Using science to update regulatory approach to radiation protection
– Edward Maher, Sc.D., Harvard University
Note: Borrowed from lowdoserad.org
That is a truth that Atomic Insights has recognized for many years, but the situation – so far – remains unchanged.
Under the auspices of the Eastern Washington Section of the American Nuclear Society and the Columbia Section of the Health Physics Society, a team of leaders, including General Chair: Alan Waltar, Assistant General Chair: Wanda Munn, and Assistant General Chair: Virginia Cleary-Ivanof has assembled a cast of contributors that is organizing a sustained effort that could produce beneficial movement.
They are leading the charge for the ANS and HPS to gather and organize the accumulated knowledge needed to encourage and support responsible standard-setting agencies to finally modernize radiation protection models. Part of their effort includes planning a joint topical meeting to be held from September 30-October 3, 2018. The meeting will be held in the Tri-Cities area of Eastern Washington.
Titled “Applicability of Radiation Response Models to Low Dose Protection Standards,” this meeting is being billed as being quite different from previous topical meetings.
“This is not just a ordinary topical meeting where distinguished professionals provide a paper that can be added to their dossier. Rather it is a meeting with potentially profound results for our entire industry.”
In an approach that is rare for professional society topical meetings, this one is being organized around a stated goal instead of a guiding theme.
The goal is to utilize current scientific data accumulated throughout the history of nuclear technology to update the approach to regulating the response to low level radiation doses.
(Emphasis in original announcement.)
A request for abstracts has been issued. In addition, the meeting organizers are actively seeking the contributions from recognized experts in the field. The topic list includes:
- Scientific foundations for radiation protection standards and emergency action guidelines
- Molecular basis of radiation response at low dose
- Applicability of linear no-threshold dose-response models
- Public perceptions of radiation risk
- Implementation of radiation protection regulations
- Opportunities for beneficial changes to radiation protection regulations
For more information, please visit http://www.lowdoserad.org.
I agree wholeheartedly with this effort. Here’s a possible idea of how to make these changes happen (i.e., get NRC to cooperate).
Many of you have heard about the EPA’s endangerment finding that was the basis of their being allowed to regulate CO2. That finding, and the EPA’s authority to regulate CO2, was challenged in court. The courts held up the CO2 endangerment finding, the apparent assumption being that it was necessary in order of EPA to have the “right” to regulate CO2. The implication being that if something cannot be shown to be a hazard, a regulatory agency does not have the authority to regulate it?
I understand that some of these potential limits have to do with the Clean Air Act, from which the EPA derives its authority to regulate air pollutants, and how the same law can potentially limit EPA’s actions. NRC, on the other hand, seems to have unlimited authority to do whatever it wants, which is problematic. Still, if we could show lack of evidence of any harm from low level radiation, as part of a court challenge, could we eliminate NRC’s (and EPA’s) authority to regulate it?
The NRC is destroying the nuclear industry in the US. LNT is the Achilles heel of the NRC.
Once the LNT hypothesis is replaced by the the hormesis theory of radiation damage, the NRC as it exists today is on life support.
Given that radiation standards should be loosened by a factor of 1000 (from .15mSv/yr to 1 mSv/day), that walk away safe reactors are 1000 times safer than LWRs, that LWRs are the safest source of energy that exists today, that the airline industry kills more people per year than the LWR nuclear industry has killed in its entire history, a compelling case can be made for replacing the current NRC regulatory model with an FAA regulatory model.
To make this change easier to accept politically, LWRs could remain within the current NRC scheme while new reactors that are walk away safe would be placed under the new regulatory process.
Within 6 months almost anybody could obtain a license to build up to a 100 MWe reactor at a site in the Idaho National Lab. After it was built, it would be turned over to the new NRC for 6 months. The NRC would do things to the reactor trying to make it self destruct. If the NRC was unable to destroy it, the design would be certified. Any utility could order one and with an ordinary construction permit build a plant. The NRC would inspect it periodically to ensure that operating and maintenance procedures were being followed.
The nuclear industry will flourish in the US.
I agree with most of what you say, but very small LWRs like NuScale are also incapable of causing any significant public harm. It is also “walk away safe” (i.e., can go indefinitely w/o active cooling). So, I would amend your statement to say that “*large* LWRs could remain under the current NRC scheme…”
I agree that radiation standards should be reevaluated. S. E. Vandenbosch
I am curious about what a change in the radiation standards of the NRC would bring for the promotion of new nuclear energy? Or is some of the purpose a scientific vindication? I’m rooting for vindication myself, but any accepted change of standards on the part of the NRC, I might imagine would take a very long time to translate toward a reduction in costs.
To that effect, I am also curious about some specific examples where a change in standards would reduce costs, either in the short or long term.
On the contrary, some costs would drop instantly.
Consider a revised exposure standard of 1 mSv/day. Immediately, job sites registering less than 125 μSv/hr require neither radiation protection nor planning for minimization of exposure; people can simply go in and do the job. Somewhat higher radiation levels could be handled with daily time limits.
This would apply many times over in things like medical imaging, not just NPPs.
