Time to stop consuming precious resources to harmonize occupational dose limits

Pressure groups and interested individuals have been striving for more than two decades to force the U. S. to reduce its occupational worker radiation protection limit from 50 mSv/year to 20 mSv/year. The primary justification for this effort is that in 1991 the International Commission on Radiation Protection (ICRP) issued publication 60 and provided their recommendation that regulators use 20 mSv/year as the occupational limit.

In 1991, the US Nuclear Regulatory Commission had just released a major update to the regulations (10 CFR 20) that establish radiation limits for US licensees. It took about ten years of study and discussion after ICRP publication 60, but on April 12, 2002, the Commission issued a decision item. With a 4-1 vote, the Commission decided they would not conduct a rulemaking to change 10 CFR 20. Here is a quote from the Staff Requirements Memorandum indicating their selected course of action.

The Commission has approved items (ii) and (iv) of Option 3. As such, the staff should continue to work with and monitor the efforts of other Federal agencies to ensure a coherent approach to U.S. radiation protection standards and dosimetric models and work with EPA and ISCORS on possible revisions to the Presidential Guidance in this area. Also, the staff should continue to monitor the work of the ICRP as it develops its revision to ICRP Publication 60.
The Commission disapproved items (i) and (iii) of Option 3 related to preparation of a communications plan and development of a technical information base at this time.
(Note: The Commission’s directive is referring to SECY-01-0148 dated Aug 2, 2001).

The ICRP issued a publication 103 in 2007 that reiterated its previous recommendation to establish an occupational dose limit of 20 mSv/yr. There was no new science introduced that justified the dose limit reduction recommended in 1991.

On December 18, 2008, the staff of the Nuclear Regulatory Commission submitted SECY-08-0197, Options To Revise Radiation Protection Regulations And Guidance With Respect To The 2007 Recommendations Of The International Commission On Radiological Protection. That staff memo was answered by the Commission on April 2, 2009 with Staff Requirements Memorandum (SRM) number SRM-SECY-08-0197.

The Commission has approved the staff鈥檚 recommended Option 3 to immediately begin engagement with stakeholders and interested parties to initiate development of the technical basis for possible revision of the NRC鈥檚 radiation protection regulations, as appropriate and where scientifically justified, to achieve greater alignment with the 2007 recommendations of the International Commission on Radiological Protection (ICRP) contained in ICRP Publication 103.

The Commission agrees with the staff and the Advisory Committee on Reactor Safeguards (ACRS) that the current NRC regulatory framework continues to provide adequate protection of the health and safety of workers, the public, and the environment. From a safety regulation perspective, ICRP Publication 103 proposes measures that go beyond what is needed to provide for adequate protection. This point should be emphasized when engaging stakeholders and interested parties, and thereby focus the discussion on discerning the benefits and burdens associated with revising the radiation protection regulatory framework. For example, while licensees voluntarily develop and implement internal constraints, the regulatory imposition of these constraints is an overreaching insertion of regulatory standards into the licensee鈥檚 management of its radiation protection program.

Jim Conca’s March 23, 2015 Forbes blog post titled The Nuclear Regulatory Commission Thinks America Should Be More Like Europe indicates that the NRC resource expenditures that began with the preparation of that December 2008 memorandum have continued, despite the decision from the Commission that there would be no safety benefit from reducing existing limits.

According to Conca’s article, the staff effort has reached the stage of an Advanced Notice of Proposed Rulemaking (ANPR). Eliot Brenner, the Director of the NRC Public Affairs Office, posted a comment on Conca’s article that clarified the actual proposal and adde a few more details about the ANPR schedule.

The NRC Advance Notice of Proposed Rulemaking (ANPR), published in July, 2014, is open for comment until June 22, 2015.

What Brenner did not mention is that the ANPR published in the Federal Register on July 24, 2014 originally had a comment deadline of November 24, 2014 or that before the ANPR issued in July 2014, there had been at least three other Federal Register notices soliciting public comments that were associated with the same research topic.

On December 17, 2012, the Commission issued another decision memorandum Staff Requirements 鈥 Secy-12-0064 鈥 Recommendations For Policy And Technical Direction To Revise Radiation Protection Regulations And Guidance. That document gave some clear directions.

The Commission has disapproved the staff鈥檚 recommendation in Option 3 to develop the regulatory basis to reduce the occupational total effective dose equivalent.

