United States
Environmental Protection
Agency
Radiation
Office of
Radiation Programs
Washington DC 20460
EPA 520/1-83-013 1
November 1983
Analysis of Costs for
Compliance with Federal
Radiation Protection
Guidance for Occupational
Exposure
Volume I
-------
DISCLAIMER NOTICE
The views and conclusions contained in this document are those of the authors and
should not be interpreted as necessarily representing the official policies or recom-
mendations of the Environmental Protection Agency or the U.S. Government.
-------
EPA 520/1-83-013-1
Analysis of Costs for Compliance with Federal Radiation
Protection Guidance for Occupational Exposure
(Proposed on January 23,1981)
Volume I: Cost of Compliance with Proposed
Radiation Protection Guidance for Workers
November 1983
Prepared under Contract No. 68-01-6486
by Jack Faucett Associates
Chevy Chase, Maryland
and
S. Cohen and Associates, Inc.
McLean, Virginia
Office of Radiation Programs
Environmental Protection Agency
Washington, D.C. 20460
-------
TABLE OF CONTENTS
CHAPTER PAGE
1 SUMMARY 1
2 INTRODUCTION 15
3 COST OF COMPLIANCE: HOSPITAL/CLINIC 22
3.1 Industry Profile: Hospitals 22
3.2 Cost of Compliance with Guidance 25
3.3 Summary of Cost of Compliance 38
4 COST OF COMPLIANCE: PRIVATE MEDICAL 40
4.1 Industry Profile: Private Medical 40
4.2 Cost of Compliance with Guidance 42
4.3 Summary of Cost of Compliance 46
5 COST OF COMPLIANCE: INDUSTRIAL RADIOGRAPHY 47
5.1 Industry Profile: Industrial Radiography 47
5.2 Cost of Compliance with Guidance 49
5.3 Summary of Cost of Compliance 54
6 COST OF COMPLIANCE: MANUFACTURE AND DISTRIBUTION
OF LARGE SOURCES 56
6.1 Industry Profile: Large Sources 56
6.2 Cost of Compliance with Guidance 56
6.3 Summary of Cost of Compliance 62
7 COST OF COMPLIANCE: MANUFACTURE AND DISTRIBUTION
OF SMALL SOURCES 63
7.1 Industry Profile: Small Sources 63
7.2 Cost of Compliance with Guidance 64
7.3 Summary of Cost of Compliance 69
8 COST OF COMPLIANCE: DENTAL PRACTICE 70
8.1 Industry Profile: Dental Practice 70
8.2 Cost of Compliance with Guidance 72
9 COST OF COMPLIANCE: WELL LOGGING 73
9.1 Industry Profile: Well Logging 73
9.2 Cost of Compliance with Guidance 74
9.3 Summary of Cost of Compliance 78
-------
TABLE OF CONTENTS (Continued)
CHAPTER
PAGE
10 COST OF COMPLIANCE: NUCLEAR FUEL PROCESSING AND
FABRICATION 80
10.1 Industry Profile: Fuel Fabrication 80
10.2 Cost of Compliance with Guidance 81
10.3 Summary of Cost of Compliance 89
11 COST OF COMPLIANCE: COMMERCIAL POWER REACTORS ... 90
11.1 Industry Profile: Commercial Power Reactors 90
11.2 Cost of Compliance with Guidance 93
11.3 Summary of Cost of Compliance 103
12 COST OF COMPLIANCE: UNIVERSITY REACTORS 105
12.1 Industry Profile: University Reactors 105
12.2 Cost of Compliance with Guidance 105
12.3 Summary of cost of Compliance 108
13 COST OF COMPLIANCE: NUCLEAR PHARMACY 109
13.1 Industry Profile: Nuclear Pharmacies 109
13.2 Cost of Compliance with Guidance 109
13.3 Summary of Cost of Compliance 112
14 COST OF COMPLIANCE: URANIUM MILL 113
14.1 Industry Profile: Uranium Mill 113
14.2 Cost of Compliance with Guidance 113
14.3 Summary of Cost of Compliance 118
15 COST OF COMPLIANCE: URANIUM CONVERSION PLANT .... 119
15.1 Industry Profile: Uranium Conversion 119
15.2 Cost of Compliance with Guidance 119
15.3 Summary of Cost of Compliance 124
16 COST OF COMPLIANCE: OTHER INDUSTRIES 125
16.1 Industry Profiles: Other Industries 125
APPENDIX A
Reprint of Federal Register - 5/18-60 128
Federal Register - 1/23/81 130
11
-------
LIST OF TABLES
TABLE PAGE
1 Estimated Cost of Compliance with Proposed Radiation
Protection Guidance for Workers 4
2 Summary of High Exposure Data for 1975 16
3 Summary of Proposed Changes in Occupational Radiation
Protection Guidance 19
4 Radiation Therapy or Diagnostic Services Offered by Hospitals,
1980 23
5 Hospital Cost'Estimating for Range C Compliance 30
6 Cost Estimate - Annual 31
7 Cost Estimate for Female Dual Badging 34
8 Cost of Internal Monitoring (Nuclear Medicine Departments) . 35
9 Cost of Ideal Hospital Program 37
10 Cost Estimate Range B Requirements in Private Medicine . . 44
11 Cost Estimate for Training Requirements in Private Medicine . 44
12 Cost Estimate for Internal Exposure Requirements in
Private Medicine 45
13 Cost Estimate for Range C Requirements in Industrial
Radiography 52
14 Cost Estimate for Range B Requirements in Industrial
Radiography 52
15 Cost Estimate for Training Requirements in Industrial
Radiography 53
16 Cost Estimate for Alternative Whole Body Limit for Industrial
Radiography 54
17 Cost Estimate of Qualifying Installers as Health Physics
Technicians 57
18 Cost Estimate of Additional Installation Teams 58
19 Cost Estimate of Qualifying Health Physicists In-House at
Large Source Manufacture 59
20 Cost Estimate for Training Requirements in the Manufacture
and Distribution of Large Sources 60
111
-------
LIST OF TABLES (Continued)
TABLE PAGE
21 Cost Estimate for Internal Exposure Requirements in the
Manufacture and Distribution of Large Sources 61
22 Number and Type of Personnel Required in the Small Source
Case Study Firm 66
23 Cost Estimate for the Small Source Case Study Firm 67
24 Cost Estimate for Interval Exposure Requirements for
Small Source Manufacture 68
25 Cost Estimate for the Alternate Whole Body Limit for
Small Source Manufacture 68
26 Cost Estimate for Range C Requirements for Well Logging . . 76
27 Guidance Estimate for Training Requirements for
Well Logging 77
28 Cost Estimate for Range C Requirements for Fuel
Fabrication 82
29 Cost Estimate for Training Requirements for Fuel
Fabrication 83
30 Initial Cost Estimate for Large LWR Fuel Case Study Firm . . 83
31 Estimate of Option 1 (modification of monitoring system) for
Small LWR Fuel Case Study Firm 86
32 Cost Estimate of Option 2 (glove box containment) for
Small LWR Fuel Case Study Firm 87
33 Summary of Cost for LWR Fuel Industry 86
34 Summary of Annual Information Reported by Commercial Light
Water Cooled Reactors 91
35 Summary Distribution of Annual Whole Body Doses at
Commercial Light Water Cooled Reactors 92
36 Total Estimated Costs for all Operating Nuclear Power Plants
of Reducing Regulatory Limits 95
37 Cost of Revised Internal Monitoring for a Large Mill (Nominal
Capacity 3,000 Tons Ore/Day) 117
38 Cost of Revised Internal Monitoring for a UFfi Conversion
Facility 123
IV
-------
CHAPTER 1
SUMMARY
On January 23, 1981 the Office of Radiation Programs, U.S. Environmental Protection
Agency published in the Federal Register proposals for revisions in the existing Federal
Radiation Protection Guidance for Occupational Exposures. This activity, undertaken
by EPA under authority given the Agency in Executive Order 10831, the Reorganization
plan of 1970 and Public Law 86-370, solicited comments from the radiation protection
community, the impacted industries and individuals as to the advisability of the
proposed changes from both a health physics and compliance cost/feasibility viewpoint.
Subsequent to the publication of the proposed guidance, the agency chaired public
hearings and accepted written comments from interested parties.
This report is a part of the continuing analysis by EPA of the cost/feasibility of the
proposed revisions. Specifically, the report evaluates each of the proposed changes in
the guidance to estimate the cost of compliance to all segments of the private sector
wherein impacts are expected to be significant. The potential cost impacts of the
following proposed changes in the guidance are evaluated:
1. Limit on the annual whole-body exposure
2. Limit on the allowable lifetime exposure
3. Reduction in allowable exposures to extremities, eyes and other organs
4. Special procedures for workplace control, worker training and monitoring
when exposures are anticipated to be less than a radiation protection
guideline, but greater than 30 percent of the guideline (RANGE C
EXPOSURES)
5. Special procedures for workplace control, worker training and monitoring
when exposures are anticipated to be between 10 and 30 percent of the
radiation protection guidelines (RANGE B EXPOSURES)
1The current guidance was published in 1960 (25 FR 4402). Copies of the 1960 Guidance
and proposed revisions as published are reproduced in Appendix A of this report.
-------
6. Training of all potentially exposed workers in radiation protection princi-
ples and quantitative levels of risk
7. Alternatives for protection of the unborn
a. women able to bare children voluntarily keep dose to unborn less
than .5 rem during pregnancy
b. in addition, women able to bear children voluntarily avoid jobs with
exposure greater than .2 rem/mo.
c. b. is made mandatory
8. Internal exposure monitoring and calculation
In addition, a ninth item, the reduction of the whole-body RPG to 1.5 rem, is also
evaluated to test the sensitivity of cost to changes in the whole-body RPG.
This study concentrates its effort on estimating the direct resource costs for each
industry that must comply with the regulations that result from the revision to the
guidance. These costs that are met by industry participants will account for a
significant portion of the total costs associated with the guidance. These costs were
2
estimated through a series of case studies and independent research.
RESULTS
The compliance costs of the proposed EPA guidelines have been estimated for several
industries including: hospitals, the private practice of medicine, industrial radiography,
well logging, nuclear fuel fabrication, manufacture and distribution of radioactive
sources, dental practices, research reactors, nuclear pharmacies, uranium mills,
uranium conversion facilities, and commercial power reactors. Cost estimates .have
been drawn from data collected during case studies of representative establishments in
conjunction with industry profiles.
For convenience, in the remainder of this report, direct resource costs will be referred
to simply as costs.
2
-Case Study Analysis of the Impacts of Proposed Radiation Protection Guidance for
Workers, Jack Faucett Asociates, prepared for EPA/ORP, July 12, 1983.
-------
It was frequently not possible to specify confidently how a case study firm and its
industry would respond to a proposed guidance. In some cases, several interpretations
of a guidance were feasible; in other cases, our knowledge of the industry was too
limited to predict with certainty its response to the guidance. It was necessary, then,
to estimate the impact of each of several options or scenarios under a proposed
guidance such that cost bounds of specific parts of the guidance could be established.
To refine these estimates and assess their probabib'ty, further analysis will be
necessary.
The estimated cost impacts (see Table 1) appear to be primarily recurring annual costs
associated with additional personnel. Range C compliance results in almost $600
million in compliance costs with the bulk of these costs occurring in hospitals and power
reactors. The next highest recurring cost occur in compliance with Range B with
hospitals accounting for $20 of $27 million. Significant annual costs of less than $10
million each are estimated for the lifetime limit, training and internal exposures.
Initial costs in nuclear fuel fabrication for internal exposure compliance account for
$20 of the $27 million in this category. Limited costs for compliance with Range C in
hospitals account for the other major initial cost impact.
Compliance costs associated with the alternate whole-body limit of 1.5 rem per year
are dominated by hospitals. The $400 million estimate for hospitals is based on a case
study establishment that established an extremely aggressive program to reduce all
exposures. This large establishment not only complied with the 1.5 rem limit, but also
complied with all other sections of the guidance. Their costs were extrapolated to all
other hospitals to estimate the industry compliance cost. However, it is conceivable
that high doses in hospitals could be reduced with an addition of personnel or a
combination of personnel and monitoring. Such a program would limit the cost of
compliance. It is unclear whether enough qualified persons would be available to
undertake such an expansion.
-------
TABLE 1
ESTIMATED COST OF COMPLIANCE WITH PROPOSED RADIATION PROTECTION GUIDANCE FOR
(Millions of 1982 Dollars)
INDUSTRY -3-a -4- -5- -6-
Private Industrial Large
Hospitals Medicine Radiography Sources
GUIDANCE
Initial Annual Initial Annual Initial Annual Initial Annual
(1) 5 Rem Annual Limit
(2) Lifetime Limit
(3) Extremities <5c Organs
(4) Range C 6 354b 13 1
(5) Range B 21 4 2
(6) Training 2 2 1
(7) Unborn Protection 1
(8) Internal Exposure 2 1
TOTAL (1-8) 8 378 16 16 1
(9) Alternate Whole-body -
1.5 Rem Annual
Limit 400C 23 4
WORKERS
-7-
Small
Sources
Initial Annual
i
2
___ q
3
Number refers to chapter number in report.
An alternative analysis results in a lower cost of about $170 million in annual cost and $2 million in initial outlays. This analysis is
based on an assumption about the number of hospitals effected, (see pp 26-30 for a comparison of the alternatives)
Q
A less expensive alternative of increases in staff of radiation workers (and therefore collective dose) could reduce this cost to about
$130 million. However, the large numbers of newly trained professionals and technicians to expand the staff may not be available at
any reasonable cost.
NOTE:
All dollars are 1982.
Where no cost estimate is shown cost is expected to be less than $500,000 for this industry and cost element.
-------
TABLE 1 (Continued)
ESTIMATED COST OF COMPLIANCE
INDUSTRY -8-
Dental
Practice
GUIDANCE
Initial Annual
(1) 5 Rem Annual Limit
(2) Lifetime Limit
(3) Extremities <5c Organs
(4) Range C
en (5) Range B
(6) Training
(7) Unborn Protection
(8) Internal Exposure
TOTAL (1-8)
(9) Alternate Whole-body -
1.5 Rem Annual
Limit
WITH PROPOSED RADIATION PROTECTION GUIDANCE FOR WORKERS
(Millions of 1982 Dollars)
-9- -10- -11- -12-
Well Fuel Power University
Logging Fabrication Reactors Reactors
Initial Annual Initial Annual Initial Annual Initial Annual
_ _ _ _ _ 8 _ _
20 1 3 243
9d 1 9
It JL £i
20 22 5 251
20 20 4 3 200
There is substantial uncertainty as to the expected cost for the internal exposure requirements in fuel fabricating facilities. One
estimate assumes substantial capital investments in older facilities resulting in $20 million in initial outlays. Alternative procedures
proposed by newer facilities may be applicable to all facilities thus reducing initial cost to $1-2 million and annual cost to about
$500,000. (see pp 83-88 for description of alternatives.)
-------
TABLE 1 (Continued)
OJ
ESTIMATED COST OF COMPLIANCE WITH PROPOSED RADIATION PROTECTION GUIDANCE FOR
(Millions of 1982 Dollars)
INDUSTRY -13- -14- -15- -16-
Nuclear Uranium Uranium Other
Pharmacy Mill Conversion Industries
GUIDANCE
Initial Annual Initial Annual Initial Annual Initial Annual
(1) 5 Rem Annual Limit
(2) Lifetime Limit
(3) Extremities <5c Organs
(4) Range C 1
(5) Range B
(6) Training 2
(7) Unborn Protection
(8) Internal Exposure 23 1 2
TOTAL (1-8) 24 1 2
(9) Alternate Whole-body -
1.5 Rem Annual
Limit 1
WORKERS
Total
Initial Annual
i
o
9 635
27
7
L 1
9 5
18 684
23 655
-------
Hospitals
The 5.0 rem/year and accumulated lifetime exposure limits would have no impact on
the industry. The guidance on exposure to extremities and organs would also have no
impact.
The proposed guidances for Range C (1.5 - 5.0 rem/yr.) and Range B (0.5 - 1.5 rem/yr.)
would result in compliance costs, and these depend on the interpretation of the
guidance. Under a strict interpretation of the guidance on Range C, all hospitals with
nuclear medicine would be required to respond. The annual costs to the industry would
be $350 million after an initial outlay of less than $10 million. The annual costs for a
liberal interpretation of the guidance, which encompasses only large hospitals (i.e. more
than 200 beds), would be $ 170 million with initial outlays of $2 million. The continuing
costs are primarily associated with additional health physics professional and technical
staff.
The guidance on Range B affects all hospitals with diagnostic radiology departments,
and therefore encompasses an estimated 7,000 hospitals in the industry. Since hospitals
responding to the guidance on Range C also satisfy Range B, only the 3,300 hospitals
without nuclear medicine departments would have to hire part-time consultants under
the liberal interpretation presented above. The total annual costs are estimated to be
about $10 million. Under a strict interpretatipn, small hospitals with nuclear medicine
departments also would have to respond to Range B, and the total annual costs could
reach $22 million. If Range C were not promulgated, total cost for Range B are
estimated to be about $24 million.
The proposed training requirements are currently being satisfied, with the exception of
instruction in quantitative levels of risk. It is estimated that to satisfy this additional
intent, estimated costs are $1.5 million annually under the assumption that Range B and
C are promulgated. If they are not, estimated instructor cost would be $5.1 million
annually.
The industry currently operates under voluntary programs similar to or precisely the
same as the unborn protection provided by Alternative a. Alternative b specifies that
the women able to have children would voluntarily avoid jobs with exposure greater
than .2 rem/mo. Few hospital workers would be affected by this alternative. The
-------
professionally rewarding nature of the potentially high exposure assignments (e.g.,
diagnostic radiography special procedures) would limit the workers requesting other
assignments and thus only negligible costs to the industry are expected.
The costs of the mandatory provisions of Alternative c depend on the acceptability of
under-the-apron badging. Such badging would eliminate assignments with recorded
exposures in excess of .2 rem/mo. in radiography and cardiology. A second badge for
each affected worker (assuming collar badge is still worn) would result in just less than
$1 million cost. If such badging were not permitted for compliance, women would be
barred from these activities and severe labor shortages would develop that could limit
available services.
The proposed guidelines on internal exposure would require routine measurement of
uptake of radioiodine during thyroid scans. The one-time costs for recalibrating the
existing scanning devises; providing instruction in self-monitoring to an average of two
technicians per hospital; and satisfying regulators that broad license holders would not
require a program beyond that currently in use are expected to cost industry about $2
million.
Under the alternate 1.5 rem whole-body limit, two options are possible. One is a
vigorous radiation protection program similar to that operated by one of the case study
firms. Such an industry-wide program would satisfy all portions of the guidelines and
could cost industry about $400 million. The other option would be a doubling of the
current staff to decrease individual exposure to less than 1.5 rem/year. The availability
of labor to meet such an expansion is a serious limitation to this option.
Private Medical
The levels of exposure in this industry are relatively low. Therefore, there would be
compliance costs only for the proposed guidances on Range B, training, and internal
exposure. The annual costs of hiring part-time consultants to monitor Range B
exposures are estimated to be $4 million. To instruct workers on levels of risk would
cost an additional $2 million annually. And to recalibrate thyroid scanning devices for
measurement of internal exposure would involve an initial, one-time cost of $1 miUion.
Therefore, the annual costs of compliance would be approximately $6 million, and the
first year costs, would be $1 million.
8
-------
Industrial Radiography
The impact on industrial radiography is limited to the guidances on Range C, Range B,
training, and the alternative 1.5 rem/year whole-body limit.
It is estimated that 25% of the approximately 750 firms in the industry would have to
hire full-time health physicists to comply with the Range C guidance. The remaining
firms would be required to hire part-time consultants to satisfy the requirements of
Range B. The annual costs of these requirements are estimated to be $15 million.
Training in radiation protection principles is currently provided. To additionally
instruct workers on levels of risk would cost approximately $800,000 annually for the
20,000 workers potentially exposed to radiation.
The impact of the alternate 1.5 rem/year limit would depend on the response of the
industry. If other firms in the industry take up the workload of active firms whose
growth would be limited by the 1.5 rem/limit, then there would be no cost to the
industry. However, if the active firms hire additional workers to lower individual
exposures, productivity in these firms would decrease. This would produce a larger, less
productive workforce at an annual cost of approximately $23 million.
In summary, annual compliance costs in this industry could be $16 million if the 5.0
rem/year RPG were implemented. If the alternative 1.5 rem/year RPG was enforced,
then the annual costs to the industry could total $23 million.
Manufacture and Distribution of Large Sources
The compliances costs of the case study firm have been generalized to the five firms in
the industry. These costs relate to the requirements on Range C, instruction on levels
of risk, internal exposure, and the alternative annual whole-jbody limit.
This would, however, be a substantial economic impact, rearranging market structure,
corporate performance and affecting job security.
-------
Several options were considered for minimizing the cost of Range C compliance. It is
believed that training current staff to qualify as health physics professionals who could
monitor the high exposure activity would result in the lowest compliance cost of
$150,000 in initial cost and $600,000 in annual costs.
Instruction on levels of risk for the industry's 400 potentially exposed workers would
cost approximately $6,000 annually. An internal dosimetry program for the industry's
25 workers with potential internal exposure would cost approximately $17,000 per year.
Finally, to reduce individual exposure to less than 1.5 rem/year would require an
expansion of 125 in the number of workers in the industry and an annual cost of about
$4 million.
Manufacture and Distribution of Small Sources
The principal costs of compliance involve an increase in personnel in response to the 5
and 1.5 rem limits on annual whole-body exposure, and to the guidance on Range C. In
addition, a computerized accounting system would be necessary to monitor internal
exposures.
The impact of the 5.0 rem/year RPG will depend on whether the industry decides to
increase radiation protection activities, or lower individual exposure by expanding the
portion of the workforce receiving exposures in excess of 5 rem/year (and consequently
increasing collective dose). The impact of the first option has not been estimated since
it is subsumed in the response to the guidance on Range C. The total costs of the
second option, expansion of the affected workforce by 50%, is estimated to be about
$550,000.
The guidance on Range C would require supervisory personnel in four activities where
annual exposures are anticipated in excess of 1.5 rem/year, and an expansion in the
number of drivers and trucks to reduce individual exposure in transport of sources to
less than 1.5 rem/year. The compliance costs of these requirements would depend on
the interpretation of the guidance. A strict interpretation would require that all super-
visory personnel be radiation protection professionals, whereas a liberal interpretation
would allow delegation of supervisory responsibilities to radiologic technicians for
activities where exposures are accumulated uniformly. The respective annual costs of
the two interpretations are about $2 million with about $250,000 higher cost for the
10
-------
strict interpretation. There would also be initial costs of $300,000 for 10 additional
trucks under both interpretations.
The third impact of the guidelines relates to internal exposure. The mechanics of
compliance would require a computerized accounting system. The initial, one-time
costs to the industry for programming are estimated to be $34,000.
The final impact relates to the alternative 1.5 rem/yr. whole-body limit. Two
alternatives exist to satisfy this requirement: replace existing hardware or an
expansion in the workforce. A cost estimate of the first option is not available. The
second option would cost the industry $3 million per year.
Well Logging
Compliance costs would result from the satisfying guidelines on Range C, Range B, and
the alternative 1.5 rem/year limit. Three options were considered for compliance with
the requirements of Range C, but only the costs of the medium and least-cost options
were estimated. The medium-cost option would have full-time health physicists at each
firm (but not at each field site) at an estimated annual cost of $20 million. The least-
cost option substitutes consultants for full-time personnel to fulfill the supervisory role.
The costs of this option are estimated to be $5 million. Staff time for training on the
risks of exposure could add about $150,000 to total the annual cost.
All firms would be required to respond to Range B, but the costs of satisfying this
requirement are subsumed under Range C. All major firms currently comply with
Range B. If Range C were not promulgated, these firms would incur few costs, but the
300 other firms in the industry could incur $300,000 in annual cost. As for the
alternative 1.5 rem/year whole-body limit, the industry is currently on the borderline of
meeting this requirement. Assuming that the combined impact of additional health
physics personnel and instruction of field engineers would result in compliance, then the
cost of the 1.5 rem/year limits would be equal to the compliance costs of the industry's
response to the Range C guidance.
Fuel Fabrication
Cost impacts for this industry are concentrated in Range C requirements for staff
11
-------
training and in monitoring of internal exposures. It is estimated that the industry would
incur annual costs of $680,000 for Range C if non-professional health physics personnel
are not permitted to assume supervisory responsibilities.
With the exception of instruction in levels of risk, the training requirements in the
proposed guidelines are currently being satisfied. To additionally provide instruction in
levels of risk to the industry's 4,000 potentially exposed workers would cost approxi-
mately $130,000 annually.
The control of internal exposures is the highest potential cost area for this industry, yet
it is also the one for which the least is understood by either industry or the regulators.
If the five firms that make up this industry respond by modifying the calculational
procedures on airborne concentration, particle size, enrichment, solubility, and worker
time-in-area, then the result in annual industry costs could be three or four hundred
thousand dollars and initial costs of $1 to $2 million. However, if the two small firms
opt for glove box containment as suggested by a case study, then the annual costs rise
to $3 million, and initial costs could be $20.6 million. This alternative is believed to be
less likely because it could put the smaller firms out of business.
Compliance with the alternative 1.5 rem/year limit would not be a problem for this
industry with respect to external exposures. However, the summation of internal and
external exposures could present compliance difficulties. This risk could be eliminated
by a program similar to the internal exposure estimates described above.
Commercial Power Reactors
Cost of compliance with the proposed guidelines are significant for this industry. Major
cost impacts occur in the whole-body limit, lifetime limit, Range C and internal
exposures guidances.
The 5.0 rem/year limit could result in the need for about 300 additional outside workers
at an annual cost of $350,000. For the alternative 1.5 rem/year limit, about 1,300
permanent station workers and 24,000 outside workers would be required. In addition,
there would be costs relating to outage extension and additional facilities. The
combined annual costs of additional operating expenses and personnel are estimated to
be $200 million. Initial expenses for additional facilities are estimated to be $3 miUion.
12
-------
Other costs would include $7.5 million for addition of several specially skilled workers
for work in high radiation fields. Additional workers would reduce the likelihood of any
workers exceeding the lifetime limits. Compliance with Range C would require a
substantial staff increase in health physics technicians. It is estimated that the current
staff of HP technicians at the 54 operating sites would have to be doubled to provide
monitoring required by Range C. The cost to the utilities of these staff is estimated to
be about $250 million. On the other hand, these costs would be greater than the cost
for operating within the 1.5 rem/year limit, that is $200 million annually and $3 million
initial expenditures. An additional $2 million in one-time programming and software
modifications for internal monitoring would be expected. Thus it is expected that
utilities would choose to operate below the 1.5 rem/year limit, thus eliminating Range
C monitoring requirements.
Nuclear Pharmacies
This industry which has developed over the past decade is dominated by two firms. The
cost of compliance is estimated to be entirely concentrated in activities associated
with the upgrading of software to account for the changes in the internal exposure
guidance. Costs are expected to be about $20,000 per year.
Uranium Mill
Impacts of the guidelines on the 20 currently operating uranium mills are expected to
be concentrated in Range C compliance and in internal exposure control, monitoring,
and recordkeeping. The addition of health physicists to the mill staff for compliance
with Range C is estimated to cost $1 million annually. The determination and
monitoring of particle size and solubility of materials and the development of a
recordkeeping system for these data are expected to cost the industry $1.5 million to
establish and $3 million annually to maintain. The alternate whole-body limit of 1.5
rem would result in costs equal to the Range C compliance costs.
Uranium Conversion
Only two uranium conversion facilities currently operate in the U.S. Impacts from the
Range C requirements are estimated to cost the industry $100,000 per year for the
expansion of the health physics staff. The development of a particle size and solubility
13
-------
monitoring and recording system to comply with the internal exposure guidance is
expected to cost the industry $250,000 initially and $500,000 annually.
Other Industries
Compliance costs for other industries where case studies were not conducted have been
estimated utilizing secondary data. These industries include education, operators of
irradiators, podiatry, chiropractic medicine, veterinary medicine, and users of industrial
guages. The impacts on transportation of radioisotopes were not estimated because
sufficient information was not available.
Except for veterinary medicine, exposures should be in Range A if equipment is
operated properly and procedures are followed. Under these conditions, the only
portion of the proposed guidelines that could impose a cost is that of training, assuming
that workers are not instructed in levels of risk. To quantify this cost for each
industry, we used the per worker training cost from a comparable industry treated in
the case studies. For example, the per worker cost for training personnel in podiatry,
chiropractic medicine, and veterinary medicine was assumed to be approximately equal
to that of other private medical practices, i.e., $20. Using this approach, the combined
annual costs for training amounted to approximately $2 million.
The other compliance costs relate to Range B exposures in veterinary medicine. Here
the Range B cost per worker in private medical practice was used, and the annual costs
totaled $300,000 for the approximately 10,400 veterinary offices in operation were
estimated.
14
-------
CHAPTER 2
INTRODUCTION
The Office of Radiation Programs, (ORP) has been reviewing the 1960 radiation
protection guidance for workers since 1974. The Office has sponsored a major study by
the National Academy of Sciences - National Research Council Committee on the
Biological Effects of Ionizing Radiation (BEIR) and conducted a study of the 1975
radiation workforce. Utilizing these studies, consultation with other affected Federal
agencies and other data, ORP issued a proposed set of revised guidelines for public
comment in the Federal Register on January 23, 1981. These guidelines were designed
to address the allowable annual and lifetime radiation dose for workers, levels of
supervision and training for categories of workers, internal and external exposures,
n
exposure to specific organs, protection of the unborn, and other issues.
Subsequent to the Federal Register notice, public hearings were held and written
comments on all aspects of the proposal were received by ORP. Comments from
interested parties made it clear that there was a substantial uncertainty as to the costs
that would be borne by industry if the proposals were adapted. This uncertainty stems
in part from the number and wide diversity of the economic sectors that employ
radiation workers. The ORP study stated that in 1975 there were over one million
radiation workers of which about forty percent were exposed to ionizing radiation.
Table 2 provides a breakdown of these employment and exposure data by industry
segment.
The estimates of the number of radiation workers by industry in 1975 were based on a
sample of monitoring data provided by a large badging service firm. In general, the
data provides a reasonable order of magnitude estimate of the size of the workforce.
However, the failure to eliminate all room or area badges and badges with erroneous
counts could seriously bias the data, particularly when the sample is expanded to cover
the universe of radiation workers on a disaggregate industry and level of exposure basis.
Occupational Exposure to Ionizing Radiation in the United States: A Comprehensive
Summary for the Year 1975, U.S. Environmental Protection Agency, Office of
Radiation Programs, EPA, November 1980, EPA 520/4-80-001.
2
The complete text is included in Appendix A.
15
-------
Table 2
SUMMARY OF HIGH EXPOSURE
DATA FOR 1975
L
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
Percent
Estimated Total 5
Activity Number of Workers rem
Power Reactors
Industrial
Radiography
Manufacturing <5c
Distribution
Fuel Processing <5c
Fabrication
Medical Hospital/
Clinic
Other Industrial
Veterinary
Medical Private
Waste Disposal
Education
Dental
Podiatrists
Uranium Mills
Chiropractors
Transportation
Source: Occupational
Summary for
tion Programs
55,000
20,000
11,000
11,000
100,000
170,000
18,000
138,000
300
22,000
270,000
10,000
300
15,000
77,000
Exposure
the Year
0.5%
0.4%
0.5%
0.7%
0.2%
0.2%
0.2%
0.3%
0.0%
0.1%
0.1%
0.0%
0.0%
0.0%
0.0%
of Workers Exposed Pei
1.0-5.0 0.5-1.0 Ag<
rem rem
12.8%
8.5%
5.7%
5.6%
4.2%
3.5%
1.1%
2.5%
0.0%
1.5%
0.5%
0.0%
0.0%
0.2%
0.2%
5.7%
6.4%
4.2%
5.9%
5.6%
1.8%
1.6%
2.8%
0.0%
1.8%
0.6%
0.0%
0.0%
0.9%
0.6%
to Ionizing Radiation in the United States:
1975, U.S. Environ
, EPA, November 1980, EPA
mental Protection Agency,
520/4-80-001.
[cent of Females
es 18-39 Exposed
to 0.5 rem
16%
0%
1%
0%
7%
1%
3%
4%
No Data
2%
1%
0%
0%
No Data
No Data
A Comprehensive
Office of Radia-
16
-------
The purpose of this study was to estimate the cost of compliance with each individual
portion of the guidance. Further, these costs were to be estimated for each industry
where significant impacts were expected. The diversity of the impacted industries
eliminated the option of applying a common cost estimation methodology across all
industries. Indeed, each industry appeared to have unique requirements for workers
that led to industry specific radiation protection procedures and options. Each industry
where significant cost impacts were anticipated required specific analysis of the job
requirements, exposure history, and potential exposure for radiation workers. The
available options for compliance with the guidelines were evaluated for technical and
economic feasibility for each industry. In order to collect the required data a series of
case studies were arranged. In each case a senior radiation protection professional and
a senior economist spent one to two days at establishments in selected industries
evaluating their radiation protection programs and options under the proposed guidance.
Representative case studies were selected on the basis of potential impact, drawing
2
heavily from the 1975 EPA study of occupational exposures. Impact was defined as
the degree to which a particular industry might be affected by the proposed guidelines.
Numbers of workers potentially exposed in excess of 5 rem was not considered to be a
sufficient criterion, since the establishment of a 5 rem/year whole-body RPG is only
one part of the proposed guidance. (Also, many of the alleged annual exposures in
excess of 5 rem in the 1975 data base may be anomalous as noted above.)
