================================================================== ------------------------------------------------------------------ Seven Comments on Proposed Radiation "Standards" for the Yucca Mountain Rad-Waste Repository: October 26, 1995 TO: NAS Report Comments Radioactive Waste Management Branch (6602J) Office of Radiation and Indoor Air US Environmental Protection Agency 401 "M" Street, SW; Washington DC 20460, USA. FROM: John W. Gofman, M.D., Ph.D. Professor Emeritus, Molecular & Cell Biology, U.C. Berkeley. Assoc. Director, Livermore National Laboratory, 1963-69. Co-discoverer of uranium-233 and its fissionability. Author of 4 books on health effects of ionizing radiation. Post Office Box 421993; San Francisco CA 94142, USA. 1. Predicting "Repository Behavior" for Thousands of Years 2. "The Rule of 1,000" in Predicting Health Effects from the Repository: The Tragedy of Common-Size Mistakes 3. Alleged "Consensus" for Killing One out of Every 2,000 People with Rad-Waste 4. Fallacy of the Safe Dose Invoked by the YMS Committee 5. An Inconvenient Axiom: If the Sum of Pollution Matters Biologically, Then Each Contribution to the Sum Matters 6. Too Much Trust? Too Many Good Manners? 7. More Radiation Experiments on the Citizenry? References NOTE: Page numbers in these comments refer to "Technical Bases for Yucca Mountain Standards," a 1995 report from the National Research Council's Board on Radioactive Waste Management, Committee on Technical Bases for Yucca Mountain Standards --- which I will call "YMS Committee" for brevity. The repository means the proposed Yucca Mountain burial site for radioactive waste (rad-waste). References are listed at the end. ================================================================== * - POINT 1. Predicting "Repository Behavior" for Thousands of Years * - The peak risk from ionizing radiation might occur "hundreds of thousands of years or even farther into the future" from Yucca Mountain, according to the YMS Committee (p.2). * - The YMS Committee explicitly endorses the assumption of the Envir. Protection Agency, Nuclear Regulatory Commission, and the Dept. of Energy that "scientifically justifiable analyses of repository behavior over many thousands of years in the future can be made" (p.1). This claim depends on the capability to assess --- correctly --- "the probabilities and consequences of modifications by climate change, seismic activity, and volcanic eruptions at Yucca Mountain" over the next million years (p.9). * - Comments: I think sane people must doubt that anyone today has such capabilities in the specificity required, even for relatively short time spans. The record with unplanned contamination, from already existing waste-storage efforts, certainly does not support the breathtaking arrogance endorsed by the YMS Committee. ================================================================== * - POINT 2. "The Rule of 1,000" in Predicting Health Effects from the Repository: The Tragedy of Common-Size Mistakes * - The YMS Committee speaks of "adverse health effects from releases from the repository" (p.4), and claims that it is possible to predict the magnitude of adverse effects from Yucca Mountain (pp.4-10). * - Comments: Nasty "surprises" occur in all human efforts --- from collapsing bridges, to an exploding space-shuttle, to already leaking rad-waste sites, to the ruination of the Three Mile Island nuclear plant. All have occurred despite expert opinions to the contrary. Murphy's Law can not be repealed by any committee. * - Adverse health effects on humans from rad-waste storage depend on many variables. For simplification, we will mention only three. First is how much rad-waste escapes in reality. Second are the actual transfer-factors in the environment in the pathways to human exposures. And third are the adverse effects per unit of radiation dose received by humans. * - It is not unusual for expert estimates to be "off" by one order of magnitude (ten-fold). So, before even considering rad-waste burial which could become irreversible rather promptly, responsible advisors and advisees would assume: (a) that subsequent escape of radioactive poisons will turn out ten times greater than predicted (very plausible, in light of experience); (b) that transfer-factors in the biosphere will turn out ten times greater than predicted (very plausible in view of vast uncertainties in the literature); and, (c) that health-effects per unit dose will turn out ten times greater than the so-called current consensus predicts (very plausible --- see Part 3, below). * - It is hardly far-fetched to consider that the adverse health effects from Yucca Mountain (and from other sources of potential nuclear pollution) could be 1,000 times greater than predicted. * - How could the YMS Committee, if objective, fail to discuss such a possibility in its Executive Summary? Surely the YMS Committee can not rule out 10-fold underestimates in ANY of the three factors of our illustration. Therefore, the YMS Committee has a duty to discuss the health consequences of such underestimates. * - What are they? "The Rule of 1,000" means that the consequences of nuclear