ML20154M994

Comment Opposing Proposed Rule 10CFR50 Re No Warning Being Required at Low Power for Nuclear Plant Licensing Purposes

ML20154M994
Person / Time
Site:	Seabrook, 05000000, Shoreham
Issue date:	05/25/1988
From:	Eddleman W EDDLEMAN, W., NORTH CAROLINA CITIZENS RESEARCH GROUP
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR16435, RULE-PR-50 53FR16435-00020, 53FR16435-20, IEIN-88-021, IEIN-88-21, NUDOCS 8806020147
Download: ML20154M994 (9)

Text

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DOCKET NUMBER PROPOSED RULE N 80 811 Yane ey st.

Durh'n, NC 27701 h

" (919)-688-3016 3 M l O 3 5j cMh88 N

3anuel Ch11k, Secretary Attn: Decketing and Service, PR 53 FR 16435, no warning required at low war e r US Nuclear Regulatory eemissied '88 MY 27 P5 :37 Washington, DC 20555 Joint Com'nents of Wells Eddleman and NC Ci(bns. Beyareb Oreus on Provosed Rule 10 CFR 50, no warning requirMitdQ;wideb for nuclear vlant licensing wurseses, 53 FM 16k35 fff, 9 May, 1988 The wrenesed rule is deeply flawed. Before addressing it in more detail, we believe the "Finding of No Significant Iuwact" (FONSI) is likely in errer, and a f ull Environmental Imuset Statement should be required. This is especially true since the wrowosed rule avulies to licensing of all nuclear power facilities new under construction, and to all future nuclear wlants, according to the Commission's own statements.

Yet, the Commission does not (and by law emnnet) assume that these plants will ultimately receive eieratirglicenses. This is particularly true of the Seabrook (NH) plant, which would still have .to urovide a warning systen satisfying the current 10 CFR $0.47 etc. requirements to receive a full power license. (Unless the Commission later obviates these requirement!-

The ease of the Shoreham nuclear plant illustrates the wroblems of allowing low-newer eseration withent a full vower license fe11 ewing: the slant that enerates at low newer irradiates many of its commenents, and its nuclear fuel, thus creating many tens of both high and low-level radioactive wastes. Widesuread news accounts indicate that the eest of cleaning us the Shoreham' 31 ant will be $kOO million to $$00 million. If that slant i

had not been made radioactive, it might have a assitive salvage value, instead of a negat6ve salvage value ef .r'oughly half a billion dellars.

Hereever, NRC ease law has recohhotFfshat the only benefit, for NEPA yrupesos, of nuclear plant eueration is electrioity produced. It is inconceivable that net electricity production in low yewer eieration (below 5 wercent iewer under NRC rules anulicable te nest US nuclear plants unless they receive a waiver) could equal four hundred million dellars.

60 147 880525 50 53FR16435 PDR bSo-lo

, pa,50 two 5.25.88 cetments en PR 10 CFM 50, no warning required at 1.w newer Thus low wower eneration clearly f ails the required NEPA cost-benefit analysis Of course, low-yewer overation must stand on its own for this analysis because to de otherwise would wre j adge the full-wower licensing wrecess.

This would be warticularly wrong 2 n the Seabrook case, since the removal of premst notification systems that now wrecludes low-wower licensing would still preclude full vower licensing even if this ill-advised, NEPA-violatigg rule were adested.

Further, the irradiated fuel af ter low-wower everation would have to either be sold to another ilant (reouiring shissing in much better shielded containers than are used to transwert "fresh" unirradiated nuclear fuel, and probably storage at the new site of use, khere it is neither fish nor fowl, i.e. if stored directly as fresh fuel, it will be irradiating the other fresh fuel in storage; if stored as sweat fuel, it will be much mese enriched in U-235 and thus will be a criticality hasard) at best, or in the alternative, kept as nuclear waste and ultimately diswesed of.

This disvesal will again be comilicated by the higher wereentage of U-235 in the enriched fuel irradiated by low-wower everation; even natural uranian has been known to initiate a chain reaction by leaching, as at Okle (Afries) and it is assumed than swent fuel may leak in storage at a "wermanent" disposal site. Partial irradiation of fuel during low wower testing can thus be a significant environmental inwact, unaecomianied by any net benefits (the not benefits will be discussed more fully below).

In addition, the irradiation of the reacter internals, bessel, and assoc &ated systems of the plant during testing at low wower create the need for eleanup when the plant does no t receive a full power eyerating lisease er for other reasons (e.5. takeover, as preposed a t Shoreham) does not operate beyond low power. This, in effect, is creating a radteactive l waste site at the nuclear vower plant, unaccomwanied by any benefits.

