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RE: COGEMA Says No to LNT
Kai,
Actually, I think you and I are drawing the same conclusions, but are
reading too much into each other comments. Cogema is not making any changes
in the laws or regulations. The IEER report is deliberately misleading.
Have a nice week.
-- John
John Jacobus, MS
Certified Health Physicist
3050 Traymore Lane
Bowie, MD 20715-2024
E-mail: jenday1@email.msn.com (H)
-----Original Message-----
From: Kai Kaletsch [mailto:info@eic.nu]
Sent: Tuesday, May 14, 2002 1:35 PM
To: RadSafe
Subject: Re: COGEMA Says No to LNT
John,
I am sorry you are having such a hard time reading. The IEER report is quite
clear. Let me summarize it for you and maybe then you are in a better
position to answer my simple question about what any of this has to do with
"rulemaking" or "change in regulations" (now that we have at least agreed
that Cogema is not violating any laws by following HPS guidance.):
The IEER claims that Cogema assigned a classification of "zero impact" to
receptors that receive less than 3 mrem. This claim is probably reasonably
factual. The key word here is "impact", this is not the same as deminimis or
below regulatory concern. (Not all regulatory issues boil down to an impact
on a hypothetical human receptor. Often laws are based on best available
technology and are orders of magnitude lower than anything that would be
calculated based on dose targets). I suppose that Cogema is free to argue
that this dose is also below regulatory concern, but some regulator would
have to agree with it. As long as they are talking about "impacts", however,
they are following HPS guidance. (The IEER report (not Cogema) quotes Roger
Clarke.)
IEER (not Cogema) then claims that Cogema's action is the same as applying a
threshold to the theory of radiation. You should know that this is not true,
because you have re-typed the HPS position statement enough times to know
that the HPS position statement stands without explicitly rejecting LNT.
This is where the main break in logic occurs. (Actually, somewhere else in
the report they use the term "negligible risk", therefore even Cogema does
not explicitly reject LNT.)
IEER goes on to say that applying a threshold is contradicting agencies that
have rejected the idea of a threshold. This is all downstream of the main
break in logic and therefore irrelevant.
IEER (not Cogema) back calculates drinking water limits on iodine based on a
3 mrem whole body dose limit to a receptor, presumably to give the
impression that Cogema plans to release 25 times the current limit on
iodine. I didn't think anybody on this list would get fooled by this sort of
nonsense, but apparently someone did, since you seem to question that Cogema
was not willing to comply with US regulations or that changes in regulations
would be necessary.
IEER goes on a rant about Cogema's corporate citizenship and some real or
perceived (I don't know) violations that occurred in the past. What did you
expect IEER to say about Cogema? That they are a great company and everyone
at IEER wishes they could get a job there??? What does that have to do with
considering <3mrem as zero impact?
I think that regulations will eventually change to come more in line with
science. Companies and individuals have to follow whatever regulations are
in place at any given time. I also believe that guidance, such as given in
HPS, is extremely important and I wish more companies would follow it,
unless it violates laws and regulations (which was my original question).
Usually, companies follow the path of least resistance and do not have the
guts to follow HPS guidance on calculating impact. This is a very short
sighted approach.
Personally, I think that the current radiation protection regulations are
fairly reasonable (compared to some other proposed or adopted laws out there
e.g pi = 3). I even believe in ALARA, even though I don't believe in LNT. I
think all industrial emissions and worker exposures should be ALARA,
regardless if the agent is shown to be harmful or not. If the agent is shown
to be beneficial it should be administered by a doctor or through a public
health initiative. Someone can be in favor of water fluoridation but opposed
to a factory puffing out uncontrolled amounts of fluoride. The problem with
ALARA comes when you are dealing with people who forget the R.
Again, I ask what any of this has to do with "rulemaking" or "change in
regulations"?
(BTW, "megalomaniac on a mission from God" were not my words!)
Kai
----- Original Message -----
From: "Jacobus, John (OD/ORS)" <jacobusj@ors.od.nih.gov>
To: "RadSafe" <radsafe@list.vanderbilt.edu>
Sent: Tuesday, May 14, 2002 7:21 AM
Subject: RE: COGEMA Says No to LNT
> Kai,
> I am sorry that you are so confused. First of all, the HPS is not a
> government or regulatory agency. Second, the original post concerning the
> Cogema involved its compliance with laws and regulations, not those of the
> HPS which is a professional society. Third, the report comes from the
IEER
> which is not noted for its pro-nuclear stance and presents a very
disjointed
> report.
>
> My impressions are that if Cogema is going to operate in the US, it will
> have to follow our regulations Doses to workers should be ALARA with a
TEDE
> of 50 mSv and exposures to the general public are to be less than 1 mSv
per
> year. The IEER report implies that the company set a de minimis of 3 mrem
> and quotes Roger Clarke of the ICRP that at low doses, there should be no
> regulatory concern. (I would interpret this as meaning that the any risks
> are too small and exposures have "zero impact" on normal health, e.g.,
> living to 80 years of age.). Then the report says that there is
> disagreements with other agencies such as the NCRP, CDC/NCI and UNSCEAR,
> which say the current data suggest that some cancers do not depart from a
> LNT relationship, and that over relationships could exist. Again, I have
> not problem with these comments as I view them to be biological concepts
and
> not statutory laws and regulations. Then, the report goes into some
weird
> analysis involving that 3 mrem exceeds the ALI for I-129. I use the term
> "blowing smoke." Finally, the report reviews various studies and claims
> that were made against Cogema operations in France. What these have to do
> with operations under US regulations is unclear since I do not see any
> significant, if any, violations of French or international laws.
