The EO starts out on a weak note, while falling into the threshold trap.
The NRC utilizes safety models that posit there is no safe threshold of radiation exposure and that harm is directly proportional to the amount of exposure. Those models lack sound scientific basis.
Here's what Trump should have said.
The NRC's regulatory philosophy is based on a 90 year old radiation harm model called LNT. LNT is biological nonsense. It denies our remarkable ability to repair radiation damage to our DNA. As a result, LNT over-predicts radiation harm to the public in a nuclear power plant release by many orders of magnitude. This ability is indisputable. To conform to undisputed science, LNT must be replaced.
A little later on, we find:
When carrying out its licensing and related regulatory functions, the NRC shall consider the benefits of increased availability of, and innovation in, nuclear power to our economic and national security in addition to safety, health, and environmental considerations.
This call to consider has no teeth. How about:
Any regulatory requirement or action shall be supported by a cost/benefit analysis. These analyses shall explicitly include the reduction in harm from displacing alternate sources of this power. //
It sounds good; but all it really requires is the delivery of some paperwork. The NRC gets to decide what's in these revisions. Once again we are asking the NRC to judge itself. We've done that before, most recently with NEIMA and the Advance Act, with nothing to show for it. There is no reason to believe that this time the results will be different. //
The sad truth is Trump can't change the incentives that will dictate the NRC's behavior. Whatever all the preambles and declaration of purposes, etc say the NRC will continue to be judged on its ability to prevent a release. And as long as we give such a bureaucracy the final say, it will be the bureaucrats' incentives that rule, not society's. But Trump could have outlawed LNT. And he could have forced ALARA underground. //
Business as usual, and the business is extracting money from the taxpayer.
