ML20202G024

Forwards,For Review & Concurrence,Draft Commission Paper & Proposed Notice of Intent for Rulemaking on Establishment of Dollar Per man-rem Value

ML20202G024
Person / Time
Issue date:	09/04/1975
From:	Mattson R NRC OFFICE OF STANDARDS DEVELOPMENT
To:	Karen Chapman, Knuth D, Kouts H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS), NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
References
NUDOCS 9902040240
Download: ML20202G024 (40)

Text

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,# g UNITED STA1E5 NUCLEAR REGULATORY COMMISSION

, ASHINGTON, D. C. 20555 W

SEP -41975~

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Kenneth R. Chapman, Director Office of Nuclear Material Safety and Safeguards Donald F. Knuth, Director i

Office of Inspection and Enforcement Herbert J. C. Kouts, Director Office of Nuclear Regulatory Research g ard C. Rusche, Director Ofrice of Nuclear Reactor Regulation REVIEW OF DRAFT COMMISSION ISSUE PAPER ON PROPOSED RULEMAKING FOR AFFIXING THE WORTH OF THE MONETARY VALUE OF RADIATION EXPOSURE REDUCTION Attached for your review and concurrence are two copies of a draft Commission paper and a proposed Notice of Intent for the rulemaking on the establishment of a dollar per man-ren value. Because of the urgent need for getting this document to the Commission, please telephone ou - m,.y.a.ur comments or suggestions to Harold Peterson of this Division I

(443-6900) as soon as possible.

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VL Roger J. Mattson, et ng Director Division of Site, Health, and Safeguards Standards Office of Standards Development

Enclosures:

1.

Issue Paper and Detailed Discussion of Alternative 2.

Proposed Notice of Intent

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For:

The Commissioners Thru:

Executive Director for Operations

Subject:

PROPOSED RULEMAKING ON THE MONETALY VALUE OF THE WORTH OF RADIATION EXPOSURE REDUCTION f

Purpose:

Commission decision on scope and content of rule-making to be described in Notice of Intent.

Categorv:

This paper concerns a major policy question.

Issues:

1.

Should the Rt lemaking Hearing be held jointly by NRC and EPA?

2.

What should the scope of the Rulemaking be, i.e., will the $/ man-rem value apply to doses received from all sources?

3.

What method (s) should be used to arrive at a dollar value?

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Issue 1 (Joint Rulemaking with (EPA) l i

Decision Criteria:

1.

EPA is developing Federal guidance on the I

(Issue 1) methodology to be used in determining as low l

l as practicable radiation exposure 1cvels.

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l 2.

EPA has proposed generally applicable environmental radiation standards for the uranium fuel cycle.

l The cost-effectiveness of these proposed standards is stated by EPA to be considerably below the Commission's interim value of $1,000 per man-rem l

reduction.

Alternatives:

Alternative 1.

Conduct a joint rulemaking with EPA.

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1 (Issue 1)

Alternative 2.

Conduct a separate rulemaking with EPA participation.

Discusnfon:

Alternative 1 has the advantage. EPA may issue Federal (Issue 1) guidance under its FRC authorities on the methodology to be used in determining as low as practicabic radiation i

exposure IcVels.

NRC would have to employ the EPA

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l methodology in determining the value of the worth of radiation exposure reductions.

If this guidance i

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differs appreciably from the methods used by NRC, the t

rev.isions necessitated ^in our methods may lead to considerable delay in the proposed rulemaking.

If a ; int rulemaking were conducted, EPA would also be bound to employ the S/ man-rem value determined by

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the rulemaking and m1 ht issue the value as guidance 6

to all Federal agencies. A joint rulemaking could provide a consistent S/ man-rem value for use by all Federal agencies and provide an example of interagency coordination rather than an apparent duplication of efforts.

There are several potential problems which would have to be resolved concerning the conduct of a joint hearing and the decision process to arrive at a final determination.

Coordination of activities and resolution of the decision mechanisms to be employed might extend the time required for the rulemaking by 6-8 months. A joint rulemaking might also limit the Commission's flexibility in arriving at an appropriate

$/ man-rem value.

The staff recommends that Alternative 1 be selected and a joint rulemaking be conducted.

The staff l

believes that the advantages of interagency coordination l

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s 0 and th'e development of a consistent value for use by all Fede al gencies outweigh possibic restrictions on the Commission's decision ficxibility.

Possible delays due to conducting a joint rulemaking may be comparabic to increased time required to modify the NRC methodology to conform to any Federal guidance developed by EPA.

Issue 2 (Scope of Rulemaking)

Decision Criteria:

1.

The Commission did not expressly limit the (Issue 2) proposed rulemaking to light-water reactors when it announced its intention to conduct this rule-making in the opinion of RM-50-2.

2.

There are ongoing studies of ALARA effluents for licensed facilities other than LWRS.

3.

There is a current program under development con-cerning ALARA for occupational exposure.

4.

If the Commission selects Alternative 1 of Issue 1, then EPA concurrence on Issue 2 will be required.

5.