I O, orating the plant systems needed to contain dais radioactivity (during either storage er cleanup) requires energy and involves some radiation exposure to personnel; cleanup involves radiation execsure te versonnel and aise increases the lead of radioactive waste f or disvesal. Te the extent the irradiated slant comwenents, activated wlant eenwonents er materials, ate. , o"e dissesed of as low-level radioactive waste in landfills er other undrerround storage ( e sne cially where there is si enificent vainfell, t e.g. over 25 inches wer year), leakage inte One e nvironment is quite vossibla All of these deterimental environmental imwaets are unaccomwanied by any met benefits. This is another powerful set of reasons why lew-wower oweratio n where full-power everation is not assured, cannet inss the NEPA cost-benefit I tests that the law requires.

I More en met benefits: Assume (generously to the benefits for the sake of argument here) that the slant involved is 1300 MW (Shereham is ever 800 and Seabreek about 1150), that the plant always wreduces electricity when the reacter is critical (not so, esweelally in low wower testing), that the reacter system's heat rate (conversion of heat from the reqcter inte l

is the same at 5% wower as at full iewer (not se: efficiency electricity)%

is less at 5 wower) and that low wower eierati on continues for 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> i

at 5%5 w%

below wower in less time than this).ower (nuclear Under the se estimistic31 ants in the assumstians U of benefits, the wlant would wreduce 1300 MW x 5% x 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br />, er 130,000 megawatt-heurs of electricity. A Ssume further that the average cleanus cod; it full vower eueration does not accur (NRC cannot lawfully wrejudge that it will) is $225 million (half the $400-te$500 million cost estimated for the 800-plus MW shorehan reactor). The cost of power is then ($225,000,000 /

130,000 ) per megawatt-heur, er about $1730 ier megawatt-heur. This is

$1 73 per kilowatt-hour, excluding the ce s t of nuclear fuel, everations, and maintenames. And this is a very sptimistic ee st estinate.

$1.73M4H is roughly ten times the cost of oil-fired weaking wower, thirty to rerty times the c ost of e mal-fired weaking wewer, and ever 50 ti mes the cost of weaking vower purchased in a 1000-MW bleek by Duke Power &ce

page 3, coraments oi PR 10 CFR 50, no warning required at low power during tight supoly conditions throughout the Southeast, at the hour of summer peak in 1986. Canadian hydrenewer, not to mention energy efficiency imparovements, cemen in at costs vastly lower than 8L73 a kilowatt-hour,

$1.73 a kilowatt-hour is aise about 20 er more times wha t Public Servie s of New Hamushire pays for vower vurchased for use, from ee-generators and small eewer wreducers.

Per amether examsle t combustom turbines (cts or ICs) can be bought f or awareximat&ly $270-M00 ser kW or eawacity. Thus, a 65 MW turbine (65 MW is 5% of the 1300 xW muelear plant assuned in the .reviens ,aragra.h:

this turbine thus has the same electrielty eutzut as the assumed nuclear plant eserating at 5% vower, i.e. 65 Mw) would eest about 626 million er less. Allowins $15 million (very gene reus) for edne r costs of installing tais turbine, and fueling it with oil at a oest of 10//kWh ($30/bb1 eil with an ineffieient 20,000 B7U/kWh turbine: both of these assumstions raise the eest) and a f ut4her genersou 10//kWh for maintenance and oweration of the turbine generating system, there wo uld be a runring co st of 20g/kWh and 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> of eueration of the turbine would cost $26 milllen.

Adding the comulete costs of buying and installing the turbine raises this to about $67 million, less than one third the ee st of cleaning uw the assumed nuclear slaat that in low newer emeration would aise rum 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> at 65 megawatts met out=ut.

Since actual energy-efficiency measures can have net costs from 2 cents a kilowatt-hour to awareximately sere (or lower: see Rocky Mtn. Institute Publication, Advanc ed Electricity-Saving Technologies and the South Texas Pro je c t , available from Reeky Mtn. Institute,1739 Snowmass Creek Rd. ,

Snowmass CO 8165k, (303) 927-3851, cost curve su(narized en p.32 thereof),

and other generating seuroes metod above, e.g. purchased sewer en peak at 30 mills /kWh in 1000 M4 bleek (Testimony of W.S. Lee, Chief Exeentive Officer, Duke Power Co. , NC Utilities Commission Decket E-7 sub kO8 (? n86) see Transcript vol.8), weaking esal at k-5//kWh running eest, or even building and runring a high cost eilsfired eembustien turbine, all cost much less than running a nuclear slant at low power, there are clearly NO met benefits in menetary terms from low-wower nuclear vlant everation under VEPA. Instead, there are large ne t co sts, be th in dellars and to the envire* ment, from eleaning un the irradiated plant and dealing with its eartly irradiated fuel (which has mise the votent' aly s e ca usi ng criticality accidents, being both irradiated, and thu) harder to handle stfely, and still highly enriched in U-235 comwared te fully sient f uel).

