ML20206E185
| ML20206E185 | |
| Person / Time | |
|---|---|
| Issue date: | 11/10/1988 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| FRN-56FR23360, REF-10CFR9.7 AA38-2, AA38-2-0145, AA38-2-145, NUDOCS 8811180005 | |
| Download: ML20206E185 (182) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
Title:
Briefing on Final Rule on Standards for Protection Against Radiation - Part 20 (Public Meeting) l Location: Rockville, Maryland Date: Thursday, November 10, 1988
!f Pages: 1 - 103 i
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l I Ann Riley & Associates Court Reporters ;
1625 l Street, N.W., Suite 921 Washington, D.C. 20006 (202) 293-3950 l
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5 DISCLAIMER 6
7 This is an unofficial transcript of_a meeting 8 of the United States Nuclear Regulatory Commission held 9 on November 10, 1988 in the Commission's office at one 10 White Flint North, Rockville, Maryland. The meeting was 11 open to public attendance and observation. his transcript 12 has not been reviewed, corrected, or edited, and it may 13 contain inaccuracies. i 14 The transcript is intended solely hor general 15 informational purposes. Asprovidedby10ChR9.103, it is 16 not part of the formal or informal record of. decision of the 17 matters discussed. Expressions of opinion in this transcript
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18 do not necessarily reflect final determination or beliefs.
19 No pleading or other paper may be filed with the Commission ,
20 in any proceeding as the result of, or addressed to, any 21 statement or argument contained herein, except as the 22 Commission may authorize.
23 24 25 s
1
.s 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 ***
4 BRIEFING ON FINAL RULE ON STANDARDS FOR PROTECTION 5 AGAINST RADIATION - PART 20 6 ***
7 PUBLIC MEETING 8 ***
9 Nuclear Regulatory Commission 10 One White Flint North 11 Rockville, Maryland 12 13 Thursday, November 10, 1988 14 15 The commission met in open session, pursuant to 16 notice, at 2.0:00 a.m. , the Honorable LANDO W. ZECH, Chairman of 17 the commission, presiding.
18 19 COMMISSIONERS PRESENT:
20 LANDO W. ZECH, Chairman of the Commission ill THOMAS M. ROBERTS, Member of the Commission ,
22 KENNETH M. CARR, Member of the Commission l
23 JAMES R. CURTISS, Member of the Commission I
24 25
- o 2
- ,~. 1 STAFF AND PRESENTERS SEATED AT THE COMMISSION TABLE
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3 S. CHILK 4 W. PARLER i
5 V. STELLO '
6 J. GUNTER i 7 A. RICHARDSON 8 D. D'ARRIGO 3 P. STANSBURY 10 J. COLVIN 11 B. MORRIS 12 E. BECKJORD 13 R. CUNNINGHAM 14 H. PETERSON 15 F. CONGEL 16 17 18 19 20 21
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- 23 24 25 t
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.,,. 1 PROCEEDINGS 2 (10:00 a.m.]
3 CHAIRMAN ZECH: Good morning, ladies and gentlemen.
4 Commissioner Rogers will not be with us this morning.
5 He is on overseas travel.
6 The purpose of the briefing this morning is to 7 discuss the final rule on standards for protection against 8 radiation. This is an information briefing which supplements 9 information contained in SECY 88-315, currently under 10 Commission review.
11 The Commission will reflect on all the comments that 12 we receive here today and also the previous comments we have 13 received, and we will not vote today, but we will vote later in 14 public session sometime in the future.
15 If I could point out that originally today's briefing 16 was intended to be an information briefing by the staff to the 17 Commission, to review and discuss the many details and the 18 various aspects of the proposed final rule. However, we 19 received a number of requests from other interested parties, so 20 today's briefing will be a combination briefing.
21 During the briefing today, the commission will hear 22 from the interested parties who have requested to appear before 23 the Commission. It will also hear from the staff as regards 24 briefing the commission as we had originally intended, for it 25 to be an information briefing.
4
, 1 We recognize the issue is of great interest, 2 certainly because of nothing more than the large number of 3 comments we received, something over 800, I understand, that 4 the staff has previously received and reviewed.
5 As many of you know, 10 CFR Part 20 establishes the 6 NRC's standards for protection against radiation that are used 7 by all licensees and enforced by the NRC staff to protect 8 radiation workers and members of the public from radiation 9 hazards.
10 Recognizing that radiation protection philosophy and 11 technology have evolved since Part 20 was promulgated'nearly 30 12 years ago, the Commission believes a revision is desirable to 13 provide better assurance of protection of public health and 14 safety. Some of the benefits of this rulemaking initiative 15 include updating regulations to reflect current scientific 16 knowledge of radiation protection philosophy, consistency with 17 recommendation of authorities on radiation protection matters 18 and also provisions for clearly identified doce limits for the 19 public and an understandable health risk base for protection.
20 First, this morning we will hear the views from some ,
21 of the representatives of the Environmental Protection Agency 22 and other interested groups, then we will hear from the NRC 23 staff concerning the proposed revisions to Part 20.
24 I underst1nd slides are available and the SECY paper 25 also as you entered the room this morning.
- O 5
e 1 I'd like to also invite the NRC staff to comment on 2 the remarks made by our eattlier presenters when they come to 3 the table this morning.
4 Do any of my fellow Commissioners have any comments 5 they would like to make before we begin?
6 (No response.)
i 7 CHAIRMAN ZECH: We will begin. Mr. Gunter, you are 8 welcome and you may proceed. L 9 MR. QUMTER: Thank you and good morning. My name is 10 Bill Gunter. I am the Director of the Criteria and Standards 11 Division in the Officia of Radiation Programs at the U.S.
12 Environmental Protect. ion Agency. I appr 'iate having the 13 opportunity to come and address the Commissien today concerning 14 these proposed revirsions to 10 CFR Part 20.
15 10 CFR Ptart 20 is by far the most widely used U.S.
16 codification of radiation protection requirements. It directly 17 affects hundreds of thousands of workers employed by NRC 18 licensees. It bras also served in the past as the model upon 19 which statas and other federal agencies, such as OSHA, base 20 their reg :lations. We estimate that the total number of 21 individuals occupationally exposed to radiation in any year now 22 exceeds 1.5 million. The importance of 10 CFR Part 20 beyond 23 its direct application to NRC licensees is clear.
24 As you know, in January of 1987, President Reagan 25 issued new Tederal guidar.ne for the protection of workers from
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,- 1 radiation. This guidance was developed through an interagency 2 effort under the leadership of EPA. We were most appreciative 3 of the essential, continuous and most help input from the 4 Nuclear Regulatory Commission during this process. e 5 The new federal guidance represents the first 6 official major revision of radiation protection principles in 7 the United States in almost 30 years. It contains a number of 8 significant changes from previous policy. These include 9 introduction of risk based weighting of doses to different 10 ptrts of the body and the use of committed dose as the primary 11 basis for control of internal expos 6re.
12 The numerical values of the guidance for maximum 13 radiation doses were reduced and now explicitly apply to the -
14 sum of external and internal doses.
15 These changes brought U.S. policy into general 16 conformance with international recommendations and practice.
17 In addition, numerical guidance is now provided for protection 18 of the unborn and greatly increased emphasis is placed on i 19 eliminating unjustified exposure and on keeping justified l 20 exposure as low as reasonably achievable.
l 21 Finally, the new guidance emphasizes the importance 22 of jnstruction of workers and their supervisors on the basic 23 risks to health from radiation and on basic radiation 24 protection principles, of monitoring and recording of doses to 25 workers, including cumulative lifetime doses and of the use of
7 1 administrative control and reference levels for carrying out 2 ALARA programs.
3 One of the most difficult decisions EPA faced when it 4 recommended this new guidance to the President was the choice 5 of the limiting value for annual dose. It would, I believe, be 6 useful to repeat here the considerations that accompanied our 7 recommendations.
8 "In recommending a limiting value of five rems in any 9 single year, EPA has had to balance a number of nonsiderations.
10 Public comments confirmed that for some beneficial activities, 11 occasional doses approaching this value are not reasonably 12 avoidable. On the other hand, continued annual exposures at or 13 near this level over substantial portions of a working lifetime 14 would, we believe, lead to unwarranted risks.
15 For this reason, such continued annual exposures 16 should be avoided and these recommendations provide such 17 guidance. These recommendations also continue a systen of 18 protection which combines limiting values for maximum dose with 19 a requirement for active application of measures to minimize 20 done, the ALARA requirement.
21 This has resulted in steadily decreasing average 22 annual doses to workers most recently to about 1/50th of the 23 recommended limiting value and to date, only a few hundred out l 24 of millions of workers have received planned cumulative doses l
25 that are a substantial fraction of the maximum previously l
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, 1 permitted cumulative dose over an occupational lifetime.
2 EPA anticipates that the continued application of the 3 ALARA requirement combined with new guidance on avoidanca of 4 large cumulative doses will result in maintaining riska to all 5 workers at low levels. EPA will continue to review worker 6 doses with a view to initiating recommendations for any further 7 modifications of the dose limitation system that are warranted 8 by future trends in worker exposure."
9 The continding importance of the considerations I lo have just cited become obvious in view of current trends in 11 risk estimates for exposure to radiation. We should soon have 12 before us the results of the careful re-evaluation of the 13 health effects in Hiroshima and Nagasaki atom bomb survivors, 14 which has been carried out over much of this decade. Based on 15 everything I have heard so far, I don't believe anyone is 16 predicting that risk assessments associated with radiation 17 exposure are going to go down.
18 It is our opinion that these draft final revisions of 19 10 CFR Part 20 are consistent with the recommendations of the 20 new federal guidance. They replace the limitation of annual 21 dose to critical organs with the risk based effective dose 22 formalism that forms a central part of the guidance. The 23 approach to control of internal exposure is now based on 24 committed doses for all radionuclides and although other
. 25 methods of implementation are possible, is completely
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-- 1 consistent with the guidance.
2 In its tabulation of annual limits on intake, the 3 rule incorporates the significant improvements in physiology 4 and dosimetry of radionuclides that have been achieved over the 5 past few decades. It provides explicit limits for protection 6 of the fetus and it presents these and other aspects of 7 radiation protection regulation in a more streamlined, 8 internally consistent fashion.
9 In a letter to the NRC dated October 31, 1986, EPA 10 commented on the proposed revision of 10 CFR Part 20. We are 11 pleased to find that NRC has responded positively to these 12 comments. Only with regard to a relatively minor point, 13 whether reports should be filed for the annual doses of all NRC 14 licensed workers or only for those likely to receive the 15 highest exposures are we are not fully in agreement. We 16 continue to urge the Commission to reconsider this point at 17 some time in the future.
18 In summary, we support prompt promulgation of this 19 rule. Accompanying me today is Allan Richardson, who chaired 20 the Interagency Committee that developed the federal guidance 21 and we would be happy to answer any questions that you may 22 have.
23 CHAIRMAN ZECH: Thank you very much. Any questions 24 from my fellow Commissioners at this time? Commissioner 25 Roberts?
10 1 COMMISSIONER ROBERTS: No.
2 COMMISSIONER ZECH: Commissioner Carr?
3 COMMISSIONER CARR: Yes, I have a question. Maybe I 4 misunderstood you. Would you read that part again about it is 5 in compliance, complete compliance and especially the 20.205 6 part?
7 MR. GUNTER: The approach to control of internal 8 exposure is now based on committed dose for all radionuclides 9 and although other methods of implementation are possible, is 10 completely consistent with the guidance.
11 COMMISSIONER CARR: It seems I read in some of the 12 stuff they gave me that the recommendation from EPA was it not 13 be used for actual computations. Did I read it wrong?
14 MR. RICHARDSON: No, there was no such 15 recommendation. The recommendation was that the control of 16 internal dose be placed first on avoidance of exposure to 17 radionuclides and secondly, control the workplace on the basis 18 of the committed dose.
19 There are a variety of ways through which you can 20 control the workplace on committed dose, the one the staff has 21 chosen to propose is based on the doses that it is indicated 22 workers may receive.
23 The guid'nce a goes further and says that if a worker 24 is over exposed on the basis of committed dose, than that 25 particular worker should be monitored in the future years,
11 1 because of the body burdens he may have accumulated, to assure 2 that he does not exceri the annual dose.
3 In the last analysis for an individual worker who has 4 ingested a body burden in excess of the committed dose 5 requirement, the bottom line becomes the annual dose 6 requirement.
7 CHAIRMAN ZECH: Commissioner Curtiss?
8 COMMISSIONER CURTISS: Just one quick question 9 following up on that point. In comments before the Agency and 10 in a presentation that we will hear later this morning, one of 11 the fuel cycle licensees will encourage us to adopt a system 12 using committed dose rather than an annual dose and makes the 13 point in the comment letter that is consistent with the 14 President's guidance.
15 Is one approach versus the other inconsistent or is 16 it just a question of both being consistent, one preferable 17 over the other?
18 MR. GUNTER: I would have to see all the details of 19 that other proposal, but without, I will just read you what Dr.
20 Stansbury will say later this morning. Setting a strict 21 committed dose system, GE would encourace the Commission to 22 adopt a system using committed dose for design and daily 23 control of the workplace and an annual dose to assess and 24 manage the actual dose to workers. In an earlier comment, the 25 same company makes the point that approach -- let me state it
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,.- 1 differently, the deletion of that approach from the proposal is 2 inconsistent with the presidential guidance.
3 MR. RICHARDSON: If I can comment, the point is how 4 you exercise control over internal exposure. It would not he 5 inconsistent -- neither approach is inconsistent with the 6 guidance if control is actually exercised based on committed 7 dose. What the point of dispute appears to be is when are you
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8 going to call an individual worker over exposed and when not, 9 and when are you going to call the workplace itself under 10 control or not under control.
11 COMMISSIONER CARR: If we control the workplace, what 12 effect is that going to have on the worker at all in his 13 lifetime? Are you satisified if we control the workplace, wo 14 are going to protect the worker?
15 MR. RICHARDSON: If the workplac: is controlled so 16 the committed doses won't be exceeded, then the worker will 17 never exceed the committed dose level.
18 COMMISSIONER CURTISS: Their argument I guess is the 19 air sampling approach is less reliable as a means of control 20 and they have suggested another control approach. l 21 MR. RICHARDSON: That is really a detailed regulatory l
22 matter that the guidance does not address.
2J MR. GUNTER: I don't hear any inconsistency thero 24 with the guidelines.
25 COMMISSIONER CURTISS: Thank you.
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,. s 1 CHAIRMAN ZECH: Would you elaborate very briefly on 2 the point of disagreement or non-concurrence you have with the 3 staff?
4 MR. GUNTER: It is not a matter of non-concurrence.
5 It-is a comment that we made that was not adopted and it has to 6 do with the coverage of reports on annual doses, whether it 7 would be for all workers or for only those likely to receive ,
8 the higher exposure we had suggested, that it would be 9 preferable to eever all workers. This has not been adopted.
10 We still believe that would be the better approach and would 11 like for you to reconsider that at some time in the future.
12 CHAIRMAN ZECH: All right, thank you very much. Let 13 me thank you very much, gentlemen, for appearing before us this 14 morning. We call on Dr. Stansbury from the GE Nuclear Energy 15 Organization. Dr. Stansbury, you may proceed. Welcome.
16 MR. STANSBURY: Thank you. Good morning, gentlemen.
17 My name is Paul Stansbury, and I represent GE Nuclear Energy.
18 I would like to take just a moment of your time to introduce i
39 myself for it's relevsnt to what GE would like to say.
20 I'm a graduate of Georgia Tech's Nuclear Energy and Hea.ith Physics program.
21 As it happens, I did my dissertation 22 research in the Nealth Physics Division of the Oak Ridge {
23 National Laboratory, in the group which did the modeling 24 calculations for ICRP-30, the scientific document on which the 25 new Part 20 is based.
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- 1 I taught Health Physics for five years at the 2 University of North Carolina at Chapel Hill. For the past six 3 years, I have worked for GE as the senior nuclear safety 4 engineer, sharing with another senior engineer, the day-to-day 5 responsibility for all technical aspects of the radiation 6 safety program at GE's fuel fabrication plant in Wilmington, 7 North Carolina.
8 I've been discussing the Part 20 revisions since 9 1983. Tnat's well over five years. I've had discussions with 10 the staff drafting the regulations; with the Health Physics 11 society, with the AIF, which of course is now NUMARC.
12 This morning, GE Nuclear Energy would ask you to 13 reconsider the staff's recommendation on the role of committed 14 doss and radiation protection from persistent radionuclides. :
15 How this issue is resolved will mold the fundamental nature of 16 health physics programs at fuel fabrication facilities for the ,
- 17 next several decades. .
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18 It will influence the cost of uranium fuel, and the ;
19 competitiveness of U.S. industries in the world market for i i
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20 reactor fuel. The issue, as GE sees it, is whether to use l l
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21 either a strict committed dose system, or a combined system 22 using committed dose and annual doser using committed dose 23 values for design and day-to-day control of the workplace; :
24 using annual dose as the dose of record for individuals l l 25 occupationally exposed.
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15 1 Under a strict committed dose system, compliance is 2 demonstrated by determining and summing a small number of 3 intakes, say, daily. Air sampling is indeed the tool to do 4 this. Once an intake is specified, the committed dose value is 5 calculated using the pre-determined values in Appendix B.
6 These are based on the reference man assumptions and integrated 7 over the next 50 years, 8 Annual dose to an individual can be determined more 9 directly. What needs to be known is the amount of radioactive t
10 material residing in the organ during the year. For the 11 uranium fuel fabrication industry, the orgh.i of concern is the 12 lung, and lung counting is an established practical method for 13 assessing lung contents.
14 A series of a few to several lung counts for each 1
15 individual will specify the average lung contents during the 16 year. One may then convert to dose, annual dose, by using the 17 physiologic parameters of reference man, such as organ weight.
la But this conversion is done without making assumptions about
! 19 how much is retained in what organs and for how long.
20 Air sampling seems straightforward and precise.
21 Radioactivity collected on a filter can be measured to a high 22 degree of accuracy. One must assume that the air sampled 23 resembles the air the worker breathed. This representativeness ;
24 is of concern to the facility health physicist, to the !
25 regulatory inspector, and potentially to a court scaeday in the .
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16 1 future. -
2 How representative is representative enough is a 3 difficult and unending question, and an important one if air 4 sampling is the major method of determining a worker's dose of 5 record. Representativeness is still an issue with lapel or 6 personal air samplers, often presumptively called breathing 7 zone air samplers.
8 I did go to college for a good while, but it didn't 9 take that to realize that all air samplers measure air the 10 worker didn't breathe. With lapel samplers, partical 11 collection problems cause difficulties where one's intuition 12 would suggest that good representativeness is obvious.
13 Determining committed dose from air sampling has two 14 further problems. It requires that more reliance be placed on 15 assumptions rather than measurements to account for the 16 distribution and retention of inhaled material. It has no way 17 to account for material ramaining in the body from prior 18 intakes, other than by lumping the committed dose from an 19 intake together with all the other committed doses from prior 20 intakes. ,
21 Lung counting to determine dose or. an annual basis 22 has some significant advantages. It's a direct measurement, 23 and representativeness is not the issue that it is with air 24 sampling. Lung counting directly accounts for individual ,
25 worker differences in clearance times, breathing rates; also
l 17 l
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,. 1 accounting for particle size and solubility to some extent. i 2 It minimizes under or overestimation of dose. There 3 are some lung counting limitations. It is easier to determine
- 4 the radioactivity on an air sample filter than in an organ.
5 Lung counting minimum sensitivity does not permit i
6 determinations of intakes at levels ot' day-to-day interest, 7 say, 40-DAC hours.
8 However, lung counting sensitivity and accuracy are 9 quite acceptable at lung contents equal to or greater than say 10 35 percent of an annual dose based action limit. In some 11 cases, a series of lung counts may be necessary to determine 1
12 the average organ contents, and thus the annual dose with ;
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13 enough precision. I would like to briefly outline other
, 14 problems wit.h the strict committed dose system -- briefly.
15 The NCRP specifically advises against it. Second,
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) 16 it is expensive. The staff estimate is $75 million. This is .
! l l 17 an okay estimate for capital costs, but GE feels the cost to l
, 18 operate under the new stricter limits will be higher still. l 19 A strict committed dose system will complicate 4 [
20 epidemiology among uranium fuel fabrication worker populations, l I
21 because the legal record of committed dose is not a good I
22 estimate of the exposure variable, committed dose is an l
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- 23 abstract modeling quantity. It is difficult to explain to {
2 24 thost outside the field of health physics. i
. 25 Explaining i: will be a liability in court, and a l
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,, 1 difficulty in discussions with workers. Lung counting is an 2 employee-oriented direct measurement. Adoption of the strict 3 committed dose will tend to discourage lung counting at fuel 4 fabrication facilities. Adopting a strict committed dose 5 system will focus health physics attention on reducing 6 conservatism in the dose determining models.
7 Such attention would otherwise be spent in reducing 8 actual worker exposures. A strict committed dose system could 9 perhaps mask the whole purpose of the proposed 10 CFR 20 10 changes to have a clearer relation be twten regulatory dose 11 limits and risk. The reason is a strict committed dose system 12 will make the new DAC functionally analogous to the old MPC.
13 Such an analogy is dangerous in that it hides the 14 real fundamental differences between the quantities and 15 falsely, it suggests that the former MPC is too large by a 16 factor of five in the case of uranium. This is not the case.
17 Instead of a strict committed dose system, GE would encourage 18 the Commission to adopt a combined system, committed doso for 19 planning and daily control of the workplace; annual doso for 20 management of actual worker exposures and determination of the 21 dose of record. Such a combined system is in accord with the 22 recent presidential guidance, and parallels the Department of 23 Energy's implementation of that guidance. It is in accord with 24 the recommendation of the NRC's own Advisory Committee on 25 Reactor Safeguards.
19 1 Finally, it makes the best use of both air sampling 2 and lung counting technology to provide excellence in the :
3 management and control of workers' internal exposures, while 4 avoiding extremely costly unnecessary conservatism. It places 5 more emphasis on direct measurement and less reliance on 6 general assumptions.
7 Use of practical, technically sound and reasonablf 8 cost effective radiation exposure management systems is ;
9 essential to the future o'. nuclear energy in this country and 10 in the world. How you decide the issue will have pervasive and 11 far-reaching impacts.
12 Thank you, and I will answer any questions, or at 13 least try to, now or at some other time.
14 CHAIRMAN ZECH: Thank you very much. Questions?
15 Commissioner Roberts? L 16 COMMISSIONER ROBERTS: No.
17 CHAIRMAN ZECH: Commissioner Carr?
18 COMMISSIONER CARR Give me your opinion on what the 19 effect will be on the worker after fifty years of the two 20 methods. [
21 MR. STANSBURY: Virtually the same, because the ALARA 22 principle is going to be used to control the averaga worker 23 exposure. Most workers' exposures are not going to be at the i
24 limits.
25 COMMISSIONER CAPRI Over fifty years, the worker is i
20 ,
1 not going to see any difference, no matter which method we 2 pick? r 3 MR. STANSBURY: Well, one can conceive of 4 hypothetical cases that would demonstrate that one system or 5 another is better at the extreme. If you look at the average 6 worker population, I'm not sure that there would be a big 7 change in the worker's actual exposure.
8 COMMISSIONER CARR: Go ahead, I didn't mean to cut 9 you off if you have something also *.o say.
1 10 MR. STANSBURY: Well, it all depends on how you 11 account for those things. Those that believe in committed 12 dose, over fifty years, would be able to show a huge dose 13 savings in terms of committed dose, because that's the way they 14 calculated it, compared t'ith what might be receiv6 4 on an 15 annual dose system. It's a bookkeeping problem.
16 The actual dose to worxers is likely to be nimilar.
17 Under annual dose, I see the added benefit that we would have a 18 better established dose record firmly based in measurements on 19 the individual. Under a committed done system, the dose of 20 record would be primarily based on air sampling for fuel 21 fabrication facilities and would have some holes in it.
22 They would actually have higbir recorded doses in l
23 rems under a committed dose system, bece,use of the conservative 24 nature of the assumptions.
I 25 COMMISSIONER CARR But it might not be -- actually, 1.
l 21 gs 1 tho' worker might not have been exposea to its is that what
(
- 2 you're saying?
l l 3 MR. STAN8 BURY: Yes.
i 4 C000tISSIONER CARR Okay. I 5 CHAIRMAN EECMt All right. Comaf.ssionet Curtiss?
l s ColetIssIoKtR r'URTISS: Just on.e quick question. Do i
- 7. you have an estimate of what the additional operational costs j j
1 8 would be above the 475 million? f i
l 9 MR. STANSBURY: That's e real issue. Integrated over j i !
( 10 how long? Fifty years? Equal to the $75 million dolla?. --
i i 11 that's just a guess, and that's my guess, not GE's.
1 i
12 CHAIRMAN ZECH: I have just one question, too. To j 13 get back to Commist,ioner Carr's question, or at least a simi)ar 4
l 14 question; it would seem to me, if I understand the difference.
i 15 between the annual dose approach and the committed dose 16 approach, that it would be conceivable that under the annual 17 dose approach, if one received the maximum dose annually each
! is year throughout his lifetime, that that could and up being a l
l 19 considerably higher number than ene would receive in the
- 20 committed dose approach method.
21 Is that correct? If not, please enlighten me.
I 22 MR. STANSBURY: No, there again, when you get into 23 extremes, one can come up with models that will show one cate l, 24 against nother. If you lcoked ht a worker near the limit and 25 he collected an annual dose of, let's say, 5 rems a year, f
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22 1 CHAIRMAN ZECH: Each year for, say, what, fifty years i 2 or forty years?
3 MR. STANSBURY: Forty years, and then he lives for 4 another thirty years, he would get the annual dose of five rems 5 in a year. If there was a build-up in the annual dose system, 6 the allowable intakes would go down as the lung contents went 7 up.
8 CHAIRMAN ZECH: Then he would get a total dose that 9 would be larger than the individual who, under the committed 10 dose approach, would get? :
11 MR. STANSBURY: Not substantially, because at the end 12 of fifty years of the employment lit'etime, with the annual 13 dose, you'd have to go ahead and accrue the slight residual 14 dose that would be committed. Under the committed dose, you 15 would have already have accrued all of that.
I 16 CHAIRMAN ZECH: So you're saying they would be 1
17 essentially the same. (
18 MR. STANSBURY: Over a lifetime.
19 COMMISSIONER CARR Let me ask that so that I 20 understand it. Are you saying that maybe in his 35th year, he 21 would not be allowed to get his 5 R? l 22 MR. STANSBURY: The way I see an annual dose system 23 working is, one would take 3 rams is what paragraph 20.205 !
24 suggested, to provide some flexibility, and convert that to a 25 lung content limit. The worker would be managed so that lung I
23
, 1 contents would'never exceed that amount. ;
- 2 Therefore, the dose would be no more than three rems ,
t 1 3 per year from internal exposure, plus a short tail after the I
! 4 individual retires, where the uranium is cleared from his body. !
5 Add that little dose into the 3 rems a year, and you have a l 6 total. j l
7 Under a committed dose system, you would essentially l
8 allow the worker to have a number of intakes so that three rems !
1 l i 9 over the next fifty years, which includes the little tail, l I !
j 10 would be the limit, or 5 reus as the case may be. I guess it j i
. 11 involves taking the graph of dose versus time, and under annual !
I L
! 12 dose, you cut it vertically, and under committed dose, you kind i f
i 13 of cut it horizontally. l l !
14 COMMISSIONER CARR: We're trying to find out if his l
! l j 15 actual limit reduces over his lifetime in both cases. Are we j i
16 actually reducing the limit he's able to be exposed to?
I j 17 MR. STANSBURY: I beg your pardon?
1 i 18 COMMISSIONER CARR: I start out this year and I get
! I i 19 5. Next year, I'm not allowed but 4.9999? The next year maybe l
20 4.9998, and finally in my fiftieth year, I'm not allowed any?
! 21 Ts that the way it works? l I l 22 MR. STANSBURY: No, not in reality. [
! 23 COMMISSIONER CARR: Is that the way it's supposed to l
' t l
24 work? !
l 's .
t l 25 MR. STANSBURY: No, the uranium compounds are cleared i
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24 1 from the lungs, and if you worked and had a series of intakes, 2 breathing the small amounts of uranium dose that are in the 3 plant, we might have an intake that give you a lung content 4 that was equivalent to 5 reus a year. Next year, your intake 5 will probably have to be a little bit more tightly controlled 6 because we wouldn't want the total lung content to go over the 7 number that corresponds to 5 reus a year on the annual dose 8 basis.
9 COMMISSIONER CARR: There would be some reduction in 10 my limit the next year?
11 MR. STANSBURY: Right, under a committed dose system, 12 your limit is up front. What you would be allowed in a year 13 under a committed dose system is much, much, much less than 14 what you get under an annual dose system. So, under a 15 committed dose system, you could have been involved in perhaps 16 a situation that is far from ideal, not be able to work for the 17 rest of the year.
18 Then when January 1st comes along, ur. der a committed 19 dose system, you erase the fact that you had that intake, and 20 you now start over with accumulating DAC hours.
21 COMMISSIONEit CARR: I have no other questions.
22 CRAIRMAN ZECH: Any other questions?
\
23 (No response.)
24 CHAIRMAN ZECH: Thank you very much, Dr. Stansbury, 25 We appreciate your being with us today.
p
25
,s 1 The representative from the Nuclear Information and 2 Resource Service, Ms. Diane D'Arrigo; is that correct?
3 MS. D'ARRIGO: Good job. Right, very definitely.
4 CHAIRMAN ZECH: Walcome, Ms. D'Arrigo. You may [
5 proceed. Yes, don't put that in front of the microphone if you l 6 would. You might move it to this side rather than at the 7 front. Thank you very much.
