Mr. HEALY. Our standards are below the NCRP but I would not say substantially. We have some values which are lower than the NCRP by an amount which we feel is sufficient to take care of our uncertainties of measurement. This is for our standards. We do operate with only a few people ever approaching the standards. So that our overall exposure at Hanford-in other words, the actual exposure the people get is considerably lower on the average than the NCRP limits.

Representative HOLIFIELD. The committee is aware of the conservative way in which you have approached the utilization of these maximums and certainly your record of prevention of accidents is very fine. Mr. HEALY. Thank you.

Representative HOLIFIELD. You have been handling very dangerous materials over the years. I think you are to be commended for taking the more conservative approach in this field and not pressing the maximum. Are there any further questions?

Representative HOSMER. Yes, Mr. Chairman. I am just wondering-Dr. Wolman testified and talked about a quantitative and qualitative approach to this. The qualitative being the acceptance of risks in the establishment of these standards, and you have talked about it and so many other witnesses have talked about it, and assumed that you were doing that. I am just wondering if you are not actually working on what he called the qualitative standard and actually your aim is no accident at all in the way you operate.

Mr. HEALY. Definitely. This is definitely the aim, that there should be no accidents. Unfortunately, there have been accidents in the atomic energy business-few, I will admit. But I do not think that we can ever expect that we will have an absolutely zero record of accidents in any endeavor.

Representative HOSMER. I don't think he feels that, either.

Mr. HEALY. That is right.

Representative HOLIFIELD. I just had a feeling that many of you have been talking in terms of acceptance of risk here when you are not proceeding in that way and you are mixing up some of your examples.

Mr. HEALY. Yes. This is the reason I put some words in the first part of my testimony on the difference between the standards provided to minimize or eliminate accidents as opposed to standards to minimize chronic exposure. I believe both types of standards are necessary in the atomic energy business. However, I believe that they are somewhat different types of standards in methods of derivation and in methods of control; in other words, of application. To prevent accidents, one uses a safety philosophy which has grown up over the years. It is not greatly different really in philosophy from the prevention of accidents of a normal type in industry. The second type of standard, that to minimize chronic exposure, I believe is where we talk mostly about the risk principle being applied. In other words, with radiation we are concerned with effects which occur at some very long time in the future. For instance, the genetic effects may not show up for several generations, so that we have no method of directly checking to see how good our standards are. So here we have to apply the risk principle on a somewhat different basis, because we can never hope to check our standards. Do I clarify that at all?

Representative HOSMER. Yes, thank you.

Representative HOLIFIELD. Thank you very much, Mr. Healy. Mr. HEALY. Thank you, Mr. Chairman.

Representative HOLIFIELD. We will reconvene in this room at 2 o'clock for the round table on the topic, "Social and Economic Concepts Underlying Radiation Protection Standards." The committee is adjourned.

The statement submitted by Dr. A. J. Vander Weyden, Deputy Director, Division of Reactor Development, AEC, will be inserted in the record at this point.

I have also a report from the Atomic Industrial Forum, Inc., on a recent seminar held in New York.

(The material referred to follows:)

STATEMENT OF DR. A. J. VANDER WEYDEN

I do not claim for myself, or for the members of the staff of the Division of Reactor Development, the technical competence to pass judgment on the level of radiation to which people can safely be exposed. Such levels must be established by those who are experts in the field of biological effects of radiation and it is then for us to design, build, and operate our nuclear facilities to satisfy these levels. I would certainly not advocate that radiation protection standards be reduced for economic reasons, but conversely, I feel that it would be a serious mistake to establish unnecessarily restrictive standards which could impose an economic burden that could seriously inhibit the beneficial uses of nuclear energy. The purpose of my discussion then is to consider the economic impact of possible changes in radiation standards and not to discuss the advisability of such changes.