• There may be distinct differences between the approaches for determining ALARA values for occupational exposures and those result:ng from effluents.

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Alternatives:

Alternative 1.

Limit rulemaking to determining (Issue 2)

$/ man-rem and $/ thyroid-rem values for application to ligt.t-water cooled nuclear power reactor ef fluents.

i Alternative 2.

Expand rulemaking to determine values which could be applied to all radioactive effluents from nuclear fuel cycle facilities.

Alternative 3.

Further expand the scope of the rule-making to encompass values for application to ALARA reductions in occupational radiation' exposure.

Alternative 4.

Further expand the scope to consider I

an appropriate value for application to low-probability accidents.

Alternative 5.

Do not initially restrict scope of rulemaking but solicit public comment on alteratives l

1-4.

Determine the scope of application as a finding of the rulemaking.

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Discussion:

The NRC staff does not believe that there would be l

(Issue 2) differences between the application of the monetary i

l worth values to population exposures from nucicar l

facility effluents which would be significant enough l

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to warrant separate values for different types of nuclear I

facilities. The staff does foresee potential differences between population exposure from effluents and occupational exposure which may require distinctly different approaches to determine ALARA Icvels. The differences the staf f has identified are:

l 1.

occupational exposure generally entails considerably higher' dose rates and higher individual doses than general population exposure from effluents, 2.

for occupational exposure, protection of the l

individual rather than an exposed population I

may be the primary concern, hence the $/ man-rem i

value may have limited application (instead a j

$/ rem value may be needed),

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l 3.

a $/ rem value for occupational exposure may bc l

b'ased upon the cost of providing additional workers l

1 in order to keep individual exposures below the 3 rem / quarter limit of 10 CFR Part 20.

The addf-1 ional costs incurred to hire additional highly skilled workers rather than providing reductions of l

individual exposures by shiciding or other tech-r 4

nology may Icad to acceptabic reduction costs I

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($/ rem) which are an order of magnitude higher than the Commission's interim $1,000/ man-rem value.

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4.

Occupational radiation exposure may be viewed as voluntary risk acceptance compared to the 1

involuntary risk imposed by facility effluents.

In expanding the scope of the rulemaking to include the determination of $/ man-rem values for application to cost-effectiveness analyses for accident preventing or consequence Ifmiting engineered safety features, several additional problems are foreseen:

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The doses received by individuals from accidents t

l conceivably could approach the levels where observable biological effects are manifested i

rather than the infinitesimal statistical individual risks which are inferred to exist at the very low doses due to effluents released during normal operation.

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2.

Considerably higher expenditures are justified l

t to prevent an immediate injury than to remove a statistical risk of low magnitude.

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The dose from accidental releases may be delivered at such high dose rates that the dose-response is markedly non-linear.

4.

A $/ man-rem developed on risk probabilities may not' justify current engineered safety features.

Despite these apparent differences, the staff believes that there is a possibility of arriving at an appropriate $/ man-rem or $/ rem values for i

occupational radiation exposure reductions and the prevention of large impact low-probability accidents.

It would be preferable for the scope of the rulemaking to derive out of the testimony rather than t,o b'e a constraint on the hearing.

Therefore, Alternative 5 is recommended.

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i Issue 3 (Methods to be Employed in Selecting a Value j

Decision Criteria:

1.

The $/ man-rem and $/ thyroid-rem values may be (Issue 3) explicitly related to the monetary worth of a human life or the cost of injury. This relation-l ship may generate adverse public reaction to l

l the proposed rulemaking.

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• 2 2.

The Commission has recogniz'ed moral, social, and human considerations may be important in arriving at the value for $/ man-rem.

3.

These additional considerations involving moral, social, and human values have not been previously explored by the :;RC staff, and considerable effort will have to be devoted to acquiring information and developing methodologies to incorporate them into the decision process.

4.

If the Commission adopts Alternative 1 of Issue 1, EPA concurrence would be required in the methods to be employed.

Alternatives:

Alternative 1.

Base the value(s) upon life cost and injury cost estimates and the statistical estimates of the biological effects due to radiation e'xposure.

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i Alternative 2.

Base the value(s) primarily upon equivalent costs that are incurred by society to reduce other perils to the same risk level, i

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Alternative 3.

Explore all of the above factors 1-2 i

but omit consideration of psychological risk percep-tion differences, i

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Altern'ative 4.

Explore all of the above factors l

1-3 but also consider psychological risk perception in arriving at a value.

l Discussion:

The staff has identified four methodologies for l

(Issue 3) arriving at the value of the worth of radiation exposure reduction.

The first method would be to examine the existing published values and select an appropriate value. The Commission has rejected-this method as a l

viable alternative since it would not necessarily l

be an independent determination.

The staff does not believe that sufficient additional information would be developed beyond what was presented in the Appendix I rulemaking to permit the selection of a value.

1 The second method would entail the examination of t'he monetary values used in society for prever. tion of loss-of-life or injury. This " life value" could then bc employed with statistical estimates of potential rad-intion effects to yield the required monetary value using the relationship:

cost / man-rem = cost /effect x effects / man-rem i

f This relationship is the basis of most of the existing i

$/ man-rem values and represents a viable method 4

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l (Alternative 1).

