Re: De Minimis - Again: Please No!

[Muckerheide <muckerheide@mediaone.net>]

Hi Joyce,

I appreciate your intent to do 'de min'. But the concept is
flawed, and was rejected for those flaws before, and likely will
be again. Plus, if you got it, the final 'negotiated' result is
likely to be at such minimal levels by the time the institutions
extracted their 'poound of flesh' that it would be of marginal
value. (The Exec VP of one of my utilities instantly stated when
it was proposed by NRC before: 'We won't use it.' (Of course, in
the future, the cost will be paid by the utility in a private
competitive industry driven by costs, instead of being able to
just stick costs to the unwitting ratepayer :-). 

And finally, if successful, it would let the EPA-minded
regulators, NRC, DOE etc etc, and industry and bureaucratic HPs
bring forth and "take credit" for "great institutional efforts"
(to make miniscule changes), so that revisiting the issue on its
merits would be dead for another 10 years.

'De min' ends up being hostage to the idea that low level rad
kills only a little, and we can live with that. That's fatal. And
its a scientific lie.

The real issue is technical integrity, objective science, and
eliminating the LNT, which can not be defended in biology, in
analysis, or in application of expending $100s Billions to control
levels that are less than 0.001 of just the variation in natural
radioactivity and radiation.

I recommend we address the disingenuous NCRP draft report, and
publicize the explicit misrepresentation of data, and the
suppression of data presented to the committee, from the basis of
the knowledgeable biological sciences. Your efforts in assessing
the data and bringing it to the HP and industry communities, and
the state and Fed agencies, would be time better spent than on 'de
min', which is an administrative dead-end, even if successful,
rather than a technical issue worthy of your effort.

Thanks.

Regards, Jim Muckerheide
Radiation, Science, and Health
==============================

> Radsafers -
> I am trying to put together a web site on the De Minimis concept (in general
> and applied to radiation exposure in particular).  I would appreciate any
> suggestions for links or other content.  I would also like any comments on my
> editorial on the subject in the November HPS Newsletter.  Thanx.
> Joyce Davis
> 
> JPDavisCHP@aol.com
> http://hometown.aol.com/jpdavischp
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