The NRC Considers Amending Radioactive Release Regulations

Tanya E. Hood
Project Manager
Office of New Reactors
 
 

Part of the NRC’s mission includes making sure nuclear power plants control and monitor the very small amounts of radioactive material that might be released during normal operations. Filtering and otherwise maintaining a reactor’s cooling water can create radioactive gases and liquids. The amounts generated and released vary depending on a reactor’s design and overall performance. The primary regulations for radioactive emissions (also called radioactive effluents) from commercial nuclear power plants are in 10 CFR Part 50, Appendix I.

These rules are designed to keep normal airborne or liquid releases low enough that any public radiation dose would be a minute fraction of the dose from natural background radiation. Appendix I also requires U.S. nuclear power plants to further reduce potential doses as much as reasonably possible. This set of regulations includes requirements for plants to regularly sample their nearby environments.  The plant’s samples of air, water, milk, soil, vegetation, sediment and fish come from the property line, on-site, and from nearby towns.

quoteIn 2007, the International Commission on Radiological Protection published recommendations that account for updated scientific understanding of the way to calculate radiation doses. For the past few years we’ve been considering amending the NRC’s radiation protection regulations. We’ve talked with public interest groups, other federal and state agencies and the industries or individuals we regulate on the possibility.

The NRC’s Commissioners gave the staff direction about potentially amending these regulations in December 2012. The Commission told the staff to begin developing the regulatory basis for revising the NRC’s radiation protection regulations in 10 CFR Part 20 and regulations for radioactive effluents from commercial nuclear power plants in 10 CFR Part 50, Appendix I “to align with the most recent methodology and terminology [in the ICRP 2007 recommendations] for dose assessment.”

The NRC just held a meeting soliciting feedback on the development of a draft regulatory basis for updating 10 CFR Part 50, Appendix I in Savannah, Ga., on June 27, 2014. The attendees, either in person, on the phone or watching our webinar, gave us some great comments to consider.

We’ll continue the discussion later this summer by issuing an Advanced Notice of Proposed Rulemaking (ANPR) in the Federal Register. The notice will list future meetings and describe the regulatory process in more detail.

Based on feedback received from the public conversations and the ANPR, NRC staff will complete the regulatory basis and make a recommendation to the Commission on whether revisions that may affect how radiation dose is calculated, how it is measured and how radioactive effluents are reported annually are warranted. The NRC staff anticipates the regulatory process related to potential updates will take several years to complete.

Next week, NRC staff from several offices will participate in the 59th Annual Meeting of the Health Physics Society, in Baltimore, Md., and will participate in a technical session that will cover, in more detail, the NRC’s efforts on this issue. In addition, Chairman Allison Macfarlane will address this topic, among others, in the meeting’s opening plenary session.

Author: Moderator

Public Affairs Officer for the U.S. Nuclear Regulatory Commission

28 thoughts on “The NRC Considers Amending Radioactive Release Regulations”

  1. The releases from all nuclear power plants in the United States are summarized in a series of annual reports that are publicly available in NRC Agencywide Documents Access and Management System (ADAMS). The most recent annual reports can also be found on NRCs web page at http://www.nrc.gov/reactors/operating/ops-experience/tritium/plant-info.html. The changes anticipated for 10 CFR 50 Appendix I would not change the NRCs requirements for these reports, and they will continue to be available for public inspection.

    Tanya Hood

  2. “Proposed Rulemaking” – Well, the main issue, judging from European nuclear power stations is that effluents and immissions, e.g. through the chimneys (Tritium, radioactive noble gases and a few aerosols) is the raised levels of child leukemia (otherwise a very rare occurrence) and thyroid cancers and other thyroid problems in closer proximity to nuclear power stations. Also veterinarians report high levels of mutations, stillbirths and visible birth defects in pets. But nothing is done to fund research into the causes. Maybe the US could do better?

  3. Mr. Engineer-Poet: I’m not a “green” as you say, nor do I agree with the notion that all “radiation” is harmful, as “radiation” is produced from many beneficial sources, including the sun. That does not mean that ionizing radiation will not damage cellular structure or that the intake of particles emitting ionizing radiation will not damage cellular structure or organs and tissue. It is a proven fact that cells may be damaged and mutated by low level ionizing radiation..

    I’m an old retired military service member who was once involved in “nuclear surety” as a clinician and health care administrator. Your tactic to attack those who do not agree with your statements is not a trait conducive to analysis in science or engineering. It is conducive for political argument in support of fallacy. As a retired military service member once involved in Human/Personnel Reliability, I’m very concerned with undue influence by the nuclear industry and its premier PAC, the NEI, and politicians who support the nuclear industry before the health and welfare of U.S. Citizens.

