ML22230A091
| ML22230A091 | |
| Person / Time | |
|---|---|
| Issue date: | 01/04/1978 |
| From: | NRC/OCM |
| To: | |
| References | |
| Tran-M780104 | |
| Download: ML22230A091 (38) | |
Text
BETURN TO SECRETARIAT RECORDS NUCLEAR REGULATORY COMMISSION IN THE MATTER OF:
PUBLIC SESSION Policy Session 78-11 SECY-77-538 -
Proposed Amendments to 10 CFR Parts 19 & 20 to Control Radiation Exposure to Transient Workers Place -
Washington, D. C.
Date -
Wednesday, 4 January 1978 ACE - FEDERAL REPORTERS, INC.
Official Reporters 444 North Capitol Street Washington, D.C. 20001 NATIONWIDE COVERAGE* DAILY Pages 1 -
35 Telephone:
(202 ) 347-3700
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- _ *..... __.... __,. __,._. -____... ___. -----.- -~-*------'""---"--'------~~:z:;.;;. ; :~ *::~:~:L;I>~~~-B~-;_:;-~-----~-*---~. -------~----.... 'h>.....,~--~ ;:-~-,~~~ -6,;c* ~- -J DISCLAIMER This is an unofficial transcript of a meeting of the Uni-ted States Nuclear Regulatory Commission held on January 4, _1978 _
. _ in the Commission's offices at 1717 H Street, N. lL;*washington, D. c9' The meeting was open to public. attendance and observation.
This transcript has not been reviewed, corrected, or edited!J and it may contain inaccuracies.
- The transcript is intended solely for general fnfonnatiana.1 purposes..
As provided by 10 CFR 9.103:, *it is not part of the fonnal or informal.
record of decision of the matters discussed.
Expressions of opinion in
- this transcript do not necessarily reflect final detenninations or beliefs.
No pleading or other paper may be filed with the Commission in any proceeding as the result of or addressed. to any.statement or-argu~.ent contained herein, except as the Commission may authori~e.
CR5934 MELTZER/Mm 2
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25 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION PUBLIC SESSION Policy Session 78-11 1
Proposed Amendments to 10 CFR Parts 19 & 20 to Control Radiation Exposure to Transieht~Workers Room 1130 1717 H Street, N.W.
Washington, D.C.
Wednesday, 4 January 1978 Hearing in the above-entitled matter was convened at *l :'.3Q; p.m., pursuant to notice, VICTOR GILINSKY, Acting Chairman, Presiding.
PRESENT:
VICTOR GILINSKY, Commissioner RICHARD KENNEDY, Commissioner PETER BRADFORD, Commissioner R. Minogue T. Engelhardt L. V. Gossick
- .1
- s. Trubatch A. Kenneke R. Alexander
- w. Kreger J. Hoyle
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P R O C E E D I N G S COMMISSIONER GILINKSY:
We are here to hear about proposed amendments to deal with radiation exposure to transient workers.
When this came up to the Commission, there was some sentiment that the cure may be worse than the disease.
However, the Staff feels otherwise.
Why don't you tell us about it.
MR.MINOGUE:
Yes, sir.
This paper of course deals with just one aspect of the major question, which is that of occupational exposure to radiation.
Specifically it is an attempt to recognize a gr,owing trend and to come to g~ips with it.
That trend I
being one towards increasing use of transient and contract workers to carry out certain types of operations.
There is no implication on the part of Staff that there is any major problem that has resulted from this to date.
We don't have,,.any data that would indicate some svstem-atic pattern of overexposures.
Before I get into the specific topic of the paoer, I think it would be very helpful to make some general observa-tiions on the nature of some of the issues involved with
- occupational exposures, because they have quite a bearing on the regulatory approach that you used to this problem area.
First, and I think foremost is that the nature of
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the problem is quite different from much of what we do in regulation. We are not dealing here with hypothetical loss of cooling accidents, and certainly we are not even dealing with somethfung that would be analogou~ to discharges into the environment where even there there is a
.tendency to use extrem ly conservative analytical models and extremely conservative dispersion models.
And so generally in much of our regulatory program we are dealing in areas where we grossly overestimate the potential hazards involved:'.:in formulating the basis of the regula tory program.
Here this is not the case. We are dealing with real people who are being really exposed to radiation and at levels which are quite a bit higher than those that you might expect to occur in terms of general population exposures.
That means that some of the questions implicit in the linear extrapolation, linear hypothesis, are perhaps a little more significant. Ne are getting up to high enough levels that you really should and believe it is right, assume there is some adverse effect to the radiation.
This leads -to:the second point.
I think it has to be recognized that there is a great deal of uncertainty as to the precise biological effect of r.adiation at these low levels.
Tm:-e is a lot of dispute, and even today yery c:urr'ent controversy on that.
