11 Comments

The main biological effect of radiation is the production of reactive oxygen species that can be metabolized and cleared. Just taking into account DNA repair is not enough. High dose rate radiation (mGy/s) has effects that low dose rate radiation do not have.

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By "effects" you presumably mean irreparable damages. That fits with the SNT model wouldn't you say?

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Mar 3
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Corcos,

I've put up with your nonsense long enough. We do not welcome unsubstantiated conspiracy claims on this site. Reword or delete the last sentence or this comment will be expunged.

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Jack, I think the most important thing you said in this article is that SNT is an engineering solution - not a biological solution. It allows us to build safe and reliable Nuclear Power Plants without constantly revising the biology. This is the advantage of the over conservative results. The engineers can get about their business and the biologists can continue to explore the exact nature of the repair mechanisms. The biological research will NOT constantly revise the engineering. As you point out LNT - by its nature - does not allow AN engineering solution. Each engineering solution is flawed by definition under LNT. SNT allows engineering solutions that can be confirmed as "SAFE." LNT cannot use the term "SAFE" no matter the solution. As long as the regulator, or insurance adjuster cannot stamp "SAFE" on a NPP we cannot build them in the USA. This is why, even with large subsidies, we don't have order books filled with new NPP builds. It is the future liability risk, which under LNT is unlimited, that makes a utility, of any size, hesitant. If the risk of exposure were known and limited, it can be accounted for, costs calculated and cost per KWH or MWH known. I think you should approach the new leaders at the EPA directly with your proposal. The approach needs to be in a Power Point or graphic format with the benefits and weaknesses of LNT, and the benefits and weakness of SNT clearly laid out. This specific post is a fantastic outline to start with. The presentation needs to be at a lay level, about 9th grade HS. Your fantastic back notes and supporting material will supply the technical depth. The simple presentation will either get them searching your notes or will go in the trash. The presentation should emphasize the difference between an engineering solution and a biological solution, and should clearly justify changing the dosage exposure by an INCREASE of 3000 times. The FAA finally dropped the regulation of cell phones in airplanes because the science just did not justify it. Individual airlines could do what they wished but they could no longer use FAA as a cover for their desire to keep people from using their phones in flight.

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David,

I like your emphasis on the engineering vs biology angle. It avoids us sounding like we are telling the biologists how to do their job.

I have no way of getting to Zeldin. But there are LNT and SNT slide shows at

https://gordianknotbook.com/download/the-linear-no-threshold-theory-slidesthe

and

https://gordianknotbook.com/download/standalone-snt-slides

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Last Energy is filling up their order book. They already have about 80 orders for their 20MW plants under power purchase agreements. That number of orders allows them to keep a supply chain operating. It is also the equivalent of an AP1000 ++. I am super interested to see if they can successfully build the units. They state their goal is to build thousands a year. None of these will be in the USA as long as LNT is the reigning paradigm. Chris Wright would be very open to your presentation that I suggested below your send to EPA. The DOE can sponsor research into your presentation.

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I had not heard of Last Energy before, so a quick search [ at https://www.neimagazine.com/news/last-energy-to-build-30-microreactors-for-texas-data-centres/?cf-view ] left me with the understanding they have or will have 80 units in Europe, and 30 planned/ pending inTX?

What have they done to obtain licensing or by-pass other licensing requirements?

I am missing something from (i.e., confused about) the above discussion of SNT modeling and insurance provisions, etc., and this type of "on the ground" work now being performed?

Is it that small plants are somehow not as much of a concern as the larger ones? It sounds like they are past any level of experimental licensing that they might have been granted for prototype or pilot installations?

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Here is the link to the Last Energy website. https://www.lastenergy.com/ The media page gives a great deal of background to the various projects. They have focused on Europe because the pattern of regulation is a bit easier to get through. They are using standard parts that can be purchased from regular vendors today. This aids them a great deal in the EU regulatory environment, the parts are well know, well categorized. They are using power purchase agreements and taking full responsibility for the reactor, fuel, and disposal. I have NOT YET seen that they have working reactors in place. When they do, I will jump up and down with several "Praise the LORDs"!!! So the SNT / LNT discussion impacts their business model in several ways. 1. The NRC reactor approval process is designed to take years. 2. The LNT model is the basis for As Low As Reasonably Achievable ALARA that means the regulations have a built in ratchet to bring radiation exposure down, every year. 3. The NRC includes the aircraft impact rule that is forcing all the vendors to either go underground or to build massive concrete structures to survive a hit by a jet. That regulation depends on the whole concept of a safety zone, evacuation zone around a plant in case of a radiation release. The zone needs to be large because LNT says that ANY exposure to radiation is harmful. Last Energy has a small footprint and the ability to co-locate their plants behind the meter that will not work with either the aircraft impact rule or the large evacuation zone.

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Do you have any comments on the Last Energy suit claiming that the NRC can't regulate them? Would love to see a post.

https://www.ans.org/news/2025-01-13/article-6680/last-energy-texas-utah-allege-nrc-overstepping-in-smr-regulation/

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V,

Dont see it going anywhere. Congressional intent was pretty clear and we have 75 years of case law with the NRC regulating even tiny bits of radioactive material. The fact that Last intends to gang together dozens of their units won't help.

I think a much stronger Article 10 case can be made that the AEA/NRC cant regulate intra-state nuclear. especially for states like AK and HI, possibly Texas, but even that would be a very heavy lift, given all the legislative and regulatory baggage.

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I hope you are wrong, suspect that you are right.

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