1. Nice job of reporting on this Rod.

    I think the NRC staff could make better use of their time by talking to the EPA to get them to align the highly conservative and restrictive EPA environmental radiation regs to the 1991 revised 10CFR20.

  2. Dose rate per year is part of the problem. Medicine, alcohol limits etc are all set on a per day basis. For very good reasons – a medicine dose per year would not only be silly, it would be out right dangerous. 400 aspirin pills a year is not a safe limit, but 2 pills a day is. We need this for rad protection as well.

    I propose to go from 50 msv/year to 1 msv/day. Drop alara- it makes no sense to put even pennies in reducing below 1 msv/day

    1. @Cyril r

      Agree that an annual dose rate is not the right limit. Though daily dose rates are useful, they may also be too limiting in certain maintenance situations.

      Recently conducted studies that can detect effects on DNA appear to indicate that healing from radiation induced effects is complete in several days. That leads me to believe that the concept of weekly limits with some guidance on rest periods that was introduced into protection limits in the early 1950s provides guidance that has a firm basis in biologic response and provides adequate protection.

      That idea also meshes well with the concept of dose fractionation used in medical applications of radiation.

      1. Hi Rod,

        Sort of agree and disagree with you on this one.

        Whether dose limits are too limiting is not relevant. Dose limits should be protective; if protective limits are too limiting, then that is the fault of a nuclear power plant or equipment/shielding design.

        An issue I can see with a dose per week limit is the extreme case where a worker does a (say) 10 mSv job once a week and stays at or below the limit. We do not know the long term health impacts of receiving 10 mSv once a week for years.

        In case of my box of aspirin it recommends no more than 6-8 per day. Translating that to a weekly limit would produce a 56 pills/week limit. However, I would never eat 56 pills in one hour (for example).

        24 hours seems like a reasonable recovery period for the human body unless the insult is particularly demanding.

    2. 100 mrem/day would be very difficult during outages……especially at boilers. This would push the ALARA concept to a whole new level and make the job of being an HP hell. Getting a dose alarm is bad enough now, I couldn’t imagine exceeding a regulatory limit. Now, 500 mrem/day could possibly work.

  3. “3,433.75 staff hours for a total of $949,360.25” = $277/hour
    so I figure one 1 FTE-year (at 80% billable hours) costs 1664 x $277 = $460,000 (not $133,000)

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