pollution could be fatal radiation-induced cancer for at least HALF of an exposed population, if today's experts turn out to be wrong just by factors of ten on a FEW key assumptions. * - Who says so? The 1990 BEIR-5 Committee of the National Research Council, and Gofman 1990. See analysis in Point 3, below. ================================================================== * - POINT 3. Alleged "Consensus" for Killing One out of Every 2,000 People with Rad-Waste * - The Committee claims (p.4) that "a general consensus exists among national and international bodies on a framework for protecting the public health that provides a limit of 1 millisievert (100 millirems) per year effective dose for continuous or frequent exposures from all anthropogenic sources of ionizing radiation other than medical exposures. A general consensus also appears to exist among national authorities in various countries to accept and use the principle of apportioning this total radiation dose limit ... typically allocating to high-level waste disposal a range of 0.1 to 0.3 mSv (10 to 30 mrem) per year." * - Comments: Let us consider 20 extra milli-rems per year (0.02 rem, or 0.02 cSv). Is this public health protection? We will compare the estimates of the 1990 BEIR-5 Committee of the National Research Council with my own 1990 estimates for an annual extra population dose of 0.02 rem per person every year. * - BEIR-5 (p.172, Table 4-2, non-leukemia columns, middle section for "lifetime exposure to 0.1 rem/year)": 495 extra fatal radiation-induced cancers per 100,000 people if we assume equal numbers of males and females. If BEIR-5 assumes a dose-rate effectiveness factor (DREF) of two, its estimate falls to 248 extra fatal cancers per 100,000 exposed people, which is one out of every 400 exposed people. The estimate at 0.02 extra rem per year would be 5 times lower, or 1 out of every 2,000 exposed people (leukemia excluded). * - Killing at this rate is hardly "negligible" and would certainly not be public health protection. It would be premeditated random murder on a very large scale. Why is no one warned by the YMS Committee's Executive Summary? * - Gofman 1990 (Table 16-C) estimates 27 extra fatal radiation-induced cancers per 10,000 persons of mixed ages, each receiving one extra rem of whole-body dose at any dose-rate. "Lifetime exposure" to an extra 0.1 rem/year for 70 years = 7 extra rems. Such extra exposure would cause (27 extra fatal cancers x 7) per 10,000 persons, or 189 fatal radiation-induced cancers per 10,000 persons. This is one out of every 53 people. The estimate at 0.02 extra rem per year would be 5 times lower, or 1 out of every 265 exposed people. This would be premeditated random murder on a truly massive scale. * - It is amazing that the YMS Committee's report fails to issue explicit warnings based on either the 1990 BEIR-5 or the Gofman-1990 estimates of cancer consequences from the so-called "consensus" limit on population exposure by high-level waste storage. In the above quantifications, heritable effects would be additional. The "Woops-We're-Sorry" Estimate * - And what if the so-called "consensus" involuntary extra dose of 0.02 rem per year actually turns out to be an average of 20 rems (20 cSv) per year, due to operation of "the Rule of 1,000"? The BEIR-5 risk-estimate would rise to 1,000 fatal radiation-induced cancers for every 2,000 exposed people, or radiation-induced death for HALF the so-exposed population. The Gofman-1990 risk-estimate would rise to a level meaning fatal radiation-induced cancer for the ENTIRE so-exposed population. * - It is up to the YMS Committee and the EPA to show conclusively that this can not happen, before any irreversible actions are taken at Yucca Mountain and other rad-waste burial sites. ================================================================== * - POINT 4. Fallacy of the Safe Dose Invoked by the YMS Committee * - The YMS Committee claims that radiation standards for Yucca Mountain "would protect public health ... provided that policy makers and the public are prepared to accept that very low radiation doses pose a negligibly small risk" (p.7). * - Two paragraphs later, the Committee suggests that perhaps there are "no effects" from "very small incremental doses of radiation." For this suggestion, the YMS Committee cites the BEIR-5 Report --- selectively. It is true that BEIR-5 (p.181) says that "epidemiologic data cannot rigorously exclude the existence of a threshold in the millisievert dose range." [100 milli-rems per milli-sievert]. * - As an interesting omission, the YMS Committee fails to cite BEIR-5 (p.4) making another statement: "The new data do not contradict the hypothesis, at least with respect to cancer induction and hereditary genetic effects, that the frequency of such effects increases with low-level radiation as a linear, nonthreshold function of the dose." * - Comments: The YMS Committee is propagating the speculation that there is a safe threshold dose or dose-rate of ionizing radiation below which there are no adverse health effects. That speculation has been disproven in Gofman 1990 with a combination of mainstream human