Nuclear Energy Blog Carnival 227

ferris wheel 202x201The 227th Carnival of Nuclear Bloggers and Authors has been published at The Hiroshima Syndrome.

•Click here to access this week’s edition.

Each week, a new edition of the Carnival is hosted at one of the top English-language nuclear blogs. This rotating feature of nuclear “posts of the week” represents the dedication of those who are working toward a future of energy abundance, improved health, and broadened security through nuclear science and technology.

Past editions of the carnival have been hosted at Yes Vermont Yankee, Atomic Power Review, ANS Nuclear Cafe, NEI Nuclear Notes, Next Big Future, Atomic Insights, Hiroshima Syndrome, Things Worse Than Nuclear Power, EntrepreNuke, Thorium MSR and Deregulate the Atom.

This is a great collaborative effort that deserves your support.  If you have a pro-nuclear energy blog and would like to host an edition of the carnival, please contact Brain Wang at Next Big Future to get on the rotation

Another Nuclear Design Approved by the NRC

• This week the GE-Hitachi ESBWR design received its Design Certification from the Nuclear Regulatory Commission.

• “Design Certification” is a step in the licensing process for new nuclear power plants that allows a basic design for a nuclear plant to simply be referenced in the actual licensing process for a site, theoretically speeding the process.

ESBWR - Illustration courtesy GE-Hitachi Nuclear Energy

ESBWR – Illustration courtesy GE-Hitachi Nuclear Energy

by Will Davis

Earlier this week, the US Nuclear Regulatory Commission granted design certification to General Electric’s Economic Simplified Boiling Water Reactor nuclear plant design, ending a years-long effort by GE to get design certification (called a DCA) and potentially paving the way to further new nuclear builds in the United States.

Dr. Solomon Levy mentions in his book “50 Years in Nuclear Power: A Retrospective” (American Nuclear Society, 2007) that the SBWR or “Simplified Boiling Water Reactor,” the predecessor design to the just-certified ESBWR, was begun as a design effort in the 1980s along with several other advanced nuclear plant designs. At that time, design was beginning to shift to passive safety features—those that take effect without operator action, which are included in the new design.

American Nuclear Society Treasurer Margaret Harding was with GE in various capacities for many years, and is familiar with BWR series development; she served as Fuel Engineering Leader for the ESBWR project. “The SBWR was a fully natural circulation reactor (meaning there are no pumps to move water through the core), was simpler, and thus less expensive than the forced recirculation designs that came before it such as the BWR/6 and ABWR,” she said. “The SBWR design eventually evolved into the ESBWR, which is even more simplified and has a number of both passive and active safety features.”

Harding said that there was a major push to reduce equipment and piping overall, leading to the decision to use natural circulation (the tendency of hot water to rise over cold water), but this led to the design of a wider, flatter reactor core that will require a slightly higher uranium enrichment than forced circulation BWR reactors and that may be slightly less economical from a fuel consumption standpoint. “But because fuel is such a small percent of your operating costs, that disadvantage isn’t huge,” she added.

Natural circulation BWR plants aren’t new; the Elk River Reactor, built by Allis-Chalmers (originally ACF) for Rural Cooperative Power Association in Minnesota in the late 1950s, was a natural circulation boiling water power reactor. Early problems with recirculation piping in various makes of boiling water reactors were another factor that led to the determined effort over the years to either move the recirculation pumps inside the reactor vessel and eliminate external piping (GE BWR/6, various ASEA–ATOM BWRs and the Hitachi–GE HP-ABWR) or else eliminate them entirely as in the ESBWR.

Of course, ESBWR is fully a GEN III+ plant (light water reactor with advanced safety features) in every sense of the term, with both fully passive and active core cooling features, a core catcher, a new containment, and more. GE-Hitachi has combined proven features from operating experience with a half century of boiling water reactors with advanced features in this design, which also interestingly is near the high end of available outputs with an electrical rating of 1600 MWe gross. The plant is available with either an 1800 RPM turbine generator for utilities that provide 60 Hz power, or a 1500 RPM unit for those that provide 50 Hz.

As of now, only two projects in the United States that have specified the ESBWR are active—namely, DTE Energy’s plan for a new Fermi-3 unit, and Dominion’s plan for a new North Anna Unit 3. DTE submitted to the NRC for a Combined License Application (COL) in September 2008, while Dominion submitted its COL in November 2007. Neither project presently has a planned date of completion for NRC review/issuance of the COL, however. In the case of North Anna-3, much of the delay centers on the fact that while Dominion initially selected the ESBWR, it switched reactor designs from 2010 to 2013 to the Mitsubishi US–APWR and then reverted to the ESBWR.

What’s next? Well, the next design to be certified in the United States might well be the South Korean APR1400. While the review process for this design was thrown back to Korea Hydro & Nuclear Power in December 2013 and remains officially at the “pre-application” status, a recent announcement by Korea Electric Power Company Engineering & Construction (which designs and builds Korean nuclear plants) reveals a sweeping inter-corporate contract among the major players in the South Korean nuclear industry to restart the push for US NRC design certification with actual application made by the end of 2014.

GE-Hitachi's ESBWR displays a number of highly advanced features, including a new containment, passive core cooling, and a core catcher.

GE-Hitachi’s ESBWR displays a number of highly advanced features, including a new containment, passive core cooling, and a core catcher.

For more information:

• GE-Hitachi has a great deal of information available to the public on its website. Click here to access their ESBWR page that includes specifications, illustrations, and very detailed downloadable documents.

See the GE-Hitachi Nuclear Energy press release.

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SavannahWillinControlRoomWill Davis is the Communications Director for the N/S Savannah Association, Inc. where he also serves as historian, newsletter editor and member of the board of directors. Davis has recently been engaged by the Global America Business Institute as a consultant.  He is also a consultant to, and writer for, the American Nuclear Society; an active ANS member, he is serving on the ANS Communications Committee 2013–2016. In addition, he is a contributing author for Fuel Cycle Week, and writes his own popular blog Atomic Power Review. Davis is a former US Navy reactor operator, qualified on S8G and S5W plants.  Davis is temporarily managing all social media for the American Nuclear Society.

Surface storage of used nuclear fuel – safe, cost-effective, and flexible

by Rod Adams

In August 2014, the U.S. Nuclear Regulatory Commission approved NUREG-2157, Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel. That action was the end result of several years worth of detailed analysis of the known and uncertain impacts of storing used nuclear fuel on the earth’s surface in licensed and monitored facilities.

As summarized in section 8 of the document, the staff determined that the environmental impact under expected conditions is small and acceptable even for an indefinite period of time. The analysis included consideration of a complete societal breakdown and loss of institutional control and determined that this situation would have an uncertain effect on the safety and security of used nuclear fuel, but determined that there is little likelihood that society will falter that much.

NUREG-2157 both eliminates the hold that was placed on issuing new or renewed nuclear facility licenses and it provides the technical basis supporting a decision to stop working on a geologic repository. If storing used material on the surface is acceptably safe, environmentally sound, and cost-effective for the foreseeable future, it would be a waste of resources to attempt to develop a facility using today’s technology. It is likely that technology will improve in the future. It is inevitable that the material of interest will become easier to handle as the shorter-lived, more active components decay at a rate established by physical laws.

NRC Chairman Allison Macfarlane wrote the following perceptive statement in her comments about her vote on the rule:

In essence, the GEIS concludes that unavoidable adverse environmental impacts are “small” for the short-term, long-term, and indefinite time frames for storage of spent nuclear fuel. The proverbial “elephant in the room” is this: if the environmental impacts of storing waste indefinitely on the surface are essentially small, then is it necessary to have a deep geologic disposal option?