Since the rule estensibly (and in law) will ausly to all future muelear units if adopted, dte need for an EIS is t> A t much s tronger.

There are about 15 nuclear slants still under eenstruction in the USA (15 units, total), and not all of these can reasenably be exnected to ever operate at full . wower. There could be other nuclear plants licensed fo r c ons truc tion, te which thi s rule would avsly. Thus the total environmental imsact of adesting the rule, even if no accident occur in low power eueration at any nuclear 31 ants in the future, can reasonably be exuected to include the decemaissisning costs of one er more irradiated wlants that did not enerate at full wower, but only at test vower levels.

If test yewer levels above 5% are allnwed, the decommissioning may be more c o s tly. Thus an E7.S is required for the fule as wronesed.

OTHER DEPECTS OF THE RULE PROPOSED:

The wrenesal assumes that a serious accident cannet hawien at low newer. This is not true. First, the yessibility of sabotage er terrerism must be considered. NRC rules have a ssume d tha t terrorists can have insider assistance. Incidents of accidental criticalities (e.g. NRC information notice 88-21, May 1988, citing pst incidents at Millstone (CT) and Verment Yankee, not to mention Permi ((g jriticality during low never testing and (based en EddLe man 's recollec exceeding allowed vower levels, show thaf

. . - _-_ . - - . - . - - - - - - . . - - -- ~

page 4 5.25.88 comments en wronesed rule 10 CPR 50 no warning a t low wower even witTout sabstage er terrorism, accidents beyond these contenstated at low wower would be nessible. NRC must carefully censider the disastrous inwact any accident without an effective warning system would have en N90's public credibility, and ability to soundly regulate nuclear ilants, shocid such an accident occur. (More en thi s w essibility below ) . The messibility of more severe accidents, including those caused er made worse by owerater orrer, imwrenser co nstruction, inwrover design, quality assuranc e f ailure, equipment failure, or other causes including vessible sabotage er terrorism or both, needs to be a part of that careful consideration. NRC gives no evidenca of having made any such consideration.

At lew power, most safety systems are essentially or even totally untested.

Leaks, wipe or weld breaks, and numerous equiument failures of ten occur in low wower testing of nuclear vlants. NaC cannet assume tha t safety systems will work (or be wroverly actuated) & ring low wower testing. Unqualified e quipment , falsified test results en equiument said to be qualified, and equipment f ailures and errors continue to be regularly reverted, e.g.

in NRC's Analysis (/ Evaluation) of 0,erational Data office 's reverts.

It is not wradant either to assume that enersters will take the correct action should an accident occur at low wower. Unanticinated a6cidents, l the assunition that nothing serious can hawyen at low wower, the assumution that there will be 1 cts of time in the even of an accident at low wower, l

and other possibilities cast doubt en this assumution.

! There is no evidence that I can see that NRC has reviewed the erwerience of slants in low wower testing (none seems to be exulicitly referenced in

, the Federal Register prosesing tne rule).

! Since equipment and other f ailures may well be encountered only for the first time in testing, and there is os . a ssurance that safety sys tems uill work, nor that overators will act correctly (or net exacerbate an accident), and no guarantee that wewer will actually be limited to {f (see e.g. reports of accidental criticalities, imureuser red witEdrawal, etc),

NRC cannot assume as it does, that acciden ts of severity sufficient to require premst effsite alerri,ng cannet hawpen once low wower emeration is allowed.

Only wher fuel has not yet been leaded could this assunition be made (and oven then, allowances for vessible sabotage er terrorism should be made).

NRC aise ignores the very real likeliheed that vanic would result if I

an accident occurred at a plant allowed to overate at low wower under this l proposed rule, during "low wower" eseration. NRC tywically assumes that l panic is unlikely, although the evident from Three Mile Island is that fear l did motivate large numbers of wee wie to self-evacuate. At Seabreak in particular, NRC's actions, including this wrecesed rule and the rulemaking to eliminate state and local anuroval of emergency slans, have lowered NMC's credibility and made it less likely in any acciden t situation that weevle will trust NRC information er other official information gotten from er through NRC. This increases the likelisheed of vanic. NMC aiwears to say that the beaches near Seabrook need not be egacuated safely during an accident. Consider what might oc cur this summer if low-wower testing at Seabreek were authorized and 100,000 people were en the beaches nearby (a number that is of ten attained, I understand). Many no doubt would seek to evacuate to the south, where the lack of early no tification would mean that reads were more likely te be elegged by local weevle in Massachusetts self-evacuating.

