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 was asked to comment by May 31. Many individuals and concerned citizens' groups submitted comments. Beyond Nuclear submitted comments along with Dr. Sam Miller who also submitted his original research in support of his comments made jointly with Beyond Nuclear. Now the Nuclear Regulatory Commission must decide if they will support Phase II of the study which recommends examining 6 pilot sites in Illinois, Connecticut, New Jersey, Michigan, California and Tennessee. Some issues raised in these two sets of comments include:
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.
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, contamination, and weather pattern data is so unreliable, no health study should hinge on it. For weather pattern data, Dr. Miller's research and comments address how detailed weather examinations must be in order to reflect reality. Weather data from industry is not detailed enough. 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.