The Nuclear Regulatory Commission has proposed a change to how it will approach standards for radiation protections, notably including the elimination of the “as low as reasonably achievable” (ALARA) principle. The proposed change was published in the Federal Register on July 15, and yesterday the agency held a public meeting on the topic.

In the meeting, Mike Franovich, director of the NRC’s Office of Nuclear Regulatory Research, gave a presentation summarizing the changes, and NRC staff answered questions from participants. The meeting facilitator, Lance Rakovan, described it as a “very popular meeting,” drawing more than 550 participants, and the NRC staff was unable to address all questions in the scheduled time.

On July 1, the Nuclear Regulatory Commission proposed removing the “as low as reasonably achievable” (ALARA) principle from its radiation protection regulations and replacing it with a graded approach. The agency also proposed increases to effluent dose limits and adjusting how it handles allowances for exceeding dose limits.

For decades, U.S. radiation protection has rested on two pillars: the linear no-threshold (LNT) model and the principle of “as low as reasonably achievable” (ALARA). Together, these have shaped occupational dose management, regulatory limits, and emergency planning across the nuclear industry.

A proposed rule from the Nuclear Regulatory Commission would update radiation protection regulations and remove “as low as reasonably achievable” (ALARA) language without changing specific radiation exposure limits that are based on the linear no-threshold (LNT) model of low-dose radiation health effects. A second proposed rule would reform reactor licensing, safety oversight, and siting practices with changes the agency said are the most significant in years.

The NRC unveiled the two proposed rules on July 1 and published them in the ADAMS public document library the same day. The rules have not, at this writing, been published in the Federal Register, but once they are, each rule will be open for public comment for 45 days.

Katy Huff, former assistant secretary of nuclear energy at the Department of Energy, recently wrote an op-ed that was published in Scientific American.

In the piece, Huff, who is an ANS member and an associate professor in the Department of Nuclear, Plasma, and Radiological Engineering at the University of Illinois–Urbana-Champaign, argues that weakening Nuclear Regulatory Commission radiation regulations without new research-based evidence will fail to speed up nuclear energy development and could have negative consequences.

One of the more pivotal issues in facilitating the use of radiation sources—including nuclear power—in the United States (and most of the Western world) is concern about the health effects of low levels of radiation. The current regulatory assumption is that every additional increment of radiation linearly increases the risk of cancer.

A report just released by Idaho National Laboratory reviews decades of radiation protection standards and research on the health effects of low-dose radiation and recommends that the current U.S. annual occupational dose limit of 5,000 mrem be maintained without applying ALARA—the “as low as reasonably achievable” regulatory concept first introduced in 1971—below that threshold.

Noting that epidemiological studies “have consistently failed to demonstrate statistically significant health effects at doses below 10,000 mrem delivered at low dose rates,” the report also recommends “future consideration of increasing this limit to 10,000 mrem/year with appropriate cumulative-dose constraints.”

Kathryn Higley

For nearly a century, the National Council on Radiation Protection and Measurements has served as the United States’ leading authority on radiation protection. Established in 1929 as the Advisory Committee on X-ray and Radium Protection, the NCRP was created in response to growing concerns about the health risks of radiation exposure following the discoveries of X-rays and radioactivity.

It was formally chartered by Congress in 1964 through Public Law 88-376, also known as the National Council on Radiation Protection and Measurements Charter Act. The NCRP has provided science-­based guidance for the public, workers, and the environment. Its work spans a wide range of topics, including protecting patients and workers in medical, industrial, and environmental settings; supporting emergency preparedness; developing risk models for low-dose exposures; guiding safe practices for new technologies such as advanced nuclear reactors; and providing information on wireless communication devices.

Craig Piercy
cpiercy@ans.org

So, President Trump has just kicked the low-dose radiation hornets’ nest.

Specifically, his recently signed executive order “Ordering the Reform of the Nuclear Regulatory Commission” calls for the NRC to “reconsider reliance” on the linear no-threshold (LNT) theory and the ALARA (as low as reasonably achievable) standard for radiation protection.

This directive will certainly reignite a vociferous debate within the radiation research community over the continued efficacy of using LNT as the basis for protecting the public and the environment, a community that has been wracked with controversy on this matter for the last few years.

I must admit that whenever the low-dose issue comes up, my first thoughts always go to Sayre’s Law.

The Hill recently published an opinion piece by Cindy Folkers and Amanda Nichols entitled “They won’t tell you these truths about nuclear energy.” Sadly, after the first sentence, their so-called truth veers into a diatribe of antiscientific fearmongering and misrepresentations.

