Greta Joy Dicus Speech

["GCARTWRIGHT.OPPD.COM" <GCARTWRIGHT@oppd.com>]

Follows is the transcript of Ms. Dicus's speech: 
 
 
 
                WHY WE NEED TO HARMONIZE RADIATION 
                      PROTECTION REGULATIONS 
 
 
                         Greta Joy Dicus 
                           Commissioner 
                          United States 
                  Nuclear Regulatory Commission 
 
                              At The 
                              1998  
              Women in Nuclear Global Annual Meeting 
                          Taipei, Taiwan 
                          April 24, 1998 
 
 
 
No.  S-98-13 
 
 
INTRODUCTION 
 
     I am delighted to participate in the 1998 WIN Global Annual Meeting.  My 
reasons are several.  First, this meeting provides an opportunity to visit 
Taiwan whose 
nuclear power program is a key component in its energy program, and perhaps 
most 
important, it is an opportunity to meet old friends and to make new ones. 
 
     This morning, I would like to share with you some thoughts on a challenge 
facing 
regulators who are responsible for establishing radiological protection 
standards and 
implementing radiological protection programs.  The challenge is how to 
translate our 
current knowledge of radiation health effects into regulatory frameworks that 
are 
protective of workers, the public and the environment and, at the same time, 
take 
appropriate account of the uncertainties in that knowledge.  To date, in my 
opinion, we 
have not successfully responded to this challenge.  How this challenge is 
resolved and 
its ultimate outcomes are matters that will affect virtually everyone working 
in the 
nuclear field and how nuclear resources may be used in the future.    
 
 
THE SCIENTIFIC CONTROVERSY 
 
     The bulk of our knowledge about human radiation health effects that forms 
the 
basis for radiation protection standards is derived from studies of the 
survivors of the 
atomic bombs that struck Hiroshima and Nagasaki.  Other human population groups 
that have provided significant data on radiation health effects are certain 
medical 
patient groups.  It is largely the result of these human studies coupled with 
research on 
radiation effects on animals and at the cellular level that have led to the 
adoption on the 
linear, non-threshold (LNT) theory to describe radiation health effects at the 
low doses 
and dose rates normally encountered by radiation workers and the public.  The 
strict 
application of that theory at these low levels of exposure is being 
challenged.  The 
reasons for the challenge are complex.  In the opinion of some, the strict 
application of 
the LNT theory has lead to unnecessarily conservative radiation protection 
standards 
particularly for specific purposes such as the decontamination and 
decommissioning of 
licensed facilities.  One way of obtaining relief from radiation protection 
standards that 
are viewed as unnecessarily restrictive or overly conservative is to challenge 
the theory 
underlying the standards. 
 
     In response to this growing controversy, the International Atomic Energy 
Agency 
(IAEA) and the World Health Organization (WHO)  sponsored an international 
conference which was held last November in Seville, Spain.  The conference 
title was, 
"Low Doses of Ionizing Radiation: Biological Effects and Regulatory Control."  
More 
than 600 persons registered for this meeting.  It was the first time that 
scientists and 
regulators had met to jointly discuss the issue. 
 
     The conference was also held in cooperation with the United Nations 
Scientific 
Committee on the Effects of Atomic Radiation (UNSCEAR).  The conference was 
opened by Dr. Hans  Blix, IAEA Director General and by Dr. Hiroshi Nakajima, 
WHO 
Director General. 
 
     There are uncertainties about the radiation health effects that are 
associated 
with the radiation dose and dose rate levels that we regulate because, with 
the possible 
exception of fetal radiation effects, radiation health effects in humans at 
these low 
levels have not been clearly demonstrated.  As a result, an assumption must be 
made 
for the extrapolation from radiation health effects observed at high radiation 
levels to 
radiation health effects that may occur at low radiation levels in order to 
formulate a 
radiological protection system.  This assumption is that there is a linear, 
non-threshold 
relationship between radiation and health effects at low doses and dose rates. 
  
