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The Greening of Nuclear Power and
The De-Regulating of Nuclear Waste:
Four Key Facts Which Need Attention

By John W. Gofman, M.D., Ph.D., November 1990





          Only a visitor from Mars, recently arrived, could fail to have noticed the intense and accelerating campaign in this country to revive nuclear power. Reporters, professors, students, and friends have asked me for a prediction:

          "What is your hunch about the outcome? Thirty years from today, will there be massive numbers of new nuclear power plants around the world?" And my answer is: "The outcome will depend very much on whether truth about health effects prevails or fails."

          This answer may surprise people, because it may sound as if I am unaware of obvious issues like prices, like the cost of alternatives (energy efficiency, renewable energy sources), like concern over air pollution, global warming, and energy independence. Far from it. I am just stating a self-evident point which is surely well appreciated by the nuclear industry.



 *   -   What the Nuclear Industry Knows:

          The opposition to nuclear power arises almost exclusively because of its menace to genetic integrity and health, a menace which will persist for hundreds and thousands of years after the electric plants are gone. If the nuclear enterprise were able to convince people that nuclear pollution does not matter -- by convincing them that low-dose ionizing radiation represents a trivial or even non-existent health hazard -- then opposition to nuclear power would fade away.

          Furthermore, such a public belief would simultaneously reduce the cost of nuclear power a great deal, by reducing the cost of containing its radioactive by-products during plant operations. For instance, today there is insistence on a host of costly measures to try to prevent escape of radionuclides into the environment during routine operations and during accidents. If low doses were to be safe, why bother? Many containment efforts would disappear, and the price of nuclear power would become more nearly competitive. This would help its revival a great deal.

          Public belief in a trivial or non-existent health hazard would also greatly reduce the cost of containing radioactive waste after operation of nuclear plants. Obviously, if the public were to believe that nuclear pollution were harmless at "low levels," why would anyone worry about short-term or long-term containment of "low level" nuclear waste? Opposition to de-regulating disposal of such waste would disappear, and such waste would go right into thousands of local landfills and incinerators.

          The U.S. Nuclear Regulatory Commission, which is presently promoting a de-regulation policy called BRC or "Below Regulatory Concern," overtly states one purpose: To reduce the cost of handling waste and of cleaning up contaminated areas (NRC Policy Statement, June 22, 1990, p. 1).

safe, safe, safe, ...           In short, the health effects of low-dose ionizing radiation have everything to do both with the strength of public opposition to nuclear power, and with the cost of nuclear power. And the nuclear industry knows it. Potential health effects from nuclear power are the main obstacle to the "greening" of nuclear power as an acceptable energy option for the world's future.

          And that is why I am convinced that the outcome of the effort to revive nuclear power "will depend very much on whether truth about radiation health effects prevails or fails."

          A key point, of course, is that there is no necessary connection between the truth about health effects and eventual public perception of health effects. Truth is whatever it is, even if no one perceives it, whereas beliefs can be molded and influenced.

          Therefore the current effort to win public approval for a resurgence of nuclear power comes at the same time as a great effort to shape a future public perception that low-dose radiation is no problem. This effort is particularly directed at opinion-making professionals and professors.

          The BRC policy itself is an important part of the effort, for it creates unlimited occasions (testimony, symposia, papers, journal editorials, etc.) for persuading policy-makers and public opinion-makers that low-dose ionizing radiation amounts to a trivial or possibly non-existent health hazard.



 *   -   A Self-Defeating Illusion:

          Among some of the many marvelous citizen-activists who work tirelessly and effectively against nuclear pollution and all of its sources, we have encountered the belief that they do not need to focus on radiation health-effects "because everyone already knows that radiation is bad for you. If we just show that nuclear pollution has occurred or can occur, the public supports us." And that has been true in recent years.

