New EPA Guidelines for Response to Radioactivity Releases

By Jim Hopf

DC Perspective

The U.S. Environmental Protection Agency just released a draft Protective Action Guideline (PAG) that sets standards and makes recommendations for the response to a large release of radioactive material into the environment (e.g., from a nuclear plant accident or a dirty bomb attack, etc.). The draft report is now out for public comments (which are due by July 15).

PAG recommendations

The PAG sets a public dose threshold of 2,000 mrem in the first year and 500 mrem in subsequent years, above which the areas in question should be evacuated. (See Table 1-1 of the PAG.) The PAG is not clear as to whether or not those same limits apply to resettlement of areas previously evacuated (i.e., if people can resettle areas after their exposure levels drop back below 500 mrem/yr). Section 3.8 of the PAG suggests that “re-entry” is allowed if annual exposure is kept under 500 mrem, but appears to say that this is only for temporary stays (to accomplish specific tasks). It’s unclear why permanent residence (resettling) would not therefore be permitted if full (annual) occupancy would not yield a dose over 500 mrem.

Apparently, the above evacuation guidelines (thresholds) are no different from the current guidelines, which were based on a 1992 PAG. The differences lie in the area of long-term cleanup standards, and (perhaps) standards for resettlement or reuse. Currently, the only guidance or precedent for such standards are the extremely strict standards that apply for EPA Superfund sites and nuclear plant decommissioning, which are based on allowable lifetime cancer incidences (for a hypothetical, most exposed individual) ranging from 10-4 to 10-6. For radiation, these standards led to dose rate limits as low as 10–25 mrem/year (i.e., far below natural background levels).

The new PAG does not appear to give any specific, recommended dose thresholds for long-term cleanup. In Section 4.1.3, it makes reference to the old 10-4 to 10-6 acceptable lifetime risk criteria, but goes on to suggest that in the case of a large scale release of radioactivity (e.g., following a severe plant accident), attaining such cleanup goals may be impractical. It then states that cleanup level (and perhaps resettlement) decisions should be made on a case-by-case basis, with inputs from local authorities and various other stakeholders, based on the principle of “maximizing overall human welfare”. In Section 4.1.4, it suggests that resettlement may be possible before the long-term cleanup goals are met, due to the fact that those goals will be met in subsequent years, resulting in acceptable lifetime exposures.

Whereas the EPA PAG does not give specific dose numbers for cleanup standards/goals, a related National Council on Radiation Protection report does talk about such values. It discussed possibly raising the allowable dose rates (for resettlement, and possibly long-term cleanup goals) to anywhere from 100–2,000 mrem/yr. That is in contrast to the existing EPA standards for nuclear plant decommissioning, which are on the order of 10–25 mrem/yr (and are based on a constant lifetime dose at those levels, and an acceptable lifetime cancer risk of 10-4 to 10-6). It did, however, go on to recommend continued cleanup efforts, even after the attainment of the (100–2,000 mrem) annual dose goal, and subsequent resettlement.

Political reaction

The EPA PAG and NCRP report have provoked a strong reaction from anti-nuclear groups, who characterize them as an enormous relaxation of radiation standards (i.e., a huge increase in allowable dose rates). In a New York Times article, however, the authors of the PAG and NCRP report insisted that they are not changing the cleanup standards or allowable dose, but are just using more accurate estimates of lifetime doses that people will receive, based on the Fukushima experience, and expected cleanup activities that will continue to occur.

I’m not entirely sure what they mean by more accurately calculating doses, when the subject is the setting of dose limits. I think that the authors are referring to what was discussed in Section 4.1.4 of the EPA PAG, where people can resettle in areas with a somewhat higher annual dose rate, while still “meeting” the old lifetime cancer risk criteria, due to an assumption that dose rates will fall off, significantly, due to decay, natural dispersion, and ongoing cleanup efforts.

Changes do not go far enough

All of these (EPA/NRC) policies and supporting analyses are based on the linear no-threshold (LNT) assumption, i.e., that cancer risk is directly proportional to radiation dose, for doses all the way down to zero. Many scientists outright disagree with this, and even most of those who do support LNT don’t really believe that the risk is truly linear, all the way down to extremely low doses (that are a small fraction of natural background). They just believe that it is a practical and conservative radiation protection policy, and that there is no better practical alternative.

It’s obvious that anyone who does not believe the LNT assumption, and believes that dose rates within the range of natural background have no health impact, will find these EPA/NRC policies to be completely absurd. I will not question or debate LNT here, however. For the reasons I discuss below, current policies—and even those suggested by the PAG—are clearly unwise, indefensible, and utterly hypocritical, even if one completely accepts LNT.

