Copyright 2000 Federal News Service, Inc.
Federal News Service
July 18, 2000, Tuesday
SECTION: PREPARED TESTIMONY
LENGTH: 5827 words
HEADLINE:
PREPARED TESTIMONY OF MS. GARY L JONES ASSOCIATE DIRECTOR ENERGY, RESOURCES AND
SCIENCE ISSUES RESOURCES, COMMUNITY AND ECONOMIC DEVELOPMENT DIVISION
BEFORE THE HOUSE COMMITTEE ON SCIENCE SUBCOMMITTEE ON
ENERGY AND ENVIRONMENT
BODY:
(NOTE: Figures
Not Transmittable)
Mr. Chairman and Members of the Subcommittee:
We are pleased to be here today to discuss the regulatory standards used
to protect the public from the risks of low-level nuclear radiation. The
scientific basis for these standards has been in question, as well as what level
of protection is appropriate and adequate for the public. As you know,
historically federal agencies, including especially the Environmental Protection
Agency (EPA) and the Nuclear Regulatory Commission (NRC), have sometimes
disagreed over how restrictive U.S. radiation standards should be. They have set
differing standards, which include varying limits on radiation exposure to the
public. The standards cover regulatory applications such as cleaning up major
weapons production sites, decommissioning commercial nuclear power plants, and
potentially constructing an underground repository for the disposal of highly
radioactive waste at Yucca Mountain, Nevada. On the basis of
our June 30, 2000, report to Senator Pete Domenici,1 our statement today
addresses three issues: (!) whether current radiation standards have a
well-verified scientific basis, (2) whether federal agencies, particularly EPA
and NRC, have come closer to agreeing on exposure limits (how much radiation
people can be safely exposed to) in the standards since we reported on this
issue in 1994,2 and (3) how implementing these standards and limits may affect
the costs of nuclear waste cleanup and disposal activities. In regard to the
scientific basis of radiation standards, we examined many scientific studies and
interviewed recognized scientists in the fields of radiation protection and
radiation research. In addition, we employed an expert consultant to help review
scientific research correlating natural occurring (background) radiation levels
around the world with local cancer rates.
In summary: U.S. radiation
standards for public protection lack a conclusively verified scientific basis,
according to a consensus of recognized scientists. Below certain radiation
exposure levels, the effects of radiation are unproven, despite many years of
research efforts. Evidence of these effects is especially lacking at regulated
public exposure levels--levels of 100 millirem a year and below from human-
generated sources.3 At these levels, scientists and regulators assume radiation
effects according to what is commonly known as the "linear no threshold
hypothesis," or model. According to this model, even the smallest radiation
exposure carries a cancer risk, and risks double as the exposure doubles. The
model is useful and relatively simple, but controversial. Some scientists argue
that the model overestimates radiation risks. Others take the position that the
model underestimates these risks. Research into low-level radiation effects
continues, including studies attempting to statistically correlate natural
background radiation levels in the United States and around the world with local
cancer rates. A promising long-term research area is focusing on low-level
radiation effects within human cells, including a 10-year Department of Energy
(DOE) program begun in 1999. Also, a major National Academy of Sciences
reassessment of the status of research into low-level radiation risks, called
BEIR VII, is under way, for which U.S. regulators have set high expectations and
which is due to conclude in 2001. Lacking conclusive evidence of low-level
radiation effects, U.S. regulators have in recent years set sometimes differing
exposure limits. In particular, EPA and NRC appear no closer to agreeing on
exposure limits today than in 1994. The two agencies continue to favor different
policies and regulatory approaches for various nuclear cleanup and waste
disposal applications, especially those relating to groundwater protection. At
nuclear sites, EPA favors applying restrictive standards-originally applicable
to community drinking water-to limiting groundwater contamination. The drinking
water standards include contamination limits for a long list of radioactive
substances, equivalent in some cases to fractions of a millirem a year. On the
other hand, NRC favors less restrictive Standards that treat groundwater as one
of various potential exposure means, or 'pathways,' within an all- pathway
exposure limit of 25 millirem a year.4 The disagreement involves EPA- and NRC-
preferred protection levels that are both well below the range where radiation
effects have been conclusively verified. In this regard, the disagreement
essentially involves policy judgments-not strictly scientific judgments. The
disagreement has complicated efforts to clean up nuclear facilities, as well as
planning for the prospective Yucca Mountain, Nevada, high-level
waste repository. It does not appear that EPA and NRC will readily agree on
appropriate groundwater protection approaches for Yucca
Mountain. Also, while the two agencies are working on a memorandum of
understanding to clarify their regulatory roles related to nuclear facility
decommissioning, they have made little progress on this matter since 1994 and
before. Our June 2000 report to Senator Domenici concludes that intervention by
the committees of jurisdiction may be needed to resolve the policy differences
and clarify the regulatory responsibilities between the two agencies. Costs of
implementing radiation protection standards at nuclear cleanup and waste
disposal facilities vary from site to site. For all sites nationwide, long-term
overall costs could be immense, although these costs have not been
comprehensively estimated. An indication of the potential costs is that
agencies, especially DOE, expect to fund hundreds of billions of dollars in
nuclear cleanup and waste disposal projects over many years in the future.
