Community Coalition Against Mining Uranium (CCAMU)
Inquiry on the Impacts of the Uranium Cycle
THE RISK OF RADIOACTIVITY: AN INTERVENTION REGARDING THE EIS OF THE MIDWEST PROJECT
Bill Adamson, Member of ICUCEC, Saskatchewan
The Proponent has recognized the dangers of radiation in uranium mining and has done some careful planning and preparation (pp.3.2225) There have been commendable efforts in lowering the risks through lead shielded machines, movement in steel pipes of ore slurry, ventilation of mine/mill areas, and the use of dosimeters for monitoring radiation levels.
However, the staff of the Regulatory Authorities need to exercise due diligence and to factor in recent scientific discoveries in their assessment.
Analysis of Premises and Working Assumptions
Back in 1962 Michael Polanyi opened a new era when he discovered the importance of analyzing and testing the tacit and unspoken working assumptions underlying scientific procedures. He comments:
“We have seen other examples too, in the work of Kepler and Einstein, to show how the most powerful visions of scientific truth may reveal later elements of fundamental error.” Hence, scientific knowledge keeps changing and shifting, as fresh insights and discoveries are made from generation to generation. One of the essentials is to keep checking the underlying assumptions. Polanyi adds: “A reasonable conception of science must include conflicting views within science and admit of changes in the fundamental beliefs and values of scientists.” (1)
For instance, the Proponent is working under old and former assumptions. Efforts have been made to reduce the radiation doses to workers, therefore the risks of cancer and ill health will be reduced. The logic seems simple. The Proponent has been using this
assumption for a long time. However, there may be other complicating factors.
The AECL workers at Chalk River have always been monitored and kept at low-dose exposures. Yet a Study by the American Journal of Epidemiology discovered that out of 13,570 employees there had been 948 cancer deaths. Such a fact should stir the curiosity and concern of scientists. If the doses to the workers were kept low, why were there so many cancer deaths? (2)
Back in 1995, in the epidemiological studies of the Ontario Miners’ Cohort, Finkelstein and Kusiak wrote: “There is also the suggestion that, for a given exposure, exposure at lower dose rates is more hazardous than exposures at higher dose rates.” (3)
After a series of Studies, the BEIR VII Report (Biological Effects of Internal Radiation) under the National Research Council came up with some surprising conclusions. This group of 19 scientists concluded that, “The scientific research base shows that there is no threshold of exposures below which low levels of radiation can be demonstrated to be harmless or beneficial.” (4)
Other studies had concluded that low-doses of radiation were perhaps more dangerous than high-doses. High-doses of radiation kill cells, which the body works to replace. Low- doses damage cells and chromosomes so that they malinger in a latency period for 15 to 20 years before producing a full blown cancer (5)
This factor has been highlighted by the Petkau Response theory, with illuminating statistics and graphs, illustrating what is known as the supralinear dose response. (6)
Working at the AECL Whiteshell Nuclear Research Establishment in Manitoba in 1972, Dr. Abram Petkau discovered that at 26 rads per minute (fast dose rate) it required a total dose of 3,500 rads to destroy a cell membrane. However, at 0.001 rads per minute (slow dose rate) it required only 0.7 rads to destroy the cell membrane.
“The mechanism at the slow dose rate is the production of free radicals of oxygen (O2 with a negative electrical charge) by the ionizing effect of the radiation. The sparsely distributed free radicals generated at the slow dose rate have a better probability of reaching and reacting within the cell wall than do the densely crowded free radicals produced by fast dose rates.“(7)
These discoveries begin to subvert the old assumption that “low dose means low risk.” The matter is more complex after all .In science one needs to keep checking the assumptions and underlying premises.
Robert Pollock of Areva has put out a coloured brochure extolling the results of a recent Updated Analysis of 17,660 miners and mill workers who worked for Eldorado Nuclear in northern Saskatchewan between 1930-1982. He states that it “contains good news for uranium mine workers.” Why does Pollock set up this “straw man” for his comparisons going back to a 50 year period when there were few safety standards to control radiation doses? (8)
Many improvements had been made from 1982 till 2006. The data were at hand to do an epidemiological study of 12,000 contemporary workers who laboured under much improved conditions and safeguards. Yet the CNSC blocked the study saying that a Consultant had calculated the task to be statistically unfeasible.
It appears to have been a rigged and manipulated feasibility study.