It is extremely difficult at this stage of the development of the nuclear industry to make more than qualitative estimates of the cost effect of revision of radiation standards. The philosophy which is currently followed by most reactor designers generally incorporates safety factors which should assure that the facilities will operate at exposure levels well below the standards to which they were designed. If the permissible levels were lowered, but still remained within those actually achieved by the current design, no changes would be absolutely required, since one could operate with smaller factors of safety than those which are currently accepted. Such a practice would probably not be wise at the current state of our knowledge, and in any event a point would eventually be reached where further lowering of permissible levels could not be accommodated within the safety factor of present design. At this point design changes, with concomitant cost increases, would be necessary.

The type and magnitude of the changes which would be required would vary for each reactor system and possibly for each specific reactor, and it is not possible to give meaningful estimates except as a result of a careful engineering cost analysis of the specific design under consideration. It is clear, however, from a very preliminary study which we have made on pressurized water systems, that decreasing allowable exposure levels would be expected to result in increased capital costs for the reactor because it would necessitate addition 1 shielding for both operation and maintenance, more complicated and more costly equipment for handling irradiated and unirradiated fuel, and waste, and much more sensitive and, therefore, more expensive control and monitoring instrumentation needed to detect the lower levels.

With regard to this last point, it is interesting to note that the techniques and instruments available for routine detection and measurement of radioactivity are presently operating at or near their lower limits of sensitivity. If the acceptable levels are lowered markedly, a major and costly program would be necessary to develop rugged reliable instruments and new and better sampling and measuring techniques to detect the new lower levels.

The economic impact of lowering the permissible levels of radiation would be felt by the nuclear industry, not only in the reactor itself, but also in all the activities that support the operation of reactors. Thus, due to shielding limitations, the amount of spent fuel that could be shipped in a given shipping

container would be less if the allowable radiation from the container were decreased. This would, of course, increase the unit cost of returning such fuel to the processing plants. Similarly, the activities of the reprocessor would be restricted by tighter standards. He would find it more difficult to dispose of the gaseous effluent from his processing, he would be required to exercise tighter control over his solid and liquid waste disposal procedures, and be would need more extensive and sensitive monitoring equipment. All of these factors would tend to markedly increase this particular cost item.

Even processing of unirradiated fuel would suffer if the allowable levels were decreased to any great degree. Since airborne dust is the major problem in most fuel fabrication, lowering permissible levels would certainly raise problems of ventilation which, at some point, could only be solved by use of remote handling techniques. The need for such handling techniques could well double, or even triple, current costs of fuel fabrication. Cold scrap recovery operations could be similarly affected.

Operating and maintenance costs for reactors and other nuclear facilities are quite sensitive to the permissible level. Since it is generally not economically feasible to completely decontaminate a piece of equipment prior to maintenance operation, the usual practice is to control the exposure of the maintenance men by limiting the time they are allowed to work in radiation areas. If allowable levels are decreased, the time during which a person can stay in a given radiation field is decreased and hence more people must be hired to do the same job, or a more thorough decontamination job must be done to lower the radiation level. Either procedure will increase costs.

Similarly, a decrease in allowable exposure levels would cause an increase in operating costs, as differentiated from maintenance costs, since it would be necessary either to decontaminate operational areas to a greater degree, or limit the exposure of operators by decreasing time on the job.

A third increase cost could possibly result from the fact that the more complicated equipment which may be installed to meet lower exposure levels might require more highly trained, and therefore more highly paid, operators and maintenance personnel. It might also be expected that the more complicated equipment would have a greater tendency to fail with the resulting increases in cost due to additional maintenance and large stores of spare parts.

My discussion to this point has centered on the areas where lowering permissible exposure levels would increase the cost of normal operation. Of probably even greater economic importance is the point that the hazard analysis of the maximum credible accident, based on lower, permissible levels of exposure, could well dictate very costly standards for such things as integrity of containment, size of exclusion areas, and distances from population centers. As you know, the problem of site selection and containment integrity is extremely critical to the future of the nuclear reactor industry, and a major decrease in levels of exposure which are assumed to be acceptable in the event of the highly improbable serious nuclear "maximum credible" accident, conid well have such great economic impact as to introduce a major delay in the achievement of economically competitive, generally accepted nuclear power.

