to reduce the comparative significance of risk due radiation exposure.
The EPA also disagreed with the NRDC's basis for assessing the signif-icance of genetic risk. Specifically, the EPA contended that (1) attention should be limited to effects in the first, or first few, generations; (2) risk is determined by the actual doses, rather than by the limit; (3) only one of the parents can realistically be expected to be a radiation worker; and (di in assessing genetic risk, the occupationally exposed group should be treated as a population. The EPA concluded that the estimated risk of genetic effect from 5 rems per year to age 30 is very low compared to the normal incidence and that the estimates are most likely overestimates.
The EPA questioned whether reducing the dose limits (radiation protec- ,
tion guides) as proposed by the NRDC would necessarily result in lowering potential genetic effects because there could be an increase in the population dose.
The EPA called attention to the admonition that radiation exposure be kept as low as reasonably achievable and expressed belief that exposures will continue to be kept well below the limits.
i i
9 Enclosure "G"
US The EPA now has the responsibilities that since 1959 (Public Law 86-373) were borne by the Federal Radiation Council. These include the responsibility to "... advise the President with respect to radiation matters, directly or indirectly affecting health, including guidance for all Federal agencies in the formulation of radiation standards...." Thus, the position of the EPA is a major factor in NRC considerations.
D. Public Responses to the Petition _ _ _ _
There was some support for the petition. One respondent supported the NRDC contention that the NRDC amendment, would resolve the fertile woman issue in a non-discriminatory way. Another stated that, with certain exceptions, his university is now operating within the NRDC proposed limits. A thirci offered an alternative formula which he felt could meet the objectives with lesser impact.
The bulk of the public comment on the NRDC petition was strongly opposed. Opposition was expressed by scientific and medical societies as well as individuals and companies. These respondents expressed, in various ways, the arguments used by the EPA in its denial. They also made clear their belief that the proposed changes in the limits would be very costly.
These cost increases cannot be taken lightly since they are real costs to society.
The radiographic industry constitutes a particularly important case; many companies contended they could not continue under the NRDC proposed j
! l l limits. In December 1976, 297 industrial radiography companies were <
~
! licensed by the NRC and 562 others were licensed by agreement states. Each i
l l 1
10 Enclosure "G"
i o
l a .
i o
I year the'NRC-licensed radiographers report measurable doses to about 5000 workers; the average annual dose is 0.6 rem. It is estimated that the proposed dose limit reduction would about double the cost of typical 1
radiography operations. Much of the cost increase would result from the increase in the number of workers needed. Other cost increases would result from the need to (1) increase the size of controlled areas, (2) !
I replace some cameras with new models that would be heavier and less !
{
convenient, (3) use less experienced workers, etc. In situations where i access is difficult or where the increased size of the controlled area interferes with other work, the cost increase could be large. Thus, a strong motivation would be produced to forego radiography. If the amount of radiography were reduced, an increased failure rate in many machines, pipelines, tanks, etc., could be expected and this could increase the i i
total of society's risks. I I
Severai commenters warned that the proposed dose limit reduction '
would create or aggravate serious shortages of skilled workers in certain areas, such as in nuclear power plant maintenance.and in radiography. For example, Westinghouse's analyses indicate that the limit reduction would increase the numbers of workers typically needed (1) 800% for refueling (from 19.to 168), (2) 750% for steam generator inspection (from 6 to 51), 1 (3) 800% for reactor coolant pump repair (from 102 to 917), etc. Similar impacts are predicted by Commonwealth Edison Company and by the Tennessee
- Valley Authority. Impacts predicted in other activities, such as medical I care, generally are less severe; increases on the order of 200% are i
! predicted.
11 . Enclosure "G"
. I 6 ,
There is considerable question regarding the impact of the change requested by NRDC. While it may be expected that a lower dose limit will resultiin lower individual doses, the staf.f is convinced, and several of the comments received in response to the notice have stated, that a lower dose limit will be counterproductive in terms of total man-rems. Exposure is received by a worker during entrance to the work area, during orienta- !
tion to the work to be performed, and while' exiting the restricted area, i
as well as during actual performance of the work. If a lower dose limit is imposed, many more workers would have to be used to achieve necessary j work in existing facilities, and the total dose could be significantly increased. Commonwealth Edison evaluated the impact of the NRDC petition on the Dresden power reactor station. Their study indicates that a ten-L fold reduction in dose limits would result in only a three-fold reduction l
.in dose.per individual (0.3 res/ year vs. 0.9 res/ year), but would result ,
1
! in an increase in the number of workers (including contractor personnel) exposed to radiation from the present 3,200 to 55,400, with an associated l
450%' increase in total dose from 2,760 to 15,100 man-ress per year. Thus, 1 ~
l the proposed reduction in the dose limit for individuals may increase the dose to the worker population. Since the risk is (theoretically) propor-l tional to the total dose, the proposed limit reduction could increase the 1
total risk.