8 MS. D'ARRIGO: I very much appreciate the opportunity 9 to address the Commissioners this morning on what I believe is 10 one of the most important responsibilities that the Nuclear 11 Regulatory Commission has, protection from radiation exposure.
12 We have at the Nuclear Information Resource Service 13 would have liked more than four working days' notice that we i 14 were given the opportunity to speak and an advance copy of the 15 proposed rule would have allowed us to have more pertinent 16 comments, but we are glad to be here in any case.
, 17 Nuclear Information Resource Service and many others [
i i 18 including unions, county and state officials, public health ;
. p 19 associations, national and local environmental groups, citizen [
1 30 organizations, church groups, concerned individuals, and even l 21 nuclear utilities and health physicists commented critically on 22 the 1986 NRC proposal regarding radiation standards. [
23 I'm speaking today on behalf of Nuclear Information !
I f
l, 24 Resource Service, Environmental Policy Institute, critical Mass [
25 Energy Project and many of the local organizations and citizens i
(
26
, , 1 groups across the country who couldn't be here.
2 The worker portion -- worker exposure portion of my 3 comments, is also on behalf of the 011 Chemical and Atomic 4 Workers and the International Chemical Workers Union and the 5 Maine Labor Group on Health.
6 The Commission received in the range of 1,000 7 comments on uhe rule so there's clearly public interest in it 8 and we would like the opportunity to comment again after 9 thoroughly reviewing this proposal that was given out today 10 before the Commission votes.
11 We're requesting regional, public, adjudicatory 12 hearings on the rule. Furthe,r, we are again requesting since 13 the radiation release to the environment and exposure to the 14 human gene pool are involved and since this is a major federal 15 action affecting the environment, that a full environmental 16 impact statement be done.
17 NRC has not considered the impact of reducing all 18 exposure and contamination levels. I would like to point out 19 that we are in agreement with Commissioner Roberts' opinion in 20 1986 that the rule should not be approved although our reasons 21 are different.
22 The NRC's cost benefit or backfit analysis concluded 23 that the proposed rule "may not provide a substantial increase 24 in overall protection of public health and safety or of the 25 common defense and security."
27
,. 1 In other words, the supposed benefits are not worth 2 the cost to implement this rule. Although our organization 3 does not support using the cost-benefit analysis to decide 4 public health and safety issues, we do find it curious that the 5 commission is proceeding *11th a rulemaking which it has 6 determined that is not economically worthwhile and which fails 7 to provide increased safety. ,
8 My statement this morning is based largely on the 9 proposed radiation standards as I was refused an advance copy 10 of the final proposal which is being released today.
11 I apologize for any criticisms that may have already 12 been taken into account and changed. The main concern that we 4
13 have with the proposed radiation standards is that the
- 14 permissible contamination and exposure levels for many of the 15 radionuclides in air and water will be increased above the
- 16 current levels.
17 NRC admits this fact in its 1986 proposal. 10 CFR i
18 Part 20, Appendix B, the table of radionuclides and 19 concentration levels, permissible contamination levels for air !
l l
20 and water, table one is for workers and table two is for the I
21 public. In the 1986 proposal, the permissible contamination 22 levels for over two-thirds of the radionuc' ides increated to 23 higher levels than are currently allowed. r 24 My understanding is that there are some changes in i 25 that but that it's basically the same thing in this final ;
1 28
,. s 1 proposal. The standards set by the Nuclear Regulatory 2 Commission for workers will set the precedent for other federal 3 and stste agencies and departments.
4 Workers at the nation's troubled weapons facilities 5 vill legally. receive higher internal radiation doses if and 6 when the Department of Energy follows the NRC's lead in 7 adopting these standards and I understand that they're moving 8 in that direction.
9 It would be preferable we feel to require cleaner 10 operations at all sites than to increase allowable worker 11 exposures. The Environmental Protection Agency used this 10 12 CFR Part 20 Appendix B to derive its safe drinking water 13 regulations. Further, many state radiation regulatory agencios 14 used 10 CFR Part 20 Appendix B to analyze nuclear plant 15 effluents, other nuclear facility releases and to indicate to 16 the public and the media what acceptable federal radiation 17 release limits are.
18 The increases in permissible exposure to the public 19 can occur at all NRC licensed facilities allegedly except the 20 uranium fuel cycle facilities, so hospitals, research reactors, 1 21 university reactors, radiopharmaceuticals, industrial and other 22 facilities will be permitted to expose the public to higher
! 23 radiation levels than are currently allowed -- internal 24 radiation.
25 I contend also that nuclear power plants will also
29 s 1 and up using 10 CFR Part 20 Appendix B. Nuclear plent licensos 2 have technical specifications vhich are the limiting conditions 3 for reactor operation.
4 These technical specifications require adherence to 5 10 CFR Part 20 Appendix B for dealing with radioactive 6 effluents, specifically liquid affluents.
7 The alarm set point on monitors for liquid waste 8 streams are set according to 10 CFR Part 20 Appendix B, for 9 example, the technical spec 3.11.1.1 for the callaway Nuclear 10 Plant in Missouri, reads "the concentrations of radioactive ,
11 material released in liquid effluents to unrestricted areas 12 shall be limited to concentrations specified in 10 CFR Part 20 13 Appendix B, Table 2, Column 2 for radionuclides other than 14 dissolved or entrained Noble gases."
15 The proposed rule also requires that uranium fuel 16 cycle facilities which is nuclear power plants, uranium mills, 17 conversion and enrichment facilities and reprocessing plants, j 18 must meet the U.S. Environmental protection Agency or EPA l
l 19 standard for 40 CFR Part 190 which limits the maximum radiation 20 dose to each member of the public to 25 millirems par year 21 whole body dose. ,
22 But 25 millirems per year is not an enforceable, 23 numerical emission standard. The Appendix B of the NRC i t
l 24 regulations is the working tool used to limit radiation 25 releases which can lead to public exposures.
a .
30 e 1 If the intent of the NRC is that the individual 2 public exposure should be limited to EPA's standards of 25 3 millirens per year, then the NRC tables should be based on an 4 annual dose to the public of 25 millirens per year rather than 5 based on a 100 millirem per year exposure level which the 6 tables in the 1986 proposal were based on. I haven't looked at 7 the one released today but I assume it's based on the same 100 8 millirens per year.
9 We advocate a changa in the standards that 10 significantly reduces the permissible contamination levels and 11 exposure levels. Another concern that we have is with the 12 method of calculating radiation doses. The weighting factor by 13 which the individual's internal dose is multiplied incorporates 14 risk estimates and we oppose incorporating risk estimates into 15 what is supposed to be an objective dose measurement.
26 In addition, there are several problems with these 17 risk estimates. First, the only risks that are considered are 18 for fatal cancers and birth defects in the first two 19 generations. There's no consideration or calculation for 20 cancers that people don't die of or for other health effects 21 related to radiation such as decreased immune system function 22 which can then lead to increased susceptibility to diseases and 23 accelerated onset of age-related diseases.
24 If radiation risks are going to be calculated and 25 used in the dose measurement, we believe that all the known
o . ,
i 31 l 1 risks should somehow be included.
- 2 secondly, the risks of developing a fatal cancer or t
j 3 birth defect in the next two generations is underestimated. j s i i 4 The Nuclear Regulatory commission uses a risk co-efficient of !
5 1.65 cancer deaths per 100,000 person rens. That's if 100,000 6 people are exposed to one rem each, 1.65 of them will die from f 7 radiation-induced cancer more than otherwise would have died. I 8 This is a controversial number. The estimates range
-; l t
9 from 1 to 37 fatal cancers per 100,000 person rems and we '
- 10 believe that NRC has chosen a very low and not a conservative '
- i J
l 11 risk estimate for basing the data. l 1 !
j 12 The re-evaluation of the Hiroshima and Nagasaki l i
- 13 dosimetry and the debate over what the dose-response curve j l
j 14 should be, that is, the biological effect from a given amount l 4
15 of radiation exposure, call into question the reliability of l 1 [
- 16 the risks which are used in the weighting factor and that's j
! i
) 17 also used in developing Appendix 5.
18 With all due respect, I have yet to understand how f
! 19 the supposedly objective measurement of internal radiation dose j 20 can incorporate a controversial risk estimate into its 21 measurement and there should be some way to measure an internal i
! 22 dose and make it comparable with external doses without l 23 depending on controversial risk estimates. [
- )
24 The third problem with the risks is that they are !
1 l 25 based on risk to the entire population when a good number of [
i l i L l [
l 32 if, 1 people in the population such as the unborn and young children 2 whose cells are dividing much more rapidly than adults, are at I l
3 auch greater risk.
4 People who have undergone voluntary radiation 5 treatment and diagnosis for personal health reasons are also at !
6 increased risk because they have already increased their f t
7- radiation-related risk, thus will be at even higher risk from r i
8 this increased, involuntary exposure. l 1
t 9 Now, referring to occupational exposures, quite a few l
4 10 unions did submit a longer list of comments. A few of them ;
11 that I've included here are the lack of worker rights regarding l 12 planned special exposures. By the planned special exposures !
i 13 provision, workers can be required, involuntarily, without l
! 14 their consent, to receive up to twice the annual dose limit in l l
15 certain situations. If it's an emergency situation, they can l 16 get 5 reus more of radiation exposure without agreeing to it. f
- 17 Pregnant workers can be exposed to .5 rems per the 9- i
. I 1
18 month pregnancy period and this is within the range of exposure [
19 that has been shown to double the risk of childhood cancer and I l 20 mental retardation. Concern is also for men p*anning
. to start !
r j 21 or add to their families. The use of risk co-efficients to 22 justify allowable dose increases to internal organs, which I 23 went through a few minutes ago, is also a concern to the j 4 l i 24 unions.
i I 25 It's also of interest that the National Radiological l
- o 33 1 Protection Board in England has adopted this scheme that is 2 proposed in the proposed rule for calculating radiation 3 exposure, but they have reduced the total annual allowable 4 exposure to each worker from 5 rems a year to 1.5 rems a year.
1 5 It has been claimed in many of the documents, even 6 from the nuclear utilities that most workers don't come near to 7 getting 5 reus a year and it was in the decisionmaking that the 8 National Radiological Protection Board in their discussion of 9 why they made this decision, that it really wasn't naking a 10 whole lot of difference. There were only a few cases where 11 workers got more than 1.5 rems a year and in those cases, they 12 could get special permission to do so.
13 Social reduction is quite advisable for the United 14 States and should be seriously considered before the Commission 15 votes on this rule.
16 Fourth, the de minimis concept that there is a level 17 of exposure so low that it is not worth regulating should be i 18 abandoned. In Japan, when a de minimis exposure level was I
19 established for workers, it gave the appearance of a j 20 significant reduction in radiation exposure but the reduction 21 was not from not recording exposures -- vait a minute -- the 22 reduction was a result of hot recording low exposures below the 23 de minimis level, not from improved worker protection.
l 24 The 1986 proposed rule calls for de minimis levels 25 for public exposures. I've been informed by the NRC staff that
34 1 this portion of the proposal has been deleted from -- that the 2 de minimis concept and declaring waste below regulatory concern 3 has been removed from the radiation standards that are being 4 presented today and are being considered under another 5 rulemaking here at the NRC, but in any case, I'll give a short 6 comment that there is unequivocal opposition to this concept 7 and this policy, a Unions, municipalities, citizens, will not accept l
9 deregulated nuclear waste which is now being referred to as BRC 10 or below regulatory concern waste. This linguistic 11 toxification as Barry Commoner calls it, of nuclear waste, 12 could allow nearly half of what is currently considered low-13 level radioactive waste to be declared regular garbage or 14 ha:ardous waste.
15 The NRC's most recent paper after your international 16 conference on below regulatory concern vaste says that up to 32 17 percent of the low level waste stream could be deregulated or 18 declared not radioactive and go to landfills, incinerators, 19 sewers, anywhere that regular garbage or hazardous materials 20 go.
21 We in conclusion do request adjudicatory hearings and 22 an environmental impact statement be done. We encourage the 23 reduction in permissible contamination levels, exposure levels 24 in 10 CFR Part 20 Appendix B and we thank tou again for the i
25 rare opportunity to address the Commission.
e 1 35 f 1 CHAIRMAN ZECH: Thank you very much.
2 MS. D'ARRIGO: You're welcome.
3 CHAIRMAN ZECH: Any questions from my fellow 4 Commissioenrs? Commissioner Roberts?
5 COMMISSIONER ROBERTS: No.
6 CHAIRMAN ZECH: Commissioner Carr?
7 COMMISSIONER CARR No.
8 CHAIRMAN ZECH: Commissioner Curtiss?
9 COMMISSIONER CURTISS: No.
10 CHAIRMAN ZECH: Thank you very much for being with us 11 today. We appreciate your testimony and thank you for your 12 presentations. We'll now hear from Mr. Joe Colvin from NUMARC.
13 Mr. Colvin, welcome, you may proceed.
14 MR. COLVIN: Mr. Chairman, gentlemen, good morning.
15 My name is Joe Colvin. I'm the Executive Vice President and 16 Chief Operating Officer of the Nuclear Management and Resources 17 Council, called NUMARC. I would like to take this cpportunity 18 to thank the Commission for being able to appear before you at 19 this meeting and present a statement on behalf of NUMARC on the 20 proposed revision of 10 CFR Part 20.
21 With me today is also our Project Manager on this 22 issue, Lynn Fairobent. NUMARC vishes to expriss its overall 23 support for the proposed revision to 10 CFR Part 20. We 24 support the Commission's efforts to incorporate revisions to 10 25 CFR Part 20 which reflect the developments and advancements
. 3 36 ,
, 1 that have occurred since the original publication of this rule 2 some 30 years ago, but also commend the NRC staff for seeking, 3 during the development stage of the proposed rule, scientific 4 and technical inputs from licensees directly affected by the .
5 rule change.
6 The industry has provided extensive comments on the 7 proposed rule. In addition, NUMARC has provided recent 8 comments in two letters dated April 26 and October 20, 9 respectively, of this year. As expressed in these lettero, 10 there are two specific areas that we urge you to consider prior [
11 to issuance of the final rule. The first one, as we have ;
12 discussed it in some depth already this morning, is with 13 Section 20.205, and the staff has recommended deletion of that t 14 proposed section from the final regulation. I 15 As you are aware, this section would allow licensees 16 to control occupational exposure to certain long-lived 17 radioactive nuclides in terms of the sum of the external deer 18 dose equivalant and the effective dose equivalent actually {
i 19 received in one year from all radioactive material retained in 20 the body. This section, as you are also aware, is of I l
21 particular in ortance to the commercial uranium fuel
[
22 fabrication workers and industry.
23 The retention of proposed Section 20.205 will allow
{
24 licensees the option of accounting for dose on an annual basis l i
25 in conjunction with tracking the 50 year committed dose, rather l
,._,___.___m.-__... . , _ _ _ _ _ . . . . . _ ___ _ _ _ . _ . _ _ _ . _ _ _ _
37 1 than requiring dose evaluation based solely on calculating the 2 50 year committed dose. We recognize that the issue of how to 3 account for radiation dose from radioactive nuclides persisting 4 in the body is decidedly cosplex and not without controversy.
5 However, both the NCRP in its Publication 84 from September of 6 1985, and the NRC Advisory Committee on Reactor Safeguards in 7 its June meeting of this year recommended the use of accounting 8 for dose from these persistent radionuclides on an annual basis 9 in conjunction with tracking the 50 year committed dose.
10 We believe there is a significant cost impact in 11 implementing the proposed rule without the inclusion of the 12 option to account for these doses on an annual basis. As 13 pointed out earlier, the NRC estimate for implementing this 14 section would require recording of doses based on the 50 year 15 committed dose as approximately $75 million to fuel fabricators 16 alone. This is an one-time cost of complying with the 17 regulation and does not reflect the annual operational cost.
18 Not stated in my paper, obviously, is the point that 19 that cost will be certainly passed on to the utility industry 20 and users of fuel.
21 We believe that retaining Section 20.205 would 22 essentially eliminate those costs without decreasing the level 23 of radiological protection afforded to workers. The NRC staff 24 has sought and obtained extensive comments on the proposed 25 rule. The decision to delete this important provision does not
38 1 appear to reflect the comments obtained.
2 If it's decided to delete this section, we strongly 3 urge that the Commission publish this proposed aspect or the 4 aspect of this proposed change for public comment due to the 5 significant difference in approach that this change represents 6 from the original draft regulations published for comment.
7 Shifting to the second area I'd like to discuss, we would urge 8 you to consider looking at the implementation of this rule.
9 Our letter to the NRC staff of April 26 of this year 10 expressed concern that the complexity of this rule could result 11 in non-uniform application of its provisions by those who must 12 regulate the various licensees.
13 We understand that the NRC staff has currently not 14 developed the corresponding guidance documents necessary to 15 provide us licensees with sufficient information to effect 16 consistent interpretation and implementation. In order to aid 17 in uniform application of the regulation and facilitate a 18 greater understanding of the new regulations and potential 19 implementation problems by all involved, we urge the Commission 20 to publish the necessary guidance documents and to consider
. 21 regional workshops for both its inspection staff and licensees, 22 with the accompanying detailed guidanco prior to the full 23 implementation date.
24 This approach was used in implementing 10 CFR Part 25 50, Appendix I, in the early 1970's and has proved beneficial
l 39 1 to both the regulator and to licensees. l l
2 In the proposed rule, the implementation period was 3 sthted to be five years from the date of publication as an 4 effective rule. It is our understanding that the final rule 5 under consideration before you today recommends an 6 implementation period of two years from the effective date of 7 the final rule.
8 We believe that this time is not adequate to ensure 9 correct implementation of the rule. We believe that a phase-in 10 of specific sections of the regulation may be beneficial for 11 both the regulator and for the licensees. NUMARC would be 12 pleased to work with the NRC staff to identify those sections 13 that could be implemented with minimum impact and that would 14 benefit most from the phased-in implementation once the 15 guidance documents are prepared and regional workshops 16 conducted.
17 For example, it would be most cost effective to have 18 all power reactor licensees simultaneously implement the 19 proposed regulations dealing with dose recording. The 20 recording of worker dose is a major portion of the 21 recordkeeping costs for the utility industry as was identified 22 in the industry's study under the National Environmental 23 Studies Project as the single most costly aspect of the 24 proposed rule.
25 In closing, we would urge the Commission to consider
40 (c , -
1 retaining the proposed Section 20.205 and restoring the five 2 year time period for full implementation utilizing a phased-in l
3 approach to achieve your goal. Thank you very much for your 4 consideration.
5 CHAIRMAN EECH: Thank you very much. Questions from j 6 sy fellow Commissioners? Commissioner Roberts?
7 CONNISSIONER ROBERTS: No.
d CHAIRMAN 2ECH: Commissioner Carr?
9 COMMISSIONER CARRt Yes. On your recommendation to 10 not delete the 20.205 rule, part of the rule, my understanding i
i 11 is if we do delete it, we're going back to already what is in i
1 12 effect. Is that correct?
l j 13 MR. COLVIN: No, sir. I don't believe that's the l
j 14 case. I believe the Section 20.205 did provide an exemption I
15 for fuel fabrication industries or for specific licensees that 16 would allow them the option of calculating either with annual j 17 dose and the 50 year committed dose, and to delete that is provision would delete that exemption and only allow the 50 19 year committed dose option, l
j 20 CHAIRMAN EECH: Commissioner Curtiss?
l 21 COMMISSIONER CURTISS No.
! 22 CHAIRMAN ZECH: Thank you very much for your 1
23 presentation. I'll ask the staff to come to the table, please.
l l 24 CHAIRMAN ZECH: Mr. Stel} 'u may proceed.
l MR. STELLO: You have
, 25 Thank you, + t. ' ,
i 1
[
41 ;
1 already heard a great deal about what Part 20 is all-about and 2 you have already heard from various speakers before us on what 3 these impacts may be and where t' hey are and possibly could have 4 a significant effect and especially in fuel fabrication 5 facilities, as you have already heard. (
6 It is my view that the overall thrust of the rule, L 7 taking into account everything will be a generally more a restrictive rule than the present rule we have in place today, [
9 I do believe that the NRC ought to issue its rule to conform to 10 the President's new guidance and that in my view is ,
11 sufficiently important. I have, therefore, recommended that 12 the backfit rule be suspended for the purpose of implementing l
13 this new federal guidance, 14 We have listened carefully to the comments that you 15 have heard this morning and with the Chairman's permission, 16 what we would like to do is include as we go through our 17 presentation this morning, some comments on what you have heard l
18 and respond to some of the issues that were raised in those 19 comments as a part of our presentation as we go through it.
20 I will very quickly turn if I can to Eric Beckjord 21 for sono brief introductory comments and others here at the 22 table will follow with presentations being made, integrating 23 those responses to the comments you have heard this morning, 24 with your permission.
25 CHAIRMAN ZECH: Thank you very much. We appreciate
42 1 the staff doing that, to integrate those responses during the 2 briefing, if you would. Mr. Beckjord, you may begin.
3 !!R. BECKJORD: Mr. Chairman, with this briefing, we 4 are approaching the completion of work that began a decade ago 5 in 1977, with the recommendations of the International 6 Commission on Radiological Protection, the ICRP. These 7 recommendations fundamentally altered the concepts and 8 philosophy underlying the science of radiation protection and 9 proposed new concepts and methods for limiting radiation 10 exposure based upon quantitative estimates of the biological 11 risks of radiation.
12 The publication of these recommendations initiated a 13 worldwide effort to re-evaluate existing radiation protection 14 standards and modify them to incorporate the new approaches.
15 In the United States, this effort led to the issuance of the 16 federal guidance on radiation protection in 1987.
17 Parallel with the development of the federal 18 guidance, the NRC was examining the implications of the new 19 radiation protection concepts. The fact that the NRC staff 20 representatives served on the Interagency Committee which 21 developed the new federal guidance assured consistency between 22 the efforts.
23 In early 1978, the NRC staff formed two task groups 24 to exauine the implication of these new concepts for the NRC 25 standards for radiation protection in 10 CFR Part 20. The work
43 1 of these task groups culminated in the issuance of an advanced l 2 notice of proposed rulemaking on March 20, 1980. This notice 3 identified the issues related to the ICRP recommendations that 4 the staff believed needed to be addressed in any revision to 10 5 CFR Part 20. Public comment was requested on these issues.
l 6 In addition, the senior staff met with many 7 organizations including labor unions, trade associations, 8 licensees, public interest groups and technical societiew 9 asking for suggestions in the revision of 10 CFR Part 20. The results from this consultation was an important input to the I 10 11 preparation of the proposed rule. l 12 The proposed rule underwent several years of internal l 13 review and modification before it was approved by the !
l 14 Commission and published for public comment at the beginning of L 15 1986. Because of the importance of this rule and its 16 complexity, the comment period on the proposed Part 20 revision 17 was extended saveral times, eventually to more than 250 days.
18 In that period, over 800 public comment letters were 19 received. The total number of comments in these letters 20 amounted to several thousand that the staff revieved and 21 analyzed.
22 In order to deal with this important task, the office 23 of Research formed two groups, tasked with the job of bringing 24 the revised Part 20 to fruition. The first group which was the 25 Steering Committee, consisted of top level managers and had the
44 jrw 1 function of directing t'a* F"ort and providing early resolution 2 of policy issues and rsi:coumar' tag approaches to be used. The 3 Steering Committee includes Dr. Bill Morris of Research; Mr.
]
4 Congol of NRRt Richard Cunningham of NMSS Donald Nussbommer 4
5 from the office of Governmental and Public Affairst Joanna 4
6 Becker from the office of General Coun,el.
7 Reporting to the Steering Committee was a working I
8 group made up of senior technical staff members. This working i
? 9 gresup was charg64 with analyzing and summarizing the public l 10 comments, preparing the regulatory text and recommending the i 11 technical approaches for consideration by the Steering l'2 Committee.
) 13 The working group was chaired by Hal Peterson of j 14 Research on my left, who was the Part 20 Project Manager.
I 15 other members of the working group were Donald Cool of NMSSr I
16 John Buchannon of NRR and Walt Cool, formerly with Research.
17 The contribution of these individuals greatly i
is facilitated the analysis, modification and resolution of j 19 difficult technical and policy issues and is the primary reason J 20 why this difficult and o splex task was completed essentially 1
l 21 in about a year and a half after approval.
l 22 I want to state my appreciation for the effort of l I also want to acknowledge substantial j 23 these individuals.
1 24 input and review from the Regional offices and by a number of
(!
25 state officials that commented on the evolving rule.
{
1 i
. - , , - . . , . , . - _ - _ ~ _ - _ - , - _ . . ~m .
45 7 . 1 I suggest now that Dr. Morris present the Part 20 !
2 revision.
i 3 CHAIRMAN ZECH: Thank you very much. Dr. Morris, you 4 can proceed. i 5 MR. MORRIS ' Thank you.
6 On page one of the handout is a list of the topics [
7 that will be covered in the presentation today, in addition, we l 8 will try to respond to the remarks of the earlier presentations l i
9 as best we can.
10 (SLIDE.)
11 MR. MORRIS: On page two, we indicate some of the key i
12 milestones in the development of the recommendations in ,
13 radiation protection that have occurred over the years. As you !
] 14 have heard in the previous remarks by Mr. Beckjord, ICRP 15 Publication 26 included recommendations for a fundamental new j 16 system for limits on doses from radiation exposure and also 1 -
17 recommended specific dose limits for workers and members of the j 18 public.
19 CHAIRMAN ZECH: Let me ask the Reporter if he is 20 getting this.
i 21 THE REPORTER: Yes, sir.
22 CHAIRMAN ZECH: Thank you very much. You may !
l i
23 proceed.
24 VOICE: Mr. Chairman, we can't hear. ;
25 CHAIRMAN ZECH: Would you speak a little louder?
r I
. o .
46 f 6
7, 1 MR. MORRIS There were other ICRP publications such 2 as Publication No. 30 in 1979 and No. 48 in 1986 which provided 3 new scientific models and data governing the distribution and 4 retention of radionuclides in the body and for calculations of 5 doses to specific organn.
6 I might point out NCRP Publication No. 91, issued in 7 1987, also had essentially the same recommendations as included 8 in the presidential guidance issued in 1987.
9 We should mention that the Interagency Committee that 10 was formed by EPA to develop the revised presidential guidance 11 was chaired by the Environmental Protection Agency and included 12 representatives of NRC, the Occupational Safety and Health 13 Administration, the Mine Safety and Health Administration, the 14 Departments of Defense, Energy, Commerce, Transportation, 15 Health and Human Services, and the National Aeronautics and 16 Space Administration, the Conference of Radiation Control 17 Program Directors, the National Academy of Sciences, and the 18 NCRP advised that committee.
19 I am going to page three of the handout.
20 (SLIDE.)
23 MR. MORRIS: Here are some of the key actions by the 22 NRC staff that Mr. Beckjord summarized earlier. I would point 23 out that in parallel with the development of the international 24 recommendations on radiation protection, the staff was 25 cognizant of these actions and when the EPA Committee was
47 1 formed, the staff had a representation on that Committee and 2 because of that, these staff actione and hRC actions were i
3 essentially consistent pretty much throughout with the evolving a
4 development of the presidential guidance.
)
5 (SLIDE. )
4 NR. NORRIst I am going to page four of the handout.
7 Here we indicate the objectives that the staff has had in 8 revising Part 201 first and foremost was the intent to conform
]
j 9 to the new federal guidance. However, there are other goals we I
l 10 have had. We have had 30 years of experience in implementing
)
i 11 the current Part 20 and we wanted to take advantage of that i
l 12 experience in revising the rule.
i l 13 ICRP Publication No. 26 had proposed explicit dose I
14 limits for the public, and we wanted to incorporate those into 15 the rule. Also, it was eur intent to update the scientific l
f 16 basis for intake and concentration limits that had been put 17 forward in ICRP Publication Nos. 26, 30 and 48.
1
! 18 COMMISSIONER CARRt In that slide, it looks as if the i
1
- 19 federal guidance and ICRP No. 26 are the same thing; is that l
) 20 right?
}
l 21 MR. MORRIS: Not precisely. The main thing there is j
] 22 that ICRP No. 26 begins with the dose limitation system. That l
23 is pretty much incorporated in the federal guidance. The 34 federal guidance does differ in some minor ways. For instance, 25 a different dose to the embryo fetus was proposed in the
f 48 :
f .
1 federal guidance than what ICRP No. 26 had indicated.
2 (SLIDE.)
3 MR. MORRIS: On page five, it just summarines some of 4 the new requirements that are involved here now. We would nov 5 place a limit on the sum of the external and internal doses 6 rather than separate limir.ations on each of these. The dose 7 limits of three rem per quarter would be replaced by a limit of a five rem per year. There would be a deletion of a cumulative 9 dose limit a: cording to the formula, five rems times the age of l
10 the individual minus the age 18.
, 11 CHAIkMAN ZECH: Why are you doing that?
i 12 !!R. 40RRIS: This was one of the recommendations in ;
13 ICRP No. 26 and in the federal guidance. '
i 14 CHAIRMAN ZECH: Can you tell me the reason behind it? l 15 NR. MORRISt If you look at that formula, essentially 16 it comes out to reflect an average dose through the years of i
i 17 five ren, five times the age of the individual minus 18, the 18 age when he could have begun working. 'the use of the new five i i
19 rem dose limit now has that same effect on the average. It 20 would have been a redundant concept.
21 The idea of the cumulative dose limit would have 22 allowed something that you could think of as a dose bank, if !
23 someone had doses well below five rems per year over a number l 24 of years, this could have been thought of the same way as a w ;
25 dose bank, to allow him to acnieve greater doses in later l
49
,s 1 years. I think the fundamental ' dea was to have an av.2 raging 2 effsct through the provision of a specific limit per year of 3 five rem.
