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Comment & References
This is by no means a complete list of all possible references. I used these in my comment to the NRC on LNT v Hormesis (comment period closes 19 Nov 2015). Not all refs are linked, but are easily found by title author/source. If you come across a link that does not work, please let me know. All comments for the proposed rule change are located at the Federal Register. My documents are listed here: https://www.regulations.gov/?utm_campaig...-0057-0043

1. The Chernobyl Catastrophe Consequences on Human Health Greenpeace, Amsterdam,
the Netherlands http://www.greenpeace.org/international/Global/international/planet-2/ report/2006/4/chernobylhealthreport.pdf Revised version. Published May 2006.
2. Depositional fluxes and residence time of atmospheric radioiodine (I-131) from the Fukushima accident Department of Marine Science, University of Southern Mississippi, 1020 Balch Blvd., Stennis Space Center, MS 39529, USA. Journal of Environmental Radioactivity (Impact Factor: 3.57). 05/2012; 113:32-6. DOI: 10.1016/j.jenvrad. 2012.04.003.
3. Ionising radiation and risk of death from leukaemia and lymphoma in radiation- monitored workers (INWORKS): an international cohort study Klervi Leuraud, David B Richardson, Elisabeth Cardis, Robert D Daniels, Michael Gillies, Jacqueline A O’Hagan, Ghassan B Hamra, Richard Haylock, Dominique Laurier, Monika Moissonnier, Mary K Schubauer-Berigan, Isabelle Thierry-Chef, and Ausrele Kesminiene Published 22 June online by Lancet Haematol 2015; 2: e276–81; http://dx.doi.org/10.1016/ S2352-3026(15)00094-0.
4. A possible association between fetal/neonatal exposure to radiofrequency electromagnetic radiation and the increased incidence of Autism Spectrum Disorders (ASD); Kane, Robert C.; Medical Hypotheses , Volume 62 , Issue 2 , 195 - 197.
5. Radiation and Children: The Ignored Victims Nuclear Information and Resource Service 1424 16th Street NW, #404, Washington, DC 20036;202.328.0002; fax: 202.462.2183 www.nirs.org/radiation/radiationandchildren.pdf.
6. Strong effects of ionizing radiation from Chernobyl on mutation rates Published 10 February 2015 Møller, Anders Pape & Mousseau, Timothy A.; Scientific Reports 5, Article number: 8363doi:10.1038/srep08363.
7. Genomic Instability Induced by Ionizing Radiation Streffer, Christian; Universitätsklinikum Essen, 45122 Essen, Germany PS-1-3.
8. Comparative biology of mouse versus human cells: modelling human cancer in mice Annapoorni Rangarajan and Robert A. Weinberg December 2003 | VOLUME 3, pp. 952-959.

9. MIT No-Evacuations Study Debunked Goddard's Journal, Ian Goddard 5 June 2012 https://www.youtube.com/watch? [/url]
10. A Radioactive Conflict of Interest, Robert Alvarez 25 June 2012 [url=www.huffingtonpost.com/robert-alvarez/mit-radiation-study_b_1623899.html]www.huffingtonpost.com/robert-alvarez/mit-radiation-study_b_1623899.html
11. Biological Research on Low Doses, Operational Issues in Radioactive Waste Management and Nuclear Decommissioning An International Summer School 6th edition Giovanetti, Anna; ENEA UTBIORADCR Casaccia Rome, Italy, 8-12 September 2014, ISPRA JRC (Varese, Italy).

