Re: EPA & NRC

[hwade@triax.com (H. Wade Patterson)]

Group:
I want to thank Mark Winslow, US EPA - Region II, for posting the text
of Ramona Trovato's speech on RadSafe.

She is the director of EPA's Office of Radiation and Indoor Air and the
title of her speech was, (EPA's) "Statement On The Nuclear Regulatory
Commission's Rule On Radiological Criteria For License Termination."

In my opinion the speech is both well-reasoned, and a full explanation
of the EPA position. Much of the EPA position is based on an assessment
of risk associated with radiation exposure; and it is the policy of EPA
to assume linearity in risk assessment. (This policy is given in Federal
Register v56 no.138 :33055; July 18, 1991, where it states that, "EPA
policy, supported by recommendations of SAB/RAC, is to assess cancer
risks from ionizing radiation as a linear response.")

Here are three quotations from the speech which illustrate the
assessment of cancer risk as linear.

1. "NRC has also added a provision that would allow as high as 100
millirem per year for unrestricted release.  This level is an increase
of seven times their original proposal and, by NRC's own assessment,
corresponds to a lifetime risk of cancer of one in two hundred (5 x
10-3)."

2. "Although 80 is better than 100 mrem/yr, it still results in a cancer
risk of 1 in 250, a risk that is simply unacceptably high."

3. "As I stated earlier, NRC removed the separate ground water standard
from the current draft.  NRC licensees now would be allowed to pollute
ground water --water that you and I could drink --with radioactive
contaminants at levels 25 times greater than drinking water standards;
this equates to a lifetime fatal cancer risk of 1 in every 200 people."

I believe this EPA policy is based on various BEIR/NCRP reports, which
unfortunately are not science-based documents.

I say not science-based because BEIR/NCRP have first selected and
adapted data, and then used circular reasoning to justify the conclusion
that, "a single event at the cellular level can give rise to cancer." 
(This latter quotation is from Roger Clarke's guest editorial last
August, Clarke, R. H. The Threshold Controversy. Health Phys. Newsletter
XXIV(8) :2; August 1996). His statement is, of course, the basis for the
LNT, collective dose and ALARA.

I have documented this lack of scientific rigour on the part of various
standard setting bodies in my recent paper. (Patterson, H. W. Setting
Standards for Radiation Protection: The Process Appraised. Health Phys.
72(3) :450-457; 1997).

By now you may be asking, "what's the point."

The point is, public policy should be based on science, not on feelings.


-- 
Wade

mailto:hwade@triax.com

H.Wade Patterson
1116 Linda Lane
Lakeview OR 97630
ph 541 947-4974