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Directives would harm public health, disproportionately affecting women and children
Over forty citizen’s sector organizations including the national nonprofit Physicians for Social Responsibility have sent a joint letter to federal officials warning of public health consequences of a series of executive orders by President Trump which direct the NRC to dramatically weaken Standards for Protection Against Radiation in the US federal code. The letter points out sharply disproportionate impacts on women and children from weakening existing radiation exposure standards and calls for strengthening them.
The letter is posted here. It was spearheaded by the nonprofit Generational Radiation Impact Project (GRIP) and Beyond Nuclear. and sent to US Nuclear Regulatory Commissioners, Health and Human Services Secretary Robert F. Kennedy Jr., Surgeon General Denise Hinton, and other key elected and appointed officials.
Recent Trump executive orders direct the NRC to “reconsider” the linear no-threshold (LNT) model. The joint letter argues that this “would undermine public trust by falsely claiming that the NRC’s radiation risk models lack scientific basis, despite decades of peer-reviewed evidence and international consensus.” The widely accepted LNT model has no limit “below regulatory concern,” i.e. no level below which radiation exposure can be treated as negligible or zero-risk. Where applied, LNT takes account of proportional cancer and health risks of all tiny exposures no matter how small.
Trump executive orders direct the NRC to undertake new rulemaking and “wholesale revision” of existing radiation regulations, which would likely lead to the NRC abandoning LNT and raising allowable exposure limits.
A July 2025 Idaho National Laboratory report commissioned by the Department of Energy recommended loosening the public radiation standard fivefold to 500 millirems. In 2021 the NRC roundly rejected a petition to raise allowable radiation exposures for all Americans, including children and pregnant women, to 10 Rems a year, 100 times the current limit.
But past NRC opposition to such changes stands to be reversed by the Trump executive orders. If federal radiation regulations were weakened to permit exposures of 10 Rems a year, scientists estimate that over a 70-year lifetime, four out of five people would develop cancer they would not otherwise get.
Today’s joint letter stresses that health damage would not be evenly distributed across the population, but would disproportionately affect women and children, who are biologically more susceptible to ionizing radiation than men. And an article published today in the Bulletin of Atomic Scientists cites several lines of evidence “that women and young girls are significantly more vulnerable to radiation harm than men—in some cases by as much as a ten-fold difference” and that “infants are especially vulnerable to radiation harm.”
“[NRC] bases its risk assessments on Reference Man, a model that represents a young adult male and fails to reflect the greater impacts to infants, children, and women—pregnant or not,” the joint letter states. “Newer research has shown that external radiation harms children more than adults and female bodies more than male bodies. Research on internal exposures…has not yet been sufficiently analyzed to discover if there are broad age-based or male/female differences in impact…. Existing standards should therefore be strengthened to account for these life-stage and gender disparities…not weakened. Radiation causes infertility, loss of pregnancy, birth complications and defects, as well as solid tumor cancer, leukemia, non-cancer outcomes including cardiovascular disease, increased incidence of autoimmune disease and ongoing new findings.”
In cases where cancer, heart disease, and vascular degradation including stroke are caused by radiation, they are documented at higher rates in women than in men, according to 2024 UNIDIR report Gender and Ionizing Radiation.
The joint letter urges the NRC to “to stand up to the Executive Order’s marching orders to ‘promote’ nuclear power—a mission outside its legal regulatory mandate,” and adopt “stronger, science-based radiation protections….Contemporary research shows that radiation’s impact is far greater on females, children, and fetuses—the most at-risk postnatal group being girls from birth to age five. A truly protective framework would replace Reference Man with a lifecycle model.”
"All US radiation regulations and most radiation risk assessments are based on outcomes for the Reference Man,” said Mary Olson, CEO of GRIP, the organization which spearheaded the joint letter, and co-author of Gender and Ionizing Radiation. “Young men like the Reference Man are harmed by radiation, but they’re more resistant to harm than are women and children. Radiation causes cancer in women at twice the rate of adult men, while the same exposure in early childhood, will, across their lifetimes, produce seven times more cancer in young females, and four times more in young males."
"We know that exposure to radiation causes disproportionate harm from both cancer and non-cancer related disease outcomes over the course of the lifetime to women and especially to little girls, but radiation is dangerous for everyone,” said Amanda M. Nichols, Ph.D., lead author of Gender and Ionizing Radiation. “[President Trump’s] executive order will allow the industry to relax the current standards for radiological protection, which are already far from adequate. This will have detrimental health consequences for humans and for our shared environments and puts us all at higher risk for negative health consequences. "
"Living near nuclear power facilities doubles the risk of leukemia in children; and radiation is also associated with numerous reproductive harms including infertility, stillbirths and birth defects.,” said Cindy Folkers, Radiation and Health Hazard Specialist with the NGO Beyond Nuclear, a signatory to the joint letter. “Exposing people to more radiation, as this order would do if implemented, would be tantamount to legitimizing their suffering as the price of nuclear expansion."