The staff proposes to thoroughly

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explore the range of " life values" employed throughout society and the biological dose-effect values which have been examined by the National Academy of Sciences (BEIR Report), the International Commission on Radiation Protection (ICRP), the United Nations Faientific Committee on the Effects of Atomic Radiation (UNSCEAR),

and other scientific bodies to arrive at $/ man-rem and $/ organ-rem values.

A third method which may be employed to obtain the

$/ man-rem value is predicated upon defining an " expected level of risk" for radiation injury. This level of risk i

might be defined as the integral of the area under the effect-probability cu'rve (the plot of estimated impact versus the estimated probability of occurrence) including normal effluents from routine operations, low-impact highly probable inadvertent releases, and low-probability high-impact accidents.

This total expected risk value could then be related to the expected risks from natural disasters (flood, fire, carthquake, etc.) and from man-made perils (automobiles, air transport, etc.).

The cost of preventing the occurrence or limiting the consequences of these other perils would also be examined. The costs to reda=2 the expected risk from these other natural and m

4 man-made perils to the level of the expected torni risk from releases of radioactive material would then be used to determine a value for the worth of radiation exposure reduction. The staff believes that this method might prove useful and presents it to the Commission as Alternative 2.

The Alternative 3 co Issue 2 would have the staff explore the applications of all of-the above methodologies in order to arrive at the $/ man-rem value.

The fourth method that might be employed to determine a

$/ man-rem value is based upon examination of individual human values for the worth of risk reduction. This would entail the examination of personal rather than societal expenditures for safety and risk prevention. This method would take into account differences between perceived risks and actual risks and the psychological factors which affect risk perception. Although the staff does not believe that this method alone should be used to arrive at the $/ man-rem value (or values), it may provide additional relevant information when combined with one or more of the above methods.

Consideration of this approach in addition to the three other methods is pro-posed to the Commi ssion as Alternative 4 to Issue 3.

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Summary:

The staff recommends that:

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1) The rulemaking be conducted jointly with EPA.

f (Alternative 1 of Issue 1) i a

2)

The scope of the application for $/ man-rem and-

$/ organ-rem values be a finding of the rulemaking.

(Alternative 5 of Issue 2) i i

3)

A variety of methods be utilized in the proposed determination to provide the broadest base for reaching a decision.

(Alternative 4 of Issue 3) l I

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l DETAILED DISCUSSION OF ALTERNATIVES l

Issue 1 (Conduct of Rulemaking)

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Alter. native 1.

Conduct a Joint Rulemaking with EPA.

EPA is working on Federal Guidance on the Pros:

a.

methodology to be used to determine "as low as practicable" radiation exposures and NRC i

would be required to employ this methodology.

b.

NRC and EPA would use the same value, eliminating inconsistencies, EPA is favorable toward a cooperative approach.

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c.

1 The additional planning and coordination Cons:

a.

could delay the rulemaking 6 months to a l

year. liowever, a similar delay might be anticipated if NRC had to adopt its methods T

to-Fl>A's Faderal guidance.

b.

The scope of their guidance is directed toward j

the methodology and not to selecting specific values.

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h' Alternative 2.

Conduct a separate rulemaking.

Pros:

a.

The rulemaking would not involve dual direction.

b.

It could proceed more expeditiously.

l Cons:

a.

Proceeding separately could give the external appearance of duplicative and uncoordinated activities.

l b.

EPA could issue Federal guidance before the proposed rulemaking is completed.

Alternative 3.

Defer action until EPA issues guidance.

Pros:

a.

The impact of their actions upon the proposed rulemaking could be fully judged.

Cons:

a.

A delay would be contrary to the Commission's publicly-expressed intention to proceed "at the earliest possible date".

b.

NRC would be placed in a responsive rather than leadership position.

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The delay could impact upon licensing actions c.

by requiring use of the interim values for a j

longer period.

1 Issue 2 (Scope of Proceedin3,s,l Alternative 1.

Limit Rulemaking to light-water-cooled nuclear power reactors.

Pros:

a.

Consistent with the Commission's stated intention in the opinion on Appendix I to 10 CFR Part 50'.

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b.

Does not involve consideration of long-term 4

impacts.

Cons:

a.

Would require separate rulemakings for other fuel cycle facilities.

i b.

There are no major differences foreseen by the staff between the magnitude and appli-3 cation of t'hese values.

Alternative 2.

Expand rulemaking to determine a value which could be applied to radioactive effluents from all fuel cycle facilities.

Pros:

a.

Would eliminate separate rulemakings b.

The issues and considerations would be similar l

for all classes of facilities.

i Wou'd be consistent with the Commission's I

c.

intent to develop ALARA effluent criteria for other fuel cycle facilities.

Cons:

a.

May require additional consideration of world-wide and long-torn impacts i

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b.

The cost-effectiveness of effluent reduction t

for other facilities has not been fully i

evaluated.

Alternative 3.

