Jim Hopf recently published a thought provoking post on ANS Nuclear Cafe titled New EPA Guidelines for Response to Radioactivity Releases. In that post he points out the illogical way that the EPA applies and enforces its assumption that any ionizing radiation is hazardous, even down at levels far below natural background.
Jim points out that under current rules, nuclear power plant operators, former weapons manufacturing sites, and used fuel repositories are required to continue clean-up efforts until models show that the most exposed person will receive a dose rate of somewhere between 10 and 25 mrem per year.
Aside: As a point of reference, the average American is exposed to about 300 mrem per year, but those doses vary over a wide range to the point where the most exposed may get 1000 mrem/yr. Around the world, there are places like Ramsar, Iran where the most exposed can receive 26,000 mrem/yr (260 mSv/yr). “Cytogenetic studies show no significant differences between people in the high background compared to people in normal background areas.” End Aside.
Depending on the isotopes involved, 10 to 25 mrem/year is the dose rate at which the EPA’s application of the linear, no-threshold dose response assumption leads to a calculation of between a one in ten thousand and a one in a million chance of early mortality as a result of exposure to radiation for a person that stays in the area for a lifetime. (The EPA’s LNT model assumes that a dose of 1750 mrem accumulated over 70 years of chronic exposure has the same health effect as a dose of 1750 mrem accumulated in a few seconds as a result of an atomic bomb explosion.)
The illogical part of the way that the EPA applies its model in the form of enforced regulation is that no other source of radiation is held to that standard, even though there is no disagreement among scientists and medical doctors that specialize in radiation about the fact that human physiology cannot distinguish between “natural” and “man-made” doses of ionizing radiation. Radiation health effects are determined by the type of radiation and the energy level, not by whether it originated from naturally occurring radium, radon, potassium, uranium, thorium, or cosmic radiation or whether it came from strontium, technetium, cesium, iodine, uranium or plutonium that spent some time inside a reactor.
Jim does not challenge the LNT; he challenges the fact that it is applied differently to exactly the same kinds of radiation based on the source of the radiation. He also points out the enormous cost (which is revenue to some people) associated with attempting to clean up areas to levels that are 1/30th to 1/12th the average level of background radiation. Simply measuring that level of contamination requires expensive equipment and skilled technicians.
In the comment thread, Jim and I have been having a friendly exchange of strongly held views. I decided to capture and repurpose the most recent part of that exchange to see if it would encourage more discussion here. Of course, I highly encourage you to participate in the ANS Nuclear Cafe comment thread as well.
In response to a comment in which I took Jim to task for not challenging the LNT, Jim wrote the following:
I never said that I believe in LNT. I basically don’t. I believe that there is most likely a threshold around the top of the typical natural range (i.e., ~1 Rem/yr), below which there are no health impacts. I also believe that if any impacts were present, they’d be miniscule, and far too small to measure. In a world filled with real, tangible, much larger risks, things that are too small to measure are too small to matter, in my view.
My point was simply that these policies are clearly indefensible and hyprocritcal even if one does assume LNT. I think that is a point worth making. I’m not sure we want to tie any progress against these ridiculous requirements to convincing the scientific/bueaucratic bodies that be (e.g., ICRP) to admit they were wrong all along and to drop LNT. That may take awhile. In fact, there is a good chance we won’t succeed, frankly.
I think that arguments like these (i.e., pointing out clear and blatant hypocrisy) are our best chance of getting things to change (e.g., getting them to relax the requirements for long-term cleanup after a severe accident). I doubt the organizations in question will listen to dose threshold (no-LNT) or hormesis arguments.
Though I like Jim a lot and think that he is generally on the right track with many of his ideas, I responded rather emotionally to his acceptance.
I am getting too old to be accommodating to people who are just plain wrong. I don’t really care if I offend them or shake their core beliefs.
Since some of those people are in positions of appointed or elected power, my mission is not an easy one. The nice thing is that I am an American, living in a country where defiance of just plain wrong policy, even when supported by the most “powerful” people in the land, is a long and valued tradition.
The most valuable “asset” in America in 1845 was the several million people held in bondage enforced by the laws of about half of the states and allowed by “the law of the land”. That did not stop people from challenging the law and telling the powerful that they were wrong.
Your guess about where the threshold might be is still a couple of orders of magnitude too low. Jerry Cuttler, Wade Allison, Myron Pollycove, Ed Calabrese, and others have done the hard work in discovering that a chronic dose rate of about 100 Rem (1000 mSv) per year does not raise cancer rates by a measurable amount. At a range of levels below that, there is a 20-40% health benefit.
Since that is true, the real impact is enormous. The powerful will resist because letting that truth out will shake the foundations of a large portion of today’s fortunes that are built on various aspects of the world’s largest enterprise – that of finding, extracting, transporting, refining, and consuming hydrocarbons from reservoirs often located in other people’s countries.
If we treat radiation with respect and recognize where it really is dangerous and where it is not, we would be able to drive the cost of building nuclear fission power systems to be roughly the same as the cost of building hydrocarbon based heat engines, but the effort required to fuel those machines and dispose of the waste products would be several orders of magnitude easier (less costly) because of the energy density and cleanliness of the process.
Keeping that technology out of the reach of billions of people is far worse than slavery because it concentrates even more wealth at the top and forces so many others to either do without power or to pay a substantial fraction of their income in tribute to the people who control access to hydrocarbons.
Here’s my bottom line – if anyone told me, my family, my friends or my neighbors that we had to leave our homes because they were contaminated with radioactive material, I would defy the order and work hard to encourage others to do so as long as a reasonably accurate estimate of the dose rate was less than 10 REM (100 mSv) per month. That is so extraordinarily unlikely that I would call it impossible; the max dose rate to the public from any conceivable event spreading contamination over a large area would be far lower than that.
Publisher, Atomic Insights
Like so many other illogical rules associated with nuclear energy and radiation, I sincerely believe that the basic purpose is to restrict the market competitiveness of a remarkable fuel product. Uranium and thorium contain 2 million times as much energy per unit mass as crude oil; since they are both more dense, the comparison on a per unit volume basis is even more impressive.
I once calculated that a car that gets 20 miles per gallon of gasoline could operate for 760 MILLION miles on a gallon of uranium. Of course, it is impossible to develop a functional fission reactor that can drive a standard car, but nuclear powered ships have been getting an equivalent fuel economy advantage since January 17, 1955. That is the date that the USS Nautilus reported that it was “underway on nuclear power” for the first time.
The ONLY way that hydrocarbons can retain their current market share against that kind of natural advantage is by artificially restricting the use of uranium or thorium by spreading fear, uncertainty and doubt about as many aspects of the competition as they can invent. They will use and support any group that works against the use of nuclear energy on the philosophy that “the enemy of my enemy is my friend”. This effort has no need to be a wide ranging conspiracy; it is simply business. It only needs a few people who really understand the financial consequences to make sure that the opposition to nuclear energy is well-funded and well-supported politically.
It is time to break a few chairs to make the point that it is simply wrong to keep so much power out of the hands of so many people.
Forbes – (April 24, 2013) Fracking Truck Sets Off Radiation Alarm At Landfill