Copyright 2000 Federal News Service, Inc.
Federal News Service
July 18, 2000, Tuesday
SECTION: PREPARED TESTIMONY
LENGTH: 3385 words
HEADLINE:
PREPARED TESTIMONY OF JOE F. COLVIN PRESIDENT & CHIEF EXECUTIVE OFFICER
NUCLEAR ENERGY INSTITUTE
BEFORE THE HOUSE
SCIENCE COMMITTEE SUBCOMMITTEE ON ENERGY & ENVIRONMENT
BODY:
My name is Joe Colvin. I am the
president and chief executive officer of the Nuclear Energy Institute (NEI). NEI
develops public policy for more than 270 members of the nuclear industry that
represent a broad spectrum of interests. In addition to representing every U.S.
utility that operates a nuclear power plant, NEI's membership includes nuclear
fuel cycle companies, suppliers, engineering and consulting firms, national
research laboratories, manufacturers of radiopharmaceuticals, universities,
labor unions and law firms.
On behalf of NEI, I would like to thank
Chairman Calvert, Ranking Member Costello and the members of this subcommittee
for allowing NEI to provide a - written statement for the record on the need for
establishing uniform radiation standards.
Nuclear Technologies Provide
Tremendous Benefits Mankind for decades has safely harnessed nuclear technology
to benefit society. America's advanced industrial economy and high standard of
living simply would not be possible without the use of nuclear technologies.
Radioactive materials are used in many consumer products, both for necessities
as well as conveniences that enhance our daily lives. Among these necessities is
nuclear energy, which provides one-fifth of our nation's electricity without
producing any air pollution. Many people do not realize the widespread
applications of nuclear technologies, such as medical diagnosis and treatment,
agriculture, industrial manufacturing and environmental protection. These uses
of nuclear technology make significant contributions to our quality of life. Ten
million Americans are diagnosed and treated every year using radioactive
materials. For example, one radioactive isotope developed at the Brookhaven
National Laboratory in New York, molybdenum-99, is used about 40,000 times each
day in the United States to diagnose cancer and other illnesses. Radioactive
materials also are essential to the biomedical research that seeks causes and
cures for diseases such as AIDS, cancer and Alzheimer's disease. The U.S. Food
and Drug Administration (FDA) requires all new drugs to be tested for safety and
efficacy. Eighty percent of these new drugs are tested using radioactive
materials. The use of nuclear technologies in the field of agriculture improves
various types of plants, controls pests and preserves food. The use of
irradiation in food safety continues to grow in the United States and has been
used for decades in Europe. In fact, food irradiation has been approved to
control food loss and to improve sanitation for more than 100 kinds of food in
41 countries.
The associated economic benefit of the use of nuclear
technology and nuclear materials on the economy is substantial, accounting for
more than $400 billion in revenues (6 percent of the gross
domestic product) and 4.4 million jobs (4 percent of total U.S. employment).
Congressional action is necessary to ensure that our nation's radiation
safety standards are scientifically based, protect against unacceptable risks to
human health and the environment, take into account relevant social and economic
factors, help optimize societal benefits and do not arbitrarily discriminate.
Congressional action is needed to improve the process for developing,
promulgating and implementing such standards.
We Live Among Radiation
from Many Sources
Every plant, animal and human on Earth is surrounded
by radiation. Radiation is a natural part of our everyday lives. Natural
background radiation exists from numerous sources--the food we eat, the water we
drink, the air we breath and the soil on which we walk.
Americans, on
average, receive 360 millirem/1 of radiation exposure each year from their
surroundings with no identifiable health risk. Natural sources of radiation
account for 82 percent of the radiation to which the public is exposed every
year. This includes sources, such as radon (55 percent), cosmic radiation from
the sun and stars (8 percent), radiation from rocks and soil (8 percent) and
radiation in food and water (11 percent). Man-made sources account for the
remaining 18 percent, including medical and dental x-rays and nuclear medicine
(15 percent) and consumer products, such as televisions, computers and smoke
detectors (2-3 percent). The degree of background radiation varies greatly from
one location to another--from 100 to 1,000 millirem--due to many natural and
man-made factors. People living in high altitudes, such as Denver, receive far
more ambient radiation than people living in low-lying coastal cities, like
Savannah, Ga.