Expand rulemaking to include occupational t

exposure.

Pros:

a.

A separate rulemaking would not be required, b.

Provides a consistent protection philosophy for both occupational and population exposure.

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Cons:

1. Risk to occupationally exposed individuals may be orders of magnitude greater than the risk to a member of the population.

2. May not be abic to justify current level of protection being provided in accordance with j

accepted safe operating practices.

3. Protection must be afforded against occu-pational exposure from accidents which have a higher probability of occurrence than accidents which would affect off-site populations.

4. Certain protective devices are provided to prevent excessive exposures which should not l

be subject to a $/ man-rem factor.

5. The costs of maintaining current individual exposure limits can be based upon the alter-i native of hiring additional skilled laborers.

Such costs have been estimated at $5,000 -

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$10,000 per man-rem.

Thus, the magnitude i

of the occupational monetary value may be expected to be higher than the value derived I

for population exposure reduction.

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6. The considerations could be different for involu..tary vs voluntary exposure.

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forecloses options on how ALARA for i

occupational exposure would be set.

i Alternative 4.

Expand rulemaking beyond Alternative 3 i

to include a $/ man-rem value for application to accident prevention.

i Pros:

a.

Would define siting or plant design criteria.

Cons:

a.

Might not justify existing engineered safety features due to the low probability of the expected risk.

j b.

Involves higher individual doses than normal effluents. The $/ man-rem might vary with the magnitude of the individual dose.

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Additional considerations would have to be c.-

included (e.g., costs of protective, action measures for controlling consequences following a release).

d.

Could extend time to complete rulemaking by one-year in order to develop these additional data.

Alternative 5.

Defer decision and permit scope of rulemaking to be defined at a later date after initial public response.

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Pros:

a.

Would permit public comment on broadest issues and involve public in determining scope.

b.

Does not foreclose Commission options to restrict scope at a later date.

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Permits rulemaking process to be initiated i

prior to investigating all issues in deptn.

Cons:

a.

Public comments may require that all issues be considered-despite staff findings that scope should be limited.

Issue 3 (Considerations to be Used) l Alternative 1.

Derive value from an examination of l

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existing life values.

Pros:

a.

would rely on societal value judgments.

b.

could represent an independent assessment.

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Cons:

a.

would extend completion date while necessary l

background was required by approximately 12 months.

b.

would not necessarily include all relevant data.

Alternative 2.

Derive value primarily from equivalent I

life costs but allow for differences in risk perception.

Pros:

a.

would include social value factors.

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would include study of risk perception.

Cons:

a.

would require greater investigative effort and costs.

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social factors may not be easily quantified.

i Alternative 3.

Include all of the above considerations.

Pros:

a.

would not require much more effort than Alternatives 2 and 3.

I b.

would provide best data base to make decisions on.

i Cons:

a.

may lengthen completion period by 3 months l

i while all data is analyzed.

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SUMMARY

OF ALTERNATIVE SCllEDULES i

1 Estimated Alternative of Completion Estimated Date for Issue 3 selected Time Promulgation of Rule 1.

24 months June 1977 2.

30 months December 1977 1

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33 months March 1978 l

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I Title 10.- Energy CllAPTER I - NUCLEAR REGULATORY COMMISSION 1

1 PARTS 40, 50, 51'and 70 - ENVIRONMENTAL PROTECTION

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Notice of Proposed Rulemaking Determination of the monetary value of radiation exposure reduction from limitations on the discharge of radioactive effluents from nuclear fuel cycle facilitics to the general environment.

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The Nuclear Regulatory Commission specified, in its opinion i

on Numerical Guides for Design Objectives and Limiting Conditions j

for Operation to Meet the Criterion "As Low As Practicable" for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor 1

Effluents, interim values of the worth of radiation exposure i

reduction to be employed in cost-benefit evaluations of radioactive waste treatment system additions *. The interim values were $1,000 per man-rem reduction in the population doses received by the whole body and by the thyroid gland.

In the Commission's view, the record of the proceedings for that rulemaking did not provide an adequate basis upon"which to select a specific dollar value for the worth of radiation exposure reduction. The interim values were selected simply to represent values slightly more conservative than previously published values and did not represent an independent l

As published in the FEDERAL REGISTER of May 5, 1975 [40 FR 19439).

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t assessment of the dollar ~value which should be employed for this l

purpose. The Commission stated, in that opinion, its intention to conduct, at the earliest possible date, a separate rulemaking to establish appropriate monetary values for the worth of a reduction in the radiation dose received by population groups.

The Commission reaffirms that intention with this notice of proposed rulemaking.

The Commission believes that the determination of a numerical monetary value for the worth of reductions in radiation exposure i

is essential to the performance of cost-benefit evaluations for radioactive effluent control systeme-We alen appreciate the potential usefulness of this value in the comparison of the envi-ronmental and public health impacts of nuclear power with those j

impacts which result from other energy sources.