12. The impacts of permanent irradiation on the flora of the eastern ural radioactive trace
Pozolotina VN, Antonova EV, Karimullina EM, Kharitonova OV, Pustovalova LA Radiatsionnaia Biologiia, Radioecologiia / Rossiiskaia Akademiia Nauk [2009, 49(1): 97-106] Journal Article, Research Support, Non-U.S. Gov't, English Abstract.
13. Assessment of radiation impact on Stellaria graminea cenopopulations in the zone of the Eastern Ural Radioactive Trace Russian Journal of Ecology V. N. Pozolotina, E. V. Antonova, E. M. Karimullina 23 November 2010, Volume 41, Issue 6, pp 459-468
14. Public health activities for mitigation of radiation exposures and risk communication challenges after the Fukushima nuclear accident Tsutomu Shimura, Ichiro Yamaguchi, Hiroshi Terada, Erik Robert Svendsen and Naoki Kunugita Department of Environmental Health, National Institute of Public Health, 2-3-6 Minami, Wako, Saitama 351-0197, Japan. Published by Oxford University Press on behalf of The Japan Radiation Research Society and Japanese Society for Radiation Oncology, Accepted February 16, 2015.
15. Understanding the Health Impacts and Risks of Exposure to Radiation Taylor A. Choi, Sylvain V. Costes, Rebecca J. Abergel Reflections on the Fukushima Daiichi Nuclear Accident 2 December 2014, pp 259-281.
16. Examples of regulatory costs for nuclear energy development Rod Adams December 7, 2011 atomicinsights.com/examples-of-regulatory-costs-for-nuclear-energy-development/
17. Radiation Basics Prepared 8/99 by Cindy Folkers, Nuclear Information and Resource Service, 1424 16th Street, NW, #404, Washington, DC 20036. Phone: 202-328-0002. Fax: 202-462-2183. E-mail: nirsnet@nirs.org. Web: www.nirs.org/radiation/ radiationbasics.pdf.
18. The toxicity of engineered nanoparticles on seed plants chronically exposed to low- level environmental radiation E. Karimullina, E. Antonova, V. Pozolotina, A. Tokarev, S. Minko; Russian Journal of Ecology, 28 May 2015, Volume 46, Issue 3, pp 236-245.
19. Radiation: The Myth of the Millirem Nuclear Information and Resource Service 1424 16th Street NW, #404, Washington, DC 20036;202.328.0002; fax: 202.462.2183 http:// http://www.nirs.org/factsheets/mythmilliremfctsht.pdf.
20. Compilation of Radiation Studies Showing Health Effects Compiled by Cindy Folkers & Mary Olson on 4/24/98, Nuclear Information & Resource Service, 1424 16 th St, NW Suite 404, Washington, DC 20036 (202)328-0002 www.nirs.org/radiation/radchart.htm.
21. “Hormesis”—An Inappropriate Extrapolation from the Specific to the Universal DEBORAH AXELROD, MD, KATHY BURNS, PHD, DEVRA DAVIS, PHD, MPH,NICOLAS VON LAREBEKE, MD, MPH; INT J OCCUP ENVIRON HEALTH 2004; 10:335–339 VOL 10/NO 3, JUL/SEP 200, pp. 335-339.
22. ALARA: The History and Science of Radiation Safety Michael Baumer http:// large.stanford.edu/courses/2015/ph241/baumer2/ March 14, 2015 Submitted as coursework for PH241, Stanford University, Winter 2015.
23. Weaknesses in EPA’s Management of the Radiation Network System Demand Attention Report No. 12-P-0417 19 April 2012 www.epa.gov/oig/reports/ 2012/20120419-12-P-0417.pdf.
minor edits 17 July 2015
24. RadNet Air Monitoring: Functioning Beta Stations listed by date and operational status www.enviroreporter.com/radnet-air-monitoring.
25. Radiation Dose Effects in Relation to Obstetric X-Rays and Childhod Cancers Alice Stewart, G.W Kneale Department of Social Medicine, University of Oxford, United Kingdom Volume 295, Issue 7658, 6 June 1970, Pages 1185–1188 www.sciencedirect.com/science/article/pii/S0140673670917824.
26. Tell EPA to keep mobile radiation monitoring lab for nuclear accidents in western U.S. org2.salsalabs.com/o/5502/p/dia/action3/common/public/? action_KEY=20657#.VX8R16Xl6zg.twitter.
27. "Dangerous Decision" Could Leave Californians Vulnerable After Nuclear Disaster www.nbclosangeles.com/video/#!/on-air/as-seen-on/Dangerous-Decision-Could-Leave- Californians-Vulnerable-After-Nuclear-Disaster/307088581.
28. EPA plan to move radiation lab out of Vegas draws protests 24 June 2015 www.reviewjournal.com/news/las-vegas/epa-plan-move-radiation-lab-out-vegas-draws-protests.
29. Why the swine www.superpig.it/en/background/why-the-swine.html
30. Swine as Models in Biomedical Research and Toxicology Testing Michael M. Swindle, Veterinary Pathology 2012, 49(2) 344-356; Medical University of South Carolina, Department of Comparative Medicine, MSC 777, 114 Doughty St, Charleston, SC 29425-7770 vet.sagepub.com/content/49/2/344.full
31. Deconstructing Radiation Hormesis Mossman, Kenneth L. Arizona State University, Tempe, AZ 85287-3501 Health Phys. 80(3):263–269; 2001 www.groenerekenkamer.nl/ grkfiles/images/Mossman.pdf.
32. Implications for human and environmental health of low doses of ionising radiation Radiobiology and Environmental Security Carmel E. Mothersill, Colin B. Seymour pp. 43-51 Department of Medical Physics and Applied Radiation Sciences, McMaster University, Hamilton, L8S 4K1, ON, Canada.
