democratic process, FOIA, ICRP, Lack of Transparency, nuclear energy, nuclear regulatory commission, nuclear safety, open government, Radiation protection, radiation safety, Rule-making, Transparency, US Federal Regulations, US NRC
The US NRC Radiation Protection comment period extension requested by Beyond Nuclear and the NIRS has been partly granted. The extension will apparently be until March. However, it doesn’t solve the problem of documents being used by the US NRC which are not publicly available in English for free (demanded under the Freedom of Information Act). One of the most important documents (ICRP 118) is available for free online at the ICRP IN RUSSIAN ONLY! Otherwise it must be purchased for a hefty price ($289.36 from Amazon) or possibly found in a university library. Does anyone really imagine that the American people are to learn Russian and read several hundred pages of complex technical information in Russian by March in order to comment on a topic as important as US NRC Radiation Protection-Safety Standards? It certainly gives the Uranium One mine owner a leg up for its US mines, since Uranium One is now owned by the Russian government. The comment docket is here: http://www.regulations.gov/#!documentDetail;D=NRC-2009-0279-0067
Here is the cover of the 385 page ICRP 118 available for free from the ICRP
Here is an interface with official governmental looking seals, etc. It is an image and so didn’t go in google translate so we don’t know what it says.
Further in, there is the following statement, which is probably related but it’s not the exact same words:
“Federal State Institution of Science Urals Research Center for Radiation Medicine with the permission of the International Commission on Radiological Protection (ICRP) and with the support of the Federal Medical-Biological Agency (FMBA of Russia).
We decided to randomly select a page to see how google translate fared with it. This is the public part of the ICRP so is supposed to be CC-BY-SA-3.0:
It did not come out very well:
“Early and late effects of radiation in normal tissues and organs
2.8. Urinary tract
2.8.1. Anatomical characteristics and proliferative organization
(349) The urinary system includes the kidneys, ureters, MO chevoy bladder and urethra; she is responsible for water and electrolyte balance, and ex-Cretu toxic end products of metabolism. Kidneys also ruyut-product produced renin, which is involved in the homeostatic regulation of arterial pressure-tion, and erythropoietin, which stimulates production of red blood cells in the bone marrow.
Kidneys (350) Kidneys – is paired organs, their main functional subunit-nitsami nephrons are organized in a parallel manner. Each human kidney than 1 million nephrons, consisting of the glomerular capillary network for filtering the blood, and a long tubular segment (55 mm in length human) divided by the kidney proximal convoluted kana-rings responsible for the resorption of a large part of water and ions from the glomerular filtrate; loop of Henle, which generates a high osmotic pressure in the interstitial fluid of renal medulla and distal convoluted tubule pochech-tion for the resorption of sodium ions. Nephron pass in col-selectivity of the tubes through which urine flows into the secondary ureters. Cloud-barrels and convoluted tubules are located in the renal cortex, collect-ing tubules and loops of Henle part – in the medulla. Compactly stowed-grids glomerular capillaries are closely associated with the epithelial podocytes and mesangial cells and surrounded by Bowman’s capsule. The epithelium of the Bowman’s capsule is associated with a single layer of epithelium lining the renal tubule. The balance between glomerular filtration and tubular reabsorption under-ported using juxtaglomerular apparatus, which secretes renin and regulates blood pressure as well as the volume of plasma. This ba-lance maintained when exposed to damaging factor until until it reaches a critical level of damage and nephron function cease-tively. The parallel arrangement provides significant nephron-th degree of redundancy in the kidneys and retain intact nephrons allows to maintain normal renal function as long as the number of damaged nephrons not become too large. (351) The kidney of an adult – a fabric with a slow recovery process with a low level of proliferation in tubular cells, and glomeruli (label incorporation index <0.5%). However, there corresponds a kidney able-operate on surgical or chemical damage transient increase proliferation, which lasts about 1 month after the injury. The irradiation also causes early dose-dependent increase in proliferation in both the proxy mal tubules (Otsuka and Meistrich, 1990), and the glomeruli (Robbins et al., 1994). Stimulate proliferation after irradiation precedes the development of functional disorders and lasts for 6-12 months”
Russian original here: http://www.icrp.org/docs/P118_Russian.pdf
Extension should be published today:
Unpublished rule: https://www.federalregister.gov/articles/2014/11/20/2014-27519/radiation-protection https://s3.amazonaws.com/public-inspection.federalregister.gov/2014-27519.pdf
The NRC says in more than one place that “The ICRP Publications referenced in the ANPR are copyright protected. The NRC cannot reproduce or provide copies of these documents. For additional information regarding obtaining copies of ICRP Publications, please see the ICRP Web site.
The NCRP Publications referenced in the ANPR are copyright protected. The NRC cannot reproduce or provide copies of these documents. For additional information regarding obtaining copies of NCRP Publications, please see the NCRP Web site. http://www.nrc.gov/about-nrc/regulatory/rulemaking/potential-rulemaking/opt-revise.html
From Regulations.gov comment site:
The ICRP is at least nice enough to make some of its information available to the public under Creative Commons, especially in other languages, but the NCRP are total jerks, as their copyright is written in such a way that you can’t really even summarize their online documents!
Despite what the NRC says on the comment docket and elsewhere, one of the important documents, 2007 ICRP, is available through the NRC for free: http://pbadupws.nrc.gov/docs/ML1208/ML12089A654.pdf (hurry and download your copies as there are important summary charts and other info that matters).
