Guest Post by Kit P: EPA, NRC and Coal Environmental Studies

In my blog post Vermont Yankee is Not Fukushima, I compared the health effects of Vermont Yankee with the more serious health effects from coal, quoting an EPA paper. Kit P made incisive comments  on that post, stating that the EPA link did not show the cause-and-effect relationships that I thought it showed.

 I felt his comments were too important to be hidden in a long (17 comment) stream of responses to a blog post. I invited Kit to write a guest post. He was good enough to write one, and here it is.



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The Purpose of Environmental Studies

One reason to read environmental studies is to learn information to make informed decisions about solving environment problems. One reason to cite environmental studies is to promote an agenda.

I worked at a nuke plant in California called Rancho Seco when it closed. Studies have cited how infant mortality improved after the plant closed. I have not read the study. One way to improve infant mortality is to provide free prenatal care for the poor which is just what happened about the same time as the closing of the plant.

My point here is to recognize the difference between improving the quality of life and fear mongering.

So on one hand I am an advocate of VY and on the other hand fear mongering about other sources of power is unnecessary. If VY closes it will be an economic loss for those who work at VY and the state that has to import power most likely by burning fossil fuel someplace else.

Is the EPA fear-mongering?

The question that this essay attempts to raise is the Obama EPA fear mongering? If so Meredith has jointed the ranks of an Obama sock puppet. She should not feel too bad being in the company of a Nobel Prize winner in Physics. (Meredith comments: "Sock puppet", "shill", whatever. No problem!)

Meredith writes:

“On the other hand, some of the worst air quality in their models is Ohio and Pennsylvania. ”

From the map, “Cross-State Air Pollution Rule (CSAPR) RIA, Table 1-1 and -2; mortality impacts estimated using Laden et al. (2006), Levy et al. (2006), Pope et al. (2002) and Bell et al. (2004); monetized benefits discounted at 3%.” http://www.epa.gov/airtransport/benefitsmap.html

The following are listed references and quotes:

• Laden et al. (2006): “Reduction in Fine Particulate Air Pollution and Mortality Extended Follow-up of the Harvard Six Cities Study” http://ajrccm.atsjournals.org/content/173/6/667.full.pdf+html  
• “Annual city-specific PM2.5 concentrations were measured between 1979 and 1988, and estimated for later years from publicly available data.”
• Levy et al. (2006), “Ozone exposure and mortality: an empiric bayes metaregression analysis."zxs http://www.ncbi.nlm.nih.gov/pubmed/15951663 
• "We gathered 71 time-series studies relating ozone to all-cause mortality, ”
• Pope et al. (2002). “Lung cancer, cardiopulmonary mortality, and long-term exposure to fine particulate air pollution.” http://www.ncbi.nlm.nih.gov/pubmed/11879110
• “The risk factor data for approximately 500 000 adults were linked with air pollution data for metropolitan areas throughout the United States and combined with vital status and cause of death data through December 31, 1998.”
• Bell et al. (2004). “Ozone and Short-term Mortality in 95 US Urban Communities, 1987-2000” http://jama.ama-assn.org/content/292/19/2372.full 
• "we estimated a national average relative rate of mortality associated with short-term exposure to ambient ozone for 95 large US urban communities from 1987-2000.” “Deaths for people aged 75 years and older comprised approximately half of total deaths in these 95 communities. ” “Ozone pollution is now widespread in urban areas in the United States and many other countries. Its rise reflects primarily increased numbers of motor vehicles and miles traveled; vehicle emissions are a major source of precursor hydrocarbons and nitrogen oxides. ”

Nice Try, EPA, But Those References Are Not About Coal

Nice try EPA but if you want to make claims about 'mortality impacts' of coal don't you think that coal should be the source of the pollution? The second problem with these studies is 'cause and effect' is not studied. The third problem is that 'mortality impacts' are not defined.

So what do all the studies say for those who are worried about air pollution cutting short their life?

• Do not smoke. 
• Do not heat your house with coal, wood, or dried manure. 
• If you do not want your children to breathe mercury, do not break things with mercury in your house bigger than a thermometer.

For the US there are just no studies that provide a 'smoking' gun for 'mortality impacts' related to coal plants, Yes there are chronically ill people and yes they die. We all die but I am skeptical that our good air quality is the cause.

NRC and EPA Regulatory Approaches

Let me approach the question from a different angle. The NRC and the EPA regulate differently.

The NRC is very site specific. Each nuke plant must show that annual offsite exposure is less than 5 mrem/year compared to 300 mrem/year average background. Each plant provides an annual report. For example, I used to live 12 miles from a nuke plant. One year I checked the annual report and the offsite exposure was below detectable. A calculation estimated the annual offsite exposure is less than 0.004 mrem/year.

Downwind of the nuke plant about 90 miles, background is 1800 mrem/year because of elevation and radon. If Downwinders are concerned about radiation, they should more closer to the nuke. This downwind location sometimes has air quality issues. The same conditions that trap radon also trap pollution from cars/trucks. However, there are not coal-based generation impacting air quality.

The US EPA looks at air quality based on regional measuring stations and can be found at http://airnow.gov/ and the Weather Channel will also provide a local report. I frequently monitor this site looking for places where the air quality is above a threshold of harm.

At the moment, Cleveland/Akron has just reached that threshold.

The EPA provides this warning, “Health Message: Unusually sensitive people should consider reducing prolonged or heavy exertion.”

The Third Approach

The '"Ain't It Awful" group hates good news. Zero is the number of people who check http://airnow.gov/ and tell me I am wrong. Air quality is very good in the US. Air pollution has no 'mortality impacts' any more.

A third approach is the correct approach. The benefits of power generation far out weighs the risks.

 Closing Vermont Yankee requires that the power be replaced as discussed in the Vermont Yankee renewal EIS: http://www.nrc.gov/reactors/operating/licensing/renewal/applications/vermont-yankee.html#impactstatements

Already know what it will say:

Table 8-2

Air Emissions from Coal-Fired Alternative

As such, Entergy concludes that the coal-fired alternative would have MODERATE impacts on air quality; the impacts would be clearly noticeable, but would not destabilize air quality in the area. (Page 8-8)

However, in the absence of more quantitative data, human health impacts from radiological doses and inhaling toxins and particulates generated by a coal-fired plant at an alternate site are considered to be SMALL. (Page 8-9)

Therefore, it is official the environmental impact of nukes is less than a coal-based power plant, but this does not justify saying that coal is causing 'mortality impacts'.

Evidence for Impacts?

Is there any evidence?

“The NRC stated in the GEIS that there could be human health impacts (cancer and emphysema)

from inhalation of toxins and particulates from a coal-fired plant, but the GEIS does not identify the significance of these impacts [Reference 8-11].”

As far as I know, lung cancer and emphysema are strongly associated with smoking and nothing else. So I went to NUREG-1437 looking for the reference. No reference was listed.

While I think WIKI is a place to start, it is a source to be skeptical about. What could be some of the other causes of emphysema?

“This could include exposure to air pollution, second-hand smoke, and/or other chemicals and toxins.[citation needed]”

Here is the deal with a smoking gun, the absence of evidence is not actually evidence. However, if coal-based power is causing 'mortality impacts' or mercury poisoning there should be lots of smoking guns.

We Can and Have Solved Environmental and Safety Issues

There is lots of evidence that systematic approaches to solving environmental and safety issues work. Measured levels of air quality have shown huge improvements over the last 50 years in the US so that it no longer has 'mortality impacts'.

Air quality is poor for billions of poor because of cooking and heating using coal and biomass. Industrial societies show that air quality improves by electrification with affordable power if coal is the source.