It's pretty hard to leave politics out of it because it's all about politics. It just shows that the Koch brothers are still very active.

He’s got a pen. He’s got a phone.

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Civilize the mind, but make savage the body.

- Chinese proverb

I have no problem with removing tax breaks and subsidies for energy, ALL energy.

Fascinating questions; I've snipped all but a couple.

The regulation of CO2 under the Clean Air Act hinges partially on the definition of 'pollutant'. This first went to the Supreme Court AFAIK in Mass. vs. EPA (https://en.wikipedia.org/...al_Protection_Agency). In 2003 the EPA (under Bush) had determined that they could not regulate CO2 from motor vehicles under the CAA - some states sued and the Supreme Court eventually decided in their favor. So the SC has said quite clearly that the EPA can regulate CO2 emissions from motor vehicles.

The EPA (under Obama) extended the reasoning in that decision to apply it to stationary sources (i.e. power plants). They were sued, and the case was decided by the Supreme Court in 2014. EPA lost on a significant component of their argument ("Tailoring Rule"), but the Court allowed them to regulate greenhouse gas emissions at facilities that were already subject to " prevention of significant deterioration" regulation under the CAA.

At this point the EPA changed course slightly and used section 111(d) of the CAA in developing the Clean Power Plan. It gets real complicated at this point and I don't pretend to fully understand it. But the CPP basically establishes performance criteria for power plants, and then requires individual states to develop plans to achieve those performance standards. It's weird because it involves the states as intermediates.

I think the Bush EPA was wrong in refusing to regulate CO2 from motor vehicles, and I think the Obama EPA was wrong in their convoluted approach to the CPP. In their decisions on these issues, the justices have said that Congress needs to do something, and I fully agree. But Congress won't touch CO2. Indeed, I wonder if their inaction is encouraging ideologues in the Executive. I wonder if our gridlocked, ineffective Congress is encouraging the Executive branch towards what might be called risky behavior - placing ideological bets that are undertaken only because they will not be checked by Congress, only by the judiciary in many years time, if at all.

You have part of the answer and are on the right track. Was really a rhetorical question, but no way for you to know that.

I was in my teens when all this happened and paid no attention, I but studied environmental law in law school in late 80s. At that time most of the big battles had happened, but events were still fresh, at least within last decade or so.

From what I can remember, the narrative was that there was a popular consensus arising from a number of factors, including, off the top of my head, Rachel Carson's book Silent Spring, DDT, Eagles, the Cuyahoga River was literally burning, many rivers were sewers, California smog, Love Canal.

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It doesn't really matter what Phil is saying, the music of his voice is the appropriate soundtrack for a bicycle race. HTupolev

Thanks for the link to Mass v. EPA. My memory was fuzzy but my intuition was correct. The curious thing about environmental law, and administrative law in general, is that courts must defer to the agency (I'm stating that broadly -- it gets complex). Clearly CO2 is a pollutant. But what regulations are needed, if any? That question is to be answered by the agency and the agency gets deference. In cases where the facts seem to call for the agency to address the issue in some way, the most the court can do is remand to the agency saying, in essence, "your reasons for x do not make sense to us, look at it further and do something or explain yourself better."

Accordingly, per the wiki article,


Thus I think the WaPo article's characterization was incorrect. Complex legal question so the slight mistake understandable. Written by a reporter not a law professor whose work is reviewed by a team on the publishing law review.

I just realized I'm ten years retired from the business and have no business talking about it anymore.

I think you are right that Obama EPA messed up by going under 111(d) instead of tackling it more broadly under 202(a). My guess is they were being too clever by half. I could read up on it, but I'll wait for one of the smart ones here to fill me in, or, perhaps more likely, just ask my old environmental law professor next time I talk to him.

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It doesn't really matter what Phil is saying, the music of his voice is the appropriate soundtrack for a bicycle race. HTupolev

I have no idea about the all the legal subtleties. If you think you're unqualified to talk about it, I'm not even qualified to judge my own qualification.

