Change at EPA could reduce the high cost of nuclear energy & improve grid cleanliness
During a recent conversation with a successful career employee of the Nuclear Regulatory Commission (NRC), the topic of radiation protection limits came up. He reminded me that the NRC’s role in radiation protection is limited to enforcing the standards that are set by the Environmental Protection Agency (EPA).
In light of President-elect Trump’s statements about finding and eliminating regulations that harm more than they help or protect, it is worth noting that the EPA is the responsible agency for 40 CFR 190, which limits maximum exposure to the general public from nuclear reactor operations to 0.25 mSv/yr. It is also the agency responsible for 40 CFR 191, which limits human exposures to radiation from used nuclear fuel, high level waste and transuranic wastes to a committed effective dose (CED) of 0.15 mSv/yr for a period of 10,000 years.
If you want to get into a contentious, multi-day discussion, ask five radiation protection experts to describe the methodology used to compute a committed effective dose from used fuel repository over time.
To put those radiation protection limits into perspective, the average American who is not occupationally exposed to radiation will receive a total of 6 mSv/year from a variety of sources including cosmic radiation (sunshine), radiation from rocks and soil and medically-related exposures.
Within the $8 billion/year 15,000 employee EPA, radiation protection limits are controlled by a marginally-resourced office of 59 people buried deep within the EPA.
The EPA branch responsible for radiation protection standards is the Radiation Protection Division (RPD) of the Office of Radiation and Indoor Air (ORIA) within the Office of Air and Radiation (OAR).
Its science and technology budget is roughly $2 million/year; that number has been essentially constant since 2011, the oldest budget still readily accessible.
Aside: In the period from 1962-1969, the budget for one of several radiation health effect research programs sponsored by the Atomic Energy Commission (AEC) was $3-$3.5 million per year in then-year dollars. That provides some perspective on the lack of interest in knowledge accumulation to support EPA standard setting. End Aside.
The radiation science budget item description that has been cut and pasted from previous justification submissions since 2013 provides rather grandiose claims of expertise for an office given such a small annual appropriation.
The agency’s radiation science is recognized nationally and internationally; it is the foundation that the EPA, other federal agencies and states use to develop radiation risk management policy, guidance, and rulemakings. The agency works closely with other national and international radiation protection organizations, such as the National Academy of Sciences, the National Council on Radiation Protection and Measurements, the International Atomic Energy Agency, the International Commission on Radiation Protection and the Organization of Economic and Cooperative Development’s Nuclear Energy Agency to advance scientific understanding of radiation risk.
Update (November 22, 2016 3:15 PM)
I contacted the U.S. EPA to directly find out how the agency conducts useful science on the health effects of radiation with an annual appropriation of just $2 million per year. Here is a quote from the response I received.
Can you point me to documents that describe the work that your organization does to determine the health impact of radiation at various doses? How do your studies on the health effects of radiation inform your public risk evaluations?
Please see “EPA Radiogenic Cancer Risk Models and Projections for the U.S. Population,” also known as the “Blue Book.” https://www.epa.gov/radiation/blue-book-epa-radiogenic-cancer-risk-models-and-projections-us-population. The Blue Book lays out EPA’s methodology for estimating cancer risks from radiation exposure, and is based on the National Research Council’s “Biological Effects of Ionizing Radiation (BEIR VII)” report.
A copy of the Blue Book can be downloaded at https://www.epa.gov/sites/production/files/2015-05/documents/bbfinalversion.pdf.
The version of 40 CFR 190 that remains in effect was issued in Jan 1977. It will be forty years old in a month. These rules are ripe for fundamental change based on the improvements in biological science during the period since they were imposed. The version of 40 CFR 191 that is still in effect was issued December 20, 1993. It doesn’t use any improved science compared to the 1977 issuance of 190; it is devoted more to explaining and justifying the selection of “committed effective dose” and a 10,000 year modeling requirement.
In 2014, the EPA issued an advanced notice of proposed rulemaking (ANPR) to review and potentially revise 40 CFR 190. That effort, however, hasn’t progressed beyond the comment collection and summary stage. It seems to be in a state of bureaucratic suspension.
Billions of dollars are spent every year to enforce and comply with the exposure limits issued by the EPA’s Division of Radiation Protection. There should be bipartisan support for making the comparatively small investment needed to use modern science to update the standards. Exposure limits should seek to protect public health and safety based on fundamental understanding of biological effects.
Standards setters should not rely on decades-old assumptions that result in limits that even a casual observer should recognize as absurdly low in comparison to other sources of routine radiation exposure.
The remainder of this post is a history lesson. I provide that warning for people who don’t ascribe to the idea that those who do not learn from history are doomed to repeat it or to be locked into bad policies for the wrong reason.
Major chapter in radiation protection story driven by Nixon agenda
As documented in Glenn Seaborg’s The Atomic Energy Commission Under Nixon: Adjusting to Troubled Times, Richard Nixon seems to have entered office with an apparent personal mission to dismantle the Atomic Energy Commission (AEC) and its congressional power base, the Joint Committee on Atomic Energy (JCAE). Contemporary news articles support Seaborg’s view. Here is the lede of a Jun 12, 1970 New York Times article titled Nixon Aides Weigh Reshaping AEC for a Wider Role.
he Nixon Administration is seriously considering a plan to break up the Atomic Energy Commission and remake it into an agency dealing with all forms of energy.
Administration sources said the proposal would shift the commission’s military programs to the Department of Defense and many of its research activities to the National Science Foundation.
The A.E.C. would then be broadened into an over‐all energy agency. One problem it would deal with is the electric power shortage, which threatens much of the East with power brownouts this summer.
Seaborg was a dedicated journal keeper; his books about his service with the AEC are based on his daily journal entries that often included copies of relevant documents (reports, correspondence, meeting minutes, newspaper articles, memos, etc.)
He summarized his final years at the AEC in the foreword of Seaborg’s book about his Nixon years.