4 CHAIRMAN ZECH: All right. Thank you, 5 COMMISSIONER CARR: Why didn't you take it as N minus 6 18?
7 MR. MORRIS: The current value is --
8 COMMISSIONER CARR: Five times N minus 18. You are i 9 taking it as age right now? What do we have now?
10 MR. MORRIS: We have no cumulative dose limit in the 11 new recommendation.
12 COMMISSIONER CARR: Nobody is keeping track of f
13 cumulative dose?
14 MR. MORRIS: We will be getting reports on cumulative 15 dose but we are not placing a limitation on that other than for 16 the purpose of those workers who might have to receive what is 17 called planned special exposures and in those cases, there 18 would be a total lifetime dose from planned special exposures.
19 CHAIRMAN ZECH: Let's proceed.
I 20 COMMISSIONER CAT R: I'm not sure why you deleted it, i
21 the dose bank concept didn't get through to me.
l 22 CHAIRMAN ZECH: Let's try again, Dr. Morris.
23 MR. MORRIS: Let me go back to the point I made l
l, 24 earlier.
25 CHAIRMAN ZECH: Please do. ,
- m. -
50 i gy 1 MR. MORRIS: With the five rem limit now in place, !
2 thct has the same effect as the previous cumulative dose limit 3 of five times the age minus the age 18. That would ? ave had an 4 effect of average, five rem per year dose limit.
5 COMMISSIONER CARR: Except for the first 18 years.
i 6 MR. MORRIS: Use of 18 years is just to take into 7 account the time when most workers begin work.
8 COMMISSIONER CARR: It is not really a five rem 9 average.
10 MR. MORRIS: It is a simplification of that, i
11 COMMISSIONER CARR: Five rem averaga aver the working 12 years, perhaps. Is that correct?
13 MR. MORRIS: Yss.
14 CHAIRMAN ZECH: The answer is yes?
15 MR. STELLO: Yes.
16 CHAIRMAN ZECH: Thank you. You may proceed.
17 (SLIDE.)
18 MR. MORRIS: Continuing on to page six of the 19 handout, there will now be a change from a series of ur.its and i
20 specific organ doses to a limit on the sum cf organ doses 21 weighted by specific separate organ risk t,etsrs.
22 The three provisionc on the previous page and this T3 provision substitute the recommendations that were in ICRP No.
i 14 26 and the new federal guidance.
25 Further than that, ICRP No. 26 proposet an explicit
d O e 51 1 limit on the dose ?o members of the public. The current 1
2 implicit limit in Part 20 is 500 millirem a year. We would be ;
1 3 adopting this new limit in accordance with ICRP No. 26. l 4 Finally, the other provision is the limit on dose to 5 the embryo fetus for pregnant workers. This dose limit is one- l 6 half a rem and would be imposed on the sum of contributions I 7 resulting from exposures of the pregnant woman to both external 8 radiation and from her intake of radionuclides. This was 9 included in the federal guidance, but as I said earlier, a 10 differont dose level had been proposed in ICRP No. 26.
11 MR. STELLO: Before we turn the slide, if I could 12 return to this question of the N minus 18. The limits in the 13 present Part 20 are three rem per quarter, 12 per year. We're 14 changing it now to five rem per year. The formula was to 15 accommodate the fact that you could be getting up to 12 rem per 16 year, which we won't allow anymore, you're going up to five, so 17 you don't need it.
18 COMMISSIONER CARR: Except that's calendar year 19 accounting. I can still get 9.99 in two months.
20 MR. MORRIS: That's correct.
21 MR. STELLO: Yes.
22 COMMISSIONER CARR: So it depends on how you look at 23 it.
24 MR. STELLO: It's still five a year.
25 COMMISSIONER CARR: But it depends on when you start
+
52-f s, 1 the calendar year.
2 MR. STELLO:- Start it any way you want, per year five 3 rem.
4 COMMISSIONER CARR: All right. But I go across the 5 end of the year.
6 MR. STELLO: Okay. In my --
7 COMMISSIONER CARR: And I go to 9.99, right?
8 MR. STELLO: N minus 18 was the same thing. It was 9 calendar year.
10 COMMISSIONER CARR: Yes, but you had an accumulated 11 collection there. Well, it won't make any difference --
12 MR. STELLO: It won't, because it's still --
13 COMMISSIONER CARR: But I'm not sure it made any 14 difference to change it either.
15 MR. STELLO: Oh, yes, because it used to be 12.
16 COMMISSIONER CARR: It used to be three per quarter.
17 MR. STELLO: Twelve per year.
18 CHAIRMAN ZECH: It's five per year.
19 MR. STELLO: Now it's five per year.
20 MR. CUNNINGHAM: One and a quarter per quarter.
21 CHAIRMAN ZECH: It is now.
22 MR. STELLO: Yes.
23 CHAIRMAN ZECH: That's my understanding.
24 COMMISSIONER CARR: It's one and a quarter per l.-s 25 quarter now.
i
, - - . _ _ _ , . . . - - - - . _ . _ - _ _ - _ _ . _ - -m, _ _ --
53
, , 1 MR. CUNNINGHAM: No.
2 COMMISSIONER CARR: No. It's five per year now.
3 MR. CUNNINGHAM: It's five.
4 CHAIRMAN ZECH: A total of five per year, three per 5 quarter, but a limit of five per year. Isn't that correct?
6 MR. STELLO: Yes. Five per year.
7 CHAIRMAN ZECH: Right, five.
8 COMMISSIONER CURTISS: I hesitate to jump in here, 9 but what's the effect of focusing on the exposures over 10 lifetime, what's the effect of the reduction of 12 to 5 11 discounted for the fact that you're r.ot counting the first 18 12 years? Does the lifetime risk go up or down when you add those 13 two together?
14 MR. CUNNINGHAH: It should stay the same.
15 COMMISSIONER CURTISS: From the standpoint of 16 lifetime exposure, you eliminated accounting of the first 18 17 years. Commissioner Roberts alluded to the reduction of 12 to 18 five yields the same result from a health and safety 19 standpoint.
20 MR. CUNNINGHAM: I think in actuality, if you 21 received a larger dose at the beginning of your working career 22 where certain types of cancer rhow up over a 20 year period, 23 solid tumors take about 20 years, leukemia is about 10 years to 24 show up. If you got that dose at the end of your working 25 career and your life expectation was not 20 additional years,
~ _- _ _ _ .
54
,r - 4 1 there may be some difference in the overall risk.
2 CHAIRMAN ZECH: All right, let's proceed.
3 MR. MORRIS: So we would now be moving to page seven 4 of the handout.
5 (SLIDE. )
6 MR. MORRIS: Licensees are currently required to 7 report annual radiation doses to workers upon request of the 8- worker. In conjunction with the revision of Part 20, Part 19 9 would be amended to require such reports even if the worker i
10 does not make the request. This was a recommendation in the 11 federal guidance.
12 Let me remark on the EPA comments. At this time, in 13 the current Part 20, we only expect to receive annual reports 14 from the seven types of licensees whose workers have the 1B highest range of do:Tes. We would receive from those licensees 16 an accumulative total or average dose for that type of facility 17 and would only receive individual reports on workers, for those 18 who terminated employment in those facilities at this time.
19 In our deliberations on what to do about this in the 20 revised rule, we decided that we could be satisfied if we 21 continued with that same general concept that now requires 22 separate dose reports for the workets rather than the 23 accumulative for that type of licensee.
24 Also, I note that on the basis of experience we've 25 had with disposal of radioactive waste into sanitary sewers,
55 c s 1 there would be a reduction in the liuits to the concentrations 2 of materials that could be reduced in the sewers. It would be 3 essentially a factor of ten below the current Part 20 with 4 regard to what can now be released. Furthermore, because of 5 experience from release of americium flakes specifically from 6 smoke detector manufacturing facilities, we no longer allow all 7 readily disbursable materials to be released, only those which 8 are biological along with soluble material.
9 This requirement was based on the concept, on 10 recognition that there are potentially multiple users of the 11 sewers who might release radioactivity into them, so we wanted 12 to reduce those limits.
13 (SLIDE.)
14 MR. MORRIS: Moving to page eight, just note that as 15 the staff has proceeded with preparation of the final version 16 of the Part 20 revision, one of the goals we set was to 17 minimize the impacts to the extent we could while still 18 implementing the basic principles of the federal guidance and 19 the scientific recommendations of the ICRP and NCRP.
20 A number of simplifications of the proposed rule were 21 achieved and we believe we have reached the goal that we set 22 out for ourselves to the best we can. However, when such 23 fundamental changes in the principles of radiation protection 24 are involved, there is some impacts that are unavoidable and 25 the revised Part 20 is more complex in that internal and L
56 g i external doses must be combined and there are new concepts and 2 terms which will require that licensees revise their procedures 3 and enhance the training of those who must implement the new 4 procedures.
5 So this ir ,ntributed to the cost of the rule.and we 6 estimated those costs in the regulatory analysis and I think we 7 have made conservative estimates of those costs. When all is 8 said and done, there may be possibilities to reduce those costs 9 below what our estimates were. Now, what you have heard about 10 earlier today is the possibility that the requirement that 11 long-lived radionuclides would have lower allowable 12 concentrations to be significant for fuel fabrication 13 facilities. Let me spend a few minutes talking about this 14 issue and going back to the comments that were made by the 15 industry earlier today.
16 (SLIDE.]
17 MR. MORRIS: Moving first to page nine of the la handout, I will comment again that the ACRS also had the view 19 that the annual dose concept should be allowed and we earlier 20 had received letters from NUMARC and from the fuel fabrication
- 21 companies which we have been analyzing. Industry comments here 22 emphasiza the contrast between two approaches for limiting the 23 rink from long-lived radionuclides. The committed dose control 24 versus annual dose control. I'll come back to these concepts 25 in just a minute, but first I think it's important to point out
- O 57 y 1 the basis for the problem that is facing the decision in the 2 Commission.
3 (SLIDE.)
4 MR. MORRIS: Moving on to page 10, note that the 5 issue has as its fundamental basis new scientific information 6 indicating an increase in risks from inhalation of insoluble 7 uranium and thorium. Because of this, one issue is that the 8 concentration limits for uranium would have to be reduced and 9 approximately by a factor of the order of five, because of that .
10 new scientific information. The point here is the new 11 scientific data that has really pushed us in this direction and 12 not the idea that we have started doing dose limitation in a 13 new way. We've always used the committed dose concept for 30 14 years to set these limir.s.
15 (SLIDE.)
16 MR. MORRIS: On page 11 of the handout, I point out 17 that the new models and data that we're talking about really 18 are about the retention of radionuclides in the body and the 19 new models for calculating organ doses. These were proposed in 20 the publications, ICRP Publications 26, 30 and 48.
21 (SLIDE.)
22 MR. MORRIS: And on page 12, as I mentioned earlier, 23 for 30 years we have been using the concept of committed dose 24 to control the risks due to the inhalation of long-lived
-w.
25 radionuclides. We believe that this is consistent with the new
58 1 federal guidance and the close reading of that guidance to u:.
2 says that you should use a committed dose concept in limiting 3 doses to the workers, but that you may use the annual dose 4 concapt in the cases where there might be an overexposure. Mr.
5 Richardson, in his comments earlier today, pointed out this 6 distinction in the federal guidance on how to use these two 7 concepts and that has been the basis for our position.
8 (SLIDE.)
9 MR. MORRIS: Moving on to page 13, defining again the 10 concept of committed dose, which essentially means that doses 11 from future decay of long-lived radionuclides retained in the 12 body are counted as though they occur in the year of 13 inhalation. So if you take radionuclide,s into the body, those 14 radionuclides will redistribute themselves according to the 15 physiology of the body and the chemical characteristics of the 16 radionuclides. They will be decaying throughout the years 17 after you had that intake.
18 What the committed dose concept does is it just takes 19 all those doses that would occur in future years and assigns 20 them to the year of the intake.
l 21 COMMISSIONER CARR How do you decide what was put ,
l l 22 into the body?
23 MR. MORRIS: Well, the rule requires that there be 24 monitoring of air and allow -- well, let me make it clearer.
25 The rule requires that a combination of methods be used, I
59
<- 1 including air sampling, body counting such as lung counting, 2 bioassay measurement of excreta from the body bra performed when 3 someone is going to be exposed to concentrations above a 4 certain level. So you'll be monitoring these doses through the 5 time that the worker would be exposed to radiation.
6 MR. STELLO: Well, Billy, I think ycu said that the 7 rule requires all of those.
8 MR. MORRIS: No. It requires a combination of those 9 -- some combination of those practices be followed. The 10 general requirement is one of monitoring and specific ways to 11 do the monitoring are allowed. This is --
12 MR. STELLO: Including lung counting.
13 COMMISSIONER CARR: Only if the guy is exposed to 14 atmosphere above some limit.
15 MR. MORRIS: I think you have to exceed a certain 16 threshold before you have to institute these measures.
17 MR. PETERSON: The monitoring requirements for 18 internal dose is set if you expect the individual to be exposed 19 to conditions that will result in a dose in excess of ten 20 percent of the limit or half a rem essentially cif6ctivo dose.
21 COMMISSIONER CARR: It seems rear,onable to control 22 the atmosphere, then you wculdn't have to do any measuring on 23 the guy.
24 MR. MORRIS: That's correct.
25 MR. PETERSON: That's one option.
60
- 1 MR. STELLO: That's one of the options, but you can 2 also use lung counting, you can actually measure it.
3 COMMISSIONER CARR: But you're saying if the 4 atmosphere control is satisfactory, then you don't have to 5 worry about measuring.anything or computing anything.
6 MR. MORRIS: That's correct.
7 MR. STELLO: That's correct, but it's an option. You 8 can still use -- I think the impression was left at perhaps you 9 could not use lung counting. You can. That's permitted.
10 There's a way to demonstrate compliance to the rule. The issue 11 becomes what you include when you do the lung count.
12 CRAIRMAN ZECH: All right, let's proceed.
13 (SLIDE.)
14 MR. MORRIS: Moving on to page 14, the annual dose i
15 control approach would assess internal doses actually occurring 16 during the year, each year, both from intakes in that year and 17 intakes in previous years. The industry proposal, as you have 18 heard, is to use that concept in lieu of the current proposal 19 that the staff proposes, l
20 COMMIJSIONER CARR: And that's no matter how they're 21 measured.
22 MR. MORRIS: As I interpret the industry proposal, 23 yes. They would alAow lung counting and they would allow air 24 sampling and --
25 COMMISSIONER CARR: Well, that's what this says, l
J 0 61
,, 1 right? Any way you measure it, you just --
2 MR. MORRIS: The whole issue is whether you take into 3 account the doses year by year or wnether you take them into 4 account in the year of the intake. That's the real debate.
5 The technology for making the measurements and the assessments 6 of what the doses are, in our rule, we would allow all of those 7 technologies that I believe the industry would like to have 8 available to them.
9 As mentioned, this concept was considered in the 10 proposed rule, but it was discarded. We felt that if we were 11 going to be consistent with the federal guidance and for 12 reasons that I'm going to explain now that we should not 13 continue to -- we should not retain this particular concept in 14 the final rule. And the reasons that we believe this is the 15 case are the following.
16 (SLIDE.]
17 MR. MORRIS: Looking at page 15, we believe that if 18 worker dose levels are controlled solely on the basis of annual 19 dose, the risk from radioactive decay of radionuclides 20 remaining in the body after the worker leaves employment will 21 have been ignored in establishing control.
22 COMMISSIONER CARR: Do you have a copy of that 23 presidential guidance there? Everywhere I read in there, those 24 qu;i..os that I read from the various statements, the quotes 25 always stop before the guidance statement.
62 1 MR. MORRIS: Yes.
2 COMMISSIONER CARR: For General Electric, for 3 instance, it says "Presidential guidance says the limiting 4 values for control of the workplace should be based on L
5 committed dose. The limiting values for assessed dose to 6 individual workers' should be based on the annual dose." Is 7 that an accurate quote of the presidential guidance?
8 MR. STELLO: No.
9 MR. MORRIS: We have --
10 MR. STELLO: Did you give it to him? Is that it?
11 MR. MORRIS: Yes.
12 COMMISSIONER CARR: Go ahend. I'll read while you I
13 talk. !
14 MR. MORRIS: I can specify the places for the quotes 15 that I think are of interest here. Does anybody have a copy of 16 --
i 17 MR. CONGEL: Yes.
18 MR. MORRIS: Could I have a copy of that, please?
19 MR. CONGEL: Yes.
20 MR. PETERSON: It's the same as you have.
I 21 MR. MORRIS: Yeah, I know, but I just can't find it.
22 COMMISSIONER CARR 2831 is what you gave me.
23 MR. CONGEL: Yes, 2831.
24 MR. ?ETERSON: 2831, No. 4.
25 MR. STELLO: 2831, No. 4.
- A
- O 63 7 , 1 MR. MORRIS: Yes. What it says there is the primary 2 means for controlling internal exposure to radionuclides, 3 agencies should require that radioactive materials be contained 4 to the extent reasonably achievable so as to minimize intaka.
5 In controlling internal exposure, consideration should also be 6 given to concomitance external exposures. The control of 7 necessary exposure of adult werkers to radioactive materials in 8 the workplace should be designed, operated, and monitored with 9 sufficient frequency to assure that, as a result of intake of 10 radionuclides, the following limiting values for control of the i
11 workplace are satisfied.
12 The anticipated magnitude of the committed effective 13 dose equivalent from such intake, plus any annual effective 14 dose equivalent from external exposure, will not exceed five 15 rem. I think that last phrase is essentially the key phrase, 16 that says that it is committed dose that you should be using.
17 They go on in this section to discuss that they believe it 18 should be the 50 year committed dose.
19 If you go on to the next page, on 2832, at the 20 beginning of the first full paragraph, you'll see that it says 21 in circumstances where assessment of actual intake for an 22 individual worker shows the above conditions for control of 23 intake have not been met, agencies should require that i
24 appropriate corrective action be taken to assure control has 25 been re-established and that future exposure of the worker is
e t 64 1 appropriately managed.
2 Provisions should be made to assist annual dose 3 equivalence due to radionuclides retained in the body from such 4 intake for as long as they are significant for ensuring 5 conformance with the limiting values specified in 6 recommendation three. So we interpret that the previous quote 7 that I made says that in order to limit doses, you use ,
8 committed dose, but if in circumstances these dose levels, 9 these limits should be exceeded, we may do further monitoring 10 using the annual dose concept in order to regain control of the 11 worker's dose condition.
12 That's the reason that we have chosen to believe that 13 we should not use the annual dose concept.
14 COMMISSIONER CURTISS: Did I misunderstand in hearing 15 you say that either of the two approaches would be consistent 16 with the guidance?
17 MR. MORRIS: I can't speak for EPA, but I believe 18 they meant to say that in these two cases. These are the two 19 ways that they interpret.
20 COMMISSIONER CURTISS: Let me ask it differently.
21 CHAIRMAN ZECH: Why don't we ask the EPA, will you 22 step to the microphone and clarify this situation for us, 23 please? Identify yourself again for the Reporter.
24 MR. RICHARDSON: I am Allan Richardson. I chair the 25 group that developed the guidance. This is not something which
65
, 1 is crystal clear. There is intentionally some flexibility in 2 the recommendation. What the recommendation says is that 3 internal exposure should be controlled on the basis of 4 committed dose and if that control fails, then the annual dose 5 limitation must still be met.
6 All of the implications that Mr. Morris has raised in 7 his slides about the use of annual dose solely as the basis for 8 controlling committed dose are correct. The guidance, because 9 there was great controversy on this matter, did not exclude the 10 use of annual dose recording for workers, but it's quite
- 11 unequivocal in the need to control the workplace on the basis 12 of the committed dose. Now, you can control a workplace by 13 monitoring the air or by looking at the worker's body, and 14 that's where the controversy really lies.
15 CHAIRMAN ZECH: Thank you very much. All right, you 16 may proceed. Proceed, please, Mr. Morris.
17 MR. MORRIS: Thank you.
18 (SLIDE.)
19 MR. MORRIS: A further point, on page 16, that wo 20 would make is that if the annual dose system is used, if 21 workers change jobs within the nuclear industry, their future 22 employees would have to take over the task and absorb the cost
! 23 of accounting for doses from previous intakes. Taking for an 24 example, a worker in a fuel fsbrication facility who had 25 intakes over a number of years and, therefore, had l
- O 66
, 1 radionuclides within his body decaying giving him doses for a 2 good part of the rest of his life perhaps, suppose he 3 transferred and went to work for a radiographer who has no need 4 for a system of monitoring and accounting for internal doses.
5 In that situation, the burden of this previous intake from the 6 fuel fabrication facility would now have been transferred to 7 essentially not only the worker, but to the new employer.
8 That is a concern of ours and we believe that that 9 would be a very difficult system to implement. It would 10 require a fundamental change to the way we regulate the 11 industry.
12 COMMISSIONER CARR: Do you mean because the 13 radiographer wouldn't be able to compute what his internal dose 14 was when he was getting ready to add his external dose?
15 MR. MORRIS: Well, the annual dose concept, you 16 recall, speaks to the idea that there would be annual 17 monitoring for internal -- for the doses from these internal 18 doses, and the radiographer would normally not have much 19 occasion to even deal with internal doses at all. Most of the 20 dose exposures there, I believe, are external. So that is sort 21 of an example --
22 COMMISSIONER CARR: I guess I don't see why that's a 23 problem.
24 COMMISSIONER ROBERTS: I don't understand that, 25 either.
= .
67
.- 1 MR. CUNNINGHAM: Let me try to expand on this. If 2 you go to an annual accounting for a dose, this would permit an 3 employer to allow an employee to take into his body a 4 sufficient amount of radioactive materials that he will get 5 five ran in the first year. Say that's the annual limit. The 6 following year, he may get 4.5 rem from that same intake in the 7 following year, on-out years he will be receiving some dose.
l 8 Now, what the industry is proposing to do is to say that if an l 9 employee gets five rem in the first year from an intake, they 10 will measure him the second year, and if that annual dose from l
i 11 that same radioactive material is calculated to be 4.5 rem, l
12 they will control him in the workplace so that he doesn't get 13 more than half a rem so that he is within the five rem limit.
14 Now, what this means is that an employer would be 15 able to mortgage the future employability of an employee. It 16 implies that they are going to control him throughout a large 17 part of his working career.
l 18 COMMISSIONER CARR: Control him always though at five
! 19 rem a year.
20 MR. CUNNINGHAM: Yeah. And assume that he will be 21 employed there and the employee wants to stay there, not work 22 in some other field. Now, let's take what Bill Morris did and 23 say, okay, this worker has this five rem initial intake fro 1 a 24 large quantity, larger than -- much larger than would be 25 involved under the committed dose concept. He will be
68 1 receiving four ren, three ren, what have you as time goes on.
2 .He leaves that employer. He goes to a radiography company 3 which only deals with external exposure.
4 The implication there is that the radiography company 5 will have to have whole body counters or what have you to 6 assess what his dose is from that internal dose that year and 7 then control the employee so that when he conducts radiography 8 he doesn't get more than half a rem or what have you to exceed 9 that five a year limit.
10 Now, this is a substantial policy issue, whether or 11 not you allow a worker to have his future dose mortgaged so 12 that it affects his employability in future years. It also 13 presents some very significant regulatory control problems.
14 You go into a plant, look at occupational exposures, you have a 15 variety -- any single employee may have a variety of doses --
16 or any population of employees may have a variety of different 17 doses to which they can be received if you go to this annual 18 dose commitment.
19 If you look at design of equipment, you look at l 20 design of equipment so that you say, okay, the exposure to l
l 21 airborne concentrations aren't going to exceed a certain level 22 and from that we know employees are not likely to receive more 23 than five rem committed dose. But if we tried to evaluate air 24 concentrations for each employee, depending on the given year 25 and previous history, is subject to a different concentration.
\
69 l
1 That becomes an extremely difficult type of thing to regulate.
2 So we have regulatory problems, we have policy 3 problems with respect to what we are allowing employees to 4 receive under this annual dose, and how we are mortgaging their 5 future and future employability in the radiation industry.
6 That's the substance of the argument. Now, what the industry 7 is faced with because of new science, you have about a factor 8 of five reduction in the amount that can be taken in for a 9 given dose. That's with new science.
10 So the industry is faced with two kinds of problems, 11 controlling concentrations down to this lower level, and 12 secondly, dealing with the problem of assessing committed dose, 13 because you're dealing with a much smaller quantity and the 14 technology for assessing, either through lung counting, 15 bioassay, does become more difficult. That is correct. But 16 there are ways to do it, we believe.
17 COMMISSIONER CARRt When he leaves his employer after 18 whatever years it is, why doesn't the employer give him a count 19 and say, okay, you're going to decay off at this rate and so 20 the next three or four years, this is all you're allowed to 21 have, and give him -- that seems a reasonable -- I believe that 22 you could give him a piece of paper that says, okay, next year 23 you can only have four, the next year three or, I mean, you can 24 have five or you can only have one next year, two the next 25 year, three the next year, and he finally works his way out of
70 1 this, I assume, if he doesn't inhale any more.
2 MR. CUNNINGHAM: Well, that's one way to look at it.
3 Yes, that's true, that's correct if the employee is willing to 4 accept that. But the question is --
5 COMMISSIONER CARR: Well, he's got to tell him 6 annually what his exposure is anyway, so --
7 MR. CUNNINGHAM: But the issue is should one employer 8 commit a person to restricting dose in the future which can 9 affect his future employability.
10 COMMISSIONER CARR: That's an employee's voluntary 11 decision when he hires out, I would assume.
12 MR. CUNNINGHAM: Right. I think that's the kind of 13 policy decision the Commission has --
l 14 COMMISSIONER CARR: That's why we're here, I guess.
15 Okay, that answers my question anyway.
16 CHAIRMAN ZECH: Thank you. All right, let's proceed.
17 (SLIDE.)
18 MR. MORRIS: Going on to page 17, it's just the same i 19 problem we've been discussing, but the issue is -- we've keyed 20 on it here, is one of worker employability after he leaves a 21 particular job. In summary, the staff has proposed that the 22 committed dose approach should be continued to assure the 23 control of dose as based on the total risk from long-lived 24 radionuclides. Those future doses and risks are not 25 discounted, that the licensee responsible for exposures deals
71 l3 1 with then rather than passing responsibility on to future 2 employers, that the employee's future employability is not 3 jeopardized.
4 I have prepared to go into some more detail on the 5 remarks made earlier by the industry representatives. We've 6 covered a lot of that and I think selectively I would just go 7 over a few of the points.
8 CHAIRMAN ZECMt Go right ahead.
9 MR. MORRIS: First off, Mr. Stansbury apparently 10 believes that licensees would be limited to air sampling in 11 determining committed dose. This is not the case, as we said 12 earlier. Section 20.204 of Part 20 allows bicassay, including 13 lung counting and measurements of radionuclides excreted from 14 the body in addition to air sampling. Combinations of these 15 are also allowed.
l 16 There was the proposal that the NCRP cdvises against l
l 17 use of committed dose. Remembering that our objective was l
18 conformance with the President's federal guidance and we've 19 discussed what that says about this issue, we did prepare --
20 COMMISSIONER CARR: We may not have agreed on it, but 21 we've discussed it.
22 MR. MORRIS: Yes.. That's what I said. NUMARC also 23 made a similar comment in its letter earlier, a few weeks ago 24 on this issue and we did respond to the specific NUMARC 25 concerns in Enclosure 9 of SECY 88-315. And there, wo quoted
72
,. -s 1 the NCRP 91, which points out twice that committed dose may be 2 used to eliminate -- to estimate lifetime risks from a given 3 intake, and that's our way of looking at this.
4 COMMISSIONER CARR: Well, on that one, I guess the 5 General Electric letter says, and this is in full quotes all 6 the way, "A committed effective dose equivalent system should 7 specifically not," underlined not, "be used as a measure of an 8 individual worker's exposure status." It says emphasis from 9 original and that quotes NCRP Page 38. L.. that an accurate 10 quote?
11 MR. STELLO: I believe it is fairly accurate.
12 COMMISSIONER CARR: Well, how can you say it agrees 13 with the NCRP then if that quote says you shouldn't use it?
14 MR. PETERSON: Because there is another quote.
15 COMMISSIONER CARRt You pick your quotes, he picks 16 his quotes.
17 MR. PETERSON: If you will note, the industry 18 comments do not generally refer t) 91, they referred to an 19 earlier report, 84. 91 does say that for the best control of 20 the dose to the individual for monitoring purposes after <
21 exposure, you should use the annual dose approach. But it also 22 says, earlier, that the committed effective dose equivalent is t
23 assumed to be a measure of the risk that will result from that 24 intake, that is of radionuclides, and it's assumed to be the 25 best measure of that.
73
, 1 COMMISSIONER CARR: But that doesn't counter what 2 they recommend.
3 ICR. PETERSON: No, it does not.
4 COMMISSIONER CARR: Okay.
5 CHAIRMAN ZECH: Let's proceed.
6 MR. MORRIS: Mr. Stansbury mentioned the committed
~
7 dose is abstract and could give false impressions because of 8 abstract modeling, but as I just mentioned, bioassay 9 measurements and radionuclide behavior in the individual can be 10 used in lieu of the generic models and I think this will avoid 11 this process of abstract modeling that Mr. Stansbury is 12 concerned about.
13 He also said that lung counting is employee oriented 14 and it's preferred by GE, but lung counting is allowed by the 15 revised rule, so there would be no prohibition on doing that.
16 He mentioned that the committed dose will mask the relation 17 between dose limits and risk. On the contrary, I believe that 18 the committed dose concept establishes limits on intake based l 19 on the total risk an individual incurs and does not involvo 20 some truncation in that risk.
