Don’t allow EPA to use “modernize” as euphemism for “tighten”
On February 3, 2014, The Hill Ballot Box blog published a call to action for nuclear energy and medical radiation therapy professionals titled EPA seeks to modernize nuclear standards.
The EPA says it has not changed its radiation protection standards since the 1970s. Radiation health researchers would probably agree that there is a need to evaluate existing standards and bring them in line with our current scientific understanding of how radiation affects human health.
However, it should be quite obvious that the people who have identified the fact that the standards have been in effect since Jimmy Carter was president do not plan on applying modern science to the effort and instead plant on simply ratcheting down the limits to make them “new and improved.”
Note: The Hill Blog mentions Richard Nixon as being the president when the standards were developed and Ford as the president when they were issued, but also states that the standards were issued in 1977. Carter was elected in 1976 and inaugurated in early 1977. End Note.
To put it in perspective, the rules have not been updated since before the high-profile nuclear meltdowns in Three Mile Island, Pennsylvania; Chernobyl, Ukraine; or Fukushima, Japan.
“These standards were the earliest radiation rules developed by the EPA and are based on nuclear power technology and the understanding of radiation biology current at that time,” the agency said in the Federal Register.
“These standards have not been revised since their initial publication,” it added.
You can find the advance notice of proposed rulemaking at EPA–HQ–OAR–2013–0689; FRL–9902-20-OAR: RIN 2060–AR12: Environmental Radiation Protection Standards for Nuclear Power Operations . The deadline for public comments will be 120 days after official publication of the proposed standards. Page 2 of the notice of proposed rulemaking provides several options for submitting comments.
The notice points to several “fact” sheets published at Environmental Standards for Uranium Fuel Cycle Facilities: Advance Notice of Proposed Rulemaking (ANPR) including:
- Advance Notice of Proposed Rulemaking
- What is the Uranium Fuel Cycle?
- EPA Radiation Protection Standards
Aside: That last one reminds me of a strange disconnect in our regulatory structure. In the first paragraph, it says “EPA does not regulate naturally occurring radiation …” but it does regulate radiation from uranium mill wastes. The radioactive material left over from uranium mining is exactly as “naturally occurring” as the radioactive material left over from coal, oil and natural gas extraction processes. Nothing in the the mining process adds isotopes that were not already in the rocks before they were mined. End Aside.
This is a wonderful opportunity to set a new direction and to set standards based on measured science instead of 70-year-old assumptions established based on a dishonest interpretation of fruit fly studies.
However, if knowledgable professionals remain silent, people with well-established and well-funded agendas will waltz into the meetings and make policies that will be exceedingly expensive and will most likely harm future human prosperity.
The EPA has new leadership. Obama understands that the actual ridiculous radiation standards could lead to civil unrest in the US.
James Conca has written a fantastic article on this and made a great parallel between the Jspanese obedient culture in face of stupid evacuation notices and US citizens with land ownership and the second amendment.
The standards will be improved. Steps have already been done towards that.
“The EPA has new leadership. Obama understands that the actual ridiculous radiation standards could lead to civil unrest in the US.”
I wish that statement were true. However, Obama has proven himself an enemy of nuclear energy. And I do sincerely hope and pray civil unrest will NOT occur, but if it does, it will be for reasons other than overly restrictive radiation standards.
Kyrie Eleison, Christe Eleison, Kyrie Eleison. Domine Deus, miserere nobis et totius mundi.
And this exercise should be supported with international guidelines.
Wake up WNA IAEA etc.
Here’s the limit, 0.25 mSv/year. “radon…excepted”?
§ 190.10 Standards for normal operations.
Operations covered by this subpart shall be conducted in such a manner as to provide reasonable assurance that:
(a) The annual dose equivalent does not exceed 25 millirems to the whole body, 75 millirems to the thyroid, and 25 millirems to any other organ of any member of the public as the result of exposures to planned discharges of radioactive materials, radon and its daughters excepted, to the general environment from uranium fuel cycle operations and to radiation from these operations.
(b) The total quantity of radioactive materials entering the general environment from the entire uranium fuel cycle, per gigawatt-year of electrical energy produced by the fuel cycle, contains less than 50,000 curies of krypton-85, 5 millicuries of iodine-129, and 0.5 millicuries combined of plutonium-239 and other alpha-emitting transuranic radionuclides with half-lives greater than one year.
And here’s the waste disposal limit [for Yucca], 0.15 mSv/year.
§ 191.15 Individual protection requirements.
(a) Disposal systems for waste and any associated radioactive material shall be designed to provide a reasonable expectation that, for 10,000 years after disposal, undisturbed performance of the disposal system shall not cause the annual committed effective dose, received through all potential pathways from the disposal system, to any member of the public in the accessible environment, to exceed 15 millirems (150 microsieverts).
I trust Gina McCarthy. She has a good reputation.
