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Change at EPA Could Reduce the High Cost of Nuclear Energy and Improve Grid Cleanliness


During a recent conversation with a successful career employee of the Nuclear Regulatory Commission (NRC), the topic of radiation protection limits came up. He reminded me that the NRC’s role in radiation protection is limited to enforcing the standards that are set by the Environmental Protection Agency (EPA).

In light of President-elect Trump’s statements about finding and eliminating regulations that harm more than they help or protect, it is worth noting that the EPA is the responsible agency for 40 CFR 190, which limits maximum exposure to the general public from nuclear reactor operations to 0.25 mSv/yr. It is also the agency responsible for 40 CFR 191, which limits human exposures to radiation from used nuclear fuel, high level waste and transuranic wastes to a committed effective dose (CED) of 0.15 mSv/yr for a period of 10,000 years.

If you want to get into a contentious, multi-day discussion, ask five radiation protection experts to describe the methodology used to compute a committed effective dose from used fuel repository over time.

To put those radiation protection limits into perspective, the average American who is not occupationally exposed to radiation will receive a total of 6 mSv/year from a variety of sources including cosmic radiation (sunshine), radiation from rocks and soil and medically-related exposures.

Within the $8 billion/year 15,000 employee EPA, radiation protection limits are controlled by a marginally-resourced office of 59 people buried deep within the EPA.

The EPA branch responsible for radiation protection standards is the Radiation Protection Division (RPD) of the Office of Radiation and Indoor Air (ORIA) within the Office of Air and Radiation (OAR).

Its science and technology budget is roughly $2 million/year; that number has been essentially constant since 2011, the oldest budget still readily accessible.

Aside: In the period from 1962-1969, the budget for one of several radiation health effect research programs sponsored by the Atomic Energy Commission (AEC) was $3-$3.5 million per year in then-year dollars. That provides some perspective on the lack of interest in knowledge accumulation to support EPA standard setting. End Aside.

The radiation science budget item description that has been cut and pasted from previous justification submissions since 2013 provides rather grandiose claims of expertise for an office given such a small annual appropriation.

The agency’s radiation science is recognized nationally and internationally; it is the foundation that the EPA, other federal agencies and states use to develop radiation risk management policy, guidance, and rulemakings. The agency works closely with other national and international radiation protection organizations, such as the National Academy of Sciences, the National Council on Radiation Protection and Measurements, the International Atomic Energy Agency, the International Commission on Radiation Protection and the Organization of Economic and Cooperative Development’s Nuclear Energy Agency to advance scientific understanding of radiation risk.

The version of 40 CFR 190 that remains in effect was issued in Jan 1977. It will be forty years old in a month. These rules are ripe for fundamental change based on the improvements in biological science during the period since they were imposed. The version of 40 CFR 191 that is still in effect was issued December 20, 1993. It doesn’t use any improved science compared to the 1977 issuance of 190; it is devoted more to explaining and justifying the selection of “committed effective dose” and a 10,000 year modeling requirement.

In 2014, the EPA issued an advanced notice of proposed rulemaking (ANPR) to review and potentially revise 40 CFR 190. That effort, however, hasn’t progressed beyond the comment collection and summary stage. It seems to be in a state of bureaucratic suspension.

Billions of dollars are spent every year to enforce and comply with the exposure limits issued by the EPA’s Division of Radiation Protection. There should be bipartisan support for making the comparatively small investment needed to use modern science to update the standards. Exposure limits should seek to protect public health and safety based on fundamental understanding of biological effects.

Standards setters should not rely on decades-old assumptions that result in limits that even a casual observer should recognize as absurdly low in comparison to other sources of routine radiation exposure.

The remainder of this post is a history lesson. I provide that warning for people who don’t ascribe to the idea that those who do not learn from history are doomed to repeat it or to be locked into bad policies for the wrong reason.

Major chapter in radiation protection story driven by Nixon agenda

As documented in Glenn Seaborg’s The Atomic Energy Commission Under Nixon: Adjusting to Troubled Times, Richard Nixon seems to have entered office with an apparent personal mission to dismantle the Atomic Energy Commission (AEC) and its congressional power base, the Joint Committee on Atomic Energy (JCAE). Contemporary news articles support Seaborg’s view. Here is the lede of a Jun 12, 1970 New York Times article titled Nixon Aides Weigh Reshaping AEC for a Wider Role.

he Nixon Administration is seriously considering a plan to break up the Atomic Energy Commission and remake it into an agency dealing with all forms of energy.