          When we warn that the most vigorous and comprehensive effort of all time is getting underway to change public opinion about the hazard of low-dose radiation, some have responded, "But people will never believe that any amount of radiation is safe." And when we inform them that a campaign is growing to suggest that a little radiation is good for health (the next medical specialty to develop could be treatment of "radiation deficiency syndrome"), they are flabbergasted. "No one will ever believe radiation is good for you!"

          We think such responses reveal a perilous amount of illusion. In contrast, history has proven again and again that persistent misinformation has a very good chance of succeeding unless it is vigorously countered with real facts.



 *   -   Key Fact #1 :   Reasonable Risk-Estimates

          Reasonable risk-estimates for radiation-induced cancer from nuclear pollution are 6 to 30 times higher per rem of dose than the current estimates from such quasi-official radiation committees as BEIR-5 and UNSCEAR-88. Realistic estimates are developed in INDY [1], step by step, using the data from the Atomic Bomb Survivors. BEIR and UNSCEAR also rely on the A-Bomb Survivors -- up to a point. Then in complete defiance of the human evidence, they divide what the evidence shows by 2 to 10 if a low dose is slowly received -- as are doses from nuclear pollution.


  1. INDY refers to the book Radiation-Induced Cancer from Low-Dose Exposure:   An Independent Analysis, by J.W. Gofman. 1990, First Edition. 480 pages. Library of Congress 89-62431. ISBN 0-932682-89-8. Available from the Committee for Nuclear Responsibility. US $29.95. No extra fee for normal shipping.

          My own best estimate, adjusting the A-Bomb data for a U.S. population, is a lifetime risk of fatal cancer of 26.6 fatal cancers per 10,000 persons each receiving a dose of 1 rem to the whole-body. This value applies to doses which are spread over time as well as to doses received all at once. In most reports (not in INDY), all the words are omitted and such a risk would be expressed as a risk-value of 26.6 x 10^-4/rem.

          By contrast, after the "2 to 10" division, the comparable BEIR-5 risk-values range from 0.86 to 4.28 fatal cancers per 10,000 persons each receiving 1 rem of dose to the whole body (INDY, p.25-12). The comparison with my own estimates is obtained by divisions: (26.6 / 0.86) = 30.9-fold, and (26.6 / 4.28) = 6.2-fold.

          Sometimes the difference between my estimate and BEIR's much lower estimates is called "the range of responsible analysis." I have trouble extending the term "responsible" to analyses which (A) override what the human evidence shows, and (B) substitute non-human evidence for human data of good quality. INDY shows how my reservation applies to the BEIR-5 Report on this issue of low doses slowly received.

          Nonetheless, a major environmental group in Washington DC is using only the BEIR-5 and derivative Nuclear Regulatory Commission risk-values. Why? The group has told us, "We are using the BEIR-5 risk-values even though we don't understand how they were derived, because we won't have to defend them. No one will challenge us if we use them."

          If major environmental groups become indifferent as to whether they are using scientifically valid or invalid numbers in their statements about nuclear pollution and Below Regulatory Concern proposals, there will be little hope for truth prevailing in the battles ahead.



 *   -   665,000 Radiation-Induced Fatal Cancers, and More:

          Using a scientifically realistic estimate like 26.6 cancer deaths per 10,000 person-rems, we can illustrate the meaning of intentional nuclear pollution policies like BRC or Below Regulatory Concern. At the moment, the Nuclear Regulatory Commission proposes that each de-regulated dumping activity be allowed to deliver a population dose up to 1,000 person-rems every year. Our numbers mean that this would be permission for each dumping activity to inflict 2.6 fatal cancers among the public every year.

          As for the aggregate population dose from thousands of un-regulated (and probably unknown) dumping activities, it is pure deception if anyone suggests that policy-makers can know in advance how big the actual combined dose to the population would really become. De-regulation would mean an increase in population doses to unpredictable levels.

          Suppose nuclear pollution were to rise, perhaps unintentionally, to levels which would give an extra average dose of 0.1 rem (100 millirems) each year to the whole U.S. population of 250 million persons:

          Dose = (250 million persons) x (0.1 rem)
                   = 25 million person-rems.

