Rogue Bureaucracies Flaunt NRC/EPA Radiation Rules

The Gordian Knot News has argued eloquently and persuasively for a return to the pre-1950 tolerance dose of 2 mSv per day. Amazingly this has had no impact on the NRC and EPA. Adopting the old tolerance dose would require abandoning LNT. Those bureaucracies have made it quite clear that that is not an option.

Based on LNT, they have set the public limits at 0.15 to 1 mSv/year depending on which reg you read. This is 2400 to 400 times lower than the old tolerance dose, and at least 24,000 to 4,000 times lower than the levels at which we see detectable harm. The result has been deadly panic whenever we have had a major release, and a regulatory system that is mandated to make nuclear power prohibitively expensive. The result has been disastrous for humanity and the planet.

However, there are several agencies which have not followed the NRC/EPA rules. One of them is NASA. The NASA annual limit for astronauts is 500 mSv, far laxer than the old tolerance dose, since an astronaut could receive a sizable portion of that 500 millisieverts in a few days.\cite{nasa-2009} This could happen if her space ship gets blasted by a strong solar flare.¹

Figure 1. Solar flares can be rather large

The normal dose rate at the space station in Low Earth Orbit is 0.5 to 1 mSv per day.\cite{kodaira-2021}

Another culprit is the Department of Transportation. The DOT requirement for shielding of radioactive material during transit is 2 mSv/h at the cask surface. This is based on the assumption that nobody will spend more than a half-hour per day hugging the cask, and therefore will receive no more than 1 mSv per day.\cite{nas-2001}[page 9]

But the most interesting miscreant is the US Navy. The reduction of the NCRP/ICRP recommended limit from 1 mSv per day to 3 mSv/week, which was based on genetic fears which proved to be ginned up and unfounded, took place in 1951. This just happened to be the time when the US Navy was setting the limits for nuclear submariners.

In 1956, Ted Rockwell wrote (I've added the sievert levels):

The National Committee for Radiation Protection has established limits for maximum permissible exposure to radiation, which are published in National Bureau of Standards handbooks. These limits are based on conservatively established radiation dose rate that is known to produce no measurable effect on human beings when received continuously over a lifetime of exposure. The established limits or standard dose rate is 0.3 rem (3 mSv) per week.

In certain cases, the dose rate may be averaged over a period of 13 weeks; that is, a radiation dose in excess of 0.3 rem may be taken during a given week so long as the average radiation dose rate at the end of 13 weeks has not been greater than 0.3 rem/week. In these cases, however, the radiation dose in any single week may not normally exceed 0.9 rem (9 mSv). Because of the difficulty of accurately controlling personnel exposure under such conditions, it is advisable to restrict the total 13 week dose to 3.0 rem (30 mSv) rather than 3.9 rem (39 mSv); NBS Handbook 59 recommends this limitation.

During periods of emergency, radiation doses in excess of the above limits are permitted. In emergencies the total cumulative 13 week allowance may be taken as a single dose; that is, up to 3.9 rem (39 mSv) may be taken in a single exposure if necessary. However, the total dosage received during any 13 week period should never exceed the established limit of 3.9 rem. In other words, if an emergency requires that an individual receive his entire 13 week allowance in one single exposure, then that individual should not be permitted to receive additional radiation exposure until the 13 week period has elapsed. This concept is used for special high level, short time maintenance work that cannot be avoided.

Operating within these limits, even those described as ``emergency" is believed to cause no biological damage, and such operation need not be reported outside the operating activity involved.\cite[pages 23-24]{rockwell-1956}

These rules were the outcome of a heated debate between Rickover and his team including Rockwell. The team argued the new limits were unnecessarily tight, and backed it up with testimony from experts. As usual Rickover responded with a salvo of sarcastic, colorful questions:

What if some kid on the Nautilus fathers a two-headed baby? If we haven't met all applicable standards for radiation protection, is that mother going to worry about your damn sonar?"\cite{rockwell-1992}[p 123]

The result was imposing a liberal interpretation of the NCRP recommendations. But when the NCRP lowered its recommendation by another factor of 30 in 1957, Rickover silently changed nothing.² The Navy still operates by its interpretation of the 1950 limits.³

The Navy's definition of a ``high radiation area", which must be locked or guarded, is 1 mSv/h or higher. Stay times are enforced when entry into an area where the dose rate is 10 mSv/h or higher. A sailor can still get up to 39 mSv in a single exposure without requiring an inquiry. However, 100 mSv in a single exposure triggers an investigation by an independent Accident Review Board. Studies show no increase in cancer among American submariners. A 2001 study by NYU looked at a cohort of 85,498 enlisted submariners. This group had experienced 584 cancer deaths. NYU put the expected age-matched cancer deaths at 685.\cite[page 51]{nnpp-2016}

But what's important here is regulatory consistency. We have a handful of rogue bureaucracies which are egregiously violating the EPA/NRC radiation requirements. According to LNT, which is ex cathedra, unquestionable dogma, they are seriously shortening the lives of the people involved. It is not time that Congress step in and protect these victims of heretical agencies?

1. NASA also imposes career limits, which range from 1000 to 4000 mSv depending on sex and age. There's also a limit of 250 mSv per month, which might be difficult to enforce.

2. The NCRP itself acknowledged, this massive change was not based on any new data.

The changes in the accumulated MPD [Maximum Permissible Dose] are not the result of positive evidence of damage due to use of earlier permissible dose levels but rather are based on the desire to bring the MPD into accord with the trends of scientific opinion.\cite[page 1]{nbs59-1957}

Opinion trends that are not based on data are hardly scientific.

3. For the doryphores, an essentially superfluous 50 mSv/y limit was added in 1967.