Wow Robert, these numbers are about 1-2 orders of magnitude below what people can receive from the natural environment, which are in turn 1-2 orders of magnitude smaller than what some claim is still below a reasonably safe harm threshold (100mSv/month).
So, these standards are at about 1000 times smaller than what could be remotely considered truly harmful, i.e. a measurable increase in risk of cancer. In what world does this makes sense?
The only purpose this can serve is to take nuclear energy “off the table” by setting in place standards that make the entire enterprise as difficult and expense as possible. When one looks at the environmental and human consequences of taking safe, cheap, emissions-free energy “off the table”, this is an outrageous situation that must be fought!
The world of regulation, of course.
Future look out – here we come! Weeeeeeeeeeeeeeeeeeeee! ( http://depletedcranium.com/wp-content/uploads/elfbikecar.jpg )
In a world where you want to do energy to expensive for the working class.
Steve: Before leaping to conclusions, please at least read The Hill article that Rod linked:
As stated, such intent appears both necessary and neutral. Rod is only asking we help ensure it remain that way. Whether repository requirements themselves can ever be rationalized remains to be seen. But one might suggest a vocal “us vs them” attitude won’t get us there. Thanks!
We need a new form of Insurance product for any form of radiological releases.
Maybe it’s time for some portion of the nuclear Industry to take ahold of this and make some dough in the process.
Perhaps Westinghouse could work with the insurance industry to offer a product that would ensure against 100mSv/month at a business portal (front door) or basement floor, payable for any reason for a non-preexisting condition: New Radon release, Neighbor pees I-129 because of a thyroid treatment, Meltdown, Dirty Bomb…. It wouldn’t be advisable to document any sort of radius around Nuclear Plants to offer such an insurance product, It would have to be offered nationwide.
If they don’t pin it down, then the regulatory standards will float based upon what is best for those who benefit from an excessively expensive regulatory environment.
“However, if knowledgable professionals remain silent, people with well-established and well-funded agendas will waltz into the meetings and make policies that will be exceedingly expensive and will most likely harm future human prosperity.”
Sorry Rod, this is already how our broken system works. The “waltz ins” you refer to are more commonly called lobbyists, and most likely are the same people who wrote the proposed rule in the first place. Once it gets this far it is cast in concrete. Here’s a case in point, my comment to NRC on the Post Fukushima Task Force “proposed rule making” about pre-staging all the emergency power supplies on US sites (edited to remove my email address).
ANPR 50 (77FR16175) 15 Rulemaking Comments
Wednesday, April 11, 2012 2:45 PM
April 11, 2012 (3:10 pm)
Subject: Comments on DocKet IU NRU-2U11-U02V. OFFICE OF SECRETARY
RULEMAKINGS AND ADJUDICATIONS STAFF
The “90 Day Task Force” report specifically identified two cases of beyond Design Basis
Accident (DBA) events associated with the Fukushima Daiichi accident. They were the
earthquake and the tsunami. A third beyond DBA event also occurred, and although “skirted around” in the report content discussion, it was never specifically identified as such.
It specifically is that on a multi-unit site when one unit has a severe core damage accident,
every other unit on that site is now beyond its Design Basis. The published timelines state
the obvious difficulties this caused for units 2-4 at Fukushima, once Unit 1 suffered severe
core damage. Examples are restoring temporary AC power sources, hooking up temporary fire system core cooling capability, and restoring spent fuel pool cooling.
The General Design Criteria are the basis for my statement. It is not even arguable. A single unit on a multi-unit site is designed, radiation protection wise, to get itself to cold
shutdown (CSD) following a core damage accident. The unit next door is not designed to get to CSD following its own core damage accident, concurrent with one next door.
You can modify this rule, and several other specific rules, and require pre-staged AC power sources etc. ad nauseum, but if nothing can be done on Unit Two, for example, because of a severe core damage accident on Unit One, you have added nothing to the layers of safety. And that is exactly what Fukushima was faced with.
Please specifically identify this third beyond DBA event in the documents associated with the post Fukumisha action plans, and also include specific corrective action steps to address it.
Very Truly Yours
SRO License 2869 (Retired)
My point is, I’m right, but they did it anyway, and obviously didn’t add the third “beyond design basis” condition to the report. And they won’t. But everyone has to spend the $ to pre-stage the equipment. But on a multi-unit site they will still have the same problems for the exact reasons I stated. And I also am not so naive as to believe NRC did not realize what I said was true. Even this “public comment” system is broken. My comment (or yours) is added to the Docket, but never acknowledged, answered, responded to, etc. etc. You are merely being placated.
I’m not saying don’t comment, because it does buy you something. If you ever want to make a court challenge once the new rule is law, and you didn’t comment on the proposed rule, you have no “standing” to challenge”.
Our regulatory process is broken. mjd.
I think here the EPA needs to be reminded of the categorical failure they have been in protecting the public and the environment from fossil fuel pollutants. Sure they have made headway against the most overt offenders, but still the transgressions of that industry as a whole are several orders of magnitude worse than the worst examples in the entire history of radiation related incidents.