          Fatal cancers = (26.6 cancers / 10,000 person-rems) x (25,000,000 person-rems) = 66,500 radiation-induced fatal cancers from each year of such exposure. This would mean 665,000 radiation-induced fatal cancers from 10 years of such extra exposure, and 1.33 million radiation-induced fatal cancers from 20 years of such extra exposure, etc. So we repeat a warning from INDY:

thumb squeezed           "People of goodwill need to look closely at the aggregate consequences of individually small risks. If pollution sources of all types are regulated individually, and each is allowed . . . to kill one person in 100,000 (a low individual risk), then only 10,000 sources could kill up to one tenth of the population. And no one would ever be able to prove it."



 *   -   Shaping the Public's Perception of Whom to Trust:

          Over the years, much of the public has come to recognize that conflict of interest is as big a problem in science as it is in politics, business, journalism, and law. Scientists want to avoid offending those who sponsor their research, their livelihoods, and their advancements. Scientists, like others, can feel tempted to bend the rules, interpret the facts in a sponsor-friendly manner, or self-censor their reports when that is the only way to advance their own interests. Human nature was not suspended for scientists.

          The corruption of science by conflict of interest has become such a problem that the problem is now admitted by universities, professional journals, and government alike (see INDY, Chapters 2, 5, 24). This fall, Arthur Caplan, director of the Center for Biomedical Ethics at the University of Minnesota, said (San Francisco Examiner, Sept. 9, 1990, p.A-8):

          "Why are [scientists] able to be any more objective in the face of the lure of money than the journalist or the educator or even the businessman? Conflict-of-interest problems are everywhere." In the same article about biomedical research, Dr. Arnold Relman, editor-in- chief of the New England Journal of Medicine, warned:

          "Conflict of interest is a big, big problem and getting bigger. It doesn't often cause people to cheat, but what it can do, in a very subtle and unconscious way, is bias their design and analysis and interpretation of results."

          The conflict of interest in radiation research cannot be denied. Professions, industries, and governments which expose people to radiation are the funders of research about the health hazards. This reminds us of a vampire guarding the blood bank. It should surprise no one if the result is an artificial consensus of scientists on one side of the hazard-issue, and an extreme shortage of scientists willing and able to challenge them. From one of the latter came a familiar tale this year.

          On Feb. 23, 1990, the Columbia (SC) State newspaper reported the public testimony of Dr. Gregg Wilkinson, a radiation epidemiologist formerly at the Los Alamos Lab -- a lab supported by the Dept. of Energy (DOE). Testifying about his 1986 analysis which showed disturbingly high rates of some cancers among workers at DOE's Rocky Flats plant, Wilkinson said:

          "There was very definite pressure from several sources within the Dept. Of Energy to, if not withdraw results from that study, to change the findings or the interpretation." Wilkinson added that he was told, "If these statements are true, this will shut the nuclear industry down." Wilkinson also testified that he was warned by a deputy director of the lab, "We should not be trying to please peer reviewers, but rather we should be publishing to please the Dept. of Energy . . . a customer of ours."

          During years of pressure from citizen-groups who protested against conflict of interest in radiation research, some nuclear officials agreed to let funding for much of such research be transferred from the most obvious nuclear promoter -- the U.S. Atomic Energy Commission (AEC) or Dept. of Energy (DOE) -- into other federal departments: NRC, EPA, NCI, CDC, NIOSH, etc. This provided no solution, in my opinion. All government agencies and government-supported institutions are just fingers on a single hand.

          In the coming years, we must expect many efforts to deny that conflict of interest may influence some claims which are made.

     * - USEFUL PUBLIC PERCEPTION in the "greening effort":   Despite the past, now the public can trust government-sponsored risk analyses because the Dept. of Energy is no longer in charge of everything. The conflict of interest problem in radiation research has been solved.