And because
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of these uncertainties, one has to recognize that there may be shifts up or down in the levels that one would appropriately allow.
Such a shift occurred-some years ago.
I COMMISSIONER GILINSKY: When you say low levels, you mean the occupational levels --
MR. MINOGUE: The levels that would be involved in occupational exposure, yes, sir.
By normal standards, they would still be considered to be low-level exposure.
This is below-level exposure.
COMMISSIONER GILINSKY:
But you-*_are saying at :these levels you think that the linear hypothesis is a reasonable approach?
MR. MINOGUE:
I think at this level it is a very reasonable approach.
And in fact, there are many people who say it may underestimate the risk.
Certainly, you are much less in a never-never land of going down to lower and lower levels in assuming the things, that there is no recovery mechanism and so on. At these levels you ~are -,~n,.kind of an inbetween gray zone.
But I think you should feel much more that the linear hypothesis is probably rather sound.
COMMISSIONER GILINSKY: And you think *it may, in fact, underestimate the --
MR.MINOGU];:: There are many people who think it may
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underestimate the effect in these ranges.
Yes, sir, this is quite a current controversy.
COMMISSIONER KENNEDY:
These ranges --
MR. MINOGUE:
Those that would be involved in occupational exposure.
The actual dose rates that we wi11 **
be talking about today that relate to these transient workers typically are at 100 MR per hour, 1 R per hour. They are decade higher than what you would talk about as potential*.~ general public exposure levels.
The average level that the limits would allow, 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> a week, would be 2 1/2 MR per hour.
But the bulk of the exposure which I will touch on in a moment, comes from operations involving maintenance, or operating on equipment ah much higher levels.
It's short duration exposure at levels in a range that are typically well over 100 MR per hour.
COMMISSIONER GILINSKY:
Why is the rate significant here?
MR. MINOGUE: Well, the higher the rate, the less --
and the higher the total exposure,the less you are making this very extreme extrapolation that is involved.when you look at general public exposure at miniscule exposure rates.
COMMISSIONER GILINSKY:
But I thought when we use the linear hypothesis, we are really looking at total doses.
MR.MINOGUE: That's correct.
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COMMISSIONER GILINKSY: Why does the rate,the MR per hour matter here?
MR. MINOGUE:
When you use the linear hypothesis down to very low dose rates, in effect, is a matter of good sound regulatory practice, and we do dlo this, of course, you assume the effect is constant, is not rate dependent.
The effect is related to the total exposure in manrem.
But I think there is a general feeling among many experts in the area, the NCRP and ICRP types, that when you do that, you are overestimating the actual effect.
I think that feeling is less clearcut as you get up to somewhat higher levels.
As you get into these somewhat higher levels, ::there is less of a feeling that the linear hypothesas is an overestimate effect.
And in fact, many feel it is an underestimate.
~
This uncertainty on these effects has some real significance.
I think the tendency has been to make people in the program, both the regulators and the industry alike emphasiz the ALARA.concept, because of this.
So that you find if,.
you look at the patterns of actual exposure, that people generally get exposures that are well below these limits.
And that re-flects to some extent efforts on the part of the -- not just the regulators, but the industry to design the plants and operat the plants in a manner that keeps the exposures comfortably below those limits..
There is always a feeling that those limits
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may nbb be all that accurate.
This was certainly true, as I mentioned a moment ago, back in the early '50s the limits were dropped by a factor of three, as there came a growing awareness that there were non-threshold effects here.
And because that. approach had been used in the design of the various plants it didn't require much of a change in the way things were done. These people generally had been v.ery gunshy of designing right up against those limits.
That also is found in our regulations.
The regulations emphasize the application of the ALARA concept.
And the licensing review in cases puts a great deal of emphasis on taking steps to reduce the total exposure of all the workers by the application of ALARA principles to occupational exposure.
You will see that as I go on. Some of the slides will show the exposures that result from this.
I really touched on the next point in response to your question, so I won't cover that.
Another matter that one has to recognize in looking at these questions of occupational exposure is the several sources that there are.
One source of occupational exposure is just the day-in, day-out operation of the plant,where you are dealing with the potential exposure of workers to equipment the~ can rather readily be shielded.
That exposure can be controlled readily and at relatively low cost,*and typically is kept to very low values.
I
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The other two categories are exposures that relate to w6rk that is where you are in direct coritact withtthe material.
Either you are handling some radioactive material, or you are working on equipment that is radioactive, or you are doing maintenance work, doi~g in-service inspection or whateve:-
And in the last group of exposure, it is exposure to process equipment that handles radioactive materials, such as waste treatment systems.
Both of these second two categories involve exposure that it is much harder to reduce the exposure rates.
And because of that, this is where most of the exposure comes from.
