The first installment of this series, Inconvenient Low Dose Radiation Science Axed Under Obama Administration, described actions taken by Department of Energy (DOE) managers to ensure that the Low Dose Radiation Research Program that they had eliminated from their budget remained dead.

They planned to prevent information about the program’s successes and future opportunities from reaching the House and Senate staffers who were working on legislation designed to require funding the program. When the scientist who was managing the program departed from the planned script, they retaliated by separating her from her position and then separating her from federal service.

Not mentioned in the first installment, but addressed in the House Science, Space and Technology committee report on the way that Dr. Noelle Metting, the LDRRP Program Manager, was treated, DOE managers have also kept Dr. Metting away from the office that she occupied and have prevented her from retrieving both personal items and hard copy notes and papers related to her program’s accumulating results.

Also not mentioned in the first installment is the unstable document management system Dr. Todd Anderson, as the designated LDRRP Program Manager following the forced departure of Dr. Metting, chose to use to archive the program records.

Instead of maintaining the existing document organization on a federally controlled server, the program’s official website is an incomplete mirror hosted on Archive.org, a non-profit private organization whose site is also known as the Wayback Machine.

DOE Office Of Science Budget Priorities

According to publicly available documents and statements, the managers in the DOE Office of Science state that the LDRRP was a productive research effort that received “over a quarter of a billion dollars” during a period starting in 1998 and ending in 2016. They do not explicitly state why other programs were found to be of such high priority that they needed to be funded with the money originally allocated to the LDRRP.

As part of the HSST hearing conducted on Sep 21, 2016, Dr. Sharlene Weatherwax provided written testimony that describes the kinds of research conducted by the DOE Biological and Environmental Research (BER) program and the processes by which potential research areas are identified and prioritized.

Her testimony describes the importance of the BER program to the nation’s biofuel program and mentions some of the advances that have been made in genetic engineering and genome sequencing as a result of science derived from the human genome project completed in 2003.

Dr. Weatherwax’s prepared testimony then describes some of the accomplishments of the LDRRP.

Over the past 18 years the program has provided new technological advances and fundamental scientific understanding of the mechanisms cells use to sense, repair and adapt to the impacts of low dose radiation. Research investigations have included a number of critical biological phenomena induced by low dose exposure including adaptive responses, bystander effects, genomic instability, and genetic susceptibility. The program has supported the development of systems genetic strategies, including the role of epigenetics in integrated gene function and response of biological systems to environmental conditions, with a goal of translating molecular scale effects of low dose radiation to whole model organisms. The program outcomes and data are available to the community and other interested agencies through peer-reviewed scientific publications

Those words beg the question, “How did the Office of Science conclude that this productive, well-managed program needed to be eliminated?”

Retirement Of Primary Congressional Sponsor

One contributing factor was that Senator Pete Domenici, the strong Congressional champion for the program, retired in January 2009. Apprently, Sen. Domenici left office without finding someone to take over his role as champion of this small, but important research project.

Unlike Congressional earmarks that direct funds to a specific project of interest to constituents, Sen. Domenici had a keen interest in nuclear energy as an issue of national importance. His replacement as a Senator from New Mexico would not necessarily be the right person to receive the turnover on the importance of sustaining the LDRRP. It’s probably that Domenici wanted the program to continue as long as it was finding evidence that reduced uncertainties in an area area of inquiry that has been the subject of intense discussion for more than 60 years.

Almost immediately after it became apparent to budget decision makers in the Office of Science that there was no longer a Congressional protector for the LDRRP, they determined they had better uses for the $20-$25 million/year being invested in the program.

Of course, the timing could be purely coincidental.

Support Inside Of DOE

Documents discovered and published by the HSST investigation prove that there were people in leadership roles within the DOE outside of the Office of Science who believed the LDRRP was important and wanted it to continue. Dr. Pete Lyons, the Assistant Secretary of Energy for Nuclear Energy, was one of those internal DOE supporters.

HSST investigators discovered an email from Dr. Weatherwax to Dr. Marcos Huerta in which she acknowledged Dr. Lyons efforts to support the program.

Marcos, this is the program that Pete Lyons has always been keeping track of and asking about, because he started the program many years ago and believes its continuation is essential for the future of [the Office of Nuclear Energy]. So whenever there’s a public meeting, etc the NE community is reminded of it, and asks about it. Right now there is proposed legislation referring to this that is asking for engagement of the national academy, and development of a plan, etc.
…
So we don’t exactly know who in Congress is specifically advocating for this program, but the community is certainly ramping up the pressure by constantly asking about its fate. In terms of budget, it’s less than 10% [actually < 4%] of the [Biological and Environmental Research] budget, and it is not directly related to administration priorities of climate or clean energy. Only two DOE national labs are engaged in any research related to Low Dose.

(Source: HSST Dec 20, 2016, p. 13)

Dr. Lyons retired from his position as the Director of the Office of Nuclear Energy in June 2015, so Dr. Weatherwax could have coordinated with him about the program’s future before the program was eliminated. Apparently, that kind of coordination did not occur. In fact, the phrasing of the email can give the impression that Dr. Weatherwas was specifically not interested in what Dr. Lyons might say. She appears to believe that he was biased by his early involvement in recognizing the need for the research and creating the program.

It’s also intriguing to note that a scientist inside the DOE would dismiss research into the health effects of radiation, a significant issue associated with nuclear power plants, as having no direct relationship to administration priorities of climate or clean energy. President Obama started making public statements about the importance of nuclear energy as a clean energy source almost as soon as he became a candidate for President.