Man-made vs. natural radiation dose

My position has always been that the issue is not LNT per se, but the fact that it is selectively applied/enforced. While LNT is debatable, there is no debate among experts that a given dose has the same health impact, whether it comes from a natural or man-made source (or isotope). And yet, there is a complete black-and-white distinction between naturally caused doses and man-made doses (specifically, those from the nuclear power or weapons industries), in terms of dose limits. Government agencies assume LNT, and then apply an extremely low (and arbitrary) allowable cancer risk criterion, to arrive at extremely low allowable radiation doses. They then apply those low limits ONLY to nuclear-industry-related activities (and isotopes). Doses from natural and other sources that are orders of magnitude larger are not regulated or responded to.

How could it be that government agencies are saying that “contaminated areas” should remain off limits, and require expensive cleanup efforts, even though the overall exposure levels in those areas are lower than the natural background exposure levels in many regions of the earth (where millions currently live, with no apparent health impacts)? Under that logic, we should be spending billions to reduce doses in high natural background dose areas (e.g., Denver), or permanently evacuate those areas.

Those natural sources are responsible for annual collective exposures that are thousands of times higher than those caused by even worst-case accidents like Fukushima, let alone the nuclear industry in general. Even the individual exposures are orders of magnitude larger than those that would be allowed by the 10-4 to 10-6 lifetime risk criterion (radon exposes hundreds of millions of Americans to a lifetime cancer risk on the order of ~1%). Many of those natural doses (such as radon) would also be orders of magnitude less expensive to reduce (in terms of dollars per man-Rem avoided).

For these reasons, annual dose limits that are a small fraction of natural background, which only apply to nuclear-industry-related sources, are clearly indefensible. The policy solution to this is obvious. Government agencies need to be told that they are no longer allowed to apply policies or regulations that distinguish in any way between different sources of radiation (e.g., natural vs. man-made, etc.). Dose is dose, period. They need to establish what safe dose levels are, regardless of source, for normal (long-term) and accident/event (short-term) conditions. The only possible exception to that may be medical exposures, under the argument that they have an offsetting health benefit.

I can possibly understand the desire to set very low exposure limits (far below the level that poses any significant health risk) for normal nuclear industry operations, based on a “good industrial practice” philosophy. Routine releases really are unnecessary and easy to avoid, and we may want to avoid long-term buildup of man-made isotopes in the environment. However, unless the above reasoning is not clearly explained to the public, such policies may be counter-productive. The public will (understandably) tend to think that doses above the limits represent a significant health threat. In the event of an accident, the government will have to apply much higher limits, and then will have to explain that those higher doses are not really a significant health threat. This will result in a loss of public trust. A better stance would be to establish higher “public health and safety” dose rate limits around the top of the natural range (i.e., on the order of a Rem/year), but then say that much lower limits will be applied for normal operations since there simply is no reason why any significant releases are necessary, or should be allowed.

Cost vs. benefit

These extremely strict dose limits are yet another example of society spending enormous sums of money to reduce or eliminate tiny risks in one area, while ignoring vastly larger, and cheaper to reduce, sources of risk in other areas. This may be true of the (chemical toxin) EPA Superfund cleanup requirements, as well as the nuclear-related requirements.

The PAG and NCRP reports, and their authors, discuss the 10-4 to 10-6 “acceptable” lifetime cancer risk criteria, and how they will be maintained. To me, something seems odd about such stringent requirements in a world where ~25 percent of the people die of cancer. Clearly, there are much larger sources of risk that these regulatory bodies are failing to protect us against. That is, there are many industries or aspects of life where these strict risk standards are clearly NOT being applied. (Automobile exhaust, coal plant emissions, and the fact that coal ash is still not classified as a toxic material comes to mind.) It seems clear that this is yet another case of selective application/enforcement of overly strict requirements; another double standard.

My understanding is that the government has general public safety policies (for industrial projects/activities, building codes, etc.) that require that ~5–10 million dollars be spent per (expected) life saved. These same policies should apply for the cleanup and resettlement of nuclear-contaminated areas. At some point (dose level), the cost of continued cleanup up effort will exceed $5–10 million per life saved (even assuming LNT). At that point, cleanup efforts should stop.

This is especially true given that there are many ways to save lives that cost far less than $5–10 million per life saved. According to this article, the EPA’s proposed soot rule would only cost ~$5,000 per life saved. Also, according to my calculations, radon abatement (in a large fraction of U.S. homes) would cost only ~$100,000 per life saved (again, if you believe LNT).

