1. Good work. I think that you omitted the word ‘no’ before the word ‘data’ in your aside, above.

    1. Bump. That sentence doesn’t make much sense unless you meant “still no data”.

  2. The EPA should take follow the conclusions of the ICRP regarding collective dose:
    “The aggregation of very low individual doses over extended time periods is inappropriate, and in particular, the calculation of the number of cancer deaths based on collective effective doses from trivial individual doses should be avoided.” (ICRP Publications 103 in the Executive summary)

  3. @ Rod,

    As a lay person I am not sure how to comment on this in a way that will help make standard’s more reasonable. For sure, the statement that

    “For this reason, it is appropriate to sum small doses delivered to large population groups to determine the integrated population dose. The integrated population dose ay then be used to calculate potential health effects to assist in making judgements on the risk resulting from radioactive effluent releases from uranium fuel cycle facilities, and the reasonableness of costs that would be incurred to mitigate this risk.”

    Is exactly opposite of what I understand to be good science in measuring effects. But do I need to support my comments with links or references?

    Frankly, all radiation standards should never fall below the highest normal background radiation found around the world. Regulating below that level is simply a political means of increasing costs.

  4. I like you guys but Im getting past the point where Im beyond disenfranchised and done with this.

    But really here is a incredible opportunity to bring radiation guidelines; with respect to related technological diagnostics and treatments, real, proven clean energy generation, and the entire future of space program (mankind’s ONLY long term, expansive future) into some kind of responsible, science based, cohesive policy.

    But no, I have a feeing its going to be another mealymouthed, petty, fear based, misinformed disaster Rod. Sorry for the pessimism.

    God knows, if anything, I hope to be made to look totally stupid and proved wrong in this.

    1. @ John,

      I understand the feelings but I see the overall argument moving in favor of Nuclear Energy. Most of the people I talk with are in favor of it. Many are willing to be persuaded. I was very discouraged at one point with the politics of an organization. I had a friend tell me that I needed to hang in there because if I quit I lost my chance to have a voice.

      You are only disenfranchised if you stop voting. We have a voice – let’s use it.

      1. In most of the environmental forum’s I visit people dont care/wont discus it or are anti nuclear and will not listen to any reasonable argument. I doubt though I will really give up.

    2. @John T Tucker

      Changing minds and politics may be slow and often frustrating, but it is a task worth pursuing. Besides, it has a far better chance of success than trying to change the laws of physics, chemistry, or meteorology.

  5. What are the radon emissions from burning natural gas? If they are at all comparable to current regulatory limits for nuclear power station emissions, then the environmental double standards should be trumpeted loud and clear.

    1. @turnages

      There are no federal limits on radon emissions from natural gas, but there are also not any federal limits on radon emissions from uranium fuel cycle facilities. There is a fairly lengthy discussion in the Final EIS for 40 CFR 190 about the difficulty of measuring and separating those emissions from the naturally occurring emanations from the earth’s crust.

      As David points out, there really is no logical reason to regulate radiation exposures that are within the variation of natural background and there is no logic in trying to regulate radioactive isotope emissions from nuclear energy to prevent doses that are several orders of magnitude lower than doses from naturally occurring isotopes. Living creatures have no way to distinguish natural from man-made radiation.

      1. Since living creatures have no way to distinguish between natural from man-made radiation and because radiation is accumulative wouldn’t regulating radioactive isotope emissions from nuclear energy make a lot of sense? Has science totally given way to Corporate manipulation?

        1. @michele

          I see it differently. Since living creatures have no way to distinguish between natural and man-made radiation and since we have all evolved on a planet that has always been radioactive, it seems eminently logical to recognize that we have natural defense mechanisms that protect us from significant harm from radiation that is within the normal variations in natural background exposure.

          That implies it is absurd to attempt to limit radiation from beneficial activities like emission free electricity production to levels that are small fractions of the natural variations found around the world. That is not to imply that there should not be some limits; it is a statement that the limited quantity is far too small under current regulations. It can be met with a great deal of cost, but that extra cost provides no additional health benefits compared to a less costly solution that results in moderate releases to be safely dispersed.

