ML25195A171
| ML25195A171 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 07/16/2025 |
| From: | Matthew Smith Nuclear Energy Institute |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML25195A099 | List: |
| References | |
| EO 14300 | |
| Download: ML25195A171 (1) | |
Text
©2025 Nuclear Energy Institute 1
Perspectives on Reconsidering the NRC Radiation Protection Framework Micheal Smith Senior Project Manager, Radiation Protection July 16, 2025
THE NUCLEAR ENERGY INSTITUTE is the policy organization of the nuclear technologies industry, based in Washington, D.C.
On behalf of its members, NEI is the unified voice of the nuclear energy industry on various policy, technical, and regulatory issues.
- 300+ MEMBERS IN 17+ COUNTRIES
©2021 Nuclear Energy Institute 3 MISSION Promote the use and growth of nuclear energy through efficient operations and effective policy
Key Enablers from the Executive Orders on Nuclear Energy National Security (14299), NRC Reform (14300), DOE Testing (14301), and Industrial Base (14302)
- NRC licensing less than 18 months
- Faster for DOE/DoD tested designs 1
- Pilot 3 reactors outside of labs
- Expand DOE testing pathways 2
- Operate at DoD facilities in 3 years
- AI as critical defense facilities 3
- Increase nuclear apprenticeships
- Prioritize nuclear energy careers 7
- Recommend a National policy
- Safe, Secure Long Term Fuel Cycle 5
- Maximize domestic fuel production
- Mine, enrich, convert, de-convert 4
- Compete for civil nuclear globally
- Pursue new 123 Agreements 6
Speed up Nuclear Reactor Licensing Expand U.S.
Nuclear Energy Exports Assess Spent Fuel and Recycling Bolster the American Nuclear Workforce Lay the Ground-Work for Faster Reactor Testing Deploy U.S.
Reactors for AI and Military Bases Amp Up Domestic Nuclear Fuel Production Add 300 Gigawatts of U.S. Nuclear Capacity by 2050
- Restarts and power uprates
- 10 large reactors in construction by 2030
Reference:
https://www.energy.gov/ne/articles/9-key-takeaways-president-trumps-executive-orders-nuclear-energy
Nuclear Versatility Spectrum of Sizes and Options Micro Small Large Variety of Outputs Electricity Hydrogen Process Heat Multitude of New Customers Data Centers Maritime Cement Steel Agriculture District Energy Space Mining Oil & Gas Aviation Rail Fashion Military Bases Petrochemical Energy Transitions Pulp & Paper Block Chain Transportation Mining Desalination Isotopes
©2025 Nuclear Energy Institute
©2025 Nuclear Energy Institute 6
- Reconsideration of RP framework is a pivotal opportunity.
- Executive Order 14300 highlights the need to modernize regulations and ensure alignment with current scientific understanding, technology, and risk-informed practices.
- Industry supports a sound, science-based framework that protects public, workers, and the environment while enabling innovation and deployment of nuclear technologies.
- This effort also affords opportunity to evaluate impacts on other areas such as emergency preparedness, accident analysis, and legacy guidance, to ensure consistency and effectiveness.
Critical Opportunity to Improve Radiation Protection (RP) Framework
©2025 Nuclear Energy Institute 7 Current Challenge: at low doses where risks are statistically indistinct from background, implementation of ALARA is overly conservative.
Existing implementation of ALARA hinders flexibility with facility design and has increased licensing inefficiencies.
Need for a clearer, graded, risk-informed framework that supports safety, consistency, predictability, and design flexibility.
Clearer direction can improve regulatory efficiency in licensing and oversight and public understanding, with the focus on ensuring dose limits are not exceeded.
Industry Recommendation:
Importance of a Graded, Risk-Informed Framework (Addressing ALARA)
Remove ALARA & minimization as regulatory requirements and establish a practical threshold (e.g., 2 rem/yr for occupational workers) in guidance below which further dose reduction would not be expected.
©2025 Nuclear Energy Institute 8
- Focused Intent: Changes should reduce unnecessary regulatory conservatism without reducing protection, enabling smarter resource allocation and project feasibility.
- Risk-Informed Reviews: Streamline licensing and design reviews by focusing on risk-significant exposures.
- Dose limits: Industry agrees with maintaining the deterministic dose limits (e.g.,
skin dose limit, etc.) but would like to better understand the idea of transitioning from an annual limit to a limit based on longer periods.
- Cost-Benefit: Reassess the need for existing cost-benefit metrics or at a minimum consider a graded approach that considers risk of low doses and economic impacts.
Modernizing Regulatory Practice to Meet the Moment
©2025 Nuclear Energy Institute 9 1.
Coordinate with EPA to eliminate 40 CFR 190 and delete 20.1301(e).
2.
Remove 10 CFR Part 50, Appendix I 3.
Remove as a minimum from 20.1502 and establish guidance for a minimum recordable dose.
4.
Consider changing license termination unrestricted use criteria from 25 to 100 mrem/yr.
5.
Allow voluntary use of modern dose methods (e.g., ICRP, NCRP) without prior NRC approval.
6.
Update existing guidance (e.g., Standard Review Plans, Reg Guides, IMCs/IPs, etc.) to support risk-informed licensing and oversight.
Broader Improvements to Improve Regulatory Efficiency and Consistency
©2025 Nuclear Energy Institute 10
- The industry is committed to maintaining safety and public trust while supporting regulatory innovation.
- Clear, transparent, and scientifically grounded, communication about radiation protection reinforces the NRCs and industrys commitment to health, safety, and national energy goals by avoiding unnecessarily conservative approaches.
- This effort is not just technical but foundational for enabling new nuclear investment, development, and credibility.
- We look forward to further engagement to ensure we achieve a durable, risk-informed, and viable regulatory framework for radiation protection.
- Todays decisions will shape the trajectory of U.S. nuclear energy and potential the world for decades to come.
Industry Commitment and Looking Forward
Thank You!