Collective exposure vs. maximum individual risk

If one believes that there is a dose threshold (below which no health impacts occur), it may be logical to establish limits on dose rate (or annual dose) for individuals that are near that threshold. However, if one truly believes in LNT, limits on individual exposure have no logical basis. A simple mathematical result of the assumption that health risk scales linearly with dose is that the total health impact (i.e., numbers of sicknesses or deaths) scales directly with the collective exposure (in man-Rem). At the end of the day, the number of cancers is all that matters. Individual risk, and whether or not it is “acceptable”, is almost meaningless. Each person either gets cancer or not, and only the number of cancers matters.

Current limits invoke LNT (as they are far below the levels at which any health impacts are seen), but then establish extremely low limits on maximum individual risk (i.e., 10-4 to 10-6), as opposed to limits on collective exposure (in man-Rem). The way these current limits work, spreading the risk (pollution) out (e.g., tall smoke stacks) helps one comply with the limits, even though LNT (the very basis of those low limits) holds that spreading the risk out does not reduce the impact at all. It’s fallacies like this that make it possible for extremely low dose limits to apply for localized decommissioning or Superfund sites, that are having negligible impact, while fossil fuel air pollution (cars and coal plants) are causing tens of thousands of deaths every single year.

If LNT is to be the basis, correct policy would be to place limits on collective exposure, for any given industrial activity. For cleanup operations (or pollution prevention for that matter), a certain amount of money per man-Rem avoided should be required. Such policies would direct attention away from localized sites and towards more widespread pollutants that are actually having far larger health impacts. One thing is clear; these extremely low (10-4 to 10-6) limits on maximally-exposed individual dose have no logical basis and are completely indefensible.

Call to action

protective action guide 2013 c 201x259The draft EPA PAG is open for public comment until July 15. I urge American Nuclear Society members to respond. My personal view is that expensive cleanup operations or not allowing resettlement in areas with annual doses within the natural range (i.e., under ~1,000 mrem/year) is neither rational nor defensible. It wastes limited resources on a small to negligible public health benefit, and it inflicts needless suffering on the local population.




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.


31 thoughts on “New EPA Guidelines for Response to Radioactivity Releases

  1. Brian Mays

    Bas – So you agree that your argument has torn to shreds, yet you continue to repeat the same silly nonsense over and over.

    Insanity: doing the same thing over and over again and expecting different results.

    — Albert Einstein

    Albert must have once met someone like you.

  2. Bas

    Indeed the meta study did not find direct cancer effects, but showed a number of other negative effects that increase the chance on cancer:
    “The scientists reported significant negative effects in a range of categories, including immunology, physiology, mutation and disease occurrence. The frequency of negative effects was beyond that of random chance. “.

    Those effects of low level radiation (stillbirth, Down, etc) are confirmed by other studies. E.g.:

    That 6 mSv/yr generate ~4% to die prematurely, is in line with the results of the famous LSS studies, etc.
    Note that low level radiation generates also other fatal diseases, just as nicotine.

  3. Brian Mays

    But such increases are found! A 2012 meta-study (review) published …

    No they haven’t been.

    Geez … you keep bringing up that data dredge by the scientific fraud. Would it stop you from mentioning it if I pointed out that the meta-study failed to find a statistically significant effect for cancer? It doesn’t even support the incorrect claim that you’re trying to make.

    Your 6 mSv/yr generate that ~4% die prematurely. That may be part of the reasons that people in US live even shorter than those in Cuba (CIA fact book, as well as UN HDR reports).

    Just when I thought you couldn’t say anything even more stupid, you come up with this gem.

  4. Bas

    … increase in cancer correlated with these differences. Nevertheless, no such increase has been found …
    But such increases are found!
    A 2012 meta-study (review) published in the prominent Cambridge journal ‘Biological Reviews’ also found those. For an easy reading account:

    Your 6 mSv/yr generate that ~4% die prematurely.
    That may be part of the reasons that people in US live even shorter than those in Cuba (CIA fact book, as well as UN HDR reports).

    Note that low level radiation generates far more diseases than only cancer (heart diseases, etc). Just like asbestos, nicotine, micro-particles, etc.

  5. Brian Mays

    Bas – Dose rate matters. The typical American already receives about 6.2 mSv per year already; however, this amount varies widely depending on where one lives and what one does. If your claim were true, it should be possible to detect an increase in cancer correlated with these differences. Nevertheless, no such increase has been found in numerous studies that have been conducted.

    Please stop trolling these sites with nonsense.

  6. Bas

    “I wrote: … LSS report no 14 proofs 5mSv in 60 years deliver enhanced chance on premature death (~3%)…
    Your post at April 25: No it doesn’t. …

    At April 17 you posted at Atomicinsights (summarized):
    “I refer to Figure 5 of the report…
    Sure, best estimate for threshold in linear model is 0 Gy, but the upper bound is 0.15 Gy. So, they can’t say with statistical certainty that there’s not a threshold as high as 150 mSv.”