So if you look at a record of where people get their occupational dose,they get it from these two sources rather tha from --
COMMISSIONER GILINSKY:
Is most of the exuosure planned exposure, or is it ina~vertent exposure?
MR. MINOGUE:
It is planned in the sense that the maintenance operation is planned typically with a recognition that the levels are high.
And there are a number:of things developed in the maintenance program to reduce the exposure t:))workers. either by minimizing occupancy time, temporary shielding, the use of automatic or semi-remote equipment, things of that type.
The licensing people focus on this in their review to make sure that the applicants have an ALAR.A program to make
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sure that the exposures are low-c in these maintenance opera-i-:
tions.
Many of these, as I will touch on in a moment, are --
the exposures are actually imposed by regulatory requitements; in-service inspection, tube plugging, things of that type.
COMMISSIONER GILINSKY:
How accurate are the dosi-meters?
MR. MINOGUE:
The dosimeters at these dose rates are quite accurate.
I wouldn't want to give you a; percentage off the top of my head.
percent?
COMMISSIONER GILINSKY:
Like 1 percent, or 10 MR. MINOGUE:
No, they are not 1 percent.
MR. ALEXANDER:30 percent.
MR. MINOGUE:
30 percent.
COMMISSIONER GILINSKY:
So if somebody is getting 100 MR per hour, he might be getting 130 or 70?
MR. MINOGUE:
Yes.
I think that as you get down.to lower levels, it is my impression -- I may be wrong, but my impression is as you get up to the 100 to 1 R per hour range, that the accuracy is hetter than that.
But the accuracy in the relatively low level, 30, 40, 50 MR is not at all good.
As Bob says, you can be way off.
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25 10 COMMISSIONER KENNEDY: What is it at 100, roughly?
MR. MINOGUE: Well, my expert says 30 percent.
I thought it was better than that, but I would have to defer to the expert.
A lot of people in the business think it is better than that, too.
I will go on to the first slide.
(Slide.)
Let me get to the specific.topic of this paper, whic is.transient workers.
There are three types of transient workers in the regulated program.
The first is something that is almost a thing of the past.
I hope it is. And that is the use of what not in a joking manner I'll call *warm bodies. This is the approach, for example, that was used on the cleanup of the Chalk River r.eactor.. back in the 1 50s, which President Carter participated in.
And that is an approach where you just bring in very large, *groups of people to do the job, and they stay as long as they have to to do something, and then you bring somebody else in.
I think that is pretty much a thing of the past.
It doesn't speak at all to~fue real safety questions.
We discussed it earlier. That. is a function of the total manrem exposure.
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25 11 And you ddn't really reduce ai;iy safety problems if you bring three more bodies.
That, I think, is a thing of the past.
I mention it for the sake of completeness and openness on the issue.,.
The things this paper is aimed at, are a group of workers who represent highly specialized skills. These are the kind of people who do in-service inspection, specialty welding and so on, who quite often are not utility employees, but are brought in as employees of some contractor, with that contractor often standing in relationship to them more like a hiring hall or a body shop type of contractor.
This Vugraph shows this rather clearly. This is based on reactor data because that is the best data we have.
We have broken the various areas of exposure into five groups; reactor operations, which I really won-t' tt.discuss much; and then a group of routine maintenance, this being maintenance that will be done in the normal course of events on any complex thing like a power planti and then special.
maintenance, this being maintenance that is directly related to regulatory requiremeniJ.s., or requirements that arise from observations of problems on operating plants.
COM.c"vlISSIONER GILINSKY: Can I stop you.
When you say numbers of workers exposed to radiation what does that mean?
MR. MINOGUE:
In an effort to not slant the figures,
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25 12, these are the numbers of workers who are in radiation levels that are high enough to get really meaningful measurements.
You look at the bottom of the page, we have got larger numbers for each of these years. This being all of the people who have had enough of a measurement to read something on their film badge. But if we folded those in you would get a picture that would be biased by secretaries and clerical people and people like that who really weren't exposed.
COM.MISSIONER GILINSKY: What is your threshold?
MR. MINOGUE: That, I'm not sure.
MR. ALEXANDER:
For gamma radiation we would probably say on the order of 20 millirem.
COMMISSIONER GILINSKY: So basically this is the number of workers who have received more than 20 millirems as a consequence of being associatelwith the nuclear industry.
COMMISSIONER KENNEDY:
Over what period?
MR. ALEXANDER:
One month.
COMMISSIONER KENNEDY:*
millirems in a month --
MR. MINOGUE:
In 1974.
COMMISSIONER KENNEDY:
MR.MINOGUE: Yes*.
23,000 in 1976.
6200 received more than 20 in 1974.
In any event, if you look at the two rows on routine maintenance and.special maintenance, in each case we have broken
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25 out the contract, workers.
And you can see the trend here developing quite sharply in both of these where the number of contract workers has:gone up~~uite substantially.
