Low Dose Radiation: Keynotes, Initials and History

Alan Walter opens the conference.
October 1, Pasco WA

Rod Adams post:

Rod Adams and I are covering the Low Rad meeting.  I urge everyone to read his post (which he posted just a few minutes ago) and comment on it.

Would you evacuate your home in the middle of the night because of a radioactive release? This question was during at the meeting. Read the answer here: Making sense from radiation protection controversy

Nonstop Learning

I am now in the morning of the third day of the Low Dose Radiation conference, and it has been non-stop learning. In between the sessions and the poster sessions, it has been hard to post.   To give you an example of what I mean, on Monday morning there were eight presentations, not counting various welcoming remarks.  At lunch, Michael Shellenberger gave a stirring talk.  In the afternoon, there were two panel discussions and four presentations. The poster session is also extraordinarily interesting.  And I haven't even mentioned the handbell concert at breakfast.  When I say "nonstop," I mean nonstop.

I cannot possibly summarize this conference.  That's the bad news.  The good news is that since I can't possibly cover the whole thing, I will just hit some high points, and add plenty of commentary. Starting with Monday morning.

Goals and First Set of Keynotes

Goals: Mike Lawrence, former director of the Hanford site,  described the goals of the conference.  The conference attempts to pull together scientific data on the effects of low-dose radiation.  A major goal is to ensure that radiation protection through evacuation after an accident is done only on scientific grounds, not on primal fear of radiation.  The doses encountered at Fukushima would have led to no deaths or very few, but the evacuation killed over a thousand people. (Some estimates are only 800 people,  but you get the idea. The difference between no deaths and hundreds of deaths is a lot of deaths.)

Brenner talk: The first keynote was by David Brenner of Columbia University.  He supported LNT as the proper measure for low-dose radiation. The two arguments that he used to support the LNT theory really struck me, but not in a good way.  He used the idea that there is a cell, and it gets zapped with radiation.  We know quite a bit about high doses, but as we lower the dose, we can expect that each cell will only be zapped one time.  Then, as we lower the dose further, fewer cells will be zapped, but each cell which is zapped will be zapped pretty much the same way.  He admitted that repair mechanisms exist, but felt they were the same (or could be considered to be the same) if every cell was zapped once, or if only half the cells were zapped.  Therefore, he considers LNT to be correct.

My opinion: this was an overly-simplistic gedanken experiment. Later in the meeting, I heard many scientists describing the complex interactions of radiation, expression of genes, DNA repair, and so forth.

He also claimed that radiation damage to a fetus was another reason to support LNT, because fetuses do not have the confounding factors that adult humans have: no smokers, drinkers, etc. So damage to a fetus can stand in for damage for adults.  My opinion: "I'll drink to that. And while I am at it, I will have a thalidomide pill, if I can find one, in case I get a little nauseated."  In other words, many things that harm a fetus (alcohol, thalidomide) are not harmful to an adult, especially at low doses.  Many choices that would have been unwise for me to make while I was pregnant are no particular problem to me now. His fetus-centric argument strikes me as a thin reed to hold such an immense regulatory structure.

McClellan talk. The second keynote was by Roger McClellan, an internationally known expert in inhalation toxicology. He has worked in both radiation toxicology and chemical toxicology, and understands the difficulties of obtaining good data at low doses.  Brenner's conclusions about low dosages were clear (but wrong in my opinion), while McClellan was nuanced. McClellan said that all industries, de facto, use ALARA (as low as reasonably achievable) for exposure, basically because no CEO wants to get sued.  He concluded that poverty is far more dangerous to human health than the low-dose issues of nuclear energy.  (I hope I am reporting this correctly.) I enjoyed his talk, and hope to read it in full at some time, to report on it more accurately.

The March of the Initials

The next part of the meeting was what I call the March of the Initials. At this point, I need to encourage people to go to the program tab of the Low Radiation Dose Conference website.

Website for Program: http://lowdoserad.org
Pdf of program: http://www.umtanum.com/TopicalManagedFiles/_Program/Program.pdf

The March of the Initials is the list of regulatory agencies, marching by in rapid fire, who presented their approaches to radiation protection. They had twenty minutes per agency.  These agencies included NRC, IAEA, UNSCEAR and others.  I was somewhat surprised (I am naive) about how different these agencies are in their approach.  David Pawel of EPA could have been giving Brenner's talk, while  Patricia Wieland of UNSCEAR acknowledged the limitations of understanding any possible levels of good or harm at low doses. She ended her talk by recommending that "regulators...use the old concept of ‘de minimis non curat prætor’ and exempt from regulations low-dose exposure situations that do not warrant control."  (Lots of us wanted to kiss Ms. Wieland, but we refrained.)

Note: Wieland was standing in for Abel Gonzalez, whose name is on the paper but could not attend the meeting.

As this point, I encourage people to go the website for the program, go to the program tab, and download the zip file of the Flash Drive for more information.

Micheal Shellenberger and History

Michael Shellenberger, founder of Environmental Progress, spoke at the luncheon, with a fascinating talk on "The Making of Radiation Panic."  History teaches us the way forward.  To some extent, the bomb-making scientists (such as Oppenheimer) found themselves displaced in the public esteem by the reactor-making leaders (such as Rickover). They did not necessarily like this fact. Also, many of the older scientists, including Einstein, had the Utopian idea that the bomb would lead to a world government, which would mostly supersede the nation-states.  This also did not happen. It's a complex story, and Shellenberger told it well.

It became a battle between the idea of promoting world peace through promoting fear of radiation, and promoting world prosperity through the use of nuclear power.  I believe Shellenberger is writing a book on this subject.  I will be eager to read it.

So Much More

There's so much more to say. But if I don't post now, I will be late to the meeting!

Department of Energy: Nuclear policy, nuclear money, and the millennial caucuses

Secretary Rick Perry and Millennial Nuclear Caucus
October 2017
From Department of Energy website

Millennials 
Starting this past fall,  I finally noticed that the current Department of Energy was not the old Department of Energy. In October 2017, DOE cooperated with the Nuclear Energy Institute and held the first Millennial Nuclear Caucus, in Washington DC. At that event, Secretary of Energy Rick Perry met with a group of young nuclear professionals.  In a post on the DOE website, Secretary Perry said: "I had the pleasure of meeting with a number of young visionaries in the nuclear field this morning." As a matter of fact, the hashtag for the Millennial Nuclear Caucus meetings is #NuclearVisionaries.  Here's a brief video of part of the meeting.