NRC has also failed to address f ully the wroblems with exis ti ng and planned sirea notification systems at nuclear vlants still under eenstruction.

the Sheeren Harris licensing beard wrote the NRC in 1986 concerning this weeple ma issug:tiens, c*Md e.g.y net be able to hear the sirens under certain normal heing inside behind closed s torm w! ndows and v.en,. ,....a....

. page $ comments on presosed "no warning at low oower" rulo 10 CFa 50 The sorts of problems the Harris board outlina d need to be f ully addressed. l Instead, NRC is moving in the esposite directj en hy requiring ne notificat!en l at low newer that okn be prenstly received b? the nosulkoe. Sinc e the NRC recognised in its 1982 consideration of this issue that offsite elements including the means to wrevide early no tiMeation and clear instructions j to the nesulace (effective sirens er alternatives such as dedicated whene-dialing systems er constantly-operating weather radies are needed to alert the menulace to receive the information), NRC must show sene change since 1982 to justify this arenesed change. This they fail to do . Low newer eierations are ne safer new than in 1982, as far as established studies g e (WRC has et evidently studied this ma tter and relies en old sta ff estimates of low-wower emeration risks).

NRC has not wrevided a factual basis for reversing its earlier wesition.

The inference is inescavable from dae Commission's discussion of Seabreek and the f acts, that the Commission is really using &is rulemaking in a desverate effort to get Seabroek operating at low wower (wessibly before a new President is elected who might change welicy in this area of nuclear licensing, e.g. if a single-administrater statute for the NFC wasses, a new wresident could name that a dminis tra ter and thus control and cha nge the welicy NRC now evidently wursues, of licensing ulants as fast as it (mm. )

However , a s n6 ted a bove , e-erati on of Seabrook or any other nuclear vlant at low newer alone, dees nothing but contaminate the plant and werhaws produce varying amounts of very exiensive electricity which eeuld be wreduced er saved by other f ar less exnensive means.

The issues lef t unresolved a t low wower, e.g. wrent no tification of the newulace in an effective manner, must still be resolved to have full newer eseration, so NRC's wrenosal is the worst of all nessible worlds, insurring the negative cost and environmental imnacts of contaninating the nuclear 31 ant and irradiating its fuel, with no benefits en ne t, without resolving any of the outstanding wreblems which prevent the wlant frem Seing to full power. NRC 's rule proceses no means to resolve these problems (unless the NRC intends to ignore daem as it evidently has chosen to ignore the requirement for an accurate environmental ineact statement on the wronesed rule ), se the result is that ins tead of having a non-contaninated nuclear slant of untested safety for everation and known inadequacies in its system for wror:mt notification of the sublic, you instead have a centaminated nuclear nlant with irradiated fuel, of somewhat better known safety (knowledge acquired at the risk of accident), a target for nossible saboteurs or terrorists, able to have a reore severe accident especially if nower restrictions or safety recuirenents a re vi olated, which still does not have an adequate system in wlace to notify the nublic wromntly in the event of an accident, and which will cost hundreds of mil 16ns of dollars to clean us, and which still has no known way to solve its problems which have thus far urevented full newer oneration. (In Seabroek's case, environmental qualification of equinment and other issues including the adequacy of the emergency slan are s till in question and/or in litigation)

Whether Seabrook is N90's waradigm examele for this rule, or its secret motive for ironesing the rule , it is an examnle i n fact of why this rule should not be adouted. ,

h, M GrdCI0fecI QVNClc h br. Jd6 [M Wehs Eddleman d/t@AS y #1/wIb C[A f2C.B / daOc d56 % g [p @ <-/% -(g [d(d 6 /4 and en behalf of NO Citizens clG q h a Research Groun as its Staff I +- cw &, re gWC[for e ,.,,, M4ddWfl

• kM5/eS.

Sclentist 25 May 1988 * /7'om M / el 124LCe 6& menavh 5 y gg"" "s M% se4 ou+ hwe.,rgggz

... .................-............... g "REVIVAL MOVEMENT" IN RADIATION-LAND Ourg ,-

E I

by Nuc.M 1 John W. Gofman, M.D.,Ph.D., April 1988

%= g[k k

...................................... B s.

G Part of the radiatico coraunity has recently #_ -

M '

been reviving a noticn which it used to concede l was irrespcosble. The notion it is promoting today is that you can be irradiated at low doses g g m p

and not be harmed at all.