13 COMMISSIONER GILINSKY: Well in fact the amount of maintenance -- that's right, the number of contract workers has gone up tremendously.
Is that as a consequence to our requirements, or what?
MR. MINOGUE: Yes.
Well, much of what is under special maintenaneeiis either because of our requirements, or identi_f ied problems like the pipe crack problems, steam generator problems, and so on.
So they have arisen either because of regulatory requirements, or operating difficulties.
(Slide.)
The next Vugraph shows much the same data, but now we are looking at total exposures.in _manrem.
As you can see, again the same trend relatively in small exposures of contract workers in '74. But in 1976, the last year of complete data, ve:rzy substantial fraction of the total exposure in manrem is to the contract workers.
Commissioner Gilinsky, this kind of touches on what you were discussing.
Let's have the next Vugraph.
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25 14 (Slide.)
This Vugraph identifies the specific things that we labelled as special maintenance.
These figures were based on an effort by Staff to estimate the number of workers.involve specifically in:these areas.
And you will recognize these as being some that are big, current problem areas.
I wanted to apply particularly the radiation level associated with each of these operations.
On the BWR pipe cracks, typically we are talking one rem per hour; a tenth of a rem on the nozzle cracks; ten rem per.hour on plugging steam generator tube leaks,and because~
of this the industry itself has taken a lot of steps to do that operation automatically, or to try to come to grips with the problems both in the redesign of steam generators and better water quality.
For a steam generator replacement, we have an estimate of iooo::manrem.
Snubber test relates to difficulties that people have had with the operability of the snubbers associated with the seismic design.
There the rate varies all over the place, and in some areas would be quite high, comparable to numbers --
COMMISSIONER GILINSKY:
Let me ask you, how do these numbers compare with, say, the manrems to whicl:J. the entire population is subject to?
MR. MINOGUE:
From nuclear power plants?
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25 15 COMMISSIONER GILINSKY:
Yes.
MR.MINOGUE:
I don't have that.
I wouldn't want to give you a guess off the top of my head.
MR. KENNEKE:
There is a table that indicates the manrems in medical workers.
MR. MINOGUE:
Yes. this is only reactors. Yes, I have later.-on a table for medical ~orkers where you see very high manrem doses there.
I just don't have the figures for the general popu-la9e.
Sorry.
Because you have been looking at reactor data, the next Vugraph is an attempt in the numbers -- as we get out of the reactor area, the numbers become less and less solid.
(Slide.)
It is an attempt to -- from another perspective, to put a handle on it.
This is across the whole range of regulated activities. It is a broader base.
It shows the number of workers who have had two or more terminations within a single quarter, not just one termina-tion.
There is a bit of difficulty here because the regulations are somewhat ambiguous.
COMMISSIONER GILINSKY:
- What is a termination.?.
Reaching the limits?
MR. MINOGUE:
No. Termination means that they
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25 16 have left the employ -- for sure the licensee.
And many licenses have read it to mean, have left the employ of some contractor of his for whom they were working within a radiation area under his control.
Recognize that when a worker enters a radiation area-under the control of a licensee in a sense he is under his jurisdiction in terms of his exposures.
Now some licensees have reported these contract workers as they left, and some have not.
One of the things this proposed regulation would do would clarify the definition of termination to make it clear that it includes workers, not just of the licensee directly but also of contractors of his.
There are two points to this Vugraph-. First, again, iti::.reflects the same trend. And second, it also indicates that-the people who are transients have been tending to get somewhat higher__'.doses. That is there is _a comparison here which would indicate that there is a factor of four greater exposure of thes transient workers. Now granted this is a very small sample, and I am not trying_ to propose to read too much into that, just an indication.
(Slide.)
MR. GOSSICK:
Can we go back to Commissioner Gilinsky's question.
Were you asking what the general populace exposure is?
COMM~SSIONER GILINSKY:
Yes, from reactors.
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to you.
17 MR. GOSSICK: Oh, just from reactors, not the total.
MR. MINOGUE:
I really don't know.
I can furnish it MR. KREGER:
Yes.
Based on measurements last year, 5
a study just completed by P&L for us, showed that the measured 6
population dose resulting from effluents, was probably about 7
5 to 20 manrem per reactor for the existing operating reactors.
8 Our. assessed value for a conservative basis on 9
reactors yet to be built, is more like 2_0 to 4 0 manrem per 10 reactor here for::the 50-mile population.
11 COM.MISSIONER GILINSKY:i :-::Well, but see, you are talkin 12 something like 1000 manrems per year for the existing reactors, 13 roughly speaking, as opposed to 20-some-odd thousand.
14 MR. KREGER:
Yes.
15 MR. MINOGUE: With the trend toward the number of 16 manrem per reactor going up, whereas it is going down as far 17 as effluents are concerned.