The following were considered as indicators of impact:
1. Numbers of whole-body exposures in excess of 5 rem
2. Numbers of whole-body exposures in Range B (0.5-1.5 rem) and Range C
(1.5-5 rem)
3. Numbers of females of child-bearing age with exposures in excess 0.5 rem
4. Numbers of organ exposures in excess of the proposed RPG's
5. Numbers of workers with measurable internal exposures
For a detailed description of the case study selection procedure and results see: Case
Study Analysis of the Impact of Proposed Radiation Protection Guidance for Workers,
Jack Faucett Associates, prepared for EPA/ORP, July 12, 1983.
2Op. cit., EPA, EPA 520/4-80-001, November 1980.
17
-------
Cross-industry data were unavailable for items 4 and 5. Thus items 1 through 3 were
used as the indicators of impact.1 Final selection of case study industries were made
using these data, specific needs of ORP, requests from the Nuclear Regulatory
Commission, and NRC data on exposure at licensed facilities.
A review of the public comments on the proposed guidance indicated that there was a
substantial amount of confusion among the public as to the intent of several portions of
the guidelines. Prior to conducting any case studies it was necessary to develop a clear
definition of the intent for each section of the guidance so that fruitful discussion of
cost, exposure and available protection options could be undertaken with each case
study firm. Working with the ORP personnel responsible for the proposed guidelines the
case study staff developed a list (presented in Table 3) which segregated the proposed
guidance into several separate issues. These issues formed the basis for the
conduct of each case study. The list, which was provided to each prospective case study
firm, compared language and data from the 1960 guidance with the proposed new
guidance. For each item interpretive assumptions were also developed and provided.
The information collected in the case studies was reviewed with other knowledgable
individuals in each industry to develop the cost estimates provided here. These costs
are the direct expenses that firms in each industry can be expected to face in order to
satisfy the requirements of the guidance. No attempt has been made to estimate the
benefits that stem from the guidance or indirect cost effects such as reduced product
demand, changes in supply patterns, and the cost to individuals. Also not included are
costs that may be associated with specific requirements placed on firms by regulations
such as record keeping and reporting. These costs could be significant. In a related
o
study for the Nuclear Regulatory Commission, utilizing the same case study data
incorporated here, evaluation of the proposed revisions to 10 CFR Part 20 for
The estimates of female exposures were taken from a contractor report, Occupational
Exposures to Ionizing Radiation within the United States for the Year 1975-A
Statistical Data Base, prepared by Teknekron, Inc., under EPA Contract No. 68-01-
1953, July 1978.
2
Jack Faucett Associates and S. Cohen and Associates, Inc., Cost of Compliance With
Occupational Exposure Revisions to 10 CFR Part 20, prepared for the Nuclear
Regulatory Commission, December 20, 1982.
18
-------
Table 3
REQUIREMENT
Justification
SUMMARY OF PROPOSED CHANGES IN OCCUPATIONAL RADIATION PROTECTION GUIDANCE
FRC GUIDANCE
"...no man-made radiation exposure
without the expectation of bene-
fit..."
PROPOSED NEW GUIDANCE
"...occupational exposure should be Justified by the
net benefit... include considerations of alterna-
tives not requiring exposure."
INTERPRETIVE ASSUMPTIONS
No substantive change from current
requirements} i.e., no new paperwork
required.
ALARA
"...encourage maintenance of radi-
ation doses as far below this guide
as practicable."
"...assure that collective dose is ALARA." Also,
maintain individual doses and lifetime doses
ALARA.
No substantive change from current
requirements; i.e., no new paperwerk
required.
RPG-t
W.B.
Rate
Accumulated
rem/qtr.
-18) limit, where N * age.
<5 rem/yr.1
<100 ram objective in lifetime.
The quarterly limit is eliminated.
Assume existing workers are grand-
fathered.
Internal Exposures
Individual critical organ limits
carried out through MFC's (Radio-
activity Concentration Guides)
X w,H, v S rem/yr., where H, Is annual dose
equivalent and committed dote equiv. to or\
i, and:
organ
Note constraints from subsequent
requirements on gonads and other organs.
"breast *>a
»lunf-0.1«
red bone marrow
.03
0.16
"thyroid s°-04
bone surfaces'
"other organs * 8'01
Radioactivity Intake Factors (RIP'S) calcu-
lated from the above.
EPA will supply values of RIP% and
corresponding MFC's, as in the Attach-
ment.
Combined uniform W.B.
and internal exposures.
Independent limits
W.B. + I WjH| < 5 rem/yr.
Hands i- SO rem/yr.
Bye lens or gonads < 5 rem/yr.
Other organs < 30 rem/yr.
Extremities and Individual
Organs
Hands & forearms, feet 4c ankles
< 25 rem/qtr. and t- 75 rem/yr.
Head and trunk, active blood
forming organs, gonads, or eye
lens *-3 rem/qtr.
Skin of W.B. & thyroid < 10
rem/qtr. and t- 30 rem/yr.
Bone < 0.1 jtgm Ra-220 or equiv.
body burden
Other organs v S rem/qtr. and
IS rem/yr.
Includes external exposure and
dose equivalent frem internal.
iltted
1As an alternative, consider W.B. RPQ< 1.5 rem/yr.
'"Annual committed dose equivalent" means the sum of all dose equivalents that may accumulate over an individual's remaining lifetime (usually taken as 50 years)
from radioactivity that is taken into the body in a given year.
If any specific RIP is larger than currently in use, use current limit.
-------
.Table 3 (Continued)
REQUIREMENT
Exposure of Minors \
SUMMARY OP PROPOSED CHANGES IN OCCUPATIONAL RADIATION PROTECTION GUIDANCE
(Continued)
PROPOSED NEW GUIDANCE INTERPRETIVE ASSUMPTIONS
1/10 RPG"s
PRC GUIDANCE
1/10 RPG%
Exposure of Unborn
No Guidance
Alternatives*
i. Women voluntarily keep dose to unbornT 0.5
rera during known/suspected pregnancy.
ii. Women able to bear children voluntarily avoid
Jobs with dose > 0.2 rem/mo., and keep dose
to unborn < 0.5 rem during known pregnancy.
III. Women able to bear children limited to Jobs
' with dose v 0.2 rem/mo. and dose to unborn
v 0.5 rem.
Requirement on the unborn Is assumed
to be met if satisfied by the woman.
Lower Limits
Permitted after consideration by
agency.
Agencies may set limits below RPO% and RIP'S
when appropriate.
Assume RPQt In this guidance for purpose*
of cost estimate. If any future lower limits,
the other regulatory agencies would Justify
them separately.
tsS
o
Higher Limits
Permitted after consideration by
agency.
Permitted after consideration by agency (but
must be publicly disclosed).
Assume RPG.% in this guidance for purposes
of cost estimate. If any future lower limits,
the other regulatory agencies would Justify
them separately.
Training
Monitoring
No guidance
No guidance
All radiation workers must be Instructed on
levels of risk from radiation and radiation protec-
tion principles.
Quantitative guidanea on risk.
Range A (assume ^0.1 RPOh Monitor area
exposure rates to assure exposures In range and
ALARA.
Range B (assume ^0.1 RPQ and < 0.3 RPQ)t
Monitor and record individual exposures.
Range C (assume 70.3 RPQ and < 1.0 RPQh
Monitor area exposure rates before and during
tasks In addition to monitoring individual
exposures.
Done one* and for all unless changes in
source and/or exposure configuration.
Individual dosimeters and records.
Individual dosimeters and records ptuj
surveys before and during tasks.
Supervision
No guidance
Range A (assume £-0.1 RPOh No requirements.
Range B (assume 7 0.1 RPO and < 0.3 RPGh
Provide professional radiation protection
supervision sufficient to assure exposures
Justified and ALARA.
Range C (assume >0.3 RPQ and £1.0 RPQh
Provide professional radiation protection
supervision before and while tasks are under-
taken which make significant contribution to
exposures in this range and to assure exposures
are ALARA.
Assume radiation protection professional
la available but not necessarily full-time.
Also, assume no formal paperwork required.
Assume full-time radiation protection
supervision. Exposure to the supervisor
is not implied.
Assume that a "radiation protection professional" is a certified Health Physicist, Medical Physicist, or Individual with equivalent training and experience.
-------
occupational exposure regulations concluded that compliance with NRC regulations and
NRC Agreement State Regulations could cost $4 million for record keeping, $8 million
for revisions to existing manuals and procedures, and $4 million for retraining of
personnel. These costs are not attributable directly to the guidance as they are
associated with specific regulatory actions.
21
-------
CHAPTER 3
COST OF COMPLIANCE; HOSPITAL/CLINIC
3.1 INDUSTRY PROFILE: HOSPITALS
In 1980, American Hospital Association (AHA) survey results show a total of 6,965
1 2
registered hospitals located in 50 states and D.C. providing a total of 1,365,000 beds .
The number of hospitals is down from a total of 7,015 and 6,988 registered hospitals in
o
1978 and 1979, respectively. Community hospitals account for 5,830 of all registered
hospitals in 1980 and for 988,387 of all patient beds. Just under 800 community
hospitals are affiliated with medical schools.
Ten percent of all community hospitals contain 400 or more beds. Community hospitals
with 100 to 400 beds now account for 43 percent of all hospitals and 51 percent of all
patient beds. Small community hospitals (less than 100 beds) have declined in number
since 1970 and in 1980 accounted for only about 15 percent of all beds.
Performance and Services
All registered hospitals in the U.S. admitted 38,892,000 patients in 1980 and recorded
262,951,000 outpatient visits. The vast majority of outpatients and admitted patients
were serviced by community hospitals. Occupancy for all registered hospitals averaged
77.7 percent of all available beds in 1980 and 75.4 percent of all available community
hospital beds. Over 19,500,000 surgical operations were performed in 1980 by those
hospitals surveyed. Expenses at 4,377 community hospitals reporting to the AHA
totaled $72.60 billion in 1980 or $1,893 per admission or $250 per inpatient day.
Table 4 highlights the number of hospitals responding to the AHA survey providing
radiation therapy or diagnostic services in 1980. Radiation therapy is available at
An additional 71 registered hospitals are located in U .S.-dependent areas.
Hospital Statistics, 1981 Edition, American Hospital Association.
2
Community hospitals are classified by the AHA as non-federal, non-institutional, short-
term (average length of stay less than 30 days), general and other special hospitals.
22
-------
CO
Table 4:
RADIATION THERAPY OR DIAGNOSTIC SERVICES OFFERED BY HOSPITALS. 1980
TOTAL
REPORTING
M\M*if \JH 1 m Ui
CLASSIFICATION
ALL HOSPITALS
6- 24 beds
25- 49 beds
50- 99 beds
100-199 beds
200-299 beds
300-399 beds
400-499 beds
500 or more
FEDERAL HOSPITALS
psychiatric
general 4 other
NON-FEDERAL HOSPITALS
psychiatric
TB & other respiratory
long-term general
short-term general
COMMUNITY HOSPITALS
6,277
234
995
1,502
1,458
772
469
319
528
340
24
316
5,937
454
10
137
5,336
5,293
RADIATION THERAPY
X-Ray
No.
1,154
5
15
52
180
224
219
167
292
51
0
51
1,103
7
0
6
1,090
1,090
%*
18.4
2.1
1.5
3.5
12.3
29.0
46.7
52.4
55.3
15.0
0.0
16.1
18.6
1.5
. 0.0
4.4
20.4
20.6
Mega voltage
No.
910
2
2
17
104
169
181
155
280
45
0
45
865
1
0
2
862
862
%
14.5
0.9
0.2
1.1
7.1
21.9
38.6
48.6
53.0
13.2
0.0
14.2
14.6
0.2
0.0
1.5
16.2
16.3
RADIOACTIVE
TMDT A WT<5
IMf ijArl 1 3
No.
1,414
0
13
67
254
309
263
205
303
58
0
58
1,356
2
0
2
1,352
1,352
%
22.5
0.0
1.3
4.5
17.4
40.0
56.1
64.3
57.4
17.1
0.0
18.4
22.8
0.4
0.0
1.5
25.3
25.5
NUCLEAR MEDICINE
Diagnostic
No.
3,689
24
215
650
1,038
683
419
284
376
185
12
173
3,504
20
4
15
3,465
3,465
%*
58.8
10.3
21.6
43.3
71.2
88.5
89.3
89.0
71.2
54.4
50.0
54.7
59.0
4.4
40.0
10.9
64.9
65.5
CT CARDIAC
cr>AiJMPn« PATUirTirniTATiniJ
Therapeutic
No.
1,485
1
11
53
280
320
279
224
317
91
2
89
1,394
2
0
2
1,390
1,390
%*
23.7
0.4
1.1
3.5
19.2
41.5
59.5
70.2
60.0
26.8
8.3
28.2
23.5
0.4
0.0
1.5
26.0
26.3
No.
1,242
5
17
38
155
250
261
210
306
42
0
42
1,200
4
0
0
1,196
1,195
LI AJAfchJ ^X*TK * ftAAJ * U l*A*4n « »VX H
-------
15-20 percent of all hospitals in the U.S., primarily at the larger hospitals with over
200 beds. Diagnostic radioisotope facilities are available at over 55 percent of all
hospitals, and over 65 percent of all community hospitals. Special radiation services
such as CT scanners and cardiac catheterization were available at 20 and 15 percent of
all hospitals, again primarily at the larger-sized hospitals. Approximately 1,800
hospitals are licensed by the NRC for radiation services and an additional 1,800
facilities are licensed, by agreement states.
There are approximately 3,700 hospitals that have nuclear medicine departments. Of
these, 1,700 are large (200 or more beds) and 2,000 are small (less than 200 beds).
Hospitals with radiation workers include those with Nuclear Medicine Departments,
Radiation Therapy Departments, CT Scanning facilities, Cardiac Catheterization and
Diagnostic Radiography Departments. The largest subcategory are those with Nuclear
Medicine Departments and due to a lack of more detailed information, it is assumed for
the performance of this study that any hospital with one or more of these facilities has
a Nuclear Medicine Department.
Employment
Slightly less than 3,500,000 full-time equivalent (FTE) personnel worked in registered
U.S. hospitals in 1980 compared to just less than 3,390,000 in 1979. Of this total,
2,873,000 FTE personnel were employed by community hospitals, most at hospitals with
more than 100 beds. Community hospital employees were paid a total of $43,283,000 in
1980 in wages and benefits with an average salary of $13,010 per employee per year2.
Approximately 70,000 employees are monitored at NRC licensed hospitals.
Physicians and dentists number only 57,292 out of all FTE personnel in all registered
hospitals. Registered nurses and LPN's number 693,385 and 258,413, respectively.
Statistics from the American CoUege of Radiology show that 660 hospitals in the U.S.
employ medical physicists full-time and an additional 520 hospitals employ medical
physicists part-time. In addition, many large hospitals employ full-time health
physicists such that about 1,000 hospitals have one or more health and/or medical
1Op. Cit., NRC, NUREG-0714.
2
Op. Cit., Hospital Statistics, 1981.
24
-------
physicists on staff. At least 50 percent of all pathologists in the U.S. are salaried and
work exclusively for hospitals, administering about 25 percent of all nuclear medicine
practiced. Total radiation workers employed in U.S. registered hospitals are estimated
to number 100,000.
3.2 COST OF COMPLIANCE WITH GUIDANCE
Guidance #1 Annual Whole-Body Limit - 5 rem/year
Although the 1975 EPA Data Base indicates 200 exposures in excess of 5 rem, it is
believed that all hospitals currently comply with the proposed annual whole-body limit.
Two reasons for this are improved health physics practice and more sophisticated
technology. Therefore compliance would entail no costs.
Guidance #2 Accumulated Lifetime Exposure - 100 rem
Except for hospitals with very active cardiac catheterization laboratories, there will be
no impact for most hospitals. Very few cardiologists (of 2,000 performing catheteriza-
tions) would be expected to approach the 100 rem limit, which would shorten their
careers under the proposed guidance. No cardiologists at the case study hospitals were
known to be close to this limit, but if care were not taken, the case study staffs could
foresee some doctors being affected by this provision. However, no data that were
provided by the case study institutions supported this fear. It is felt that there would
be no cost to the industry. The cost would be borne by the individual since so few
cardiologists would be affected.
Guidance #3 - Exposure to Extremities and Organs
There exists considerable controversy relating to the hand exposures of radiologists
during fluoroscopy. Exposure rates in the direct beam are very high, and although it is
generally acknowledged that the direct beam is avoided, it is suspected that this
prohibition is not universally regarded. Moreover, hand protection (lead-impregnated
gloves) is seldom worn and monitoring (ring badges) is rarely performed. Therefore,
quantitative data are virtually non-existent.
1Op. Cit., EPA, 1975.
25
-------
Hand exposures for physicians performing cardiac catheterization have been evaluated
in detail by Rueter.1 In his judgments exposures for this procedure are typically 5 to 10
mrem per catheterization performed. Therefore, for a physician performing the
recommended (by the Inter-Society Commission for Heart Disease Resources) number
of cardiac catheterizations (6 per week), hand exposures might be expected to be as
high as 3 rem, well within proposed limits.
Most hospitals measure eye exposure with collar badges, and this is an acceptable
health physics practice. Since these measurements are within the proposed annual 5
rem limit for eye exposure, the requirements relating to eye exposure would have no
impact on the industry.
Guidance #4 - Anticipated Exposures in Range C (1.5 - 5.0 rem/yr.)
Hospitals which anticipate annual exposures to personnel above 1.5 rem could respond
according to several interpretations of the proposed guidance, which range from strict
to liberal:
1. A health physicist or medical physicist (radiation protection professional)
must supervise all activities where significant exposures are anticipated.
These activities include cardiac catheterization, diagnostic radiology (in
special procedures), and nuclear medicine. Therefore, a minimum of
three health physicists would be required in hospitals providing all of
these services, and in hospitals with multiple special procedures rooms,
more than three radiation protection professionals are required.
2. A radiologic technician is delegated supervisory responsibility for Range
C activities, and a health physicist or medical physicist supervises the
team of technicians.
3. A radiologist or nuclear physician with training and experience in health
physics supervises Range C activities.
Fred Renter, Bureau of Radiological Health, private communication, January 25, 1982.
26
-------
Options 1 and 3 did not appear feasible. Therefore, their costs were not estimated.
Option 3 was excluded because a radiologist or nuclear physician, although experienced
in health physics, is not considered equivalent to a health physicist or medical physicist
according to the opinion of the President of the American Association of Physicists in
Medicine.
Option 1 is not feasible because the current population of radiation protection
professionals is not sufficiently large. A reasonable estimate of 7,300 health physicists
would be demanded, assuming an average of three at each of the 1,800 large hospitals
(with more than 200 beds) with Nuclear Medicine Departments, and one at each of the
1,900 smaller hospitals (less than 200 beds)with Nuclear Medicine Departments. This
coverage would require approximately 70% of the total number of medical and health
physicists currently in practice.
Currently about 1,000 hospitals have either health or medical physicists on staff. Of
these, about 600 are part of an active health physics monitoring program and the
balance are exclusively performing other functions such as therapy dose targeting and
calculation. Option 2 would require those hospitals with Nuclear Medicine and no
radiation protection professoinal on staff (about 2,700 hospitals) to hire staff with those
qualifications. This option is also very difficult to imagine, but given enough lead time,
the growing number of universities offering degrees in health or medical physics and
related disciplines could meet the increased need.
In addition, option 2 appears to agree with the intent of the guidance, namely,
supervision of Range C activities by a radiation protection personnel (who are not
necessarily professionals). Since Range C exposures are generally routine and uniformly
accumulated, direct supervision by a health physicist at each activity is not warranted.
These activities can be adequately supervised by a radiologic technician under the
oversight of a health physicist.
Two scenarios are presented in the cost analysis for option 2. The two scenarios vary in
that they are based on different estimates of the size of the hospital in which five
percent of exposures are anticipated to be in Range C. Five percent of exposures
anticipated in Range C is judged to be sufficient to trigger the requirements of this
guidance.
27
-------
Scenario I includes all hospitals with nuclear medicine departments (about 3,700
institutions ), while scenario n only includes the 1,800 large hospitals (more than 200
beds) with nuclear medical departments. It is estimated that about 600 hospitals
currently employ full-time health or medical physicists and supervise Range C
activities, thereby satisfying the requirements of the guidance. These hospitals are
expected to be large facilities. It is further estimated based on case study and related
data that roughly 400 large hospitals employ a full-time health or medical physicist
with duties other than radiation protection or exposure monitoring and that 500
hospitals retain part-time health physics consultants. None of these hospitals are
believed to satisfy the supervisory requirement. In estimating the number of personnel
necessary for compliance, the following assumptions were made:
the services of part-time consultants would be subsumed by the impact of
Range C requirements; therefore, they constitute an avoided expense in
the cost estimate presented in Table 5;
75% of the 500 part-time consultants currently employed are associated
with large hospitals;
a health physicist already on staff currently devotes 10% of his time to
non-supervisory tasks; this work would be delegated to a radiologic
technician;
small hospitals on average have only one department where Range C
exposures are anticipated; therefore, one radiologic technician would be
required;
large hospitals on average have three departments where Range C
exposures are anticipated; therefore, three technicians would be required;
at large hospitals which currently monitor high-exposure activities, two
additional technicians on average would be required;
equipment such as survey meters, calibration sources, etc. required for a
monitoring program would cost approximately $2,000.
Table 5 presents the calculation of costs for scenarios I and n under the above
assumptions.
Estimates of total hospitals by category are rounded from Table 4 to reflect the few
institutions not included in the American Hospital Association survey and changes since
1980.
28
-------
Scenario I estimates are:
Line 1 - 2,700 hospitals with nuclear medicine but without current HP staff
Line 2 - 6,800 HP technicians including 1 for each of 1,900 small hospitals
with nuclear medicine; 2 for each of 600 large hospitals with
nuclear medicine and a monitoring program; 3 for remaining 1,200
large hospitals with nuclear medicine and no monitoring programs;
and 100 technicians to replace time of HP's who are now required
to supervise the health physics program.
Line 3 - 3,100 hospitals with nuclear medicine and without a current
radiation protection program.
Line 4 - 375 large hospitals with nuclear medicine and part-time HP
service.
Line 5 - 125 small hospitals with nuclear medicine and part time HP
services.
Scenario n estimates are:
Line 1 - 800 large hospitals with nuclear medicine and no health or medical
physicists on staff
Line 2 - 4,900 technicians as in scenario I less 1,900 for small hospitals not
included in scenario n
Line 3 - 1,200 large hospitals with nuclear medicine and no health physics
program.
Line 4 - 375 large hospitals with nuclear medicine and part-time HP
services.
29
-------
Table 5; Hospital Cost Estimating for Range C Compliance
General Assumptions (Based on case study data)
1. Full annual cost of physican and health physicist (HP) = $68,000; (a base salary of
$40,000, times a multiplier of 1.7 for overhead and fringe).
2. Full annual cost of radiologic technologist, diagnostic technician, and radiologic
technician = $25,500, (base salary of $15,000 times 1.7 multiplier).
3. Annual cost of a radiation services consultant
$4,200 small hospital
$7,800 large hospital
SCENARIO I
No. of Units
1.
2.
3.
4.
5.
1.
2.
3.
4.
Full-time H.P. (+)
Technicians (+)
Equipment (+)
Part-time H.P. services (-)
Part-time HP service (-)
TOTAL
Full-time H.P. (+)
Technicians (+)
Equipment (+)
Part-time H.P. services (-)
TOTAL
2,700
6,800
3,100
375
125
SCENARIO H
800
4,900
1,200
375
Cost Annual
$68
25
2
7
4
$68
25
2
7
,000
,500
,000
,800
,200
,000
,500
,000
,800
183.
173.
(2.
(.
$353
54.
125.
(2.
$176
Cost
6
4
9)
5)
.6
4
0
9)
.5
Initial Cost
6.2
6.2
2.4
2.4
30
-------
Guidance #5 - Anticipated Exposures in Range B (0.5 to 1.5 rem/year)
Range B exposures are anticipated at any hospital which has diagnostic radiology. Since
all hospitals provide this service, the proposed guidance impacts on the entire industry.
Compliance requires monitoring of Range B activities, and the availability of a radiation
protection professional to assure exposures are justified and ALARA. Under scenario I
from above, all hospitals with nuclear medicine would already have to hire a full-time
health physicist. Therefore, only the 3,300 hospitals without nuclear medicine (all
assumed to be small hospitals) would be required to hire a part-time consultant at $4,200
per year. The annual cost to the industry would be $13.9 million.
Under scenario n from above, the 2,000 small hospitals with nuclear medicine
departments would have to retain a part-time consultant in lieu of responding to the
guidance on Range C. However, 125 of these hospitals already employ a part-time health
physicist. Therefore, a part-time consultant would be necessary at these 1,875 hospitals,
as well as the 3,300 hospitals without nuclear medicine. At a consultant cost of $4,200
per year, annual industry costs would be $21.7 million.
If the guidance on Range C was not promulgated, then 325 additional large hospitals which
currently employ neither full-time nor part-time health physicists would have to hire
part-time consultants at $7,800 per year. The additional costs would be $2.5 million per
year.
Table 6: Cost Estimate - Annual
Expense Scenario I Scenario n
Part-time $13.9 million $21.7 million
Consultant
In lieu of
Range C
$24.2 million
Guidance #6 - Training
It is estimated that 50 percent of hospitals with nuclear medicine currently satisfy the
requirements on training in radiation protection principles and levels of risk. The other
portion of the industry would have to provide two hours of additional instruction in
levels of risk.
31
-------
Instruction at hospitals not currently in compliance would be given by the full-time
health physicist hired in response to Range C or by part-time consultants hired in
response to Range B as an integral part of a total health physics program. Therefore,
the costs of compliance are limited to the cost of staff time during training, a
negligible cost which is not estimated here.
The industry has approximately 100,000 monitored and unmonitored workers with
potential occupational exposure. It was noted above that approximately 50 percent of
all radiation workers in hospitals with nuclear medicine departments already receive
adequate training. The number of radiation workers by size of hospital or type of
department is not available to estimate how many radiation workers at hospitals
without nuclear medicine receive adequate instruction. It is assumed that half the
radiation workers are in hospitals with nuclear medicine and half of these hospitals
provide qualified instruction. Hospitals without nuclear medicine we assumed to not
provide adequate instruction. It follows that 25% of radiation workers currently
receive adequate instruction. The remaining 75,000 workers then must receive two
hours of instruction at a full hourly rate of $10 per hour or $1.5 million.
If Range B and C were not promulgated instructor time would have to be added.
Assuming 5,150 hospitals (1/2 of hospitals with nuclear medicine and all other hospitals
with radiation workers 7,000 - 1,850) would have to hire consultants to provide 2 hours
each quarter in levels of risk instruction at $250 per quarter total annual cost would
increase by $5.1 million.
Guidance #7 - Exposure to the Unborn
Three alternatives are under consideration by EPA. Under Alternative a, women
voluntarily keep the dose to the unborn to less than 0.5 rem during known and suspected
pregnancy. All hospitals currently operate under this option. Therefore, there would be
no impact if Alternative a were retained under the proposed guidance.
Under Alternative b, women able to bear children voluntarily avoid jobs with potential
exposure in excess of 0.2 rem/mo., and keep dose to unborn less than 0.5 rem during
known pregnancy. Since jobs with the potential exposures of 0.2 rem/mo. are
considered the most rewarding, it is unlikely that many women would request transfer
32
-------
to low exposure jobs. Furthermore, a request for transfer from a small number of
female workers at a large hospital would have negligible impact because the request
could probably be accommodated by rotating staff. At small hospitals, however, a
request for transfer could result in discharge. But again, assuming that few females ask
for transfer, there would be no cost to the industry.
The other possible reason for compliance costs under Alternative b relates to exposure
during pregnancy. But here as well, no impact is expected because the number of
pregnant women at one time is too small. Assuming that the proportion of pregnant
radiation workers is the same as the general female population (i.e., 6%), then only 4,000
women are potentially affected. The case studies indicate that staff rotation in larger
facilities would permit most pregnant workers to remain on the job at low exposure
activities. Assuming that 66% of pregnant workers are employed at hospitals capable
of accommodating requests for transfer to low exposure jobs, then about 1,300 women
would have to take leaves of absence without pay. This cost would not be borne by the
industry, but by the individual. In summary, no cost to the industry is expected under
Alternative b, both in regard to women able to bear children and women who are
pregnant.
The impact of Alternative c depends on the form of monitoring. Under-the-apron
monitoring is appropriate for measuring exposure to the unborn in cardiac catheteriza-
tion and special procedures where the photon energies are relatively low. Since
exposures measured under-the-apron are not usually in excess of 0.2 rem/mo. in these
activities, these jobs would not be closed to female workers. Therefore, the impact of
Alternative c with under-the-apron monitoring in departments other than nuclear
medicine would be limited to the incremental costs of dual badging. Assuming that 2/3
of approximately 85,000 female radiologic technicians work at hospitals, then approxi-
mately 56,000 workers would be dual badged. Average badging costs are $15/year.
Therefore, the total costs would be $840,000.
Assumes that 2/3 radiation workers are female (66,000 female workers times 6 percent
is approximately 4,000 pregnant radiation workers).
33
-------
Table 7; Cost Estimate for Female Dual Badging
No. of
female
workers
Badging
Cost/year
Annual
Cost
Expense
Dual-badging 56,000 $15 $840,000
Dual badging would not provide the full protection for females in nuclear medicine
because of the existence of some high energy photons which a lead apron may not
provide the necessary protection. However, no case study hospital reported annual
exposures in nuclear medicine of more than 2.5 rem/yr. and exposures in this
department are accumulated relatively uniformly. Thus, exposures of 0.2 rem/mo. are
not anticipated. It follows that jobs in nuclear medicine would remain open to females,
which would impose no cost on the industry. Therefore, the compliance costs of
Alternative c with under-the-apron monitoring is the costs of dual badging where
appropriate.
However, if over-the-apron monitoring is considered the only acceptable way of
measuring exposure to the unborn, women would be barred from high exposure activities
other than nuclear medicine. To replace these workers, the number of male radiation
workers would have to increase by a factor of 2 to 3. This is not feasible at this time.
Moreover, female radiation workers would be deprived of their right to work, which
may conflict with the EEO objectives of the hospital, and produce morale problems
among staff.
Guidance #8 - Internal Exposures
Internal exposures in hospitals are likely to occur only in the preparation or use of
nuclear medicines. The potential internal exposures from Tc-99m can easily be shown
to be well within the 30 percent threshold for monitoring. Only radioiodine might
require some monitoring and clinical uptake probes are readily available in all nuclear
medicine departments. However, these instruments might require calibration, and the
nuclear medicine technologists might require some outside assistance in performing the
calibrations. It is estimated that one-half of the facilities requiring instrument
calibration would use the services of a consultant at a cost of about $500. In addition,
these facilities would require a phantom at a cost of about $200.
There are approximately 1800 NRC medical (non7private practice) licensees.1 There
are approximately 3,700 hospitals nationwide (Agreement and non-Agreement States)
. cit., NRC, NUREG-0714.
34
-------
that have nuclear medicine departments. It is estimated that only about one-third of
the nuclear medicine departments in the country have quantitative internal exposure
2
monitoring programs.
Under the proposed changes, the scanning device would have to be recalibrated. This
would constitute a one-time, initial cost. In addition, an average of two nuclear
medicine technologists would have to receive instruction in self-monitoring during a
one-hour seminar. (The average annual salary of a technician is $15,000.) These two
services calibration and instruction could be provided by a consultant hired at a
cost of $500. Therefore, the costs of internal monitoring for the approximately 2,500
hospitals with nuclear medicine departments which are estimated to currently lack a
bioassay program would be about $1.8 million.
Table 8: Cost of Internal Monitoring (Nuclear Medicine Departments)
Expense
1. Part-time consultant
2. Staff time (2 hrs./
hospital)
3. Phantom
No. of
hospitals
2,500
2,500
2,500
Unit cost
$500
$12/hr.
$200
Initial
Cost
$1,250,000
$ 60,000
500,000
TOTAL $1,810,000
The one category of licensees that would require more extensive internal monitoring is
the research hospital possessing a broad license. There are 95 NRC licensees in this
category and an estimated equal number of Agreement State licensees. It is estimated
Q
that two-thirds of these have adequate bioassay programs. Approximately 24,000
individuals who work for NRC licensees were monitored for external exposures in
A
1979. Taking into account the number not reporting and Agreement State licensees,
American Hospital Association, Hospital Statistics, 1981, p. 191-197, Table 12A.
Bill
1982.
4
2Bill Walker, U.S. Nuclear Regulatory Commission, private communication, September
3Ibid.
*0p. cit., NRC, NUREG-0714.
35
-------
the total number of estimated employees in this category is 52,000. It is assumed, then,
that approximately 17,000 are not monitored for internal exposure.
Assume that a six-month program of internal monitoring is required to demonstrate
that intakes are less than 30 percent of the limit. Assume that most of the researchers
are handling tritium and P-32, and that 20 percent would be sampled to demonstrate
that intakes are less than 30 percent the limit. Assume quarterly urinalyses at a cost of
$12/urinalysis.1 The one-time cost would be 0.2 x 17,000 x 2 x $12 = $81,600. In
addition, a small fraction of workers, say 10 percent, might be handling gamma
emitters. Assume two whole-body counts are required on a sample of 20 percent of
these researchers. At $139 pei
x 17,000 x 2 x $139 = $94,520.
o
these researchers. At $139 per whole-body count, the one-time cost would be 0.1 x 0.2
Therefore, the total cost for hospitals resulting from the internal exposure monitoring
requirements are expected to be approximately $2 million in start-up costs, with
negligible continuing costs.
Guidance #9 - Alternative Annual Whole-Body Limit - 1.5/rem year
Assuming that exposures greater than 1.5 rem/yr. are anticipated at hospitals which
have nuclear medicine, approximately 3,700 hospitals would be affected by the proposed
guidance.