Almost exactly right! We should ask hard questions of those who maintain that “deep geologic disposal is necessary” because “a majority of the public industry, academia, and regulators” say it is. Here are some questions worth asking:

  • Why do you think a mined deep geologic repository is required?
  • What makes it so important?
  • Where is the recorded vote on which you base your claim that it is the majority opinion?
  • If there was a vote, when was that vote taken?
  • Have there been any changes in circumstances that challenge the validity of that determination?
  • Should options besides a mined deep geologic repository be reconsidered?
  • How much will it cost each year to simply defer action into the indeterminate future?
  • From an accounting perspective, aren’t costs that are deferred far into the future worth less, not more, if they are recalculated into today’s dollars?

Those who have read Macfarlane’s full comment should recognize that she is not only the source of the “elephant in the room” statement above, but she is also the source of the assertions that the United States must continue pursuing a mined geologic repository because we have a “long-established responsibility to site a repository for the permanent disposal of spent nuclear fuel,” and she wants to make sure that the NRC’s determination that continued surface storage represents a small environmental impact for the indefinite future does not enable “avoiding this necessary task.”

Last week, I had the opportunity to ask Chairman Macfarlane if she thought that the NRC had a role in deciding U.S. policy on long-term nuclear waste storage. She explained that the only role for the NRC would be to review the license application submitted for any specific facility. The responsibility for planning and developing that facility and obtaining the funds necessary would be under the purview of a different agency.

I asked what the NRC’s role should be if no organization submits an application for a facility. She admitted that its only role in that case would be to continue monitoring existing facilities and approving license renewals or new licenses.

Congress can, and should, make a determination that the plan for nuclear waste for the indefinite future is to continue safely storing used material. It should remove the responsibility for permanent disposal of nuclear waste from the Department of Energy and put it into industry’s hands to solve. Of course, the industry will remain under the watchful eye of the already established federal regulator using procedures and processes that are already in place and continually being refined. It should make use of existing products and services, continue improving those offerings and should consider the need for facility consolidation as that makes economic sense.

Macfarlane and I also agree about when we would begin to believe that the United States can site, license, build, and operate a mined deep geologic repository, as she said:

I will have confidence in the timing when a renewed national consensus emerges on a repository for spent nuclear fuel.

(Emphasis added.)

There is no reason to suspect that a sufficiently bulletproof consensus will ever exist. Recent history has proven that it takes just a handful of people elected or appointed into the right positions to derail even the best laid plans made with strong support throughout the rest of the country.

Though Macfarlane seems concerned about the potential impact if there is a “loss of institutional control,” the controls required to ensure continued safety and environmental protection from used nuclear fuel are simple and easily implemented. As long as we do not believe that future generations will forget how to read, we can be sure enough that they will remember how to keep used nuclear fuel safely isolated.

Many people in Chairman Macfarlane’s generation—which is also my generation—probably believe at least some of the many entertainment products depicting that there is going to be an inevitable dystopia in the future. Those fictional predictions of the future might have made for good reading or viewing, but they are as useful a decision tool as any other wild fiction. Even if their fanciful dystopia becomes reality, used nuclear fuel will be low on the prioritized lists of risks.

Macfarlane has expressed some concerns about the financial responsibility associated with continued storage of used nuclear fuel. Establishing bonds or other forms of continued financial surety is a common business practice. Radioactive materials are not uniquely hazardous or even uniquely long-lived compared to other elements and compounds in common industrial service. We have learned to live with them. We have proven that we know how to protect the public from any harm. There is no reason to expect that society will forget the lessons it has already learned.

A simple financial solution would be to have nuclear plant owners establish a used fuel fund that would be as isolated from their normal finances as their decommissioning funds. The experience that we have with the current Nuclear Waste Fund shows that a tiny fee on each unit of nuclear electricity will grow into a very sizable fund if undisturbed over time. We should stop stealing the capital accumulated by such a fee to pay for other continuing government expenses and we should not fritter it away by conducting geologic studies of the depths under any region that has the proven potential to produce politically powerful majority leaders. (Nearly every state in the union has that potential given the longevity of any proposed repository program.)

In the conclusion of her seven page comment, Macfarlane included the following statement:

Finally, I note that at least one commenter has suggested that development of a repository in the U.S. has developed into a Sisyphean task. I agree that much in the national management of spent fuel and development of a geologic repository over the past decades fits this analogy.

Once again, I agree with Macfarlane’s description of the current situation associated with attempting to site a single geologic repository in the United States.

Americans must remember that we are not subjects of Greek gods condemned to continue the frustratingly impossible task of pushing a rock uphill every day just to have it roll back down at the end of the day. We are free members of a society that has the ability to make choices and to change its mind to adapt to new situations or when new information is revealed. The cancellation of Yucca Mountain through actions of a tiny group of people shows that successfully siting a repository in the United States, with its multiple interest groups and arcane procedural rules, is not possible.

The good news is that we don’t need a repository in order to operate nuclear power plants safely and to store the created residues in a way that produces negligible environmental impacts. We don’t need a government program that can be milked for assets and jobs for decades before being derailed. We don’t need to have the federal government—which means us, as taxpayers—pay the costs of continued storage; the costs are predictable and can be paid with a small fee on each unit of power generation.

Making the choice to quit now and spend our limited resources on something more useful must not be judged as unfair to future generations. Used nuclear fuel has potential value, and we can create savings accounts now that can enable a different long-term solution in the distant future when there is more general agreement that constipating nuclear energy would be a suicidal course of action for society.

As technology improves, assets build up in the coffers of responsible parties, nuclear power plant sites continue to be developed, nuclear power plant sites occasionally become repurposed, and the demand for nuclear fuel changes, future societies can change their mind. Nothing in the above plan precludes any choices for the future; the key action needed today is to stop digging the hole that currently seems to provide no possibility for escape.

Rod Adams is a nuclear advocate with extensive small nuclear plant operating experience. Adams is a former engineer officer, USS Von Steuben. He is the host and producer of The Atomic Show Podcast. Adams has been an ANS member since 2005. He writes about nuclear technology at his own blog, Atomic Insights.

ANS Webinar with NRC Chairman Allison Macfarlane

Nuclear Regulatory Commission Chairman Allison Macfarlane today fielded questions from in-person and virtual attendees at a live, unscripted 60-minute webinar on nuclear energy issues. The event—”Bloggers’ Roundtable”—was held in Washington, DC, and was a collaborative effort of the NRC and the American Nuclear Society. The webinar provided an opportunity for nuclear bloggers and social media personalities to discuss the NRC’s perspectives on a wide range of nuclear-related issues.

Webinar recording of A Conversation with U.S. NRC Chairman Allison Macfarlane

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ANS Moderator Margaret Harding noted that many questions referred to the proper purview of the NRC—such as, could the NRC take a stronger role in “promoting” nuclear energy? Should another government entity be in that business? How do you make the jargon of the trade more accessible and understandable to laypersons?

Other questions dealt with the preparations for licensing of small modular reactors; radiation regulation in light of challenges to the linear no-threshold model; rulemaking concerning post-Fukushima safety enhancements; and much more.

Questions that were more technical or required a more detailed response are to be tackled as follow-up responses here at ANS Nuclear Cafe.

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A stand-alone video from today’s virtual forum is under construction—for immediate access please tune in and enjoy the webinar recording. Thank you to NRC Chairman Macfarlane, ANS Moderator Harding, and all attendees.