18 19 20 21 22 23 24 COM.MISSIONER.GILINSKY:
That is quite a difference.
MR. *_MINOGUE:
Okay, this next Vugraph summarizes briefly what the present regulatory requirements are.
The basic limit t'oday is 1 1/4 rems per quarter, Ace-Federal Reporters, Inc.
or 5 rem per year, with some provisos in the regulation that permit -- they were originally intended to apply to rather extraordinary cases and actually are applied quite commonly,--
that permit hig~er exposure rates if certain specific 25
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25 18 requirements are met regarding recordkeeping, reporting, and so on.
COMMISSIONER GILINSKY:
How do you keep these records?
Are there records for each individual worker that go along with him in some way?
MR. MINOGUE: There are records of overexposures.
I'm not -- nothing in this rule change will change the reporting requirements to NRC. I'm not that familiar with them in detail.
There are requirements to report e_xposures over some limit; and there are other requirements to keep records on people in exposures in a lower range, but I don't have those at my fingertips. I'm sorry.
COMMISSIONER GILINSKY:
Well, but you say the basic limits are 3 rems per quarter if it is known that 5 times N to the minus 18 is not exceeded.
MR. MINOGUE: That is just a fo.rmulat that relates to the age of the workers.
COMMISSIONER GILINSKY:
Right.
MR. MINOGUE:
It really relates to his age.
COMMISSIONER GILINSKY: But 5 times that N to the minus lij is the total dose, isn't it?
MR. MINOGUE: Well, but the effect of that is really to. say that younger people can't be exposed to these levels.
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25 19 COMMISSIONER GILINSKY:
Let me understand.
5 times N to the minus 18 is what?
MR. MINOGUE: This is a formula that reduces the level for younger employees. And-N is the worker's age, isn't it?
MR. ALEXANDER:
N is the worker's age. And 5 times N minus 18 formula simply says that each worker can get 5 rems each year.
COMMISSIONER GILINSKY:
Right.
MR. MINOGUE:
Unless he is young.
COMMISSIONER GILINSKY:
So how have you kept the records to know that?
MR. ALEXANDER:
These are kept on forms that the NRC provides.
COMMISSIONER GILINSKY:
And when a worker moves around from job to job, does he carry these along with him?
MR. MINOGUE: He gets the information, but it is not prompt reporting. It may be some time before-the information comes to him.
COMMISSIONER GILINSKY: But I mean, who keeps that record?
MR. MINOGUE: That record is kept by the licensee.
But it is available, as I understand it, to the employees.
Not promptly.
COMMISSIONER GILINSKY: And when he moves somewheres
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25 else, how does that record move with him?
MR. MINOGUE:
It doesn't.
COMMISSIONER GILINSKY: It doesn't?
20 COMMISSIONER KENNEDY:. Does::ne:w licensee have any obligation to go to the old licensee to get that information?
MR. KENNEKE: If it goes over 1 1/4 he has to get that information. He has to go back into the occupational history.
MR." MINOGUE:
I am not sure on that specific.
If he, is under 1 1/4, even under the proposed regulation, he is under no obligation to go back to the employee's previous employer.
Even this regulation that we are proposing would have him just ask the employee what, if any, previous occupa~
tional _exposure record he had.
COMMISSIONER GILINSKY: But would you verify that record?
I mean, how would you know?
MR. MIN.0GUE:
Under this proposed regulation you would not attempt.. to verify it.
You would take the employee I s word for it.
It should be' recognized, of course, in some cases' he may not tell you the truth, because it affects his job.
That was one of the points you raised as a written question.
I thinkthe ansewr is that you don't get 100 percent coverage.
What ___ younare.doing is exchanging the burden, a
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25 21 regulatory burden, which should be quite substantial, to tell each utility or~other licensee hirirtg people~resh, that they have an obligation to go back to the guy's prior employer, previous employer directly, to get a report of his exposure.
That is a big burden of making inquiries.
With this regulation as we propose it, they would ask the new hire, or employee, whether he had previous exposure, and they would accept his answer at face value.
Sometimes these guys might not tell the truth.
In that case --
COMMISSIONER GILINSKY:
Would he necessarily know the answer?
MR. MINOGUE:
Yes.
Another part of the.rule would be a requirement that if he asks his employer let's say that he is leaving company A for work assignment at company B which also would involve radiation.
If he asks his employer to furnish him with a prompt estimate, and if his exposure exceeded one quarter of the 1 1/4 quarterly *limit;.* his employer or the licensee would be obliged to provide this.iri:Bormation to him promptly so that he can carr it with him.
COMJ\\USSIONER GILINSKY:
Well, why don't you go on.
COMMISSIONER KENNEDY:
How does he know that he is entitled to this?
MR.MINOGUE: Well, he can ask for it.