21 Furthermore -- but on the other hand, the annual doso 22 concept would ignore future doses when workers leave their 23 current employment. He mentioned that it is misleading that 24 the NPC's for uranium were a factor of five too large. The nov 25 scientific information in ICMP 26, 30, and 48 do ind!,cato --
74
]
1 does indicate that the concentration limits for uranium should 2 be reduced by a factor of approximately five. That seems to be 3 the outcome of the new science, I don't know how to avoid that.
4 And he mentioned that the annual dose concept is in 5 accord with the presidential federal guidance. We've discussed 6 that issue and I see no problem going back to that one. NRC 7 cost estimates are too low. This was also a subject of the 8 NUMARC comments earlier today. These cost estimates are 9 discussed in the regulatory analysis, Enclosure 7 to SECY 88-10 315. There is a figure of $75 million total cost that has been 11 estimated which would be the initial cost of developing 12 procedures and training and the annual cost.
13 We believe this is an upward bound. The rule allows 14 flexibility to use bioassay, including lung counting and air 15 sampling, so there is flexibility to allow the licensees to do 16 things using this flexibility that would reduce the burden. It 17 also allows adjustments to airborne concentrations and intake 18 limits based on site-specific physical or chemical 19 characteristics of airborne materials. That is the aerosol, 20 size distribution, or density. So there is more flexibility 21 that they would have there.
22 So we believe that there are ways the licensees may 23 be able to comply with this provision that would not cause the 24 large cost that were the upward bound levels that we put into 25 the regulatory analysis. These high costs would be the result
75 y 1 of having to install glow boxes or something like that. We are 2 thinking that there will be other ways to deal with this issue.
3 Mr. Stansbury mentioned that the committed dose is 4 not useful for epidemiology. I would like to point out that 5 the primary purpose of the NRC regulations is to set limits on 6 risks, not to provide basis for research. But you will recall 7 that the National Cancer Institute has requested NRC's 8 cooperation in establishing a worker dose registry, as 9 discussed in SECY 88-177 earlier this year. The cost for this 10 would be no greater than the current reporting cost if the 11 Commission decides to require licensees to report doses to 12 workers in c6nformance with the new federal guidance.
13 If the information on these reports is required, Part 14 19 would include, we believe, sufficient information to support j 15 epidemiology studies. We think of it, though, as a fallout of i 16 the new requirements rather than a principal basis for 27 promulgating it. I think that covers most of the issues that 18 Mr. Stansbury brought up and I think that in those comments and 19 other discussion, we have pretty much covered the remarks that 20 Mr. Colvin made on this issue. :
21 What I'd like to do now is to move on and go into 22 some of the ACRS comments and then we may come back to other 23 parts, other presentations.
24 (SLIDE.)
25 MR. MORRIS: Turning to Page 19 of the handout,
76
- 7. 1 please, where we indicate some of the specific ACRS comments 2 that were transmitted to the Commission in a letter dated June 3 7, 1988. The staff'S written response to ACRS comments was 4 included in the commission paper, so I will only briefly 5 summarize these at this time.
6 We've discussed the issue of annual dase centrol 7 versus committed dose, so A=t's go on to the second issue. The 8 ACRS recommended that an evaluation be conducted on the health 9 effects from discharge of excreta from patients undergoing 2 10 therapy or diagnosed as using radioactive materials. Such 11 discharges are exempt in the revised Part 20. It turns out 12 that a project to assist the potential health effects from ,
13 discharge to sewers has been underway for the past year, so we 14 will be able to report to the ACRS on this issue in the near 15 future.
I 16 Preliminary results indicate doses from these
! 17 discharges are small and wo Lelieve this exemption should be 18 retained because of the special benefits it allows to medical
- 19 patients which justified as small risks. The ACRS also
! 20 recommended that the revised rula provide exemptions from 21 security requirements to prevent access to radioactive 22 materials when the quantities are small enough to represent J
23 only minimal risks. The staff reply pointed out that there are 24 certain quantities and forms of materials for which exemptions
- x 25 are granted in Part 20, but noted that further exemptions would -
i
77
,- i be inconsistent with the longstanding policy that control Le 2 maintained over radioactive materials to prevent possible 3 contamination of the workplace or environment. !
4 That is we believe there should be no relaxation of 5 controls over such materials and possible exposure to the 6 p'?blic would have a compensating benefit. This is not a casc 7 where we're releasit:g consumer products or has a particular 8 benefit, it would just be a relaxation of security controls.
9 Turning to slide 20, please.
10 (SLIDE.)
11 MR. MORRIS: The ACRS rwcommended that those who 12' receive transportation packages containing radioactive l 13 materials should only have to monitor for external radiation if 14 the packages have an externel radiation warning label. The l l
15 staff reply points out that incidents which occurred in the I
16 past demonstrate that there is potential for leakage of ;
17 packages or failure of shielding which could result in serious i
18 radiological consequences.
19 To guard against such events, the final rule includes 20 requirements to monitor packages as soon as practical. The [
21 ACRS proposed changing the definition of natural background to ;
22 emphasize that exempted sources do not include sources of 23 natural origin which have been technologically enhanced. That ,
i 24 would a cases such as uranium or radium in phosphates and !
s 25 fertilizers. However, the regulation of these is not within
- i. ..
78 !
ys 1 the NRC's statutory aut,hority and the staff would conclude thet
- . 2 the exemptions should remain.
- l 3 The ACRS also proposed that the definition of whole l 4 body dose, in that definition, consideration be given et l 5 development of weighting factors for converting partial s l 6 external exposure to equivalent whole body doses. The 1
7 definition reu ins the same in the final rule, but use of such I
e weighting factors has now been allowed through redefinition of ,
9 the concept of weighting factors.
! l i
10 (SLIDE.) [
t 11 MR. MORRISt I think at this time, we have alreadv
(
<- 12 mentioned that we believe that the benefit of conforming with
[ [
13 the revised federal guidance on occupational protection and the i 1 !
j 14 consistency with the national and international radiation }
i ;
- 15 protection standards, this is on Page 21 of the handout. [
l 16 (SLIDE. ) [
- l l l 17 MR. MORRIS
- And further on Page 22, the need to l I j j 18 update the technical basis for intake and concentration limits i I
l 19 and to incorporate the many y3ars of experience in implementing j i
20 radiation protection under the current Part 20, to provide ;
j 21 explicit dose limits for the members of the public, are a :Jasis l
! f 22 for our recommendation that you approve this proposed final l [
i l
1 23 rule.
I l
f 24 As we mentioned, we are trying to look at ths various [
N. I I
l 25 comments made in the earlier presentations to see it we can F i !
t !
L __ . ~ _ , _ _ _ , _ _ _ _ _ , . . _ __ _ . _ _ . _
79
<- 1 somehow come back and address some of those and it might be 2 appropriate at this time to see if there are any questions and 3 then come back to these issues.
4 CMAIRMAN ZECH: Thank you very much. Questions from 5 my fellow Commissioners? Commissioner Roberts?
6 COMMISSIONER ROBERTS: I have a request, not a 7 comment. I would like to see in writing the ACRS position on 8 the deletion of Section 20.205. Secondly, in the SECY paper, 9 Page 7, I find this "logic" on why this is exempt from 50.109 10 is totally illogical. That's all I have.
11 CHAIRMAN ZECH: Thank you. Commissioner Carr?
12 COMMISSIONER CARR: Yes, i've got a couple of 13 questions, as one of my former Commissioners used to say, but 14 annual reporting of the individual doses to the worker, I guess 15 that's to the radiation worker. Who is supposed to do that? 1 16 MR. MORRIS: The licensee.
17 COMMISSIONER CARR: Okay. Am I a radiation worker? !
18 MR. MORRIS: I think if you visited a plant, that --
19 COMMISSIONER CARR: Who is supposed to report it to 20 me? Annually? 1 21 MR. STELLO: I don't believe the old rule required it !
22 annually. I think you get a report after your visit.
23 MR. MORRIS: It's a termination report in the current 24 previsions.
25 COMMISSIONER CARR: I'm still uneasy because when you
' O 80
- 1 get down to employse's employability after he leaves his past 2 job, when I was employed here, nobody asked me how much 3 radiation I had before I got here. I don't guess anybody 4 cares. How are we getting away from the individual employee's 5 rosponsibility to monitor his own radiation? You're going to i
6 let him go a year before the employer t..ls him?
7 MR. MORRIS: We believe this information being 8 supplied to the worker each year gives him a --
9 COMMISSIONER CARR: Well, don't they do that now?
10 MR. MORRIS: Gome dc and some don't. It's not a 11 requirement. I don't know the eract numbers that do or do not, 12 since we don't have any way of monitoring that. But I think --
13 I agree that it's an important part of the principal to have l
14 the employees cognizant of the doses that they might be 15 encountering and this annual report is essentially a report 16 card for how well that was done during the year and the 17 employee is a participant in that, I believe. He has 18 opportunities to avoid exposures that go beyond the kinds of 19 things you can do with procedures.
20 COMMISSIONER CARR: I guess my point is I think we 21 can take care of that employee's caployability after he leaves l 22 in a lot of ways, how much he can take the next year after he l l
23 terminates. The other one I think I'm worried about is I don't 14 know that our residents aren't getting more radiation than 25 they're allowed. The only guy that knows is them.
1 - - -- -_. _
8 0 81
, 1 MR. CONGEL: The resident is under the control and 2 turns his badge in to the licensee at the plant where he work.s 3 and gets his reports back.
4 COMMISSIONF.R CARR: So who knows how much he gets, 5 except him. A licensee is only required if he is overexposed, 6 but he doesn't know where else he might be going. Each 7 licensee reports to him, but he could go to five or six 8 different places and they still -- he'd be under unless he kept 9 track, right?
10 MR. CONGEL: Yes. If you're talking about our 11 individual inspectors who do -- l 12 COMMISSIONER CARR: That's what I'm talking about.
13 MR. CONGEL: Tho residents are usually, at one place, i 14 they're easier to keep track of.
15 COMMISSIONER CARR: Well, whoever travels around.
16 All I'm saying is I don't see us taking care of our own people, i
17 MR. CONGEL: No. The inspectors do have the recards L 18 of the ones who travel plant to plant kept at the regional f 19 headquarters where they are based.
20 COMMISSIONER CARR: Who monitors them?
i 21 MR. CONGEL: There are two things. First of all, the l
22 inspectors are provided with an exposure record.
23 COMMISSIONER CARR Sure. I am, too. ;
7 24 MR. CONGEL: In addition to that, I know that in each t 25 of the regions there is a group that is responsible for
82
,. 1 colleting the exposure records of the inspectors and their 2 responsibility for informing --
3 COMMISSIONER CARR Who does it for th' headquarters?
4 MR. CONGEL: The records are kept in our Office of 5 Research. .
6 COMMISSIONER CARR: I keep mine. Nobody gets mine 7 but me, I don't think. Anyway, let's look at that a little 8 bit. On those fuel cycle facilities --
9 MR. STELLO: I think you raised a goud point.
10 COMMISSIONER CARR: Yeah, it worries me.
11 MR. STELLO: This particular regulation, in terms of 12 the extent to which we've taken into account people that are in 13 the regulatory business, they have to get to a lot of plants.
14 They have to keep track of their own records.
15 COMMISSIONER CARR: Contractors, you know.
16 MR. STELLO: Well, the contractors, they're covered 17 by the regulation.
18 COMMISSIONER CARR: I mean our contractors that do --
19 MR. STELLO: Oh, yeah, people that work for us. We 20 ought to look at it. I think that it is an area that we ought 21 to take a look at an,$ make sure that people understand what 22 their responsibilities are.
23 COMMISSIONER CARR: On the fuel cycle facilities, are 24 you going to grandfather those people that have been working 25 there 38 years? I mean, if I figure it like I've been figuring
83
- - 1 it for them, are they going to be overexposed? It's such a 2 serious problem and we haven't been keeping track of it, right?
3 MR. MORRIS: Using the committed dose concept, their 4 doses will have been described each year as the intakes 5 occurred. I don't think that there would be a need to do any 6 grandfathering of those cases.
7 COMMISSIONER CARR: Well, what you're saying to me is 8 this current system is okay.
9 MR. MORRIS: Yes, that's what we -- yes. The current 10 system is the one we proposed to continue, it's just that the 11 new scientific data has caused some of those limits to go down. !
12 But otherwise, the system would remain as it has always been.
13 COMMISSIONER CARR: The only thing we're going to 14 change then is the air control in the workplace.
15 MR. MORRIS: Well, there may be other ways to do the 16 same thing. You could do that, but there are other options.
17 COMMISSIONER CARR: It looks like we're going to have 18 to. I mean, that's one of the effects of the rule, isn't it?
19 MR. MORRIS: No, no, no. It's just to control the 20 doses to the workers.
21 COMMISSIONER CARR: I thought we were going to lower 22 the limits on uranium by a factor of five. ,
23 MR. CUNNINGHAM: Well, that's the way it comes out. :
i 24 COMMISSIONER CARR Well, that's a fact, I guess.
s 25 MR. CUNNINGHAM: Yes, that's a fact. In practice, t
. o 84
- 1 the exposures, and thin is a general statement but it's fairly 2 accurate, the exposures to workers, the committed dose has been J running about ten to 15 percent of the limits. What the factor 4 of five is going to do in actuality is move that so worker 5 exposures under the present way they operate very close to the 6 limits. That means that you're going to have to do more close 7 monitoring because you don't have that cushion. That's the 8 first thing. You do closer monitoring.
9 You might have to adjust certain parts of the plan to 10 take care of air concentrations, but really it's a problem 4
11 first of closer monitoring of people because you're closer to 12 the limits, and make sure you don't go over.
13 COMMISSIONER CARR: Okay. And then on consistency 14 with national standards and all that, everybody has kind of 15 left the Health Physics Society recommendation out of this. Do l 16 you want to address thet? A Physics Society position paper 17 presumably approved the committed dose for control of workplace 18 and annual dose for worker dose. In 1985, a full membership 19 referendum supported that.
20 MR. PETERSON: I think the quote is correct. The 1
21 Health Physics Society took the same position as the NCRP.
22 Again, from a scientific point of view, as Dr. Stansbury 23 pointed out, when you look at the long term control of the 24 worker, there is little difference far out in what the worker 25 is going to get under either system. It's a question of
85 f- 1 whether you account for that tail after employment.
2 Now, he indicated if you do account for that tail 3 after employment, then the two systems would give you the same 4 total lifetime dose. The problem is their system doesn't 5 account for that tail and the committed dose does.
6 COMMISSIONER CARR I understand that.
7 MR. PETERSON: From a scientific point of view, the 8 annual dose is probably preferable. We're arguing against it 9 on a regulatory point.
10 COMMISSIONER CARR: I have one other question, I 11 quess for the general counsel. Your argument for no backfit 12 analysis kind of hung on we're complying with Presidential 13 guidance and, therefore, we shouldn't have to do a backfit 14 analysis. But from what I hear, the Presidential guidance kind 15 of allows it to go either way. Do you think we require backfit 16 analysis, particulary on this 20.205 portion of it or do you 17 have to study that some more?
18 MR. PARLER: Well, I can tell you what I think now.
19 I'd be pleased to stuoy it some more if necessary. The 20 starting point is that the backfit rule does apply to 21 Commission actions. It does apply to rulemaking. As some of 22 you may recall, there was a big debate about that some years 23 ago as to whether the backfit rule should apply to rulemaking.
24 The backfit rule requires a basic finding that a commission 25 action will require substantial additional protection to the
86 ,
s 1 public health and safety. And even if it does, the benefits 2 would outweigh the costs.
3 If you can't pass that obstacle over the backfit 4 rule, you have to fall within one of the exceptions, one of 5, which is to provide adequate protection to the public health 6 and safety. The language on Page 7 of this paper to which 7 reference has already been made as perhaps being illogical 8 speaks about suspending the backfit rule. That suggaets to me (
9 that the basic requirements of the backfit rule, that is that 10 the proposed change would require -- would result in 1 .
11 substantial additional protection cannot be met.
12 Furthermore, it seems to me that the staff has chosen 13 . ' to rely on the provision of adequate protection to the l
14 public health and safety exception. With that background, then 15 the Commission is left with this question. If it has a 16 regulatory policy decision that it believes should be made and 17 it will be compatible with its mission, whether it be because 18 of a statute or a Presidential document or the movement in the l 19 worldwide community over the last decade that has been alluded 20 to, whether the backfit rule precludes the commission from 21 making that regulatory policy d', cision.
22 The backfit rule, the way that it was written, did i
23 not provide for that contingency. What we have been trying to 24 do over the last couple of years is to apply a common sense 25 approach to questions such as this and at least indicate to the 2
l
. . j 87 fs 1 Commission that it is up to the Commission to make that 2 decision if it thinks that a particular propwaal is a right way 3 to move in.
4 Otherwise, the Commission would be stymied in making 5 important regulatory policy decisions by the backfit rule. It j 6 would either have to amend the backfit rule or, in this case, l
7 suspend it. Now, my own personal view is that the thing -- the 8 backfit rule isn't literally being suspended, that this is an I
9 interpretation of the backfit rule. As a matter of fact, the
]
1 10 paper covers many of the pros, the cons, the benefits, the i
11 costs, why the Commission is moving in the direction. What the ;
j 12 paper has done, accomplished is the basic objective of the j P i 13 backfit rule, that is having a disciplined managed approach, f i
~
14 True, there is no exception. True , the basic l
15 findings of the backfit rule apparently can't be satisfied 16 here. It's up to the Commission to decide what they want to l l
17 do. In my judgment, they would not be precluded from acting [
18 because of the lack of explicit provisions in the backfit rule l 19 for situations such as this and they wouldn't be precluded t
20 either if there were a specific statute that required a L l
21 Commission action. That contingency is not covered in the [
\
22 backfit rule.
23 COMMISSIONER CARR: Thanks.
24 COMMISSIONER ROBERTS: I have a question. ,
t s
25 CHAIRMAN ZECH: Yes, go ahead. [
i I
88 1 COMMISSIONER ROBERTS: Reading Page 7, the staff 2 recommends that the backfit rule 50.109 not be applied to the 3 Part 20 revision. The basis for this is that conformance to 4 the Federal guidanca on occupational radiation exposure issued 5 by the President should take precedence over compliance with 6 the backfit rule. Can't you imagine a scenario where there is 7 Federal guidance that makes no sense and is contrary to law?
8 MR. PARLER: Well, of course, I would hope the 9 Commission, in its informed judgment, including the advice from 10 myself or whoever may be in my position, would recommend to you 11 under such circumstances that you not exercise your discretion 12 and forget about the backfit rule.
13 What I was trying to advise the Commission on earlier 14 in my responses to comnissioner Carr is if you do have a 15 situation where it is sound regulatory policy to move in a 16 particular direction because of advice from the President or 17 from some other place which is authentic and is part of the 18 national policy, that perhaps the Commission would not want to 19 be precluded from acting by the literal language of the backfit 20 rule.
21 COMMISSIONER CARR: I understand.
22 CHAIRMAN ZECH: That's my understanding of the 23 backfit rule exactly and what it really means to me in the way 24 I look at it is that the backfit rule does not preclude this 25 Commission from doing what we think is right. Simplo as that.
o .
89 r- 1 I think that's a proper interpretation of it.
2 MR. PARLER: I would like to add --
3 COMMISSIONER ROBERTS: I don't disagree with that 4 general statement.
5 CHAIRMAN ZECH: You don't or you do?
6 COMMISSIONER ROBERTS: I do not disagree with that 7 general statement.
8 CHAIRMAN ZECH: Well, that's all it means. It does 9 mean that if we believe that we should make some decision and 10 we do think it's in the public interest, then this Commission 11 is not precluded from doing so and we should indeed make that l
, 12 decision, in my judgment, recognizing that we may be overriding
- t, 13 the backfit rule. I think we have the authority to do that and i 14 I think we should keep that in mind and exercise it when 15 necessary.
16 MR. PARLER: May I make one other comment? Every 17 paper would come to the Commission which the staff would say, 18 Commission, please just suspend the backfit rule or exempt it, 19 and there wasn't a good underlying foundation for it, I would '
20 think that would be an abuse of the backfit rule and I would 21 object to it.
22 CHAIRMAN ZECH: Well, 7 would agree with that.
23 MR. PARLER: But mjr.ds to differ as to whether or not 24 these are good reasons ht.e or are we moving in the direction 25 that the paper recommends.
90
,f
. 1 COMMISSIONER ROBERTS: Yes, we can differ on that.
2 MR. PARLER: Right.
3 CHAIRMAN ZECH: The essence of my point is that if 4 the Commission, in its judgment, believes it's the right thing 1
5 to do and it is in the public interest, then we should do so.
6 Not precluded by the backfit rule or anything else. ,
7 MR. STELLO: That's why we brought it to the a Commission, because it isn't a clear policy issue.
9 CHAIRKSM ZECH: Commissioner Carr? i 10 COMMISSIONER CARR I'd like to join our 11 representative from the Nuclear Information and Resource 12 Service. I didn't get the paper in time to really look at it. (
13 With that, I quit.
14 CHAIRMAN ZECH: Commissioner Curtiss?
15 COMMISSIONER CURTISS: I just have two quick 16 questions and one following up on the backfit discussion. Is 17 the staff taking the position that what is being proposed here 18 is not required to bring the facilities into compliance with 19 the statutory levels of health and safety that we're required ,
20 to abide by? Is this an additional level of protection that 21 goes beyond that statutory level?
22 MR. STELLot We struggled with that very question.
23 Let me see if I synopsize it, I might need some help. Do the s
24 current regulations in totality that exist today give us 25 confidence that the public is being adequately protected?
'91
,,.- 1 Answer, yes. Another way td look at it, if you took this rule 2 and put it on a scale and tried to do a cost benefit analysis, 3 would it pass? Answer, no.
4 COMMISSIONER CURTISS: Followup then on what Mr.
5 Parler has said, in the SECY paper itself but in more detail in 6 one of the enclosures, it seems to me that the staff is >
I 7 articulating an exception or clarification of the backfit rule l
8 that we should consider in the context of waiving that rule or 9 not applying it construing the backfit rule that goes to j
, 10 situations where this agency, either in the case of a statutory 3
11 requirement that was referred to or in this case, the matter of ,
l 12 the Federal guidance. But in those instances, the backfit rule 13 really didn't envision the conforming steps that this agency ,
l 14 would take should be covered by the cost benefit analysis. Is l r
15 that sort of a fair summary of what the premises of the I 16 recommendation to waive the backfit rule or to proceed with !
1 17 that interpretation of the backfit rule?
18 MR. PARLER: The gentlemen are looking at the general (
I 19 counsel and the general counsel is personally involved in the 20 decision to shift from a line on something that's needed for I 21 adequate protection, and incidentally as I see it, we could be !
22 thinking about adequate protection, not right now, but say i i
23 something that is needed for adequate protection over the long [
]
- 24 term, ten, 20, or 30 years in the future. [
,r.
I 25 Just because we rely on the adequate protection 4
i '
92 1 exemption as an exception to the backfit rule does not mean 2 that people should inquire or that the action implies that 3 there is some immediate problem now. There was uncertainty at 4 the proposed rulemaking stage as to how the backfit rule would 5 be handled. For that reason, the question was put to the 6 public in the enclosed rulemaking. Their response of the 7 public is summarized on Page 105 of Enclosure 3 to the paper.
8 All of the commentors, practically all of them were
, 9 opposed to a suspension or an exemption from the backfit rule.
10 Their reason for doing that, as I understand it from the 11 summary, is that otherwise you will not have a uniform 12 interpretation of application of the backfit rule. From my 13 earlier remarks in responding to the two Commissioners, I don't 14 believe that that argument would necessarily hold up because I 15 think that we have well identified circumstances, which you, 16 Commissioner, have just alluded to as to when it would be 17 appropriate to consider an exemption, a limited exemption from 18 the backfit rule.
19 As I said earlier, everything that the backfit rule 20 contemplates has been done except making the finding that there 21 would be a substantial additional protection to the public and 22 that if that were the case, that the benefits would outweigh 23 the costs.
24 COMMISSIONER CURTISS: I guess at some point, and I 25 agree with a lot of what has been said here. In trying to
93 f~, I review the file last night, it's clear that a lot of analysis 2 has gone into this and the discipline, I take it, the 3 backfitting rule was designed to accomplish has essentially 4 been a discipline analysis, but undertaken by the staff. I 5 think at least the spirit of the backfit rule has been met in 6 the paper that we have before us and the years of 7 consideration.
8 In addition, I agree with what the Chairman has said 9 that this agency can do and is not constrained by the 10 backfitting rule from doing what it thinks is right from the 11 standpoint of public health and safety. My questions go more 12 to the generic significance of a decision to waive the bacP. fit 13 rule in this context. Let me ask just one other question and 14 then I have a final question.
15 If the Commission waives the backfit rule in the 16 manner described in the enclosure because this is a situation 17 where Federal guidance is being conformed to, is that then 18 considered an interpretation of the backfit rule that would 19 apply to any subsequent case that comes up or is the precedent 20 nature of that limited to just this one case involved in Part 21 207 22 MR. PARLER: In my judgment, we take them one at a 23 time, look at the facts of the particular situation, look at 24 the applicable law and come up with the best common sense 25 judgment. So to handle case by case, as far as I'm concerned,
94
<- 1 that it wouldn't have precedent for anything.
2 MR. STELLO: If I might add one --
3 MR. PARLER: That's the general counsel speaking. He 4 is speaking for himself.
5 MR. STELLO: I would try to help to answer the 6 question. The Commission, in responding to the presentations 7 we've given on information related to severe accidents, has 8 reminded the staff that what the Commission wishes to have is 9 when the staff believes that even though something may not pass 10 a cost benefit test and there is a belief that we, as a matter 11 of policy, should still go ahead with the backfit. The 12 Commission has reminded the staff to be assured that we inform 13 the Commission of those kinds of issues so that the Commission, 14 at least once before, has recognized this potential problem 15 could exist as you get into severe accident issues, and 16 specifically asked us to bring it to them.
17 MR. PARLER: I certainly agree with that point, Mr.
18 Chairman. That's a different point that something shouldn't be 19 kept from the Commission because of potential concerns about 20 the ability to comply explicitly with the backfit rule.
21 CRAIRMAN ZECH: I agree and that, I think, is well 22 understood. I hope the staff well understands that.
23 MR. STELLO: We do.
24 CHAIRMAN ZECH: Bring to the Commission those such --
25 MR. STELLO: We intend to.
- a 95 1 CHAIRMAN ZECH: -- cases that end up in that 2 circumstance. '
3 COMNISSIONER CURTISS: I wonder if I might ask, and I 4 don't think we need to go into it here, if the counsel could 5 take a look at whether there is any benefit given the limited 6 nature of the waiver here in just granting an exemption under 7 5012 to the agency's backfitting regulations versus the 8 approach that the staff has suggested, which is to waive the 9 backfit rule but not using the 5012 exemption.
10 MR. PARLER: We would be pleased to look at that, Mr.
r 11 Chairman. I don't think that it makes too much difference one 12 way or the other, but we'd be pleased to look at it and provide 13 the advice. While we are doing that, and we hope to do it 14 expeditiously, I'm suggesting to the Commission that the (
15 Commission should not feel, under circumstances such as this, 16 that its hands are tied because of the failure of the backfit -
17 rule when it was adopted to anticipate contingencies such as
- 18 this.
19 COMMISSIONER CURTISS: One quick final question. '
20 When the IAEA did its OSORT review of the Calvert Cliffs plant, 1
21 did they review the radiation protection programs of the plant, 22 and if so, was it done against the international guidance?
23 MR. PARLER: We'll have to check and give you that 24 answer, because I don't think any of us here really know the l lI 25 answer to that question.
96 I
, 1 COMMISSIONER CURTISS: What I'd like to get a sense 2 of at some point is when the plant was reviewed first, were the 3 radiation programs covered, were they reviewed against the 4 international guidance which we're presumably incorporating 5 here and what was the upshot of it?
6 MR. PARLER: Let us get you that answer.
7 COMMISSIONER CURTISS: Thank you. That's all I have.
8 CHAIRMAN ZECH: Commissioner Carr has another 9 question.
10 COMMISSIONER CARR: I have one more I forgot to ask.
11 According to my staff's look at this thing, it says that we're 12 going to require nia) new reg guides, thrae major revisions to 13 reg guides, and 55 minor revisions and you estimate something 14 like six man years. Based on that, what I'm concerned about is 15 what the NUMARC representative said whether we shouldn't make 16 the effective date five years after the proposed rule or 17 whether we should give some consideration to, since we've got a 18 lot of work to do, taking a look at making the effective date 19 after these things get on the street.
20 COMMISSIONER ROBERTS: If I may interject, you're 21 drawing a good analogy to what is going to happen about the 22 maintenance rule, but that's a privato comment.
23 CHAIRMAN ZECH: To which we all don't agree.
24 COMMISSIONER ROBERTS: I understand that, s.
25 MR. MORRIS: You know, in the Commission paper we had
I 97 ,
1 1 an analysis done to analyse what the workload would be. We )
2 have budgeted this work. It's in the five year plan, it's in l 3 the budget planning. Admittedly, there is a challenge to get 4 all of that done on time. When you're proposing to take on 5 that challenge, in order to get these --
6 COMMISSIONER CARR By on time, do you mean you're 7 going to have that done before '91?
8 MR. MORRIS: In time to support the final 9 implementation date of the rule, yes. That's our plan.
10 COMMISSIONER CARR All those are expected.
11 MR. MORRIS: It's a lot of work, yes.
I 12 COMMISSIONER CARR Okay.
13 CHAIRMAN ZECH: Well, let me -- do you have another I
14 comment to make?
15 MR. MORRIS: Well, if you wish, we could go into some I 16 of the comments made by the representative of the Nuclear 17 Information and Resource Service.
