“Protection Standards for Nuclear Power Operations” means what?

The Environmental Protection Agency (EPA) of the United States is a full blown oxymoron when it comes to protecting U.S. residents from the danger of increased exposure to ionizing radiation. That’s the kind of radiation that comes from natural sources like Uranium and the sun, as well as unnatural sources like Uranium mines, nuclear weapons, and nuclear power plants (even when they haven’t melted down like Fukushima). The EPA is presently considering allowing everyone in the U.S. to be exposed to higher levels of ionizing radiation.

In 1977, the EPA established levels of radiation exposure “considered safe” for people by federal rule (in bureaucratese, “the regulation at 40 CFR part 190”). In the language of the rule, the 1977 safety standards were: “The standards [that] specify the levels below which normal operations of the uranium fuel cycle are determined to be environmentally acceptable.” In common parlance, this became the level “considered safe,” even though that’s very different from “environmentally acceptable.” “Acceptable by whom? The environment has no vote.

The phrase “considered safe” is key to the issue, since there is no “actually safe” level of radiation exposure. The planet was once naturally radioactive and lifeless. Life emerged only after Earth’s radiation levels decayed to the point where life became possible, in spite of a continuing level of natural “background radiation.” The reality is that there is no “safe” level of radiation exposure.

In January 2014, the EPA issued a very long proposal (in bureaucratese, an “Advance Notice of Proposed Rulemaking”) to consider raising the “safe” radiation levels established in 1977. According to the EPA, the proposal “does not propose revisions to the current regulation, but is being issued only to collect information to support EPA’s review.” The public comment period on the EPA proposal ­– titled “Environmental Radiation Protection Standards for Nuclear Power Operations” – has been extended to August 4, 2014.

Comments from the public may be submitted online at regulations.gov, by email via vog.apenull@tekcod-r-dna-a, as well as by hand, fax, or U.S. mail, all listed on site.

Is the EPA actually immersed in a protection racket?

The studied ambiguity of the proposal’s title – “Environmental Radiation Protection Standards for Nuclear Power Operations” – goes to the heart of the issue: who or what is really being protected, nuclear power operations?

Quite aware that it is perceived by some as placing the desires of the nuclear power industry above the safety needs of the population, the EPA begins its proposal for changing radiation limits with this defensive and apparently contradictory passage:

This Advance Notice of Proposed Rulemaking is being published to inform stakeholders, including federal and state entities, the nuclear industry, the public and any interested groups, that the Agency is reviewing the existing standards to determine how the regulation at 40 CFR part 190 should be updated and soliciting input on changes (if any) that should be made.

This action is not meant to be construed as an advocacy position either for or against nuclear power.

EPA wants to ensure that environmental protection standards are adequate for the foreseeable future for nuclear fuel cycle facilities. [emphasis added]

As far as the EPA is concerned, the uranium fuel cycle does not include Uranium mining, despite the serious environmental danger that process entails. Once the environmental and human degradation from Uranium mining has been done, the EPA begins regulating environmental protection from nuclear fuel cycle facilities, beginning with milling and ending with storage or reprocessing facilities for nuclear waste.

According to the agency itself, “EPA’s mission is to protect human health and the environment. EPA sets limits on the amount of radiation that can be released into the environment.”

Radiation exposure is chronic, cumulative, and unhealthy

Given the pre-existing radiation load on the environment from natural sources, it’s not clear that there is any amount of radiation that can be released into the environment with safety. The EPA pretty much evades that question, since the straight forward answer for human health is: no amount. Besides, the semi-captured protection agency is just as much engaged in protecting economic health for certain industries as it is in protecting human health. This leads it to making formulations that manage to acknowledge human reality without actually supporting it:

The Agency establishes certain generally applicable environmental standards to protect human health and the environment from radioactive materials.

These radioactive materials emit ionizing radiation, which can damage living tissue and cause cancer.

The EPA’s 1977 rules were promulgated in an era of optimism about the expansion of nuclear power in the U.S. Even the EPA was predicting 300 operating reactors within 20 years. In 1973, President Nixon had predicted 1,000 reactors by 2000.

In 1979, the Three Mile Island nuclear power plant accident happened, when the reactor core partially melted down. The number of operating nuclear power plants has never risen much above 100 since then. The nuclear industry wants a relaxation of limits on radiation releases to stimulate new plant construction.

Lower radiation levels provide more environmental protection

Environmental organizations like the Nuclear Information and Resource Service (NIRS) are urging the EPA to lower radiation release standards, to “protect more, not less.” According to NIRS, regulation of nuclear power has a sorry history:

Nuclear power operations that release radioactivity have been given an enormous “free pass” to expose communities (and the biosphere) to levels of radiation that are too high. When converted to RISK of cancer, the current regulation allows harm 2000 times higher than the EPA’s stated goal of allowing only 1 cancer in a million from licensed activities. Even using EPA’s more lax allowable risk level of 1 in 10,000 current EPA radiation regulations allow 20 times higher than that.

Nuclear proponents have long argued that there are “safe” levels of radiation, or even that some radiation exposure is good for you. What “safe” actually means in this context is that there are low levels of radiation that will take a long time to cause harm (cancer, genetic damage) and that in the meantime the odds are close to 100% that you will die from some other cause.

In 2005, the National Academy of Sciences addressed “safe” levels of radiation and concluded that there are none in any scientifically meaningful sense.

Humans are exposed to a basic, damaging level of ionizing radiation from multiple sources from gestation till death. This natural background radiation is at a relatively low level, but the risk from radiation is cumulative. Every additional exposure above background radiation adds to the risk. Some of these risks, like radiation treatment to ward off cancer, are widely accepted as reasonable trade-offs. The reasonableness of greater exposure from the nuclear fuel cycle and the uncontrolled growth of nuclear waste is not such an obviously beneficial trade-off.