NukeWorker Forum
News and Discussions => Nuke News => Topic started by: Marlin on Jul 15, 2014, 03:17
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Absurd Radiation Limits Are A Trillion Dollar Waste
http://www.forbes.com/sites/jamesconca/2014/07/13/absurd-radiation-limits-are-a-trillion-dollar-waste/
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This is a great article. I love the guy James Conca. He is a huge asset to nuclear power.
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As mentioned - great article.
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These limits are in place, purposely restrictive, to provide and ensure a significant buffer zone between the escalation of a simple industrial mistake and a truly catastrophic event.
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These limits are in place, purposely restrictive, to provide and ensure a significant buffer zone between the escalation of a simple industrial mistake and a truly catastrophic event.
Even so the limits are too restrictive even the overly conservative (and ideological in my opinion EPA) now thinks so. Reference excerpt from article.
"For a nuclear waste repository like Yucca Mt, it’s even more absurd. We have to make sure the dose to a distant drinking water well won’t exceed 4 mrem in the year 4000 A.D.
Keep in mind that we radworkers can get 5,000 mrem/year and think nothing of it. We’ve never had problems with these levels. Emergency responders can get up to 25,000 mrem to save human lives and property. I would take 50,000 mrem just to save my cat.
Therefore, using 25 mrem to force-evacuate New York City seems overly cautious.
This wouldn’t be bad if it didn’t have really serious social and economic side-effects, like pathological fear, significant deaths during any forced evacuation, not getting medical procedures you should have, shutting down nuclear power plants to fire up fossil fuel plants, and a trillion-dollar price tag trying to clean-up to levels even Mother Nature doesn’t care about (WSJ; Heartland).
Keeping to these present ultralow levels, and similar levels promulgated throughout our regulatory arena (Atomic Insights), has cost the United States about $500 billion since 1970, and will cost us a lot more in the years to come (Low-Level rad Summit).
Take a national nuclear waste repository like Yucca Mt. To make sure that dose to a distant drinking water well won’t exceed 4 mrem in the next 100,000 years, will cost about $180 billion over 60 years, and that’s if it goes without a hitch. Lots of other costs are not covered in that $180 billion, like the cost to prepare the waste to go there, one task being to turn 57 million gallons of waste up at Hanford, Washington into glass. The vitrification plant being built to do this, and the 40 years to operate it, will cost another $90 billion, and has had nothing but hitches. If more science-driven decisions were made, these costs would drop by seventy to eighty percent (Reason).
Fortunately, the EPA is now considering 5 rem (5000 mrem) as a more reasonable radiation threat level for evacuation, based on historical events, previous regulations and knowledge from nuclear experts (NYTimes). This particular change will be for only one of the regulations governing radiation, the one-time dose from an attack or an explosion, but will have a huge effect on all the other regulatory guidelines as well (Washington Energy Report)."
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Further reinforcing the opinion of overly conservative limits.
Fukushima Evacuation More Dangerous than Radiation, Doctors Say
http://ndreport.com/fukushima-evacuation-more-dangerous-than-radiation-doctors-say/
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These limits aren't too low.....Trust me, I'm a professional!
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Sew, watts the limits proposed? 5r/year? dose the public the same as professionals? rays the effluent limits by e6?
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Sew, watts the limits proposed? 5r/year? dose the public the same as professionals? rays the effluent limits by e6?
Articles lately seem to depend too much on inserted links, this is from a link in the article. Probably easier to read than the article I cited.
Raising the EPA Radiation Limit Will Save Thousands of Lives and Billions of Dollars
The EPA is raising the radiation threat level by a factor of 350. That may sound unbelievable but it is assuredly a good thing: The previous limits were far lower than science justified and caused hundreds of billions of dollars of economic loss to America and the world.
http://reason.com/archives/2014/07/06/raising-the-epa-radiation-limit-will-sav
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Over the years, radiation protection standards have exhibited a downward trend to more rigorous limits that require increased commitments of personnel and resources for their enforcement. There are several reasons for this trend, including increased recognition of the long-term health effects of radiation, improved protection measures that permit radiation use at lower levels of exposure, growing numbers of persons exposed occupationally to radiation, and a greater intolerance to involuntary risks in society, with radiation targeted as a highly visible source of involuntary risks in the form of nuclear power plants and radioactive waste sites.
