September 1998

This conference is a discussion about low-dose ionizing radiation, and so it is key to focus on the radiation standards which protect public health and safety.

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 or 1 mSv per year.

I want to point out that 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:

1. 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 a by those who get ten times less.

    

2. 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.

    

3. ICRP applies a dose-rate-dose effect factor which lowers the evaluated risk associated with a given dose, usually by a factor of 2.

    

4. The use of the Total Effective Dose Equivalent which is a regulator’s mechanism for calculating dose, where more radioactivity is required to produce the same dose as before.

    

5. 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).

This 100 millirems, when ever it is cited, should also include the regulator’s own risk assessment. Again, this is the ICRP giving the various national regulators a basis for their regulations. The same ICRP which is under heavy attack from the professionals who depend most upon the irradiation of others – Health Physicists.

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 would be more than one person from the graduating class of a metropolitan high school, every year…and remember we are talking 1 in 286 Standard Men!

Compare 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.

Radiation is regulated 35 times less protectively than even the least protect toxic waste level. This is using NRC and ICRP’s risk assessment.

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. These are the same people who tell us that a millirem is a millirem is a millirem.

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 whole-heartedly, since they confer 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.

It is not at all difficult to posit a situation where individuals may be affected by multiple sources, a local medical incinerator, a nuclear power reactor, and 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.org

Nuclear Information & Resource Service, 1424 16^th St NW Suite 404

Washington, DC 20036 http://www.nirs.org/