CNSC asked Dr. Geoffrey Howe if he could find evidence that radon gas and alpha radiation would compose a risk securing “five to ten times” the normal rate of cancer. He did not think the statistics would necessarily show such an extreme risk. (9) So, the CNSC jumped in and cancelled the epidemiological study which had already begun. The Proponents were relieved. The Press was ecstatic and went ballistic printing headlines like “Federal agency says workers safe from radiation,” which is untrue and misleading. (10)
Since that time, Dr. Geoffrey Howe completed his Updated Analysis on the earlier cohort of miners and concluded that those uranium miners had a 30% higher rate of cancer than ordinary citizens, and that three quarters of them were still alive, and that there could be still more casualties in the future. (11)
Why would the CNSC decline to do an epidemiological study on miners who had worked in much improved situations and safeguards? Were they afraid that the old assumption of “less dose equals less risk” might not prove out to be the case? Everyone overlooked the additional statement made by Dr. Geoffrey Howe that “…one could argue that those doing a potentially risky job have the right to be monitored to ensure that their health is not being adversely unexpectedly affected.” (12)
Bob Pollock, in his brochure, waxes eloquent stating, “In fact the current risk for uranium workers developing lung cancer due to radon gas exposure is so low that there is no statistical difference between it and the risk faced by the general population.” (13) But this is not stated in the Updated Analysis at all. Pollock unfairly associates his own comments by juxtaposing them with the Study title
Members of the public need to read the Updated Analysis of the Eldorado Miners’ Cohort (2006) for themselves. Bob Pollock’s poetic licence ran away with his wishful thinking! In reality the Updated Analysis concludes:
“ Exposure to RDP (radon decay products) is one of the best
studied carcinogenic phenomena in epidemiology. The results
obtained from these studies, primarily of underground miners,
are very consistent in showing increases in lung cancer risk
from such exposure, but no increases in any other disease.
These results are consistent with physiological considerations
(i.e. where radon products are deposited in the body) and with
many animal studies. The quantitative results of these studies
are also very consistent with the model proposed by the BEIR
IV Committee providing a good fit to most data sets.” (14)
A New Era in Radiological Studies
A new era was introduced with the release of the BEIR VII Report.
This was the latest in a series of sub-committee reports under the National Research Council.
The Study integrated the results of biological studies with recent epidemiological studies in a large study of some 323 pages plus several extensive appendices. The Study acknowledges two competing hypotheses. One is that low doses of radiation are more harmful than a linear, no-threshold model of effects would suggest. The other hypothesis suggests that risks are smaller than predicted by the linear no-threshold model, or that low doses may even be beneficial. (15)
The BEIR Study did state:”The mechanisms that lead to adverse health effects of ionizing radiation are not fully understood. Ionizing radiation has sufficient energy to change the structure of molecules, including DNA, within the cells of the body. Some of these molecular changes are so complex that it may be difficult for the body’s repair mechanism to mend them correctly. However, the evidence is that only a small fraction of such changes would be expected to result in cancer or other health effects.” (16)
The Study did not find sufficient evidence to sustain either hypothesis, however, it came to the following conclusion: “A comprehensive review of available biological and biophysical data supports a ‘linear-no-threshold’ (LNT) risk model—that the risk of cancer proceeds in a linear fashion without a threshold and that the smallest dose has a potential to cause a small increase in risk to humans.” (17)
Another Research Study for Consideration
In 2003 an additional study on radiation risk was published. It was assembled by 46 scientists from across Europe. It was edited by Dr. Chris Busby on the Faculty of the University of Liverpool. It was titled:
2003 Recommendations of the European Commission on Radiation Risk (ECRR): the Health Effects of Ionising Radiation Exposure at Low Doses for Radiation Protection Purposes. (18) It is worthy of serious consideration.
The contributors to this Study felt that a wide cross section of professions needed to be involved in such a complex issue, not leaving it limited only to physicists, radiologists, and medical regulators.
The Study soon questions the system which is used by the International Commission on Radiation Protection which was initiated before DNA was discovered. Recent discoveries about the effects of radiation on tissue cells and chromosomes have triggered the need to take a fresh look at the matter. The Commission had found enough evidence that low-level exposure to man-made radioactive material caused ill health which the conventional models were failing to predict. (19)
The issue of radioactive effects is rather complex for a layman to comprehend. However, the ECRR claimed that conventional models were dealing with external exposure to radiation but did not adequately take into account the internal exposure to alpha particles in the lungs. Alpha particles are highly charged with energy, and apparently fly off in all directions in a spontaneous, random manner.