     * - REALITY:   Nothing has been solved with respect to the conflicts of interest which characterize radiation research. When the government is committed to helping the nuclear enterprise in every way, those who distribute and those who receive the government's research money unavoidably know which results will be welcome, and which may get them into "hot water" -- regardless of which initials the agency wears.



 *   -   Mis-Shaping Public Perception of a Key Event:

          When the BEIR-5 Report on radiation was issued (December 19, 1989), a press release was also issued emphasizing that the BEIR-5 Committee had raised its cancer risk-estimates by 3- to 4-fold over its previous estimate in 1980. Surely, then, this committee must be independent of the radiation community and credible, despite its government funding.

          Newspapers and journals spread the word from coast to coast: "A prestigious committee of the National Research Council has found radiation to be much more harmful than previously thought" -- and they overlooked a caveat found far back in the press release. Not surprisingly, but very sadly, citizen-groups joined the refrain in their own statements.

          Only later did such citizen-groups recognize what the BEIR-5 Report really means: We, the BEIR Committee, raise the Committee's previous estimate by 3-fold for radiation-induced solid cancers if the dose is received all at once, but if the dose is received slowly, then divide our new estimate by 2 to 10.

          By invoking this "2 to 10" division -- which is completely at variance with the direct human evidence -- the BEIR Committee is providing new risk-values for nuclear pollution which can be the same as, or even much lower than, BEIR's previous 1980 risk-values. The "greening" of nuclear power will be assisted by these low risk-values, since the public will not be aware of the methods which produced them.

          Could anyone be surprised if the nuclear industry might be eager to sell the BEIR-5 Report as "the gold standard" concerning estimates of radiation health hazards? It is unfortunate for public health that various citizen-groups have helped the sale. Not only does the BEIR-5 Report permit large underestimates in the cancer-risk from nuclear pollution, but it also states (p. 181): "The possibility that there may be no risks from exposures comparable to external natural background radiation cannot be ruled out."

     * - USEFUL PUBLIC PERCEPTION in the "greening" effort:   The government-funded BEIR-5 Committee proved its objectivity when it raised its previous risk-estimates.

     * - REALITY:   With its recommended division by "2 to 10, " the BEIR-5 Committee avoided the necessity of raising its previous risk-estimate for low-slow exposures;   the current risk-estimates from the BEIR-5 Committee which apply to nuclear pollution, occupational exposures, and many medical exposures, are 6-fold to 30-fold underestimates relative to my own estimates based on direct human evidence. If the nuclear industry finds it can use the 6-fold underestimate, and even can secure the blessing of major environmental groups, it may move toward using the 30-fold underestimate available from BEIR-5.



 *   -   Key Fact #2 :   No Safe Dose or Dose-Rate

          Proof already exists that there is no safe dose or dose-rate of ionizing radiation. In other words, there is no threshold level below which the risk of radiation-induced cancer disappears. The human evidence and its analysis are laid out for all to see in Chapters 18 through 21 of INDY. Contrary to claims by the radiation community that it is impossible to know what happens at low doses, the mainstream professional literature already provides good human evidence of cancer-induction by the lowest conceivable doses and dose-rates. The same evidence implies (but does not prove with quite the same conclusiveness) that there is no safe dose or dose-rate with respect to heritable genetic injuries.

Take Out The Garbage!

          The evidence which permits the disproof in INDY of any safe dose or dose-rate is not new. It has simply been ignored by the radiation community, which keeps repeating: "We don't know what happens below doses like 10 rems. We don't know that there is any injury at all, especially if such doses are received slowly." Since nuclear pollution generally involves population doses slowly received at doses well below one rem per year, such statements are extremely helpful to the "greening" of nuclear power. Such statements are seen more and more often. Examples include the BEIR-5 Report, p. 181 (full quote in INDY); Journal of the American Medical Assn, August 1, 1990, p.623; and National Cancer Inst. Report #90-874, July 1990, p.7.