l
)
E. NRC Evaluation of the NRDC Petition The NRC has evaluated the petition and has decided that the petition l l
should be denied.
i 12 Enclosure "G" i I
l .
i* , l l
The NRC is particularly concerned that the NRDC proposed reduction in the limits for individuals might result in an overall increase in exposure.
l If it is necessary to use a number of wor.kers on a single job to meet exposure limits, the cumulative exposure can become large. This results from the use of less efficient workers and from exposures incurred while ]
entering and exiting the restricted area and while orienting to the work to be done.
The NRC believes that workers are better protected by a safe work-place owing to an effective program for keeping exposures low than by a radical reduction of the individual dose limits with attendant increases in population exposure, costs and other impact. The overall NRC program for eliminating unnecessary radiation exposure in the work place is.
summarized in the next section.
c l
F. NRC Programs to Keep Occupational Exposures "As Low As Reasonably ._ _ .
]
Achievable" _
The NROC request for public hearings on occupational ALARA under the new limits is being denied primarily because (1) the limits are not being changed, and (2) hearings on the general subject of ALARA are not likely to be productive because an ALARA program should be specific to each individual operation.
This denial notwithstanding, the NRC continues to be acutely aware of occupational radir. tion exposure conditions and has taken aggressive action
, 1
! to achieve an a ;eptable degree of control. The goal of the NRC with regard to occupational health is to provide safety in the work place from 13 Enclosure "G"
l' ionizing radiation. This goal is accomplished through a system of l-regulation which controls the radiological protection that is provided by NRC licensees for their workers. Two approaches to the achievement of this goal have been implemented. Prior to January 1, 1971, radiation protection limits were published in NRC regulations, and licensees were required to conduct their operations in a manner to assure that these l
limits were not exceeded. After several years of experience with this approach it became evident that workers were receiving radiation exposures which were within the limits, but which could be further reduced with relative ease. These exposure reductions appeared to be reasonably achievable through better facility and equipment designs, better worker training, and better operating procedures. Additional exposure reduction was considered desirable because of the widely accepted scientific and NRC policy view 1
that some degree of risk is associated with any radiation exposure, however f
small. Therefore, in January,1971, Title 10, Code of Federal Regulations, Part 20, was amended to state that licensees should maintain exposure levels as far below the limits as practicable, thus initiating a new era in assuring worker protection. This approach is now well along in the l implementation phase.
The first major step in this program occurred with the issuance of Regulatory Guide 8.8, "Information Relevant to Maintaining Occupational Radiation Exposures As Low As Practicable (Nuclear Reactors)." Reactors were chosen for this first effort because of the large number of workers
- and their record of relatively high occupational exposures, especially
?
l during maintenance operations. After the is:;uance of this guide there -
I 14 Enclosure "G" i
m .
i were marked improvements in both the design and operation of nuclear power reactors with respect to occupational radiation protection. The guide has been expanded to better chronicle the favorable results and design approaches accomplished by industry design experts.13 This will in turn lead to l
further exposure reductions across the full spectrum of industry design i l
practice. ]
1 Operators of nuclear power plants have found that there is often an I l
economic advantage (p.saintaining occupational exposures ALARA, particularly throughimproveddeffgns. Operations must be conducted within NRC dose limits; and if it is necessary to bring in extra workers to complete a (In fact the total dose may be increased.)
task, the costs are very high.
l I
It has been reported that the cost is about $7,000 per man rem. These costs may be saved if the design provided radiation protection suf ficient l
l to make the use of extra workers unnecessary, and plant operators are s .
! becoming aware of this fact.
l NRC is now placing additional emphasis on the concept of maintaining
( occupational radiation exposures as low as is reasonably achievable (ALARA).
l A plan of action was adopted in February, 1977, which will strengthen the regulatory program in this important area. The major elements of this plan are:
"Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations Will Be As Low As Is Reasonably Achievable,"
! Nuclear Regulatory Commission Regulatory Guide 8.8, Issued July 1973, Revision 2, Issued for comment, March, 1977.
15 Enclosure "G"
l r :
l
- l. l
- 1. To require NRC licensees to develop individual, written occupa-tional ALARA program which can be incorporated into their licenses, thus making each program inspectable and enforceable;
- 2. To develop a series of regulatory guides on training of workers in radiation protection techniques at various types of licensed facilities; l
l
- 3. To develop a series of regulatory guides on maintaining occupa-i l
tional exposures ALARA in facilities other than nuclear power plants (which are covered by Regulatory Guide 8.8).
l
- 4. To develop a series of regulatory guides which offers guidance ,
i on the content of license application, including radiation protection;.