Administration sources said the proposal would shift the commission’s military programs to the Department of Defense and many of its research activities to the National Science Foundation.

The A.E.C. would then be broadened into an over‐all energy agency. One problem it would deal with is the electric power shortage, which threatens much of the East with power brownouts this summer.

Seaborg was a dedicated journal keeper; his books about his service with the AEC are based on his daily journal entries that often included copies of relevant documents (reports, correspondence, meeting minutes, newspaper articles, memos, etc.)

He summarized his final years at the AEC in the foreword of Seaborg’s book about his Nixon years.

It is the story of a once proud and privileged government agency that is declining in reputation and influence, how one establishes goals when choices are limited by an impoverishment of means, of the maneuvers that are employed to sustain what seems to be worthwhile endeavors, and of how one sorts out policy and politics, chooses between adherence to principle and compromise and in the end must sometimes fight rearguard actions for survival.

All in all, it is far from being a triumphant story. The Nixon years were difficult ones for the AEC. In part, this may have been due to the special foibles of this president and his administration. More significantly, however, our difficulties can be attributed to the spirit of the times, particularly the opposition to the Vietnam War and a rising environmental consciousness.
(p. ix, x)

Furor over radiation standards

A section in Seaborg’s book on the Nixon years is titled The Furor Over Radiation Standards

John Gofman and Arthur Tamplin were two well-credentialed employees of the AEC’s Lawrence Livermore Laboratory. Gofman, for example, had earned his PhD in nuclear inorganic chemistry as a grad student under Glenn Seaborg, the Chairman of the Atomic Energy Commission and winner of the 1951 Nobel Prize in Chemistry for the isolation of plutonium.

According to Seaborg, Gofman was “as bright a graduate student as I have ever had.” He was the co-discoverer of the fissile isotope U-233; the work resulting in that isolation had been the topic of a “very brilliant doctoral dissertation. Seaborg expressed regret that Gofman had chosen to go to medical school after completing his PhD instead of joining the Manhattan Project. (Seaborg, The Nixon Years p. 123)

In 1969 Gofman and Tamplin began loudly touting calculation results predicting that exposing the American public to radiation doses at the then allowed rate of 0.17 RAD/year (170 mrem/yr or 1.7 mSv/yr) would produce 32,000 excess deaths per year from leukemia and solid cancers.

Gofman and Tamplin’s calculations were based on the belief that there was no safe dose of radiation. Despite a lack of evidence of harm from doses that were 10-50 times higher than the AEC’s limits, the two scientific colleagues devised coefficients using data from much higher dose levels and produced calculated effects that assumed that the relationship between dose and cancer risk remained constant down to the last gamma ray. Their work was a return to the straight line, no safe dose model promulgated by the 1956 BEAR 1 (Biological Effects of Atomic Radiation) committee.

Gofman and Tamplin did not publish their work in academic journals. Instead, they presented it to the public, politicians and the press. They made a number of appearances at public meetings in Vermont, Minnesota and California and testified in front of Congress at the invitation of Senator Edmund Muskie during the second half of 1969.

In the summer and autumn of 1970, articles about the two [Gofman and Tamplin] appeared in McCalls, Esquire, Atlantic Monthly, Newsweek, National Geographic, Reader’s Digest, Life, Barrons, and the National Journal. During the same time period, there were feature articles in several newspapers, including the Philadelphia Enquirer (a series of seven articles), the Christian Science Monitor (a three part series), the New York Times, and the Washington Post (the last two with several articles each). In addition, all three television networks did special programs, one on ABC giving the subject of ‘Nuclear Energy and the Environment.’ Ever present in these media presentations was the allegation of about 32,000 extra cancer deaths per year, a statistic that by its very repetition began to achieve a semblance of reality.
(Seaborg, The Nixon Years pg 131-132)

It seems likely that the two scientists were supported by a public relations firm or, at a minimum, a skilled publicist. The AEC inadvertently contributed to the attention Gofman and Tamplin were able to attract by actively defending itself and taking action that could easily be construed as retaliation against the attacks from within.