It is the story of a once proud and privileged government agency that is declining in reputation and influence, how one establishes goals when choices are limited by an impoverishment of means, of the maneuvers that are employed to sustain what seems to be worthwhile endeavors, and of how one sorts out policy and politics, chooses between adherence to principle and compromise and in the end must sometimes fight rearguard actions for survival.
All in all, it is far from being a triumphant story. The Nixon years were difficult ones for the AEC. In part, this may have been due to the special foibles of this president and his administration. More significantly, however, our difficulties can be attributed to the spirit of the times, particularly the opposition to the Vietnam War and a rising environmental consciousness.
(p. ix, x)
Furor over radiation standards
A section in Seaborg’s book on the Nixon years is titled The Furor Over Radiation StandardsThe Nixon Years p. 123)
In 1969 Gofman and Tamplin began loudly touting calculation results predicting that exposing the American public to radiation doses at the then allowed rate of 0.17 RAD/year (170 mrem/yr or 1.7 mSv/yr) would produce 32,000 excess deaths per year from leukemia and solid cancers.
Gofman and Tamplin’s calculations were based on the belief that there was no safe dose of radiation. Despite a lack of evidence of harm from doses that were 10-50 times higher than the AEC’s limits, the two scientific colleagues devised coefficients using data from much higher dose levels and produced calculated effects that assumed that the relationship between dose and cancer risk remained constant down to the last gamma ray. Their work was a return to the straight line, no safe dose model promulgated by the 1956 BEAR 1 (Biological Effects of Atomic Radiation) committee.
Gofman and Tamplin did not publish their work in academic journals. Instead, they presented it to the public, politicians and the press. They made a number of appearances at public meetings in Vermont, Minnesota and California and testified in front of Congress at the invitation of Senator Edmund Muskie during the second half of 1969.
In the summer and autumn of 1970, articles about the two [Gofman and Tamplin] appeared in McCalls, Esquire, Atlantic Monthly, Newsweek, National Geographic, Reader’s Digest, Life, Barrons, and the National Journal. During the same time period, there were feature articles in several newspapers, including the Philadelphia Enquirer (a series of seven articles), the Christian Science Monitor (a three part series), the New York Times, and the Washington Post (the last two with several articles each). In addition, all three television networks did special programs, one on ABC giving the subject of ‘Nuclear Energy and the Environment.’ Ever present in these media presentations was the allegation of about 32,000 extra cancer deaths per year, a statistic that by its very repetition began to achieve a semblance of reality.
(Seaborg, The Nixon Years pg 131-132)
It seems likely that the two scientists were supported by a public relations firm or, at a minimum, a skilled publicist. The AEC inadvertently contributed to the attention Gofman and Tamplin were able to attract by actively defending itself and taking action that could easily be construed as retaliation against the attacks from within.
Aside: Turning critics into martyrs is never a good way to win a technical argument. End Aside.
Using hindsight, it’s apparent that the AEC made another major error in its effort to defend its authority to set limits. Its response to the 32,000 number was to claim it was too high because no one was exposed to doses anywhere close to the 1.7 mSv/year limit. Instead of reassuring anyone, that argument merely encouraged people to suggest lowering the legal limits since power plants were obviously capable of meeting much stricter limits.
That line of defense also begged the question, if 32,000 deaths/year isn’t accurate, what is the real number? In such a situation, there is no good answer. Now, with modern science it is possible to answer the question by saying that no one in a population whose annual exposure limit is 1.7 mSv will have an increased risk of cancer. That same statement can accurately be made for exposures up to 100 mSv/yr and perhaps even higher.
Minnesota imposes limits much lower than AEC’s limits on the Monticello plant
The Monticello plant site is about 40 miles north of the twin cites of Minneapolis and St. Paul. Expressing their concerns about drinking water contamination, the state of Minnesota insisted on the right to establish radioactive material release limits that were much stricter than those established by the AEC.
State authorities had been influenced by furor that Gofman and Tamplin had helped to initiate.
In Aug 1969, Northern States Power, the license applicant for the Monticello plant sued the state of Minnesota, challenging its legal standing to impose limits on radioactive material discharges. Minnesota was eventually joined by about 20 other states as intervenors or friends of the court.
Seaborg tried to interest the Nixon Administration’s Justice Department in joining the case on the side of the utility to defend the AEC’s preemptive responsibility to regulate radiation. According to the way the AEC and the JCAE interpreted the Atomic Energy Act of 1954, Congress had expressed its intent to elevate radiation regulation to the federal government. Seaborg was told that it had always been part of the Republican ideology to defend states rights. Assistant Attorney General William Ruckelshaus had been instructed by the White House to keep the Justice Department out of the case. [Seaborg, The Nixon Years p. 106)
How did the EPA get the authority to establish radiation protection standards?
When President Nixon issued Reorganization Plan No. 3 in the summer of 1970, he consolidated the radiation protection activities of the following existing agencies: Federal Radiation Council, Department of Health Education and Welfare Bureau of Radiological Health (HEW-BRH), Atomic Energy Commission Division of Radiation Protection Standards.
Radiation Protection at the EPA describes the functions from those organizations that were assigned to the EPA. All of the duties of the Federal Radiation Council were transferred to the EPA and the FRC was abolished. There was a less complete transfer of functions from the other organizations.
EPA was generally provided research, monitoring, standard setting, and enforcement authorities for each category of pollutant. However, the transfer of radiation protection responsibilities to EPA was more limited than that of other pollutants, in that the authority for enforcement of radiation standards was retained by the Atomic Energy Commission (AEC). EPA would later gain enforcement authority for the regulation of some radioactive materials under certain environmental statutes.
According to a New York Times article published on June 12, 1970, only 20 people were reassigned from the AEC to the EPA. Some experts in the field apparently found new work within the AEC instead of transferring to a new agency.
Why did Nixon take authority for radiation protection standards away from AEC?
It’s invariably risky and controversial to attempt to answer questions about why politicians take certain actions. That doesn’t mean that the research isn’t worth the effort or that the developed explanation isn’t worth sharing.
