Against the Implementation of Council Directive 96/29/EURATOM (OJ L159 29th June 1996)
the "Basic Standards Directive".

Low Level Radiation Campaign Briefing
on DETR consultation on reforming the
Radioactive Substances Act 1993
to conform with the Directive.

June 1999

Do we really want nine Chernobyl accidents every year for the next ten years?
European Council Directive 96/29/Euratom
the so-called "Basic Safety Standards Directive" on radiation protection.
Low Level Radiation Campaign Briefing June 1999

What’s wrong with the Directive,
What’s wrong with the UK government’s present proposals for transposing it into UK law,
How to respond to them

This Directive was adopted by the European Council of Ministers in 1996. All member states are required to transpose it into domestic law by May 2000. In the UK the transposition is taking place in two parts; revision of the Ionising Radiation Regulations - consultation on this closed a year ago. revision of the Radioactive Substances Act 1993 - consultation closes on 25th June 1999. A further round of consultation is promised for the autumn. The Department of Environment, Transport, and the Regions (DETR) is the lead department. Michael Meacher in the responsible minister. The Directive covers all aspects of ionising radiation. Most of it is uncontentious, but hidden within the text are deregulatory provisions which threaten to allow a flood of contaminated materials into landfill and incinerators, and even into consumer goods.
This can be represented very simply:
nuclear waste contained in licensed sites(9Kb) nuclear waste released to environment(16Kb) radioisotopes reconcentrate in environment(17Kb)
Radioactivity is under regulation inside licensed sites, where radiation doses are mostly to workers who are monitored and are compensated for detrimental effects by the social and financial benefits of having employment. This is in line with the ICRP “Justification” principle to which all authorities pay lip service. Waste is recycled, reused, incinerated, and dumped, steadily increasing the general level of man-made radioactivity in the environment, and exposing the unwitting public whose doses are not monitored, whose health detriment is written off as trivial, and who obtain no social or economic benefit to offset the exposure. Contrary to official assumptions about radioactive discharges in the environment, distribution does not become uniform. Many nuclides reconcentrate through a variety of as yet poorly described physical and biological mechanisms, thus exposing the population unequally. Hot particles remain a permanent source of high local doses to tissue following ingestion and/or inhalation.
Dilution in the Environment

The implications for public exposure are not disputed. The Directive seeks to allow man-made radioactivity to be dispersed as widely as possible, and dilution in the environment is seen as an important means of reducing doses. At the launch of the DETR consultation in March an Environment Agency speaker admitted that "The radioactivity could get onto our cornflakes ...."
Just how dangerous it is to have radioactivity in our cornflakes is, however, a topic of hot scientific dispute not unlike the BSE controversy; the sheer quantity of radioactivity that could be deregulated has been ignored; and the key question of how much of it could be diluted to qualify for deregulation is being fudged.
We deal with each of these issues in more detail below.

How dangerous is it?

It is clear that single atoms of internal isotopes can cause genetic damage. The question is not one of arbitrary dose limits, but of how many such atoms will be released into the environment where we run the risk of swallowing and inhaling them.

The science underlying radiological protection is in crisis. Officially, there is supposed to be "an international consensus" about levels of dose which may be considered "trivial" and "below regulatory concern".
Actually there is no consensus. Many scientists are deeply concerned that the scientific models of health hazard at low dose are seriously in error, and their unease is supported by a large and growing amount of evidence linking disease with radioactive pollution.

This is a complex subject, which has been dealt with in some detail in earlier briefings. We cannot afford much space for it here, but this website has a great deal of information in the Health section of htis site

Scientists working either for the nuclear industry or for institutions like the National Radiological Protection Board which have cosy relationships with the industry, (see more on this on this site) have established concentrations of specific radioisotopes in bulk material which, once deregulated, would cause public exposure doses of the order of some tens of microSieverts from any one practice during a year.
"Practice" in this context means, for example, the recycling of contaminated metal from decommissioning one reactor. The assumption is that since 10microSv is "only" about 0.5% of Natural Background Radiation (NBR) it represents a trivial and acceptable additional risk. Further explicit assumptions are that we might be exposed to radiation from up to ten of these 10microSv sources at once, and that 40microSv is also "of the order of 10microSv", so 40microSv also represents a trivial and acceptable additional risk.
According to officially accepted risk estimates 10microSv per practice, multiplied by 10 overlapping practices would induce 250 fatal cancers in the UK population each year. The ethics of exposing the public to this risk are to say the least dubious, even if it were an accurate estimate, but it is not. It is based on a large number of assumptions. Many of them are extremely crude and some of the most crucial are demonstrably false.
For example: that the effects of man-made and natural radiation are the same
We have evolved genetic repair mechanisms which cope reasonably well with random damage from our radioactive environment; but man-made isotopes have only existed since 1945, and many are very bioactive. There is a great deal of evidence showing that the man-made isotopes are far more likely to cause cancer and a range of other genetically determined diseases.