Aside: Turning critics into martyrs is never a good way to win a technical argument. End Aside.

Using hindsight, it’s apparent that the AEC made another major error in its effort to defend its authority to set limits. Its response to the 32,000 number was to claim it was too high because no one was exposed to doses anywhere close to the 1.7 mSv/year limit. Instead of reassuring anyone, that argument merely encouraged people to suggest lowering the legal limits since power plants were obviously capable of meeting much stricter limits.

That line of defense also begged the question, if 32,000 deaths/year isn’t accurate, what is the real number? In such a situation, there is no good answer. Now, with modern science it is possible to answer the question by saying that no one in a population whose annual exposure limit is 1.7 mSv will have an increased risk of cancer. That same statement can accurately be made for exposures up to 100 mSv/yr and perhaps even higher.

Minnesota imposes limits much lower than AEC’s limits on the Monticello plant

The Monticello plant site is about 40 miles north of the twin cites of Minneapolis and St. Paul. Expressing their concerns about drinking water contamination, the state of Minnesota insisted on the right to establish radioactive material release limits that were much stricter than those established by the AEC.

State authorities had been influenced by furor that Gofman and Tamplin had helped to initiate.

In Aug 1969, Northern States Power, the license applicant for the Monticello plant sued the state of Minnesota, challenging its legal standing to impose limits on radioactive material discharges. Minnesota was eventually joined by about 20 other states as intervenors or friends of the court.

Seaborg tried to interest the Nixon Administration’s Justice Department in joining the case on the side of the utility to defend the AEC’s preemptive responsibility to regulate radiation. According to the way the AEC and the JCAE interpreted the Atomic Energy Act of 1954, Congress had expressed its intent to elevate radiation regulation to the federal government. Seaborg was told that it had always been part of the Republican ideology to defend states rights. Assistant Attorney General William Ruckelshaus had been instructed by the White House to keep the Justice Department out of the case. [Seaborg, The Nixon Years p. 106)

How did the EPA get the authority to establish radiation protection standards?

When President Nixon issued Reorganization Plan No. 3 in the summer of 1970, he consolidated the radiation protection activities of the following existing agencies: Federal Radiation Council, Department of Health Education and Welfare Bureau of Radiological Health (HEW-BRH), Atomic Energy Commission Division of Radiation Protection Standards.

Radiation Protection at the EPA describes the functions from those organizations that were assigned to the EPA. All of the duties of the Federal Radiation Council were transferred to the EPA and the FRC was abolished. There was a less complete transfer of functions from the other organizations.

EPA was generally provided research, monitoring, standard setting, and enforcement authorities for each category of pollutant. However, the transfer of radiation protection responsibilities to EPA was more limited than that of other pollutants, in that the authority for enforcement of radiation standards was retained by the Atomic Energy Commission (AEC). EPA would later gain enforcement authority for the regulation of some radioactive materials under certain environmental statutes.

According to a New York Times article published on June 12, 1970, only 20 people were reassigned from the AEC to the EPA. Some experts in the field apparently found new work within the AEC instead of transferring to a new agency.

Why did Nixon take authority for radiation protection standards away from AEC?

It’s invariably risky and controversial to attempt to answer questions about why politicians take certain actions. That doesn’t mean that the research isn’t worth the effort or that the developed explanation isn’t worth sharing.

The controversy over radioactive material release standards delayed the commercial operation of the Monticello plant by more than a year. The publicity about that struggle, combined with the media attention attracted by Gofman and Tamplin and the campaigns waged against radioactive releases from tests conducted as part of the Ploughshares program resulted in an upwelling of expressed public distrust in the AEC. (Note: Ploughshares was the program name for the effort to use nuclear explosives for civil engineering and hydrocarbon fracking.)

Nixon’s action to move radiation effects research and standards setting to the EPA was portrayed as a way to defuse public concerns about the AEC being the standard setter, the enforcer and the promoter of the use of radioactive materials in commerce and defense applications. It was also the first step in his effort to dismantle the AEC.

The next installment in this series will describe how the EPA seized its new authority and decided to drastically lower the allowed public exposure limits and the limits on radioactive effluent releases.

Note: Nixon was a big supporter of the frequently criticized Ploughshares program, which was run out of the Lawrence Livermore laboratory located in his home state of California. Less than two weeks after Nixon’s inauguration, Seaborg briefed him on the program. Nixon asked Seaborg to brief the press and provided detailed guidance for what he wanted Seaborg to say.