4 Revival of the "safe dose" idea has direct

• imlications for the hundreds of millions of individuals who receive low-dose exposure to I icnizing radiation frce medical exams (the new "First, we have to convince the people -

purh for repeated mammograms is an exaw le), from that gocd health isn't everythmg."

cocupaticnal situations (like the atcmic veterans, ard like millicos of military and civilian workers today), and from the mvircnnent The U.S. Govemment has always been (fallout from Chernobyl reaches at least 500 overwhelmingly the source of funds for research aillion people). cn radiogenic cancer, and it eve ccotrols such of the im ortant raw data (for instance, the The tectnical name for this notico is exposure-records of workers at all the naticnal "protection by a safe threshold-dose." This laboratories and of soldiers and naval paper will sMw scientific evidence, including persconel). However, govemmental research funds the very newest, that no harmless threshold-dose are distributed into channels where the exists with respect to causing extra cancer in ecnflict-of-interest is not instantly obvious to tumans. the casual press. The Departments of Energy and Defense ard the National Laboratories are less prceinent than they used to be.

t l 1. WHO IS THE RADIATION COMMUNITY 7 Nowadays, many grants are placed with the Naticnal Academy of Sciences (for the A-bomb survivor study and the BEIR Ccumittee reports, By the term "radiatico community," I mean for instance), the National Cancer Institute l evsrycne who needs to expose other people to low (whose former director, Arthur Uptcn, came free I doses of icnizing radiatico: the entire medical the Oak Ridge Naticnal Laboratory), the I and dental professicn (and most ewhatically, the Envircnmental Protection Agency, medical research I radiology and nuclear medicine specialties), the cm ters, and with countless professors of

! nuclear electric utilities, the uranium business "mvircnmental sciences", "biostatistics",

l and its owners, the U.S. Government (which "physics", and "biology."

spcosors both civilian and military uses of l

I nuclear energy), and all the scientists, These research funds have necessarily regulators, and dose-ocnitors wMse livelihoods, created a tuge pool of spcosor-friendly radiatico grants, or advancements depend cn the good experts. Scme are available for service with the opinico of ttose who need to expose other people radiatico ecumittees, service as expert witnesses to low doses of radiaticn. for defendants in radiatico lawsuits, service running and advising the professimal journals, l Both icgic and observaticn cmfim that and for public educatico via mass media.

l pecple who need to expose other pecole tc, radiatico have a bias in favor of experts who will say such exposures create a negligible amount of radiation-induced human cancer, or " " " " " " " " " " " " " " " " " " " " "

better still, ncoe at all. 2. EXANPLEB OF THE "REVIVAL MOVEMENT" It is inherently unsafe, in tems of health,

""" " "" " " "*"" " - """" " " ="

to let such people @cosor (and thereby ccotrol) e Sept. 27 1988: Bertram Wolfe, President (then) nsarly all the research cn radiation-induction of of the American Nuclear Society: "There is an tuman cancer. It's as if the Tobacco Institute increased risk of future cancer for doses of 100 ccotrolled all the research co the potential Ren and above. . At ruch lower, more cormcn health haza2ds of smoking. radiatico exposures, no clear effects cn health have been found despite more than 40 years of looking." (Article by Wolfe in the DDWER POST, page 48. )

Committee for Nuclear Responsibility e Oct. 27, 1988: Dr. Dixy Lee Ray, former l A .#r aw.cn6.ut errastmio sima 1971 chairpersen of the Atomic Energy Cormissico, pob 11207, San Francisco, CA 94101 charges myself and ' anti-nuclear activists' with disregarding "the extensive and growing evidence Gifu are tax-deductible. that even chrcnic exposure to low levels of radiation causes no damage. ' ( Article by Bay in i

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . the WASHINGTON TIMES, Section H.) 1.

" " - - - - " - " " " " " " " " " " " " " " * = = =

o Augu:t 7, 1987: In the JOUBHAL OF WE AMERICAN M101 CAL ASSN, an invited ' commentary

• artic1s FIGURE W.

entitled "Physician 2' Oblig tima in Radictim Ccnccr-Roto vs. Dono in A-Bomb Studico Issues" was written by Merle K. Loken, M.D.,

Ph.D., frce the Div. of Nuclear Medicine of the University of Minnesota Hospitals. Loken tells

• his huge readership (the emphasis is his own) i that "Effects, whether genetic or sceatic, have *' q been clearly deemstrated ONLY after exposures to .

