The U.S. Nuclear Regulatory Commission (NRC) has received three petitions for rulemaking (PRM) requesting that the NRC amend its “Standards for Protection Against Radiation” regulations and change the basis of those regulations from the Linear No-Threshold (LNT) model of radiation protection to the radiation hormesis model.
The radiation hormesis model provides that exposure of the human body to low levels of ionizing radiation is beneficial and protects the human body against deleterious effects of high levels of radiation. Whereas, the LNT model provides that radiation is always considered harmful, there is no safety threshold, and biological damage caused by ionizing radiation (essentially the cancer risk) is directly proportional to the amount of radiation exposure to the human body (response linearity).
Three petitions have been filed to help prevent unnecessary, radiation-phobia-related deaths, morbidity, and injuries associated with distrust of radio-medical diagnostics/therapies and from nuclear/radiological emergencies through countering phobia-promoting misinformation spread by alarmists via the news and other media including journal publications.
One petitioner suggests that there is “vast literature” that demonstrates that low doses of radiation have no deleterious effect, and some studies even suggest that low doses of radiation may have protective effects. The petitioner writes, “[t]he literature showing protective effects supports the concept of hormesis, in which low levels of potentially stressful agents, such as toxins, other chemicals, ionizing radiation, etc., protect against the deleterious effects that high levels of these stressors produce and result in beneficial effects (e.g., lower cancer rates).” On May 16, 2015, the petitioner submitted an additional reference to the NRC providing technical information supporting her requests.
Part of the NRC’s mission includes making sure nuclear power plants control and monitor the very small amounts of radioactive material that might be released during normal operations. Filtering and otherwise maintaining a reactor’s cooling water can create radioactive gases and liquids. The amounts generated and released vary depending on a reactor’s design and overall performance. The primary regulations for radioactive emissions (also called radioactive effluents) from commercial nuclear power plants are in 10 CFR Part 50, Appendix I.
These rules are designed to keep normal airborne or liquid releases low enough that any public radiation dose would be a minute fraction of the dose from natural background radiation. Appendix I also requires U.S. nuclear power plants to further reduce potential doses as much as reasonably possible. This set of regulations includes requirements for plants to regularly sample their nearby environments. The plant’s samples of air, water, milk, soil, vegetation, sediment and fish come from the property line, on-site, and from nearby towns.
In 2007, the International Commission on Radiological Protection published recommendations that account for updated scientific understanding of the way to calculate radiation doses. For the past few years we’ve been considering amending the NRC’s radiation protection regulations. We’ve talked with public interest groups, other federal and state agencies and the industries or individuals we regulate on the possibility.
The NRC’s Commissioners gave the staff direction about potentially amending these regulations in December 2012. The Commission told the staff to begin developing the regulatory basis for revising the NRC’s radiation protection regulations in 10 CFR Part 20 and regulations for radioactive effluents from commercial nuclear power plants in 10 CFR Part 50, Appendix I “to align with the most recent methodology and terminology [in the ICRP 2007 recommendations] for dose assessment.”
The NRC just held a meeting soliciting feedback on the development of a draft regulatory basis for updating 10 CFR Part 50, Appendix I in Savannah, Ga., on June 27, 2014. The attendees, either in person, on the phone or watching our webinar, gave us some great comments to consider.
We’ll continue the discussion later this summer by issuing an Advanced Notice of Proposed Rulemaking (ANPR) in theFederal Register. The notice will list future meetings and describe the regulatory process in more detail.
Based on feedback received from the public conversations and the ANPR, NRC staff will complete the regulatory basis and make a recommendation to the Commission on whether revisions that may affect how radiation dose is calculated, how it is measured and how radioactive effluents are reported annually are warranted. The NRC staff anticipates the regulatory process related to potential updates will take several years to complete.
You may submit comments by any of the following methods (unless this document describes a different method for submitting comments on a specific subject):
• Federal Rulemaking Web Site: Go to http://www.regulations.gov and search for Docket ID NRC-2015-0057.
Address questions about NRC dockets to Carol Gallagher; telephone: 301-415-3463; e-mail: [email protected]. For technical questions contact the individual listed in the FOR FURTHER INFORMATION CONTACT section of this document.
• E-mail comments to: [email protected]. If you do not receive an automatic e-mail reply confirming receipt, then contact us at 301-415-1677. • Fax comments to: Secretary, U.S. Nuclear Regulatory Commission at 301-415- 1101.
• Mail comments to: Secretary, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, ATTN: Rulemakings and Adjudications Staff.
• Hand deliver comments to: 11555 Rockville Pike, Rockville, Maryland 20852, between 7:30 a.m. and 4:15 p.m. (Eastern Time) Federal workdays; telephone: 301-415-1677. For additional direction on obtaining information and submitting comments, see “Obtaining Information and Submitting Comments” in the SUPPLEMENTARY INFORMATION section of this document.
FOR FURTHER INFORMATION CONTACT: Solomon Sahle, Office of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission, Washington DC 20555-0001; – 3 – telephone: 301-415-3781, e-mail: [email protected]. SUPPLEMENTARY
AN ANTI-NUCLEAR ACTIVIST COMMENT
No amount of radiation is safe, natural or man-made. The NRC should have a zero tolerance level on any radioactive releases, and any reactor that can’t operate without emitting radiation should be shut down.
Wall St. Journal, Jan. 22, 2014: “Restarting nuclear reactors while we still have no place to dispose nuclear waste is a criminal act toward future generations,” [Former Prime Minister Morihiro] Hosokawa said during a news conference where he laid out his campaign promises for the Feb. 9 election.
Bloomberg, Jan. 22, 2014: “The myth that nuclear power is clean and safe has collapsed,” Hosokawa told reporters in Tokyo today. “We don’t even have a place to store nuclear waste. Without that, restarting the plants would be a crime against future generations.”
Kyodo News, Jan. 22, 2014: “Nuclear power is out of date and the most costly source of energy,” Hosokawa said. “The severity of risks associated with nuclear power is high. We have to switch to renewable and environmentally friendly energies, and lead the world in that field.”
Reuters, Jan. 22, 2014: “I foolishly once believed the myth that nuclear energy is clean and safe,” he told a news conference. “That myth has completely broken down.”
Kyodo News, Jan. 22, 2014: “Nuclear power is out of date and the most costly source of energy,” Hosokawa said. “The severity of risks associated with nuclear power is high. We have to switch to renewable and environmentally friendly energies, and lead the world in that field.”
Kyodo News, Jan. 18, 2014: Many voters, however, may cast ballots for anti-nuclear candidates because the man-made Fukushima disaster, triggered by the massive earthquake and tsunami on March 11, 2011, raised questions about the viability of Japan’s future. Naoto Kan of the DPJ, also a former prime minister, is urging Tokyo residents in his blog to concentrate on backing Hosokawa if they think Japan should phase out nuclear power, calling Hosokawa’s run “a nightmare for the LDP.” “Japan has faced many problems, and the issue of nuclear power generation leads to the fate of this country,” Hosokawa said after securing Koizumi’s support.
Mainichi, Jan. 15, 2014: […] former prime minister [Hosokawa] said the issue of nuclear power will determine the fate of Japan. […] Despite the outbreak of the unprecedented disaster at the tsunami-ravaged Fukushima No. 1 Nuclear Power Plant, the nuclear power policy was not sufficiently debated in the two post-disaster national elections. […] As Koizumi points out, the outcome of the election will have a huge impact on the direction of national politics.
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