ML20211A064
| ML20211A064 | |
| Person / Time | |
|---|---|
| Issue date: | 09/17/1997 |
| From: | Nelson R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Jim Hickey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-3 NUDOCS 9709240109 | |
| Download: ML20211A064 (11) | |
Text
.
September 17, 1997 e
MEMORANDUM TO: John W. N. Hickey, Chief Low-Level Waste and Decommissioning j
Projects Branch j
Division of Waste Management Office of Nuclear Material Lafety and Safeguards i
i FROM:
Robert A. Nelson, Chief
[0riginalsignedby)
Low-Level Waste and Regulatory Issues Section Low-Level Waste and Decommissioning 2
Projects Branch j
Division of Waste Management Office of Nuclear Material Safety t
and Safeguards t
2
SUBJECT:
TRIP REPORT - MEETING OF NATIONAL RESEARCH COUNCIL'S COMMITTEE ON EVALUATION OF EPA GUIDELINES FOR EXPOSURE TO NATURALLY OCCURRING RADIOACTIVE MATERIALS I
l On September 15 and 16, 1997, I attended the subject meeting held at the National Academy of Sciences Study Center in Woods i
i Hole, MA.
The report of my trip is attached.
V i
Attachment:
As stated CONTACT: Robert A. Nelson, NMSS/DWM (301) 415-7298 TICKET: N/A DISTRIBU TION :
CentralaFile LLDP r/f NMSS r/f JGreeves MFederline CPeperiello WKane CJones CTrottier PSobel RJohnson PUBLIC Ta receive a copy of this document in small Lox on '0FCe* line enters
'C' = Copy without Ott:chasnt/ enclosures
- E'
= copy with attachment /enclosdres
'N'
= No copy Pr.th & File Name: C:\\WIst\\ DOCS \\ NORM.MTG OFC' LLPIf)
LLQ[
NAME RN$ don JHhkey DATE Q//7/97 7/h/97 OFFICIAL RECORD-COPY ACNW: YES NO X-Category: L Proprietary or CF Only IG
- YES NO
.l LSS : YES NO
.2 Delete file after. distribution:
Yes No X
t? 'H 1 9709240109 970917 PDR WASTE WM-3 PDR
)
)
gggBh1
.8
/ocd ll!,I,I ll I.ll.lli. l.l j
/om eseu4'.o'
\\
UNITED STATES 1
p j
NUCLEAR REGULATORY COMMISSION e
t WASHINGTON, D.C. 30en 000i Septenter 17, 1997 MEMORANDUM TO: John W. N. Hickey, Chief Low-Level Waste and Decoramissioning Projects Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards Low-LevelWasteandRegua/[,p Robert A. Nelson, Chief FROM:
t61 Issues Section Low-Level Waste and Decommissioning Projects Branch Division of Waste Management Office of Nu ear Material Safety and Safeguards
SUBJECT:
TRIP REPORT - MEETING OF NATIONAL RESEARCH COUNCIL'S COMMITTEE ON EVALUATION OF EPA GUIDELINES FOR EXPOSURE TO NATURALLY OCCURRING RADIOACTIVT MATERIALS On September 15 and 16, 1997, I attended the subject meeting held at the National Academy of Sciences Study Center in Woods
)
Hole, MA.
The report of my trip is attached, a
Attachment:
As stated CONTACT: Robert A. helson, NMSS/DWM 4
(301) 415-7298 1
l l
r.~.-
e v
.r--
-.... ~
p 43...
vm.
,,-~o
Septenber 17, 1937 MEMORANDUM TO: John W. N. Hickey, Chief Low-Level Waste and Decommissioning Projects branch Division of Waste Management Office of Nuclear Material Safety and Safeguards FROV Robert A.--Nelson, Chief
[0riginalsignedby]
Low-Level Waste and Regulatory Issues Section Low-Level Waste and' Decommissioning Projects Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards
SUBJECT:
TRIP REPORT - MEETING OF NATIONAL RESEARCH COUNCIL'S COMMITTEE ON EVALUATION OF EPA GUIDELINES FOR EXPOSURE TO NATURALLY OCCURRING RADIOACTIVE MATERIALS 1
On September 15 and 16, 1997, I attended the subject meeting held at the National Academy of Sciences Study Center in Woods Hole, MA.