I 18 CHAIRMAN ZECH: I was going to ask you to do that.
19 MR. MORRIS: It was difficult to fold those into the 20 remarks during the --
21 CHAIRMAN ZECH: Go right ahead.
l 22 MR. MORRIS: Because I had to jot down those remarks 23 as she was speaking. The point was made that we should not i
i 24 bring risk estimates into those limits, but that is exactly I'
25 what I see ICRP 26 did and what has been endorsed by the
i .
98
, ,- 1 scientific community as a way to make sure that the dose limits ,
2 are associated with an understanding and a limitation on risk. !
3 There was a proposal that the risk coefficient that 4 we're using is too low and it may change and further that the 5 British NRPB has recommended a different number than the five -
6 rem limit based on the possibility of those numbers changing. ;
7 We recognize that those data from the Hiroshima and Nagasaki 8 bombing survivors are being reevaluated. The BEIR-5 report i 9 will come out early next year. But the ICRP was aware of this t
10 information also and they revisited this issue and they 11 reaffirmed that they believed that the five rem limits were 12 appropriate because the total package of radiation protection 13 is more than just a dose limit. It's the dose limits plus the (
l 14 ALARA programs.
l
, 15 The comment was made that there should be hearings on l :
16 this, but I would point out that the EPA in its development of i 17 the Federal guidance, did hold hearings in several cities and )
I 18 got public comment on that at that time. I think that plus the t
19 public comment process has aired all the issues that are l
20 involved in this rulemaking and we believe that that has been f i
21 appropriately dealt with. !
[
22 We have done an environmental assessment. It is not 23 a full environmental impact assessment because we believe that !
24 the environmental impact of this rulemaking are minimal. That l 25 is not necessary. The statement was made that the .5 rem dose
99 e 1 limit during pregnancy was too high. I pointed out to you ;
l 2 earlier that the ICRP had a value of 1.5 rem for the pregnancy.
3 The Federal guidance came out with a lower number and we have 4 adopted that lower number and believe it is supported by the 5 best technical evidence we have today and we will be developing 6 regulatory guidance that will further explain how this limit 7 should be adhered to in practice. We believe that this will be 8 an acceptable dose limit for the pregnant worker.
9 We have, in the rulemaking on Part 20, eliminated the 10 concept of defining de minimis levels because we are doing you knew, in a policy development project that we have 4
12 underway. There was a concern about the impacts of the new 13 concentration limits as they might be promulgated through the 14 technical specifications and a discussion of the other limits,
{
15 nuch as the 2PA 25 millirem limit in Appendix I, turns out that
- 16 the adoption of the 100 millirem limit dose to the members of 17 the public is probably not going to have an impact because 18 these other limits are in place, the limits, the design 19 objectives that is in Appendix I and the limits in the EPA.
20 And those will be the predominant impact. Mr. Congel mentioned 21 that he might want to speak to the issue of how those technical 22 specifications are derived and I'd like to give him an 23 opportunity to do that.
24 KR. CONGEL: The point I wanted to make when I 25 listened to the presentation was the fact that in our present i
o 100 1 technical specifications, effluents are limited on the short 2 term basis by the concentrations that are specified in the 3 present Part 20, Appendix B. With the reduction of the 4 allowable off-site limit to the general public, going from 500 5 to 100, the only effect I would see on the technical l 6 specifications is the guidance for short term limiting would be 7 effected, mainly the set points that were referred to in the >
8 testimony.
9 But as was pointed out by Dr. Morris, the design 10 objective limits of Appendix I would not change at all, so we t
11 would be only faced with changing those parts of the technical 12 specifications that refer to controls for short term limits.
13 MR. STELLO: You might want to give what the number i
14 is, the average that we're seeing around nuclear plants at the 15 moment?
)
16 MR. CONGEL: Well, it's a very small fraction of the 1
17 Appendix I design objectives, which are essentially millirem to [
18 the total body from airborne effluents and 3 millirem to the [
19 total body from liquid effluents. I'd like to add, for the 20 liquid effluents, there are factors of conservatism of at least 21 one and about two orders of magnitude. So the number of ,.
22 changen that we're talking about here really will have no l 23 effect on the impact -- the environment by power plants.
l 24 MR. STELLO: We're through.
25 MS. D'ARRIGO: May I respond to that?
I i
101 1 CHAIRMAN 2ECH: Yes. You may respond briefly.
2 MS. D'ARRIGO: The first point was you said that the 3 ICRP has revisited, the ICRP, the International Commission on 4 Radiological Protection, revisited the data only up until March 7 5 1980. The Hiroshima and Nagasaki dead are coming out now.
6 There have been quite a few studies since March of 1980 that 7 really haven't been taken into consideration for calculation of 8 risk coefficients. Also, the EPA hearings were held in the 9 late '70's and this issue is something that is going to, as the 10 man from the EPA earlier stated, there are thousands of workers 11 and facilities that are going to be effected by this rule 12 change and we can debate whether or not nuclear power plants 13 actually, the 110 that there are, are going to meet these --
14 need to meet these criteria.
15 But the point is there is still a significant anount 16 of potential increase in radiation exposures and releases that 17 will result from this rule change and the later data since 1980 18 hasn't really been taken into consideration. Regarding birth 19 defects, the exposures to pregnant workers at .5 ram, Dr. Alice 20 Stewart's studies have shown that there is, in that range, a 21 possibility of doubling the risk of cancers in children that 22 are exposed in utero to that level of radiation.
23 So even though it'o three-fold lower than ICRP 24 suggested, it is still not something that the general public 25 would consider an acceptable risk. Further, there is a paper
I
- 102 j 1 in the British Journal of Radiology, Volume 57, 1984, regarding !
l 2 in utero exposure to radon radiation, otake and schull, and it l 3 points out -- it looks -- it concludes that one to two rads of 4 exposure in utero doubles the risk of retardation. We've heard l 5 also in the past that five rads doubles the risk of j 6 retardation.
f i 7 So this is a risk that the NRC, if you pass this j 8 rule, is saying is acceptable risk and workers might not know I 9 that they're pregnant and get out of the exposure in time to e j 10 avoid the risk. Since the proposal has been around since 1977, {
l 11 the ICRP recommeredation, maybe we should wait until early next I l
l 12 year and see what their five concludes before voting on it, and [
13 further, the -- you were talking back and forth about the !
i 14 backfit rule and I don't really see what the benefit is. I l l 15 sean the industry said that it's costing them money. Health l I I j 16 physicists are saying that it's difficult to do these j i
j 17 calculations. You talked for half an hour about how difficult f t r i
18 it is going to be to meacure, the different kinds of
! 19 measurements that are going to need to happen, you're not going i
l 20 to know for a year.
l And what we're saying is that there are no benefits f 21 j
l 22 and why should we put the money in, the NRC put the money in, i 23 the industry unless we're really going to have a significant l r
l 24 increase in protection. I think those are the comments that -- f 25 let's see -- technical specifications, f i
103 f
1 I think those were all the comments that I got.
2 Thank you.
3 CHAIRMAN ZECH: Thank you very much.
4 MS. D'ARRIGO: Thank you for the opportunity to 5 respond.
6 CHAIRMAN ZECH: Thank you.
7 MR. STELLot Mr. Chairman, we are through. Our 8 considered technical judgment is that the commission ought to 9 go forward with the rule.
10 CHAIRMAN ZECH: Thank you very much. Let me thank 11 all of the guest speakers and the staff for a very informative 12 presentation. It's a complex matter and a very important 13 matter, as we all recognize. As I indicated in my openin t s 14 remarks, it was clear to me before we started the meeting that 15 we'll need to do a fair amount of reflection. That was only 16 reemph'nsized a number of times during the meeting today. I 17 would ask my fellow Commissioners to reflect carefully on what
- la we have heard and we will make a decision when we feel that we {
19 are confident that we can rake the best possible decision.
20 So unless there are any other comments from my fellow 21 Commissioners, thank you very much. We stand adjourned.
22 (Whereupon, at 12:38 p.m., the Commission was j 23 adjourned, to reconvene at the call of the Chair.)
i 24 25
CERTIFICATE OF TRANSCRIBER This is to certify that the attached events of a meeting of the U.S. Nuclear Regulatory Commission entitled:
TITLE OF MEETING: Briefing on Final Rule on Standards for
. Protection Against Radiation - Part 20 PLACE OF MEETING: Rockville, liaryland DATE OF MEETING: Thursday. November 10. 1988
) were transcribed by me. I fur'ther certify that said transcription is accurate and complete, to the boat of my ability, and that the transcript is a true and accurate rwcord of the foregoing events, a
'S
, _N j j (/ John Trowbridge y i
s.
l Ann Riley & Associates, Ltd.
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GE Nucksr Inwry cmma c.mo, c.~.-~,a n ~cmu November 7, 1988 Mr. Samuti J. Chilk Secretary of the Commission US Nuclear Regulatory Commission 11555 Rockw 114 Pike Rockville, MD 20850 Dear Mr. Chilk GE Nuclear Energy looks forward to addressing the Commission on the sucject of the proposed changes to 10CFR20, at 10 a.m. on November 10, 1988. As you requested in your letter of November 3, we have provided you with 12 copies of our prepared statement (see enclosed). In addition we have transmitted a telecopy to you.
Please be advised that we intend to have Dr. Paul S. Stansbury give the actual presentation. He will require no viewgraphs.
Please contact me 1.t we should provide any further infomation at this time.
Sincerely, GE NUCLEAR ENERGY M ._0_ -
& 2 l T. Preston Winslow, Manager Licensing & Nuclear Materials Management
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STATEMENT FOR NOVEMBER 10TH CCMMISSION BRIEFING CN 10CFR20 SY QE NUCLEAR ENERGY GE Nuclear Energy would like to present in alternative to the !
costly, unnecessarily conservative strict application of cammitted done being considered in the proposed changes to 10CFR20. The alternative is this: for the persistent chamical forms of radionuclides used in the uranium fuel fabrication industry, allow licensees the option to (1) control the work place using air sampling and associated action guides and limits based on committed dose models and (2) determins the interns 1 dose of record for occupationally exposed _ individuals on the basis of annual dose as determined with appropriate measuraments, primarily lung counting.
To help in your consideration of this matter, GE would like to review the salient features, of both committed and annual dose from the practical viewpoint of day-to-day health physics in a commercial fuel fabrication plant. How the new 10CFR20 incorporates either or both of these concepts will mold the fundamental nature of health physics programs at fuel fabrication j facilities and will prderitize the importance of assumptions l versus the importance of measurements in the protection of worker health.
Under a strict committed dose systam, compliance with internal dose limits must be demonstrated by determining and summing a number of small intakes (i.e., daily). The tool to do this in air sampling. once the intakes are assessed, radiation dose is l
deterministically calculated using the Appsndix 5 values which are has.d on Ref.rence aan 2s.umptions int.grae.d ever the next str.tv i l years, l
_i-l l
. 9 It is the assumptions about how a material which enters the body is deposited, how it moves from organ to organ, and how fast it is eliminated from the body that,specify the committed dose that would be entered in an individual's record. Such assumptions are almost universally established to b= Gor-ssrvative: 1:e: to overestimate laternal doses. While deviating from the standard assumptions is theoretically possible, doing so in practical, everyday situations will not be feasible and doesn't really do much for the worker.
Annual dose to an internal organ can be determined much more directly. What needs to be known is the amount of radioactive l material residing in the organ during the year. For individuals l occupationally exposed in the commercial fuel fabrication i
industry, this can be accomplished most practicably with a series f of lung counta. One may then convert to dose using the physiologic parameters of Reference Man (such as organ weight) without having to make assumptions about how much is retained in the organ and for how long.
Granted, air sampling seems straightforward and precise. The radioactivity collected on a filter can be measured to a high degree of accuracy. But there is inherent in air sampling a serious question of representativeness, i.e., the relation of the radioactivity on the filter to that which may have been inhaled, even for the highly touted lapel air samplers, often presumptively named breathing zcne air samplers. This question of representativeness ir. of concern to the facility health physicist, the regulatory inspector, and potentially to a court considering a claim for radiation injury. Determining internal dose from air sampling has two further handicaps it requires the use of assumptiona rather than measurements to account for retention of inhaled material, and it tends to "write off" the effect of all previously deternined and duly recorded intakes.
2-
i . .
9 Lung counting to determine doses on an annual basis has some significant benefits. Since it is a direct measurement, representativeness is not the issue it is with air sampling.
Second, lung counting measurements directly account for differences in individual'elearance times, particle size and solubility, minimizing over or under estimations of dose. Third, lung counting measures and accounts for previous intakes, it does not "write off" prior dose.
It is easier to determine radioactivity on an air sample filter than it is to determine radioactivity in an internal organ.
Because of minimum sensitivity limitations, lung counting of uranium cannot be used to determine intakes at a level of day-to-day operational interest, say 40 DAC-hours. However, detection sensitivity and accuracy become quite acceptable at an organ contents equal to 35% of a practical action guide or regulatory limit. Further, when needed, a series of lung counts can be made to determine average lung contents with more precision and it is the average over time which is the dosimetrical'.y important quantity for determination of annual internal dese.
There are several further problems with a strict committed dose system.
- 1. The NCRP in its Report 84 (1985) specifically advises against the use of committed dose for determining an individual's exposure status. The more recent NCRP 91 Report, published in 1987, reaffirms the Report 84 comments on committed dose.
^
- 2. Ic is expensive. The NRC staff has estimated a $15M cost associnted with the internal dose provisions of the proposed 10CFR20. Industry believes and GE concurs this cost is low.
It may reflect the necessary capital costs but it does not i
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reflect the ongoing operational costs. Most of this cost.is attributable to the over-conservatism in the committed dose models.
- 3. Since a sizable pert of the committed dose is deilvered in the future, the quantity is useless for epidemiological purposes. Good, straightforward applied epidemiology is important te the nuclear industries and the NRC -- it has the potential to provide clear demonstration of the overall efficacy of the licensees' radiation safety programs and the Commission's regulations. Using committed dose as the dose of record will seriously limit the usefulness of epidemiology among uranium fuel fabrication workers by complicating the exposure variable. .Use of annual dose limits will encourage lung counting of workers thus maximizing the usefulness of routinely collected radiation protection data in the further development radiation protection models and limits.
- 4. Committed dose is an abstract concept including dose delivered in the current year, doses to be delivered in the next 50 years, and doses which may never be delivered due to ;
overestimating assumptions. Just explaining the concept to a listener outside the field of health physics will be a i daunting task and a real liability to the defendant in a lawsuit alleging radiation injury. Adopting a strict committed dose limit system is likely to give false ;
impressions about permanence and concreteness of what was developed as an abstract modeling quantity. ,
c
- 5. Lung counting is employee oriented. It provides the individual, his amployer, and a re7ulatory agency the best, most direct demonstration that the.overall radiation safety program is working in all cases. A strict committed dose
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.* a
, systam will severely focus uranium facility health physics attention on air sampling, sume of DAC-hrs, and associated issues of representativeness and over-conservatism, thus diminishing the attention to actual worker exposure management.
- 6. Implementation of a strict committed dose is likely to mask the whole purpose of the internal dose portions of the proposed 10CFR20 changes, i.e. to adopt a regulatory system which more clearly demonstrates the relation between dose limits and risk. A strict committed dose system will make DAC the prime measure of compliance demonstration, resulting in DAC being treated functionally as analogous to the current MPC. Such perceived functional equivalence will tend to hide the fundamental difference of the new quantity, and further, will tend to suggest, completely misleadingly, that the previous MPC's for uranium were a factor of five too large.
Instead of a strict committed dose system, GE would encourage the commission to adopt a system using committed dose for design and daily control of the work place and annual dose to assoas and manage the actual dose to workers. Such a system is in direct accorc with the Presidential Guidance developed by Federal agencies under EPA's chairmansh'ip published in January 1987 and parallels the Department of Energy's imp.lementation of that guidance. It is in accord with the recent recommendation of the Commission's own Advisory Comnittee on Reactor Safeguards.
Finally, it makes best use of both air sampling and lung counting to provida excellence in control of internal exposures in the work place while avoiding extremely costly, unnecessary conservatism.
Use of a technica31y sound, effective and reasonably cost-effective rad'.ation control and management program is er.sential to the future of nuclear energy in this country and in t ',te world.
Presented by Paul S. Stansbury, Ph.D.
i l
NUMARC Briefing to the Comission on 10 CFR 20 Thursday, November 10, 1988 Good morning. I am Joe Colvin, Executive Vice-President and Chief Operating Officer of the Nuclear Management and Resources Council (NUMARC).
. I'd like to thank the Comission for the opportunity to appear before you at this meeting to present a statement on behalf of NUMARC on the proposed revisions to 10 CFR Part 20. With me today is Lynne Fairobent, NUMARC Project Manager on this issue.
NUMARC wishes to express its overall support for the proposed revision to 10 CFR Part 20. We support the Comission's efforts to incorporate revisions to 10 CFR Part 20 which reflect developments and advancements that have occurred since the original publication of this rule some thirty years ago. We also comend the NRC staff for seeking, during the development stage of the proposed rule, scientific and technical input from licensees directly affected by this rule change. The industry provided extensive coments on the proposed rule. In addition, NUMARC provided recent coments in our letters dated April 26, 1988 and October 20, 1988. However as expressed in these letters, there are two specific areas that we urge you to consider prior to issuing the final rule. ,
First, we understand that the Staff has recomended the deletion of the proposed Section 20.205 from the final regulation. This section would allow licensees to control occupational exposure to certain long-lived radionuclides in terms of the sum of the external deep dose equivalent and the effective dose equivalent actually received in one year from all radioactive material retained in the body. This section is of particular importance to the comercial uranium fuel fabrication workers and industry. The retention of the Proposed Section 20.205 vould allow its licensees the option of accounting for dose on an annual basis in conjunction with tracking the 50-year comitted dose rather than requiring dose evaluation based solely on calculating the 50-year comitted dose.
We recognize that the issue of how to account for the radiation tase from radionuclides persisting in the body is decidedly complex and not without controversy. However, both the National Council on Radiation Protection and Measurements in Publication 84, issued in September 1985 and the NRC Advisory Comittee on Reactor Safeguards at its June 1988 meeting, recomend the use of accounting for dose from these persistent radionuclides on an annual basis in conjunction with tracking the 50 year comitted dose.
We believe there is a significant cost impact in implementing the proposed rule without the inclusion of the option to account for these doses on an mnual basis. The NRC estimate for implementing this one section of the f;nal rule that would require the recording of dose from long-lived radionculides based on the 50-year committed dose is 75 million dollars to 1
the fuel fabricators alone. This is the one time cost of complying with the regulation and does not reflect the annual operational costs. We believe that retaining Section 20.205 would essentially eliminate this cost without decreasing the level of radiological protection afforded to workers.
The NRC staff sought and obtained extensive coments on the proposed rule. The decision to delete this important provision does not appear to reflect the comments obtained. If it is decided to delete this section, we strongly urge that the Commission publish this proposed change for public comment due to the significant difference in approach that this change represents from the original draft regulations published for comment.
The second area that we urge you to consider relates to the implementation of the rule. Our letter to the NRC staff of April 26, 1988, expressed concern that the complexity of this rule could result in a non-uniform application of its provisions by those who must regulate the various licensees. We understand that the NRC Staff has not yet developed the corresponding guidance documents necessary to provide its licensees with sufficient information to effect consistent interpretation and implementation.
In order to aid in uniform application cf the regulation and facilitate a greater understanding of the new regulations and potential implementation problems by all involved, we urge the Commission to publish the necessary guidance documents and to consider regional workshops for both its inspection staff and licensees with the accompanying detailed guidance prior to the full implementation date. This approach was used in implementing 10 CFR Part 50 Appendix ! in the early 1970s and proved beneficial to both the regulator and to licensees.
In the proposed rule, the implementation period was stated to be five years from date of publication as an effective rule. It is our understanding that the final rule under consideration before you today recommends an implementation period of two years from the effective date of the final rule.
We believe that this time is not adequate to ensure correct implementation of this rule.
We believe that a phase-in of specific sections of the regulation may be beneficial from both the regulatory and licensee viewpoints. NUMARC would be pleased to work with the NRC staff to identify those sections of the regulations that could be implemented with minimum impact and those that would benefit most from a phased-in implementation once the guidance documents were prepared and regional workshops were conducted. For example, it would be more cost-effective to have all power reactor licensees simultaneously implement the proposed regulations dealing with dose recording. Recording of worker dose is a major portion of the recordkeeping cost for the utility industry and was identified by an industry study (AIF/NESP-30) as the single most costly aspect of the proposed rule.
In closing, we urge the Commission to consider retaining the proposed Section 20.205 and restoring the five year time period for full implementation, utilizing a phased-in approach to achieve your goal. Thank you for your consideration.
2
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Nuclear Information and Resource Service 142416th Street, N.W., Suite 601, Washington, D.C. 20036(202) 3284002 Comments of Diane D'Arrigo Nuclear Information and Resource Service to the United States Nuclear Regulatory Commission on the Part 20 Radiation Protection Standards Proposed Rule Commissioners Meeting Noveaber 10, 1988 I very much appreciate the opportunity to address the Commissioners this morning on what I believe is one of the most important responsibilities of the Nuclear Re protection from ionizing radiation exposure.gulatory Commission, We would have liked more than 4 working days notice that we were being allowed to speak. An advance copy of the proposed rule, which we were denied, would have afforded us the opportunity to make even more pertinent comments.
Our organization, Nuclear Information and Resource Service, and many others including unions, county and state officials, public
' health associations, national and local environmental groups, citizen organizations, church groups, and concerned individuals, even nuclear utilities and health physicists commented critically on the 1986 NRC proposal regarding radiation standards.
I speak, today, on behalf of Nuclear Informatien and Resource Service, Environmental Policy Institute, Critical Mass Energy project, and many of the organizations and citiizns across the country who couldn't be here. The worker exposure portion of my comments is also on behalf of the Oil Chemical and Atomic Workers, the International Chemical Workers Union and the Maine Labor Group on Health. '
The Commission received in the range of 1000 comments on the rule, so there is clearly public interest in it. There are many interested parties that would like the opportunity to address the Commission regarding this final proposal and, as requested in a large percentage of the comments on the proposed rule, the unions representing radiation workers, citizens and environmental groups would like the opportunity to comment again after thoroughly reviewing the final proposal, beroru U.c Commission votes. We request regional public adjudicatory hearings on the rule.
dedicated to a sound non nudearmpolicy. ,
Further, we are requesting again, since increases in radiation release to the environment and exposure the human gene pool are involved, and since this a major federal action affecting the environment, that a full Environmental Impact Statement (EIS) be done. NRC has not considered the impact of reducing all exposure and contamination levels'.
I would like to point out that we are in agreement with Commissioner Roberts' opinion in 1986 that the rule should not be approved, although our reasons are different. The NRC's cost-benefit (backfit) analysis concluded that the proposed rule "may not provide a substantial increase in the overall protection of public health and safety or the common defense and security." In other words, the supposed benefits are not wceth the costs to implement this rule. Although Nuclear Information and Resource Service does not support using cost-benefit analysis to decide public health and safety issues, we do find it curious that the Commission is proceeding with a rulemaking which it has determined is not economically worthwhile and which fails to provide increased safety.
My statement this morning is based largely on the proposed radiation standards as I was refused an advance copy of the final proposal which is being released today.
I. The main concern with the proposed radiation standards is that the permissible contamination levels of many radionuclides in air and water will be increased above current levels. NRC admits this fact in its 1986 proposal.
. The NRC argues that there will be a potential reduction in external exposure to workers as a result of the new proposed method of calculating dose. We agree that external dose should be reduced and commend the removal of the rule (5(N-18)) which currently allows up to 12 rems of external exposure annually to workers, depending on their ages.
Regardless, it is our position that the permissible contamination levels in air and water should be reduced for all radionuclides. :
i There is no justification for increasing allowable internal radiation exposures to workers and the public. <
t 10 CFR Part 20 Appendix B gives the permissible contamination levels for air and water. Table I is for workers and Table II~is for the public.
{
In the 1986 proposal, the permissible contamination levels for over two thirds of the radionuclides increase to higher levels
( than currently allowed. My understanding is that the proposal i being released today has some changes in those levels, but that for the most part, there is no significant change. There are still increases in permissible contamination of workers and the ,
public. !
2
- O The standards set by NRC for workers will set the precedent for the other federal and state agencies and departments. Workers at the nation's troubled weapons facilities will legally receive even higher radiation doses if and when the Department of Energy follows the NRC's lead in adopting these standards. It would be preferable to require cleaner operations at all sites than to increase the allowable exposures to workers.
The Environmental Protection Agency used 10 CFR 20 Appendix B to derive its Safe Drinking Water regulations (National Interim Primary Drinking Water Regulations, June 1977).
Further, many state radiation regulatory agencies use 10 CFR Part 20 to analyze nuclear plant effluents and to indicate to the public and the media "acceptable" federal radiation release limits.
The increases in permissible exposure to the public can occur at all NRC licensed facilities except (allegedly) uranium fuel cycle facilities. So, hospitals, research reactors, university reactors, radiopharmaceutical plants, industrial and other facilities will be permitted to expose the public to higher radiation levels than currently allowed.
But I contend that nuclear power plants will also end up using 10 CFR 20 Appendix B. Nuclear plant licenses have technical specifications, which are the limiting conditions for reactor operation. These technical specifications require adherence to 10 CFR Part 20 Appendix B for dealing with radioactive effluents, specifically liquid effluents. The alarm-set point on monitors
, for liquid waste streams are set according to 10 CFR Part 20 Appendix B. For example, technical specification 3.11.1.1 for the callaway nuclear plant in Missouri reads, The concentrations of radioactive material released in liquid effluents to UNRESTRICTED AREAS shall be limited to concentrations specified in 10 CFR Part 20, Appendix B, Table II, column 2, for radionuclides other than dissolved or entrained noble gases.
The proposed rule also requires that uranium fuel cycle facilities (nuclear power plants, uranium mills, conversion and enrichment facilities, reprocessing plants) must meet the U.S.
Environmental Protection Agency (EPA) standard (40 CFR 190) which limits the maximum radiation dose to each member of the public to 25 millirems per year. But 25 millirems per year is not an enforceable numerical emission standard. Appendix B is the working tool used liait radiation releases which lead to public exposures.
If the intent of the NRC is that the individual public exposure be limited to 25 millirems per year, as required by EPA, then 3
0 NRC's 10 CFR Part 20 Appendix B should be based on an annual dose to members of the public of 25 millirems / year rather than 100 millirems / year (51FR 1119 column 3).
We advocate a change in the standards that significantly reduces the permissible contamination levels.
The requirement that facilities meet the EPA dose limit is not a guarantee. If a nuclear facility which is supposed to meet the EPA regulation of 25 millirems per year has a problem meeting that limit, a variance can be requested which will allow exposures to the public of up to 100 millirems per year continuously and up to 500 millirems per year "noncontinuously."
We oppose the variances allowed by both NRC and EPA.
The point is that changes in 10 CFR 20 Appendix B, which inciease
. worker and public internal radiation exposures will have major direct and indirect impacts on many facilities, agencies, workers and the public. Appendix B is used as working tool in the field and as a basis for other state and federal agencies' permissible contamination limits.
II. Another concern we have is with the method of calculating radiation doses. The weighting factor, by which an individual's internal dose is multiplied, incorporates risk estimates. We oppose incorporating risk estimates into what is supposed to be an objective dose measurement. In addition, there are several problems with these risk estimates:
A. The only risks considered are for fatal cancers and birth defects in the next two generations. Not'all risks from rodiation exposure are considered. Nonfatal cancers, birth defects beyond the next two generations, decreased immune system function thus increased susceptibility to diseases and accelerated onset of age-related diseases are ignored. If radiation risks are going to be calculated into the dose measurement, all known risks should be included.
B. The risks of developing a fatal cancer or birth defects in the next two generations is underestimated. The NRC is assuming that the risk of fatal cancers (1.65 per 100,000 person rems) and birth defects in the next two generations are numbers upon which everyone agrees but there is serious scientific debate. National and international radiation bodies and independent scientists disagree--estimates range tremendously (from 1 to 10 to 37 fatal cancers per 100,000 person rems). The reevaluation of the Hiroshima and Nagasaki dosimetry and debate over the true dose-response curva (the biological effect of a given amount of radiation exposure) call into question the reliability of the risks included in the weighting factor.
With all due respect, I hav'e yet to understand how the supposedly objective measurement of internal radiation dose can incorporate 4
l
a controversial risk estimate into its measurement. There must be a way to measure internal dose and make it compatable with external dose without depending on controversial risk estimates.
C. NRC bases its risk estimates on the entire population but some members of the population such as young and unborn children whose cells are dividing much more rapidly than adults, are at much greater risk. People who have undergone voluntary radiation treatment or diagnosis for personal health reasons have already increased their radiation-related risks thus will be at even higher risk from this increased involuntary exposure.
III. occupational Exposure The unions have requested public hearingsto further discuss their concerns which include:
A. The lack of worker rights regarding Planned Special Exposures. Workers twice the annual canlimit dose be required, involuntari in certain l y receive up to situations,to B. Pregnant workers can be exposed to .5 rer.3 per pregnancy, which is within the range of exposure that has been shown to double the risk of childhood cancer and mental retardation. Concern is also for men planning to start or add to their families.
C. The use of. risk coefficients to justify allowable dose increases to internal organs.
The National Radiological Protection Board in England has adopted the scheme for calculating radiation exposure that is put forth in the proposed rule, but they have reduced the allowable annual exposure to workers from 5 rems per year to 1.5 rems per year, with a consideration to lower that amount further to .5 rems in the near futuro. Such a reduction is quite advisable for the United States and should be seriously considered before the Commission votes on this rule.
