Implications of improved radiation protection standards for Fukushima evacuees

By Rod Adams

The American Nuclear Society’s annual meeting for 2012 included a President’s Special Session titled Low-Level Radiation & Its Implications for Fukushima Recovery (Warning—the link leads to a 54 MB, 208 page PDF full of disruptive information that might change your opinion on the benefits of spending billions of dollars every year to keep radiation doses as low as unreasonably achievable).

The session was well attended and 200 printed copies of the 208-page compilation of presentations and papers were snapped up quickly. Unfortunately, I am not yet able to judge if the situation today is any more favorable to a rational reconsideration of current regulations than it was during the period between 1994–1999 when Jim Muckerheide, Ted Rockwell, Ted Quinn, Andy Kadak, and others arranged a sustained series of special sessions on the health effects of low level radiation at ANS annual meetings.

That series culminated in technical briefing papers that supported revised ANS and Health Physics Society (HPS) position statements in favor of taking new approaches to radiation protection and some acknowledgment by Nuclear Regulatory Commission commissioners such as Greta Dicus that the science being gathered supported the need for a reevaluation of the linear no-threshold model (LNT) model and the regulations that use it as their basis.

Unfortunately, that effort came to naught after the officially selected Committee to Assess Health Risks From Exposure to Low Levels of Ionizing Radiation from the National Academy of Sciences decided that the evidence of no or positive effects from very low levels of radiation was not convincing enough. They refused to overturn their long-held assumption that the linear relationship between dose and damage was valid enough for government regulations all the way down to a zero dose.

Little changed in the radiation protection field as a result of the multi-year effort and more billions of dollars were spent—and collected by the recipients of the spending—each year for more than another decade to protect people from doses that have never been shown to cause harm to people. The LNT is used to justify such absurd regulations as requiring that the high level waste repository in the United States must designed to ensure that annual doses to the most exposed person will be less than 15 mrem per year. That is 1/20th of the average background radiation in the United States.

My curiosity about the conclusion reached by the BEIR VII committee was strong enough when I first read the report. I had attended a number of the special sessions at ANS meetings, become a member of Radiation, Science and Health and developed a high level of respect for Jim Muckerheide, Myron Pollycove, Jerry Cuttler, Sohei Kondo, and John Cameron, among others. I could not understand why the information those highly qualified and courageous scientists and engineers were developing and presenting was being ignored.

However, while working in Washington and living in Annapolis, Md., I developed a friendship with a member of the Uniformed Public Health Service. He served a tour of duty in the office of the Environmental Protection Agency (EPA) that controls the expenditure of the funds that the U.S. government appropriates each year to support the Life Span Study (LSS) of the victims of Hiroshima and Nagasaki conducted by the Radiation Effects Research Foundation. He told me that the senior government service (GS) employees that controlled that funding had established a small fiefdom. They had decided that they would do everything in their power to make sure that the money kept flowing to people that supported the status quo assumption. They made no secret of the fact that the LSS was their career ticket during conversations in the office.

After hearing that story, I more fully understood why the BEIR VII committee was so sure that the Life Span Study of atomic bomb victims—whose doses were given in a very short period—was considered to be a gold standard. It can be difficult to argue with funding sources that have a preconceived notion about the answers they expect to receive as deliverables. The thing that still bothers me, however, is realizing that a tiny group of functionaries can selfishly hold so much power over so many for such a small thing as a government job.

During the intervening years since the last sustained effort to bring sense and science to regulations and emergency response criteria associated with low level radiation doses, I have engaged in numerous conversations with nuclear energy professionals who have resisted—sometimes quite strongly—the idea that there is such a thing as a safe dose of radiation. Some were shocked to hear me suggesting that science showed that it was possible that radiation might even be beneficial at certain doses. Those concepts go against so much of their training and indoctrination.

The report produced for the 2012 special session should help reach these skeptical professionals, especially the ones who have nurtured the important nuclear philosophy that they are learning professionals who must always maintain a questioning attitude that is open to change if given new, reliable information.

Even though it is a big file at 54 MB, the President’s Special Session: Low-Level Radiation & Its Implications for Fukushima Recovery should be spread widely and reprinted often. Far more nuclear professionals have unfettered access to high speed data networks now than they did in 1999. Though the Internet was available and papers from the ANS sessions were posted on web sites, the network was not very fast or very ubiquitous in the small towns that host the workers at most nuclear power plants and national labs.

I hope that the plight of the evacuated residents of the Fukushima prefecture will encourage interested observers to recognize the deleterious effects of maintaining regulations based on an inaccurate model in the name of “conservatism” or “precautionary protection”.  If sensible rules prevailed, nearly all of the Fukushima evacuees would be able to return home and rebuild their homes, villages, and lives.