The report of my trip is attached.
Attachment:
As stated l
CONTACT: Robert A. Nelson, NMSS/DWM (301) 415-7298 TICKET: N/A DISTRIBUTION:
Central File LLDP r/f NMSS r/f JGreeves MFederline CPaperiello WKane CJones CTrottier PSobel RJohnson PUBLIC l
To receive a copf of this document in small box on '0FCa* line enters
'C'
= Copy without f
ettechnent/ enclosures-ama. C_opy with attachment / enclosures
'N' No copy Path &-File Name: C:\\WEKI\\ DOCS \\ NORM.MTG
'OFC LLP[/)
LLQ[
NAME Rkldon JHhlkey DATE G//7/97 7/b/97 OFFICIAL RECORD COPY ACNW: YES NO 1
Category:
Proprietary or CF Only IG
- YES NO 1
LSS : YES NO 1
Delete file after distribution:
Yes No 1 4
r-
,r
-,,r,.,ww--.-~
,,y
.-,w.,
,_.w,-,-,.m-.-
-4.-
,,..,%,y-m,,
..m-,~,.m_.,
,,y,..-.r.
,.e
--r,
TRIP REPORT Dates:
September 15 & 16, 1997 Location:
J.
Erik Jonsson Woods Hole Center Nat!Onal Academy of Sciences Wooda Hole, MA Purpose Observe, and participate as requested in, meeting of Nctional Research Council, Commission on Life Sciences, Board on Radiation Effects Research, Committee on Evaluation of EPA Guidelines for Exposure to Naturally Occurring Radioactive Materials Persons Contacted:
S.
Simon, National Research Council Staff Committee Members:
B. Goldstein, Chairman T.
Gesell S.
Ibrahim D. Kocher E.
Landa A.
Paschoa Others:
L.
Seltow, ~1S EPA C.
McDaniel, EOP
Background:
The statement of work (SOW) for this committee is included as.
The agenda for this meeting is included as.
Discussion Topics:
1.
The Committee's initial discussion was focused on a review of draft materials developed by the Committee members since the last meeting.
Because of the draft nature of these materials, observers wera not provided copies.
Discussion topics involving these draft materials included:
Industrial / commercial processes involving NORM EPA regulations and guidance The essential bases of standards and regulations Summary of ICRP 60 & NCRP 116 provisions that may be applicable to NORM Attachment
Use of pathways analyses in setting standards and determining compliance 2.
The Committee members discussed at length the differences that exist between NRC and EPA.
Although DWM staff had provided copies of the joint NRC/ EPA " White Paper on Risk Harmonization" (SECY-95-249) after the last meeting, it was apparent that some members had not read it.
When asked to comment on thene differences, I referred to this document noting that our differences are primarily in the area of risk management.
I briefly summarized this section of the White Paper.
3.
In a discussion related to that summarized in paragraph 2 above, the Committee members discussed the disagreements between NRC and EPA cuncerning NRC's decommissioning rule.
When asked to comment on this topic, I reported that the two principle areas of disagreement are the value for the all-pathways 'ase criterion (i.e.,
25 vs 15 mrem /yr) and the need (or lack thereof) for a separate groundwater standard.
I presented NRC's position on these issues and Lauren Setlow presented EPA's.
We did not engage in a debate.
In addition, in response to a question, I explained the genesis of, and justification for, the 25 mrem /yr criterion.
4.
The Committee expressed significant interest in NRC's planned response to EPA /ORIA's recent CERCLA guidance related to NRC's decommissioning rule.