If I understand Wade Allison, and I may not, the 1 mSv/day needs the further proviso of not more than 300 days per year. But 5 days per week and 50 weeks of exposure per year is only 250 days per year; easy to manage.
I’ve seen a plot which suggests that the peak of hormetic effect lies at about 700 mSv/yr. That would argue for 2 mSv/day limit. 1 mSv/day allows a comfortable margin for non-work exposures.
Consider the question “What do you do with the waste?” and the billions of dollars currently envisioned to be spent on a repository that has enough engineered layers to keep radiation doses to less than 15 mrem (0.15 mSv) per year to the most exposed individual at any time during the next 10,000 years.
Instead, of meeting that standard, engineers are given the constraint of protecting people from exceeding 1 mSv/day.
Of course, NOT spending billions would eliminate imagined revenue streams, but we are not building any repositories right now in the U.S. anyway.
A 100 mrem/day limit is going to be tough for a Boiler…..especially during outages.
Really? What kind of exposures are typical in BWR outage work?
Reactor disassembly/reassembly down in the cavity is performed in 50-150 mrem/hr…..3 hour jumps 2 times a day for the (5) workers per jump. Cavity and dryer/separator pit decon following drain down usually results in exposures of 200-300 mrem for ~20 workers.
The drywell, depending on the work to be performed and the work location can be anywhere from 20-1000 mrem/hr.
Control Rod Drive exchange undervessel are in a consistent field of 100 mrem/hr (higher during the CRD removal duration) and they usually do 2-4 hours jumps.
Various areas in the Reactor Building can be fairly high dose, for example Residual Heat Removal heatchanger rooms and anything having to do with the Reactor Water Clean Up system.
Furmanite (or other emergent valve work) in the Turbine building at power (of course, within minutes after shutdown the N16 gammas decay away but most Furmanite is done online in dose rates 150-1000 mrem/hr.
We just completed our latest refuel outage for 145 person Rem (our lowest by far in the last 10 years) in 37 days.
I see you’d still have to do minimization planning for a fair amount of outage work inside the reactor proper, but how much would a 1 mSv/day floor below which exposure is considered “of no health concern” simplify the rest of the work and routine plant operations?
During normal plant operations, the <100 mrem/day limit would be fairly easy to maintain.
I'm a Radiation Protection Tech, so the ALARA concept is what employees me. Having said that, the whole ALARA concept is both ridiculous, expensive and is partly (mostly maybe) to blame for holding this AMAZING technology back.
I have thought about (and been asked many times) going into Operations, and the operation and systems of these plants are certainly more interesting than telling workers to stand where its 5 mrem/hr instead of 7 mrem/hr. However, the level of scrutiny from the NRC and INPO on Operations is astounding. The stress of the constant training and testing is enough to keep me away…..for now.
Simply place a minimum threshold on how Low “As Low as Reasonably Achievable.” This is the worst driver of costs on any plant refueling outage, especially when any modifications are involved. If a plant manager remains in the lowest quartile of annual dose rates for several years it can be assured that he will be looking for a new job – and not in nuclear power.
Every plant I worked at it was typical to spend 1/4 of the total cost of the modification on full size mockups, extensive training, practice, critiques and retries, and then repeat as needed to minimize exposure time and man-rem. These mockups looked like the real thing. For example, it was not uncommon to have all of the welders that would be working on the pipe replacement, the HP technicians, two or three plant training instructors, a videographer, etc. working on the mockup 4 to 6 weeks before the plant outage. All to save a few rem, but expend thousands of dolars. Multiply that by ten – twenty for each plant and 100 for the 100 plants.
“If a plant manager remains in the lowest quartile of annual dose rates for several years it can be assured that he will be looking for a new job – and not in nuclear power”
Believe you meant highest quartile and this would explain why I’ve had 5 different Plant Managers in the (almost) 10 years I have been here. We are just finishing up the chemical decon of our RHR system…..which costs millions of $$ to lower the dose rates in our RHR pump and Hx rooms ~30%.
Lowest ranking – highest dose rate. Retired 12 years ago thus not sure how they classify it now. Like you, at the last plant I worked at all it took was two bad outages and they were gone. Most went to the “Spent Fool Pool” but some also left before the INPO eval was given and they knew they were gonners.
We are ranked (BWRs and PWRs are separate for obvious reasons) with lowest dose plants being 1st quartile and highest dose plants being 4th quartile. This weighs heavily on the very idiotic INPO index rating system which is the only reason why Upper Management really cares about dose. Too many factors go into the 2 year rolling average for person REM that its pretty ridiculous to even compare……yet, that’s why we have INPO.
@Bonds 25 says August 17, 2017 at 5:30 PM
“This weighs heavily on the very idiotic INPO index rating system which is the only reason why Upper Management really cares about dose.”
As we have discussed before, INPO is now (by fear) managing all the plants. Even with a more reasonable regulatory process, the manning required for just the INPO BS, plus the new ‘security’ manning, will still be the O&M Budget Plant Killers. Get rid of INPO and put the security cost where it belongs….the US Government, and all the current fleet will be making money again.
Instead, we are having increased INPO “help”, adding more security headcount, delay fences and razor ribbon.
It really is quite ridiculous
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