Differences in the costs of the EPA and NRC regulatory approaches to radiation
protection have not been comprehensively estimated. However, agency analyses
indicate that more restrictive radiation standards cost more to implement, as
might be expected. These analyses also generally show accelerating costs to
achieve the most restrictive protection levels.
Background
U.S.
radiation standards protect the public from very low radiation levels.
Specifically, the standards regulate human-generated exposures to the public in
the range of 100 millirem a year and below. This regulatory range is in the
lowest portion of the low-level radiation exposure range-- which extends up to
about 10,000 total millirem. The low-level range includes natural background
radiation, which varies locally in the United States, but averages about 300
millirem a year. At exposure levels equivalent to or below background radiation
levels, radiation is commonly considered to be a relatively weak source of
cancer risk, although there is limited understanding of such causation.5 Above
about 10,000 total millirem, the high-level radiation exposure range begins. In
this range, extending without limit into the hundreds of thousands of millirem
or even more, the cancer risks of radiation are better understood, and other,
immediate health effects become apparent. Above about 30,000 total millirem,
radiation exposure is a well-known cause of cancer. At about 200,000 millirem of
instantaneous or short-duration radiation exposure, there can be blood cell
changes, infections, and temporary sterility. Above about 400,000 millirem,
short-duration exposure can cause death within days or a few weeks.
EPA
and NRC administer the majority of federal radiation standards.
EPA
issues environmental radiation protection standards as mandated under
Presidential Reorganization Plan No. 3 of 1970. NRC issues standards as part of
its mandate to regulate civilian sources of nuclear radiation, under the Atomic
Energy Act. Under the same act, DOE has issued public and worker protection
standards applicable on- site at the department's nuclear installations. Both
EPA and NRC have major regulatory roles related to nuclear site cleanup and
decommissioning and nuclear waste disposal. In regard to nuclear cleanup, EPA
administers Superfund, the legislation that governs cleanups of federal and
nonfederal facilities, and NRC regulates the decommissioning of commercial
nuclear power plants, as well as other commercial nuclear facilities, under the
Atomic Energy Act. DOE is involved in nuclear site cleanup as the manager of
over a dozen major nuclear weapons production sites. In regard to Yucca
Mountain, EPA has the role of issuing standards to protect the public
from releases of radioactive materials from the facility. NRC has the role of
issuing technical requirements and criteria and licensing the facility. DOE is
involved as the developer and potential operator of the facility.
EPA
and NRC have historically implemented different regulatory approaches in their
radiation standards, as we reported in 1994. EPA has implemented a risk-based
radiation protection approach, setting a range of acceptable risk--between 1
chance in 10,000 and one chance in a million of an individual getting cancer. In
association with this approach, the agency addresses individual environmental
contamination sources, co-regulates chemicals and radioactive substances, and
seeks to protect both human health and environmental resources. EPA's approach
has been described as "bottom up," setting a relatively restrictive risk goal to
be pursued through the best available technology--but allowing less restrictive
acceptable risks in site- specific situations. In contrast, NRC favors a
dose-based, radiation- specific protection approach. The commission's
regulations focus on human health protection and 'all pathways" of exposure in
the environment. NRC's approach has been described as "top down," setting
relatively less restrictive dose limit but reducing doses well below the limit
in site-specific situations where the reductions are "reasonably achievable."