33. Radiological Bioconcentration Factors for Aquatic,Terrestrial, and Wetland Ecosystems at the Savannah River Site (U) G.P. Friday, C.L. Cummins, and A.L. Schwartzman Prepared for the U.S. Department of Energy under contract no. DE-AC09-89SR18035 pbadupws.nrc.gov/docs/ML1016/ML101600579.pdf.
34. Health Effects of Prenatal Radiation Exposure PAMELA M. WILLIAMS, LT COL, USAF, MC, David Grant Medical Center, Travis Air Force Base, California STACY FLETCHER, CAPT, USAF, MC, Ehrling Bergquist Clinic, Offutt Air Force Base, Nebraska Am Fam Physician. 2010 Sep 1;82(5):488-493. www.aafp.org/afp/2010/0901/p488.html.
35. The Impact of Radiotherapy on Fertility, Pregnancy, and Neonatal Outcomes of Female Cancer Patients Jennifer Y. Wo, M.D. and Akila N. Viswanathan, M.D., M.P.H. www.ncbi.nlm.nih.gov/pmc/articles/PMC2865903/ Int J Radiation Oncololgy Biology / Physics 2009 Apr 1; 73(5): 1304–1312.
36. Biological Effects of Radiation USNRC Technical Training Center Reactor Concepts
Manual www.nrc.gov/reading-rm/basic-ref/teachers/09.pdf
37. The Impact of Uterine Radiation on Subsequent Fertility and Pregnancy Outcomes BioMed Research International Wan Tinn Teh, Catharyn Stern, Sarat Chander, and Martha Hickey www.hindawi.com/journals/bmri/2014/482968/ Volume 2014 (2014), Article ID 482968, 8 pages.
38. Residential radon exposure and risk of lung cancer in never smoking women María Torres Duran, Alberto Ruano Ravina, Isaura Parente Lamelas, Virginia Leiro Fernandez, José Abal Arca, Carmen Montero Martinez, Carolina Pena ALvarez, Javier Gonzalez Barcala, Olalla Castro Añon, Antonio Golpe Gomez, Cristina Martínez, Maria Jose Mejuto Martí, Alberto Fernandez Villar and Juan Miguel Barros Dios, ERJ September 1, 2014 vol. 44 no. Suppl 58 P2734.
39. Geographic variation in radon and associated lung cancer risk in Canada Perry Hystad, Michael Brauer, Paul A. Demers, Kenneth C. Johnson, Eleanor Setton, Alejandro Cervantes-Larios, Karla Poplawski, Alana McFarlane, Alan Whitehead, Anne-Marie Nicol journal.cpha.ca/index.php/cjph/article/view/4002.
40. Differences in Lung Cancer Mortality Trends From 1986–2012 By Radon Risk Areas in British Columbia, Henderson, Sarah B.; Rauch, Stephen A.; Hystad, Perry; Kosatsky, Tom, Canada Health Physics: May 2014 - Volume 106 - Issue 5 - p 608–613 journals.lww.com/ health-physics/Abstract/2014/05000/ Differences_in_Lung_Cancer_Mortality_Trends_From.10.aspx
41. What are the risks from medical X-rays and other low dose radiation? B F Wall, BSc, , G M Kendall, PhD, , A A Edwards, MSc, , S Bouffler, PhD, , C R Muirhead, PhD, , and J R Meara, FFPH, Health Protection Agency, Radiation Protection Division, Centre for Radiation, Chemical and Environmental Hazards, Chilton, Didcot, Oxon. OX11 0RQ, UK 2005 www.birpublications.org/doi/abs/10.1259/bjr/55733882?journalCode=bjr.
42. What Three Mile Island, Chernobyl, and Fukushima can teach about the next one Edward Moore Geist April 28, 2014 thebulletin.org/what-three-mile-island-chernobyl-and-fukushima-can-teach-about-next-one7104.
43. Knowing Endangerment: Worker Exposure to Toxic Vapors at the Hanford Tank Farms September 2003 The Government Accountability Project (GAP) www.hanfordchallenge.org/cmsAdmin/uploads/2003_Knowing_Endangerment_002.pdf.
44. Hanford Tank Vapor Assessment Report Savannah River National Laboratory October 30, 2014 SRNL-RP-2014-00791 srnl.doe.gov/documents/ Hanford_TVAT_Report_2014-10-30-FINAL.pdf
45. Measures against increased environmental radiation dose by the TEPCO Fukushima Dai-ichi NPP accident in some local governments in the Tokyo metropolitan area, T. Iimoto, H. Fujii, S. Oda, T. Nakamura, R. Hayashi, R. Kuroda, M. Furusawa, T. Umekage and Y. Ohkubo Radiation Protection Dosimetry 2012 rpd.oxfordjournals.org/content/early/ 2012/08/25/rpd.ncs224.short
46. 250 mSv: Temporary Increase in the Emergency Exposure Dose Limit in Response to the TEPCO Fukushima Daiichi NPP Accident and Its Decision Making Process Shojiro Yasui Journal of Occupational and Environmental Hygiene Volume 12, Issue 4, 2015 pp. D35-D42 www.tandfonline.com/doi/abs/10.1080/15459624.2014.989366#.VZ_90be07M0.
47. Long term behavior of radioactive plume of TEPCO FNPP1 released 134Cs and 137Cs in the North Pacific Ocean through the end of 2014 Aoyama, Michio; Tsumune, Daisuke; Tsubono, Takaki; Hamajima, Yasunori; Kumamoto, Yuichiro EGU General Assembly 2015, held 12-17 April, 2015 in Vienna, Austria. id.3132 http://meetingorganizer.copernicus.org/E...3132-3.pdf.
48. Radiocaesium activity concentrations in macrofungi from Galicia (NW Spain): Influence of environmental and genetic factors M.A. Garcíaa, J. Alonsoa, b, M.J. Melgara, Ecotoxicology and Environmental Safety Volume 115, May 2015, pp. 152–158.
49. Radioactivity studies on farm raised and wild catfish produced in Mississippi, USA J. Billa, F. Han, S. Didla, H. Yu, J. Dimpah, O. Brempong, S. Adzanu Journal of Radioanalytical and Nuclear Chemistry May 2015 doi:10.1007/s10967-015-4159-5.
50. ML15051A503 Marcus pbadupws.nrc.gov/docs/ML1508/ML15083A002.pdf
51. ML15057A349 Miller pbadupws.nrc.gov/docs/ML1508/ML15083A003.pdf
52. ML15075A200 Doss et al pbadupws.nrc.gov/docs/ML1508/ML15083A004.pdf