More to come
When I saw the announcement of the first caucus, I felt terrific. The Department of Energy promoting young people and nuclear! Well, the only word was--- awesome!

Next, I realized there was more to come. I learned that the Washington meeting was going to be the first of a series of caucuses.  So far, there has been the first Caucus in Washington, another in Ohio, and a third a few days ago at Texas A&M University.  The Caucuses are listed on this page of the Department of Energy website.  https://energy.gov/ne/millennial-nuclear-caucus Videos of the Caucuses are at the U. S. Department of Nuclear Energy Facebook page
https://www.facebook.com/NuclearEnergyGov

UPDATE: The next Millennial Nuclear Caucus will be March 7 in Washington D.C. https://www.eventbrite.com/e/millennial-nuclear-caucus-tickets-43452885751

The most recent Caucus took place at Texas AMU on February 20. Once again, the millennial panelists were from various types of nuclear facilities: national labs, start-ups, operating plants. This time, the leader from DOE was Suzie Jaworowski, senior advisor to the DOE Office of Nuclear Energy. Here (hopefully) is a direct link to video of the meeting on the DOE Nuclear Facebook page
https://www.facebook.com/NuclearEnergyGov/videos/215074865735271/

Hype or real?
Now, first of all, I would be happy even if this new look by DOE were only hype. I am happy that the the government is holding and co-sponsoring events like the Millennial Nuclear Caucus. Previous administrations tended to act as if nuclear power were some sort of embarrassment. The current DOE Facebook page and the nuclear-positive events show a change in attitude.

However, if you go to the video of the Texas meeting on the Facebook page,  you will see Rod Adams ask a question that he admits puts Suzie Jaworowski "on the spot."  (Move the slider to about 1:02) To paraphrase Adams's question: This is all very good, but the DOE budget proposal has less money for nuclear for next year than it had for this year.  Is DOE really going to be able to support nuclear?

Side note:  Optimism, pessimism, realism  and everything in between before the official start of the Advanced Reactor Summit V is Rod Adams post which includes his comments on the Millennial Caucus meeting.

What was Jaworowski's answer?  Since the budget isn't totally set, the answer couldn't be totally set either. Jaworowski answered that DOE is focusing on its priorities. High priorities include keeping the existing fleet going, and keeping the pipeline of future projects underway. There are also plans for public-private partnerships, with government and private money leading to innovations.

Policy or money?
You might say Jaworowski gave a standard-issue answer, and maybe it was.  But I notice the nuclear group at DOE running events, making videos, posting to FB, and I am encouraged.

The federal government has been running immense deficits for years, and the Republicans are the party of "small government and decreased government spending." Therefore, budget cuts were inevitable, from both a practical (deficits) and policy (Republican) point of view.  Considering that budget cuts will be coming, the new pro-nuclear initiatives of the current administration are very welcome.

In other words, if the major role of the government is to spend money, then things are looking bad.  If the major role of the government is to set policy, then things are looking better.  I think this administration's policies will be pro-nuclear. I believe these policies will have an impact.

I am well aware that support of energy initiatives usually requires both policy and money.  I know money/policy is not a simple either-or.  However, setting policy is the first step.

If you look at Rod Adams post (linked above) you can see a somewhat more pessimistic evaluation of the future of nuclear. I'm not so sure of myself as to say he is wrong.  And he isn't completely pessimistic, either. Maybe I am just an optimist.  Still, I am optimistic about the DOE initiatives.

Only time will tell.

The Oil-filled Grid: Communications

Early January Nor'Easter
Wikimedia, NOAA

Oil on the Grid

About two weeks ago, I wrote a blog post The Northeast Grid and the Oil. This described our early-January polar weather, and how Northeastern power plants could not get enough natural gas in the below-zero weather. Homes had priority for natural gas delivery, and plants that could use oil switched from natural gas to oil.

As a matter of fact, the oil stocks were also getting depleted.

I want to update the cold-snap story with some other posts. The general public doesn't read my blog, so I did some outreach. I wrote an op-ed about the grid for my local paper, the Valley News.  The op-ed was printed on the front page of the Sunday Perspective section on January 28, and has been shared around 200 times on Facebook. Oil Kept the Power Grid Running in Recent Cold Snap.

Why were people so interested in the article?  Because a secure electric supply is an important part of personal safety during extremely cold weather.  Most home furnaces require electricity to spread the warmth into the household. People who have chosen heat pumps are also dependent on reliable electricity.

Nuclear plants and pipelines and controversy, oh my!

There were more articles on the situation, of course, not just mine.  Actually, I think there were too few articles.  Nearly running out of oil when you can't get gas---this can be a major deal during severe winter weather! I will point out some interesting articles, and I hope that people who read this will send links to a few more.

Rod Adams post described the "sobering statements" made by the grid operator about oil supply, and the weird statements made by nuclear opponents.  (Pilgrim should have shut down before the storm? Really?) He shares some graphics from ISO-NE on the weak performance of solar panels during the days of the crisis.  He also discusses Pilgrim going off-line, and whether that could have been prevented. As usual, his post has an active and informed stream of comments. Performance of the New England power grid during extreme cold Dec 25-Jan 8, at Atomic Insights blog.

Meanwhile, over at Forbes, several columnists were commenting on the situation.
Jude Clemente wrote What Happens When You Don't Build Natural Gas Pipeline
David Blackman wrote Amid Deep Freeze, New Englanders Can 'Thank' N.Y. Gov Cuomo For Their High Energy Bills
Christopher Helman wrote Natural Gas Demand Hits Record As Cold Bomb Targets Northeast

Over WBUR radio, Bruce Gellerman has a fascinating seven minute segment on how the power plants actually operated during the cold snap, including an interview with a manager of a peaker plant that runs about 800 hours a year. Do We Need More Natural Gas Pipelines?

There's a lot of controversy built into all these articles. The role of nuclear.  The need (or not-need) for more natural gas pipelines. Will new emissions regulations make handling the next cold snap much harder? Did renewables make a great contribution during the cold snap?  Or not?

The Electric Supply

A steady electric supply is hugely important to winter safety. In my opinion, it should not be such a subject of controversy.  My hope is that  reason will prevail, and we will have the nuclear plants, pipelines and energy security that we need.

