Linear No Threshold: Comment to the NRC

Filing a Petition to the NRC for Reasonable Radiation Rules.

I am a member of S.A.R.I., Scientist for Accurate Radiation Information.  Recently, three distinguished members of SARI have filed an NRC petition, asking the NRC to re-visit the radiation protection rule making which is based on the Linear No Threshold (LNT) assumption, and the consequent ALARA (As Low As Reasonably Achievable) rules.  These rules force the nuclear industry (and any other industry using radiation) to assume that ANY radiation is harmful, and protection against radiation must be constantly increased.

Here's the petition in the Federal Register. The comment period is open until September 8, so you have a few days to file your comment.

Update: The comment period is now open until November 19.  (Yes, it surprised me, also.  See the third page of this pdf.)

The Problem with ALARA

Sunrise in Denver

Due to LNT and ALARA, you can't say: the radiation here is so low that the radiation is not a problem.  Since LNT and ALARA claims that all radiation is harmful, it's a constantly escalating fight against any radiation.

Meanwhile, there is no evidence that radiation at the standard background level matters in terms of cancer or birth defects. There is not more cancer in areas with high background radiation (such as Denver) and less cancer in areas with low background radiation (such as the Mississippi Delta).  As a matter of fact, the situation is rather the opposite.  People in Denver tend to be healthier and live longer and so forth.  However, that is more likely to be due to socioeconomic factors than background radiation factors.

There is some evidence that low doses of radiation are protective. This is called hormesis. From what I have read, I have come to think that low levels of radiation are protective, by a sort of vaccination effect. I am also aware that this idea is very controversial.  I am not a biologist, so I don't like to get into the weeds on this.

However, it is completely clear to me that the relationship between cancer and radiation is not linear, or we would have to evacuate Denver posthaste!

Here's a reasonable drawing of the possible shapes of a low-dose radiation effect curve:

• linear response is curve B 
• hormesis protection is curve D, 
• low-dose radiation is worse-than expected is curve A
• low-dose radiation is not-as-bad-as expected is curve C  

As far as I can tell, nobody knows which of these curves is correct.  A and B are least likely to be correct. All the curves agree at high dose, and the effects are very hard to measure at low dose.

From Lawrence Berkeley Lab
Different hypothesis for radiation dose response

The Comments

I will post my own comment as a separate blog post tomorrow.

Please comment if you can.  Here's the link, and then you have to follow the "submit a formal comment" button.  

It took me a while to comment, because I kept thinking---well, I'm not a biologist etc etc. But just look at the opponent comments!  As you can imagine, a lot of the opposition comments are barely one step above: "Are you frigging crazy!  All radiation is dangerous!"

I decided I could comment.  I figured I could do a little better than that.

Some more background

Petitioners:

The three people who submitted petitions to the NRC are:

Dr. Carol S. Marcus, Professor of Radiation Oncology at UCLA
Mark L. Miller, Certified Health Physicist
Dr. Mohan Doss, Associate Professor at Fox Chase Cancer Center

Rod Adams post:

Rod Adams post on pro-nuclear people receiving flak on this (because we are over the target).

NIRS Firing Flak at Pro-Nuclear Fanatics

A couple of random articles I found, plus a link to the S.A.R.I. website, which has more articles

Drosophila Melanogaster

Fruit Fly article the first: Weak radiation doses prolong life in fruit fly females

Fruit fly article the second: Low doses not linear response

(A friend wrote me that he didn't LIKE fruit flies, so what's with the fruit flies?  My answer is one type of fruit fly is frequently used for genetics experiments, and has been for at least fifty years.)

S.A.R.I. http://radiationeffects.org

New EPA Radiation Guidelines: Please Comment Today or Tomorrow

New Guidelines for Response to Radioactivity Releases

The EPA published new guidelines for response to radioactivity releases.  These guidelines can be considered to be "in light of" Fukushima, where hasty evacuations caused hundreds of deaths.  Here's  the EPA announcement.  Tomorrow is the deadline for comments on these guidelines.
You can email comments to:
a-and-r-docket@epa.gov
Be sure to mention Docket ID No. EPA-HQ-OAR-2007-0268.

EPA and IAEA

An ANS blog post describes the guidelines: New EPA Guidelines for Response to Radioactivity Releases by Jim Hopf.  Among other things, the new guidelines say that a public dose level of 2000 mrem the first year and 500 mrem in subsequent years is the guideline for evacuations.  Apparently, this is not much of a change from previous guidelines.

Meanwhile, the IAEA has issued a publication called Actions to Protect the Public in an Emergency due to Severe Conditions at a Light Water Reactors. (Note: that link leads to a long pdf which will take time to download.)  The IAEA publication might be considered the international version of the EPA proposed guidelines. It seems more complete in its analysis, and more liberal in its guidelines for health and safety.