Addendum A: List of news found via google searches regarding radiation exposures (LNT v Hormesis) https://drive.google.com/file/d/0B7PbzAzkdGjNUGdQcFZ4NVg0YjQ/view? usp=sharing
Addendum B: Nuclear Energy Enshrined in Public Law through Finance, False Science, Intimidation, Lack of Ethics and Special Appointments https://drive.google.com/file/d/ 0B7PbzAzkdGjNUnVYNXhzQl9vUHc/view?usp=sharing

Addendum A

List of news found via google searches regarding radiation exposures (LNT v Hormesis)
Addendum B

[b]Nuclear Energy Enshrined in Public Law through Finance, False Science, Intimidation, Lack [/b][b]of Ethics and Special Appointments [/b]
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Thanks Pia
"All models are flawed, some are useful."
George E. P. Box
Two reports supporting continuation of the linear no-threshold model:

Nuclear Regulatory Commission (NRC) Advisory Committee on the Medical Uses of Isotopes (ACMUI) Final Report on the Hormesis/Linear No-Threshold PetitionsOctober 28, 2015  http://www.nrc.gov/docs/ML1531/ML15310A418.pdf 

Comments of the Natural Resources Defense Council & Committee to Bridge the Gap on the Nuclear Regulatory Commission’sNotice of Docketing Petitions for Rule making 10CFR Part 20 Linear No-Threshold Model and Standards of Protection Against Radiation Docket ID No.NRC-2015-0057 committeetobridgethegap.org/wp-content/uploads/2015/11/NRDC-CBG-Comments-LNT-Docket-19-Nov-2015.pdf

And, the Blue Book Published April 2016: EPA Radiogenic Cancer Risk Models and Projections for the U.S. Population https://www.epa.gov/radiation/blue-book-...population

"A large body of epidemiological and radiobiological data support the risk models. In general, results from these data are consistent with a linear no-threshold (LNT: The assumption that the risk of cancer increases linearly as radiation dose increases. This means, for example, that doubling the dose doubles the risk and that even a small dose could result in a correspondingly small risk. Using current science, it is impossible to know what the actual risks are at very small doses.) dose response model in which the risk of inducing a cancer in tissue irradiated by low doses of radiation is proportional to the dose received."
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They've repackaged this old rule change proposal and you have until 30 May to submit your comments. Same cast of nuclear actors at play, Miller, Mohan & Doss.

Hormesis Advocates Dodge Scientific Rigor With Special Pleadings; Ties To Tobacco Industry-Koch Brothers Exposed By CHP Emeritus – US EPA Comment Deadline May 30th https://miningawareness.wordpress.com/20...-may-30th/

Comment to EPA here: https://www.regulations.gov/docket?D=EPA...-2018-0259
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EPA Press Office (press@epa.gov)

WASHINGTON (April 24, 2018) – Today, U.S. Environmental Protection Agency (EPA) Administrator Scott Pruitt signed a proposed rule to strengthen the science used in regulations issued by EPA. The rule will ensure that the regulatory science underlying Agency actions is fully transparent, and that underlying scientific information is publicly available in a manner sufficient for independent validation.

“The era of secret science at EPA is coming to an end,” said EPA Administrator Scott Pruitt. “The ability to test, authenticate, and reproduce scientific findings is vital for the integrity of rulemaking process. Americans deserve to assess the legitimacy of the science underpinning EPA decisions that may impact their lives.”

This proposed rule is in line with the scientific community’s moves toward increased data sharing to address the “replication crisis”—a growing recognition that a significant proportion of published research may not be reproducible. The proposal is consistent with data access requirements for major scientific journals like Science, Nature, and Proceedings of the National Academy of Sciences as well as recommendations from the Bipartisan Policy Center’s Science for Policy Project and the Administrative Conference of the United States’ Science in the Administrative Process Project.

The proposed rule builds upon President Trump’s executive orders on regulatory reform and energy independence:

Executive Order 13777, issued in March 2017, provides that regulatory reform efforts shall attempt to identify “those regulations that rely in whole or in part on data, information, or methods that are not publicly available or that are insufficiently transparent to meet the standard of reproducibility.”