          Additionally, the best evidence indicates that radiation doses are not accumulative except in the rare case of a limited number of isotopes that can be absorbed into living tissue and can give continuous doses until they are eliminated. Kr-85 is an inert gas and is not one of those isotopes. Neither is Cs-137; its biological half life is about 60 days.

          There is nothing corporate on this site. I am an independent researcher and writer, not a corporate employee.

  6. Indeed there is no logical reason to regulate radiation exposures, whether from radon or from other radioactive substances, that are within the variation of natural background.

    My point was whether there was any mileage in arguing “you don’t regulate natural gas power stations for radioactive emissions at all, and they routinely emit x Bq per year because of NG radon content, so why should you regulate the heck out of NPPs, and adopt a sinking-lid ALARA policy, when they only emit y Bq per year???

    Assuming y << x here, of course. That's why the NG emissions from radon might be interesting. But then, I guess people get themselves panicky about NG radon too.

    1. @turnages

      Some disagree with me, but I believe focusing attention on the radioactive releases from both natural gas and coal is a losing strategy for nuclear. All it does is to reinforce the excessive fear of radiation and distract from the very real damage and risk factors associated with hydrocarbon extraction, refining, transportation, distribution and consumption.

      Hydrocarbons are wonderful tools, but in many applications they are no longer the “best available” technology.

      1. Interesting side angle – if EPA requires “best available technology” in abating warm water plumes and fish entrapment from power plant cooling water intakes/discharges, why couldn’t it be argued that the Feds also should be mandating “best available technology” in baseload electricity generation itself?

        There are powerful arguments to be made that next-generation nuclear wins that completion hands-down.

        1. “Best available technology?” Who decides? Big Brother is not your friend. Be careful what you pray for.

  7. Correct me if I am wrong……

    Weren’t the “limits” raised subsequent to the Fukushima event? If there is this concerted effort to exaggerate the dangers of radiation exposure by the regulatory agencies, (in the hopes of impeding the use of NE), wouldn’t it have behooved these agencies to have maintained the pre Fukushima limits, and fostered the impression that we all were receiving dangerous exposures?

    1. POA – as far as I know, there were no changes in limits after Fukushima.

      There were some articles about Japan’s government being confused about which limits to apply.

      Agencies and international radiation protection committees have not made it easy for the public to understand. Part of the communication problem is a stubborn insistence by practitioners to keep using the measuring system they were taught during their training.

      I guess they expect the public to adapt to the confusing results instead of the pros making the simple conversions and speaking a consistent language.

      1. ZERO PEOPLE DIED from radiation from Fukushima. One got a sunburn on his ankle. 1600 people have died from the stress of the completely unnecessary evacuation. The fault is with the Japanese law that is 1000 times too strict.

        Chernobyl is not a ghost town. There are still people operating the remaining reactors. The Chernobyl accident killed fewer than 100 people.

  8. Just FYI, radon exposure in the UK from the use of natural gas in homes has been estimated at 4 microsieverts (per year, presumably), in:

    Dixon, D. W. “Radon exposures from the use of natural gas in buildings.” Radiation protection dosimetry 97.3 (2001): 259-264.

    This is about 10 times the amount from the hypothetical 1000 GW of US reactors emitting Krypton-85 to the world population.

  9. One other important question: do US nuclear reactors currently capture Kr-85 in order to be within this regulation? Anyone know?

    1. I believe Kr-85 is generally trapped inside the cladding of intact fuel rods.  It’s only in reprocessing that the gaseous fission products are freed.

      Since it has a half-life of about 11 years, sitting on spent fuel for a couple decades would eliminate the bulk of it.

      1. E-P is right.

        Here is the publicly available 2012 NRC radioactive effluents report for the entire Indian Point site, units 1, 2, and 3 (as an example): http://pbadupws.nrc.gov/docs/ML1315/ML13157A132.pdf

        On page 12, we can see that no Kr-85 was released. The majority of the tiny noble gas (monitored and permitted) releases were in the form of Xe-133.

