So there apparently was this element of lack of knowledge and the inclusion of a certain amount of prudent judgment or value judgment, as well as the scientific facts involved, in the setting of these guidelines. Dr. LAPP. I think that up until a very short time ago there was no reason for this to be in need of more universal participation in setting up the standards, because radiation was not a global or truly national problem. When it becomes such, I think you have to provide some means for allowing information and viewpoints to come in. I think that is being done now. We are seeing the injection of this into these various considerations.

Representative HOLIFIELD. We face a growing problem here. The more of these isotopes that are distributed and the more reactors that are built, the greater our sphere of interest becomes. While Dr. Somerville, I think, did point out that in some States they have been very alert to this problem, I believe I could point out than in many States, possibly 48 States out of the 50, there has not been the interest that there has been in the 2. Therefore, there is a great field of need because in some of the States there is a total lack of radiological protection by statute.

Thank you very much, gentlemen. I think this has been a very profitable roundtable, and I thank each one of you for your participation.

Tomorrow we will have concepts of practical application, in this

room.

The committee is adjourned.

(The following statements were submitted for the record:)

COMMENTS ON QUESTIONS IN OUTLINE TOPIC III-B ON THE SUBJECT "RADIATION PROTECTION CRITERIA AND STANDARDS: THEIR BASIS AND USE," BY WILLIS GALE, PRESIDENT, COMMONWEALTH EDISON CO.

III-B. CONCEPTS PRIMARILY SOCIAL AND ECONOMIC AND CONCEPTS OF POLICY Statement of general policy

The policy of Commonwealth Edison Co. for Dresden Nuclear Power Station is that operation of the plant shall not constitute a hazard to employees, inhabitants of the immediate environs, or the population of the general area. (1) For hazards other than that of radiation, how-given assumed concepts of benefits, risks, and costs-are protection criteria and standards developed? Certain minimum standards have been developed by Government agencies, but today's alert management has gone beyond these minimums to provide a safe working environment. Through extensive safety education and training, and as a last resort by disciplinary action, great strides have been made to eliminate work hazards.

Development of protection criteria and standards today is aided by the National Safety Council, U.S. Department of Labor, and various State health and safety agencies, and the American Standards Association.

The benefits of increased productivity, high employee morale, and reduction of costs of liabilities become apparent to industry and are augmented by humanitarian reasons for increased safety.

Risks and costs: Benefits, risks, and costs are so closely related that alteration of any one of the three will have its effects upon the other two. An illustration of this point might be the variation in costs as a function of changes in risk. If more or greater risks are present, higher cost can be expected and will be reflected in insurance premium rates, employee medical costs, greater maintenance costs for damaged or excessively worn equipment.

(2) From a policy and economics point of view, to what extent can experience and practice in developing criteria or standards for hazards other than radiation be applied to radiation hazards?

Previously developed protection criteria and standards for conventional plants are applicable also to a nuclear power station since much of the equipment is operated in a similar manner. Therefore, a framework is readily available from which to extend the additional criteria for radiation protection. Current AEC regulations and contemplated revisions were followed in designing the station and provide the basis for insuring maximum protection for station personnel and the public.

The attached paper entitled "What Constitutes a Safety Program in a Nuclear Power Station," presented to the National Safety Conference in October 1959 by our Mr. J. F. Jones, outlines Edison's safety program for conventional stations as adapted to our Dresden Nuclear Power Station.

(3) What is meant by "philosophy of risk"? Does it apply to both individual and population standards?

A. The electric utility industry has always recognized that there are hazards in the generation and handling of its product. Hence, extreme measures have been taken to train its employees and educate the public in the safe handling and use of electricity.

The fact that hazards do exist has not prevented the industry from continually making innovations in methods of production and distribution. Atomic power is the latest of these innovations.

Commonwealth Edison would not have built and would not operate Dresden Nuclear Power Station unless it were convinced it could be done without endangering its employees and the public.

Every known safety measure has been incorporated in the designing of the plant. Safeguards for the operating personnel of the nuclear plant and for the public have been incorporated.