I was asked to comment on the economic effect of changes in the maximum permissible exposure level. Since changes could be in either direction, we have also made a brief preliminary survey of the effect of major increases in allowable exposure levels, and have concluded that, while there would, of course, be some saving in shielding and equipment and possibly in operating and maintenance costs, there would be no major cost reductions by increases in levels of a magnitude that we considered as reasonable.

In conclusion, then, a major decrease in allowable radiation levels could result in appreciable cost increases which, if they come about, would seriously delay the day when nuclear power is a competitive factor in our economy, and which would, therefore, increase the development costs which are needed to achieve this result.

If it can be shown that lower exposure levels are needed to protect the public, I would certainly not argue against such changes; but until and unless this is shown, I hope the nuclear industry is not saddled with the potentially crippling costs which might result from such a change.

ATOMIC INDUSTRIAL FORUM, INC.-SEMINAR ON ECONOMIC AND ADMINISTRATIVE IMPLICATIONS OF RADIATION PROTECTION STANDARDS AND CRITERIA, MAY 10, 1960

On May 10, 1960, an informal seminar was held at the Atomic Industrial Forum headquarters in New York to discuss economic and administrative implications of radiation protection standards and criteria. A major purpose of the meeting was to provide an opportunity for an informal exchange of authoritative opinion on the impact of present and proposed exposure limits and the effects of these limits and their administration on progress in the peacetime atomic energy program.

The seminar was not designed to cover all aspects of the problem and was limited to certain areas of discussion. This report describes the proceedings of the seminar in general and does not necessarily represent the opinion of individual participants on all points.

The following persons participated in the seminar: Steven Brown, National Lead Co.; H. H. Dooley, United States Radium Corp.; Abraham Edelmann, Nuclear Science and Engineering Corp.; Jack Healy, General Electric Co., Hanford; S. Allan Lough, AEC Health and Safety Laboratory, New York; William McAdams, General Electric Co.; Bernard B. Smyth, Dow, Lohnes & Albertson; Oliver Townsend, New York State Office of Atomic Development; Robert Wells, Westinghouse Electric Corp.; and G. Edwin Browns, Jr., Atomic Industrial Forum.

Also invited, as observers, were K. Z. Morgan, Oak Ridge National Laboratory, and Hal Hollister, technical consultant, Joint Committee on Atomic Energy.

Invited, but unable to attend, were Dr. Donald Chadwick, Federal Radiation Council; Alex Somerville, General Motors Research Laboratories; and Charles F. MacGowan, International Brotherhood of Boilermakers, AFL-CIO.

In the general opinion of the seminar group, any evaluation of radiation exposure levels and their economic impact must, of necessity, be judged on a case-by-case basis and overgeneralization should be avoided. At the same time, there appeared to be a general consensus among the group on the following points, as they emerged from the discussion:

1. Current exposure levels, as specified by the National Committee on Radiation Protection and Measurements (NCRP), do not in general present an unreasonable burden to industry in developing the peaceful uses of atomic energy. There have been some instances where arbitrary levels set by local authorities, departing from generally accepted limits, have caused substantial economic burdens and have tended to provide a disincentive for proceeding with peacetime atomic development.

2. A greater problem exists in the interpretation and codification by State and Federal authorities of recommendations made by the NCRP and in the administrative burdens associated with these standards when incorporated in current and proposed regulations. It was suggested that more emphasis be placed on delineating the intent of safety requirements and less on the methods to be utilized in meeting them. Several participants pointed to the need for increased flexibility in administrative procedures so as to insure maximum progress consistent with effective control of radiation hazards.