Dr. Lyons said that he stopped keeping close tabs on the program about the time that he was confirmed in the position of Assistant Secretary in April 2011. His professional attention, not surprisingly, became focused on events and policies influenced by the March 11, 2011 events at the Fukushima Dai-ichi nuclear power station.

However, Dr. Lyons stated that whenever the LDRRP was discussed in staff meetings, he “pleaded” for the program to be continued and described the importance of the program’s research results.

He said that he was joined in this effort to protect the program by leaders in both Environmental Management and the National Nuclear Security Administration (NNSA). When asked why, if the program was so important to his mission, he did not put it into his own budget, Dr. Lyons explained that he didn’t want to give nuclear energy opponents the opportunity to dismiss the program results. He feared they would claim that it was fatally flawed by being funded by the Office of Nuclear Energy. He indicated that would be seen in a light similar to having the nuclear industry fund the research.

He acknowledged that the same charge might be levied by nuclear energy opponents simply because the funding was from DOE, but he thought that the basic science arm of the DOE was the right place for the program to be managed. It is the organization with the management expertise, the equipment, and the specialized scientists. He was unaware of any other agency that was doing the kind of biological experiments conducted under the program in a real effort to understand how living systems react to radiation and how that reaction varies in different dose regimes.

Impact On Regulatory Actions

Dr. Weatherwax and Dr. Todd Anderson, the two DOE managers above the LDRRP Program Manager, told each other and the HSST investigators that the “program was not intended to address regulatory policy” because the EPA and the NRC were the regulatory agencies that establish regulations associated with radiation. That assertion exposes a fundamental misconception; the DOE is the regulator for occupational exposure to radiation in most of the facilities at the national labs.

Dr. Weatherwax’s prepared testimony also indicates a misunderstanding of modern science associated with low dose radiation.

At that time there was ample evidence from atomic bomb survivor studies to clearly indicate a statistically significant linear response between observed human health effects (cancer) and radiation at relatively high doses but no statistically significant data available at the low doses (less than 100mSv) more commonly experienced by most people.

Aside: The phrase “statistically significant” doesn’t mean the same as significant. In the lowest exposed cohort of the atomic bomb survivors (21,343 people) 39 people had died of leukemia by 1998. 4% of that total (2 people) was attributed to radiation. 1781 people had died of other forms of cancer; just 0.5% of that number (9 people) is the “statistically significant” excess due to radiation exposure. Readers can determine if those numbers rise to the level of significance or concern. End Aside.

The atomic bomb survivor studies have numerous limitations. Here are just two of them. Not only do they only provide indications of effects at high total doses, but they also provide information on a population where the dose rate was very high and where nearly all of the total dose happened in seconds to minutes, potentially overwhelming the repair mechanisms that were being identified by carefully crafted experiments under the LDRRP. Doses were not measured, only estimated based on distance from the blast and assumed shielding.

Weatherwax’s testimony also included the following statement.

Current radiation protection standards are based on the presumption that any exposure to radiation presents some risk of cancer to the exposed individual. That is, the relationship between cancer risk and radiation exposure is linear and there is no threshold level of radiation below which there is not some risk of cancer. Any changes to the current protection standards would require strong and compelling evidence that a higher amount of radiation is safe.

The problem with adhering to that precautionary philosophy is that it is only appropriate in an area of ignorance, or where there is conflicting evidence. In the case of low dose radiation, even the most authoritative bodies that have advocated use of the linear, no threshold assumption have admitted that the atomic bomb survivor studies provide no information about doses below 200 mGy. Evidence discovered by experimentation using measured doses at that level and below has to provide a higher quality basis for decision making that having no information at all.

In the internal email from Dr. Weatherwax to Dr. Huerta that was quoted above, one more assertion was made.

But in terms of our program priorities, we feel we have accumulated sufficient research results to inform EPA’s regulatory process. EPA has indicated that they do not require additional research information that would cause them to overturn their current regulatory limits, which are based on the extremely conservative Linear No Threshold (LNT) theory.

With that that statement, “EPA has indicated that they do not require additional research information that would cause them to overturn their current regulatory limits…” Dr. Weatherwax seemed to be telling her colleague that she had checked with a counterpart at the EPA and found out that agency had not any interest in continuing the LDRRP, especially if it would threaten their current regulatory model.

When the EPA was contacted to find out if that correctly represents their position, Enesta Jones, a spokesperson from the U.S. EPA Office of Media Relations, provided the following comment dated Jan 12, 2017.

EPA supports low dose radiation research as a way to better inform our regulatory activities.

Though Dr. Weatherwas did not respond to email or return calls, Rick Borchelt, Director, Office for Communications and Public Affairs, DOE Office of Science, provided the following comment in response to a request to address the apparent disagreement between what Dr. Weatherwax wrote in her email in Oct 2014 and what the EPA spokesperson wrote in Jan 2017.

The email of October 3, 2014, reflected the understanding in DOE based on interagency discussions at the time.

The good news from this whole episode is that the EPA has expressed interest in low dose radiation research and acknowledges that the experimental results from modern science would be used to better inform its regulatory activities.

Not only would LDRRP restoration be a positive step, but any legislation that directs that the research be revived should include guidance about gathering the evidence that has been revealed already. It should be used to support near term rulemaking.

Many radiation effects experts believe there is sufficient reliable evidence available to reverse the regulatory ratcheting that has been imposed since the advocates of the “no safe dose” assertion won the public communications battle. It’s important to know that they won that battle without having evidence to support their claim. They must not be allowed to win the war.