Stakeholder Dialogues - can they be trusted?
Wings of Death & the "Second Event" theory Page Two  Euratom Reading List
"Found: the cause of leukaemia"! Who does Sir Richard Doll think he's kidding? How big is ICRP's error? Depleted Uranium hazards The Scientist and the Airbrush - a case study of what happens when evidence of radiation detriment surfaces
Updates on the Theory Health effects NEWS new issue!Radioactive Times                      new issue!
Reviews of "Wings of Death" and the "Second Event" theory COMARE's Sellafield report
- the fatal flaw
Leukaemia in Wales: latest developments Second Event theory is published at last

Stakeholder Dialogues - is it worth getting involved?

Link to latest news

Link to Radioactive Times comment on Stakeholder Dialogues - DAD is dead - long live UNCLE:

CIRIA is overseeing a Stakeholder Dialogue to develop guidelines for managing land contaminated with radioactivity and chemicals. It is supposed to arrive at a consensus of how such land (mostly nuclear licensed and MoD sites) can be delicensed, after discussions between present licensees (like BNFL), MoD, the Environment Agency, DETR, DTI, potential contractors, and local interests like County Councils, environmentalists, and NGOs.
About sixty people attended a workshop in June 2000 - two from NGOs, two from local authorities, one from the Nuclear Free Local Authorities,
and all the rest from the industry and the regulators.
The Ciria homepage is claiming that the workshop was a great success, but this is questionable, as the absence of NGOs such as Greenpeace, FoE, and site-specific interest groups was repeatedly mentioned a a cause for concern.

LLRC got involved to warn participants that the radiation risk factors to which they will be working are unsafe and that decontamination standards are going to change. Pretty fundamental stuff, but if you were dealing with the health of the people who will be living, working, and growing food on delicensed sites for the next few hundred years wouldn't you want to know?

LLRC duly put the matter on the agenda. Since this is a complex subject we offered some written material. The organisers asked us to submit it for inclusion on their website - they have a Soapbox, which is advertised as

... Topical articles by people involved/interested in the issues addressed by SAFEGROUNDS ...
... written by other stakeholders on relevant topics that they feel passionate about. Other authors will include leading figures from:
liability holders
remediation specialists
NII/HSE/EA
end users
environmentalists
pressure groups
developers
members of the public
CIRIA REFUSED TO PUT LLRC'S CONTRIBUTION ON THEIR SITE
[but it's on this page]

The reason they gave for refusing to publish is that, in the opinion of one member of the steering committee, it was irrelevant as it discussed the effects of fallout. Is radioactivity in weapons test fallout and from Chernobyl in some way different from the radioactivity left on nuclear sites, or was this committee person misleading the ignorant? We referred to fallout (as we often do!) because that is where some of the evidence is to be found that they have got their models wrong.
A second reason was that we had written something they thought was factually wrong. We asked them to be specific but they did not say what is wrong with it. In any case their Soapbox had a disclaimer:

The views expressed in contributions to the SAFEGROUNDS site do not necessarily reflect the views of the SAFEGROUNDS team.

We discussed all this on the 'phone to CIRIA in the summer of 2000. They promised to take the matter to the project steering committee meeting on 22nd August, and to contact us after that. They didn't contact us, and their Soapbox still didn't carry our article. We posted this page on our web site well after August 22nd, so we think we were more than fair to them.

The problem is that Stakeholder Dialogues are commissioned by Government (DTI in this case) and are dominated by nuclear apologists. People with an alternative view are not on the steering committees. They may be invited to give their views in Workshops, but are very likely to lack the human and financial resources to participate fully. (This is based on experience - see this link for more)
And, as Green MEP Caroline Lucas said in July 2000, We should not mistake access for influence.

The lack of representation by NGOs has been addressed by means of a questionnaire, which is a step in the right direction.
But sorry, we still don't mistake access for influence.

Ciria asked LLRC for a meeting, and this happened in January 2001.
In a frank, but polite and businesslike exchange, Cira and the Environment Council explained the dialogue process,
and LLRC explained that their long experience of having their case excluded and misrepresented had led them to put the most sinister reason for being censored.
The objections to posting LLRC's submission turned out to be piffling:
we had not been sufficiently explicit about how the appalling state of NRPB's science had implications for delicensing land;
and
our use of the word scam to describe adding contamination levels from historic discharges to the current UK exemption level to derive a clean-up target level.
It isn't illegal, so it's not a scam, was the objection.
LLRC wasn't going to quibble about that, but pointed out that the European Commission doesn't agree. (More on this later - watch Radioactive Times)

Ciria agreed to post LLRC's submission if suitable amendments were made.


Paper originally submitted to Ciria by email in June 2000

Radioactively contaminated land:
Unappreciated hazards

There is a fundamental issue which has to be resolved before standards for remediation and / or reuse of contaminated land could gain widespread acceptance.

The official view of radiation hazard at low dose is seriously flawed, particularly as far as internal radiation from incorporated radionuclides is concerned. It depends on studies [NRPB says they are "pivotal"] of the survivors of the Hiroshima A-bomb. The group considered to be "exposed" consisted of those who were in the open at the time of the explosion. Their exposure was therefore

· a large dose of
· externally delivered
· gamma rays,
· at high dose rate.