The controversy over radioactive material release standards delayed the commercial operation of the Monticello plant by more than a year. The publicity about that struggle, combined with the media attention attracted by Gofman and Tamplin and the campaigns waged against radioactive releases from tests conducted as part of the Ploughshares program resulted in an upwelling of expressed public distrust in the AEC. (Note: Ploughshares was the program name for the effort to use nuclear explosives for civil engineering and hydrocarbon fracking.)
Nixon’s action to move radiation effects research and standards setting to the EPA was portrayed as a way to defuse public concerns about the AEC being the standard setter, the enforcer and the promoter of the use of radioactive materials in commerce and defense applications. It was also the first step in his effort to dismantle the AEC.
The next installment in this series will describe how the EPA seized its new authority and decided to drastically lower the allowed public exposure limits and the limits on radioactive effluent releases.
Note: Nixon was a big supporter of the frequently criticized Ploughshares program, which was run out of the Lawrence Livermore laboratory located in his home state of California. Less than two weeks after Nixon’s inauguration, Seaborg briefed him on the program. Nixon asked Seaborg to brief the press and provided detailed guidance for what he wanted Seaborg to say.
The president expressed a great interest–and he asked me particularly to tell you this–in the peaceful uses of atomic energy. He particularly identified the peaceful uses of atomic explosions as an area in which he had a special interest.
Though his support can be explained in several ways, it is conceivable that the underlying motive on the part of some members of Nixon’s close circle was a desire to maintain the link in the public’s mind between nuclear power and nuclear weapons by labeling explosive detonations as “peaceful uses.”
So, it just makes sense to look the horse right in the eye…so thats what I did.
I sent the following question to Myron Ebell, via his email….
“Curious. Do you intend to relieve the nuclear energy industry of its onerous regulations, or does your intention to deregulate just involve the fossil fuel industries?”
“Thank you, should you choose to respond…..Jon ****”
He responded, almost immediately…
“Dear Jon, I can’t talk about what the transition is doing. Most nuclear issues are within the Department of Energy team’s purview and thus outside mine. However, the President-elect did give several speeches about energy policy during the campaign. You might consult those. Yours, Myron. “
Ebell is correct. Almost all nuclear regulations are under the control of the NRC.
His response to you illustrates the importance of the point I was trying to make in this post. Though the EPA has little or no interest in studying or adjusting radiation dose limits, it has the statutory authority and responsibility to eastablish the overall standard that hundreds of NRC regulations and inspections are designed to achieve and enforce.
The branch assigned the task of conducting the science and producing the rules has a small staff and a very limited budget. Their rules are thus four decades old and do not incorporate modern scientific knowledge.
Rather than constantly searching for the “truth” on radiation exposure we should come at it from an entirely different direction.
We reject is is a danger to humans (from nuclear used in power reactors, naval ships, etc.)
Real danger produces real causalities. Period. Seventy years of nuclear power has produced nearly NO causalities. Radiation can be harmful, but, like fire, it has been handled with great care resulting in almost 100% safe, productive use of the power source. We will never satisfy the opposition arguing about radiation doses, etc.
The test of a “safe” technology is the causalities it produces or does NOT produce.
In the 1600”s in Salem, Mass. witch hunters saw evil spirits invisible to all but themselves. People were executed based on the imaginary evil spirits alleged by the witch hunters. Today we put the whole planet and everyone on it in great peril by playing along with today’s radiation witch hunters who produce no causalities. proving their claims. Its time to ignore completely seers of invisible evil. Our precarious global warming stage demands we do that now!
POA’s question is a good one. Fossil fuel interests do run the government, regardless of the party in power. In the US context, this means hostility to nuclear energy and to reforming absurd regulations to conform to modern science. In the UAE, fossil fuel interests see things differently and are facilitating a admirable 4-reactor build in cooperation with South Korea. Why should the UAE burn, to them precious and declining, gas and oil for domestic electricity, when more profits will be made selling them on the world market, especially when prices rebound? It is interesting that Canadian oil sands interests seem to like Terrestrial Energy’s IMSR project, which will facilitate oil sands’ extraction without burning copious quantities of natural gas, as they do now. And so, until I see a similar self-interest for U.S. oil/gas companies to sing a pro-nuclear tune, I expect that such a radiation science reform at the EPA may be forced on them by geopolitical events. Namely, when China is ready to crank up the mass production lines for Gen III and IV reactors, it will be in their interests to collaborate with the Russians and others to require world nuclear regulatory bodies to discard the “No Safe Dose” regulations in favor of scientific ones. Not only will this mean cheaper nuclear, but it will be safer. Safety is not enhanced by requiring absurd behavior. Until then, it seems to be in Chinese/Russian interests to allow Japanese radiophobia (and that of the U.S. EPA, etc) to go unchallenged, which only hurts their Japanese etc. competitors on the world market. The sting of being losers on the growing and soon-to-be giant world market may compel regulatory reform. And it is not just commercial competition at stake. Surely State Dept. etc. think tanks are not unaware of the geopolitical influence Russia/Rosatom is building up with its export of reactors to a dozen or more countries? Beijing has ambitions that dwarf this effort. We live in a stagnant pool, a declining empire. It will not be able to call the shots forever.
“We live in a stagnant pool, a declining empire. It will not be able to call the shots forever.”
Wow! powerful words. Maybe, it will be a good thing to allow the people of the world to make their own decisions. I’m not sure that our leadership guided by the captains of industry have taken the correct paths in recent years. Nuclear power is just one such example.
I have spent considerable time searching the net, trying to find Mr. Ebell’s stance on NE. His answer to my email is consistent with virtually every comment I can find from him concerning NE. He alway seems to imply an indifference, as though NE is ouside his sphere on interest, or influence. Nothing from him positive, nothing negative.
Assuming, without any evidence to support it, that Ebell intends, or decides in the future, to endorse NE, and take some of the governmental reins off through deregulation, new plants would still be a long term project to bring them online. However, removing regulations on fossil fuel extraction, mining, refining, transportation, and distribution would enjoy immediate ramifications for an industrial infrastructure already in place. Any environmental benefits gained by giving NE a boost in the long term, could easily be offset by the immediate effects of an injection of steroids into our fossil fuel industry. Frankly, I strongly doubt that Ebell will have a positive effect on anything other than the bank accounts of oil industry executives whose interests are global, and corporate, and hardly concerned with what kind of planet our grandchildren are going to inherit.