Residents living near nuclear power plants receive an
infinitesimal amount of radiation, especially when compared to naturally
occurring sources of radiation. Living within 50 miles of a nuclear power plant
increases ones radiation exposure by a mere 0.009 millirem (less than
one-thousandth of one percent of radiation exposure from all sources), according
to the Environmental Protection Agency. To put this in perspective, one would
have to live near a nuclear power plant for 2,222 years to get the same amount
of radiation exposure one gets from a single diagnostic medical x-ray (20
millirem). In comparison, the EPA notes that people living within 50 miles of a
coal-fired power plant also receive an extremely small radiation does of 0.03
millerem from the naturally occurring radiation in coal--though it is still more
than three times the radiation they would receive from living near a nuclear
power plant.
Radiation Safety Standards Should Be Science-Based and
Consistent
Sound, effective public policy should produce scientifically
based standards that ensure clarity, consistency and predictability qualities
lacking in the current way ' that our nation establishes various radiation
safety standards. First and foremost, any standard adopted must guarantee that
both the public and the environment continue to be protected.
The
world's scientists have been studying radiation for more than a century, and
from the beginning scientists recognized the need to establish safety standards.
For the past 70 years, national and international organizations have been formed
that provide recommendations and regulations for the protection of people and
the environment regarding exposure to radiation. Among these are the National
Council on Radiation Protection and Measurements (NCRP), the National Academy of
Sciences (NAS) Committee on the Biological Effects of Ionizing Radiation (BEIR),
the International Commission on Radiological Protection (ICRP), the
International Atomic Energy Agency (IAEA) and the United Nations Scientific
Committee on the Effects of Atomic Radiation (UNSCEAR).
In the United
States, the Nuclear Regulatory Commission (NRC), the Environmental Protection
Agency (EPA) and the Department of Energy (DOE) are the principle federal
agencies responsible for establishing radiation safety regulations. Their
authority comes from the Atomic Energy Act of 1954, as amended, and a number of
environmental protection statutes. In addition, other federal agencies, such as
the Department of Transportation (DOT), the Food and Drug Administration (FDA)
and the Occupational Safety and Health Administration (OSHA) also have
responsibility for setting radiation safety standards. Their authority is
derived from a variety of other federal laws. These agencies often work with the
international organizations listed above.
Industry strongly urges these
agencies to work even more closely and consistently with these international
bodies to assure that their regulations are based on internationally recognized
scientific standards.
Government agencies at the international, federal,
state and local levels regulate the manufacture, use, transport and disposal of
man- made and some naturally occurring radioactive materials to ensure the
protection of public and worker health and safety. Unfortunately, having
multiple federal agencies establish radiation safety standards have led to
inconsistency in standards that is misleading and confusing to the public.
Furthermore, inter-agency conflicts regarding jurisdiction and regulatory
requirements undermine the credibility of these regulatory agencies, and
inconsistent radiation standards lead to increased cost of regulation to the
federal government or consumers.
For example, the EPA and NRC disagree
over radiation safety standards for the proposed Yucca Mountain
repository for used nuclear fuel, and about appropriate' radiation safety
standards for the cleanup and decommissioning of government and civilian nuclear
facilities. Americans have a right to expect their government to adopt
consistent radiation safety standards to protect them in all circumstances.
Unfortunately, our government has a wide range of radiation safety
standards that are inconsistent.
EPA's uranium fuel cycle standard is 25
millirem while the same agency's proposed radiation safety standard for the
planned Yucca Mountain used nuclear, fuel repository is 15
millirem. According to the GAO, meeting the proposed EPA radiation standard for
Yucca Mountain win increase the repository costs by billions of
dollars. The EPA compounds the inconsistency and the added cost by applying a
separate groundwater radiation standard to Yucca Mountain. That
standard, adopted from the Safe Drinking Water Act, would be as low as 0.2
millirem for some radioisotopes, such as Nickel 63 and Iodine 129. Meeting the
very strict groundwater standard win cost American electricity consumers
billions of dollars-- without any proven benefit to public health and safety.