(In implementing its standards, DOE has historically implemented the same "top
down" protection approach.)
U.S. Radiation Standards Lack a Conclusive
Scientific Basis
U.S. radiation standards for public protection lack a
conclusively verified scientific basis, according to a consensus of recognized
scientists. Below certain exposure levels, the effects of radiation are
unproven. At these levels, scientists and regulators assume radiation effects
according to the "linear no threshold hypothesis," or model, under which even
the smallest radiation exposure carries a cancer risk. However, the model is
controversial among scientists, and decades of research into radiation effects
have not conclusively verified or disproved the model, including studies
attempting to statistically correlate natural background radiation levels in the
United States and around the world with local cancer rates. Research is
continuing, including a promising 10-year DOE program begun in 1999, addressing
the effects of low-level radiation within human cells. Also, the National
Academy of Sciences is conducting a major reassessment of the status of research
into low-level radiation risks, called BEIR VII, for which the regulators
requesting the work have set high expectations.
According to a consensus
of recognized scientists, below about 5,000 to 10,000 total millirem of
exposure, the effects of radiation are unproven. Evidence of these effects is
especially lacking at regulated public exposure levels--levels of 100 millirem a
year and below from human-generated sources. The consensus view that we
encountered among scientists and in the scientific literature is that the
research data on low-level radiation effects are inadequate to either establish
a safety threshold or to exclude the possibility of no effects. Individual
viewpoints differed. Some scientists and studies held that the data support the
existence of a safety threshold-an exposure level below which there are no risks
from radiation. Other scientists and studies held that there is no such
threshold and there can be risks at even the lowest exposure levels. In
addition, other scientists and studies noted that risks from low-level radiation
are complicated and variable, depending on factors such as the type and amount
of radiation involved, body organs exposed, sex of the person, and/or age at
exposure. For example, some researchers hold that children and fetuses may be
more at risk from low-level radiation than adults. Some scientists and studies
held that there are considerable data to support the view that low levels of
radiation can actually be beneficial to health--the highly controversial theory
of hormesis. Proponents of hormesis argue that research indicating beneficial
effects has not been adequately considered in the "consensus" scientific
community.
Although conclusive evidence of low-level radiation effects
is lacking, regulators still have the task of developing radiation standards to
protect the public. In doing so, regulators routinely assume that low-level
radiation effects exist, according to the "linear no threshold hypothesis" or
model. According to this model, even the smallest radiation exposure carries a
cancer risk, and risks double as the exposure doubles. This model is endorsed by
national and international radiation protection organizations and is used as a
preferred model by EPA, NRC, and DOE. It is thought by many to be a conservative
"fit" to the data, unlikely to underestimate the risks of radiation. However,
the model is controversial. Some scientists argue that use of the model to
assess risks from radiation may result in either over- or underestimating
radiation risks.
Decades of radiation effects research have neither
verified nor disproved the linear model. The research data on low-level
radiation effects generally include two different types of studies. One type
follows the long-term health of a studied population, seeking statistically
significant cancer effects, and is called epidemiology. Another type subjects
animals or tissue or cell cultures to radiation, seeking biological evidence of
radiation effects, and is called radiobiology. Epidemiology has been a key basis
for the linear model, including research evidence accumulated on over 85,000
Japanese survivors of the Hiroshima and Nagasaki atomic bomb blasts. The
Japanese data have well established high-level radiation effects, and scientists
have extrapolated this relationship to the low-level radiation range as
well--with considerable inherent uncertainty. Extrapolating from high-level
exposures, delivered instantaneously or for a short duration, to low-level
exposures delivered over years, may be subject to question. Also, the estimated
doses received by the Japanese survivors are still subject to re-evaluation,
even after many years of effort devoted to determining these doses.
