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| issue date = 10/11/2018 | | issue date = 10/11/2018 | ||
| title = C. Jones' Presentation: Nrc'S Radiation Protection Policy - What Does It Take for Change? at the ANS-HPS Joint Topical Meeting in Tri-Cities, Wa - October 2018 | | title = C. Jones' Presentation: Nrc'S Radiation Protection Policy - What Does It Take for Change? at the ANS-HPS Joint Topical Meeting in Tri-Cities, Wa - October 2018 | ||
| author name = Jones C | | author name = Jones C | ||
| author affiliation = NRC/RES/DSA | | author affiliation = NRC/RES/DSA | ||
| addressee name = | | addressee name = | ||
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=Text= | =Text= | ||
{{#Wiki_filter: | {{#Wiki_filter:NRCs Radiation Protection Policy - | ||
*Below Regulatory Concern (BRC) Policy Statements | What Does it Take for Change? | ||
*Is LNT the Issue? Options for Licensees | Cynthia G. Jones, Ph.D. | ||
*Exploring Case Studies | U.S. Nuclear Regulatory Commission Office of Nuclear Regulatory Research 1 | ||
*LNT & ALARA: | ANS-HPS Topic Meeting, October 1, 2018 | ||
*External influencing factors | |||
*Impacts*Thoughts for the Future | Overview | ||
-124; 2005 The Below Regulatory Concern (BRC) Policy Statements | * Key Milestones for Radiation Protection Policy | ||
*NRC issued two BRC policy statements : | * Below Regulatory Concern (BRC) Policy Statements | ||
-1986: Radioactive Waste BRC | * Is LNT the Issue? Options for Licensees | ||
-1990: BRC Policy Statement for a consistent risk framework | * Exploring Case Studies | ||
*Low-Level Radioactive Waste Policy Amendments Act of 1985 | * LNT & ALARA: Why go beyond ALARA? | ||
*1991: NRC issues indefinite moratorium on use of the statements | * External influencing factors | ||
*1992: Energy Policy Act of 1992 revoked the 1986 and 1990 BRC policy statements | * Impacts | ||
*1993: Formal withdrawals of BRC Policy Statements and related rulemaking which would have implemented the 1986 BRC Waste Statement | * Thoughts for the Future 2 | ||
*NRC continues to issue exemptions on a case | ANS-HPS 2018 Topical Meeting, October 1, 2018 | ||
-by-case basis | |||
*2009-12: NRC engaged in extensive stakeholder outreach to update Part 20 & Part 50, App. I | Key Milestones* | ||
*2012: NRC Commission direction (SECY 0064):-Update methodology and terminology to align with ICRP 103 | NRC Radiation Protection Policy 1957: Atomic Energy Commission issues 10 CFR Part 20 1977: ICRP 26 published 1980: BEIR III issued 1980: NRC issues an Advanced Notice of Proposed Rulemaking 1986: NRC issues proposed Part 20 changes 1987: NCRP issues Report 91 1990: NRC Below Regulatory Concern Policy Statement issued 199o-1: ICRP Report 60 issued 1991: NRC issues its revised Part 20 updating it to ICRP 26 & 30 2007: ICRP issues Report 103 2009: NRC: stakeholder outreach to update Part 20 & Part 50, App. I 2016: NRC discontinues Part 20 & Part 50, App. I rulemakings ANS-HPS 2018 Topical Meeting, October 1, 2018 *See also Health Phys. 88(2): 105-124; 2005 3 | ||
-Develop improvements for effective implementation of ALARA | |||
-Continue discussions for dose limits to the lens of the eye & embryo/fetus | The Below Regulatory Concern (BRC) | ||
-Disapproved reduction of dose limits from 50 mSv/y to 20 mSv/y | Policy Statements | ||
-Disapproved SI units | * NRC issued two BRC policy statements : | ||
-Improve reporting of occupational exposure | - 1986: Radioactive Waste BRC | ||
*2014: Advanced Notice of Proposed Rulemaking for Part 20 | - 1990: BRC Policy Statement for a consistent risk framework | ||
*2015: Advanced Notice of Proposed Rulemaking for Part 50, App I | * Low-Level Radioactive Waste Policy Amendments Act of 1985 | ||
