Thursday, June 26, 2014

Protecting Against Nothing: The Failings of ALARA

Partial list of EPA drinking water regulations
ALARA and Reason

In Howard Shaffer's recent guest post: "No Safe Dose" Is Bad Science,  Shaffer described the questionable science behind the Linear Non Threshold (LNT) standard for radiation protection.  In my introductory remarks for his post, I wrote this sentence:

"Protecting" against very low levels of radiation increases the cost of nuclear plants, but the LNT (Linear Non Threshold) model says we must protect against any level of radiation, no matter how small.

An anonymous commenter asked a question about this statement.  He didn't ask directly about LNT.  He asked about LNT's daughter:  ALARA (As Low As Reasonably Achievable). LNT claims that no radiation dose is safe,  and ALARA claims that we must continually attempt to decrease the amount of any radiation dose.

So, back to the commenter's question.   I had claimed that LNT forces us to protect against "any level of radiation," and he asked:

How would you reconcile that statement with the actual U.S. regulatory regime, which relies on the As Low As Reasonably Achievable approach? (Emphasis in the original statement.)

Mineral Water
"Reasonable" is Unreasonable

My answer (edited a bit from the original that I posted).

The term "reasonable" is intrinsically unreasonable. How is reasonable defined? By whom is it defined?

Here's a simplified example of the difference between "reasonable" levels and a threshold level. My town water meets threshold limits for safety. My town provides town water and it sends residents the analysis results for their water. I am proud to say that our town has an excellent municipal water department. The water is safe to drink: all ions and all contaminants are below the EPA levels that define safety for those materials. 

Let's say the EPA safety limit for "A" is 10 parts per million (ppm).  Let's say, in the town water, "A" is at the level of 5 ppm. 

The water is safe. 

Town water and threshold limits

The water is safe, and people can't go to the town select board and insist that new water treatment methods are available and therefore must be acquired by the town.  They can't insist that the town needs to lower the level of "A" from half the EPA safety limit to a quarter of the limit. People can't force the town to upgrade its water system just because those people believe that the new lower limit is "reasonably" achievable. Once the  town water has met  its threshold for safety, further water treatment is not required.

That's the difference between a threshold level--and the unreasonable term "reasonable." 
  • A threshold is a number. A system (water supply, power plant) can do a measurement and prove that it meets the criteria. 
  • In contrast, the term "reasonable" is open to endless expensive interpretations.


Note: The commenter then asked a second question.  I will answer it in a separate post.


Joffan said...

Hi Meredith

First I'm going to enlist you in a move to avoid using the word "theory" or even "hypothesis" after LNT. LNT is a model used for regulation.

Next I want to imagine a parallel case to the "protecting against nothing" that applies to nuclear.

Some people are afraid of what might be under their bed. So I suggest that beds are regulated to include full under-bed lighting (with mains connection and battery back-up for 8 hours), alarm systems to detect under-bed movements and a series of roller doors that can seal off the under-bed area with suitable powered and manual backups. Functions on all systems and backups will need to be tested every three months and any problems with these systems will be the subject of fines and possible ban from using the bed.

Sleeping on the floor, however, will be unregulated.

Meredith Angwin said...


Thanks for the comment!

I am SO pleased that sleeping on the floor will be unregulated in your scheme, because my grandkids and some of their friends will visit over July 4. You guessed it! They plan to sleep on the floor in sleeping bags!

I need to get the grown-up guest beds set up, however. Boy, that is going to be hard. ;-)

Meredith Angwin said...


About LNT. It isn't even "linear" as you know. It has a fudge factor to change the slope in some areas. When I objected to this as non-linear, the usual commenter (no longer allowed on this blog) explained that I didn't understand the equation, and I was referring to the quadratic part of the linear equation.

"Quadratic part" of a "linear equation"? In the real world, an equation with a quadratic term (x squared) is customarily referred to as a quadratic equation, not a linear equation! Many quadratic equations have terms in both x and x squared, but they are quadratic equations nonetheless.

The term "linear" in Linear Non Threshold is sheer anti-scientific propaganda. Even LNT defenders can't turn the equation into a true linear equation. They just like the term "linear." It serves their purpose.

Tom Buchanan said...

Here's how ALARA is defined by the NRC:

"As defined in Title 10, Section 20.1003, of the Code of Federal Regulations (10 CFR 20.1003), ALARA is an acronym for "as low as (is) reasonably achievable," which means making every reasonable effort to maintain exposures to ionizing radiation as far below the dose limits as practical, consistent with the purpose for which the licensed activity is undertaken, taking into account the state of technology, the economics of improvements in relation to state of technology, the economics of improvements in relation to benefits to the public health and safety, and other societal and socioeconomic considerations, and in relation to utilization of nuclear energy and licensed materials in the public interest. For additional detail, see Dose Limits for Radiation Workers and Dose Limits for Radiation Workers."