relatively large doses of radiaticn (usually more ""

than 100 rads).. .In the final analysis, NO DATA

• FICH HUMANS EXIST WAT. SHOW WAT 1DW-LEVEL RADIATION EXPOSURES P1000CE MEASURABLE BIO 1DGIC I 'c8 -

En BUf5." 2 19%.1985 e Fall 1987: U.S. Dept. of Energy report HEALW @ so -

AND ENVIl0HHDffAL CONSEQUENCES OF WE GEPHOBYL 7 so - 192-1982 NUCLEAR ECWER PIET AfrIDIiNT (DOE /ER -0332) put r _

this footnote cn its tables of estimated cancers  : to - t from the fallout: "The possibility of zero health i 199,3973 effects esnnot be excluded." a so -

3 I

e Feb. 1988: Robert E. Alexander, U.S. Nuclear so -

19W'1978 Regulatory Ccemissica, Office of Research, and President of the Health Physics Society, writes .o , , , , , , , , , , ,

about potential cancer and genetic consequences o ea o. . u u i u u of nuclear power accidents, and urges readers Don a s m m a not to eliminate "consideraticn of the

. probability of zero effects, a highly significant

! probability at low doses." (ENVII0HHDffAL SCIENCE l AND TEGNOLOGY, Vol.22: 2: p.144.)

e April 4,1988: Arttur I. Holleb, M.D. , Senior the earlier curve because the 1coger you watch a V.P. for Medical Affairs for the American Cancer fixed group of people, the more cases of cancer

' Society, advocat d repeated =runrrams for weem the people develop.

l during his appearance cn Cable News Network

! (Scnya Friadman program). Discussing the risk of Associated with each curve are four the exam itself causing breast cancer, he said, datapoints, with error-bars. These are the actual

( observaticns reported by the RERF (Be78, Ka82, I "RMiatim exposure has been reduced tremendously Pr88, Pr87). Each curve is the best fit for its since the 1980s and the risk -- if it exists at own four datapoints, by the method of curvilinear all - is negligible."

regressicn. Is curvilinear regression the l Numerous additicnal examples are ecliected scientifically appropriate way to handle such data? Irxieed it is. Essentially no cne disputes l elsewhere (Go88). that the curvilinear regression which provides j

the best fit to the available data also provides

.. .. .................... the soundest idea of what the dose-response is

3. EVIDENCE: LOW-DOSE CANCER-EFFECTS It should be noted that Figure W involves no extrapolation. Curvilinear regression is a Powerful scientific evidence against any tectnique which can take account of the relative safe "threshold-dose" of icnizing radiatico lies reliability of each actual observation and can l in the shape of the dose-response relationship tell you what curve you would be most likely to for radiogenic tuman cancer. see if you had more observations, in between the I

ones which you do have. Curvilinear regressico In Figure W are the dose-response curves interpolates between datapoints and smoothes out which the radiatico ce==nnit r has surely hoped the wobble which comes from the random

! never to see. fluctuations in all measurements.

Those four curves ccndense a mountain of What is self-evident from Figure W is that human evidence as it has unfolded over the years these dose-response curves have neitber the shape in the 1950-1974,1950-1978, and 1950-1982 of a straight line (the linear relaticnship), nor follow-ups of the A-bomb survivors, as well as the direction of bend illustrated in Figure F for 1950-1985 in the new DS88 database ("the new (so-called "concave-upward"). All the curves in dosimetry") whose scientific status is so Figure W have the supra-linear shape (so-called problenatic. "ccncave-, downward" ) .

The curves plot the cancer-rate per 1000 Supra-linearity in and of itself is powerful persons versus internal organ-dose in sieverts evidence not only against any harmless (1 sievert per 100 rems). Where a curve meets the threshold-dose, for the reasons explainM below, vertical axis, the value of the intercept is the but also against additional falsehoods which are spontanecus cancer-rate during that period per promoted by scoe influential oenbers of the 1000 persons. Of course each curve lies above radiation corzunity: 2

But the supra-linser shape of dose-response C ,FALSEH000 1: At emte (instantanecus) 1m in Figurs W tells us something very iwortant:

doses, the risk per sievert of exposure is such radiogenic cancer does not depend on the LESS than the risk at heute HIGH doses, so people interaction of two or more events. The evidence (like Gofman) who use the linear relationship to shows that dose-respmse bends in just the wrong utrapolate from high d 2ses down to low doses are direction for "protection by slow delivery."

exaggerating the cancer-risk at low doses. This This is most notable at the lowest doses.

claim of ten includes disglay of Fantasy Curves, lika the "concave-upward illustraticos in Figure -------= - - - - _ - - - _ - - - - - - - - -