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Over the years, radiation protection standards have exhibited a downward trend to more rigorous limits that require increased commitments of personnel and resources for their enforcement. There are several reasons for this trend, including increased recognition of the long-term health effects of radiation, improved protection measures that permit radiation use at lower levels of exposure, growing numbers of persons exposed occupationally to radiation, and a greater intolerance to involuntary risks in society, with radiation targeted as a highly visible source of involuntary risks in the form of nuclear power plants and radioactive waste sites.
I agree that is the conventional wisdom but I don't think it reflects reality. We can look at a long period of exposure records with no attributable effects due to occupational dose or even effects detectable in greatly varied background radiation around the world . Part of the reason for raising the limits is an imbalance of other risks such as evacuating personell where stress kills and no effect is calculated for exposure to the public (Fukishima). 4 mr/yr in drinking water in in the next 100,000 years for Yucca mountain is another example of overkill. Further is the recognition that the linear model of dose effect is not valid based on years of occupational exposure. Much of the calculated effects of exposure depends on the old model that seems irrelevant now.
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no buddy has bin evacuated domestically four a very long time, sew the article must have Ben written to encourage the lowering of the effluent rates and using the e.p.a. changes as cover. easement of effluence would have a moor immediate positive impact for the business.
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The fundamental principles of radiological protection, justification, optimisation and the application of dose limits, underlie the constantly evolving nature of our endeavor. Radiation and its effects is the most studied all physical phenomenon. Objectively, the limits currently in place represent the sum of that collective wisdom and substantial resource investment.
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The fundamental principles of radiological protection, justification, optimisation and the application of dose limits, underlie the constantly evolving nature of our endeavor. Radiation and its effects is the most studied all physical phenomenon. Objectively, the limits currently in place represent the sum of that collective wisdom and substantial resource investment.
While that's a true statement as far as it goes, it doesn't utilize that collective wisdom. The basic underlying assumption of the linear, no threshold risk assessment for chronic exposure is not born out by observed data. I think that is the fundamental argument presented in this thread. Another example would be that many of the EPAs limits for radioactive materials occurring in nature are below what mother nature provides in our environment.
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The fundamental principles of radiological protection, justification, optimisation and the application of dose limits, underlie the constantly evolving nature of our endeavor. Radiation and its effects is the most studied all physical phenomenon. Objectively, the limits currently in place represent the sum of that collective wisdom and substantial resource investment.
Again I agree with you from the standpoint of conventional wisdom but the very studies that you mention drive a new perspective. Linear dose response is losing it's influence as a driver of regulation as there is evidence to the contrary in the data collected over the years. Much of our dose effect prediction is based on on a non-threshhold linear dose response. As it loses ground in the application of dose limits and the calculation of dose effect prediction, limits and predicted dose will fall. This has been coming for a long time. The sum of the wisdom gained as you put it validates this approach. At one time internal dose was to be avoided unless the licensee provided the NRC justification so respirators were the name of the game for all airborne contamination work, now "dose is dose" and respirators are viewed in the terms of ALARA and relative risk as heat stress and other physical risk can be considered. This is just part of a natural evolution of radiation protection for the very reasons you state. we have done many studies and have a better understanding than the days when reddening of the skin was a dose limit. What happens if we find a cure to all cancers what happens to dose limits then when we bend another dose risk downward.
Once again I agree that there has been a lot of study and data collection that has shaped our current state of regulation but it will also shape the future of the regulatory landscape. There does not seem to be a lot of opposition to these new dose limits even in the EPA which I do not see as a pro-nuclear agency so I am inclined to think it will continue to influence dose limits and dose calculations further in other agencies as well.
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We figured out the consequences of low doses of radiation a long time ago. Today the limits are based on public perceptions and political cya. We have plenty of old data giving mounds of evidence based on millions of cases that low levels of radiation have small effects if any. You can find plenty of questionable data out there to provide evidence in the other direction too. Reminds me of how in the 70s people thought a stick of butter was going to kill them. And today's new demon is cholesterol. It takes alot of oomph to tread through all the data and find the most realistic "truth".
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Historical precedents suggests erring on the side of caution. Examples abound. Michaelson-Morely 1887, Einstein 1905, Hubbell 1929, Penzias-Wilson 1964. We are waist deep in a topic widely knowledged as unresolved. The potential for irrevocable outcomes of extraordinarily negative consequence are obvious.