My one contribution is to question whether the recent actions are being oversold. As in this is a new life for coal. Because it's my understanding that coal is effed for lots of reasons having little to do with government regulation. Primarily the cost of natural gas getting crushed, followed after by the costs of solar and wind also falling.

So some part of this is just political posturing. No matter which way it goes, there is no substantive resurgence of coal in the coming decade or so. It's just a matter of which sides gets to declare victory to their "base."

Could be wrong, that's just how I see it.

I'm thinking the same way as you. But that includes the last sentence, and now I'm confused because is that a double negative or something to agree with that? I guess I'm saying if you are wrong, so am I.

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It doesn't really matter what Phil is saying, the music of his voice is the appropriate soundtrack for a bicycle race. HTupolev

I'm not an attorney, but I often consult with them. My impression is that environmental law has become more difficult in the last decade or so, partially because the landmark legislation is outdated, partially because Congress refuses to take action, and partially because of executive branch overreach and/or pandering to industry (engaged in by both parties).

If you want a good example of how environmental regulation has failed the public, look at the PFAS issue. EPA got the manufacturers to stop making PFOS in 2002, but never regulated the use of products containing it. So firefighters continued to use AFFF containing PFOS, and it continued to leach into groundwater all around the country. Meanwhile only few toxicology studies were undertaken. Finally in 2009 EPA issued a non-binding Provisional Health Advisory level for PFOS and PFOA in drinking water. Non-binding, that is, until EPA arbitrarily applies an Administrative Order under the emergency provisions of the SDWA (as they did in several cases). Then in 2016 they updated the HA numbers, but still didn't make them enforceable. So the states are in the position of having to deal with affected water supplies, without having any regulatory tools. Meanwhile the public is outraged that their drinking water supplies have been polluted and their states aren't doing anything about it (the states' hands having been tied by EPA). The result is a patchwork of regulation as states adopt their own contaminant levels, many of them different and ranging over a couple of orders of magnitude. The result? Adverse effects on public health, and billions out of the treasury. Meanwhile industry has switched to shorter-chain PFAS (google "chemours genx cape fear"), and so the whole scenario will play out again in a couple of decades.

Congress is starting to act on the issue, but so far they are 1) providing funding to DoD to clean up PFAS, and 2) requesting that CDC/ATSDR conduct health surveys. What's needed is 1) a broad basic research effort on PFC toxicology, and 2) an updated TSCA that provides a precautionary principle for any further industrial uses of PFAS.

I'm not holding my breath ...

 

In places yes. But not enough to create a national movement. It is not on the radar of the general public.

Since I learned years ago how PFCs -- non-naturally occurring chemicals -- were ubiquitous in the environment (literally ubiquitous -- like in every ecosystem and in every living creature), I have always wondered why an environmental movement did not arise regarding their manufacture and use, like it had over DDT. It is like PFCs are the teflon chemical. ;)

I would find it difficult to be comfortable being in the flourocarbon business knowing that the products don't degrade (well, very slowly) and have now found their way into everything and everybody. We are all stockholders of Dupont and 3M in a sense.

But PFCs are in use everywhere in our society: in the fiber optic cables carrying the internet, in frying pans, and in the rain jackets the Sierra Club members wear on their hikes. PTFE is in bicycle chain lubricants and ski wax. It is the slippery slope.

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It doesn't really matter what Phil is saying, the music of his voice is the appropriate soundtrack for a bicycle race. HTupolev

These are especially slippery....

Haven't you previously argued here that environmental protection measures taken in the 70s and 80s did all that was necessary and that the Trump 'roll-backs' were/are perfectly fine? So I'm a bit confused about your stance (do we need more or less regulation?) and your attempt to take an apolitical stance on these issues (given your apparent big-business bias seen here previously). Or maybe I have you confused with someone else.

It's only hard for you.



And that's what she said.

