ICBE-EMF challenges U.S. NRC modernization rules for deregulating safety measures

Nuclear Regulatory Commission (NRC) plans to modernize nuclear power generation by encouraging the development of micro-nuclear plants to meet the huge increase in demand for energy resources caused by the construction of hyperscale data centers and manufacturing plants.

ICBE-EMF submitted comments to NRC’s proposed rules as they offer less health protections while placing more weight on technological and economic benefits. This proposed rule is not consistent with international nuclear safety rules. Over 1,000 comments were submitted to NRC about this rulemaking, mostly expressing similar concerns raised by ICBE-EMF.  

Here are ICBE-EMF’s comments:

Ionizing radiation has long been recognized as a DNA-damaging human carcinogen by national and international health agencies (e.g., WHO’s International Agency for Research on Cancer, US Environmental Protection Agency, US National Toxicology Program) with no detectable threshold. Therefore, it is critically important that exposures to ionizing radiation be maintained at achievable levels that pose the least possible health risks to the general public and workers. The International Commission on the Biological Effects of Electromagnetic Fields (ICBE-EMF) has the following concerns regarding the NRC’s proposed rules for nuclear plants from the standpoint of their impact on health and safety protection for workers and the public.

• Discontinuing application of the ALARA principle or, as low as reasonably achievable, while acknowledging there is no established safe dose of radiation and would continue to apply the model of LNT, or Linear non-threshold, is problematic. Nuclear plant licensees would no longer have an incentive to push doses below the regulatory limits to ensure the health and safety protection of workers and the public, even when such action would be technically feasible at minimal cost.
• NRC proposes a new framework based on a graded approach to dose management that will be enforced by compliance monitoring using the existing hard dose limits and fixed thresholds, which NRC acknowledges are not science-based.
• This regulatory change will have the effect of functionally allowing more radiation exposure than is occurring today at many nuclear plants and that could be readily achieved at future facilities. NRC justifies these changes are meant to reduce the regulatory burden on nuclear plant licensees and to encourage new reactor development. This rule therefore provides no evidence that this new framework is more health-protective. Instead, it will likely lead to less health-protective levels than what is currently achievable
• NRC is promoting more weight be placed on technological advancement, economic considerations and operational circumstances. It is clear that these changes would create greater emphasis on the monetary value of lost human lives, rather than on preserving lives.
• Optimizing protection of worker health and safety has long been recommended by the International Radiation Protection Agency (IRPA) and is the underlying theme for most other nations. We recommend that NRC adopts dose limits that are consistent with the international exposure limits. For such a well-established human carcinogen, it makes no sense that exposure limits for ionizing radiation are set at levels in which cancer risk for workers is higher than what OSHA typically establishes for chemical carcinogens. In addition, and in the interest of women’s health, we strongly urge the NRC to set exposure levels based on cancer risk for women who are more susceptible than men to radiation-induced cancer.