There was also a general consensus on these related points:

1. There has been a widespread tendency on the part of the public to place undue emphasis on potential radiation hazards in relation to other industrial hazards. On the whole, the safety record in the atomic energy field has been remarkably good in comparison to that achieved in other industrial activities. It was suggested that the National Safety Council might appropriately devote more attention to this matter of comparative safety among various industries. Publication of their findings would, it was felt, place radiation hazards in better perspective.

2. One of the most pressing needs identified by the seminar participants is for a broad scale educational effort throughout industry, labor, Federal, State, and local governments, and the public at large, regarding the potential hazards

of atomic radiation. It is believed important to relate these potential hazards to the benefits to be gained from atomic energy development. Several participants cautioned that such an effort should not be attempted on a "crash" basis, but should be carried out systematically at all levels over an extended period of time. It was argued that such a program would in the long run be far more effective and productive of worker safety than "education by regulation."

3. In this connection, participants pointed to the continuing need for professional guidance at the working level among those utilizing atomic and other sources of radiation, with emphasis on the practical controls required. It was believed that this need is most apparent among the growing list of small firms and organizations employing radioisotopes. It was noted, in this regard, that the American Board of Health Physics has recently taken steps to establish a certification procedure for health physicists.

Economic effects of exposure limits

In discussions on the economic effects of radiation exposure limits the opinion was expressed, as mentioned above, that evaluations must be made on a case-bycase basis if they are to prove meaningful. However, it was noted that economic impact-or lack of it-often appears to be directly related to how close a user of radiation approaches radiation exposure limits in his day-to-day operations. Variations from this rule of thumb appear to depend on the nature of the operation and the type of equipment being used.

For example, comparatively higher levels of exposure are often encountered in milling operations and in the chemical reprocessing of reactor fuel. Conversely, many reactor facilities routinely operate at 100 to 300 percent below current radiation exposure limits.

It was also noted that the economic burden of lowering exposure limits tends to be greater for smaller companies where radiation protection costs account for a higher percentage of total operating budgets and where their limited number of operations happen to be affected by the reduced limits.

With regard to uranium milling operations, it was noted that the radium content of the liquid effluent from ore tailings wastes, when there is no treatment, ranges from 50 to 1,000 times the radium limits which AEC licensees must comply with under provisions of 10 CFR, part 20, and that this presents a major control problem. Effluent control now appears to require additional processing steps involving significant increases in capital costs, depending in size upon the individual plant in question.

In the case of power reactors, substantial safety margins are provided, both through design and conservative operating practice. One estimate showed that if current exposure limits were increased 10 times, there would be a 5 percent decrease in radiation protection costs. If current limits were lowered 10 times, there would be a 50 percent increase in these costs. It was pointed out, in this connection, that, while an increase in cost of a few percent is not large in absolute terms, it does represent an important economic factor.

Some participants noted that moderate changes in existing exposure limits present much less of a problem than arbitrary action by local authorities in applying more rigid limits. It was pointed out that this is a continuing problem and requires additional education at the State and local level on the nature and control of radiation hazards.

Reference was made to certain radiation exposure limits contained in the proposed revision to AEC regulation 10 CFR 20 which in the opinion of some participants would cause substantial economic burdens in relation to the potential hazards and to the safeguards to be achieved. For example, it was noted that the 200 percent reducation in gamma limits has raised certain operational problems that could add substantial and unwarranted costs to uranium casting, and possibly to other fabricating operations. The reduction in the beta exposure limits, it was pointed out, is apparently not subject to substantiation as necessary in view of the relatively small hazard involved. It was noted, in this regard, that external beta radiation associated with normal uranium processing operations, does not have the penetrating characteristics associated with gamma radiation.

While the AEC operations that are currently experiencing the initial effect of the reduced beta exposure limits have handled the situation temporarily by an extensive rotation of regular plant personnel, it is now apparent that smaller