Okay.  I haven't done the hard work of comparing these two documents, but it seems that both sets of guidelines are well thought out. The EPA document has been broadly attacked, and it is worth supporting it with a brief email. I did.

A little context on the numbers. You can get about 500 mrem a year by living in the granite hills around here, for heaven's sake. According to the NRC, the average American gets 620 mrem per year: half from background and half from medical, air travel, etc. Move uphill on a granite mountain and the background dose will surely go up.

Hargraves Review of the EPA Guidelines

Dr. Robert Hargraves has reviewed the EPA and IAEA documents, and this is the email he wrote to the EPA in support of their new guidelines. Basically, he concludes that the EPA document is over conservative.

Dr. Robert Hargraves
author
THORIUM Energy cheaper than coal

EPA,

I appreciate the importance of your work to guide emergency response in the event of a radiological emergency. The lack of such guidelines for Fukushima drastically increased the harm to the public from overly aggressive evacuation and relocation. Having rational guidelines in place will strike a balance between radiological harm and relocation harm. You published PAG Manual, http://www.epa.gov/radiation/docs/er/pag-manual-interim-public-comment-4-2-2013.pdf and asked for comments.

The IAEA has just published a similar document, Actions to Protect the Public in an Emergency due to Severe Conditions at a Light Water Reactor, http://www-pub.iaea.org/MTCD/Publications/PDF/EPR-NPP_PPA_web.pdf. I recommend that the EPA draft document be compared to this IAEA document and that the differences be explained, rationalized, or eliminated. It makes little sense for documents from EPA and IAEA to differ. Why should US guidelines be so different from international guidelines?

The differences are enormous. The EPA guideline document is far too conservative. For example, on page 7 of the EPA PAG draft, relocation of the public is recommended if radiation doses will exceed 20 mSv in the first year, or 5 mSv/year thereafter.

"2 rem (20 mSv) projected dose first year
Subsequent years, 0.5 rem (5 mSv)/year
projected dose"

In the IAEA document, page 59, relocation is recommended only for radiation doses exceeding 200 mSv/year (25 microSv/hour).

EPA's guidelines are excessively conservative, by a factor of 10 (200 mSv/20 mSv) in the first year, and a factor of 40 (200 mSv/5 mSv) in the subsequent years. Repeating my observation...

EPA RECOMMENDED DOSE LIMITS ARE TOO LOW BY A FACTOR OF 10 TO 40 !

Over 1000 people died near Fukushima from the stress of unnecessary relocation. The EPA-recommended guidelines will cause similar, unnecessary public harm in a US radiological emergency.

I recommend that the EPA review its draft recommendations and set radiological dose exposure limits based on evidence of observed public harm from ionizing radiation.

Radiation Superstition: Guest Post by Bob Hargraves

Radiation Superstition by Robert Hargraves

Nearly a million people each year die of breathing particulates from burning coal; the climate temperature may increase 2°C this century; more than a billion people have no electricity.  Yet within

our reach is a solution to these global crises of increasing air pollution deaths, climate change, and the

Coal Mine, Wyoming

growing populations of nations trapped in energy poverty.

The welcome growth of the global middle class increases energy demand. If the world's economy prospers enough to allow everyone to enjoy just half of the electricity benefits that Americans now take for granted, world electric power generation will triple. Most electricity will come from coal burning, which grew 8% worldwide in 2011. Germany leads the way, building more coal plants. Wind and solar power are too intermittent and too expensive to displace coal worldwide.

Nuclear power is the solution within reach; it's safe and affordable, with low environmental impact. Yet opposition to it borders on superstition, defined by Merriam-Webster as a "belief or practice resulting from ignorance, fear of the unknown, trust in magic or chance, or a false conception of causation ... a notion maintained despite evidence to the contrary".  Let's explore evidence.

People rationally fear possible accidents spreading deadly radioactive materials. Indeed massive doses of radiation did kill 38 emergency workers at Chernobyl, and the fallout of short-lived iodine resulted in 4000 cases of thyroid cancer and 15 deaths. However there is no evidence of the thousands of hypothetical deaths predicted by extrapolation of deadly exposures to lower radiation doses. Opponents of nuclear power have now hyped this death number up to one million, without observable evidence.

Low-level radiation

Using simplistic mathematical extrapolations from the effects of high-radiation accidents, nuclear power opponents claim that no amount of radiation is safe -- not even the low-level natural radiation that comes from the sky and from earth's radioactive potassium, uranium, and thorium created billions of years ago. Potassium is in our food and our bodies. Rocks contains the thorium and uranium that decays to radon or fuels electric power plants.