I explained that NRC staff disagrees with several points made in the guidance.
I committed to provide a copy of the NRC response as soon as it is publicly available.
5.
Dr. Goldstein expressed confusion over the exclusion of radon from consideration in cleanup standards.
A general discussion of radon ensued.
At the conclusion of this discussion, it was not apparent that Dr. Goldstein's confusion had been eliminated.
I committed to provide the Committee with the related discussion from the statement of considerations which accompanied NRC's final decommissioning rule.
6.
The Committee members briefly discussed several topics that may be included in the report in response to " charge 3" in the SOW (see third bullet on page 2 of Attachment 1).
The Committee views this charge as the least important of the three.
In response to this charge, the members agreed to identify related issues but the Committee would not conduct an analysis of these issues.
Potential issues raised by Committee members included:
The variability in chemical form of racunuclides in the environment.
Pathway analyses do not take into 2
4 account this variability.
Differences in risk values assigned to internal organ exposures from specific emitters.
Inconsistent exposure pathways analysis - use of generic / default input parameters when conducting site /
population-specific assessments.
Uncertaint ok fencerning the lirear-no-threshold hypothesis.
7.
The open session of the meeting concluded with a discussion of the outline for the draft report, related writing assignments, and preparations for the next meeting.
8.
The next meeting will be held in Irvine, CA, on october 27 and 28, 1997.
This will be the third of four planned meetings.
The only presentation scheduled for this meeting is one on risk assessment procedures to be given by EPA.
9.
The meeting was to conclude with an executive session at which preliminary conclusions and recommendations would be discussed.
Actions:
1.
Provide rationale for exclusion of radon from NRC's decommissioning rule (NRC - R. Nelson).
2.
Provide the NRC staff response to EPA /ORIA's CERCLA guidance dated August 22, 1997, when publicly available (NRC - R.
Nelson) 3.
Provide presentation on EPA's procedures for risk assessment at the next Committee meeting (EPA - L. Setlow).
3
1 NATIONAL ACADEStY OF SCIENCES NATIONAI, RESEARCll COUNCII, COMMISSION ON LIFE SCIENCES HOARD ON RADIATION EFFECTS RESEARCII EVALUATION OF EPA GUIDELINES FOR ENPOSURES TO NATURALLY-OCCURRING RADIOACTIVE SIATERIALS (NORM)
SUMMARY
Pursuani to a Congressional mandate (Amendment No. 91 in Conference Report ilR. 2099), the i
National Academy of Sciences National Research Council (NAS) proposes to establish a j
multidisciplinary committee to conduct a study and report on the scientific and technical basis for EPA's recommendations relative to protection from radiation exposure due t naturally-occurring radioactive materials (NORM). The committee will examine the EPA guidelines in light of recommendations made for these same materials by other bodies, such as the National Council on Radiation Protection and Measuremert iNCRP).
It will also incorporate inte its deliberations the resuhs of relevant peer reviewed research done by the National Cancer institute, the Centers for Disease Control and Prevention, and other organizations and individual investigators. The committee will summarire the areas of agreement and difference between the EPA guidelines and that from other advisory bodies, and identify which differences are based upon risk management policy and which are based upon scientific and technical issues. It will evaluate the basis for, and comment on, those differences that are based upon scientific and technical issues.
ORIGIN AND BACKGROUND:
NORM, such as radium, uranium, and thorium, are found in water, soil, fuels, and a variety of waste streams from commercial mineral processing and extractions operations. NORM expusures, such m those from radium and uranium in drinking water, are frequent. He implications fcc health o, external ar,J intemal exposures to radiation, including those from NORM, have been ?.ssessed in a variety of scientiac studies, ranging from large epidemiological studies of exposed populations, through modeling studies in which doses are calculated from known exposures, to laboratory measurements of biological effects at the molecular: cellular, and mammalian levels.