He is entitled to it in any event. If he has not been exposed to these levels
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25 22 and he asks for it --
COMMISSIONER KENNEDY:
What prompts him to ask for it?
MR.MINOGUE: The fact that he is going to work for another company that would s~nd him to work for a licensee, because he knows he will be asked the question.
COMMISSIONER GILINSKY: Would it be too burdensome to have some great central computer storage that would simply keep track of all this?
MR. MINOGUE:
I think that is more burdensome than what this rule would propose.
COMMISSIONER GILINSKY:
Have a little address and memory for each --
MR. MINOGUE: Well,.that's a lot of paperwork flowing back and forth.
This is a system that a guy is leaving, and knows he.is going to b:e assigned to another utilij::y --
COMMISSIONER GILINSKY: This would be maintaining a data bank on 36,000 people in the power reactor field alone, loo~ing at these data~
COMMISSIONER GILINSKY: Well, we maintain some data banks --
MR. MINOGUE: Well what we are trying to do here is keep the burden low. This does not -- at no point have I tried to allege that.we have got a lot of overexposures.
What
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23 we are trying to do here is recognize a trend towards growing work, use of these transient workers and create a framework 3 where the utility or the other licensee in whose area they are 4
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25 working, is made aware, with some reasonable assurance, of their previous exposure record, and is also under some obliga~
tion to limit their total exposures, and under an obligation to inform employees promptly of what their probable exposures were when they changed employment.
But to try to do a.J.J.l that, without creating some gigantic empire of paper flowing back and forth.
There is not much paper flowing back and forth here.
There is a question on an employment application,and a piece of paper that t~e guy is handed if h~ asks for it, as he walks out the door, and that's it.
There.wa~ a fairly conscious effort here on the part of the staff to ~eep the burden low, because there is no over-whelming evidence that a lot of people are -- there is no evidence at all that people are getting overexposed to any sig*nif icant degree I because they are transient workers.
It is more a matter of looking at this pattern of employment and the growth in these workers, and recognizing the kind of requirements that we are imposing arid the kind of difficulties that are arising, the highly-specialized skills these are calling for.
Just.. recognizing, there is only so many of these
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25 24 guys around.
And we are going to see, we are likely to see more and more people working in multiple licensees.
We are just trying to Qome to grips with this problem before it gets big. Right now there really is no problem.
But, recognizing there is no real problem, we are trying to keep the burden as small as we can.
Let me go on to the next Vugraph.
(Slide.)
This really seconds what I was just saying.
Again, and throughout, -these are the workers exposed to fairly hefty levels. You know, this isn't the trivial exposures included.
You can see here that the average*.quarterly exposure compar.ed to a limit of 1 1/4, of workers in these four fields which, except for the medical licensees, is the major exposure groups,is consistently a nice small fraction of the limits.
But as reflected,the present program has in effect been working.
The next Vugraph is on the medical workers themselves.
(Slide.)
And at this point, our data bank gets pretty fuzzy. We have a very limited sample from a voluntary program of several years ago where we got some replies, and this is based on that sample.
So these are really rough,. estimates, but give some flavor of first, the large number of workers involved in the medical field who are exposec;l, the relatively low average 'dose,and the
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25 25 relatively small percentage of these, but it is not zero by any means.
It gets over.3 rem per quarter.
It is 1/4 of 1.25, which is the threshold for the system in this rule falling into place.
And in the medical area, if these figures are correct, we would expect only about 4 percent of the workers to be affected by this regulation~
(Slide.)
This next Vugraph -- and you have anticipated some of.these, Commissioner Gilinsky -- this tries to summarize the total exposure in each of these areas, and gives a pretty fair picture that we a:redealing here really primarily with power reactors and medical licensees, in terms of where the big manrem exposures:have occurred.,
Patterns of employment that would lead one to expect a high percentage of transient workers*
You would expect_ -*c: *,.
a lot of that in the commercial power reactors and industrial nadiography areas and much less of it in the remaining three areas.
We don't have hard figures on the turnover, but probably the highest turnover of any of these groups would be medical workers, and we have some estimates on that, in the range of 10 to 20 percent.
And of course, now the people turning over, some of them would be affected, 4 percent of them would be affected by this regulati.oh.
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25 26 COMMISSIONER GILINSKY:
Now mi..ning is not included here?
MR.MINOGUE:
Mining is not regulated.by us.
COMMISSIONER GILINSKY:
By the NRC.
It is the Labor Department?
MR. MINOGUE:
Yes, sir.
The exposure in mining is pretty hefty.
MR. KENNEKE:
Bob, how does th~t.~22. 9 compare with the* previous 13. 5 on prior chart medical?
MR. MINOGUE: Well this is everything else, so the 13.5 is part of it.
But it is the biggest single block.
The rest of *it is bits and pieces here and there.