Update: FERC Acts to Support Reliability

Secretary Rick Perry

The Energy Study 

In April, Secretary of Energy Rick Perry announced that he was requesting a study about whether today's electricity markets are doing an adequate job in terms of providing grid reliability, reliance and stability. Under most circumstances, an announcement of such a proposed study would cause everyone to fall asleep. Nowadays, though, this proposed study was considered revolutionary and perhaps obscene.

The general weltanschuang (German used quite deliberately) of studies under the last administration did not encourage looking at questions of mere grid reliability.  The only allowable questions seemed to be: "How can we get more renewables (and gas backup) on the grid?"  When Secretary Perry asked for a reliability study, he set the natural gas industry into a state of shock. They had a pretty good idea of what such a study would show. They didn't like it one bit.

If you think people were upset that this study was performed at all, you can imagine the anger when it showed the value of base-load plants. The DOE study showed a need to increase grid reliability by supporting base-load plants that can store fuel on site. Yes, that means coal and nuclear.

The FERC Rule-Making

After a FERC study is completed, if it shows a need for a change in the electricity markets, the next step is FERC making a rule for the change. FERC starts this process by issuing a Notice of Proposed Rulemaking, (NOPR). FERC recently issued an NOPR for the Grid Resiliency Pricing Rule, based on the DOE study.
Here's the link to the proposed rule: https://www.energy.gov/sites/prod/files/2017/09/f37/Notice%20of%20Proposed%20Rulemaking%20.pdf

The bulk of the rule is on page 11: (FERC shall)...issue a final rule requiring its organized markets to develop and implement market rules that accurately price generation resources necessary to maintain the reliability and resiliency of our Nation's bulk power system.  The proposed rule allows for recovery of costs of fuel-secure generation units frequently relied upon to make our grid reliable and resilient. 

Update: The easiest way to comment on this rulemaking is to use the Nuclear Matters link Urge Policymakers to Protect Nuclear Energy.  You fill out your contact information and click :Submit. There is a pre-written comment on the form, but you can edit it as you wish.  Click the link and submit your comment today or tomorrow!  Time is short. October 23 is the last day for comments.

Beating Back the Attacks

There are so many things to say about this rule-making!  And so many things have been said!  You would think this is the first NOPR that FERC had ever issued.  It isn't.  Here's a brief run through the proposal and the attacks on the proposed rule.

The DOE study:  
I recommend Rod Adams excellent blog post of August 24, Long awaited DOE report on electricity markets and reliability. The post includes links to the study itself.

Is this rule-making legal?  Is it rushed?  
Yes it is legal. Once again, Rod Adams has a good overview: Rick Perry Directs FERC to Complete Final Action on Resiliency Pricing Rule in 60 Days. In Utility Dive's article Powelson: FERC 'will not destroy the marketplace' in cost recovery rulemaking, Acting FERC Commissioner Neil Chatterjee explains that the new rule will have a record, docket, and analysis. Just like the rest of the rules. In the same article,  Scott Hempling, a Georgetown law professor, said there is no statutory obligation for any particular period of time for comments.  My own understanding is that 60 day and 90 day comment periods are pretty standard.

Isn't this "rule" kind of vague?
Yes. It is slightly more vague than usual.  According one of the articles in Utility Dive, energy lawyers say that the vagueness of the rule may give more room for industry input on the final product.   But frankly, it is not out of line with other FERC rule-making.  For example, in FERC 1000, one of the most complex and contentious parts of the rule is stated pretty simply: Local and regional transmission planning processes must consider transmission needs driven by public policy requirements established by state or federal laws or regulations.  FERC rarely tells system operators exactly what to do: FERC directs them to "consider this" or "allow for that" etc.  Kind of vague, but then again, they are the system operators and they have their own constraints.

Is FERC Fuel-Neutral, Part 1:
Former FERC Chairman Jon Wellinghoff said that a proposed rule supporting baseload plants "would blow the market up."  At FERC, according to Wikipedia, Wellinghoff's three priorities were integration of renewables, energy efficiency, and demand-side energy practices, such as real-time pricing.  Wellinghoff didn't mention reliability in his priorities as FERC chairman. I also don't notice that anybody blamed him for supporting the expansion of renewable energy. When some people claim that FERC must be "fuel neutral," they apparently don't mean "treat renewable installations like other power plants."

Is FERC Fuel-Neutral, Part 2:
FERC doesn't like rules that say: Gas plants shall or coal plants shall. For a FERC rule, don't actually name the type of plant.  The new proposed rule doesn't name types of plants.  Any plant that can store 90 days worth of fuel qualifies for recovery of costs of fuel-secure generation units.  FERC and grid operators have many rules for how plants get paid: there's the whole business of ancillary services.  Grid operators pay for ancillary services (reactive power, quick dispatch) even though only certain types of plants can provide these services.  If FERC determines that "fuel security" is important for grid reliability, it can make sure that plants that are able to supply the fuel-security service are paid for that service. This is not revolutionary.

And the final question: Is this going to "blow up the markets"?
There is no market to blow up.  On Friday, Utility Dive quoted Rick Perry saying: There is no free market in electricity. I have been saying this for a while.  I recommend an article by Travis Kavulla, of the Montana Public Service Commission. His article in American Affairs  is titled: There Is No Free Market for Electricity: Can There Ever Be?  It's a good summary of how nobody can "blow up the market" because there really isn't a market.

Finally...

Actually, there is no "finally" because FERC is beginning the rulemaking process, and we won't see the final rule for perhaps 90 days.  That is, 60 days for comments, some more time for putting the final rule together.  But in another way, I can say:

Finally, the government is paying attention to the reliability of the electric grid!

Update: Not WARNing at V.C. Summer

June 9, 2017 photo of Summer construction
SCEG photo

Update:

SCEG withdrew its original petition to abandon the Summer Project, but this was only to facilitate government review of the petition.  After withdrawing the petition,  SCANA held a press conference and re-iterated its plans to abandonn the nuclear project.

Meanwhile, knowledgeable people have emailed me that the construction workers at Summer are probably not covered by WARN, but employees of Westinghouse and Fluor probably are covered.  I am not a lawyer, and I am merely repeating what they said.  It is probably true, however.

None of this is good news for the project or the workers.


The Stop-Work at Summer

At the V.C. Summer construction site in South Carolina, a stop-work order was issued by the plant owners. Within hours, thousands of people had to turn in their badges and leave. There is simply no way to sugar-coat this story.