So far, I am more hopeful than optimistic. Perhaps some of you can convince me that this time is going to be different, and we really will see a gradual shift toward more rational radiation regulations.



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.

28 thoughts on “Implications of improved radiation protection standards for Fukushima evacuees

  1. Joffan

    I can’t be sure of this, of course, but I suspect that Bob had no idea that DDREF, the low-level fudge factor, until I pointed out to him that it was an intrinsic part of the BEIR VII “LNT” model. As ICRP admits in their abstract of “Low-dose Extrapolation of Radiation-related Cancer Risk”, “Unless the existence of a threshold is assumed to be virtually certain, the effect of introducing the uncertain possibility of a threshold is equivalent to that of an uncertain increase in the value of DDREF.” That is, you can ignore the threshold by breaking linearity to a variable degree. But then collective dose means nothing (which it never did of course), cumulative dose means nothing (ditto), and all harm calculations need to account for this ever-changing fudge factor without simplistic multiplication games. Well, if you’re seriously contributing, that is – non-serious scare posts will just take the easy way.

  2. Jim Raleigh

    I think the industry needs to revisit the NRC’s “Below Regulatory Concern” rulemaking effort from the 80’s and early 90’s…

    And, ALARA would need to be redressed; so it would not be ALAUA (U=Unreasonably): “The Commission uses the ‘as low as reasonably achievable’ (ALARA) standard for radiation protection. The basic philosophy for the ALARA standard has been expressed by the International Commission on radiological protection. The ALARA standard is based upon the theory that there is no safe radiation level. By using a linear hypothesis, the effect of radiation is scaled from a very harmful dosage down to a zero dosage.”

    Of course, unhappy groups like Public Citizen helped force the BRC policy and rulemaking down…

    NRC has issued three policy statements creating categories of deregulated radioactive materials. Each policy statement has broadened the definition of exempted radioactive wastes which could be disposed of without regulation. The first policy statement was announced in response to the 1985 Amendment in which the Commission promulgated exemption standards for various levels of radiation. In this policy, the maximum effective dosages are very low, the impact to the environment must not be significant, and there is no mention of recycling radioactive materials into consumer goods. The second policy statement, issued in 1988, was expanded to include any type of radioactive material (not just waste) to be deregulated. This statement also raised the permissible levels of public exposure to radiation. The NRC’s July 1990 definition of the BRC has been
    greatly expanded, and departs from its previous posture. The NRC has
    not issued any guidelines for implementing this policy, but intended to exempt materials on a case-by-case basis.

    Excerpt from :
    “In reaction to public concern about the 1990 policy, the Commission in February 1991 announced the initiation of a consensus-building process to clarify differences and work toward resolution of issues related to implementation of the policy with regard to waste disposal. The agency further announced that, during the consensus-building process, the NRC would defer action on petitions for rulemaking involving requests for BRC waste disposal exemptions.

    In July 1991, the Commission placed a complete moratorium on
    implementation of the 1990 BRC policy statement and embarked on a
    phased consensus-building process to seek the advice of affected
    interests on a re-evaluation of the policy.

    When the consensus-building process was terminated in
    December 1991, due to the difficulty of obtaining the
    participation of all affected interests in the process, the
    Commission indefinitely extended the moratorium on the
    implementation of the policy.

    Later the Energy Policy Act of 1992 revoked the 1986 and
    1990 BRC policy statements.

    The Energy Policy Act did not, however, revoke the
    Commission’s authority under the Atomic Energy Act to exempt
    classes of radioactive materials from licensing. The Commission
    will therefore continue to address individual exemption requests
    using criteria and guidance in existence prior to the 1990 policy

  3. Rod Adams

    David – I cannot explain why anyone would want to regulate radiation levels that cause no measurable harm, but I suppose it is because they are under constant pressure to define safe nuclear as something with ZERO risk. As most rational people know, there is no such thing. That leads to the Jaczko interpretation that a safe nuclear plant is one that is not running.

    There are definitely people in the radiation protection racket that would be harmed if reasonable standards applied, but the losers would not include anyone selling monitoring equipment. After all, my commentary about doses is predicated on the fact that the dose is measured and controlled to be at low (safe) levels. That means you still need to measure dose rates.

  4. David Walters

    Question for Rod. So…is it in your opinion that current radiation protection levels should be re-examined so that regulations can be developed to prevent exposure at levels upward from the current levels, to say, 100mSv? I suspect those in the health physics field, that is those that manufacture monitoring, protection and other components might well object…it would likely shrink their industry.