epidemiology and nuclear track-analysis --- not by epidemiologic data alone. * - The same analysis (Gofman 1990) also disproves the speculation that low doses of extra radiation might be good for human health, which is the so-called "hormetic hypothesis." The "hormetic hypothesis" was recently propagated by a source with four EPA experts prominently displayed on its advisory committee (see Belle Newsletter 1994). * - As an integral part of this statement, I attach a 4-page abbreviated summary of my disproof of any safe dose or dose-rate for ionizing radiation. The summary is entitled: What Is Factually Wrong with This Belief: "Harm from Low-Dose Radiation Is Just Hypothetical --- Not Proven." * - We are unaware of any refutation of our 1990 analysis. On the contrary, the 1993 UNSCEAR Report (especially pages 627-636, p.681, p.696 Table 17) quite explicitly validates the method which we used. The 1994 Belle Newsletter does not even attempt to refute our analysis. Position of Britain's National Radiation Protection Board * - It is also of interest that on October 16, 1995, the London Times carried a story by its science editor (Nigel Hawkes) headlined Radiation Level "Is Never Safe." It refers to a new report (not yet in my hands) supporting the view that there is no harmless level of radiation. The new report is by Britain's National Radiation Protection Board (see NRPB 1995). The newspaper quotes Dr. John Stather, assistant director of NRPB, as follows: * - "Low radiation doses --- even extremely low doses --- have an associated risk which increases with increase in dose. The risks may be considered unimportant when compared with other risks of living, but they are not zero." Position of the Natl. Research Council on Orwellian Science * - No realist would deny that efforts continue to exonerate low-dose ionizing radiation from doing any harm. This goal can be easily achieved by two practices already in operation. * - The first practice is conduct of radiation health research without equal funding for parallel research by independent "watchdog" scientists. The present system is so riddled by conflict of interest that there will soon be almost no data worthy of trust, until an independent "watchdog" system becomes the established "norm" in radiation research, worldwide. * - The second practice is perpetual, retroactive alteration of the input to such studies as the A-Bomb Survivor Study. This assault against the fundamental rules of science invites the entry of bias into the results, yet is has been endorsed by the National Research Council's BEIR-5 Committee and now by the National Research Council's YMS Committee (at page 4). * - How can any arm of the National Academy of Sciences endorse such Orwellian practices? How can the Academy tolerate such behavior? ================================================================== * - POINT 5. An Inconvenient Axiom: If the Sum of Pollution Matters Biologically, Then Each Contribution to the Sum Matters * - The YMS Committee treats nuclear pollution from Yucca Mountain as if the burden which it imposes on public health should be evaluated in isolation (p.3). * - Comments: The practice of evaluating risks from separate sources of nuclear pollution without regard to the global totality of such sources is reckless and unethical. * - Why? If the totality of irreversible nuclear pollution matters biologically --- and the absence of any threshold means that it definitely does matter --- then the separate contributions which compose the totality can never be "negligible." Moreover, if the evidence showing no threshold were still unavailable, decent policy-makers worldwide would have a duty to insist, emphatically and publicly, upon the ASSUMPTION of no threshold (see Point 7). * - The YMS Committee needs to emphasize to its readers a fact which governments try to hide: Even a very low level of risk per individual has immense, real, and tragic consequences in the AGGREGATE, when that low level of risk is "permitted" for billions of people via "standards" for worldwide nuclear pollution. See Point 3. * - It is worth noting that, in the USA alone, there are an estimated 45,000 sites which are polluted or potentially polluted by radioactive poisons --- according to a report commissioned by the Environmental Protection Agency in 1992 (see EPA 1992). Worldwide, there is radioactive pollution from above-ground bomb tests. There is also the radioactive fallout from the Chernobyl accident in Europe and the former USSR. The fact that humans have already created large amounts of nuclear pollution, adds to the moral argument for allowing NO MORE. ================================================================== * - POINT 6. Too Much Trust? Too Many Good Manners? * - The concept of irreversible rad-waste burial represents an assault against current and future generations. Virtually no one believes it will all stay contained and out of the biosphere. * - Indeed, when the U.S. Government seeks advice from the National Research Council on setting "standards" (so-called permissible limits) for future radiation exposure from Yucca Mountain and other rad-waste burial