This page gives an indication of the important updated information found in ICRP 118 which was published in 2012
This page is a summary of the 2007 Radiation Rules, ICRP 103. Notice that it is available for free in most major languages except English! The English summary of approx. 35 pp. is virtually worthless. It is 10% but not the most useful 10%. There are a couple of pages which lay out the most important points, but they are not freely available. Translating from another language sometimes has pitfalls for mathematically oriented topics, such as radiation protection, because some languages (e.g. French) use commas where English uses periods and vice versa.
Reading this one can get some idea of the types of organizations (pro-nuclear or radiologists) which support the ICRP, they do not seem to list them – perhaps someplace within the site.
http://www.icrp.org/index.asp (red box added)
Some questions asked in the NRC Rules Docket:
Q1-1: What are the implications of changing the NRC’s regulations to specify “total effective dose” in place of the current term “total effective dose equivalent?” To the extent possible, please provide specific implementation and operational cost information on the impacts of this change relative to licensee procedures, training, recordkeeping, and reporting. This information is necessary for the NRC to determine whether the imposition of such requirements on NRC licensees is justified.
Q1-2: If the NRC adopts the dose assessment terminology and methodology of ICRP Publication 103 (2007) in a future rulemaking, what time period should the NRC consider providing for implementation of the ICRP Publication 103 (2007) methodology and terminology?
Q1-3: How should the calculations of effluent concentration, currently in the 10 CFR part 20 radiation protection regulations, be modified to reflect advances in modeling that are now available? In particular, the NRC is interested in preliminary views on the age and gender averaged approach.
Q1-4: Should the public dose limit of 0.5 mSv (50 mrem) continue to be the basis for the effluent concentration limits for the radionuclides in 10 CFR part 20, appendix B, Table 2, Columns 1 and 2? Should it be reduced or otherwise modified?
Q2-1: Is closer alignment with or adoption of the ICRP Publication 118 (2012) recommendations regarding the dose limits to the lens of the eye appropriate given the scientific information now available?
Q2-2: How should the impact of a radiation-induced cataract be viewed in comparison with other potential radiation effects?
Q2-3: What mechanisms could be applied to keep the cumulative exposure to the lens of the eye below the threshold of 0.50 Gy (50 rad)?
Q2-4: What methods should be allowed for measurement or assessment of the dose to the lens of the eye?
Q2-5: What methods should be allowed for recording dose to the lens of the eye when the eyes are protected?
Q2-6: What are the potential operational impacts of lowering the annual occupational dose to the lens of the eye from the current NRC regulatory standard of 150 mSv (15 rem) to 50 mSv (5 rem)? Would a reduction in the occupational dose limit for the lens of the eye require changes in programs, procedures, practices (e.g., increased use of protective eyewear), or in-room shielding? If so, please describe these changes, including any potential implementation and operational costs.
Q2-7: What are the potential impacts on State regulatory programs of a reduction in the occupational dose limit to the lens of the eye from the current NRC regulatory standard of 150 mSv (15 rem) to 50 mSv (5 rem)?
Q3-1: Are there any significant anticipated impacts associated with reducing the dose limit to the embryo/fetus of a declared pregnant woman, including operational impacts? What are the potential implementation and operational costs?
Q3-2: Are there any benefits or impacts associated with applying the reduced dose limit over the entire gestation period, or only to the period after declaration?
Q3-3: Are there any anticipated implementation impacts on recordkeeping if the dose limit to the embryo/fetus is lowered to 1 mSv (100 mrem)? What are the potential implementation and operational costs?
Q3-4: Are there technological implementation issues, such as limits of detection, which would make adoption of the ICRP Publication 103 (2007) recommendation difficult in certain circumstances?
Q3-5: Are there data on actual dose distributions to the embryo/fetus of a declared pregnant worker? What are the trends for these data?
Q5-1: Will promulgation of amendments to the 10 CFR part 20 regulations with dose limits and other measurements shown in dual units, with the SI units shown first, followed by the traditional units in parentheses, cause an undue burden or hardship upon any licensee or class of licensees? If so, please explain and provide examples, including any potential implementation or operational costs.
Q5-2. Should 10 CFR 20.2101(a) be revised to allow licensees the option of providing records in SI units or in traditional units? Should licensees be allowed to provide reports in the units used in licensee records? Should licensees be required to record and report in both sets of units? Please provide reasons why or why not.
Q5-3. Should the NRC amend the appendices for 10 CFR part 20 to show values in SI units only, in traditional units only, or in both sets of units? If both SI and traditional units are provided, which set of units should be considered as the regulatory standard? If only one set of units is specified, what would be the most effective means to provide the other set of units (e.g., in a separate guidance publication)? Please provide reasons why or why not.
Q6-1: What criteria should the NRC use to identify additional categories of licensees that should be required to submit annual occupational exposure reports under 10 CFR 20.2206(a)?
Q6-2: What are the benefits of collecting occupational exposure information in one central database to assess the total annual occupational exposure of those individuals who work at more than one licensed facility or contractor facility during the calendar year and receive occupational exposures at these facilities?
Q6-3: Should Agreement States be required to adopt regulations that are compatible with the requirements in 10 CFR 20.2206?
Q6-4: Should the NRC consider a gradual expansion of the 10 CFR 20.2206 licensee reporting categories in a step-wise fashion (e.g., staggered compliance dates for different categories of licensees)? What are the advantages or disadvantages for this option?
Q6-5: What are the potential implementation and operational costs associated with expanding the occupational exposure reporting requirements?”