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The only easy question that the EPA asks, in their call for comment about nuclear facilities, is if they should consider cancer mortality (death) or cancer morbidity (illness) for risk assessment. But, ionizing radiation can lead to diseases other than cancer, so why is this not mentioned?

From a social, economic and individual perspective morbidity (illness) matters the most.

So, the issue is not simply dead is dead, but who will care for the sick? Who pays? You can be certain that it won’t be the nuclear industry. It will be insurance, taxpayers, and family members who act as caregivers. Most likely it will be the sick helping the sicker.

Ionizing radiation is believed to contribute to Alzheimer’s disease-dementia, as well as other diseases – Who will care for these people ? This is a major social problem, not factored into the cost of nuclear energy. https://miningawareness.wordpress.com/2014/03/14/alzheimers-disease-and-ionizing-radiation/

So, the EPA is improperly trying to narrow the definition of impact to only cancer, and within cancer to narrow the definition again to deaths only.

Illness won’t look nice and cozy like this, when many become ill
Ancher, Michael, "The Sick Girl", 1882, Statens Museum for Kunst.
“The Sick Girl”, 1882, by Michael Ancher, Statens Museum for Kunst

It may first look like this:
hospital ward Middle Ages

Then like this:
Der Triumph des Todes. Ein Gemälde des flämischen Malers Pieter Brughel des Älteren
The Triumph of Death by Pieter Brughel the Elder

Then there is the needless suffering. Also, reporting only deaths from cancer could exclude those who die after a 5 or 10 years or longer fight with cancer.

The US EPA must count both deaths and illness! They must count non-cancer illnesses, too. The only cases where deaths matter more than illness were where deaths hit working adults disproportionately and leave orphans, and the elderly. Radiation appears to disproportionately impact vulnerable children and the elderly.

The moral test of government is how it treats those who are in the dawn of life, the children; those who are in the twilight of life, the aged; and those in the shadows of life, the sick, the needy and the handicapped. Hubert Humphrey Remarks at the dedication of the Hubert H. Humphrey Building, November 1, 1977, Congressional Record, November 4, 1977, vol 123, p. 37287http://en.wikiquote.org/wiki/Hubert_Humphrey

Genetic damage may be recessive and take multiple generations to appear.

And, the animals? What about their illness and death? Who will care for them if they are ill? Will wild animals be given thyroid medication, for instance? And, for some animals death could be species extinction. And, trees and other plants?

Chickadee deformed beak USGS
Black-capped Chickadee with deformed beak, USGS photo

Isn’t the EPA supposed to be the Environmental Protection Agency? How about modeling the dispersion of radionuclides from nuclear facilities into the air and water and estimating the impacts over time and space? Some radionuclides persist in the environment for centuries. How about standards really restricting the emissions of all radionuclides into the environment.

Comment period ends today; it can be anonymous: http://www.regulations.gov/#!submitComment;D=EPA-HQ-OAR-2013-0689-0001)

Paper discussing bird deformities at Chernobyl, including beaks: http://cricket.biol.sc.edu/chernobyl/papers/Mousseau-Moller-Bull-Atomic.pdf
Cause of beak deformity in Pacific Northwest Chickadees is considered unknown.