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Nuclear Energy Blog Carnival 225

ferris wheel 202x201The 225th Nuclear Energy Blog Carnival is being hosted this week right here at the ANS Nuclear Cafe.  Every week, the world’s top pro-nuclear authors and bloggers submit the most popular or most important articles from that week; the selections are then compiled at one of a set of rotating sites and featured as the “Carnival.”  Let’s jump right in to this week’s significant contributions.

Nuke Power Talk – Gail Marcus

A New Path Forward?

At Nuke Power Talk, Gail Marcus discusses the recent announcement from Loving County, Texas, that they are interested in serving as a host site for the nation’s high-level waste.  This expression of interest is in line with the recommendations of the Blue Ribbon Commission, as well as with the experiences of other countries, and could, in time, help pave a new path forward for HLW disposal in the US.

Gail Marcus also published a trio of posts this week at Nuke Power Talk that capture the main points of several articles recently printed in The Guardian in the UK that attempt to explain policymakers to scientists, scientists to policymakers, and the public to both scientists and policymakers.  Particularly in the nuclear area, where the views of the public and of policymakers are so important to the future of the industry, it is worthwhile to think about such things as the different pace, interests, and influences of each of these groups.

Science and Policymaking: Part I

Science and Policymaking: Part II

Science and Policymaking: Part III

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Forbes – Jim Conca

Germans Boared with Chernobyl Radiation

While the news media would like Germans to be afraid of wild radioactive boars roaming Saxony, these boars aren’t even mildly radioactive. You’d have to eat 3,000 lbs of this “hot” boar meat to equal a single medical CT scan. Which would make meals pretty boaring.

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Atomic Insights – Rod Adams

Is it really necessary to have a deep geologic repository for spent nuclear fuel?

It’s time to give the United States nuclear enterprise permission to quit trying to site a deep geologic repository for used nuclear fuel.

Quoting Chairman Macfarlane: In essence, the GEIS [for continued storage of spent fuel] concludes that unavoidable adverse environmental impacts are “small” for the short-term, long-term, and indefinite time frames for storage of spent nuclear fuel. The proverbial “elephant in the room” is this: if the environmental impacts of storing waste indefinitely on the surface are essentially small, then is it necessary to have a deep geologic disposal option?

Good question. The answer is no.

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Yes Vermont Yankee – Meredith Angwin

Another name for methane: the Microgrid for Vermont

Vermont’s major distribution utility is Green Mountain Power, and their CEO just announced a business partnership to build microgrids in Vermont. She hopes the microgrids will ultimately eliminate  the “archaic” grid built with “twigs and twine.”  Actually, the partnership goal is to sell small, gas-fired Stirling engines, called “Smart Solar” engines, and to sell natural gas. Green Mountain Power is a wholly owned subsidiary of Gaz Metro of Quebec. Vermonters should not assume that Gaz Metro has their best interests at heart.

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Neutron Bytes – Dan Yurman

Saudis update ambitious nuclear energy plans

The Kingdom of Saudi Arabia plans to kick off a much talked about $80 billion program to shift 15% (17 GWe) of its electric generating capacity from fossil fuels to nuclear reactors.

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Next Big Future – Brian Wang

Thorium Isotope Breeder Proposed by Maglich, who has constructed four Migma Colliding Ion Beam fusion systems (with explanatory video and text)

Fusion isotope breeders can work with thorium molten salt reactors for nonproliferation

$10 trillion would be needed to rebuild the electric grid to support large additions of solar and wind generating sources

John Kutsch gives an informative energy rant; a second video debunks Dr. Helen Caldicott.

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Atomic Power Review – Will Davis

APR+ Design Certification Received

While the rest of the world watched for further hints of when a new boiling water reactor type might get through the type approval process in the USA, a different type of reactor received design certification in South Korea.  Details on this announcement and the APR+ in this post.

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ANS Nuclear Cafe - submitted by Paul Bowersox

ANS Winter Meeting – What’s In It For You?

Will Davis presents an appeal to those who have not yet committed to attending the ANS Winter Meeting in California.  There are many good reasons to attend if you can find the means – here are just a few worth considering.

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That’s it for this week’s entries.  THANK YOU to all the authors and submitters!

ANS Winter Meeting, November 9-13: What’s In It For You?

by Will Davis

I’d like to take this opportunity to ask you a question: Have you considered attending the American Nuclear Society’s Winter Meeting yet? Before you answer, I’d like to give you a few compelling reasons to do so from my own personal experience.

ANS_2-1205-2 attendees 200x133•  People  At ANS National meetings—at all ANS meetings, really, but especially at the two major national meetings each year—you’ll get a chance to meet and speak with people from every corner of the industry, and from a number of eras as well. People you have perhaps only e-mailed, and people who rarely use e-mail—they will be there. This is a prime opportunity to meet folks you’ve always wanted to meet. “But, what will that get me?” you say.

ANS_2-1206-student poster 200x132•  Networking  There is no end to the networking opportunities that happen around these meetings—before sessions, at lunch, and all evening afterward. Industry groups, regulatory groups, universities… they’re all present. Most folks find their schedules so packed with these meetups that by the time the actual meeting week arrives, there’s precious little other time undesignated. The number of things that can happen as a result of these networks is practically unlimited. The inspired atmosphere of the meetings makes great things happen—I’ve seen it.

•  Learning  To pick a particular topic, I can honestly say that in discussions both in person and on the internet about the Fukushima Daiichi accident, I have been consistently better equipped than even some other nuclear advocates as a direct result of having attended the ANS Winter Meeting in San Diego a couple years back. Personnel from TEPCO, other Japanese utilities, national and world regulatory bodies, universities, and laboratories around the world convened for a three-day Fukushima Daiichi sub-topical that provided an incredible level of detail and examination of the accidents. The same experience could not be had anywhere unless one went to Japan. I have considered this, and other ANS meeting topicals, to be invaluable. Again, only one possible example of what can happen for you if you attend these meetings.

Winter Meet 2013  ANS_2-1067 200x132•  Working  You can certainly make the case that your employer might well find you to be a more valuable employee after you’ve attended one of these meetings. The opportunities to grow and learn as a person and as an employee, and thus bring the benefits of those increased skills back to your employer, are never greater than at an ANS meeting. The technical papers presented, and opportunities to find out about new methods, or new programs, are a fertile field for growth. For those looking for employment in a nuclear-related field—what better environment in which to find out what’s hot, what’s available, and make that best first impression?

1117ZZ_0014CS 200x133I am sincerely hoping that folks who hadn’t thought about attending will reconsider after having read what I have to say. I think that the ANS national meeting experience is invaluable. I’ve tried over these years to relate it to everyone I can, so that the opportunities made possible by this ANS membership benefit are seized by everyone who can attend.

Yes, there will be a number of presentations honoring those who have earned high awards from ANS. There will be plenaries, and perhaps a formal dinner or two. Those have a rightful place at such meetings and I personally enjoy all of them. But I must say that I find the advantages of the additional aspects I’ve described above to be the best reasons to attend; I hope you’ll consider it.

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SavannahWillinControlRoomWill Davis is the Communications Director for the N/S Savannah Association, Inc. where he also serves as historian, newsletter editor and member of the board of directors. Davis has recently been engaged by the Global America Business Institute as a consultant.  He is also a consultant to, and writer for, the American Nuclear Society; an active ANS member, he is serving on the ANS Communications Committee 2013–2016. In addition, he is a contributing author for Fuel Cycle Week, and writes his own popular blog Atomic Power Review. Davis is a former US Navy reactor operator, qualified on S8G and S5W plants.

Nuclear Energy Blog Carnival 224

ferris wheel 202x201The 224th edition of the Carnival of Nuclear Bloggers and Authors has been posted at Things Worse Than Nuclear Power.  Click here to see this latest installment in a long running tradition among pro-nuclear authors and bloggers.