B. Illustrations of this philosophy are being observed in the world around us, wherein individuals and nations apply the principle. Nations take "calcu lated" risks to achieve what is deemed valid goals and ends. More specifically, the individual worker and scientist in the nuclear industry assumes an additional risk in solving the challenging problems. We exert every effort to the end that these risks in our industry are minimized.

(4) Discuss the applicability of the "graded-risk" or "graded level of action" concept. Illustrate.

Turning to the insurance industry for the purpose of discussion, risks in terms of liability are divided into categories dependent upon the frequency of occurrence against which the insured desires protection. Small losses occur on a rather fixed frequency and the funds required to cover this type of loss are determined with relative ease. High loss risks occur very infrequently and with little or no pattern, and thereby complicate the determination of funds to be reserved. Very high losses, obviously, are beyond any ordered or scientific method of evaluation, and therefore funds reserved for the loss are determined by evaluating expert opinions on probabilities of the loss occurring and the specific area to be effected. Fund reserves for the latter category of loss cannot be based upon experience; rather they are based principally upon judgment of the insurance institution and somewhat upon what the traffic will bear. (5) Discuss the "philosophy of allocation" of exposure.

The breadth of this philosophy involves two categories: exposure among specialized work groups within the nuclear industry and exposure of the public. 1. The practice of distributing exposure among a work group in nuclear installations is recognized as acceptable. This practice affords protection to individuals against continuous exposure equal to or-on rare occasions-above the prescribed limits. The policy of distributing exposures also increases flexibility in the work group and provides a judicious use of exposure.

2. On the other hand, the philosophy of controlling or regulating the exposure of the public by allocation would seem impossible; the reason is that exposure for the whole population, including the above work group, results from a number of sources, i.e., natural resources, manmade (other than fallout), and environmental contamination (fallout).

(6) What are the implications of a hazards situation in which the group taking the risk is different from the group obtaining the direct benefits associated with the risk?

Here again is an example of the relativeness of risk. Industry in general accepts the fact that certain groups take risks for the benefit of other groups. The nuclear power industry is no different. However, it may well be that risks are no greater than segments of other industries.

(7) What constitutes an adequate reason for accepting a given degree of exposure risk?

The problem of evaluating a reason for accepting any risk or exposure risk is dependent upon the extent of the risk compared to the benefits to be gained. The training, experience, and maturity of judgment of the individual making the decision are important factors. Illustration: Driving an automobile in excess of speed limits just to be "on time" at the job. Commonsense, which is essentialy the sum total of training, experience, and maturity, is used to make the decision by evaluating the risks involved and the end benefit.

The evaluation of an adequate reason for accepting a given degree of exposure largely involves the forementioned factors fortified with the existing well-defined limitations on exposure or dose which are accepted as safe.

The following examples may illustrate criterions for accepting a given degree of exposure and exposure risk.

A. An individual may be injured and be unable to remove himself from an extremely dangerous situation. His continued presence will result in a lethal dose (exposure). Provided the time interval was sufficient (which reflects the dose rate) for someone to undertake rescue, the saving of a human life would certainly be reason for accepting the added exposure risk. However, conversely, if the victim were beyond saving and the rescuer would sustain injury and pos sibly death, the reason to undertake such a risk would be questionable.

B. With a destructive malfunction of certain operating equipment in a nuclear plant, a large portion of the personnel might be significantly injured from the resultant release of radioactive material. Rescuing the personnel would con stitute an adequate reason for accepting a given degree of exposure if the effects would be less than lethal. However, one cannot predict how individuals might react to these conditions; it is conceivable that even a lethal dose (exposure) would be acceptable to one for the benefit or welfare of many.

C. Routine cleaning of floors in the plant (not radioactively contaminated would not constitute an adequate reason for accepting a degree of exposure in excess of ordinary operating conditions. Likewise, it would be inconsistent to accept a lethal dose (exposure) or any exposure in excess of ordinary operating conditions just for the sake of saving a piece of equipment in the plant.