          The DOE and NRC speculate about a safe dose or dose-rate, and imply that they are being cautious if they "count" any cancers at all from nuclear pollution. They do not concede that any really occur. Examples include DOE's report on Chernobyl, in Science magazine, Dec. 16, 1988 (quoted in INDY); NRC Policy Statement on "Below Regulatory Concern," July 13, 1990, p. 13 -- citing the BEIR Committee.

          INDY documents our statement that "Some segments of the radiation community appear to believe passionately that no one should impede the nuclear enterprise on the basis of what they label as speculation and conjecture about injury from low doses and dose-rates. Instead, they ask the world to accept their speculation and conjecture that low doses and dose-rates are safe -- a notion which would surely result in increased exposures" (INDY, p.24-19).

          In INDY, we also commented on proposals of the nuclear enterprise to exclude some low doses entirely from risk-benefit analyses -- proposals which amount to claiming that a safe dose or dose-rate has been proven. Under such an approach, most doses (and thus most cancers) even from the Chernobyl accident would disappear from analysis. The assist which this would provide for the "greening" of nuclear power is self-evident.



 *   -   Media Assistance with the Safe-Dose Suggestion:

          During the massive reporting in July 1990 about the radioactive pollution released from the Hanford Reservation in Washington, media accounts commonly featured the idea that this was the Department of Energy's first admission that the doses "may have exceeded the safe level." The press did not ask, "What safe level? Where is the evidence for any safe level?" Instead, the press unintentionally served as a transmission belt for the "safe level" suggestion.

          The cleverness of the government's media effort is another warning to citizens who wish not to be poisoned. DOE, by admitting that it has violated the "safe level," builds the image of saintliness, reform, and contrition in the public's perception while simultaneously selling the false idea that some "safe level" exists.

          The media (again unintentionally) also was exceptionally helpful with the safe-dose idea regarding the Chernobyl accident. The word "Chernobyl" was seldom written or uttered without calling it "the nuclear accident which killed 31 people." Although it was also described as the accident which spread fallout all over Europe, the meaning of this fact in terms of additional fatalities from Chernobyl- induced cancers was almost never mentioned. Thus public perception was nudged in the direction of regarding the fallout as having no health effects.

     * - USEFUL PUBLIC PERCEPTION in the "greening" effort:   There is a safe level of ionizing radiation, and even the worst sorts of nuclear accidents may kill very few people.

     * - REALITY:   Chernobyl fallout will continue to irradiate people for over a century. A scientifically reasonable estimate of Chernobyl-induced cancers, occurring in Europe and the USSR during the next century and beyond, is about 475,000 fatal cancers. This huge number, however, will be rendered undetectable by the far greater number of cancer-deaths which will arise in these countries from other causes over the same time-span. But the existing proof in INDY that there is no safe dose or dose-rate means this:   The Chernobyl-induced cancers will not be "hypothetical" or "mere conjecture." They will really occur.

     * - ANOTHER ASPECT OF REALITY:   It is not more acceptable to inflict death an a half-million people scattered over time and place than to inflict death on a half-million people in a brief period in one city. Killing is killing. But if the deaths are scattered and unseen, it is far easier to mold public perception than if the deaths are seen. As pointed out in INDY if the winds and rains had happened to dump most of the Chernobyl fallout into the city of Kiev, the increase in fatal cancers would be seen. But seen or unseen, the Chernobyl-induced cancer deaths will be real.



 *   -   Key Fact #3 :   Not Safer Than We Thought

          When an inadequate study of a presumably exposed population fails to find a provable excess of cancer, the study is not evidence of a safe dose or dose-rate. Long ago, we pointed out the difference between "No effect observed" versus "No effect occurred." Even leading members of the radiation community concede this point (see INDY, Chapter 21). Nonetheless, it was very helpful to the "greening" of nuclear power when the following headline appeared:

          "Study Denies Living Near Reactors Is Risk To Health" (San Francisco Chronicle, Sept. 20, 1990). This headline referred to release of a study by the National Cancer Institute (NCI) entitled "Cancer in Populations Living near Nuclear Facilities," NIH #90-874 (in three volumes), July 1990.

