In late 2010, the Nuclear Regulatory Commission (NRC) requested that the National Academy of Sciences (NAS) Nuclear Radiation and Studies Board (NRSB) investigate the cancer risks around NRC-licensed facilities. In April of 2012, the NAS NRSB released Analysis of Cancer Risks in Populations near Nuclear Facilities: Phase I. The public has until May 30 to submit comments to crs@nas.edu or via fax 202-334-3077 on this nearly 400-page report. Beyond Nuclear has reviewed the report and has concluded the following:
The Phase I report recognizes many of the shortcomings of prior health studies including the imperfection of relying on data from the atomic bomb exposures in Japan, and investigation of cancer deaths only rather than examining incidence.
We support a case-control study as outlined by the NAS phase one report but NOT the ecologic study the NAS seems to be proposing if it contains dose estimates which rely on industry data or if it includes adults. In general, a case-control study of childhood cancer will be the most scientifically defensible and probably the least expensive.
We like that the NAS report recognizes industry collected effluent data and environmental contamination data are incomplete and not reliable for reconstructing doses for individuals. However, the NAS goes on to claim that effluent release data could be used to estimate dose to populations and that environmental contamination sampling could be used to establish the highest dose anyone in the public receives.
Beyond Nuclear contends that an upper dose limit should NOT be established based on measurements of environmental contamination because these data don't give a complete picture of TOTAL environmental contamination over the operational life of a nuclear facility. As a general principal, we would point out that industry effluent and contamination data is so unreliable, no health study should hinge on it. Dose estimates are not necessary to perform a health assessment, and if based on bad data, may actually act to obscure the truth. If a dose assessment is to be performed it should be de-coupled from an epidemiological assessment and done as a separate investigation. This holds true for environmental contamination assessments as well.
Viable, scientifically independent and defensible studies can be conducted based on many of the principles and methods detailed in the NAS Phase I report. But clearly, some of these Phase I report assumptions must be abandoned in order to obtain a scientifically supportable and publicly acceptable picture of cancer risks around nuclear facilities. It is our job, as members of the public, to weigh in on which methods are appropriate. Please send your comments to NAS to crs@nas.edu or via fax 202-334-3077. Feel free to integrate our thoughts expressed above into your statement. Beyond Nuclear will be submitting formal comments as well.