I think the EPA has been out of control, overstepping their authority and negligent. The EPA has said the Obama regulations had no measurable effect on climate change and that it is a "enormously beneficial" symbolic act. In the link below you can watch Obama EPA chief Gina McCarthy Testify to Congress: 'The value of this rule is not measured in that way. (Temperature impact) It is measured in showing strong domestic action which can actually trigger global action to address what's a necessary action to protect...I'm not disagreeing that this action in and of itself will not make all the difference we need to address climate action, but what I'm saying is that if we don't take action domestically we will never get started and we'll never...' In short the EPA is trying to pass laws that will not impact the climate and will hurt our economy and each citizens wallet to demonstrate leadership. This kind of insanity can only exist inside the government.

https://www.youtube.com/watch?v=hkkeLpbz0-Y


Carbon emitting fuels account for 87% of American's energy needs and throughout history access to energy positively impacts economic growth. The idea that every business and individual is going to is going to cut back on energy consumption, or be charged more money, without an alternative in place to ludicrous. By restricting the production of carbon emitting fuels, without cost effective alternatives, will hurt the economy and each and every American citizen. Everything we buy is impacted by the cost of energy and business are not going to eat the increased cost they will simply increase prices. Making energy more expensive is not a solution to the problem and the EPA has no business taking control of America's electrical power infrastructure.


As far as negligence is concerned look into the Flint water crisis, the DC water crisis and the Gold King mine blowout. The smart kids at the EPA intentionally opened a abandoned mine which let loose 3 million gallons of toxic waste into rivers of Colorado, New Mexico, Utah and the Navajo Nation. Then the EPA claimed they cannot be sued for their negligence. Hopefully that is false or at a minimum the law is changed. The EPA has also gone on land and water grabs all over the nation. Essentially the EPA wants to control all water in the US and lord over all carbon dioxide emissions.

+1

You're being a little disingenuous, I feel. No-one expects to see measurable climate change effects within a single presidential administration. I haven't watched the video but from what you quoted it seems like the point she is making is that nations need to show some leadership on the issue of climate change and be willing to endure some cost towards making the planet cleaner. Is that such a terrible thing? As discussed in another thread, the state of South Australia has completely weaned itself off coal as a source of energy. Is it perfect? No. Does their electricity cost more? Absolutely. But your attitude of 'what's in it for me?' is the kind of attitude that will mean change only comes at a glacial pace (unlike the pace they're melting) and potentially too late. Of course, we'll only know in a couple of generations by which time we'll be dead, so I guess maybe you're right... fuck it.

The clip is short and I quoted the relevant statement. Like the Kyoto protocol and the Paris accords each climate change suggestion involves tons of money and has almost zero impact. We need both a greater understanding of humans impact on climate and new technology not taxes.

Sure there are flaws in Kyoto and Paris but doing something is better than nothing, and richer developed countries may have to carry a greater financial burden.

It's also pretty apparent that pumping millions of tonnes of CO2 into the atmosphere is not good for the future of the planet and its ecosystems, as well as all the other pollutants and destruction of the environment we humans create. Ergo, burning cleaner fuels and trying to reduce the impact of humans is net a good thing. Yes, technology will be a huge part of that process and until the technology allows us to produce renewable energy at a cheaper cost, it might cost us the consumer a little more. I'm ok with a little more. Even in some cases a lot more. Gasoline in the UK costs about 4 times what it costs in the US. That's mostly due to tax. It's too much IMO, but I also think gasoline tax in the US is ridiculously low. If it were higher there would be greater incentives to use public transportation, buy smaller, more fuel efficient cars, develop better battery technology etc etc

And while we can all try to do our little bits, through government policies is the most meaningful way all these things can change.

If we wait until we fully understand the effects of our impact on the planet (which could take another 100 years or more) it will likely be way too late to reverse much of the damage and it will certainly be too late for all the hundreds or even thousands of animal and plant species we've wiped out. But God forbid that our electricity or gas bills should go up 10%...

By their own admission or their data the government policies past and present have next to zero impact on climate change. The CPP would reduce temperatures 1/100th of a degree the Paris Accord if fully implemented would reduce temperatures 0.023 degrees by 2100. The idea that we need to do something incredibly expensive regardless of its impact or the world is going to end is incredibly short sighted at best.