          We are studying all three volumes. Meanwhile, we can state categorically that the NCI study in no way supports the concept of a safe dose or dose-rate of ionizing radiation.

          One must expect a whole series of similar reports to be issued by the radiation community, publicized even further by the vast resources of the nuclear enterprise in its "self-greening" effort, and solemnly used for guest editorials in medical and scientific journals.

     * - USEFUL PUBLIC PERCEPTION in the "greening" effort:   Nuclear power is a lot safer than we thought. If there were any cancer effects, the National Cancer Institute (NCI) would have found them.

     * - REALITY:   Even the NCI Report did not make any such claims. The public should not be misled by publicity generated for the kinds of studies which should not and will not find any excess cancer.



 *   -   Key Fact #4:   Unknown Doses from Nuclear Pollution

          The magnitude of doses to date from nuclear power has never been independently evaluated. However, newspapers and magazines commonly carry the familiar "pie-chart" supplied by the radiation community in which average U.S. doses from nuclear power are alleged to be less than 1 millirem (0.001 rem) per year. By comparison, average doses from natural background radiation are alleged to be the equivalent of about 300 millirems (0.300 rem) per year.

     * - USEFUL PUBLIC PERCEPTION in the "greening" effort:   Nuclear pollution is a trivial issue.

     * - REALITY:   A de-regulation campaign is underway which can drastically increase levels of nuclear pollution to unpredictable levels. Moreover, validation of the "pie-chart" dose estimate for nuclear power is non-existent. Nuclear utilities are the source for data on how much radioactive pollution is released at their power plants. Until more citizen-groups achieve their own monitoring and measuring networks, there can never be an independent check on any figures or claims about the doses from nuclear power.

          Meanwhile, if we presume that average doses from nuclear pollution are really much smaller than average doses from natural background sources, this presumption would provide no justification whatsoever for increasing nuclear pollution.

          Our analysis in INDY leads to the conclusion (Chapter 25) that low-dose ionizing radiation -- including the natural doses -- may account for 1 out of every 4 cancer deaths. It would be outrageous to increase rather than decrease exposures to such a carcinogen. Indeed, since children are much more sensitive than adults to radiation carcinogenesis, it would be a very good idea to reduce childhood exposure to natural background radiation (for instance, from radon, from certain building materials, from frequent flying). Any campaign which implies that it would be OK to let nuclear pollution add to such doses would be a literally deadly disinformation campaign.



 *   -   Your Achievement of an Encouraging Track-Record

          In an effort to "green" nuclear power by denying its menace to health, we all must expect a barrage of additional perception-molding moves. Panic seems to be occurring among the nuclear advocates, as they realize that the scientific evidence has mounted strongly in opposition to their claims. The stronger the evidence grows, the more shrill the nuclear advocates may become.

          Citizen-activists can have confidence, however, for you have succeeded in the past -- despite poor odds and unfair circumstances -- to educate the public well about the menace of low-dose radiation. Citizen-activists -- certainly not the government nor the professional societies -- achieved the public education with which the nuclear enterprise is now trying to cope.

          John Morley, the English statesman and writer (1838 - 1923), has stated that "It makes all the difference in the world whether we put truth in the first place, or in the second place." Most citizen-groups, mindful of Morley's statement, have a track-record of shaping a correct public perception which is consistent with scientific reality on the radiation issue.

          We know it is not fair that you should have to continue this work year after year, but so far, humanity has failed to devise any system which automatically delivers fairness. Quite the opposite. Injustice, deception, and tyranny automatically prevail when good people do nothing, as Edmund Burke pointed out so well. Unless citizens continue to disseminate truth about health effects, misinformation on health effects will prevail . . . and nuclear power will revive worldwide . . . and nuclear pollution (not just accidental, but also intentional) will escalate to unpredictable levels.

          Someday humans may solve the "automatic justice" problem. Meanwhile, can we afford to poison the planet irreversibly?

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