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Historical precedents suggests erring on the side of caution. Examples abound. Michaelson-Morely 1887, Einstein 1905, Hubbell 1929, Penzias-Wilson 1964. We are waist deep in a topic widely knowledged as unresolved. The potential for irrevocable outcomes of extraordinarily negative consequence are obvious.
Again we are in agreement on the historical approach just not the future approach. In most debates of this type I end my opinion with a Dennis Miller quote he ended many of his rants with, and say we will have to agree to disagree.
"That's just my opinion I could be wrong." Dennis Miller
[coffee]
But in this case I prefer to quote Phil Williams a local radio show host.
"That's my opinion, feel free to make it yours" P.W.
[devious]
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Clinging tenaciously to what is stable and concrete in the chaos of contemporary technological advance is not an opinion. It is a survival tactic. We have no idea what the future century offers us. Faraday's fields, Maxwell's equations, Einstein's relativity... Certainly we are not so devolved as to not take account of these historical lessons. We don't know. But we will.
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Clinging tenaciously to what is stable and concrete in the chaos of contemporary technological advance is not an opinion. It is a survival tactic. We have no idea what the future century offers us. Faraday's fields, Maxwell's equations, Einstein's relativity... Certainly we are not so devolved as to not take account of these historical lessons. We don't know. But we will.
That's just it, the historical studies and data point to relaxed exposures. This is not contempory studies and data that justify the reduction in limits.
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The preponderance of evidence is that radiation in small doses does no harm and may actually do some good. Spending (lots of) extra money on an irrational fear of one of the most studied phenomena in history is in itself irrational. The lower standards do not reflect logic, they are the result of improved technology that allows us to measure smaller and smaller doses coupled with the evidently incorrect assumption that less is always better. Even if less was better, spending exorbitant amounts of money to achieve lower doses is not a good investment. It is like making cars cost a million dollars just to make them a little bit safer. It is not socially responsible, even if it sounds like a humanitarian thing to do. Sort of like forcing the expenditure of billions of dollars to lower the levels of a non-polluting gas in the atmosphere.
The evaluation of risk must always include benefit and cost. Otherwise it is just trivia.
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If these limits were of no relative consequence and decisions were made for their modification to accommodate contemporary opinion the consequences would open a window of opportunity driven by economic concerns which would erode the accomplishments, over many decades, in the advancement of radiological safety.
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If these limits were of no relative consequence and decisions were made for their modification to accommodate contemporary opinion the consequences would open a window of opportunity driven by economic concerns which would erode the accomplishments, over many decades, in the advancement of radiological safety.
OK, we are not getting anywhere. All limits are based on risk and reward. Risk is not being modified it is being reevaluated based on the data and studies that you cite. The historical risk is now being looked at from a position supported by all of those studies and historical data. The level of risk is not being reduced, the risk incident to the level exposure is being more realistically assessed. This is advancement of radiological safety.
::)
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OK, we are not getting anywhere. All limits are based on risk and reward. Risk is not being modified it is being reevaluated based on the data and studies that you cite. The historical risk is now being looked at from a position supported by all of those studies and historical data. The level of risk is not being reduced, the risk incident to the level exposure is being more realistically assessed. This is advancement of radiological safety.
::)
Damn... I thought that was what I said.
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Damn... I thought that was what I said.
Just responding to his most recent post. I have said pretty much the same thing in several posts hoping rephrasing it or the use of a little nuance in the angle would move the discussion forward. Regulations are not the summit of our knowledge they are stew of politics. This is a change whose time has come, radiation hormesis and the decline of the linear non-threshhold dose effect relationship have been ascending in the radiation protection community for some time the regulations just have not kept up (there I go again from a new angle).
[coffee]
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Just responding to his most recent post. I have said pretty much the same thing in several posts hoping rephrasing it or the use of a little nuance in the angle would move the discussion forward. Regulations are not the summit of our knowledge they are stew of politics. This is a change whose time has come, radiation hormesis and the decline of the linear non-threshhold dose effect relationship have been ascending in the radiation protection community for some time the regulations just have not kept up (there I go again from a new angle).
[coffee]
Yeah, I got it... forgot the wink emoticon.