Actually, there are at least two stories here: the first story is about why V.C. Summer was cancelled. That story has been widely discussed.  The second story is about how the  layoffs happened, and their legality (or not).  This story has not been covered very much. It will be covered here.

At the end of this post, I have an annotated list of resources  about the first topic, why Summer was cancelled.

The Human Cost

On Facebook, one friend wrote about how difficult the Summer closure was for his family.  I will not quote his statements here, but his post made me feel very sad for all the hard-working people at Summer.  I mean I was feeling bad already, but his post made me feel worse. The cancellation of Summer had a huge human cost. You can't lay off 5600 people without immense pain, and immense ripples in the community.

It is too mild to say that the layoffs themselves were not handled well.  In my opinion, the way the layoffs were handled was certainly immoral, and may have been illegal.  In this article, Fired nuclear construction workers crash State House, workers said they had "no warning from superiors before being let go about lunchtime Monday." In a video at WLTX, workers said "We met at our lunch location and they read these letters to us...."

It's impossible to get numbers, but most sources say 5000 people were affected by the equivalent of letters-read-at-the-lunch break.  In the video above, a worker says that he has never heard of so many people being laid off at one time.

My first reaction was that I thought that such a layoff was simply illegal.  A federal law, the WARN act, requires employers to give advance notice of large layoffs. Nolo.com has good article on the WARN act and South Carolina. (Nolo sells consumer-oriented legal books and software.)

WARN and the big boys

WARN covers employers who have at least 100 full-time-equivalent employees.  If 50 or more employees are laid off at one job site, WARN requires sixty days notice. (You can read the fine print at Nolo.com)

On Facebook, I said that I thought the short warning of this layoff was probably illegal. One person commented that I was making unwarranted assumptions.  In his opinion, a big employer would read the laws and obey them. Okay.  Basically, he was right about the biggest of the big boys on the job site: SCEG. According to this video and article from WISTV, SCEG notified the state of 615 layoffs at Summer (layoffs of their own employees), giving the requisite 60 days notice according to the WARN requirements.

However, they gave Westinghouse no such 60 days notice, because Westinghouse is a contractor, not an employee. Westinghouse immediately "furloughed" 870 employees, according to the Pittsburgh Post-Gazette.  However, these employees have no reason to believe that they will be called back from  this "furlough."  According to Post-Gazette article, a field engineering manager at Westinghouse has sued Westinghouse for violating WARN. He is attempting to achieve class-action status with his lawsuit.

SCEG covered its own employees, but employees of large and small subcontractors seem to be subject to the largest sudden layoff that I have ever heard about.

WARN and the not-so-big-boys

Westinghouse, with hundreds of employees on this project, is one of the big boys. Nevertheless, it seems to have issued as quick a lay-off notice as might have been issued by any local supplier of portapotties. Westinghouse is now being sued.  I suspect that many of the other contractors may also be sued.

Chess Pawn, Wikipedia

Opening Gambit or Closing the Door?

Why did the layoff happen in this sudden way?  It saved some money for SCEG, until they get sued, of course. It devastated towns and businesses and gave locals a pretty grim idea of what their utilities think about their welfare. Looking at a project that is over budget by billions of dollars, I don't think saving two months worth of salaries was the entire motivation. Decades of bad feelings are likely to arise from the sudden layoffs, and two months payroll was saved? To me, it doesn't make sense.

That is just my opinion, of course, but there it is.  Sometimes, dramatic events are the opening moves in fierce negotiations.  "Now that I have  your attention...."

Sometimes, of course, dramatic statements are the closing moves: "Look, I mean it, and nothing you can do will change my mind." However, that sort of statement often comes after a long fruitless negotiation.  Not always, but usually.

Games people play

If this were a chess game, I would say: This is more likely to be an opening gambit than a closing statement.

But wait, V.C. Summer is not a chess game!  In a chess game, the pawns are little pieces of plastic or wood or ivory.

At V.C. Summer, the pawns are more than 5000 real live people.

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Addendum:  Why V.C. Summer was cancelled.

I recommend three excellent blog posts on the reasons for the project cancellation.

In 2016, Will Davis wrote at ANS Nuclear Cafe: Nuclear Plant Costs-- A Look Back and Ahead 
This post describes the cascading effects of various types of cost overruns, including changes to the specifications, delays, and incomplete planning.

On July 31, 2017, Dan Yurman at Neutron Bytes wrote Utilities Pull the Plug on AP1000s at V.C. Summer.  He looks at the cost overruns, but also notes that Santee Cooper refused to go along with a plan to complete just one of the reactors.

On August 1, 2017, Rod Adams wrote: Tragic day in South Carolina as 5,000 people lost their jobs at VC Summer. Rod's post concentrates on design changes, specifically the Aircraft Impact Assessment Change.  There are 120 comments on that post.  Many of these comments are from very knowledgeable people.

Atomic Insights features Campaigning for Clean Air

Yesterday, my book Campaigning for Clean Air was featured on Rod Adams's Atomic Insights blog: How to Campaign for Clean Air While Eating Plenty of Brownies.

Here is a taste of what Rod had to say:

Like the best how-to books, Meredith’s little instruction book for budding nuclear advocates is punchy, filled with practical exercises, gives step by step instruction with options and provides pointers to additional sources of help and information. It’s well organized and motivating; there are times when you want to simply put down the book and take one of her recommended actions to see how it works and feels. 

Read the entire post

Closing Diablo Canyon would be a loss for California

March for Environmental Hope
In San Francisco June 24
From Mothers for Nuclear Facebook page

Diablo Canyon and Agreements

Closing Diablo Canyon would be a great loss for California air quality and grid reliability.  To be blunt about it: What are these people thinking?  

Well, they aren't thinking.  They are kicking the can down the road.  My post at Northwest Clean Energy blog, Closing Diablo Canyon a big loss for California, gives an overview of the PG&E agreement with anti-nuclear groups, how they are kicking the can.  I encourage you to read it.  

What are these people thinking?

The Southern California Grid has a rolling-blackout plan, even now, with Diablo operating.  According to the San Diego Union Tribune  "natural gas curtailments" could interrupt electricity service for as many as 14 days this summer.   Basically, gas supplies are constrained: in California, part of the constraint is the aftermath of the massive Aliso Canyon gas leak.