The president expressed a great interest–and he asked me particularly to tell you this–in the peaceful uses of atomic energy. He particularly identified the peaceful uses of atomic explosions as an area in which he had a special interest.

Though his support can be explained in several ways, it is conceivable that the underlying motive on the part of some members of Nixon’s close circle was a desire to maintain the link in the public’s mind between nuclear power and nuclear weapons by labeling explosive detonations as “peaceful uses.”

The post Change at EPA could reduce the high cost of nuclear energy & improve grid cleanliness appeared first on Atomic Insights.

Photo Credit: Chris Hunkeler via Flickr

Content Discussion

Thorkil Soee's picture
Thorkil Soee on November 21, 2016

May be the following will add some more information. and
However, the public has been pumped up with fear of radiation as for instance here
Until the realities are understood by those responsible, it will be difficult to “go scientific”

Bob Meinetz's picture
Bob Meinetz on November 21, 2016

Great, Rod. Now we just have to try to explain to Sarah Palin what a “millisievert” is.

And to Bristol, Willow, Track, Piper, Trig, and little illegitimate Trump why their cush jobs at the EPA create a “conflict of interest”.

And to ask Sarah how an agency dedicated to protecting the environment might be capably directed by someone who “loves that smell of the emissions”.

No sugarcoating it: an EPA under Trump will be a disaster for nuclear, a disaster for the environment, and a windfall for fossil fuel. Drill, Baby, Drill.

Darius Bentvels's picture
Darius Bentvels on November 22, 2016

Many research in past decade shows that health and genetic damage due to a little extra radiation (e.g. 0.2mSv/a = ~10% of background), is bigger than estimates based on LNT predict.
So based on recent research results, allowed emissions by nuclear facilities should be decreased significantly.

DNA is single stranded when the cell divides, so it cannot be repaired when it’s damaged by a passing radiation particle. Sperm is produced shortly (<6 days) before conception thanks to an extreme high cell division rate. So then sperm is vulnerable for radiation as its DNA cannot be repaired.

DNA of sperm which generates boys is smaller than that of sperm which produce girls. So 'male' sperm has less chance to be damaged & killed by increased radiation.
Which is shown at e.g. nuclear waste plant Sellafield, where workers near radio-active material get 39% more boys than girls (while all radiation safety standards for workers are respected).

While those workers get a good salary in return for the increased risk on genetical damaged offspring, the general public around those facilities do not get anything in return while they also suffer from offspring with increased levels of genetic damage as found by many studies.

Studies found highly significant increased levels of genetic damage to the offspring of people living up to 40km (!) away from such nuclear facilities.
Here an overview with many links to scientific studies.

It also shows that the genetic damage to the public by surface nuclear (waste) sites in France and Germany (Gorleben) is substantial*). So German authorities ordered a due diligence study regarding Gorleben by pro-nuclear scientists. Those enlarged the surveyed area around Gorleben in the expectation it would show that the original research results were an anomaly.
To their horror, they found even worse damage (the enlargement was downwind).
The authorities then arranged a discussion conference with all involved scientists, which resulted in the premature closure of Gorleben in 2015. While the huge storage building (500x20meter with 0.5meter thick walls) is still largely empty.
*) While in USA the dry casks are stored in the open air, German authorities were more careful and stored the dry casks with nuclear waste in a special constructed storage building with thick walls which is situated in a guarded and fenced area surrounded by an high dike.

Thorkil Soee's picture
Thorkil Soee on November 22, 2016

You write [quote] Studies found highly significant increased levels of genetic damage to the offspring of people living up to 40km (!) away from such nuclear facilities.[/quote]
However it does not match experience in Japan after the nuclear bombing. There has not been any more birth-defects than in the rest of the population. See

Mark Heslep's picture
Mark Heslep on November 22, 2016

Fascinating history Rod.

There seems to be an indirect suggestion in the article that the dose rule would would have a better chance for change if it were once again under control of the nuclear agency, the NRC. Is there any direct reason for believing that this is so?

Mark Heslep's picture
Mark Heslep on November 22, 2016

Mark Heslep's picture
Mark Heslep on November 22, 2016

Here an overview with many links to scientific studies

Not many studies, only Scherb referencing himself, and nothing else published.