    That implies you admit any threshold to be 300 mSv is harmful.
    And extra radiation of 5 mSv/year over 60 years =>300mSv => harmful.
    In line with your own statement of April 17.

  7. Bas

    In your answer to Robert, you wrote:
    “… not sure how this would affect Japan … not sure they are following US policies … why they are not allowing resettlement of the lower dose areas.”

    In line with the new recommendations of the UN linked Codex commission, Japan lowered the max. allowed radiation limits by roughly a factor 10 in 2012.
    Japanese limits are now ~10 times below the US and EU limits.
    Seems that Germany is busy to convince the EU to follow.

  8. Bas

    … no difference in impact between natural and man-made doses …
    Fully agree.

    … defend doing nothing about … other/natural sources while spending vast sums of money to clean up … exposures are miniscule …
    As a smart authority you would do the same.
    There is a huge difference between risks people choose, and risk that is forced upon them while they are aware of it (and not used to it).

    For the US, you’ll get trials for compensation if a Down syndrome is born. Authorities hate to go down. And that will happen then in public.

    Complainers will be supported by radiation experts.
    These experts show studies about significant enhanced chances (on Down, neural tube defects, stillbirth, etc.) with raised radiation levels of only 0,2mSv/year.

    So how can an authority then convince the public that it is reasonable to accept the extra risks for such serious birth issues (for all defects together it will be >1% at 2mSv/year) that destroy peoples life (partially).

    Because NPP’s electricity is a few cent/kWh cheaper on the expense of the handicapped family with a Down child and/or the tax payer?
    While many experts are convinced that PV panel solar (incl. some storage) will become cheaper than nuclear in <10years (despite the huge liability subsidies that NPP's enjoy).

    I do not see how that authority can save his skin.
    May be you do?

    In NL we see the first actions regarding radon in houses.

  9. JimHopf


    My case is still rock solid even if it were true that high natural background doses were having a significant impact. If those higher natural doses were having the effects that you (and your sources) assert, then how can we justify doing absolutely nothing to reduce those natural doses (or even warn the public about them)? My main point is that there is no difference in impact between natural and man-made doses, so applying different standars/responses to them is completely indefensible.

    Natural background doses, from sources like radon, etc.., result in collective exposures that are thousands of times larger than those that result from even a worst-case nuclear accident. Many of those natural sources would also be far cheaper to reduce (dollars per man-Rem). So, how can you defend doing nothing about those other/natural sources while spending vast sums of money to clean up the land around a (post accident) nuke, even though the collective exposures (from the nuke accident) are miniscule in comparison?

  10. JimHopf


    I actually agree with you that a threshold would not be harder to administer. What I was describing is not what I believe, but what THEY believe, i.e., the experts who continue to support LNT as the basis for radiation protection policies. This is based on quotations I’ve heard from various experts (from ICRP and BEIR, etc..).

    They basically said that it probably is not truly linear all the way down to zero, but that there is a lot of uncertainty (since any effects are in the noise), and therefore LNT remains the best practical policy since it is clearly conservative and straightforward to administer. The point I was making is that even the experts that support LNT as a policy don’t really, truly, believe that it is linear all the way down to zero.

    In a related matter, those same expert bodies have recently stated that using LNT to calculate extremely small risks and then summing them over very large populations to get significant health impacts is not a proper use of the theory/policy. That is telling since if you truly believe in LNT (all the way down to zero), then it WOULD be appropriate, mathematically, to do that.

  11. JimHopf


    I don’t disagree with anything you are saying, and all efforts to get rid of LNT and establish a valid threshold will have my full support. It just boils down to the question of what the most effective arguments are, at this juncture and with the bodies in question (i.e., EPA, as well as NRC, ICRP, BEIR, etc..). My personal view is that arguments showing these policies to be blatently hypocritical even if LNT is assumed will be particularly potent.

    You’ve probably read my earlier ANS post about how to reduce nuclear costs, and NQA-1. If you asked me my opinion as to whether eliminating LNT or eliminating NQA-1 would produce greater cost reductions, I would probably choose NQA-1.

    Would eliminating LNT result in the elimination of NQA-1, and absurdly strict NRC design and construction requirements/regulations in general (since preventing a large-scale release is no longer “important to safety”)? I’m not sure. There seems to be a mindset in the industry that a severe nuclear accident (and large scale release) is simply unacceptable, period. It seems to not be directly tied to public health impacts (anymore).

    Case in point, NRC saying that regulations need to be tightened even further as a result of Fukushima, despite the complete lack of measurable health impacts. Their arguments seem to be based on the societal impacts (long term evacuation and economic impacts, etc…). Now, I know that you’ll argue that those very impacts are only due to policies/actions that are based on LNT. From a factual perspective, I agree with you. On the other hand, I’m not sure I can imagine society simply ignoring a large-scale release of radiation. Too much ingrained fear and deep-seated prejudice against the technology. Perhaps these are fights that we must win, but it’s going to be a long slog……..