Reporting about the Fukushima accident created hysteria without basis. A UN scientific committee charged with investigating the accident's health effects reported in December that no radiation health effects have been observed among public or workers, and it cautioned against extrapolation to predict health effects of low-level radiation. Radiation superstition causes great harm. Japan is wasting billions of dollars preventing repopulation of radiologically safe areas. Hundreds have died from evacuation stress. Importing liquified natural gas to replace nuclear power has driven Japan's balance of trade negative.

People unnecessarily fear low-level radiation from accident-dispersed material, buried waste, or medical procedures. EPA required Yucca Mountain engineers to limit accidental releases to just 1/20th of natural radiation for 10,000 years. Dental X-ray technicians routinely drape lead blankets on patients to protect them, but it would take over 10,000 such X-rays to observe any health effect.

Prolonged radiation exposure is safe at natural environmental levels; each cell rapidly repairs DNA strand breaks: one per second per cell. Early life evolved when the natural radiation rate was 3 times greater than now. Today people living in places where natural radiation is 5 times normal exhibit no more cancers. People living in mile-high Denver get more cosmic radiation, but exhibit no more cancers.

Thorium, Energy Cheaper than Coal
Available Through Amazon

Radiation dose rates are as important as doses. High radiation rates overwhelm natural cellular defenses. Doses deadly to Chernobyl workers would have no effect if spread over a lifetime. Cancers are destroyed by multiple concentrated radiation treatments, allowing time between for less-irradiated tissue to recover. In 2012 MIT radiation researchers discovered no DNA damage from exposure rates 30 times as great as natural radiation, and Lawrence Berkeley Lab scientists actually observed how low-level radiation stimulated repair within cells. Long-term, low-dose radiation is benign.

Nuclear industry and shipyard workers exposed to low-level radiation developed fewer cancers. Accidental contamination of building steel by recycling a medical radiation source exposed 8000 Taiwan residents to radiation 7 times natural levels over 30 years, and cancer rates were dramatically reduced. Last year the Dose Response Journal and the American Nuclear Society published compendia of articles evidencing how low-level radiation is benign or healthful.

The vague radiation regulation, "as low as reasonably achievable" encourages ever more costly impediments to affordable nuclear power. This could be fixed with "as high as reasonably safe" limits that are set with evidence, as practiced for other environmental hazards. Nuclear power can solve our energy, climate, and poverty crises. Should we forsake the future of the planet by clinging to a superstition?

Background of this post:

This post first appeared on Rod Adams blog, Atomic Insights.

On Adams' blog, you can follow many related links about this post.

The post was written as an op-ed, but rejected by a large number of papers, despite its reasonable length and tone, and Hargraves' impressive resume.

On my own blog: Monday Blue Ribbon to Robert Hargraves
Vermont Yankee Explained (the animation) by Robert Hargraves
Plus, Hargraves excellent suggestion that Vernon leave Vermont and join New Hampshire (what's a river, anyhow?)


Hargraves Resumé:

Author: THORIUM: energy cheaper than coal
Energy policy study leader: ILEAD@Dartmouth
Vice president: Boston Scientific
Management consultant: Arthur D Little
Vice president: Metropolitan Life
President, DTSS
Assistant professor of mathematics: Dartmouth College

PhD, physics, Brown University
AB, mathematics and physics, Dartmouth College

Fukushima Oversimplified and Simplified

We Start with Complete Lack of Clarity

Trying to understand what is going on at Fukushima has not been an easy task. Even after the first weeks, information out of Japan was hard to parse. For example, on April 4, the Capacity Factor blog attempted to understand inconsistent radiation readings in Japan, while on March 27, Cheryl Rofer blogged about the ways radiation measurements could go wrong.

Then there was the entire "tellurium shows there is re-criticality" business.

First, the Japanese reported the presence of tellurium in a water sample.

Second, Arnie Gundersen and others were quick to claim that this proved the reactors had "gone critical" again with a fission chain-reaction.

Third, the Japanese admitted that their measurement was wrong: there was no tellurium present.

The measurement was wrong and Gundersen's re-criticality theory was wrong, too.

In other words, we had a complete lack of clarity.

We Move to Oversimplification

There's a scale, the INES scale, for nuclear accidents. On this scale, Three Mile Island was a 5, and Chernobyl was a 7. Seven is the highest level on the scale. Until April 11, the Fukushima accident level was assigned as a level 5, the same as Three Mile Island (TMI). That was obviously too low an assignment: nobody was evacuated or burned by radioactive water at TMI. Then the Fukushima level was raised to a 7, the highest level possible. Fukushima has only emitted 1/10th the radiation that Chernobyl did. (Also, unlike Chernobyl, nobody has been killed by radiation at Fukushima.) Capacity Factor has an excellent post comparing Fukushima level 7 with Chernobyl level 7.