Each week, a new edition of the Carnival is hosted at one of the top English-language nuclear blogs. This rotating feature of nuclear “posts of the week” represents the dedication of those who are working toward a future of energy abundance, improved health, and broadened security through nuclear science and technology.

Past editions of the carnival have been hosted at Yes Vermont Yankee, Atomic Power Review, ANS Nuclear Cafe, NEI Nuclear Notes, Next Big Future, Atomic Insights, Hiroshima Syndrome, Things Worse Than Nuclear Power, EntrepreNuke, Thorium MSR and Deregulate the Atom.

This is a great collaborative effort that deserves your support.  If you have a pro-nuclear energy blog and would like to host an edition of the carnival, please contact Brain Wang at Next Big Future to get on the rotation.

Video Matinee: Controlling a Nuclear Power Plant

This new video from AREVA takes a fascinating look at the “brain and nervous system” for controlling a nuclear power plant: the plant’s Instrumentation and Control (I&C) system.

Thanks to AREVA Next Energy Blog for sharing this video.

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Nuclear Nonproliferation and Safeguards Education at Universities

By Lenka Kollar

I recently attended a Safeguards Education Roundtable at the Argonne National Laboratory sponsored by the Next Generation Safeguards Initiative (NGSI).  University professors and nonproliferation experts from U.S. national laboratories met at this event to discuss safeguards education at universities. The goal of NGSI is to “to develop the policies, concepts, technologies, expertise, and infrastructure necessary to sustain the international safeguards system” as it evolves in the future. A major pillar of the program is developing the next generation of professionals to work in the nonproliferation and safeguards field—and to make sure that the next generation of nuclear professionals is aware of nonproliferation and safeguards issues.

The employment opportunities for students interested in nonproliferation are quite diverse. National laboratories in the United States and around the world perform technical and policy research to address safeguards issues. The International Atomic Energy Agency in Vienna also employs safeguards inspectors and other professionals working in safeguards, security, and nuclear energy development.

Even if students are not interested in working directly in the nonproliferation field, it is important that these issues are brought to the attention of nuclear professionals as they enter the workforce. Safeguards and security are very important within the nuclear industry and nonproliferation is a worldwide issue. An increasing number of nuclear engineering programs are including nonproliferation education within their curricula.

The goal of the roundtable at Argonne was to familiarize university professors with nonproliferation education and to discuss how NGSI can help with curriculum development. Attending professors came from a variety of universities and programs, both engineering and policy. In many instances, engineering and policy professors have worked together at universities to provide nonproliferation education for students of both fields.

Below are some resources that professors and students can use to teach and learn more about nonproliferation and safeguards. NGSI also sponsors classes that students and young or mid-career professionals can attend.

Textbook: Deterring Nuclear Proliferation: The Importance of IAEA Safeguards by Michael D. Rosenthal et al.

Textbook: Nuclear Safeguards, Security, and Nonproliferation: Achieving Security with Technology and Policy by James E. Doyle

Nuclear Safeguards Education Portal

International Atomic Energy Agency

Nuclear Nonproliferation, Safeguards and Security (NSSS) in the 21st Century
Brookhaven National Laboratory
Three-week course in June
Application Deadline: Mid March

International Safeguards Policy and Information Analysis
Monterey Institute of International Studies & Lawrence Livermore National Laboratory
Five-day course in June
Application Deadline: Early March

Nuclear Nonproliferation and International Safeguards
Pacific Northwest National Laboratory
Two 3-day courses in June and July
Application Deadline: Late April

Safeguards Pre-Inspector Course
Idaho National Laboratory
Two-week course in March/April
Application Deadline: Early February

Finally, if you’re interested in becoming more involved in nonproliferation within the American Nuclear Society, check out the Nuclear Nonproliferation Technical Group!

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Lenka_Kollar_casual_small 125x125Lenka Kollar is the Owner & Editor of Nuclear Undone, a blog and consulting company focusing on educating the public about nuclear energy and nonproliferation issues. She is an active ANS member, serving as Secretary of the Nuclear Nonproliferation Technical Group and member of the Professional Women in ANS Committee. Connect with Lenka on LinkedIN and Twitter.

Webinar with NRC Chairman Allison Macfarlane—Thursday, Sept. 11, 9 AM Eastern

The American Nuclear Society will host an online webinar for nuclear bloggers—an unscripted question-&-answer session with Nuclear Regulatory Commission Chairman Allison Macfarlane—on Thursday, September 11, 2014, from 9 AM–10 AM Eastern Time

To register for the webinar, click the ‘Register’ link at:

https://ansbrief.webex.com/ansbrief/onstage/g.php?d=667766847&t=a

How to submit questions

Macfarlane

Macfarlane

Participants in the September 11 session may submit questions ahead of time by sending to Paul Bowersox at the American Nuclear Society. The conference call webinar will be listen-only and facilitator Margaret Harding, ANS Treasurer, will take questions via online webinar chat while the discussion is in progress. Those registrants unable to attend via computer may dial in to listen at the number listed on their registration confirmation.

Harding

Harding

To attend in-person

A limited number of spaces are available for writers to join in person at 2000 M Street, NW, Washington, DC, Conference Room A (basement level). Space is limited to the first 20 respondents.

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Nuclear Energy Blog Carnival 223

ferris wheel 202x201The 223rd edition of the Carnival of Nuclear Bloggers has been posted at Next Big Future.  You can click here to access this latest post in a long running tradition among pro-nuclear authors and bloggers.

Each week, a new edition of the Carnival is hosted at one of the top English-language nuclear blogs. This rotating feature of nuclear “posts of the week” represents the dedication of those who are working toward a future of energy abundance, improved health, and broadened security through nuclear science and technology.

Past editions of the carnival have been hosted at Yes Vermont Yankee, Atomic Power Review, ANS Nuclear Cafe, NEI Nuclear Notes, Next Big Future, Atomic Insights, Hiroshima Syndrome, Things Worse Than Nuclear Power, EntrepreNuke, Thorium MSR and Deregulate the Atom.

This is a great collaborative effort that deserves your support.  If you have a pro-nuclear energy blog and would like to host an edition of the carnival, please contact Brain Wang at Next Big Future to get on the rotation.

Motives for pushing a no-threshold dose radiation risk model (LNT) in 1955-56

By Rod Adams

Dr. Edward Calabrese recently published a paper titled The Genetics Panel of the NAS BEAR I Committee (1956): epistolary evidence suggests self‐interest may have prompted an exaggeration of radiation risks that led to the adoption of the LNT cancer risk assessment model.

Abstract: This paper extends a series of historical papers which demonstrated that the linear-no-threshold (LNT) model for cancer risk assessment was founded on ideological-based scientific deceptions by key radiation genetics leaders. Based on an assessment of recently uncovered personal correspondence, it is shown that some members of the United States (US) National Academy of Sciences (NAS) Biological effects of Atomic Radiation I (BEAR I) Genetics Panel were motivated by self-interest to exaggerate risks to promote their science and personal/professional agenda. Such activities have profound implications for public policy and may have had a significant impact on the adoption of the LNT model for cancer risk assessment.

This new work was inspired when Calabrese found a 2007 history of science dissertation by Michael W. Seltzer titled The technological infrastructure of science. One facet of the paper is to explain how self-interest can create biases that affect scientific conclusions, policy setting, and public communications. Identical measurements and observations can be used to support dramatically different reports depending on what the scientists are attempting to accomplish.