MR.KENNEKE:
You mean it is nonradioactive material, like X rays and --
MR.MINOGUE:
No~it:is licensees involved in distribu tio.n*of radioactive material and so on, who were not --
MR. KENNEKE:
I see what you mean.
MR. MINOGUE: Research facilities and so on.
(Slide.)
The next Vugraph summarizes the essence of the regulation.
Let me just summarize.
I have touched on this, but what it really reguiresi first, itre:ruires a licensee to ask a new employee or a new assignee into a radiation* 1.area about his exposure in previous job assignments.
He*is permitted to accept the answer he gets
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25 27 at face value.
Second, it requires a licensee to take the employee' total exposure history into account in making work assignments.
So, in effect, to carry forward the previous exposure burden from the previous job.
And it restricts your ability as a licensee to expose -_i the man forever.
And third, it nquires licensees to promptly inform a man who is terminating, who asks for it, what his exposure wa:=3 in working within:the radiation area.
Estimates are per-mitted.
Estimates might be obtained by analyses of the varioIBtypes of operation, measured radiation levels, times exposed and so on.
Or, I think in most cases would be more likely obtained by use of self-reading dosimeters.
In fact, if you were to ask what is the main impact of this regulation likely to be, I think one is to even further encourage what is already widespread, which is the use of self-reading dosimeters by people who are working in radiation fields high enough that they are likely to go over one-fourth of the quarterly limits.
COMMISSIONER KENNEDY:
Is there any reason why that shouldn't be required?
MR. MINOGUE:
I, personally, think it is a very good practice.
When I wo:rked in the Navy program, we required it
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25 28 of people who were working in such fields.
COMMISSIONER KENNEDY:
Why don't our regulations require it?
MR. MINOGUE: I don't have a good answer for that.
Maybe they should. This is kind of doing it through the back door.
Maybe we should do it through the front door.
Myself, I think it is a very good practi cie because a guy in that kind of situationr if he suspects something wrong, or the equipment is not of condition he expects -- and I've done it myself -- you just whip the thing off and look through it, and you can look at what your exposure has been.
And if it is higher than it ought to be, you know to get the hell out of there.
When I worked in the Navy program there were two people on one of the submarines whose lives wer.e saved because of wearing these self-reading dosimeters.
They looked at them, they were off scale,they got out of there. They got exposures of one or two R instead of being killed.
So I think it is very good.
A very large percentage of the licensees -- we are really talking here only about the higher levels, you certainly don't need this kind of equip-ment for lower levels -- but a very large percentage of licensees already do this just as a matter of good engineering practice.
So maybe we should require it.
I want to.look into some of the impacts of that.
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25 29 COMMISSIONER KENNEDY:
Independent of this, would you do that, please?
MR.MINOGUE:
Yes, sir, I will.
The other effect that*I think this regulation will have, is that because it puts more of a burden on a licensee to be concerned about the guy's total exposure, I think it should reduce some of the exposure of people in this transient worker group.
I think that will have some effect at reducing exposure.
I don't think it will be dramatic, but it will be an_effect.
rh~~next Vugraph may be missing fromLfue projector.
Do you have the.one ons*costs?
Okay, we have the one on costs, which is in the stack the public has.
These costs were really obtained through the operations of an AIF special task force which has taken a hard look at this question as it relates to some of these activities integrated on the Vugraph, and has come up with an estimate of costs.
These costs are quite low.
I think that reflects the very careful effort we have made to-minimize the undue regulatory burden. And in fact I would describe these as really di minimus costs.
They are low enough that they are almost indeterminate.
CO'-iMISSIONER KENNEDY:
Less than $1000.a :reactor.
MR. MINO~UE:
Yes.
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25 30 (Slide.)
The next Vugraph gives some summary-;- of this AIF participation.
I will say a good word for AIF for a change.
I think that the general attitude that they havettaken as an organization towards many of these questions involved in radiation exposure and occupational work, has been~very constructive.
They have done a lot of very good work trying to come to grips with some of the problems, come up with alternate approaches and so on. And this certainly is an exampl.
They have attempted to give us an input to this proposed regulation. And as I understand it, they have been quoted to me, that they feel that what we have proposed here is a good, workable solution.
COMMISSIONER GILINSKY:.Have you had any discussions with any other groups that are --
MR. MINOGUE: There were some discussions with AILMA I'm sorry, sir, I didn't hear the end of your question.
COMMISSIONER GILINSKY:
That have been concerned wit occupational doses, or labor groups, or MR.MINOGUE:
Yes.
There was a union representat1ve on this AIF group from the International Brotherhood of Electrical Workers.
That struck me as a little odd.
But in preparing for this briefing, I am assured by some of my associates, that
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9 10 11 12 13 14 31 many of the workers involved in doing this kind of work are, in fact, members of that union.
So I think that is a reasonable effort to get some input froo the workers.