F ("F" for Fantasy). E FALSm000 3: Then is a significant probability of a harmless threshold-dose and ZEE 0 O scIarrIFIC REALITY: Figure W ("W" for Woe) radiation-induced cancer from low-dose exposure, is based on evidence rather than fantasy. It shows that the calculatim of future cancers from E SCIEfrIFIC REALITY: The available evidence, the linear dose-response model will never ocndensed in Figure W, cleuly indicates that (A) ov:r-estimate the number of radiation-induced the most severe cancer hazard per dose-unit cancers from low doses; the linear model occurs at the lowest doses, ard (B) radiation UFDER-ESTIMATES THDL In all the curves, the carcinogenesis is not a "two-hit" or multi-injury steepest rise in cancer-rate occurs closest to phenomenm. What the curves of Figure W suggest the vertical axis - in other words, 'IHE RISK is that radiation carcinogenesis is probably a PER SIEVERT IS 1HE HOST SEVERE AT 'lHE 1MEST single-hit phenomenon - proportional to dose DOSES. Those who claim the opposite usy also (linear) at very low doses, and that as dose claim that black is white, rises, additional carcinogenic injuries in the same cell are siw ly redundant, and injuries which prevent cell-replicatico are also O FALsai0oD 2: Whenever doses are delivered occurring. Under such circumstances, additional slowly, they are less harmful than the same doses dose-units are less and less effective at dalivered instantaneously, so risk-estimates from producing additicnal cancers. Thus the steep the A-bomb survivors have to be reduced whmever slope at low doses turns to a more gentle rise doses are given gradually over time. (less effect per sievert at higher doses).

O scInfrIFIC REALITY: The above claim is not The available evidence does not ocntain even based on any human epidmiologic evidence a hint of a concave-upward dose-respcose; the wh tsoever; the claim is based on speculation Fantasy Curves are fantasies. This should from Fantasy Curves like those in Figure F. discredit the speculation that repair mechanisms are swawed at high doses, but that as dose Protection fece slow delivery of radiation decreases, repair will work better and better, could occur, and probably would occur, if until finally at scee very low dose, repair will radiatico-induced cancer depended cn the work perfectly and deliver a safe threshold-dose intzractico of two or more injuries. As dose below which no radiatico-induced cancer occurs.

went down, injuries would be less closely packed both in time and space, and the probability of Unfortunately, this is NOT what is actually carcinogenic interactico would decrease. If this happening. How do we know? If repair were wers happening, the evider.ce on dose-response working better and better as dose decreases, the would be concave-upward, as explained elsewhere dose-response curves would be ccocave-upward, and (Go81, pp 389-401), would be flat as they approached the vertical axis. But what the evidece stows for dose-l . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . =

respcnse is exactly the opposite. In Figure W, i FIGURE F. the slope - which dwiets the change in Curves with Shapes cancer-rate per sievert - grows steeper and

................"Concave-Upward" ........................

stoeper as the ourvos approach the vertica1 axis.

l The no-threshold meaning of Figure W is independently ecnfirmed by tuman epidemiology in five other studies of exposures at or nearly at the lowest conceivable dose-rate (Go88; Go88).

In view of what I see from the real-world

_ evidence en radiogenic cancer, it would be reckless disregard for the lives of others

1 4=

if I were to favor revival of the harmless threshold-dose.

a-3 ......................................

4. WHY DO EXPERTS DISAGREE ?

l

..................n...................

l People always want to understand why experts i -

disagree. In any field, one must distinguish l between genuine scientists and some experts who o ,,, .,,,,,,,,,,,,,,,,,,,,, ..... .... . ..... ,1 . .

may be overly spmsor-friendly. I'm not at all sure that the respcosible scientists in this Dess field do disagree. Exawles: 3.

- - . - - ~ -. .. - -- - - - - - - .- - -- - - - - - - - - - - - - - -

~

Dr. Edwaad Redford the epidemiologist who.

$jhy .-

GQ h.'v survivore'soolcarlyshowingth'sfalse

• ' kak ohairman cf thetheBEIk-3 their a' .prefsrenon, the radiation oceamittees (BEIR vigorous dissent when NatimalCommittee, Academy of - wrote 80, UMSGG 86) have started to advocate lose Scianoes issaned en mprocedented "recall" of the emphasis-on the lumen epidemiological evidence Ccannittee's report. After the "recall" and. and more emphasis on oell-studies and animal intervention by a escoial new panel appointed by experiments. Ttis amounts to substitaiting the NAS, the Final heport on imizing radiation speculation aboit what the tuman observations came out in 1980 support a concave-upward "cught"'to be showing for what the actual ourve for dose-respmse, ord said, observatims of irradiated humans truly are oorrectly, that the conoave-upward model "has showing! This is me way to stand soience on its already been refuted by the evidenoe." head. ,

Then in 1983, scientists of the A-bomb study

.. , . . . J. : .