Compliance could be achieved in one of two ways, which constitute the upper and lower
boundaries on cost:
(1) the imposition of a radiation protection program similar to the one at one
o
of the case study medical centers, which has an annual cost of $340,000.
(The full cost of the program is $450,000, but 25% of its work is outside
the facility.) Such a program would also have the benefit of decreasing
collective dose.
Roland Finston, Stanford University, private communication, January 1982.
Helgeson Nuclear Services, private communication, February 1982.
Op. cit., Jack Faucett Associates, July 12, 1983, pp. 39-47.
36
-------
(2) an increase in the number of personnel in jobs with exposures in excess of
1.5 rem/yr. to reduce individual exposures, at the expense of an increase
in collection exposure.
The first option entails the development of an extremely active health physics program
that would not only reduce the likelihood of exposures in excess of 1.5 rem but would
satisfy every intent of the proposed guidelines. This is not, however an inexpensive
option. If the ideal program were applied to all hospitals with nuclear medicine
departments and we assume that the program cost by size of hospital would vary as
follows:
Table 9; Cost of Ideal Hospital Program
Estimated
Overall
Cost
(millions)
238
281
170
77
Hospital Size
(bed)
>400
200-400
100-200
<;100
Number
in
Category
700
1,100
1,000
900
Percent of
Ideal Program
Cost
100
75
50
25
766
This total could be thought of as the cost of all hospitals converting to an ideal
program. These costs could be reduced somewhat over time as the program becomes
established (10-15 years).
It is virtually impossible to identify the components of the ideal program cost
associated only with the reduction of the annual limit to 1.5 rem/year. The
administration of that program would argue that such reductions can only occur as part
of a total program. It is not believed that all hospitals and radiation protection
program administrators would be so zealous. Relaxing some standards, and concentrat-
ing the program on the annual limit could be expected to reduce the total cost of the
ideal program by about one half or $400 million.
The alternative program would spread the collective dose over a larger number of
workers. Approximately 2,200 employees are currently exposed to an excess of 1.5
rem/year . If the high exposure staff could be doubled and if half of the additional
1Op cit., NRC NUREG-0714 and JFA estimates for NRC Agreement State
Licensees.
37
-------
workers are doctors and the other half are technologists, the average full cost of the
additional worker (both physicists and technicians would be $59,500, and the costs to
the industry would total $130 million. In addition, there would be an increase in
collective exposure. (An estimate of the magnitude and cost of this increase in
collective exposure is considered to be beyond the scope of this study.) It is, however,
very uncertain whether the addition of staff as suggested would eliminate the exposures
in excess of 1.5 rem/year. If such activity were possible, it would provide a less costly
alternative to the suggested Range C costs.
3.3 SUMMARY OF COST OF COMPLIANCE
The 5.0 rem/year and accumulated lifetime exposure limits would have no impact on
the industry. The guidance on exposure to extremities and organs would also have no
impact.
The proposed guidances for Range C (1.5 - 5.0 rem/yr.) and Range B (0.5 - 1.5 rem/yr.)
would result in compliance costs, and these depend on the interpretation of the
guidance. Under a strict interpretation of the guidance on Range C, all hospitals with
nuclear medicine be required to respond. The annual costs to the industry would be
$350 million after an initial outlay of less than $10 million. The annual costs for a
liberal interpretation of the guidance, which encompasses only large hospitals (i.e. more
than 200 beds), would be $ 170 million with initial outlays of $2 million. The continuing
costs are primarily associated with additional health physics professional and technical
staff.
The guidance on Range B affects all hospitals with diagnostic radiology departments,
and therefore encompasses an estimated 7,000 hospitals in the industry. Since hospitals
responding to the guidance on Range C also satisfy Range B, only the 3,300 hospitals
without nuclear medicine departments would have to hire part-time consultants under
the strict interpretation presented above. The total annual costs are estimated to be
about $10 million. Under the liberal interpretation, small hospitals with nuclear
medicine departments also would have to respond to Range B, and the total annual costs
could reach $22 million. If Range C were not promulgated, total costs for Range B are
estimated to be about $24 million.
38
-------
The proposed training requirements are currently being satisfied, with the exception of
instruction in quantitative levels of risk. It is estimated that to satisfy this additional
intent, estimated costs are $1.5 million annually under the assumption that Range B and
C are promulgated. If they are not, estimated instructor cost would be $5.1 million
annually.
The industry currently operates under voluntary programs similar to or precisely the
same as the unborn protection provided by Alternative a. Alternative b specifies that
the women able to have children would voluntarily avoid jobs with exposure greater
than .2 rem/mo. Few hospital workers would be affected by this alternative. The
professionally rewarding nature of the potentially high exposure assignments (e.g.,
diagnostic radiography special procedures) would limit the workers requesting other
assignments and thus only negligible costs to the industry are expected.
The costs of the mandatory provisions of Alternative c depend on the acceptability of
under-the-apron badging. Such badging would eliminate assignments with recorded
exposures in excess of .2 rem/mo. in radiography and cardiology. A second badge for
each affected worker (assuming collar badge is still worn) would result in just less than
$1 million cost. If such badging were not permitted for compliance, women would be
barred from these activities and severe labor shortages would develop that could limit
available services.
The proposed guidelines on internal exposure would require routine measurement of
uptake of radioiodine during thyroid scans. The one-time costs for recalibrating the
existing scanning devises; providing instruction in self-monitoring to an average of two
technicians per hospital; and satisfying regulators that broad license holders would not
require a program beyond that currently in use are expected to cost industry about $2
million.
Under the alternate 1.5 rem whole-body limit, two options are possible. One is a
vigorous radiation protection program similar to that operated by one of the case study
firms. Such an industry-wide program would satisfy all portions of the guidance. Based
on the actual cost of such a program for the case study institution, a large medical
center, the costs of compliance for all other hospitals of any size was estimated to be
$400 million. The other option would be a doubling of the current staff to decrease
individual exposure to less than 1.5 rem/year. The availability of labor to meet such an
expansion is a serious limitation to this option.
39
-------
CHAPTER 4
COST OF COMPLIANCE; PRIVATE MEDICAL PRACTICE
4.1 INDUSTRY PROFILE: PRIVATE MEDICAL PRACTICE
Census data for 1977 indicate a total of 189,143 physician offices in the U.S. generating
receipts of $28.8 billion. In addition, there were 5,888 offices of osteopathic physicians
($776 million in receipts) and 14,343 chiropractor offices ($680 million in receipts) (U.S.
Department of Commerce, 1977 Census of Service Industries; Health Services).
Performance and Services
Although specific data on the types of services available at private practice locations
are not available, the range of services offered is estimated to be fairly large
considering a trend to group practices and the degree of medical specialization.
Estimates are also not available on the number of patients seen by private practitioners
on a yearly basis. Many physicians are also affiliated with community hospitals,
teaching hospitals, or medical centers which increases their potential caseload.
As such, estimates of the use of x-ray sources of radiation by private practitioners at
their locations is also difficult to estimate. In 1970, when the Bureau of Radiological
Health conducted its study on population exposure to X-rays, only 24 percent of
fluoroscopic procedures were found to be performed out of hospitals.1 Special proce-
dures such as mylograms, cystography, hysterosalpingograms, and arteriography were
found to be performed exclusively in hospitals in 1970. Although this situation may now
have changed, more recent data are not available. Best estimates would place radiation
exposures in private offices at 10 percent of those received in hospitals.
Somewhat better estimates are available concerning private practices in nuclear
medicine. According to Nuclear Regulatory Commission (NRC) data,2 there are
David Johnson, Bureau of Radiological Health, private communication, January 26,
1982.
Occupational Radiation Exposure, Twelfth Annual Report 1979, NUREG-0719.
40
-------
approximately 300 NRC medical licenses in private practice. If 40 percent of all
private practices are federally licensed, there may be an additional 450 private
practices (for a total of 750) licensed by NRC Agreement States. It is estimated that
there are no private medical offices in the U.S. with full-time radiation protection
professionals. However, possibly as high as 20 percent of all private practices in
nuclear medicine may retain consultants for licensing and radiation protection at a cost
of approximately $100 per month . Some training in radiation protection principles is
likely received by workers employed by private practices in nuclear medicine.
From an extrapolation of data compiled by the American College of Radiology, there
2
were approximately 17,000 radiologists in 1980. Fifty to sixty percent of these
radiologists are estimated to be in private practices. On average a practice will have
six radiologists on staff and operate 1.6 offices for a total of approximately 2,500
private radiology offices nation wide. As with private practices in nuclear medicine,
full-time radiation protection professionals are likely not employed by private diagnos-
tic radiology practices, however, unlike nuclear medicine practices, the use of
consultants or in-house training programs is rare to non-existent.
Of the non-radiologists, specialists in orthopedics, chiropractors, and some urologists,
gastroenterologists, and pediatricians also operate their own X-ray machines. Little
data is available on these practitioners, however, it is unlikely that workers in these
offices are uniformly instructed in the principles of radiation protection.
Employment
Of the 136,164 physician offices with payroll in 1977, total payments for wages and
benefits totaled $11.9 billion in 1977. Census data show that 137,465 associate
physicians ($8.2 billion in payroll), 6,101 nurse practitioners ($73 million in payroll), and
33,909 physician assistants ($277 million in payroll) were employed in private physician
offices. In addition, 66,428 RN's ($567 million) and 43,118 LPN's ($290 miUion) were
employed in physician offices. Sole practitioners and partners numbered 83,399 in 1977
(U.S. Department of Commerce, 1977 Census of Service Industries; Health Services).
1Hugh O'Neil, Health Physics Services, private communication, January 13, 1982.
2Robert Harrington, American College of Radiology, private communication, February 1,
1982.
41
-------
Data on the number of radiation workers in private physician offices are not available.
Estimates given in the preceeding section indicate that there are approximately 9,300
radiologists in private practice and perhaps as many as 750 - 1,500 physicians in the
private nuclear medicine practices.
Only 13 states license technologists for private practices. Of those licensed technolo-
gists, those who work in radiation therapy or diagnosis are registered radiologic
technologists and therefore have received formal training. In other states, workers may
or may not be formerly trained in radiologic technology (McGowan, private communica-
tion).
4.2 COST OF COMPLIANCE WITH GUIDANCE
Private Medical
Guidance #1 - Annual Whole-body Limit - 5.0 rem/yr.
N
Sound health physics practice suggests that there should be no impact, and case studies
and follow-up research confirms this. However, the 1975 EPA study indicated that as
many as 400 employees in this industry may have been exposed to doses greater than 5
rem. More recent data on exposure in nuclear medicine private practices reported to
o
NRC indicate that no exposure in excess of 3 rem occurred in 1978 or 1979. Improved
health physics practices and risk awareness by both employers and employees should
have reduced these high 1975 exposures at little or no cost. Thus, no impact from this
revision to the guidance is anticipated. However, anxiety was expressed over the
possibility that the 5 rem limit would constrain high-exposure frontier research.
Guidance #2 - Accumulated Lifetime Whole-body Exposure
There is no impact. Accumulated exposure for a technologist at one case study firm
with 15 years of experience was an order of magnitude below the 100 rem limit.
1Op. Cit., EPA, 1980, EPA 520/17-80-001.
2Op. Cit., NRC, NUREG-0714.
42
-------
Guidance #3 - Exposure to Extremities and Organs
There is no probable impact. There is no reason to believe that exposures to the eye
are greater than whole-body exposures, therefore monitoring at the collar should be
sufficient to measure exposures to both the whole body and the eye lens.
Doses to the hand have been as high as 2 rem/year. Most nuclear medicine private
practitioners now use unit dosages prepared out-of-house, which should result in hand
exposures 2 orders of magnitude below the 50 rem/yr limit.
Guidance #4 - Exposures in Range C (1.5-5.0 rem/yr.)
In general, private practitioners do not anticipate exposures above 1.5 rem/year. In the
private practice of a case study radiologist, the highest annual exposure was 1.0 rem.
In the case study practice of a nuclear physician, the average exposure was less. If
these exposures are representative of the industry, there should be no impact. Again,
the 1975 EPA study indicates that over 3,500 workers received between 1 and 5 rem in
1975. Utilizing the NRC exposure distribution for its private practice licensees, it is
estimated that approximately 700 of these exposures were in excess of 2 rem. It is
believed that good health physics practice can eliminate all of these exposures at little
or no cost. This position was supported by all knowledgeable industry persons contacted
in case studies or subsequent research. Any activity that could result in high risk of
unusual occupational exposure should be accomplished in a hospital setting.
Guidance #5 - Anticipated Exposures in Range B (0.5-1.5 rem/yr.)
Exposures in Range B can be anticipated in diagnostic radiology, and in the private
practice of nuclear medicine, exposures are sufficiently close to 0.5 rem to anticipate
exposures in this range. Therefore, a radiation protection professional would have to be
available to assure that exposures are justified and ALAR A.
If a nuclear physician or an experienced radiologist were considered equivalent to a
radiation protection professional, this guidance would have negligible impact. However,
if equivalence is not accepted, then the 2,500 radiology offices and 80% of the 750
private offices in nuclear medicine would have to employ part-time consultants at an
estimated $100/month. The total cost would be roughly $3.72 million.
JOp. Cit., NRC, NUREG-0714. 43
-------
Table 10: Cost Estimate Range B Requirements in Private Medicine
Expense
1. Part-time consultancy for
radiology practices
2. Part-time consultancy for
nuclear medicine practices
TOTAL
No.
of firms
2,500
600
Cost/firm
$1,200
$1,200
Annual
Cost
$ 3
$ .72
million
million
$3.72 million
Guidance #6 - Training
In most instances, training in radiation protection and levels of risk is received during
formal education. However, to keep up with new developments in technology and
procedure, an annual refresher course would be necessary. This instruction could be
given by the part-time consultant hired to monitor Range B exposures and the cost
would be included in the $1,200 per year fee. Therefore, the cost impact would be
limited to the hour of additional staff time during instruction. It is assumed that all
practices in radiology and nuclear medicine would be Range B establishments and thus
all radiation workers would require instruction. Utilizing the employment figure from
the 1975 EPA report for private medical practice overstates, to some degree, the
number of employees who would require this instruction since other practices included
(urology, pediatry, etc.) may include radiation workers who are not exposed in Range B.
It is believed that the error in the assumption is slight. No exposure data on the other
practices are available to refine the estimate. Given an average worker cost (salary
plus fringe plus overhead) of $25,000, an additional hour of instruction for the 138,000
would cost $1.66 million.
Table 11; Cost Estimate for Training Requirements in Private Medicine
Expense
Instruction
Guidance #7 - Exposure to the Unborn
No. of
workers
138,000
Cost/hour
$12
Costs
$1.66 million
Since private practitioners already conform to Alternative a, there would be no cost.
And since hospitals, and not private practitioners, generally perform services with
' 44
-------
potential exposures greater than 0.2 rem per month, there would also be no impact
under Alternatives b or c.
Guidance #8 - Internal Exposures
Internal exposures are anticipated in private practices of nuclear medicine, but not in
those of radiology. Therefore, the impact is limited to the roughly 750 nuclear
medicine practices. The radionuclide of principal interest is radioiodine. The thyroid
scanning device, which currently is used to determine arrival of the radioisotope at the
organ, can be recalibrated to detect and measure uptake to the administrating
technologist. Recalibration would require hiring a part-time consultant who would
instruct the technologist in self-monitoring during a one-hour seminar. The cost of the
consultant is estimated to be $1,200 and the average salary of a technologist is about
$15,000 ($25,000 including fringe and overhead). NRC data1 indicate that there are
approximately 7 monitored workers per practice and it is assumed that each would learn
the required procedures. Total cost for this guidance is estimated to be about $1
million.
Table 12: Cost Estimate for Internal Exposure Requirements in Private Medicine
No. of
Expense Units
1.
2.
Part-time consultant 750
Staff time (1 hr/worker) 5,250
(7 workers/practice)
TOTAL
Initial
Unit cost Cost
$l,250/week $ 937,500
$12/hour $ 63,000
$1,000,500
Guidance #9 - Alternative Annual Whole-Body Limit - 1.5 rem/year
The case studies and all contacts with knowledgeable industry professionals indicated
that no activity undertaken in private medical practice should result in routine exposure
in excess of 1.5 rem per year. While the 1975 EPA data indicate exposures in excess of
1.5 rem, it is believed that current exposures are lower than the 1975 data and that
planning for reducing what few exposures greater than 1.5 rem now occur (NRC data
indicate that about 0.5 percent of monitored workers in private practice were recorded
in excess of 1.5 rem) should lead to only limited and localized cost. An example might
JOp. Cit., NRC, NUREG-0714.
45
-------
be the replacement of an old x-ray machine with a new system that provides shielding
and columnated rays. To the extent that such replacement occurs because of a 1.5 rem
limit, the cost should be attributed to the guidance. However, these costs would have
to be reduced by any benefit accrued to the establishment from the use of the new
technology.
4.3 SUMMARY OF COST OF COMPLIANCE
The levels of exposure in this industry are relatively low. Therefore, there would be
compliance costs only for the proposed guidances on Range B, training, and internal
exposure. The annual costs of hiring part-time consultants to monitor Range B
exposures are estimated to be $4 million. To instruct workers on levels of risk would
cost an additional $2 million annually. And to recalibrate thyroid scanning devices for
measurement of internal exposure would involve an initial, one-time cost of $1 million.
Therefore, the annual costs of compliance would be approximately $6 million, and the
first year costs, would be $1 million.
46
-------
CHAPTER 5
COST OF COMPLIANCE; INDUSTRIAL RADIOGRAPHY
5.1 INDUSTRY PROFILE: INDUSTRIAL RADIOGRAPHY
Industrial radiography is one of several processes utilized to test the quality of a
product or service without destroying the object of the evaluation. One of the most
common uses of these techniques is the evaluation of a weld. Building superstructures,
ships and pipelines are areas where extensive welding must be evaluated without
destruction of the property. Nondestructive testing (NDT) can be carried out by one in-
house division. Engineering firms often offer NDT as part of a full service design,
construct and test system. There are also many small firms with 2 to 50 employees
that specialize in NDT. An NRC licensee or an NRC Agreement State Licensee is
required to purchase and utilize the radioactive source material used to expose x-ray
film.
There were 370 NRC licensees in 1979, mostly in the North, and roughly 500 NRC
Agreement State licensees geographically concentrated in Texas and Louisiana. The
larger firms usually maintain licenses with the NRC and one or more Agreement States.
Therefore, an estimated 700-800 industrial radiography establishments are currently in
operation.
Performance and Services
About half of all radiography performed is undertaken by in-house staff with the
balance performed by contractors. Employees may be full-time radiographers, or they
may be NDT technicians who work for testing firms where they perform various NDT
tasks (i.e., ultrasonics, visual inspections, etc.). Radiography is performed in a variety
of ways:
1. At the firm's facilities. Clients are urged to bring pieces to the firm's
facilities to reduce costs. In this mode, a radiographer may work alone
(others are available, should assistance be needed).
47
-------
2. On-site radiography at short distances from the firms' facilities. A
minimum of a two-man team, one of whom must be a licensed radiograph-
er, is generally sent. For these relatively close jobs, film processing may
be performed at the home facility, where an automatic film processor is
used.
3. On-site radiography at relatively long distances from the firms' facilities.
At these distances, a mobile darkroom and possibly an extra technician
are generally sent with the team.
4. Radiography with the client's equipment. Only the people are sent. The
client's sources and darkroom facilities are used.
Employment
The number of workers in this industry is not known precisely. In Louisiana, an NRC
Agreement State, there are approximately 1,100 radiographers and assistants or
approximately 15 per licensee. In 1979, there were approximately 13,000 individuals
monitored among the NRC licensees, and NRC has about 40% of the total number of
licensees. However, there are some firms licensed by both the NRC and NRC
Agreement States; licensees in NRC agreement States appear to be smaller firms with
about half as many employees on average as NRC licensees. Therefore, it is reasonable
to assume that there are about 20,000 radiographers and assistants in the U.S. (15 per
Agreement State licensee plus 35 per NRC licensee).
The number of field teams is also not precisely known. Several algorithms were
proposed to obtain the number of teams in the field at any one time. One which is easy
to apply to existing data and was suggested by a case study firm predicts that the
number of field teams is equivalent to the number of radiographers (plus assistants)
divided by five. Using this algorithm, we estimate that approximately 4,000 teams
routinely operate at one time.
Workers in Texas and Louisiana typically start out very young and approximately 5% of
radiographers plus assistants are female. There is a high rate of turnover and it is
unclear how many remain in the field for more than 20 years because of the physically
demanding nature of the work.
48
-------
Appendix A to Part 34 of the NRC Rules and Regulations is very specific on instruction
required in radiation protection principles. The Agreement States also conform to
these guidelines.
5.2 COST OF COMPLIANCE WITH GUIDANCE
Industrial Radiography
Guidance #1 - Annual Whole-body Limit - 5.0 rem/yr
There is estimated to be no impact on NRC licensees. A potential for exposures in
excess of the proposed annual limit exists at operating nuclear plants largely due to
background exposure. Nuclear power plant licensees carry the responsibility for
conforming to the regulation and thus exposures in excess of the proposed limits, if any,
are included in the commercial nuclear power data base.
There may be significant impact to NRC Agreement State Licensees in the Gulf Coast
Region, which includes approximately 250 firms in the States of Texas and Louisiana.
Each of these firms would be expected to have at least one individual exposed to
greater than 5 rem/yr. In Louisiana, there were 60 overexposures (greater than 3
rem/qtr.) in 1980 and out of 70 licensees in the State.
Cumulative exposures in industrial radiography are directly proportional to the number
of radiographs obtained. Radiographers and radiographer's assistants are paid by the
hour, so that their annual income is also proportional to the number of radiographs
obtained. Therefore, the most direct affect of a curtailment in allowable annual dose is
lower annual earnings for radiographers in the Gulf Coast Region. If additional
radiographers were available to take up the workload, the result would be more
employment, lower annual income per radiographer, and probably higher collective
dose, but no apparent cost to the industry. However, the availability of additional
radiographers is questionable and could lead to a less skilled workforce that could result
in fewer operators per unit time. While no precise measure of the productivity change
that might result is available, industry experts did not indicate that this was a major
concern, since tasks are very repetitive and satisfactory skill levels can usually be
reached.
49
-------
The evidence of high radiographer utilization appears to be very localized, and may in
fact be diminishing as the reduced level of activity in oil and gas exploration will
require fewer hours of radiography.
Guidance #2 - Accumulated Lifetime Exposure - 100 rem
There is no quantifiable impact, although the guidance could limit the career length of
a young person entering the field to 25 - 30 years. This career span, however, should be
enough. Very few people are likely to stay active in industrial radiography beyond 45 -
50 years of age since it is physically demanding work. However, if an individual rises in
the management chain, it may be necessary for him to receive exposure during the
retrieval of a stuck source or some other comparable incident. This could have an
impact on a very small group of individuals, and potentially limit the flexibility of some
firms in the future. The cost impact, however, is not quantifiable.
Guidance #3 - Exposure to Extremities and Organs
The impact is negligible. Eye exposure is commensurate with whole-body exposure, and
therefore is below the limit. Hand exposures are also well within the proposed 5.0
rem/year limit.
Guidance #4 - Anticipated Exposures in Range C (1.5 -5.0 rem/yr)
According to the NRC data base, only 8% of the total number of industrial radiography
personnel monitored receive exposures in excess of 1 rem/yr. Moreover, approximately
one half of these exposures are likely to be less than 1.5 rem. These percentages,
however, refer to the whole industry. Firms differ greatly in size, workload, and type
of industrial radiography. From a conservative point of view, then, the larger and more
active firms are expected to fall into Range C.
The proportion of firms in this category is assumed to be 25%. This percentage does
not include industrial radiographers working at power plants, since the utility in these
cases would have responsibility for compliance. While this number is only an estimate,
it appears reasonable and consistent with all information collected in the case studies.
J0p. Cit., NRC, NUREG-0714.
50
-------
There are approximately 750 firms and 20,000 radiographers in the industry. Strict
interpretation of the guidance would require supervision of each field team by a health
physicist. Using an algorithm derived from the two case studies which predicts one
field team for every group of five radiographers plus assistants, it is estimated that
there currently are 4,000 field teams in the industry. Assuming that only 25% of all
firms fall into Range C, then 1,000 health physicists would be required.
This is not considered feasible for two reasons: first, excepting the largest establish-
ments, supervision of each field team would likely bankrupt most firms. Second,
assuming that the number of health physicists in the country is currently about 8,000 ,
and furthermore, that they already are employed, it is unlikely that 1,000 health
physicists are or would be available to this industry.
An alternative interpretation of the guidance would require each firm falling in Range
C to have a full-time health physicist on staff, with monitoring responsibilities
delegated to a radiographer on each field team. These radiographers would be qualified
as radiologic technicians in a two-week seminar given by the full-time health physicists.
It is also assumed that the regulations would provide enough lead time to allow training
a quarter of the staff per year.
Under this interpretation, 187 firms would have to hire full-time health physicists and
at least one radiographer per team would have to be qualified as radiologic technician.
Assuming that one radiographer and one-half back up per team and an attrition rate of
25% for radiographers, the training program would be given to approximately 375
workers annually. Given a salary of $40,000 (full cost of $68,000) for a health physicist
and an average salary of $25,000 ($42,500 full cost) for senior radiographers (team
leaders), the annual costs would be approximately $13 million. This total takes into
account the avoided expense of approximately $350 per month for the 150 part-time
consultants currently employed by the most active firms in the industry.
^Robert Alexander, U.S. Nuclear Regulatory Commission, private communication, Janu-
ary 13, 1982.
51
-------
Table 13; Cost Estimate for Range C Requirements in Industrial Radiography
Expense
Full-time health physicist (+)
Qualification of radi-
ographers (+)
Part-time consultants (-)
TOTAL
No. of
workers
187
375
150
Cost /firm
$68,000
1,600
4,200
Annual
Cost
$12,720,000
600,000
630,000
$12,690,000
Guidance #5 - Anticipated Exposures in Range B (0.5 - 1.5 rem/yr)
All firms can anticipate Range B exposures, and therefore are required to monitor
radiation workers and retain professional radiation protection supervision to assure
exposures are justified and ALARA. The industry satisfies the former guidelines under
NRC and NRC Agreement State regulations. Each firm also has a Radiation Safety
Officer who assures exposures are justified and ALARA, but he is seldom a radiation
protection professional. Therefore, a consultant would have to be retained by firms
that do not anticipate Range C exposures. Assuming that approximately 563 firms fall
into this category, and a cost of $350 per month for HP consultant services, the annual
costs would be $2.36 million.
Table 14; Cost Estimate for Range B Requirements in Industrial Radiography
No. of Cost/ Annual
Expense Firms Consultant Cost
Radiation protection 563 $4,200 $2,360,000
Guidance #6 - Training
Training in radiation protection principles is uniform because of NRC requirements.
Although the biological effects of high levels of exposure are included, the long-term
stochastic effects are not. To include this would require an additional 2 hours of
instruction for each worker beyond the current 16 hours.
Assuming that the full-time or part-time health physicist hired in response to the
requirements for Range C and Range B would be providing instruction to workers as a
part of his contract, the impact of the training requirement would be limited to the
52
-------
cost of staff time during instruction. The annual costs would be $800,000 for the 20,000
potentially exposed workers. The average salary of all workers is approximately
$25,000 ($42,500 full cost).
Table 15; Cost Estimate for Training Requirements in Industrial Radiography
No. of Cost/ Annual
Expense Employees Employee Cost
Supplemental training (2 hrs) 20,000 $41.00 $817,307
Guidance #7 - Exposure to Unborn
There would be no impact. Firms under NRC and Agreement State regulation are
currently operating within the guidance of Alternative a. Under Alternative b, there
should be little difficulty in shifting pregnant workers to low exposure jobs. Under
Alternative c, females would be barred from field work, which would curtail their
freedom of choice. Their number at this time, however, is too small to have an impact
on the industry.
Guidance #8 - Internal Exposures
There is no impact since all sources are sealed.
Guidance #9 - Alternative Annual Whole-body Limit - 1.5 rem/yr
Both case study firms felt that the lower whole-body limit would have a large impact on
their workload and growth. While this may constitute a cost to an individual firm, it is
not necessarily an industry cost if other firms were to pick up the slack.
However, the 1.5 rem/year RPG could limit the productivity of workers in high
exposure jobs, which would be a cost to the industry. One way to estimate this cost is
to estimate the number of additional employees necessary to perform the same amount
of work and decrease individual exposure to less than 1.5 rem/year. We noted above
that 8% of the workforce have annual exposures in excess of 1.0 rem. Taking a
conservative estimate that one-third of these receive less than 1.5 rem/year, then
53
-------
approximately 5.4% of 20,000 workers receive annual exposures greater than the
alternative annual limit. If this portion of the workforce is expanded in size by 50% to
spread exposures over more workers, then 540 additional workers would be required, and
the annual costs would be $23 million.
Table 16; Cost Estimate for Alternative Whole Body Limit for Industrial Radiography
No. of Cost/ Annual
Expense Workers Worker Cost
Additional workers hired to 540 $42,500 $22,950,000
reduce individual exposure.
5.3 SUMMARY OF COST OF COMPLIANCE
The impact on industrial radiography is limited to the guidances on Range C, Range B,
training, and the alternative 1.5 rem/year whole-body limit.
It is estimated that 25% of the approximately 750 firms in the industry would have to
hire full-time health physicists to comply with the Range C guidance. The remaining
firms would be required to hire part-time consultants to satisfy the requirements of
Range B. The annual costs of these requirements are estimated to be $15 million.
Training in radiation protection principles is currently provided. To additionally
instruct workers on levels of risk would cost approximately $800,000 annually for the
20,000 workers potentially exposed to radiation.
The impact of the alternate 1.5 rem/year limit would depend on the response of the
industry. If other firms in the industry take up the workload of active firms whose
growth would be limited by the 1.5 rem/limit, then there would be no cost to the
industry. However, if the active firms hire additional workers to lower individual
exposures, productivity in these firms would decrease. This would produce a larger, less
productive workforce at an annual cost of approximately $23 million.
This would, however, be a substantial economic impact, rearranging market structure,
corporate performance and affecting job security.
54
-------
In summary, annual compliance costs in this industry could be $16 million if the 5.0
rem/year RPG were implemented. If the alternative 1.5 rem/year RPG was enforced,
then the annual costs to the industry could total $23 million.
55
-------
CHAPTER 6
COST OF COMPLIANCE: MANUFACTURE AND DISTRIBUTION OF LARGE SOURCES
6.1 INDUSTRY PROFILE: LARGE SOURCES
Gross sales in this industry were $25 million in 1981. There are five competitors which
supply large radioactive sources to various industries. Several of these firms also
manufacture and distribute small sources. Information relating to firms which are
active in both markets was not available. The case study firm is principally involved in
the production of cobalt sources, and less so in other segments of large source
production. Therefore, it is not representative of the industry. Nevertheless, lacking
sufficient information on its competitors, we assumed that the compliance costs for the
industry were a factor of five greater than the costs for the case study firm. This
procedure will have to be refined in the next part of the study. The case study firm has
80 employees, and all are monitored. Assuming that employment is roughly proportion-
al to market share, then approximately 400 workers are potentially exposed in this
industry.
6.2 COST OF COMPLIANCE WITH GUIDANCE
Guidance #1 Annual Whole-body Limit - 5.0 rem/year
There would be no impact from this guidance. The case study firm voiced concern
about the intangible costs related to public perceptions in the event of an accident.
Thus restricting exposure to a low limit increases a risk of a legal overexposure and
increased public scrutiny.
Guidance #2 Accumulated Lifetime Whole-body Limit - 100 rem
The firm felt that compliance with the 100 rem limit could be accomplished at minimal
costs. Some concern, however, was expressed about the potential for career shortening,
but its impact is not quantifiable.
56
-------
Guidance #3 Exposure to Extremities and Organs
This guidance would have no cost impact at the case study firm, although some anxiety
was expressed about being close to the limits on hand and eye exposures. Assuming that
the guidelines can be satisfied with tighter monitoring, and that this applies to the
other firms, then there would be no costs for the industry.
Guidance #4 - Anticipated Exposures in Range C (1.5 - 5.0 rem/year)
Exposures in excess of 1.5 rem/yr may be anticipated for personnel involved in three
tasks. The first is source installation, which involves teams of three workers headed by
an installer. In the course of a typical installation, an exposure of 50-75 mrem is
expected.
Three options for compliance for installation of sources have been considered. The first
involves qualifying installers as radiologic technicians in a two-week intensive course.
The cost would include instructor time ($l,250/week) and staff time. In addition, it is
assumed that the salary of the installers would likely be increased to $50,000 from
$40,000 as compensation for additional responsibilities. Based on data provided by the
case study firm, which controlled about 20% of this market, it is assumed that there are
ten teams currently operating nationwide in five companies. The overhead and fringe
benefit rate of the case study firm of 70% of labor cost will be assumed for all firms.
While there is a high turnover rate for helpers, installers remain in their position for a
reasonably long period of time. We will assume that one new installer per year must be
qualified after the initial upgrading of the current workforce.
Table 17: Cost Estimate of Qualifying Installers as
Health Physics Technicians
Initial
Instructor for 2 weeks $12,500
(5 companies initial year,
1 annually)
Staff time (2 installers 32,700 3,270
initially, 1 annually)
Increased salary 100,000 100,000
(no additional overhead)
Total $142,200 $105,770
57
-------
The second option entails an increase in the number of teams to reduce individual
ange C. To be under Rang
team is estimated to be halved to 20 installations per year. Therefore, ten additional
teams would be required.