    Your link posting concerning the title “Fukushima and the Beneficial Effects of Low Level Radiation” is more of the Radiation Homesis fallacy. It is science fact mixed with fallacy. Regarding Dr. Allison’s presentation in the VIMEO video, I agree with Dr. Allison in part and disagree with him in part. Your UNSCEAR document is an old and familiar read in the Fundamentals of Radiobiology; an older read which has many improvements since its original publication, which I think was in 1955.

    Since you dismiss Dr. Gofman because of the “Ratical site”, consider: Richard Wakeford, Review of Evaluation of the Linear-Nonthreshold Dose-Response Model for Ionizing Radiation (National Council on Radiation Protection, NCRP Report No.136), Journal of Radiological Protection, 2002, Vol. 22 No.3 – “The chapter on DNA repair and processing concludes that it is likely that exposure of humans to low doses and low dose rates does result in permanent alterations in DNA sequences, which points away from a threshold.”

    Wakeford states, “The report begins by examining the way in which radiation energy is deposited in cells. It concludes that at low doses and low dose rates the relevant biological damage would be produced by a ‘single hit’ because of the spatial and temporal sparseness of the events causing the damage. Since cancer is considered to be monoclonal (single cell) in origin, this suggests that the dose-response is linear at low doses with no threshold.” No threshold means that any dose of ionizing radiation can lead to cancer which means that there is no safe dose of ionizing radiation.

    “There is no safe level of exposure and there is no dose of (ionizing) radiation so low that the risk of a malignancy is zero.” – Dr. Karl Morgan, the father of Health Physics

    Also concluded by the National Academy of Sciences BEIR VII, Phase 2, 2006 study, pg 15: There is a “no-threshold dose-response relationship between exposure to ionizing radiation and the development of cancer in humans.”

  4. Transferring regulatory authority concerning emission releases from nuclear facilities away from the NRC to other government alphabet agencies does not insure public health and safety. Your suggestion “billpks” complicates the problem by diminishing NRC regulatory control of an already compromised regulator by the nuclear industry’s PAC – NEI, and its political supporters.

    The purpose of the NRC as our regulator is to protect humans and the environment, not the nuclear industry. Your suggestion seems to prefer the protection of the nuclear industry over humans and the environment by attacking the NRC’s chair and attempt to diminish the regulators control over nuclear facility emissions. A previous tactic of the NEI and others who benefit directly from nuclear industry “payola.”

  5. Radiation and nuclear has alaways been a big issues for the humanity and I wont let corporations and stuff like that destroying what we have built. I dont want the next generation to come and eat poison you know..
    Regards

  6. Garry Morgan’s “scholarly article” is published only on a radical anti-nuclear website.  Just look at the main page:

    http://www.ratical.org/

    Garry is one of the many “Greens” who will immediately and assiduously deny anything that does not come from the anti-nuclear echo chamber, no matter how solid its scientific source.  And that, my friends, is the level of “proof” allowed here by NRC blog policy.

    In the real world (outside said echo chamber), the phenomena they say we should be seeing (with great certainty!) are not merely failing to appear, we see the OPPOSITE.  The Goiania incident in Brazil?  The survivors of ARS are not dying any faster than the unexposed population.  There’s actually a deficit of cancers in the moderately-exposed group of Chernobyl cleanup workers (an “anomalous” ERR/Gy = –0.47, in other words, hormesis).

    http://ehp.niehs.nih.gov/1204996/.

    More stuff from sources far more trustworthy and verifiable than the echo chamber:

    http://www.nuclearsafety.gc.ca/eng/pdfs/Presentations/Guest-Speakers/2013/20130625-Cuttler-CNSC-Fukushima-and-beneficial-effects-low-radiation.pdf
    http://www.unscear.org/docs/reports/1958,%2013th%20session%20%28Suppl.%20No.17%29/1958final-3_unscear.pdf#page=30

  7. A scholarly article – Radiation-Induced Cancer From Low-Dose Exposure John W. Gofman, M.D., Ph.D. 1990; CHAPTER 18 Disproof of Any Safe Dose or Dose-Rate of Ionizing Radiation,
    with Respect to Induction of Cancer in Humans – “The nine studies entered in Table 21-A demonstrate that the following doses are not safe, with respect to cancer-induction: 9.0 rads, 7.5 rads, 4.6 rads, 1.6 rads, 1.0 rad, 0.9 rad, 0.5 rad, and 0.1 rad. Claims abound that epidemiological evidence for human cancer-induction is absent at low doses, but such claims are clearly mistaken.”
    http://www.ratical.org/radiation/CNR/RIC/chp18.html
    Table 21A link: http://www.ratical.org/radiation/CNR/RIC/chp18.html#tab21a

  8. Totally false.  Not only are certain amounts of radiation safe, certain amounts of radiation have been shown to extend the lives of experimental animals by as much as 30%… and we have known this for more than 5 decades.