 
     There is some evidence of a threshold and possibly for an hormesis effect 
for 
selected biological media and selected radiation effects at low levels of 
radiation.  But 
such evidence, frankly, must become overwhelming and be demonstrated in humans 
before there will be serious consideration to moving away from the current LNT 
assumptions that underlie the present radiation protection framework.  
Further, while 
their views are not widely accepted, there are also scientists who believe 
that there is 
evidence that radiation health effects at low doses and dose rates are 
underestimated 
by the LNT assumption. 
 
     A variety of views were expressed during the course of this conference 
but the 
discussions did not lead to resolution of  the current controversies over the 
appropriateness of using the linear, non-threshold (LNT) model that underlies 
present 
ICRP recommendations and regulatory radiation protection programs.  While no 
consensus was reached at the end of the Seville conference, the prevailing 
view was 
probably best expressed by Dr. Sheldon Wolff of the Radiation Effects Research 
Foundation who said in the closing session  that data on hormesis effects must 
be 
convincingly positive before changes to theories underlying radiation 
protection 
recommendations could be made, otherwise, "we are dealing with religion, not 
science."  
 
 
     Nonetheless, the conference discussions were useful because they showed 
why  
it has proven to be very challenging to translate our knowledge of radiation 
health 
effects into a regulatory framework that is protective of workers, the public 
and the 
environment and, at the same time, takes into account the uncertainties about 
that 
knowledge and the resulting need to make assumptions to construct a radiation 
protection system.  The challenge is complicated by the fact that many of the 
recommended dose limits and constraint levels that are thus derived are 
comparable to 
or smaller than background radiation levels.   
 
     It should, therefore, not be surprising that policy makers responsible for 
establishing ionizing radiation protection regulations have not always followed 
international standards recommended by scientific expert bodies such as the 
ICRP and 
those recommended by national scientific expert bodies such as the NCRP in the 
United States.  The unfortunate result in some cases is a patchwork quilt of 
radiation 
protection requirements that often conflict with each other.  Most important, 
it is a 
situation that does not engender public confidence in our scientists and in 
our policy 
makers. 
 
     I cannot defend a framework that results in a failure to develop 
consistent 
radiological standards.  For example, in the United States, not only have we 
not 
adopted the ICRP's latest recommendations for standards as found in ICRP-60, 
to be 
consistent with international recommendations, but we are even inconsistent 
within our 
borders due to conflicting standards among our Federal agencies. 
 
     When seen in this light, it becomes apparent that what is lacking in the 
United 
States is an effective means of attaining and assuring harmonization of 
radiation 
protection standards at a National level. 
 
 
THE NEED FOR HARMONIZATION OF RADIATION PROTECTION STANDARDS 
 
     I am personally in favor of a National commitment in the United States to 
more 
closely follow the recommendations of the ICRP.  Such national commitments are 
not 
without precedent.  Members of the European Union are expected to adopt 
radiological 
protection standards which follow those contained in the IAEA Basic Safety 
Standard 
(BSS) by May 13, 2000.  The IAEA Basic Safety Standards, of course, is based 
upon 
ICRP recommendations.   
 
     The ICRP recommendations, in contrast to the fragmented, piecemeal 
statutory 
approach currently in place in the United States, constitutes a coherent 
system for 
radiological protection.  It includes appropriate cautions and warnings that 
help guard 
against slavish application of radiation protection recommendations 
independent of the 
origin and the purpose of the radiation source, the assumed risk of the 
radiation relative 
to that from background radiation and the costs to mediate the assumed risks.  
As Dr. 
Roger Clarke, ICRP Chairman, demonstrated in comments made at the Seville 
conference, it is flexible enough to address emerging challenges such as how 
to deal 
with standards applicable to decontamination and decommissioning of nuclear 
facilities.  
  
     With national and international harmonization of radiation protection 
standards 
will come, in due time, greater confidence of the public in our national 
regulatory 
programs. 
 
     While harmonization will help to address part of the challenge facing the 
current 
regulatory frameworks,  the overriding issue of the LNT controversy needs 
attention.  
Let me suggest a possible path forward on this matter. 
 
