This piece assumes some familiarity with two radiation harm models, Linear No Threshold (LNT), and Sigmoid No Threshold (SNT). At a minimum, you will need to be familiar with LNT is Nonsense and A Sigmoid No Threshold Primer. SNT has been attacked from the pro-nuke side on the grounds that, in accepting the premise that there is no perfectly harmless dose, SNT concedes too much. This school holds nuclear's future depends on a
I commented on twitter to the head of the Canadian nuclear regulator that LNT could be retained along with a conservative but reasonable cost benefit calculation such as the regulation costing no more than 100x its benefit according to LNT
I feel that there is a two pronged rhetorical strategy available.
Point: "You should respect the science and make the change to SNT"
Counterpoint: "We refuse"
Point: "If you use LNT a reasonable cost benefit factor must be applied. You may now choose between that and SNT"
Wow, talk about damming with faint praise. Calling SNT "less wrong" than LNT is a bit like saying Newton was less wrong than Aristotle in explaining motion. The whole point of the piece is that the policy implications of SNT are completely different than those of LNT.
But it is true that SNT is an epidemiological model which does not attempt to model the actual processes in play in cancer induction. AFAIK, the most advanced model that does attempt this is the Warsaw Model being developed by Professor Fornalski's group. But we don't know when the Warsaw Model will be ready for nuclear power policy use (eg plume analysis). And it is my understanding that if and when the Warsaw Model is ready, the policy implications will be very similar to those of SNT. Why are we waiting?
I agree that SNT would already be a big step. But with SNT radiation still stays dangerous down to the lowest levels - this, as we both know, is not correct.
SNT doesn't take the fear out from radiation, it just lingers it.
And fear leads to panic and wrong decisions as I wrote recently:
I try to avoid using words like "safe" and its antonym "dangerous". Whether or not something is "safe" or "dangerous" is a subjective judgement. Most of us regard commercial aircraft travel to be "safe" despite the non-zero probability of a crash. Others disagree, and that's their right.
Whether or not there is a dose rate below which there is absolutely zero harm --- I personally don't think that argument has been made --- nuclear power, like commercial aircraft travel, will always involve a non-zero risk, since there is always a probability any threshold will be exceeded.
The issue is at what point does the risk become societally acceptable (aka negligible). The EPA and NRC have told us what they think that level is. Congress has silently acquiesced. So I think we can assume society agrees.
The problem is the combination of LNT and this risk level results in "acceptable" dose rates that are easily exceeded in a release. So we adopt horrendously expensive and largely ineffective policies to prevent a release; and we panic when a release happens, which panic results in grievous harm societal harm.
But if the EPA/NRC acceptable risk level is combined with SNT and reasonable buffer zones, the impact of even a very large release is no worse than any other industrial casualty. We can use the same methods for regulating that risk as we do for refineries or chemical plants.
Of course, there will always be some people who regard any radiation risk, however small, as unacceptable. You offer the example of tritium. These people cannot be persuaded by logic. Consider the Austrians. Under Austrian law, the health spas must keep their radon levels at 30 times the EPA action level for remediating basements. Otherwise, the customers cannot use their government health insurance to pay for the treatment. Austria is stridently anti-nuclear.
Such inconsistent attitudes are strongly encouraged by ALARA. But who invented ALARA? Who enforces ALARA? The NRC, that's who. So you are right. It is not enough to replace LNT with SNT. The nuclear establishment will also have to abandon ALARA and be consistent with their own definition of acceptable risk.
But this they will never do, for this scenario would reveal the NRC has no reason to exist. Both LNT and NRC must go.
I think it is a good strategy to avoid terms like "safe" and "dangerous" in some elements of the discussion, especially when it boils down to subjective judgements.
In turn, these terms do not exist for nothing. "Safe" and "dangerous" are valid terms to be used, but they also need to be put in context. It's all about risk assessment.
I often use metaphorical terms. For instance the dangers of "water". It is obvious that people drown, and sometimes even in ridiculously small amounts of water. On the other hand, applying LNT and ALARA on water would be more than contra-productive.
Austria and their ingrained fear from radiation, is an interesting case. I wonder if there will sometime be a gigantic law case, when a person is deprived from their health coverage. There is plenty of evidence that a little bit of radon exposure reduces the risk of lung cancer - as you certainly know.
We both agree that LNT and ALARA need to go. That this is difficult, we both know. That's why you call your site 'Gordian Knot'; and the only way to unknot a Gordian Knot is by cutting. But SNT still allows for ALARA to be applied...
If the NRC is gone, who will enforce ALARA? The underwriter's inspectors will call out operating practices they dont like, which is fine. But if an underwriter cancels a policy unreasonably, the plant will just turn to another insurer. And in the design and building, we will have hard and fast rules for what is legal and what is not. That's all we need.
Pls reread the Underwriter Certification pieces.
By the way, based on the results to date, after doing all its calculations, the Warsaw Model results in --- wait for it --- a sigmoid harm curve. Fornalski can run his model with and without an adaptive response. For a constant dose rate profile, the effect of the adaptive response is to shift the sigmoid curve to the right.