    The “all radiation is unsafe” claim is part of the effort to ban above-ground nuclear testing.  That effort was successful, but now the paranoia it engenders has already blocked our first and best option for controlling climate change.  By the mid 1970’s the USA was on track to eliminate coal for electric generation, until the NRC’s regulatory micromanagement (and failure to consider hazards continued or even created by failing to use nuclear power instead of coal or gas) made it impossible to continue.  The USA continued to burn coal instead, China and India went into the coal-burning business in a huge way, and 400 ppm CO2 is now in our wake.  Thanks, Greenpeace!

  9. Good job NRC for not supporting censorship!

    The Engineer-Poet has no comment on the BIER VII Report which does not support radiation hormesis THEORY?

    This statement sums up Radiation Hormesis Theory: “[Radiation] Hormesis is [not] just bad science, [the] studies are fraudulent – consisting of comparisons between populations without control for the age group and smoking. As typical in scientific fraud, research conclusions focus entirely on the non-scientific aspects such as safety policies, entirely ignoring the scientific implications (if the response is not linear, then you have to throw entire concept of dose out of the window. It is only the linear no threshold response model under which all kinds of ionizing radiation are equivalent (up to the scaling factor)). To put it very bluntly, there’s all reasons to think that hormesis proponents are not merely mistaken, but are actively lying. A genuinely mistaken scientist explores the scientific consequences of his erroneous research. A fraudster, on other hand, focuses solely on promoting the policy changes which he wants to enact through his fraud, and shies away from the scientific implications of his research; for the science is interlinked, and scientific implications of fraudulent research would contradict a lot of other, seemingly unrelated experiments and knowledge.” (dmytry.blogspot.com/2009/…/radiation-hormesis )

    There is Dr. John Gofman, MD, PhD, one of the original scientists on the Manhattan Project and holds patents for the separation of plutonium. The title: “Radiation-Induced Cancer From Low-Dose Exposure,” John W. Gofman, M.D., Ph.D. 1990. The entire publication is available on line, I would suggest all interested parties read it. It is very relevant to the radiation release issue. http://www.ratical.org/radiation/CNR/RIC/contents.html

  10. Having now had the opportunity to review the Chairwoman’s speech to the HPS I came away gravely concerned that with all the talk of changes to radiological protection standards that such work is proceeding under this value:

    “In fact, a questioning attitude – asking ourselves how and where we can improve – is also the foundation of ALARA (as low as (is) reasonable achievable), which, in my opinion, is the cornerstone of effective radiation protection.”

    There is an imperious – head held above one’s scientific and technical peers – quality to this speech that belies the suggestion that NRC is in fact open to risk-informed input from outside its own ranks. That the speech doesn’t even acknowledge the differing professional opinions regarding the validity of the LNTH amounts to a virtual rebuke to the members of the HPS.

    I wonder: Is the Chairwoman aware that during the period since the last reactor near site health studies the average exposure across the entire population has doubled while the amount of exposure from NPP remains fully compliant with Appendix I and therefore negligible?

    What that change means is that the traditional rationale for Appendix I ALARA has been practically subverted by the medical establishment. It seems to me that money being spent with the National Academies would have been better spent on looking for consequences in relation to benefits of all that added medical exposure. 50 mrem of incidental exposure from released patients is likewise a candidate for evidence-based regulation taking the place of and anachronistic reliance upon ALARA.

    And finally, I find nothing in this defense of ALARA that acknowledges the substantially fatal consequences of Mismanaged Evacuation Stress Syndrome which is now very evident in the surrounding public impacted by the Fukushima disaster. Silence on that particular point is negligent in my view.

  11. The difference is that you give your children these doses. There is no parental choice in radiation releases to children around nuclear plants.

  12. The NRC does not “fact check” comments posted here. As long as they adhere to the comment guidelines, they are approved. Readers of this blog should understand comments are the opinion of the submitter.