Is The Donald your source? As the researchers cited in the article below assert, even if you keep warming at "tolerable" levels that is better than "dangerous." What you're saying, essentially, is that if the Paris Deal would only have a minor impact, it's not worth it. The problem with that (myopic) view is that, without the Paris Deal and continuing to allow emissions to rise, we are going to get to "dangerous" levels of warming. You're arguing that's better?

http://www.bbc.com/...environment-40135049

The President argued that even if the accord was fully implemented it would only have a "tiny, tiny" impact.
But researchers have told BBC News that the President was "cherry picking in the extreme" in his use of the facts. They say that the Paris deal could make the difference between tolerable and dangerous levels of warming.
While much of his statement on withdrawal was concerned with the negative economic impact of being part of the Paris agreement, the President also mentioned the negligible impact that the deal would have on temperatures.
"It is estimated it would only produce a two-tenths of one degree … Celsius reduction in global temperature by the year 2100," he said during his lengthy explanation.
"Tiny, tiny amount."
Climate researchers have immediately taken issue with the President's use of the data.
"This is cherry picking in the extreme," said Prof Niklas Höhne, who works with the Climate Action Tracker to monitor likely emissions levels.
"He picked the study that has the least impact of the Paris agreement on the global temperature increase."
The study on which this assertion was based was carried out by scientists at the Massachusetts Institute of Technology in 2014 and published in 2015.
Crucially the study didn't include all the commitments made by countries in the run up to the meeting in the French capital at the end of 2015 that agreed the wide-reaching Paris deal.
Another major question is that the study presumed that none of the actions proposed would continue past 2030.
"Their study assumes that countries implement their Paris pledges by 2030 but then move back to high emissions," said Prof Höhne.
"We think that is unrealistic because if the countries implement Paris they will likely continue with similar policies."
A subsequent investigation in 2016 by the same group at MIT suggests that up to one degree of warming could be averted if all the promises made in the Paris agreement were honoured. The authors believe that withdrawing from Paris is the wrong approach.
Their findings on how much difference Paris will make are echoed by the Climate Action Tracker researchers who found that 0.8 of a degree of warming could be avoided if countries stuck to their pledges. This difference could help prevent dangerous levels of warming for the whole planet.
"It is a considerable impact, and it is the first time since 2009 we see a considerable downward trend in temperatures because countries have made proposals for what they are going to do," said Prof Höhne.
"This, for me, is a really strong point of the Paris agreement."
How strongly the US pullout will impact future global temperatures is currently being assessed by scientists, including those at the World Meteorological Organisation (WMO).
"This is an additional 0.3 degrees on the warming, due to the withdrawal of the US," Deon Terblanche, the head of the WMO's Atmospheric Research and Environment Department, told a meeting in Geneva, stressing that this was an estimate and not a modelled result.
"That's a worst case scenario, and this is probably not what will happen."
Prof Niklas Höhne agrees that the full impact of the US pullout could be less than feared.
"President Trump wants to stop the Clean Power Plan, but it is very likely that some of the states will go even further and be more aggressive and we also hear there is pushback from many major companies that they want to go towards more renewables.
"In essence progressive states and companies could compensate for Trump."

You sound like sick patients who argue that they don't want to change their behavior because it will at best provide a status quo or a very slight improvement.
Ironically, this also happens a lot in clinical settings...If I'm going to do all this crap that's really hard or expensive, it'd better provide some real improvements stat, otherwise I'd rather just die.
Sigh.

Showing leadership doesn't mean forcing those costs onto the citizens.

Showing leadership would mean no more private jets.

Showing leadership would be Al Gore living in a tiny house.

Showing leadership would be no more drivers and SUVs for legislators.

If those touting changes in lifestyles would actually make some of their own. Their words wouldn't sound as hollow.

And you sound like someone who's more concerned with the cure than the consequences. Think about that for a moment at the human level.