COMMISSIONER GILINSKY: Whatabout other groups'?
I think we had a petition here, was it from the NRDC, on occupational doses?
MR. MINOGUE: Yes, sir.
The NRDC petition speaks to an issue we have touched on peripherally through this briefing, which is what the limits should be.
There are kind of two ways you can come out with occupational exposure. You can look at the ~peed limit. That is, you can look to changing the limit without giving that 15 much concern as to how many people are exposed; or you can put 16 emphasis on ALARA, that is the. concept of trying to reduce the 17 total exposure.
18 The approach reflected in this*rule is really more 19 the ALARA type of approach, and I think the NRDC people 20 generally have put much more emphasis on the speed limit 21 approach, reduce the exposure limits.
22 23 24 COMMISSIONER GILINSKY:
But, did you contact them at all in getting comments from them?
MR. MINOGUE: On this paper?
No, sir, I don't Ace-Federal Reporters, Inc.
believe so.
25 Not.. to my knowledge.
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25 32 We have discussed the limit question with them, of course, on a number of occasions.
COMMISSIONER KENNEDY:
It is proposed -- this paper, as I understand it, it is proposed by the Staff that this paper be put out for comment in any event," is that correct?
MR.MINOGUE:
Yes, sir.
Without faulting them, I don't think that they have generally shown much interest in this {:l!pproach to the problem:
of reducing exposures.
This* is not the way they think yo~ do i It happens to be the way I think you do it.
So we just have,a difference of opinion.
(Slide.)
The last Vugraph discusses, in an effort to be responsive, some of the questions that we have gotten back from various Commissioners; discusses some of the alternatives.
The first one is an entirely different approach.
This was one that Chairman Hendrie raised, which is, couldn't we just set a daily or.a weekly dose limit for transient workers.
The Stafffs view on that is that this is much too.
complicated to use as a basis for regulation.
You wouU:need a data base where you really knew all the operations, what the dose rates are, what the times of exposure are.
You know, there are so*.: many commutations and permutations, it seems to us that you are better off if you
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25 33 basically put this burden on the licensee, who is more directly involved with the operation of the olant rather than try to do it through tech specs.
COMMISSIONER KENNEDY:
If I understand this correctly, this would not limit or eliminate the burden either, of ascertaining what exposure the man had already received?
You still have the same problem?
MR.MINOGUE: That's right, it doesn't change that at all.
It doesn't change that at all.
But if I understood the comment, and I got it indirectly, what Chairman Hendrie was talking.cbout would be more a matter of trying to establish some specific requirement that you_ would really implement to the licensing process in terms of your review of the man's ALARA program.
Of course we do a lot of that already, put the emphasis there. But specifically geared to the question of transient workers. And I think the consensus of Staff is that that just gets too complicated, and it would require more detailed information about the details of the plants than we really have at hand.
It also would eliminate some flexibility that I do think you need.
Many of these operations involve very high levels of particular skills, and you need a framework where you can make a decision to permit exposure of some worker because he is.the only guy that is qualified to do some
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25 34 particular operation, rather than have somebody do it that.,
isn't really qualified.
I think you need some flexibility in the area of occupational exposure.
The other three items*on this Vugraph reflect three possible approaches b,the coverage of this rule.
In presenting it I have made no effort to gloss over the fact that our data gets softer and softer as we get away from reactors.
What we have recommended here is to apply this regulation to all licensees. Bl+/-.there certainly are viable alternatives.
That is the second one.
The third one would be to apply only to the reactor licensees, where we have got a good hard data base, and a good impact assessment, and where clearly a major problem exists where you have.. both high manrem exposures and a large number of transient workers involved.
Another possibility would be t.o broaden that.;some-wha t and cover the radiographers, the processing plants, and th manufacturers of radioactive products --.this being a group tha already has special reporting requirements imposed on it. It would.,basically expand these somewhat.
And then, of ~ourse, the final, which is what the Staff people paper recommends, is to cover all licensees, which would also pick up the medical license~.
If there is any con-troversy that would develop out of putting this regulation out, it would be in the m~dical area.
Our data base is a bit soft,
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25 35 and generally speaking the medical profession does not welcome this type of action on the part of this agency.
So I think I can predict what we recommended may raise some controversy in the area of medical workers.
COMMISSIONER KENNEDY:
Presumably, if that arises, we will hear from them on public comment?
comment.
on this?
MR. MINOGUE:
Yes, sir, this is going out for (Laughter.)
Well, that terminates it.
COMMISSIONER GILINSKY:
Is that about it?
MR. 'MINOGUE:
Yes, sir, that's it.
COMMISSIONER GILINSKY:
Are there any other comments (No response. )
Well, why don't you let us think about this.
Thank you very much.
(Whereupon, at 2:20 p.m., the hearing in the above-entitled matter was concluded.)