The Current State of Radiation Protection in the United States

Executive Summary

The United States lacks a cohesive radiation protection framework. Seventy-nine regulations across ten federal agencies create a system where acceptable risk levels vary by up to 100,000-fold depending on jurisdiction rather than actual hazard. This fragmentation increases compliance costs, creates standards that are confusing for both workers and the public, and obscures the technical debates over the underlying radiation safety sciences.

Advanced reactor developers must navigate incompatible requirements from NRC's dose-based limits, EPA's risk-based air emission standards, and EPA's environmental standards: separate analyses for the same fundamental risk. Some As Low As Reasonably Achievable (ALARA) goals for reactor effluents are set so low they render broader limits functionally meaningless.

These inconsistencies stem from competing regulatory philosophies, not science. The NRC and DOE use dose-based frameworks accepting optimization through cost-benefit analysis. The EPA uses risk-based frameworks under the Clean Air Act, back-calculating doses from acceptable cancer risks. Agencies recognize each other's approaches but cannot legally reconcile them.

Substantial improvements are achievable through executive branch action. A graded approach distinguishing dose limits, action levels, and de minimis thresholds would keep the U.S. regulatory system generally aligned with international standards while leading the way on reasonable safety standards. Full harmonization will require Congressional action to reconcile the Clean Air Act's risk-based mandates with the Atomic Energy Act's dose-based framework.