So basically: “We believe in science” and “Science is what we tell you it is- it cannot be questioned”
I commented on twitter to the head of the Canadian nuclear regulator that LNT could be retained along with a conservative but reasonable cost benefit calculation such as the regulation costing no more than 100x its benefit according to LNT
I feel that there is a two pronged rhetorical strategy available.
Point: "You should respect the science and make the change to SNT"
Counterpoint: "We refuse"
Point: "If you use LNT a reasonable cost benefit factor must be applied. You may now choose between that and SNT"
We all agree that LNT is nonsense.
Concluding that SNT is right is also nonsense.
Nevertheless, it is less wrong and data shows this clearly - so we have an improvement.
Following science would also mean to get a model that describes the data.
I mean for a realistic description on impact vs dose and possibly accounting for dose rate.
Differentiating at least in 2 bins for fast and slow absorption would be a big step.
However, this does not work easily when there is a fall-out of various type nuclides with vastly different half-life times.
This may be more complex for regulators, but then they may need to be trained.
HansPeter,
Wow, talk about damming with faint praise. Calling SNT "less wrong" than LNT is a bit like saying Newton was less wrong than Aristotle in explaining motion. The whole point of the piece is that the policy implications of SNT are completely different than those of LNT.
But it is true that SNT is an epidemiological model which does not attempt to model the actual processes in play in cancer induction. AFAIK, the most advanced model that does attempt this is the Warsaw Model being developed by Professor Fornalski's group. But we don't know when the Warsaw Model will be ready for nuclear power policy use (eg plume analysis). And it is my understanding that if and when the Warsaw Model is ready, the policy implications will be very similar to those of SNT. Why are we waiting?
Excellent reply, Jack !
I agree that SNT would already be a big step. But with SNT radiation still stays dangerous down to the lowest levels - this, as we both know, is not correct.
SNT doesn't take the fear out from radiation, it just lingers it.
And fear leads to panic and wrong decisions as I wrote recently:
https://arxiv.org/abs/2309.07083
HansPeter,
I try to avoid using words like "safe" and its antonym "dangerous". Whether or not something is "safe" or "dangerous" is a subjective judgement. Most of us regard commercial aircraft travel to be "safe" despite the non-zero probability of a crash. Others disagree, and that's their right.
Whether or not there is a dose rate below which there is absolutely zero harm --- I personally don't think that argument has been made --- nuclear power, like commercial aircraft travel, will always involve a non-zero risk, since there is always a probability any threshold will be exceeded.
The issue is at what point does the risk become societally acceptable (aka negligible). The EPA and NRC have told us what they think that level is. Congress has silently acquiesced. So I think we can assume society agrees.
The problem is the combination of LNT and this risk level results in "acceptable" dose rates that are easily exceeded in a release. So we adopt horrendously expensive and largely ineffective policies to prevent a release; and we panic when a release happens, which panic results in grievous harm societal harm.
But if the EPA/NRC acceptable risk level is combined with SNT and reasonable buffer zones, the impact of even a very large release is no worse than any other industrial casualty. We can use the same methods for regulating that risk as we do for refineries or chemical plants.
Of course, there will always be some people who regard any radiation risk, however small, as unacceptable. You offer the example of tritium. These people cannot be persuaded by logic. Consider the Austrians. Under Austrian law, the health spas must keep their radon levels at 30 times the EPA action level for remediating basements. Otherwise, the customers cannot use their government health insurance to pay for the treatment. Austria is stridently anti-nuclear.
Such inconsistent attitudes are strongly encouraged by ALARA. But who invented ALARA? Who enforces ALARA? The NRC, that's who. So you are right. It is not enough to replace LNT with SNT. The nuclear establishment will also have to abandon ALARA and be consistent with their own definition of acceptable risk.
But this they will never do, for this scenario would reveal the NRC has no reason to exist. Both LNT and NRC must go.
I think it is a good strategy to avoid terms like "safe" and "dangerous" in some elements of the discussion, especially when it boils down to subjective judgements.
In turn, these terms do not exist for nothing. "Safe" and "dangerous" are valid terms to be used, but they also need to be put in context. It's all about risk assessment.
I often use metaphorical terms. For instance the dangers of "water". It is obvious that people drown, and sometimes even in ridiculously small amounts of water. On the other hand, applying LNT and ALARA on water would be more than contra-productive.
Austria and their ingrained fear from radiation, is an interesting case. I wonder if there will sometime be a gigantic law case, when a person is deprived from their health coverage. There is plenty of evidence that a little bit of radon exposure reduces the risk of lung cancer - as you certainly know.
We both agree that LNT and ALARA need to go. That this is difficult, we both know. That's why you call your site 'Gordian Knot'; and the only way to unknot a Gordian Knot is by cutting. But SNT still allows for ALARA to be applied...
HansPeter,
If the NRC is gone, who will enforce ALARA? The underwriter's inspectors will call out operating practices they dont like, which is fine. But if an underwriter cancels a policy unreasonably, the plant will just turn to another insurer. And in the design and building, we will have hard and fast rules for what is legal and what is not. That's all we need.
Pls reread the Underwriter Certification pieces.
By the way, based on the results to date, after doing all its calculations, the Warsaw Model results in --- wait for it --- a sigmoid harm curve. Fornalski can run his model with and without an adaptive response. For a constant dose rate profile, the effect of the adaptive response is to shift the sigmoid curve to the right.