Defending LNT and the Goldstandard

Why didn't the nuclear industry push back?

LNT is fraudulent nonsense

The Linear No Threshold (LNT) theory of radiation harm is the basis for a uniquely stringent form of regulation, lauded as the Goldstandard. Under the Goldstandard, a government agency, whose goal is to prevent any releases of radioactive material, is given absolute power to do whatever it must to achieve that goal, including changing its own regulations whenever it wants. In the US, that agency is called the Nuclear Regulatory Commission (NRC). According to the NRC chairman, the NRC's responsibility is safety "without regard to economic and social costs". The Goldstandard has made nuclear power prohibitively expensive in most parts of the planet. As a result, instead of providing humanity with reliable, near zero pollution and CO2 electricity while consuming far fewer resources than other sources, nuclear power has been a tragic flop.

LNT can roughly model the harm we see when very large doses of radiation are received over a period of hours or less; but it completely fails to model the lack of detectable harm when the same or larger doses are received over extended periods. LNT's predictions are orders of magnitude too high at the dose rates which the public will experience in a nuclear power plant release. Check out LNT is nonsense and The LNT-is-not-inconsistent-with-the-data argument. This abject failure is the result of LNT's denial of our ability to repair radiation damage, an ability that is absolutely necessary for any organism that depends on oxygen based metabolism. This ability is not disputed by any knowledgeable observer. Only by LNT.

LNT has been debunked by Lauriston Taylor, the founding president of the National Council on Radiation Protection, by Rickover’s right hand man, Ted Rockwell, by the French Academy of Science, by Scientists for Accurate Radiation Information, and a number of other researchers and doctors. Even the defenders admit that their data show strong non-linearity at low dose rates. But they must ignore populations that have received very large doses over long periods with no detectable harm. Here's how the EPA handled the radium dial painter data, which showed no increase in cancer in women who endured 20 mSv/d for 10 years. According to LNT, the cumulative doses should have killed these ladies many times over.

EPA policy is to assess cancer risks from ionizing radiation as a linear response. Therefore, use of the dial-painter data requires deriving a linear risk coefficient from significantly non-linear exposure data or abandoning EPA policy. \cite{epa-1991}

Abandoning EPA policy was not an option. As an upper level EPA apparatchik more recently put it, EPA's support for LNT is``set in stone".\cite{edwards-2015} UNSCEAR and WHO recommend that LNT not be used to estimate harm at release dose rates; but then inconsistently claim it should be the basis for regulation.

Calabrese has meticulously documented the scientific fraud that was conducted by the Rockefeller Foundation in order to establish LNT as the basis for radiation harm, fraud that was aimed at stopping nuclear weapons testing. Promotion of a 13

hour video based on Calabrese's findings caused an unseemly rift in the Health Physics Society, the main professional organization responsible for radiation protection. The HPS President was censured by his board for promoting the Calabrese video and asking Congress to rethink LNT. No one questioned the validity of Calabrese's findings.

Far most tellingly, we have had four major releases of radiation from nuclear power plants: Windscale, Three Mile Island, Chernobyl, and Fukushima. In every case, supporters of LNT predicted widespread increases in cancer. In every case, those predictions have proven false.¹ Radiation is like the Wizard of Oz, all powerful and scary, until Toto tips over the screen; and it is revealed as just another hazard, a manageable part of nature.

The supporters of LNT

We know why the NRC has to support LNT and the Goldstandard. They are essential to the NRC's existence.

The Department of Energy is the government agency supposedly charged with promoting nuclear power, which in fact it did in the 1950's and 1960's. But the DOE was always conflicted by also being responsible for controlling the bomb, which they thought required everybody to be frightened of low dose rate radiation. LNT was perfect for that purpose. As LNT based regulation drove the price of nuclear power up, the DOE became dependent on the fear it had created. It was far easier to extract billions of dollars per year in taxpayer money to clean up radiation contaminated sites which it had created, than reverse its decades-long position on LNT. The fact that the dose rates at these sites were usually less than natural background levels meant that LNT had not only to be accepted, but assiduously promoted using best practice advertising. The DOE depends on LNT.

Fear of low dose rate radiation also supports the vast national lab structure that was left over from the Manhattan Project. This no-longer-needed animal must be fed 20 billion dollars per year. It is usually the largest employer in each of its congressional districts. Much of that money goes to working on (and not solving) LNT created "problems". If you are a national lab employee, criticizing LNT is a not a smart career move. The same thing goes for the Nuclear Engineering Departments, which depend on DOE funding for their existence.

It is hardly surprising that government bureaucracies and radiation protection workers are strong supporters of stringent regulation, and will seize on any rationale to perpetuate and expand their power. But the perplexing question is: where was the pushback from the nuclear industry?

We are continually being warned that in a free market society, powerful industry forces will inevitably capture the regulators. There is considerable truth in this position. The bell ringers can cite some important examples in their favor. Why did regulatory capture not happen in nuclear power? What little pushback there was evaporated early in the 1970's. And by the 1980's, industry was a cheerleader for the Goldstandard which was destroying its business. Makes no sense.

Misdirecting Greed

Here's the real genius of the Goldstandard. It's self-perpetuating. Anybody who hopes to get through the process can't say anything bad about the process. Not only do you not want to get on the bad side of an omnipotent regulator who's free to make up the rules as he goes; but you also need to assure your investors that this is a reasonable regulatory regime that we can prosper in.

And once you somehow fight your way through the regulatory maze at the cost of hundreds of millions of dollars, you become its biggest defender. Can you imagine how pissed Nuscale and the other incumbents would be, if tomorrow Congress declared the NRC to be an unnecessary evil? Henceforth we are going to depend on the same system by which we regulate other hazardous, beneficial industries. To protect their hard won position, the incumbents must claim that the Goldstandard is absolutely essential to protecting the public from the horrific dangers of nuclear power. They must promulgate LNT and the Two Lies.

If they are successful, they enjoy the deepest, widest moat in existence. Yeah, nuclear power is a bust. But they control what's left, a series of multi-billion dollar taxpayer funded boondoggles. As the name proudly proclaims, the Goldstandard is expensive and that gold is what they have decided to go after. The regulators have captured the industry with your money and mine.

Table 1 shows how things line up. It's a bit one sided. To make matters worse, many of the most vocal opponents are nuclear establishment retirees, who carefully kept their mouths shut during their productive years. If the public is looking for "experts", their choice is a few old guys or everybody else. The Goldstandard has bought off everybody that counts; and it does it with our money.

The last clause is the key. Congress could stop this nonsense. But it will take going up against some strong special interests, including not only the members who represent national lab districts, but the nuclear industry itself. My guess is that things will need to get a lot worse before that happens.

1. The only detectable increases in cancer to the public in all the releases to date were to children at Chernobyl who consumed contaminated milk. Since a large portion of the radioactive material in the milk concentrates in the tiny thyroid gland, the dose rates to these kids' glands were magnified by roughly a factor of 1000. This overwhelmed the ability of the gland's repair system, and we saw a jump in childhood thyroid cancer. This jump could easily have been avoided by confiscating contaminated milk as was done at Windscale and Fukushima.