- 5. To continue to investigate new methods for reducing radiation levels due to activation products at nuclear power plants; l
l
- 6. To continue to investigate new methods for reducing the amount of maintenance required on radioactively contaminated components i at nuclear power plants; 1
l
- 7. To assure participation in and review of nuclear facility designs i by personnel competent in radiation prote~ction; 16 Enclosure "G" l ._.
i l
t
- 8. To assure that the occupational ALARA exposure concept is included l in regulatory guides and national standards;
- 9. To assure that the Office of Inspection and Enforcement notifies I the other NRC Offices regarding major problem areas in occupa-tional exposures discovered during inspection.
I
- 10. To develop a new regulation providing additional protection for temporary workers at nuclear facilities; I
It is believed that implementation of this action plan will ensure continued refinement and implementation of methods for reducing radiation exposure l at NRC-licensed facilites.
Copies of the petition for rulemaking and of the Commission's letter of denial are available for public inspection at the Commission's Public Document Room at 1717 H Street, NW, Washington, D.C.
__- Dated at Washington, D.C. this day of , 1977.
i l
Samuel J. Chilk Secretary of the Commission l
l 17 Enclosure "G"
^ . . .
/ o g UNITED STATES 3 g NUCLEAR REGULATORY COMMISslON 3 j W ASHINGTON, D. C. 20555
% /
Naturcl Resources Defense Council, Inc. _
917 Fifteenth Street, N. W.
Washi.ngton, D. C. 20005 ,
Gentlemen:. =e n + ' ;
l
- By letter dated Septanber 26,1975, the Natural Resources. Defense Council,c .
Inc., petitioned the Nuclear Regulatory Connission to reduce current. -
limits for whole body occupational exposure to radiation and to hold hearings to deterwine the extent to which it is practicable to keep exposures below these new limits.
The Connission has reviewed the petition and the supporting document as well as the relevant connents from members of the public. The Commission also reviewed, and generally agreed with, the response of the Environmental Protection Agency to a similar petition. Our general conclusion is that the' proposed reduction in exposure limits is not justified at this time-becacse (1) practical considerations and deliberate efforts to keep doses "as low- as reasonably achievable" will keep doses well below the limits and (2) lowering the limits might increase the cumulative dose and the resulting overall risk. The issues are addressed in more detail in the enclosure.
- The Connission has concluded that the limits should. not be lowered at this time. Therefore, we are denying the petition. The Connission, in conjunction with the Environmental Protection Agency and others, maintains a continui_ng review of the exposure limits and related matters.' Your concerns will be taken into account in our continuing review process.
Your continuing interest in-these matters is welcome.
Sincerely, Joseph M. Hendrie Chainnan
Enclosure:
Federal Register Notice Enclosure "H" j
i
t ENCLOSURE I I
~~
DRAFT LETTER TO CONGRESSIONAL COMMITTEES i
l
Dear Mr. __ :
- Enclosed for the inforination of the Committee are copies of- a Denial- -~
- of Petition for Rule Making to be published in the Federal Register.
The denial leaves unchanged i 20.101 of 10 CFR Part 20 which establishes the limits for occupational exposure to ionizing radiation.
i l
The Natural Resources Defense Council, Inc. (NRDC) petitioned the NRC to reduce the occupational radiation exposure limits. The petition would have lowered the limits by a factor of 10 for workers under 45 l years of age. The petition also would have the limits for older workers lowered by some unspecified amount.
~
A similar petition was filed by the NRDC with the Enyironmental Protec-tion Agency. The EPA denied the petition on August 10, 1976.
4 The NRC has evaluated the issue and concluded that the petition should.
be denied because the changes requested by the petition would have severe deleterious impact without commensurate benefita. While further reduction i of the limits would reduce the radiation doses of some individual workers, it would tend to increase the overall occupational exposure to radiation.
~
Enclosure "I" 1
l
i gg ~ .
i 2
This increase would result from the need to rotate workers into and out
~
of jobs involving radiation exposure. The impacts of the NRDC-proposed limit reduction would' include increasing many costs, including the costs of energy and of medical care. The limit reduction would have a serious
- -impact on industrial radiography, making some important procedures imprac !
ticable; this in turn would increase the public hazards from pipelines, bridges, ships, etc., which rely heavily on radiography to ensure safety.
I Thus, the NRDC petition is being denied. j Sincerely, l
Robert B. Minogue, Director .
Office of Standards Development l I
Enclosure:
Denial of Petition For Rule Making j i
l l
l N
1
' Enclosure "I" l
-