ML18271A153

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

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