My post isn’t directed at Ebell. It’s directed at other decision makers who need to know where the various Lilliputian threads are that continue to restrain the atomic Gulliver.
I’m not a fossil fuel opponent. I like using it. In modern machines, it’s pretty darned clean. Nuclear energy is superior in many ways, however. It can compete and win in many markets as long as it isn’t artificially restrained.
Fossil fuel interests, however, learned long ago that openly fighting against nuclear to protect their investments wouldn’t work. They successfully devised a more effective strategy of relying on “environmentalists” as surrogates [mercenaries]. That strategy won’t work anymore, now that it’s been recognized and exposed.
If you want to see less fossil fuel extraction, you should ardently support nuclear energy abundance. It will inevitably drive market prices down and reduce development incentives, especially in remote, undeveloped areas.
“I’m not a fossil fuel opponent. I like using it. In modern machines, it’s pretty darned clean.”
And those modern machines burn fossil fuel “pretty darned clean” as a direct result of regulatory intervention by entities such as the EPA. Surely you don’t believe that the auto industry, the trucking industry, etc., would police themselves responsibly without that regulatory intervention? The current scandal surrounding the Volkswagon mileage and emission claims drmonstrate the foolish nature of such a belief.
As the owner or former owner of three Volkswagen Jetta TDIs (2001, 2002 and 2012), I have a bit of standing on the emissions testing cheating scandal. The perpetrators made an enormous tactical error in deciding to cheat rather than to resist the regulatory ratcheting in the first place. As a result of taking a dishonest shortcut to achieve a desired result, they have cost their company tens of billions of dollars.
The haircut isn’t being completely absorbed by investors – VW recently announced that it was laying off 30,000 employees and had renegotiated its labor agreement.
I’ve developed pretty good relationships with the two VW dealers I’ve patronized for the past 15 years; their businesses were severely harmed by the scandal.
Here’s the thing, though. My 2012 Jetta, even on the road and without the artificially low emissions produced by the testing protocol, produces substantially lower emissions than either my 2001 or 2002 vehicles did. Because of regulatory ratcheting, however, it is in violation of the law while the other two vehicles are fully compliant and allowed to continue operating until the end of their natural lives.
In terms of mileage for my vehicles, VW was actually quite moderate in the claims it put on the sticker. Even though I occasionally exceed posted speed limits on the highway, I generally obtained 2-5 miles per gallon more than what the sticker said. Over the past 15 years, my cars have averaged about 45 MPG in mixed urban, suburban and open road driving conditions.
All of the nonsense that you have read about the number of computed lives cost by the NOx produced in excess of current requirements is based on exactly the same kind of linear, no threshold dose model as the predictions of cancer deaths from low levels of radiation. The NOx emitted by those VW 2.0 liter engines is a tiny fraction of the NOx produced by the tens of millions of diesel engine trucks and buses on the road, so it would be a tiny fraction of the total NOx — or the chemical daughters as NOx breaks down — to which anyone would be exposed.
As I see it, VW and other diesel car makers did not want to invest the political capital required to resist the regulatory ratchet by explaining the trade offs between high mileage and slightly elevated NOx. NOx isn’t the result of dirty fuel or inefficient burning. It is actually the product of the very high temperatures achieved in high efficiency combustion engines. It is produced because the nitrogen and oxygen in the incoming air stream combine at very high temperatures. It has a short half life in the atmosphere and is only a hazard in congested cities, especially under temperature inversion conditions.
“All of the nonsense that you have read about the number of computed lives cost by the NOx….”
I expect that kind of presumptive forshadowing from some here, Rod. I hate seening you do it, though. It is a tactic intended to shift attention away from what was said, so a response can be waged that avoids having to compose a direct rebuttal.
I have read NOTHING about NOx, and I know even less about it No doubt, considering what side of your brain pushes you down the road, you understand, and have offered a sound scientific argument, about why fear of NOx may be exagerrated. I wouldn’t know.
My comment, however, had to do with VW’s handling of a regulation they believed was too onerous technically, from a manufacturing standpoint, (Or production costs?), to adhere to, so they simply….well…lied. So where does the line get drawn, Rod? Will a system of relaxed regulation also yield the same response from VW when they are faced with a regulation, or body of regulations, they disagree with, or find too expensive to adhere to, even in its relaxed state? What about BP, and all the protocols, regulations, and safety practices they ignored in pursuit of profit on Deepwater Horizon? By their own actions, entities and corporations producing products that present potential dangers to our societal whole demonstrate the absolute NEED for stringent regulation. They WILL NOT police themselves responsibly, sans governmental intervention. It has been proven time and time again.
Because of the huge money involved in the construction of a nuclear power plant, even with relaxed regulations, the same concerns are warranted. Face it, the construction companies, reactor builders, utility companies, etc., are not in this because of an altruistic pursuit of clean air and a healthy planet. The science might start out that way, with a star gazing nerd dreaming of utopia. But when big money gets involved, it doesn’t take long for a utopian dream to become a corporate mightmare.
If you’ve read nothing about NOx, it is only because you have limited yourself to headlines or shallow articles. That was the targeted pollutant of VW’s cheating. See, for example, this page that was created to track stories related to the “VW Group diesel NOx emissions scandal”
As I noted in my comment, it wasn’t that VW was seeking relaxed regulations. The root of the problem here is that the regulators severely tightened the standard. It’s quite possible that the NOx standard was tightened at the request of other car makers who had not invested in diesel engine technology and were unable to match the overall performance that VW was getting in terms of torque, quiet ride, durability and milage.
Please read my previous comment carefully to see what I think VW should have done instead of cheating.
“My comment, however, had to do with VW’s handling of a regulation they believed was too onerous technically, from a manufacturing standpoint, (Or production costs?), to adhere to, so they simply….well…lied.”
