Re: NRC Graph

[Al Tschaeche <antatnsu@pacbell.net>]

JMUCKERHEIDE@delphi.com wrote:

> > >>Looked at from this perspective, the graph as presented tends to support
> > >>the misconception that radiation exposures have a phenomenal impact for
> > >>any specific effect. More to the point, how is an uniformed member of
> > >>the public going to look at it? I think they would interpret it as "any
> > >>exposure, no matter how small, results in a significant additional
> > >>risk". How about we show this to a number of people and ask them to
> > >>interpret it?
> 
> I interpret it as misrepresenting the data to the self-interest of the NRC to
> foster public fear that any amount of radiation is a great hazard.
> 
> I'd infer from this graph that NRC is misrepresenting the data, in the
> language Robley Evans used about BEIR 1972 in his 1974 HPJ article, Radium in
> Man, and all who bother to consider the data (either contrary to the LNT, or
> that data that is claimed to support the LNT but can only do so by
> misrepresentation.

Here is a copy of a letter I sent to all of the NRC Commissioners on
this subject.  The underlining and italics and bolding don't seem to be
there so I identified my comments in each paragraph. Sorry it is so
long. I don't know how to make attachments to email yet.  

Perhaps if more of us sent the NRC our concerns, we'd get farther.  Al
Tschaeche

9 December, 1997

Dr. Shirley Ann Jackson, Chairman
U. S.  Nuclear Regulatory Commission
Washington DC 20555

Dear Chairman Jackson:

I have communicated with you before (27 November, 1996) on the matter of
radiation protection.  Although I did not receive a reply to my letter,
I trust that this matter continues to be of concern to the NRC and to
you personally.

I have determined that the NRC continues to tell the American public in
NRC communications that there is no dose of radiation, no matter how
low, that does not carry with it a risk of harm.   For the NRC to
continue to tell the public such a thing seems to me to be incorrect in
light of the current information and data about the beneficial, and zero
effects of low doses of radiation.   Particularly, on the NRC web page,
there is a document, "The Biological Effects of Radiation," accessable
to the public that contains several statements that support my
determination and concern for the veracity of NRC information. 

Specifically the following quotations appear at various places in that
document.  My comments about each NRC statement appear underlined after
the statement.  Concluding comments follow the list.

"Introduction

Whether the source of radiation is natural or man made, whether it is a
small dose of radiation or a large dose, there will be some biological
effects (emphasis added)."  
Comment:  A member of the public interprets "biological effects" as harm
or injury.  This statement would better serve the public if it were
reworded as follows: "Whether ...... there may be some .....( word
‘will' replaced by the word ‘may."

"Exposure Levels
...  The second category (of biological effects of radiation) represents
exposure to low doses of radiation over an extended period of time
producing chronic or long-term effects."  
Comment:  Again, a member of the public reads the sentence as low doses
produce harm.  The sentence would be better if it read: "The second
.....period of time that may produce chronic .....(word ‘producing'
replaced by the words ‘may produce.'

"Annual Exposure to Average U.S. Citizen

...  The principal effect of  low doses of radiation (below about 10
rad) received over extended periods of time is non-lethal mutations with
the greatest concern being the induction of cancer."  Comment:  There
are no data that demonstrate this statement is true!  It is misleading
to tell the public a fact that the NRC does not know is true.  One might
even accuse the NRC of lying to the public in such a statement because I
know that many NRC staff know such a statement cannot be supported by
data.  The princilal effect of low doses of radiation may be beneficial
or at least zero.  The NRC should not tell the public low doses of
radiation are harmful when it is not known that they are.

"Effects of Exposure to Low Doses of Radiation

.... One very important fact to remember is that radiation increases the
spontaneous mutation rate ...."  
Comment:  It is not known that this statement is true for low doses nor
is it known to be true for humans at high doses.  Such a statement is
very misleading to the public and should be deleted.

"Somatic Effects to the individual exposed

... Unlike genetic effects of radiation, radiation induced cancer is
well documented.  Many studies have been accomplished which directly
link the induction of cancer and exposure to radiation"  
Comment:  Not for low doses.  This section is a discussion of the
effects of low doses so these statements are false.  These statements
are particularly misleading to the public because they are false for low
doses. Therefore, the statements should be deleted.

"In-Utero Effects on Embryo/Fetus

... Radiation is a physical teratogenic agent." 
Comment:  Not demonstrated for low doses!  The NRC seems to be trying to
frighten the reader by telling him/her about all of the harm low doses
of radiation cause.  It is not known that any deleterious effects occur
at low doses.

" .... The actual effects of exposure in-utero that will be observed
will depend upon the stage of fetal development.  TABLE: 0-1 weeks after
conception - intrauterine death; 2-7 - developmental
abnormalities/growth retardation/cancer; 8-40 - same as above with lower
risk plus possible functional abnormalities."  
Comment:  None of these effects is demonstrated for low doses!

"Linear No-Threshold Risk Model

General consensus among experts is that some radiation risks are related
to radiation dose by a linear no-threshold model. ... 

NO THRESHOLD - Any dose, no matter how small, produces some risk.
...more exposure means more risk, and there is no dose of radiation so
small that it will not have some effect."  
Comment:  This is the nub of the problem.  The NRC should not endorse
the linear no-threshold hypothesis as a representation of reality.  Any
risks should only be estimated for doses ABOVE 5 rem per year or 10 rem
short term dose.  Nothing should be said about risks from doses below
those levels unless it is to tell about zero effects or beneficial
effects.

Concluding Remarks

It should not be difficult for the NRC to tell the public what is known
and what is unknown about the effects of low doses of radiation.  But
the NRC should not tell the public (or itself or its staff) that low
doses actually do produce harm when it is not known that such is the
case (and low doses may, in fact, be beneficial).

I respectfully request that you instruct the appropriate NRC staff to
examine all public documents for information about low dose effects and
to expunge all language that states or implies that low doses are, in
fact, harmful or have deleterious effects.  When, and if, it is
demonstrated on the basis of human data that low doses are, on balance,
harmful, then, and only then should the NRC say so.

In addition, NRC documents should be examined for discussion of the
concepts of As Low As Reasonable Achievable (ALARA) and Collective
Dose.  ALARA should not be used below 5 rem per year or 10 rem short
term dose unless there is a clear benefit of the reduction based on
prior experience and measured benefits and the harm is not based on the
linear hypothesis.  Collective dose should not be used at all.

Finally, the NRC should question the use of Effective Dose Equivalent
(EDE).  EDE is not demonstrated on the basis of human experience to
represent risk, particularly at low doses.  At high doses EDE is
meaningless where high organ doses are concerned.

It might be worthwhile for the NRC to cause to be performed experiments
to demonstrate the real effects of low doses starting with the premise
that such effects are beneficial.  Many billions of taxpayer's dollars
may be saved and the benefits of nuclear technology experienced as a
result.

Sincerely,



A. N. Tschaeche, CHP


cc:	Commissioner Greta J. Dicus
	Commissioner Nils J. Diaz
	Commissioner Edward McGaffigan, Jr.