  12. Brian Mays

    LSS report no 14 proofs that 5mSv in 60 years deliver enhanced chance on premature death (~3%).

    No it doesn’t. You need to learn about statistical significance. If I ignore statistical significance, then I can make an equally valid case that the LSS demonstrates that exposure to low doses of radiation reduces the risk of getting cancer.

    raised stillbirth levels in W-Europe after Chernobyl (rise of 1 stillbirth per 1000 babies) with enhanced radiation levels ~o,4mSv/year: …

    You need to do better than a weak ecological study with poor statistics and an even weaker methodology.

    Regions with high background radiation are often in the mountains having better air (less micro particles, etc).

    Oh please. Just how much more ridiculous are your claims going to get?! You’re embarrassing yourself.

    If you compensate for those than higher background radiation delivers more premature death: …

    Not that junk paper again! A dredge through the literature to cherry pick a handful of papers that can be perverted to support the authors’ predetermined conclusions doesn’t impress me and shouldn’t impress anyone else either. I guess that it shouldn’t surprise anyone that this “study” was performed by a guy who was found guilty of scientific dishonesty in his home country ten years ago.

  13. Bas

    …How could … agencies … require expensive cleanup efforts, even though the overall exposure levels … are lower than the natural background exposure levels in many regions of the earth (where millions currently live, with no apparent health impacts)?…

    The issue is that your last addition:”.. with no apparent health impacts)?” has been proven to be false. Especially if you look at fetus in the uterus and babies. Some studies:
    – LSS report no 14 proofs that 5mSv in 60 years deliver enhanced chance on premature death (~3%).
    – raised stillbirth levels in W-Europe after Chernobyl (rise of 1 stillbirth per 1000 babies) with enhanced radiation levels ~o,4mSv/year:
    Those babies also had significantly more often Down syndrome, etc.
    – Regions with high background radiation are often in the mountains having better air (less micro particles, etc). If you compensate for those than higher background radiation delivers more premature death:
    (check also the studies showing supra LNT at low doses)

  14. Cal Abel


    Thank you for getting this topic out there. I think we will continue to see such regulatory creep (EPA & NRC) as long as the idea of ALARA is on the books, 10CFR20.

    I basically hold LNT as an entirely artificial construct, which any model is, but one that does not match reality. I think there is a threshold dose response, and that a threshold model more closely matches reality. This can easily be tested using Bayesian hypothesis testing, basically a ratio of the information entropy of the residuals. The one with the lowest entropy wins. (E.T. Jaynes, 2003, “Probability Theory: The Logic of Science”)

    I question the argument that LNT is needed because it is a simple regulatory model and that a threshold is too difficult to regulate. Below is a paper where I test this hypothesis by adapting a simple threshold based modern regulation, OSHA’s hearing conservation, to radiation exposure. What I found intriguing was that when this was done, several consequences came about. First is the definition of a radiation area and a high radiation were in a sense derived based off of continuous exposure rates and 15 minute exposure rates. Also the impulse dose rate just using the ratio of OSHA was consistent with AEC research in the late 1940’s before the quackery of LNT was introduced.

    This approach even allows for methods of energy discrimination and adjusting the radiation meter indications based on known radionuclide concentrations, expected energy distribution of measured radiation. Instead of just compensating for one isotope, Co-60, we can use in situ information.

    Also by defining a regulatory threshold, regulatory creep is contained.

  15. Joris van Dorp

    Thanks for the article and the comments. Very illuminating, also for a non-nuke like me.

    Thanks Rod for your analogy between slavery in olden days, and the demonization of nuclear power + dominance of fossil hegemony in today’s world. I’m going to be employing that one with a lot of enjoyment.

  16. Rod Adams


    I should have proofread more carefully.

    In the 6th paragraph above, I have a typo:

    “If we treat radiation with respect and recognize where is really is dangerous and where it is not”

    Should be:

    “If we treat radiation with respect and recognize where it really is dangerous and where it is not”

  17. Rod Adams


    I am getting to old to be accommodating to people who are just plain wrong. I don’t really care if I offend them or shake their core beliefs.

    Since some of those people are in positions of appointed or elected power, my mission is not an easy one. The nice thing is that I am an American, living in a country where defiance of just plain wrong policy, even when supported by the most “powerful” people in the land, is a long and valued tradition.

    The most valuable “asset” in America in 1845 was the several million people held in bondage enforced by the laws of about half of the states and allowed by “the law of the land”. That did not stop people from challenging the law and telling the powerful that they were wrong.

