AFAIK, the Environmental Protection Agency is the issuing authority over the Protective Action Guides that provide guidance (requirements) for emergency management and evacuation.
By the Energy Reorganization Act of 1974, the EPA is the agency that is supposed to have the scientific expertise to establish radiation protection standards that the NRC then implements with detailed regulations.
I agree with your main point about the absurdity of our current standards, but we need to aim at the right targets in order to make the necessary changes.
It's not that simple. Legally, the CAA contains the following out.
(9)Sources licensed by the Nuclear Regulatory Commission No standard for radionuclide emissions from any category or subcategory of facilities licensed by the Nuclear Regulatory Commission (or an Agreement State) is required to be promulgated under this section if the Administrator determines, by rule, and after consultation with the Nuclear Regulatory Commission, that the regulatory program established by the Nuclear Regulatory Commission pursuant to the Atomic Energy Act [42 U.S.C. 2011 et seq.] for such category or subcategory provides an ample margin of safety to protect the public health.
Far more importantly, as a practical matter, when a nuclear plant has a release the NRC takes over. The EPA was nowhere to be found at TMI. The NRC was all over the place.
It is true that the NRC can only make recommendations. In the US, it's the governors that actually order an evacuation. At TMI, thank God, Gov. Thornburgh rejected most of the NRC's recommendations. But few politicians have the common sense and courage that Thornburgh exhibited.
US nuclear's overriding problem is the NRC. I'm aiming at the right target and the necessary change is abolition.
It seems to indicate that the EPA is still the authority that approves the NRC standards and thus is the agency that must change its own standards before the NRC can.
A good example to me is the long running battle between the NRC and the EPA over the standard for releases from the planned repository at Yucca Mountain. The NRC insisted that the EPA's preferred standard of 10 mrem/yr (0.1 mSv) was too low, but it several years of contention – as documented by a couple of GAO reports – before the issue was finally resolved by setting a level that was 50% higher than the EPAs preference. Of course, it was still an absurdly low 15 mrem/yr.
Here is one of the GAO reports that discusses the contentions between the NRC and the EPA.
That report highlights another facet of the issue - the NRC has no authority over the standards set for activities and locations that are not related to its licensed activities. It's the EPA standards that are driving the $3 B/yr clean up effort at Hanford, for example.
The LNT assertion is producing a lot of cost and harm outside of nuclear energy generation.
Youre almost off topic. This piece is talking about what happens in a release. What happens is the NRC moves in and starts making recommendation, int he TMI case this included some unhinged recommendations. In a really large releases, those recommendations will turn a manageable disruption into deadly chaos.
But TMI was 46 years ago. Our communications and media construct has changed rather dramatically.
The Protective Action Guides given to local emergency management by the EPA and used for their training may turn out to have a larger effect than whatever the NRC might do.
Fukushima was 14 years ago. The NRC was quite clear about what it would have done. The media went running to the NRC, not the EPA.
The EPA has been issuing PAG's since 1992.
But yeah, after we get rid of the NRC, we will still have to deal with the EPA, A substack related to this issue will be published in the next few days.
Seems to me the EPA should have absolutely no jurisdiction in nuclear matters as there are no emissions from correctly operating plants other than some saturated vapor and runoff water. In a perfect world. The NRC should be the governing authority on all things nuclear. That just furthers your point about major reform and a reboot of their goals and metrics to more evidence based standards. But what do I know? All safety agencies seem to become empire builders, extending their authority and power as far as they're allowed even when it kills the thing they’re trying to regulate.
The NRC is in charge of all things nuclear. That's why we are in the mess we are. That's why the next big release in the US will be deadly for the public rather than a big painint he butt for the locals.
Lots of good points in this post(and in all of your writing). Some other point of view on the problem is precondition to fear and no attempt to quantify the risk for the public. This could be changed without touching NRC/EPA entrenched bureaucracy so perhaps worth considering? During the incident people expect guidance and decisions being made rather fast, drastic measures feel better than indecisiveness like "placebo in the syringe" may be more potent than "placebo in the pill". Leaders want to show decisiveness as to following public demand.
Would people (and leaders) consider evacuation differently if the NRC would have to quantify the risk to the public? Would people support evacuations if the message would be "when you evacuate, based on LNT, the worst case scenario, your personal risk of cancer will decrease by 0.015 percent, risk of death from cancer by half of that". By evacuation you risk uprooting all of your life, stress, never being able to come back (not because the place is contaminated, but because abandoned places deteriorate fast, schools, shops, services and jobs in affected areas may not recover in your lifetime). Governments will perhaps compensate you well and you may be a customer of lawyers for life, but it is going to be life somewhere else.
Alternative is to stay in place without panic, mask if outdoors, avoiding excessive outdoors activities, Iodine may or may not be recommended (easy measure). Consuming local foods before thorough hotspot checkups clears them should be avoided. In days the affected area will be checked for contamination and hotspots and further plans will be drawn (evacuation highly unlikely). Increase in cancer risk is unlikely to be measurable, and you would do better to reduce cancer risk by healthier life (you lived next to NPP, so your region is much cleaner and wealthier than powered by coal anyways). Better healthcare is more important for the risk of dying from cancer than mSieverts.
When would I consider evacuation? I guess 1% of increased risk would start to be a threshold. What would be the release to cause that even with LNT?
Ideally people living in a potential "plume zone", once in 30years somewhere in the world, would understand quantitative risks before incidence would occur, because during an accident it is a bit too late to educate.