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Yeah, I got it... forgot the wink emoticon.
Emoticons are our freind [GH] [beer]
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I understand. I apologize for the lack of clarity in my postings.
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Sew, watts the limits proposed? 5r/year? dose the public the same as professionals? rays the effluent limits by e6?
hoe kay, now that we're prepared two blow the glow all around, numbers please.
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"Just responding to his most recent post. I have said pretty much the same thing in several posts hoping rephrasing it or the use of a little nuance in the angle would move the discussion forward. Regulations are not the summit of our knowledge they are stew of politics. This is a change whose time has come, radiation hormesis and the decline of the linear non-threshhold dose effect relationship have been ascending in the radiation protection community for some time the regulations just have not kept up (there I go again from a new angle)."
BIER 7 was clear on hormesis. Relevant ICRP publications are clear on this topic. My intention was to contribute, not to antagonize.
I apologize.
No need to apologize I just saw no movement from what seemed to be 'reduced limits were a step backwards'. Finally something new to rebut. The third citation is on Hormesis is from a Rio Grande Chapter HPS Spring Meeting in a slide presentation ( I like emoticons and lots of pictures 8) ) the first two are a little drier but clearly state that dose projections under 100 mSv are not valid due to questions on the linear non-threshhod model.
RADIATION RISK IN PERSPECTIVE
POSITION STATEMENT OF THE
HEALTH PHYSICS SOCIETY*
In part because of the insurmountable intrinsic and methodological difficulties in determining if the health
effects that are demonstrated at high radiation doses are also present at low doses, current radiation protection
standards and practices are based on the premise that any radiation dose, no matter how small, may result in
detrimental health effects, such as cancer and hereditary genetic damage. Further, it is assumed that these
effects are produced in direct proportion to the dose received, that is, doubling the radiation dose results in a
doubling of the effect. These two assumptions lead to a dose-response relationship, often referred to as the
linear, no-threshold model, for estimating health effects at radiation dose levels of interest. There is, however,
substantial scientific evidence that this model is an oversimplification. It can be rejected for a number of
specific cancers, such as bone cancer and chronic lymphocytic leukemia, and heritable genetic damage has not been observed in human studies. However, the effect of biological mechanisms such as DNA repair, bystander
effect, and adaptive response on the induction of cancers and genetic mutations are not well understood and
are not accounted for by the linear, no-threshold model.
https://hps.org/documents/risk_ps010-2.pdf
RISK ASSESSMENT
POSITION STATEMENT OF THE
HEALTH PHYSICS SOCIETY*
Risk assessment should include consideration of uncertainties
The establishment and use of risk coefficients to estimate public health determinants from individual or
population exposures must be considered in the context of uncertainties in the estimates. It is essential that all
uncertainties, assumptions, and inferences used in this assessment process be explicitly stated and that any
biases incorporated into the assessments for the purpose of ensuring prudent public health protection (such as
“margin of safety”) be clearly noted, including consideration of dose and species extrapolations and statistical
uncertainties. In addition to “best guess” or central estimates of risk, ranges of risk should be provided. Any
conservative assumptions, safety margins, and uncertainty factors should be clearly delineated.
Limitations of extrapolation of risk to low dose
Health risks of radiation exposure can only be estimated with a reasonable degree of scientific certainty at
radiation levels that are orders of magnitude greater than levels established by regulators for protection of the
public.
Radiological risk assessment, particularly for radiogenic cancer, currently is only able to demonstrate a
consistently elevated risk in those groups of the study populations that have been exposed to radiation at high
doses (>1 Sv). In order to estimate radiation risk in the low-dose region, typical of most occupational and
environmental exposures, health effects in the high-dose region are extrapolated to the low-dose region using
a variety of mathematical models, including the linear, no-threshold model. Cancer and other health effects
have not been observed consistently at low doses (<100 mSv) because the existence of a risk is so low as to not
be detectable by current epidemiological data and methods.
