Thursday, August 27, 2015

Linear No Threshold: Comment to the NRC

Filing a Petition to the NRC for Reasonable Radiation Rules.

I am a member of S.A.R.I., Scientist for Accurate Radiation Information.  Recently, three distinguished members of SARI have filed an NRC petition, asking the NRC to re-visit the radiation protection rule making which is based on the Linear No Threshold (LNT) assumption, and the consequent ALARA (As Low As Reasonably Achievable) rules.  These rules force the nuclear industry (and any other industry using radiation) to assume that ANY radiation is harmful, and protection against radiation must be constantly increased.

Here's the petition in the Federal Register. The comment period is open until September 8, so you have a few days to file your comment.

Update: The comment period is now open until November 19.  (Yes, it surprised me, also.  See the third page of this pdf.)

The Problem with ALARA

Sunrise in Denver
Due to LNT and ALARA, you can't say: the radiation here is so low that the radiation is not a problem.  Since LNT and ALARA claims that all radiation is harmful, it's a constantly escalating fight against any radiation.

Meanwhile, there is no evidence that radiation at the standard background level matters in terms of cancer or birth defects. There is not more cancer in areas with high background radiation (such as Denver) and less cancer in areas with low background radiation (such as the Mississippi Delta).  As a matter of fact, the situation is rather the opposite.  People in Denver tend to be healthier and live longer and so forth.  However, that is more likely to be due to socioeconomic factors than background radiation factors.

There is some evidence that low doses of radiation are protective. This is called hormesis. From what I have read, I have come to think that low levels of radiation are protective, by a sort of vaccination effect. I am also aware that this idea is very controversial.  I am not a biologist, so I don't like to get into the weeds on this.

However, it is completely clear to me that the relationship between cancer and radiation is not linear, or we would have to evacuate Denver posthaste!

Here's a reasonable drawing of the possible shapes of a low-dose radiation effect curve:
  • linear response is curve B 
  • hormesis protection is curve D, 
  • low-dose radiation is worse-than expected is curve A
  • low-dose radiation is not-as-bad-as expected is curve C  

As far as I can tell, nobody knows which of these curves is correct.  A and B are least likely to be correct. All the curves agree at high dose, and the effects are very hard to measure at low dose.
From Lawrence Berkeley Lab
Different hypothesis for radiation dose response

The Comments

I will post my own comment as a separate blog post tomorrow.

Please comment if you can.  Here's the link, and then you have to follow the "submit a formal comment" button.  

It took me a while to comment, because I kept thinking---well, I'm not a biologist etc etc. But just look at the opponent comments!  As you can imagine, a lot of the opposition comments are barely one step above: "Are you frigging crazy!  All radiation is dangerous!"

I decided I could comment.  I figured I could do a little better than that.

Some more background


The three people who submitted petitions to the NRC are:

Dr. Carol S. Marcus, Professor of Radiation Oncology at UCLA
Mark L. Miller, Certified Health Physicist
Dr. Mohan Doss, Associate Professor at Fox Chase Cancer Center

Rod Adams post:

Rod Adams post on pro-nuclear people receiving flak on this (because we are over the target).

NIRS Firing Flak at Pro-Nuclear Fanatics

A couple of random articles I found, plus a link to the S.A.R.I. website, which has more articles

Drosophila Melanogaster
Fruit Fly article the first: Weak radiation doses prolong life in fruit fly females

Fruit fly article the second: Low doses not linear response

(A friend wrote me that he didn't LIKE fruit flies, so what's with the fruit flies?  My answer is one type of fruit fly is frequently used for genetics experiments, and has been for at least fifty years.)



Chris Bergan said...

If anyone, like Mrs. Angwin, is hesitant to write the the NRC, please take a look at some of the other comments. Just be sure to include the docket #2015-15441 and preferably your real name also.

As an example here is comment #58; an obviously rabid anti...

"Are you all f****** insane?! Demonstrate it on yourselves first, show that it doesn't damage your DNA and give you cancer, then we'll consider believing you.

Is it just a coincidence that there's an upside down pentagram in that logo up there?" Submitter Name: Noneof Yourbusiness

Chris Bergan said...

Oops; somehow I posted an incorrect docket number. That one is to a specific comment.

The correct Docket ID is: NRC-2015-0057. There has also been an extension on the comment period until Nov 19.!docketDetail;D=NRC-2015-0057

Thorkil Soe said...

May be the following is useful

Meredith Angwin said...


That is a very good blog post, with good references.

Let me see if I can make the link work.
Thorkil's blog

If not, people can cut and paste the link.


Thorkil Soe said...

I have also written the following: Radon and more - the “more” is about the ridiculous claims related to radiation at Fukushima. Greenpeace and nuclear.
If you can forgive me for my poor language, it may be interesting.

AuldLochinvar said...

When I first read the species name, I was delighted to know it was "the Black Bellied Fruit Fly". The Scots biologist J.B.S.Haldane, in a letter to his future Indian colleagues, described himself as by birth and training a man of violence, but in the name of non-violence noted that "the Hooded Cobra is a beautiful animal, and I should hate to have to kill one."
He also noted that when they experiment even upon flies in his laboratory, instead of releasing them to starve, they kill them with the utmost suddenness, to minimise any possible pain.

AuldLochinvar said...

It is certainly true that there is a level at which all living things that use potassium have RNA or DNA repair mechanisms to nullify the level of mutation from radiation damage at the rate of mere kBq from potassium 40.

Dennis Mitton said...

Asking the NRC to revisit LNT will be tough to impossible. But not too long ago I wrote the ERA regarding an issue with their RadTown page. They stated that humans are immune to the effects of K-40 since we evolved in its presence and have ourselves evolved speacial ways to fend off the radiation. When I wrote to tell them that this was wrong - that the levels are simply so low as to have no net effect - they wrote me back a very nice thank ou letter and promptly changed the site. So now I write EPA Consultnat on my resume!

Good luck.

AuldLochinvar said...

The assumption that nuclear radiation's effects have no threshold of harm is manifestly false. EVERY organism that depends upon potassium is necessarily descended from ancestors capable of surviving the constant nuclear irradiation from its isotope 40.
Every energy resource that was known to the 18th century, and especially wind, was utterly overwhelmed by the fossil carbon industries. Nuclear energy, which resides in thorium and in uranium 238 as well as uranium 235, is newer than that. It is our only hope for reversing or at least halting the climatic changes which continuing use of fossil carbon will cause.
The NRC, before it declines to license or re-license any reactor, should ascertain the carcinogenic and neurotoxic effects of the probable alternatives, which are liable to include gas turbines and "fracking" at the very least.