    What I don’t understand is why regulators would regulate to, say, 10Msv, knowing full well there doesn’t exist a single study that shows levels above that are harmful? Can you explain?


  5. Rod Adams

    If you did not bother to download or read any of the 208 pages of the report on the President’s Special Session, why are you wasting time commenting? Get busy and start reading. After all, science is a matter of constantly questioning and testing assumptions.

    That is one of the reasons I have never been satisfied with the LNT. It is not testable at doses below about ten rem (100 mSv) and the best defense that its supporters can muster is that at least it provides a “conservative” or “precautionary protective” standard. That, IMHO, is not much of a defense considering the importance of nuclear energy and radiation in medical and industrial use.

    By the way – though I do not consider my advocacy of atomic energy to be inaccurate or propaganda, I will never shy away from admitting that I am a pro nuclear advocate who is seeking to break down the artificially erected barriers to development.

    Speaking of carcinogen regulation, does anyone else remember that gasoline pumps used to carry a warning about the fact that exposure to fumes had been proven to cause cancer in laboratory mice? I have noticed in recent years that those warnings seem to have disappeared from pumps in all of the states where I fill my tank. Did the hydrocarbon industry successfully lobby for their removal or did the science change? Inquiring minds want to know.

  6. DV82XL

    Applebaum. Only in the circles that you find in the windmills of your mind have you not lost any arguments. The fact is that no one accepts your position among the commenters in this thread demonstrates clearly that you have not convinced anyone, and that my dear sir, is loosing by any rational definition of the term.

    You are not a scientist, nor do you represent the scientific consensus in this matter, (which clearly you do not understand) you are a priest spouting dogma with a conviction that only comes from being both closed and narrow minded. Like a priest, you have not changed your approach when arguing this topic and therefore do not bring anything new to the table.

    You have become a tiresome little bore – a troll that contributes nothing and counts for nothing.

  7. William Mullins

    The challenge at hand is not going to be met explaining determinism in far-from-equilibrium systems like tissue cells to Mr. Applebaum – it’s not worth the effort to try.

    The difficulty that requires some original thought is how do we unwind a regulatory system that was built upon a cautious conjecture that is now scientifically rendered too cautious by a factor of 1000? The falsification of the LNTH constitutes a disruptive innovation to the existing regulatory paradigm – how are we using the knowledge of such changes to anticipate an adjustment to the regulatory scheme that is doable?

    Most practitioners operating under the present nuclear energy licensing scheme – be they regulatory or licensee – are conditioned to an accretion of precedent that is held together more by a system of bureaucratic virtue reinforcement than by any enterprise learning system. They don’t know the bio-physics and no one has ever suggested they needed to know it.

    One line of disruption involves bringing usage in line with other Complex, High-Consequence Circumstance capital enterprise sectors. Within the main line of nuclear hazards control (i.e. power reactor licensing practice) key terms, including Quality, Risk, Protection, and Culture have evolved into parochial usage (e.g. risk always refers to hypothetical dose consequence without regard to cost) that deviates from the sense of these terms in the broader society. The inertia associated with these terms is substantial.

    Much like those who spent decades searching for evidence of the luminiferous ether, the science will overtake the Myth of Spectacular Exception for ionizing radiation – but the changes to the Political Compacts and Social Contracts that surround the technical reality of hazard potential are going to require a shift in the Sustaining WHY of nuclear energy utilization.

    Certainly the benefits of nuclear medicine provide one basis for shift to a more positive perception, but I suspect the real payoff will come in terms of the comparative benefits of nuclear power in the pursuit of National Energy Security. There remain many reasons to want very robust, high reliability operations for nuclear power plants – but compared to the potential for infectious disease outbreaks or tsunamis wiping out cities, the threat of a large radiological catastrophe is both manageable and a prudent investment risk in comparison to many other technology predicaments we give less concern to about the uncertainties of their long term consequences..

  8. Meredith Angwin

    I had no idea that the LNT theory had a fudge factor to account for the fact that lower-doses-over-time have less cancer than the same dose all at once. I naively thought that Linear Non Threshold meant, you know, Linear. You know…Linear Non Threshold. If you claim that Linear Non Threshold is correct because the theory isn’t, after all, linear…well, I won’t argue with you. I am not a specialist in fudge factors.

    But if LNT needs a non-linear fudge factor to be correct, it might also need a new name, so it doesn’t mislead people. I don’t think that I can be blamed for “not understanding” LNT when it has some kind of non-linear factor in it and I thought it was linear. Seems like the name was set up to mislead people like me, IMHO.

