It’s past time for another GAO investigation of radiation standards
As a former federal agency bureaucrat, I should have thought of this long ago. When agencies disagree over matters with significant budgetary impact, one way to arbitrate the dispute is to involve the people in Congress who are responsible for funding the agencies and the programs affected by their differing points of view.
One possible outcome of the discussions is a request by Congress for an investigation by the GAO (now the Government Accountability Office but formerly known as the General Accounting Office).
The continuing dispute over radiation standards, primarily between the NRC and the EPA, is well suited for a GAO investigation, especially since there is fundamental disagreement over the scientific basis for the regulations.
As I learned this morning — again, I apologize for treating history as news just because it is news to me — the GAO has been called in at least twice before — in 1994 and again in 2000 — in an attempt to resolve agency differences over radiation standards. For the 2000 effort, the agency provided both a report and testimony before the U.S. House of Representatives Subcommittee on Energy and Environment, Committee on Science.
In both efforts, the GAO reported that agencies used different models, different standards of protection, and different units of measure, resulting in duplicative, confusing and potentially very costly regulations. The 2000 report went further and was more explicit about its finding that there was no firm scientific basis for any of the regulations because they were derived using a model that had not been proven and could not be supported with measured evidence.
Here is are sample quotes from the testimony resulting from that investigation.
U.S. radiation standards for public protection lack a conclusively verified scientific basis, according to a consensus of recognized scientists. Below certain exposure levels, the effects of radiation are unproven. At these levels, scientists and regulators assume radiation effects according to the “linear no threshold hypothesis,” or model, under which even the smallest radiation exposure carries a cancer risk. However, the model is controversial among scientists, and decades of research into radiation effects have not conclusively verified or disproved the model, including studies attempting to statistically correlate natural background radiation levels in the United States and around the world with local cancer rates. Research is continuing, including a promising 10-year DOE program begun in 1999, addressing the effects of low-level radiation within human cells.
…
According to a consensus of recognized scientists, below about 5,000 to 10,000 total millirem of exposure, the effects of radiation are unproven. Evidence of these effects is especially lacking at regulated public exposure levels—levels of 100 millirem a year and below from human generated
sources.
…
Some scientists and studies held that there are considerable data to support the view that low levels of radiation can actually be beneficial to health—the highly controversial theory of hormesis. Proponents of hormesis argue that research indicating beneficial effects has not been adequately considered in the “consensus” scientific community.
…
Decades of radiation effects research have neither verified nor disproved the linear model. The research data on low-level radiation effects generally include two different types of studies. One type follows the long-term health of a studied population, seeking statistically significant cancer effects, and is called epidemiology. Another type subjects animals or tissue or cell cultures to radiation, seeking biological evidence of radiation effects, and is called radiobiology.
(Emphasis added.)
The 2000 report expressed high hopes for useful information from the DOE’s Low Dose Radiation Research program, which was initiated in 1999 with an expectation of lasting at least 10 years. Here is a quote from that report.
Radiobiological studies, particularly molecular studies, may eventually develop more conclusive scientific evidence of low-level radiation effects than epidemiological studies, according to scientists. Past radiobiological research has helped to establish, among other evidence, the genetic effects of radiation and its effects on individual body organs.
Recently, there has been interest in research into the cellular processes through which radiation causes cancer, in part in relation to progress in human genome research in the 1990s. Researchers have been obtaining a better understanding of specific phenomena such as DNA damage and repair, chromosomal instability, so-called “bystander” effects on neighboring cells, and cellular adaptation to exposures.
Researchers are looking into such cellular processes for biological signs (or “biomarkers”) of radiation cancer causation. Several stages are apparent in the development of radiation caused cancer: DNA damage, misrepair, cancer initiation, cell proliferation, and tumor promotion (with subsequent malignant transformation). To date, the first stage in the process is better understood than the long-term second stage. Since fiscal year 1999, DOE has funded a research program targeting the biological effects of low-level radiation at the cellular level, with total funding of almost $220 million projected over 10 years.
The program is considered unique in that it is designed specifically to better validate the effects of very low levels of radiation in areas such as cells’ response to radiation damage, thresholds for low-dose radiation effects, and features distinguishing radiation-caused cell damage from damage from causes internal to the cell. Many scientists and regulators we interviewed said this type of research could eventually help to determine more conclusively the effects of low-level radiation and their potential link to cancer causation.
(Paragraph breaks added for improved readability online.)
Aside: I acknowledge that the GAO report states that the program is a 10-year effort, but few scientists would be willing to agree that the duration of investigation required to arrive at a defensible conclusion can be predicted ten years in advance. End Aside.