This option could be more expensive than direct supervision by a health physicist at
each installation. However, two other factors should be taken into account; first, the
full cost of a health physicist who travels extensively could be significantly higher than
the standard
>ary
the salaries of installers would be expected to decrease significantly if workloads were
reduced by a factor of 2. Assuming that the revised salaries of installers and helpers
are $10,000 less than their current level and an overhead and fringe rate of 70%, the
anni
costs to the industry of additional staff would be $680,000.
Table 18: Cost Estimate of Additional Installation Teams
No. of
Workers
Salary
Full Cost
(1.7 overhead multiplier)
A. Additional workers
(1) installers
(2) helpers
B. Avoided expense (-)
10
20
30
$30,000
$20,000
$10,000
$510,000
$680,000
(510,000)
Total
$680,000
Under the third option 10 to 15 full-time health physicists would be necessary to
directly supervise source installations. Assuming their salary is increased to $50,000 as
i
compensation for traveling, the annual costs would range from $850,000 - $1,275,000.
These costs are greater than option 2 and since
are accumulated uniformly
during installation, the direct full-time supervision of a health physicist may not be
warranted. The first option satisfies the requirements at least cost and would be
selected.
58
-------
The two other areas where Range C exposures are anticipated are source fabrication
and waste handling. These operations may involve significant exposures. Therefore,
the supervision of a radiation protection professional would likely be required.
Although no health physicist is currently on staff of the case study firm, at least three
members of the engineering staff, and possible as many as five, could potentially pass
the health physics certification examination with several months of study. This
approach would be a less costly approach than hiring two full-time health physicists.
Moreover, experience has demonstrated that a newly-hired health physicist would
contribute little until having spent roughly two years at the plant to become
sufficiently familiar with its operation. Therefore, it is expected that the case study
firm and the industry as a whole would prefer training its current staff.
Assuming that training would take three months for each engineer and that it would be
staggered throughout the year because engineers are critical to the operation of the
firm, then a full-time instructor would be necessary. The annual salary of an instructor
is $25,000.
Table 19; Cost Estimate of Qualifying Health Physicists In-House
At Large Source Manufacture
Salary Full Costs
(1.7 overhead factor)
1. Instructor (5 firms) $25,000 $212,500
2. Staff time
(45 man-months) $40,000 $255,000
Total $467,500
Assuming the cost from Option 1 for source installation and the estimated cost for
health physics supervision in waste handling and source fabrication, the total cost of the
Range C guidance would be an initial cost of $145,200 and an annual cost of $573,270.
Guidance #5 - Anticipated Exposure in Range B (0.5-1.5 rem/yr)
All personnel potentially exposed in excess of 0.5 rem/yr. are currently monitored for
also
does not perform hands-on monitoring or assure that exposures are ALAR A. These
59
-------
functions could be performed by the group of health physicists who are hired or trained
in-house to satisfy the guidance on Range C. Therefore, the costs of monitoring would
be subsumed under Range C.
Guidance #6 - Training
Each new employee is given a briefing of approximately two hours duration on radiation
protection principles. This briefing does not include quantitative guidance on levels of
risk. Nor does the NRC Regulatory Guide 8.29 "Instruction Concerning Risks from
Occupational Radiation Exposure", which has been recently distributed to all radiation
workers. Therefore, an additional hour of instruction to all radiation workers would be
necessary.
Since a full-time instructor would be hired to qualify three engineers as health
physicists under Range C, the impact of a training program would be limited to the
costs of staff time taken up during instruction. At an average salary of $20,000 and an
overhead rate of 1.7, an hour of additional instruction for the 400 radiation workers
would cost for the industry approximately $6,400.
Table 20; Cost Estimate for Training Requirements in the Manufacture
and Distribution of Large Sources
No. of Annual
Expense workers Cost/hr Costs
Staff time (1 hr/worker) 400 $16 $6,400
Guidance #7 - Exposure to Unborn
There would be no impact because females are not employed for tasks where exposures
may be received in excess of 0.5 rem/9-month period, or in excess of 0.2 rem/month.
Guidance #8 - Internal Exposures
Five individuals at the case study firm are potentially exposed from inhalation of
airborne activity, and there is no existing internal dosimetry program. Assuming that
the other firms in the industry also lack internal dosimetry, then approximately 25
individuals would have to be monitored quarterly for internal exposure. The estimated
60
-------
cost per count (for 1 to 10 individuals) is $169. Therefore, quarterly counts for 25
workers would cost approximately $17,000 annually.
Table 21; Cost Estimate for Internal Exposure Requirements in the Manufacture
and Distribution of Large Sources
No. of Cost/
Expense workers count Cost
Quarterly counts 25 $169 $ 17,000/yr.
Guidance #9 - Alternative Annual Whole-Body Limit - 1.5 rem/year
For the case study firm 34 man-rem of collective exposure were accumulated in 1981
above the exposure level of 1 rem/year, which is the assumed administrative limit for
an annual limit of 1.5 rem. In order to reduce this man-rem to below the limit
n
(administrative limit times number of workers with productivity loss) an additional 25
workers would have to be hired and a 12% increase in total man-rem would be expected.
Assuming the industry would require 125 workers at a full cost of $34,000 per year,
total cost would be $4,250,000 annually. As no exposure above 1.5 rem would now be
anticipated, costs for Range C would be eliminated. Thus the net cost of the 1.5 rem
whole-body limit would be about $3,750,000 annually with an additional savings of about
$150,000 in the initial year.
Helgeson Nuclear Services, private communication, February 22, 1982.
2See Chapter 11 of this report for detailed description of methodology (page 85).
61
-------
6.3 SUMMARY OF COST OF COMPLIANCE
The compliances costs of the case study firm have been generalized to the five firms in
the industry. These costs relate to the requirements on Range C, instruction on levels
of risk, internal exposure, and the alternative annual whole-body limit.
Several options were considered for minimizing the cost of Range C compliance. It is
believed that training current staff to qualify as health physics professionals who could
monitor the high exposure activity would result in the lowest compliance cost of
$150,000 in initial cost and $600,000 in annual costs.
Instruction on levels of risk for the industry's 400 potentially exposed workers would
cost approximately $6,000 annually. An internal dosimetry program for the industry's
25 workers with potential internal exposure would cost approximately $17,000 per year.
Finally, to reduce individual exposure to less than 1.5 rem/year would require an
expansion of 125 in the number of workers in the industry and an annual cost of about
$4 million.
62
-------
CHAPTER 7
COST OF COMPLIANCE; MANUFACTURE AND DISTRIBUTION OF SMALL SOURCES
7.1 INDUSTRY PROFILE: SMALL SOURCES
The principal uses of small radioisotopes are research and clinical diagnostic products
for the sciences. In the research products line, chemicals are labeled with C-14, H-3,
S-35, P-32 (all beta emitters), 1-131 and 1-125 (gamma emitters). Additionally, small
calibration sources (less than 100 mCi) are manufactured from as many as 100 isotopes.
The predominant radioisotopes in the clinical diagnostics' line are Mo-99 (for generation
of Tc-99m), Tl-201, Ga-67, and Xe-133. Isotopes are made by nuclear transmutation
using cyclotrons, reactors, and accelerators.
Most of the higher exposures are experienced in four activities. These are production
of Mo-99 generators, production and maintenance on accelerators, waste management,
and transportation of radioisotopes. A transportation industry, mostly truck, services
the industry. There are an estimated one million shipments of Mo-99 generators
annually. An estimated 200 - 500 individuals who transport radioisotopes may be
receiving non-negligible exposures.
The industry does not manufacture large, multi-curie sources for purposes of irradiation
or radiography (i.e., Co-60, Ir-192, etc.). These are all reactor-produced sources.
Another segment of the radioisotope manufacturing industry makes tritium signs, smoke
detector sources, etc. This industry incorporates a number of small firms, has few
employees and is thus neglected in this case study.
Gross industry sales are approximately $175 million. The industry is comprised of five
major firms, one of which serves 50 percent of the market. The number of employees
and potentially exposed workers are known, only for the largest firm, which has 1,700
total employees and 1,300 workers with potential exposure. Assuming that employment
is proportional to market share, then the number of radiation workers in the industry is
approximately 2,600.
63
-------
7.2 COST OF COMPLIANCE WITH GUIDANCE
The unit cost assumptions utilized in this section are:
full-time health physicist = $68,000 ($40,000 salary x 1.7 -
(annual) fringe + overhead )
health physics technician = $37,400 ($22,000 salary x 1.7 -
(annual) fringe + overhead )
trucker (annual) = $25,000
truck (initial) = $30,000
truck (operating) = $64,000 (90,000 miles/yr)
radiation worker (annual) = $34,000
Guidance #1 - Annual Whole-body Limit - 5.0 rem/year
The case study facility currently operates under a self-imposed limit of 5.0 rem.
However, to have an adequate safety margin of 20% under a regulatory limit of 5 rem,
the firm would operate with an administrative limit of 4 rem/year. There are two
possible strategies for achieving the 4.0 rem/year limit.
(a) hire additional radiation protection staff to tighten radiation protection
procedures and increase monitoring;
(b) hire additional workers to reduce individual exposure to less than the
annual 5 rem limit
If the firm chose to expand its radiation protection staff, then the costs would be
subsumed by the costs of hiring full-time health physicists in response to the guidance
on Range C.
If the firm expanded technical staff to reduce individual exposure, approximately eight
additional workers are estimated to be necessary. This is an increase of 50% in the 16
workers estimated to have received annual exposures in excess of 4.0 rem. Assuming a
full cost per worker of $34,000, the respective costs to the firm and the industry would
be $272,000 and $544,000 respectively. In addition, there is estimated to be an increase
in collective exposure of up to 10%.
64
-------
Guidance #2 - Accumulated Lifetime Exposure - 100 rem
There is some potential for career-shortening. This would happen only in rare cases for
technicians who start out at an early age and continue with the firm for more than 20 -
25 years in high exposure jobs. The quantification of costs to the industry is extremely
difficult, depending on the availability of technicians.
Guidance #3 - Exposure to Extremities and Organs
There would be no problem in satisfying the requirements on hand exposure. The case
study firm did express anxiety about eye exposure. However, it was believed that
tighter surveillance and tightening of procedures would remove the potential for eye
exposure above the proposed limit.
Guidance #4 - Anticipated Exposures in Range C (1.5 to 5 rem/yr)
Approximately 10% of the monitored employees at the case study firm may have been
in Range C in 1980 and 1981. Five activities would contain essentially all of these
personnel. They are:
(a) Accelerator maintenance Supervision of the four cyclotrons, which
operate on 24-hour shifts, would require six individuals. One technician is
currently responsible for monitoring on a spot-check basis.
(b) Production of Mo-99 generators Exposures are accumulated relatively
uniformly. One supervisor could cover this room. A technician currently
monitors its operations.
(c) Waste handling Exposures as high as 100 mrem can be received during a
single task. The area is currently monitored by a technician.
(d) Hot processing Exposures of 100 mrem can be received during a single
task. One supervisor would be required.
(e) Delivery of Mo-99 generators The firm currently employs 20 truck
drivers who load and unload sources. At any one time, as many as 300
shipments may be in progress.
65
-------
Cost estimates are given for a strict and a liberal reading of the proposed guidance.
For the strict interpretation, a radiation protection professional must be present at
each high exposure activity. Under a liberal interpretation, a health physicist would
only be required to supervise activities where a significant fraction of the annual limit
exposure could be received during a single task, and not for activities where exposure
are uniformly accumulated during the year. In the latter case, a radiologic technician
would be adequate as long as a professional supervisor was immediately available. This
applies to the production of Mo-99 generators, although not for hot processing and
waste handling, where high exposures can be received during a single task. For
maintenance of the four cyclotrons, a health physicist could supervise a team of health
physics technicians. Since maintenance is a 24-hour activity, two professionals would
be required.
The fifth high exposure activity is delivery of Mo-99 generators. It would be
impractical to assign a health physics personnel to each truck. Exposures are uniformly
accumulated and the cost would be prohibitive. An alternative to supervision is a
reduction in individual exposure to a level where Range C exposures would not be
anticipated. This could be accomplished by increasing the firm's trucking staff by 50%
and its fleet by five trucks.
The following cost tabulation applies to the case study firm, and is presented for a
strict and liberal interpretation of the guidance.
Table 22: Number and Type of Personnel Required in the Small Source
Case Study Firm
Accelerator
Mo-99
Waste
Hot processing
Trucking
Strict Interpretation
6 health physicists
1 health physicist
1 health physicist
1 health physicist
10 truckers
5 trucks
Liberal Interpretation
2 health physicists
5 radiologic technicians
1 radiologic technician
1 health physicist
1 health physicist
10 truckers
5 trucks
TOTAL
Less (-)
9 health physicists
10 truckers
5 trucks
4 health physicists
6 radiologic technicians
10 truckers
5 trucks
3 radiologic technicians 3 radiologic technicians
66
-------
Table 23: Cost Estimate for the Small Source Case Study Firm
Expense
Health physicists
Radiologic technician
Trucking (operating)
Trucks
Minus: Current workers
Annual
Initial
Annual (Industry)
Initial (Industry)
Strict
$ 612,000
$ 570,000
$ 150,000
$ 102,000
$1,080,000
$ 150,000
$2,160,000
$ 300,000
Liberal
$
$
$
$
$
$
$
$1
$
272,000
204,000
570,000
150,000
102,000
944,000
150,000
,888,000
300,000
Guidance #5 - Anticipated Exposure in Range B (0.5 - 1.5 rem/yr)
Both the monitoring and supervision requirements of this guideline are currently being
satisfied by the radiation safety officer. Therefore, there would be no impact.
Guidance #6 - Training
This is currently carried out, including instruction on levels of risk.
Guidance #7 - Exposure to the Unborn
No industry costs are expected. If women were discharged under Alternatives b and c,
the impact would be the negligible cost of rehiring and training male workers. Since
only 10% -20% of technologists are women, their replacement with males should
present no difficulty. This, however, could conflict with the EEO objectives of the
firm.
Guidance #8 - Internal Exposures
No additional dosimetry would be required. However, the mechanics of compliance
would require a computerized accounting system. This system could be programmed
with approximately four person-months of effort. Assuming a yearly salary of $30,000
for a programmer, the initial, one-time industry costs would be $34,000.
67
-------
Table 24: Cost Estimate for Internal Exposure Requirements
for Small Source Manufacture
Expense
Programmer
No. of
firms
2
No. of
months/
firm
4
Programmer
cost /year
$51,000
Initial
Cost
$34,000
Guidance #9 - Alternative Annual Whole-body Limit - 1.5 rem/yr
Two drastic alternatives exist to reduce exposures to less than 1.5 rem/year: either the
addition of expensive equipment or an expansion in the workforce. Since an estimate of
the total costs of equipment was not available, only an estimate for the second option is
presented. Utilizing data from the case study firm, it is estimated that approximately
50 additional workers at a salary of $20,000 per worker would be required. The annual
cost of this option would be $1.7 million for the case study firm and approximately $3.4
million for the industry. However, the reduction in individual dose would be
accompanied by an increase in collective dose of 10% - 20%.
Table 25; Cost Estimate for the Alternate Whole-body Limit
for Small Source Manufacture
No. of
Expense firms
No. of
workers/
firm
Full
worker
cost/yr
Annual
cost
Additional workers 2 50 $34,000 $3.4 million
68
-------
7.3 SUMMARY OF COST OF COMPLIANCE
The principal costs of compliance involve an increase in personnel in response to the 5
and 1.5 rem limits on annual whole-body exposure, and to the guidance on Range C. In
addition, a computerized accounting system would be necessary to monitor internal
exposures.
The impact of the 5.0 rem/year RPG will depend on whether the industry decides to
increase radiation protection activities, or lower individual exposure by expanding the
portion of the workforce receiving exposures in excess of 5 rem/year (and consequently
increasing collective dose). The impact of the first option has not been estimated since
it is subsumed in the response to the guidance on Range C. The total costs of the
second option, expansion of the affected workforce by 50%, is estimated to be about
$550,000.
The guidance on Range C would require supervisory personnel in four activities where
annual exposures are anticipated in excess of 1.5 rem/year, and an expansion in the
number of drivers and trucks to reduce individual exposure in transport of sources to
less than 1.5 rem/year. The compliance costs of these requirements would depend on
the interpretation of the guidance. A strict interpretation would require that all super-
visory personnel be radiation protection professionals, whereas a liberal interpretation
would allow delegation of supervisory responsibilities to radiologic technicians for
activities where exposures are accumulated uniformly. The respective annual costs of
the two interpretations are about $2 million with about $250,000 higher cost for the
strict interpretation. There would also be initial costs of $300,000 for 10 additional
trucks under both interpretations.
The third impact of the guidelines relates to internal exposure. The mechanics of
compliance would require a computerized accounting system. The initial, one-time
costs to the industry for programming are estimated to be $34,000.
The final impact relates to the alternative 1.5 rem/yr. whole-body limit. Two
alternatives exist to satisfy this requirement: replace existing hardware or an
expansion in the workforce. A cost estimate of the first option is not available. The
second option would cost the industry $3 million per year.
69
-------
CHAPTER 8
COST OF COMPLIANCE; DENTAL PRACTICE
8.1 INDUSTRY PROFILE: DENTAL PRACTICE
According to data from the Bureau of Census, there were 99,289 dental offices in the
U.S. in 1977 generating $10 billion in receipts. Only 82,739 offices report a payroll and
of this total, 59,811 are sole practitioners. Partnerships numbered 2,675 in 1977 and an
additional 20,253 were classified as professional service organizations (U.S. Department
of Commerce, 1977 Census of Service Industries Health Services).
The membership directory of the American Dental Association (ADA) shows 117,000
dentists practicing in 1979 in the U.S. (ADA, 1982). Out of 6,416 dentists responding to
an ADA survey, the ADA estimates that 87.9 percent of the total dentist population are
general practitioners while 12.1 percent can be classified as specialists. Approximately
73 percent of all dentists work as solo practitioners, according to the ADA, i.e., they
work without other dentists in the same practice. Seventy-three percent of all dentists
also are sole proprietors of their practices. Most of these (91.9%) are general
practitioners while only 8.1 percent are specialists. Only 4 percent of all dentists work
in a partnership arrangement (85.1% are general practitioners) with 61.8 percent
working with one other dentist, 24.1 percent with two, and 14.0 percent, working with
four or more dentists (ADA, 1982). Some 25 percent of all dentists are shareholders in
an incorporated practice. An estimated 1.7 percent of all dentists are female.
Performance and Services
According to the ADA survey, 32 percent of all single dental practices treat between 40
and 59 patients per week. Some 25 percent of the "solo dentists" see between 60 and 79
patients per week. The median number of patients per week for all solo dentists is 59.5
(ADA, 1982). Specialists tend to see more patients per week (79.7) compared to general
practitioners (55.3) and the average number of patients seen per week increases as the
number of dentists in a single practice increases.
70
-------
ADA survey respondents reported that an average of 43.1 hours per week are spent on
activities associated with the primary practice. An average of 33 hours is spent
treating patients and 2.5 hours on laboratory procedures.
Dental services offered are quite specialized including periodontistry (1.5% of all
specialists), orthodontics (5.1%), dental surgery (2.8%), endodontistry (0.8%), pedodon-
tistry (1.5%), prosthodontistry (0.4%), in addition to the general dentistry practitioners.
The use of x-rays is common to all these services. X-rays administered to patients
include the Panorex or "full view" exposure of the mouth in addition to the limited view
exposures of some portion of the mouth. Full view exposures are generally taken of the
patient's mouth only once at the start of treatment as a new client. Limited exposure
x-rays may be taken several times over the course of treatment, but, in recent years it
has been recommended that the number of these exposures be limited and proper
protection equipment and practices employed.
In recent years with the onset of advertising by dentists, the trend has been towards
multi-chair, full service dental operations so that with increased client volume it is
possible to achieve economies of scale. An average weekday patient load at such a
facility can number from 150 - 200 patients of which 20 - 30 may be first-visit patients.
ADA estimates show that 10 percent of all practices are multi-chair (more than 3
dentists) facilities.
In addition, dental services are offered in hospitals, both federal and non-federal.
American Hospital Association survey results show 3,695 of all registered hospitals (59
percent) providing dental services, including 2,986 community hospitals (56 percent)
(Hospital Statistics, 1981).
Employment
Census data for 1977 show that 27,666 associate dentists were employed in dentist
offices in 1977 for a total payroll of $1.4 billion. Dental hygienists, technicians, and
assistants numbered 44,851, 8,130, and 131,329, respectively. A 1975 occupational
exposure survey estimated a total 265,700 dental workers in the U.S. of which 15 - 20
percent were potentially exposed to radiation (EPA, 1980). A typical multi-chair
facility may employ 30 - 35 individuals of which one-half to two-thirds could be
identified as radiation workers. These include, for the most part, the dentists
71
-------
themselves and their dental technicians. The ADA survey shows that 5.5 percent of all
solo dentists employ no auxiliary personnel, 60.5 percent employ 1 to 3 persons, while
34 percent employ 4 or more auxiliary personnel. Somewhat more than half of all
dentists (54.9%) employ one chairside assistant. ADA survey results show that
hygienists are paid, on average, a higher weekly salary ($270) than other auxiliary
personnel. Over 38 percent of all dentists employ a dental hygienist (ADA, 1982). Full-
time hygientists reportedly treat an average of 41.5 patients per week.
8.2 COST OF COMPLIANCE WITH GUIDANCE
The dental industry employs the largest workforce of radiation workers. There is,
however, no reason for these workers to be exposed to any substantial radiation doses.
Health physics practice for this industry has improved steadily over the past decade.
Practices even the most active, that follow basic safety procedures should have no
measurable exposure and should experience no costs as a result of the guideline. Some
practices may require investment to replace older equipment, but these costs are not a
result of the guidance and are required by current regulations.
The case study firm was a large urban practice with over 30 dentists and staff. The
facility utilized 12 x-ray machines, most of which are about 20 years old. The facility
sees over 1,200 patients per week. This facility's records indicate that almost all staff
receive less than measurable exposure. The only measured exposures over the past
several years were attributed to the exposure of a badge attached to a lab coat left in
an x-ray room for several days.
72
-------
CHAPTER 9
COST OF COMPLIANCE; WELL LOGGING
9.1 INDUSTRY PROFILE: WELL LOGGING
Well logging is a geophysical technique frequently used in energy and mineral
exploration to determine various subsurface rock properties in order to assess an area's
mineral/energy potential. Its predominant application is in oil and gas exploration.
Instruments are lowered into shafts down to depths of up to 35,000 feet and non-
destructive measurements, read at the surface, are made over the entire length of the
shaft. Measurements of electrical resistivity, gamma-ray attenuation, density, magne-
tic susceptibility, and sonic attenuation and travel time are made in order to assess
such rock properties as porosity, permeability, fluid content, and the geometrical
configuration of the reservoir. Two of these measurements involve the use of radiation
sources, encapsulated in stainless steel, handled by the well-logging field team.
Performance
In 1977, well surveying and logging receipts for the oil and gas field services sectors
totaled $556.5 million, up from $141.4 million in 1972 (DOC, Census of Mineral
Industries; Oil and Gas Field Services, 1977). Estimates place the number of well-
logging firms in the U.S. at 200 to 300 with the largest five of these performing about
80% of all well-logging services. In 1978, the Nuclear Regulatory Commission (NRC)
licensed approximately 80 firms. Agreement states like Texas and Louisiana (where
well-logging services are concentrated) currently license some 70 and 35 well-logging
firms, respectively. Many of these firms are relatively small operations. It is unclear
what effect the current recession will have on the number or profitability of firm.
^Joseph Gorell, Radiation Control Office, State of Texas, private communication,
January 18, 1982.
73''
-------
Employment
Total employment in the well-logging industry is estimated to be 25,000. Some 2,600
professional well loggers in the U.S. are members of the Society of Professional Well
Log Analysts (more than 3,000 worldwide) with membership, only a fraction of all
practitioners, increasing rapidly.
The heart of a well-logging operation is the field team, each typically comprised of
three members two operators and a field engineer. In the larger firms, there may be
as many as 700 such field teams performing roughly 400 jobs per day. Training
requirements, particularly for the field engineers, are substantial with instruction in
radiation protection principles required and information on quantitative levels of risk
soon to be added. Operators are usually not formally trained.
9.2 COST OF COMPLIANCE WITH GUIDANCE
Well Logging
Guidance #1 - Annual Whole-body Limit - 5.0 rem/yr
There is no impact from this guidance. It appears that the case study firm, an NRC
licensee, is representative of the industry on occupational exposure. Given that it
would have no problem in compliance, the same conclusion can be generalized for the
entire industry.
Guidance #2 - Accumulated Lifetime Whole-body Exposure - 100 rem
Assuming that the case study firm is representative of the industry, no impact is
expected.
Guidance #3 - Exposure to Extremities and Organs
Exposures to extremities are not greater than whole-body exposures. Therefore this
guidance would have no impact.
74
-------
Guidance f 4 - Anticipated Exposures in Range C (1.5 - 5.0 rem/yr)
The distribution of exposures for a case study firm indicates that less than 10% are in
excess of 1.0 rem/yr., and a large proportion of these probably fall between 1.0 and 1.5
rem. Moreover, exposures are accumulated relatively uniformly throughout the year.
Therefore, it is unlikely that a "significant" contribution to the annual exposure would
be accrued in the course of a single task. Nevertheless, from a regulatory standpoint, a
conservative view is likely to be taken, and therefore Range C exposures would be
anticipated.
Depending on the definition of supervision, there are three options for compliance. The
strict, high-cost interpretation entails supervision by a health physicist at each field
site. This approach is not feasible for several reasons. First, direct supervision by a
radiation protection professional at each field site as well as the firm's headquarters
and factory would require between 2,500 - 4,500 health physicists for the industry. The
current national pool of health physicists could not satisfy this demand. Second, a full-
time professional for each field team would put most small firms out of business.
Third, it is unlikely that direct supervision by a health physicist would improve the level
of radiation protection at an individual site. If a problem involving a potentially high
exposure were to occur during the 30 to 90 seconds when the source is exposed, the
proper action would depend on an assessment of risk in continuing the operation, which
requires an engineer's knowledge of well-logging.
The medium-cost option would entail the employment of two full-time health physicists
at each of the five firms that dominate the industry, and a full-time health physicist at
each of the small firms. Monitoring responsibilities at all firms would be passed on to
the crew chief of each field team, who would be qualified as a radiologic technician.
The least-cost interpretation differs from the medium-cost approach in requiring only
part-time health physicists at small firms.
The medium-cost approach could also place small establishments out of business.
Substituting part-time consultants for full-time professionals would probably be econo-
mically feasible, but may not satisfy the intent of the guidance.
75
-------
Qualification of an engineer as a radiologic technician under the medium and least-cost
options could require two weeks of instruction, which would be given by the health
physics personnel at each firm. With approximately 4,000 field engineers in the
industry at any one time, and an industry turnover rate of one-third, 1,350 workers
would receive training annually, assuming that the lead time provided by a regulation
would allow training only new personnel. A new field engineer earns about $30,000 per
year and a typical industry overhead rate is 70 percent of salary.
In summary, if full-time health physicists are required at small firms (although not at
each field site), then the annual industry costs of additional staff and instruction of
field workers would be $23.5 million. Alternatively, if consultants are permitted to
fulfill the supervisory requirement on a part-time basis, and also give instruction to
field engineers, then the annual costs to the industry would be $4 million. The cost
impact of the high-cost option has not been estimated because this approach would not
be feasible.
Table 26; Cost Estimate for Range C Requirements for Well Logging
(a) Medium-cost option full-time health physicists required at all firms
No. of Full Cost/
Expense personnel workera Cost
1. Instruction of engineers 1,350 $ 2,000 $ 2.7 million
(staff time)
2. Full-time health physicists 260 $68,000 $ 17.7 million
TOTAL $ 20.4 million
(b) Least-cost option part-time health physicists permitted at small firms
No. of Full Cost/
Expense personnel worker8 Cost
1. Instruction of engineers 1,350 $ 2,000 $ 2.7 million
(staff time)
2. Part-time health 250 $6,000 1.5 million
physicist
3. Full-time health physicists 10 $68,000 .!_ million
TOTAL $ 4.9 million
aData on case study firm suggest an overhead and fringe multiplier of 1.7.
76
-------
Guidance #5 - Anticipated Exposure in Range B (0.5 - 1.5 rem/yr)
The monitoring requirements are currently being carried out. The supervision require-
ments are not. However, the costs of satisfying the Range B requirements would be
subsumed by the Range C requirements. If Range C were not promulgated, the 300
firms in the industry would have to hire a health physics consultant at an estimated cost
of $300,000 per year.
Guidance #6 - Training
Two hours of instruction would have to be given to all field operators. However,
supervisory personnel would already receive training in response to the guidance on
Range C. Thus, approximately 10,000 (approximately 4,500 field teams with 2 or more
operators per team) operators would have to be trained. Assuming a turnover rate of
1/3, then approximately 3,300 operators would receive two hours of instruction annually
from health physics personnel at the firm. At an average salary of $25,000 per operator
and a 70 percent overhead and fringe factor, the total cost of staff time during
instruction would be $132,000.
Table 27; Guidance Estimate for Training Requirements for Well Logging
No. of
Expense workers worker Cost
Staff time (2 hrs/worker) 3,300 $40 $132,000
Guidance #7 - Exposure to Unborn
It is estimated that there is minimal cost to the industry under the three alternatives.
If procedures are strictly followed in the field, exposures can be limited to less than 0.5
rem in nine months. Moreover, pregnant females are unlikely to work in the field for
more than six months because of heavy lifting requirements. Therefore, Alternative a
would impose negligible costs both for the industry and female workers. But if pregnant
females chose to remove themselves from the field under Alternative a, they would
probably lose their jobs.
Alternative b would likely have negligible impact on the industry since exposures in
excess of 0.2 rem/mo. are highly unlikely. But again, as under Alterntive a, women
requesting removal from the field would probably be discharged.
77
-------
Alternative c would bar pregnant women from field work if the 0.5 rem limit were
strictly adhered to. But given the small size of the female workforce in the field, the
industry would incur no costs. Therefore, the primary impact would be on freedom of
choice of females and the EEO objectives of the firm.
Guidance #8 - Internal Exposures
No cost impact is expected. Only one radionuclide with potential for internal exposures
is used, and at a level of radioactivity well below the amount set by the NRC which
would require bioassays.
Guidance #9 - Alternative Annual Whole-body Limit - 1.5 rem/yr
Exposures in this industry are currently bordering on 1.5 rem/year. With closer
supervision and strict adherence to radiation protection procedures, compliance with
this guidance might be anticipated. Assuming that the combined impact of additional
health physics personnel and instruction of field engineers would result in compliance,
then the costs of the 1.5 rem/year limit would be roughly equivalent to the compliance
costs of the industry's response to Range C.
9.3 SUMMARY OF COST OF COMPLIANCE
Compliance costs would result from the satisfying guidelines on Range C, Range B, and
the alternative 1.5 rem/year limit. Three options were considered for compliance with
the requirements of Range C, but only the costs of the medium and least-cost options
were estimated. The medium-cost option would have full-time health physicists at each
firm (but not at each field site) at an estimated annual cost of $20 million. The least-
cost option substitutes consultants for full-time personnel to fulfill the supervisory role.
The costs of this option are estimated to be $5 million. Staff time for training on the
risks of exposure could add about $150,000 to total the annual cost.
All firms would be required to respond to Range B, but the costs of satisfying this
requirement are subsumed under Range C. All major firms currently comply with Range
B. If Range C were not promulgated, these firms would incur few costs, but the 300
78
-------
other firms in the industry could incur $300,000 in annual cost. As for the alternative
1.5 rem/year whole-body limit, the industry is currently on the borderline of meeting
this requirement. Assuming that the combined impact of additional health physics
personnel and instruction of field engineers would result in compliance, then the cost of
the 1.5 rem/year limits would be equal to the compliance costs of the industry's
response to the Range C guidance.
79
-------
CHAPTER 10
COST OF COMPLIANCE; NUCLEAR FUEL PROCESSING AND FABRICATION
10.1 INDUSTRY PROFILE: FUEL FABRICATION
This industry manufactures nuclear fuel for light water-cooled reactors (LWR's) and
employs approximately 10,000 people. The raw material is uranium hexafluoride (UFg),
received in 2 MT containers from the uranium enrichment plants. The finished
products are fuel assemblies ready to load into LWR's. Intermediate products consist of
UO0 powder, UO0 pellets, and fuel rods (strings of pellets clad in zirconium alloy).
/ £t
The industry is dominated by five large firms. A few small processors manufacture fuel
for research reactors or high temperature gas-cooled reactors. In these cases, however,
the finished products differ substantially from LWR fuel. Health physics considera-
tions, however, are similar; i.e., the risks are from soluble and insoluble compounds of
the uranium isotopes.
The process is similar in most of the major facilities. For some of the producers, the
conversion to UO« and the processing of the UO« into fuel rods are performed at
separate sites. Initially, UFg from the enrichment plant is converted to UO2 powder by
a chemical ammonium diuranate (ADU) process. The UO2 powder is processed (e.g.,
hammermilling, predensification, granulating, blending) to prepare it for subsequent
processing. Pressed UO, pellets are sintered, ground, and loaded into fuel rods. Fuel
rods are assembled into fuel bundles, and the bundles are shipped to various reactor
sites. A large number of support activities, such as laboratory analyses, process
development, maintenance, and waste treatment are also conducted.
Health physics considerations, which are similar for the entire group, relate to the risks
of internal exposure from soluble and insoluble compounds of uranium isotopes. No firm
would have a problem in satisfying the proposed guidances on external exposure,
assuming that the delegation of supervisory responsibilities from the current staff of
radiation protection professionals to non-professionals is allowed. Therefore, the
probable impact of the new regulations would result from the requirements on internal
exposure and training in levels of risk, and additionally, in Range C, assuming that a
strict interpretation of the supervisory requirements.