One imaet never forget that the real-world published en analysis showing that the evidence evidence ~from whole human beingo is 'always the from Nagasaki (where neutrons were no issue) was ultimate reality-oheck, whether the imeue is consistent with a linear or sopra-linear .a . . imizing radiation, a new '

dose-response, but not with concave-upward (We83). re~===nded martical p tweMe.g.r stical,dora red eal f.' .

.1 masteotomy 'pculd not pass the:tehlity-chsok as a And now, in the very newest report cf A-bomb necessary, taant for small brysist. ),

survivoro (Sh87,.gg29-30), HERP scientists report r.. .@.e Et2 u the dose-repechse invariably" comes out of the W}ir emports appear to' p'about-data looking ooncave-domward (supra-linear) ' - canoer free low-dose radiati

-- .,Mw .. .vv .w

.* *v Mz lip&r n ~4MJ:With res;'ylb * .ME-i[2"'

L 1 Heenshile, thi r,edistion oosemittees'arey'"

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eof tWvival g W.,

l obenging their tune. In the past, they havo w ~ threshold-dose, I think it'reveivesimuppor[bos" ' m l

always emphasized that the shape of the .

almost none~of the scientists who work directly

dose-response curve is the key issue in maaa==ing ' and personally with the human epidemiological low-dose onnoer-hazard, and they have put forth evidence.h After 25 years of interaction with the

('* what I call their Fantasy Curves. The final ' radiatim ocasunity, it is my opinion,that the BEIR-3 report stated that it "preferred" thoes . current "Revival Movement"' originates among shapes. i members 'ofg'he t radiatico -=)ity who are one stage, too, three, foor, five5six stages removed But no one wants to look outrageously from the~ ectual evidence. 3 :.y wrcng. With the tusen evidonoe from the A-bcab '

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REFERENCES e Pr06 Prootm

+ S. Fujita 198E. Dale L. + Hiroo Kato + K.J. Kopecky LIFE SPAM SIUDY REPORT 10, PART o Be78 hha, 0.W. + Hiroo Kato + C.E. Iand 1W8. I CANCER MbRTALITY AMONG A-BWB SURVINORS IM "Studies of the Mortality of A-Bcd Survivors,: 8: HIf0SHIMAAIONAGASAEI 1950-1982. RERF Tectnical Mortality and Radiaticn Does, 1950-1974," RADIATIm Report TR-1-88. (Hiroeltima City: Radiaticn Effects RESEAIG 75: 136-201. Research Fotodaticn.)

o co81 Gofunn J.W. 1981. RADIATION AND HWAN e Pre? Presten Dale L. + D.A. Pieros 1HE HEAL 1H. ISBN 0-87156-E75-6. (San Francisco, CA: - EFFECT OF GAMES IN DOSIMFTRY ORTALITY N CANCEk )198 RISK ESTIMA11tS IN THE A10NIC BCDS SURVIVORS. RERF Sierra o Go88 Club Gofman Books.)W.

J. 1988. "A-ing Chemoby1's Tectnical Report TR-9-M. (See Pr06 above.)

Cancer-Ccmsequen,ces: licaticn of Fcur ' Laws'of

• Sh87 Shinusu Y. + Hiroo Kato + W.J. Sctull +

Radiation Carc ." at the symposium IDW-LEVEL D.L. Preston + S, Fujita + D. A. Pierce 1987. LIFE RADIATIN , ,1988 at the Naticnal' Meeting of SPAN S!UDY REFORY 11. PART I. 000fARISdM OF RISK th3 American ical Society. CDEFFICIENTS POR SITE-SPIEIFIC CANCER MORTALITY BASED e Go88 Gofman J.W. W 1HE DS8B AND T850 SHIEIDED KEINAS AND OMAN FIG IDW-COSE EIPOSURf:1988. AN INDEPHOENT RADIATIW-INDUCED AMALYSIS. In CANCER DOSES. RERF Tectnical Report TR-12-87. (See Pr08 rees. ISBN 0-932882-88-I. (San Francisco, CA: GR above.)

Inc.) e Ws83 Wakabayashi, T. + H. Kato + T. Ikeda + W.J.

"Sta. diesKato of t$eHiroo + William J. Sctull 1982 .7:

e Sctull,1983. "Studies of the Mortality of A-Bcab Mortality of A-Bomb Survlvors: Report 7, Part 3. Incidence of Cancer in Mortality, 1950-1W8: Part I Cancer Mortality," Survivors, 1959-1978, Based on the Tumor Registry, Nagasaki,"

RADIATIN RESEAfG 90: 385-4b2. RADIATIW RESEAfCH 83: 112-148. 4.

_ - . - - . . _ _ . . . . _ . _ _ _ , - __ ___.~._._ _ _.. - _ - - -- - - - - -