IV. The de minimis concept, that there is a level of exposure so low that it is not worth regulating, should be abandoned. In Japan, when a de minimis level was established for workers, it gave the appearance of a significant reduction in radiation exposure. The reduction was a result of not recording low exposures below the de minimis level, not improved worker protection. The 1986 proposed rule called for de minimis levels for public exposures. We have been informed that the proposal being released todaydebtd the de minimis concept but that it has been moved to a separate rulemaking process with*mthe NRC.
There is unequivocal opposition to this concept and policy.
Unions, municipalities, citizens will not accept deregulated nuclear waste, now being referred to as BRC or Below Regulatory concern waste. This "liguistic detoxification" ( as Barry Commoner calls it) of nuclear waste could allow nearly half of 5
what is currently considered "low-level" radioactive waste being redfined as regular garbage and going to landfills, incinerators, sewers anywhere in the country.
V. To conclude, I will ask you to step back and consider how much we are hearing recently about acid rain and gases from fossil fuel plants.'The gases and liquid effluents that are routinely released from nuclear facilities will be increased by this rulechange. These are affluents that are much more difficult to monitor than those from fossil fuel based industrial facilities and about which, we know less. This rule is changing some basic permissible levels. citizens have the right to analyze and actively participate in these changes. Nuclear workers, their unions and citizens have the right to be actively involved in ;
rules affecting their health and safety.
We request adjudicatory hearings and an environmental impact statement be done. We encourage the reduction in permissible i contamination levels in 10 CFR Part 20 Appendix B. And we thank you again for the rare opportunity to address the commission.
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Comments on Part II Title 10 Part 20 Dated January 9, 1986.
Standards for Protection Against Radiation; Proposed Ruler Extension of Comment Period and Publication.
By Karl 2. Morgan March 27, 1986 I have taken a hurried look at the Federal Register, Part II NRC 10 CFR 19 et al of Tuesday, January 9,1986 and considered this a terrible retreat of the NRC from its obligation to protect the public from the harmful effects of nuclear power. The NRC and EPA have finally weakened to political pressure and given second place to the health of radiation workers and the public by adopting the Handbook 26 recommendations of the International Commission on Radiological Protection (ICRP).
I was a member of ICRP for a quarter of a century but now am an emeritus member. During the years I was active with ICRP I was chairman of the Internal Dose comrittee that prepared ICRP-2.
Tables I and II of present Title 10 Part 20 are, for the most part, a complete adoption of the tables of (MPC)a and (11PC) w (maximum permissible enncentrations in air and water) from IC RP- 2. During the quarter of a century I was en active member of ICRP we recognized an inconsistency in the rules by which we had set values for (MPC) a and ' (MPC) W, namely we set the dose rate limit at 5 rem /y for both the total body and the gonads. It
. Radiation Co=en ts , ';r. I arl 2. .Morg;an p.2 seemed obvious that if the whole body, including the gonads, got 5 rem /y the dose allowed to the gonads alone would be greater.
I suggested the solution was very simple,viz. reduce the limit to whole body to 2.5 rem /y. Unfortunately, after I retired from active membership in ICRP, they moved in the other direction and kept the 5 rem /y for whok body and raised the dose limits to all other organs. In this reckless move, ICRP jumped from the frying pan into the fire because with other modifications the dose rates to the thyroid and bone became 167 rem /y instead of the previous 30 rem /y and ICRP realized that this could cause radiation sickness in employees. Thus, to save f ace, ICRP picked the n' umber 50 rem /y out of thin air as ;the limiting dose rate for these two organs. I took a look at some of the radionuclides of major interest in the nuclear industry (28 altogether) and found that in about half the cases the proposed values of (RPC)a and (MPC)w were increased in the January 9, 1986 NRC Title 10 Part 20 tables for occupational exposure using using ICRP-26 recommendations. All the values are not increased because of other changes brought on by ICRP-26, e.g. here the dose to a critical organ is determined not only by the amount of radionuclide in this organ but also by the additional dose from the radionuclide deposited in adjacent body organs.
During the past few years I have met with members of URC twice trying to convince them that this was not an appropriate
. m .
Radiation coe_,ents, Dr. l'arl . Morgan p.3 i .
time to increase value's of MPC because the present ICRP-2 was a
published in 1959 and today we know that the risk of ,
radiation-induced cancer is more than ten tii.aes what we believed it to be in 1959. I, along with R.E. Alexanddr, of the NRC, urged !
we adopt the ICRP-26 values when they were lower than the ICRP-2 or Title 10 Part 20 values but otherwise we keep the present values.
The newly proposed values of January 9, 1986 are not only higher than present values in at least 50% of the cases but the values are not given directly; instead they are given in an
,obsure and surreptitious manner. Values of Annual Limit on Intake (ALI) and Derived Air Concentration (DAC) are given instead of (MPC)w and (MPC) a. I can't help but believe this ,
choice was made only as a coverup or to make it more difficult l
1 for the radiation worket and members of the public to realize that at a time when the Maximum Fermissible Concentrations of l l
radionuclides in air, water and food should be reduced by at least a factor of 10 they are being increased. In practice the health physicist or radiation worker will never use ALI or DAC but must convert them to (MPC)w and (MPC)a respectively.
I In the attached table we have for radiation workers, (MPC) w= 3.6 4 x 10 E-6 (ALI) oral microcuries/cc and !
t l
r
e .
i.acia:icn Co=.ent s. I.ar! :. ': Organ p.,
(tiPC) a= 4.17 x 10 E-10 (ALI)inhal microcuries/cc.
The values of (MPC)a and (MPC)w for members of the public should be 1/30 of the above occupational values except when the whole body is the critical organ. In this case the values for public are 1/100 the occupational values in order to reduce the genetic risk.
There are many other ways in which the January 9, 1986 proposed changes of Title 10 Part 20 are a serious regression and a political concession to the nuclear industry at the expense of th.e workers and public in terms of a greater somatic, teratogenic and genetic risk.
It is unfortunate trtt the Government Agencies we have set up to protect the public so consistently come to believe their mission is to protect big business. We have numerous examples of this. For example, the Veterans Administration. is not offering help and compensat. ion to the servicemen who, in the line of duty, have suffered radiation damage. Even in the early period we have a good example. L'h e n , in about 1960, it was shown that uranium n.iners in the Colorado Plateau were dying o lung cancer from radon levels higher than those in Bohemia and Schnuberg, Saxony 500 years earlier, the AEC, PHS and FEC fought against reducing
t
. Radiation Coc:nents, Karl . ?: organ p. 5 the Radon-222 level. In uranium mines to the value given in IC RP-2 . Finally, an honest man showed up in Washington, Secretary of Labor (1962-69), Mr. W.W. Wirtz, and he unilateraly adopted the ICRP-2 value of 0.3 WL (working level) or 4 WLM/y.
I hope it is not too late for NRC and EPA to recant its
- crayfish posture and consider the need to reduce the values of
] MPC rather than increase them.
l i
WJinjM PERM 1551B'.E CONCENTRATIONS OF RADIONUCLIDES
- n Mi:co:uries ver Cu::: Cen: 1me:er (uCi/::)
l EXPOSUP.ES TO GENERAL PUBLIE OCCUPATIONAL EXPOSURES WATER
.ATER AIR AIR 10"FR?O ICRP-? ! 13 FR?O ICRP-? 10CTR?O ICRP-?
,u-198 1 3E-7 (2E-6 *(2E-9 l *(7E-7 2E-9 IE-5 7E-6 6E-7 BE-4 1.8E-3 IE-9
$3-140 l IE-7 3E-5 7E-4 6E-4 BE-6 SE-2 1.5E-1 2E-3 de 7 6E-6 l JE-9 (2E-9 3E-5 2E-5 SE-7 (4E-7 4E-3 3.6E-3 l
- o-53 *(lE-9
.*(IE-8 1E-10 lE-10 9E-7 9E-7 4E-S 4E-8 3E-4 2.5E-4 1E-6 Cs-134 l 2E-10 2E-10 2E-6 6E-3 6E-8 4E-4 3.6E-4 lE-5 Cs-137 7E-10 (5E-9 2E-5 lE-7 (IE-7 2E-3 2.9E-3 Fo-69 *(7E-10
?E-9 4E-9 lE-5 1.SE-5 1 129 l 1.lE-4 li-10 2E-10 7E-7 IE-6 !
lE-4 -- -- lE-7 7E-7 -- l tr-d5 lE-5 I 3E-14 2E-14 IE-6 2E-9 Np-237 4E-12 2E-12 9E-5 2.5E-7 2.2E-6 lE-12 4E-13 1E-3 lE-3 L Po-210 1E-10 IE-10 , 4E-6 4E-3 1.lE-5 7E-12 9E-13 2E-7 l 90-210 5E-10 3E-10 2E-5 2E-7 2.5E-5 2E-14 (2E-14 2E-6 Pu-235 2E-12 (3E-12 lE-4
'(6E-12 2E-6 lE-7 1E-4 2.2E-5 2E-14 (2E-14 Pu-240 2E-12 (2E-12
- (6E-12 9E-13 2E-9 7E-S 3E-10 4E-7 7.3E-6 2E-13 R&-22o at-11 (IE-10 3E-5 3E-6 SE-3 (4E-B 4E-4 7.3E-4 IE-9 Au-105 *(2E-ll
'(5E-9 ,
(IE-9 3E-6 6E-6 3E-4 1.5E-3 , 3E-10 Sr-59 3E-3 (4E-7
'(2E-11 '(6E-14 1E-12 (3E-12 1E-5 3E-7 U-233 7E-11 (6E-10 1E-3 3.6E-5
'(2E 11 '(6E-14 3.5E-3 4E-10 (4E-10 2E-5 2E-5 2r-95 'E-7
)
'(lE-7 1 (M?C)a = 4.17E-10( ALI)a
'O CFR 20: ('PC)w = 3.64E-6(AL!)s are 1/33 of values for
. RP-2: (M?C,a and (MPC)w values for i.amoers of
- t tne publi:
o::upational workers except . hen radionuclide is a gonad exposure proolem, in ani:r.
case reduction fae:or is 1/103.
Jou-:e: K.2. Morgan, April 7, 1986.
- J44EN!S C.1 10 CFR 23
- 1 WW r NEWS 182% RELEASE Nuclear Informaton and Resource Service, 142416th Street, N.W., Suite 601, Washington DC 20036, (202) 328-0002 PRESS STATEMENT MOVEMBER 10,1938 Nuclear Information and Resource Service representative, Diane D'Arrigo, testified today at the Nuclear Regulatory .
Commissioners meeting, opposing the proposed radiation st'andards which would increase allowable worker and public exposure to ioniring radiation.
There is no safe level of exposure. Any radiation exposure increases the risk of cancer, birth defects, and genetic damage, accelerates the sging process, and causes other health problems including impaired immunity.
Some of the provisions of the proposed rule that threaten human health and environmental quality include:
- Increased Internal Exposure Levels Exposures to 65% of the most significant radionuclides, including strontium-90 and iodine-131, will increase up to 10 times or more above present "allowable" levels. This is unacceptable because even at low levels many of these radionuclides are inccrporated into internal organs and continually irradiate the body for years.
- Weighting Factor = Tool for Increasing Internal Exposures A "weighting factor" is used to equate the internal dose to individual organs and tissues to external (total body) dose.
Presently, internal and external doses are measured separately.
The weighting factor is derived from observations of survivors of high level radiation exposures and animal experiments, not chronic low level exposures to humans, which is what would be permitted by the proposed rule. Multiplying the actual internal exposures by the weighting factor results in a lower value for total body exposure than the body actually received. The exposure is trosted as if it were spread over the whole body when it has really boon concentrated in one organ or one small area of one organ. Both the way the weighting f actor is derived and its use are unacceptable.
- Inadequate Definition of Radiation Risk Rs.iiation risk is li=itec, in the rule, to fatal cancers and birth defects within two generations. No consideration is given to nonf atal cancers, health effects other than cancer, or mutations that are recessive and may not show up until later generations. Tell the NRC that any rule that increases radiation exposure MUST take into account all known health effects of radiation, not just fatal cancers and scre defects.
t *
- Poor Basis for "Acceptable" Risk Radiation risks are compared to risks taken by workers in non-nuclear jobs. These risks are used to determine a level of risk, due to radiation exposure, that can be imposed on the public, workers, and future generations. This assumes that all individuals are at average risk and does not account for half the population that are more radiosensitive than average, such as the young, the old, and the already ill. It does not take into account that radiation risks will be in addition to the non-nuclear risks that individuals already experience.
- De Minimus" Levels of Exposure to the Public are Not Counted Radioactive releases that pose "a level of risk (in the NRC and industry opinion) so low that it would be a trifle..." will not be counted in dose calculations to the public. The NRC has succumbed to industry pressure to allcw this level of exposure because industry claims the risk is "so low that no resources could be justified to control it." This concept allows unregulated releases to the environment and sets a dangerous precedent. Proposals for "de minimus" categories of both radiation exposure and waste should be strongly opposed.
- Workers' Annual Dose Can Be Doubled Without Worker Concent "Planned Special Exposures" allow the licensee to expose workers to twice the annual limit in one year. The licensee need only give authorization in advance. This provision is based purely on economics and not on health concerns as it doubles workers' annual dose to insure that nuclear f acilities have the workers they need for "hot" jobs. Workers cannot refuse this work. There is no need for this loophole in radiation standards.
- Pregnapt Workers Advised to.De Cautious The NRC is to be commended for admitting, in the proposed rule, that pregnant women and the fetus should have less exposure than other individuals. The level, however, should be set much i lower, with provisions for placing the pregnant worker in a
! non-radioactive area during the pregnancy.
Even though revision of the present standards is long overdue and sorely needed, no new NRC rule on radiation standards should be passed unless exposures are reduced or eliminated.
Unions, environmental and citizen groups and individuals are demanding public hearings and an Environmental Impact Statement before the Commission votes on the final version of the proposed rule.
' Los T Elbson, M D . Pres,derr Cato' H. Kamsantm. Prestent.rtret W:htt J Hatchet. Pass.Presc'es
- Johr R. Seffrin, Ph.D.. Fece#res, dent Thomas J Godar. M.D Vict. President l Charles P Fehon M.D.. Secrriory AMERICAN : :: LUNG ASSOCIATION J.,,el!""s'i',;'n',7;/C," '
The Chnstmas Seat People
- e 1740 Broadway New York. N.Y. 10019-4374 (212) 315 8700 October 30, 1986 Docketin'g and Service Branch Secretary of the Commission U.S. Nuc3 ear Regulatory Commission Washington, DC 20555 .
Re: F.R. Part II, Titla 10 Parts 19 et.al. "Standards for Protecticn Against Radiation", proposed rule published January 9, 1986
Dear Mr. Secretary:
The American Lung Association and its medical section, the American Thoracic Society submits its official comments on the proposed rule, "Standards for Protection Against Radiation." In recognition of the fact that exposure to radiation can cause lung cancer in humans, the U.S. Nuclear Regulatory Com.nission is strongly urged to adopt standards that result in the lowest possible exposure to radiation from nuclear power facilities.
The propoced standards may permit exposure levels sufficiently high to result in human morbidity and mortality, and should be revised to ensure that worker and community radiation exposure ic reduced to the maximum extent possible.
Resp ctfully submitted, conrad M son, Ph.D.
W Chairperson National Air Conservation Co==1ssion b' l David W. Cugell, M.D. -
Chairperson Occupational Health Committee
/vr ,
bec. Bob Weyruller Allen Rubin Fran Du'ielle IIinns D'Arrigo, NITJ /
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- ~
Accord Rassarch and Education:I AssociDt:s,Inc, 314 West 91st Street New York, N.Y.10024 Phone:(212) 580-3889 31 October, 1986 Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Attn: Docketing and Service Branch
Dear Sir or Madam:
As physicians and scientists concerned with the futures of our patients, ourselves, and the rest of the human race, we object to the NRC's proposed changes in radiation standards (Federal Register 10 CFR Parts 19, et al., Jan. 9, 1986) on several grounds.
- We object to the NRC's underlying assumptions of accepta.ble risk.
- We disagree with the NRC's calculations of estimated risks.
- We call for publication and open discussion of the revised Hiroshima / Nagasaki dosimetry.
- We object to the increase, by the NRC, of permitted exposures for over 65% of the radioisotopes regulated.
- We call for public hearings and an anvironmental impact statement.
The NRC proposes an "acceptable level of risk for a member of the publicd as one per 1,000,0Q0 to one per 100,000 per year, which it considers as "producing no undue concern." The NRC opti-mistically estimates the risk from radiation-induced cancer to be 1.65 deaths por 10,000 person-rens of exposure. With the NRC's page 1
-L ABOR DCN AT E D
U.S. Nuclear Regulatory Commission Page 2 October 31, 1986 recommended exposure limit for the general public of 0.5 rem per year, over an 80-year lifetime, this means:
1.65 deaths /10,000 person-rem x 0.5 rem / year x 80 years / lifetime
= 66 deaths /10,000 lifetimes i.e., one person in every 150 exposed to these doses would be expected to die from cancer as a direct result of the "normal" operations of licensed nuclear facilities. For workers in nuclear facilities exposed to the permitted 5 rem per year, over a working lifetime of 40 years, the expected risk becomes 1 cancer death for each 30 workers.
The NRC has based much of the proposed regulations on publications of the International Committee on Radiological Protection (ICRP) . In ICRP Publication 26, 1977, the Committee estimated that the annual level of exposure of 0.1 rem to the public would result in an "acceptable" number of cancer deaths; but the limit proposed was 0.5 rem per year. This limit was -
rationalized on the basis that the exposures to members of the public would average to lower levels. The NRC has accepted the 0.5 rem yearly limit, although the ICRP has further modified its i recommendations. In Publication 43, 1984, the IRCP states, " ...
for repeated exposures over prolonged periods, that it would be prudent to further restrict this to 1 mSv (0.1 rem) irem each year of lifelong exposure"(1) . Those individuals exposed to the full permitted dose will incur a risk five times greater than "acceptable". ,
The NRC proposed regulations are based on "acceptable risks,"
as discussed above, and an estimated cancer death rate of 1.65 per 10,000 person-rem. If the estimation of the cancer death rate is increased, as we will show it should be, the actual death risk becomes even greater than 1 in 150 (public) or 1 in 30 (worker).
l Current literature supports the linear aose-response model and the relative risk projection for radiation-induced cancer fatalities (2-5). In 1980 the BEIR Committee concluded that when these =edels are applied, the predicted cancer death rate becomes 3.85 per 10,000 person-rem (6). Furthermore, ongoing recalc-ulation of the doses received by Hiroshima-Fagasaki bomb sur-vivors who have and are still developing cancer indicate that the radiation doses received were in fact lower by a factor of two than had been previously calculated (7,8). As the number of
- s U.S. Nuclear Regulatory Cc==ission Page 3 ;
Octcher 31, 1986 l observed cancers remains the same, this would raise the estimated rate of cancer deaths two-fold, to approximately 8 per 10,000 l person-rems (9,10). I The NRC's calculation of risk is based entirely on cancer mortality (11). This method eliminates from consideration all ;
cases of cancer in which the patient survives, or dies of another cause (12). The method ignores the vast amounts of money, i physician time, patient time off work, and anguish spent during .;
the tedious process of diagnostic evaluation, treatment and '
follow-up for "curable" cancer. As health workers, we deal from I day to day with all aspects of disease. We feel it is the job of the NRC, as a public health protection agency, to protect the health of the public by preventing disease, and not to assign allowable levels of exposure to radiation based on mortality statistics alone. Thus for a more co=plete evaluation of the cancer-related impact of radiation exposure, the death rate should be multiplied by a factor of roughly 3 (using the ICRp estimated ratio of total to f atal cancers) (13) , yielding 24 cancers per 10,000 person-rem. Subrtituting this number in the preceding risk calculation, wich the allowed exposure of 0.5 re=/ year over 80 years, we now have a one in ten risk of incurring radiation-induced cancer over a lifetime for a member of che public. For a radiation worker exposed to S rem /yaar over 40 years, the lifetime radiocenic cancer risk becomes one in two.
The effect of dose fractionation is another serious consideration when estimating cancer incidence as a result of exposure to low level radiation. The radiation exposures in Hiroshima and Nagasaki were received in one very short period.
Currently available evidence shows that fractionation of a' -
radiation dose into multiple smaller doses produces higher rates of mutagenesis and cell transformation compared to the total dose given at once (14-17). This strongly suggests that in the low-dose range, fractionation of doses over time increases the cancer production por rem of exposure.
There are other effects of radiation exposure which the NRC ignores. These include synorgistic onhancement of chemical carcinogenesis (18-22), and genetic effects manifested in recossive mutations which will be expressed after the two-generation limit used by the NRC.
We feel, in summary, that the accumulation of scientific data since the publication of Icap #26 overwhelmingly argues in f avor of a decrease in the permissible radiation exposure, rather than the increases proposed by the NRC. These increases apply to internal exposures resulting frem ingested or inhaled radioisotopes, and are acco=plished through the misuso et organ weighting factors and of the "annual limit of intake" concept.
U.S. l'uclear Regulatory Co==ission Page 4 October 31, 1986 Ter bone, thyroid, and skin, previous organ dose limits of 30 rems / year for each are being increased to 50 re=s/ year.
It should also be recognized that the 5 rem /0.5 rem exposure limits for workers and public apply only to "routine releases from ;
nor=al operatiens" of nuclear facilities. Workers can be required ;
without their consent to incur lo rems / year exposure in "special" f situations if their employer dee=s it "necessary." Larger <
exposures to both workers and public from nuclear accidents are !
not cove. red by these regulations. Some 3,000 such "events" were t recorded in 1985 alone (23). !
The "de minimis" rule establishes a dangerous precedent for i allowing unregulated radiation releases and exposures. By the !
linear dose-response hypothess, any given radiation dose i will cause a predictable number of cancers whether the radiation is concentrated in a small number of people a*. high risk, or ,
spread over a large population at lower risk. Small, continuous [
releases unregulated and ignored under the de minimis rule will ;
ultimately have a significant cumulative effect.
j, No safe level of radiatien exposure exists. At a time when evidence is accu =ulating that the hazards of radiatien are greater i than was previously thought, there is no justification for I i increasing any permitted exposures. Rather than yielding to the t
convenience and expansion of the nuclear industry, the NRC should i
, fulfill its mandate to protect the public health.
L
! Respectfully, ,
t .
! c-N ncy E r, F.D. f A
Marjorie Baron, M.D.
(
Leslie Gulick, B.S.N.
- 0..,
( lh Richard Piccioni, Ph.D.
- t
[
i Note: All of the authors are volunteer staff-scientists with l Accord Research and Educational Associates. ,
l' l
l
U.S. Nuclear Regvlatcry Commission Page 5 October 31, 1986 REFERENCES '
- 1. ICRP Publication 43. Principles of monitoring for the radiation protection of the population. Annals of the ICRP 1984; 15:4.
- 2. Radford EP. Radiation dosimetry (letter). Science 1981; 213:602. '
- 3. Radford EP. Human health effects of low doses of ionizing !
radiation: The BEIR III controversy. Radiation Research ,
i 1980; 84:369-394. !
- 4. Furcinitti PS, Todd P. Gamma rays: Further evidence for lack of a threshhold dose for lethality to human cells. l Science 1979; 206:475-6. '
- 5. Borek c. Thu induction and control of radiogenic transformation in vitro: celluler and molecular mechanisms.
Pharmac Ther 1985; 27:99-142.
- 6. Committee on the biological effects of ionizing radiations.
Effects on populations of exposure to low levels of ionizing radiation. Wash, DC: National Academy of Sciences National Research Council, 1980.
- 7. Radford EP. Report on joint Japanese-American workshop held on Feb 16-17, 1983, in Nagasaki, Japan concerning <
reassessment of radiation doses received from atomic bombs ;
in Hirorhima and Nagasaki, August, 1945. .
- 8. Morgan KZ. Radiation dosimetry (letter) . Science 1981; !
213:604. i
- 9. Rotblat J. The risks for radiation workers. Bull Atom Sci 1978; 34:44.
- 10. Radford Ep. Report on joint Jemanese-American workshop held on Feb 16-17, 1983, in Nagasaki, Japan concerning :
reassessment of radiation doses received from atomic bombs in Hiroshima and Nagasaki, August, 1945. [
- 11. Standards for protection against radiation; proposed rule. !
10 CFR Parts 19 et al. Federal Register Jan 9, 1985; 51:1102.
- 12. ICRP Publication 45. Qualitative based for developing a '
unified index of harm., Annals of the ICRP 1985; 15(3):29. *
- 13. ibid.231.
i f.
.o .
U.S. Nuclear Regulatory Cor.missien Page 6 October 31, 1936
- 14. Borek C. Neoplastic transformacion following split doses of X-rays. Br J Radiol 1979; 52:845-848.
- 15. Borek C, Hall EJ. Effect of split doses of X-rays on neoplastic transformation of single cells. Nature 1974; ,
252:499-501.
- 16. Miller RC, Hall EJ. X-ray dose fractionation and oncogenic transformations in cultured scuse embryo cells. Nature l'978; 272:58-60.
i
- 17. Borek C. The induction and control of radiogenic transformation in vitro: cellular and molecular mechanisms.
Pharmac Ther 1985; 27:99-142.
- 18. CiPaolo JA, Donovan PJ, Nelson RL. X-irradiation enhancement of transformation by ben:o(a) pyrene in hamster embryo cells. Proc Nat Acad Sci 1971; 68:1734-37. '
- 19. Borek C, Ong A. Interaction of iono:ing radiation and food pyrolysis products in producing oncogenic transformation in vitro. Cancer Letter 1981; 12:61-66.
- 20. Han A, Elkind MM. Enhanced transformation of mouse 10Tl/2 cells by 12-0-tetradecanoylphorbol-12-acetate following exposure to X-rays or to fission-spectrum neutrons. Cancer
?esearch 1982; 42: 477-483.
- 21. Ishimaru T, Okada H, Temiyasu T, et al. Occupational factors in the epidemiology of leukemia in Hiroshima and Nagasaki. Am J Epidemiol 1971; 93:157-65.
- 22. Whittlemore A, McMillan A. Lung cancer =ortality among US l uranium miners: A reappraisal. J Natl Cancer Inst 1983; 71:489-99.
- 23. Nuclear Power Safety Report: 1985. Wash, DC: Public Citizen, 1986.
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INTERNATIONAL INSTITUTE OF CONCERN FOR PUBLIC HEALTH 67 MOWAT AVENUE, SUITE 343, TORONTO, ONTARIO M6K 3E3 CANADA (416) 533-735' T . U.S Nuclear Regulatory Commission Re: 10 CFR Parts 19, 20, 30, 31, 32, 34, 40, 50, 61 and 70
' Standards for Protection Against Radiation From: Rosalie Bertell, Ph.D, G.N.S.H.
An upda ti ng of radiation protection standards in the U.S. has been needed for some time. However, the proposed revision is already seriously outdated and the revision is in a direction contrary to that of the most recent scientific findings.
The proposed standards are given as a response to:
ICRP 26, adopted 17 January 1977 ICRP 30, adopted July 1978 ICRP 32, adopted March 1981 These documents are more than 5 years old, and they depend on scientific research which predates these ICRP screening dates.
More importantly, even ICRP appears to be changing its position.
One of the most recent ICRP doanments , Publication 43, adopted May 1984, reads in part:
"For stochastic ef fects in members of the public the Commission recom= ends that the committed effective dose equivalent from exposure to radioactive materials in any year be limited to 5 mSv, (500 mrem) and, for repeated exposures over prolonged periods, that it would be prudent further to restrict this to 1 mSv (100 mrem) from each year of lifelong exposure."
This is the first indication that ICRP is admitting that its permissible doses were too high by a factor of at least 5. The U.S. National Academy of Science (BCIR III-1980) estimates of radiation induced cancers are about eight times higher than the old ICRP figures being used by the N.R.C. for its new aule making.
For comparison, the following estimates of radiation induced cancers after one million person rems of exposure are found in the literature:
i This is a re-cycled paper produu, 1
. i l Estimated by i 11-30 years after i lifetime !
I l l l
~ - ~
lICRP (prior to 1984) 1 ----
l 125 I IICRP (after 1984) 1 - - - -
l 600 1 IUNSCEAR 1977 l ----
l 100 l IBEIR III-1980 1 350-719 l 1
IJohn Gofman-1981 1 ----
13,333-4,2551 IRosalie Bertell-1982 1 369-823 1 549-1,6481 I I I I One can recognize here a new concensus that the predicted cancers used by governments (UNS0 EAR) were low by a factor of six to sixteen. There is in addition, a new in-house review of the Hiroshima Atomic Bomb data , being funded by the U.S. Departtient of Energy. Dr. Edwa rd Radford , who is in charge of this review, has told me personally that my estimates of radiation induced cancers based on published research would be doubled after the published reanalysis of the Hiroshima data. This would mean r,oughly 2000 cancers in contrast to the pre-1984 ICRP figure of 125 cancers (a factor of 16 higher).
It is certainly a poor time for the NRC to adopt the seriously flaxed earlier ICRP recommenda tions. Updating again in view of easily predictable, and even already known, changes in radiation risk estimates will be costly in lives, dollars and guvernment credibility. The present outdated document should not be approved.
In addition to these obvious reasons for not finalizing the NRC regulations at this time, I would like to call to your attention two research papers which indicate that the public is suffering harm under present regulations. Relaxing standards at thin moment in time is harmful to the public health. That the proposed NRC regulations will relax standa rds f or some impurt tn t radionuclides and allow higher doses to some body parts will be shown later.
The first research deals with low birthweight infant deaths down-wind of state-of-the-art nuclear power plants which have not experienced serious accidents. Almost one hundred excess low birth-seight inf ant des chs have occured in the first few years of normal operation in the observed down-wind areas (see enclosure) of Wi sconsin.