>
> My conclusion is the IEER report is a typical snow job that is trying to
> raise warning signs and arouse the population to block the planned
> processing of MOX fuel. I must say, it is well researched. I just think
it
> should be reviewed with a critical eye.
>
> -- John
> John Jacobus, MS
> Certified Health Physicist
> 3050 Traymore Lane
> Bowie, MD 20715-2024
>
> E-mail: jenday1@email.msn.com (H)
>
> -----Original Message-----
> From: Kai Kaletsch [mailto:info@eic.nu]
> Sent: Monday, May 13, 2002 3:28 PM
> To: William V Lipton; Jacobus, John (OD/ORS)
> Cc: RadSafe
> Subject: Re: COGEMA Says No to LNT
>
>
> Sorry folks. I guess where I get confused is where in this whole thing is
> "rulemaking" or "change in regulations" an issue?
>
> The way I understand it is that Cogema, in some impact statement, has
chosen
> to follow HPS guidance (or similar: 3 mrem vs. 5 rem?) on how to calculate
> impact. Then there was some unrelated stuff thrown in (not in the Cogema
> report, but in the IEER report discussing the Cogema report) about iodine
> and some unrelated other Cogema issues. I would like to ask you again: Has
> Cogema violated any laws or regulations by following HPS guidance on how
to
> assess impacts?
>
> Feel free to re-type the entire HPS position statement. This doesn't
change
> the fact that HPS specifically instructs NOT to calculate a collective
> impact from small individual doses.
>
> Kai
>
> ----- Original Message -----
> From: "William V Lipton" <liptonw@DTEENERGY.COM>
> To: "Jacobus, John (OD/ORS)" <jacobusj@ors.od.nih.gov>
> Cc: "Kai Kaletsch" <info@eic.nu>; "RadSafe" <radsafe@list.vanderbilt.edu>
> Sent: Monday, May 13, 2002 12:14 PM
> Subject: Re: COGEMA Says No to LNT
>
>
> > John - As usual, you said it better than I could. Let me add: (a) As
you
> > stated, this is a position statement, not rulemaking. Although I
largely
> agree
> > with this statement, I feel strongly that rulemaking must consider
inputs
> from
> > all interested parties, and am highly suspicious of any party which
feels
> he has
> > a monopoly on "scientific truth," whatever that is. (b) Kai seems to
> have
> > overlooked other parts of the position statement such as, "The
possibility
> that
> > health effects might occur at small doses should not be entirely
> discounted."
> > Regardless of "scientific truth," I am strongly opposed to any change in
> > regulations which would allow unnecessary dose or widespread
contamination
> of
> > the environment.
> >
> > The opinions expressed are strictly mine.
> > It's not about dose, it's about trust.
> > Curies forever.
> >
> > Bill Lipton
> > liptonw@dteenergy.com
> >
> > "Jacobus, John (OD/ORS)" wrote:
> >
> > > Kai,
> > > I am not sure what you mean by "the "megalomaniac on a mission from
God"
> in
> > > the HPS." I do believe that the HPS position statement is a position
> > > statement. It has nothing to do with the violation of any law or
> > > regulation. Remember, there is still free speech, and the HPS is
> exercising
> > > its option to make a statement. I believe that their statement is
> valid.
> > > With regard to COGEMA, I believe that the issue is whether or not they
> > > violated a law or regulation, which is a little different.
> > >
> > > By the way, the whole quote from the HPS is
> > >
> > > "In accordance with current knowledge of radiation health risks, the
> Health
> > > Physics Society
> > > recommends against quantitative estimation of health risks below an
> > > individual dose of 5 rem in
> > > one year or a lifetime dose of 10 rem in addition to background
> radiation.
> > > Risk estimation in this
> > > dose range should be strictly qualitative accentuating a range of
> > > hypothetical health outcomes
> > > with an emphasis on the likely possibility of zero adverse health
> effects.
> > > The current philosophy of
> > > radiation protection is based on the assumption that any radiation
dose,
> no
> > > matter how small,
> > > may result in human health effects, such as cancer and hereditary
> genetic
> > > damage. There is
> > > substantial and convincing scientific evidence for health risks at
high
> > > dose. Below 10 rem
> > > (which includes occupational and environmental exposures), risks of
> health
> > > effects are either too
> > > small to be observed or are non-existent."
> > >
> > > -- John
> > >
> > > -----Original Message-----
> > > From: Kai Kaletsch [mailto:info@eic.nu]
> > > Sent: Monday, May 13, 2002 12:16 PM
> > > To: William V Lipton; Jacobus, John (OD/ORS)
> > > Cc: RadSafe
> > > Subject: Re: COGEMA Says No to LNT
> > >
> > > John and Bill:
> > >
> > > Do you disagree with the position statement by the "megalomaniac on a
> > > mission from God" in the HPS?:
> > >
> > > ( http://www.hps.org/documents/radiationrisk.pdf )
> > >
> > > "In accordance with current knowledge of radiation health risks, the
> Health
> > > Physics Society recommends against quantitative estimation of health
> risks
> > > below an individual dose of 5 rem in one year ."
> > >
> > > Isn't that what the report claims Cogema did? Is the HPS position
> statement
> > > in violation of any US laws or regulations?
> > > . . .
> > >
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