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Federal Register / Vol. 86, No. 156 / Tuesday, August 17, 2021 / Proposed Rules respect to evacuation decisions, the State and local authorities who make those decisions are not subject to the AEA or to the NRCs ALARA
requirement.
Moreover, ALARA is an operating principle designed to minimize the potential stochastic effects of low levels of ionizing radiation that members of the public and occupational workers may be exposed to as a result of routine licensee activities. The long-term potential in terms of years or even decades for the induction of cancer from these routine activities is the primary stochastic effect that the application of ALARA seeks to minimize. In an emergency situation involving the release of radioactive material, the overriding concern associated with evacuation decisions is to avert potential acute radiation exposure.
The NRC has concluded that the selection of a specific dose response model, LNT in this case, and the ALARA concept, which is premised upon the LNT model, do not lead directly to an unjustified fear of radiation, and thereby do not directly contribute to evacuation casualties and associated socioeconomic costs after a nuclear incident. The NRCs rationale for continuing to use the LNT model as the basis for its radiation protection regulations is set forth earlier in this document. The costs of mass evacuation scenarios described by the commenters do not provide an adequate basis to discontinue the use of the LNT model.
Comment: One commenter asserted that there may be cases where, in efforts to minimize even low radiation exposure to workers and the public in the design, operation, and accident management of nuclear facilities, we may actually increase the probability of much larger exposures from severe accidents.
Response: The NRC disagrees with this comment. The operating experience of nuclear facilities has not shown any relationship between severe accident risk and radiation protection practices.
Comment: Several commenters expressed concern that the publics fear of radiation exposure due to the NRCs continued use of the LNT model could result in patients postponing or foregoing CT scans and other diagnostic radiology procedures, thereby resulting in adverse medical consequences to the patient. Other commenters asserted that the use of LNT in the medical field can inhibit lifesaving processes that require a higher radiation dose than what is currently acceptable or can add to the cost of certain procedures, also
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inhibiting patients from receiving important treatment.
Response: The NRC disagrees with this comment. Moreover, the NRCs regulations do not apply to the decisions of a physician to prescribe a certain diagnostic or therapeutic modality to treat a patient. The physicians recommendation and the patients decision to undergo a CT scan are wholly informed by the professional judgement of the medical provider and are therefore outside the scope of the NRCs regulatory authority. The NRC
does not regulate machine-generated radiation, which is the type generated by the use of x-ray machines and CT
devices. Machine-generated radiation is regulated by the states, and as such, any application of the LNT model to the NRCs radiation protection requirements would not affect these medical uses.
Moreover, current evidence demonstrates that the use of radiation producing devices in medical diagnostic tests and therapies in the United States is increasingall while LNT has been in place as the underlying dose-response assumption for radiation protection. For example, the NCRP reported that the average medical exposure in 2006 had increased substantially from the early 1980s, primarily due to the increased use of CT, interventional fluoroscopy, and nuclear medicine.91 With respect to CT, the NCRP stated that technological advances in CT and the ease of use of this technology have led to many clinical applications that have increased the use of CT at a rate of 8 to 15% per year for the last 7 to 10 years prior to 2006. 92 CT scanning further increased from 2006 to 2012.93 The use of interventional fluoroscopy and nuclear medicine have also similarly increased.94 The commenters claims that patients are postponing or foregoing radiology procedures is not supported.
These commenters did not present evidence to support the assertion that the NRCs use of the LNT model results in adverse medical treatment consequences.
Comment: One commenter stated that the summary of the petitioners position 91 NCRP, Ionizing Radiation Exposure of the Population of the United States, Report No. 160
2009, at 5.
92 Id., at 85 alteration added.
93 Fred A. Mettler, MD, Professor Emeritus and Clinical Professor, Department of Radiology, Mew Mexico School of Medicine, presentation entitled Dose, Benefit, Risk and Safety at the 2018 Annual Meeting of the NCRP March 5, 2018. Dr. Mettlers presentation is expected to be published in the Health Physics Journal in 2019.
94 Id., at 117 the number of procedures in radiographic fluoroscopy increased by 54%
between 2002 and 2005 and at 195 5% annual growth in the number of nuclear-medicine procedures between 1995 and 2005.

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as described in the NRCs June 23, 2015, notice of docketing 80 FR 35870, characterized the petitions inaccurately, by stating that the petitioners wanted the NRC to amend the basis for radiation protection under 10 CFR part 20 from the LNT model to the hormesis model.
The commenter expressed concerns that readers would be negatively biased against the petitions due to this representation of the petitioners position.
Response: The NRC disagrees with this comment. In her petition, Dr.
Marcus requested that the NRC amend its radiation protection regulations in 10
CFR part 20 to take radiation hormesis into account. 95 Dr. Marcus then made several specific recommendations, including the complete removal of ALARA from the NRCs radiation protection regulations; the end of differential doses to pregnant women;
embryos and fetuses, and children under 18 years of age; and an increase in radiation dose limits to members of the public so that the public dose limit would be equal to the dose limits for occupational workers. In her petition, Dr. Marcus states that the removal of ALARA is not only harmless but may be hormetic, and in requesting that public doses should be raised to worker doses, asked why deprive the public of the benefits of low dose radiation? 96 In addition, Dr. Marcus referenced studies which she argued suggest that low doses of radiation decrease cancer rates and asserted hormesis is a perfectly good alternative explanation for such results.97 Similarly, in his petition, Mr.
Miller recommends that public dose limits should be raised to match worker dose limits, as these low doses may be hormetic, and that low-dose limits for the public perpetuates radiophobia. 98 Moreover, in its June 23, 2015, Federal Register notice of docketing, the NRC stated that the petitions were publicly-available and should be consulted for additional information.99 Thus, the NRC concludes that it accurately summarized the petitions in its June 23, 2015, Federal Register notice of docketing.
Comment: One commenter stated that a public education system should be put in place to dispel fear of low-level radiation.
Response: The NRC considers this comment to be outside the scope of the issues raised by the petitions, because 95 Marcus
petition PRM2028, at 7.

96 Id.
97 Id.,
at 4.
petition PRM2029, at 67.
99 80 FR, at 35872.
98 Miller
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