So, with California ISO considering its rolling black-out planning and gas curtailments, PG&E plans to close Diablo Canyon!  How did California get into such a fix, anyway?

Part of the answer is about requiring unrealistic renewable energy standards, and another part is having anti-nuclear groups at the planning table for the agreement, with pro-nuclear groups excluded (unless they are unions).  

Well, hey, I'm used to pro-nuclear groups being excluded.  When Jaczko met with  "citizen volunteer groups" in Brattleboro a few years ago, the Energy Education Project that Howard and I founded was not considered a citizen's group.  Howard and I sat in the peanut gallery, not at the table. 

The history and the actions

To understand the history of the Diablo Canyon situation, read my post at Northwest Clean Energy Blog.  Also, watch quick videos of the California Lands Commission hearing at Rod Adams blog post:  Showing Up and Speaking for Diablo Canyon in California.

To learn about actions you can take for Diablo Canyon, go to the Save Diablo Canyon or Californians for Green Nuclear Power websites.  These websites have links for donations, signing petitions, and for breaking news.  There are several other groups also active for Diablo Canyon. For more links, visit my blog post Diablo Canyon and What To Do About It.

Actions are more important than history. 

Patty O'Donnell at the Department of Energy Summit on Nuclear Power Plants

A lilac 

Department of Energy Summit on Improving the Economics of Nuclear Power Plants

On May 19, the Department of Energy held a summit on Improving the Economics of America's Nuclear Power Plants.  The four-hour meeting included many distinguished speakers, including Department of Energy Secretary Ernest Moniz, Senator Cory Booker, and more.  You can watch the entire meeting at this link.

A major purpose of the meeting was to find ways to keep America's nuclear fleet running.  Scientific American reported on the meeting. They quoted Secretary Moniz: "We are supposed to be adding zero carbon sources, not subtracting or simply replacing (them)..." The Scientific American article features a picture of Vermont Yankee. The Bloomberg article on the meeting has the following title -- Moniz: Closing Nuclear Plants Poses 'Huge Problem'.

Vernon's own Patty O'Donnell spoke at this meeting.  O'Donnell described the human impact due to Vermont Yankee closing.  If you move the video slider to the 2:39 mark (2 hours and 39 minutes into the four hour video) you can watch her ten minute talk.  It was an important and moving description of the effects of the plant closing. Her talk showed a part of the human face of "why we need nuclear energy."

Adams blog focuses on O'Donnell's talk

Rod Adams' Atomic Insights blog post about the meeting focused on O'Donnell's talk. His post is Real people are harmed when other people decide to close nuclear plants.  I encourage you to read it, and also to read the comments. Adams blog gets interesting and knowledgable comments.

Adams also made a YouTube of O'Donnell's talk.  He has it posted on his blog post, and I am sharing it here.  Big THANK YOU to Rod Adams!  A ten-minute video is so much more appealing than a four hour video. I share his video below.





********
Two little notes:

I used a picture of a lilac on this blog post because a lilac is blooming outside my window now, and because I imagine myself handing a bouquet of flowers to Patty O'Donnell.

My own major blog post on this subject is Circles of Pain around Vermont Yankee Closing.

Fired or Laid-Off?

The Carnival
Almost every week, there's a nuclear blog "Carnival"--a compendium of important nuclear blog posts from the last week.  This week Rod Adams hosted Carnival 308 at Atomic Insights.

(I have hosted the Carnivals on many occasions. For example, Carnival 304 was at Yes Vermont Yankee.)

What "Laid-Off" actually means
My recent post on Cinco de Bye-O is one of the posts in Carnival 308. As customary, I sent Adams a link and a proposed  "blurb" about the blog. (The Carnival hosts can edit what they receive, but it is polite to send them something so they don't have to start from scratch, summarizing all the posts.)

Adams edited my description, and I think his edits and comments are worth sharing.  He changed the words "laid-off" to the word "fired."He didn't just do this in a vacuum. Here is his comment on the change.

Aside: I changed the submitted description of the article to use “fired” instead of laid off. Too many people have forgotten that “lay offs” was originally intended to describe a temporary condition in which employees were asked to stay home while waiting for work to return with the season or the end of a sales slump. The 100 people who left the premises of Vermont Yankee on May 5th have no prospect of returning. Their plant’s productive capacity has been destroyed. End Aside.

 I appreciate Rod Adams "Atomic Insights"  of all kinds.

Read the Carnival!
I encourage you to read the Carnival this week.  There are links to posts (and comments about the posts) on interim storage, decarbonizing Britain,  the environmental impacts of fracking, an e-book edition of the book Nuclear Firsts, innovative power plants, and more.  

I think that reading the Carnival is the fastest and most pleasant way to keep up with nuclear industry news.  Read it this week.

Nuclear Blogger Carnival 298, at Yes Vermont Yankee

Once again, we are proud to host the Carnival of Nuclear Energy Bloggers, right here at Yes Vermont Yankee. The Carnival is a compendium of nuclear blogs that rotates from blog site to blog site, and it is always a pleasure and an honor to host it.

Let's start with blog posts directly about nuclear energy.  Nuclear power is moving forward, world-wide, despite opposition.

Fukushima Updates--Leslie Corrice

Takahama unit #3 restart

Takahama unit #3  has restarted, and this has spurred  numerous FUD-based press reports. The main reason is the use of MOX fuel bundles in 15% of the core. The postings also focus on allegedly inadequate emergency planning, the lack of a national nuclear waste disposal option, the inference that the only benefit of nukes is making money, and citizens claiming a violation of their human rights.

Neutron Bytes - Dan Yurman

SMR developers form advocacy group in DC

Leading developers and potential customers of small modular reactors (SMR) have formed a consortium, called SMR Smart, to advance the commercialization of the innovative light water reactor designs.

Also, developers of advanced nuclear reactors are pleased with their DC summit meeting held last week.

Next Big Future--Brian Wang

China plans on at least 110 Nuclear Reactors by 2030
Many will be 1400 MW or larger.  The Chinese supply chain is well in place.

Lightbridge is making progress on improved nuclear fuel
This fuel should increase energy production by 17% in existing reactors.

Bad air quality in Japan from lack of nuclear energy and air pollution in China
Hopefully, reactor restarts in Japan will ease the problem. But right now it is pretty bad, with 60% of monitoring sites in Japan above the particulate pollution standard. 