Executive Order 13783, also issued in March 2017, provides that “It is the policy of the United States that necessary and appropriate environmental regulations comply with the law, are of greater benefit than cost, when permissible, achieve environmental improvements for the American people, and are developed through transparent processes that employ the best available peer-reviewed science and economics.”

Chairman Lamar Smith (R-TX): “Administrator Pruitt’s announcement ensures that data will be secret no more. For too long, the EPA has issued rules and regulations based on data that has been withheld from the American people. It’s likely that in the past, the data did not justify all regulations. Today, Administrator Pruitt rightfully is changing business as usual and putting a stop to hidden agendas.”

Senator Mike Rounds (R-SD): “Sound, reliable science is vital to helping us make important policy decisions that impact the health of American families and their livelihoods. Inserting new levels of transparency in the EPA rulemaking process will help make the agency more accountable to the American people and help everyone understand the impact of EPA’s decisions. Today’s directive is a significant step toward making sure these decisions are not made behind closed doors with information accessible only to those writing the regulations, but rather in the full view of those who will be affected.”

Dr. Edward J. Calabrese, Professor, Environmental Health Sciences, University of Massachusetts: “The proposal represents a major scientific step forward by recognizing the widespread occurrence of non-linear dose responses in toxicology and epidemiology for chemicals and radiation and the need to incorporate such data in the risk assessment process.”

Dr. Louis Anthony (Tony) Cox, President, Cox Associates; Member, National Academy of Engineering; and Editor-in-Chief of the Journal Risk Analysis: “I believe that transparency and independent reproducibility of analyses and conclusions are bedrock principles of sound science. Some commentators have expressed concerns that making the data behind policy conclusions and recommendations accessible and transparent might threaten the privacy of individuals. But this concern can be fully met by applying current privacy-protection techniques for data analysis. These techniques have been developed and used successfully for years at the Census Bureau and elsewhere. Thus, we can have the scientific benefits of accessible data while protecting individual privacy.”

Dr. Jason Scott Johnston, Director, Olin Law and Economics Program, University of Virginia School of Law: “EPA’s proposed rule, Strengthening Transparency in Regulatory Science, is badly needed. “Best practice" among peer-edited scientific journals is to require that data and statistical routines used in published papers be posted online and/or made publicly available. To apply the same standards to research that EPA says justify regulations affecting billions of dollars in economic activity and millions of human lives is essential for those regulations to truly be scientifically based.”

Bruno Pigott, Commissioner of the Indiana Department of Environmental Management (IDEM): “IDEM supports transparency in rulemaking. Good, sound science leads to better regulations.”

Dr. George Wolff, Principal Scientist, Air Improvement Resource, Inc., and former Chairman of EPA’s Clean Air Scientific Advisory Committee (1992 – 1996): “In the development of regulations based on environmental studies, numerous subjective assumptions and choices must be made regarding the selection of data and models that have a profound impact on the strength of any statistical associations and even whether the associations are positive or negative. The appropriateness of the assumptions and choices are not adequately evaluated in the standard peer review process. That is why it is essential that the data and models be placed in the public domain for a more rigorous evaluation by qualified experts. The proposed regulation, Strengthening Transparency in Regulatory Science, will provide an opportunity for such evaluations.”

Read the April 30, 2018 Proposed Rule: Strengthening Transparency in Regulatory Science (PDF) link in the Federal Register.
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There are twenty five points which the EPA is seeking comments on for this proposed rule change affecting radiation exposure standards. Source: https://www.regulations.gov/document?D=E...-0259-0001

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Don Fitz on the book Energy: Missing From the Nuclear Story


"The author insists that only nuclear power can save humanity from energy poverty and, thus, rejection of nuclear power is elitist.  What about nuclear radiation poisoning, which is critical to nuclear dangers?  Rhodes presents a case which may well become the next generation of pro-nuclear apologies. Reviewing theories of 1926, he accuses Herman Muller of committing the original sin of radiation theory after his discovery that low doses of radiation caused genetic mutation in fruit flies. Muller developed the critically important “linear no-threshold” (LNT) model which postulates a “linear” relationship between the quantity of radiation received and the likelihood of cell damage, or, that there is no dose of radiation so small that it is without negative effects.

Rhodes’ attempts to discredit Muller have three disturbing characteristics. First, he bases his arguments on character attacks against scientists and environmentalists. Next, he minimizes or ignores large bodies of data.
Third, his arguments lack internal consistency as he repeatedly contradicts information from different parts of the book.  For example, on p. 324 he claims nuclear power is “carbon-free energy” but on p. 332 says nuclear power creates greenhouse gases during “construction, mining, fuel-processing, maintenance, and decommissioning.”

Rhodes borrows his denunciations of Muller from an article by Edward Calabrese, who brags to have unearthed evidence that Muller suppressed research in 1946. During his Nobel Prize acceptance speech, Muller did not acknowledge that he had received a paper that Calabrese thinks contradicted the LNT theory.  Calabrese’ charge, repeated by Rhodes, is absurd, both because it is ridiculous to think that a Nobel Prize speech would be changed due to one unreplicated finding and because Muller was later instrumental in ensuring the publication of that paper.