  9. Bob Applebaum

    I don’t care about credentials, my own included, I only was responding to a specific question. If you don’t like my exercise of free speech don’t read it. My world-view is based on science, if that offends you, think about how it has led to longer lives, better comfort, and more knowledge for so many people. Or be a pro-nuclear ideologue. The choice is yours.

  10. Brian Mays

    I have studied research on radiation response in humans and I’m Board certified.

    There are also people who claim to be board-certified astrologers. BFD.

    Sorry, Bob. Board certification might qualify you to do cookie-cutter work based on the current practices in your field, but it does not make you a researcher, and it doesn’t qualify you to be an expert on research in this field.

    Personally, I wouldn’t trust most board-certified physicians to understand the latest research in epidemiology, so why should I trust you?

    I know your background, and I know that you do not have a research degree, and I know that you have never done research in this field or any other field, as far as I have been able to discover. (You can correct me on this, by the way, by citing a few of your publications.)

    To summarize, you are a board-certified troll, who pops up on these websites discussing the effects of low-level exposure to radiation to snipe at anything that anyone has to say that does not mesh with your world view.

    We’re tired of your BS. I, for one, have been over and over this stuff with you to no end. When you start losing the argument, you retreat from the comments section and post something on your own personal blog, where you can control the conversation.

    I’m sorry to point this out to you, but that’s pathetic. Perhaps you should crawl back under the rock from which you came.

  11. Bob Applebaum

    I can’t respond directly to Rod’s comment. No, I didn’t download the 54 Mb, however I’m familiar with older problems with the work of the people mentioned, and unlike you (“I could not understand why the information those highly qualified and courageous…), I do understand their faults.

    You are a lazy thinker, you rely on credentials instead of facts and logic. Credentials only increase the probability that what someone says is correct, but when they don’t, their credentials don’t matter.

    There is no LNT “assumption”, it is a theory just like any other scientific theory, and there is nothing in my sales agreement related to scientific theories. Why do you oppose science? Could it be a pro-nuclear bias?

    Yes, I spend a lot of time explaining how small the risk is. I criticize people who promote the anti-science of Gundersen, Caldicott, etc. just like I criticize the anti-science you promote. (And I don’t care what their credentials are…they are factually wrong).

  12. Rod Adams


    Have you read any of the science papers that are referenced in the President’s Special Session report?

    How do your credentials stack up against those of people like Jaworski, Cuttler, Pollycove, Rockwell, and Kondo?

    You dismiss Dave Rossin’s doctorate; exactly what degrees and what published papers do you have on the topic?

    Was your contined defense of the LNT assumption a part of the sales agreement when you sold RACE, making millions of dollars from the fear that continues to be associated with even the smallest doses of radiation?

    Do you really think it is beneficial for people to believe that any dose of radiation results in an increased risk of the big “C”? Do you ever spend any time helping anyone to understand how small the increase is, even if you believe in the LNT – an assumption that can only be taken on faith?

  13. Bob Applebaum

    Yes I do have a habit of criticizing anti-science propagandists. But I’m all for equality and I criticize climatology-deniers, evolutionary biology-deniers, as well as health physics-deniers. And what you say about the Board shows your ignorance of the science. Yes, humans can adapt and guess what? We get cancer. Daily living (which includes radiation exposure which contributes to the second leading cause of death, cancer) involves risks. So does radiation. For most of us the risks of radiation are small compared to other risks, but not zero.

  14. Bob Applebaum

    It’s obvious your DR. isn’t in health physics. LNT is not simple, only your simplistic understanding of it is. It is very complicated.

  15. Bob Applebaum

    In the arena of determinism, there is an outcome and a cause(s). The cause(s) are directly observable to determine the outcome. So for radiology, you can avoid skin reddening (one of many effects) by fractionating the radiation dose (the cause has been fractionated by time, and the effect isn’t observed).

    Cancer is a different effect from skin reddening. It’s cause is still radiation, but each increment of radiation contributes to the effect (cancer). Unlike skin reddening, you can get cancer without any excess radiation, you can get no cancer with a lot of radiation. Dose rate does matter, and your statement implies you don’t understand LNT. The rate of cancer incidence is not the same for high single doses as compared to the same doses which are fractionated. To correct for this difference the LNT theory includes a “fudge” factor.

  16. Rod Adams

    Sorry – I need to do a better job of proof reading.

    The third paragraph in the above should have said “… the board that certified you was trained…” (not training)

  17. Rod Adams

    @Bob Applebaum

    Do you have a Google alert set for LNT?

