[ RadSafe ] LNT Petition Discussion

William Lipton doctorbill34 at gmail.com
Mon Jun 29 11:15:10 CDT 2015

I don't think that radiophobia can be blamed on LNT; think Hiroshima, ....
As a practical matter, it's  extremely rare to have a dose exceeding 1 rem
per year at a power reactor.

You're  right that good work practices should stand on their own, but they
don't.   My experience is that management does not worry about
"eventually;" that will be someone else's  problem.

 On Jun 29, 2015 10:50 AM, "Miller, Mark L" <mmiller at sandia.gov> wrote:

> Bill,
> I think that even a cursory review of the basis of our current regulations
> would lead to the conclusion that they are NOT based on science (isn't that
> what we're supposed to be about?).  Starting with the many Calabrese
> articles regarding Dr. Muller's apparent distortion of the facts regarding
> his research, coupled with the understandable Cold War fear mongering, we
> got the 5 rem/year standard we been saddled with for the past 60+ years.
> Defining the EXACT threshold will always be as elusive as determining how
> many angels can dance on the head of a pin.  However, there is pretty
> compelling scientific evidence that nothing quantifiably significant
> happens below 10 rem/year (HPS Position Statement PS010-2).  While it SEEMS
> to be a sensible basis for planning, the fact is that it has led to
> overwhelmingly negative unintended consequences, such as radiophobia and
> the persistent erroneous myth that "no matter how small the radiation dose,
> there is an associated risk".
> I would agree with you comment about ALARA leading to good work practices
> (based on my 39 years in the profession), EXCEPT it gets tied to the
> persistent erroneous myth that "no matter how small the radiation dose,
> there is an associated risk" (there is NOT).  That leads to radiophobia,
> and so on.  Good work safety practices stand on their own merits, and
> management [eventually] understands that they pay dividends.  I believe
> strongly in things like you mentioned (training on a mock up before the hot
> work, keeping a nearby contaminated system filled with water while the work
> is in progress, or sequencing the work logically.  Outages are now much
> shorter and less costly, as well as lower dose. )  However, these practices
> don't need to hide behind a nebulous term like ALARA, not does such a
> nebulous and subjective term have any place in regulations!
> In reality, LNT has led to worldwide radiophobia and has likely caused
> much more harm than the good that was intended.  Go to the NRC website and
> read/comment on the petitions for yourselves.
> http://www.regulations.gov/#!documentDetail;D=NRC-2015-0057-0010
> Mark
> -----Original Message-----
> From: William Lipton [mailto:doctorbill34 at gmail.com]
> Sent: Saturday, June 27, 2015 12:38 PM
> To: The International Radiation Protection (Health Physics) Mailing List
> Subject: Re: [ RadSafe ] LNT
> Many thanks for taking the time to reply to my posting.
> I am not in a position to evaluate the many studies you cite.  You may be
> right, but your view is still far from a consensus.  As you stated, if
> there are 2 opposing hypotheses, one of them must be wrong.  However, keep
> in mind that I am NOT saying that LNT is a fact, only that it is a sensible
> basis for planning, in the absence of overwhelming evidence to the
> contrary.  If unsure of which hypothesis is correct, I'll take the
> conservative one.
> Also, keep in mind that epidemiological studies show association, but not
> cause and effect.  We need a lot more knowledge of radiation biology before
> a reasonable person can accept hormesis.
> In any event, I definitely would not want an expectant mother to be
> exposed to 10 rems, or even 5 rems.
> My 26 years of experience in nuclear power have convinced me that ALARA
> does lead to good work practices.  It forces good work planning.  In the
> "good old days," management often ignored ALARA.  They operated with fuel
> failures, they exposed workers to 3 rems/quarter (They used to schedule
> outages to span a quarter, so they could dose everyone to 3 rems, and then
> start all over, again.), and they did sloppy work.  They lived to regret