“A cell is either hit or not hit. . . The small outcome of radiation hits will also depend on DNA repair and replication systems and factors effecting their efficiency. . . . Thus the result of a hit for the cell may range from ‘no measurable effect’ through ‘accurate repair of damage’ through ‘fixed mutation’ to ‘cell death.’. . . . (20)
Hence, the ECRR objects to the “averaging” of radiation doses and dosimeter readings because they do not adequately take into account the nature and effects of radiation exposure.
“For this reason it is important to emphasize that it is the dose to the individual cell which is the parameter of interest. . . In other words,
averaging the energy transferred in a given mass of tissue may suggest a low dose whilst in reality all the energy may be transferred into a very small part of the tissue. Some cells will then receive a very large dose whilst most will get none. Thus, depending on the severity of the dose, the boundary between deterministic and stochastic (random) effects is dependent on the mass of the tissue into which the energy is absorbed.” (21)
This moves us into new area of scientific investigation. “Advances in technology have recently enabled computer control of microbeam radiation sources so that single cells may be hit, and new chromosome staining techniques have enabled their descendants to be identified and checked for damage. This has shown important effects. Genomic instability engendered by radiation at very low doses (i.e. up to 10mSv ) results in an increased level of genetic mutation in the cell which is hit.” (22) The study continues:
“. . . the complex ways in which the organism responds to low dose radiation both at the cell and organism level has been overlooked..”(23)
The simplistic formula that low dose equals low risk is being jostled by other findings like the Petkau Reponse with its “supralinear” function, plus the works of Burlakova, Goffman, and Busby leading to the statement:”However, there are good reasons for assuming that effects in the low dose range from zero close to about 10mSv are likely to follow some kind of supralinear or fractional exponent function.” (24) The supralinear is a response which rises sharply from zero dose but flattens out at a higher dose.(25)
The ECRR Study addresses the topic of premises and working assumptions and the differing scientific methods used by various groupings with respect to radiation effects. It identifies what it believes to be the weakness of a physics based model with respect to internal, low level exposures.
Rather, the ECRR prefers a more radical and complex model that uses an inductive approach that “considers each type of exposure according to its cellular radiation track structure in space and time.” (26) It is complicated to follow the biological and biochemical results of radiation exposure at various stages of biological development, but observations of anomalies that have occurred in historical events makes it important. (27)
The Report questions the utilitarian cost-benefit premise used by the uranium industry. It is one thing to measure costs and benefits, plus the questionable distribution of such benefits to particular segments of the population, and another the intractable measurement of the negative health consequence of radiation releases. In the Canadian scene this is highlighted by the frequent reference to the ALARA Principle—(as low as reasonably achievable). The dollar benefits frequently outweigh the health consequences. (28)
The ECRR also goes into a lengthy discussion of moral and ethical principles involved in radiation risk. For instance, the models of radiation refer largely to the determination of doses to humans, generally to the neglect of animals and plants who are more exposed than people.
Should the nuclear industry be allowed to continue emitting radioactive waste which will cause only a small number of deaths? Since citizens of modern nations have never given consent to the contamination of their bodies by routine emissions of nuclear wastes, and are unlikely to be aware of the processes, such emissions can be considered to be immoral and a neglect of individual rights. Since the severe dangers of smoking have been revealed, many restrictions have been imposed. Should there be restrictions imposed on the release of radioactivity? Is there not a strong case for adhering to the Precautionary Principle? (29)
Is it morally adequate to use natural analogues to downplay the costs and consequences of radiation? For instance, should the risk of one death in 100,000 persons exposed to radiation be discounted in comparison to the larger risk of being killed in a car accident or from cancer caused by smoking? Is it adequate for policy makers to decide that while children will inevitably die from leukemia as a result of radioactive discharges, that since their numbers are quite small that therefore they are not worthy of consideration? The Report concludes: ”If the industry is to continue within a sound ethical framework serious questions need to be addressed and those who will suffer its health consequences need to be informed and consulted to a far greater extent than they ever have been.” (30)
This lengthy exposition deals with rights-based theories, virtue ethics, discounting, cost-benefit, different levels of sensitivity, and collective doses. It makes evident the need for more ethical consideration, debate and dialogue in the Saskatchewan scene.