Neutron Bytes - Dan Yurman

French gov’t struggles to overcome a panic attack about UK’s Hinkley Point nuclear power project

French energy group EDF has postponed giving final approval for construction of the twin 1600 MW Areva EPRs in Somerset, UK. The current cost estimate, which is a work in progress, is pegged at between $18-20 billion.

The move to delay the final investment decision is said to have been made as a result of concerns within the French government and by investors about whether the financing was firmly in place for the huge project and whether costs could be contained over a decade long period of construction of the reactors.

Next:  Can renewables replace fossil fuel and nuclear?  Well, no. Here are some posts on that issue.

Forbes--James Conca
Exxon Believes That Global Use Of Oil And Gas Will Continue To Increase
The largest fossil fuel company in the world predicts our energy mix won’t change a whole lot over the next 25 years. In fact, Exxon Mobil projects that oil and gas will actually increase by 2040, even as coal decreases a bit. This unfortunate future stems from the age-old conundrum of trying not to eat sugar when your pockets are full of candy. The Earth has so much fossil fuel, and it has become so cheap to extract it, that it defies logic to think that humans will not keep burning it as their main source of energy.

Northwest Clean Energy--Meredith Angwin
Reality: Less nuclear means more natural gas
Vermont Yankee and San Onofre closed recently. Natural gas-fired plants took over and made the electricity that replaced the nuclear outputs.  Meanwhile, paper after paper, and study after study, trumpet the coming world of renewables.  These are just studies.  Though renewables maybe would'a, could'a, should'a replaced the closed plants, the reality is that less nuclear means more natural gas.

Atomic Insights--Rod Adams
Another day, another model “proving” capabilities of weather-dependent power

The National Oceanographic and Atmospheric Administration (NOAA) and the Cooperative Institute for Research in Environmental Sciences (CIRES) jointly published a paper about a new model they've created to simulate using weather-dependent energy sources to reduce greenhouse gas production from the US electricity sector. 

Their scenarios include generous amounts of natural gas, a nationwide HVDC transmission network,  and other conditions. Some news outlets have published headlines citing  the large reduction without noting the required conditions. Shocking, isn't it?

The Atomic Show (podcast)---Rod Adams

Atomic Show #249 - All Electric America by S. David Freeman and Leah Y Parks

Freeman has been actively doubting the value of nuclear energy since the mid 1970s. He's now in his 90s. Leah Y Parks is a writer who earned an MS in environmental engineering and has some experience in developing water infrastructure projects. She, like Freeman, believes that wind, solar and water can do it all, even if all energy now supplied by burning fossil fuels is converted to electricity.  The conversation is civil, even though the participants have unresolvable disagreements. 

Yes Vermont Yankee--Guest Post

Overreach at the Attorney General's Office: Guest post by Deborah Bucknam

In this case, strong-arm tactics are being used to promote renewable use, whether people want it or not. Recently, the Vermont Attorney general's office announced that they were investigating Annette Smith for possibly "practicing law without a license." Ms. Smith is a prominent anti-wind advocate.  In this guest post, Vermont lawyer Deborah Bucknam explains that the preposterous charge will likely be thrown out. Nevertheless, the charge will  hamper free speech and encourage wind developers. 

Updated: Overreach at the Attorney General's Office: Guest Post by Deborah Bucknam

I need to update this post with a link:

As described in the blog for Vermonters for a Clean Environment, the complaint about Annette Smith originated with David Blittersdorf, a wind developer in Vermont. 
https://vermontersforacleanenvironment.wordpress.com/2016/01/31/i-represent-david-blittersdorf/

Overreach at the Attorney General’s office 
By Deborah T. Bucknam, Esq.

Vermont’s Attorney General has filed a complaint against Annette Smith, the activist who helps Vermonters opposed to Industrial Wind, navigate the administrative jungle that best describes the Public Service Board proceedings. I have represented folks opposed to Industrial Wind at the Public Service Board, and the hearings are overrun by lawyers—most of whom favor the government’s and the developer’s positions on Industrial Wind. Neighbors opposed to an Industrial Wind project face a phalanx of government and industry lawyers in a proceeding that is costly, time consuming and often confusing. In other words, the fix is in.

Now the Attorney General is siding with Vermont’s large law firms and big lobbyists to deprive opponents of Industrial Wind the advice of a person who knows the intricacies of the proceedings and can help those who cannot afford the high priced lawyers the developers can. And make no mistake: even though this is a preposterous charge, and will likely be thrown out, its purpose will be fulfilled: to chill anyone’s free speech rights who dares to question the powerful in Montpelier.

“Practicing law without a license” is a hoary concept left over from the medieval guilds where skilled tradesmen (including lawyers) sought to keep out competition. It was revived in the early 20th century when the newly organized Bar attempted to persuade legislatures to define the practice of law and regulate it—to the Bar’s advantage. Legislators were wary of such a regulatory scheme, so the effort waned until the Great Depression, when lawyers’ incomes plummeted, and the organized Bar launched a new effort to keep out those who were in competition for their services. This time the Bar sought the help of the Judiciary, which took up the cause. That is where it stands today: the unauthorized practice of law is regulated in large part by the Judiciary. Over the years, lawyers targeted different groups: realtors, bankers, and investment advisors, with varying success. The reason for this effort was supposedly to protect consumers from service providers who did not adhere to the strict professional conduct rules of the Bar. However, with the advent of strong consumer protection statutes and competition among providers, this “protection” is mostly a red herring.

The concept of unauthorized practice of law is so vague as to call into question its constitutionality. The practice of law is, according to the Vermont Supreme Court, "the rendering of services for another involving the use of legal knowledge or skill on his behalf -- where legal advice is required and is availed of or rendered in connection with such services.” Under that standard, hundreds of public servants in Vermont provide “legal advice”—providing information about relevant statutes, procedures and regulations---to the public and to Vermont attorneys smart enough to get the information directly from those in the know at state agencies. Yet these public servants will not –and certainly should not--be prosecuted. Only Ms. Smith, who provides similar information to those who cannot pay for those high priced lawyers is prosecuted by the Attorney General. This is precisely the constitutional issue: a rule violates the Due Process clause of the constitution because it is too vague to put the public on adequate notice as to when a violation occurs, and it opens the door for selective prosecution—exactly what has happened here. The Attorney General’s action appears to be an effort to silence opposition to Industrial Wind, and to help the large Burlington law firms and their clients to keep from having to deal with pesky Vermonters who oppose their clients’ projects.