  10. Thanks for sharing this, Rod. I had read elsewhere that the comment period had already closed but it looks like it has been extended. I made sure to put in my two cents to the EPA!

  11. One important note on commenting on ANPRs, with the caveat that this is my impression based on my watching a few proceed through rule making. Reg experts or lawyers can weigh in if I’m wrong. If you don’t comment at the ANPR point, you have no “standing” to comment/challenge at the regulation point. Is some logic to this; if you didn’t complain when asked for comments, bug off after the reg is final.
    If you think you might have a need to comment on the final reg, better comment on the ANPR. Or your reg comment can be discarded as “no standing to comment or challenge” on the reg. I have seen examples where that was used to not consider reg challenges.

  12. Rod…….

    Are you sure? It was my understanding that Obama signed on, in April, to an EPA proposal to raise limits. And immediately after Fukushima was damaged, I would swear that the limits were raised. Seems to me I remember the anti sites having their panties all bunched up about it.

    1. Short search found…….(have not figured out how to post links with this phone. It is, unfortunately, smarter than I am.)

      Press Clips

      For Immediate Release: Apr 08, 2013


      Civilian Cancer Deaths Expected to Skyrocket Following Radiological Incidents

      Posted on Apr 08, 2013  | Tags: EPA

      Washington, DC — The White House has given final approval for dramatically raising permissible radioactive levels in drinking water and soil following “radiological incidents,” such as nuclear power-plant accidents and dirty bombs. The final version, slated for Federal Register publication as soon as today, is a win for the nuclear industry which seeks what its proponents call a “new normal” for radiation exposure among the U.S population, according Public Employees for Environmental Responsibility (PEER).

      Issued by the Environmental Protection Agency, the radiation guides (called Protective Action Guides or PAGs) allow cleanup many times more lax than anything EPA has ever before accepted. These guides govern evacuations, shelter-in-place orders, food restrictions and other actions following a wide range of “radiological emergencies.” The Obama administration blocked a version of these PAGs from going into effect during its first days in office. The version given approval late last Friday is substantially similar to those proposed under Bush but duck some of the most controversial aspects…


      1. Thanks poa. The PEER link is here. The new nominal exposure limit after “radiological emergency” is to be 2,000 millirem or 20 mSv, in line with what Japan finally accepted for Fukushima repopulation: 20 mSv/yr.

        Glad to see we’re reading from the same page.

      2. In emergency situations it cedes exposure guidelines to expert organizations. It was never a lowering of general guidelines. That was more misinformation. FUD fuel.

    2. @poa

      I can’t find any evidence of revisions to the regulations in the past couple of decades. If you can find a link or two, I can do some more looking.

  13. It makes me sad and even sick to see the EPA responses. There’s no indication whatsoever that 0.0004 mSv per day has negative health effects. The EPA and NRC are basing themselves on atomic bomb survivor studies where people were exposed to over 1000 mSv per second and that showed a fairly poor but more or less linear correlation with bad health effects like cancer. Ok, so 1000 mSv per second is very likely not good for you. Does that mean we can say that it is extremely likely that 0.000000076 mSv per second (average background radiation in the world) is bad for you?

    The whole idea of a collective dose with low dose rates is ridiculous.

    LNT says every 20000 mSv kills one person. At an average of 2.4 mSv/year natural background radiation, and 7 billion people, this means that EPA is saying that 840000 people per year will be killed from natural background radiation. Can someone at EPA confirm this figure? Do they really believe this? Because they must, clearly, if they plan to make regs on Kr85 more stringent.

    So if the EPA is worried about 0.0004 mSv, what are they going to do about granite and the soil in your garden? What are they going to do about Denver? Maybe evactuate Denver?

    What we do know is that natural background radiation varies from 0.5 to over 300 mSv, though these are extreme values. There is not the slightest indication of bad health effects at the higher end of the range, such as in Ramsar or the Brazil beach sands.