It is currently Calabrese, rather than Muller, who is discredited, largely due to his increasingly weird assertions that acceptance of the LNT theory was due to “falsifying and fabricating the research record.”  Calabrese’s objectivity is also called into question by his funding from the nuclear industry and companies such as ExxonMobil, Dow Chemical, and General Electric.

Calabrese’s hostility could also be due to the near-universal rejection of his “hormesis” theory that small levels of radiation benefit human health. In 2006, Calabrese made arguments for hormesis to the international Committee on Biological Effects of Ionizing Radiation which rejected them in favor of the LNT model. The LNT model is accepted by a long list of agencies and health organizations.

Many researchers have documented effects of low level radiation (LLR) from the various stages of nuclear power production, background radiation, X-rays and CT scans.  Since Muller’s first experiments on fruit flies, other studies show these insects being susceptible to radiation levels 50 times lower than found then.  As fruit fly research faded away, by the 1970s it was replicated with mice."
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If the linear no threshold dose model is correct, then we have nothing to worry about most nuclear fallout

Its odd to me that some people...anti nukers...clamor for it, yet its the system being used...the system that insists its impossible to have cancer  clusters around nuclear plants or that nobody will die from Fukushima
Non-linear responses, different transistors have different response curves to reach full conductance.  Radio-iodine dose thresholds are different than radio-cesium dose thresholds.  Source matters as they have different absorption risks.  Nuclear fallout is something to be concerned about because it is different than pre-atomic background radiation sources.
"The map is not the territory that it is a map of ... the word is not the thing being referred to."
Code: What anti-nukers are making a fuss about regarding EPA's LNT is that pro-nukers want the feds to recognize their own/special version of radiation health paradigm, which ultimately puts more people at risk, especially women and children. LNT is not perfect, but it's a heckuva lot better than what Miller, Marcus, Doss, SARI et. al. want to replace it with.
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(08-28-2018, 01:17 PM)piajensen Wrote: Code:  What anti-nukers are making a fuss about regarding EPA's LNT is that pro-nukers want the feds to recognize their own/special version of radiation health paradigm, which ultimately puts more people at risk, especially women and children. LNT is not perfect, but it's a heckuva lot better than what Miller, Marcus, Doss, SARI et. al. want to replace it with.

There is a problem...a big one...with the LNT dose risk model.  It underestimates danger by hundreds of times.  Inherent in the model is the assumption that all nuclear radiation has a similar biological effect.  This idea perpetuates the biggest excuse ever made for man made fallout;  namely that it is no worse than background radiation. 

So when the activists insist on this LNT model, they perpetuate a misunderstanding of radiation effects which also permits the poisoning of the ecosphere with nuclear fallout.   Why ignore this?  Activists are working against their cause.

It is very disappointing that the activists clamor for the risk model already in existence, thus perpetuating ignorance and the poisoning of life on earth. 

The healthiest human who ever lived had a radiation load of about 70 bq/kg which is 700% more radiation than the amount causing heart disorders in children.  Thus, radiation = radiation effect is not true.

" We should pay particular attention to the fact that the presence of even relatively small amounts of Cs-137 in children from 10-30Bq/kg leads to a doubling in the number of children with electrocardiographic disorders "

Instead, the anti nuclear activists should stand up for great pioneers like Bandazhevsky who have labored long to uncover the truth of man made radiation

It's a Catch-22. If we push for revising nuclear guidelines now, with the cureent regime in charge, we'd probably wind up with a far worse set of guidance.
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(11-17-2018, 11:28 AM)piajensen Wrote: It's a Catch-22. If we push for revising nuclear guidelines now, with the cureent regime in charge, we'd probably wind up with a far worse set of guidance.

That is an assumption.   The push to revise nuclear guidelines should be based on the sound science of dosimetry coming from Chernobyl, for example the findings of Bandazhevsky, Yablokov and others, which would require more stringent guidelines of exposure to man made nuclear products.   Not a small adjustment either.  It is the ICRP LNT dose model that allows the nuclear industry to exist, yet the anti nuke activists insist on it.   That isnt sane....
That definitely has merit, but considering the persistent forces in the US and abroad that are tenaciously trying to corrupt the current LNT guidance, I can't help but think we'd have one heckuva uphill battle at this time. Should the Presidency, House & Senate solidly flip to dems in the next rounds of elections, then I think we'd have more leverage.
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There have been some calls to drop the LNT model as Code says. I haven't seen anything better to replace it with yet. Pia, sadly a blue wave takeover would not help either. Dems bow as low to the nuke industry as the Reps do. Dr. Ian Fairlie has some advice I think worth mentioning on his website. https://www.ianfairlie.org/?s=lnt

LNT: an idea which should be retired? No, it should be retained
"The map is not the territory that it is a map of ... the word is not the thing being referred to."
" I haven't seen anything better to replace it with yet. "

wow, really?   What about the recommendations of the European Committee on Radiation Risk?   What about Bandazhevsky?