> that, having to live with the extra expense of operating a dirty plant.
> Many ALARA practices are cheap and easy, e.g., training on a mock up
> before the hot work, keeping a nearby contaminated system filled with water
> while the work is in progress, or sequencing the work logically.  Outages
> are now much shorter and less costly, as well as lower dose.  Experience
> has shown that the industry can operate effectively while maintaining
> worker exposures ALARA.
> I look forward to seeing how your petitions play out.
> Bill
> On Sat, Jun 27, 2015 at 12:52 PM, Doss, Mohan <Mohan.Doss at fccc.edu> wrote:
> > Dear Bill,
> >     My comments on the problems you listed:
> > (1) When NRC completes its review of the petitions, if it decides they
> > have merit, and agrees that LNT model should not be used for
> > regulations, NRC can ask EPA to change its stance regarding the LNT
> > model. Since we are affected by NRC regulations in our work, it is
> > appropriate to petition NRC about the regulations.
> > (2) Scientific method requires validation of proposed hypotheses with
> > evidence. When evidences support two opposing hypotheses on any
> > subject, only one of the hypotheses can be correct, and the other one is
> wrong.
> > This means, evidences quoted on the wrong side are faulty or incomplete.
> > The subject will ultimately get resolved in the future, resulting in
> > the resolution of the issue. One indication of the resolution of the
> > issue is the reversal of conclusions of the evidences on one side.
> >   In the case of low-dose radiation (LDR) carcinogenicity, atomic bomb
> > survivor data were quoted as the most important data by BEIR VII
> > report and other publications. These data (with the recent update) no
> > longer provide evidence for LDR carcinogenicity, as indicated by
> > recent publications.  For example, in the recent debate on the subject
> > in Medical Physics, Dr. Little did not quote atomic bomb survivor data
> to claim carcinogenicity of LDR.
> > Since these are the most important data, if the updated data supported
> > LDR carcinogenicity, he would undoubtedly have used the data when he
> > made claims of LDR carcinogenicity, as he did in a previous debate.
> > Another data quoted by BEIR VII report, the 15-country study of
> > radiation workers, has also had its conclusion of LDR carcinogenicity
> > reversed. The evidences for radiation hormesis are on firmer footing,
> and have not been reversed.
> > The reversals of major evidences supporting the LNT model indicate the
> > correct side is not likely to b  e the LNT model.
> >    I have been studying literature on this subject for some time, and
> > I am yet to see even a single publication with valid evidence showing
> > low-dose radiation causes cancer.  Extrapolation from high dose to
> > low-doses does not constitute evidence. Of course there are many
> > publications that make such claims, but when they are examined closely,
> invariably major flaws are
> > found in the analysis or data nullifying their conclusion.   Thus, there
> is
> > universal agreement between all the available valid evidences, and so
> > there is no need for consensus. The valid evidences speak for themselves.
> >   Groups such as ICRP do not consist of superior human beings that
> > have better grasp of scientific knowledge that we have to wait for
> > them to give their consensus opinions, when all the valid evidences
> > provide a unanimous conclusion. There is no law or Congressional
> > mandate that EPA has to follow ICRP recommendations.  Their mandate is
> > to protect public and workers from harm due to radiation. Since
> > low-dose radiation does not cause any harm but reduces cancers,
> > regulating low-dose radiation does not protect the public but harms
> > the public, and so EPA's present regulations regarding low-dose
> > radiation are illegal. In fact their regulations have caused
> > incredible amount of public harm by blocking cancer prevention studies
> using low-dose radiation.
> >     You said use of the LNT model is safe, conservative. The
> > experience in Fukushima has shown that it is dangerous to use the
> > model, as indicated by the deaths its use has caused. LNT model is