Darius Bentvels's picture
Darius Bentvels on November 23, 2016

Of course,
few children were concepted in the aftermath of the bomb.
The bomb produced a gamma blast, so children concepted in the up to ~5 days thereafter had really increased levels of genetic damage. But I think the survivors had more urgent things to do than creating children.

Sperm lives only ~5 days in the male and the genetic damage occurs at the moment of sperm production as then the cells are vulnerable:
Then only one DNA streng so no reference for repair, (to) little energy in the new cell for correct repair, etc .

Read the PPT I linked and follow the links in the PPT towards the scientific publications.
Seems you only want to attract traffic to your own site.

Darius Bentvels's picture
Darius Bentvels on November 23, 2016

I agree, as NRC is pro-nuclear.
Not strange since most of the staff would loose their job if nearly all nuclear power plants would stop.

Darius Bentvels's picture
Darius Bentvels on November 23, 2016

Few more:
The first easy to read publication I know is a 1996 NYT article about a study that shows increased genetic (germline) damage in young children ~300km away from Chernobyl in Belarus. The article also explains the difference between (the effects of) radiation from the atomic bomb and nuclear power plants.

Then UK scientist showed in 2002 significant increased levels of a.o. Down syndrome in UK areas that got some Chernobyl fall-out (>1,500mile away).
Thereafter more scientific publications, in a.o. Germany, showing more damage.

The max. allowed radiation emissions should be decreased towards below 0.05mSv/a (so 5 times less) as studies showed, e.g. this one, that an increase of 0.1mSv/a already create significant increased levels of serious birth defects.

According to the results of the linked study an increase of 0.1mSv/a implies: ~12% more serious deformities (of the skull, face, jawbone, neck, spinal column, hip joint, long bones of the legs, and feet), ~3% more stillbirth, etc.

Mark Heslep's picture
Mark Heslep on November 23, 2016

Your’e stuck in a loop Bas

No real epidemiologist takes the statistician Scherb seriously. Linking him again, and again, and again is trolling.

Mark Heslep's picture
Mark Heslep on November 23, 2016

The article also explains the difference between (the effects of) radiation from the atomic bomb and nuclear power plants.

From the article:

A more skeptical view was taken by Dr. James Neel, a geneticist and physician at the University of Michigan, who conducted extensive studies on Japanese atomic bomb survivors and their children.

Dr. Neel said his research did not point to germline effects, nor did a recent study of minisatellite regions in Japanese subjects.

“This new work implies a sensitivity to the genetic effects of radiation that’s far, far in excess of either experimental work with fruit flies or mice, or our own studies in Japan,” Dr. Neel said. “This is not the study that’s going to establish that effect. I would urge them to repeat this work just as soon as possible.

“This is such a sensitive subject. There’s near hysteria in Russia over it.”

Mark Heslep's picture
Mark Heslep on November 23, 2016

What would cause you to lose your job of trolling this forum?

Darius Bentvels's picture
Darius Bentvels on November 23, 2016


Darius Bentvels's picture
Darius Bentvels on November 23, 2016

Based on the report of Scherb etal, German govt closed nuclear waste site Gorleben prematurely (a loss of many tenth millions) while it was still largely empty.
The Gorleben dedicated nuclear waste storage site:

Mark Heslep's picture
Mark Heslep on November 23, 2016

And Lysenkoism wrecked genetics and agricultural advance in the Soviet Union.

Bob Meinetz's picture
Bob Meinetz on November 23, 2016

Bas, “Scherb etal” are unqualified hacks. Please stop trotting this crap out, or both you and your scary-red-dot photos will be banned again.

This time, I have a simple but effective text-recognition algorithm for identifying your posts, no matter what you decide to call yourself. I can’t take much credit. You’re so predictable, it was amazingly easy to construct.

Mark Heslep's picture
Mark Heslep on November 23, 2016

BTW, that photo was infamously photoshopped and used in a paper by Gleick et al, and later corrected. No bear; penguin. Plenty of evidence for AGW without faked photos.