The staff should develop improvements in the NRC guidance for those segments of the regulated community that would benefit from more effective implementation of ALARA (as low as is reasonably achievable) strategies and programs to comply with regulatory requirements.

Several people who have read and commented on the July 2014 ANPR believe the section proposed as “improvements” to NRC guidance to provide benefits in the form of “more effective” implementation of ALARA strategies describes onerous requirements. They would effectively by-pass the Commission’s decision and implement the ICRP’s recommended 20 mSv/year occupation dose limits despite that recorded decision. Here’s a link to a comment submitted by Dr. Carol Marcus, PhD, MD.

I contacted the NRC Office of Public Affairs to find out how much money and manpower the NRC staff has invested in its effort to follow ICRP recommendations, starting from the issuance of the April 2009 Staff Requirements Memorandum that described those recommendations as “measures that go beyond what is needed to provide adequate protection.” Here is the response I received from Scott Burnell from the Office of Public Affairs.

From time of issuance in 2009 through 2013, the staff worked on generic activities and preparation work related to the rulemaking including developing regulatory basis, holding three facilitated public workshops and writing the 2012 Commission Paper. The staff estimates this level of effort by FSME/NMSS staff was about 3 FTE and about $100,000 in contract support. Due to the work’s generic nature it was indirectly tracked over the course of several years, so we can’t match a dollar figure to the FTE.

In 2013, the office opened a dedicated activity code for the project; from 2014 / 2015 that includes 3,433.75 staff hours for a total of $949,360.25 in staff charges.

Even though Scott was unable to provide a specific conversion factor between Full Time Equivalents (FTE) and dollars, a reasonable approximation would be that 3 FTE at the levels that would be working on this kind of overarching rule making might cost $400,000 per year ($133,000 each for salary plus benefits). Therefore the agency spent about half a million dollars per year for 4 years and then another million dollars in a year and a half (FY2015 is only half over.)

Someday I am going to develop a model that estimates the amount of industry effort expended as a function of each FTE of regulatory effort. Perhaps someone already has such a model, but I would guess that the ratio is at least 10-20 industry FTE for each NRC FTE in a rulemaking scenario.

Things move slowly in all layered organizations, especially those that include plenty of opportunities for public involvement in the decision making process. However, any good manager who has a limited quantity of resources should be willing to frequently ask his people the question, “Please tell me again, why we are doing this?”

A rulemaking process on an issue where a determination has already been made that there is no safety benefit should be a prime candidate for reevaluation. One that is still in the information gathering stage after more than 6 years of effort might be one where the most effective next step is to say ALL STOP.

Nuclear Spent Fuel Expert Describes Vermont Yankee Dry Cask Safety

By Guy Page

By 2020, the spent fuel left over from all 42 years of Vermont Yankee鈥檚 operation is scheduled to be stored in huge steel 鈥渄ry casks鈥 on pads at the plant site in Vernon. Just how strong and reliable are Vermont Yankee鈥檚 鈥渄ry cask鈥 spent nuclear fuel containers?

Consider the following dry cask testing conducted at Sandia National Lab:

  • A tractor-trailer carrying a container ran into a 700-ton concrete wall at 80 MPH.
  • A container was broadsided by a 120-ton train locomotive traveling 80 MPH.
  • A container was dropped 2,000 feet onto soil as hard as concrete, traveling 235 MPH at impact.
  • A container was subjected to a device 30 times more powerful than a typical anti-tank weapon.
  • A container was subjected to a simulated crash of a jet airliner and the armament of an F-16.

In each case, post-incident assessments demonstrated that the containers would not have released their contents.

All of the information shared above was reported Jay Tarzia, Principal of Radiation Safety and Control Services Inc. and chair of the New Hampshire State Radiation Advisory Committee, on March 26 to the Vermont Nuclear Decommissioning Citizen鈥檚 Advisory Panel at Brattleboro Union High School.

Dry casks are designed to resist floods, earthquakes, tornadoes, projectiles, and temperature extremes. Tipped over, they will stay intact. And of course, heavy shielding prevents radiation leakage. They also remained intact after being submerged in water for eight hours and exposed to a 1,475 degree fire for 30 minutes. There have been no known or suspected sabotage attempts or releases of radiation since the first dry cask system was licensed in 1986. At Fukushima, 400 dry casks were exposed to earthquake and tsunami. Although knocked over and tossed around, none were breached.