That is especially true when there is difficulty at the margins of measurement where it is not easy to discern “signal” from “noise.” The risk of agenda-driven conclusions has become greater as the scientific profession has expanded far beyond the sporadically funded idealists motivated by a pure search for knowledge, and into an occupation that provides “good jobs” with career progression, regular travel opportunities, political influence, and good salaries.

On the other hand, their efforts on the committee illustrate one component of the technological infrastructure of genetics outside of the laboratory: the increasing significance of large-scale laboratories, federal funding agencies, policy-making committees, and government regulatory bodies as critical components of the technological infrastructure of science. Clearly, how the science of genetics was to advance into the future would have much to do with traditionally non-epistemic factors, in addition to epistemic ones.

Finally, in considering all these themes together, it is difficult to conclude that there is any sharp separation between the practice of science and the practice of politics (in the Foucauldian sense of power/knowledge). Rouse’s view of the intra-twining of epistemology and power, his view of epistemic politics, is pertinent here. The practice of science was at times the playing of politically epistemic games, whether at the level of argumentation in the contestable theoretical disputes of population genetics, at the level of science policy-making, as with the various organizations and committees responding to the scientific and political controversies surrounding the efforts to establish exposure guidelines in the light of concerns over fallout from atomic testing, or with the planning of the future infrastructure of experimentation based on funding opportunities.

(Seltzer 2007, p. 307–308)

Admittedly, the language in the above quote uses jargon from the field of historians, but my translation is that Seltzer found ample evidence to support an assertion that the majority of geneticists on the BEAR I Genetics Panel were more concerned about fitting into a political narrative than they were in answering the questions they were ostensibly assembled to answer. Their tasking was to provide political decision-makers with scientifically supportable answers about the genetic effects of the radiation exposure that might be expected as a result of atomic weapons testing. However, they decided to complete a different task.

Some members of the committee had an agenda to assert the zero threshold dose response assertion desired by politically active members of the scientific community. They knew that answer—whether or not it was the truth—would assist their scientific colleagues in their efforts to raise concerns about fallout to a fever pitch. Fallout fear was their agreed-upon lever for gaining public support for their efforts to halt nuclear weapons testing.

Other members of the committee were more concerned about obtaining financial support for a long-term research program in general genetics research. That desired research program could only be tangentially related to determining the effect of the tiny, but chronic and largely unavoidable radiation exposures to human populations from highly dispersed atmospheric weapons testing fallout.

(Warning: If you are interested in the history of how the no-threshold dose assumption was imposed and you are pressed for time, please do not download Seltzer’s paper and begin reading it. It is full of intriguing information, but it is 450 pages long including footnotes. The section on radiation health effects controversies is 112 pages long.)

Here is a quote from Calabrese’s paper that does an excellent job of summarizing the important take-aways from Seltzer’s historical research for people who are mainly interested in encouraging a new look at radiation protection assumptions and regulations:

Seltzer provided evidence that members of the Genetics Panel clearly saw their role in the NAS BEAR I committee to be a vehicle to advocate and/or lobby for funding for radiation genetics (p. 285 footnote 208). Moreover, it was hoped that the committee, which would exist continuously over many years, would influence the direction and priorities for future research funding. According to Seltzer (2007), such hoped for funding possibilities for radiation geneticists can be seen in letter correspondence between Beadle, Dobzhansky, Muller and Demerec.

Demerec responded by saying that “I, myself, have a hard time keeping a straight face when there is talk about genetic deaths and the tremendous dangers of irradiation. I know that a number of very prominent geneticists, and people whose opinions you value highly, agree with me” (Demerec to Dobzhansky 1957). Dobzhansky to Demerec (1957b) responded by saying “let us be honest with ourselves—we are both interested in genetics research, and for the sake of it, we are willing to stretch a point when necessary. But let us not stretch it to the breaking point! Overstatements are sometimes dangerous since they result in their opposites when they approach the levels of absurdity.

Now, the business of genetic effects of atomic energy has produced a public scare, and a consequent interest in and recognition of (the) importance of genetics. This is to the good, since it will make some people read up on genetics who would not have done so otherwise, and it may lead to the powers-that-be giving money for genetic research which they would not give otherwise.” (Dobzhansky to Demerec (1957b)

Calabrese goes on to tie this newly uncovered history-of-science work to several other papers that he has recently published regarding his own excavation work digging through the collected papers of major players in the drama associated with using fears of radiation to slow and then stop nuclear weapons testing.

In retrospect, therefore, a historical assessment of the LNT reflects the so-called “perfect toxicological storm”: Muller receiving the Nobel Prize within 1.5 years after the atomic bomb blasts in Japan, the deliberate deceptions of Muller on the LNT during his Nobel Prize lecture (Calabrese 2011a, 2012), the series of stealth-like manuscript manipulations and deceptions by Stern to generate scientific support for the LNT and to prevent Muller’s Nobel lecture deceptions from being discovered (Calabrese 2011b), the series of subsequent false written statements by Muller to support Stern’s papers and to protect his own reputation (Calabrese 2013), the misdirection and manipulation of the NAS Genetics Panel by the actions of Muller and Stern (Calabrese 2013), and now evidence of subversive self-interest within the membership of the Genetics Panel to exaggerate risk for personal gain. This series of Muller/Stern-directed actions inflamed societal fear of ionizing radiation following the bombings of Japan and during the extreme tensions of the cold war with its concomitant environmental contamination with radionuclides from atmospheric testing of nuclear weapons, and led to the acceptance of the LNT model for cancer risk assessment by a human population that had become extremely fearful of radiation, even at very low doses.

(Calabrese 2014 p. 3)

Though the scientist-led antinuclear weapons movement saw fear of fallout as one way of inciting public action to limit atmospheric weapons testing and its uncontrolled releases, other people might have had less admirable motives. There are many solid financial reasons to encourage people to fear all sources of ionizing radiation, especially the doses that members of the public could possibly receive from nuclear energy production.

After all, even in the 1950s, the fuel industry was one of the largest and most important businesses in the world and was the source of a number of enormous fortunes. The industry has always been interested in avoiding the unprofitably low prices that result when there are more energy options and when the total supply of available energy is greater than the immediate need.

When I spoke to Dr. Calabrese for Atomic Show #218, he indicated that he had not done much to find out where the BEAR I committee members thought they would be obtaining the funds that might be made available if they exaggerated the dangers of low dose radiation. Modern scientists often assume that basic scientific research funding comes from a government agency, but that is something that developed gradually after World War II. Before then, nearly all funding for science came from private sources.

A 1987 biography of Warren Weaver published by the National Academies of Science described the genesis of the NAS study of radiation started in 1955.

Paraphrasing the description on pages 506–507, in the United States one of the largest basic science funders was the Rockefeller Foundation. In 1954, there were numerous articles in the press indicating that the public was confused about the effects of radiation. At a Rockefeller Foundation board meeting, attendees asked Detlev W. Bronk, who was both a Rockefeller Foundation board member and the NAS president, if there was a way to produce some definitive answers.

The NAS proposed forming six committees to investigate various aspects of the issue and the Rockefeller Foundation agreed to provide the necessary funds to produce the reports. Warren Weaver served as the chairman of the Genetics Committee for the first BEAR reports. Of the other members of the committee, at least four (George W. Beadle, M. Demerec, H. J. Muller, and A. H. Sturtevant) had been recipients of Rockefeller Foundation grants before 1956 and several continued receiving substantial grants well after their work on the committee.