EPA has published several guidelines and recommendations relative to the risks from exposure to a variety of sources of technically-enhanced NORM in water and soil and may examine additional sources in the future. In a number of cases involving technically-enhanced NORM, different bodies developing guidance have arrived at different numerical values, ostensibly for the same environmental conditions. The NAS is being asked to examine any scientific or Proposal No. 97 CLS-043 Pagei
technical basis for these differences.
Specifically, the committee will examine:
Whether these differences are based upon scient;de and technical infomiation, or on policy decisions related to risk management, if there are differences in the scientine and technical basca for these guidelines, e
whether there is merit for the different scientific and technical assumptions made.
Whether there is relevant and appropriate scientific infonnation that has not been used in the development of contemporary risk analyses for NORht.
PROPOSED TASKS:
The National Research Council will establish a multidiscip;;aary committee of approximately sis (6) persons in the Board on Radiation Effects Research. The committee members will be chosen to represent radiation health effects; epidemiology and biostatistics; radiobiology; radioisotope dosimetry and metabolism; environmental pathway analysis; and risk management, policy, and analysis. The committee will meet approximately four timet The committee will examine and summarize the available literature on NORh1 guidelines and recommendations from EPA, the NCRP, the International Commission on Radiological Protection (ICRP), and other authoritative bodies. The committee will delineate the areas of agreement and difference between EPA guidelines and recommendations, and those of other bodies. In areas where NORh1 guidelines issued by EPA disagree with those of other bodies, the committee will identify the reasons for the differences, differentiating those based on scientinc and technical issues from those in which risk management policy resulted in the difference.
The committee will examine th; scienti0c dr and tehnical methodologiec used by EPA, NCRP, and other bodies to develop guidelines and recunmendations for NORht. Peer reviewed literature on estimation of radiation risk (National Cancer Institute, Centers for Disease Control and Prevention, etc.), as it may be relevant to NORhi exposure and health or biological effects, will be included in this evaluation.
Based on the above analysis, the committee will evaluate and comment on any differences in treatment of scientinc and technical issues identined, including, but not limited to, the relative merit of the different scientinc and technical assumptions made, and the overall quality of the risk assessment processes. The scope of these evaluations will not include costs, site specific assessment issues, or risk management policy judgments.
Proposal No. 97-CLS-043 Page 2
{~
O 1.'
l.
The committee will, as part cf its evaluation, address the overall validity of applying risk estimates derived from general assessments of radiation risk, such as those of the Biological Effects oflonizing Radiation (BEIR) and the United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR), to estimation of risks from NORht. It will address whether there is relevant scientific information that has not been used in the risk analyses for NORht. As appropriate, it will also evaluate and comment on other general methodologies employed to arrive at risk assessments for radiation exposure in general and their applicability to the risks from exposure to NORht.
For example, in the case of NORhi such as radium and its decay products, exposures may result from a complex array of radioisotopes. The committee may recommend whether exposures from such mixtures ofisotopes necessitate novel approaches to the process of risk estimation.
DEllVERA13LES AND DISSELNATION PLAN:
The commi. tee will produce a consensus report that identifies and comments on any scientific and technical basis for differences between EPA's guidelines, and recommendations on NORh1 versus those of other bodies. The report will be reviewed in accord with National Research Council procedures. The committee's report will be provided to the EPA, which is then charged by the Congressional mandate to provide the report to the various appropriate corimittees of Congress along with its views on any need to revise its guidelines for exposure to NORh1 based upon the NAS/NRC evaluation.
Reports resulting from this effon shall be prepared in sufficient quantity to ensure their distribution to the sponsor, to committee members, and to other relevant panies, in accordance with Academy policy. Reports may be made available to the public without restrictions.