Researchers at the Department of Energy’s Argonne National Laboratory are developing and deploying ARG-US (from the Greek Argus, meaning “Watchful Guardian”) remote monitoring systems technologies to enhance the safety, security, and safeguards (3S) of packages of nuclear and other radioactive material during storage, transportation, and disposal.

The Steam Generating Team (SGT)—a joint venture of Framatome and United Engineers & Constructors Inc.—has completed a project to replace the Unit 2 steam generators at the Watts Bar nuclear plant, Framatome announced last week.

Watts Barr’s owner and operator, the Tennessee Valley Authority, awarded Framatome the contract for the work in early 2020.

Using basic hand tools and remote manipulators, operators at Savannah River Nuclear Solutions (SRNS) were able to reduce radiation exposure to workers performing cutter head maintenance in the Savannah River Site’s Tritium Extraction Facility (TEF).

According to SRNS, the innovative procedure proved to be an excellent example of real-world application of As Low As Reasonably Achievable (ALARA) principles of time, distance, and shielding.

Mary Lou Dunzik-Gougar

Nuclear energy is the cleanest, safest, densest, and most reliable energy source. The value proposition for nuclear energy is unparalleled. It is the only commercially proven, “dispatchable” clean energy technology that can be scaled up fast enough to meet the demand for electricity in a decarbonizing scenario. It is the answer for governments and nongovernmental organizations worldwide that are clamoring for a reduction in human-generated CO₂ emissions. Humans flourish when they have access to plentiful, safe, and reliable energy. Nuclear excels at all of these.

Mary Lou Dunzik-Gougar

During my time as vice president and president of ANS, I have been advocating for a new approach to implementing dose limits across the nuclear industry. A lack of understanding and an unfounded fear of radiation has resulted in widespread efforts to minimize dose, rather than to optimize radiation protection in a holistic sense. I want to put the “reasonably” back into ALARA (“as low as reasonably achievable”). Such a paradigm shift, from minimization to optimization, while easily said, equates to a major cultural change spanning international government agencies, industry, nongovernmental organizations, professional societies, and even academia. It is essential to have the active participation of all stakeholders in a transparent process to effect such a change. This process will not only lead us toward a more level playing field for nuclear, it will also greatly impact public perception of nuclear and radiological technology.

Join ANS on Thursday, January 21, at noon (ET) for a Q&A with an expert panel as they discuss how to communicate about the risk of low-dose radiation. “Talking About Low-dose Radiation Risk” is a free members-only event that serves as a follow-up to the “Risky Business” President’s Session that took place during the ANS Virtual Winter Meeting last November. The session will take a deeper dive into the many questions generated from the thought-provoking discussion.

Register now to attend the webinar.

ANS President Mary Lou Dunzik-Gougar took to the video screen on November 18 during the 2020 ANS Virtual Winter Meeting for the President’s Special Session on radiation risk, echoing a comment by Exelon Nuclear’s Bryan Hanson, the Winter Meeting’s general cochair, who earlier in the week characterized radiation as one of the most misunderstood aspects of nuclear.

“I think that’s very true,” Dunzik-Gougar said. “So much misconception and misunderstanding. I have always had a passion for communicating about such things as radiation, helping people understand the nature of radiation and the relative risks of nuclear, but mostly about its benefits. But I think we in the industry can better prepare ourselves with knowledge about radiation and its impacts and also educate ourselves on how to talk about the risks of radiation with people not in our own echo chambers to help change the perception among a broader scope of people.”

The panel of experts assembled to help impart some of that knowledge to session attendees included Amir A. Bahadori, assistant professor at Kansas State University; Donald A. Cool, a technical executive at the Electric Power Research Institute and a former senior executive at the Nuclear Regulatory Commission; Paul Locke, associate professor at the Johns Hopkins Bloomberg School of Public Health; and Shaheen Dewji, assistant professor at Texas A&M University.

Radiation has benefited mankind in many ways, including its use as an energy source and an indispensable tool in medicine. Since the turn of the 20th century, society has sought ways to harness its potential, while at the same time recognizing that radiological exposures need to be carefully controlled. Out of these efforts, and the work of many dedicated professionals, the principles of justification, optimization, and limitation have emerged as guiding concepts.

Justification means that the use of radiation, from any radiation source, must do more good than harm. The concept of optimization calls for the use of radiation at a level that is as low as reasonably achievable (ALARA). Dose constraints, or limitation, are meant to assist in reaching optimization and protection against harm by setting recommended numerical levels of radiation exposure from a particular source or sources. Together, these three principles form the bedrock of the international radiation protection system that drives decision-­making and supports societal confidence that radiation is being used in a responsible manner.