US nuclear bodies submit comments on radiation protection

6 August 2014

Following a US Environmental Protection Agency proposal to revise Environmental Radiation Protection Standards for Nuclear Power Operations (40 CFR 190) in February 2014, the American Nuclear Society and Nuclear Energy Institute have announced that they have commented.

In the proposal, EPA said, "These standards were the earliest radiation rules developed by EPA and are based on nuclear power technology and the understanding of radiation biology current at that time."

ANS urged a 'comprehensive rewrite' of the rules. ""Since [they were originally published], the global scientific community made substantial advances in understanding the health effects of ionizing radiation and has collected a large body of epidemiological data related to low level radiation exposure," said president Michaele Brady Raap.

ANS has offered comments on six issue areas, including the dose limit calculations intended to protect individuals.  In a statement to the EPA, the American Nuclear Society urged the EPA to refrain from over-estimating the likelihood of dose contributions from multiple radiation sources, or from applying protective factors that have already been accounted for in the dose constraint.  Both of these practices, ANS believes, result in dose limits that are overly restrictive without appreciable improvement in safety.  Other issues focused on by the Society include updated dose methodology (dosimetry), radionuclide release limits, water resource protection, spent nuclear fuel and high-level radioactive waste storage, and new nuclear technologies.

It also said that the larger environmental and health context in which EPA's radiation standards are used has changed. There is now a fairly robust scientific consensus that climate change could pose significant potential risks to the general public. There is nearly global consensus that the continuation and expansion of nuclear energy is a necessary component to any meaningful strategy to reduce CO2 emissions as a means of mitigating those potential risks.

The NEI's position is that the nuclear industry's operating procedures protect the public and the environment far beyond the regulatory requirements. NEI said that revising the regulation would place additional regulatory burdens on nuclear facilities with little or no benefit to public health and the environment.

NEI's senior project manager for radiation safety and environmental protection, Jerry Hiatt, provided industry recommendations on several questions raised by EPA should the agency proceed with rulemaking.

  • Dose vs. Risk Based Limits: Rather than change to a risk-based limit that would be hard to define and implement, Hiatt's comment letter said EPA should continue to express public radiation exposure limits in terms of "effective radiation dose." The use of dose-based limits is supported by expert organizations worldwide, including the International Commission on Radiation Protection, the European Union, the Health Physics Society and the National Council on Radiation Protection.
  • Dose Methodology: A single dose limit expressed in terms of effective dose "is a logical solution," Hiatt says. This would automatically incorporate the most current scientific advances in dosimetry and could be developed to be consistent with potential changes to the Nuclear Regulatory Commission's regulations.
  • Radionuclide Release Limits: EPA should no longer use the concept of "collective dose" [as defined in 40 CFR 190.10(b)] to globally limit the total discharge of any specific radionuclide to the environment. The concept "has been widely dismissed" by the scientific community as a means for assessing radiation risk and adds no value to public and environmental protection, Hiatt says. An effective dose limit on exposures to individuals located near nuclear facilities [in 40 CFR 190.10(a)] would continue to "protect the public and the environment against the effects of all released radionuclides from uranium fuel cycle facilities."
  • Water Resource Protection: The nuclear power industry agrees with EPA that ground and surface waters are valuable resources and that it is far "better to take measures that prevent water contamination than to subsequently have to clean up the contamination. However, the agency should continue to use "all-pathways" dose standards to protect ground and surface water from contamination. "Pathway-specific" limits for groundwater remain unnecessary, NEI says. Hiatt noted that the industry's groundwater protection and underground piping initiatives provide an additional layer of protection to the public health and the environment.
  • Used Fuel Storage: The industry believes existing regulations governing used fuel storage up to the time of disposal are sufficiently protective, and there is no need to develop a separate rule.
  • New Nuclear Technologies: NEI believes the current regulations adequately cover all known potential nuclear technologies, including alternative fuel cycles and facilities, and small light water reactors.

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