    It would help a lot if EPA would stop being so deliberately obtuse with utterly unscientific concepts such as “collective doses” (the idea of inferring effects in a population without knowing individual dose nor dose rate is patently absurd and as unscientific as it gets). We might as well divide the number of aspirin pills being sold worldwide with the lethal dose of aspirin and then argue that hundreds of millions are being killed by aspirin a year!

    It would also help greatly if a relevant timeframe is given. Dose per year is silly. How much food, or alcohol do you take in a year? Heck anything sounds scary on that amount of time. The EPA is saying that one glass of beer a day is the same as drinking 365 glasses one one day of the year.

    We should be angry. This is an organisation that is supposed to protect us. In stead they fiddle with the margin of the margin of the margin, wasting people and resources, while doing very little to curb particulate matter pollution from fossil fuel and biomass burning (some 7 million premature deaths a year worldwide, over 30000 in the USA alone).

  14. Thanks for this post, Rod. I really encourage AtomicInsights readers to follow the link to the ANPR and submit comments. It is easy! The previous comments are visible and reading through them is disturbing (“…it is a scientific fact that any radiation is harmful”). If knowlegeable people don’t take just a few minutes to comment then we have no one to blame but ourselves. Even Bas from the Netherlands took the time to add his 2 cents.

    1. @gmax137

      Even Bas from the Netherlands took the time to add his 2 cents.

      And that should be motivation enough for Atomic Insights readers to make their own comments. Remember, be logical, use good reference material, and limit your responses to the topics discussed in the ANPR.

    2. Re: ” The previous comments are visible and reading through them is disturbing (“…it is a scientific fact that any radiation is harmful”). I

      The anti-nuke eco hypocrisy is speechless. Yet they get away with murder bamboozling the eagerly agreeing public. One of the main problems with our side is this seductive tendency to go TOO scientific to explain nuclear things to the public! If the public gets glassy-eyed and cowering at rads Bq per year and severits then the pro-nuker has failed at getting in the groove with the layperson’s mentality! I’m in NYC where people cough at smoky bus stops and subways breezing by stations whip up gutter and platform particles of God knows what into tens of thousands of lungs daily — and it’s largely accepted as a way of life — at what cost is just the price of living. They are being injured daily by fossil effects (as well as toxic chemicals and asbestos dust, etc) yet we have Chicken Littles squawking a panic about how the max radiation we receive should fit on the head of a pin — and the public gets that! Why? Because no one’s explained in simple language just what X amount harm X amount radiation does to a regular person in real life! I always felt that the way to get the public in tune with how harmful radiation is is to use a kind of Health Equivalency Impact Measurement; i.e. one second-hand of passersby cigarette smoke/inhalation of bleach at home/being caught behind a belching diesel truck/ is equivalent in bad health effects to X milli-rems of radiation, etc. Sweet and simple equivalence comparisons even Bonzo could understand. Why this isn’t done and used as forefront 1st ammo info in any nuclear debates gets me! It de-fangs the FUD dragon 50% at the get-go. What I’d LOVE to see is someone making a real legal case to shutdown Grand Central Station and the Empire State Bldg and lots of such locales based their granite and rock emissions! (Hey, lawyers come out of the walls to protect some desert insect!) You talking about making a point to sensibly raise min rad levels or appear a hypocrite by leaving GCS open for commuters to get zapped every day? Even local media TV reporters might understand this!

      James Greenidge
      Queens NY

      1. James has provided a method that has been exploited by the ECO-zealots to advance their cause. They sue the EPA for not applying an EPA rule/Reg to some endangered plant, animal, habitat, whatever that the law was not aimed at or written for and win their case (I think the EPA gives in, primarily to increase their power) and then this case sets precedence for the EPA to go after all the “violators.”

  15. I posted the following comment on the website:

    The EPA is concerned about a Kr-85 dose level of 0.0004 mSv per year. According to Dr. Jerry Cuttler, there is no indication of bad health effects for chronic radiation doses up to approximately 700 mSv/year and prompt doses of up to approximately 150 mSv per year.


    Thus, the EPA is concerned over dose rates more than a million times less than what is demonstrated to be harmful to humans.