AFAIK, the Environmental Protection Agency is the issuing authority over the Protective Action Guides that provide guidance (requirements) for emergency management and evacuation.
https://www.epa.gov/radiation/protective-action-guides-pags
By the Energy Reorganization Act of 1974, the EPA is the agency that is supposed to have the scientific expertise to establish radiation protection standards that the NRC then implements with detailed regulations.
https://www.epa.gov/radiation/radiation-regulations-and-laws
I agree with your main point about the absurdity of our current standards, but we need to aim at the right targets in order to make the necessary changes.
Rod,
It's not that simple. Legally, the CAA contains the following out.
(9)Sources licensed by the Nuclear Regulatory Commission No standard for radionuclide emissions from any category or subcategory of facilities licensed by the Nuclear Regulatory Commission (or an Agreement State) is required to be promulgated under this section if the Administrator determines, by rule, and after consultation with the Nuclear Regulatory Commission, that the regulatory program established by the Nuclear Regulatory Commission pursuant to the Atomic Energy Act [42 U.S.C. 2011 et seq.] for such category or subcategory provides an ample margin of safety to protect the public health.
Far more importantly, as a practical matter, when a nuclear plant has a release the NRC takes over. The EPA was nowhere to be found at TMI. The NRC was all over the place.
It is true that the NRC can only make recommendations. In the US, it's the governors that actually order an evacuation. At TMI, thank God, Gov. Thornburgh rejected most of the NRC's recommendations. But few politicians have the common sense and courage that Thornburgh exhibited.
US nuclear's overriding problem is the NRC. I'm aiming at the right target and the necessary change is abolition.
Jack - Thank you for the clarification.
It seems to indicate that the EPA is still the authority that approves the NRC standards and thus is the agency that must change its own standards before the NRC can.
A good example to me is the long running battle between the NRC and the EPA over the standard for releases from the planned repository at Yucca Mountain. The NRC insisted that the EPA's preferred standard of 10 mrem/yr (0.1 mSv) was too low, but it several years of contention – as documented by a couple of GAO reports – before the issue was finally resolved by setting a level that was 50% higher than the EPAs preference. Of course, it was still an absurdly low 15 mrem/yr.
Here is one of the GAO reports that discusses the contentions between the NRC and the EPA.
https://www.gao.gov/assets/t-rced-00-252.pdf
That report highlights another facet of the issue - the NRC has no authority over the standards set for activities and locations that are not related to its licensed activities. It's the EPA standards that are driving the $3 B/yr clean up effort at Hanford, for example.
The LNT assertion is producing a lot of cost and harm outside of nuclear energy generation.
Rod,
Youre almost off topic. This piece is talking about what happens in a release. What happens is the NRC moves in and starts making recommendation, int he TMI case this included some unhinged recommendations. In a really large releases, those recommendations will turn a manageable disruption into deadly chaos.
Okay.
But TMI was 46 years ago. Our communications and media construct has changed rather dramatically.
The Protective Action Guides given to local emergency management by the EPA and used for their training may turn out to have a larger effect than whatever the NRC might do.
As always, I might be wrong.
On to other topics.
Fukushima was 14 years ago. The NRC was quite clear about what it would have done. The media went running to the NRC, not the EPA.
The EPA has been issuing PAG's since 1992.
But yeah, after we get rid of the NRC, we will still have to deal with the EPA, A substack related to this issue will be published in the next few days.
Seems to me the EPA should have absolutely no jurisdiction in nuclear matters as there are no emissions from correctly operating plants other than some saturated vapor and runoff water. In a perfect world. The NRC should be the governing authority on all things nuclear. That just furthers your point about major reform and a reboot of their goals and metrics to more evidence based standards. But what do I know? All safety agencies seem to become empire builders, extending their authority and power as far as they're allowed even when it kills the thing they’re trying to regulate.
David,
The NRC is in charge of all things nuclear. That's why we are in the mess we are. That's why the next big release in the US will be deadly for the public rather than a big painint he butt for the locals.
Lots of good points in this post(and in all of your writing). Some other point of view on the problem is precondition to fear and no attempt to quantify the risk for the public. This could be changed without touching NRC/EPA entrenched bureaucracy so perhaps worth considering? During the incident people expect guidance and decisions being made rather fast, drastic measures feel better than indecisiveness like "placebo in the syringe" may be more potent than "placebo in the pill". Leaders want to show decisiveness as to following public demand.
Would people (and leaders) consider evacuation differently if the NRC would have to quantify the risk to the public? Would people support evacuations if the message would be "when you evacuate, based on LNT, the worst case scenario, your personal risk of cancer will decrease by 0.015 percent, risk of death from cancer by half of that". By evacuation you risk uprooting all of your life, stress, never being able to come back (not because the place is contaminated, but because abandoned places deteriorate fast, schools, shops, services and jobs in affected areas may not recover in your lifetime). Governments will perhaps compensate you well and you may be a customer of lawyers for life, but it is going to be life somewhere else.
Alternative is to stay in place without panic, mask if outdoors, avoiding excessive outdoors activities, Iodine may or may not be recommended (easy measure). Consuming local foods before thorough hotspot checkups clears them should be avoided. In days the affected area will be checked for contamination and hotspots and further plans will be drawn (evacuation highly unlikely). Increase in cancer risk is unlikely to be measurable, and you would do better to reduce cancer risk by healthier life (you lived next to NPP, so your region is much cleaner and wealthier than powered by coal anyways). Better healthcare is more important for the risk of dying from cancer than mSieverts.
When would I consider evacuation? I guess 1% of increased risk would start to be a threshold. What would be the release to cause that even with LNT?
Ideally people living in a potential "plume zone", once in 30years somewhere in the world, would understand quantitative risks before incidence would occur, because during an accident it is a bit too late to educate.