The NAS biography described Weaver’s successful committee chairmanship:

The first committee was chaired by Weaver, who successfully mediated the opposing positions of the two groups of geneticists who were members of the committee and prepared a report that had their unanimous support. After the first summary report was published in 1956, there was virtual editorial unanimity in the nation’s newspapers that the “report should be read in its entirety to be appreciated” and that it deserved the close attention of all concerned citizens.

Pages 506–507

In the June 13, 1956, edition of the New York Times, the news of the committee’s report occupied the entire far right column of the front page from top to bottom. Here is the top portion of the article:

Peril to future of man

Below those scary, attention-grabbing phrases, the article’s lead was designed to shock and raise serious concerns:

Washington, June 12 — A committee of outstanding scientists reported today that atomic radiation, no matter how small the dose, harms not only the person receiving it but also all of his descendents [sic].

The article continued:

The six committees studied the radiation problem in the fields of genetics, pathology, meteorology, oceanography and fisheries, agriculture and food supplies, and disposal and dispersal of radioactive wastes.

Overshadowing all others because of its implication for mankind was the report of the genetics panel. This was headed by Dr. Warren Weaver of the Rockefeller Foundation. It was this foundation that provided the funds for the year-long survey.

It is important to understand that the primary data that the genetics committee had available to review were from experiments using X-rays on fruit flies, most of which were conducted by foundation grantees and members of the committee.

It is also worth noting that Warren Weaver served as director for Natural Sciences for the Rockefeller Foundation from 1932–1959. During that period the program that he directed provided more than $90 million in grants for experimental biology. (NAS biography pg 504.) He had a distinguished career, received many awards, and had a major influence in selecting the science that was funded for molecular biology, radiation health effects, and genetics.

Weaver was a mathematician by education with a lifelong interest in statistics and Lewis Carroll’s Alice in Wonderland. According to his obituary, he had the world’s largest collection of various editions of the book. Upon his death, the collection was given to the University of Texas.

The Rockefeller Foundation was, and remains, interested in maintaining the dominance of oil and natural gas in our energy supply system. Those fuels were the source of the largess that the foundation has been able to give for more than 100 years.

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Note: A version of this article appeared on Atomic Insights on July 19, 2014, under the headline of Selfish motives for LNT assumption by geneticists on NAS BEAR I. At the time, I was not aware that the Rockefeller Foundation provided grants supporting all of the Biological Effects of Atomic Radiation committees from 1955-1962.

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Adams

Adams

Rod Adams is a nuclear advocate with extensive small nuclear plant operating experience. Adams is a former engineer officer, USS Von Steuben. He is the host and producer of The Atomic Show Podcast. Adams has been an ANS member since 2005. He writes about nuclear technology at his own blog, Atomic Insights.

Graduate Student Members Awarded Automatic Membership in ANS Young Members Group

By Ben Holtzman

For too long, graduate students have been inadvertently marginalized due to a lack of status recognition in the American Nuclear Society, but those days are now past. The ANS Board of Directors has unanimously approved the joint Student Sections Committee (SSC)/Young Members Group (YMG) proposal to offer free YMG membership to graduate students. This is a great day for all Young Members, regardless of whether they’re still in graduate school or not.

We in the YMG have discussed on many occasions our belief that including graduate students as Young Members would be an appropriate classification and would better assist in integrating graduate students into the fabric of ANS during a crucial juncture of their careers. Well, we now have our chance. Of course, YMG will benefit from this change not only because it will bring graduate students into our organization to be among their friends and peers, but YMG will also benefit through the influx of energy and ideas of our newly incorporated peers. But how did we get here?

This change would have been impossible without the support, initiative, and drive of many individuals. The process began when a YMG/SSC special subcommittee on retaining students and the YMG Executive Committee identified a need to automatically give graduate students YMG membership as a way to address student attrition. A proposed plan of action was taken to the YMG Executive Committee, the SSC Executive Committee, and the ANS Membership Committee to explain the proposed change and attain each respective group’s endorsement. In parallel, it became apparent that the YMG rules would need to be updated to allow for such a classification of graduate students as Young Members. This wording change was developed with assistance from the ANS Bylaws and Rules Committee (BRC) and sent to YMG for approval. After YMG approved the change, the BRC subsequently approved it as well.

This rule change, in conjunction with the endorsed proposal by YMG and SSC Executive Committees and the ANS Membership Committee, allowed for a formal proposal to the ANS Board of Directors to be drafted by motivated volunteers. It was this formal proposal that has been approved granting graduate students automatic and free membership in the YMG.

Therefore, on behalf of all Young Members, let me be the first to officially welcome all graduate students into the YMG. We look forward to working with you as we continue to make our Society truly the Society of choice for all nuclear professionals.

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Ben Holtzman c2 141x120Ben Holtzman has been actively involved with the American Nuclear Society for 10 years. He has been on numerous governance committees and division executive committees, has contributed to an ANS Standard, and was a Presidential Executive Assistant. He is employed as a Senior Licensing Engineer, AP1000 International Licensing, at the Westinghouse Electric Company.

Unintended Anti-Nuclear Consequences Lurking in the EPA Clean Power Plan

By Remy Devoe

The Environmental Protection Agency’s proposed Clean Power Plan has gained favor with some nuclear energy advocates. An extensive analysis of the proposal, however, reveals that current nuclear generating capacity would largely suffer under the new carbon rules. In fact, the results of an evaluation performed by my fellow graduate student Justin Knowles and myself show that 15 states are actually incentivized to shut down all of their nuclear units and replace them with natural gas combined cycle (NGCC) generation. In effect, this plan allows for increasing carbon emissions; a far cry from the stated goals of the Clean Power Plan.

We conducted our analysis after learning about the plan in July while participating in the Nuclear Engineering Student Delegation in Washington, DC. While in Washington, EPA representatives explained to us how nuclear energy was considered in the rule, but admitted that only a small portion of current nuclear energy generation would be credited in a state’s emissions rate. The EPA contacts we met with encouraged us to submit a comment of what changes we would make and analyses to support these recommendations. We have been working to understand this plan since then, and intend to submit our analyses with our comment.

Reading the entire 130-page rule is a daunting task, but the root of our concern can be found in the section titled “New and Preserved Nuclear Capacity” (page 34870 of the Federal Register), which states that current nuclear generation is given 5.8 percent credit for replacing fossil-fuel energy. While seemingly arbitrary, this figure comes from an Energy Information Administration (EIA) report that states that six reactors in the United States (equivalent to 5.8 percent of U.S. nuclear generation) are at risk of being shut down. The EPA recognizes that keeping current nuclear generation is the only way this plan will be able to achieve its goal, but erroneously attributes only 5.8 percent of the energy produced from nuclear plants to calculating a state’s emissions reduction goal.

The current rule regulates emissions through a state’s carbon intensity in lbs/MWh using an equation developed by the EPA for this specific purpose. (For example, the EPA provides a sample calculation for Ohio). As you can see, only fossil fuels, renewables, 5.8 percent of current nuclear generation, and 100 percent of nuclear presently under construction are used in this calculation. The plan then outlines a Best System of Emissions Reductions (BSER) used to calculate what carbon intensity a state can attain if they implement emissions reduction practices. This new carbon intensity is the goal that each state must meet by 2030.

Since current nuclear generation is only valued at 5.8 percent of its energy generation, the loss of one plant in a state has only a marginal effect on a state being able to achieve its goal under this standard. If this rule is intended to be a carbon regulation, then all energy sources should be valued based on their emissions and no technology should be given preference over another. Renewables, coal, natural gas, and others are given credit for 100 percent of their current capacity; nuclear energy should be no different.