    Moderator

  13. While it is unlikely to happen, it would be a most salutary development if NRC were to do away with Appendix I and transition the control of effluent releases to EPA; of occupational doses to OSHA; and of post accident emergency management to FEMA oversight. Then the agency could focus entirely the reliability of safeguards against release of man-made radioactive materials from designed containment. With respect to power reactors, decay heat and prompt criticality are the concerns of most importance to national energy security.

    Judging by the slow decline of the US NP sector into irrelevance under the existing standards for exaggeration of radiological consequences of miniscule exposures, the anti-nuclear types will get what they want even as the last NRC Chairman speechifies to some future Health Physics Society meeting on the rigorous scientific basis upon which oversight of decommissioning is proceeding.

  14. No amount of radiation is safe, natural or manmade, and “scientists” who promote the hormesis theory are jsut lille the ones who tried to tell us cigarettes don’t cause lung cancer or other diseaese. The NRC should have a zero tolerance level on any radioactive releases,and any reactor that can’t operate without emitting radiation should be shut down.

  15. Yes, I routinely give my children small doses of things that would be poison in large doses. These things are called medicines and vitamins. Aspirin is the best example. We gave our daughter a sedative once so that she could stay calm while getting stitches. Of course, in a large enough dose, the sedative would have been crippling or lethal. We encourage our children to swallow two cups water or take a bath whenever necessary, but we make sure that they don’t get get two cups of water in the lungs. We did this by teaching them to swim.

  16. No amount of radiation is safe, natural or manmade, and the effects are cumulative. The NRC should have a zero tolerance policy on releases of radiation. If reactors cannot operate without emitting radiation, they should be shut down.

  17. how about radiation hormesis craziness

    If someone shows you scientific documentation that the phenomenon is real, and you call it “craziness”, it’s you that’s crazy.  In your case, Garry, paranoid:  living in fear of ineffable hazards despite evidence that they do not exist, like monsters under the bed.

    The Health Physics Society has this to say (emphasis added):

    for populations in which almost all individuals are estimated to receive a lifetime dose of less than 10 rem above background, collective dose is a highly speculative and uncertain measure of risk and should not be used for the purpose of estimating population health risks.

    NRC moderator:  you should not publish comments which make assertions without documentary evidence.

  18. Anti-nuclear gospel, how about radiation hormesis craziness. The next think you will be saying it is beneficial to pulverize spent nuclear reactor fuel and spread it in our upper atmosphere as a solution to the nuclear waste problems.

    Read the BIER VII Report, then get back to reality and stop with the radiation hormesis propaganda.

    I agree, the NRC must make a stand on science and not listen to the purveyors of radiation hormesis fallacy.

  19. Thank you for the chapter and verse from the anti-nuclear gospel.

    In truth, we have known that those talking points are not merely wrong, they were known to be wrong by the people who created them. Yes, they are lies. Radiotherapy sessions divide the total radiation dose because healthy tissues recover over time. People who have examined the data found that low, steady (chronic) doses of ionizing radiation are harmless or even beneficial. It has been known since no later than 1958 that steady, low-rate irradiation with Co-60 gammas can extend the life of mice and guinea pigs around 30%.

    The NRC should make a stand on science, and only on the science. Green orthodoxy and anti-nuclear paranoia should have no influence on our policies and standards.

  20. You should take due note of (and inform the EPA about) the conclusions of the ICRP regarding collective dose:
    “The aggregation of very low individual doses over extended time periods is inappropriate, and in particular, the calculation of the number of cancer deaths based on collective effective doses from trivial individual doses should be avoided.” (ICRP Publications 103 in the Executive summary)

  21. The EPA has already acted and increased radiation tolerance levels. Most countries in the western world will. If Fukushima’s insignificant radio active release would have happened near Texas, the second amendment would have kicked in and no one US citizen would have tolerated an evacuation notice. Eating a bag of chips everyday exposes me to more radiation than most evacuated zones in Japan. Yet I live to be a free man. Japanese citizens get to stay in shelter and live in fear for no scientific reason at all.

  22. You say absolutely nothing about whether you’re hoping (and yes, I do suspect you of bias) to allow more radiation or less.
    Also, could you please post Chairman Macfarland’s speech to the Health Physics Society? Hopefully it will give the public a clue to your thinking.

  23. All ☢ releases to the environment should be disclosed to the public, then the PUBLIC, not the NRC or any other Government entity can determine if additional oversight is needed…

  24. All radiation is cumulative. The levels released by nuclear plants should be zero and if not they should be shut down. Would you feed your children just a little bit of poison?

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