The regulation wasn’t too onerous from a manufacturing or production point of view. It was technically too onerous from a fundamental engineering/combustion chemistry point of view. As I tried to briefly explain in my previous post, high efficiency combustion engines need high temperatures. The higher the temperature, the better the efficiency. However, if you burn ANYTHING in air at high enough temperatures, you are going to produce nitrogen oxides (NOx) because the nitrogen in the air begins to oxidize. The only solution is burning at lower temperatures, thus reducing efficiency and possibly producing other harmful emission products.
In power plants or very large vehicles, it is possible to put in a post combustion processing system that removes the NOx from the exhaust, but that kind of system would not fit into a Jetta or Golf sized engine compartment. The price required to pay for the extra system would probably price the vehicles completely out of range of the target market.
Even without the post combustion processing, my Jetta TDI cost several thousand more than a similarly equipped gasoline TDI. I made the investment because I drive a lot and liked the 30-40% improvement in gas mileage along with the added benefit of diesel durability and diesel torque. I owned my 2002 TDI for 10 years and drove 222,222 miles with no major maintenance. I had planned on getting at least that many miles from my 2012 before the cheating scandal was exposed.
I’m quite sad that I may never again be able to drive such a satisfying automobile.
I don’t think that is entirely correct; that all NOx emissions from hydrocarbon combustion are from high temperature disassociation only. Fuel oils lower in the distillation process (e.g. residual, heavy fuel oil) have nontrivial wt. %’s of Nitrogen that contribute to NOx emissions. The best source I can find with numbers is below, but it doesn’t mention highway diesel: http://www.dec.ny.gov/chemical/31240.html
I assume fuel sources of Nitrogen are as equally low as Sulfur in highway fuels.
As someone part of the maritime industry, I wanted to make it clear that NOx emissions from ship fuels are not just from highly efficient engines, but the fuels themselves.
“As the owner or former owner of three Volkswagen Jetta TDIs (2001, 2002 and 2012), I have a bit of standing on the emissions testing cheating scandal. ”
“In terms of mileage for my vehicles, VW was actually quite moderate in the claims it put on the sticker. Even though I occasionally exceed posted speed limits on the highway, I generally obtained 2-5 miles per gallon more than what the sticker said. ”
You don’t need standing to be mistaken. They were not “moderate in claims.” Their cheat on emissions also impacted mpg testing:
( http://www.consumerreports.org/volkswagen/did-volkswagen-use-cheat-mode-as-a-selling-point/ )
The difference is the approximate decrease in mpg to expect after the “fix.”
“All of the nonsense that you have read about the number of computed lives cost by the NOx produced in excess of current requirements is based on exactly the same kind of linear, no threshold dose model as the predictions of cancer deaths from low levels of radiation. ”
Similar methods are used for estimating coal deaths as well, but are you sure they didn’t put these NOX changes into the “complete models of life, the universe, and everything” used for climate change, and see what came out?
It is also possible that the approximate models are accurate enough over the applicable ranges, and it’s not nonsense:
( bmjopen.bmj.com/content/5/5/e006946.full )
“The NOx emitted by those VW 2.0 liter engines is a tiny fraction of the NOx produced by the tens of millions of diesel engine trucks and buses…”
Finally, something to agree on; however, those trucks and buses provide more benefit to more people, so the regulations are a balancing act of many factors, values, and judgments. Once you’ve accepted the government has the power to regulate a gas we all breathe out, CO2, there is no limit.
“The only solution is burning at lower temperatures, thus reducing efficiency and possibly producing other harmful emission products.”
Maybe you aren’t familiar with filtering and urea injection systems used to treat the exhaust, as used in cars by Mercedes and Audi. Yes, the prices are higher, and therefore, it seemed like a miracle that VW could meet the standards without those systems. Indeed they couldn’t. At least VW didn’t directly kill people, such as from faulty airbags or accelerators and other things, which resulted in lower penalties?
“I’m quite sad that I may never again be able to drive such a satisfying automobile.”
You could begin another lobbying campaign, to raise those emission limits, similar to the campaign to raise radiation exposure limits.
I think the newfound fixation on fossil fuels is a trollish distraction. This administration isn’t going to penalize the fossil fuel industry or consumers. Its off the table now.
No POA, no one is advocating the removal of all environmental regulation. Its dishonest to suggest so or that there is any kind of equivalency between fossil fuel and nuclear safety standards or that the industries operate on the same set of incentives, initial mechanisms or outcomes.
“No POA, no one is advocating the removal of all environmental regulation. Its dishonest to suggest so…yadayadaya…”
I haven’t suggested that, Jon. Whats dishonest is implying that I have.
Got buyer’s remorse yet, Jon? Trust me, you will.
Anyone see Exxon-Mobil’s latest commercial? Not techie but people oriented and it sticks. Just a round-robin of their scientists and engineers explaining what they do to “help the planet.” A very simple inexpensive commercial that the nuclear won’t do and so deserves the public scorn it does. Exxon knows you reap what you sow.
The problem is that regulated nuclear utilities can’t do that, because their regulators look askance at any self-promotion expenses. Nor can their organizations like NEI do it for them, for the same reason. Merchant plants in “deregulated” markets might, but the companies like Entergy and Exelon don’t seem to see an upside.
I have noted the careful PR that was launched after the gulf disaster. In fact, many times I have commented here about it. BP went so far as to go to a green logo shortly after that. Also, they turned up their PR volume louder than the media reporting about the ongoing and long term damage to the gulf, knowing that all they had to do was wait out the media, then concoct some BS about the damage being behind us, and the clean-up being a success. Of course, anyone following the story closely knows it will NEVER get cleaned up, and that lives have been ruined by BP’s ability to weasel out of its settlement obligations with am armu of attorneys that no common man can afford to fight. (Also a favorite Trump strategy). This is the industry that Trump and Ebell are about to deregulate.
Of course, we saw no such PR effort from the NE industry on the heels of Fukushima. Foolishly, and disastrously, the industry allowed the media to control the narrative without offering a strong PR rebuttal.