UT students at the EPA Clean Power Rule hearing

(left to right): UT students Daniel Tenpenny, Gregory Meinweiser, and Remy Devoe at the EPA public hearings in Atlanta

Following these revelations, a triumvirate of three students from the University of Tennessee ANS student section attended the EPA hearing in Atlanta to share our comments on the new carbon regulations and draw attention to the subject. We were very fortunate that each of us was allowed to provide public comments, and the EPA responded by requesting detail on our analyses and an official comment on its plan. Afterwards, one of the panelists requested a conference call to clarify our points and asked for a personal copy of our analyses.

Below you can watch each of our public comments:

Daniel Tenpenny

Remy Devoe

Greg Meinweiser

To create a fully developed comment, we—with the aid of our advisor, Dr. Steven Skutnik—used the data provided by the EPA to perform our analyses. We simulated a hypothetical scenario in which all nuclear plants were shut down and their generation replaced by natural gas combined cycle units. The results of this analysis were astonishing. By crediting nuclear at only 5.8 percent of its generating capacity, 15 states were shown to have lower emissions rates under the rule as currently proposed when all nuclear generation was replaced by NGCC—a clear indication that the EPA’s method of emissions calculations is flawed. By valuing only a fraction of current nuclear generation, utilities are incentivized to shut down nuclear plants in favor of natural gas, the exact opposite of the EPA’s stated intent with this plan. Our analysis has exposed a perverse incentive for states to allow the retirement of carbon-free nuclear generation for replacement with carbon-emitting sources.

We must insist that the EPA considers the total generation from all energy sources in calculating carbon emissions intensity. If the EPA gives nuclear energy its full due, then every reactor in the nation must keep running or be replaced with other clean energy sources for a state to meet its goals, making currently operating nuclear units all the more valuable to states. We can make this happen, but only if the nuclear community rises to this urgent challenge, rallying together to push for a fairer, more effective rule that credits current nuclear generation at 100 percent of its current capacity in state-level emissions goals.

I urge each and every one of you to take a look at the Clean Power Plan and submit a comment. The comment period on the carbon rule is open until October 16, 2014, and the final rule will be implemented in June 2015.

coal and nuclear


Head ShotRemy Devoe is a graduate student in Nuclear Engineering at the University of Tennessee-Knoxville. He is currently working towards his Master’s degree in nuclear engineering and plans to pursue a PhD in the same. His research focus is in nuclear fuel cycles and used fuel management. He is currently the Vice-President of the University of Tennessee American Nuclear Society Student Chapter.

Proposed Revisions to Nuclear Plant Release/Public Exposure Regulations: ANS Response to EPA

By Jim Hopf

DC PerspectivesIn January, the U.S. Environmental Protection Agency issued an Advanced Notice of Proposed Rulemaking (ANPR) concerning 40 CFR 190—the regulations that govern public exposure and release of radioactive materials resulting from normal nuclear power plant operations (it does not pertain to nuclear accidents). The public comment period for the proposed rulemaking ended on August 3.

On August 1, the American Nuclear Society submitted a formal comment to the EPA. I also submitted a comment, personally.

EPA ANPR

In the ANPR, the EPA did not make any proposed changes to the regulations. Instead, the ANPR was a proactive solicitation of public input. The EPA asked if 10 CFR 90, which was issued in 1977, should be revised or updated. It also asked for public input on six specific issues or questions:

  1. Should the 40 CFR 190 public exposure limits be expressed in terms of (individual) dose or health risk?
  2. If dose limits are used, should the dose calculation methodologies be updated, and if so how?
  3. Should release limits for specific isotopes be retained (in addition to public dose limits) and should release limits be applied industry-wide or to individual facilities?
  4. Should a separate groundwater standard be added?
  5. Should specific rules pertaining to spent fuel and waste storage be added?
  6. Should revised or new standards be added to address new or emerging technologies (such as new reactor types or fuel cycle technologies)?

Details about the ANPR in general can be found in the EPA notice. More details about the six issues that the EPA sought public comment on can be found in this EPA slide presentation. Also, more information can be found in a July 15 ANS Cafe post by Rod Adams on the EPA ANPR.

ANS response

ANS submitted a response to the ANPR in an August 1 letter. ANS made some general comments, as well as specific comments on each of the six issues listed above. ANS’s responses are summarized below:

General

ANS stated that the EPA should move forward with a comprehensive rewrite of 40 CFR 190, due to the substantial advances that have occurred since 1977 in the understanding of the health effects of ionizing radiation, particularly in the area of low-level exposure.

ANS also stated that other things have changed, since 1977, with respect to the overall environmental and health context that applies to radiation standards. Public doses from air travel and medical procedures have increased dramatically since then (with medical procedures alone increasing the average public exposure to ionizing radiation by 200 mrem/year), and no detectable public health impacts have resulted from that increase in exposure. Also, as the negative public health and environmental impacts from fossil-fueled power generation have become more clear, there is more of as consensus that nuclear power has significant environmental benefits that may offset any negative impacts from public radiation exposures.

ANS also stated that while 40 CFR 190 specifically applies to the nuclear power industry, the risk modeling methodologies that form the bases of any requirements or limits should be consistent with those used to regulate other (non-nuclear-industry) sources of public radiation exposure.

Issue 1

ANS stated that an individual, total effective dose limit should be applied, as opposed to any kind of health risk limit.

Issue 2

ANS stated that dosimetry methodologies should be based on “effective dose” and urged the EPA to use standards and methodologies that are consistent with other agencies, such as the U.S. Nuclear Regulatory Commission. ANS also suggested using the effective dose definition used in ICRP Publication 103 (in its response to Issue 1), that document being one of the methodologies suggested by the EPA in its Issue 2 question.

Issue 3

ANS strongly recommended that the EPA revise 40 CFR 190 to discard any radionuclide release limits, as they are “duplicative, unnecessary and inconsistent with international practice.” ANS stated that limits on overall individual dose are sufficient to protect public health.

The reason for the radionuclide release limits currently in 40 CFR 190 was that in 1977, large-scale reprocessing was anticipated and there were concerns about long-term buildup (in the environment) from routine radionuclide releases from reprocessing facilities. This issue is far less significant now, given that the United States has not pursued reprocessing. The limits were also based on an extreme application of the linear no-threshold (LNT) theory, with very small doses to very large populations being used to predict significant health impact—something that is now considered questionable scientific practice by most experts.

Issue 4

ANS argued against having any separate regulations or dose criteria for specific public exposure pathways, such as a separate groundwater standard. Instead, limiting total effective dose to an individual, from all pathways, is the best approach for protecting public health.

Issue 5

ANS stated that there should be no specific EPA regulations related to storage of spent fuel and other forms of radioactive waste. Spent fuel and waste storage operations are already rigorously regulated and monitored by the NRC, making EPA involvement unnecessary. Any releases into the environment from storage operations would be covered by limits on overall public exposure (from all nuclear plant operations).

Issue 6

With respect to potential new reactor and/or fuel cycle technologies, ANS reiterated its position that limits on overall exposure (total effective dose) for individual members of the public is the most rational and effective approach for protecting public health. After all, any health impacts will be a function of dose, regardless of the source of that dose. It is clear than any limits on public exposure should be technology-neutral.

My own response

I submitted my own response to the EPA ANPR. My response concurred with ANS positions, and made many of the same points, with a few exceptions.

It is clear that any limits should be on public exposure (dose), and regulations should not distinguish between specific isotopes, pathways, or technologies. While there may be some disagreement over the health risk from a given amount of radiation exposure (rem), there is almost complete agreement that any health impacts from radiation are solely a function of dose (in the case of long-term exposure, at least). The science of dose determination is very well-developed, with the radiological and biological half-lives, and the chemical/biological behavior of various isotopes within the body, being fully accounted for in dose calculations. Dose is dose.