Proposal No. 97 CLS-043 Page 3 I
w-,
,---_w-1 e
e ' L t
s V
e O
5 4
6 h
f s
)
it t
6 i
k t
.I i
4 l
2 f'+-'
e r-e.-Spee +w-v-e - -,wy+*e-
-1==w v e vv 4,*-ev-e-,*
w ir-+,
p1- -
-v es yw w
"'Wa--e+-
v-i--vrew-4-4e ew ew.ar wr--
- v w v e-e-e s ee w o -w
-"-*--*-m---+=w--+w----ee-+-
NATIONAL RESEARCH COUNCH 7
COMMISSION ON LIFE SCitNCES
!!*1 Con $ntuuan Ascewe Wunnnston D C.2'All SoARD oN RAptAttoh tersets MtslARCH N4 Aman in mam:
FAA (N21 hum COhBUTTEE ON EVALUATION OF EPA Gl'IDELINES FOR EXPOSt"RE TO N ATifR ALLY OCCURRLNG RADIOACTIVE MATERIALS Second meeting: 1.416 September 1997
( both days of mectlup ute at J. Erik Jonsson Woc,ds Hole Center of the National Academy of Sciences, Woods Hole, MA 1 AGENDA 15 San **>=her 1997' S 8;20 AM Dreakfast at tuccting wates for committec 5:30 9:30 AM Closed Session
- general committee business
- future anangcments for conference calls, logistics, research needs, etc.
9:30 AM noon OPEN SESSION Committee Dhcussion (see section below) 12:00-1:00 PM Lunch for conumuee (visitors cost is $12.00) 1.004:00 PM OPEN SESSION Committee Disenssion (see section below) 5.00 PM Adjourn Reception for cornmittee (visiton welcome, drinks can be purchased) 6:00 PM Dinner for comi"ce (visitors cost is $32.'J0, reservations necessary) 16 Cant-kar 1997:
8 8:30 AM Breakfast at rnectmgs center for committee 8:30 AM nytn. OPEN SESSION - Committee Discussion (see section below)
Committee writing scasion dependent on schedule.
12:00-1:W l'M Lunch for committee (sisitors cost is $12.00) 1:00 - 2:00 PM Closed Comruittee Writing Session.
w m O ~ ~ ~ " + < * * ""~*
ru w nos na ce..es,o w rw er ren.m 4~,saa eenre erseaLaansu to arew rowenem
/-
~
2:00 3:00 PM Closed for Committee Business
- Revising report outlinc
- Further writing assignments
- Schedule for written material
- Travel and fmancial business 3.00 PM Adjousu DISCUSSION PERIODS During the open Discussion Periods, the committee membets will hoe the opportunity to d:scuss the topics noted below as well as other areas determined to be relevant to the committee charge. No presentations by outside speakers am scheduled at thi meeting Members of the public may be recoFnized by the Committee Chair and contribute to the discussion. Some individual committee members will be reporting on specific areas and their names are noted by those topics.
- Goldstein: Review of cornmittee charge.
- Panchom: Report on intomational Symposium on Radiological Problems with Natural Radioactivity in the Non Nuclear Industry (Amsterdam meeting).
- New informatica collected on intemational legis!* tion and regulations for NORM.
- Scientific bases for intemational guidelines.
- Kochar: status of summarizing EPA mdance and regulations.
5
- Notable dibrances in regulations unons agencies and countries.
- Defining the boundaries between policy and science in determining the basis of previously establiabed regulations.
- W.nuinn nf rsion guidelines, both 11.S. and intemational.
- How to summarize history of NORM guidelines and its relevance to current policy?
- Discussion of Litetyturc ou NORM pauvided.t 1st ma-ting.
7
- New liteene.
- Conceptual differences of regulations for exposure to NORM in industry vs. clean-up and decommissioning activities.
- Issues of NORM not addressed in current guidelines.
' Other usefh* '.nfbrmation or analytic approaches to riA aacannt fot NOP31 that is not currently in use.
- Issues ofimplementation of NORM guidelines.
- Units for regulating NORM (concentrstion vs. exposure).
- Risk harmonization (NORM vs. other societal risks).
..