80"
-------
10.2 COST OF COMPLIANCE WITH GUIDANCE
The light water reactor (LWR) fuel fabrication industry is dominated by facilities
operated by five of the largest manufacturing firms in the nation. The facilities range
in age from 20 years to 5 years and the largest facility has five times the capacity of
the smallest. The estimated impacts of revision to the guidance are several times
larger than the impacts in any other industry except hospitals. However, great
uncertainty as to the accuracy of these numbers exists and costs could be as much as an
order of magnitude lower under some assumptions. Almost all of the compliance costs
are a result of revisions in the limits for internal exposure, adjustment to the dose
calculation models, and the summation of internal and external exposure. The case
study report covers two facilities and discusses the compliance options anticipated by
the two firms. In one, more precise estimation of internal exposure is expected to keep
employees below the limits and in the other substantial engineering changes (extensive
process containment construction) is expected to lower exposures. This study did not
have sufficient resources dedicated to this industry to refine the industry estimates or
to develop alternatives for regulation or compliance.
A survey sponsored by the Health Physics Society being conducted in the fall of 1982 is
designed to provide cost estimates from each member of the industry which would then
be published by the Atomic Industrial Forum (AIF). In addition, AIF is planning to
sponsor an independent study of internal dosimetry in the fuel fabrication industry that
may lead to a better understanding of compliance options. These studies may shed
some additional light on the cost implications, but it is felt that additional study of
internal exposure costs may be warranted. Such a study could result in a more thorough
understanding of the impacts and/or program revisions that could substantially reduce
these costs.
Guidance #1 - Annual Whole-body Limit - 5.0 rem/yr
Of approximately 4,000 monitored workers reported to the NRC in 1981, none received
an external exposure in excess of 3 rem. Thus, from the standpoint of external
exposure, no impact from this provision is expected.
JOp. Cit., NRC, NUREG-0714.
81
-------
Guidance #2 - Accumulated Lifetime Whole-body Exposure - 100 rem
This provision is not expected to be utilized. Therefore, no impact from this provision
is expected as no long-time employees of the case study firm approached this limit.
Guidance #3 - Exposure to Extremities and Organs
Exposure histories at case study facilities indicate that high extremity exposures do not
occur in this industry. Therefore, no impact from this provision is expected.
Guidance #4 - Anticipated Exposures in Range C (0.5 - 1.5 rem/yr)
Currently, exposures from the inhalation of uranium are "anticipated" in Range C, and
it is possible to receive a "significant" contribution to Range C from a single task. It is
expected that at least as high a percentage of workers would be in Range C under the
new proposed Derived Air Concentrations for uranium (a factor of ten lower than the
current maximum permissible concentration for insoluble uranium).
For the case study firms, technicians from the Radiation Safety Office monitor during
incidents of high airborne concentrations of uranium. At least one individual, and at
certain times during the week, two may be required to monitor.
If the "radiation safety professional" was permitted to delegate responsibility for
supervision under this guideline, the costs are expected to be zero since this would fall
within their current operating procedures. If not, and assuming similar Range C
experience at the other plants, two additional health physicists would have to be hired
at each of the five LWR fuel fabricators. The total annual costs would be $680,000.
Table 28; Cost Estimate for Range C Requirements for Fuel Fabrication
(Strict Monitoring Assumption) '
No. of Cost/
Expense firms worker Costs
Additional health physicists 5 $68,000 $680,000
(2 per firm)
82
-------
Guidance #5 - Anticipated Exposure in Range B (0.5 - 1.5 rem/yr)
The monitoring and supervision requirements are currently being carried out full-time
by radiation protection professionals.
Guidance #6 - Training
With the exception of instruction in quantitative levels of risk, the training require-
ments in the proposed guidelines are currently being satisfied. To additionally satisfy
the requirement relating to levels of risk, two additional hours of training for each of
the industry's 4,000 workers are estimated. The average salary of a worker is $17,500.
In addition, 60 more hours of instruction time (plus preparation) would be required at
each firm, and there are five firms in the industry. The average salary of an instructor
is $30,000. Therefore, assuming an overhead and fringe multiplier of 1.7 the annual
costs for the industry are estimated to be about $127,500.
Table 29; Cost Estimate for Training Requirements for Fuel Fabrication
No. of
Person
Hours
8,000
300
Cost/hr
$15
$25
Costs
$120,000
7,500
1. Staff time
2. Instruction time
Total $127,500
Guidance #8 - Internal Exposures
Case studies were conducted on two of the five firms in this industry. In one, the one-
time cost of revision of internal monitoring was estimated by the case study firm to be
$400,000, with annual costs of $100,000. In the other, a one-time cost of $9.8 million
was estimated, with annual costs of $1.2 million. The first was a large fabrication
facility, whereas the second was comparatively small and of older vintage.
It was initially felt that there would be no costs to one of the three large facilities in
the industry because it is relatively new and has relatively low airborne levels of
activity. Although it is true that airborne concentrations are relatively low at this
newer facility, costs for internal compliance at this facility may be higher than those
83
-------
for other facilities. This is the case, in part, because this facility currently does not
record MPC-hrs (levels are too low at the current limits, but will not be at the
revised limits.) Imposition of the revised limits will require the initial development of
an automated recordkeeping system, whereas these systems would only require up-
grading at facilities where case studies were conducted.
Two of the four in this category are relatively large. The large case study firm is
assumed to be representative of the large facilities. The case study firm would modify
its procedures for measuring potential exposures to airborne concentrations of uranium
from airborne monitoring data in conjunction with time and area assignments (TIA) for
personnel. From the calculated potential exposures to airborne concentrations, internal
doses are estimated by organ for each individual. These estimated internal doses are
checked using the bioassay procedures, and measured external exposures obtained from
personnel dosimetry are routinely added to the estimated internal doses.
The modification of this program entails (1) relaxing the conservative assumptions in
the calculation of particle size, solubility and percentage of uranium enrichment, (2)
more accurate monitoring of the time spent by each employee in each part of the plant,
and (3) expanding the urinalysis and bioassay programs to cover an radiation workers
with potential exposures in Range C. The staff responsible for the radiation protection
at this facility at the time of the initial case study provided an estimate of expected
costs by category. These costs were the best approximation by the staff of the actual
cost including all fringe, overhead, and special hardware requirements. The approxi-
mate costs of these modifications were estimated to be $214,500 in initial costs and
$28,000 in annual cost.
Table 30; Initial Cost Estimate for Large LWR Fuel Case Study Firm
Initial Annual
Cost Cost
1. TIA tracking system $112,500
2. Adjustment of calculational $102,000
procedures
3. Whole-body bioassays-counting $120,000
4. Urinalysis $ 8,000
Total $214,500 $128,000
84
-------
Subsequent to the initial case study, the staff at the large facility left the firm and a
new radiation staff was hired. In the course of an investigation of the cost of the
revision to 10CFR Part 20 regulations, a follow up on the initial case study was
conducted. The new staff agreed with the basic plan of the old staff for ensuring
compliance, but felt the cost estimates were not realistic and that they failed to
include all costs. The new staff provided a revised estimate of $400,000 in initial cost
and $100,000 annual cost. The initial cost is comprised of various activities including
new hardware for time-in-area assignments, equipment and measurements of solubility
and particle size or better containment of process steps. No item-by-item breakdown
was provided. The cost was estimated by the new staff by computing the total number
of man-rem currently being accumulated annually in excess of the proposed limits and
multiplying these by $1,000 per man-rem. The rationale is based on the proposed NRC
safety goal for limitation on reactor hardware modification to $1,000 per man-rem
reduced.
The second case study firm is representative of the two smaller firms in the industry,
which are early vintage facilities. The small case study firm had one radiation worker
for every four at a large facility. It is assumed that with production efficiencies,
output of the small firm would be about one-fifth that of a large firm. The case study
firm is considering two options to comply with the proposed guidance. The first is
modification of its procedures to calculate airborne concentrations like the other case
study firm. The costs of this approach estimated by the authors are believed to be
more than proportional to the costs to the larger firm because much of the effort is
comprised of planning, design and software. It is estimated, then, that the costs of
modifying the firm's calculational procedures and augmenting its time-in-area (TIA)
tracking system would be 75% of the costs to the larger firm. However, for an
expanded urinalysis and bioassay program, the costs are estimated to be roughly
proportional to output, and therefore, would be approximately 25% of the costs to the
large case study firm. (A proportion of 25% instead of 20% is used in estimating this
cost because the older firms are less efficient than the larger, more recent facilities.)
85
-------
Table 31: Cost Estimate of Option 1 (modification of monitoring system) for
Small LWR Fuel Case Study Firm
Initial Annual
Cost Cost
1. TIA tracking system $100,000
2. Adjustment calculational procedures $ 76,500
3. Bioassays $30,000
4. Urinalysis $ 2,000
Total $176,500 $32,000
The second option for the small case study firm entails glove box containment in all
operations. This option was initially supported for two reasons: first, the firm felt that
modification of its calculational procedures would not sufficiently lower calculated
internal exposures to satisfy the proposed requirement on Derived Air Concentrations
(DAC's); second, the firm expressed anxiety about making adjustments which would not
improve the protection of its workers, but serve only to satisfy new regulations. These
cost estimates were developed by the engineering division of the case study firm. No
further detail was provided, however, for the activities planned, these costs did not
appear measurable.
The initial favorable response to glove box containment could change because the costs
of this option might bankrupt the firm. The modification approach is fifty times less
costly and it is believed it would satisfy the guidance.
86
-------
Table 32: Cost Estimate of Option 2 (glove box containment) for
Small LWR Fuel Case Study Firm
1.
2.
3.
4.
Containment
Process modifications
Ventilation
Engineering and construction
supervision
plus annual operating costs
Total Costs
Initial
Cost
$2,400,000
$2,400,000
$3,100,000
$1,900,000
$9,800,000
Annual
Cost
$1,200,000
$1,200,000
Several alternatives are available to estimate the total cost to this industry of the
internal dosimetry guidance. Little information was available to this study to test the
accuracy of the various cost options estimated by past and current staffs of the case
study firms. In addition, it is difficult to separate the costs incurred simply because of
a revised regulation and those related to better management control. It should also be
noted that several benefits such as productivity or management information would
accrue to manufacturers from those activities in addition to simple regulatory
compliance. The cost of compliance with the guidance on internal exposures can be
summarized below.
Table 33; Summary of Cost for LWR Fuel Industry
Option 1
1.
2.
3.
Initial
(000)
2 Small Firms 209
2 Large Firms 429
1 Modern Firm
Annual
(000)
32
256
Option 2
Initial
ToooT
19,600
429
215
Annual
(000)
2,400
256
128
Option 3
Initial
ToTjoT
390
800
595
Annual
(000)
50
200
125
Total
638
288
20,244 2,784
1,785 375
87
-------
Option 1 is the low cost estimate based on the initial estimate of the large firm and
assuming that 1) the costs for the other large firm are the same, 2) the procedures are
applicable to the two smaller firms (at lower cost) and 3) the modern firm incurs no
cost. Option 2 is the high cost option assuming that 1) the two large firms' costs are
the same as for Option 1, 2) the two small firms undertake the high cost containment
option and 3) the modern firm incurs costs equal to the large firms' cost. Finally,
Option 3 assumes 1) the revised cost estimate provided by the large case study firm
holds for both large firms, 2) adjustment of the two small firms' cost estimate under
Option 1 to be consistent with the revised large firm estimate under Option 3 and 3) the
modern firm costs are the average of the revised large and small firms' costs.
Only further study of the actual responses required by these firms could allow more
accurate estimates. Substantial differences remain between the companies in their
estimates of real costs of compliance. For the purpose of this study, the authors
believe that the third option might be reasonable; further study is required however,
before one estimate could be adequately defended against all others. The defender of
Option 2 would be able to make a good case, but it is believed that these costs are so
high that the smaller firms would leave the industry, which currently has substantial
overcapacity.
Guidance #9 - Alternate Annual Whole-body Limit - 1.5 rem/yr
No impact from this provision is anticipated with regard to external exposures. At one
case study facility, only 5 workers received exposures in excess of 1.5 rem in 1980 and
similar exposure patterns were observed at the other facility. However, under the
requirements for summation of internal and external exposures, facilities might be
required to adopt a program similar to that described above for internal exposures.
Thus, the cost of this program could be $2 million in initial costs and $400,000 in annual
costs. If the revised internal program and a 1.5 rem annual limit were put in place at
the same time, the above expenditures would cover both aspects of the guidance.
88
-------
10.3 SUMMARY OF COST OF COMPLIANCE
Cost impacts for this industry ore concentrated in Range C requirements for staff
training and in monitoring of internal exposures. It is estimated that the industry would
incur annual costs of $680,000 for Range C if non-professional health physics personnel
are not permitted to assume supervisory responsibilities.
With the exception of instruction in levels of risk, the training requirements in the
proposed guidelines are currently being satisfied. To additionally provide instruction in
levels of risk to the industry's 4,000 potentially exposed workers would cost approxi-
mately $130,000 annually.
The control of internal expsoure is the highest potential cost area for this industry yet
it is also the one for which the least is understood by either industry or the regulators.
If the five firms that make up this industry respond by modifying the calculational
procedures on airborne concentration, particle size, enrichment, solubility, and worker
time-in-area, then the result in annual industry costs could be three or four hundred
thousand dollars and initial costs of $1 to $2 million. However, if the two small firms
opt for glove box containment as suggested by a case study, then the annual costs rise
to $3 million, and initial costs could be $20.6 million. This alternative is believed to be
less likely because it could put the smaller firms out of business.
Compliance with the alternative 1.5 rem/year limit would not be a problem for this
industry with respect to external exposures. However, the summation of internal and
external exposures could present compliance difficulties. This risk could be eliminated
by a program similar to the internal exposure estimates described above.
89
-------
CHAPTER 11
COST OF COMPLIANCE: COMMERCIAL POWER REACTORS
11.1 INDUSTRY PROFILE: COMMERCIAL POWER REACTORS
The technical specifications for a commercial nuclear power reactor requires the
submittal of an annual report which provides the number of individuals exposed to
radiation and their cumulative annual doses, broken down by type of personnel, work
function, and occupation. These individual reports are compiled by the U.S. Nuclear
Regulatory Commission (NRC) and reported to the public annually. Table 34, taken
from an NRC report , is a summary of the annual information reported by commercial
light water-cooled reactors and Table 35 is a summary of the annual whole-body doses
at these reactors, broken down into exposure ranges, for the years 1969-1980.
In 1980, there were 68 operating light water-cooled power reactors with a total
installed electrical generating capacity of 47,532 MWe (68 x 699 MWe). There were
80,331 individuals who received measurable exposures, out of a total number monitored
of 133,878. These individuals had an annual collective dose of 53,796 man-rems. There
were 311 individuals in 1980 with whole-body exposures greater than the proposed 5
rem/yr RPG. There were 12,786 individuals (assuming that one-half the individuals in
the 1.0-2.0 rem/yr range received exposures in excess of 1.5 rem/yr) with whole-body
exposures greater than the alternative RPG of 1.5 rem/yr.
It is expected that as of December 31, 1982, there will be 82 operating units at 54 sites,
2
owned and operated by 44 utilities.
Occupational Radiation Exposures at Commercial Nuclear Power Reactors 1979,
Nuclear Regulatory Commission, March 1981, NUREG-0713.
2
For those cases in which a plant is owned by more than one utility, only one utility is
counted.
90
-------
Table 34: SUMMARY OF ANNUAL INFORMATION REPORTED
BY COMMERCIAL LIGHT WATER COOLED REACTORS
1969 -1980
Yew
1989
1970
1971
1972
1973
1974
1975
1978
1977
1978
1979
1980
NllllllMf
Of
Reactor*
7(5)
10(7)
13(9)
18 (12)
24
34
44
83
87
84
87
68
Annual
Collective
DOM*
(Mm ranu)
1.247 (663)
3,502 (1,609)
3,628 (1.981)
6,566 (4.213)
13,963
13.722
20,879
26,433
32,511
31,809
39,759
53,796
No. of
Worken
With
Measurable
DOM*
744*
2.661*
2.778"
4.143*
14,780
18,468
25.491
35,447
42.266
45,998
64.073
80,331
Qron
MW-Yr*
Electric
Generated
1,289
1,892
3,220
5,602
7.164
10^83
17,769
21,911
26,444
31,614
29,920
29.155
Average
DOM
Per
Worker
(Reim)
0.89*
OJBO'
0.71*
1.02*
0.94
0.74
0.82
0.75
0.77
0.69
0.62
0.67
Avenge
Collective
DOM Per
Reactor
(Man-rem*)
178
350
280
365
582
404
475
499
570
497
593
791
Avftfftflt No*
Personnel With
Measurable
DOM* Per
Reactor
149*
380*
309*
345*
616
543
579
689
742
719
956
1.181
AVWVQ0
ntoft*fwns
Per
MW-Yr
IjO
1.9
1.1
1.2
14
14
1.2
1.2
1.2
1.0
1.3
U
Avenge
MW-Yr*
OcfMritwl
Per
Reactor
184
189
248
311
299
320
404
413
464
494
447
429
*
AWTVpv
Rated
Capacity
(MWe) Net
247
300
367
408
496
575
630
663
877
702
70S
699
Dwrtrie tfw v*«n 1M* through 1«72, (It i
deoftoetta
i but hm did not lubmrt the number of pmonml out i
I doMt. Th* number of tMeton
trwt did report dew and number of worker, h riven hi peteiilli.m In the ncond column. Tht collecttw dont ihown In pmnthem In the thbd column, u well the i
numbers In the i_._l,ili^, eolumnt. »r» all boed on the deti fubmltud bv the number of reectorl thown In perentheM*. Thb) coir eel ton, wid other*, chanted tome of MM «etoei from
thoe> eppeeilni In eerlier NUREG itocument*.
Source: Occupational Radiation Exposures at Commercial Nuclear Power Reactors 1979, Nuclear Regulatory
Commission, March 1981, NUREG-0713.
-------
Table 35: SUMMARY DISTRIBUTION OF ANNUAL WHOLE BODY DOSES
AT COMMERCIAL LIGHT WATER COOLED REACTORS
1969-1980
Yiw
1969
1970
1971
1972
1973
1974
1975
1976
1977
1978
1979
1980
Number of Individual with Wholi Body Exposure in the Indicated Ranges (Remsl
No Measurable
Exposure
Measurable
<0.10
0.10-
0.25
0.25-
0.50
050-
0.75
0.75-
1.0
1.0-
2.0
0.0-1.25 1.25-2.0
2.479 128
6,839 146
8,586 410
14.095 688
19.043
20.472
18.854
25,704
24.868
3o,i4a I
45.087
63.547
5.494
6.735
8.841
12.821
13.970
16,639
24.301
29.638
1.698
2.887
3,674
5.130
6.534
6.943
9,846
11,750
1,214
2X156
2,750
4.135
5.050
5.504
8,159
9^20
740
1.182
1.685
2,520
3.258
3,399
5,189
6.082
652
906
1.339
2.030
2,486
2,498
3.479
4.518
2.468
2.503
3,948
4.880
6.162
6,405
7,934
11.474
2.0-
3.0
134
166
315
532
1,584
1.378
1.872
2.354
2.837
2,989
3.307
4.515
3.0-
4.0
65
163
137
199
422
471
691
789
1,130
1.080
1.251
1,537
4.0-
6.0
25
88
105
111
251
226
423
487
569
418
477
686
_!....
5.0-
6.0
5
98
17
46
125
86
169
188
141
67
86
192
-L.
6.0-
7.0
2
8
11
21
71
30
60
70
66
26
28
98
1
7.0-
8.0
1
9
38
6
24
26
36
8
13
18
,..!.,
8.0-
9.0
6
16
12
11
21
2
3
_i_
9.0-
104)
6
7
6
6
10.0-
11.0
1
1
(>12)
2
(11-12
1
Total
Number
MonitofM
2,838
7.509
9.581
16.713
33323
38.938
44443
60.521
67.134
76.1211 1
109.160
133.878
Annual
Collect!**
Dot**
(Man-ramt)
13^63"
13,722**
20^79
26^33"
32^11"
' 31J04**
39.759
53.796"
<£>
Is?
"Summary of raporti Mibmittad in accordance with 10 CFR 20.407 by plantt that had bean in commercial operation for at least one full year as of December 31 of
each of the indicated years.
**The collective closes were not reported by the plants but were calculated by the staff by using the method described in this document.
Source: See Table 34
-------
11.2 COST OF COMPLIANCE WITH GUIDANCE
Guidance #1 - Annual Whole-Body Limit - 5.0 rem/yr and Guidance #9 - Alternate
Annual Whole-Body Limit - 1.5 rem/yr
This section covers both the 5 and 1.5 rem whole-body limit. The methodology and
procedures are the source for both estimates of cost, thus they are combined here for
clarity. The management at most power reactors establishes administrative exposure
limits which are below the regulatory limits. This procedure is used to provide
adequate margins of safety in measuring, recording, and reporting actual exposures
received by employees. One effect of reducing the regulatory limit is to narrow the
margin of safety between the regulatory and the administrative limits, thereby
increasing the probability of exceeding the regulatory limit. In our evaluation that
follows, we adopt an administrative limit which is 80% of the regulatory limit.
Increased Worker Demand and Additional Collective Exposure
Stone and Webster Engineering Corporation used the data from the NRC annual
report to estimate the increase in the number of workers and the collective exposure
resulting from a reduction in the whole-body annual limit. A correlation model was
o
used, similiar in approach to that previously employed by Golden . The Stone and
Webster approach is adopted along with the 1980 data from the NRC report (Tables 34
and 35), to estimate the additional number of workers and the additional collective
exposure that would result from reductions in the regulatory limits. These increases
result from an increase in the number of crew changes required to operate and maintain
the power plants at reduced occupational exposure limits. To keep these plants
operating, additional permanent station personnel and contract workers would be
needed.
Occupational Exposure of Commercial Nuclear Power Reactors, 1980, Annual Report,
U.S. NRC Report NUREG-0713, December 1981.
2
J.C. Golden, "Effect of a Change in Regulatory Limits for Occupational Radiation
Exposure on Manpower Requirements and Radiation Dose (Man-rem) Expenditures of a
Nuclear Power Station", Commonwealth Company, June 1976.
o
E.A. Warman et. al., "Estimated Additional Number of Workers and Additional
Cumulative Exposure Due to Reducing Annual Dose Limits per Individual", Stone &.
Webster Engineering Corporation Report RP-29, April 1978.
93
-------
From the data base given in Table 35, and an administrative limit of 4.0 rem/year, the
model estimated that 272 additional workers would be required, and collective exposure
would increase 135 man-rem per year. For the regulatory limit of 1.5 rem/year, 25,677
additional workers would be necessary, and collective exposure would increase by 5,381
man-rem per year. The operation of the model is presented below.
Differential Operating Cost in 1982 Dollars
The Stone and Webster report did not address the differential operating costs.
However, in assessing the impact on operating power plants of a 500 mrem/yr
regulatory limit, Vance developed a cost equation based on increased worker demand.
His cost estimates have been converted to 1982 dollars by using an annual inflator of
11%. The methodology for developing the worker demand used in the Vance report
2 3
adopted the same technique used by Pelletier and Golden . For the proposed 5
rem/year annual limit, it is likely that all of the additional workers required would be
obtained by using contractor personnel. Therefore, using the Vance equation for the
costs of contractor personnel (i.e., $l,270/outside worker), the cost of additional
workers would be $342,735 in 1982 dollars.
For the alternative regulatory limit of 1.5 rem/year, the estimated increase required in
workers is likely to be satisfied by a combination of a permanent station and contract
personnel. We can make a reasonable estimate of numbers required in each category by
using a ratio developed by Vance. From Table 35 in the Vance report, the ratio is 19
outside workers to one permanent station worker. Using this ratio, we obtain 1,284
permanent station workers and 24,393 outside contractor workers. The cost of hiring
additional permanent station personnel is the worker's base salary multiplied by a
payroll factor. Vance estimated that average annual salary for non-supervisory
workers is $25,900 per year. Using an average direct payroll multiplier of 1.4, the total
annual cost of a permanent employee $36,260. Therefore, the cost for contractor
personnel would be $30.73 million, and for permanent station personnel, $46.56 million,
for a total of approximately $77.4 million in 1982 dollars.
J. Vance et. al., "A Preliminary Assessment of the Potential Impacts of Operating
Nuclear Powerplants of a 500 Mrem/Year Occupational Exposure Limit", prepared for
the Atomic Industrial Forum, April 1978.
2
C.A. Pelletier and P.G. Voilleque, "Potential Benefits of Reducing Occupational
Radiation Exposure", Atomic Industrial Forum Report AIF-NESP-010R, May 1979.
o
Op. cit., J.C. Golden, June 1979.
94
-------
To estimate the costs of outage extension and additional facilities under the reduced
regulatory limits, we used the most recent assessment of reduced occupational exposure
limits conducted by Catalytic, Inc. for the Atomic Industrial Forum. Extension in the
outage time results from the extension in critical path duration, which is a consequence
of the increased number of workers required for a task. The cost associated with the
outage extension is estimated from the cost of replacement power, assumed to be
$22,700 (net) per hour. These additional workers require additional on-site facilities for
training, supplies, and offices.
Under the assumption that the proposed EPA limit would be delivered during a calendar
quarter (which was the time frame used in the Catalytic report), the proposed 5.0
rem/year annual limit was estimated to have no impact. For the proposed alternative
annual limit of 1.5 rem/year (using the 1.0 rem/quarter regulatory limit), the Catalytic
report estimates a cost of $106.06 million for outage extension and $3.2 million for
additional facilities in 1982 dollars.
Table 36 presents the total estimated costs, in 1982 dollars, of the proposed EPA annual
limit and the alternative annual limit for the entire commercial reactor industry in the
year 1980.
Table 36: Total Estimated Costs for All Operating
Nuclear Power Plants of Reducing Regulatory Limits
Regulatory Limit
iiu^a^i
Differential Worker Demand
Permanent Station
Outside Workers
Total
Differential Operating Costs
(1982 dollars)
Personnel (Perm. Stat.)
Personnel (Outside)
Outage Extension
Additional Facilities
1.5 rem/yr
1,284
24,393
25,677
1.5 rem/yr
(million)
$ 46.56
30.73
106.06
3.22
5.0 rem/yr
0
272
272
5.0 rem/yr
(million)
0.34
0.0
0.0
Total Additional Cost
186.65
0.34
95
-------
The Catalytic report was also used to check our earlier cost estimates using the Stone
and Webster methodology. It is believed that this was the most valuable application of
the Catalytic report because it considered reductions in quarterly limits, rather than
annual limits, and therefore was not appropriate as a principal estimator of the costs of
the proposed EPA annual limits.
The comparison of the results the Catalytic report with the costs estimates from the
Stone and Webster methodology was accomplished by assuming that the entire annual
limit would be delivered during a calendar quarter. This can be justified on the basis
that most of the exposure is obtained during the annual refueling and maintenance
outage, which is less than three months in duration.
On this basis, the proposed 5.0 rem/year annual limit would obviously have no impact (it
is higher than the current quarterly limit). For the alternative annual limit of 1.5
rem/year, the data is compared with the Catalytic result corresponding to a quarterly
dose limit of 1.0 rem/qtr., which is $2.2 million per 1,100 MWe reference plant in 1982
dollars. Multiplying by the 43 reference plants required to obtain the total 1980
generating capacity given in Table 34, an additional manpower cost of roughly $93.67
million in 1982 dollars is obtained. This is considered to be in relatively close
agreement with our estimate (using the Stone and Webster methodology) of approxi-
mately $77.36 million.
Calculation of Cost of Compliance
The terms used in the Stone and Webster model are defined as follows:
DD = designated individual dose (rem/year)
DL = regulatory limit (rem/year)
DA = administrative limit set by licensee to assure regulatory limits are not exceeded
MD = number of workers receiving an annual dose greater than DD in the original data
base
Study of the Effects of Reduced Occupational Radiation Exposure Limits on the
Nuclear Power Industry, prepared by Catalytic, Inc., Atomic Industrial Forum Report
AIF-NESP-017, January 1980.
96
-------
= additional number of workers required if DD is also equal to DA
collective exposure accumulated by Mp workers receiving annual doses above
DD in the original data base
= additional collective exposure accumulated if DD is set equal to D. (in
man-rem)
EQ= individual worker nonproductive fraction of his total dose in the radiation
environment in the original data base (fraction is defined as nonproductive dose
divided by nonproductive ]
assumed to be equal to 0.1.
divided by nonproductive plus productive dose). For this application, E is
The principal assumptions made in the Stone and Webster correlation model are:
The administrative limit is set as DD = DA = 0.8 D, (e.g., for a regulatory
limit of 5 rem/year, DD = DA = 0.8 x 5.0 = 4.0 rem/year).
The nonproductive dose per worker remains constant.
The total nonproductivity fraction, designated as E, increases linearly
with the number of workers. This follows as a consequence of the
presumption that the total productive dose remains constant. Mathema-
tically, this is expressed as E = EQ (MD +
The total man-rem previously above D. is shared by the increased
number of workers, MD +&Mp, with each of the individual workers
presumed to receive the administrative limit D..
The mathematical model based on the above assumptions and definition of terms is
simply stated as follows
97
-------
Additional Worker Demand (AM.J
A MD = £-=f- - MD
D ° D
D
Additional Collective Exposure
= DA(MD+AMD)-RD
From the data base given in Table 35, and an administrative limit of DA = 4.0 rem/year,
it is determined that MD = 997 workers and RD = 4941 man-rem. RD was calculated by
multiplying the number of individuals in each dose range by the midpoint of each range
and then summing the product. This method was used in Stone and Webster to calculate
the collective dose. Our estimate is as follows:
Additional Worker Demand (A MD) for DL = 5.0 Rem/year
AM = (1 - 0.1X4941)
4.0 - (0.1X4941) - 997 = 272 additional workers
597
Additional Collective Exposure (A RQ) for DL = 5.0 Rem/year
ARD = (4.0X997 + 272) - 4941 = 135 additional man-rem
4
Therefore, using the Vance equation for the costs of contractor personnel, we obtain:
$Q = $1,270 (A MD)
($1,270X272 workers) = $342,735 in 1982 dollars
for DL = 5.0 Rem/year.
Consider the alternative regulatory limit of D, = 1.5 rem/yr., it is determined from
Table 35 that DA = (0.8)(1.5) = 1.2 rem/year, Mp1 = 18,523 workers and RD = 38,819
man-rem.
Using these data, our estimate is as follows:
Simplify by using a value for DA = 1.0 rem/year
98
-------
Additional Worker Demand (AM,-.) for DL = 1.5 Rem/year
(1-0.1X38,819)
AMD = l.Q - (0.1X38^819) - 18,523 = 25,677 additional workers
18,523
Additional Collective Dose (A RD) for DL = 1.5 Rem/year
ARD = (1.0X18,523 + 25,677) - 38,819 = 5,381 additional man-rem
For the alternative regulatory limit of 1.5 rem/year, the estimated increase required in
workers is likely to be satisfied by a combination of a permanent station and contract
personnel. A reasonable estimate can be made of numbers required in each category by
using a ratio developed by Vance. From Table 2 in the Vance report, the ratio is 19
outside workers to one permanent station worker. Using this ratio, we obtain 1,284
permanent station workers and 24,393 outside contractor workers. The cost of hiring
additional permanent station personnel is the worker's base salary multiplied by a
payroll factor. Vance estimated that the average annual salary for nonsupervisory
workers is $25,900 per year in 19. Using an average direct payroll multiplier of 1.4, the
total annual cost of permanent employee in 1982 is $36,260/year. Therefore, we obtain:
A$0 = ($1,270X24,393)
= ($30.75 million for contractor personnel
and
A$Q = ($36,260X1,284)
= $46.56 million for permanent station personnel,
for a total of approximately $77.36 million in 1982 dollars for DL = 1.5 Rem/year.
The Catalytic report was also used to check our earlier cost estimates using the Stone
and Webster methodology. It is believed that this was the most valuable application of
the Catalytic report because it considered reductions in quarterly limits, rather than
annual limits, and therefore was not appropriate as a principal estimator of the costs of
the proposed EPA annual limits.
99
-------
The comparison of the results the Catalytic report with the costs estimates from the
Stone and Webster methodology was accomplished by assuming that the entire annual
limit would be delivered during a calendar quarter. This can be justified on the basis
that most of the exposure is obtained during the annual refueling and maintenance
outage, which is less than three months in duration.
On this basis, the proposed 5.0 rem/year annual limit would obviously have no impact (it
is higher than the current quarterly limit). For the alternative RPG of 1.5 rem/year,
the result compares with the Catalytic result corresponding to a quarterly dose limit of
1.0 rem/qtr., which is $2.2 million per 1,100 MWe reference plant in 1982 dollars.
Multiplying by the 43 reference plants required to obtain the total 1980 generating
capacity given in Table 33, we obtain an additional manpower cost of roughly $93.67
million 1982 dollars. This is considered to be in relatively close agreement with our
estimate (using the Stone and Webster methodology) of approximately $77.36 million.
Guidance #2 - Accumulated Lifetime Exposure - 100 rem
This industry is one of the only ones included in this study that had consistently strong
objections to the 100 rem lifetime limit. Aside from the claims that this guidance was
not based on a sound technical rationale, power plants felt that several key personnel
who carry out technical operations in high radiation fields (i.e., steam generator
jumper) would reach the lifetime limit during their career. These individuals would be
extremely difficult to replace. One estimate provided by a case study firm was that
150 such key contractor employees would be effected. If we assume that an additional
75 such workers would allow lower utilization of these key individuals, the cost to the
industry would be the fees paid by reactors to cover the cost of these additional
workers. Assuming full cost per worker of $100,000 per year, this guidance would result
in an annual cost of $7,500,000. Serious concern was raised by all case study reactors
as to whether any additional skilled workers could be made available, at any reasonable
price.