In
addition, epidemiological studies have attempted to statistically correlate
natural background radiation levels in the United States and around the world
with local cancer rates, with inconclusive results. A premise relating to such
studies is that if the linear model of low- level radiation effects holds,
places with significantly higher background radiation levels should have
elevated cancer rates. With the help of an expert consultant, we examined 82
such studies, done in the United States, Europe, Asia, and South America. In the
United States, areas of high natural background radiation include the Rocky
Mountains, where levels are over three times higher than along the Gulf Coast.
Also, in some areas of the world, mean annual doses can be more than double the
average U.S. levels. Such studies are subject to methodological difficulties,
including the small size of the studied population and the pursuit of small
radiation caused cancer effects that are difficult to detect among all cancers
in the population, The results of the studies were inconclusive overall. Studies
differed, though they generally found little or no evidence of elevated cancer
risks from high natural background radiation levels. One prominent U.S.
statistical study, by Bernard Cohen, University of Pittsburgh, in 1995, found a
strong tendency for lung cancer rates to decrease with increasing radon
exposures in 1,601 counties nationwide. However, the study has been criticized
by epidemiologists as methodologically flawed because it is a compilation of
average statistics in these counties-not data on individuals.
Conclusive
evidence of radiation effects may not soon be obtained, but radiobiological
studies may hold more future promise than epidemiological studies, according to
researchers and regulators. Recently, there has been interest in research into
the cellular processes through which radiation causes cancer, and since fiscal
year 1999, the Congress has funded a DOE research program targeting the
biological effects of low-level radiation at the cellular level. Many scientists
and regulators we interviewed said this type of research could eventually help
to determine more conclusively the effects of low-level radiation and their
potential link to causing cancer. The DOE program projects total funding of
almost $220 million over 10 years. The program is considered
unique in that it is designed specifically to better validate the effects of
very low radiation levels, in areas such as cells' response to radiation damage,
thresholds for low-dose radiation effects, and features distinguishing
radiation-caused cell damage from damage from other, intra-cellular causes.
U.S. regulators have concluded that a major reassessment of the status
of epidemiological and radiobiological research into low-level radiation effects
is warranted.
At their request, a committee of the National Academy of
Sciences is conducting such a reassessment, called BEIR - VII. The last such
Academy study was done in 1990. The 1990 analysis, called BEIR V, established
risk estimates that have been influential for U.S. regulators in setting
radiation standards.6 It also gave the linear model a qualified endorsement,
stating that the model was not inconsistent with the available research data,
but that at low radiation exposures, risks either less or greater than expressed
in the linear model could not be excluded. U.S. regulators have set high
expectations for the BEIR VII effort, which to a degree may shed light on the
controversy concerning the linear model The effort is due to conclude in 2001.
In requesting BEIR VII, the regulators set expectations that the committee would
focus on areas not necessarily emphasized in the 1990 study, including (1) any
clear indications of the weight of evidence for radiation risks at low doses and
dose rates, (2) epidemiological studies on nuclear workers, (3) evidence of
radiation effects specifically at the very low levels where regulators set
radiation standards, and (4) evidence of hormesis. However, according to
scientists and agency officials, and on the basis of the research evidence to
date, it may be too much to expect BEIR VII to fully resolve the current
controversy by either validating or disproving the linear model.
EPA and
NRC Continue to Disagree on Radiation Standards
In 1994, we reported
that EPA and NRC disagreed on radiation standards. Today, they appear no closer
to agreement. In the absence of conclusive scientific evidence of low-level
radiation effects, the two agencies continue to have a policy disagreement
concerning how much radiation risk is acceptable to protect the public. The
disagreement essentially involves groundwater protection, at dose levels well
below the range where radiation effects have been verified. EPA prefers a more
restrictive approach than does NRC. Essentially, EPA favors specially protecting
groundwater at nuclear sites, regulating groundwater to drinking water
standards. Conversely, NRC favors including groundwater and other exposure
means, or pathways, under an all-pathway exposure limit. The all-pathway
exposure limit is less restrictive than the drinking water standards. The
disagreement is affecting the implementation of nuclear site cleanup regulations
and the development of regulations for the disposal of highly radioactive waste
at Yucca Mountain.