sites, the government is conceding that some of the poison will probably get into the biosphere. In response, the YMS Committee concedes that rad-waste burial at Yucca Mountain is possible only if people are convinced that "very low radiation doses pose a negligibly small risk" (p.7). * - How can any level of premeditated random murder be presented by policy-makers as "negligible"? Is this really happening in the USA? Can anyone in the National Research Council or the Environmental Protection Agency possibly endorse a right to inflict radiation-induced cancers and inherited afflictions on current and future generations? These are criminal acts. * - Perhaps we have come to this disgraceful situation because of too much trust (and even too much politeness) toward the National Academy and the Environmental Protection Agency and the rest of so-called public health protectors. It is time for the citizens to say: "But the Emperor is wearing no clothes!" * - Gordon E. Durnil, in his 1995 book entitled The Making of a Conservative Environmentalist, sees the moral issue clearly: "Conservatives believe in individual rights. But is not the insidious invasion of our bodies by harmful unsolicited chemicals the most flagrant violation of our individual rights? We conservatives bemoan the decline in values that has besieged our society. Why then should we not abhor the lack of morality involved in discharging untested chemicals into the air, ground and water to alter and harm, to whatever degree, human life and wildlife?" ================================================================== * - POINT 7. More Radiation Experiments on the Citizenry? * - I hope that the Environmental Protection Agency will come to its senses, reject radiation "standards" for Yucca Mountain, and start opposing the whole terrible plan to bury wastes in ways which will become irreversible. At the very least, we must keep the radioactive poisons we have produced where humans can keep repacking them and really contain them for the time required for their decay. We owe that effort to all our descendants, regardless of expense. * - And this duty belongs also to those who insist that perhaps a safe dose or dose-rate of ionizing radiation will be found. They have no moral right to endorse actions which expose humans to extra radiation unless they can validly replace our proof, that no such dose or dose-rate exists, by a conclusive proof that it does exist. * - People can not justify exposing other people to extra ionizing radiation via nuclear pollution by speculating, contrary to the evidence, that MAYBE a safe dose exists. The people who advocate such a position are accomplices to premeditated massive experimentation on their fellow humans --- even into future generations. Experimentation on other humans without their individual consent is a crime identified by the Nuremberg Tribunals. * - Silent "neutrality" on the issue amounts to complicity with such experimentation. Dante Alighieri, a 14th century poet, wrote something which belongs on every wall in the National Academy of Sciences and in the many institutes where its members work: "The hottest places in hell are reserved for those who, in time of great moral crisis, maintain their neutrality." # # # # # ================================================================== References BEIR-5 Report, 1990. Committee on the Biological Effects of Ionizing Radiation (BEIR), Health Effects of Exposure to Low Levels of Ionizing Radiation. 421 pages. ISBN 0-309-03995-9. National Academy Press, Washington, "DC, USA. 1990. Belle Newsletter 1994. Belle Newsletter, Vol.3, No.1, July 1994. This is "a publication of the NE Regional Environmental Public Health Center, University of Mass. School of Public Health, Amherst, MA." The July 1994 issue opens with a list of Advisory Committee Members and a 7-page "article on "radiation hormesis," written by the vice-president of the Central Research Institute of Japan's Electric Power Industry. EPA 1992. Environmental Protection Agency, a survey of sites contaminated or potentially contaminated by radioactive poisons. Prepared for the EPA by L.T. Skoblar of the Roy R. Weston consulting firm in "Edison, New Jersey, and by J.J. Mauro of the F.Sam "Cohen firm in McLean, Virginia. See the New York "Times, April 9, 1992. Durnil 1995. Gordon E. Durnil, The Making of a Conservative Environmentalist. Indiana University Press. 1995. Gofman 1990. John W. Gofman, Radiation-Induced Cancer from Low-Dose Exposure: An Independent Analysis. 480 pages. ISBN 0-932682-89-8. Committee for Nuclear Responsibility, San Francisco, CA, USA. 1990. NRPB 1995. John Stather + Roger Cox, Risk of Radiation-Induced Cancer at Low Doses and Low Dose-Rates for Radiation Protection Purposes. 78 pages. ISBN 0-85951-386-6. Vol.6, Number 1, in the series "Documents of the NRPB." National Radiation Protection Board, Chilton, Didcot, England. 1995. UNSCEAR 1993. United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR), Sources and Effects of Ionizing Radiation: UNSCEAR 1993 Report to the General Assembly, with Scientific Annexes. 922 pages. No index. ISBN 92-1-142200-0. 