Guidance #3 - Exposure to Extremities and Organs
For the case study plants, maximum annual extremity exposures appear to average a
few rem per year for a few workers. The maximum all time extremity exposure for the
case study plants was less than 20 percent of the proposed limit. Therefore, it is
unlikely that the revised extremity limits would have an impact. Extremity exposures
100
-------
are monitored if fields exceed specified thresholds. Because of this historical
monitoring and because the results have not indicated extremity exposures approaching
the limits, it is assumed that a pilot program to demonstrate that extremity exposures
are well below the limit would not be required.
When high beta doses to the eye are anticipated, protection goggles are worn and this
does not degrade personnel performance. Since this is generally the only potential for
eye lens expsoure, significantly different from whole-body exposures, it is not anticipa-
ted new costs will be incurred.
Guidance #4 - Anticipated Exposures in Range C (1.5 to 5 rem/yr)
All power reactors would anticipate exposures in excess of 1.5 rem for some percentage
of workers. The actual number would depend on the number and length of station
outages during the year. Only one of the five reactor stations visited currently
complies with the requirements for monitoring Range C staff and those procedures
appear extremely atypical. Three stations indicated that supervision by HP technicians
are provided when radioactive fields are anticipated to be 1 rem/hr. To comply with
Range C requirements, it was generally agreed by the staff of each station that such
monitoring would be required in all fields of 100 mrem/hr. and that such monitoring
would require an appropriate doubling of the HP technician staff at each reactor. This
includes both permanent station personnel and contractor personnel brought in during
outages.
It is assumed that compliance with Range C would require an increase of 100 percent of
the HP technicians at a full cost of about $45,000 per employee ($26,000 salary plus 50
percent fringe and overhead plus 25 percent overtime earnings). The current staff of
HP technicians at the 54 sites with operating units is about 5,400 . Therefore the total
cost would be $243 million dollars. By comparison, the estimated cost for the alternate
whole-body limit of 1.5 rem per year was estimated to be about $200 million. The
latter estimate is obtained utilizing current HP practices and additional workers to
distribute high doses.
JOp. Cit., NRC, NUREG-0713.
101
-------
It should be noted that both strategies rely heavily on the industry being able to attract
a substantial number of new workers. Such activity would no doubt increase unit cost
of workers and could increase the estimates by 15 to 20 percent.
Guidance #5 - Anticipated Exposures in Range B (0.5 - 1.5 rem/yr)
All nuclear power reactors have employees exposed in Range B and currently carry out
all activities required by the guidance. Therefore, there will be no cost impact.
Guidance #6 - Training
No impact from this guidance is anticipated as all stations currently have extensive
training programs that meet or exceed the requirements of the guidance.
Guidance #7 - Exposure to the Unborn
The females at the case study reactors accounted for 2 to 15 percent of the radiation
workforce. Most of the utilities are already operating under Alternative a for the
protection of the embryo/fetus. Some of them go so far as to remove pregnant females
from work in radiation areas. For one of the case study utilities, the pregnancy policy
is in a state of flux, and an option is to specify in job descriptions a willingness to be
exposed in excess of 0.5 rem over nine months. Females who accept the job under these
conditions, therefore, would be subject to dismissal should they become pregnant.
The cost impact on the utilities of Alternative b or c would be negligible. There would,
however, be an increasing disinclination to hire females of child bearing age for work in
radiation areas. To a certain extent, this disinclination has been present over recent
years at a number of plants.
Guidance # 7 - Internal Exposures
It is not expected that the revised internal exposure provisions would alter the existing
internal monitoring programs at the plants. Those utilities (the majority) that use
MFC- hours as the surrogate for internal dose will continue to do so, and the calculated
doses are so low that it is unlikely that any utility will refine their methods by
measuring particle size, solubility fraction, etc. The few utilities that use the results
of bioassay for compliance will probably not alter their procedures. Amongst the case
102
-------
study plants, there are no instances of intake in recent memory that exceed 30 percent
of the limits. Nonetheless, it is highly unlikely that any utility will discontinue its
existing monitoring program.
The revised provisions for handling internal exposures will require modifications in dose
accounting software. The requirement to convert the internal monitoring data to
internal organ dose and combine with external exposure applies for all monitored
workers. Also, it is assumed that the conversion factors or algorithms will be supplied
by the NRC in the form of Regulatory Guides (and be internalized as a cost to the
NRC).
A considerable range of one-time costs for these software modifications were esti-
mated by the case study utilities. Two utilities estimated no costs, one estimated
$10,000, another $130,000, and yet another 2i man-years (not including the costs of
reformatting the output records or retraining.) The average is approximately $50,000
(assuming $50,000 for a man-year). This is considered realistic, since the $130,000
estimate would most likely include some reformatting of records. At $50,000 for each
of 44 utilities, the total initial cost of these modifications would be $2.2 million.
11.3 SUMMARY OF COST OF COMPLIANCE
Cost of compliance with the proposed guidelines are significant for this industry. Major
cost impacts occur in the whole-body limit, lifetime limit, Range C and internal
exposures guidances.
The 5.0 rem/year limit could result in the need for about 300 additional outside workers
at an annual cost of $350,000. For the alternative 1.5 rem/year limit, about 1,300
permanent station workers and 24,000 outside workers would be required. In addition,
there would be costs relating to outage extension and additional facilities. The
combined annual costs of additional operating expenses and personnel are estimated to
be $200 million. Initial expenses for additional facilities are estimated to be $3 million.
Other costs would include $7.5 million for addition of several specially skilled workers
for work in high radiation fields. Additional workers would reduce the likelihood of any
workers exceeding the lifetime limits. Compliance with Range C would require a
substantial staff increase in health physics technicians. It is estimated that the current
103
-------
staff of HP technicians at the 54 operating sites would have to be doubled to provide
monitoring required by Range C. The cost to the utilities of these staff is estimated to
be about $250 million. On the other hand, these costs would be greater than the cost
for operating within the 1.5 rem/year limit, that is $200 million annually and $3 million
initial expenditures. An additional $2 million in one-time programming and software
modifications for internal monitoring would be expected. Thus it is expected that
utilities would choose to operate below the 1.5 rem/year limit, thus eliminating Range
C monitoring requirements.
104
-------
CHAPTER 12
COST OF COMPLIANCE: UNIVERSITY REACTOR
12.1 INDUSTRY PROFILE: UNIVERSITY REACTORS
There are 50 university reactors currently operating in the U.S. The larger reactors
are generally 2 MW(t) swimming pool reactors with MTR-type fuel of which about 10
are currently operating. These reactors are licensed by NRC for experimental purposes
and are not designed to produce electric power. They generally are used by student and
faculty to evaluate experiments designed to study radiation effects and to produce
radionuclides for research. Typical experiments would include neutron activation
analyses, analysis of radioactive partition coefficients in water/oil systems, gamma-ray
spectroscopy and neutron embrittlement of reactor pressure vessel steels.
Only one case study was undertaken in this sector and the findings are extended to
cover all reactors. The case study reactor was a large research reactor.
12.2 COST OF COMPLIANCE WITH GUIDANCE
Guidance #1 - Annual Whole-body Limit - 5 rem/yr.
o
NRC data reports no exposure in excess of 4 rem in 1979 and only 1 in excess of 3 rem
in that year. Therefore, no impact from the guidance is anticipated.
Guidance #2 - Accumulated Lifetime Exposure - 100 rem
The highest lifetime exposure recorded by the case study reactor was less than 10 rem.
In general, there are no activities at these facilities that would place workers or
students in danger of reaching that limit. Therefore, there would be no impact.
Nuclear Reactors Built, Being Built or Planned in the U.S. as of December 31,1981; U.S.
Department of Energy, Report DOE/TIC-8200-R45, June 1982.
2Op. cit., NRC, NUREC-0714.
105
-------
Guidance #3 - Exposure to Extremities and Organs
The experience of the case study institution was that no excessive extremity exposures
occur in normal research reactor activities. Measured hand exposures are only ten
percent of the proposed limit, and eye exposures are expected to be minimal, although
they are not currently monitored. Therefore no impact from this provision is expected.
Guidance #4 - Anticipated Exposure in Range C (1.5-5 rem/yr.)
Exposures in excess of 1.5 rem/yr. are not anticipated at these types of facilities. This
is corroborated by recent experience at the case study reactor in which the highest
annual exposures were in the range of 0.5 to 0.75 rem. Nevertheless, the case study
facility abides by the proposed Range C supervision and monitoring guidance. A health
physicist is permanently assigned to the reactor facility. Any time that something is
taken out of the pool, the health physicist supervises the activity and performs
continuous monitoring. These procedures are believed to be typical of university
reactors.
NRC data for 1979 indicate that about one percent of monitored personnel in the
research reactor category, (includes university reactors, and privately owned research
reactors) received exposure in excess of one rem and most of this case probably below
1.5 rem. It is believed that if there are some exposures over 1.5 rem at university
reactors, they are few and could be lowered at little or no cost.
Guidance #5 - Anticipated Exposures in Range B (.5 - 1.5 rem/yr.)
University reactor facilities conform to the proposed guidance of Range B based on
data from the case study facility. Every proposed experiment is reviewed by the
Reactor Safety Committee. Moreover, as discussed above, facilities are often
monitored in conformance with the Range C guidance.
Guidance #6 - Training
In general it is believed that all University reactor personnel receive adequate training.
To the extent that quantitative measures of risk are not presented, they could be added
to the curriculum at little or no cost.
106
-------
Guidance #7 - Exposure to the Unborn
The case study facility is currently operating under a mandatory version of Alternative
a. It would not be difficult to amend the existing policy to conform with Alternative b.
This would state that a female of child-bearing age could voluntarily decide not to pull
samples out of the pool. This is the only activity that could potentially expose the fetus
in excess of 0.2 rem/mo. It would not be difficult to accommodate this degree of
flexibility, since only about 20 percent of operators are female.
If Alternative c were imposed, women of child-bearing age could not be hired as reactor
operators. This should not be an extreme hardship for the facility since sufficient
number of male operators are usually available. However, it would limit the potential
sources of support for females.
Some concern was expressed about the ability to estimate the committed dose
equivalent to the fetus from radionuclides taken into the body. It is assumed that the
NRC would provide some guidance, possibly as a Regulatory Guide, on the calculation
of internal exposure to the fetus. In any case, it is unlikely that internal exposures
would contribute significantly to fetal exposures at this facility. It is believed that
there would be no cost impact from this guidance.
Guidance #8 - Internal Exposure
There would be no impact at the case study facility, since no additional monitoring
would be required under normal operations. At present, routine bioassays are
performed at the reactor facility.
The Derived Air Concentrations (DAC's) for the radionuclides potentially encountered
at the reactor facility, primarily gamma and beta emitters, are largely unchanged under
the EPA guidelines. The levels of tritium in the air above the pool are well below the
detection limit (8 x 10~7^/_Ci/ml).
No new software or staff would be required at the case study facility for treatment of
internal exposures. Measurable intakes are infrequent and several well-qualified staff
and faculty members would be available to estimate the dose. Assuming this facility is
representative, no impact from this guidance is expected.
-------
Guidance #9 - Alternative Annual Whole-body Limit
A 1.5 rem/yr. limit would have no impact at the case study facility. Limits are
currently maintained nearly an order of magnitude below the proposed 5 rem annual
limit. At present, the Radiation Safety Committee must approve exposures in excess of
0.5 rem/yr. Only a couple of individuals have been exposed in excess of 0.5 rem/yr.
over the past two years at this facility, and their exposures have been less than 0.75
rem/yr. No activities at university reactors should require exposure above 1.5 rem per
year. Therefore no cost impact is anticipated.
12.3 SUMMARY OF COST OF COMPLIANCE
Little or no cost for compliance with the proposed guidance are anticipated.
108
-------
CHAPTER 13
COST OF COMPLIANCE; NUCLEAR PHARMACY
13.1 INDUSTRY PROFILE: NUCLEAR PHARMACIES
Nuclear pharmacies constitute a new industry that supplies nuclear medicine to
hospitals. Currently about half of all nuclear medicine is prepared by independent
pharmacies that did not exist 15 years ago. The independent pharmacy purchases
pharmaceutical remedies from small sources manufacturers (see Chapter 7) and
prepares unit doses that are delivered to hospitals ready for use with individual
patients. Due to recent consolidation this $60 million dollar industry is now dominated
by two firms who share the market equally. Both firms are aggressively marketing
their services in an attempt to expand beyond the major metropolitan areas where large
markets attracted the initial pharmacies. It is estimated that there are currently about
60 pharmacies with about 1,000 employees. Corporate plans for the dominate firms call
for opening about one additional pharmacy per month over the next several years.
Products and Services
Ninety percent of the radiopharmaceuticals consist of Tc-99m (eluted from a molyb-
denum generator) or Tc-99m tagged compounds. Most of the remainder are either
iodine-131 or xenon-133. A smattering of Tl-201, Ga-67, 1-123, Yb-169, Cr-151, and
In-111 is also handled. A typical pharmacy handles approximately five Curies per day
of Tc-99m and roughly 200 mCi of the others. Operations of both major firms are very
similar. A case study was conducted for one firm and the other was contacted by
phone.
13.2 COST OF COMPLIANCE WITH GUIDANCE
Guidance #1 - Annual Whole-body Limit - 5.0 rem/yr.
Whole-body exposures for this industry are extremely low. The case study firm did not
have an exposure in excess of 1 rem in 1981. Therefore, no impact from this provision
is expected.
109
-------
Guidance #2 - Accumulated Lifetime Exposure - 100 rem
Data from the case study firm and other sources indicate that currently no lifetime
exposures exceed 5 rem. Operation of these independent pharmacies should result in
exposure histories similar to or below in-hospital pharmacies where the data also
supports the assumption that no employees will approach the 100 rem lifetime limit.
Therefore, no cost impact is attributed to this guidance.
Guidance #3 - Exposure to Extremities and Organs
Some efforts are required to assure that hand exposures are maintained below 50
rem/yr. Continuing the relatively aggressive radiation protection programs instituted
by the two principal firms in this industry should be sufficient to control hand
exposures. The incremental costs to keep hand exposures under the revised limit should
be minimal.
There may actually be a cost benefit from the new extremity limits. Presently, in the
case study firm, the cost of personnel monitoring is $36,000/yr. Approximately $9,000
of this is from the weekly hand monitoring of 100 employees ($1.72/badge/week). If the
quarterly limit were dropped, monthly monitoring should suffice, providing a cost
savings of approximately $7,000. Also, the annual costs for analysis of exposure data is
estimated to be approximately $15,000. This would be reduced by approximately 50
percent if weekly monitoring were dropped. Procedures are similar for both firms and
thus these benefits would be assumed to accrue equally to both.
Guidance #4 - Anticipated Exposures in Range C (1.5 to 5 rem/yr)
Exposures in excess of 0.3 times an RPG are only possibly anticipated for the hands
(greater than 15 rem/yr.). At present, the average annual exposure to the hands in the
case study firm is 12 rem/yr. High doses to the hands are obtained by the dispensers
who "pull doses." However, full-time supervision and monitoring by a radiation
protection professional would not be required under the proposed guidelines because
there is no single task in which the contribution to the annual exposure is "significant."
These are repetitive tasks that accumulate dose in a uniform way over the entire year.
110
-------
Guidance #5 - Anticipated Exposure in Range B (0.5 - 1.5 rem)
The guidance for exposures in the range of 0.1 to 0.3 RPG describes the existing
program at both firms. Thus, there would be no impact from this guidance.
Guidance #6 - Training
The training program which is currently under development by the case study firm
satisfies the proposed guidance. By the time that the guidelines are formally proposed,
this training program will be well under way and it is believed a similar program will
also be in place for the other firm. Thus, no impact.
Guidance # 7 - Exposure to the Unborn
Approximately five percent of the dispensers and handlers of the case study firm are
female. All female employees are required to read NRC Regulatory Guide 8.13. The
case study firm suggested that if a female becomes pregnant, she would probably be
asked to take a leave of absence. Exposures to the fetus could probably not be
maintained below 500 mrem with certainty. If a handler were to become pregnant, she
would be kept out of the restricted area (no packing, just delivering). Whole-body
exposures to deliverers can easily be kept below 500 mrem over a nine-month period.
Therefore, the case study firm is currently operating under a mandatory version of
Alternative a, and it is believed that the other firm has a similar program.
It is possible, though unlikely, for a worker who milks generators or compounds
radiopharmaceuticals to receive a W.B. exposure in excess of 0.2 rem/mo. Thus, if
Alternative b or c were to be promulgated, women of child-bearing ages would be
precluded from doing these jobs. However, there are currently only about six women in
the case study firm who perform these jobs. Thus, the cost impact would be
inconsequential. However, these alternatives would pose substantial EEO problems.
Guidance # 8 - Internal Exposure
The two radioisotopes of concern from an internal exposure perspective are iodine-131
and xenon-133. Intakes of these isotopes are currently a very small fraction of the
proposed RIF's.
Ill
-------
If the proposed internal exposure guidance were to be promulgated, no additional
monitoring is expected to be required. However, the existing software would have to be
modified to convert the measurements to dose and to add the weighted organ dose to
the external exposure. It is estimated that the industry cost to develop the additional
software is approximately $30,000. Moreover, the operating costs for the dose tracking
systems, currently at approximately $30,000/yr. for the case study firm, would be
increased by an estimated 30 percent, or approximately $18,000 annually for the
industry.
Guidance #9 - Alternative Annual Whole-body Limit - 1.5 rem/yr.
The industry could operate within a 1.5 rem/yr. W.B. exposure limit with little or no
impact.
13.3 SUMMARY OF COST OF COMPLIANCE
This industry which has developed over the past decade is dominated by two firms. The
cost of compliance is estimated to be entirely concentrated in activities associated
with the upgrading of software to account for the changes in the internal exposure
guidance. Costs are expected to be about $20,000 per year.
112
-------
CHAPTER 14
COST OF COMPLIANCE; URANIUM MILL
14.1 INDUSTRY PROFILE: URANIUM MILL
As of January 1, 1982, 18 firms were operating 20 uranium mills with total employment
of approximately 2,400 workers. Industry output continues to contract in 1982 after a
decade of steady increase to a 1980 peak of 16,745 thousand tons of ore received. The
uncertain future of nuclear power and the current uranium surplus leaves the future of
this industry difficult to predict. For the purpose of this cost study we have assumed
that the 20 operating plants will continue to operate for the foreseable future. Further
contraction of the industry would reduce the estimated costs roughly in proportion to
lost capacity.
The industry currently consists of 20 operating uranium mills, located in western states
and accounts for 85% - 90% of natural U3Og production. These mills have a combined
rated capacity of about 54,000 tons of ore per day and an output of 21,000 tons per year
of yellowcake. Of these mills, 76 percent utilize conventional acid leach - solvent
extraction processes, and 10 percent utilize conventional alkaline leach processes.
Although record yellowcake production occurred during 1980, reports for 1981 indicate
a decline in production. For calendar year 1982, a greater decrease in production is
expected. During 1981, several of the larger mills curtailed their operations, while
others either shut down completely or temporarily closed down until such time as
demand for yellowcake catches up with supply. It is estimated that the workforce in
the industry has been reduced by about 60 percent because of this decreased demand.
14.2 COST OF COMPLIANCE WITH GUIDANCE
Guidance #1 - Annual Whole-body Limit - 5 rem/yr
No impact from this provision is expected with respect to external exposure. In 1979,
o
no exposures reported to NRC were in
workers had doses reported over 2 rem.
2
no exposures reported to NRC were in excess of 4 rem and only 4 of 1,500 monitored
Statistical Data of the Uranium Industry, U.S. Department of Energy, GSO-100(82),
January 1982.
2Op. cit., NRC, NUREG-0714.
113 *
-------
Guidance #2 - Accumulated Lifetime Limit - 100 rem
The case study firm indicated that this provision would have no impact, as no mill
employees would approach this limit. Some concern was expressed for mine, however,
this would not affect the mill unless mine workers shifted to the mill. Thus no impact
from this provision is expected.
Guidance #3 - Exposure to Extremities and Organs
Potential exists for high hand and skin exposure for scrap pickers who sift the ore as it
arrives at the mill, where a dose rate of 3 mrem/hr is expected. However, it is
expected, from the experience of the case study mill, that these exposures would be
less than ten percent of the new limit. Therefore, no impact from this provision is
expected.
Guidance #4 - Anticipated Exposures in Range C (1.5 to 5 rem/yr)
The average annual internal exposure in the precipitation and packaging area of the
case study mill is 1.62 rem. All other areas are less than 1.5 rem. About three percent
of case study employees monitored receive whole body exposures in excess of 1.5 rem.
The main impact from the proposed guideline would be due to the new internal exposure
limit. The solubility class for the Derived Air Concentrations for uranium inhalation is
a critical parameter for compliance in this industry. If the new guidelines on internal
exposures are imposed it would be difficult to maintain combined exposures significant-
ly below the limit. The difficulty in meeting the new internal limit is discussed later in
this chapter.
Potential internal exposures are monitored with a multiple air sampling system and
external exposures for all personnel are measured with TLD dosimeters. One senior
environmental engineer, one environmental technician and two industrial hygiene and
health physics technicians provide radiation protection services. It is anticipated that a
certified health physicist at a cost of $40,000 per year plus a 35 percent overhead
114
-------
burden would have to be employed in the precipitation and packaging area to comply
with the proposed Range C guidance. Assuming each of the 20 mills would have to hire
1.5 health physicists, the industry cost would be $1.1 million annually.
Guidance #5 - Anticipated Exposures in Range B (0.5 - 1.5 rem)
The case study mill is currently operating in full compliance with this proposed
guideline. All personnel wear TLD dosimeters to measure external exposures. Poten-
tial internal exposures are monitored with a multiple air sampling system. One senior
environmental engineer and two industrial hygiene and health physics technicians
maintain records on external sources of radiation and airborne concentrations at the
four mill operating areas, review health physics procedures and are available to monitor
during non-routine operations. It is assumed that other industry participants have a
similar structure and that no costs will result from this guidance.
Guidance #6 - Training
There would be no impact from the training requirements of the proposed guidelines,
since it is assumed that all new employees in the industry receive instruction in
radiation protection principles, as a result of the NRC or NRC Agreement State
license.
Guidance #7 - Exposure to the Unborn
Approximately eight percent of the personnel at the case study mill were females of
child-bearing age. However, there would be no impact from the proposed provision for
the embryo/fetus, since the present corporate policy follows NRC Regulatory Guide
8.13, 'Instruction Concerning Prenatal Radiation Exposure." Women are instructed to
inform their supervisors when they are diagnosed to be pregnant. As soon as the
supervisor is notified, the woman is removed from a high exposure job and is assigned to
a job in a non-controlled area. It is assumed that other mills currently follow
Regulation Guide 8.13 and therefore, there would be no impact from proposal a.
Alternatives b and c would result in females being denied positions. It is not
anticipated that this would result in any labor supply difficulty.
115
-------
Guidance #8 - Internal Exposures
Data from the case study mill indicates that the current average intakes in most areas
are higher than the Allowable Limit of Intake (ALD prescribed by ICRP-30 for insoluble
(Class Y) uranium 0.054 uCi.1 Therefore, in order to comply with the new standards,
the conservative assumption of total insolubility utilized by the case study mill and
assumed to be utilized by other mills would have to be relaxed. The DAC for soluble
uranium (Class D) is a factor of about 30 higher than that for insoluble uranium (Class
Y). It is estimated that using actual solubility fractions would lower the calculated
exposure by a factor of about 15. The justification for this relaxation would require
continual determination of the actual solubility fractions in the mill process areas.
Establishment of a routine system for measuring solubility fractions would take a
professional approximately six person-months of effort. Then routine monitoring of this
parameter is expected to take a technician approximately ten person-days each month.
(It is assumed that NRC would require continual routine monitoring of this parameter.)
The one time equipment cost for solubility fraction sampling is estimated by the case
study mill to be approximately $22,000. Additionally, laboratory support is estimated
to cost approximately $30,000 per year.
Particle size, determinations would also have to be made at approximately 10 locations
for a one-time equipment cost of $20,000, and would require one day per month of a
technician and one-half day per month of a professional. In addition, to provide
adequate monitoring, personal sampling pump assemblies would be required at a cost of
$9,000 for the case study firm. All particulate air samples would have to be analyzed
for isotopic content at a cost of $192,000 per year. (This includes personnel and
laboratory cost estimated by case study mill.)
The computer software and hardware used for the evaluation of personnel exposures
would also have to be upgraded. It is estimated that to modify the software,
approximately six man-months of a programmer would be required. Hardware costs of
$30,000 are estimated. Additionally, a full-time records clerk would have to be
employed at an annual cost of $16,200.
1Op. eft., ICRP-30.
116
-------
Table 37: Cost of Revised Internal Monitoring for a Large Mill
(Nominal Capacity 3,000 Tons Ore/Day)
Solubility Measurement System
- Professional for setup
- Technician for monitoring
- Monitoring equipment
- Laboratory support
Determination of Particle Size
- Monitoring equipment
- Professional analytic time
- Tech. data collection time
- Personal pump assemblies
- Isotopic Analysis
Unit
Cost
a
Initial Annual
6 pers./days/yr. $ 216
12 pers./days/yr. $ 108
20,000
9,000
.5 person/yrs. $54,000 $27,000
.5 person/yrs. $27,000 $13,500
22,000
30,000
1,296
1,296
192,000
Record-Keeping
- Programmer
- Hardware
- Records clerk
Total Cost
.5 person/yrs.
1 person/yr.
Includes a 35 percent mill overhead rate.
$34,000 17,000
30,000
16,200
$125,000 $254,292
The costs are summarized in Table 37. These estimates are based on data provided by
the case study firm, which operates a large facility. Many of the costs anticipated by
the mill will occur regardless of mill size (e.g., program set-up). Some costs are
expected to be a function of the age and size of the facility, number of workers and
expected capacity utilization. No data are available to develop specific cost estimates
for each of the 20 facilities currently operating. Therefore, the estimated cost for the
case study mill will be assumed for each of the seven larger facilities (nominal capacity
1
Op.cit., Statistical Data of the Uranium Industry
117
-------
greater than 3,000 tons of ore per day); half the case study costs will be assumed for
the seven midsized facilities (nominal capacity between 3,000 and 1,500 tons/day); and
one quarter of the case study mill costs will be assigned for the six small facilities
(nominal capacity less than 1,500 tons/day). Utilizing these assumptions, industry costs
are estimated to be approximately $1,500,000 in initial costs and $3,062,000 in
continuing annual costs.
Guidance #9 - Alternative Whole-body Limit - 1.5 rem/yr
The imposition of this alternative RPG would have a cost impact on the mill operations,
particularly in light of the reduced intake limits. It is reasonable to conclude that there
would be a problem in the precipitation and packaging area. In order to meet the
guideline it would probably require a process change; i.e., a change to a slurry process.
Moreover, it would possibly require additional people for health physics protection and
to demonstrate compliance with the guidance. No firm cost estimate was provided by
the case study mill and other data are not sufficient to develop a separate estimate.
Therefore, it is assumed that the costs of the 1.5 rem/year limit will be the same as
Range C requirements or $1.1 million annually.
14.3 SUMMARY OF COST OF COMPLIANCE
Impacts of the guidelines on the 20 currently operating uranium mills are expected to
be concentrated in Range C compliance and in internal exposure control, monitoring, and
recordkeeping. The addition of health physicists to the mill staff for compliance with
Range C is estimated to cost $1 million annually. The determination and monitoring of
particle size and solubility of materials and the development of a recordkeeping system
for these data are expected to cost the industry $1.5 million to establish and $3 million
annually to maintain. The alternate whole-body limit of 1.5 rem would result in costs
equal to the Range C compliance costs.
Two firms (Pathfinder Mines and Union Carbide) operate two facilities each and thus
could realize some economies in program development. However, such refinements are
considered beyond the accuracy of the aggregate cost estimates provided.
118
-------
CHAPTER 15
COST OF COMPLIANCE; URANIUM CONVERSION PLANT
15.1 INDUSTRY PROFILE: URANIUM CONVERSION
This industry is comprised of two facilities that utilize distinctly different production
processes. One plant produces uranium hexafluoride (UF-) with a complex wet
chemistry process at a rated output of 10,000 MT/yr and employs 160 people. The plant
operates three shifts per day, seven days per week. The other conversion plant in
operation utilizes a dry process and has a rated output of 14,000 MT/yr of UFfi. The
raw material is uranium concentrate (yellowcake) and some yellowcake slurry is
received from all uranium mills in the country. Both plants, due to the reduced demand
for uranium in the nuclear power industry, are currently operating at reduced capacity.
The distinct production processes selected by these two plants will result in some
unique radiation protection problems. However, a case study was conducted for only
one facility. The personal at the case study facility indentified some of these
differences, but felt that the total cost of compliance for the other facility would
probably be similar to the cost for their facility. Hence we have utilized the cost
estimates from the case study facility and applied them to the other facility to
estimate industry impacts. Refinement of these estimates would be possible through an
additional case study.
15.2 COST OF COMPLIANCE WITH GUIDANCE
Guidance #1 - Annual Whole-body Limit - 5 rem/yr
The revised limit is not expected to have an impact on this industry, at least with
respect to external exposures. The highest whole body exposure in 1981 at the case
study facility was less than one rem. Exposures reported to NRC for the industry
category that includes these facilities were all less than 3 rem.
JOp. eft., NRC, NUREG-0714.
119
-------
Guidance #2 Accumulated Lifetime Expsoure - 100 Rem
The reduction of the accumulated exposure limit to 100 rem is not expected to have a
cost impact at this plant. The highest accumulated exposure for plant personnel is
considerably lower than the 100 rem limit.
Guidance #3 - Exposure to Extremities and Organs
No activities at the case study facility that would result in high extremity exposure
were identified. Therefore, no impact is expected from the revised extremity limits
other than some relatively low cost periodic extremity monitoring.
Guidance #4 - Anticipated Exposures in Range C (1.5 - 5 rem)
The whole-body exposures of all plant personnel at the case study plant have been
maintained at less than 1.0 rem for the years 1979, 1980, and 1981, except for one
employee in 1980. The main impact from the proposed guideline would be due to the
new internal exposure limit. Some plant workers would be potentially exposed to
airborne concentrations in excess of the revised insoluble uranium limit (RPG IxlO"11
uCi/me). The average annual exposures for the case study plant in each of the five
process areas would range from 1.4 to 2.3 times the insoluble uranium limit for the year
1981. If the new guidance on internal exposures were to be imposed, it would be
difficult to maintain combined exposures significantly below the limit. The difficulty in
meeting the new internal limit is discussed later in this chapter.
Potential internal exposures are monitored by means of an extensive air sampling
system in which 45 sampler heads are connected to a central vacuum and the filters
changed after each eight-hour shift. The manager of Health Physics and Industrial
Safety and five health physics technicians provide radiation protection services at the
plant. It is anticipated that a certified health physicist, at a cost of $40,000 per year,
would have to be employed to provide radiation protection, supervision in the plant
areas in order to comply with the proposed Range C guidance. At an overhead factor of
1.35, a cost of $108,000 per year would be incurred by the industry.
120
-------
Guidance #5- Anticipated Exposures in Range B (0.5 - 1.5 rem)
The case study plant is currently operating in full compliance with this proposed
guidance. All personnel wear film badges to measure external exposures. Potential
internal exposures are monitored with an extensive air sampling system. The manager
of Health Physics and Industrial Safety and five health physics technicians maintain
records on external sources of radiation and airborne concentrations in the six plant
areas, and are available to monitor during non-routine operations. These professionals
are expected to assure that exposures are justified and are ALARA.
Guidance #6 - Training
The existing training program satisfies the proposed guidance on training.
Guidance #7 - Exposure to the Unborn
At present, approximately 19 percent of the plant employees are females of child-
bearing age. Presently the corporation management conforms to the policy as
described in Regulatory Guide 8.13, "Instruction Concerning Prenatal Radiation Ex-
posure." Accordingly, there is not expected to be a cost impact from Alternative a of
the guidance for protection of the unborn. The proposed Alternative b is not considered
to be a viable alternative at this plant since pregnant women are assigned to non-
radiation areas. Alternative c might result in women not being considered for certain
jobs, but neither have would result in cost impacts.
Guidance #8 - Internal Exposure
The current approach at the case study facility is to calculate time-weighted average
exposure concentrations (TWA) based on mesured airborne concentrations of uranium
and work location cards. The TWA is calculated for each person that routinely works in
a process area and is recorded as a fraction of the MPC. Internal doses are not
estimated unless the calculated airborne exposure is greater than 40 MPC-hrs/week for
soluble uranium and 520 MPC-hrs/qtr. for insoluble uranium. These exposures are
verified using the bioassay procedures described in the case study report and the results
are recorded along with MPC-hrs. Measured external exposures obtained from the film
badge readings are not currently added to the estimated internal exposures. A
121
-------
computer program at the plant is currently in place which provides output data for
determining compliance with existing regulation.
Workers are potentially exposed to airborne concentrations in excess of the revised
insoluble uranium limit (DAC of 2 x 10 uCi/ml). For 1981, the average annual
personnel exposures in each of the five process areas in the case study facility range
from approximately 0.7 to 1.2 times the insoluble uranium DAC. The approach to
compliance with the revised limits would require the calculation of potential exposure
to uranium for each worker. The conservative assumptions currently made would have
to be relaxed. In particular, measured particle sizes and solubilities would be used in
the calculations.