Coalition decries NRC allowing Holtec to break the law, by rushing ahead with sleeving of dangerously degraded steam generator tubes without agency authorization
In a stunning admission critics are calling the “Friday Night Massacre,” the U.S. Nuclear Regulatory Commission (NRC) Staff acknowledged that it was watching, but had done nothing to stop, Holtec International, as it violated the regulatory conditions of its license at the Palisades atomic reactor.
Late Friday night, July 18, NRC Staff posted a report suggesting that Holtec was already actively performing its proposed steam generator tube sleeving repairs without agency approval.
“The NRC is not an Elliot Ness tough cop regulator. Instead, the 'Friday Night Massacre' at Palisades shows NRC and Holtec are more like Ness joining in with Al Capone on the St. Valentine's Day Massacre,” said nuclear engineer Arnie Gundersen, the environmental coalition’s expert witness on nuclear safety issues, such as the dangerously degraded steam generators.
The smoking gun NRC document, entitled “PALISADES NUCLEAR PLANT – RESTART INSPECTION REPORT,” dated July 17, 2025, stated, in relevant part on Page 5 (Page 8 of 17 on the PDF counter):
“…The inspectors verified that the following NDE [Non-Destructive Examination] and repair/replacement activities were conducted appropriately per the ASME [American Society of Mechanical Engineers] Code or required standard, and that any potential indications and defects were identified and evaluated at the proper thresholds:…
…Steam Generator Tube Inspection Activities (IP Section 03.04)
Steam generator ‘A’ tube sleeving and eddy current testing…”
“If the existing ‘defueled’ Technical Specifications are in effect, Holtec cannot do any sleeving. Sleeving requires a Tech Spec change. So if Holtec has already sleeved, then they violated the current Tech Specs,” said Gundersen. “Holtec may claim that they did it at their own risk, but last I looked, you can’t break the law anticipating the law might change in the future. And the NRC tacitly acknowledges they knew the law was being broken,” Gundersen added.
"Of course, Holtec is not only proceeding at its own risk, but is putting the Great Lakes State, and the entire Great Lakes Basin, at existential risk, of a Chornobyl- or Fukushima-level radioactive catastrophe," said Kevin Kamps, radioactive waste specialist at Beyond Nuclear, based in Kalamazoo, Michigan.
“It appears that Holtec could well already be rushing ahead with the sleeving of dangerously degraded steam generator tubes, even though our legal challenge against the adequacy of that proposed band-aid fix is still underway at the NRC licensing board,” said Wally Taylor, an attorney based in Cedar Rapids, Iowa representing the coalition.
“If Holtec is indeed already sleeving damaged steam generator tubes, this means the Atomic Safety and Licensing Board proceedings have been turned into a farce by NRC Staff’s complicity in the regulatory violations,” said Terry Lodge, an attorney based in Toledo, Ohio representing the coalition. “Holtec decides what to do, and when, while NRC maintains the mere illusion of regulation, and with a wink and nod, allows Holtec to proceed, in secret, despite our coalition’s official legal intervention opposing these dangerous shortcuts on safety,” Lodge added.
“Did NRC wait to publish the Palisades restart inspection report late on a Friday night, while we were busy meeting an entirely related deadline, hoping we would have less chance of noticing it?” asked Taylor.
Gundersen has previously testified in written declarations that the already degraded steam generators, in need of replacement for two decades, were made significantly worse by Holtec’s “rookie error” of neglecting to implement critical safety maintenance — wet layup — from 2022 to 2024, allowing corrosive chemical attack both inside and outside the exceedingly thin-walled steam generator tubes. Gundersen has also warned that a cascading failure of steam generator tubes could result in a reactor core meltdown, and catastrophic release of hazardous radioactivity into the environment.
Ironically, the coalition’s legal counsel were, at that very moment late Friday night, rebutting attacks on the coalition’s petition to intervene and request for hearings, regarding Holtec’s License Amendment Request (LAR) to the NRC, for permission to merely sleeve dangerously degraded steam generator tubes, rather than replace the steam generators in their entirety. The coalition had petitioned to intervene and requested a hearing on June 16, 2025. NRC Staff and Holtec then filed Answers, challenging the coalition’s petition and request. The coalition had until 11:59pm Eastern Time on Friday, July 18 to file its Reply to the Answers. The coalition met the deadline, defending its concerns regarding potentially dangerous operations to commence, potentially in the very near future, from using questionable repairs on its old, degraded steam generators, if NRC approves Holtec’s scheme.
