ML21210A442

Denial Letter to Dr. Carol S. Marcus - Petitions for Rulemaking, Linear No-Threshold Model and Standards for Protection Against Radiation

ML21210A442
Person / Time
Issue date:	08/11/2021
From:	Annette Vietti-Cook NRC/SECY
To:	Marcus C - No Known Affiliation
Cox, Vanessa
Shared Package
ML21210A440	List: ML21210A441 ML21210A442 ML21210A443
References
NRC-2015-0057, PRM-20-28, PRM-20-29, PRM-20-30, RIN 3150-AJ44
Download: ML21210A442 (2)

Text

August 11, 2021 Dr. Carol S. Marcus 1877 Comstock Avenue Los Angeles, CA 90025-5014

Dear Dr. Marcus:

I am responding to the petition for rulemaking (PRM) that you submitted to the U.S. Nuclear Regulatory Commission (NRC), PRM-20-28, dated February 9, 2015 (Accession No. ML15051A503 in the NRCs Agencywide Documents Access and Management System). The NRC received two additional petitions on the same topic (PRM-20-29 and PRM-20-30); all three petitions were docketed using the same Docket ID (NRC-2015-0057). In these petitions, you and the other two petitioners request that the NRC amend Part 20 of Title 10 of the Code of Federal Regulations (10 CFR), Standards for Protection Against Radiation, based on what you characterize as new science and evidence that contradicts the linear no-threshold dose-effect model that serves as the basis for the NRCs radiation protection regulations. The specific recommendations made by you and the other petitioners are:

• Maintain worker doses at present levels, with allowance of up to 100 mSv (10 rem) effective dose per year if the doses are chronic;

• Remove the As Low As Is Reasonably Achievable principle entirely from the regulations, because you claim that it makes no sense to decrease radiation doses that are not only harmless but may be hormetic;

• Raise the public dose limits to be the same as the worker doses, because you claim that these low doses may be hormetic; and

• End differential doses to pregnant women, embryos and fetuses, and children under 18 years of age.

The notice of receipt and request for comment on your petition was published in the Federal Register on June 23, 2015 (80 FR 35870). The public comment period was initially set to close on September 9, 2015, but was subsequently extended to November 19, 2015 (80 FR 50804).

The NRC received over 3,200 public comment letters.

The NRC has considered the petitions, and the arguments raised therein, as well as the comments received in response to the petitions. For the reasons stated in the enclosed Federal Register notice (FRN), the NRC is denying the three PRMs (PRM-20-28, PRM-20-29, and PRM-20-30) in their entirety. Given the current state of scientific knowledge, the NRC has determined that its current radiation protection regulations are effective and provide for the adequate protection of human health and safety such that changes to 10 CFR Part 20 are not warranted at this time.

C. Marcus The FRN denying the petitions is being transmitted to the Office of the Federal Register for publication.

Sincerely, Annette L. Digitally signed by Annette L. Vietti-Cook Vietti-Cook Date: 2021.08.11 09:46:07 -04'00' Annette Vietti-Cook Secretary of the Commission

Enclosure:

Federal Register notice