As stated in our opinion on the numerical guidelines for achieving as low as reasonably achievabic effluent. releases for light-water-cooled nuclear power reactors, it is the Commission's view that cost and benefit can be most usefully appraised when expressed in commensurate units, and that the most appropriate unit would seem to be units I

of money. The Commission would welcome suggestions on other i

possible units of equivalence or other methods of weighing costs and I

I benefits.

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The Commission recognizes that the determination of a monetary value for the worth of radiation exposure reduction will entail i

2 The change in terminology from "as low as practicable" to "as low as reasonably achievable" was proposed by the Commission in a notice which appeared in the FEDERAL REGISTER of August 6, 1975 (40 FR 33029).

I Enclosure "A" i

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the consideration of aesthetic, moral, and human values which.

are usually regarded as being inestimable.

It is possible that-

.various individuals ior social groups may hold widely differing i

perceptions of how these factors should be appraised. Because of

.these considerations, the Commission welcomes comments and opinions on the desirability of its proposed course of action on this matter I

and suggestions on how these considerations should be incorporated in this rulemaking.

Scope of. Proposed Rulemaking - In its deliberations on the scope of this proposed.rulemaking, the Commission has considered four alternatives. The first' alternative was to confine this rulemaking to the value of radiation exposure reduction associated.

with radioactive effluent limitations for light-water-cooled nuclear power reactors. This scope is consistent with our announced inten-tion to apply this monetary value to evaluating as-low-as-readily achievable design objectives and operating limitations as specified in the recent amendments to 10 CFR Part 50.

The s*econd alternative was to expand the scope of this proceeding to encompass a value for use in determining as-low-as-readily-achievabic effluents for all nuclear facilities which result in radiation expoaure of population groups. This alternative would include the determination i

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of.a value for application in the cost-benefit analysis of efflucot reductions for all nuclear power reactor types (including nigh-temper-1-

ature-gas-cooled reactors and liquid-metal-cooled and other types of i

! Enclosure "A"

I fast-breeder reactors) as well as for application to uranium and thorium milling and fuel fabrication facilities, spent fuel reprocessing plants, mixed oxide fuel fabrication facilities handling plutonium and other transuranic elements, and to radioactive vaste storage j

and disposal facilities.

The inclusion of all components of the nuclear fuel cycle in this proposed rulemaking is consistent with the intention of the i

former Atomic Energy Commission to develop as low as practicabic numerical guidance for radioactive effluents from other portions of the huclear fuel cycle as announced in the Federal Register of May 10, 1974 (39 FR 16901). The similarities of the effects which could be incurred and of the areas of application for such a monetary value outweigh the possibility that different numerical j

monetary values may be required due to dif ferent effluent composi-tions, magnitudes of releases, or indirectness of association with the electricity producing facilities. The Commission believes that the cost of waste treatment systems should not enter into this determination, rather, the converse should apply, in that the monetary value for the worth of radiation exposure reduction should govern the effluent control systems which would be required to attain as-low-as-reasonabily achievable effluent limitations.

The third alternate scope of the proposed rulemaking was to further expand the rulemaking to include appropriate monetary values for the worth of reducing occupational. radiation exposure. The NRC staff has identified several potential differences which might indicate that occupational exposure should be treated differently Enclosure "A" l

r than exposare to population groups from radioactive materials released as efficunts. These potential differences are:

1.

Occupational exposure generally results in doses to indi-viduals which a,rc considerably higher than received by the general population from effluents from nuclear power facilities; 2.

For occupational exposure protaction of the individual may be paramount and the $/ man-rem value may not be applicabic (protection of the individual from radioactive effluents has been considered in the formulation of the design objectives and limiting conditions of operation specified in Appendix I to 10 CFR Part 50);

3.

There may be additional considerations for reducing individual j

occupational exposures than for reducing population doses. The alternatives for control are not necessarily limited to engineering solutions.

4.

Occupational radiation exposure might be considered as a t

voluntary risk acceptance rather than an involuntary risk l

imposed upon the individual.

Notwithstanding, the possible differences identified by the staff, the Commission wishes to solicit the comments of interested individuals and groups on whether occupational exposure reductions should be included in the proposed rulemaking.

l The fourth alternative considered by the Commission was to expand the proposed rulemaking to include the determination of the worth of radiation exposure reductions for application to 1 Enclosure "A" l

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9 preventing or limiting the consequences of very low probability accidents which may have significant impacts.

The NRC staff has identified several areas where it believes there are differences between the application of a $/ man-rem value for reducing routine

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effluents and a value which would be used for determining the cost-effectiveness of engineered safeguards or of protective measures for preventing or mitigating the consequences of accidents. These 1

differences included differences in total doses and dose rates, large differences between the probabilities for incurring radiation exposure, and the differences in the biological effects which may be manifested. The Commission does not wish to omit the public comment on this aspect and, therefore', requests comments on the desirablity of including in this rulemaking monetary values for defining the cost-effectiveness of accident mitigation equipment i

or procedures.

Proposed Approach - The monetary equivalent for the worth of a j

reduction in radiation exposure can be expresscd as the product of i

i two factors. The first term is a risk factor which denotes the

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probability of incusring biological damage as a consequence of radiation exposure.