    Just teasing, but you do have a habit of piping up anytime I write about the issue.

    Sure, you are “Board certified” but the board that certified you was training in the established regulatory assumption. Its rules were not based on science and measurements of actual effects on cells that were a part of living organisms or based on epidemiology from populations exposed to chronic doses with adequate recovery and repair.

    The issue, as I understand it, is that humans are biological creatures that adapt, not metals that respond based on the the laws of physics.

    One of the numbers that Jerry Cuttler has shared with me is that just daily living exposes DNA to about 6 million times as many damaging events as exposure to radiation at 100 mrem per year. Stochasticly, I am willing to bet that the daily living is more risky than the radiation.

  18. Rod Adams

    Nolan – it looks like those studies might provide some illuminating information, but none of them are complete. Do you really believe that the information will be so different from what we have already accumulated with about 100 years worth of dose and dose rate information on a variety of populations?

  19. Joel Riddle

    I would have guess Mr. Applebaum would find this post, but he was quicker than I would have guessed.

  20. Meredith Angwin

    Are you saying that healing from high doses is predictable, but cancer from low doses is not predictable (stochastic, depends on some indeterminate factors)? If so, I agree with you.

    If you are saying that cancer implications of very low doses delivered over time is the same as a one-time higher dose, because of the “stochastic effects,” your argument makes no sense and I don’t agree with you. It is a principal of radiation protection that the dose rate will matter. If you believe the Linear part of Linear Non Threshold, you must agree that dose rate matters.


    My DR. is in metallurgy. We demonstrated that in many cases radiation embrittlement of metals can be “annealed out” by controlled heat treatment. Bodies of humans or animals are not comparable to reactor pressure vessels, but all radiation specialists know that there are recovery mechanisms in living tissue. These will reduce calculated health risks when doses are spread over time.
    One serious problem is that we have not found a useable and acceptable protocol that accounts for the recovery process. Attempts have not come up with anything simple enough to be adopted widely. The LNT is simple, but WRONG.

  22. Bob Applebaum

    Sorry to disappoint, but I wouldn’t kill anyone, and I have a pretty good understanding of medical physics. The radiology effects you are referring to are deterministic effects, carcinogenesis is a stochastic effect. You don’t understand that difference, most radiologists do, though not all. I have studied research on radiation response in humans and I’m Board certified.

  23. Meredith Angwin

    I know Mr. Applebaum has some training in radiation control, but I do hope he is not at work in any hospital, because he would kill his patients. Radiation therapy is given in relatively small doses spaced out over several weeks. If Mr. Applebaum were in charge, I suppose radiation treatment would be given all at once to save money on repeated visits to the hospital and repeated use of equipment. After all, if small doses over a long time have the same effect as if a big dose all given at one time, why not save money on repeated visits? Of course, “why not” is that giving one big dose might kill the patients.

    Radiation professionals who are responsible for people’s health know that people heal from small doses in a way that is not true for large doses. Recent research on DNA repair confirms this fact. Mr. Applebaum’s devotion to the linear-non-threshold theory means he has not bothered to learned what radiologists know and practice.

    In this note, Applebaum multiplies boundary-line-dose per year by 30 years and assumes the same dose is given all at once. Then he draws a conclusion about fatal cancers. This is specious. I hope he talks to some practicing radiologists, and also studies the research on radiation response in humans.

    (Above, I wrote “relatively” small doses because even spaced-out cancer treatment dosages are far higher than any dosage to the public or to nuclear workers.)

  24. E. Michael Blake

    A clarification: The book made available during the session does not include the presentations by the speakers at the President’s Special Session itself. As far as I can tell, this is the case also for the PDF available at the link, which I believe is made up of the pages of the book.

  25. Jim Raleigh

    Rod: You would think that the “Special Session” information in concert with the NRC’s State-of-the-Art Reactor Consequence Analyses (SOARCA) project report (NUREG-1935) would put the masses at ease… It is high time that the regulations are changed to better reflect reality!

    BTW — I like your new acronym: ALAUA

  26. Bob Applebaum

    This shows you can lead someone to knowledge but not make them think. LNT is applied to all gentoxic substances, which includes radiation. For most toxins, EPA allows a fatal risk estimate range of 1E-6 to 1E-4. If you multiply the risk associated with the NRC allowable licensee public dose rate of 100 mrem/yr for 30 years (consistent with EPA treatment of other toxins) you get a fatal cancer risk of 1.5 E-3, HIGHER THAN other EPA regulated substances. There is a threshold associated with radiation, but it is an energy threshold.

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