Therefore, it is clear that it is dose, and only dose, that should be controlled. To support the determination of any isotope-specific release limits, the EPA would have to do extensive pathway calculations to equate a given release (of a given isotope) with some predicted dose to a member of the public. That would be duplicative, as plant operators are already required to perform extensive environmental monitoring around the plant sites. This is necessary to determine public doses to comply with EPA and NRC public dose limits. Also, how would any EPA analyses account for differences between various sites (whereas plant operator monitoring and dose calculations are already site-specific)? Limiting dose, as opposed to releases of specific isotopes, maximizes flexibility and places the focus where it should be, i.e., on controlling the maximum overall exposure to members of the public.

As for long-term environmental buildup being a justification for isotope-specific release limits, it seems to me that this problem would be a uniquely small one for the nuclear industry, given the fact that radionuclides decay away (with most of the significant isotopes having relatively short half-lives). Meanwhile, other industries, whose pollutants often do not decay away at all, don’t seem to be asked the same questions (mercury from coal plant emissions being one possible example). Instead, the focus seems to be based solely on immediate (present day) health impacts from their pollution, as determined by various epidemiological studies. In the context of Issue 3, I asked the EPA why this question is seemingly only being asked of the nuclear industry.

Where I differed from ANS

While I agree that any regulations should be based on dose, I didn’t entirely agree with ANS’s position that limits should be placed on individual dose (to some most-exposed member of the public). To be fair, the EPA essentially asked responders to choose between a limit on individual dose or a limit on allowable individual health risk. Given that choice, I would pick a limit on dose, as did ANS. However, I also recommended different, even better, bases for regulations, which were not suggested by the EPA.

Limits on collective dose

Many nuclear professionals believe that repudiating the LNT theory (on low-level exposure health effects) would be key to rationalizing dose (or release) regulations. I’ve often argued that all we need to do is point out that LNT is being selectively applied (to the nuclear power/weapons industry only).

Current public individual dose limits are determined by using LNT to argue that there is some health risk even at very low doses, and then applying an absurdly low limit on allowable health risk (e.g., a 10-4 or 10-6 lifetime cancer risk). This process results in very low limits on individual exposure, that are only applied to nuclear industry related exposures. Much larger doses from other sources, such as natural background, radon, medical, and air travel are simply ignored (not regulated).

The problem with this “logic” is that if you assume LNT, and that the dose response is truly linear all the way down to zero, it then follows (purely mathematically) that total health impact (i.e., cancers or deaths) scale directly with collective exposure, in man-Rem. As I argued to the EPA, the concept of limiting maximum individual risk is not even meaningful. At the end of the day, you either die (from radiation-induced disease) or you don’t, and the number of deaths (which is what you’re really trying to avoid) scales directly with collective exposure (man-Rem). Thus, it is hard to justify placing limits on exposure to a (most exposed) individual, as opposed to limiting overall collective public exposure. The only downside to limits on collective exposure is that it may be somewhat harder to determine (or estimate) than maximum individual exposures.

Limits in individual exposure, as opposed to collective exposure, work against nuclear, since any pollution that nuclear plants release (under normal operations or in an accident) tends to stay localized, whereas many forms of pollution from many other industries drift far and wide. I believe that this is one reason why nuclear plant limits are a small fraction of natural background (far too small to have any measurable public health impact) while fossil fuel generators are still allowed to cause ~10,000 deaths in the United States annually (according to the EPA itself).

Also, the other sources of radiation exposure I listed earlier affect most or all the U.S. population, whereas any nuclear plant releases would affect only a handful of local residents. This results in differences in collective exposure that are even more vast than the differences in individual exposure (between nuclear power sources and other sources). The collective exposure that U.S. residents get annually from radon is far larger than the total public collective exposure that will result from the Fukushima accident, yet nothing is done about it. Such exposures are unregulated. Public exposures from U.S. nuclear plants, under normal operation, are about a million times smaller than the public exposures from these other, unregulated sources.

Based on the above reasoning, I asked the EPA to consider limiting collective public exposure from U.S. nuclear plants, as opposed to limiting the exposure to a maximally exposed individual. I also asked the EPA to put any proposed limits on collective exposure in the context of the collective exposures the U.S. public gets from other sources. I essentially asked how they could apply strict controls limiting nuclear operations to tiny public collective exposures while completely ignoring other sources of collective exposure that are a million times larger.

Cost-benefit analysis

The EPA currently performs cost-benefit analyses to justify most of its proposed regulations in most industries. In fact, the EPA even uses a published dollars-per-life-saved figure of ~$10 million per life as the basis for its regulations. This makes sense (to me) as the basis for any regulations, as one shouldn’t arbitrarily apply limits on doses, or health risks, regardless of the cost. Such policies allow society’s limited public health and safety resources to be applied where they will have the most impact.

Thus, I suggested to the EPA that they go one step further than limiting collective public exposures (man-Rem). I suggested that the best policy of all would be to establish a criterion for how much plant operators should have to spend per public man-Rem avoided. This would be similar to industry ALARA (As Low As Reasonably Achievable) policies currently in place for limiting exposures to plant personnel. If the EPA does not want to leave it up to operators to perform such cost estimates, then, at a minimum, the EPA should keep the $10-million-per-life-saved criterion in mind when determining limits on public collective exposures from plant operations. $10 million per life saved corresponds to a spending requirement of ~$4,000 per man-Rem avoided (based on current LNT estimates of one death per ~2,500 man-Rem). The EPA could consider industry input when determining what limits on public collective exposure would correspond to a cost of ~$4,000 per man-Rem.

I also (again) asked the EPA why nothing at all is being spent to reduce all the other, vastly larger sources of public collective exposure, and inquired about what other practices it should mandate (e.g., radon abatement) that could be performed for $4,000/man-Rem or less.

Distinction between different sources of exposure

ANS alluded to how nuclear industry–related sources of public exposure are treated differently than non-nuclear industry sources when it said that “the risk modeling methodologies that underlie them must be consistent with those used in EPA’s regulatory involvement (or lack thereof) pertaining to all other pathways of public exposure to ionizing radiation.”

I was more direct. I stated that “with the possible exception of medical exposures (that have an offsetting health benefit), all public exposures should be treated equally by regulations, regardless of source.”

It is indefensible to arbitrarily apply strict regulations to some sources of public exposure while ignoring much larger sources of public (collective) exposure. Given this fact, dose limits that are a small fraction of natural background (which ranges up to ~1,000 mrem/year in many places) are hard to justify. When considering collective (as opposed to maximum individual) exposures, strict limits on localized exposures in the vicinity of a nuclear plant are even harder to justify.

Although it is outside the scope of 10 CFR 190, this argument is even more important with respect to setting exposure limits in the event of nuclear accidents. Given the relatively small number of affected people (on the order of 100,000, based on the Fukushima experience), the assumption of LNT should allow individual exposure limits of several Rem/year, as that would still result in overall collective exposures that are smaller than those received routinely by the overall population. Expensive cleanup operations (e.g., to get doses down to 100 mrem/year, as Japan is considering) are hard to justify, given that far larger reductions in overall public collective exposure could be achieved at far lower cost in other areas (such as radon abatement or reducing unnecessary medical exposures).

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Hopf

Hopf

Jim Hopf is a senior nuclear engineer with more than 20 years of experience in shielding and criticality analysis and design for spent fuel dry storage and transportation systems. He has been involved in nuclear advocacy for 10+ years, and is a member of the ANS Public Information Committee. He is a regular contributor to the ANS Nuclear Cafe.