    Dr. Cuttler further mentions that natural DNA damage (from food, etc.) is more than 1000 times the damage caused by natural background radiation. Natural background radiation in turn is over 1000 times higher than the Kr-85 dose the EPA is worried about.

    Organisms have powerful protection mechanisms against all cell and tissue damage, regardless of being caused by food or radiation or other sources. Low levels of radiation up-regulates protections, resulting in a net beneficial effect up to around 2 mSv per day (some 700 mSv per year).

    Furthermore, the use of collective dose to estimate risks in a large population exposed to very small radiation doses, is explicitly argued againsts by both the NRCP and ICRP recommendations. The EPA is not correctly following NRCP and ICRP recommendations in using very low chronic doses in population risk estimates and follow up cost-effectiveness calculations.

  16. I’m hoping this 40 CFR 190 and the changes on when to evacuate during an incident will result in a reduction in the sizes of Emergency Planning Zones and thus costs. This is particularly beneficial for SMRs, that would like to take the EPZ down to the plant boundary.

  17. 1. Look up “hormesis.” Low doses LOWER your risk of cancer. http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2663584/

    “The Linear No-Threshold Relationship Is Inconsistent with Radiation Biologic and Experimental Data”


”Nuclear Energy and Health: And the Benefits of Low-Dose Radiation Hormesis”

    Search “Hormesis”

    2. Coal contains: URANIUM and all of the decay products of uranium, ARSENIC, LEAD, MERCURY, Antimony, Cobalt, Nickel, Copper, Selenium, Barium, Fluorine, Silver, Beryllium, Iron, Sulfur, Boron, Titanium, Cadmium, Magnesium, THORIUM, Calcium, Manganese, Vanadium, Chlorine, Aluminum, Chromium, Molybdenum and Zinc. There is so much of these elements in coal that cinders and coal smoke are actually valuable ores. We should be able to get ALL THE URANIUM AND THORIUM WE NEED TO FUEL NUCLEAR POWER PLANTS FOR CENTURIES BY USING COAL CINDERS AND SMOKE AS ORE. Unburned Coal and crude oil also contain
    BENZENE, THE CANCER CAUSER. We could get all of our uranium and thorium from coal ashes and cinders. The carbon content of coal ranges from 96% down to 25%, the remainder being rock of various kinds.
    If you are an underground coal miner, you may be in violation of the rules for radiation workers. The uranium decay chain includes the radioactive gas RADON, which you are breathing. Radon decays in about a day into polonium, the super-poison.

    Chinese industrial grade coal is sometimes stolen by peasants for cooking. The result is that the whole family dies of arsenic poisoning in days, not years because Chinese industrial grade coal contains large amounts of arsenic.

    Yes, that ARSENIC is getting into the air you breathe, the water you drink and the soil your food grows in. So are all of those other heavy metal poisons. Your health would be a lot better without coal. Benzene is also found in petroleum. If you have cancer, check for benzene in your past.
    See: http://www.ornl.gov/ORNLReview/rev26-34/text/coalmain.html
    in case the ORNL site does not work.

    Make coal fired power plants meet the same requirements on radiation release that nuclear power plants have to meet.

  18. Coal contains: URANIUM and all of the decay products of uranium, ARSENIC, LEAD, MERCURY, Antimony, Cobalt, Nickel, Copper, Selenium, Barium, Fluorine, Silver, Beryllium, Iron, Sulfur, Boron, Titanium, Cadmium, Magnesium, Thorium, Calcium, Manganese, Vanadium, Chlorine, Aluminum, Chromium, Molybdenum and Zinc. We chould get all the uranium we need to fuel nuclear power plants for centuries by using coal cinders and ash as ore.
    So treat coal fired power plants equally with nuclear.

    1. @Asteroid Miner

      Though I agree with the fundamental concept of equal protection under the law, I’d prefer to move the regulatory bar closer to the permissible health impacts that we have accepted for coal and natural gas rather than those we have imposed on nuclear.