So, the INES scale has the same rank (7) for two accidents that are an order of magnitude apart in terms of radiation release. However, what about a bigger-than-Chernobyl accident? A two-reactor Chernobyl? That would be an INES 7 also.

Oversimplification.

Real Simplification, Also Known As Clarity

Luckily, in recent days, some clarity has come to general understanding of the Japanese situation. We first moved from complexity to oversimplification, and now we are approaching knowledge.

A wonderful interactive graphic from the New York Times puts many types of earthquake damage on the same graphic (finally!) in a move that Edward Tufte would appreciate.

For our purposes, though, we should look at the "radiation" levels tab of the graph. If you look at a given circle on the map, the color indicates the radiation dosage at that point. Each circle also contains information on the dosage rate, and how long it would take (at that dosage rate) to receive an exposure that:

• equals a chest xray,
• equals the allowed dosage of a United States nuclear worker,
• becomes a dosage at which long-term health effects become more likely.

Furthermore, in the Radiation tab of the Times graphic, there is a slider under View Readings Each Day. If you move the slider to March 17 and then move it forward in time, you can see the overall radiation levels decrease with time. The colors of the dots become less intense. It's a great visual and shows that the radiation is getting under control. Airborne radiation levels are diminishing.

This makes sense, because most of the radiation was released in the early days of the accident.

There's another good source if you want to see the time evolution more directly. The NEI (Nuclear Energy Institute) blog linked to a new graphical blog based on Japanese data sources. This blog has graphs of the main parameters of the reactors over time on one set of charts. For our purposes, another set of charts is more interesting: these charts map the evolution of the radiation levels in Ibaraki prefecture and Tokyo, with a comparison to European background levels.

Once again, the charts show the same clear story of steadily decreasing radiation levels. Radiation spikes at the beginning of the accident, then steady decreases.I have grabbed one of these charts below. As usual, double-click to enlarge it.

Final Clarity?

Final clarity is not available yet. Power has been restored to the Fukushima site, radiation levels off-site are decreasing, the major radiation outflow from the plants now is water, which is intrinsically easier to control than air-borne emissions. But nobody would say that the problems are over.

Fukushima isn't Chernobyl, and it isn't Chernobyl on steroids (as Gundersen predicted) but it is serious. This Fox news clip is not particularly upbeat, but I think it is a good summary of the situation to date.

The graphic at the top of this post is a picture of a snubber at Brown's Ferry. Brown's Ferry is a sister plant of Fukushima and Vermont Yankee. The snubber is isolates vibrations for Unit 1 and is part of the seismic activity safety equipment for the plant. Photo used with permission of TVA.

Eye chart from Wikimedia.

Potluck and Genetics

When Howard and I walked into the community building for the potluck and the debate, we felt right at home. There were about fifty people there, perhaps less, and many of them were "the usual suspects"--people we had seen at many hearings.

By the way, this isn't a youth movement. Most of the people were on the far side of fifty (as I am, myself). They may be remembering their days as college-age protesters, but they aren't college-age protesters.

Howard had debated against Deb Katz in the past, and she greeted him nicely and asked if he wanted to be on the platform with her. "Of course," he answered. She never invited him up there. She had arranged to debate with a comedian, after all. I saw some people I knew, including an anti-VY man who is getting interested in thorium reactors for the future. We email occasionally, and greeted each other with honest warmth. People made sure that we had food, soup, cookies.

We sat at the table. At each place setting, there were two handouts. One was a short yellow piece containing a poem and a quote. The quote was from Gayle Green's book "The Woman Who Knew Too Much."

"And cancer is not the worst of it. Alice Stewart warns. Even more dangerous than cancer is the threat to future generations That's what you really need to be afraid of. It's the genetic damage, the possibility of sowing bad seeds into the gene pool from which future generations are drawn. There will be a buildup of defective genes into the population. It won't be noticed until it is too late. Then, we'll never root it out, we'll never get rid of it. It will be totally irrevocable."

A sentence at the top of the page stated that Alice Stewart, M.D., was born in Great Britain in 1906 and investigated the dangers of exposure to radiation.

This piece gave me the chills. First of all, it had that early-20th-century tang of eugenics (those irrevocable bad seeds) and eugenics led to untold misery. Second, it seemed to imply that radiation from un-natural sources was the main cause of mutations, and without such radiation there would be no bad seeds! Forget about crossover patterns between chromosomes and every other source of mutation that has been operating since the dawn of life. I leaned over to Howard, desperate to discuss this. But we couldn't talk, because the debate was about to begin.