Revision 1
March 19, 1998
by Radiation, Science, and Health, Inc.,
Edited by J. Muckerheide

1.8
Costs

"Current cost/benefit estimates related to radiation protection, e.g. regarding the consequences of population exposures after accidents, decommissioning and waste management programs etc., are based on the linear-no-threshold hypothesis and the related collective dose concept, as recommended in ICRP 60, the Basic Safety Standards (BSS), and EU directives. However, the extrapolation from very high to very low doses is increasingly questioned by radiation scientists for fundamental radiobiological reasons, as well as by epidemiological studies with exposed populations. Moreover, if also applied to natural radiation (e.g., in mining or high natural radiation areas, or radon in buildings), the resulting high costs justify, for ethical as well as socio-economical reasons, a careful analysis of the actual benefits of such measures, to be compared with demonstrable health detriments and the cost benefit ratio in other public health and risk reduction programs in modern industrial societies."

"In recent years, ‘big money’ is involved. To give only a few examples from Germany:

"1. After the Chernobyl accident, the costs of destruction of slightly contaminated produce, milk (in one of the federal states down to a level of 20 Bq/l of I-131, corresponding to 20% of the natural K-40 activity in milk.), etc. have been about 300 million $ in the western part of the country (Becker 1996a).

"2. The radiological component in the remediation of former uranium mining areas in eastern Germany amounts to about 2,000 million $ (Becker 1996b).

"3. The decommissioning of the pilot reprocessing plant WAK in Karlsruhe is estimated to cost approximately 25 times its original construction costs, including a 250 million $ facility for the vitrification of only 80 m3 of liquid wastes.

"4. With the current exemption level for low-level wastes corresponding to exposures of the public of no more than 10 mSv p.a. (which is 0.4% of the average natural exposure and 0.04% or less of some high background areas) thousands of millions of $ are being spent for the ‘radiological component’ in the decommissioning of nuclear power plants-costs which would be substantially reduced by using higher limits."

"5. Earlier this year, the cost of police protection for a simple radwaste transport to one of the temporary storage facilities (Gorleben) was 60 million $, not counting hundreds of acts of sabotage against railways and roads, based on Greenpeace claims of a QF of 600 for fast neutrons, etc.

"Many more examples could be listed with the situation in countries with large nuclear military facilities, ships, etc., such as the former Soviet Union and USA, being particularly difficult and expensive. This was, for example, recently pointed out in a study for the U.S. Army (Brodsky 1996). There are aspects of the present regulatory system in radiation protection which raise serious questions. To mention only a few examples:

"Increased natural radiation levels. With the average background in Europe fluctuating, substantially, and being exceeded by a factor of 10 to 100 in areas of Brazil, India and Iran without any detectable health effects over many generations, it would make little sense to consider the evacuation of whole towns or regions in Saxony, Finland or Cornwall, or to close down mining operations in Southern Africa which would be required if current radiation policy were to be applied uniformly.

"Radon. Current regulations of the U.S. Environmental Protection Agency (EPA) apparently require the radon level in buildings not to exceed the outdoors level (which is practically impossible), and radon levels in tap water not to exceed 10 Bq/l, while the normal Rn content of drinking water exceeds 1000 Bq/l in many parts of the world, and water with 100.000 Bq/l used for the treatment of various diseases in radon spas. In Europe, the maximum recommended in-door radon levels currently vary between 200-600Bq/m³, but no detectable increases in lung cancers have been found at levels which are at least ten times higher (with the possible exception of very heavy smokers).

"In fact, levels up to 700.000 Bq/m³ in air have been observed in some public water facilities in Bavaria (Becker 1996b), and 20-50% of all homes in S.W. England are above the current U.K. ‘action level’..."

"Considering that in the long-term trend ICRP-recommended dose limits became smaller, the obvious question arises about the validity of the underlying linear no-threshold (LNT) hypothesis and the closely associated collective dose concept. Does it, for example, really make sense (or is it radiobiologically plausible) to officially publish estimates on ‘additional Chernobyl - caused cancer deaths’ of about 300 in Sweden, 450 in Finland, and exactly 363 in Bulgaria (Becker 1996c) The direct and indirect socio-economical and political implications of ICRP-based ‘predictions’ of casualties not only in the directly affected areas around Chernobyl, but in the whole Northern Hemisphere, have been tremendous, and resulted not only in tens of thousands additional abortions by scared women in Western Europe. but also to economic losses in the 15.000 million $ range in Germany alone due to the cancellation of nuclear programs, etc. (Becker 1996a).

"It is, therefore, more than justified to ask how stable the foundations of the current ‘House of Radiation Protection’ actually are - and, in case they are not, whether this house can be repaired by evolutionary processes or will require a total re-construction. Instead of attempting a definitive answer to this probably most important question in our field not only in this decade, some questions urgently, require an answer from the best in the radiation science community - for the benefit not only of mankind in general, but more specifically for that of regulators and administrators acting on behalf of the tax-payers and utility customers:

"1. How much of our rapidly decreasing funds can we afford to devote to the further reduction of potential risks which, if they exist at all, are so small that they could not be detected in decades of painstaking and expensive research efforts? Tens of billions of dollars are spent every year worldwide in decommissioning, redemption, or nuclear waste programs, which could obviously be used much more beneficially in other areas of public and individual health, in rich and even more so in poor countries.

"2. In claiming frightening numbers of additional cancer fatalities due to the Chernobyl accident, of radon in houses, medical radiography, etc. - based essentially on the multiplication of zero with infinity - how much psychological and economical damage in the public acceptance of many beneficial radiation uses including energy production without climatic side effects, radiation medicine, and research, has been done?

"3. How do we explain to the critical observer the multitude of well- documented observations of adaptive response (some of them documented in UNSCEAR 1994 with 400 references (UNSCEAR 1994) and hormesis (Luckey cites 2000 references in his well-known 1991 book on this subject - see also (Luckey 1997) as well as the many epidemiological and experimental studies clearly showing either thresholds (between about 0.2 and 2 Gy, ranging from leukemia among the bomb survivors in Japan to bone and lung cancer in humans and animals), or biopositive effects in Cohen’s (1995) and many other radon studies, the absence of observable genetic disorders in Hiroshima/Nagasaki and the Chernobyl region, etc.? Many of the very good arguments for no negative, and in many cases positive effects of slightly increased radiation levels have been summarized in recent compilations (Walinder 1995, Kondo 1993; Jaworowski 1995, Muckerheide 1995, Becker 1997a, ANS 1996). Very reasonable explanations for such bioneutral or biopositive effects, based on the dominating influence of stimulated repair of non-dominant radiation doses, have been abundantly presented (Walinder 1995, Kondo 1993, ANS 1996).

"4. How about the cost/benefit ratio in the current radiation protection programs relative to our treatment of other civilizatory and natural risks, e.g. in the chemical industry? Could it be that elements of self-interest are involved in ‘keeping the radiation hazards alive’ (after all, it is an industry involving more than 10¹⁰ U.S. $)? And how about scientific integrity and credibility in suppressing results which to not confirm ‘official’ dogmas, such as the U.S. Naval shipyard workers study (ANS 1996), or the opinion of the French Academy of Sciences (Academie des Sciences 1995)?

"5. How could it happen that over-conservative administrative concepts such as LNT and collective dose, originally created to simplify bookkeeping under certain limited circumstances, could degenerate to such an extent in the hands of regulators and ill-informed public opinion makers? And how could we correct this situation soon against the ideological objections of ill-informed journalists and politicians, and other doomsday ‘Zeitgeist’ prophets?"