The second term is a cost-per-risk factor which denotes the cost to society associated with the manifestation

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of this effect. This relation can be expressed by the following l

equation:

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probability of incurring effect 1) cost

=

man-rem reduction all effects man-rem

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) Enclosure "A" l '

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A similar relationship for putential effects from irradiation l

of individual organs or tissues might also be postulated. The j

Commission intends that both factors should be examined by the NRC

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1 staff in order to arrive at the monetary equivalence value.

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l The Commission is awrre that the effects of radiation entail pctential ill health or loss-of-11fc and that the cost factor represents the cost associated with human suf fering or death. We recognize that a monetary value on human life is often implicitly and, sometimes explicitly, set for the evaluation of public pro-jects and that such values might be deduced from a variety of sources as enumerated below.

The Commission proposes to collate, compile, and examf.ne these existing monetary transvaluations in order to l-arrive at an appropriate value for the cost factor in the above l

equation.

We, therefore, intend to examine the various life values i

which have been set by society in the past or to deduce such values i

from analysis of related information rather than presumptuously i

setting a monetary value on human life.

l Determination of the Risks Associated with Radiation Exposure -

The Commission and the NRC staff will examine the risk estimates j

i provided in the reports of International Commission on Radiological Protection (ICRP), the United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR), and the National Academy 1

of Sciences - National Research Council BEIR Report on the Effects on Populations of Exposure to Low Levels of Ionizing Radiation, as well as additional availabic reports.

In lieu of definitive information i Enclosure "A" l

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9 or authoritative guidance to the contrary, it is the Commission's direct intention that numerical estimates of the risks, expressed i

in terms of the probabilities of somatic and genetic damage, be developed from application of a linear, dose-rate-independent, non-threshold dose-effect model. This means that chronic radiation effects which have been observed in humans exposed to very high i

doses delivered at high dose rates will be assumed to occur in direct proportion to the total dose received even at very low doses and dose rates. Under the no-threshold hypothesis, it is assumed that any radiation exposure (above zero dose) has an associated risk of damage, even though the probability may be so low that the effect is not manifested within the lifespan of any individual.

The Commission recognizes the errors and simplifications inherent in this approach and the problems associated with estimat-

)

J ing the probable effects at low dose rates and low total doses f' rom effects which have been observed at considerably higher dose rates i

and higher total doses.

If there is a threshold for radiation damage, l

the postulated effects may not occur at these very low dose rates and any expenditure for additional control would be wasted.

If the dose-response is non-linear, the ef fects projected using a linear dose-response model may be considerably overestimated and the i

expenditures may be incommensurate with the real risk.

It is also l

conceivable that a non-linear response could produce higher risks l

- at low doses than would be predicted by extrapolations from higher dose rates where cell destruction (rather than damage) precluded j Enclosure "A" l

l f

p-L cancer induction. Clearly, experimental conformation of any of

[

these hypotheses would be of considerabic benefit in assessing the risk from radiation exposure. However, the absence of defi' (tive l

and conclusive proof that another dose-effect model should be cmployed the Commission believes that the adoption of a linear, dose-rate-independent..non-threshold dose-effect relationship will insure that the risk is not underestimated.

The Nuclear Regulatory Commission agrees with the view of the National Council'on Radiation Protection'and Measurements (NCRP) that knowledge of. radiation effects for both somatic.and get4 etic' injury is incomplete. The available data on the biological effects l

of very' low doses delivered at low dose rates is,especially sparse and inadequate. The Commission further recognizes that the totality of radiation effects may not be known even for doses which are con-siderably higher than the doses resulting from nuclear facility

(

l effluents.

i The Commission has carefully considered the NCRP's admonitions concerning the quantification of the risks associated with low

~

levels of radiation' exposure as expressed in their recent Report No. 43.

We have weighed!these admonitions together with the nuclear industry's need for numerical design objectives and the benefits which are

!~

associated with a fully documented cost-benefit analysis, i

In our rulemaking on numerical guidelines for achieving I

"as-low-as-practicable" design objectives and effluent limitations i

i for light-water-cooled nucicar power reactors, the Commission 1

i j

recognized that engineers cannot design facilities and radioactive r

' Enclosure "A" E

- l i

.-a

1

^

1

\\

effluent control systems to satisfy philosophical concepts. Visible numerical criteria are required to insure a common understanding

{

l between the designers, the Commissions's licensing staff, and the public of the Commission's intent in setting as-low-as-readily achievable design objectives and operating ifmitations for radio-active materials in effluents.

In the previous rulemaking on Appendix 1 to 10 CFR Part 50, the Commission also stated its conviction that meaningful cost-benefit balances are an essential part of the considerations of the as low asreadilyachievableconceptforcontrolofinsults[tothepopula-tion from radioactive effluents or from other pollutants. We feel that the cost-benefit approach has many advantages, both in terms of insuring the proper consideration of all important factors in reaching a decision and in terms of openly displaying the rationale underlying a decision. We further affirm these convictions that in our belief, the usefulness of the cost-benefit approach overwhelmingly outweighs any disadvantages associated with the imprecisions inherent to its applications.

t In redffirming these convictions, the Commission recognizes that it may be seemingly at odds with The National Council on Radiological Protection and Measurements and with their recent guidance issued after we undertook the task of defining numerical i

ALAP guidelines.