The irony of that comment...

It's ironic in what way? That you can't connect cure at all costs to quality of life? You're right, extremely ironic and cruel. While you're right about excessive expectations it's also reasonable to take quality of life into consideration.

Because I provided an analogy. Which is obviously not entirely comparable.
There are plenty of patients who go one smoking during chemo. There are plenty of patients who go on drinking while having liver issues. And on and on and on.

You seem to believe that my post was meant to say screw patients and their well being (which given what my research is about is rather funny). But then it’s the lavender room. My fault for expecting anything from this place.

Do you really think it's worth spending trillions of dollars on the Paris Accords when by their own admission it was have no discernible effect on global temperatures? The juice isn't worth the squeeze.

There have been some constructive comments elsewhere in this thread but I just wanted to point something out: at this point, short of a massive direct subsidy, nothing can save coal in the U.S. New coal cannot compete with new natural gas in most power markets and it's basically impossible to finance a new CFPP in the U.S. What will be interesting, to me, is what the future backbone of baseload generation will be in twenty years. Gas won't be cheap forever.

Nuclear: The regulatory and logistical burdens for building a new LWR/BWR nuclear power plant in the U.S. (and most developed nations frankly) are so monumental that I doubt they'll ever make a comeback. That said, there's a lot of promising alternative reactor designs out there. India has a pressurized heavy water reactor designed to run on thorium that has a lot of potential. Maybe GE will finally sack up and build a PRISM reactor or perhaps some other conglomerate will take on the task of commercializing the LFTR. In the more distant future we might see some sort of a fission direct energy conversion reactor.

Solar: PV solar will never provide baseload generation but CST could in the southwest. Unfortunately, Ivanpah was absolutely botched so it will be a while before utilities are willing to touch that technology again.

Wind: will never be able to provide baseload generation and will likely never contribute more than 10% to the NA grid.

Geothermal: viable for baseload but costs in the U.S. are much higher than what the economy is accustomed to.

<pink>I wonder if we are already at peak natural gas</pink>

Your analogy sucks first of all and 2ndly I've read enough of your posts to know that you have difficulty connecting patients mental health to their current situation. IE. "I've got cancer now, so why should I give a fuck?"

It's actually a problem I understand very well, and a problem that remains a head scratcher for many.
Roughly half the smokers who get diagnosed with lung cancer report quitting.
https://www.ncbi.nlm.nih.gov/...articles/PMC2684817/

You can say whatever the hell you want about what you think of me, and what you think you know about mental health during cancer.
I really don't care. Cancer is just one example. There are many other examples in healthcare where patient's behavior would yield much better
clinical outcomes, yet patients don't change their behavior. Obesity and type 2 comes to mind.

That certainly does not mean that all or even close to a majority of patients think 'I have cancer screw it, I'll do what I want'. Changing behavior is very difficult, even under critical clinical conditions. But it's still a behavior that is observed in some patients, and a non negligible rate.

As for my analogy sucking. Yes possibly. Very probably actually since clearly, it has totally missed the mark, as far as you are concerned.

You can also use head injuries and American football.

Another note.
It is sad that in a country with many of the world's best universities, it is not fashionable for some to be scientific ignorant. We have anti vaccine, anti evolution to anti physics (climate deniers).

I had to laugh when someone posted a video of Lamar Smith. Lamar is a christian scientist, that means he is e science denier. He has a science understanding of a 3 year old.

Thank you for that interesting analysis. But I am a bit skeptical. Everything you say sounds rational and informed; however, I wonder how a man can be so informed about golf, tri-bikes, and energy. ;)

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It doesn't really matter what Phil is saying, the music of his voice is the appropriate soundtrack for a bicycle race. HTupolev

Actually, I'm curious (since you seem to know a lot about energy) what your take is on nuclear.
France draws over 76% of its electricity from it, largely a consequence of the "Plan Messmer" in the early 70s.
It's allowed us to get electricity for cheap, and I think France still exports a lot of its production.
Now, I have no idea how expensive it is, the pros and cons, and knowing my birth country, I can't imagine any of
this NOT crawling under intense regulations.