1993. * - We encourage people (especially at DOE and its labs and subsidiaries) to reprint and distribute these proposals widely. No permission is required. * - John W. Gofman, M.D., Ph.D., is chairman of the Committee for Nuclear Responsibility, and Egan O'Connor is editor. Dr. Gofman is professor emeritus of Molecular and Cell Biology at the University of California, Berkeley, and author of four books on the health consequences of exposure to ionizing radiation --- 1981, 85, 90, 94 (in preparation). In earlier years, JWG proved the fissionability of uranium-233 (in 1942) and developed chemical techniques to deliver the first milligram-quantities of plutonium for the Manhattan Project (in 1943); did pioneer research on heart disease and lipoproteins (1947-1963); established (in 1963) the Biomedical Research Division of the Livermore National Lab, where he examined the health effects of radiation and studied chromosomal origins of cancer. Support for his research was taken away in 1972, in reprisal for his emphatic and persistent public statements about the health hazards of radiation. "Power concedes nothing without a demand. It never did and it never will. Find out just what people will submit to, and you have found out the exact amount of injustice and wrong which will be imposed upon them ..." --Frederick Douglass, former slave (USA) and educator, 1817-1895. "Man's most valuable trait is a judicious sense of what not to believe." -- Euripedes, Greek dramatist, 5th century B.C. "All that is necessary for the triumph of evil is that good men do nothing." -- Edmund Burke, English statesman, 1729-1797. "It makes all the difference in the world whether we put truth in the first place, or in the second place." -- John Morley, English statesman, 1838-1923. "A lie which is half a truth is the wickedest lie of all." -- Alfred Tennyson, English poet, 1850-1892. "Don't be afraid to take a big step if one is indicated. You can't cross a chasm in two small jumps." -- David Lloyd George, British statesman, 1863-1945. "It is no use saying `we are doing our best.' You have got to succeed in doing what is necessary." -- Winston Churchill, British statesman, 1874-1965. "The truth must always be known by ONE before it can be known by the majority." -- Attributed to Henrik Ibsen, Norwegian dramatist, 1828-1906. "Make no little plans; they have no magic to stir men's blood ... Make big plans; aim high and hope and work." -- Daniel Hudson Burnham (architect). "To sin by silence, when they should protest, makes cowards of men." -- Abraham Lincoln, 16th president of the USA, 1809-1865. "We owe almost all our knowledge not to those who have agreed, but to those who have differed." -- Charles Caleb Colton. RECENT TV VIDEO-TAPES Related to Some Topics in CNR's "Proposals" Essay: * - CNN's "Earth Matters," a 30-minute broadcast on Feb. 27, 1994. Covers harrassment and intimidation of specific whistleblowers over nuclear power-plant safety. About $35 per copy. Cable News Network, Library Tape Sales, Post Office Box 105366, Atlanta GA 30348. Tel: 404-827-1335 *1. Fax: 404-827-1840. * - "CNN Presents," a one-hour broadcast on March 13, 1994 about some past causes of DOE's credibility problems and about Hazel O'Leary's goals for the future. About $50 per copy. For acquisition, see above. * - "Story of Linda Mitchell, Whistleblower at the Palos Verdes Nuclear Power Plant." A segment of about 12 minutes, broadcast March 6, 1994, on the TV program "Working Woman." Available for purchase from the National Whistleblower Center (see Part 3A, above), which represented her claim before the US Dept. of Labor. * - San Mateo (California) Public TV, 26-minute interview with Prof. John W. Gofman, broadcast in February 1994. Covers the menace to human health caused by a fear-induced slave-mentality among radiation researchers. CNR has copies, made by a copy-service from a VCR "master." $9 including tax and shipping. * - ABC's "The Cover-Up at Ground Zero," a one-hour broadcast on Feb. 2, 1994 (first program in Peter Jennings' "Turning Point" series). Documents how the government deceived "downwinders" in Utah with respect to fallout from above-ground bomb testing. Includes the daughter-in-law of the former director of the Los Alamos National Lab. She was downwind and pregnant during that time. While the government was assuring the public that there was no danger from the fallout, her father-in-law told her that SHE ought to go somewhere else because it was a serious situation. Also documents how our Dept. of "Justice" is dealing with dying plaintiffs who worked at the Nevada Test Site. ---------------------------------------------------------------- | Committee for Nuclear Responsibility, Inc. | | Post Office Box 421993, San Francisco, CA 94142, USA. | | Internet: http://www.ratical.org/radiation/CNR/ | | An educational group since 1971. | ---------------------------------------------------------------- This document is available electronically at: http://www.ratical.org/radiation/CNR/YuccaMtnRWR.html (fancy HTML) http://www.ratical.org/radiation/CNR/YuccaMtnRWRP.html (plain HTML) http://www.ratical.org/radiation/CNR/YuccaMtnRWR.txt (ascii TEXT)