Ouch….here we go again. Another quake in Japan, another tsunami, and another plant that has lost cooling, supposedly. It was just a coupla topics ago that “bonds25” was telling us how “epic” the 2011 disaster was. It will be interesting to see, after the news gets straightened out, why this plant lost cooling, if in fact it did.
Well, there can be no doubt that no counter narrative will be launched to offset the bad PR that nuclear energy is once again going to experience. No matter how minor the damage, the news reports are using this quake to resurrect mention of the 2011 event. Citing scientific data, exposure levels, etc. are NOT a counter narrative. The public doesn’t trust them, because they don’t understand them. The industry needs to humanize the lack of danger, emphasize the lack of danger by demonstration. Pictures of scurrying figures in white moonsuits is a pretty powerful message. How you can counter that is beyond me. One hopes we don’t see that on tonight’s news channels, and, if we do, one hopes people such as Ms Korsnick are looking for ways to minimize the impact of such images.
I cant believe NO news site that I have seen commented on the length of time the fuel had been out the reactor making a theoretical catastrophe all but impossible. Im sure someone there knows this stuff better than I do and its inexcusable they did not attempt to convey a accurate situation report.
This quake was only a mag 7.3, nothing compared to the monster 9.1 of 2011. (About 1/500 the energy.) The latest I got from Yahoo is that there was a tsunami warning that is now cancelled.
Talk about nuke plants with lost cooling sounds like pre-emptive rumor seeding by anti-nuke propagandists. IIUC no units on the east coast have been restarted yet, and no plant with fuel that’s been cooling since late 2011 even needs water cooling any more.
Actually, the first reports of a loss of cooling on the spent fuel pool came from TEPCO, not “anti-nuke propagandists”. I followed it from minutes after the quake. There was considerable media confusion in the first two hours, even about which plant was affected.
And the quake in 2011 was NOT a 9.1. Nor was this one a 7.3.
Regardless, it will be interesting to see what knocked out the cooling to the pool, initially. I recall all the “it wasn’t the quake, it was the epic tsunami” excuses in 2011. Here you have a quake, of far less magnitude, no tsunami flooding….and….once again, a cooling failure.
Yeah, I know, the choir here will holler no harm, no foul. But thats not the way the press will treat it. Nor should they. Japan is on an extremely active siesmic zone. If the plants can’t be constructed to withstand quakes without equipment failures, even if the failures are minor, then perhaps they shouldn’t be in Japan. It is not unreasonable to expect quakes, in the 6 to 8 magnitude level. If a 6.9 can cause an equipment failure, that ain’t a good sign.
The cost of producing the commercial is trivial compared to the cost of airing the commercial on outlets that attract a large number of viewers.
The cost of airing such commercials is trivial compared to the cost of NOT airing such commercials.
I recommend Wade Allison’s “Radiation and Reason” for a modern view, based in part on radiation therapy studies, of the harmless and possibly beneficial effects of low dosage rate ionizing radiation. Dr. Allison is not the only one, but I don’t have access to my list of the papers at this time.
Russian/Chinese cooperation in nuclear energy is being stepped up. From Rosatom today:
“Underway Towards New Power Units
Russia and China will strengthen their strategic partnership in the civil nuclear industry. At a meeting held in early November, Russia’s Prime Minister Dmitri Medvedev and Premier of the China’s State Council Li Keqiang made a joint statement on the development of strategic partnership in the civil nuclear industry. Emphasizing a balance of interests and mutual benefit of the parties, the communiqué is aimed to facilitate Rosatom’s major projects in China.”
China and Russia are also cooperating to dethrone the US dollar as the currency used for all world oil sales. I suspect that most US/Russian conflict today centers on this attempt to destroy the petrodollar.
If Russia/China can cooperate on such a major geopolitical attack on US financial interests, I do not doubt that they will attack US/Japanese radiophobia in international nuclear regulatory bodies, when it suits their interests to do so. For now, not challenging and sometimes encouraging Japanese/US radiophobia/idiocy is in their interests. This will change when they are ready to destroy their competitors on the world market. Offering major cost reductions through being scientific about radiation, will be a compelling argument. IMHO. In the short term, I suspect China will order a bunch of AP1000s (once proven, which will be soon) in part, to launder all sorts of US dollar reserves in a productive way, before it inflates and depreciates. Just a guess.
“In light of President-elect Trump’s statements…….”
It is rapidly becoming, more so every day, that what Trump says is complete and utter BS. If I had been conned by this feckless liar, and actually voted for him, I’d already be po’ed beyond conciliation. Special prosecutor…off the table. Immediate deportations….off the table. Repeal Obamacare…..off the table. Separation between presidency and business interests….off the table…
So, “in light of President-elect Trump’s statements”, as opposed to his actual actions, with nary a coupla weeks gone by….
Its anyone’s guess what this lying posturing con man is going to do, about energy issues, or anything else.
And now, he admitting to man’s influence on climate change. He waged a campaign completely and utterly comprised of positions that would sell to his base, with no conviction, or intent, to carry through on those positions. Clinton is now close to 2 million votes ahead on the popular vote, and the poor hapless idiots that voted for this shyster are finding out what they voted for, and what they got, are two totally different things.
“In light of president -elect Trump’s statements….” On what day, Rod? What moment? On twitter, or……????
What a joke. I NEVER thought I’d see such an embarrassing debacle unfolding in an American presidential election and outcome. This can only get worse.
Out of the four position changes that you’ve mentioned, three seem like Trump is moving closer to the center. Backing off on immediate repeal of Obamacare, deferring on appointing a special prosecutor to go after his former political opponent, and retracting his promise for immediate deportations may all offend some members of his base, but they also may appeal to some who voted for him under the assumption that much of what he said on the campaign trail was designed simply to attract free media attention and the votes of a few people that he would have no problem betraying after the election.
I am concerned about what I read of his closed door session with the network execs and talking heads and his abrupt decision to cancel a previously agreed meeting with reporters from the New York Times. Watching, waiting and criticizing as loudly as necessary is a worthwhile approach.
I’ll refrain from, and discourage, divisive name calling from both right and left.
