20 Comments

As you say, the NLT figment of harmful radiation to the general public has squandered a phenomenal amount of western money building a needless sarcophagus, When fear rules, money flows.

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The scenario you are postulating, of an unnecessary large scale evacuation because a SFP is on fire, has already happened (well after Chernobyl). It happened at Fukushima. The on-site NRC expert said in a press interview/release the 'Fukushima U4 SPF was on fire' (despite the utility was saying no). And further he said he would 'stake his career on it.'

In response to that, the Chairman of the US NRC announced that all US citizens within 50 mi of the plant should evacuate.

In response to that, the PM of Japan called for the Fukushima evacuations. After all, if the PM couldn't believe the Chairman of the "Gold Standard of Nuclear Safety" who could he believe?

My problem with that whole ordeal was it was a repeat of what happened at TMI2, as a result of NRC experts announcing the possible H2 explosion fiasco, resulting in the PA Governor calling for a precautionary evacuation of woman and children. The ensuing panic caused an additional 100K people to flee.

So where was the TMI2 lesson learned?

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Aug 11·edited Aug 11

If UL certification can happen in the U.S., it seems unlikely to happen quickly. But the NRC has rule making authority and could reverse the close packing rule. If the NRC decided to reverse its decision on this rule, what would be a reasonable period of time for this action (removal of tight packing) to be completed? Is it likely that on site cask storage space would become an issue?

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Paul,

To be clear, the Underwriter Certification of nuclear power we are proposing is quite different from the UL stamp that you will find on a lot of products. See manual.

Yes, the NRC could reverse its decision. The French nuclear safety authority banned dense-packing. But the issue has come up again and again. In every case, the NRC has done studies which end up supporting dense-packing.

It would take a while. One of the problems is that the shielding becomes activated, so even

if you clear the pool of all the elements that are more than 5 years old, you still have the

issue of replacing this material. I dont know how tough a problem this is.

Area is not an issue. The dry cask storage pad is a very small fraction of the plant area.

All the fuel is going to end up there eventually.

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I'm wondering why you reference and indirectly give bandwidth the UCS fearmongers? Rod Adams wrote a good rebuttal on June 20, 2017 to their extreme opinions opposing an aspect of nuclear power generation here: https://atomicinsights.com/spent-fuel-pools-protect-public-dont-believe-skeptics/ Please note the NRC conclusions based on extensive research and analysis that are found in Rod's article.

Periodically, the local fearmongers have raised this issue at Diablo Canyon Power Plant near San Luis Obispo, California.

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Tragically, the blanket of fear from insignificant radiation exposure has smothered rational energy policies for some 50 years.. And that impoverishes so very many honest, but ill-informed people.

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Gene,

I'm not in the business of selling nuclear. I'm in the business of balancing benefit and cost. In this case, the benefit of going back to open racking clearly outweighs the cost. We pretty much eliminate a worst case scenario for a roughly 1% increase in cost.

But the piece's main takeaway is the destructive potential of LNT. If nuclear is successful, we will have releases. And if LNT dictates the response, that response will lead to tragically unnecessary disruption and mortality, as it did at Chernobyl and Fukushima. The vonHippel scenarios show how unimaginably harmful LNT can be,

Under SNT, there would be little or no evacuation in these scenarios. But we would still face the compensation issue. Under the Amercan tort system, the claims would be in the hundreds of billions of dollars. Under UCert it would be far less. But since UCert grossly over-compensates just about everybody to ensure that nobody is under-compensated, even the UCert compensation is probably uninsurable. The solution is obvious: go back to open-racking.

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deletedAug 12
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Equating NRC staff hours and dollars spent with common sense is almost an oxymoron. PRA's are easily manipulated to come up with whatever the target probability is. Nobody knows what the probability of a spent fuel pool fire is. Since the cost of going back to open-racking is nearly in the noise, it's the only sensible choice.