The DOE Low Dose Radiation Research program was ended several years ago. There have been 15 more years worth of research and published material regarding the biological effects of low dose radiation, the history of the promoted effort to establish a no-threshold model, and the results of continuing evaluations of the various sources of epidemiological information.
Note: At the time this post was written, the DOE Low Dose Radiation Research web page at http://lowdose.energy.gov was not available. It was still listed as the reference site on the following pages DOE Low Dose Radiation Research Program at PNNL and DOE Biological Systems Science Division (BSSD) Radiobiology: Low Dose Radiation Research.
Billions of dollars per year are still being expended to achieve site clean-ups to the disputed agency standards and people are still being purposely frightened by statements regarding health risks of exposures that are within the natural variation of background. Those supposedly worrisome doses are often orders of magnitude below the doses that have been proven to be harmful to human beings.
Bottom line: It’s time for the GAO to take another hard look at the available scientific data and interview the experts in the field.
The GAO is the right body of investigators to consider the psychological, financial, and operational effects of continuing to assert that the tiniest dose of radiation carries a finite amount of health risk even though there is no evidence supporting that claim.
Good article!
A question I have which failed to Google up is that there seems NO research study on the role particulates and gases from fossil emissions has on a general population. There’s lots of “closed office/area” and second-hand smoke studies, but none that I can find which tracks and studies the health and genetic effects of fossil fuel on individuals within a large population from infants to elders. It’s like despite all the known facts and assumptions that much respiratory diseases are from fossil sources, there’s no actual smoking gun aimed at those specific sources once the pollution’s in the air. A coal particle found in an infant’s lungs simply gets no news or traction or investigation. It’s just regarded as the price kids pay for living in civilization. Here, it seems nuclear is vehemently demanded to provide that very kind of micro-detail of its minuscule if measurable effects on health which fossils have never been called upon to research and cough up for hundreds of years despite millions overtly impacted and suffering by it unlike nuclear. There just seems an outrageous prejudice going on here, especially by the grudging — if ever — support clean nuclear ought get from renewables fans.
James Greenidge
Queens NY
The DOE low-dose research website is available on the “Wayback Machinea internet archive. The most recent retrieval was September 2015:
https://web.archive.org/web/20150905100153/http://lowdose.energy.gov/
James,
Try these:
Pope III, C. Arden, et al. “Particulate air pollution as a predictor of mortality in a prospective study of US adults.” American journal of respiratory and critical care medicine 151.3_pt_1 (1995): 669-674.
Smith, Kirk R., et al. “Public health benefits of strategies to reduce greenhouse-gas emissions: health implications of short-lived greenhouse pollutants.” The lancet 374.9707 (2010): 2091-2103.
When the low dose radiation research program began to show hormesis, it was defunded and the government erased this link:
http://lowdose.energy.gov/radiobio_slideshow.aspx
Being suspicious, I had copied all the files to my Mac. I just loaded them onto Amazon for you all.
https://s3.amazonaws.com/hargraves/DOELowDoseRadiation/AdaptiveResponse.ppt
https://s3.amazonaws.com/hargraves/DOELowDoseRadiation/BackgroundRadiation.ppt
https://s3.amazonaws.com/hargraves/DOELowDoseRadiation/BystanderEffects.ppt
https://s3.amazonaws.com/hargraves/DOELowDoseRadiation/DNADamageRepair.ppt
https://s3.amazonaws.com/hargraves/DOELowDoseRadiation/DirtyBombs.ppt
https://s3.amazonaws.com/hargraves/DOELowDoseRadiation/GeneticSensitivity.ppt
https://s3.amazonaws.com/hargraves/DOELowDoseRadiation/GenomicInstability.ppt
https://s3.amazonaws.com/hargraves/DOELowDoseRadiation/HealthEffectsRadiation.ppt
https://s3.amazonaws.com/hargraves/DOELowDoseRadiation/InternalRadiation.ppt
https://s3.amazonaws.com/hargraves/DOELowDoseRadiation/RadiationDose.ppt
Robert Hargraves……. what an excellent anticipatory move! Simply marvellous!
Good find, Keith — but notice how these conclusions don’t condemn fossil plants in availing preventative filtering measures nor tracks down specific plants for cause and inspection or shutting down — totally unlike the shotgun leveled at nuclear plants where this quibble over safe radiation minimums on the head of a pin effects the operations and welfare of all nuclear plants. It’s almost an old joke that antinukers act like vultures hovering over nuclear incidents to find that one great poor irradiated person to turn into a victim-hero which justifies shutting down all NPs yet the half the kids living in eyeshot of stacks belching black gray stuff are daily coughing on their way to school. The “greens” and related parties’ health concerns and hypocrisy is just incredible to me!