The environmental coalition legally intervening against Holtec’s unprecedented, unneeded, exorbitantly expensive for the public, and extremely high risk for health, safety, and the environment, Palisades restart scheme includes: Beyond Nuclear, Don’t Waste Michigan, Michigan Safe Energy Future, Nuclear Energy Information Service of Chicago, and Three Mile Island Alert of Pennsylvania.
Deadly scenarios threatened could not happen at renewable energy site
Amidst accusations from both the Russian and Ukrainian sides that the Zaporizhzhia nuclear power plant in southeastern Ukraine has been wired for detonation or could be deliberately attacked during the current war there, one absolute truth remains: nuclear power plants are inherently dangerous.
In a time of national crises in multiple countries, increasing natural disasters and a worsening climate emergency, nuclear power is demonstrating that it is a liability rather than an asset.
Each nuclear reactor contains a lethal radioactive inventory, in the reactor core and also in the fuel pools into which the irradiated fuel is offloaded and, over time, densely packed. Casks also house nuclear waste offloaded from the fuel pools. Zaporizhzhia is the largest nuclear power plant in Europe with at least 2,204 tons of highly radioactive waste within the reactors and the irradiated fuel pools.
Depending on the severity of what transpires, any or all of this radioactive fuel could be ignited.
Amidst the unpredictability caused by the “fog of war", there remain many unanswered questions that have led to rumor and speculation:
Has the Zaporizhzhia nuclear plant in fact been wired for detonation and whose interests would be served by blowing up the plant?
Why is there an exodus of both Russian and Ukrainian plant personnel?
Will the sabotage of the downstream Kakhovka dam that resulted in catastrophic flooding, also lead to an equally catastrophic loss of available cooling water supplies for the reactors and fuel pools?
Will the backup diesel generators, frequently turned to for powering the essential cooling each time the plant has lost connection to the electricity grid, last through each crisis, given their fuel must also be replenished, potentially not possible under war conditions?
None of these threats would make headlines if Zaporizhzhia was instead home to a wind farm or utility scale solar array. This perhaps explains the rush now to downplay the gravity of the situation, with claims in the press that a major attack on the plant would “not be as bad as Chornobyl” and that radioactive releases would be minimal and barely travel beyond the fence line.
This is an irresponsible dismissal of the real dangers.
After the massive explosion at Chornobyl, the graphite moderator used in the reactor fueled the fire, with the smoke further lofting radioactive fallout far and wide. This has led to an assumption that major fires and explosions at Zaporizhzhia would result in less serious consequences since the reactor designs are not the same as Chornobyl’s.
However, if the uranium fuel in the Zaporizhzhia reactors or irradiated fuel storage pools overheats and ignites, it could then heat up the zirconium cladding around it, which would ignite and burn fiercely as a flare at temperatures too hot to extinguish with water. The resulting chemical reaction would also generate an explosive environment. The heat of the release and detonation(s) could breach concrete structures, then loft radioactive gas and fallout into the environment to travel on the weather.
Fallout could contaminate crucial agricultural land, potentially indefinitely, and would include Russia, should prevailing winds travel eastward at the time of the disaster.
And while Europe allows an already too high 600 becquerels per kilogram (Bq/kg) of radioactive cesium in food, contaminated food supplies from Ukraine that read at higher levels after a nuclear disaster could be exported to countries with even weaker standards, including the US where the limit is an unacceptable 1200 Bq/kg. But will those consuming such foodstuffs be counted among the victims of such a nuclear disaster?
The true numbers of those harmed by the Chornobyl disaster will never be known due to institutional suppression and misrepresentation of the numbers and the absence of record-keeping in the former Soviet countries affected. Therefore, to describe a major nuclear disaster at Zaporizhzhia either as “worse than” or “not nearly as bad as” Chornobyl is too broad and speculative without looking at the specifics.
Those specifics depend on whether the disaster involves hydrogen explosions such as happened at Fukushima, or fires resulting from a bombing raid or missile attack, which could disperse more radioactivity further. It would also depend on whether all six reactors suffered catastrophic failures, whether all of the fuel pools were drained and caught fire and whether the storage casks were breached.
It would further depend on which way the wind was blowing, and if, when and where it subsequently rained out a radioactive plume, all factors that influenced where the Chornobyl radioactive fallout was deposited.
If Zaporizhzhia comes to harm, each side in the conflict will likely hold the other responsible. But ultimately, the responsibility we all share is to reject the continued use of a technology that has the potential to wreak such disastrous consequences on humanity.
Zaporizhzhia is in the news now almost every day. The propaganda may be deliberately alarmist, but the basis for the alarm is very real or it would not be the subject matter for headline-getting in the first place.
