An Open Letter to Secretary Wright

Dear Secretary Wright,

I'm an MIT graduate who was a tenured Course 13 faculty member before leaving MIT to seek my fortune in the tanker market. I ended up running a fleet of very large tankers and building the four largest ever double hull ULCC's in Korea. Along the way, I've also managed offshore rigs, and ran a tiny family oil field in Indiana. This introduction is aimed at convincing you I might not be a crackpot, despite what I'm about to tell you.

The radiation harm model which informs our radiation protection regulation is called Linear No Threshold or LNT. LNT is biological nonsense. It denies our bodies' remarkable ability to repair DNA damage. In fact, a providential Nature has equipped us with DNA damage repair systems that can easily handle dose rates 100's of times above normal background. She had to do this to allow us to have an oxygen based metabolism. But this system can be overwhelmed if the dose rate is high enough. No knowledgeable observer denies we have these repair systems.

LNT denies we have such repair systems, so the harm just keeps building up. For LNT, it does not matter whether we receive a 1000 mSv dose in a spike or 1000 mSv spread more or less evenly over a life time. As a result, LNT is many orders of magnitude too pessimistic when a dose is spread over months and years, which is the case for the public in a nuclear power plant release.

LNT was not legislated by Congress. It was adopted by the AEC in the 1950's without any Congressional mandate, as part of the campaign to control nuclear weapons. This was before we understood much about DNA repair. We barely knew DNA existed. This decision could be reversed by Executive Order. But to do so, we need a replacement harm model.

Sigmoid No Threshold (SNT) is such a model. SNT is at least as accurate as LNT when a dose is received in a single spike and far, far more accurate when a dose is spread over a protracted period. SNT is just as easy as LNT to implement. A Plug In Replacement for LNT outlines SNT.

If SNT replaced LNT, the policy implications would be momentous. For example, if we recompute the dose rate limits based on the existing EPA Maximal Individual Risk for cancer, the EPA clean up target of 0.15 mSv per year goes to 0.11 mSv per day, which would kill all the current radiation clean up programs. We could and should rethink how we regulate nuclear power. The Two Lies monograph explores the possibilities. We could make nuclear cheap again. Nuclear would finally achieve its promethean promise.

Sadly, the current nuclear power establishment (regulators, vendors, and much of the DOE) has a big stake in the status quo. The current administration is a once in a life time opportunity to break their strangle hold on nuclear. We must seize it.

Your fellow brass rat,

Jack Devanney