Thorkil Soee's picture
Thorkil Soee on November 23, 2016

@ Bentvels
Some 75,000 children born to parents who survived high radiation doses at Hiroshima and Nagasaki in 1945, have been the subject of intensive examination.
The much trumped damage from radiation has not been found.
Try to read on

Darius Bentvels's picture
Darius Bentvels on November 23, 2016

Apparently you are convinced that TEC applies pro-nuclear censorship to its comments section and even bans people in order to propagate nuclear??

They are sponsored by German Siemens. So they bite the hand which feeds them. Rather strange?

Darius Bentvels's picture
Darius Bentvels on November 24, 2016

Thanks for confirming my genetic damage story.

Furthermore the US-Japanese Radiation Effect Research Foundation concluded in her last Life Span Study report (nr.14, 2012):

– a formal dose-threshold analysis indicated no threshold for the cancer risks. Zero dose is the best estimate!

– there is a latency period of 20-60years before the increased cancers (and other serious diseases) due to a small increase in the radiation level show.
(similar as with smoking, asbestos, etc)

Darius Bentvels's picture
Darius Bentvels on November 24, 2016

You prefer that the last few pro-renewable knowledgeable commentators are also removed?
So pro-nuclear commentators (=near all here) can reinforce themselves in cries, which express their frustration that the world is moving towards more renewable and not towards more nuclear?

Such removal would not give you and others the opportunity to understand the reasons behind the move towards more renewable.
But, may be you don’t want to know and prefer to be surrounded with similar minded people even at a discussions forum?

A bad development as it implies we are moving towards segregated societies in a country. A prerequisite for many civil wars. Such as the one we saw in Bosnië.

Mark Heslep's picture
Mark Heslep on November 24, 2016

You prefer that the last few pro-renewable knowledgeable commentators are also removed

Not at all. But that’s not you. Dogmatic is not the same as knowledgeable.

prerequisite for many civil wars.

I’ve not seen this one from u before: to ask Bas to leave is to start a war, thousands die as in Bosnia. In retrospect it’s not surprising.

Engineer- Poet's picture
Engineer- Poet on November 25, 2016

The lying liar Bas Gresnigt lies again:

According to the results of the linked study an increase of 0.1mSv/a implies: ~12% more serious deformities (of the skull, face, jawbone, neck, spinal column, hip joint, long bones of the legs, and feet), ~3% more stillbirth, etc.

The average resident of Colorado receives 1000 mrad (10 mSv) from natural sources every year, compared to about 3 mSv for the US average.  By Bas’s claims, this should result in 840% more serious deformities, 210% more stllbirth, etc.

This simply is not happening.  It’s a sick fiction.

Bas needs to be checked into a facility to determine whether he is insane.  If insane, he needs to be put under 24/7 inpatient psychiatric care until he is cured of his delusions; if he is lying, he needs to be put in prison for maliciously propagandizing millions of people to remain in danger from coal emissions, and the entire planet from climate disruption.  Regardless, he needs to be removed from the internet in general, and theenergycollective in particular.

I know my particular proposal for controlling the public face of his symptoms is unpopular, but extreme measures are called for.

Darius Bentvels's picture
Darius Bentvels on November 25, 2016

Sorry but your reference states: “Colorado, for example, natural radiation exposure can be 1000 mrem per year ”
So the av. radiation level will be much lower.
It even doesn’t state that there live (significant number of) people in those few places!

Can you show decent scientific study published in peer reviewed scientific journal, which shows that there is no increased level of birth defects?
Or is that allegation also unfounded?
If it’s not founded:

Why do your create the false impression that such increased low level radiation is not harmful, while many scientific studies show that it is harmful?

Here another one, showing significant (P<0.01) increased levels of a.o. trisonomy 21 (=Down Syndrome) in Berlin (~1000miles from Chernobyl).

Engineer- Poet's picture
Engineer- Poet on November 28, 2016

– there is a latency period of 20-60years before the increased cancers

Latency period for leukemias is 5-7 years, and other cancers are much less than 20 years.

IOW you are lying again, Bas.  I wish I could force you to choose between shutting up or betting your life on the truth of your statements.  That would be something to see, especially if I could choose your mode of execution when (not if) you lost.

Darius Bentvels's picture
Darius Bentvels on November 29, 2016

Please cite your link more correct:
“The latency period … for solid tumours is at least 10 years”

That latency period stretches towards 60years as shown by the Life Span Studies. Read report no.14.