The GAO estimates that the costs at Yucca Mountain have been
increased by $10 billion since 1993 as part of DOE's effort to
plan for meeting stricter radiation safety standards and many billions more may
be spent in order to comply with the EPA's proposed standards.
The NRC
generally establishes a 25 millirem standard for all individual sites as part of
an overall 100 millirem safety standard for the general public.
Some
standards arbitrarily discriminate against nuclear energy in comparison to the
standards for regulating naturally occurring and man-made radiation in other
industries. An example of this is the coal ash that is produced by coal fired
power plants. Even though coal ash contains concentrated amounts of uranium that
can subject people to radiation exposure levels of several millirem per year,
the federal government does not regulate the radioactivity levels in its use and
disposal.
Consequently, the EPA does not apply standards for groundwater
to protect it from radioactivity from coal ash in the same manner that the
standards are applied for nuclear facilities. NEI is not advocating that the
low-level radiation in coal ash is dangerous. To the contrary, NEI believes that
there is no scientific justification for regulating materials containing safe
low levels of radiation regardless of the nature of the facility where it is
produced. Equivalent doses of radiation should be treated in the same manner.
There is no difference in the effects of natural or man-made radiation. It is
not scientifically justified and it is contrary to common sense to treat
radiation from various sources differently. Moreover, it jeopardizes public
confidence in regulations when federal agencies are inconsistent in establishing
radiation standards.
As noted in the recent GAO report, Radiation
Standards: Scientific Basis Inconclusive, and EPA and NRC Disagreement Continues
(GAO/RCED 00-152, June 2000), public policymakers should make radiation
standards consistent because it has tremendous budget implications. According to
the GAO, the long-term cost of complying with overly strict radiation safety
standards is likely to be billions of dollars. Therefore, the cost to the
federal government of cleanup at DOE nuclear facilities increases dramatically
when radiation safety levels are arbitrarily made lower than public or
environmental safety requires.
Congressional action is necessary to
ensure that our nation's radiation safety standards are scientifically based,
protect against unacceptable risks to human health and the environment, take
into account relevant social and economic factors, help optimize societal
benefits and do not arbitrarily discriminate.
Another situation where
congressional action is clearly necessary concerns the establishment of
radiation safety standards for the removal of materials from federal and
civilian nuclear facilities. The NRC has long had dose-based standards for the
controlled and safe removal of liquids and gases from plant sites. The NRC
requires that all solid materials be treated on a case-by-case basis. This
process is extremely time-consuming and costly, both to the NRC and the
companies that operate these facilities. However, the NRC is now considering the
development of a radiation protection standard for the release of solid
materials. This dose-based standard would replace an inconsistent system that
treats the same levels of radiation in materials at different types of
facilities in very different manners. Solid materials that do not pose a threat
to public health and safety or the environment should be available for reuse
and/or disposal in landfills. Unnecessary regulatory burdens--those not tied to
the protection of the public health and safety--should be eliminated.
Potential Health Risks of Exposure to Low Levels of Radiation Are Very
Small Possibly Zero
To ensure radiation safety standards are set
conservatively, national and international scientific organizations, including
the NAS, NCRP, ICRP, IAEA and UNSCEAR, assume a linear relationship between
radiation dose and its effect. This means that small doses are assumed to have
health effects in direct proportion to the known effects of large doses even
though no health effects have been directly observed at low doses. Many
scientists question the validity of the linear hypothesis because of the lack of
evidence and the knowledge that many other agents that are harmful at high doses
have no effect at low doses. For example, the BEIR V committee of the NAS
specifically pointed out that a threshold might exist below which radiation
causes no harm.
Although numerous scientific studies have been conducted
of populations exposed to radiation, there is no consistent evidence that humans
are harmed by exposure to radiation at levels below 10,000 millirem. For
example, the National Cancer Institute (NCI) of the National Institutes of
Health in 1990 announced that a large-scale NCI study found no increased
incidence of cancer mortality for people living near 62 nuclear facilities in
the United States. This research, which evaluated mortality from 16 types of
cancer, showed no increase in the incidence. This study was the largest of its
kind ever conducted.