The EPA-NRC disagreement involves
policy judgments, not strictly scientific or technical differences. For both the
cleanup and decommissioning of nuclear facilities and the disposal of nuclear
waste, EPA's standards reflect the agency's "bottom up "protective approach,
setting a relatively restrictive risk goal to be pursued through the best
available technology. Also, EPA is attempting to implement a consistent
regulatory policy--for both chemical and radioactive pollutants- f protecting
groundwater as a national resource. In this respect, at nuclear sites EPA (1)
sets a risk-based limit of 15 millirem a year for exposure from all pathways and
(2) favors additional, more restrictive groundwater protection, to the same
standards the agency applies to drinking water in community water supplies. In
relation to various radioactive substances, these standards set exposure limits
that are equivalent in some cases to fractions of a mil!item a year. Conversely,
NRC's approach does not include special groundwater protection. The commission's
approach reflects its "top down" strategy-setting a relatively less restrictive
dose limit but pursuing lower doses where reasonably achievable. NRC prefers to
set radiation-specific, dose-based standards, and the Commission includes
groundwater and other exposure means (or "pathways") under an all-pathway
exposure limit of 25 millirem a year. (DOE also prefers an all-pathway
approach.)
In specific cleanup and waste disposal applications, the
differing EPA and NRC approaches have been implemented as follows. In 1995, EPA
drafted cleanup standards reflecting 15-millirem-a year all-pathway protection,
plus separate groundwater protection. The agency withdrew the standards
unfinalized in 1996, after other agencies objected to them, and implemented the
same approach in 1997 in the form of nonbinding Superfund guidance. Also in
1997, NRC finalized its own cleanup standards, in the form of decommissioning
standards reflecting all-pathway 25 millirem-a-year protection. Both EPA and NRC
issued proposed standards for the Yucca Mountain high-level
waste repository in 1999. EPA's draft standards reflect 15-millirem-a-year
all-pathway protection, plus extra groundwater protection, while NRC's draft
standards reflect 25-millirem-a-year all-pathway protection. (Under the Energy
Policy Act of 1992, NRC's final standards are to be consistent with EPA's final
standards.)
The differing EPA and NRC approaches have contributed to
various regulatory complications. For example, in the 1990s, perceived dual
regulation by EPA and NRC has complicated the cleanup and decommissioning
process at some sites where both agencies' standards may apply. Such situations
can lead to duplication of effort, regulatory delays, and added compliance
costs. Also, such situations can raise public questions about what cleanup
levels are appropriate and safe. For example, in 1999, in individual situations
at NRC- licensed sites, EPA has indicated that it might not view cleanups
performed to NRC's standards as adequately protective under its Superfund
guidance. EPA considers such situations to be the exception, not the rule.
However, licensees, including two New England power plants in 1999, have
construed EPA involvement in such a situation as a warning that EPA could
reevaluate the adequacy of a cleanup that has met NRC's requirements. Also, as
we have reported, EPA and DOE have had historical differences concerning
standards and acceptable risks for cleanups at DOE sites. These differences have
contributed to regulatory delays and higher regulatory and cleanup costs while
raising public questions about what cleanup levels are appropriate.7
Further, the EPA-NRC disagreement over standards for Yucca
Mountain is complicating planning for the repository. How the
disagreement is resolved could affect the technical credibility and
acceptability of the final standards that are to be issued, prospectively in the
summer of 2000. In large part, the disagreement has centered on the technical
basis for EPA's extra groundwater protection approach for the repository. In
particular, the National Academy of Sciences, mandated to recommend standards
for the repository, has commented that EPA has not provided a technical
rationale for its groundwater approach and that the agency is proposing to apply
outdated drinking water concentration limits to groundwater at the repository.
The limits are based on 1970s-era dose estimation methods. NRC, DOE, and other
commenters have raised similar criticisms. NRC and DOE have also pointed out
that EPA has not done a comprehensive analysis of the health benefits and costs
of its groundwater approach for Yucca Mountain.