 
JOINT U.S. - RUSSIA  RADIATION HEALTH EFFECTS RESEARCH 
 
 
     After becoming an NRC Commissioner, I was appointed as the NRC's 
representative to the Joint Coordinating Committee for Radiation Effects 
Research 
(JCCRER), a U.S. - Russian endeavor to coordinate joint government-sponsored 
radiation health effects research.  While this research will include both U.S. 
and 
Russian populations, it is primarily focussed on workers and populations in 
the southern 
Urals area of Russia where the Russian nuclear weapons manufacturing center, 
Mayak 
is located.  As a result of early operational practices and some accidents at 
Mayak, 
workers at the plant and populations around the site were exposed to unusually 
large 
amounts of radiation and radioactive materials.  In many cases, the doses were 
comparable to those received by survivors of the Hiroshima and Nagasaki atomic 
bombings.  A significant difference is that the exposures of the Mayak workers 
and 
populations were protracted - in many cases extending over many years - in 
contrast to 
the doses received by atom bomb survivors.  Thus, there is a unique 
opportunity not 
only to gain additional insights into radiation health effects by studying the 
Mayak 
groups but to also learn more about radiation health effects at protracted 
exposure 
rates.  
 
     In addition, many of the workers and significant numbers of the 
surrounding 
population ingested radioactive materials in amounts large enough to result in 
significant internal doses and, in some cases, radiation health effects not 
seen in 
western radiation workers.  For some workers, both internal and external doses 
were 
significant.   The worker population, in contrast to US radiation worker 
populations, 
includes a large number of women as well as men.  These are examples of other 
aspects that have the potential to provide further insights into radiation 
health effects in 
humans. 
 
     Underlying this are the extensive health records for the workers 
maintained by 
the Russian government since the beginning of operations of the Mayak plant.  
Health 
records also exist for many members of the surrounding population who were 
exposed 
to radiation as a result of operations and accidents at the Mayak complex.  
While dose 
reconstruction will be a challenge, especially for the population, it is 
feasible. 
 
     As you can see, the research opportunity is a great one.  It is for this 
reason that 
I am a strong supporter of the JCCRER research effort.  In the United States, 
the 
Departments of Energy and Defense, the Environmental Protection Agency, the 
National Aeronautics and Space Administration and the NRC are joined in the 
JCCRER 
effort and work has begun.  The unique research opportunities in the southern 
Urals 
area of Russia were repeatedly mentioned at the Seville conference. 
 
     Research is clearly needed to better describe radiation health effects 
particularly 
at the low radiation levels which are the subject of regulatory effort.  In 
addition to 
human studies, molecular studies promise to shed further light on this 
subject.  All such 
research deserves your strong support. 
 
 
CONCLUSIONS 
 
     In summary, regulatory agencies are faced with the challenge of how to 
translate 
our current knowledge of radiation health effects into regulatory frameworks 
that are 
protective of workers, the public and the environment and, at the same time, 
take 
appropriate account of the uncertainties in that knowledge.  These 
uncertainties have 
lead to a controversy over whether the present approach of using the LNT to 
model 
radiation health effects at low doses and dose rates is appropriate for 
establishing 
regulatory standards for radiological protection.   At the legislative level, 
different 
statutory approaches to enable protection of workers, the public and the 
environment 
have resulted, in the United States, at least,  in a patchwork quilt of 
radiological 
protection requirements that often conflict with each other.  This is a 
situation that does 
not engender public and political confidence in our scientists and in our 
policy makers. 
 
     In the long term, the controversy underlying radiation protection 
standards can 
only be addressed by reducing the uncertainties in our knowledge of radiation 
health 
effects.    To do this requires further research into the radiation health 
effects of ionizing 
radiation.  Thus, strong international and national support of radiation 
health effects 
research will continue to be needed.    
 
However, even when reducing the uncertainties in our knowledge of radiation 
health 
effects becomes a reality and ICRP recommendations are refined accordingly, 
there 
must be national and international commitments to harmonize radiation 
protection 
regulatory standards with those of the ICRP.   
 
     I believe that these are attainable goals.  Moreover, attaining these 
goals is 
essential to strengthen and retain public and political confidence in our 
science and in 
our regulatory frameworks. 
 
End of Speech 
 
Gary Cartwright 
gcartwright@oppd.com 
 
Remember, every time you open your mouth to talk, your mind walks out and 
parades up and down the words. 
-Edwin H. Stuart