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
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Issue date:	10/11/2018
From:	Clint Jones NRC/RES/DSA
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Jones C
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Download: ML18271A153 (17)

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NRC's Radiation Protection Policy -What Does it Take for Change?Cynthia G. Jones, Ph.D.U.S. Nuclear Regulatory CommissionOffice of Nuclear Regulatory Research 1ANS-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 2ANS-HPS 2018 Topical Meeting, October 1, 2018 Key Milestones*NRC Radiation Protection Policy1957: Atomic Energy Commission issues 10 CFR Part 201977: ICRP 26 published1980: BEIR III issued1980: NRC issues an Advanced Notice of Proposed Rulemaking1986: NRC issues proposed Part 20 changes1987: NCRP issues Report 911990: NRC Below Regulatory Concern Policy Statement issued199o-1: ICRP Report 60 issued 1991: NRC issues its revised Part 20 updating it to ICRP 26 & 302007: ICRP issues Report 1032009: NRC: stakeholder outreach to update Part 20 & Part 50, App. I2016: NRC discontinues Part 20 & Part 50, App. I rulemakings 3ANS-HPS 2018 Topical Meeting, October 1, 2018*See also Health Phys. 88(2): 105

-124; 2005 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 4ANS-HPS 2018 Topical Meeting, October 1, 2018 Evolving NRC Policy

• 2009-12: NRC engaged in extensive stakeholder outreach to update Part 20 & Part 50, App. I toreach alignment with ICRP 103

• 2012: NRC Commission direction (SECY 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 5ANS-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 6ANS-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

-Worker's 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*PRM-20-28, PRM-20-29 and PRM 30ANS-HPS 2018 Topical Meeting, October 1, 2018 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 8ANS-HPS 2018 Topical Meeting, October 1, 2018

• NCRP Commentary 27, "Implications of Recent Epidemiologic Studies for the Linear

-Nonthreshold Model and Radiation Protection Ex 2: ExemptionsNRC 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 9ANS-HPS 2018 Topical Meeting, October 1, 2018 Ex 3: ALARA & DecommissioningCurrent 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 10ANS-HPS 2018 Topical Meeting, October 1, 2018See 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?

11ANS-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 12ANS-HPS 2018 Topical Meeting, October 1, 2018 Where do we go from here?

13ANS-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 14ANS-HPS 2018 Topical Meeting, October 1, 2018 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 15ANS-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 16ANS-HPS 2018 Topical Meeting, October 1, 2018 17Thank you!For further information, contact:cynthia.jones@nrc.gov www.nrc.gov