Responses to Recent Studies on Radioactivity
Several of the major points of the BEIR VII Report and the ECRR Report were brought to the attention of government leaders in Saskatchewan. The study results were sloughed off, brushed aside and ignored. Nor did these regulatory authorities give any studies or empirical evidence to refute these new insights and discoveries of these recent studies. They simply did not deal with the concerns and problems raised. There was no grappling with the conclusions of the BEIR VII report.
On the advice of government staff members, the former Minister of Labour in Saskatchewan wrote:
“The report by the European Committee on Radiation Risk,
portions of which you included in your letter, does not really
present any new information. It simply considers the scientific
literature and then makes extreme assumptions from the data
available. The conclusions of this report, while interesting, do
not enjoy the broad scientific support of the ICRP. Specifically,
risk estimates formulated by the European Committee on
Radiation Risk are in strong disagreement with those of the
ICRP and various other national scientific bodies.” (July 24,
Such a statement is a quick way to brush aside the work of 46 research scientists! It also smacks of what has been termed the
“Culture of Denial.” This reminds one of the writings of Michael Polanyi, who examined the premises and working assumptions of the scientific methods, and concluded that at any time the scientific world might be completely wrong.
Polanyi wrote: “Any contradiction between a particular scientific notion and the facts of experience will be explained by other scientific notions. There is a ready reserve of possible scientific hypotheses available to explain any conceivable event. Secured by its circularity and defended by its epicyclical reserves science may deny or at least cast aside as of no scientific interest, whole ranges of experience which to the unscientific mind appear both massive and vital.” (Personal Knowledge, 1958) (28)
Morton Sinclair is quoted as saying, “It is difficult to get a man to understand when his salary is dependent on his not understanding it.”
The Long View
We do well to recall that once the uranium genie is out of Pandora’s box, the results only magnify down the nuclear chain. Radioactive particles in the wind currents of our planet keep increasing from the millions of tonnes of crushed ore and radioactive tailings; from conversion plants at Port Hope and Blind River; from reactor plants which give off tritium-13 and carbon-16; from the 90 different deadly chemicals in the burnt fuel waste lasting thousands of years; from the increased cases of childhood leukemia near reactor plants; from the tests of 520 nuclear devices; from the explosions of Hiroshima and Nagasaki; from the widespread radiation from the explosions at Three Mile Island, Sellafield, and Chernobyl; from the use of depleted uranium bombs and ammunition over Basra and Baghdad resulting in the mutation and deformity of one out of eight newborn babies in that region. (31)
A Few Observations by the Regulatory Authorities Re The EIA
Health Canada—“The EA does not consider the increase in radiation doses for certain workers in open-pit methods as compared to the previously approved jet-bore technology, nor other considerations like greater fugitive dust emissions associated with open-pit mining. (p.2)
“When the actual mining starts, the radon levels are likely to be much higher in the open-pit mine and the near stock-piled ore (figure 7.1-1)” (p.5) The dangers have not gone away!
Clarification is needed between estimated dose estimates---“The average annual worker dose was 1.2 mSv, which is about half of the predicted value of 2.1 mSv.” (p.8-16) in contrast with “The average dose is estimated to be 3.4 mSv/year, with a maximum dose of 9.4 mSv/year.” (Table 8.2-3) (p. 5).
Re: Human Health—“It is based on too much assumptions based on past studies. . . The attitude of ‘nothing will go wrong’ scenario is not appropriate to modern day science.” (p. 15)
Canadian Nuclear Safety Commission (E-DOCS-#3190441)
“It is the opinion of CNSC staff that these predictions are conservative and that AREVA should be able to achieve lower maximum doses
and ensure radiation doses are as low as reasonably achievable by implementing the protective measures described. . . . “
Its chart indicates a predicted radiation dose level of an average
annual dose for all jobs at 3.4 mSv for mill workers and 2.8 mSv for miners; and a highest average dose for any job group of mill workers at 9.4 mSv. The maximum exposed millworker at 13.4 mSv and for a miner 13.8 mSv.
It may be noted that these dose estimates still fall within the range of 0 to 10 mSv suggested by the ECRR as potential for molecular damage and genomic disturbance. Also, the ECRR recommends a maximum dose for nuclear workers of 5.0 mSv. (pp.74, 83, 84 and 183)
One may read the following statements: “Before laying out the system of quantification of dose that is used in its model, the ICRP admits the possibility of the errors likely to be associated with its use to which the ECRR report draws attention.” (p. 35)
Then again, “Responding for the ICRP, Dr. Valentin, its scientific secretary, told the workshop that the ICRP was an independent body which gave advice on radiation safety, but that those who considered this advice unsafe or questionable were entirely free to consult any other group or organization.” (p.2)
It is my strong recommendation that this controversy needs to be revisited, and the issues thoroughly examined.