The U.S. Nuclear Regultory Commission (NRC) licensing allows fuel to be stored for up to 100 years and the NRC is developing an extended storage program for up to 300 years. After 100 years, the fuel鈥檚 radioactivity will have shrunk to about one percent of its beginning total radioactivity. Stress on the canister will be greatly reduced. But Mr. Tarzia did not minimize the longterm nature of dry cask management. After about 4,000 years, the fuel鈥檚 radioactivity will return to the level of the original uranium ore. 鈥淭he fuel will be radioactive for a long time. We need to manage it,鈥 he said. 鈥淭he security doesn鈥檛 go away when the plant goes away, when there鈥檚 a long-term storage site.鈥 The industry is running computer models now showing the outer limits of how long the canisters will last. Ultimately, a long-term storage process or facility will make dry cask storage unnecessary, he predicted.

In closing, Mr. Tarzia predicted that within decades, waste-free nuclear fusion will produce limitless electricity.

Editor’s note: Notwithstanding our disagreement with the prediction in the final sentence, the above information is worth sharing to people who express their deep concerns about “nuclear waste,” what we prefer to call reusable nuclear fuel.
This post first appeared on the site of the Vermont Energy Partnership and is reprinted here with permission.

SMRs – lots of noise but DOE budget that’s 1% of annual wind tax credit

I’ve been spending some time watching, rewatching and clipping interesting excerpts from the Senate Appropriations Energy and Water subcommittee hearings on the FY2016 Department of Energy budget. It’s not everyone’s idea of entertainment, but it’s fascinating to me to watch publicly accessible discussions about how our government makes decisions, sets priorities and spends the money […]

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Look out for “market ingenuity” from stressed LNG project developers

On Wednesday, March 18, 2015, a sobering LNG market analysis article from RBN Energy, LLC titled A Whole New World-Big Changes Coming to LNG Market concluded with the following prediction. Several industry forecasts suggest that, despite 2014鈥檚 pause in demand growth, LNG demand will rise at a healthy annual pace of 4 to 5% over […]

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NRC issues SER for Westinghouse Small Break LOCA PIRT

I apologize for the acronym soup in the title. Here is what I really wanted to say, but couldn’t fit into the title field. On February 27, 2015, nearly three years after it was submitted, the Nuclear Regulatory Commission (NRC) issued a letter reporting that the NRC staff had prepared a final Topical Report Safety […]

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Contradicting Arjun Makhijani’s claim about bombs from power reactors

On March 3, 2015, Arjun Makhijani testified in front of a committee of the Minnesota Senate. The committee was conducting an investigation on whether or not it should recommend lifting the state’s current moratorium on building new nuclear reactors. Here is the presentation that he prepared and delivered. During his recorded testimony, Makhijani falsely stated […]

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Ethics of international radiation protection system

The U. S. National Council on Radiation Protection (NCRP) held its annual meeting in Bethesda, MD on March 16 and 17. On the second day of the meeting, Jacques Lochard, Vice Chair of the International Commission on Radiation Protection (ICRP), gave a talk titled The Ethics of Radiation Protection. The slides from that talk are […]

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South Australian senator believes there’s value in “nuclear waste”


South Australian Sen. Sean Edwards sees economic opportunity for his state by taking advantage of other countries鈥 irrational fear of radioactive materials. He wants to turn what some call “waste” into wealth. He and his staff recognize that there are tens of billions of dollars set aside in government budgets around the world for safe […]

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Irish people should ignore Arnie Gundersen because he’s wrong

A friend who often gets involved in discussions about nuclear energy stories with frightened people in his social media network contacted me to find out what I thought of an article titled Nuclear plant could be a ‘Chernobyl on steroids,’ says expert. Then the same story showed up on one of my daily news feeds. […]

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Wear green today in honor of St. Patrick and nuclear energy

Diablo green

Later today, March 17, 2015 (St. Patrick’s Day), Californians for Green Nuclear Power will be donning the green and holding a rally at the plaza in front of the San Luis Obispo County building at 1055 Monterey from noon until 1:30 PM (PDT). They want to show that the groups fighting to shut down the […]

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Tritium – aka radioactive hydrogen – from reactors is not a threat to human health

Fukushima Tank Farm

Tritium, also known as radioactive hydrogen, is an isotope that releases an 18 Kev beta particle. The isotopic half life is about 12 years. Among other possible production mechanisms, it is produced in low quantities and concentrations in any reactor where water is exposed to a neutron flux. The production rate is higher in heavy […]

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