I guess you're missing the point. The alternative ... not changing anything ... will see temperatures continue to rise to "dangerous" levels. So Yes, spending money and changing direction on fossil fuels - even if it means global temperatures remain the same - is a lot better than doing nothing.

The Paris agreement also set the stage for further agreements and cooperation between developing and first world nations to reduce emissions. Trump has done serious damage to that longer term process.

Nuclear has absolutely enormous potential that is suffocated by regulation. In the case of France, the near-entirety of its fleet consists of second generation light water reactors. They're perfectly safe but many of them are nearing the end of their service lives. To replace them with modern LWRs/PWRs/BWRs would probably double the cost of electricity in France. Why is this? Simply put, a Gen 3/4 LWR uses nearly 10x the raw material as a Gen 2 LWR largely owing to what's known as a "core catcher" along with absolutely absurd emergency cooling tanks that are operated by gravity in the event of an emergency. Also, every single step of building a modern LWR requires intense oversight from engineers. Every nut and every friggin bolt is inspected. Every single power plant may as well be a bespoke unit even though there are many standardized and approved designs out there.

What's needed to turn the tide for nuclear are Small Modular Reactors (SMRs) that are factory built and fueled and then shipped to site for installation. LWRs aren't terribly cost effective if they're shrunken down for a variety of physics driven reasons so an entirely different design must be pursued. Ideally the reactor would run much hotter and thus have a higher power density. Theoretical designs for such a reactor have abounded since the sixties but the problem is nobody has been willing to bear the cost of validating such a reactor. You have to keep in mind that LWRs and BWRs were basically validated by the U.S. Navy. The cost of validating a new reactor design for civilian nuclear power is incredibly high.

Edit to add: a high temperature SMR coupled with a super-critical CO2 turbine has the potential to compete with natural gas in NA which is to say it would be quite cheap. There's a precedent for a CO2 cooled reactor in the British AGR though I'm not up to speed wether or not anyone has proposed scaling this down to an SMR.

IMO, in another severe economic downturn a wise expenditure of public funds in any western country would be to fund the construction of SMRs for installation on large military bases.

Don't forget the MS in Economics. Also, I could function as a MOS 91F tomorrow with hardly any additional training ;) In short, I've led an interesting and incredibly random life thus far.

I guess the latter point being to mitigate potential risks of a terrorist attack.
If on a military base, I guess no need to add an incredible amount of regulations (besides those already implemented on MBs) ?

In the U.S, a nuclear power plant owned by a branch of the armed services and installed on a military base or vessel would not be subject to NRC regulations or oversight ;)

Why couldn't the same reactors used on subs and aircraft carriers be used commercially. Seems like they would be your small, factory built reactor, that could be delivered and installed easily.

Eh... it's not quite that straight forward. First, you have to understand that nuclear reactors built for submarines don't really have to worry about emergency cooling systems because they're surrounded by the ultimate heat sink: the ocean. Second, power output sort of scales with volume and certain fixed costs (for example: security but also many others including control systems which are going to be expensive regardless of scale) favor larger reactors. In short, it's complicated. See this presentation but page eight in particular.

My gut take on the sector is that *if* nuclear makes a comeback it will be driven by some sort of small modular molten salt reactor cooled by CO2 directly powering a supercritical CO2 turbine but such a design is not without significant issues of its own. More advanced direct energy conversion designs are many decades away for civilian applications though they would have the power and energy densities you'd normally only see in science fiction.

According to which model? To say they have struggled to accurately predict the future is a massive understatement. I do not think the ready, fire, aim approach is wise when we are talking bout trillions of dollars and thousands of lost jobs.

Clearly your mind is made up but I doubt very much you have taken the time to read much of the respected science on the topic.

Whats the deal with the replacement plant in uk? That will be first new next gen plant here.