The point, Rod, is not what promises were LIES, the point is the lying itself. At this point, its obvious that those that voted for him, as well as those thay didn’t, have absolutely no idea what exactly this con man intends to do. It pains me seeing our media fail to hold this man to account. Meanwhile, white supremists celebrate him with sieg heil salutes, while he tweets immature and ridiculous insults at a broadway cast. You can sugaf coat it if you want, but these are not simple “retractions” of campsign promises. It is nothing less than abandonment of the very positions that earned him the majority of the electoral vote. He is a fraud, and there simply cannot be any reasonable denial of that FACT.
We need to stop the presses! A politician’s campaign promises are turning out to be audience flattering, special interest-pandering, contribution-seeking, media attention-getting vapor. How will democracy survive?
Rod, comparing Trump’s campaign tactics, and conflicts of interest, to preceding electoral tactics and conflicts is disingenuous, and naive.
With regard to conflicts of interest, I’d say that Nelson Rockefeller’s were at least as extensive and as varied as Trump’s. Of course, he only served as VP and was only rumored to be a presidential candidate.
Tactics used this year were certainly unprecedented; I’m pretty sure that Twitter storms have never been used to send the media off topic before.
“the assumption that much of what he said on the campaign trail was designed simply to attract free media attention and the votes of a few people that he would have no problem betraying after the election.”
– of course, and hurray !!!!, someone finally gets it. If you looked closely at previous positions and in depth statements there was not much cause to believe the heavily publicized “positions”. Nothing hes done since being elected has been a “reversal” much less even a slight surprise.
“Blahblah…Trump as the closet leftist, betrayer and compromiser…blahblah…”
I never said that. I said he decieved you, and there is no telling what he will do. It has come to the point where you need to fabricate strawmen arguments in order to sputter forth with rebuttals. And you still can’t lose the right versus left nonsense. If you had a brain, you’d be thinking right and left versus we, the people. But you are too partisanly deranged to even see it. You still think the side of the aisle claimed by these criminals determines their loyalties, and demands your subservience and support. Its ridiculous. Blinded by partisan ignorance, you will cheer foolishly while the rug is pulled out from under you. It really quite pathetic, John.
Concerning the impacts on the industry from a relaxation of public radiation dose standards:
Higher allowable post-decommissioning radiation levels could significantly reduce plant decommissioning costs, but those costs only amount to a fraction of a cent/kW-hr. Same story with more reasonable dose limits for a repository (0.1-0.2 cents/kW-hr is already enough). I also don’t see that significant a cost savings for LLW waste disposal (in terms of overall nuclear power cost).
More reasonable allowable public doses would also significantly reduce the costs of land cleanup after a meltdown (as well as reducing decommissioning costs for the melted reactors). But those meltdown events are extremely rare, so the overall cost of meltdowns is already low. My back-of-the-envelope estimates of the “accident cost” is on the order of 0.1 cents/kW-hr (based on Fukushima’s total eventual cost of ~$100 billion, divided by the ~100 trillion kW-hrs nuclear has generated over the last several decades).
It is clear to me that most of nuclear’s large (and escalating) cost is due to what can generally be thought of as meltdown prevention activities. This includes everything from overly-strict regulations and procedures, excessively strict component fab QA requirements (NQA-1), all the expensive safety systems that are required, the new expensive security requirements, and paying for all those expensive NRC staff hours.
I’ve often asked the following question concerning efforts to get rid of LNT and promulgate more reasonable dose limits: Does that mean that the NRC will then consider meltdowns to be OK? Or will they continue to insist that everything be done (and no cost spared) to prevent them. After all, the notion that meltdowns must be prevented is not directly tied to strict public dose limits (or vice versa).
We need to MAKE that tie. Promulgating a higher dose standard will not be enough. The industry would need to make full use of it, i.e., pick up that ball and run with it. The new dose standard would be just the beginning.
The industry would need to insist that all the costly measures currently required to reduce/eliminate meltdown probabilities be justified by cost-benefit analyses, that make use of detailed PRA analyses. And yes, if those analyses were done, more reasonable public dose limits, and/or estimates of health impacts from various radiation levels, would definitely affect those analyses and their conclusions. As one example, it would be all that much harder to argue that an SMR (with its much smaller potential source term), it capable of causing any public harm under any circumstances.
I’m all for more reasonable dose standards, but that alone will not be enough to significantly reduce nuclear’s costs. We need to take it further, and attack the notion that any release of radioactivity from a nuclear plant (i.e., a meltdown) is the “ultimate disaster” and must be prevented at all costs. It is certainly true (at a minimum) that for advanced reactor technologies (e.g., SMRs), we should not put the improved technology towards even more orders of magnitude of safety (e.g., meltdown frequency) but instead put those benefits towards reducing costs (while maintaining meltdown frequencies of current plants).
You have correctly fleshed out the actions that are needed in parallel with the establishment of dose standards that are based providing an adequate safety margin so that we avoid doses and dose rates that scientific evidence says are harmful to health of people or the environment.
My opinion is that part of that very public and inevitably contentious effort will require full exposure of the motivated effort that purposely created the “no safe dose” boogeyman that could never be actually photographed or detected.
The industry and the government sponsors in the old AEC never understood the importance of determining the levels at which actual harm occurred. Their engineers told them they could build systems that really did reduce doses down to the barely detectable levels. System designers went along with the regulatory notion that limits could be a “stretch goal” that required attention and continual design improvements because that is how they were wired to think. The businessmen at the top often went along because tighter regulations could be justification for more spending, which generally led to higher short-term profits in the rate regulated utility environment.
Competitive suppliers kept driving ever tightening limits because they understood the end game of forcing nuclear costs as high as possible so that they could no longer claim that their technology was a lower cost replacement.
I believe that the best way to tear down the artificial barrier is to use the communication tools now at our disposal to to tell the story and demand changes. Hydrocarbon interests control a vast pool of resources, but I don’t believe they will engage in a head-on battle. They learned a long time ago that the public isn’t terribly interested in defending the interests of big companies and banks from threats to their profits posed by new technologies.
