Nuke Pro: NRC is Proposing to Increase the Radiation We Shall be Hit With by 10 to 100 Time Current Limits, Hormesis

Thursday, August 20, 2015

NRC is Proposing to Increase the Radiation We Shall be Hit With by 10 to 100 Time Current Limits, Hormesis

After you read this mess, you are going to want to submit a response to the NRC, which you can do simply right here. Annoymous is OK too, but I see no reason for it.

http://www.regulations.gov/#!docketDetail;D=NRC-2015-0057

Here are the 3 people who submitted letters to NRC all around the same time frame. Are these people or monsters>?

And here is the "3rd piece of work", he didn't copy the other 2, the other 2 copied each other.

He posted a 6 page letter to NRC, here
http://www.regulations.gov/#!documentDetail;D=NRC-2015-0057-0003

With a lot of references cited....32, but he is the author of 10 of them, LOL.

The ones not authored by Doss (think Dose), all have one thing in common, they call for actual real scientific studies to be done. That is what is missing in all these papers....actual scientific studies. They want to throw LNT out, and replace it with "radiation is good for you" without actually doing the studies. And they are proposing random radiation to be unleashed on the public, not a controlled observed and closely monitored medical procedure.

Citation 31 from Doss list....

Given the high prevalence of breast and prostate cancer, and
evidence of LDI efficacy in other cancers, controlled studies of LDI
in breast or prostate cancer are suggested. Monitoring of specific
tumor markers in the blood, such as PSA, and CT images, would
provide an early indication of regression or lack thereof.

Citation number 1, is a $239 E-book, yeah thanks for that "citation" of which a chapter was publsihed in a website controlled by Doss, called Dose Response.

Adaptive protections have a maximum after single tissue absorbed doses around 100–200 mSv and disappear with higher doses. Low dose-rates initiate maximum protection likely at lower cell doses delivered repetitively at certain time intervals. Adaptive protection preventing only about 2–3 % of endogenous lifetime cancer risk would fully balance a calculated-induced cancer risk at about 100 mSv, in agreement with epidemiological data and concordant with an hormetic effect. Low-dose-risk modeling must recognize up-regulation of protection.

If we accept this homesis promotion literature as "fact" even then their story falls apart rapidly on a quick review. Those fine folks (Doss, Marcus, Miller) are proposing that dose rates up to 100mSV a year be acceptable. But even the citiation above rejects that as "disappear with higher than 200mSV". Disappear means that any potential benefit goes away, and only the bad is left. Well people live more than 2 years....so there is a huge problem with a 100 mSV a year acceptable rate. Even at 100mSv, if you take their statements as fact, you only only balancing out the bad with the good for a breakeven, NOT A NET BENEFIT. The only benefit would be more profit to the radiation industries. Seriously, in the USA average dose is somewhere between 3 and 6 mSV per year, so in 30 years, you would have 90 to 180 mSV cumulative.....the "sweet spots" for HORMESIS, but after that the benefits "disappear".

This is from the Canadian nuke plant worker study, and reanalysed study.

No matter how they try to reprocess the information to minimize the damage to their case, it matters not, clearly those getting over 100mSV career dose are getting 400% more cancer! Over a 30 year carreer, that is just 3.33 mSv per year. And Dr. Strangelove is proposing to allow 100mSv per year?

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Here are some of the comments on this Docket

One in particular I liked, in full here

I do not support the 10CFR20 rule change suggested by Mohan Doss, et al, Dr. Carol Marcus and Mark Miller in their petitions.

The similarity in their petitions makes me wonder who the "man behind the curtain" is that is pursuing this agenda:

From Dr. Carol Marcus' petition (citations removed for clarity):
I will present scientific data as reported in study after study to justify that safety regulations and policies should no longer be derived from the LNT model in order to ensure these requirements are more risk-informed... There has never been scientifically valid support for this LNT hypothesis since its use was recommended by the U.S. National Academy of Sciences Committee on Biological Effects of Atomic Radiation (BEAR I)/Genetics Panel in 1956. The costs of complying with these LNT-based regulations are enormous. Prof. Dr. Gunnar Walinder has summed it up: The LNT is the greatest scientific scandal of the 20th century.

From Mark Miller's petition (citations removed for clarity):
I will present scientific data as reported in study after study to justify that safety regulations and policies should no longer be based on the scientifically unjustified LNT model... There has never been scientifically valid support for this LNT hypothesis since its use was recommended by the U.S. National Academy of Sciences Committee on Biological Effects of Atomic Radiation (BEAR I)/Genetics Panel in 1956. The costs of complying with these LNT-based regulations are incalculable. Dr. Gunnar Walinder has summed it up: The LNT is the greatest scientific scandal of the 20th century.

All three petitioners state the current LNT-based regulations are not based on science. They suggest that low-levels of radiation may have a "hormetic" effect "in which low levels of potentially stressful agents, such as toxins, other chemicals, ionizing radiation, etc., protect against the deleterious effects that high levels of these stressors produce and result in beneficial effects (e.g. lower cancer rates)." (quote from Mr. Miller's petition).

All three petitioners say the benefit of this "hormetic" effect outweighs the cost of the current "As Low As Reasonably Achievable" principle. If this "hormetic" effect exists, then the current "Linear, no-Threshold" standard is denying the public the health advantage of a low radiation dose.

All three petitioners cite the research of B.L. Cohen to support the statement "Comparison of residential radon levels and lung cancer rates in the counties of the USA has shown an inverse correlation between radon levels and lung cancer rates" (quote from Mr. Doss' petition). That is their only substantiation of this "hormetic" principal for ionizing radiation.

Unfortunately, the World Health Organization said this about Cohen's research: "Cohens geographical correlation study has intrinsic methodological difficulties which hamper any interpretation as to causality or lack of causality"
(IARC Monographs on the Evaluation of Carcinogenic Risks to Humans 78. World Health Organization, International Agency for Research on Cancer. 2001, p. 160)

I believe the current "Linear, no-Threshold" standard is satisfactory and that there is no substantial science upon which to base any change in the 10CFR20 limits.

I hope you extend the comment deadline as requested by numerous other commentors. This will allow for a reasoned, timely and informed discussion by commentors from a wide variety of backgrounds and interests.

About me:
I successfully completed the Reactor Operations class at the Reed Research Reactor
I graduated in the top half of my (Officer) class at Naval Nuclear Power School
I passed the Department of Energy, Division of Naval Reactors comprehensive "Nuclear Engineer Officer" exam

Thank you,
Daniel Burke
danielburke1@outlook.com

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Comment (72) of Jeff Davidson on FR Doc # 2015-15441

Please do not change the safeguards currently in place to protect us. Nuclear workers assume additional risk of exposure to radiation. To rase the acceptable level of exposure to...

Public Submission
Posted:
08/20/2015
ID:
NRC-2015-0057-0085

Submitter Name:
Jeff Davidson

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Thursday, August 20, 2015

NRC is Proposing to Increase the Radiation We Shall be Hit With by 10 to 100 Time Current Limits, Hormesis

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