Particle size distributions in air are presently not available for the facility. It is
estimated that using actual measured particle size distributions would reduce calcu-
lated potential exposures by about 20 to 30 percent. Larger gains are potentially
available from the use of measured solubility factors.
Determination of actual solubility fractions could lead to the relaxation of the
conservative assumption of total insolubility (Class Y). The MFC's for soluble uranium
are a factor of about 30 higher than those of insoluble uranium. It is estimated that
using actual solubility class (i.e., Class W solubility) would lower the calculated
potential exposures by about a factor of fifteen (i.e., Class Y to Class W).
Establishment of a routine system for measuring solubility fractions would take a
professional approximately six person-months of effort. Then routine monitoring of this
parameter is expected to take a technician approximately ten person-days each month.
(It is assumed that NRC would require continual routine monitoring of this parameter.)
The one time equipment cost for solubility fraction sampling is estimated by the case
study plant to be approximately $22,000. Additionally, laboratory support is estimated
to cost approximately $30,000 per year.
Particle size determinations would also have to be made at approximately 10 locations
for a one-time equipment cost of $20,000, and would require one day per month of a
technician and one-half day per month of a professional. In addition, to provide
adequate monitoring, personal sampling pump assemblies would be required at a cost of
$9,000 for the case study firm. All particulate air samples would have to be analyzed
JOp. eft., ICRP-30. '122
-------
for isotopic content at a cost of $192,000 per year. (This includes personnel and
laboratory cost estimated by case study plant.)
The computer software and hardware used for the evaluation of personnel exposures
would also have to be upgraded. It is estimated that to modify the software,
approximately six man-months of a programmer would be required. Hardware costs of
$30,000 are estimated. Additionally, a full-time records clerk would have to be
employed at an annual cost of $16,200.
Table 38: Cost of Revised Internal Monitoring for a
UFg Conversion Facility
Solubility Measurement System
- Professional for setup
- Technician for monitoring
- Monitoring equipment
- Laboratory support
Unit
a
Cost Initial Annual
.5 person/yrs. $54,000 $27,000
.5 person/yrs. $27,000 $13,500
22,000
30,000
Determination of Particle Size
- Monitoring equipment
- Professional analytic time
- Tech. data collection time
- Personal pump assemblies
- Isotopic analysis
6 pers./days/yr. $ 216
12 pers./days/yr. $ 108
20,000
9,000
1,296
1,296
192,000
Record-Keeping
- Programmer
- Hardware
- Records clerk
Total Cost
alncludes a 35 percent overhead rate.
.5 person/yrs. $34,000 17,000
30,000
1 person/yr. 16,200
$125,000 $254,292
123
-------
While there is some uncertainty as to the costs for the other plant, it is anticipated that
it also will have to undergo changes in the calculation procedures to show compliance
with the internal dose revisions to the guidance. Therefore, as a crude estimate, total
costs for the industry are expected to be approximately double the one plant cost or
$250,000 initially and $500,000 annually.
Guidance #9 - Alternative Whole-body Limit - 1.5 rem/yr.
The imposition of this alternative limit would have a cost impact on the conversion
plant operations, given the parallel imposition of the reduced intake limits. There
would probably have to be process changes and/or increased confinement on certain
operations. Moreover, considerably more effort would have to be expended on this
radiation protection program. No data are available to calculate such costs. There-
fore, the cost of compliance with Range C will be utilized as $108,000.
15.3 SUMMARY OF COST OF COMPLIANCE
Only two uranium conversion facilities currently operate in the U.S. Impacts from the
Range C requirements are estimated to cost the industry $100,000 per year for the
expansion of the health physics staff. The development of a particle size and solubility
monitoring and recording system to comply with the internal exposure guidance is
expected to cost the industry $250,000 initially and $500,000 annually.
124
-------
CHAPTER 16
COST OF COMPLIANCE; OTHER INDUSTRIES
16.1 INDUSTRY PROFILE: OTHER INDUSTRIES
Education
According to the 1975 survey, there were an estimated 111,600 individuals (including
89,800 students) potentially exposed in this category, 37,200 of which (including 30,000
students) received measurable exposures. Of the 18,253 individuals monitored in 1978
by NRC academic licensees (388 of them), only 76 (0.4%) received exposures in excess
of 1.0 rem and 223 (1.2%) were exposed in excess of 0.5 rem. Therefore the impacts of
the Range C requirements, and possibly even those of Range B, as well as the
alternative guidelines relating to exposure of the unborn, are expected to be minimal.
The only significant cost might be for training of students and staff.
Private Medical Other Than Radiologists
Other than the practice of radiology (including nuclear medicine), occupational ex-
posure occurs in practices operating their own X-ray machines. Included are podiatry,
chiropractic medicine, and veterinary medicine (as well as orthopedics, gastroenter-
ology, urology, and pediatrics. According to the 1975 survey, there were 42,800
workers in podiatry, chiropratic medicine, and veterinary medicine with 12,000 of them
receiving measurable exposures. With the exception of veterinary medicine, exposures
should be in Range A if equipment is operating properly and procedures are followed.
Under these conditions, the only element of the proposed guidelines that could impose a
cost is that of training, since it is unlikely that the workers in these offices are
uniformly instructed in the principles of radiation protection or on levels of risk.
However, approximately 3% of recorded annual whole-body exposures in veterinary
medince were in excess of 0.5 rem in 1975. Therefore, Range B exposures are
anticipated in this industry. This would require monitoring by part-time health
physicists at each veterinary practice. According to the 1979 Census, there were
10,403 veterinary establishments in 1978.
LOp. cit. EPA, 1980, EPA 520/4-80-001.
125
-------
Users of Industrial Gauges
This category potentially involves a very large number of firms; however, the impact of
the proposed guidelines, with the possible exception of the training requirements, is
expected to be small. In 1978, there were 2555 NRC licensees in this category ("Other
Measuring Systems"), with possibly an equal number of Agreement State licensees. The
average number of monitored workers per NRC licensee was approximately nine. Only
0.2% of those monitored received annual exposures in excess of 1.0 rem, and less than
0.6% received annual exposures in excess of 0.5 rem. Therefore, the impacts from
Range B and C requirements, and from the exposure to unborn alternatives, are
expected to be minimal.
Operators of Irradiators
In 1978, there were 228 firms licensed by the NRC to operate irradiators, 53 of which
possessed sources in excess of 10,000 Ci. It may be assumed that there were an equal
number of Agreement State irradiator licensees. The average number of monitored
workers per NRC license was approximately 17. Of the workers monitored by NRC
licensees, only about 24% received measurable exposures. Furthermore, only approxi-
mately 0.5 percent received annual exposures in excess of 1.0 rem and roughly 1.3%
were exposed to more than 0.5 rem per year. Therefore, the Range, C, Range B, and
exposure to the unborn requirements would be expected to have minimal impact. It is
expected that most employees of irradiator licensees already receive instruction in
radiation protection principles, although instruction in levels of risk is probably not
generally included.
Transportation
According to the 1975 Survey, there were 77,000 workers potentially exposed to
ionizing radiation in the transportation category, approximately 12,000 of which
received measurable exposures. The average exposure was low, approximately 0.030
rem. However, there may be as many as 500 independent truck drivers who ship
radiopharmaceuticals and receive doses in excess of 0.5 rem per year. Some of these
truck drivers may even receive exposures in Range C. It is unlikely that a significant
number of these truck drivers are female. It is also unlikely that a significant number
of individuals the transportation category currently obtain instruction in radiation
protection principles or levels of risk. In summary, there certainly would be compliance
costs in transportation. At this time, however, sufficient information is not available
to estimate the magnitude of the impact of the guidance.
126
-------
APPENDIX A
Reprint from Federal Register - 5/18/60
Federal Register - 1/23/81
127
-------
4402
Reprint from Federal Register - 5/18/60
FEDERAL RADIATION COUNCIL
RADIATION PROTECTION GUIDANCE
FOR FEDERAL AGENCIES
AAemoremdum for the President
Pursuant to Executive Order 10831 and
Public Law 86-373, the Federal Radia-
tion Council has made a study of the
hazards and use of radiation. We here-
with transmit our first report to you
concerning our findings and our recom-
mendations for the guidance of Federal
agencies in the conduct of their radia-
tion protection activities.
It is the statutory responsibility of the
Council to "* * * advise the President
with respect to radiation matters, di-
rectly or indirectly affecting health,
including guidance for all Federal agen-
cies in the formulation of radiation
standards and in the establishment and
execution of programs of cooperation
with States * * *"
Fundamentally, setting basic radiation
protection standards involves passing
judgment on the extent of the possible
health hazard society is willing to accept
in order to realize the known benefits
of radiation. It involves inevitably a
balancing between total health protec-
tion, which might require foregoing any
activities increasing exposure to radia-
tion, and the vigorous promotion of the
use of radiation and atomic energy in
order to achieve optimum benefits.
The Federal Radiation Council has
reviewed available knowledge on radia-
tion effects and consulted with scientists
within and outside the Government.
Each member has also examined the
guidance recommended in this memo-
randum in light of his statutory responsi-
bilities. Although the guidance does not
cover all phases of radiation protection,
such as internal emitters, we find that
the guidance which we recommend that
you provide for the use of Federal agen-
cies gives appropriate consideration to
the requirements of health protection
and the beneficial uses of' radiation and
atomic energy. Our further findings and
recommendations follow.
Discussion. The fundamental problem
In establishing radiation protection
guides is to allow as much of the bene-
ficial uses of ionizing radiation as pos-
sible while assuring that man is not
exposed to undue hazard. To get a true
insight into the scope of the problem
and the impact of the decisions involved,
a review of the benefits and the hazards
is necessary.
It is important in considering both the
benefits and hazards of radiation to ap-
preciate that man has existed through-
out his history in a bath of natural
radiation. This background radiation,
which varies over the earth, provides a
partial basis for understanding the ef-
fects of radiation on man and serves as
an indicator of the ranges of radiation
exposures within which the human popu-
lation has developed and increased.
The benefits of ionizing radiation.
Radiation properly controlled is a boon
to mankind. It has been of inestimable
value in the diagnosis and treatment of
diseases. It can provide sources, of
energy greater than any the world has
yet had available. In industry, it is used
as a tool to measure thickness, quantity
or quality, to discover hidden flaws, to
trace liquid flow, and for other purposes.
So many research uses for ionizing radia-
tion have been found that scientists in
many diverse fields now rank radiation
with the microscope in value as a work-
ing tool.
The hazards of ionizing radiation.
Ionizing radiation involves health haz-
ards just as do many other useful tools.
Scientific findings concerning the bio-
logical effects of radiation of most im-
mediate interest to the establishment of
radiation protection standards are the
following:
1. Acute doses of radiation may pro-
duce immediate or delayed effects, or
both.
2. As acute whole body doses increase
above approximately 25 rems (units of
radiation dose), immediately observable
effects increase in severity with dose,
beginning from barely detectable
changes, to biological signs clearly indi-
cating damage, to death at levels of a
few hundred rems.
3. Delayed effects produced either by
acute irradiation or by chronic irradia-
tion are similar in kind, but the ability of
the body to repair radiation damage is
usually more effective in the case of
chronic than acute irradiation.
4. The delayed effects from radiation
are in general indistinguishable from,
familiar pathological conditions usually
present in the population.
5. Delayed effects include genetic
effects (effects transmitted to succeeding
generations), increased incidence of
tumors, lifespan shortening, and growth
and development changes.
6. The child, the infant, and the un-
born infant appear to be more sensitive
to radiation than the adult.
7. The various organs of the body differ
in their sensitivity to radiation.
8. Although ionizing radiation can in-
duce genetic and somatic effects (effects
on the individual during his lifetime
other than genetic effects), the evidence
at the present time is insufficient to jus-
tify precise conclusions on the nature of
the dose-effect relationship at low doses
and dose rates. Moreover, the evidence
is insufficient to prove either the hypoth-
esis of a "damage threshold" (a point
below which no damage occurs) or the
hypothesis of "no threshold" in man at
low doses.
9. If one assumes a direct linear rela-
tion between biological effect and the
amount of dose, it then becomes possible
to relate very low dose to an assumed
biological effect even though it is not de-
tectable. It is generally agreed that the
effect that may actually occur will not
exceed the amount predicted by this
assumption.
Basic biological assumptions. There
are insufficient data to provide a firm
basis for evaluating radiation effects for
all types and levels of irradiation. There
is particular -uncertainty with respect to
the biological effects at very low doses
and low-dose rates. It is not prudent
therefore to assume that there is a level
of radiation exposure below which there
is absolute certainty that no effect may
occur. This consideration, in addition
to the adoption of the conservative hy-
pothesis of a linear relation between bio-
logical effect and the amount of dose,
determines our basic approach to the
formulation of radiation protection
guides.
The lack of adequate scientific infor-
mation makes it urgent that additional
research be undertaken and new data
developed to provide a firmer basis for
evaluating biological risk. Appropriate
member agencies of the Federal Radia-
tion Council are sponsoring and encour-
aging research in these areas.
Recommendations. In view of the
findings summarized above the following
recommendations are made:
It is recommended that:
1. There should not be any man-made
radiation exposure without the expecta-
tion of benefit resulting from such ex-
posure. Activities resulting in man-made
radiation exposure should be authorized
for useful applications provided in rec-
ommendations set forth herein are
followed.
It is recommended that:
2. The term "Radiation Protection
Guide" be adopted for Federal use. This
term is defined as the radiation dose
which should not be exceeded without
careful consideration of the reasons for
doing so; every effort should be made to
encourage the maintenance of radiation
doses as far below this guide as
practicable.
It is recommended that:
3. The following Radiation Protection
Guides be adopted for normal peacetime
operations:
Tyre of exposure
Rfldiatlon worker:
(a) Whole body, bond and trunk, active blood form-
ing organs, gonads, or lens of eye.
(b) Skin of whole body and thyroid
(c) Hands and forearms, feet and ankles
(d) Bone
Population:
(a) Individual ;.
Condition
[Accumulated dose
1 13 weeks
/Year
\13wecks
lYcar
\13 weeks
Body burden
[Year
U3 weeks . . _
Year
Dose (rcm)
fi times the number of years beyond
age IS.
30.
10.
75.
25.
0.1 microeram of radtum-22fi or ils
biological equivalent.
5.
0.6 (whole body).
The following points are made in re-
lation to the Radiation Protection
Guides herein provided:
<1) For the individual in the popula-
tion, the basic Guide for annual whole
body dose is 0.5 rem. This Guide ap-
128
-------
Wednesday, May 18, 1960
FEDERAL REGISTER
4403
plies when the individual whole body
doses are known. As an operational
technique, where the individual whole
body doses are not known, a suitable
sample of the exposed population should
be developed whose protection guide for
annual whole body dose will be 0.17 rem
per capita per year. It is emphasized
that this is an operational technique
which should be modified to meet spe-
cial situations.
(2) Considerations of population ge-
netics impose a per capita dose limitation
for the gonads of 5 rems in 30 years.
The operational mechanism described
above for the annual individual whole
body dose of 0.5 rem is likely in the im-
mediate future to assure that the go-
nadal exposure Guide (5 rem in 30
years) is not exceeded.
(3) These Guides do not differ sub-
stantially from certain other recom-
mendations such as those made by the
National Committee on Radiation Pro-
tection and Measurements, the National
Academy o'f Sciences, and the Interna-
tional Commission on Radiological
Protection.
(4) The term "maximum permissible
dose" is used by the National Committee
on Radiation Protection (NCRP) and
the International Commission on Ra-
diological Protection (ICRP). However,
this term is often misunderstood. The
words "maximum" and "permissible"
both have unfortunate connotations not
Intended by either the NCRP or the
ICRP.
(5) There can be no single permissible
or acceptable level of exposure without
regard to the reason for permitting the
exposure. It should be general practice
to reduce exposure to radiation, and pos-
itive effort should be carried out to ful-
fill the sense of these recommendations.
It is basic that exposure to radiation
should result from a real determination
of its necessity.
(6) There can be different Radiation
Protection Guides with different numer-
ical values, depending upon the circum-
stances. The Guides herein recom-
mended are appropriate for normal
peacetime operations.
(7) These Guides are not intended to
apply to radiation exposure resulting
from natural background or the pur-
poseful exposure of patients by practi-
tioners of the healing arts.
(8) It is recognized that our present
scientific knowledge does not provide a
firm foundation within a factor of two
or three for selection of any particular
numerical value in preference to another
value. It should be recognized that the
Radiation Protection Guides recom-
mended in this paper are well below the
level where biological damage has been
observed in humans.
It is recommended that:
4. Current protection guides used by
the agencies be continued on an interim
basis for organ doses to the population.
Recommendations are not made con-
cerning the Radiation Protection Guides
for individual organ doses to the popu-
lation, other than the gonads. Unfor-
tunately, the complexities of establishing
guides applicable to radiation exposure
of all body organs preclude the Council
from making recommendations concern-
ing them at this time. However, current
protection guides used by the agencies
appear appropriate on an interim basis.
It is recommended that:
5. The term "Radioactivity Concen-
tration Guide" be adopted for Federal
use. This term is defined as the concen-
tration of radioactivity in the environ-
ment which is determined to result in
whole body or organ doses equal to the
Radiation Protection Guide.
Within this definition, Radioactivity
Concentration Guides can be determined
after the Radiation Protection Guides
are decided upon. Any given Radioac-
tivity Concentration Guide is applicable
only for the circumstances under which
the use of its corresponding Radiation
Protection Guide is appropriate.
It is recommended that:
6. The Federal agencies, as an interim
measure, use radioactivity concentration
guides which are consistent with the rec-
ommended Radiation Protection Guides.
Where no Radiation Protection Guides
are provided, Federal agencies continue
present practices.
No specific numerical recommenda-
tions for
-------
Friday
January 23, 1981
Part XV
Environmental
Protection Agency
Federal Radiation Protection Guidance
for Occupational Exposures
130
-------
7836
Federal Register / Vol. 46, No. 15 / Friday, January 23,1981 / Notices
[RH-FRL 1722-5]
Federal Radiation Protection Guidance
for Occupational Exposures; Proposed
Recommendations, Request for
Written Comments, and Public
Hearings
AGENCY: U.S.'Environmental Protection
Agency.
ACTION: Proposed recommendations for
radiation protection of workers.
SUMMARY: We are proposing to make
recommendations to the President for
new guidance to Federal agencies for
the protection of workers exposed to
ionizing radiation. These proposals are
based on a review of existing guidance
in the light of scientific knowledge of
radiation risks and of experience in the
control of occupational exposure. The
proposed recommendations Include both
qualitative guidance on radiation
protection and numerical guides for
maximum allowed dose equivalents
(RPG's'). The most significant changes
proposed are (a) that a graded set of
minimum radiation protection
requirements be introduced in three
levels; (b) that the RPG for maximum
whole-body dose equivalent be reduced
from three rem * per quarter to five rem
per year, and that regulatory agencies
establish lower limits for specific types
of work situations; (c) that limitation of
internal doses 3 take into account the
sum of the risks to all organs, rather
than continue to be based only on the
most significantly exposed organ; (d)
that the RPGs for the whole body apply
to the appropriately weighted sum of the
doses from both internal and external
exposures; and (e) that the dose to the
embryo and the fetus be limited through
one of several alternative
recommendations.
We welcome written comments on
these proposals and will hold public
hearings as discussed below. We will
carefully consider all oral and written
comments in preparing our final
recommendations to the President.
DATES: 1. All written comments in
response to this notice must be received
' by us by April 24, 1981, in order to be
used.
2. Public hearings will be held at the
following locations, beginning no earlier
'Radiation Protection Guides.
'A rod is a unit of measure for dose, i.e.. the
amount of ionizing radiation energy absorbed per
unit weight of tissue. Thus, the same energy
absorbed by twice as much tissue gives only one-
half the number of rads. The rem, a unit for dose
equivalent, is a rad multiplied by factors which
describe how damaging the type of radiation is.
*ln this notice we henceforth use "dose" to mean
"dose equivalent."
than 60 days following*publication of
this notice: Washington, D.C., Chicago,
Illinois. San Francisco, California,
Houston, Texas. We will publish the
times and addresses for these hearings
shortly.
3. Instructions of interest to those who
wish to appear at the public hearings
are given below under the heading
"Public Hearings."
ADDITIONAL INFORMATION: We will be
happy to send a gopy of a background
report which provides additional
information on these proposed
recommendations to anyone requesting '
it. Please send requests to Mr. Luis F.
Garcia at the address below. This report
is also available for inspection and
copying at EPA's Central Docket Section
and ten Regional Offices (addresses
below).
ADDRESSES: Written comments should
be addressed to the Director, Criteria
and Standards Division (ANR-460), U.S.
Environmental Protection Agency,
Washington, D.C. 20460, Attention:
Docket No. A-79-46. These comments
and the public hearing record will be
filed under the above docket number
and will be available for inspection and
copying at the U.S. Environmental
Protection Agency's Central Docket
Section, Room 2903B, Mall 401 M Street.
S.W., Washington, D.C. 20460, and at the
Agency's library in each of its ten
regional offices: Region I: JFK Building,
Room 2100-B; Boston, Massachusetts
02203 [Tel. 617-223-5791); Region IL 28
Federal Plaza, Room 1002, New York,
New York 10278 (Tel. 212-264-2881);
Region III: Curtis Building. 6th & Walnut
Streets, Philadelphia, Pennsylvania
19106 (Tel. 215-597-0580); Region IV: 345
Courtland Street, N.E., Atlanta, Georgia
30365 (Tel. 404-881-4216); Region V: 230
South Dearborn Street, Room 1417,
Chicago, Hlinois 6OW4 (Tel. 312-353-
2022); Region VI: First International
Buildinc, 12ni Elm Street, 28th Floor,
Dallas, Texas 75270 (Tel. 214-767-7341);
Region VII: 324 East llth Street, Kansas
City, Missouri 64106 (Tel. 816-374-3497);
Region VIII: Radiation Program Office
(in lieu of library), 1860 Lincoln Street,
Second Floor, Denver, Colorado 80203
(Tel. 303-837-2221); Region IX: 215
Fremont Street, 6th Floor, San Francisco,
California 94105 (Tel. 415-556-1841:
Region X: 1200 Sixth Avenue, 12th Floor,
Seattle, Washington 98101 (Tel. 206-442-
1289).
FOR FURTHER INFORMATION CONTACT:
Contact Mr. Luis F. Garcia, U.S.
Environmental Protection Agency
(ANR-460), Washington, D.C. 20460 ,
(Telephone 703-557-8224), about these
proposed recommendations or the
public hearings.
SUPPLEMENTARY INFORMATION:
Statutory Authority
The Administrator of the
Environmental Protection Agency (EPA)
is charged under Executive Order 10831,
Reorganization Plan No. 3 of 1970, and
Public Law 86-373 to "* * * advise the
President with respect to radiation
matters, tlirectly or indirectly affecting
health, including guidance for all
Federal agencies in the formulation of
radiation standards and in the
establishment and execution of
programs of cooperation with States."
This guidance has historically taken the
form of qualitative and quantitative
"Radiation Protection Guidance." The
recommendations we propose here
would replace those portions of existing
Federal guidance that apply to radiation
protection of workers, which were
adopted in 1980 (25 FR 4402).
Previous Actions by EPA
We began this review of the 1960
radiation protection guidance for
workers in 1974. The most recent notice
of this activity listed the principal issues
being addressed and announced our
intent to hold public hearings on
proposed recommendations (44 FR
53785, Sept 17,1979).
We have sponsored two major studies
in support of this program. First, the
Committee on the Biological Effects of
Ionizing Radiations, National Academy
of SciencesNational Research Council,
has reviewed the scientific data on the
health risks of low level ionizing
radiation developed since its 1972
report. Second, we have carried out a
study of occupational radiation
exposures and published our findings in
a report entitled: "Occupational
Exposure to Ionizing Radiation in the
United States: A Comprehensive
Summary for the Year 1975." We have
also considered recent
recommendations of the National
Council on Radiation Preelection and
Measurements.
In developing these proposals, we
have also consulted with the technical
staffs of the Federal agencies that
regulate or influence the regulation of
occupational exposure, and will
continue this consultation in developing
final recommendations. These agencies
are the Occupational Safety and Health
Administration, the Nuclear Regulatory
Commission, the Mine Safety and
Health Administration, the Department
of Defense, the Department of Energy,
the Department of Transportation, the
Food and Drug Administration, the
National Aeronautics and Space
Administration, the National Institute
for Occupational Safety and Health, and
131
-------
Federal Register / Vol. 46, No. 15 / Friday. January 23. 1981 / Notices
7837
the National Bureau of Standards. These
agencies, which have not formally
endorsed these recommendations, will
formally review final proposals when
they are developed following public
review.
Issues Addressed
The principal issues we addressed in
formulating these recommendations
were identified in the advance notice
cited above. They were:
1. Are the doses currently received by
workers and the maximum doses
permitted under existing guidance
adequately low? In this regard, a) how
adequate is the basis used for estimating
risks to health from radiation exposure,
and b) what are the appropriate bases
for judging maximum individual and
collective radiation doses in the work
force and the tradeoffs between these
two indices of the health impact of
occupational exposure?
2. Should the same guides apply to all
categories of workers (e.g., dental
workers, nuclear medicine technicians,
nuclear maintenance personnel,
industrial radiographers)? Should
specific guides be developed for
pregnant women, female workers who
could bear children, and/or men?
3. On what time basis should the
guides be expressed? Quarterly?
Annual? Should the lifetime
occupational dose be limited? Should
the age of the worker be a factor?
4. Should the guidance reflect or cover
medical, accidental, and/or emergency
exposures?
5. is existing guidance for situations
that involve exposure of less than the
whole body adequate? In this respect, a)
what organs and parts of the body
should have designated limits, and b) on
what basis should guidance be
expressed for exposure of more than one
organ or portion of the body?
6. How should the radiation protection
principles requiring a) justification of
any exposure, and b) reduction of the
dose from justified exposures to the
lowest practicable or as low as is
reasonably achievable level be applied
to exposure of workers? Should the
concept of lowest feasible level be
applied to exposure of workers?
7. What, if any. relationship should be
maintained between permissible levels
of risk to health from radiation exposure
and other regulated hazards of disease
or accidents?
Additional issues suggested since
publication of the advance notice
include:
8. Should the guidance include
lumerica! values for the factors (called
quality" and "modifying" factors) used
i convert dose (measured in rads) to
dose equivalent (measured in rem)? If
so, should this be developed now or
issued later as supplementary guidance?
9. What guidance should apply to
workers who do not use radiation
sources, but who are exposed to
radiation due to the activities of workers
under the control of other employers?
10. Are there situations that may
require doses higher than normally
permitted? Should we provide special
guidance for them?
Many of these issues are addressed
below. However, for a more complete
and extensive discussion please refer to
the background report cited above under
the heading "Additional Information."
Risks From Occupational Exposure
There are three kinds of risks from the
low levels of ionizing radiation
characteristic of occupational
exposures. The most important of these
is cancer, which is fatal at least half the
time. Another risk is the induction of
hereditary effects in descendants of
exposed persons. The severity of these
effects ranges from fatal to
inconsequential. We assume that at low
levels of exposure the risk of cancer and
hereditary effects is in proportion to the
dose received, and that the severity of
any induced effect is independent of the
dose level. That is, while the probability
of a given type of cancer occurring
increases with dose, such a cancer
induced at one dose is equally as
debilitating as that same type of cancer
induced at another dose. Thus, for these
effects we assume that there is no
completely risk-free level of radiation
exposure.
The third type of risk includes a
variety of other effects on workers and
on the children of women exposed
during pregnancy. These effects range
from serious effects on children, such as
mental retardation, to less serious
effects on workers, such as opacification
of the lens of the eye and temporary
impairment of fertility. For these effects
we believe the degree of damage (i.e.,
the severity) depends to some extent on
the dose level. At the dose levels
allowed by current radiation protection
guides, we believe that none of the
effects on workers themselves occurs to
a degree sufficient to be clinically
detectable. At these levels, however,
effects on children exposed in utero may
be serious.
The risks of effects on health from low
level ionizing radiation were reviewed
for EPA by the National Academy of
Sciences (NAS) in reports published in
1972 and in 1980. We have used these ,
studies and others to estimate the risks
associated with the current and
proposed Federal guides for limiting
radiation dose. Details of Ihese and
other risk estimates we use are provided
in the accompanying background
report.4
A worker who received the largest
lifetime dose allowed under present
guides (5 rem per year from age 18 to
assumed retirement at age 65, or 235
rem) would have a lifetime risk of about
3 to 6 in 100 of dying from radiation-
induced cancer, and numerically
comparable chances both of nonfatal
cancer and, for male workers, of
mutational effects in his descendants.5
Risks of mutational effects from
exposure of female workers are
assumed to be three to four times
smaller. However, in our recent national
survey of exposures for the year 1975,
99% of all workers received less than
half of, and only 0.15% exceeded, an
annual dose of 5 rem. Based on these
and other data, we believe that only a
few workers involved in accidents have
received close to the current maximum
allowed lifetime dose.
The average worker exposed to
radiation sustains only a small risk of
death from radiation. The estimated
average risk of death due to radiation-
induced cancer is smaller, for example,
than the risk of job-related accidental
death in the safest of all major
occupational categories, retail trades,
for which the annual death rate was 60
per million workers in 1975. We estimate
that the collective dose to the more than
one million workers potentially exposed
to radiation in their workplace for that
same year will not lead to more than 15-
36 premature cancer deaths. Other ways
of expressing this risk are that the
exposure of an average worker to
radiation in 1975 represented an average
lifeshortening of about two to three and
a half hours, or an average increase in
his chance of cancer death of about one
to three in 100,000. In 1975 about one
sixth of United States deaths were from
cancer.
The comparative time-loss associated
with nonfatal cancer is also estimated to
be very small. The average time lost by
4 Our estimated ranges of risk for cancer death
are based on absolute and relative linear risk
models used by the 1972 BEIR Committee and the
assumption that the risk of incurring most
radiogenic cancers continues throughout the lifetime
of exposed persons. The 1980 BEIR report which
" was just published, gives estimates based on a
variety of risk models, some of which yield lower
and some higher values. Based on our preliminary
review, we do not believe that the differences
between these values and those we have adopted
here would lead to any changes in these proposals.
8 Mutational effects here mean those hereditary
effects included by the BEIR Committee in their 1972
report as serious disabilities. Examples are
congenital malformations leading to premature
death, hemophilia, sickle cell anemia, cystic
fibrosis, diabetes, schizophrenia, and epilepsy.
132
-------
7838
Federal Register / Vol. 46, No. 15 / Friday, January 23, 1981 / Notices
U.S. workers) due to all occupationally-
related injuries and illnesses over a
working lifetime is one month. For
radiation-induced nonfatal cancers it is
estimated to be about four days for a
hypothetical individual receiving the
largest lifetime dose allowed (235 rem),
and for the average worker it is about
two hours.
Limitation of Whole Body (External)
Exposure
Based on these observations, risks
due to occupational exposure to
radiation do not appear to be
unreasonably high for the average
worker. They are comparable to risks of
accidental death in the least hazardous
occupations. However, a worker
exposed to the current maximum
allowed dose year after year would
sustain substantial risks. The proposed
radiation protection guidance contains
provisions to avoid the accumulation of
large lifetime doses through reduction of
the maximum allowed annual dose and
through specific minimum radiation
protection requirements for workers in
high-dose work situations. These
include on-the-job radiation protection
supervision for high-dose jobs,
maintenance of lifetime dose records,
and an admonition that exposure of
workers should be managed so that their
lifetime doses do not exceed 100 rem.
Existing Federal guidance permits
doses up to 3 rem per quarter (or 12 rem
per year), within an overall cumulative
limit of 5(N-18) rem, where N is the age
of the worker. This flexibility, which
allows annual doses greater than 5 rem,
does not permit specific tasks that
require doses to individuals of more
than 5 rem (since the 3 rem per quarter
limit prohibits this), but it does permit
the same worker to accomplish several
tasks requiring doses at or near this
quarterly limit in a given year. In view
of the risks, it is our judgement that
repeated exposures in a year at such
levels should not occur, and these
recommendations would eliminate this
flexibility. One appropriate solution in
cases where workers with specific skills
are in short supply is to train additional
workers, rather than to impose higher
risks on a few individuals.
Because we assume that any exposure
carries some risk, we believe that it is
important to avoid unnecessary
exposures at any exposure level.
Although more than 97% of all workers
in our survey received annual doses less
than one rem, these same workers
accumulated about half of the collective
dose received by the entire work force.
Many of these workers, because their
doses are low compared to the limits,
may receive only minimal training,
supervision, and monitoring for
radiation protection. Many also work in
situations where there is no need for
exposures.to ever approach the existing
or the proposed new RPGs. On the other
hand, some exposures at higher doses
are justified. The proposed
recommendations, therefore, provide a
graded system of radiation protection
which would establish minimum
radiation protection requirements for
each of three different ranges of
exposure within the basic guides for
maximum allowed dose to all workers.
We anticipate that maximum exposure
of the vast majority of workers would be
effectively limited to the lowest of these
ranges (less than approximately 0.5 rem
to the whole body per year) through the
deterrent of requirements for increased
justification, on-the-job radiation
protection supervision, and monitoring
in the two higher ranges. In addition, the
recommendations encourage regulatory
agencies to establish more restrictive
regulatory limits for work situations not
requiring the maximum doses allowed
under the basic guides.
The proposed guidance leaves
agencies considerable discretion in
implementing the minimum radiation
protection requirements for justification
of exposure of workers in each of the
various ranges. We are considering
additional guidance which would
recommend the establishment of more
explicit requirements for the highest
range (Range C). These requirements
could include establishment of criteria
for use of Range C, or prior application
to and approval by the regulatory
agency of Range C exposure (either for
specific or more general job situations).
We request specific comments on these
and similar approaches to further
restrictions on the exposure of workers
at these higher levels.