that chronic internal radiation with alpha and beta emitters has the same effect as acute external irradiation with gamma rays.
This extraordinary leap of faith is central to the accepted radiation risk paradigm. This is the result of basing it on studies of people who survived exposure to the huge single flash of gamma rays from the Hiroshima bomb, and comparing their disease rates with a baseline population who were shielded. The flaw is that both the study population and the controls lived in the city and so were equally exposed to internal radiation from fallout. So the Hiroshima studies tell absolutely nothing about internal radiation.

that there is a linear relationship between dose and health effect.
One of the world’s most senior radiation biologists has called this "a large region of uncertainty", and many studies (even those used by the NRPB to support their paradigm) show a wavy dose/response curve with far higher effects per unit dose in the low dose range;

that the intensity of radiation dose can be understood in terms of a model of absorbed dose averaged across a whole organ or the entire body
there is a long-standing debate about the validity of applying the absorbed dose concept to radiation protection in the low dose range. Genetic mutations are caused at the microscopic scale of the individual cells in the path taken by a single electron as it is ejected from a radioactive atom. Cells which are hit get a massive dose, their neighbours get none.
So we can liken the "absorbed dose" model to emptying a Colt 45 into a football stadium and averaging the effect of the 6 bullets across the whole crowd of spectators. The assumption that between them 25,000 people should be big enough to stop six bullets without significant harm will not console the six grieving families.
When radioactive atoms are built into body tissue the conventional idea of "dose" becomes largely redundant. Some isotopes may be worse than others (no-one yet knows the whole truth) but the decay of any single atom is capable of inducing genetic damage which may induce a lethal mutation.
There is now so much evidence that nuclear pollution, even at the lowest levels, is a cause of the inexorable rise in cancer and other genetic disorders that we should resist having these unstable atoms dumped into the walls of our homes, our soil in our gardens, the cars we drive, and the pots we cook in.
The question then is not "Do the Clearance and Exemption provisions comply with the 10microSv dose criterion?" but "How many radioactive atoms will be released from nuclear sites into the environment where everybody is exposed to inhaling and swallowing them?"

Table 1: Wastes from all sources in stocks at 1.4.94 and predicted arisings in terms of volume and activity. Compare with isotopes releases from Chernobyl of 100,000TBq (source: NIREX)

Dates ILW cu. metres LLW cu. metres ILW activity TBq LLW activity TBq
Stocks 1994 66,102 4177 4,000,000 4
Arisings 1994-99 28,156 69,642 1,700,000 67
Arisings 2000-09 56,271 109,480 3,400,000 105
Arisings 2010-29 37,138 192,459 2,240,000 185
Arisings 2030-59 22,668 291,598 1,370,000 279
Arisings 2060+ 78,979 1,239,720 4,770,000 1187
Total 289,314 1,907,076 17,500,000 1826

(TBq = terabecquerel = 1,000,000,000,000 Becquerels. 1 Becquerel = the radioactive decay of one atom per second)
Low level waste (LLW) and intermediate level waste (ILW) arising between 1999 and 2009 is equivalent to 34 Chernobyl accidents
LLW and ILW arising or already accumulated between 1994 and 2009 is equivalent to ninety Chernobyls
LLW and ILW arising or already accumulated between 1994 and 2059 is equivalent to 127 Chernobyls.

How could radioactive waste qualify for deregulation?

Since the Directive sets no limit on the total quantity of releases, the entire stock of waste held by nuclear site operators could, in principle, be released into the environment... See Part 2 of this Briefing
cartoon: Sgt Mercer Investigates Nuclear Site Clearance (22Kb)

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This page was last updated 23rd September 1999 (except formatting June 2001)