[ RadSafe ] Re: Radiation Hormesis

Wed Jan 2 12:05:48 CST 2008

Hi, Steve.

Having been involved with the public comment process from both sides, I
believe that there is relevance in the words of that great American
philosopher, Robert Heinlein; "You win a track meet by having one guy
who can high-jump seven feet, not seven guys who can each high-jump one
foot."  A few comments from people who can add to the process it is way
better than a lot of comments from people who are adding noise, not
signal.

I've commented on a number of reports, EISs, etc. over the years.  The
three that come to mind as showing definite signs of my comments
changing the final produce were at the national level and specific to
one DOE site.  In each case I believe that the authors were honestly
addressing the issue they were dealing with (which were all pretty
technical and multi-facetted), but had become so focused as to have lost
sight of fairly important points.  I believe that it is likely that if
they had not written the reports, but were reviewing them instead, they
probably would have spotted the problems.

I can sympathize with the people who deal with public comments, as so
often they have to deal with input with somewhat more emotional content
than is useful.  I remember one public meeting about plans to ship spent
fuel by rail at which one commenter (representing a rather large
environmentalist group) objected to the plan because of the "thousands
of cases of random murder" that would be caused by the public being
exposed to radiation while the cars were waiting on a siding.  His
scenario not only required the entire population of the state to spend
24 hrs. standing about 10 ft. away from each car, but to do so for the
dozen or so cars in each train simultaneously.  Another commenter seemed
to labor under the impression that since the shipping containers had
been evaluated for survivability if hit by a crashing jet, the
containers caused jets to crash, and having a number of them in one
place made such a crash almost a certainty.  With input like that I am
afraid that sometimes the people who should be using public comments to
improve their product can loose interest.  

-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On
Behalf Of Steven Dapra
Sent: Monday, December 31, 2007 6:50 PM
To: radsafe at radlab.nl
Subject: RE: [ RadSafe ] Re: Radiation Hormesis

Dec. 31

         I may have been a little hasty when I said public comment was a
fraud and a hoax.  You have obviously had some successes, Mike, and I am
glad to hear of them.  At which level of government were your comments
made?

         I have made public comments concerning local level events, and
have seen other people make comments at them, and our comments were
treated as if they (and we) did not exist.  It's going to take a lot
more than public comments to straighten out the mess in regulation.
Congress is going to have to start exercising rigorous oversight over
the agencies it has loosed upon America.  That's a good stopping point,
lest I commence making a speech.

Steven Dapra

At 09:03 AM 12/31/07 -0800, Brennan, Mike  (DOH) wrote:
>I do not agree with the idea that public comment is useless. I 
>certainly agree that only a tiny portion of the public comments, but as

>long as at least some of that public is knowledgeable about the topic, 
>and as long as the people seeking the comments are willing to listen 
>(both points that I grant are not always true), comments can have an 
>effect.  I can think of three cases in which I submitted comments on 
>drafts or proposals in which I pointed out flaws or logical fallacies, 
>and the final version was changed.  In one case the changes probably 
>prevented millions of dollars of testing and regulation for something 
>that, when you stepped back and looked at it, was not a viable pathway 
>(I pointed out that for radioactive material in sewage sludge there was

>no worker ingestion pathway, as the workers take great care to never 
>get it in their mouths, and if they do not to swallow, and certainly 
>not to have it happen on an ongoing basis, and if they did the rad 
>wouldn't be in the top ten of problems that needed to be addressed).
>
>I am not claiming that these changes were made on my input alone 
>(though in one case the wording in the final was closer to my comment 
>than it was to the wording in the draft), but I do believe that in many

>cases comments are taken seriously and can make a difference.
>
>-----Original Message-----
>From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On 
>Behalf Of Steven Dapra
>Sent: Friday, December 28, 2007 5:52 PM
>To: radsafe at radlab.nl
>Subject: Re: [ RadSafe ] Re: Radiation Hormesis
>
>Dec. 28
>
>          Public comment is a de facto fraud and hoax.  It's an  
>opportunity for a minute portion of the public to blow off steam, or to

>think it may have some salutary influence, while the regulators, etc., 
>go right ahead and do what they planned to do all along.  Besides, who 
>has the time to read that dry-as-dust legalese (in what --- six point
>type?) and decipher what the writers are trying to say, let alone 
>compose a response or a suggestion.
>
>Steven Dapra

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