> definitely not conservative.
> >     Regarding the 10 cSv dose limit during pregnancy: there is
> > evidence that 5 cGy prenatal dose has a protective effect against
> > birth defects caused by subsequent high dose radiation in a mouse
> > model http://www.ncbi.nlm.nih.gov/pubmed/23109298.
> >     (3) I am amused by your statement that ALARA promotes work
> > efficiency.  In reality, LNT model and ALARA makes us do a large
> > number of steps which have no protective effect for workers, patients or
> the public.
> > These steps all add to the expenses which are ultimately paid for by
> > the public, for no benefit to the public. The examples you quoted
> > relate to poor work practices that should be discouraged. No need to
> > invoke ALARA for preventing such practices.
> >    So, I don't see any problems with the petitions. The first seven
> > comments that have appeared in the NRC website have overwhelmingly
> > supported the petitions.
> >     With best regards,
> >                                                   Mohan
> >
> > -----Original Message-----
> > From: radsafe-bounces at agni.phys.iit.edu [mailto:
> > radsafe-bounces at agni.phys.iit.edu] On Behalf Of William Lipton
> > Sent: Wednesday, June 24, 2015 8:02 PM
> > To: radsafe
> > Subject: [ RadSafe ] LTN
> >
> > The NRC recently received petitions from Carol Marcus, Mark Miller,
> > and Mohan Doss requesting that NRC radiation protection regulations be
> > based on hormesis rather than the Linear No Threshold (LNT)
> > hypothesis.  A notice <
> > http://t.signauxsix.com/e1t/c/5/f18dQhb0S7lC8dDMPbW2n0x6l2B9nMJW7t5XYg
> > 7fJZRbW7fKkvK5v_SkHW7fclSC56dwMyf3M8tTM02?t=http%3A%2F%2Fwww.gpo.gov%2
> > Ffdsys%2Fpkg%2FFR-2015-06-23%2Fpdf%2F2015-15441.pdf&si=631043172912332
> > 8&pi=3f637c94-a7fb-4341-9402-45c5eadd5fdc
> > >
> > requesting comments was published in the Federal Register on June 23,
> > 2015.  Although flawed, these petitions are probably worthy of some
> > discussion.
> >
> > The problems with these petitions are best describe in 3 categories:
> >
> > (1) procedural - Since NRC rad protection regulations must be based on
> > EPA guidance, the NRC cannot change their basis even if it wanted to.
> > They should petition the EPA, which superseded the Federal Radiation
> > Council, in 1970.
> >
> > (2) scientific - The EPA requires following scientific consensus, as
> > published by groups such as the International Commission on
> > Radiological Protection (ICRP).  The references quoted by the
> > petitioners do not seem to represent scientific consensus.  It's
> > important to keep in mind that LNT is NOT presented as being real,
> > only as a safe, conservative basis for planning.  One of the petitions
> > even recommends raising the allowed dose for declared pregnant workers
> > AND members of the public to 10 rems.  This is clearly approaching
> levels at which teratogenic effects have been found.
> >
> > (3) practical - Besides assuring adequate standards for radiation
> > protection, the LNT  - based concept of "As Low As is Reasonably
> > Achievable" (ALARA) promotes sound practices which generally increase
> > work efficiency.  Keep in mind that the definition of ALARA specifies
> > practical measures which take economic, technological, and societal
> > factors into account.  I've personally found that, at power reactors,
> > the application of ALARA concepts promotes sound work planning, which
> > increases efficiency and, ultimately, saves money.  (When I began my
> > career in rad protection, in the 1970's, there were reports of
> > physicians increasing x-ray exposure times rather than replacing weak
> > film developer solutions, as well as poorly collimated beams which
> > exceeded the film size.  Also, power reactor Radiological
> > Environmental Technical Specifications allowed plant operation with
> > failed fuel.  Those reactors which did this have long regretted this
> > practice, since it resulted in residual alpha c  ontamination which
> > makes work much more difficult.  Such non-ALARA practices should not
> > be allowed.)
> >
> > Bill Lipton CHP (emeritus)
> > _______________________________________________
> >
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