NRC rejects 1 mr/yr dose limit.

[don@radpro.uchicago.edu]

The following material is excerpted from today's Federal Register.     
Extensive deletions are indicated by an elipsis...

[Federal Register: March 13, 1995]
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NUCLEAR REGULATORY COMMISSION
10 CFR Part 20
[Docket No. PRM-20-23]
Steve Gannis, Denial of Petition for Rulemaking
ACTION: Denial of petition for rulemaking.
-----------------------------------------------------------------------
SUMMARY: The Nuclear Regulatory Commission (NRC) is denying a petition
for rulemaking (PRM-20-23) from Steve Gannis. The petition is being
denied on the basis that the proposed action is not necessary because:
current public dose limits adequately protect the health and safety of
the public; the requirement that doses are as low as is reasonably
achievable (ALARA) provides an ample margin of safety; and the proposed
1 mrem/yr limit is not supported by the recommendations of the
International Commission on Radiological Protection (ICRP), the
National Council on Radiation Protection and Measurements (NCRP), or
Presidential guidance.

...

FOR FURTHER INFORMATION CONTACT: Charleen T. Raddatz, Office of Nuclear
Regulatory Research, U.S. Nuclear [[Page 13386]] Regulatory Commission,
Washington, DC 20555, telephone (301) 415-6215.

SUPPLEMENTARY INFORMATION:

The Petition

    By letter dated January 8, 1994, Mr. Steve Gannis filed a petition
for rulemaking with the NRC. The petitioner requested that the NRC
reduce the limit for radiation dose to members of the public from the
current 100 mrem/yr to 1 mrem/yr.
    As a basis for the requested action, the petitioner cited the NRC
policy statement on radiation doses that should be considered ``Below
Regulatory Concern'' (BRC)(issued July 3, 1990; FR 27522, and withdrawn
August 24, 1993; 58 FR 44610). Table 1 (July 3, 1990; 55 FR 27527 and
55 FR 27232) of that policy statement shows that if a person received
the maximum allowable dose every year of the average 70-year life-span,
he or she would have an additional 1 in 285 chance of death from cancer
as a result of that dose. The petitioner further contends that non-
fatal cancers would result at the same rate.

...

NRC Response

    None of the commenters in favor of the petition presented any
information that was convincing concerning the need for a lower dose
limit for members of the public. Annual doses to members of the public
from natural and man-made sources are summarized in Table 2 (from NCRP
Reports, Numbers 92, 93, 94, and 95).

                                 Table 2
------------------------------------------------------------------------
                                                     Average annual dose
                       Source                       --------------------
                                                       in mSv     mrem
------------------------------------------------------------------------
Naturally occurring radon..........................     2.0        200.0
Other naturally occurring..........................     1.0        100.0
All occupational exposures.........................     0.009        0.9
Nuclear fuel cycle.................................     0.0005       0.1
Other consumer products............................     0.1         10.0
Diagnostic medical x-rays..........................     0.39        39.0
Nuclear medicine...................................     0.14        14.0
                                                    --------------------
      Total........................................     3.64       364.0
------------------------------------------------------------------------

...

    One commenter compared 1 mrem/yr exposure to common radiation
sources. Some of the examples given were: (1) Flying from New York City
to Los Angeles exposes each passenger and crew member to 5 mrem; (2) a
one week Colorado ski trip raises your annual exposure by 11 mrem; and
(3) sleeping in bed with another person exposes each person to 0.1
mrem/yr from exposure to radioactive material in the other person's
body. This commenter argued that radiation is the most studied hazard
agent on earth. This commenter stated that after 99 years and billions
of research dollars, no statistically significant negative effects of
low levels of radiation have been shown in well controlled studies, and
in fact, some studies suggest that there may be benefits from chronic,
low level radiation exposure, possibly because, by stimulating enzyme
production, the organism is protected from damage by stronger radiation
and toxic chemicals. This commenter's argument is based, in part, on
the observation that background radiation levels in Colorado are about
twice that of the rest of the United States, yet cancer rates are tied
for the third lowest in the nation.
 

___________________________________________________________________

Don Jordan                          Tel. (312) 702-6299
Office of Radiation Safety          Fax        702-4008
The University of Chicago           email: don@radpro.uchicago.edu
1101 East 57th Street, Room 11
Chicago, Illinois  60637  
           -- Opinions expressed are soley the author's --