I couldn’t agree more with everything you said in your 3rd paragraph. I’ve come to believe that many people working within the industry have been nuclear’s worst enemy, perhaps even more so than the (external) anti-nukes. From engineers who love the challenge of approaching perfection (e.g., trying to meet extremely low dose limits, even though it is completely unnecessary), to businessmen who see onerous requirements as an opportunity to make more money.
I also loved the line about the “..boogeyman that could never be actually photographed…”
Have you seen this depressing news story (which relates to this problem)?:
The EPA head quaking in her boots, trying to explain to the public why dose limits of 2 Rem/yr for the first year and 500 mrem/yr for subsequent years, that only apply in radiological emergencies, is OK. This, despite the fact that nuclear workers are allowed to get 2 Rem every year (w/o any discernible health effect), and 500 mrem/yr is within the range of natural background. And both being far lower than the level at which any health impacts are seen.
But the news reporters don’t choose to provide these helpful, pertinent explanation, but instead focus on how the old limits were hundreds to thousands of times lower. And yes, of course, that will lead to public alarm. They got ~67,000 public comments against the proposal, and only 6 in support. (We nuclear supporters really dropped the ball on this one.)
The real story here, of course, and the depressing part of the story as far as I’m concerned, is that the original limits were that absurdly low. What in the name of God were they thinking when they established them? Who were those people? That’s the real disturbing part of that story. It all says more about the old limits than the new ones. What a profound disservice to humanity.
BTW, I have one other theory about why the industry agreed to such absurd requirements. Yes, they thought it would actually make them more money. But another part of it is that they thought that they could get away with it. That is, they thought that nuclear could survive that high cost structure. The reason is that, in earlier decades, many people actually thought that fossil fuels were running out. Also, renewables didn’t seem to have much potential. Thus, many thought that nuclear was inevitable (i.e., that it wouldn’t have any real competitors in the future).
Well, it turns out that both fossil fuels and renewables are, and will be, capable competitors to nuclear. Now, all the sudden faced with the need to be competitive, and unable to afford the high cost structure that it signed up for, nuclear is in an awkward position. They basically have to try and tell the public that those extreme standards were never necessary. In other words, that they lied. It will be an extremely tough sell.
“Well, it turns out that both fossil fuels and renewables are, and will be, capable competitors to nuclear.”
In following your comments, I’ve been impressed with your moderate approach, which seems to understand the factors that have shaped opinions against NE, rather than just disgarding those opinions as unfounded. Whether these opposing opinions are on firm footing or not, they have been formed in no small part by the actions, and inactions, of the industry. You seem to understand that dynamic far more than many here. The misinformed aren’t your enemy, they are your potential allies, if only the industry can find a way to inform them. I have hopes for Korsnick in this regard. I think she “gets it”.
What interests me about the part of your comment I quoted, is your consideration of renewables as being a “capable competitor”. I’m curious if you can expand on why you think renewables are a “capable competitor”. Such a comment is extremely rare on this website.
The main reason is the significant drop in per kW-hr price. Look at the latest levelized cost projections from the EIA (which is a very conservative govt. organization):
The figures show that the raw, per kW-hr price for both wind and solar are now significantly lower than nuclear, even before the federal subsidy.
Yes, those figures are just the raw price of wind and solar kW-hrs, produced both where and when those sources happen to produce them, (i.e., produced at ideal sites, remote and far from demand centers, and only when the sun is shining or wind is blowing). Sites closer to most of our demand centers (i.e., in the Northeast or Southeast, as opposed to the windy Great Plains or sunny southwestern deserts) would have a significantly higher per kW-hr cost. Alternatively, very long distance transmission would add significantly to the cost. And then there are intermittency limitations, of course, which will prevent them from providing most of our power and will require fossil backup, etc..
But still. that means that in many sections of the country, renewables will actually make sense for providing a significant fraction of power, on raw economics alone. And their costs may fall further. They have reached the point where they are clearly not a “joke”, and are a competitor to be taken seriously. Especially given that, in those sections of the country, their presence may harm the economics of nuclear plants.
It must be added that (although it seems unfair), having a high degree of popularity and political support is a genuine, tangible factor that make them a more formidable competitor. Frustrating as it is, the large amount of subsidies and other market interventions on renewables behalf (most notably state Renewable Portfolio Standards) do not appear to be going anywhere, for the foreseeable future. Renewables appear to be showing that, with the amount of support/intervention that they are (politically) capable of getting, they can “beat” nuclear. Perhaps even existing nuclear, let alone new.
With the low price of natural gas (which doesn’t appear to be going anywhere), the low/falling cost of renewables, and the high degree of political support that renewables have, the gas/renewables mix alternative is currently a compelling competitor to the nuclear-heavy approach (e.g., France). And yes, a mix of gas and renewables is a viable option for providing ALL of our electricity.
And sadly, that alternative is not merely a viable competitor to nuclear. It is (currently) soundly defeating nuclear. Yes, it’s due to unfair, unlevel, policy and regulatory playing fields, but that’s what’s occurring, and it’s due to the far greater amount of political support that those sources enjoy.
All that said, there is some reason for hope. With respect to the policy playing field, precedent was set in New York, and it may repeat itself in Illinois. The notion that nuclear (both new and existing) deserves some tangible financial support for its non-emitting nature is finally getting some traction.
I personally feel that fair policy is not enough, and that a fair regulatory playing filed (that would allow reduced nuclear costs) is also necessary. No real progress so far on that front. Could Trump offer an opportunity there? Personally, I’m not that optimistic (as he’s pro-fossil, not nuclear), but anything is possible.
Thanks, Jim. In addition, I think it must be noted that the political standing, as well as John Q’s impression of renewables is based in no small part on prodfessional, and successful, marketing. Part of that marketing, of course, has been taking advantage of the climate change narrative. On this website, often, some nuclear advocates argue against the theory of human induced climate change and global warming. Regardless of the veracity of their argument, it amazes me they can’t see how very self defeating it is. Minimizing the reasoning and need for a policy of clean energy production ain’t a very smart way to try and sell it.
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