[ RadSafe ] EPA to make radiation standards more protective? Comments already submitted - add yours!

Neil Keeney gneilkeeney at gmail.com
Sat Aug 2 21:35:06 CDT 2014

Thanks Mark:

I think content of the links you provided were exceptionally well
described. In particular, the excerpts and citations provided by the
Kennecott synopsis seem to support a very good case for  hormesis.

The initiative behind resurrection of this proposed rule-making would seem
to be an effort led by one or, at best, a couple of individuals in a policy
area rather than a scientific viewpoint from the agency as whole...

I continue to puzzle over what actual problem is resolved by the proposed
regulatory limits other than a compulsion to adhere to the precepts and
presumptions of LNT dose.

As you and others have pointed out over time and as has been repeatedly
demonstrated across the domain of biological insults in general, there is
an apparent pro-survival response to and effect from biological insults
delivered at low levels or concentrations.  This example concerns the
classic - bacterial growth versus penicillin concentrations...

These observations were stated to have been cited, ironically enough, by
the some of the earliest radiological researchers, (the Curies) in their
descriptions concerning anaphylaxis .  Recall also that Charles Richet was
awarded the Nobel Prize (*in 1913!)* for his work in this specific area.
Radiation exposure, at low levels, is biologically stimulative and, by all
appearances, enhances organismal pro-survival qualities...

Neil Keeney

On Fri, Aug 1, 2014 at 12:28 PM, Miller, Mark L <mmiller at sandia.gov> wrote:

> Here are some comments that others are making.  Folks should read them and
> submit their own comments ASAP.
> http://radiationeffects.org/2014/08/01/kennecott-uranium-company-comments-on-epas-proposed-anpr/
> http://radiationeffects.org/2014/08/01/u-s-nuclear-regulatory-commission-staffs-comments-on-epas-proposed-rulemaking/
> http://radiationeffects.org/2014/08/01/saris-response-to-epas-anpr-regarding-its-standards-for-nuclear-power-operations/
> http://radiationeffects.org/
> Mark
> -----Original Message-----
> From: Maury [mailto:maurysis at peoplepc.com]
> Sent: Thursday, July 31, 2014 10:22 PM
> To: radsafe at agni.phys.iit.edu
> Subject: [ RadSafe ] EPA to make radiation standards more protective?
> I just wonder if folks on Radsafe are aware of this pending EPA increase
> in radiation restriction/regulation? Is this really what is needed ...
> more regulation? The following is an extract from posting by: Nuclear
> Information and Resource Service. Time is short but I wondered if anyone
> might wish to submit comments to EPA. .
> Best,
> Maury&Dog (MaurySiskel maurysis at peoplepc.com)
> ==============================================
> "Tell EPA to make radiation standards more protective Send additional
> comments to EPA now: deadline is Sunday, August 3 July 31, 2014
> Dear Friends,
> The Environmental Protection Agency's Radiation Standards for the Nuclear
> Power Fuel Chain are so important that NIRS invites you to make a
> supplementary comment before the August 3 comment deadline. You can edit
> the comment we provide; as written it supports a longer document submitted
> by NIRS and many allied organizations. Offering the same points from many
> individuals underscores the importance of these points:
> Nuclear power operations that release radioactivity have been given an
> enormous "free pass" to expose communities (and the biosphere) to levels of
> radiation that are too high. When converted to RISK of cancer, the current
> regulation allows harm 2000 times higher than the EPA's stated goal of
> allowing only 1 cancer in a million from licensed activities.
> Even using EPA's more lax allowable risk level of 1 in 10,000 current EPA
> radiation regulations allow 20 times higher than that....."
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