I can hardly believe it.   The LNT ICRP model is the PROBLEM, not the solution.   Pee -Are -Oh -Bee -El -EE -Em......what does that spell?

'the tiniest doses from ingested or inhaled radioactive materials released by accidents like Chernobyl and Fukushima, produced by the 1960s atmospheric bomb tests, and emitted routinely under licence from nuclear sites like Sellafield and Hinkley Point, kill and deform babies at doses of less than 1mSv.

The Government and the nuclear industry defend the ICRP position by referring to natural background radiation. But, though it is true that life has been exposed to natural background radiation, including radon, throughout evolution, there has never been on Earth, prior to 1945, the new Uranium fission and activation products like Strontium-90, Caesium-137, Tritium, Carbon-14, Plutonium-239 and their nasty ‘daughters’ and relations. These substances and the entirely new, airborne, radioactive, pure particles of uranium and radium only appeared about 70 years ago. Already we can see the terrible damage they have caused to the human genome.'

strong effects of ionizing radiation from Chernobyl on mutation rates

Timothy A Mousseau

The surprisingly high mean effect size suggests a strong impact of radioactive contamination on individual fitness in current and future generations, with potentially significant population-level consequences, even beyond the area contaminated with radioactive material.


Genetic Radiation Risks-A Neglected Topic in the Low Dose Dabate

"The evidence supports a dose response relationship which is non-linear and is either biphasic or supralinear  and largely either saturates or falls above 10 mSv. Conclusions We conclude that the current risk model for heritable effects of radiation is unsafe. The dose response relationship is non-linear with the greatest effects at the lowest doses. Using Chernobyl data we derive an excess relative risk for all malformations of 1.0 per 10 mSv cumulative dose. The safety of the Japanese A-bomb epidemiology is argued to be both scientifically and philosophically questionable owing to errors in the choice of control groups, omission of internal exposure effects and assumptions about linear dose response."


make of it what you will;

"Radiation Dose Is Meaningless"


F. Whereas, the ICRP has not taken into consideration new discoveries of non-targeted effects
such as genomic instability and bystander or secondary effects with regard to understanding
radiation risk and particularly the spectrum of consequent illnesses,

G. Whereas, the non-cancer effects of radiation exposure may make it impossible to accurately
determine the levels of cancer consequent upon exposure, because of confounding causes of

H. Whereas, the ICRP considers the status of its reports to be purely advisory,

I. Whereas, there is an immediate, urgent and continuing requirement for appropriate regulation
of existing situations involving radioactivity, to protect the human population and the biosphere,
We the undersigned, acting in our individual capacities

1. assert that
the ICRP risk coefficients are out of date and that use of these coefficients leads to
radiation risks being significantly underestimated,

2. assert that employing the ICRP risk model to predict the health effects of radiation leads to
errors which are at minimum 10 fold while we are aware of studies relating to certain types of
exposure that suggest that the error is even greater,

3. assert that the yield of non-cancer illnesses from radiation exposure, in particular damage to the
cardio-vascular, immune, central nervous and reproductive systems, is significant but as yet

urge the responsible authorities, as well as all of those responsible for causing radiation
exposures, to rely no longer upon the existing ICRP model in determining radiation protection
standards and managing risks,

urge the responsible authorities and all those responsible for causing exposures, to adopt a
generally precautionary approach, and in the absence of another workable and sufficiently
precautionary risk model, to apply without undue delay the provisional ECRR 2003 risk model,
which more accurately bounds the risks reflected by current observations,

6. demand immediate research into the health effects of incorporated radionuclides, particularly
by revisiting the many historical epidemiological studies of exposed populations, including reexamination
of the data from Japanese A-bomb survivors, Chernobyl and other affected
territories and independent monitoring of incorporated radioactive substances in exposed

7. consider it to be a human right for individuals to know the level of radiation to which they are
exposed, and also to be correctly informed as to the potential consequences of that exposure,

8. are concerned by the escalating use of radiation for medical investigation and other general

9. urge significant publicly funded research into medical techniques which do not involve
radiation exposures to patients.

Statements contained herein reflect the opinions of the undersigned and are not meant to reflect
the positions of any institution to which we are affiliated.

Professor Yuri Bandazhevski (Belarus)
Professor Carmel Mothersill (Canada)
Dr Christos Matsoukas (Greece)
Professor Chris Busby (UK)
Professor Roza Goncharova (Belarus)
Professor Alexey Yablokov (Russian Federation)
Professor Mikhail Malko (Belarus)
Professor Shoji Sawada (Japan)
Professor Daniil Gluzman (Ukraine)
Professor Angelina Nyagu (Ukraine)
Professor Hagen Scherb (Germany)
Professor Alexey Nesterenko (Belarus)
Dr Sebastian Pflugbeil (Germany)
Professor Michel Fernex (France)
Dr Alfred Koerblein (Germany)
Professor Inge Schmitz Feuerhake (Germany)
How do the ICRP and ECRR change the LNT model?  They have different coefficients, yes, and I think ECRR more realistic of the risk.  