*SECY-16-0009: | * 1991: NRC issues indefinite moratorium on use of the statements | ||
*Dec 2016: NRC discontinues Part 20 & Part 50, App. I rulemakings | * 1992: Energy Policy Act of 1992 revoked the 1986 and 1990 BRC policy statements | ||
1.Petition for rulemaking 2.Request an exemption 3.ALARA & Decommissioning | * 1993: Formal withdrawals of BRC Policy Statements and related rulemaking which would have implemented the 1986 BRC Waste Statement | ||
*2015: NRC received 3 similar petitioner requests* to amend Part 20 with regard to the LNT hypothesis (80 FR 35870 ) | * NRC continues to issue exemptions on a case-by-case basis ANS-HPS 2018 Topical Meeting, October 1, 2018 4 | ||
*Petitioners assert that valid scientific studies and evidence exist that contradicts LNT hypothesis | |||
*Petitioners recommend | Evolving NRC Policy | ||
- | * 2009-12: NRC engaged in extensive stakeholder outreach to update Part 20 & Part 50, App. I to reach alignment with ICRP 103 | ||
-End differing doses limits for pregnant women, embryos and fetuses, and children under 18 years of age 7 | * 2012: NRC Commission direction (SECY-12-0064): | ||
*>3,200 public comment letters received | - Update methodology and terminology to align with ICRP 103 | ||
*NCRP Commentary 27* issued in April 2018: | - Develop improvements for effective implementation of ALARA | ||
-Review of recent epidemiologic studies support the continued use of the LNT model for radiation protection | - Continue discussions for dose limits to the lens of the eye & embryo/fetus | ||
-Concluded that no alternate dose | - Disapproved reduction of dose limits from 50 mSv/y to 20 mSv/y | ||
-response relationship appears better than LNT | - Disapproved SI units | ||
*Currently developing a Commission paper for a decision on petitioners requests | - Improve reporting of occupational exposure | ||
* NCRP Commentary 27, | * 2014: Advanced Notice of Proposed Rulemaking for Part 20 | ||
-Nonthreshold Model and Radiation Protection Ex 2: | * 2015: Advanced Notice of Proposed Rulemaking for Part 50, App I | ||
-SECY-99-077: Approval for a Th licensee to use alternate ICRP internal dosimetry models (ICRP 68); and to approve future exemptions, case | * SECY-16-0009: Recommendation to discontinue rulemaking | ||
-by-case (e.g., fuel cycle facilities) | * Dec 2016: NRC discontinues Part 20 & Part 50, App. I rulemakings 5 | ||
-SECY-99-136: Exemptions granted to transfer baghouse slag containing <0.05 wt% source material to exempt persons if doses were less than 1 mSv/y (NRC notification if >0.25 mSv) | ANS-HPS 2018 Topical Meeting, October 1, 2018 | ||
-SECY-01-0148 : Continuance to consider and grant licensee requests to use the ICRP revised internal dosimetry models on a case-by-case basis | |||
-based and risk | Is LNT the issue? | ||
-informed:-NRC terminates ~100 materials licenses/y | What are the Options for Licensees? | ||
-NUREG-1757, V2, R1: Decommissioning Guidance | Case studies: | ||
-Reasonable land use | : 1. Petition for rulemaking | ||
-Flexibility: screening vs site | : 2. Request an exemption | ||
-specific dose assessment | : 3. ALARA & Decommissioning 6 | ||
-No calculations needed for ALARA (App N) | ANS-HPS 2018 Topical Meeting, October 1, 2018 | ||
-No need to go below the regulatory limits | |||
-Requests for exemptions (e.g., ICRP 26 | Ex 1: Petition for Rulemaking | ||
-2002 NRC-EPA MOU: facilitates decision | * 2015: NRC received 3 similar petitioner requests* to amend Part 20 with regard to the LNT hypothesis (80 FR 35870 ) | ||
-making | * Petitioners assert that valid scientific studies and evidence exist that contradicts LNT hypothesis | ||