EPA
says that its proposed groundwater protection approach for the repository is
justified on policy grounds and is technically justifiable as well. The agency
seeks to protect groundwater at the site as an environmental resource in a
region where the population has been growing quickly. In addition, EPA says that
the standards for Yucca Mountain should be in accord with
agency policy of coregulating chemicals and radionuclides according to similar
regulatory requirements. EPA believes that its regulatory approach has fully
addressed the pertinent overall technical issues related to setting radiation
standards for the site. EPA officials recognize that the drinking water
concentration limits to be applied to groundwater at the repository are
outdated, but they said the agency is in the process of updating the limits by
the fall of 2000. Further, EPA officials agreed that the agency has not done a
comprehensive analysis of the health benefits and costs of the agency's
groundwater approach for Yucca Mountain. However, they are
developing a regulatory impact analysis to accompany their final standards.
While according to EPA this analysis will not constitute a specific technical
rationale for its groundwater approach, and will not be a comprehensive
cost-benefit analysis, the analysis will address in detail various technical and
cost issues related to the standards' implementation.It does not appear that EPA
and NRC will readily agree on appropriate groundwater protection approaches for
Yucca Mountain. Also, while the two agencies are working on a
memorandum of understanding to clarify their regulatory roles related to nuclear
facility decommissioning, they have made little progress on this matter since
1994 and before. Our June 2000 report to Senator Domenici concludes that
intervention by the committees of jurisdiction may be needed to resolve the
policy differences and clarify the regulatory responsibilities between the two
agencies.
Costs To Implement Radiation Standards Vary But Could Be
Immense In the Long Term
The costs of implementing radiation protection
standards at nuclear cleanup and waste disposal facilities vary from site to
site. For all sites nationwide, the long-term .overall costs could be immense,
likely in the hundreds of billions of dollars, although these costs have not
been comprehensively estimated. Also, EPA, DOE, and NRC analyses indicate that
(1) more restrictive radiation standards are more costly to implement than less
restrictive standards and (2) costs accelerate to achieve the most restrictive
protection levels.
The costs of nuclear cleanup and waste disposal are
largely radiation standards driven.
Over the long term, DOE, as well as
regulated activities, may spend hundreds of billions of dollars in nuclear
cleanup and waste disposal projects, in large part to help protect the public
from radiation exposure. For example, DOE has projected funding for
environmental cleanup at its nuclear sites from fiscal year 2000 through fiscal
year 2070 to be anywhere from $151 billion to
$195 billion (in 1999 dollars). And this estimate could go
higher. In addition, the Nuclear Energy Institute has estimated over
$38 billion in costs to NRC licensees to decommission their
nuclear facilities, including nuclear power plants, in coming decades. Further,
DOE has estimated long-term funding of over $43 billion, and
potentially over $55 billion according to the latest
projections, for the Yucca Mountain repository system, in large
part to help ensure that the public is protected from the high-level waste
stored there. This estimate could also go higher, considering that since 1993
there have been repository-performance- related cost increases of over
$10 billion to achieve added confidence that performance
requirements and radiation protection requirements can be met over thousands of
years. (Furthermore, in planning for commercial low-level nuclear waste
disposal, state compacts and unaffiliated states have incurred almost
$600 million in costs, although no disposal sites have yet been
built.)
Differences in the costs of the EPA and NRC regulatory
approaches to radiation protection have not been comprehensively estimated.
However, agencies' cost analyses indicate that more restrictive radiation
standards cost more to implement, as might be expected. Agencies routinely do
such cost analyses to support their nuclear regulatory efforts. Many such
analyses estimate both the costs and health benefits from meeting radiation
standards, relying on the linear model. Such analyses sometimes determine
hypothetical cancer deaths averted from meeting different protection levels, as
well as dollars expended per hypothetical cancer death averted.8 We examined
numerous DOE, NRC, and EPA cost analyses, which the agencies provided to us as
best available data. Most of the analyses were site-specific, but EPA attempted
a nationwide analysis in 1996. The analysis, to support a prospective EPA
cleanup standard, addressed potential nuclear cleanup costs for 16 generic types
of facilities around the country, based on actual DOE, NRC-licensed, and
Department of Defense sites. The analysis did not address overall soil cleanup
costs for these sites. Instead, it estimated incremental costs to clean up soil
at these sites below a 100 millirem a year baseline, as shown in table 1.
