Mary Olson, Nuclear Information and Resource Service
September 1998

This conference is a discussion about low-dose ionizing radiation, and so it is key to focus on the radiation standards governing those whose activity requires the involuntary exposure of others to ionizing radiation.

Current recommendations by the International Committee on Radiological Protection (ICRP) that are at the root of the U.S. Nuclear Regulatory Commission’s regulations, say that the general public is allowed to receive 100 mr (1 mSv) per year.

This is not a protective standard. Even if it were a protective standard, it is not a standard that is capable of protecting any given individual. This is because:

• It is derived and applied using averages. It is quite allowable for some people to get 10 times more radiation, just so long as they are balanced by as many who get ten times less.

• The regulators rely on the assumption of a standardized individual – so doses are calculated and applied to the Standard Man ( average height, weight, 35 years old). Children, fetuses, elders and others will actually receive a higher dose from the same level of radiation exposure.

• ICRP says it assumes a linear-no threshold dose-response curve, and yet it applies a dose-rate-dose effect factor which lowers the evaluated risk associated with a given dose, usually by a factor of 2.

• The use of the new Total Effective Dose Equivalent calculation where more radioactivity is required to produce the same dose as before. This suggests that a millirem behaves more like a form of currency (like the dollar) than like a unit of measurement like an inch. There can be no standard “reference millirem!”

• And finally: no one can actually verify either a milliSeivert or a millirem directly anyway. This sort of regulation is completely unenforceable except under controlled, monitored conditions or very gross negligence (in which the Price Anderson Act will limit the liability of some licensees—by the way, Price Anderson comes up for reauthorization by the US Congress between now and 2001).

Whenever this 100 millirems a year allowable limit for radiation exposure to the public is cited, ICRP’s risk assessment for this dose should also be cited, or we do not know how to interpret what this standard means. ICRP also provides the various national regulators, such as NRC with a basis for their regulations.

ICRP is under heavy attack from extremists among the health physicists. This profession as a group depends most upon the irradiation of others for their livelihood. Any assertion that radiation exposure standards should be more lax coming from this group is about like letting the loggers set forest policy.

According to ICRP and NRC, for every 1000 people exposed, over a 70 year lifetime, at 100 millirems a year, 3.5 in 1000 are expected to die of cancer due to this exposure.

Doing the very simple division, this is a 1 in 286 chance of fatal cancer from this allowable level. That is actually 1 in 286 Standard Men.

It is important to remember to qualify these numbers with points 1 – 5 above. ICRP states that they assume a linear-no-threshold model for fatal cancer risk assessment, but in fact, they apply enough “tweeks” to their numbers that there is an effective threshold built in. Others would put the risk associated with 100 millirems 2 – 10 times higher.

Compare all of this to the 1 in a million death rate in the general public that is considered controversial from an industrial activity. Then compare the 1 in 286 level to the least stringent Superfund standard for toxic chemicals of 1 in 10,000 fatal cancers, though these clean-ups are more typically taken to the risk factor of 1 in 100,000 or 1 in a million.

Current radiation standards, based on ICRP recommendations allow 35 times more cancer deaths than even the least protect toxic waste level.

It is also important to point out that we are not talking about 1 death and 285 healthy people. Typically, for every fatal cancer there is a non-fatal cancer. There are likely to be non-cancer effects, to the immune system, to the reproductive systems and possibly to offspring as well. The long term genetic impacts are not known.

This is not a protective standard. There are those who say that because we can’t (yet) fingerprint cancer that contribution to the overall cancer rate is not something that can be determined. One cannot justify any contribution to an epidemic simply by invoking the fact of the epidemic.

It has been suggested that because there are so many different toxic chemicals, that each has to be regulated more stringently. This may be so, but so far we have assumed that people are only ever exposed to 100 millirems. In fact, the NRC does not choose to follow ICRP’s recommendation that 100 mr be the annual dose limit to members of the public. Instead NRC confers on each and every licensee the ability to expose the public to 100 millirems in air, 100 millirems in water and up to 500 millrems in sewage, per year.

It is not at all difficult to posit a situation where individuals may be impacted by multiple licensees, for example, a community may be subject to a local medical incinerator, in the effluent pathway of a nuclear power reactor, and also affected by a nuclear laundry. One could well imagine that these people would be well above the 100 mr a year total recommended for the public.

This permissive form of regulation is a form of subsidy to the nuclear industry. Lax clean-up standards that the NRC adopted 2 years ago will save nuclear waste generators hundreds of millions of dollars, maybe more, while transferring the costs to those who will suffer with tainted food, water, homes and work places. When we are asked to consider the cost of nuclear clean-up to society, the regulators never consider these true social costs of allowing residual nuclear contamination.

Mary Olson 202-328-0002 maryo@igc.orghttp://www.nirs.org