    Your guess about where the threshold might be is still a couple of orders of magnitude too low. Jerry Cuttler, Wade Allison, Myron Pollycove, Ed Calabrese, and others have done the hard work in discovering that a chronic dose rate of about 100 Rem (1000 mSv) per year does not raise cancer rates by a measurable amount. At a range of levels below that, there is a 20-40% health benefit.

    Since that is true, the real impact is enormous. The powerful will resist because letting that truth out will shake the foundations of a large portion of today’s fortunes that are built on various aspects of the world’s largest enterprise – that of finding, extracting, transporting, refining, and consuming hydrocarbons from reservoirs often located in other people’s countries.

    If we treat radiation with respect and recognize where is really is dangerous and where it is not, we would be able to drive the cost of building nuclear fission power systems to be roughly the same as the cost of building hydrocarbon based heat engines, but the effort required to fuel those machines and dispose of the waste products would be several orders of magnitude easier (less costly) because of the energy density and cleanliness of the process.

    Keeping that technology out of the reach of billions of people is far worse than slavery because it concentrates even more wealth at the top and forces so many others to either do without power or to pay a substantial fraction of their income in tribute to the people who control access to hydrocarbons.

    Here’s my bottom line – if anyone told me, my family, my friends or my neighbors that we had to leave our homes because they were contaminated with radioactive material, I would defy the order and work hard to encourage others to do so as long as a reasonably accurate estimate of the dose rate was less than 10 REM (100 mSv) per month. That is so extraordinarily unlikely that I would call it impossible; the max dose rate to the public from any conceivable event spreading contamination over a large area would be far lower than that.

    Rod Adams
    Publisher, Atomic Insights

  18. JimHopf


    The PAG may seem to imply a 500 mrem/yr resettlement policy, but it is not clear. Discussion with the authors implied that they would allow resettlement only if they thought that nobody in that population would receive more than a 10-4 lifetime cancer risk (assuming LNT, of course).

    They only “relaxed” the policy to allow consideration (and assumptions) of significant fall off in annual doses due to decay and natural forces in addition to continued cleanup efforts (an important point). But the (absurd) 10-4 requirement still stands, they insist. This basically means that the average lifetime exposure for the resettlers (ONLY from the isotopes released from the plant, mind you!) still must not exceed ~10-25 mrem/year (somewhere in there). This is clearly insufficient reform.

    Anyway, if one did really allow a 500 mrem, or 1,000 mrem, threshold for resettlement, it would make a huge difference, vs. both the old US policies and the (only sort of) revised policies proposed in the PAG. I’m not sure how this would affect Japan, however, since I’m not sure they are following US policies in this regard. I’m also, frankly, no sure why they are not allowing resettlement of the lower dose areas. Any notion that it’s because they’re worried about another release from the plant makes me furious (that being another subject…..).

  19. JimHopf


    I never said that I believe in LNT. I basically don’t. I believe that there is most likely a threshold around the top of the typical natural range (i.e., ~1 Rem/yr), below which there are no health impacts. I also believe that if any impacts were present, they’d be miniscule, and far too small to measure. In a world filled with real, tangible, much larger risks, things that are too small to measure are too small to matter, in my view.

    My point was simply that these policies are clearly indefensible and hyprocritcal even if one does assume LNT. I think that is a point worth making. I’m not sure we want to tie any progress against these ridiculous requirements to convincing the scientific/bueaucratic bodies that be (e.g., ICRP) to admit they were wrong all along and to drop LNT. That may take awhile. In fact, there is a good chance we won’t succeed, frankly.

    I know that I talked alot about radon, but I wasn’t actually suggesting that we embark on a large radon abatement program. I found the radon example to be a particularly good one in terms of exposing the absurdity (and hypocrisy) of the nuclear cleanup requirements. There we have a huge population (hundreds of millions) being subject to a lifetime radiation exposure that is actually orders of magnitude larger than the lifetime allowables for a localized site (and a handful of potentially exposed individuals). My point was that, given this, the absurdly strict requirements for nuclear cleanup are unjustified.

    I was making what I thought to be an extremely compelling point, even to people who insist on believing LNT. If you believe LNT, how can you except having hundreds of millions of people getting several hundred to ~1000 mrem/yr, resulting in a lifetime cancer risk of ~1% (according to LNT), but absolutely not allow (almost regardless of cost) a handful of people getting more than a 10-4 lifetime risk. It’s an argument that nobody can ignore, even of you set the LNT debate aside.

    I think that arguments like these (i.e., pointing out clear and blatant hypocrisy) are our best chance of getting things to change (e.g., getting them to relax the requirements for long-term cleanup after a severe accident). I doubt the organizations in question will listen to dose threshold (no-LNT) or hormesis arguments.