(a) What are the practical limits to which radiation protection can be carried! The current AEC and National Committee on Radiation Protection exposure limits and proposed revisions are practical. They permit operation of the plant with a reasonable number of persons who would spend approximately 40 hours per week for 50 weeks per year performing their assigned duties. Based upor present knowledge of radiation effects, there is no necessity for changing thes limits.

(b) How do the costs of radiation protection relate to the degree of protection! One can safely say that the costs of radiation protection are directly related to the degree of protection. Additional protection in the form of more shielding. remote operating and maintenance mechanisms, and other plant complexities tr meet more restrictive criterions for radiation protection would require greate: capital investment.

(c) Do indirect economic or social "costs" exist which also increase with increasing protection? Illustrate: e.g., impairment of feasibility of power re actor project.

Any further restrictions beyond the proposed radiation limits would add finascial burden upon the power reactor program and could deter advancement in the use of nuclear power. Overemphasis of protective measures in the environs of the plant could have an alarming effect upon the public and retard public acceptance of this vital new industry.

(d) Is there any precedent for insisting upon "absolute safety," assuming it to be available?

We know of no such precedent. It is difficult to imagine a situation in which some objective could be attained and still guarantee "absolute safety." The concept of "absolute safety" is incompatible with an industrial economy. In fact, it is incompatible with life itself.

(8) What is the nature of the decision process whose result is expressed as radiation protection "criteria" or "standards"?

A decision process for the preparation of radiation protection standards won' require certain prior information before the standard could be formulated The prior information needed would include the nature of the nuclear project.

the magnitude of the operation, the general policy limiting expected risk to be experienced as a result of the operation, and expected expenditures to be available for the operation.

The outline of the steps of a decision process would be as follows:

I. Preparation :

A. Investigation:

1. Discovery.

2. Collection.

3. Condensation.

B. Analysis.

C. Comparison.

II. Making the decision:

A. Evaluation.

B. Command (regulation).

Preparation in this application would require collection of all previous knowledge on the subject of radiation hazards, biological effects, permissible limits, instrumentation availability, and shielding characteristics of different materials. Where certain information is not available experiments would be required to discover new data such as shielding characteristics of new materials or old materials under new conditions, and study of a biological system's response to radiation in comparison to the response of measuring devices.

Condensation of raw test data into comprehensible form for interpretation is necessary to ascertain that enough data has been assembled and that its validity is assured.

Analysis must be made of the data of an investigation. The observed effects and the interpretation of these facts will provide meaning and value to each of a number of alternatives. For example, the biological effects of gamma rays, neutrons, alpha and beta particles require measurement. Knowledge of these effects has definite results in the design of any plant.

Comparison is necessary to evaluate the benefits, risks and costs for one set of conditions with those of an alternate. An example might be in the design of a ventilation system as contrasted to wearing respiratory protection in certain areas of a plant.

Making the actual decision will depend upon a simultaneous evaluation of all collected data and review of these to assure conformity with the original policy. Each method of control of exposure would be evaluated in the light of current and proposed regulatory limitations. The cost of the different methods would be a factor, but not necessarily the dominant one.

The evaluation would include the results of defining the anticipated hazards, their sources, locations in which to be expected, and magnitude of each hazard. The command or protective standard then is formed and would include limits of annual radiation exposure and exposure rates during definite time intervals, and the necessary radiation protection procedures.

No comments on questions 8(a), 8(b) and 9 of Outline Topic III-B.

(The following supplementary statement was submitted to the Joint Committee on Atomic Energy by Dr. Ralph E. Lapp.)

I have reviewed Staff Report No. 1 of the Federal Radiation Council, "Background Material for the Development of Radiation Protection Standards," dated May 13, 1960. I wish to comment largely upon section VII, "Summary and Recommendations," pages 36 through 39, section numbers 7.1 through 7.18.

My comments are of a preliminary nature and are deliberately "mild" in flavor for two reasons. First, the report is labeled as a staff paper and does not apparently constitute a policy statement. Second, the Federal Radiation Council is still in its infancy and I have no desire to be harshly critical of the newborn.

