20131222 (ON)
Journal: December 22, 2013
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Law                                Human Rights (Freedom and Security)                                Morality

Costs cannot be separated from safety standards, which, to be met, require associated material, construction, maintenance, management costs and other costs. A-bombs, Chernobyl, and now Fukishima are showing clearly the linear, no threshold dose response hypothesis, LNTDRH, upon which all regulations of nuclear safety are based, overestimates health effects at low doses, i.e. those below about 1 to 5 rem per year.

The current LNTDRH is extrapolated from data at high doses to those at much lower doses where regulations are applied. Empirical doses on which the model are based range from about 10's to 1000's of rem (0.1 to 10 Sieverts, to be more modern), whereas regulations generally are applied at 10's of mrem levels, factors of 1000's to 100,000's less than the range of the underlying data.

If we regulated nuclear risk like coal, i.e. in terms of death or cancer per kilowatt AND we use reasonable, empirical dose response data, we could build a lot more, much cheaper nuclear plants and cause much less harm than coal currently does to both the environment and human health. MANY more plants, MUCH cheaper. Why don't we?

ALARA, a regulatory principle of "As Low As Reasonably Achievable" often used, implicitly if not explicitly, by regulatory agencies setting risk standards, like the EPA's radiation standards for cask storage and geologic disposal. "What is reasonable"? The courts have an answer; bankruptcy. So as long as you can "afford" more reduction in risk, i.e. you can still make a profit, you must reduce risks you impose on the public by meeting standards set for your industry in consideration of your financial ability to meet them. Thus, if you can afford to reduce risk you must -- in absolute terms, independent of risk of other alternative sources of the same product, in this case, electricity; it is the "reasonable" thing to do.

A hidden consequence of ALARA thinking is that the safest industries are penalized by extra cost to reduce risk, while the dirtiest are exempted from similarly stringent regulations because they can't afford it. ALARA keeps costs of alternatives about equal and lets risk vary (and subsidies) as the independent variable. I and others propose switching that standard and letting cost float while we fix the risk, say for a MW of electicity. Therefore the market will choose the lowest cost alternative to achieve the social goal of lowest risk.


The cost of nuclear would plunge if we were reasonable about risk. For example, the waste disposal standard for Yucca Mountain is basically to maintain for 1,000,000 years releases from the wastes of 70 or so reactors (30 to 50 years of power for 70 million people or so) to 200 mrem, in an essentially uninhabited, desert. 1,000,000 years! Really? What else do we regulate for such long periods?

It is very expensive to "assure" (NRC's term) predictions for such a time. Is it any wonder Yucca Mountain arguments foundered on model predictability and uncertainty. I often hear the rejoinder, "radioactive materials are dangerous for long times", to which I say, "Sure, but not as long as mercury, lead, and arsenic from many other human activities".

Despite the unreasonable (unique) time element, the allowed dose, 200 mrem is ridiculously low; a dose increment equivalent to moving from Chicago to Denver, an increment that is empirically unobservable in the number of cases of diagnosed cancers. Regulations for risks from on-site storage casks are similarly low, even lower for off-site releases, based, in part, on the utilities' presumed financial ability to meet them.

It takes 10 or so rem (10,000 mrem) to begin to see effects of radiation in empirical or epidemiological studies, yet our extrapolated, linear, no-threshold models (LNTDRH) predict a few cancers caused by radiation lurking among the many from other causes. Since absolute safety is the implicit ultimate standard of ALARA, and the nuclear industry can afford such costs (barely, but that's the whole point of ALARA), its only "reasonable" that they do it and save future humanity from a few cancers.

HOW STUPID. Let costs float and set acceptable risks in terms of human health. THEN apply that SAME risk standard to all power generating alternatives. Using "apples to apples" data, select the safest. Not as we do now, hold the cost steady and change the engineering to most efficiently meet the competitive cost, set, by the way, by the most expensive. We cut off our nose to spite our face.

Plus let's use hormesis as the model for low-dose radiation, as most empirical data suggest, or at least a quadratic model with a one rem threshold of regulatory concern. If we were to make these two conceptual switches, we could have "power so cheap you won't meter it", "so safe you won't care" as was promised long ago. Is it time yet? Think of the benefit, as well as the risk.