*10 CFR 20.1101(b) | * Petitioners recommend | ||
-implementation of ALARA | - Workers effective doses up to 100 mSv (10 rem) per year if chronic | ||
*NRC Regulatory Guide 8.29 (1996) | - Removal of ALARA from the regulations, as it makes no sense to decrease radiation doses that are not only harmless, but may be hormetic | ||
-Because of the | - Raise public dose limits to same level as worker dose limits, as these low doses may be hormetic | ||
*ALARA is intended to be an operating principle rather than an absolute minimization of exposures*What pushes licensees to go beyond ALARA? | - End differing doses limits for pregnant women, embryos and fetuses, and children under 18 years of age 7 | ||
ANS-HPS 2018 Topical Meeting, October 1, 2018 *PRM-20-28, PRM-20-29 and PRM-20-30 | |||
*But licensees have many external factors: | |||
-NRC as the regulator | Current Status of LNT Petitions | ||
-Stakeholder questions/concerns | * >3,200 public comment letters received | ||
-Other Federal or State regulations | * NCRP Commentary 27* issued in April 2018: | ||
-Accreditation requirements | - Review of recent epidemiologic studies support the continued use of the LNT model for radiation protection | ||
-Insurance requirements | - Concluded that no alternate dose-response relationship appears better than LNT | ||
-Peer pressure to lower doses | * Currently developing a Commission paper for a decision on petitioners requests | ||
* NCRP Commentary 27, Implications of Recent Epidemiologic Studies for the Linear-Nonthreshold Model and Radiation Protection 8 ANS-HPS 2018 Topical Meeting, October 1, 2018 | |||
*UNSCEAR highlights the concepts of attributability, inference of risk, and use of collective dose which could impact | |||
-Justification | Ex 2: Exemptions NRC receives and has approved many exemptions to Part 20 based on justification. Examples include: | ||
-Optimization | - SECY-99-077: Approval for a Th licensee to use alternate ICRP internal dosimetry models (ICRP 68); and to approve future exemptions, case-by-case (e.g., fuel cycle facilities) | ||
-Graded approach | - SECY-99-136: Exemptions granted to transfer baghouse slag containing <0.05 wt% source material to exempt persons if doses were less than 1 mSv/y (NRC notification if >0.25 mSv) | ||
-Low doses and associated uncertainties | - SECY-01-0148 : Continuance to consider and grant licensee requests to use the ICRP revised internal dosimetry models on a case-by-case basis 9 | ||
-The LNT hypothesis & its use in the safety standards | ANS-HPS 2018 Topical Meeting, October 1, 2018 | ||
-Challenges in communicating radiation benefits and risks | |||
*Stakeholder engagement & communication support are needed for paradigm shift | Ex 3: ALARA & Decommissioning Current 1997 decommissioning regulations are performance-based and risk-informed: | ||
*Educate external influences for a moderate approach | - NRC terminates ~100 materials licenses/y | ||
*Focus on the facts that NRC regulations do allow for flexibility to: | - NUREG-1757, V2, R1: Decommissioning Guidance | ||
-Use risk-informed, performance based approaches for implementation | - Reasonable land use | ||
-Request exemptions to use new models/methodology | - Flexibility: screening vs site-specific dose assessment | ||
*Completion of the health risk assessment from low | - No calculations needed for ALARA (App N) | ||
-dose/ dose rates (Million Worker Study) | - No need to go below the regulatory limits | ||
*Improving realism in dose assessment | - Requests for exemptions (e.g., ICRP 26 72) | ||