Being especially encouraging of opinion and dismissive of science, overly strict, even ridiculous on radiation standards is not going to make up for backing down and dropping the ball elsewhere. And thats what this is really probably about.
Indeed the NRC, and now the EPA, suffer from the same regulatory failure, i.e., minimizing a specific hazard without regard to the resulting overall hazards. In this case, we have an attempt to reduce a minimal (or more likely, non-existent) hazard from radiation. The resulting regulatory burden causes power utility companies to build fossil-fueled generating plants instead instead of much safer nuclear power plants — nuclear power plants that are already much safer than the fossil fuel power plants even with old existing rules.
In these “new and improved” proposed rules I detect more than a hint of what has been called chronological snobbery. This is the attitude that in this day we must surely know better than those who worked in the field 40 years ago. While this often may well be true, what is really known much better in this case is political correctness and bowing to pressure groups.
Excellent post …
“minimizing a specific hazard without regard to the resulting overall hazards”
This is also what is happening with medical products in EU: EU recently removed a widely used, mostly safe painkiller (no efficient painkiller is without side effect and risks), mostly because it was used for suicides in a single country. All Europe has to treat pain without a useful, cheap, well known, extremely rarely abused substance because of a tradition of suicide in a small country.
It is crazy. It is beyond crazy. The regulators are mad. Or, maybe, this substance was old and cheap, and old and cheap and safe (or at least well understood) old treatments must be replaced with new, expensive, and badly known substances.
Almost nobody here in France wanted to ban this substance, and many health professionals say it will be a problem. Stronger painkillers will be used.
This craziness has been forced on French regulators by EU regulator. As if the French health agencies weren’t sufficiently inane!
The EPA has a recent history of ignoring scinece and favoring the fossil fuel industry. I think they will try to appear “firm” here even if it is based in no real or proven safety considerations.
EPA halted ‘fracking’ case after gas company protested
a confidential report obtained by the Associated Press and interviews with company representatives show that the EPA had scientific evidence against the driller, Range Resources, but changed course after the company threatened not to cooperate with a national study into a common form of drilling called hydraulic fracturing. Regulators set aside an analysis that concluded the drilling could have been to blame for the contamination. ( http://www.usatoday.com/story/news/nation/2013/01/16/epa-gas-company-protested/1839857/ )
BTW Rod Moniz seems to think there is plenty of Gas.
U.S. Energy Secretary Plans To Review New England’s Natural Gas Shortage
There is an ample supply of natural gas because of new drilling techniques, like hydraulic fracturing or fracking, but it has become costly to transport it into New England. Pipelines into the region are packed, as cold weather raises demand for heating and the region’s power plants have increased their reliance on the fuel in recent years. ( http://www.courant.com/business/hc-murphy-natural-gas-20140130,0,890005.story )
Mind you I realize we need the NG and probably the fracking too. But Fracking NGs and Oil’s has waste issues :
Class II wells in operation in the United States inject over 2 billion gallons of brine every day. Most oil and gas injection wells are in Texas, California, Oklahoma, and Kansas. ( http://water.epa.gov/type/groundwater/uic/class2/index.cfm )
Its not just “Brine” but a mixed bag of hydrocarbons and elemental contaminants as well and although it bing mildly radioactive has been hyped in the press that is probably, from a health perspective , the very least worrisome thing about it. There is at least one reported case of an aquifer being contaminated with this liquid in Texas.
Despite all the propaganda stating otherwise these types of wells ARE sometimes related to increased seismic activity and it have been known to be for over half a century.
I am not sure how this really affects operating nuclear power plants. That is supposedly controlled by 10 CFR and the NRC. I have a strong feeling that this is a backdoor (like a backdoor into a computer to hack it) approach to KILL Yucca Mt. The spent fuel pool is controlled by their 10 CFR part 50 license and the onsite storage is controlled by their, separate,10 CFR part 72(?) license. Both of these are issued and administered by the NRC.
I do remember that the EPA got their hand in our pants by forcing us to burn “low sulfur” diesel fuel in the emergency diesels and diesel fire pump. I forget as to weather we lost the fight or gave up as it was cheaper to bend over that fight it.
Why all of the stink over an area that was the site, or at least within a few miles of the earliest site and many years of nuclear bomb testing? This is like locking the gate to a prison after the riot and it was burned to the ground. The radiation is in the ground already, sure you may be able to tell the difference between the radiation from a leaking storage canister and that of the bomb spoils as it infiltrates any water that you detect it in but as a famous SOS said “At this point what difference does it make?”
Or perhaps they will lighten the dose limit on fuel disposal sites, now that yucca mountain has spent it’s exorbitant money. Makes you wonder WHY the EPA didn’t entertain the use of a more rational dose limit when yucca was being studied…. They could have done it then. Why wait will yucca was essential dead to finally start allowing some common sense?
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