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Just because there is a theoretical possibility does not justify the unnecessary expenditure of likely billions of dollars. Burdening nuclear power with unique regulations that fail to satisfy risk-benefit analyses is central to the nuclear power opposition playbook. See for example https://www.forbes.com/sites/jamesconca/2014/07/13/absurd-radiation-limits-are-a-trillion-dollar-waste/

July 13, 2014, Forbes Magazine

Absurd Radiation Limits Are A Trillion Dollar Waste

James Conca, Ph.D.

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Depends on the ratio of consequences to cost. Nobody had argued more strongly than I have that the great bulk of the NRC regulatory burden and its consequences is a tragic net disbenefit to society and the planet.

But each issue must be evaluated separately. And central to my argument is the worst case release is tolerable. Unlike the nuclear establishment, I wont tell the Negligible Probability Lie. If a truly successful nuclear uses dense-packing, we will have 10,000 dense-packed spent fuel pools spread all over the planet.

A big dense-packed spent fuel fire combined with an LNT dictated response is pretty close to intolerable.

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I remain optimistic that by the time we have 10,000 dense-packed spent fuel pools spread all over the planet that a regulatory scheme that properly reflects the low risk of ionizing radiation replaces the rejected LNT hypothesis. Now, there are less than 440 nuclear power reactors.

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(There were formatting problems, which I anticipate are now resolved.)

The NRC staff’s recommendation to the Commission following its study of the risk and potential consequences of a spent fuel pool fire and the potential benefit of requiring an expedited program of moving fuel from spent fuel pools into dry storage containers is documented in COMSECY-13-0030 dated as follows:

The staff’s assessment concludes that the expedited transfer of spent fuel to dry cask storage would provide only a minor or limited safety benefit, and that its expected implementation costs would not be warranted. Therefore, the staff recommends that no further generic assessments3 be pursued related to possible regulatory actions to require the expedited transfer of spent fuel to dry cask storage and that this Tier 3 Japan lessons-learned activity be closed.

The staff did not reach that recommendation quickly or cheaply. The conclusion is provided as part of a ten page memorandum that enclosed a 159 page supporting document titled Regulatory Analysis for Japan Lessons-Learned Tier 3 Issue on Expedited Transfer of Spent Fuel

That regulatory analysis was based on previously completed work, including a congressionally mandated post-Fukushima effort that was documented in a 416 page study titled Consequence Study of a Beyond-Design-Basis Earthquake Affecting the Spent Fuel Pool for a U.S. Mark I Boiling Water Reactor dated October 2013. I haven’t asked what the entire effort cost, but the Consequences study itself was the result of more than $3 million and 11,000 professional staff hours spent during FY11-FY13.

When asked for a comment in response to the publication of the Science opinion piece questioning the NRC’s competence and integrity as an effective safety regulator, Scott Burnell of the NRC’s public affairs office provided the following statement.

“The staff’s analysis followed well-established, Commission-approved directives for identifying all attributes affected by the proposed alternative and analyzing them either quantitatively or qualitatively (https://www.nrc.gov/reading-rm/doc-collections/commission/secys/2013/2013-0112scy.pdf). The staff’s technical conclusions regarding potential safety benefits were reached before considering potential costs.

The NRC’s current conclusions regarding spent fuel pool safety and security are best summarized by the staff’s response last summer to the National Academies Phase 2 report on lessons learned from Fukushima:

https://www.nrc.gov/docs/ML1618/ML16188A300.pdf

https://www.nrc.gov/docs/ML1618/ML16188A303.pdf

The NRC welcomes well-supported analysis on issues relating to the agency’s mission. The staff will review the Science policy paper and determine whether any additional action is required. Absent such a review, the NRC stands by the conclusions from the staff’s work to date.”

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Great article Jack!

You are writing about groundshine in Bq/m2 and you translate this into mSv/d.

I assume that implies one person standing and receiving gammas and some betas, depending on the isotope in question. You are mentioning Cs137, which gives mostly 660 keV gammas and also less energetic ones, and few 100 keV betas, that can go up to 1.1 MeV.

However, in real life, the person is not just standing, but also breathing, eating and drinking. Thereby, Cs137 will be ingested. Is there a reasonable way to estimate the rate at which Cs137 would enter the body and how much this would increase the dose rate in mSv/d?