The reason is simple. Nuclear power is the most dangerous way to boil water. It is unnecessary, expensive, and an obstacle to renewable energy development. It is intrinsically tied to the desire for — and development of —nuclear weapons, the use of which could be the other lethal outcome in this war.
It is time to see sense. Calling for a no-fire zone around Zaporizhzhia is not enough. We must call for no nuclear power at all.
While IAEA Pushes to Secure Ukraine’s Beleaguered Zaporizhzhia Nuclear Plant, US Nuclear Plants Remain at Risk, Warns Sign-on Letter
Yesterday the White House received a letter signed by some 90 NGOs plus over 70 individuals and counting telling President Biden that “nuclear plant security must begin at home.” The sign-on letter was spearheaded by the Nuclear Energy Information Service (NEIS).
While the US has expressed its concern that Ukraine’s Zaporizhzhia Nuclear Power Plant (ZNPP) is under threat of attack and Congress has authorized federal spending to help with ZNPP security issues, US civilian nuclear power plants remain vulnerable to attack at home, and government spending and regulation to make them harder targets is lagging badly.
ZNPP, Europe’s largest nuclear plant, is currently occupied by over 2500 Russian troops. It has been repeatedly shelled, cutting the plant off from the electrical grid seven times, raising concerns about cooling loss and meltdown risks. Each side in the conflict accuses the other of using these risks to gain advantage in the war. The International Atomic Energy Agency is currently pushing for an agreement to secure ZNPP before a renewed Ukrainian offensive in the area aggravates risks to the plant.
But meanwhile, the letter to President Biden points out, security threats to US nuclear power plants remain underrecognized and inadequately addressed.
“The security of U.S. nuclear power plants does not seem to be receiving a commensurate amount of attention, neither from the U.S. Nuclear Regulatory Commission (NRC), nor the Administration,” the letter warns. “Worse, your Administration is also seeking to expand the nuclear industry in dangerous ways that compound nuclear plant security threats…The US government must learn the lesson of Zaporizhzhia -- that attacks on nuclear facilities and other external dangers they face are credible threats and could happen here -- and prioritize domestic US nuclear plant security accordingly.”
Documentation submitted with the letter cites studies that find US civilian nuclear power plants are insufficiently protected from credible terrorist threats, and highly vulnerable to cyberattack. Security decisions are left up to the plant’s owners, which have an incentive to cut costs and maximize profits. In addition to attacks on operating or decommissioned plants themselves, the highly radioactive nuclear waste they generate is also vulnerable to attack, both in storage facilities and during transport. Nuclear waste transport dangers were pointed out in writing repeatedly to Transportation Secretary Buttigieg, but as yet DOT hasn’t issued a reply.
“The recent catastrophic train derailment in East Palestine, Ohio, and the crash of two Boeing 737MAX jets demonstrate the real-world consequences of inadequate or capriciously enforced safety regulation and oversight,” the letter argues. “We can’t add radiological releases from US nuclear plants or nuclear waste shipment and storage to this list.”
The letter writers submitted a list of recommendations to improve US nuclear plant security, including framing and enforcing enhanced, mandatory security measures for existing nuclear facilities and spent nuclear fuel, with costs borne by nuclear plant owners rather than US taxpayers. Other recommendations include Hardened Onsite Storage (HOSS) for highly irradiated “spent” nuclear fuel (SNF), and preventing proposed SNF shipments by truck, train, and barge across the country to two recently licensed consolidated interim storage facilities (CISFs) in Texas and New Mexico, which would concentrate radioactivity and themselves be potential terrorist targets.
The proposed New Mexico CISF is owned by the private US-based company Holtec International, which formerly contracted to handle spent fuel management at ZNPP, and recently signed a contract with Ukraine’s Energoatom to develop and deploy small modular nuclear reactors in Ukraine.
“Holtec’s performance in handling spent fuel has been abysmal in Ukraine and similarly abysmal in the United States,” said Kevin Kamps, Radioactive Waste Specialist with the national NGO Beyond Nuclear, which signed onto the letter. “That’s one illustration among others that the problem is not limited to Ukraine, and that US nuclear plants are subject to security threats we need to start addressing.”
“What sense does it make to send tens of millions of dollars to Ukraine to enhance security and safety, when our own 92 operating reactors and 90,000 tons of high-level radioactive wastes are not secure?” asked NEIS director Dave Kraft. “What sense does it make to sprinkle the next-generation micro- and mini- nuke reactors around the nation and the world, boasting they can be mobile on flat-bed trucks or housed in factories or Wal-Marts, when it is daily demonstrated that silent drones are capable of turning heavily armored tanks and military vehicles into shredded heaps of burning metal? This is the real world nuclear power now exists in, and this Administration is not prepared to provide the safety and security necessary for it to survive.”