Among one group of friends, we comfort ourselves with the following mantra, “When you’re taking flak, you’re right over the target.”
Aside: Several members of the group are old enough to have fathers who flew in WWII when the phrase was common among bomber pilots. End Aside.
I thought about that reassuring thought when I stumbled across a Nuclear Information and Resource Service (NIRS) web page headlined Tell NRC to reject efforts by pro-nuke fanatics to weaken radiation standards. The page is referring to a request for comment on a petition for rulemaking that has been mentioned on Atomic Insights several times recently.
That petition asks the NRC to eliminate the “no safe dose” assertion — also known as the linear, no-threshold (LNT) dose model — as the basis for radiation regulations because that assumption is not conservative. Experience has proven that it harms people instead of protecting them.
The harm comes from at least two separate impacts of the model.
The “no safe dose” model asserts to the public that every dose of radiation, no matter how small or controlled, poses a health risk. Some people take the advice to the extreme of refusing effective medical treatments or necessary diagnostic procedures because they are afraid of the potential side effects.
From another direction, accepting and promoting the “no safe dose” assertion causes long-lasting psychological harm to people who have been exposed to doses of radiation so small there there is no evidence, even after a hundreds years of searching for it, that proves that the dose produces any measurable harm to anyone.
Because of the way that the “no safe dose” assertion is described as potential genetic damage that might harm children that have not even been conceived several generations in the future, people who have been exposed can legitimately feel like they have been permanently damaged with no hope of repair or recovery. They can fall into a state of despair due to feeling like there is an invisible sword hanging over their heads.
Even worse, exposed people — like the Japanese hibakusha — have been shunned or isolated from society because of the unsubstantiated belief that they carry damaged genes that make them poor parental prospects.
Here is how NIRS describes the people who submitted the petitions.
In February, a group of pro-nuclear fanatics—there is really no other way to describe them—submitted three petitions for rulemaking to the Nuclear Regulatory Commission (NRC).
Now, some people might be offended by being called a “pro-nuclear fanatic,” but in my case it is just as accurate as calling me a Naval Academy football fanatic or a Miami Dolphins fan. I’ve even toyed with the idea of creating a Fission Fan Club, so I take no offense at the label and instead wear it with pride.
Disclosure: There are three separate petitions all asking for similar actions. I signed one of the petitions as a member of Scientists for Accurate Radiation Information (SARI), so I am included as a target for NIRS name calling.
The NIRS page includes several other statements worth a response.
The concept of ALARA (a requirement that nuclear operators reduce exposures “as low as reasonably achievable”) would be tossed out the window.
I sure hope so. It is a ridiculous standard that can never be achieved. With a constantly lowered bar, more and more money is spent for less and less return. Think of a limbo contest where the bar is already low enough so that only cockroaches can fit underneath it.
Emergency Planning Zones would be significantly reduced or abolished entirely.
That would be a fantastic result. Nuclear reactor accidents progress more slowly than other industrial accidents. They can move more slowly than hurricanes and have less potential for creating conditions that would require moving people to protect them from harm.
Evacuation is not an effective public health response in the event of an accident at a nuclear plant that has a US operating license. Those plants employ sufficient layers of physical protection and they must regularly prove that those layers are functional.
Instead of being forced to spend money to limit radiation releases, nuclear utilities could pocket greater profits.
It might be too much to expect of a typical activist group, but it would be nice if people who plan to protest would do a small amount of current research. NIRS should realize that market conditions have resulted in many US nuclear plants producing so little revenue that their owners are considering permanently shutting them down. That condition is caused by a temporary oversupply of electrical generating capability, which, in some markets, has lowered prices below the level that enables steady profits.
Lowering costs for nuclear plants would reduce the pressure to provide increased revenues through set asides or subsidies and would enable those ultra-reliable — the US fleet has achieved >97% capacity factor during the past 2 months — ultra-low emission generating plants to continue operating for a few more decades.
The final line of the NIRS page deserves a to be quoted since it is a call for action that I fully support.
The comment deadline is September 8, 2015, so please share widely now. Thank you.
Update: The Federal Register published a notice on August 21, 2015 extending the comment period by 60 days. End Update.
Based on the flak from the NIRS PR machine, pro-nuclear fans must be right over the target in our effort to encourage our government to revise its regulations.
We are asking for rules that are based on modern science, instead of stubbornly adhering to a 60-year old model that was initially suggested and promoted by a small, deceptive, politically and economically motivated committee supported by identifiable merchants of doubt.