*Use the UNSCEAR concepts of attribution in practice | - 2002 NRC-EPA MOU: facilitates decision-making 10 ANS-HPS 2018 Topical Meeting, October 1, 2018 See www.nrc.gov/waste/decommissioning.html | ||
*Use of ALARA as designed | |||
*Strong scientific support for a different dose | LNT & ALARA | ||
-response relationship | * 10 CFR 20.1101(b) - implementation of ALARA | ||
*For change to occur there must be international and national consensus | * NRC Regulatory Guide 8.29 (1996) | ||
- Because of the ..absence of scientific certainty regarding the relationship between low doses and health effects, LNT is used as a conservative assumption for radiation protection purposes | |||
* ALARA is intended to be an operating principle rather than an absolute minimization of exposures | |||
* What pushes licensees to go beyond ALARA? | |||
11 ANS-HPS 2018 Topical Meeting, October 1, 2018 | |||
Why go beyond ALARA? | |||
ALARA: making a reasonable effort to maintain exposures as far below the limit as is practical | |||
* But licensees have many external factors: | |||
- NRC as the regulator | |||
- Stakeholder questions/concerns | |||
- Other Federal or State regulations | |||
- Accreditation requirements | |||
- Insurance requirements | |||
- Peer pressure to lower doses 12 ANS-HPS 2018 Topical Meeting, October 1, 2018 | |||
Where do we go from here? | |||
13 ANS-HPS 2018 Topical Meeting, October 1, 2018 | |||
UNSCEAR 2015 Report Attributing Health Effects to Ionizing Radiation Exposure and Inferring Risks | |||
* UNSCEAR highlights the concepts of attributability, inference of risk, and use of collective dose which could impact | |||
- Justification | |||
- Optimization | |||
- Graded approach | |||
- Low doses and associated uncertainties | |||
- The LNT hypothesis & its use in the safety standards | |||
- Challenges in communicating radiation benefits and risks ANS-HPS 2018 Topical Meeting, October 1, 2018 14 | |||
Impacts | |||
* Regulatory agencies make changes based upon science, national and international recommendations, and in the U.S., the participatory rulemaking process | |||
* Stakeholder engagement & communication support are needed for paradigm shift | |||
* Educate external influences for a moderate approach | |||
* Focus on the facts that NRC regulations do allow for flexibility to: | |||
- Use risk-informed, performance based approaches for implementation | |||
- Request exemptions to use new models/methodology 15 ANS-HPS 2018 Topical Meeting, October 1, 2018 | |||
Thoughts for the Years Ahead | |||
* Completion of the health risk assessment from low-dose/ | |||
dose rates (Million Worker Study) | |||
* Improving realism in dose assessment | |||
* Use the UNSCEAR concepts of attribution in practice | |||
* Use of ALARA as designed | |||
* Strong scientific support for a different dose-response relationship | |||
* For change to occur there must be international and national consensus ANS-HPS 2018 Topical Meeting, October 1, 2018 16 | |||
Thank you! | |||
For further information, contact: | |||
cynthia.jones@nrc.gov www.nrc.gov 17}} |
Latest revision as of 14:25, 20 October 2019
ML18271A153 | |
Person / Time | |
---|---|
Issue date: | 10/11/2018 |
From: | Clint Jones NRC/RES/DSA |
To: | |
Jones C | |
References | |
Download: ML18271A153 (17) | |
Text
NRCs Radiation Protection Policy -
What Does it Take for Change?
Cynthia G. Jones, Ph.D.
U.S. Nuclear Regulatory Commission Office of Nuclear Regulatory Research 1
ANS-HPS Topic Meeting, October 1, 2018
Overview
- Key Milestones for Radiation Protection Policy
- Below Regulatory Concern (BRC) Policy Statements
- Is LNT the Issue? Options for Licensees
- Exploring Case Studies
- LNT & ALARA: Why go beyond ALARA?