Vermonters are being strangled by government overreach. The Attorney General’s action is a disgraceful example. If you don’t agree with the powerful and well-connected in this state, then just shut up, or you may be the target of the Government and its unlimited resources.

---

About the Author

Deborah Bucknam, Esq. has practiced law for 37 years, and has a private practice in St. Johnsbury, Vermont

-----

About the post

In the last two weeks, opponents of industrial wind have rallied in Vermont, and the Vermont administration is beginning to "investigate" them.   Below is a brief summary and history.

A bill against industrial wind

Two Vermont legislators introduced a bill to ban industrial wind on our ridge lines.  They held a press conference in Montpelier on January 21: the press conference was attended by many supporters.  The supporters wore green vests and cheered for banning industrial wind.  

The Ethan Allen Institute (my Energy Education Project is part of the Institute) made made a three-minute video of the highlights of the press conference.  Ethan Allen Institute posted a blog post with the video, and Rod Adams posted about the conference at his blog: Vermonters Say They Want Industrial Wind to Go the Way of the Billboard. Both posts have lively comment streams.  I have also posted the video at the bottom of this post.

The Administration strikes back

 The press conference and the Ethan Allen Institute post took place on January 21, 2016. Perhaps purely by chance, on January 22, the Vermont Attorney General opened an investigation into whether Annette Smith, the highest-profile anti-wind advocate in Vermont, is "practicing law without a license."  This was reported in a VtDigger article by Mike Polhamus on January 23: AG's office investigating complaints against Annette Smith, anti-wind advocate.  As Polhamus points out: this is a charge with penalties left entirely to the court's discretion.  He also quotes Ms. Smith: "I believe this has the potential to shut down my organization of 16 years. It clearly falls under the definition of harassment.”

There are (at this writing) 147 comments on the Digger post. The vast majority are in support of Annette Smith. An early comment was written by Peter Galbraith, a former Senator in Vermont (and a Democrat). A short quote: "Annette Smith is a person of integrity who has helped the weaker party in what would otherwise be a very uneven contest. This investigation will have a chilling effect on all citizen advocates."

This post:

I wanted to write something really powerful about this issue: about the environment, about freedom of speech, about government harassment of dissenting views, about crony capitalism.  Then, to my great relief, I received this press release from Deborah Bucknam in my email inbox.  I have never met Ms. Bucknam, but she said it all, much better than I could.  Thank you, Ms. Bucknam. 

 Video by Ethan Allen Institute

Podcast and my book

Podcast and my book

Rod Adams

Last night I was on the Atomic Show podcast, hosted by Rod Adams.  Here's the link: Atomic Show #250---Being nice nukes.   My fellow guests were Steve Aplin of Canadian Energy Issues, Gwyneth Cravens, author of Power to Save the World, and Bob Apthorpe, a nuclear safety professional who is most well known as @arclight on twitter. We had a fine conversation on the nuclear energy outlook worldwide.  

For me, some of the conversation was very special.  I have written a book Campaigning for clean air: secrets of pro-nuclear advocacy and community.  The draft is complete, but the book is still being reviewed by various people.  

Two of those people happened to be on the podcast with me:  Adams and Cravens.  At the beginning of the podcast, Adams asked me why I mentioned my blogs but not my book.  Good question indeed!  I don't know the answer to that one!

Meanwhile, people commented on the book (with praise) and asked me questions about it.   Adams and Cravens said very nice things. I was blushing.  Luckily, you couldn't see me.

I hope you will listen to the podcast.

Pilgrim, Fitzpatrick, Rod Adams, and The Boxer

The Double Shock

Yesterday, Rod Adams wrote about the double shock of Pilgrim and Fitzpatrick closing.  It was a terrible set of events. We need every nuclear plant to keep operating.  We need them for their clean reliable power, for their ability to supply power without greenhouse gases and nitrogen oxides, for their ability to supply power during polar vortexes and other fossil-fuel supply crunches.

Adams said this better than I can, in the post
Deeply troubled by FitzPatrick and Pilgrim announcements. We need their clean electricity production to continue

A long time ago, I did a post: I am not Spock, at the American Nuclear Society blog. In this post, I wrote that I am not Spock.  I am a person with emotions.  I am committed to nuclear energy for the sake of my children and grandchildren.  This is an emotional commitment, as well as a logical energy choice.  I am having a deep emotional reaction, a reaction of grief, to the closing of these two plants.

The Serenity Prayer

Adams post includes his thoughts about the Serenity Prayer:

God, grant me the serenity to accept the things I cannot change,
The courage to change the things I can,
And the wisdom to know the difference.

I value the serenity prayer, but I don't completely follow it.  If I try to change something, and I don't succeed, was I therefore unwise? If I tried to make something good happen, but it didn't happen, was I lacking in wisdom, because the thing I tried to accomplish ended up being a "thing I cannot change"?

On the other hand, when a friend called two days ago to tell me that her cancer was no longer in remission, I clung to the serenity prayer. "I cannot change this. I cannot change this.  I can only accept it.  I can only do one thing: keep being her friend, whatever that will mean in the future."

Showing up and paying attention

This is the mantra that I use about my activism. For some issues, I find it more powerful than the serenity prayer.

Part of my comment on Adams blog post:

I personally find this mantra more helpful:
– Show up
– Pay attention
– Tell the truth
– Don’t be attached to the consequences.

In this mantra, when the consequences are not what I would like, I tell myself “Well, I did the first three steps” as opposed to “I can’t tell the difference, can I?” And I can say: “Oh well, the fourth one is always the hardest, but I did the first three.”

The Boxer

I decided to head this post with Simon and Garfunkel's The Boxer. I have been listening to it, somewhat compulsively, in the past few days.

The Boxer "carries a reminder," he carries a scar, from every blow that hurt him. He has been hurt so badly that he wanted to quit, hurt so badly that he said he would quit.

But The Boxer doesn't quit.

The last line is:
"But the fighter still remains."

Thank you

Thank you to Rod Adams for his posts and his courage.  Thank you to everyone who works in the nuclear industry, giving us clean power and clean air.  And thank you to everyone who defends the industry.

The fighter still remains.