  19. Equal protection can cut both ways. The nuclear industry could sue for the same protection that coal gets. Since coal puts 100 to 400 times as much radiation out and nobody says anything, nuclear should have the same privilege.

    As for John P. Holdren, write emails to the president.

  20. Keep this book on prominent display: “Radiation and Reason, The impact of Science on a culture of fear” by Wade Allison. 2009. [The Wade Allison in England, not the other Wade Allison at Harvard.]
    Professor Allison says we can take up to 10 REMs per month, a little more than 1000 times the present “legal” limit. The old limit was 5 REMs/lifetime. A single dose of 800 REMs could kill you, but if you have time to recover between doses of 10 REMs, no problem. It is like donating blood: You see “4 gallon donor” stickers on cars. You know they didn’t give 4 gallons all at once. There is a threshold just over 10 REMs/month [100 millisieverts/month]. You are getting .35 rems/year NATURAL background radiation right where you are right now if you are where I am.

    Radiation workers were allowed 5 REMs /lifetime. Divide 5 REMs by your present Natural Background Radiation. For Americans, Natural Background Radiation is at least .35 REMs/year. Our Natural Background Radiation uses up our 5 REMs/lifetime when we are 14 years old. That old regulation is nonsense.

    The occupational worker limit was 5 REM/year. That is 1/24 or 4% of a realistic limit. Allowing for some leeway, the limit is still too strict.

    Natural Background Radiation is radiation that was always there, 1000 years ago, a million years ago, etc. Natural Background Radiation comes from the rocks in the ground and from exploding stars thousands of light years away. All rocks contain uranium. Radon gas is a decay product of uranium.

    1rem = .01 sievert = 10 millisievert
    milli means .001

    1. @Asteroid Miner

      I think you are missing a “non” in front of “radiation workers” in this phrase. “Radiation workers were allowed 5 REMs/lifetime.”

  21. Rod:

    Per your observation that “In fact, the EPA in 1977 had not even begun to consider that CO2 was a problem,” recall the dominant scientific climatic paradigm at the time was global *cooling* perhaps ominously the onset of a reversion to the prevailing ice age temperatures of the past couple million years (i.e. Pleistocene Epoch); global surface temp records showed a distinct negative slope between the years 1940-1978. As Asteroid Miner suggests the imposition of the uniquely burdensome fission industry radionuclide emission standard (limits on weakly interacting radioactive noble gases) on natural gas or coal power would result in their immediate curtailment.

    My ANPR comment:
    “Since the EPA’s original regulations on industry radionuclide emissions were issued in the mid-1970s the burning of billions of tons of coal has been directly implicated by, among others, Abt Associates (an EPA contractor), the National Academy of Sciences, and the Harvard School of Public Health in the mortality of over half a million residents of the US. Research published decades ago by the Oak Ridge National Laboratory observes that the combustion of coal with typical quantities of 1-4 ppm radon, thorium, and uranium inexorably release directly to the biosphere approximately twice the mass of radionuclides as the entire US nuclear energy sector generates as isolated stockpiles of used fuel annually, Simple extrapolation of even the conservative LNT theory of radiocarcinogenesis would indicate that a regulatory regime even a thousand times more liberal than EPA’s current limits on radiological emissions could not approach fossil fuels’ current allowable annual impact on US and world mortality and morbidity.”

  22. Just a historical aside, the gas industry didn’t think the lead in their fuel was significant either. Over time, we realized differently. Keep this in mind. The process repeats in other industries as well.. for example, the ozone depletion by CFCs.

    You do need to exercise a certain skepticism with regards to beliefs you are predisposed to accept. In my case, I believe in better safe than sorry. So, I have to ask myself, how could I prove my belief wrong. In part, reading material like your article is one way to do that. In particular, the cost of weighing this radioactive gas against CO2 and climate change.

    This said, I’m going to emphasize that in North St. Louis County, we have reports of cancer from people who lived near or around Cold Water Creek. The people responsible for the radioactive contamination of that water probably weren’t too terribly afraid of the exposure to civilians either. It is something to keep in mind.

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