The seccnd research, which I hope to present at the International Conference on Nuclear Wa ste in Winnipeg, September 1986, deals with a residential exposure to radium and its decay products at a chronic level of 200 to 300 mrem (2 to 3 mSv) per year. This is below the pre-1984 ICRP recommendation for the general public and above the post-1984 reco=mendation. The exposed people suffered a significant drop in white blood cell count (see enclosure), which of course decreases their ability to fight infection. In view of the current U.S. epidemic of / IDS, this inability to fight infection is of great public health concern.
I 4 I
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This empiracle evidence is a second very strong reason for not relaxing radiation exposure standards at this time-Some emissions from nuclear facilities which would actually be ,
allowed to increase under the proposed NRC regulation include:
Radionuclide In Air In Water !
- H- 3 x x ;
i Be- 7 x x Fe- 59 x x Kr- 85 x --- I
- Sr- 89 x x !
- Sr- 00 x x 'l Zn- 95 ---
x -
Ru-106 ---
x I- 129 x x ,
[.
I- 131 x x [
Au-198 x x ;
Ra-226 x x :
i Pu-239 x ---
l l Pu-240 x ---
1 i Note: x indicates that releases exceeding those !
j permitted by ICRP 2 (1959) would be permitted by the l proposed NRC regulations. l Clearly increasing radionuclides in the environment and food chain at this moment in time when both theoretical and empiracle !
evidence indicates that they are more harmful than was recognized !
j by ICRP 26, 30 or 32, is reckless to say the least. l We strongly oppose rule-making on this shakey basis, and urge an immediate updating of the NRC information base. A more cautious t lowering of the permissible dose limits for both work.cs and the i j general public would be a more appropriate response to current i scientific knowledge.
When this proposed regulation is combined with NUREG 0956, one !
t finds that the nuclear industry will be required to spend less on
! safety and reduction of radiation exposures. This is hardly a !
, way to cut costs in an industry dying because of its past bad [
record with respect to safety and public health concerns. i l.
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, s k f Statement of J. William Gunter, Director Criteria and Standards U.S.
Division, Office of Radiation ProJrams
> Environmental Protection Agency Public Hearing on Proposed Revisions to 10 CFR Parc 20 November 10, 1988
' My name is J. William Gunter. I am Director of the i Criteria Programs at the U.S. and Standards Division in the Office of Radiation Envivonmental Protection Agency. We appreciate having the opportunity to address the Commission concerning Code of Federal these proposed revisions to Title 10, Part 20, of the Regulations. ;
10 CFR Part 20 is by far the most widely used U.S.
codification of radiation protection requirements. It directly affects hundreds of thousands of workers employed by NRC
, licensees. It has also served, in the past, as the model upon which States and other Federal agencies, such as OSHA, base their own regulations.
We estimate that the total number of
- individuals occupationally exposed to radiation in any year now exceeds 1.5 million. The importance of 10 CFR Part 20 beyond its direct application to NRC licensees is clear.
As you know, in January of 1987 President Reagan issued new Federal guidance for the protection of workers from radiation.
This guidance was developed through an interagency effort under the leadership of EPA. We were most appreciative of the essential, continuous, and most helpful input from the Nuclear Regulatory Commission during this process, i i
The new Federal quidance represents the first official major revision of radiation protection principles in the United States in almost 30 years. It contains a number of significant l
changes from previous policy. These include introduction of ,
risk-based weighting of doses to different parts of the body and ,
the use of commitsed dose as the primary basis for control of internal exposure. The numerical values of the guidance for ;
maximum radiation doses were reduced, and now explicitly apply to the sum of external and internal doses. These changes brought U.S. policy into general conformance with international recommendations and practice. In addition, numerical guidance <
is now provided for protection of the unborn, and greatly i increased emphasis is placed on eliminating unjustified exposure and on keeping justified exposure as low as reasonably l achievable (ALARA). Finally, the new guidance emphasizes the t 1
importance of instruction of workers and their supervisors on i the basic risks to health from radiation and on basic radiation ,
protection principles; of monitoring and recteding of doses to '
i
, e workors, including cumulativa lifetima dosos: and of the use of administrative control and reference levels for carrying out ALARA programs.
One of the more difficult decisions EPA faced, when it recommended this new guidance to the President, was the choice of the limiting value for annual dose. It would, I believe, be useful to repeat here the considerations that accompanied our recommendations:
"In recommending a limiting val'ae of 5 rems in any single year, EPA has had to balance a number of considerations. Public comments confirmed that, for some beneficial activities, occasional doses approaching this value are not reasonably avoidable. On the other hand, continued annual exposures at or near this level over substantial portions of a working lifetime would, we believe, lead to unwarranted risks.
For this reason such continued annual exposures should be avoided, and these recommendations provide such guidance. ...(T]hese recommendations also continue a system of protection which combines limiting values for maximum dose with a requirement for active application of measures to minimize dose - the ALARA requirement.
This has resulted in steadily decreasing average annual doses to workers (most recently to about one-fiftieth of the recommended limiting value), and, to date, only a few hundred out of millions of workers have received planned cumulative doses that are a substantial fraction of the maximum previously permitted cumulative dose over an occupaticaal lifetime. EPA anticipates that the continued application of the ALARA requirement, combined with new guidance on avoidance of large cumulative doses, will result in maintaining risks to all workers at low levels. EPA will continue to review worker doses with a view to initiating recommendations for any further nodifications of the dose limitation system that are warrented by future trends in worker exposure."
The continuing importance of the considerations I have just cited becometoobvious lor exposure in view of current trends in risk estimates radiation.
We should soon have before us the results of the careful reevaluation of the health effects in Hiroshima and Nagasaki atom bomb survivors, carried out over much of this decade. I do not believe that anyone is predicting that current assessments of risk will go down.
It is our opinion that these draft Final revisions of 10 CFR Part 20 are consistent with the recommendations of the new Federal guidance. They replace the limitation of annual dose to critical organs with the risk-based effective dose formalism that forms a central part of the guidance. The approach to control of internal exposure is now based on committed dose for all radionuclides and, although other methods of implementation are possible, is completely consistent with the guidance. In J
'l f
- its thbulation of Annual Limits on Intake, the Rule incorporates the significant improvements in physiology and dosimetry of radionuclides that have been achieved over the past few decades. It provides explicit limits for protection of the fetus. And it presents these and other aspects of radiation protection regulation in a more streamlined, internally consistent fashion.
In a letter to the NRC dated October 31, 1986, EPA commented on the Proposed revision of 10 CFR Part 20. We are pleased to find that NRC has responded positively to these comments. Only with regard to a relatively minor point, whether reports should be filed for the annual doses of all NRC licensed workers or only for those likely to receive the highest exposures, are we not fully in agreement. We continue to urge the Commission to reconsider this point at some time in the future.
In summary, we support prompt promulgation of this rule.
Accompanying me today is Allan C.B. Richardson, who chaired the Interagency Committee that developed the Federal guidance. We would have. be pleased to attempt to answer any questions that you may Thank you.
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' January 27, 1987 i e l l
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i The President !
! Radiation Protection Guidance to Federal (
Agencies for Occupational Exposure;
) Approval of Environmental Protection i j
j Agency Recommendations j i
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[This reprint incorporates corrections pubbshed m the l Federal Registers of Friday. january 30. and Wednesday. j 2
February 4.1987,l l j
I t E___________.________ ___ _ ____
em rdad a ** Presidential Documents Vol. $2. No. t*
Tuescas Januarv :*.1987 Title 3- Recommendations Approved by the President
.The President Radiation Protection Guidance to Federal Agencies for Occupational Exposure The recommendations concerning Federal radiation protection guidance for occupational exposure transmitted to me by the Administrator of the Environ-mental Protection Agency in the memorandum published below arc approved.
I direct that this memorandum be published in the Federal Register. To promote a coordinated and effective Federal program of worker protection, the Administrator is directed to keep informed of Federal agency actions to implement this guidance and to interpret and clarify these recommendations from time to time, as necessary, in coordination with affected Federal agen-cies. Consistent with existing authority, the Administrator may, when appro-priate, consult with the Federal Coordinating Council for Science, Engineenng and Technology. The Administrator ma.' also, when appropriate. Issue inter-pretations and clarifications in the Federal Register.
Approved: January 20,1987 k Q n.ume wo. mm-u hiemorandum for the President FEDERAL RADIATION PROTECTION GUIDANCE FOR OCCUPATIONAL EXPOSURE This memorandum transmits recommendations that would update previous guidance to Federal agencies for the protection of workers exposed to ionizing radiation. These recommendations were developed cooperatively by the Nu-clear Regulatory Commission, the Occupational Safety and Health Adminis.
tration, the hiine Safety and Health Administration, the Department of De-fense, the Department of Energy, the National Aeronautics and Space Admin-istration, the Department of Commerce, the Department of Transporte. tion the Department of Health and Human Services, and the Enytronmental Protection Agency. In addition, the National Council on Radiation Protection and hieas-urements (NCRH. the National Academy of Sciences (NAS). the Conference of Radiation Control Program Directors (CRCPD) of the States, and the Health Physics Society were consulted during the development of this guidance.
Executive Order 10831, the Atomic Energy Act. as amended, and Reorganiza-tion Plan No. 3 of 1970 charge the Admmistrator of the Environmental Protection Agency (EPA) te ". . . advise the President with respect to radi-ation matters, directly or indirectly affecting health, including guidance for all Federal agencies in the formulation of radiation standards and in the estab-lishment and execution of programs of cooperation with States." This guid.
ance has histortcally taken the form of qualitative and quantitative "Federal Radiation Protection Guidance." The recommendations transmitted here would replace those portions of previous Federal guidance (25 FR 44021 approved by President Eisenhower on hiay 13,1960, that apply to the protec-
F Q o, .
~
nderal Resister # Vol. 30. No. C Tuescov. ianucey 27 m7 / Presioentiai Dacuments 2323 non at workers exoosed to somzine raciation. The portions et that eutdance wnich apply to exoosure of the senerai pubite would not ce cnansed by these recommendations.
These recommenaations are based on consideration of (1) current scientific understanoine of effects on health from ionizine raatation. i:) recommenda.
tions of international anc national organizations involved in raciation protec-tion. IJ) proposed "Federal Radiation Protection Guidance for Occupational Exposure" published on lanuarv 23,1981 (46 FR 7836) and public comments on that proposed guidance, and (4) tr.e collective expenence of the Federal neencies in the controi of occupational exposure to ionizina radiation. A summary of the considerations that led to these recommenaations is provided below. Publ ic comments on the previously proposed guidance aind a response to those comments are contained in the document "Federal Radiation Protec-tion Guidance for Occupational Exposure-Response to Comments" (EPA
'i 0/1-84-0111. Single copies of this report are available from the Program Manasement Office I ANR-458). Office of Radiation Procrams. U.S. Environ-mental Protection Agencv. Washinston. D.C. 20460: telephone 1202) 475-8388.
Bachcourd
.\ review of current raciation protection sutoance for warners ocean in 1974 with the formation of a Federalinterasency comtmitee oy EPA. As a result of the deliberations of that committee. EPA puolished an ' Advance Notice of Proposed Recommencations and Future Public Heanns ' on September 17.
1979 (44 FR 53785). On lanuary 23,1981. EPA published "Federal Radiation Protection Guidance for Occupt.tional Exposures: Proposed Recommenda-tions. Request for Written Comments. and Public Hearings" (46 FR 7836).
Public heannus were held in Washington. D.C. [Apnl 00- 3. 1981); Houston.
Texas IMay 1-2. 1981): Chicago. Illinois (May 5-6. 1981). and San Francisco.
California (May tl-9.1981) (40 FR 15:05). The public comment period closed Julyti. 1991 (46 FR 2ti3571. On December 15,1982, representatives of the ten Federal agencies noted above. the CRCPD. and the NCRP convened under the sponsorship of the EPA to review the issues raised in public comments and to complete development of these recommendations. The issues were carefully consioerea dusina a senes of meetincs, and the conclusions of the workins aroup nave provided the basis for these recommendations for revised Federal cuidance.
EPA has also sponsored or conducted four maior studies in support of this review or occucationai radiation protection eutdance. First. the Committee on the Diolostcal Effects of ionizing Radiations. National Academy of Sciences-National Research Council reviewed the scientific data on health nsis of low levels of iomzine radiation in a report transmitted to EPA on July : .1980:
"The Effects on Popuiations of Exposure to Low Levels of loniztna Radiation:
19807 %tional Academy Press. Washmaton. D.C.1980. Second. EPA has published two studies of occupational radiation exposure: "Occupational Exposure to ionizma Radiation m the United States: A Comprenensive Sum-mary for the Year 1975" (EPA 5:0/4-80-0011 and "Occupational Exposure to lonizma Radstion in the United States: A Comprehensive Review for the Year 1980 4-d Summary of Trends for the Years 1960-1985" (EPA 5:0/1-84-005).
Third the Agency sponsored a study to examine the chances m previously denvec concentration limits for intake of radionuclides from air or water that resuit from use of uo to date dosimetnc and biolosteal transport models.
These are presented in Federal Guidance Report No.10. "The Radioactivity Concentration Guides: A New Calculation of Denvec Limits for the 1960 Radiation Protection Guides Reflectine Updated Models for Dostmetry and Biolo ical Transport" f EPA 5:0/1-84-0101 Finally, the cost of implementme the enances in Federai suidance proowsed on January 23.1981 was surveyed and the findmes published in the two volume report: ' Analysis of Costs for Comonance with Federal Radiation Protection Guidance for Occucational Escosure: Volume I-Cost of Comoitance ' t EPA 5:0/1-83-413-11 ano "Volume li--Case Study Anaivsis of the impacts" IEPA 5 0/1-83-413-21. These F.PA
0324 Federal Revist:r i Vol. 52. No. C Tacso:v. lanuarv ."' W87 Presidenttal Docum:nts reports are available from Nananai Technical Information Service. U.S. De-partment of Commerce. 5285 Port Royai Road. Sprmeheld. Viramia .:2161.
The interagency review of occupational raatation protection nas conttrmea the need for revising the orevious Federal sutdance, wnich was promuisateo in 1900. Since tnat time knowiease of the effects of iomzine radiation on numans has increased subs'antiallv. We now nave a greativ improveo ability to estimate nsk of harm due to irractation of mdividual organs and tissues. As a result. some of the old tiumerical suides are now believea to be less and some more protective than formeriy. Other risks. specifically those to 'ne unborn.
are now considered to be more significant and were not addressed by the oid guidance. These disparities and omissions should be corrected. Drawms on this improved knowledge the International Commission on Radiological Pro.
tection t!CRP) published. in 1977. new recommenoations on radiation protec-tion philosopny and hmits for occupational esposure. These recommendations are noW in use,in whole or substantial part. in most other countnes. We have considered these recommendations. amons others and believe that it is appropnate to adopt th generai features of the ICRP approacn m radiatwn protection sutdance to Federai agencies tor occupanonal esposure. In two cases. protection of the unborn and the management at lons. term esposure to ;
internally deposued radioactiutv. we nase found it advisable to make audi-tions.
There are four types of possible effects on health from esposure to ionirms radiation, The first of these is cancer. Cancers caused by radiation are not different from those that hase been historically observed. whether trom known or unknown causes. Althouen radiosen'.c cancers have been observed in humans over a ranse of higher doses. few useful data are available for defining the effect of dosas at' normal occupattonal levels of exposure. The second type of effect is the induction of hereditary effects in descendants of esposed persons. The seventy of hereditary effects ranges from inconsequen-tial to fatal. Although such effects have been observed in npenmental animals at high doses, they have not been confirmed in studies of humans.
Based on extensive but incomptete scientific evidence. it is prudent to assume that at low levels of esposure the nsk of incurnne either cancer or nereditary effects is Imcarly related to the dose received in the relevant tissue. The seventy of any such effect is not related to the amount of dose received. That is. Once a cancer or an hereoitary effect has been induced. ci severite is indepenuent of the dose. Thus tc.r these two types of effects. it is assumeu that there is no t.ompietely risi. tree ieset of esposure.
The third type includes a sariety of effects for which the degree of damase li,e. seserity) appears to depena on the amount of dose received and for which there is an effective thresnold below which chnically observable etfects do not occur. An example of sucn an effect is radiation sickness ssndrome, which is observed at high doses and is fatal at sery high doses. Exampies of lesser effects include opacification of the lens of the eye. erythema of the sim, and temporary impairment of fertihtv. All of these effects occur at relativeiv high doses. At the levels of dose contemplated under both the prenous Federal eutdance and these recommendations. chnically observable examples of this third type of effect are not known to occur.
The fourth type meludes effects on children who were esposed m utem Not only may the unborn be more sensitive than adults to the mduction of malformations. cancer. and herecitary effects, but recent studies nave drawn renewed attention to the risk of severe mental retardation from esposure of the unborn dunns certam penoas of presnancy. The risk of less severe mental retardation appears to be similarly elevated. Althoush it is not yet clear to what estent the frequency of retardation is propornonal to the amount of dose Ithe data available at occupational levels of esposure are hmitedt it is prudent to assume that prnportionailty eststs.
The nsks to health from esposure to low levets of onizma raatation were reviewea for EPA by the NAS m reports puchshed m 1972 and m 1980.
- 'ederai Reitister i Vol. 52. L.17 Tuesosv. lantierv 3 1987 Rcsioential Docurmnts 2325 Resproma car.cer there continues to be diviced opinion on how to mterpolate between the absence of radiation effects at zero dose and the observed effects of radiation Imostly at hish doses) to estimate the most probable effects oflow doses. Some scientists believe inat available data bMt support use of a linear model for estimatma such effects. Others nowever, bsheve that other models, which usually predict somewhat lower nsks. provse better esumates. These C:.'arences of opmion have not been resolved to date by studies of the effects uf racistion in humans, the most important of which are those of the Hiroshi-ma and Nagasaki atom bomb sumvors. Studies are now underway to reas-sess radiation dose calculations for these survivors and in turn to provide improved estimates of risk. It will be at least several years before these reassessments and estimates are completed. and it is not likely that they will conclusivelv resolve uncertamties in esumating low dose effects. EPA is momtonne the progress of this work. When it is completed we will initiate
' reviews of the nsks oflow levels of radiation in order to provide the barts for any indicated reassessment of this guidance.
In spite of the above uncertainties estimates of the nsks from exposure to low levets of iomzma radiation are reasonaoly weil bounded. and the averase worker is believed to mcur a relauvely smati nsk of harm from radiation. This situation has resulted from a system of protection which combmes limits on maximum dose with acuve application of measures to minimize doses withm these itmits. These recommendations contmue that approach. Approximately 1.3 million workers were employed in occupations in which they were poten.
tially exposed to radiation la 1980, the latest year for which we have compre.
hensive assessments. About half of these workers received no measurable occupational dose. In that year the averase worker measurably exposed to external radiation received an occupationai dose equivalent of 0.2 rem to the whole body, based on the readings of individual dostmeters worn on the surface of the body. We estimate (assumme a linear non. threshold modell the increased risk of premature death due to radiation. induced cancer for such a dose is approximately 2 to 5 in 100.000 and that the increased risk of senous hereditary effects is somewhat smaller. To put these estimated nsks in perspective with other occupational hazards, they are comparable to the observed risk of job related accidental death in the safest mdustnes. whole, sale and retail trades. fur which the annuai accidental death rate averased about 5 per 100.000 from 330 to 1984. The l' S. averase for all industnes was 11 per 100.000 in 1984 and W5.
These recommendations are based on the assumption that nsks cf iniu:y from exposure to radiation should be considereo m relation to the overall benetit derned from the activities causing the exposure. This approach is similar to that used by the federal Radiation Council (FRC) in developina the 1960 Federal guidance. The FRC said then. "Funaamentally, settma basic radiation protection standards mvolves passmg judaraent on the extent of the possible health hazard society is willing to accept in order to realize the knowii beneitts of radiation.' This leads to three casic pnnciples that have governed radiation protection of workers m recent decades in the United States and in most other countries. Although the precisc formulation of these pnnciples has evolved over the years. their intent has contmued unchanged. The first is that any 3Clivity involving oCGoanonal exposure should be determined to be useful enough to society to wurrant the exposure of workers:i.e.. that a fmding be made t! at the activity is "justified". This same principle applies to virtually any human endeavor which involves some nsk of injury. The second is that, for tustified activities. exposure of the work force should be as low as reasonably achievable (commonly designated by the acronym "ALARA"); this has most recently been charactenzed as "optimization" of radiation protection by the international Comniission on Radiolostcal Protection !!CRP). Finally to provide an upper hmit on nsk to individual workers. "limitation" of the maximum illowed mdividual dose is required. This is required above and bevono the protection provided by the i:rst two principles because their pnmary oblective is to minimize the total harm from occupanonal exposure in
- - - - - ~
e .
2838 Federal Resister / Vol. 52. No. t7 / Tuesd:v. januarv v.198'/ / Pr:sidential Docum:nts the entire work force: they do not limit the way that harm is istnbuted among individual workers.
The pnnciple that activities causmg occupational exposuto should produce a net benefit is important in radiation protection even though the judgment of net benefit is not easily made. The 1960 guHance says:"There should not be any man made radiation exposure without the expectation of benefit resulting from such exposure . . And "It is basic that exposure to radiation should result from a real determination of its necessity." Advisory bodies other than the FRC have used language which has essentially the same meanma. In its most recent revision of international guidance (1977) the ICRP said " , no practice shall be adopted unless its introduction produces a positive net benefit." and in slightly different form the NCRP. in its most recent statement (1975) on this matter, said * . all exposures should be kept to a practicable minimum: . . . this pnnciple involves value judgments based upon perception of compensatory benefits commensurate with nska. preferably in the form of realistic numencal e;timates of both benefits and nsks from activities involv-ing radiation and alternative means to the same benefits."
This pnnciole is set forth in these recommendations in a simpic form: "There should not be any occupational exposure of workers to ionizing radiation without the expectation of an overall benefit from the activity causma the exposure " An obvious difficulty in making this ludgment is the difficulty of quantifying in comparable terms costs (including risks) and benefits. Given this situation. informed value judgments are necessary and are usually all that is possible. It is perhaps useful to observe. however. that throughout history individuals and societies have made nsk benefit judgments, with their success usually depending upon the amount cf accurate information available. Since more is known about radiation now than in previous decades, the prospect is that these judgments can now be better made than before.
The preceding discussion has implicitly focused on maior activities,i.e those instituting or continuing a general practice involving radiation exposure of workers. This pnnciple also applies to detailed management of facilities and direct supervision of workers, Decisions on whether or not particular tasks should be carned out (such as mspectmg control systems or acquinns specific experimental datal require judgments which can. in the aggregate. be as significant for radiation protection as those justifymg the basic activities these tasks support.
The principle of reduction of exposure to levels that are "as low as reasonably achievable" f ALARA) is typically implemented in two different ways. First it is applied to the enameenna design of facilities so as to reduce, prospcctively, the anticipated exposure of workers. Second it is applied to actual operations:
that is, work practices are desianed and carried out to reduce the exposure of workers. Both of these applications are encompassed by these recommenda-tions.' The pnnciple applies both to collective exposures of the work force and to annual and cumulative individual exposures. Its application may therefore require complex ludgments, particularly when tradeoffs between collective and individual doses are involved. Effective imp'ementation of the ALARA pnnciple mvolves most of the many facets of an effective radiation protection program: education of workers concernma the health risks of exposure to radiation: training in regulatory requirements and procedures to control expo 9ure: monitonng, assessment, and reporting of exposure levels and doses: and management and supervision of radiation protection activities, including the choice and implementation of radiation control measures. A cornprehensive radiation protection program will also melude, as appropnate.
- The recomendation that Federal agencies. throuan thett regulations operationai procedures and other appropriate means. maintain cases At. ARA is not intenced to espress. and therefore should not be interpreted as espressing a view whether the ALARA concept shouid ccnstitute a duty of care in tori htisation Implementation of the ALARA cancept requires a comptes subiectne balancine of scientific. economic and socias ! actors esnerath resuittr's in the attain.
ment of nerate dose leseis significanuv beiow the masimam permitted by ' tis suicance
Federal Resister
- W1. 32. No.17 ' Tuescov. lonuarv .* PJ87 ' Prcsiu:ntias Documents 2327 properiy tramed and quainfieo radiation protection personneh aueountely designed operated, ano maintained facilities and equipment: ano quainty assurance ano aucit procedures. Anotner important aspect of such programs is maintenance of records of cumulative exposures of workers and implementa-tion of appropriate measures to assure that lifetime exposure of worxers repeatedly exposed near the limits is mimmtzed.
The types of work ano activity wnich involve worker exposure to raciation vary greatly and are aaministered by many different Federal ano State agencies under a wide variety of lesisiative authorities. In view of this complexity. Federal radiation proteciton guidance can address only the broad prerequisites of an effective ALARA program, and regulatotv authorities must ensure that more detailed requirements are identified una carned out. In doins this, such authonties may find it useful to establish or encourase the use of 11 admmistrative control levels specifying. tor specific catesones of worners or work situations, dose levels below the limitins numencal values recomtnend-ed in this guidance: 2) reference ievels to indicate the neeo for such actions as recording. investigation. and intervention: and 3) local soais for Smitins individual and collective occupational exposures. Where tne enforcement of a general ALARA requirement is not practical under an agency's statutory
.iuthonty, it is sufficient that an agency endorse and encourase ALARA. and establish sucn regulations wnsen result from ALARA findtnes as may be use ul and appropnate to meet the ooiectives of this sutdance.
The numerical radiation protection suidance which has been m effect since 1960 for limiting the maximum allowed dose to an individual worker is based on the concept of limattna the dose to the most entically exposed part of the body. This approach was appropnate, given the limitations of scientific information availatie at that time. and resulted in a set of five mdependent numerical guides for maximum exposure of al the whole body, head and trunk, active blood forming organs. sonads. and lens of eye: bl thyroid and skm of the whole body: c) hands and forearms feet and ankles: di bone, and el other organs. A consequence of this approach when several different parts of the body are exposed simultaneously is that only the part that recaives the hishest dose relative to its respective guide is decisive for limiting the dose.
Current knowledge permits a more comprehensive approach that takes into account the separate contnbutions to the total nsk from each esposed part of the body. These recommencatinns mcorporate the dose weighting sy stem mtroduced for this purpose by tne ICRP in 1977. That system assigns weisnting factors to the vanous parts of the body ior the risks ct Lrthat cancer and serious prompt genetic effects (those m the first two generationst these factors are chosen so that the sum of weighted dose equivalents represents a risk the same as that from a numencally equal dose equivalent to the whole body. The ICRP recomment inat the effective it.e. weighted) dose equivalent incurred in uny year Se limited to 5 rems. Dased on the public response to the similar proposal published bv EPA in 1981 and federal esperience with comparable esposure limits. the Federal agencies concur. These recommenda-tions therefore replace the 1960 wnole body numerical suides of 3 rems per quarter and 5lN-18) rems cumulative dose equivalent lwhere N is the ase of the worker) and associated entical organ guides with a lim:tmg value of 5 rems effective dose equivalent incurred in any year. Supplementary limiting values are also iecommended to provide protection against those nealth effects for which an effective tnreshold is believed to exist.
In recommendme a limittne value of 5 rems in any single year. EPA has nad to balance a number of considerations. Public comments conittmed that. for some benefictal activities, occasional doses aproachins this value are not reasonably avoidable. On the other hand. contmued annuci esposures at or near this level over substantial portions of a workins lifetime would. we behere. lead to unwarranted nsks. For this reason such continued annuai exposures should be avoided. and these recommendations provide sucn suid.
ance As noted earlier, these recommendattons also continue a ssstem of protection wnich combines limitma vaiues for maumum core with a require-
- 328 Federal Revister i Vol. 32. .No.17 Tuescev.lanuerv .:7 W87 ' Pr; sic:ntial Documents ment for active application of maasures to minimize doses-the ALARA requirement. This has resulted a steadily decreasma averase annual dosas to workers (most recently to a'caut t one fiftieth of the recommended limmna value), a'nd to date, only a few hundred out of millions of workers nave received pianned cumulative doses that are a subatantial fraction of the maximum previously permitted cumulative dose over an occupational lifetime.
EPA anticipates that the contmued application of the ALARA requirement.
combined with new guidance on avoidance of large cumulative doses. wiil result in mamtaining nsks to all workers at low levels. EPA will continue to review worker doses with a view to initiating recommendations for any further modifications of the dose limitation system that are warranted bs future trends m worker exposure.
Certain radionuclides. If inhaled or ingested, may remam in and conimue to irradiate the body for many years. These recommendatbns provide that radionuclides should be centained so as to minimize mtake to the extent reasonably acntevable. When avoidance of situations that may result in such intake is not practical the recommendations distinguish between pre expo-sure and post exposure situations. With respect to the former. Federal aren.
cies should base control of prospective mternal exposure to radionuclides te s.
facihty design morutonne. traimne. and operatmo procedurest upon the entire future dose that may result from any intake (the committed dosel. not iust upon the dose accrued in the year of intake. This is to assure that. pnor to exposure to such matenals. proper account is taken of the nsk due to doses in future years.
With respect to post exposure situations. most siemficant internal exposure to radionuclides occurs as the result of inadvertent intakes. In the case of some long. lived radionuclides, it may also be difficult to measure accurately the small quantitles corresponding to the recommended numencal guidance for control of committed doses, in such cases, when workers are inadvereently exposed or it is not otherwise possible to evoid intakes in excess of these recommendations for control of committed c.ase. it will be necessary to take appropria:e corrective action to assure control has been reestablished and to properly manase future exposure of the worker. In regard to the latter requirement, provision should be made to contmue to monitor the annual dose received from radionuclides in the body as lone as they remain in sufficient amount to deliver doses sismficant compared to the limittne values for annuai dose. These recommendations extend those of the ICRP because it is appro, pnate to maintain active management of workers who exceed the guidance for committed dose m order that mdtvidual differences m retention of sucn materials .n the body be monitored. and to assure, whenever possible. con.
formance to the limitma values for annual dose.