  20. Robert Hargraves

    Jim Hopf’s recommendation is a 10 mSv/year limit to resettlement of evacuated areas, and that the PAG implies a 5 mSv/year limit.

    What would be the impact of such limits on Fukushima resettlement?

    [I signed already.]

  21. Rod Adams


    Though I agree with your basis premise that the unfairness between the standards for risk for certain “man-made” influences and other similarly risky influences is a problem, I strongly dispute the implication that it would be just as acceptable to tighten all standards and expend the money doing things like mitigating radon exposures.

    Unlike you I do challenge the LNT and all other non-threshold dose response assumptions. No, Bob Applebaum, I do not seek a special exemption for radiation but believe that the work of people like Ed Calabrese who publish in the Dose-Response journal not only shows empirical evidence of unmeasurably low risk below a threshold, some of the papers have explained the biological mechanisms leading to a systematic response of multicellular creatures to certain levels of substances and energy sources that would be hazardous at substantially higher dose rates.

    Studying the impact on single cells tells scientists nothing about the impact on beings made up of billions of cells that each have specialized functions allowing them to function as systems. We are no longer limited to the scientific knowledge available to Mueller in the 1950s. We can sequence DNA, have incredible computing power, and have electron microscopes that can detect things that Mueller and his colleagues could not have imagined.

    There is a dose at which the risk to anyone from a substance or radioactive dose is zero, but below that dose, the substance or dose actually stimulates repair mechanisms that provide a generally positive response. It makes so much sense for those of us who have always known that a moderate amount of exercise, a moderate quantity of wine, a moderate quantity of food and the correct dose of medicine leads to improved health, while excessive amounts of each can be harmful or even deadly.

    It is absurdly simplistic to believe that the most accurate model of radiation response is a straight line. Stubbornly clinging to that 1950s vintage model is roughly analogous to the statement made by the patent examiner in the late 1800s about wanting to close the office since everything worth inventing (or knowing) has already been invented.

    I want the government to use the best available science, which is not represented by a bunch of appointed scientists sitting around choosing which studies they like and discarding all of the ones that do not support their preexisting conclusion because they all know that their LSS funding might dry up if they actually included contradictory evidence.

    Dr. Nelson should not be controlling our regulatory assumptions and should not be denying people the potential benefits that can come from more reasonable models about how radiation affects human beings – who are made up of refined biological systems, not isolated cells.

  22. Brian Mays

    I did not challenge LNT.

    Jim – Of course you didn’t. Don’t take it personally. Rabid evangelicals don’t need a valid reason to preach. It’s what they do.

  23. JimHopf


    Your view is shared by many, but it is one I disagree with. I spoke to your point in the following sentences:

    “Individual risk, and whether or not it is “acceptable”, is almost meaningless. Each person either gets cancer or not, and only the number of cancers matters.”

    I’m not sure how else, or better, to say it. At the end of the day, what happens is that a certain number of people get cancer, and that number should be minimized. The only tangible reality, for each individual, is that they either get cancer or not.

    One could try to argue that if a significant fraction of the population of a given locality all got cancer, it may have a negative local sociological impact (beyond the impact to the individuals), but the levels of individul cancer risk we’re talking about here are far too low for that to be an issue.

    In any event, the case is very strong even if one just looks at individual risk. Radon exposes hundreds of millions of Americans (i.e., individuals) to a ~1% lifetime cancer risk, and the govt. is doing nothing about it (not even warning people about it). Same for living in high natural background areas. Thus, they are allowing individual risks that are 100-10,000 times higher what they allow for the nuclear/Superfund sites (even though for those cases we are talking about only a handful of hypotehtical most-exposed individuals).

    If ~100 million Americans can get ~1 Rem/year from radon, w/o any concern from the govt., then a small number of local, affected individuals should be able to get ~1 Rem/yr living in the “contaminated zone” in the aftermath of a major nuclear accident.

  24. JimHopf


    I did not challenge LNT. All of my arguments assumed that it applies. My point was that these policies are arbitrary, irrational and indefensible even if LNT is assumed to be completely true.

    I’m not asking for a special privelege. Quite the reverse. The point is that these ultra-low limits are ONLY applied to Superfund, nuclear site decommissioning, and (apparently) cleanup after a major release of man-made radioactivity. Meanwhile, vastly higher doses (chemical or radiological), and risks in general, are allowed in all other walks of life, which amount to vastly higher individual lifetime exposures, collective exposures, and overall public health impact.

    In terms of nuclear VS. Superfund, you are right. What my arguments show is that the Superfund (chemical) standards are deeply questionable (i.e., indefensible) as well. What I’ve learned in this exercise is that the Superfund program (and standards) is basically a joke; an immense and tragic waste of America’s public health and safety dollar. Applying that money to reduce coal plant emissions, auto emissions, even radon abatement, would save orders of magnitude more lives (assuming LNT).

