Re: A LNT Experience !!NOT!!

[BLHamrick@AOL.COM]

In a message dated 04/17/2002 4:51:56 PM Pacific Daylight Time, muckerheide@attbi.com writes:



> Glad you brought it up! It's shown how much "denial" exists about how
>
> radiation is controlled by the LNT, each seeing only little corner of their
>
> world. And it's no accident! :-)


Ruth, I'm glad you brought it up too.  California has gone absolutely over the edge, and LNT really is to blame.  A judge recently ruled that our adoption of the NRC's License Termination Rule (LTR) was illegal, because we didn't do a CEQA evaluation (CEQA is the state equivalent of NEPA).  It was not exempt from CEQA she said, because it allegedly had a "significant adverse impact on the environment."  She said this, because in her uneducated reading of the law, she seemed to think that because there was no express release limit labeled "decommissioning release limit" in the regulations prior to the adoption of the LTR, that the prior limit was essentially zero radiation above background.


Of course, our lawyers are likely to blame for this.  To my knowledge, none of them are physicists, nor do they have any practical regulatory experience.  God forbid they asked me, a lawyer AND a physicist, for my opinion, advice, counsel or recommendations, because I'm not in their "club."  Having shunned the title of lawyer (despite having passed the Bar), in favor of remaining a humble physicist, I apparently don't qualify to offer legal advice on these cases.  The state's getting what it asked for:  A slap in the face by a technologically illiterate court, enabled by, what by all indications were in my opinion, technologically incompetent counsel.


In the end, this all comes back to LNT, because the only "safe" dose is no dose, in the eyes of the people, the eyes of the court, and apparently in the eyes of all the physicists who don't have the courage, stamina or understanding of the issues to stand up and speak out to our legislators or try to get our views published in the media.


I am sickened by the lies perpetrated by many anti-nuclear types.  Here's just one example:


1.  The EPA's limit on residual radioactive contamination is 1E-6 risk.  WRONG.  They still officially publish the 1960 Federal Radiation Council limit of 500 millirem per year as a recommended dose limit to members of the public.  1E-6 is the recommended starting point for risk evaluations at CERCLA sites.  It is, in no way shape of form, a compulsory limit.  The CERCLA evaluations recommend a risk range of 1E-6 to 1E-4, when there are no ARARs, AND EPA has expressly stated that their acceptable risk range includes, BUT IS NOT LIMITED TO, 1E-6 to 1E-4.  They have NO requirement for decommissionings.  They have a "process," which, by the way, THEY HAVE EXPRESSLY STATED SHOULD NOT APPLY TO NRC decommissioned sites.


I'm sorry about yelling, but I have read more lies in the media in the last four months about our regulations, and about the "dangers" of radiation, all DIRECTLY attributable to the LNT mythology that I have HAD it.  At this point, LNT is as much mythology as hormesis, except that hormesis has a much better chance of actually being demonstrated to be fact.


If anyone knows how to petition the NRC to take back the Agreement State status of a state, I'd be interested in knowing.  The California courts and legislature are clearly determined to incapacitate our agency, and quash our ability to competently regulate radioactive material use here.


Barbara