I think qatar has several hundred years of gas. Super size LNG tankers have been getting bigger. Why would gas prices rise? Qatar can build another train and bring it on line.

Arent most Nuclear plants PPP deals so financed from private sector over multiple decades?

I don't necessarily disagree, but feel compelled to say "Yeah, we tried that".

https://en.wikipedia.org/wiki/Army_Nuclear_Power_Program


I drive past an entombed SM1A on a regular basis.

I haven't followed what's going on in the UK but if I had to guess significant budget overruns are involved.

Regarding natural gas, I'd like to quote the great Yogi Berra: "things tend to work until they don't." The whole world is investing in natural gas fired electrical production. Gas is cheap and plentiful for now but the geological formations we're drilling now are subject to the same rules as everything we've drilled in the past: the low sweet spots of fields are drilled first and as time goes on the gas cap grows smaller. Reservoir pressures drop. Production declines. There might be a ton of gas in the ground but it might take 2x the number of rigs to meet a certain daily production ten years from now than it does today. Maybe 4x or 10x in 20 years. If the entire world acts like gas will be cheap and abundant forever, you can be assured that it will become scarce.

Right, but at no point in the time period was massive Keynesian stimulus in the forefront of policy maker's minds. In fact, the U.S. was shuttling along on one of the largest influxes of government stimulus in history (WW2). There will come a time in the not so distant future where policy makers will have to come up with stimulative projects they can sell to the public. SMRs for DOD facilities would be an easy sell IMO.

Frankly, I get a little nervous when you speak of economic stimulus and nuclear power. I would rather reactors be built carefuly and methodically rather than throwing money at the problem. I live within 25 miles of four coal-fired power plants; two at major DoD facilities. The local populace is rabidly pro-DoD; yet I'm not sure they would support SMRs. Maybe if you gave them unmetered electricity!

I think any place that has an INES 5 or higher would get nervous. 3 Mile Island was level 5, and it certainly left many in the US nervous about nuclear energy.
France has a huge nuclear program for the size of the country and population, and despite a couple of incidents, never got anything higher than 4, and that was in 1980.

I think this would be an interesting chart if it compared dollars to the number of joules of produced.

Recent ATSDR Report may get things moving. I haven't gotten into the numbers at all nor have any idea how these new thresholds correspond to levels in Public Water Supplies.

Poorly written ABC News story.

If the administration tried to block this report from ATSDR, that is a disgrace.

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It doesn't really matter what Phil is saying, the music of his voice is the appropriate soundtrack for a bicycle race. HTupolev

This whole rollout has been badly botched, and there's going to be a shitstorm. But if I had been part of the White House I might well have tried to delay or manage the rollout, too. And I am not one to miss an opportunity to bash this White House. Let me explain ...

The issue is that the ATSDR toxicity profile is suggesting that several of the PFAS (PFOS, PFOA, PFHxS, and PFNA) are far more toxic than previously believed. Using PFOS as an example, if their suggestions are incorporated into an updated EPA Health Advisory level for drinking water, the HA would be lower by a factor of ten for PFOS - it would go from 70 ppt to 7 ppt. To give you an idea how low 7 parts per trillion is, even as recently as 2015 the top commercial laboratories would have struggled to meet 7 ppt as a detection limit.

So, (you ask, as I did) what is the basis for this ten-fold increase in the supposed toxicity of PFOS? You will probably imagine (as I did) that there were new studies, or a more careful analysis, or some other substantive increase in our knowledge of PFOS toxicology. You would be wrong (me too).

The new report uses a 2005 study (delayed ossification of rat phalanges) as the basis for the new MRL (Minimum Risk Level) for PFOS. This single study, and most of the other assumptions are exactly the same as those in the 2016 EPA Health Effects document for PFOS.

The only difference (the only goddamn difference), is that they add an additional uncertainty factor of 10, to allow for the supposition that "immunological endpoints may be more sensitive than developmental endpoints." (I may have the quote a little bit wrong, I'm going from memory.)

