NRC holds public meeting for proposed rule eliminating ALARA

The Nuclear Regulatory Commission has proposed a change to how it will approach standards for radiation protections, notably including the elimination of the "as low as reasonably achievable" (ALARA) principle. The proposed change was published in the Federal Register on July 15, and yesterday the agency held a public meeting on the topic.

In the meeting, Mike Franovich, director of the NRC's Office of Nuclear Regulatory Research, gave a presentation summarizing the changes, and NRC staff answered questions from participants. The meeting facilitator, Lance Rakovan, described it as a "very popular meeting," drawing more than 550 participants, and the NRC staff was unable to address all questions in the scheduled time.

Franovich concluded the meeting by encouraging participants to submit public comments, which will be accepted until August 31, using the federal rulemaking website. In issuing the final rule, the NRC is obligated to respond to "significant, relevant comments." NRC technical staff member David Garmon said that all comments would be reviewed by a technical staff person.

Background: The proposed rule change maintains the use of the linear no-threshold (LNT) model while eliminating the LNT-based ALARA, making the argument that the principle is too ambiguous and promotes unnecessary conservatism in approaches to radiation protection. The agency has proposed implementing a graded approach instead.

Baseline radiation limits for radiation workers and the public remain unchanged, while an increase to the effluent release limit and avenues for simplifying the process of permitting a higher dose under specific circumstances are proposed.

The rule change introduces a "caregiver" concept, which Franovich said aims to streamline allowing members of the public to voluntarily receive higher doses to provide care for someone receiving medical treatment.

Franovich cited "extensive experience" through the exemption process in this area, compared with the special exposure process for radiation workers, which he said licensees have not really used.

Question themes: Multiple members of the public said that the allotted time for public feedback was insufficient, particularly for what one participant described as a "monumental shift in the protection guidelines."

Franovich said the NRC has received multiple requests for an extension, which it has rejected, saying it came down to the assessment that "it would compromise our ability to deliver on the executive order for timely NRC action." He said that extension requests submitted through regulations.gov are considered individually.

In his summary, Franovich noted the long-standing debate on what the appropriate model is to use for low-dose radiation, which he described as difficult in the absence of definitive studies. The science of low-dose radiation also came up in questions from the public, such as one asking why non-cancer health risks of radiation weren't considered.

"Fundamentally, for us to adopt such an approach to factor those in, we're still left [with] the conundrum: Is there a consensus standard replacement model that we could readily use in this short time frame that really has the backing of peer review?" said Franovich. "We get advice from the National Council on Radiation Protection and Measurement. Has NCRP finished their work to be in a position to actually make that recommendation to federal agencies? And what we concluded was we're simply not there yet."

Clarifying questions were asked about the proposed changes in medical contexts, including how an administration regimen is defined and how dose limits may impact members of a household beyond a caregiver.

NRC technical staff member Sarah Spence said regimen accounting would track a given product or radiopharmaceutical over the number of times administered as part of the intended therapeutic cycle, and that diagnostic portions would not be included as contributing to a caregiver dose. She also said that the NRC does not expect the increased limits for caregivers to change the dose received by other household members.

"We see it as actually providing some more flexibility for patients, because usually the maximally exposed individual from a given treatment is the spouse or someone that is co-sleeping, and it's not usually someone else. It's usually those eight hours spent very close to somebody or needing a lot of, say, mobility assistance," she said.

A member of the public described concerns that proposed changes to effluent reporting seem like the basis for a below regulatory concern level.

"I want to categorically deny that that we are implementing some type of below regulatory concern. That is absolutely not the case," said Garmon. "The 25 mrem is meant to be a threshold in terms of effluence for where a licensee has to report effluence to us, they have to record and monitor their effluence down to zero."