The linear no-threshold theory of radiation risks
Quote:D. The Importance of LNT in Radiation Protection

Regardless of dissenting views on LNT, the reality is that most if not all concepts used in radiation protection today are strongly based on the LNT theory. For example, LNT allows radiation doses (i) to be averaged within an organ or tissue, (ii) to be added from different organs, and (iii) to be added over time. The LNT also underpins the concepts of absorbed dose, effective dose, committed dose, and the use of dose coefficients (eg Sv per Bq of a radionuclide).

The use of the LNT also permits
•the ICRP principle of limitation – ie annual dose limits/constraints
•the ICRP principle of optimization -ie comparison of practices
•radiation risk assessment at low and very low doses
•individual dosimetry with passive detectors
•the use of collective dose, and
•the use of dose registers over long periods of time.

In fact, the LNT underpins all legal regulations in radiation protection. Indeed if the LNT were not used, it’s hard to imagine our current radiation protection systems existing at all.

The ECRR doesn't argue against LNT.  It argues against the multipliers used by the ICRP to determine risk.  Both ICRP and ECRR dose coefficients would still be a linear response at low dose, LNT, just a different slope to the line.  I think we could agree that a better LNT model would use ECRR annual dose limits/constraints instead of ICRP recommendations.
"The map is not the territory that it is a map of ... the word is not the thing being referred to."
" Both ICRP and ECRR dose coefficients would still be a linear response at low dose, LNT, just a different slope to the line.  I think we could agree that a better LNT model would use ECRR annual dose limits/constraints instead of ICRP recommendations."

well I dont agree there.   How dangerous is a dose of 70 bq/kg of internal radiation?   How dangerous is a dose of zero bq/kg of man made radiation?  It turns out that the cross species bystander effect confers danger to an animal exposed to zero becquerels of radiation, whereas the healthiest animal to ever live was continuously exposed to 70 bq/kg of radiation from potassium....as we well know.

I realize there are people who want to raise the radiation limit, and set some kind of threshold.  Their thinking does not stand up to scientific scrutiny.  They are either fooled by some studies or motivated by greed.  Should I compromise truth and safety because of such people?

The dose effect is not linear. Different sources of radiation cause different biological effects.   For this reason any kind of CONCEPT based on a linear dose response is simply flawed.  Worse than flawed, it is misleading.   

That kind of thinking allows the nuclear industry to excuse itself as being less dangerous than background radiation, and this is also proof for the public.   It makes intuitive sense to them.  It is the message from Woods Hole and NOAA and everyone.  They are fooled and thus the nuke industry continues.

Read the bystander effect thread for more information


Busby et al 
"ionizing radiation has been shown to
cause genomic instability in cells and their descen-
dants  and through the ‘bystander effect’
also in cells in the vicinity of an ionization track which
have not themselves been intercepted. These
genomic/bystander effects are sharply supralinear at
the lowest doses and saturate after two or three tracks
per cell and this raises questions about the basis
of the ICRP linear no-threshold model currently
employed. These discoveries also suggest that the
outcome of radiation exposure will be a general effect
on morbidity and not merely somatic or heritable
mutation effects"

(PDF) Ionizing radiation and children's health: Conclusions. Available from: https://www.researchgate.net/publication...onclusions 

Note that nuclear fallout causes general morbidity with likely no threshold, whereas background radiation, at least some forms, may not cause any morbidity, and is possibly a useful aspect of biology.  There may also be a threshold. 

more from Busby

"The ICRP radiation risk model, developed in 1952 and currently still the basis of legal limits has failed the human race and is now embarrassing in its manifest error....This situation has now become embarrassing to the scientific community and to the commitment of scientific philosophy to accepting truth from experiment and from observation."

In this paper you can see Busby and others disagree with the linear no threshold model

But very little background is given in that paper.  In fact nobody knows the full answer to the radiation exposure question.   Yet the Linear no threshold concept is a stranglehold on understanding.  that concept is wildly untrue considering the bystander effect, which is now considered by science to dominate low level radiation effects.

Anti nukers and pro nukers alike need to open their minds...perhaps read a few more studies

radiation does not equal radiation.   That is a fact!
Horse: I was thinking about the younger, thinking, people who are getting elected, like Tulsi Gabbard,not so much the 'blue wave' in general. With more people in office employing critical thinking and analysis, unlike the rubber-stamping, mindless lifers on the hill, there is greater opportunity to crack the calcified 'brain' of those charged with looking out for the people. For me, it isn't about party affiliation, though I'd steer clear of repugs. Yes, dems have a bad record also.
just pm me if needed.
Big Grin 
Here's an idea. Pile up all the documented radiation damages to health, realize the LNT debate plays into maintaining nuclear enterprises (energy & weapons) and declare that nuclear radiation is simply too damaging to carbon based life and eliminate all nuclear ventures, There. Problem solved. No need to wade through volumes of radiation data & propaganda. Time saved can be spent on securing the future.  Heart
just pm me if needed.

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