    Apparently, the govt. thinks it’s not OK for a handful of (hypothetical) maximally exposed individuals to get more than 10-4 (or even 10-6!) lifetime cancer risk if they wander onto (or occupy) a localized industrial site, but it’s perfectly OK for hundreds of millions of Americans to suffer a ~1% lifetime cancer risk from radon!

    We’re talking about a collective exposure of ~100 million man-Rem per year in the US, that EPA claims (using LNT) causes ~36,000 deaths every single year. Allowing a ~1 Rem/yr radiation level after a significant nuclear accident results in a collective exposure of only a few hundred thousand man-Rem per year (i.e., 0.1% to 1% as much). Cleaning that area down to, say, 15 mrem/yr would cost far more than it would to greatly reduce the radon dose.

    What I’m asking for is a lack of “special treatment”, and an end to capricious and arbitrary policies, and huge double standards. We need to apply our resources to risk reduction objectively and rationally, so that our finite amount of resources reduce overall risk as much as possible.

  25. Josiah Narog

    I agree with your basic premise, but isn’t there also a logical limit to your proposed focus on total “man rems”? I mean, if a given activity dramatically increases the risk of cancer occurance for an individual, but that activity applies to only a single individual, it might not increase the total “man rems” sufficiently to merit attention, but it would still be wrong.

    The total man rems on the Enterprise may have been low, but boy did Spock get the lion’s share of them.

    I apologize if I’m mis-understanding your point, but I think that some blend of maximum individual exposure combined with cumulative exposure seems reasonable, albeit the maximum individual exposure limits should be much much higher.

    Let me know if I’ve gone sideways or if that makes sense.

  26. Mike Keller

    Government regulations and logic are generally incompatible, particularly when the bureaucrats have an agenda to push. The EPA is a classic example.

  27. Cory Stansbury

    Signature #44 here.

    I wonder what the effect on fracking costs would be if all wastewater was regulated by the NRC. After all, sampling of waste treatment plants often show radioactivity >3000x the drinking water limit and >300 times the NRC allowable discharge limit from Nuke plants. Not only does the absurdity of radiation regulations irk me, but the selective focus is just asinine.

  28. Andrea Jennetta

    Fantastic, Jim! Thank you for plainly and clearly stating what we in the industry have felt for a long, long time. I plan to circulate this post widely.

    On a related matter, you might have already seen and signed what I call the “LNT sucks” petition on the White House website. We are up to 85 signatures–which for the lame, apolitical nuclear industry is extraordinary.

    Just in case you haven’t, here it is:

    I’m asking people to let me know their signature #–I’m signer #13–as a way to get them excited and to follow up with well-deserved shout-outs for getting off their asses and DOING something (for a change).

    Sure it’s symbolic, but it can certainly send a message to TPTB that we’re angry and we’re not gonna take it anymore. :) It is also a way for individuals in the nuclear energy industry to get in the habit of being political.

    Politics is the ONLY thing holding us back.

    Thank you, thank you, thank you!

  29. James Greenidge

    What’s good for the goose is good for the gander, and one good publicity way nuclear energy can erase its evil radiation stain is for some bold legal eagles at the Atomic Workers Unions and Nuclear Professional organizations to challenge the EPA for singling out nuclear plant emissions for scrutiny and ignoring the higher radioactive emissions of coal fired-plant smokestacks. All we need is a daredevil to climb a smokestack with a Geiger counter and a eager beaver news crew hungry for a major scoop! (Hey, if such positively works for Greenpeace…) Imagine the EPA being forced to shut down non-nuclear faculties around the country that don’t meet rad emissions regulations imposed nuclear plants! I’d savor just to see the legal challenge and the EPA dance!

    James Greenidge
    Queens NY

  30. Bob Applebaum

    You seem to want special priviledge. The EPA uses 10-4 to 10-6 for all the toxics they regulate. LNT is not debatable in a scientific sense. There is no known mechanism which prevents a single photon from posing cancer risk. If you know of one, collect your Nobel Prize.

  31. Brian Mays

    It’s not about preventing cancer. If the US government wanted to prevent cancer, it could ban tobacco, ban alcohol (again), ban all wood stoves and fireplaces, and establish a buffer (evacuation) zone around every freeway and interstate. Any of these ideas would be more effective at preventing cancer than these EPA guidelines, and that’s just the beginning.

    If they are really interested in preventing cancer they could make shift work and stir-frying illegal (both have been determined by the World Health Organization to increase the risk for cancer). Isn’t it ironic that the worker manning the graveyard shift at a nuclear power plant is possibly more at risk of getting cancer from the hours that he works than any radiation that he is exposed to at the plant?

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