Section 3.12

137

My comments in the panel discussion of May 31, 1960, made clear that I do not agree with the descriptive evaluation given in sections 3.12 and 3.18 of the contribution of fallout to the manmade environmental contamination. The emphasis upon Cs as the principal contributor to the gamma hazard overlooks the importance of shorter-lived activities present in fallout as measured in the United States during 1958 and 1959. In this connection I am appending a paper submitted to Science magazine on June 5, 1960, detailing my views. (The paper referred to is contained in the Joint Committee files.)

1. Recommendation.-The Federal Radiation Council should prepare and publish an expository statement on fallout, complete with technical appendixes, surveying all aspects of the problem. The American people need such a document and it is long overdue. The technical data are now out in the open, due almost entirely to the investigations of the Joint Committee on Atomic Energy, but they have not been integrated into a simple and understandable exposition. 2. Recommendation.-The Federal Radiation Council take pains to consult with scientists who have advanced critical views of the fallout problem in order that any FRC statements will be subject to divergent views prior to publication. Section 7.1

Providing a Federal policy on human radiation exposure is important but it is equally, if not more important to recognize that current medical practice involves radiation exposures in excess of commonsense standards. It should not be necessary to await the promulgation of detailed standards before attention is given to the radiation excesses of the medical profession. Dr. Jack Schubert and I have detailed a partial record of these excesses in "Radiation," a book published by Viking Press in 1957; I understand that Dr. Schubert will include material from this book in his supplementary statement.

3. Recommendation.-The Federal Radiation Council should take steps to issue as soon as possible a radiation guide for the layman detailing the nature of radiation exposure associated with current medical practice both in the diagnostic and therapeutic field.

4. Recommendation.-The Federal Radiation Council should authorize an extensive survey of the medical profession to determine the status of radiation practice and the condition of radiation equipment. This survey should include all applications in which X-rays, radium and its products, and radioisotopes are involved. This survey should be published promptly both in statistical form and in an abbreviated expository form suitable for the lay reader.

5. Recommendation.-The Federal Radiation Council should study the problem of radiation controls, based upon its survey of the extent and nature of radiation hazards present in the United States. It should thereupon institute or recommend adequate regulation and control for the proper reduction of radiation hazards in the United States. The medical profession may be expected to resist such regulation and control, and pressure will be brought to hear to allow the medical profession to continue as it has in the past. The record of the medical fraternity gives no reason for the optimistic assumption that it will set its own house in order. Radiation hazards have been recognized for well over half a century and yet the overuse and improper use of penetrating radiation has continued. Each year witnesses the increased exposure of the U.S. population to larger amounts of radiation. This is the No. 1 radiation hazard in the United States today and it deserves priority attention by the Radiation Council. Section 7.2

A major shortcoming of the report is that it fails to direct emphasis to sources of radiation exposure in terms of man-rem units. In other words, it fails to put the radiation problem in proper perspective. Too much attention is focused upon occupational hazards whereas this is clearly No. 3 on the list of contributors to the national radiation dosage. Medical exposure is No. 1; fallout radiation is No. 2 (but declining), and occupational exposure is No. 3. An additional category involves irradiation from natural sources under man's control, namely, building materials which add to the natural background. This touches upon a complex problem in view of the economic consequences, but it should be thoroughly explored so that it can be assessed in quantitative terms.

6. Recommendation.-The Federal Radiation Council should reassess its Staff Report No. 1 and focus emphasis upon medical exposure as the No. 1 problem of radiation exposure in the United States.

Section 7.3

With respect to the factual material presented in subsections 1 through 9, the comment may be made that subsection 6 is important enough to deserve special emphasis. In fact, the Federal Radiation Council may wish to specify four periods of human exposure during which radiation safeguards have a somewhat different degree of importance, i.e.

Period I-Exposure in utero.

Period II-Exposure during infancy.

Period III-Exposure in youth.

Period IV-Exposure in adult life.