The Commission and its staff have taken this l

position with due regard for the wealth of knowledge and experience represented by the NCRP and of the considerable merits of its h

l Enclosure "A" I

i

1 admonitions.

It is our belief that, in pursuing our present course of action, we are in accord with the guidance of the l

International Commission on Radiological Protection, particularly as expressed in its recent report No. 22 and with the recotmnenda-I tions of the National Academy of Sciences - National Research Council Advisory Committee on the Biological Effects of Ionizing Radiations, as contained within their 1972 report, and consistent with the practices employed by the U. S. Environmental Protection Agency in setting generally applicable environmental radiation protection standards. The Commission requests comments on this i

position, particularly from the scientific bodies listed above.

Determination of the Costs Associated with Radiation Injury -

The Commission recognincu that there are considerable differences between the two component factors which enter into our equation for the monetary value of the worth of radiation exposure reduction.

The determination of the magnitude of the risk factor is primarily l

a technical judgment based upon available scientific data and the recommendations of learned scientific bodies. Although the available information on radiation effects is not as complete as the Commission I

would desire, the analysis of these data to arrive at risk estimates is a minor undertaking compared to the myriad of factors which must l

be considered in evaluating the magnitude of the cost-per-ef fcct l

l term. These factors include comparability of effects, societal value judgments, individual inequities balanced against public gains, moral issues, and dif ferences in risk perception and risk 3

acceptance.

l Enclosure "A" t

i

)

As we have indicated in the preceding text, the Commission j

does not itself propose to set a dollar value on human life or injury. Rather, we intend that the NRC staff should evaluate the l

1 range of the values which have been set by society for various applications and recoiuaend a value which will insure that any potential risks of radiation injury are commensurate with the benefits which accr'ue from nuclear power and the risks associated f

with other forms of human endeavor.

The monetary value of preventing loss-of-life might enter into j

many societal decisions ranging from the determination of the radius of a curve on a highway to national expenditures on health care. The Commission believes that examination of the life saving costs inherent in health care expenditures, transportation safety measures, and pollution control costs will provide values directly comparable to the cost which should be attributed to radiation injury.

In addition, indirect economic factors such as the costs of lost productivity associated with injury or loss-of-life can provide useful information for the present deliberation.

In addition to the expenditures for life saving, we believe that examination of com'pensation payments can provide additional information of value in assessing society's transvaluation of human

)ffe. These compensation payments are in the form of monetary awards for injury or loss-of-life and hazard payments for high-risk occu-

.pations.. We recognize that these estimates may be of only marginal application to the proposed rulemaking since, in the first case, the compensation is for a life already lost or injury already incurred, l

- 12 ~

Enclosure "A"

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.- -.. - -.~.

i i

l l

rather than for prevention.

In the second case, hazardous duty pay l

applies to voluntary rather than involuntary risk acceptance.

The Commission wishes to clarify its position on the value of human life. He believe that the worth of a single identifiable 1

human life is immeasurable and that expenditures to save a given individual may f ar exceed any reasonable value deduced from any of i

the foregoing information. The risks which may be associated with radioactive effluents f rom normal operation of facilities in the 5

nucicar fuel cycle pose a small incremental risk to any individual.

1 The radiation effects of principal concern involve considerations of the integrated population dose, the summation over a number of individuals receiving small incremental exposures.

The effects which might result from these exposures are of a statistical nature and might.be manifested only when large population groups are involved, even for the supposition of a linear, dose-rate-independent, non-threshold dose-effect mode.

The overall risks that the Commission foresees being associated with radioactive effluents from normal opera-tion of nucicar power and nuclear fuel cycle activities should comprise only a ve,ry small fraction of the risks that would be projected from exposure to the natural radiation which exists in our environment.

Criteria for Selection of a Value - There are moral, ethical, social and human values to consider in addition to purely actuarial con'siderations.

It is clear that neither the Commission nor its staff have special expertise to weigh these considerations. Therefore, we will rely heavily upon the advice of other groups and individuals i

. Enclosure "A"

)

[.

I i

e

~*s o

I l

I l

who have expertice in cost-benefit analyses. We recognize the difficulty associated with assigning purely monetary values to l

int angible or otherwise inest inabic factors.

We are aware that the National Academy of Sciences and the National itesearch Council arc l

{

investinating methodulonies for cost-benefit evaluations applied to radiation exposure and we hope to draw upon their expertise and l

thoughts.

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The Commission's staff has not, at this early stage, finalized l

I their criteria for the selection of a single value for the monetary equivalent of the worth of radiation exposure reduction. We do j

kncw that this value must catisfy the following conditions:

l 1.

The risk from these radioactive discharges must not be incommensurate with other involuntarily imposed risks to the indi-vidual from other forms of human endeavor.

l 2.

