Answer to Question #274 Submitted to "Ask the Experts"

Q

I was wondering if cost-benefit analyses have been done on changing occupational radiation safety standards from the present standards.

A

Cost-benefit analyses are normally conducted in connection with rulemaking, and the Nuclear Regulatory Commission (NRC) has not initiated rulemaking to change occupational radiation protection standards from those in the current regulations, which are based on ICRP 26 and 30, to ones based on ICRP 60 and later publications. There a number of reasons for this. One of the more important is that NRC-licensed facilities are now maintaining a level of protection for their occupationally exposed workers and members of the public that is at least as high as that recommended by the latest ICRP recommendations. As an example, the annual doses for occupationally exposed workers are, with very few exceptions, well below the current ICRP recommended average dose limit of 2 rem per year. This is partly the result of the requirement to keep exposures as low as reasonably achievable (ALARA) and partly due to licensees' self-imposed administrative dose limits for their workers that are designed to maintain low occupational exposures at their facilities. However, a cost-benefit analysis is being done by an interagency steering committee on radiation standards which includes, among others, the NRC and the Environmental Protection Agency (EPA). The work is just starting, and the purpose is to decide on whether it is time, and cost effective, for all federal agencies to switch to the latest guidance. As you probably know, EPA has already taken a step in this direction with its publication of Federal Guidance Report No. 13, which is based on the latest models, data, and guidance. NRC is also moving in this direction by permitting the use of these newer models and guidance documents in regulated activities on a case-by-case basis where appropriate. However, because, as stated above, workers and the public are now being provided with a level of protection at least as high as that currently recommended by the ICRP, and because of the very high cost involved in such substantial regulatory changes, we do not anticipate changing the occupational radiation-safety standards in the near future. This reluctance to change the regulations is further strengthened by our knowledge that the current recommendations and models are expected to be revised again, possibly substantially, within the next five years.

Sami Sherbini, NRC