The nuclear regulatory commission thinks America should be more like Europe

TheUnited States Nuclear Regulatory Commission thinks America should spend a lot of money and effort to change the safest radiological program in the world just so we can be the same as Europe. As if conformity in this area is important or that their safety record is better than ours. Which it isn’t.

NRC has proposed a rulemaking (ANPR) to change the existing U.S. radiation protection regulations to align with those of the International Commission on Radiological Protection (ICRP). The most important change would be to drop our present worker radiation limits from an average of 5 rem/year to an average of 2 rem/year (50 mSv/year to 20 mSv/year). Specifically, it’s the cumulative exposures and dose averaging over a 5 year period so as not to exceed 2 rem in any given year.

This is an unnecessary and expensive change that would not lead to better safety or lower exposures. The industry’s safety record is already as good as it can get (Nuclear Naval workers). Echoing the consternation of many radiation scientists, physicians and specialists, Dr. Carol Marcus at UCLA’s David Geffen School of Medicine made an impassioned plea to the NRC for scientific sanity, asking them to reconsider their decision to reduce radiation limits for workers even further below the already low dose limits that have controlled the field extremely well for the last 60 years.

It’s not like this is a simple bureaucratic change, like swapping out someone’s guidebook or updating a website. This would involve making sweeping changes at all hospitals, all commercial nuclear sites, all DOE and government sites, all radiological sites, many state and city operations, many universities, and even oil field operations. This would not be just rewriting every guideline, handbook, and operating manual, and retooling/resetting every monitor, detector and computer program, but changing work schedules, hiring more workers, and preventing many crucial medical procedures.

This will cost America billions of dollars, not to mention the lawsuits that will follow. For no good reason. The NRC itself doesn’t actually believe in adverse health effects of low-level radiation. They’ve said many times that, “Although radiation may cause cancer at high doses and high dose rates, public health data do not absolutely establish the occurrence of cancer following exposure to low doses and dose rates — below about 10,000 mrem (100 mSv). Studies of occupational workers who are chronically exposed to low levels of radiation above normal background have shown no adverse biological effects” (NRC.gov).

America’s radiation workers have the lowest work-related injury and death rate of any worker group in the world, including office workers and stockbrokers (BLS). According to data from the Occupational Safety and Health Administration, it’s safer to work at a nuclear power plant than to sit at a desk trading stocks (see figure).

The nuclear industry is the safest workplace environment for employees and workers. There are no  health effects from radiation above any other workplace environment, and even non-lethal   routine accidents,

 like falling off a ladder, are rare at nuclear facilities as seen in this OSHA data

 for a ten-year period from 1990 to 2000. The reason is the complete proceduralized safety 

requirements for every activity onsite. No one thinks about safety in an office building, 

but everyone thinks about safety constantly at a nuclear facility. Source: OSHA data

And that’s because we’re obsessive-compulsive when it comes to radworkers and safety. We proceduralize everything – every activity, every job, every endeavor. We monitor everyone and everything for radiation as well as a host of other diagnostics.

At an American nuclear facility, you have to have ladder training to use a ladder. And two qualified operators are required to operate a ladder. It is a rare event when someone falls off a ladder. Or gets a radiation dose over any limit. Or have any kind of accident at all.

But you know on the 7^th floor of the AIG building in New York, someone is standing on a rolling chair trying to hang a picture. And they’re going to fall and break their arm, which gets reported to OSHA. Safety just isn’t a constant thought in most jobs outside of nuclear. I wish it were.

So why the expensive and unnecessary push to change the limits?

The NRC has decided the United States should just be more like Europe – they want the two bureaucracies to align. I can see the advantage to that kind of congruence in attempts to change us from the English system of measure to the metric system – at least that would save money in the long run.

But instead of having Europe sync with our more effective guidelines and safety programs, NRC is willing to drop ours to match theirs.

Really?

America’s safety record in nuclear energy is better than anyone in the world. Why should we change that? It was Japan’s rebuffing of our warnings and recommendations that led to the Fukushima accident. We told Russia their RBMK reactors at Chernobyl were a bad idea. They ignored us.

The Three Mile Island accident was trivial compared to the only two real nuclear disasters in history, with no human health or environmental impacts, but we responded to TMI by completely revamping our safety systems, giving NRC serious authority to regulate, and implementing new guidelines that have prevented any significant accident in the last 35 years.

In fact, we didn’t learn that much from Fukushima that we hadn’t already known and planned for a decade earlier. I’m not normally a nationalist, but in the area of nuclear, no one comes close to America’s safety and security with respect to nuclear. It’s a bit insane to adopt Europe’s program for no reason other than administrative congruence.

According to Dr. Marcus, who is also Professor of Radiation Oncology, Professor of Molecular and Medical Pharmacology (Nuclear Medicine), and Professor of Radiological Sciences, ”The NRC plan to make its radiation protection program closer to that of the ICRP has no scientific basis. It is based instead upon the idea that uniformity is a good thing. But uniformity makes no sense if it makes everyone uniformly wrong.”

The NRC seems to believe that decreasing worker dose limits to 2 rem/year, at the same time we have to implement the ALARA Program, is actually attainable. While this may be achievable for many who have a Radioactive Materials License and unlimited funds, it is not true for many other workers still exposed to radiation. Because their radiation exposures come from natural background or machines, these people don’t fall under NRC’s rules.

Pilots who repeatedly fly over the north pole receive exposures approaching the 5 rem/year limit, but this is not a radiation-regulated activity. So now the NRC will be saying “while can’t force you to change, this is dangerous and should be stopped”, even though it’s not dangerous at all and has never caused any problems.

The annual background radiation dose in Copper City, Colorado is just under 1 rem/year. As this is nearly half the newly proposed 2 rem/year limit, together with the ALARA principle, NRC would recommend that the residents of this town have so much rad that they shouldn’t do any rad-type job like being a miner, an airline pilot, a radiation worker or be a doctor in oncology or cardiovascular intervention where annual doses can reach 5 rem. What about the patients who will die without that intervention? We’ll have to double the number of medical workers in these fields to give the same level of care and meet these proposed rules.

Who pays for that?

And just forget about sick people getting those crucial CT and PET scans or radiation therapies in the last few months of the year when workers and doctors come close to their new 2 rem limit. NRC will tell them, “No, it’s just too dangerous now”, even though nothing has changed. These new limits will make some doctors and workers leave their film badges in their offices before they walk into their labs or operating rooms, just like many radworkers did in the old days.

And older radiation workers will think they were saddled with a fatal error in accruing doses under the old limits, even though there’s no history of radworker health effects below 10 rem. What about individual States? What about small cities with only one interventional radiologist or cardiologist. And the patient needing emergency procedures late in the year? Are they supposed to go elsewhere. Or just tough it out and wait until the next year? I understand the bureaucratic lure of uniformity but this ruling makes no scientific sense whatsoever, and is unworthy of NRC’s normally high level of understanding and attention to detail.

http://www.forbes.com/sites/jamesconca/2015/01/07/nuclear-power-turns-to-salt/