The risk estimates used to derive the numerical monetary value must be based upon the best radiobiological data which are j

j currently availabic.

l 3.

The estimate of the monetary cost associated with ill health or loss-of-life should not be incommensurate compared to other life-saving expenditures presently made by society.

l l

4.

The criteria employed in adjudging the monetary equiva-lent for radiation exposure reduction must be publicly specified in i

detail, i

5.

The views of the public and other interested parties must be sought and carefully considered.

1 i Enclocure "A" 1.

I

c

=

o 6.

The public health and welfare will be the predominant concern in this rulemaking.

_ Sol'. citation of Comments and Pertinent Information - The purpose of this notice is to invite advice, recommendations, and data sub-missions relevant to this matter from all interested persons.

Specifically, comments are requested on the following questions:

1.

Should values also be developed for application to occupational exposure reduction and/or the mitigation and prevention of low-probability, high impact accidents, in addition to considering a value for use in analyzing the cost-effectiveness of radioactive effluent control systems?

I Are there differences in these applications which a.

should be considered in arriving at applicabic values?

I b.

Should this rulemaking be limited t o light-water-reactor effluents or should the value be applicable to all radio-active effluents released during normal operation of any facility in the nucicar fuel cycle?

Should the same value be applied to other sources c.

of radioactive material discharges such as medical treatment

centers, I

research institutions, and industrial firms using radio-active materials?

d.

What considerations should be included for these other facilities or applications?

I l

t

Enclosure "A"

e e

2.

Are there alternative methods for setting the monetary value for the worth of reductions in radiation exposure which do not involve the equation:

i cost

.,I effects )

eost geffect) dose reduction i

dose 3.

What methods should be used in detiving the dose-to-risk factor?

a.

Are there more suitable methods for describing radiation dose-effect relationships than the linear, dose-rate-independent, non-threshold, dose-effect model?

l I

b.

How should the differing radiosensitivities of various organs and tissues be considered?

I c.

Should relative or absolute risk estimates, or both be used?

d.

How should potential genetic effects on future generations be compared with somatic effects to an individual?

c.

Ilow should risk estimates based upon different i

1 methodologies be compared and combined?

,f.

How should changes in radiosensitivity with age, health, sex, etc., included?

4.

How shall the cost-per-effect factor be derived?

1 a.

What considerations should be included?

b.

What additional data sources might provide value-of-i 1

life-saving estimates in addition to health care, transportation safety, and pollution control expenditures?

9 Enclosure "A"

.m

.m 6

i I

i I

l l

c.

Should adjustments be made for inflation and the changing worth of the U. S. dollar in evaluating life-values from earlier studies?

l d.

How should compensation payments for injuries incurred l

or locs-of-life be adjudged in estimating Ilfe-saving or injury-

]

prevention costs?

l 5.

How shall the cost-per-effect and effect-per-dose factors l

be combined?

a.

Should cost-per-effect for effects which might occur late in life be subject to a discount rate?

I b.

How should the cost for treatment and morbidity /

l-mortality considerations be used in weighing fatal, fatal-unless--

treated, and non-fatal biological effects?

c.

How should inequitics in the cost-benefit relation-l

' ship (the risk or cost being borne by one group and the benefits accruing to another group or to society in general) be addressed?

6.

What' criteria should be used for the selection of appropri--

l ate $/ man-rem and $/ organ-rem values?

a.

How should other risks which are accepted by society be employed in the selection?

j b.

Should the risks from naturally-occurring radiation or radioactive materials be employed in setting an acceptabic risk from l

man-made radioactive materials?

I c.

how should differences between voluntarily assumed risks and imposed risks be weighed?

d 1 1:r. closure "A" I

4 s

o 7.

Ilow should the monetary valut of the worth of radiation exposure reduction be applied?

1 Should weighting factors be applied which are depen-a.

dent on the size of the exposed population?

If so, how should these factors he determined?

b.

What geographical limit ation or boundary should be used for determining the size of t he exposed population?

(1) the local population around a specific site (within 80 kilometers or 50 miles)?

(2) The population of the United States?

(3) The total population of the world?

(4) The population which receives a dose greater l

than some limiting value?

(5)

Should population growt.h be considered?

c.

Over what period should the population dose be computed?

(1) an annual dose rate?

(2) the average life time of an individual (70-year dose commitment)?

(3) the 100-year dose commitment?

(4) the infinite dose commitment?

s d.

What composition by age of exposed individual should be as'sumed?

(1) only adults (standard man)?

(2) the typical individual in the U. S. population (age groups weighted by the perr entage of the U. S. population in that age range)? Enclosure "A" f

j0 o

(3) the current ar.c group distribution around a specific site?

All int erested persons who desire to submit. conunen t s, s ugge s t~i on s,

or technical dat a be:n ing upon t he f act ors enumerated above, or other relevent information should send their comments to the Division of Rules and Records, Office of Administration, U.S. Nucicar Regulatory Commission, k'ashington, D.C.,

indicating that they apply to Docket No. PRM-50-XXX, on or before November 15, 1975.

. Enclosure "A"

.