In the absence of direct observations, estimation of radiogenic health risks at low doses must be viewed
with caution. In most instances, to estimate risks (e.g., cancer) of small doses of radiation, a linear
extrapolation from large doses to zero is used. Extrapolation assumes that the pathway of radiogenic
effects is identical at any dose, which may not be valid. At high doses (>1 Sv), cell killing and cell
replacement occurs, creating an environment favorable for tumor growth. At low doses (<100 mSv), cell
killing and proliferation of surviving cells (which may be mutated or otherwise damaged) is much less
probable. In discussing the question of the limitations of extrapolation to estimate radiogenic risk in the 10
microsievert range, the National Academy of Sciences, in its 1990 BEIR V report noted, “ . . . the possibility
that there may be no risks from exposures comparable to external natural background radiation cannot be
ruled out. At such low doses and dose rates, it must be acknowledged that the lower limit of the range of
uncertainty in the risk estimates extends to zero” (NRC 1990). The Health Physics Society recommends that assessments of radiogenic health risks be limited to dose estimates near and above 100 mSv. Below
this level, only dose is credible and statements of associated risks are more speculative than credible.
Thus, compliance with regulations to achieve very low levels of exposure result in enormous expenditures
of money with no demonstrable public health benefits.
https://hps.org/documents/riskassessment_ps008-1.pdf
The LNT Hypothesis vs. Radiation
Hormesis: Different Implications for
Managing the Fukushima and other
Radiological Emergencies
http://www.rgchps.org/wp-content/uploads/2011/04/LNT-Hypothesis-vs-Radiation-Hormesis.pdf
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hoe kay, now that we're prepared two blow the glow all around, numbers please.
[beer] [devious]
Articles lately seem to depend too much on inserted links, this is from a link in the article. Probably easier to read than the article I cited.
Raising the EPA Radiation Limit Will Save Thousands of Lives and Billions of Dollars
The EPA is raising the radiation threat level by a factor of 350. That may sound unbelievable but it is assuredly a good thing: The previous limits were far lower than science justified and caused hundreds of billions of dollars of economic loss to America and the world.
http://reason.com/archives/2014/07/06/raising-the-epa-radiation-limit-will-sav
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"No need to apologize I just saw no movement from what seemed to be 'reduced limits were a step backwards'."
Yes, I agree. Badly presented on my part.
I have known for quite some time that the limits that we work with are absurdly low given their effects.
I remember when I first saw the famous photographs of tomato plants exposed to varying levels of exposure including complete darkness. Hormesis seemed obvious.
In review of ICRP publications 26, 30, 54, 60, 103 and BEIR 7, I thought that the epidemiologists that established these progressively more restrictive limits were well-informed about the generally debilitating nature of radiation exposure and the implications for chromosomal damage at sub micro-Sievert levels.
Given the level of knowledge and experience of the posters on this thread and the general growing consensus of the radiation protection community I again question what I thought I knew.
How will these limits change in application in the future?
Will the RESRAD post remediation limit be raised from 25 MR per year to 30?
How will any changes affect ISFSIs, effluents, shipping limits and post decommissioning and remediation site use.
How will any changes affect long-term economic considerations.
Thank you for the opportunity to be included in this discussion. I consider myself to be in very good company.
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"No need to apologize I just saw no movement from what seemed to be 'reduced limits were a step backwards'."
Yes, I agree. Badly presented on my part.
I have known for quite some time that the limits that we work with are absurdly low given their effects.
I remember when I first saw the famous photographs of tomato plants exposed to varying levels of exposure including complete darkness. Hormesis seemed obvious.
In review of ICRP publications 26, 30, 54, 60, 103 and BEIR 7, I thought that the epidemiologists that established these progressively more restrictive limits were well-informed about the generally debilitating nature of radiation exposure and the implications for chromosomal damage at sub micro-Sievert levels.
Given the level of knowledge and experience of the posters on this thread and the general growing consensus of the radiation protection community I again question what I thought I knew.
How will these limits change in application in the future?
Will the RESRAD post remediation limit be raised from 25 MR per year to 30?
How will any changes affect ISFSIs, effluents, shipping limits and post decommissioning and remediation site use.
How will any changes affect long-term economic considerations.
Thank you for the opportunity to be included in this discussion. I consider myself to be in very good company.
Clearly EPA limits as called for in the original article but NRC regulated evacuation rules,NRC regulated exposure to the public and transient exposure from DOT limits on packaging. Probably no change to occupational worker limits but I could be wrong.
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The EPA is raising the radiation threat level by a factor of 350. [beer] [devious]
that's the factor yins figure releases will be raised? mite raise background around a plant during the life, but not much.