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|
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
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
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.)