Table 1: Potential Incremental Costs to Achieve Different Soil Cleanup
Levels--EPA Analysis.
As shown in table 1, EPA estimated significant
nationwide cost differences to achieve different cleanup levels, including
differences between the 15 millirem a year and 25 millirem a year levels,
favored by EPA and NRC, respectively, as all-pathway protection levels. In
addition, some DOE and NRC analyses of individual sod cleanup site: either
actual or generic sites showed cost differences in the multiple millions of
dollars per site between the 25-mil!item-a year and 15- millirem-a-year levels.
(According to DOE and NRC officials, sod cleanup analyses do not represent
overall site cleanup costs, which may include additional expenditures, such as
for the decontamination and removal of structures, as well as liquid waste
treatment.)
The EPA, DOE, and NRC analyses also generally showed
accelerating costs to achieve the most restrictive protection levels, below 10
millirem a year. For example, a 1995 DOE analysis of the plutonium- contaminated
Nevada Test Site and test ranges estimated, from a 100- millirem-a-year
baseline, cost increases of over three times to achieve 25 millirem a year, and
over six times to achieve 15 millirem a year, but over 28 times achieve the
5-millirem-a-year level. These accelerating costs can be shown graphically in
the form of a cost curve, as depicted in figure 1:
Figure 1: Cleanup
Costs As A Function of Cleanup Levels--Nevada Test Site Analysis, 1995
Agencies generally did not have analyses showing the cost differences
between EPA's groundwater protection approach and NRC's all-pathway approach.
However, two DOE analyses showed potential multi-million dollar added costs to
meet EPA drinking water standards in onsite aquifers through long-term "pump and
treat" techniques, involving pumping the water out of the ground, treating it,
and discharging it back into the ground. Less aggressive approaches, such as
allowing natural attenuation or dilution of the contamination, were less
expensive.
Mr. Chairman, the cost data and analyses we examined indicate
that protecting the U.S. public from the risks of low-level radiation is a
costly undertaking. This is especially the case at the currently regulated
public exposure levels of 100 millirem a year and below from human-generated
sources--in some cases, levels of fractions of a millirem a year. Protecting at
such levels, well below the levels where radiation effects have been verified,
is essentially a policy judgment by regulators. Such an approach may be arguably
prudent, using the linear model as its fundamental scientific basis. To the
extent that the linear model is in question, new and better research evidence
relating to the validity of this model could alter regulatory policies. In this
regard, the National Academy of Sciences BEIR VII effort is important and bears
watching. However, according to scientists and regulators, conclusive evidence
either validating or disproving the linear model may not be forthcoming for
years, despite the promise of ongoing radiobiological research.
Mr.
Chairman, this concludes my prepared statement. I will be pleased to respond to
any questions that you or Members of the Subcommittee may have.
FOOTNOTES:
1 See Radiation Standards: Scientific Basis
Inconclusive, and EPA and NRC Disagreement Continues (GAO/RCED-00-152, June 30,
2000).
2 See Nuclear Health and Safety:. Consensus on Acceptable
Radiation Risk to the Public Is Lacking (GAO/RCED-94-190, Sept. 19, 1994).
3 A millirem is a commonly used unit of measurement of the biological
effect of radiation. The radiation from a routine chest X-ray is equivalent to
about 6 millirem.
4 All-pathway exposure refers to exposure through
soil, water, and air.
5 Low-level radiation, along with many other
environmental and biological events, may mutate cell structure. To counter these
mutations, which occur by the thousands daily in each human cell, the human body
has active cell-repair processes, though such processes are not entirely error
free.
6 BEIR VI was a 1999 Academy assessment of risks from radon.
7 See for example Nuclear Cleanup: Completion of Standards and
Effectiveness of Land-Use Planning Are Uncertain (GAO/RCED-94-144, Aug. 26,
1994); and DOE: Accelerated Cleanup of Rocky Flats-Status and Obstacles
(GAO)RCED-99-100, Apr. 30, 1999).
8 Such analyses can be potentially
controversial, relying on the linear model to estimate population risks-i.e.,
projecting low radiation exposures across large populations to enumerate
hypothetical cancer deaths.
END
LOAD-DATE: July
19, 2000 