- External influencing factors
- Impacts
- Thoughts for the Future 2
ANS-HPS 2018 Topical Meeting, October 1, 2018
Key Milestones*
NRC Radiation Protection Policy 1957: Atomic Energy Commission issues 10 CFR Part 20 1977: ICRP 26 published 1980: BEIR III issued 1980: NRC issues an Advanced Notice of Proposed Rulemaking 1986: NRC issues proposed Part 20 changes 1987: NCRP issues Report 91 1990: NRC Below Regulatory Concern Policy Statement issued 199o-1: ICRP Report 60 issued 1991: NRC issues its revised Part 20 updating it to ICRP 26 & 30 2007: ICRP issues Report 103 2009: NRC: stakeholder outreach to update Part 20 & Part 50, App. I 2016: NRC discontinues Part 20 & Part 50, App. I rulemakings ANS-HPS 2018 Topical Meeting, October 1, 2018 *See also Health Phys. 88(2): 105-124; 2005 3
The Below Regulatory Concern (BRC)
Policy Statements
- NRC issued two BRC policy statements :
- 1986: Radioactive Waste BRC
- 1990: BRC Policy Statement for a consistent risk framework
- Low-Level Radioactive Waste Policy Amendments Act of 1985
- 1991: NRC issues indefinite moratorium on use of the statements
- 1992: Energy Policy Act of 1992 revoked the 1986 and 1990 BRC policy statements
- 1993: Formal withdrawals of BRC Policy Statements and related rulemaking which would have implemented the 1986 BRC Waste Statement
- NRC continues to issue exemptions on a case-by-case basis ANS-HPS 2018 Topical Meeting, October 1, 2018 4
Evolving NRC Policy
- 2009-12: NRC engaged in extensive stakeholder outreach to update Part 20 & Part 50, App. I to reach alignment with ICRP 103
- 2012: NRC Commission direction (SECY-12-0064):
- Update methodology and terminology to align with ICRP 103
- Develop improvements for effective implementation of ALARA
- Continue discussions for dose limits to the lens of the eye & embryo/fetus
- Disapproved reduction of dose limits from 50 mSv/y to 20 mSv/y
- Disapproved SI units
- Improve reporting of occupational exposure
- 2014: Advanced Notice of Proposed Rulemaking for Part 20
- 2015: Advanced Notice of Proposed Rulemaking for Part 50, App I
- SECY-16-0009: Recommendation to discontinue rulemaking
- Dec 2016: NRC discontinues Part 20 & Part 50, App. I rulemakings 5
ANS-HPS 2018 Topical Meeting, October 1, 2018
Is LNT the issue?
What are the Options for Licensees?
Case studies:
- 1. Petition for rulemaking
- 2. Request an exemption
- 3. ALARA & Decommissioning 6
ANS-HPS 2018 Topical Meeting, October 1, 2018
Ex 1: Petition for Rulemaking
- 2015: NRC received 3 similar petitioner requests* to amend Part 20 with regard to the LNT hypothesis (80 FR 35870 )
- Petitioners assert that valid scientific studies and evidence exist that contradicts LNT hypothesis
- Petitioners recommend
- Workers effective doses up to 100 mSv (10 rem) per year if chronic
- Removal of ALARA from the regulations, as it makes no sense to decrease radiation doses that are not only harmless, but may be hormetic
- Raise public dose limits to same level as worker dose limits, as these low doses may be hormetic
- End differing doses limits for pregnant women, embryos and fetuses, and children under 18 years of age 7
ANS-HPS 2018 Topical Meeting, October 1, 2018 *PRM-20-28, PRM-20-29 and PRM-20-30
Current Status of LNT Petitions
- >3,200 public comment letters received
- NCRP Commentary 27* issued in April 2018:
- Review of recent epidemiologic studies support the continued use of the LNT model for radiation protection
- Concluded that no alternate dose-response relationship appears better than LNT
- Currently developing a Commission paper for a decision on petitioners requests
- NCRP Commentary 27, Implications of Recent Epidemiologic Studies for the Linear-Nonthreshold Model and Radiation Protection 8 ANS-HPS 2018 Topical Meeting, October 1, 2018
