View source for NUREG/CR-4214, Comments on Quantification of Public Health Risks.Nrc Should Be Encouraged to Use Health Effects Models Noted in NUREG/CR-4214 & SECY-86-8 in Preparation of Environ Assessment & Pra.Addl Comments Provided

{{Adams
| number = ML20155F976
| issue date = 04/16/1986
| title = Comments on Quantification of Public Health Risks.Nrc Should Be Encouraged to Use Health Effects Models Noted in NUREG/CR-4214 & SECY-86-8 in Preparation of Environ Assessment & Pra.Addl Comments Provided
| author name = Ward D
| author affiliation = NRC ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS)
| addressee name = Palladino N
| addressee affiliation = NRC COMMISSION (OCM), NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| docket = 
| license number = 
| contact person = 
| case reference number = FRN-56FR23360, RTR-NUREG-CR-4214
| document report number = AA38-2, AA38-2-0019, AA38-2-19, ACRS-R-1192, NUDOCS 8604280385
| document type = CORRESPONDENCE-LETTERS, INTERNAL OR EXTERNAL MEMORANDUM, MEMORANDUMS-CORRESPONDENCE
| page count = 2
}}

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         #   w. ...g'o,,                           UNITED STATES
       !             n                  NUCLEAR REGULATORY COMMISSION
: o.   $             ,E              ADVISORY COMMITTEE ON REACTOR SAFEGUARDS O                                        WASHINGTON, D. C. 20666 April 16, 1986 Honorable Nunzio J. Palladino Chairman U. S. Nuclear Regulatory Comission Washington, D. C. 20555

==Dear Dr. Palladino:==

==SUBJECT:==
ACRS COMMENTS ON QUANTIFICATION OF PUBLIC HEALTH RISKS In the course of its work, the Advisory Comittee on Reactor Safeguards has in recent months had occasion to review environmental and proba-bilistic risk assessments for several nuclear power plants. One obser-vation made as a result of these reviews is that the NRC Staff does not normally use the best available data and health effects models in estimating the public health risks to nearby population groups due to routine and potential accidental releases of radionuclides from these plants.
Because the NRC has been a leader in support of the development of health effects models (as represented, for example, by the publication of NUREG/CR-4214 in July 1985) and in gaining international hamoniza-tion in the application of such models (as sumarized in SECY-86-8 issued on January 7,1986), we believe that the NRC Staff should be encouraged to move forward more rapidly in using these improved models in the preparation of environmental and probabilistic risk assessments
              .- . . for U. S. plants.
We also recomend that population dose estimates produced as a result of probabilistic risk assessments be expressed both in terms of the total dose and in terms of the number of people exposed within each dose range. In addition, we recomend that the NRC give further considera-l tion to the establishment of a de minimis level for terminating the calculation of collective populatfiin doses associated with such assess-ments. Although the proposed revision of 10 CFR 20 suggests a possible cutoff at a dose rate of I mrem /yr, we believe that selection of such a value should include consideration of the total dose as well as spatial and temporal factors, possibly coupled with appropriate cost-benefit assessments.
Dr. Harold W. Lewis did not participate in the preparation of this report.
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Honorable Nunzio J. Palladino                      April 16, 1986 Additional coments by ACRS Member Harold W. Lewis and by ACRS Members Dade W. Moeller and David Okrent are presented below.
Sincerely, f
i        i     .          .
David A. Ward Chainnan Additional Comments by ACRS Member Harold W. Lewis It gives me great discomfort to add comments to this letter because my only real objection is to its mildness in the face of the fact that the NRC Staff has yet to apply the results of the 1980 Academy Report on the Biological Effects of Ionizing Radiation (a great improvement over the 1972 report) in a single licensing review. This is 1986 and there have been additional improvements since 1980 but they are not yet in finished form. The Comittee says "does not normally," which is, I suppose a euphemism for never.
I do wish the record to show that I did not participate in the prepara-tion of this letter. The Committee completed and fonnally approved a stronger and more complete letter at its March meeting, but it was decided during the intervening month (without benefit of a meeting) not to mail it to you. Since I believe that the final approval of a letter means just that and that this substitution is therefore improper, I could not bring myself to participate.
Additional Comments by ACRS Members Dade W. Moeller and David Okrent We believe that it is relevant to note that, at least in our opinion, the earlier letter was either inaccurate or at best unsatisfactorily incomplete, in one or more of its recomendations.
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