Updated: Nuclear Blogger Carnival 285, Here at Yes Vermont Yankee

Once again, we are proud to host the Carnival of Nuclear Energy Bloggers, right here at Yes Vermont Yankee.  The Carnival is a compendium of nuclear blogs that rotates from blog site to blog site, and it is always a pleasure and an honor to host it.

I am happy to update it with new posts…and unhappy to update it with the news that the Fitzpatrick plant will close.

Nuke Power Talk -- Gail Marcus

Scary Energy Scenarios: My Real Fears on Halloween.

At Nuke Power Talk, Gail Marcus reflects on the Halloween holiday and conjures up futures that are scarier than ghosts and goblins.  When short-sighted policies and misinformed views dominate energy decisions, these futures can go from being scary to--being scary and being real.

Salaries by Degree Field (Update---new post)

In another blog from Gail Marcus at Nuke Power Talk, she reports on the results of a salary survey by academic degree field.  Engineering fields in general ranked high, and nuclear engineering was #2 for mid-career alumni out of 319 academic fields surveyed.

Energy Reality Project--Rick Maltese

Educating a new nuclear workforce: Guest post by Beth Kelly (Update--new post0

This is a post about filling new nuclear jobs in a hypothetical growing market.  However, unless you assume that all nuclear plants in the country will close within ten years (an unwarranted assumption), you must notice that about half the workers at nuclear plants will retire within ten years.  And that leads to job opportunities for younger workers.

Audio version of Chapter 8 of Maltese's book: Energy Reality, a Necessary Renaissance (Update--new post)

Rick Maltese is writing a book he titles Energy Reality: A Necessary Renaissance. He has been posting his chapters at patreon, a crowd-funding website.  This is the first audio sample.

Atomic Insights-- Rod Adams

Several important nuclear energy developments from the Westinghouse press office

Westinghouse announced that the first two  reactor coolant pumps for their AP1000 reactor have passed all qualification tests and should arrive at the Sanmen site in China for installation by Dec 31, 2015.

The next day, Westinghouse announced that they are buying the nuclear plant construction assets of CB&I, their partner at Plant Vogtle and VC Summer.

An excellent discussion of the facts and implications, and of course, a very lively comment stream.

 Yes Vermont Yankee--Meredith Angwin (update, bad news)

Ginna continues operation, surcharges in context, and Fitzpatrick

The Ginna nuclear power plant has been received some financial relief, and will keep operating for at least another 18 months. Sadly, Entergy announced today that the Fitzpatrick plant will close (the post include links to articles about Fitzpatrick.)  In this blog post, Angwin compares the financial relief to Ginna to other electricity surcharges, including Vermont's own local "Efficiency Vermont" charges (much higher than the Ginna per-household costs) and the cost of proposed carbon taxes.

ANS Nuclear Cafe--Ted Besmann

The Power of Nuclear Energy

In this post, Besmann describes some of the economic hazards that currently face the U.S. fleet of nuclear plants.  The EPA proposed clean power rule gives less than 6% credit to emissions reduction from nuclear plants, for example. At the same time, the EPA claims that it would be worth paying  an extra $12 to $17 dollars per ton of CO2 that is not emitted.  But this monetary value is theoretical and not available to nuclear plants.

Vermont Yankee closed: the consequences were completely predictable

Vermont Yankee Closed: The Consequences were 100% Predictable

Last Monday, American Nuclear Society's blog, ANS Nuclear Cafe, featured my post  Vermont Yankee Closes: the Consequences Were 100% Predictable  The consequences were not only predictable, they were indeed, predicted.

In this blog post, I give a historical summary of many predictions, over many years. They all calculated that closing Vermont Yankee would have cause huge economic effects on the region.  They predicted the economic losses in the region would be in the multi-hundred-million-dollar per year range.

Yes. All the economists predicted hundreds of millions in losses for the local area. Nine figures. Their economic-loss predictions range from  $100,000,000 per year to over $400,000,000 per year.  Some of the differences depend on whether the economists were looking at just-Vermont, or at the tri-state region.

In other words, huge.  And these predictions are coming true.

I ask the question: why were all these economic predictions ignored?  Why was the state of Vermont so eager to close Vermont Yankee down?

Please visit my ANS post and write some comments.  Share your thoughts and share the article.

More Press for Vermont and Vermont Yankee

Okay.  I am blushing furiously.  But here are some more links….

Besides writing the article for ANS Nuclear Cafe,  I was on Pat McDonald's TV show, Vote for Vermont: Beyond the Sound Bite.  I link to the video of my interview in this blog post: Vermont Energy with Pat McDonald.

Rod Adams

But wait, there's more!  Rod Adams embedded the video on his blog, Atomic Insights.  The blog post is titled: Meredith Angwin with Pat McDonald on Vote for Vermont.  But Adams didn't just embed it: he also summarized the conversation. He especially noted McDonald's shock about the source of New England renewables.

The morning of the show, I went to the New England grid operator site and took a screen shot of the percentage renewables and the percentage-what-type-of-renewable, and brought the screen shots to the show. They were very typical screen shots, though the low demand on the grid showed a higher percentage of nuclear than might be seen at other times.  But the shocker was the renewables.  McDonald didn't expect to learn that almost half of our vaunted New England "renewable" electricity consists of burning refuse, and most of the rest of our renewable mix consists of burning wood.  (See graphics below.)

If you don't have time to watch the half-hour video, read the summary at Adams blog.

But Wait, There's More!

The ANS Nuclear Cafe blog has a feature called "Friday Matinee."  Most Fridays, they embed a video on the blog.  Yes….this Friday…the video was the Pat McDonald show featuring me.  Video: ANS Member Meredith Angwin on Vote for Vermont.

You have SO many opportunities to watch the show. You can watch the video at my blog, Adam's blog, ANS Nuclear Cafe blog.  I do hope you will watch it….

There is still more.  The ANS post about economic predictability was reprinted in the Ethan Allen Institute newsletter (I am director of their Energy Education Project).  I was on Rod Adam's panel in a recent podcast: Atomic Update.  I will be on the Common Sense radio show this coming Tuesday, October 6 on WDEV.  The show is between 11 and noon, and you can listen on line and even call in, toll-free. (The date of the WDEV show is now correct.  An earlier version of this post had an incorrect date.)

Okay. That's enough for now.  I can't blush any redder, so I will quit writing.

Monday morning fuel mix on the grid
Renewables are 7%

And here are the renewables, the 7% above
 Consists of 48% wood, 45% refuse

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