On September 8, 2015, the NRC announced that it would stop funding the National Academy of Sciences’s (NAS) five-year-long, multimillion dollar effort to create a method that could be used to study whether or not populations that are exposed to radiation doses that are a tiny fraction of average background radiation related to proximity to licensed nuclear energy and fuel cycle facilities have an elevated risk of contracting cancer.

In support of the decision and in addition to the press release, the NRC made public SECY-15-0104, Analysis of cancer risks in populations near nuclear facilities study, dated August 21, 2015. While the press release emphasized the impracticality of completing the study, given the schedule and financial resources required in a time of tightening budgets, the policy issue paper provides a deeper understanding of the decision process.

Though the NRC paper uses a lot more words that are shaded in fuzzy language the essential point is that the staff determined it was silly — “impractical” — to spend millions of dollars and ten or more years looking for evidence of an effect or lack of effect of radiation doses on the order of 0.01-1 mSv. The effort is analogous to trying to conclusively prove that witches exist or don’t exist.

Even though it has not begun any health studies, the NAS has generated several reports about how they could potentially organize a study. Those reports would together require almost a ream — 500 sheets — of paper to print out. Producing the reports involved the efforts of a 20 specialists in various disciplines and the contributions of a substantial administrative staff and were reviewed by another significantly sized body of NAS scientists.

The summaries of those reports include numerous caveats and cautions identifying the non availability or inaccuracy of the necessary information along with some discussion about ways to assume away many of the complexities in order to produce answers that no one will believe. Producing those reports has consumed something approaching $3 million dollars and 4-5 years worth of intermittent effort.

The NAS was just doing its contracted job.

Background

In April 2010, while being led by Chairman Greg Jaczko, the NRC asked the NAS to perform a study on cancer incidence and mortality in populations living near NRC licensed facilities. The official reason behind the request was that the existing study performed by the National Cancer Institute (NCI), performed during the period from 1987-1990, was outdated. According to SECY-12-0138, Next steps for the analysis of cancer risks in populations near nuclear facilities study, the staff was being challenged when it used the NCI study as the source for communicating the lack of health risk to the public.

The NRC’s reasoning for requesting the study described fact that some members of the public “expressed recurrent concerns” about the release of effluents that, by law, cannot produce more than 1 mSv/year to the most exposed person in the general public. There is a provision in the law for exceptional circumstances that would allow a licensee to continue operating with effluent releases that could produce as much as 5 mSv to the most exposed person, but it is unclear if that provision has ever been used.

As noted in SECY-12-0138, the NRC is confident that its licensees are accurately reporting their effluent releases and calculating the resultant public doses. According to those reports, public exposures are a small fraction of the regulatory limit and generally less than 1% of the exposure that the average American receives from all background sources.

Based on that information alone, the NRC shouldn’t have asked the NAS to attempt a study. No reliable evidence has been found during the 120 years that mankind has been using radiation and radioactive materials indicating that a dose of less than 100 mSv results in an elevated risk of contracting cancer. Even adherents of the “no safe dose” assertion will — if they are being honest — admit that if you cannot detect a risk at 100 mSv, there is no chance of detecting a risk at 0.1 mSv or 0.01 mSv.

Phase 1 report and decision process

The NAS committee essentially admitted the impossibility of the task when it opted not to calculate the sample sizes needed to detect health effects. It reported that the numbers of exposed persons required to find a possible association would be “truly enormous.” The NRC staff determined they meant in excess of hundreds of millions. There are not hundreds of millions of exposed persons living in the vicinity of nuclear plants. Even if there were, doing dose reconstructions and gathering health information would provide lifetime employment (albeit rather boring employment) for hundreds of researchers.

During the public comment period held in 2012 after the NAS released the phase 1 summary report, the Health Physics Society (HPS), the Nuclear Energy Institute (NEI), and the Electrical Power Research Institute (EPRI) all expressed their concern that the proposed study wouldn’t satisfy anyone because of its low statistical power, would cost a great deal of money, and would consume additional resources among the staff and the affected facilities. HPS and NEI formally recommended that the NRC not proceed to the next step.

Those organizational comments, however, were outweighed by the 44 comments submitted that encouraged the NRC to proceed with the pilot studies. Just 13 comments were received that supported the HPS and NEI recommendation, despite the following plea in an April 2012 ANS Nuclear Cafe article for interested nuclear professionals to provide their comments.