We have considered both higher and
lower alternatives to the proposed 5
rem/year RPG for whole-body exposure.
This value is proposed because (a) it is
the current internationally-accepted
value, (b) there appear to be essential
jobs requiring near 5 rem per year, and
(c) the risks to the few workers in these
jobs are not high compared to other
industrial hazards. In addition, the costs
for levels significantly lower (one rem/
year or less) appear to be unwarranted,
both in terms of increased collective
dose to the entire workforce (in return
for a few lower individual doses), and in
terms of increased economic costs.
In 1975 the National Council on
Radiation Protection and Measurements
took the position that no change was
required in the recommendation given
by it in 1971. That recommendation is
that "The maximum permissible
prospective dose equivalent for whole
body irradiation from all occupational
sources shall be 5 rems in any one year"
(NCRP Report No. 39, Jan. 15,1971).
Likewise the International Commission
on Radiological Protection in 1977
recommended a basic dose-equivalent
annual limit of 5 rem for whole body
exposures to Ionizing radiation (ICRP
Publication 26, Jan. 17,1977). In support
of its recommendation the ICRP states
that "The Commission believes that for
the foreseeable future a valid method for
judging the acceptability of the level of
risk in radiation work is by comparing
this risk with that for other occupations
recognized as having high standards of
safety, * * *." The radiation risk factors
given in ICRP Publication 26 in arriving
at its recommendation were reviewed
by ICRP in May 1978 and no changes
were made (ICRP Publication 28,1978).
Nevertheless, these recommendations
are all value judgments; there is not now
compelling evidence for any particular
value and it is hard to get such evidence.
In judging the acceptability of the risks
involved, it is necessary to identify (a)
activities that cannot be performed at
particular maximum dose levels, (b)
skilled professionals and workers in
limited supply whose numbers would be
difficult to quickly increase in order to
reduce average annual doses, and (c)
the costs for additional workers and
equipment that would be needed to meet
different limits. For example, we are
aware of a small number of
maintenance tasks at nuclear power
stations that could not be done under
some limits less than 5 rem/year. There
may be many more examples of
professions, principally in medical
areas, with limited labor pools. These
include cardiologists performing
catheterizations using fluoroscopy; and
radiologists, neuro-radiologists, and
nuclear medicine technologists with
large patient loads for special
procedures. Finally, studies by the
Department of Energy and the nuclear
power industry report that large costs
and many more workers would be
needed to greatly reduce the dose limits
for many operations. Their projections
of costs and personnel requirements
increase expotentially with decreasing
limits. We therefore request, in addition
to comment on reduction of the current
RPG of 3 rem/quarter to our proposed
recommendation of 5 rem/year,
comment on the above factors for
reduction of the current RPG to 0.5 rem/
year, 1 rem/year, and 3 rem/year.
Limitation of Partial Body Exposures
Exposure of portions of the body can
occur through localized irradiation of
133
-------
Federal Register / Vol. 46, No. 15 / Friday, January 23, 1981 / Notices
7839
extremities (such as hands in glove
boxes), or by breathing or swallowing
radioactive materials, which then
migrate to different organs of the body.
Current guidance limits such
exposures through separate numerical
guides for organs and for individual
parts of the body that are easily
exposed, such as hands and feet or lens
of the eye. Some organs recognized as
easily subjected to high doses or as
particularly sensitive to radiation have
specific guides.
These current guides are applied
separately. For example, even though a
worker has received the maximum
allowed dose to his thyroid, he may also
receive doses to his lungs, skin, or any
other organ, as long as no single organ
receives more than the dose specified by
its guide. We assume that the risks
associated with such multiple doses are
additive.
An alternative approach is to limit the
total risk of fatal cancer in all exposed
organs. This method has been adopted
by the International Commission on
Radiological Protection (ICRP). It is also
adopted in these recommendations, but
only when it leads to a greater degree of
protection than limiting the dose to
critical organs. Specifically, the
recommended guidance provides that (a)
either the combined risk of fatal cancer
from all doses to individual organs not
exceed the risk permitted under the
whole body guide or (b) the dose to the
most significantly exposed organ not
exceed its guide, whichever is more
restrictive. The recommendations also
provide, when workers receive both
external doses from whole-body
exposure and internal doses from
radionuclides, that the sum of the risks
of fatal cancer from external whole-
body doses and those due to breathing
or swallowing radioactive materials not
exceed the risk of fatal cancer allowed
by the whole-body guide.
The numerical weighting factors
chosen to relate risks to individual
organs to v,hole-body risk are discussed
in the background report cited above. In
general, they are consistent with recent
determinations of risk of fatal cancer by
national and international scientific
bodies, such as the NAS and the ICRP.
We have chosen the limiting annual
dose to most single organs to be 30 rem?
rather than the internationally-adopted
value of 50 rem, because we do not see a
need for a value higher than any now
used in this country. The risk associated
with 30 rem to any of these organs is
equal to or less than that of 5 rem to the
whole body. Additional differences from
internationally-used values for gonads,
lens of eye, and hands are discussed
below.
It is usually impractical to directly
monitor the dose received by a worker
who breathes or swallows radioactive
materials, but it is useful to be able to
predict doses that may be received from
breathing contaminated atmospheres or
swallowing contaminated materials. To
make decisions about radiation
protection of such workers possible, it is
necessary to calculate the amounts of
different kinds of radioactive materials
which, when breathed in or swallowed,
give the maximum dose allowed by the
RPGs. Those calculations require
complex models of metabolism and
dosimetry. We propose that these
limiting amounts of radioactivity be
designated the "Radioactivity Intake
Factors" (RIFs), and that they replace
the currently used "Radioactivity
Concentration Guides."
Recent advances in modeling
metabolism and dosimetry have
produced significant changes in the
doses calculated for radioactive
materials in the body. For many
radioactive materials the changes in the
RIFs due to changes in the models are
considerably larger than the changes
due to the proposed new RPGs. These
new models more often reduce
allowable intakes than raise them.
However, for those cases where the RTF
for any specific radionuclide would be
increased, the question arises whether
regulations adopted by implementing
agencies should retain existing values,
in accordance with proposed
Recommendations 2 and 6. We believe
that, for existing applications,
experience gained over the past two
decades shows that current values can
be reasonably achieved. Accordingly, in
cases where the RIF for any specific
radionuclide would be increased under
the proposed guidance, we recommend
that the value adopted in regulations
governing existing applications be no
higher than that now in use. A summary
of the changes due to the new models
and to the proposed new guides is
provided for the more significant
radionuclides in the background report.
Limitation of Risk From Mutations
The current guides for limiting dose to
the gonads are identical to those for the
whole body. For a given annual dose, '
the risk of mutational effects in all of a
male worker's descendants combined is
believed to be numerically comparable
to his lifetime risk of fatal cancer. The
risk to a female worker's descendants is
smaller. The medical severity of these
hereditary effects is usually less/than,
and, at worst, comparable to,' death from
cancer. For these reasons we do not
believe that a more restrictive guide is
required for the gonads than for the
whole body. The proposed new guide for
gonadal dose is therefore identical to
that proposed for the whole body. This
guide is specified separately and not
included in the scheme proposed above
for weighting partial-body doses
because the risks involved are of a
fundamentally different nature: the
affected individual is not the one
exposed to radiation and the effects
include different types of harm.
Limitation of Risk to the Unborn
(Fertilized Oocyte, Embryo, and Fetus
Protection of the unborn from
radiation is an already well-established
principle; the purpose of the guide for
gonadal exposure is to limit mutational
effects in children conceived after the
exposure. However, those conceived but
not yet born, the "unborn," are also at
risk. Their risks are greater, for a given
dose, than the risks to those not yet
conceived. Current guidance does not
contain a dose limitation to protect the
unborn from these risks.
The risk of serious harm following in
utero exposure requires careful attention
because of the magnitude and diversity
of the effects, because they occur so
early in life, and because those who
suffer the harm are involuntarily
exposed. These risks are not as well
quantified as those to adults.
Nevertheless, available evidence
indicates that at critical periods in the
development of the unborn, for the same
dose, risks may be many times greater
than those to adults.
There are several factors which
mitigate this situation. First, the
exposure of most workers under annual
limits is relatively evenly distributed
over the year, so that only a quarter of a
worker's annual dose is delivered to the
unborn during any trimester. Second, the
mother's body provides considerable
shielding of the unborn for most types of
exposure. Finally, the total period of
potential exposure is small for the
unborn compared to that for a worker
a period of months compared to a
working lifetime.
It is difficult to provide for protection
of the unborn without affecting the
rights of women to equal job
opportunities. This difficulty is
compounded because the critical period
for most harm to the unborn occurs soon
after conceptionduring the second and
third month after conception, when a
woman may not know that she is
pregnant. Based on our assessments of
the risks and the other factors noted
above, we believe that the maximum
dose to the unborn should be a factor of
ten below the maximum permitted adult
workers in any year. This is also the
current recommendation of the National
134
-------
7840
Federal Register / Vol. 46, No. 15 / Friday, January 23, 1981 / Notices
Council on Radiation Protection and
Measurements. In Recommendation 8
we propose four alternatives which
would, with varying degrees of
certainty, achieve this objective.
The first two alternatives rely upon
voluntary compliance and, therefore,
should have less impact on equal job
opportunities for women. The first
assumes a woman knows she is
pregnant within six weeks of
conception, and will then, along with her
employer, take appropriate protective
action. It therefore does not guarantee
that doses to the unborn during the
critical early stages of pregnancy will be
less than 0.5 rem.
The second alternative adds a
voluntary limit on dose rate to women
who can bear children in order to
protect the unborn whose existence is
not yet known. It permits women to hold
any job, but encourages women able to
bear children not to take those few jobs
which potentially involve high dose
rates.
The third alternative insures
protection of all unborn throughout
gestation by making the voluntary
requirements of the second mandatory.
It would bar women of child-bearing
capacity from those few jobs which
involve high dose rates.
The final alternative would restrict
the exposure of all workers, male and
female, to a level which would protect
the unborn at the level of the first
alternative. This alternative preserves
equal job opportuntity for women at the
cost of causing more total harm. Studies
of several high exposure activities show
that decreasing the dose limits to this
extent would significantly increase the
collective dose to workers, and that
some current activities would not be
possible.
None of these alternatives is
completely satisfactory; they each
involve either varying degrees of
adequacy of protection of the unborn,
some sacrifice of equal job opportunity
for women, or causing more total harm,
or foregoing some of the benefits to.
society from activities using radiation.
We invite public comment on the
relative importance to be attached to
each of these factors in formulating
guidance, and on whether or not the
guidance should address this matter
now. We would also be happy to receive
suggestions for other alternatives.
Limitation of Other Risks
The risk of nonfatal cancer is not only
intrinsically less important than that of
fatal cancer, but is very much smaller
than other nonfatal occupational risks.
Thus, we believe the protection
provided against fatal cancers includes
adequate protection against nonfatal
cancers.
While adequate protection against
cataracts of the lens of the eye might be
provided by a higher maximum average
annual dose than the 5 rem now
allowed, no operational difficulty is
reported with use of 5 rem as an annual
limit. That value is therefore retained in
these proposals.
The maximum annual dose for skin of
the whole body is maintained at 30 rem,
since a need for allowing higher doses
has not been demonstrated. However,
the current guide permits 75 rem to
hands and forearms, or feet and ankles,
because of the assumed lower risk when
only these portions of the skin and
underlying tissue of these extremities
are involved. We agree that at low dose
rates the risk depends in some degree on
the amount of skin and tissue exposed,
and that exposure of the extremities is
therefore less dangerous than of the
whole body. However, for forearms,
feet, and ankles such a high value is not
needed and we propose that the guides
for skin and the whole body apply to
these extremites. For the hands a higher
value appears to be justified for work in
glove boxes. It is proposed to be 50 rem,
the limit recommended by the ICRP.
Other Considerations
x These recommendations apply to
workers exposed to other than normal
background radiation on the job. It is
sometimes hard to identify such
workers, because everyone is exposed
to natural sources of radiation and many
occupational exposures are small.
Regulatory agencies will have to use
care in selecting classes of workers
whose exposure does not need to be
regulated. In selecting such classes we
recommend that the agency consider
both the collective dose which is likely
to be avoided through regulation and the
maximum individual doses possible.
The question often arises whether or
not exposure for medical purposes and
other nonoccupational exposures should
be considered in calculating the doses
that workers receive within the guides.
If there were a threshold for risk of
health effects from radiation, this could
be an important consideration.
However, since we assume that the risk
at low doses is proportional to the dose,
each exposure must be justified on its
individual merits. For this reason, in
Note 1 to the recommendations we
exclude medical and other
nonoccupational exposure from the total
calculated occupational radiation
exposure of workers.
In many jobs diagnostic x-ray
examinations are a routine part of
periodic or pre-employment physical
examinations. Some of these
examinations are a condition of
employment and some are not. Federal
radiation protection guidance on use of
diagnostic x-rays was issued by the
President on February 1,1978 (43 FR
4377). These recommendations provide
that, in general, use of such x-ray
examinations should be avoided unless
a medical benefit will result to a worker,
considering the importance of the x-ray
examination in preventing and
diagnosing diseases, the risk from
radiation, and the cost. Although all of
the recommendations in that guidance
may be usefully applied to x-ray
examinations of workers,
Recommendations 1 through 4 are
particularly pertinent. Because this
matter has been addressed by separate
Federal guidance, exposure from such
diagnostic x-ray examinations is not
included in this guidance for
occupational exposure.
Current Federal guidance provides
that occupational doses to minors (those
below the age of eighteen) be limited to
one tenth the RPGs for older workers.
We propose no change.
No other general types of exposed
workers are singled out for special
protection by these recommendations.
However, one special class of workers
underground uranium minersis
already subject to a separate Federal
guide (36 FR 12921). That guide limits
exposure of their lungs to radioactive
decay products of radon gas. The Mine
Safety and Health Administration
regulates exposure of all underground
miners in accordance with this guide.
We expect to review the guide on the
exposure of miners to decay products of
radon in the future. Exposure of miners
to other radiation is governed by the
Federal radiation protection guidance in
these proposed recommendations.
We have not addressed the issues of
emergency exposures or of whether
overdoses in one year should lead to
additional restrictions on doses in future
years. Such situations must be dealt
with on the merits in each case and
under the regulatory mandate of the
controlling Federal agency. We do not
consider it either practical or reasonable
to prejudge or prescribe general
conditions for such situations beyond
the general principles which apply to all
radiation exposure that are set forth
below in Recommendations 1 and 2.
We recognize, in addition, that some
situations may exist which justify
planned exposures exceeding the guides.
Recommendation 9 provides for this. It
requires that the controlling Federal
agency fully consider and disclose the
reasons for any such exposures.
135
-------
Federal Register / Vol. 46, No. 15 / Friday, January 23, 1981 / Notices
7841
Estimated Impact of These Proposals
We estimated above that the exposure
of 1.1 million workers in 1975 (the latest
year for which we have complete
statistics) will lead to 15-36 additional
premature cancer deaths and
comparable numbers of serious
mutational effects and nonlethal
cancers. If this new guidance is adopted,
workers should be harmed less in the
future. We are not able to quantify the
improvement because we cannot predict
how efficiently the guidance will be
implemented and we do not know how
much of existing exposure is unjustified.
However, the proposed
recommendations provide a framework
of graded minimum requirements to cut
down the amount of unjustified
exposure, and a recommendation that
implementing agencies establish lower
regulatory limits for workers who can
operate significantly below the new
maximum limits. We believe that most
workers can. The proposals also reduce
the maximum annual and lifetime dose
that any workers can get by about 60%.
We have made only a limited
assessment of the costs of implementing
this proposed guidance. We do not
believe it would be prudent to attempt a
detailed analysis, because agencies
developing regulations to carry out this
guidance may use different means, and
their specific proposals will be
subjected to public review and
economic analysis when they are
developed.
The principal cost will be that
associated with reduced RPGs. in order
to comply with a reduced RPG an
enterprise can hire more workers,
reassign (and, if necessary, retrain)
present employees, improve its
procedures or technology, or curtail the
activity. In general, a mix of these will
be used, depending on the value of the
reduced RPG, on the cost of each
alternative, and on other factors. Since
we do not know what mix will be used,
for the purpose of developing rough
numberical estimates of the upper
bounds of costs we have used a simple
model based on the costs for hiring new
workers only.
From the distribution of doses found
in our national survey of exposures for
the year 1975, we computed the total
excess collective dose between the old
RPG of 3 rem per quarter and the
proposed RPG of 5 rem per year.
Dividing this excess by the value of the
proposed new RPG gives the minimum
number of workers that must be hired to
absorb this dose. The average labor
cost, including overhead, for each
additional worker was assumed to be
$40.000 per year. This method yields a
cost of about $35 million per year. We
believe the actual cost of meeting the
new RPG will be much less.
We have also attempted to evaluate
costs if existing workers now receiving
lower doses are retrained to do high-
dose jobs instead of hiring new workers.
Some workers are very difficult to
replace (e.g., medical professionals, such
as cardiologists and radiologists; and
workers in small enterprises with very
limited labor pools). However, we
believe that most workers can be
relatively easily retrained (e.g., medical
technicians and skilled laborers, such as
welders and pipe fitters) to handle tasks
which cause higher exposures. We
estimate that workers that can be
reassigned to these jobs would require
training varying from a few days to a
few months. For these workers, the costs
are expected to range from a few
percent to a few tens of percent of the
annual cost of new hires. In addition,
these costs are incurred only once
instead of annually, as in the case of
new hires. We therefore estimate that
the costs based on the above new hires
model may be as much as ten times too
high, for the first year, and an even
greater over-estimate in succeeding
years. We welcome comments on the
costs of implementing these proposals,
on whether or not the costs are
reasonable, and why.
Proposed Recommendations
We propose nine recommendations as
guidance to Federal agencies in the
formulation of Federal radiation
protection standards for workers, arid in
their establishment of programs of
cooperation with States. In all cases but
one we have made single
recommendations for public comment.
The exception, Recommendation 8,
addresses protection of the unborn
during gestation. Because this
recommendation involves issues that go
beyond simple radiation protection of
workers, including equality of
employment rights and the rights of the
unborn, we have proposed four
alternatives for public consideration.
The recommendations follow:
1. All occupational exposure should
be justified by the net benefit of the
activity causing the exposure. The
justification should include comparable
consideration of alternatives not
requiring radiation exposure.
2. For any justified activity a
sustained effort should be made to
assure that the collective dose is as low
as is reasonably achievable.
3. The radiation dose to individuals
should conform to the numerical
Radiation Protection Guides (RPGs)
specified below. Individual doses should
be maintained as far below these RPGs
as is reasonably achievable and
consistent with Recommendation 2.
Radiation Protection Guides
a. The sum of the annual dose
equivalent 6 from external exposure and
the annual committed dose equivalent '
from internal exposure should not
exceed the following values:
Whole body 5 rem
Gonads 5 rem
Lens of eye 5 rem
Hands 50 rem
Any other organ 30 rem
b. Non-uniform exposure of the body
should also satisfy the condition on the
weighted sum of annual dose
equivalents and committed dose
equivalents,
Hw, that
where Wj is a weighting factor, Hi is the
annual dose equivalent and committed
dose equivalent to organ i, and the sum
excludes the gonads, lens of eye, and
hands. Recommended values of Wi are:
Breast 0.20
Lung 0.16
Red bone marrow 0.16
Thyroid 0.04
Bone surfaces 0.03
Skin 0.01
Other organs 8 0.08
c. When both uniform whole-body
exposure and nonuniform exposure of
the body occur, in addition to the
requirements of 3a, the annual uniform
whole-body dose equivalent added to
the sum of weighted annual dose
equivalents from additional nonuniform
exposure, Hw, should not exceed 5 rem.
4. The following Minimum Radiation
Protection Requirements should be
established by appropriate authorities
and carried out in the workplace, on the
basis of the range of doses anticipated
in individual work situations. The
numerical values specifying the dose
ranges may be adjusted to fit the needs
of specific situations by implementing
agencies.9
6 "Dose equivalent" means the quantity expressed
by the unit "rem," as defined by the International
Commission on Radiation Units (IU73).
'"Annual committed dose equivalent" applies
only to dose equivalents from radionuclides inside
the body. It means the sum of all doae equivalents
that may accumulate over an individual's remaining
lifetime (usually taken as 50 years) from
radioactivity that is taken into the body in a given
year.
"Applies only to each of the five other organs
with highest doses.
8 Suggested numerical ranges are: Range A, less
than 0.1 RPG; Range B, 0.1-0.3 RPG; Range C 0 3-1 0
RPG.
136
-------
7842
Federal Register / Vol. 46, No. 15 / Friday, January 23, 1981 / Notices
Minimum Radiation Protection
Requirements
Range A
a. Determine that exposures result
only from justified activities and are as
low as is reasonably achievable. These
determinations may often be made on a
generic basis, that is, by considering
groups of similar work situations and
protective measures.
b. Monitor or otherwise determine
individual or area exposure rates to the
extent necessary to give reasonable
assurance that doses are within the
range and are as low as is reasonably
achievable.
c. Instruct workers on basic hazards
of radiation and radiation protection
principles, and on the levels of risk from
radiation and appropriate radiation
protection practices for their specific
work situations. The degree of
instruction appropriate will depend on
the potential exposure involved.
Range B
The above requirements, plus:
d. Provide professional radiation
protection supervision in the work place
sufficient to assure that both individual
and collective exposures are justified
and are as low as is reasonably
achievable.
e. Provide individual monitoring and
recordkeeping.
Range C
The above requirements, plus:
f. Justify the need for work situations
which are expected to make a
significant contribution to exposure in
Range C and provide professional
radiation protection supervision before
and while such jobs are undertaken to
assure that collective and individual
exposures are as low as is reasonably
achievable.
g. Carry out sufficient additional
monitoring of workers to achieve
Recommendation 4f.
h. Once a worker has been exposed in
Range C, maintain a lifetime dose
record, including at least all subsequent
annual doses (as specified in
Recommendation 3c) in Ranges B and C.
i. Maintain lifetime doses as low as is
reasonably achievable. The
accumulation of doses (as recorded
under Recommendation 4h) by
individual workers should be managed
so that their lifetime accumulated dose
is less than 100 rem.
5. a. "Radioactivity Intake Factors"
(RffsJ should be used to regulate
occupational radiation hazards from
breathing, swallowing, or immersion in
media containing radionuclides. The RIF
for a radionuclide is defined as the
maximum annual intake (in curies) for
which the committed dose equivalent to
a reference person satisfies the
Radiation Protection Guides in
Recommendation 3. RIFs may be
derived for different chemical or
physical forms, and for intake by
breathing, swallowing, or for external
exposure from air containing a
radioactive gas. Exposure regulated
through use of the RIFs should meet the
same Minimum Radiation Protection
Requirements as equivalent exposure
under the Radiation Protection Guides.
b. When a RIF for a specific
radionuclide in a specific chemical or
physical form determined on the basis of
part (a) is larger than that currently in
use, a value no greater than that in
current use should be adopted in
regulations governing work situations
identical or similar to those currently in
existence.
6. Federal agencies should establish
limits and administrative levels that are
below the RPGs and the RIFs, when this
is appropriate. Such limits or levels may
apply to specific categories of workers
or work situations.
7. In addition to any other Federal
restrictions, the occupational exposure
of individuals younger than eighteen
should be limited to one tenth of the
Radiation Protection Guides for adult
workers.
8. Exposure of the unborn 10 should be
restricted more than that of workers.
This should include special
consideration of ALARA practices for
women. Women able to bear children
should be fully informed of current
knowledge of risks to the unborn from
radiation. In addition, employers should
assure that protection of the unborn is
achieved without loss of job security or
economic penalty to women workers.
Due to the complexity of the issues
involved, we propose four alternative
recommendations on numerical
limitation of dose to the unborn for
public comment. We would be glad to
receive other recommendations for
dealing with exposure of the unborn.
a. Women are encouraged to
voluntarily keep total dose to any
unborn less than 0.5 rem during any
known or suspected pregnancy; or
b. Women able to bear children are
encouraged to voluntarily avoid job
situations involving whole-body dose
rates greater than 0.2 rem per month,
and to keep total dose to the unborn less
than 0.5 rem during any known
pregnancy; or
c. Women able to bear children
should be limited to job situations -
10 "Unborn" here means the fertilized oocyte, the
embryo, and the fetus.
involving whole-body dose rates less
than 0.2 rem per month. Total dose to
the unborn during any known period of
pregnancy should be limited to 0.5 rem;
or
d. The whole-body dose to both male
and female workers should not exceed
0.5 rem during any six month period.
9. In exceptional circumstances the
RPGs may be exceeded, for cause, but
only if the Federal agency having
jurisdiction carefully considers the
specific reasons for doing so, and
publicly discloses them unless this
would compromise national security.
The following notes clarify
application of the above
recommendations:
1. Occupational exposure of workers
does not include that due to (a) normal
background radiation and (b) exposure
as a patient of practitioners of the
healing arts.
2. When the uniform external whole-
body exposure occurs in addition to
exposure from radioactive materials
taken into the body, the requirement of
Recommendation 3c may be satisfied by
the condition that
Hext
wb
where He^t is the annual external whole-
body dose equivalent, RPGwb is 5 rem, Ij
is the intake of radionuclide j, and RIFj
is defined as in Recommendation 5.
3. The values currently specified by
the ICRP for quality factors and
dosimetric conventions for measurement
of the various types of radiation may be
used for determining conformance with
the RPGs. The model for a reference
person and the metabolic models
currently specified by the ICRP may be
used to calculate the RIFs. We will
recommend other factors, conventions,
and models when and if they are more
appropriate.
4r. Numerical guides for emergency
exposures are not provided by this
guidance. Agencies should follow the
general principles established by
Recommendations 1, 2, 7, 8, and 9 in
dealing with such situations.
5. Procedures for handling
overexposures are not addressed by this
guidance. The equitable handling of
such cases is the responsibility of the
employer and the Federal agency having
regulatory jurisdiction.
6. Limits for periods other than one
year may be derived by Federal
agencies from the annual RPGs and RIFs
when necessary for administrative
137
-------
Federal Register / Vol. 46, No. 15 / Friday, January 23. 1981 / Notices
7843
purposes. Such limits should be
consistent with Recommendation 2 and
the three ranges in Recommendation 4.
7. The existing guide for limiting
exposure of underground uranium
miners to radon decay products ia not
changed by these recommendations.
These proposed recommendations
would provide general guidance for the
radiation protection of workers. They
would replace that part of existing
guidance (see 25 FR 4402 of May 18,
1960] which applies to workers.
Individual Federal agencies, with their
knowledge of specific worker exposure
situations, would use this guidance as
the basis upon which to develop
detailed standards and regulations to
meet their particular statutory
obligations. We propose to follow the
activities of the Federal agencies as they
implement the final Guidance, to issue
any necessary clarifications and
interpretations, and to promote the
coordination necessary for an effective
Federal program of worker protection.
Public Hearings
Public hearings on these proposed
recommendations will be held as
indicated above under the heading
"Dates." Because of their major
responsibilities to regulate radiation
Exposures in work places, the Nuclear
Regulatory Commission (NRC) and the
Occupational Safety and Health
Administration (OSHA) will participate
in sponsoring these hearings. The
following conditions and procedures
will govern the conduct of the hearings:
1. Purpose. Type, and Scope
These hearings are to provide
additional opportunity for people to
express opinions and provide factual
information to aid EPA, OSHA, and
NRC in carrying out their respective
responsibilities for guidance on and
regulation of occupational exposure to
ionizing radiation. The hearings will be
informal and legislative in nature rather
than adjudicatory or formal rulemaking
hearings. Technical rules of evidence,
discovery, subpoena powers, testimony
under oath, and similar formalities will
not apply.
The issues to be covered by these
hearings are those listed above under
the heading "Issues Addressed." They
include those listed in our advance
notice of September 17,1979 (44 FR
53785) and additional issues suggested
since then. As indicated in that notice,
both EPA and NRC have been petitioned
by the Natural Resources Defense
Council, Inc., to revise occupational
guidance and standards. The subject
matter of these hearings encompasses
the issues raised in those petitions (See
40 FR 50327 of October 29,1975).
2. Presiding Officer and Panel
The hearings will be conducted by a
presiding officer. A six member panel
consisting of representatives of EPA,
OSHA, and NRC will assist the
presiding officer. A principal
responsibility of the panel will be to
clarify the testimony by eliciting views,
comments, and factual information from
participants. Members of the panel will
not present views or respond to
questions on behalf of their agencies.
The membership of the panel may vary
from time to time.
The presiding officer and panel shall
have the joint responsibility to assure a
fair and impartial hearing and to
'encourage the development of testimony
that will contribute to informed
decision-making. It will not be the
function of the presiding officer or the
panel to issue an opinion or to make
decisions at the conclusion of the
hearings. The presiding officer shall
conduct the hearings in an orderly, fair,
and expeditious manner and make
procedural decisions. His functions shall
include, but not be limited to, the
following:
a. Regulating the course of the
hearings and the conduct of
participants, including establishing
reasonable time limits for the hearings,
establishing the sequence |ind length of
presentations and questioning, and
opening and closing each hearing
session;
b. Making determinations concerning
procedure and similar matters;
c. Assuring that questioning of
speakers by panel members and others
is consistent with the nature and
purpose of these hearings;
d. Making determinations on the
relevance of oral testimony and
questions to the issues identified as
within the scope of the hearings, or, in
consulation with the panel, to additional
issues pertinent to the proceedings; and,
as necessary, terminating irrelevant
presentations;
e. Ruling on late requests to
participate;
f. Deciding how long the hearing
record will remain open for written
comments and additional data after the
end of the oral proceedings.
3. Participation in the Hearings
Persons or organizations who wish to
give presentations longer than ten
minutes or present extensive data and
evidence must give written notice to the
Director, Criteria and Standards
Division (ANR-460), U.S. Environmental
Protection Agency, Washington, D.C.
20460, no later than 28 days prior to the
scheduled date of a hearing. The notice
should include: (1) the name, address,
and telephone number of the participant;
(2) the hearing at which they wish to
testify; (3) the organization (if any) that
they will represent; (4) the amount of
time requested; and (5) which of the
issues they want to address. Oral
presentations will generally be
restricted to 30 minutes. Detailed or
lengthy material should be summarized
orally and presented in full in written
submissions. Requests for longer times
for oral presentations will be
condsidered only on the basis of a
detailed summary of the material to be
presented. The Agency will notify
participants in advance if their allocated
time is less than that requested.
An opportunity will be provided each
day of the hearings for persons who
have not submitted a notice as specified
above to make brief oral statements. A
register will be provided at the
beginning of each hearing for this
purpose. A minimum period will be set
aside for such statements in the agenda
for each hearing, and the presiding
officer may allocate additional time, as
necessary. The maximum time allowed
for such statements will depend on the
number of registrants and the
availability of time, but will generally be
limited to periods of no more than 5 to
10 minutes each. In order to assist the
management of the hearings, persons
wishing to make such statements are
encouraged to register promptly at the
beginning of the hearing.
Attendance at the hearings will be
open to all members of the public, and
seating will be made available on a first-
come first-served basis.
4. Testimony and Written Submission
a. The oral proceedings will be
recorded verbatim and a transcript
made availabe promply for inspection
'and copying, as specified below under
the heading "The Public Hearing
Record." It will help the panel if
speakers supply copies of their oral
testimony before they give it. However,
this in not required.
b. Fourteen copies of any written
statements and documents on which
speakers intend to base their oral
statements must be submitted to the
Director (see "Addresses" above) no
later than 14 days before the beginning
of the hearing in which they will testify.
We would appreciate if speakers would
also provide eight additional copies for
the use of the panel.
c. Questions may be directed to
speakers by the hearing panel, by other
speakers, and by other members of the
public. Speakers may respond or not, as
138
-------
7844
Federal Register / Vol. 46, No. 15 / Friday. January 23. 1981 / Notices
they wish. Questions should be designed
to elicit relevant information and should
not be repetitious of questions asked by
others. The views of questioners should
be expressed in their statements and not
as prefaces to questions. Such informal
questioning will be at the discretion and
under the control of the presiding
ff, r °
officer.
d. Members of the public who are not
able to attend the hearings or prefer not
to ask questions themselves may suggest
questions to the hearing panel to ask of
speakers. These must be submitted no
later than 14 days before any hearing to
the Director (see "Addresses" above).
The panel will decide whether or not to
ask these questions.
e. Members of the public may also
submit comments during the-post-
hearing comment period set by the
presiding officer. These post-hearing
comments should be confined to
responses to data and opinions
submitted at the hearings or to written
comments received by the Agency.
f. In addition to these public hearings,
we would appreciate any written
comments on these proposals. These
will be given equal consideration in
formulating final recommendations. The
procedure for submitting such written
comment is given above under the
headings "Dates" and "Addresses."'
Participants in the hearings may refer to
and comment on such written
comments, which will be available for
public inspection and copying as
specified below under "The Public
Hearing Record."
5. Opening Statement
At the opening of each hearing, EPA
will provide a summary statement of the
proposed recommendations and of the
major issues involved. At that time
speakers and other members of the
public can ask questions of the EPA
representatives in order to clarify the
proposed recommendations and the
reasons why EPA is proposing them.
5. The Public Hearing Record
The procedures for filing documents in
these hearings will be specified by the
presiding officer, except as already
provided herein.
The hearing record will include the
transcript of oral statements by
speakers, the questions and answers,
and all written materials filed in
connection with these hearings. Items in
this public hearing record will be filed
under EPA Docket No. A-79-46 and will
be available for public inspection and
copying as soon as possible (Vowing
their receipt, at tl.e LI S. T: - cental
Protection Agencv's CL"- ra' : kct
Section, Room 2903B, Mall, 4.
------- |