NAS's BEIR VII committee concluded in 1998 that
sufficient new scientific information has become available since the publication
of the BEIR V report to warrant a significant reduction in, and possibly even
elimination of, the health risks currently associated with low levels of
radiation. A final report from this committee is expected in 2003.
DOE
embarked on a research program in 1998 aimed at determining how human cells
react to low levels of radiation. Advances in molecular biology, including new
data and technology from the human genome project, have given researchers the
tools they need to study the effects of low levels of radiation on human cells.
Through this program, DOE is funding studies designed to answer the key
question: Do cells repair damage caused by low levels of radiation in the same
way they repair normal damage caused by cellular processes?
Global
Approach To Radiation Safety Standards Necessary Economic globalization is a
trend that must be considered in setting safe radiation standards for protecting
public health and safety. Given greater global economic integration,
compatibility with standards adopted by other nations and international agencies
is important because materials are imported and exported between the United
States and other nations on a daily basis. Differing regulatory standards could
create confusion and economic disparities in commerce. It is in our
self-interest as .Americans to ensure that our companies are not placed at a
competitive disadvantage due to the unintended consequences of governmental
policy that is not based on sound science.
America must not abdicate its
role as world leader in the peaceful uses of nuclear technology.
Since
the inception of the civilian nuclear industry in the 1950s, the United States
has been the world leader in using nuclear technology to improve health care,
bolster our economy and enhance our quality of life. It is critical that we play
a leadership role in determining reasonable radiation standards. We must work
together with other nations to ensure the development of scientifically sound
and reasonable international radiation safety standards. There is considerable
effort by other nations and by international agencies, such as the International
Atomic Energy Commission (IAEC)--an agency of the United Nations, to establish
standards in this area. NEI urges the United States to fully participate in
these international efforts.Conclusions and Call for Congressional Action
Federal radiation safety standards should: Be scientifically based,
practical, and implementable; Be based on proper risk-benefit calculations;
Optimize societal benefits with regard to implementation costs; Utilize a
coherent framework of justification, limitation and optimization; and Provide
maximum flexibility in implementation.
The scientifically based
recommendations of the National Council on Radiation Protection and Measurements
(NCRP), the International Commission on Radiological Protection (ICRP), and the
International Atomic Energy Agency (IAEA) provide a credible, useful, and
readily available source for radiation safety standards.
Congressional
action is needed to: Improve the usefulness and consistency of federally funded
scientific research on radiation health effects by requiring:
(1) a
process of standardized, credible scientific peer review of research objectives,
procedures, results, and conclusions;
(2) timely publication of research
reports; and
(3) use valid research results and conclusions in federal
radiation safety policy.
- Require federal radiation safety standards to
be based upon and consistent with the recommendations of relevant scientific
consensus bodies, such as the NCRP, ICRP, and the LAEA. Eliminate overlap and
redundancy between the authorities of various federal agencies in setting and
implementing radiation standards by consolidating such authority within the
Nuclear Regulatory Commission. the independent agency that has expertise in this
area.
- Ensure that radiation safety standards intended to protect
public health and safety and the environment are established at levels
sufficient to do so in a scientifically sound manner. Public policy should
require the consistent treatment of the same levels of radiation from different
sources. Moreover, public policy on radiation standards should be communicated
effectively by the federal government to the public. Whether radiation is
man-made or naturally occurring does not impact the relative safety of the
material. To arbitrarily distinguish between various categories of radiation is
not scientifically justified and should be prohibited by public policy.
Man has harnessed nuclear technologies for medical diagnosis and
treatment; research into cures for disease; the development of new drugs;
hardier, more disease-resistant crops; everyday consumer goods and services; and
to generate electricity without producing greenhouse gases or acid rain. We must
make sure that these tremendous benefits of nuclear technologies are not
jeopardized by radiation safety standards that are impractical, inconsistent and
lack a sound scientific basis. Federal radiation safety standards must not
arbitrarily discriminate against nuclear technologies.
FOOTNOTES:
1 A millirem is a unit of measurement of the biological effect of
radiation. For example, the radiation from a diagnostic medical x-ray is
equivalent to about 20 millirem.
END
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July 19, 2000 