The EIS for the Midwest Project, in regards to the effects of radiation, merely continues with “business as usual,” the same old assumptions and formulas, the same old procedures, and does not even acknowledge, let alone make adjustments, for recent discoveries in
biochemistry, radiology, genetics, or epidemiology. It should be rejected until Areva brings its science up to date.
END NOTES---REFERENCE SOURCES
1. Michael Polanyi, Personal Knowledge :Towards a Post-Critical Philosophy, London: Routledge and Kegan Paul, c 1958 & 1962, pp.160,164.
2. “Components and Modifiers of the Healthy Worker Effect. Evidence from Three Occupational Cohorts and Implications for Industrial Compensation.” The American Journal of Epidemiology, Vol.128, No.6, p.1366, c.1986.
3. M. Finkelstein and R. Kusiak, “Clinical Measures, Smoking, Radon Exposure and Lung Cancer Risk among Elliot Lake Uranium Miners,” Health and Safety Studies Unit, Ontario Ministry of Labour, May 1995, p. 1, Emphasis mine.
4 Report In Brief, June 2005, BEIR VII, pp1&2., also
BEIR VII: “Health Risks From Exposure to Low Levels of Ionizing Radiation, The National Research Council, National Academies Press, Washington, D.C. 2006, pp.62, 63.
5. Howe, Nair, Newcombe, Miller, and Abbatt, “Lung Cancer Mortality (1950-80) in Relation to Radon Daughter Exposure in a Cohort of Workers at the Eldorado Beaverlodge Uranium Mine,”
JNCL, Vol. 77, No. 2, August 1986, p. 362.
Geoffrey R Howe, & Ron Stager,”Risk of Lung Cancer Mortality After Exposure to Radon Decay Products in the Beaverlodge Cohort Based on Revised Exposure Estimates,” Radiation Research,146,37-42(1996), p. 41
6. 2003 Recommendations Of the European Commission on Radiation Risk (ECRR): The Health Effects of Ionizing Radiation at Low Doses for Radiation Protection Purposes., ed. By Dr. Chris Busby, Published by Green Audit Press, Aberstwyth, UK. Pp. 78-79.
7. Summary statement by Alexandra McKee-Bennett, in a paper entitled, “The Future For Our Children: The Need to establish a Sustainable Energy Future For Our Children, “Port Hope, Ontario, Sept. 28, 2004, p.5.
8. Communique, Areva Resources, Canada, Inc., May 2007,
“Uranium Miners Cohort Study Update,” p.4.
9. Feasibility Study: Saskatchewan Uranium Miners’Cohort study , Part II,” Senes Consultants, Ltd., October 2003, pp. 3-2.
10 “Federal agency says workers safe from radiation,” Saskatoon Star Phoenix, June 19, 2004, p.A9
11. Dr. Geoffrey R. Howe, Updated Analysis of the Eldorado Uranium Miners’ Cohort, Part I of the Saskatchewan Miners’ Cohort Study, N. Y., Columbia University, March 16, 2006, pp. 14, 26, 41, 46.
12. Feasibility Study, op.cit., p. 3-2
13. Communique, op. cit., p.4
14.Howe, Updated Analysis, op.cit., p.46.
15. Report In Brief, BEIR VII. Op. cit., p.4
16. Ibid., p.2.
17. Ibid., p. 1.
18 2003 Recommendations of ECRR, op. cit.
19. Ibid., p. 2.
20. Ibid., p.73.
21. Ibid., p.74, emphasis mine.
22. Ibid., p. 83.
23. Ibid., p.9.
24. Ibid., p.83
25. Ibid. p.78
26. Ibid., p.8
27. Ibid., p. 8,2.
28. Ibid., pp.20,21
29.Ibid., pp. 24-27
30. Ibid., p.27
31 Morton Sinclair, quoted in the film, “An Inconvenient Truth,” by
32. Film. “Blowin’ In The Wind,” Australian Documentary on Depleted . Uranium, ed. Peter Scott, Frontline Films, 2005. Featuring
Dr. Doug Rokke, Army/Airforce Commander of the DU cleanup.