The control group consisted of people who were elsewhere at the time or were shielded. The problem is that both groups, by definition, lived in the bombed cities, and were therefore exposed to ingesting, inhaling and absorbing fallout. This means the studies are silent on internal radiation and the very different types of exposure involved:

· chronic low doses from
· internal
· alpha and beta emitters
· at low dose rate.

It is essentially a physics based model. As far as the epidemiology is concerned all that has been done is to extrapolate the exposed group’s high dose data points in a straight line down to the low dose region. The extrapolation has been widely criticised on various grounds. For example, Goodhead calls it a large region of uncertainty, while others question the validity and relevance of bomb survivors’ data. (we gave the usual references - this is all from our compendium.

A further shortcoming is that doses are averaged over large volumes of tissue, although it is well known that radiation damage to body cells is caused by discrete tracks which either hit vital structures or miss them altogether. The fact that cancers are also known to be monoclonal (i.e. to start with mutations to one cell) ought to alert us to the inadequacy of the averaging approach.

Chris Busby’s Second Event theory describes the hazard from isotopes which decay more than once, where there is an enhanced probability [relative to the yardstick of Natural Background] that a first decay damages a cell, initiating its repair process, and a second or subsequent decay disrupts the repair. NRPB’s Cox and Edwards discuss this in the International Journal of Radiation Biology. Responding, Busby observes that by NRPB’s own calculation the existence of one atom of radioactive Strontium within an individual cell is, as far as that cell is concerned, equivalent to doubling the external natural background exposure.

The great instability of many man-made isotopes makes them "second event" hazards by virtue of their rapid decay. This does not apply to the natural nuclides. However, Busby points out [also in IJRB] that where natural nuclides exist in the form of hot particles they confer "second event" hazards on any tissue in which they lodge; insoluble Uranium oxides are an example. This is of considerable relevance to land re-use, especially as attention begins to be directed to the impact of dust. [Note: There is a DG11/ WHO Symposium on dust in Kos in September.] [Note: In fact this Symposium, at the International Hypocrates Centre, was funded by DG Research It was entitled Is Cancer of Primarily Environmental Origin? The proceedings are, we hear, to be published, and will reveal that the answer to the question is Yes. It was not solely concerned with dust (our mistake), though this aspect was dealt with by LLRC's Dr Chris Busby. He presented a paper on the epidemiology which confirms that radioactive dust is a significant factor in the causation of cancer, and discussed the mechanisms governing the environmental mobility of such dust.]

Human health effects from low level pollution

There is a lot of evidence of effects not accounted for by the NRPB model - too much to list here. There is a Compendium on the Web at www.llrc.org/compendium.htm.

Calculating the error

Post-Chernobyl doses were measured in UK. This allows the authors of a recently published paper 5 to calculate the error in official risk estimates for the first time. From their findings of distinct peaks in infant leukaemia in 1987 - 88 [a phenomenon also observed by others in Greece, Germany, and the USA] they suggest a range of values, depending on which exposure route is responsible for the disease;

· the 88 - 110 microSievert fallout exposure to the combined populations of Wales and Scotland predicts between 0.11 and 0.136 leukaemia cases compared with 12 observed, suggesting an error of between 109-fold and 88-fold
· use of the in utero risk factor of 0.0125 reduces the error to between 55 and 44-fold, though this may be a considerable underestimate since the prediction is for a 70 year lifetime, whereas the disease observations are only for the first year of life.
· if the cause were pre-conception dose to the fathers, then the risk factor for heritable damage of 0.004 may be used to calculate an error of more than 2000-fold.
To cite just one example out of many, an error of this magnitude is easily enough to account for the Seascale leukaemia cluster on the basis of doses from undisputed environmental contamination.

These are matters of peculiar relevance to this workshop, but they are the subject of current debate - new theory and increasing amounts of observed health effects are in unresolved tension with existing standards based on demonstrably bogus science.

These are matters of science, open to proof or disproof, but crucially for Stakeholder processes, they are not amenable to consensus. They are very unlikely to be seen as leading to mutually beneficial solutions or a balance ... with different stakeholders’ needs [let’s not forget that UKAEA, abetted by NRPB, are already interpreting the 400 Becquerels / Kg level which still defines the lower limit of radioactive substances requiring regulation as meaning 400 Bq/kg in addition to the 700 Bq/Kg legacy of man-made contamination at Harwell, which they regard as “background”. This scam will lead to land at 1100 Bq / Kg being sold off for housing, schools and playing fields!] Is this what they couldn't let pass?] Can the present process take these things on board, when the Consultative Group is to advise on non-technical issues, while the Stakeholder Group is to meet only three times in thirty months?


Latest: CIRIA asked LLRC for a meeting.
LLRC's Richard Bramhall met representatives of the Safegrounds and Environment Council teams on 22nd January. This page has been amended to reflect what happened.
During the discussions they told us their specific concerns about the above paper. We revised it and resubmitted it for inclusion in
their Magazine on 16 February 2001.
This page was last updated 27 February 2001

Send mail to bramhall@llrc.org with questions or comments about this web site.

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