James Greenidge
Queens NY
While I agree with the above effort to get LNT repealed, I still believe that we have an even stronger and unassailable argument pertaining to the *selective application* of LNT. Just getting rid of the selective application should be enough to achieve our goals.
Scientists may (still) disagree about LNT, but at the end of the day, you either believe in a threshold (which is at or above the top of the range of natural background), or you believe in LNT. Either way, current radiation standards, that apply for nuclear-industry-related exposure sources only, are indefensible.
If you believe in LNT, you have to accept the results of that (mathematical) model. If LNT is true, then health impacts (deaths, etc) scale directly with collective exposure (man-Rem). Well, the fact is that humanity’s overall collective exposure from nuclear industry sources, including releases like Fukushima, is negligible compared to humanity’s collective exposure from other sources, such as natural, medical and air travel, etc.. I believe that nuclear industry related collective exposure is literally on the order of one millionth of mankind’s collective exposure, over the last several decades. Certainly less than 0.1%
This begs the question of why such a relentless effort to minimize mankind’s (miniscule) exposure due to nuclear-industry-related sources is necessary, while little to no attention or effort is made to reduce the much larger sources of collective exposure. We hear a great deal about Fukushima, and nuclear safety, etc., but hear almost nothing at all about the much larger sources of exposure. And we spend thousands of times as much money (per man-Rem) to reduce nuclear-industry-related exposures than we do to reduce other sources of exposure (e.g., radon), if indeed we spend any money at all on reducing those other sources of exposure.
This should be an easy argument to win. Are there any real, valid arguments against it? Is there any scientific disagreement over the fact that all exposure sources are the same in terms of health risk/impact?
As for policy remedies, we would simply bar the EPA and NRC, etc., from drawing any distinction between nuclear industry related sources of exposure and any other sources. They would have to determine what level of exposure is “safe”. If they try to put the value within the range of natural background, the result would be comical, as they would be required to order the evacuation of all areas with natural background levels higher than that. If they put the “safe” level above the range of natural background (e.g., ~1 Rem/yr), then many of the industry’s problems would just go away. Ridiculous decommissioning/cleanup standards would go away.
Alternatively, we could demand that similar amounts of money and effort be directed to reducing man-Rems, regardless of their source. Spending a large amount of money reducing nuclear-industry-related man-Rems while refusing to spend one thousandth as much on reducing radon exposures (in homes/buildings) would not be allowed. The net result would be a drastic reduction in the amount of money required to reduce the (relatively tiny amount of) man-Rems from nuclear industry sources, such as plant decommissioning requirements, or even cleanup/evacuation activities after a release (meltdown).
Ideally, this economic analysis would be extended to nuclear safety regulations and requirements. The analysis would ask what the cost-effectiveness of all such regulations are, starting with an estimate of the reduction in accident/release probability, and (finally) converting that into an estimate of dollars per man-Rem avoided. Such analyses would almost certainly show that strict nuclear safety regulations, and strict dose requirements for nuclear cleanup operations, are extremely cost-ineffective means of reducing collective exposure (orders of magnitude more expensive than other options).
The study has already been done http://www.ncbi.nlm.nih.gov/pubmed/7604170
at least in terms of dollars per life saved.
But the bureaucrats use ALARA where “reasonable” means “politically expedient”
In my view ALARA is at least as pernicious as LNT.
Heres a link to the actual Tengs paper
http://www.ce.cmu.edu/~hsm/bca2005/lnotes/500-interventions.pdf
Check out bottom of page 377. Of course, this assumes LNT.
If you are not an LNT-er you can tack on a few more zeros.
As far as full-body gamma exposures are concerned, there is a strong difference between an instant exposure (no effects statistically detected under 100 mSv) and a chronic exposure, for which no medical drawback has ever been detected for radiation exposures of up to 1 mSv/h (which would lead to 8766 mSv/year). The ~1mSv/yr limit usually accepted therefore corresponds to a ~10_000 safety margin.
This amounts to say that one has seen people drown in 10cm of water, “therefore” areas with 1 µm of water should be considered dangerous !
Do you have a reference for that?
Some research in Japan may yield information about effects of low dose radiation. One town administered Potassium Iodide tablets to residents of a small town west of Fukashima to block I-131 which has an 8 day half life. Two hundred students who received potassium iodide tablets wore dosimeters giving a measure of dose. Although a larger sample is highly desirable comparison of the incidence of leukemia of these students with that of people in other parts of Japan may give some information about the effects of low dose radiation. Remarkably, no other residents of Japan were given potassium iodide pills, at least in a systematic way.
See this (French) Wikipedia article and its references :
https://fr.wikipedia.org/wiki/Faibles_doses_d'irradiation