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Hans Peter,

Yes, the radiation protection people attempt to come up with "dose coefficents" to get from Bq/m2 to Sv/h. The numbers used inthe post are those recommended by EPA.

Google Federal Guidance Report 12 to see the method they used. Such coefficients assume a linear relation ship between concentration and dose rate.

It is only during plume passage that inhalation is an important pathway. This will almost be

a matter of hours at any one point, There are also "dose coeff" to get from Bq/m3 to dose rate for each isotope. The inhalation dose can be cut by two orders of magnitude by masking up wiht N95 masks during plume passage. See

https://jackdevanney.substack.com/p/four-simple-questions

There will be some resuspension of the deposited material but the effect will almost always be in the noise.

Ingested radioactivity will also be a non factor if and only if there is intelligent control of contaminated food as there was at Windscale. Contaminated food was also a non factor at Fukushima but over-reaction by the Japanese government caused its own problems. But yes there are alos dose coefficients for ingested isotopes.

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Thanks Jack, much appreciated !

The Federal Guidance Report 12 is insightful. It is quite old and dates back to 1993 !!

Some revision using modern tools with better Monte Carlo and more computing power would not be wrong. I would definitely recommend looking into GEANT4 to track down particle tissue interactions precisely.

I agree that N95 masks help a lot. But when deciding to evacuate or not a larger population from a certain region, then masks should not become a mandatory gadget, except for very short term usage only.

At Windscale, tons and tons of dairy products (milk, cheese, ...) were dumped, mainly for Iodine-131. Dumping it for Cesium-(134, 137) or Strontium-(89, 90) may not be justifiable, but would have been down anyhow. Especially cheese could be stored long enough to clear from Iodine before eating, but probably no one would buy such cheese anyhow.

In the end, these are relevant questions when decisions need to be made to evacuate or not a certain region. Allowing people back in a previously evacuated region is an additional step to be made. Also to look into is on how much effort is needed to decontaminate a certain region.

In Bavaria (Germany) meat from wild boar needs to be tested before it can be served. The tolerated level is 600 Bq/kg from Cs-137 decays. If above, the meat is dumped. Wild boars like eating truffels for which they dig into the ground and thereby, they ingest Cs-137 still today. This Cs-137 is coming from the Chernobyl falllout, where some also claim that atomic tests in the 1950's also (still!) plays a significant additional role.

But only since Chernobyl happened, people started caring and limits on boar meat were set.

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The German boar limit is nonsensical. You would need to eat a kg/week of 400,000 Bq/kg Cs-137 contaminated meat to get up to the tolerance dose rate of 2 mSv/d.

https://jackdevanney.substack.com/p/eating-bavarian-boar

Evacuation is almost never a good idea. Even the US EPA is now recommending shelter-in-place over evacuation until the plume has passed. UCert assumes no evacuation and is designed to discourage evacuation.

c

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Fully agree, but the Germans insist on their 600 Bq/kg limit.

Well, not dumping but selling for a higher price the above limit meat would be a good idea - taking hormesis into account and the healing effect promised.

Did I ever send you my Fukushima tritiated water release paper discussing how much tritiated water one can drink?

You can find it online: https://tinyurl.com/4b8hmvh9

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Breathing of dust, long after the plume has passed, seems like a valid concern. LNT is clearly bunk for sparsely ionizing radiation distributed over our entire body. But if the source is particles lodged in our lung, I wonder if the effect on a small volume of tissue is enough to overwhelm our DNA repair.

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David,

As always, depends on the dose RATE. There have been studies of resuspension. Caracappa put the resuspension dose rate at 0.4% of the groundshine dose rate at Fukushima. My reading of the literature is it would take very unusual conditions (fire, dust storm) before the resuspension dose rate becomes a significant pathway. In those conditions, people should mask up , and not just for radiation. Even then the dose rates

are unlikely to be harmful. Evangeliou put teh additonal dose rate in the Chernobyl CEZ after the fires of 2015 at around 1 mSv/year. A volcano might do it.

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