These recommendations also mcorporate guidance for hmiting exposure of the unborn as a result of occupational exposure of female workers, it has lone been suspected that the embryo and fetus are more serssitive to a vanety of effects of radiation than are adults. Althouah our knowledge remams incom-plete, it has now become clear that the unborn are especially subject to the nsk of mental retardation from expc - o radiation at a relatively early phase of fetal development. Available t itific evidence appears to indicate that this sensitivity is greatest dunng Se penod near the end of the hrst inmester and the beemnmg of the second tnmester of pregnancy, that is, the pened from 8 weeks to about 15 weeks after conception. Accordmaly, wnen a woman has declared her pregnancy, this guidance recommends not only that ,
the total exposure of the unborn be more limited than that of adult workers. '
but that the monthly rate of exposure be further inmited m order to provide Editional protection. Due to tne mcomplete ttate of knowledee of the transfer of radionuclides from the mother to the unborn (and the resultma uncenatnty in dose to the unbornl. in those few work situations where mtake of radionu.
clides could normally be possible it may also be necessary to institate measures to avotd suc;. intakes ov presnant women m order to satisfy tnese recommencations.
. s Federal Register s Vol. 5 :. No.17 / Tuescev. Januerv r 1987 . l> residential Docum:nts 2329 The health protection obiectives of this guidance for the unborn shouid be aCitteVed in aCCordance With the provisions of Title Vil of the Civil Riehts Act of 1904. as amended, with respect to discrimination in employment practices.'
The guidance applies only to situations in which the worker has voluntarily made her pregnancy known to her employer. Protection of the unborn may be achieved through such measures as temporary job rotation. worker self.
selection, or use of protective equipment. The guidance recognizes that protec.
tion of the unborn is a joint responsibility of the employer and worker.
Workers should be informed of the risks involved and encouraged to voluntar.
ily make pregnancies known as early as possible so that any temporary arrangements necessary to modify exposures can be made. Converselv, em.
players should make such arrani,ements in a manner that mmimtres the impact on the worker.
The recommended numerical guidance for limitina dose to workers applies to the sum of dose from external and internal sources of radiation. This proce-dure is recemriended so as to provide a sinale hmit on the total risk from radiation exposure. Therefore. in those cases where both kinds of radiation sources are present. decisions about the control of done from internal sources should not be made wuhout equal consideration of their implication for dose from external sources.
The guidance emphasizes the importance of recordkeepmg for annual. com.
mitted. and cumulative (lifetime) doses. Such recordkeeping should be de-signed to avoid burdensome requirements for cases in which doses are insignificant. Currently. *egulatory records are not generally required for doses small compared to regulatory limits for annual external and internal doses.
Under this guidance such regulatory practices would contmue to be approprt- '
ate if due consideration is given to 'he implications of summing internal and euernal doses and to recordkoping needs for assessma cumulative doses. To the extent reasonable such records should be established on the basis of individual dosimetry rather than on monitoring of exposure conditions.
In summary many of the important changes from the 1960 guidance are structural. These include introduction of the concept of risk based weightine of doses to different parts of the body and the use of committed dose as the primary basis for control of internal exposure. The numerical values of the guidance for maximum radiation doses are also modified. These changes orina this guidance into general conformance with international recommenoations and practice. In addition, guidance is provided for protection of the unborn.
and increased emphasis la placed on eliminattna uniustified exposure and on keepine justified exposure as low as reasonably achievable. both lone. stand, ing tenets of radiation protection. The guidance emphastres the importance of instruction of workers and their supervisors monitortna and recordma of doses to workers, and the use of administrative control and reference lesels for carrytna out A1. ARA programs.
These recommendations apply to workers exposed to other than normal background radiation on the lob. It is sometimes hard to identify such workers becat.se everyone is exposed to natural sources of radiation and many occupational exposures are small. Workers or workplaces subject to this guidance will be identified by the responsible implementing agencies. Agen.
cies will have to use care in determming when exposure of workers ooes not need to be regulated. In making such determtnations asencies should consider
'The Ceul Rights A6t of 1964 as amenced preuces inat 11 shalt be en unlawfW emc6osment precoce for an emptoser it s to f ail or refuse to rure or to eacharse ans incaidual. or otrerwise to dacriminate against any anomdust with respect to tus compensanon. terms condmons or trmines ot empiosment. tecause et such inomc.al s - ses at 121 to hmit seeresste or dessih tus empiosees or a:pucants for e.apio> ment in ans was wmch woWd depme or 'eno to deprne anv indindual of empiosment opportunities or einerwise easerien af fect his stat s es .n empionee. because of suca tnamdual s ses '42 U S C, xce-liall The Pvenancs Dsscriminanen Act of 19's def nes because of ses a mewde twcasse of er on t** h4s s or tretnanct cnudNrth or re'ated mecicas condit: ens i4;(J S C cCOW!
e s 0830 Federal Rettister i Vol. 52. No.17 ! Tuesf av, lanuary 27,1987 / Presid:nnal Docum:nte both the collective dose which is likely to be avoided through regulation and the maximum individual doses possible.
Implementation of these recommendations will require changes that can reasonably be achieved only over a period of time. It is expected that Federal agencies willidentify any problem areas and provide adequate ilexibility and the necessary transition periods to avoid undue impacts, while at the same time assuring reasonably prompt implementation of this new guidance.
Upon implementing these recommendations, occupational exposure should be reduced. It is not possible to quantify the overall exposure reduction that will be realized because it cannot be predicted how efficiently these re:omrt inda-tions will be implemented or how much of existing exposure is unnecennary.
These recommendations reditce the maximum whole body dose that workers may receive in any one year by more than half (i.e., from 3 rems per quarter to 5 reme per yearl. require that necessary exposure to internal tsdioactivity be controlled on the basis of committed dose, require that internal and external doses be considered together rather than separately, and provide increased protection of the unborn. We also expect the strengthened and more explicit recommendations for maintairline occupational exposure "as low as reason.
ably achievable" will improve the rad;ation protection of workers. Finally, these recommendations would facilitate the practice oi radiation protection by introducmg a self consistent system of limits in accordance with that in practice internationally.
Recommendations The followmg recommendations are made for the guidance of Federal agen.
cies in their conduct of programs for the protection of workers from ionizing radiation.
- 1. There should not be any occupational exposure of workers to ionizing radiation without the expectation of an overall benefit from the activity causing the exposure. Such activities may be allowed provided exposure of workers is limited in accordance with these recommendations.
- 2. No exposure is acceptable without regard to the resson for permitting it, and it should be general practice to maintain doses from radiation io levels below the limiting values specified in these recommendations. Therefore. it is fundamental to raciation protection that a sustained effort be made to ensure that collective doses, as well as annual. committr d. and cumulative lif time individual doses, are maintained as low as reasonably achievable (c' r AA).
economic and social factors being taken into account.
- 3. In addition to the above recommendations radiation doses received as a result of occupational exposure should not exceed the hmitme saiues for assessed dose to matvidual ivorhers specified below. These are gtven sepa-rately for protection against different types of effects on health and apply to the sum of doses from external and internal sources of radiation. For cancer and genetic effects. the limiting value is specified in terms of a derived quantity called the effective dose equivalent. For other health effects, the limitine values are specified in terms of the dose eqi.ivalent ' to specific organs or tissues.
' Dose equa aient ' is the product c f ibe absorted case,4 weats f actor mMich var:es w nh the enern end h pe of radiation and otPer modtfung iactors as cefinea by the (niernation 6 Commission on Red.aison Unos at:4 Measurements i
e .
Federsi Resister i Vol. 52. No.17 ' Tueso:v. janu-tv 2r 1987 / Presioential Docum:nts 2331 Cancer ana Genetic E//ects. The effective dose equivalent. H i receiveo in any year by an adult worker snould not exceed 5 rems 10.05 sievertl.8 The effective dose equivaient is defined as:
H =
{ q H. ,
T where we is a weightina factor and He is the annual dose equivalent averaged over organ or tissue T. Values of w, and their corresponaing organs arid tissues are: -
Gona a s .. . . . . . . . . . - . . a :'s -
Dre a e t: .. . . . . . . . . . - . -. .._ -. Ois Red t>one marrow .. - . . ~ . . . . . - _ . 0 12 tmna s .. . . . . . . . . . . _ . . . . . . . ~ . . . _ . . . . . . . . . oi:
Th ytr.4 . . _ . . - . . _ 0 03 sone sunaces.. . . . . . . . - . . . . . . . _ _ . _ . . . . _ . . - _ a 03 Reenainder 4 - . . ~ . . . - . . . . . . . . . . . . . - ..- 03o For the case of umform irradiation of the whole body, where He may be assumea the same for eacn organ or tissue the effective dose equivalent is equal to the dose equivalent to tne whole body.
Other Health Effects. In addition to the limitation on effective dose equwalent.
the dose equivalent. Hr. received in any year by an adult worker snould not exceed 15 rems (0.15 sievert) to the lens of 'he eye, and 50 rems (0.5 sievertl to any other organ, tissue (including the skin). or extremity
- of the body.
Additional limiting values which apply to '.he control of dose from internal exposure to radionuclides in the workplace are specified in Recommendation i 4. Continued exposure of a worker at or near the limiting values for dose l received in any year over substantial portions of a working lifetime should be avoided. This should normally be accompli.=hed through application uf appro-pnate radiatioit protection practices established under Recommendation 2.
- 4. As the pnmary means for controllina internal exposure to radionuclides, agencies should require that radioactive matenals be contained. to the extent I reasonably achievable. so as to minimize intake. In controlhna internal expo-
! sure consideration should also ba given to concomitant external exposure.
The control of necessary exposure of adult workers to radioactive matenals in the workplace should be designed, operated. and rnonitored with aufficient frequency to ensure that, as the result of intake of radionuclides in a vear, the foliawing hmstine values for centrol c/ tbc workp/cce are satisfied; tal the
.inticipated magnitude of the committed effective dose equivalent from such intake plus any annual effectne dose equivalent from external exposure will not exceed 5 rems (0.03 sievertl. ano (b) the anticipated magmtude of the commuted dose equivalent to any orsan or tissue from such intake plus any annual dose equivalent from external exposure will not exceed 50 rems 10.5 sievert). The committed effective dsse equivalent from internal sources of rr.diation. H 3e. is defined as:
E,50 " N T,50
- I I
d The unit of Jese equisaient in tre ssstem of special quanuties for toniting tactshon currentiv in use on ne United States is the re's in the recenov.acopied tnternationai esstem 151) tne unit of dose eqmaient is the ~ s;esert One s,esert tuo reve i a Remainser' means the itse o"ter ergans Isuch as hser. kidness spten trea mvmus.
- .crenats pancreas. stomaca smati inteshne. urper iaree intest ne. ano lower taree it'estine but l netudtne satrL tens et the ese. .no e tre*utiest with the hisneet ocses The weiennes nactor for each saca organ is c on l
- ' F stremity means the forearms anc mands or tre lower 6ess and feet l
1 Federal Resister i Vol. 52. No.17 i Tuesoav. januarv r 127 Presidential Documents
- 332 wnere wt is ceitned as in Recommenaanon 3 ano the committed dose equivalent. Hri. is the sum of all dose equivalents to organ or tissue T that may accumulate over an individual's anticipated remaining lifetime ttaken as 30 yearsi from radionuchdes tnat are retamed in the bocy. These conoitions on committea doses should provide tr.e pnmary basis for the control of internal exposure to radioactive matenais.*
In circumstances where assessment of actual intake for an individual worker shows the ar>ove conditions for centrol of intake have not been met.
agencies should require thet appropnate corrective action be taken to assure control has been reestablished and that future exposure of the worker is appropnately managed. Provision should be made to assess annual dose equivalents due to radionuclides retained m the body from such intake for as long as they are siemficant for ensunna conformance with the limitine saiues specified in Recommendation 3.
- 5. Occupational dose equivalents to individuals under the age of eishteen should be limited to one tenth of the values specified in Recommendations J and 4 for adult workers.
& Exposure of an unborn child should be less than that of adult workers Workers should be informed of currrent snowledge of risks to the unoorn' from radiation and of the responsibility of both employers and workers to mimmize exposure of the unborn The dose equivalent to an unborn as a result of occupational exposure of a woman wno nas declared that she is pregnant should be mamtained as low as reasonaoly achievable. and in any case should not exceed 0.5 rem 10005 sievert) dunne the entire gestation penod.
Efforts should be made to avoid substantial vanation above the uniform monthly exposure rate that would satisfy this hmittna value. The limitina value for the unborn does not create a basis for discnmination. und should be achieve 'in conformance with the provisions of Title Vil of the Civil Rights Act of 1964. as amended, renarding discrimination in employment practices, in.
cluding hinna, discharse. compensation. and terms. conditions. or pnvdeses of employment.
7 Individuals occupationally exposed to radiation and managers of actisities involvma radiation should be instructea en the basic risks to heaith from toriizine radiation and on basic radiation protection pnnciples. This shound. as a minimum. include instruction on the somatic lincludins in uterol ana genetic effects of ionizine raciation. the recommendations set forth in Federai radi-ation protection autdance for occupational exposure and apphcable resuta-tions and operatina procedures wntch tmpiement this uuidance. the seneral lesels of nsk and appropriate rcdtation protection practices for their work situations. and the responsibilities of indty' dual workers to avoid and mini-mize exposure. The degree and type of instruction that is appropnate will depend on the potential radiation exposures mvolsed.
el Appropriate monitonna of workers ano the work place should be performeo and records kept to ensure conformance with these recommendations. The I
I rspes and accuracy of monitanna methods and procedures utilized should be f penocically reviewed to assure that appropnate techniques are bema compe-tently applied Maintenance of a cumulative record of hfetime occupational doses for each worker is encouraged. For doses due to intake of radioactive matenais, the committed effective dose equwaient anc the quantity of eacn radionucade in the body snould be assessed $nd recorced. to the extent practicaole. A sammary of annual. cumulattse. and ccmmitted effectise dose equisalents shouid be provided each worker on no Wss than an annual basis. more w *en r e t, c anamnt en intu, ci r a.c .m , -..ieno t no ,..ren ..ntiea a +a
'et ,$teT% in .sti,91 C en trin utiOn t *f Pn im M etatet t<a a nn.44 di tet If. f atare % ref t 4"U t at 49
- fdhonal L TOi , A re t Ln ditet mag 14 ast g eg t a e g r e r t.t c'4.e 11 **. L .r;ae
.s belt.P qi (UIP Oild 5L e W % $ r C #'" Fne 9 0J itO n J t $e i. r n w rn a u neo io r w e m e .n w tmm meni,ng w am < < nt e:Nn 4iw i 9dtPi with LUT!M
e a Federal Rdster i Wl. 52. .%. !? ' ruesdev. l.inuerv 3 19s? Presidential Documents 2833 4
detailed information concerning his or ner exposure should be made available upon the worker s request.
- 9. Radiation exposure control mtasures snould be designed. seiected. utilized, and maintained to ensure that anticipated and actual doses meet the objec-tives of this guidance. Establishment of administrative control levels' below the limitina values for control may be useful and appropriate for achieving this objective. Reference levels
- may also be useful to determine the need to take such actions as recordma, investigation. and intervention. Since such admm-istrative control and reference levels will often involve ALARA consider.
ations. they may be developed for specific catesones of workers or work situations. Agencies should encourage the establishment of measures by which management can assess the effectiveness of ALARA efforts. meludina.
where appropnate, local goals for linitting individual and collective occupa-tional doses. Supervision should be provided on a part time, full. time, or task-by task basis as necessary to maintam effective control over the exposure of workers.
- 10. The numerical values recommended herein should not be deliberately exceeded except dunna emersencies er under unusual circumstances for which the Federal agency having lunsdiction has carefully considered the reasons for doins so iri light of these recommendations, if Federal agencies authorize dose equivalents greater inan these values for unusual circum.
stances, they should make any genene procedures specifying conditions under which such exposures may occur publicly ava.lable or make specific instances m which such authonzation has been given a matter of public record.
The follow ng notes are provtded to clarify application of the above recom-mendattons: .
- 1. Occupational exposure of workers does not include that due to normal backaround radiation and exposure as a patient of practitioners of the heahng arts.
- 2. The custina Federal guidance (34 FR 5?6 and 36 FR 1:'3211 for limitma esposure of underground mmers to radon decay products applies independ.
ently of, and is not changed by. these recommendations.
- 3. The values specified by the International Commission on Radiological ;
Protection llCRP) for quahty factors and dosimetnc conventions for the various types of radiation, the models for reference persons and the results of their dosimetric methods and metabolic models may be used for determining conformance to these recommendations.
- 4. "Annual Limits on intake" (Alls) and/or "Denved Air Concentrations
! (DACal may be used to limit radiation esposure from mtake of or immersion in radionuclides. The ALI or DAC for a single radionuclide is the maumum l
mtake m a year or aserage air concentration for a working year, respectively.
for 4 reference person that. m the absence of any external dose, satisfies the conditions on committed effective dose equivalent and committed dose quiv-
' alent of Recommendation 4. AL!s and DACs may be denved for different chemical or physical forms of radioactive materials.
- 5. The numencal values provided by these recommendations do not apply to workers responsible for the management of or response to emergenctes.
These recommendations would replace those portions of current Federal l Radiation Protection Guidance (25 FR 4402) that apply to the protection of workers from ionizing radiation. It is expected that individual Federal agen-cies. on the basis of their knowledge of specific worker exposure situations.
^ Administratise controi lesels are requirements determined by 4 competent authorits or the t onesement vi en institution or facilits Thes a e not enmars hmits and mas tr.erefore t'e esteeced econ appros ai of competent authority or managemet t as sitwebons cectate
- Deference irseis are not nmits ena mas t.e eurensed in terms of orig usetut pararreter thes !
t ce weu to cetermine a curse ut 4cuan estn es re:orcine insesneanon or .ntersennon unen s a.we ut 4 parameter cureas ut is trmeces m euced tne reference iesei l
e .
2334 Federal Resister / Vol. 52. No.17 / Tuesday, lanuary 27. 1987 / Presdenti:1 Documents will use this new guidance as the basis upon which to revise or develop detailed standards and regulations to the extent that they have regulatory or administrative jurisdiction. The Environmental Protection Agency will keep informed of Federal agency actions to implement this guidance and willissue any necessary clanfications an$lInterpretations ;equired to reflect new infor-mation, so as to promote the coordination necessary to achieve an effective Federal program of worker protection.
If you approve the foregoing recommendations for the guidance of Federal agencies in the conduct of their radiation protection activttles. I further recommend that this memorandum be published in the federal Register, tm M mese.
Administrator Ennronmental Protection Agency.
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6-i REVISION OF 10 CFR PART 20 "STANDA.RDS FOR PROTECTION AGAINST RADIATION" STAFF PRESENTATION TO THE COMMISSION
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NOVEMBER 10, 1988
SUMMARY
OF PRESENTATION
- RECOMMENDATIONS ON RADIATION PROTECTION
- NRC ACTIONS
- OBJECTIVES OF PART 20 REVISION
- SIGNIFICANT NEW REQUIREMENTS
- IMPACTS OF PART 20 REVISION
- IMPACT ON FUEL FABRICATION FACILITIES
- ACRS COMMENTS
SUMMARY
OF BENEFITS OF PART 20 REVISION l
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I RECOMMENDATIONS ON RADIATION PROTECTION 1977 ICRP ISSUES PUBLICATION 26.
l 1979 ICRP ISSUES PUBLICATION 30, 1981 EPA ISSUES DRAFT FEDERAL GUIDANCE ON OccVPATIONAL EXPOSURE.
1986 ICRP ISSUES PUBL! CATION 48.
1987 PRESIDENT APPROVES FEDERAL GUIDANCE ON OCCUPATIONAL EXPOSURE.
[
1987 NCRP PUBLISHES NCRP REPORT 91.
1 l
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NRC ACTIONS 1957 ORIGINAL PART 20 PUBLISHED.
1978 STAFF TASK GROUPS FORMED TO REVIEW ICRP-26 RECOMMENDATIONS.
1980 ADVANCE NOTICE OF PROPOSED RULE-MAKING PUBLISHED.
80-85 DRAFTS REVIEWED BY NRC STAFF.
1986 PROPOSED RULE PUBLISHED.
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OBJECTIVES OF "*hT 20 REVISION CONF 0nM TO NEW FEDERAL GUIDAt1CE l (ICRP 26). !
l r INCORPORATE LESSONS LEARNED FROM 30 YEARS OF IMPLEMENTING PART 20. l ADD EXPLICIT DOSE LIMITS FOR THE PUBLIC ;
i (ICRP 2G). -
UPDATE SCIENTIFIC BASIS FOR INTAKE AND l l
' CONCENTRATION LIMITS (ICRP 26, 30, 48). ,
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SIGNIFICANT NEW REQUIREMENTS .;
LIMIT cN SUM OF INTERNAL AND EXTERNAL DOSES RATHER THAN SEPARATE LIMITS.
DOSE LIMIT OF 3 REM / QUARTER REPLACED BY 5 REM / YEAR.
, DELETION OF CUMULATIVE 5(N-18) DOSE LIMIT (N = AGE). -
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SIGNIFICANT NEW REQUIREMENTS CHANGE FROM LIMITS ON SPECIFIC ORGAN DOSES TO LIMIT ON SUM OF ORGAN DOSE WEIGHTED BY ORGAN RISK FACTORS.
EXPLICIT LIMIT (100 MREM /YR) ON DOSE TO MEMBERS OF THE PUBLIC (OLD IMPLICIT i LIMIT 500 MREM /YR), j LIMIT ON DOSE TO THE EMBRYO / FETUS FOR i
DECLARED PREGNANT WORKERS. ;
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i SIGNIFICANT NEW REQUIREMENTS ANNUAL REPORTING OF INDIVIDUAL DOSES TO THE WORKER.
LOWER LIMITS ON DISPOSAL OF RADIOACTIVE WASTE INTO SANITARY SEWERS.
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r IMPACTS OF PART 20 REVISION i GREATER COMPLEXITY OF RULE.
NEW CONCEPTS AND TERMS WILL REQUIRE REVISED PROCEDURES AND TRAINING.
~
ANNUAL DOSE REPORTS TO WORKERS.
- COSTS TO CONTROL DOSES FROM CERTAIN LONG-LIVED RADIONUCLIDES COULD BE SIGNIFICANT FOR FUEL FABRICATION I
FACILITIES. ,
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IMPACT ON FUEL FABRICATION FACILITIES
- SUBJECT OF ACRS COMMENT
- LETTERS RECEIVED FROM NUMARC AND FUEL FABRICATION COMPANIES
- INDUSTRY COMMENTS EMPHASIZE CONTRAST BETWEEN TWO APPROACHES FOR LIMITING THE RISKS FROM LONG-LIVED RAD 10NUCLIDES--f0MMITTED DOSE CONTROL
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VERSUS ANNUAL DOSE CONTROL.
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. IMPACT ON FUEL FABRICATION ;
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THE ISSUE HAS AS ITS FUNDAMENTAL BASIS j NEW SCIENTIFIC INFORMATION INDICATING ,
AN INCREASE IN RISKS FROM INHALATION OF !
INSOLUBLE URANIUM AND THORIUM L L
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IMPACT ON FUEL FABRICATION ,
FACILITIES INCREASED RISK ESTIMATES ARE BASED ON NEW MODELS AND DATA ON DISTRIBUTION AND RETENTION OF RADIONUCLIDES IN THE BODY AND NEW MODELS FOR CALCULATING ORGAN DOSES.
THE NEW SCIENTIFIC INFORMATION WAS ,
INCLUDED IN ICRP PUBLICATIONS 26, 30, AND 98.
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r COMMITTED DOSE
- NRC PRACTICE FOR THE PAST 30 YEARS (CURRENT PART 20) REQUIRES RISKS FPOM INHALATION OF LONG-LIVED RADIONUCLIDES TO BE CONTROLLED BY LIMITING COMMITTED i DOSE. >
- CONSISTENT WITH NEW FEDERAL GUIDANCE.
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COMMITTED DOSE COMMITTED DOSE MEANS THAT-DOSES FROM FUTURE DECAY OF LONG-LIVED RADIO- .
NUCLIDES RETAINED IN THE BODY ARE COUNTED AS THOUGH THEY OCCUR IN THE YEAR OF INHALATION.
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ANNUAL DOSE CONTROL APPROACH ASSESS INTERNAL DOSES ACTUALLY'OCCURING DURING THE YEAR BOTH FROM INTAKES IN THAT YEAR AND INTAKES IN PREVIOUS YEARS.
INDUSTRY PROPOSAL IN LIEU OF CURRENT APPROACH BASED ON COMMITTED DOSE.
CONSIDERED IN PROPOSED RULE BUT DISCARDED FROM FINAL VERSION.
l 14
C 'D IMPLICATIONS OF ANNUAL DOSE APPROACH
~
IF WORKER DOSE LEVELS ARE CONTROLLED SOLELY ON THE BASIS OF ANNUAL DOSE, RISKS FROM RADIOACTIVE DECAY OF RADIONUCLIDES REMAINING IN THE BODY
~
AFTER THE WORKER LEAVES EMPLOYMENT WILL HAVE BEEN IGNORED IN ESTABLISHING CONTROLS.
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IMPLICATIONS OF ANNUAL DOSE APPROACH IF THE ANNUAL DOSE SYSTEM IS USED, WHEN WORKERS CHANGE JOBS WITHIN THE NUCLEAR INDUSTRY THEIR FUTURE EMPLOYERS WOULD HAVE TO TAKE OVER THE TASK, AND ABSORB THE COSTS, OF ACCOUNTING FOR DOSES FROM PREVIOUS INTAKES.
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IMPLICATIONS OF ANNUAL DOSE APPROACH
- ALSO, CURRENT DOSES FROM INTAKES INCURRED DURING PREVIOUS EMPLOYMENT WOULD LIMIT THE ADDITIONAL DOSE THE WORKER COULD RECEIVE ON THE NEW JOB, PERHAPS TO THE POINT THAT THE NEW JOB WOULD BE JEOPARDIZED.
17
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I RECOMMENDATION
- THE COMMITTED DOSE APPROACil SHOULD BE CONTINUED TO ASSURE (A) CONTROL OF DOSES IS BASED ON TOTAL RISK FROM LONG-LIVED RADIONUCLIDES, (B) THAT THE LICENSEE RESPONSIBLE FOR EXPOSURES DEALS WITH THEM RATHER THAN PASSING i
RESPONSIBILITY ON TO FUTURE EMPLOYERS, AND (C) THAT THE EMPLOYEE'S FUTURE EMPLOYABILITY IS NOT JEOPARDIZED.
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SPECIFIC ACRS COMMENTS ALLOW USE OF ANNUAL DOSE CONTROL IN ,
LIEU OF COMMITTED DOSE.
ANALYZE HEALTH EFFECTS OF DISCHARGE OF EXCRETA FROM MEDICAL PATIENTS TO SANITARY SEWERS.
EXEMPT SMALL QUANTITIES OF RADIOACTIVE SOURCES FROM SECJRITY REQUIREMENTS.
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SPECIFIC ACRS COMMENTS MONITOR ONLY THOSE TRANSPORTATION PACKAGES HAVING WARNING LABELS FOR c
EXTERNAL RADIATION.
MODIFY CERTAIN DEFINITIONS.
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SUMMARY
OF BENEFITS OF :
PART 20 REVISION CONFORMANCE WITH 1987 REVISED FEDERAL I
Gil! DANCE ON OCCUPATIONAL PROTECTION.
i CONSISTENCY WITH NATIONAL AND l INTERNATIONAL RADIATION PROTECTION STANDARDS. [
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SUMMARY
OF BENEFITS OF PART 20 REVISION NEED TO UPDATE TECHNICAL BASES FOR INTAKE AND CONCENTRATION LIMITS.
l INCORPORATES MANY YEARS OF EXPERIENCE IN IMPLEMENTING RADIATION PROTECTION UNDER CURRENT PART 20.
EXPLICIT DOSE LIMITS FOR MEMBERS OF PUBLIC.
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11/10/88 SCHEDULit!G NOTES TITLE: BRIEFING ON FINAL RULE ON STANDARDS FOR PROTECTION AGAINST RADIATION - PART 20 SCHEDULED: 10:00 A.M., THURSDAY, NOVEMBER 10, 1988 (OPEN)
DURATION: APPP0x 1-1/2 HRS PARTICIPANTS: ENVIRONMENTAL PPOTECTION AGENCY (EPA) 5 MtHS E
- J. WILLIAM GUNTER, DIRECTOR CRITERIA AND STANDARDS D!YlSION OTHER ATTENDEES:
- ALLAN C.B. RICHARDSON, CHIEF, L GUIDES AND CRITERIA BRANCH NUCLEAR INF0PMATION typ RESOURCE SERVICE 5 MINS t
- DIANE D'ARRIGO I GE NUCLEAR ENERGY 5 MING
. - PAUL STANSBURY,PH.D.
NUMARC 5 MINS
- JOE F. COLVIN EXECUTIVE VICE PRECIDENT AND CEO EQQ 45 MINS f
]
- VICTOR STELLO, JR. I Efd
- SILL MORRIS OTHER ATTENDEES:
I
- ERIC BECKJORD, RES
- RICHARD CUNNINGHAM, hMSS
- HAROLL PETERSON, RES k
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[ Meeting
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Beier aa on r, ant uutc on sra.voaao.s roa ft20rEcrion Abarasr Rao,aroca 0Rr 20 f Meeting Date: //,// O/ 67 Open / Closed s
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