Ex 2: Exemptions NRC receives and has approved many exemptions to Part 20 based on justification. Examples include:
- SECY-99-077: Approval for a Th licensee to use alternate ICRP internal dosimetry models (ICRP 68); and to approve future exemptions, case-by-case (e.g., fuel cycle facilities)
- SECY-99-136: Exemptions granted to transfer baghouse slag containing <0.05 wt% source material to exempt persons if doses were less than 1 mSv/y (NRC notification if >0.25 mSv)
- SECY-01-0148 : Continuance to consider and grant licensee requests to use the ICRP revised internal dosimetry models on a case-by-case basis 9
ANS-HPS 2018 Topical Meeting, October 1, 2018
Ex 3: ALARA & Decommissioning Current 1997 decommissioning regulations are performance-based and risk-informed:
- NRC terminates ~100 materials licenses/y
- NUREG-1757, V2, R1: Decommissioning Guidance
- Reasonable land use
- Flexibility: screening vs site-specific dose assessment
- No calculations needed for ALARA (App N)
- No need to go below the regulatory limits
- Requests for exemptions (e.g., ICRP 26 72)
- 2002 NRC-EPA MOU: facilitates decision-making 10 ANS-HPS 2018 Topical Meeting, October 1, 2018 See www.nrc.gov/waste/decommissioning.html
LNT & ALARA
- 10 CFR 20.1101(b) - implementation of ALARA
- NRC Regulatory Guide 8.29 (1996)
- Because of the ..absence of scientific certainty regarding the relationship between low doses and health effects, LNT is used as a conservative assumption for radiation protection purposes
- ALARA is intended to be an operating principle rather than an absolute minimization of exposures
- What pushes licensees to go beyond ALARA?
11 ANS-HPS 2018 Topical Meeting, October 1, 2018
Why go beyond ALARA?
ALARA: making a reasonable effort to maintain exposures as far below the limit as is practical
- But licensees have many external factors:
- NRC as the regulator
- Stakeholder questions/concerns
- Other Federal or State regulations
- Accreditation requirements
- Insurance requirements
- Peer pressure to lower doses 12 ANS-HPS 2018 Topical Meeting, October 1, 2018
Where do we go from here?
13 ANS-HPS 2018 Topical Meeting, October 1, 2018
UNSCEAR 2015 Report Attributing Health Effects to Ionizing Radiation Exposure and Inferring Risks
- UNSCEAR highlights the concepts of attributability, inference of risk, and use of collective dose which could impact
- Justification
- Optimization
- Graded approach
- Low doses and associated uncertainties
- The LNT hypothesis & its use in the safety standards
- Challenges in communicating radiation benefits and risks ANS-HPS 2018 Topical Meeting, October 1, 2018 14
Impacts
- Regulatory agencies make changes based upon science, national and international recommendations, and in the U.S., the participatory rulemaking process
- Stakeholder engagement & communication support are needed for paradigm shift
- Educate external influences for a moderate approach
- Focus on the facts that NRC regulations do allow for flexibility to:
- Use risk-informed, performance based approaches for implementation
- Request exemptions to use new models/methodology 15 ANS-HPS 2018 Topical Meeting, October 1, 2018
Thoughts for the Years Ahead
- Completion of the health risk assessment from low-dose/
dose rates (Million Worker Study)
- Improving realism in dose assessment
- Use the UNSCEAR concepts of attribution in practice
- Use of ALARA as designed
- Strong scientific support for a different dose-response relationship
- For change to occur there must be international and national consensus ANS-HPS 2018 Topical Meeting, October 1, 2018 16
Thank you!
For further information, contact:
cynthia.jones@nrc.gov www.nrc.gov 17