Now, I'm not a toxicologist, but I dabble, and this is the first time I've ever seen an uncertainty factor like this. It's bizarre, and I have to wonder if it was politically motivated. The assumptions and uncertainty factors in this document are literally an order of magnitude more conservative than most other similar tox profiles.

So I can appreciate the bewilderment on the part of the EPA, DoD, and the White House. And maybe these issues should have been worked out before the release of the report. But the White House completely botched things by doing things like writing emails that referred to a potential "public relations nightmare". Yeah, no shit, you didn't think that would get leaked?

Now that the report is out, there is a formal public comment period. The peer review for the report was done by four academics. Now the industry toxicologists and DoD policymakers will have their crack at it. It should prove interesting!

What would be the political motivation to make it *more* conservative? I assume some kind of environmental lobby?

Wow. Such an informative and well crafted explanation. Thanks for that. I really enjoyed reading that. I once dabbled in toxicology as my career was in environmental regulation. Long time ago now and I don't really follow it anymore.

I'd guess that the immunological uncertainty factor has to date back to the Obama administration. Not saying that it was improperly political or anything, but that just sets the landscape. Trump administration was going to look bad countermanding anything that looks like hard science and probably more so since it originated in prior "environmentally friendly" administration. Providing that there is no reasoned science supporting the uncertainty factor, then it should not stand -- or the next thing will be a suit from NRDC asking for application of the uncertainty factor to a whole range of chemicals.

Aside from the stupid email, seems that the administration may have played this right. Even if they had good reason to quash the study, they would come under attack when it came out that they did so. So, let the study go to public comment, create a record of comments opposed to the uncertainty factor, then revise the study.

Oh, and regarding ppt, I'm old enough to remember my surprise, saying something like, "What? We're going to ppb now?"


Toxicologists are in a tough spot. They have a desire to apply a precautionary principle type of thinking to ensure that they might not be hurting people. Could be that a few just got a little loose and injected their own desire for an extra safety factor.

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It doesn't really matter what Phil is saying, the music of his voice is the appropriate soundtrack for a bicycle race. HTupolev

Yes. There's a fairly strong environmental movement growing around PFAS. Groups like EWG have been pushing for single-digit action levels for PFAS in drinking water for several years. To be clear, I don't necessarily oppose that, if it's technically feasible at reasonable expense. But the scientific data currently available don't really support such drastic action.

To be fair to the authors and reviewers of the PFAS tox profile, I should point out that adding additional uncertainty factors is not necessarily a political act. For one thing, some toxicologist are by nature more cautious than others. The uncertainty factors included in all these evaluations are somewhat subjective and the judgment of experts will vary. For another thing, MRLs (Minimum Risk Levels) as developed by ATSDR are not the same thing as a "safe" level - an MRL is a level at which the experts feel there is minimal risk, but does not imply that a higher level is necessarily unsafe.

However, when the public sees a published MRL it is perceived as a number which, if exceeded, is unsafe. That's partially due to lack of understanding, and partially due to human nature and "anchoring". And the science behind the MRLs ends up feeding into MCLs, RSLs, CULs, and the rest of the acronym soup of action levels for various purposes.

Good background on MRLs here: https://www.atsdr.cdc.gov/...isklevels/index.html

And EWG has a decent article here including a map of PFAS sites: https://www.ewg.org/...xpanding-pfas-crisis

There is a bit of irony in what you and GP are discussing:

https://www.cbc.ca/...al-imaging-1.4714130

IIRC C River used to produce 50% of the worlds medical isotopes.

Side note my brother was an electrician at Darlington, in the 80’s the largest construction project on the planet.

Maurice

Indeed! If you look through lists of Maximum Contaminant Levels for drinking water there are very few MCLs below 1 ppb.
http://www.health.state.mn.us/...ctsheet/com/ioc.html
http://www.health.state.mn.us/...eet/com/voc_soc.html

In fact, except for dioxins there are no MCLs at all below 0.2 ppb (200 ppt)


Yes, please see my reply to trail where I tried to be a little more generous to toxicologists.