The American Nuclear Society includes experts in the field of radiation biology who should take the time to read the phase one scoping summary, learn more about the proposed study methods, and provide informed comments. The most reasonable decision would be that there are any number of higher priority ways to spend the money and the scientific resources that would be needed to perform the proposed phase two study; it is unlikely to provide any new or useful information.

After receiving the phase 1 report and the public comments, the NRC staff decided to proceed with the pilot phase in two steps. The first step would be a detailed planning and estimating phase. That phase was completed in December 2014. It created such sticker shock that the staff spent another nine months evaluating options and getting additional estimates.

Response to planning estimate

The NAS told the Nuclear Regulatory Commission that it would take them 39 months and about $8 million to complete a pilot study focusing on just seven chosen facilities. That effort would not provide any usable health information; it would simply prove (or disprove) the feasibility of executing a study using the chosen methods. The NAS did not provide any estimate of the schedule and cost associated with the phase 2 nationwide study that would, if completed, provide usable estimates of the health effects. According to SECY-14-0104 that would push issuance of potentially useful material to 2025 or later, more than 15 years after the initial request was issued.

What the paper did not say was that the mere existence of the study process would continue to provide grist for people who repeatedly encourage public angst about nuclear energy, radiation and radioactive materials. A good example of the types of response that the existence of an NAS study can stimulate can be found in a June 2012 article titled Is it safe to live anywhere near the nuclear plant at San Onofre? Here is a sample quote from the lengthy, fear-generating article.

Recently another ugly possibility has emerged which might threaten the health of everyone nearby: the danger of cancer caused by the radiation that Edison regularly releases into the air and ocean. It just might be that living near a NPP is dangerous even if it runs like a Swiss watch and never has an accident. The reason for this new worry comes from a recent bombshell report from none other than the prestigious National Academy of Sciences (NAS). On March 29, the NAS issued a 412 page report entitled “Analysis of Cancer Risks for Populations Living Near Nuclear Facilities.” This scientific study, written by 20 leading radiation epidemiologists, was commissioned by the NRC. Those who want to wade through it can check it out: http://www.nap.edu/catalog.php?record_id=13388#aboutprepub The NAS carefully reviewed all the scientific evidence linking cancer to nuclear power plants and concluded that many studies are flawed and that new research is needed. The main thrust of the report was to recommend careful epidemiological studies in six population zones near NPP in the U.S.

There is no doubt that certain “stakeholders” will continue to show up at public meetings and submit public comments asserting that there must be a risk from radiation since no one has proven there is not a risk. The more scientifically supportable statements about the health effects of low level radiation is to state that there is no evidence of negative effects below 100 mSv acute dose. There is no conclusive evidence that radiation health effects are cumulative if adequate recovery time is allowed between doses.

The public communications challenge about the lack of risk associated with low dose radiation continues to be traceable to the well-publicized BEIR 1 report published on June 13, 1956 by a carefully selected group of geneticists, nearly all of whom had close ties to the Rockefeller Foundation.

That lengthy report, which was published in full by the New York Times and Science Magazine concluded with the following memorable lines.

But we must watch and guard all our expenditures [of radiation]. From the point of view of genetics, they are all bad.

That selected group of geneticists had no evidence for their conclusion. There was no experimental evidence on any subjects (insects, plants or animals) at doses less than 250 mSv over a relatively short period of time. The best available evidence between 250 mSv and 500 mSv suggested that there was a threshold below which there was no hazard. More recent studies conducted as part of the DOE’s defunded, but incomplete Low Dose Radiation Research program tended to support a similar conclusion.

The threshold response evidence available before his Nobel Prize speech of 1946 was purposely submerged by obfuscation and discrediting commentary (see pages 433-434 of linked paper) by Hermann J. Muller, a scientist who owed whatever career success he had to the unfailing support, comfort, and promotional efforts of the Rockefeller Foundation. He continued to promote the no threshold — aka “no safe dose” — assumption throughout the ten years between his Nobel Prize and the formation of the BEIR Genetics Committee. That committee deferred to his strong advocacy and Nobel Prize-winning authority.

In 1956 the Rockefeller Foundation was one of the richest and most powerful foundations in the world. Its wealth came from the Standard Oil Company and its progeny, which at one time had controlled about 85% of the world’s lucrative petroleum market.

(Note: The paper linked in the penultimate paragraph above can be obtained by specific request. Use the contact form below.)