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US NRC Comment Deadline on “Radiation Protection” next Monday 22 June 2015, 11.59 pm (one minute to midnight) NY-DC (ET). Comment here: http://www.regulations.gov/#!documentDetail;D=NRC-2009-0279-0098 (ID: NRC-2009-0279-0098) The original list of questions to be answered is found here: https://www.federalregister.gov/articles/2014/07/25/2014-17252/radiation-protection
US EPA: Radionuclides in Drinking Water: A Small Entity Compliance Guide, p. 3
US EPA: Radionuclides in Drinking Water: A Small Entity Compliance Guide, p. 3
Electromagnetic Spectrum NASA
The comment from GE Inspection Technologies says:
Utilizing technology adopted by the medical profession and developed by GE Healthcare, GE Inspection Technologies has created industrial products utilizing Digital Radiography (DR) and Phased-array Ultrasonic Testing (PAUT). Both of these technologies require less or no penetrating radiation compared to traditional technologies, resulting in improved worker safety through lower radiation exposure.”
GE Inspection Pelligrino p. 1
GE Inspections Pelligrino p. 2
http://www.regulations.gov/contentStreamer?documentId=NRC-2009-0279-0046&attachmentNumber=1&disposition=attachment&contentType=pdf (Emphasis our own.)

It contrasts starkly with the Lockheed Martin statement:

What is brilliant about this story is that, from what can be found online, Mr. Pelligrino found that it was difficult to sell some of the equipment due to cost, so he set up a rental service, thus making money and saving lives! He apparently sold his company to GE. This is but one illustration that money can be made with innovative new technologies, which save lives. There can be no excuse for leaving the high exposure rates from 1956, which have been condemned by the ICRP since 1991. ICRP is mostly made up by radiologists and nuclear advocates. And, ICRP rules still allow for unacceptable risk. The proposed change is from 50 mSv per year to an average of 20 mSv per year over a five year period with no year exceeding 50 mSv, i.e. a five year average of 100 mSv.

50 mSv is 5 rem is 5,000 mrem. 20 mSv is 2 rem is 2,000 mrem. It is the difference between an estimated 18.4% exposure-induced cancer rate for workers vs. 7.4%, of which an estimated 56% will die (based on BEIR VII est. for those working from age 18 to 65). For 36 mSv it would be 13.2%.

While nuclear energy is totally unnecessary, other uses of x-rays have long been mostly unnecessary. In the medical field, MRIs and ultrasounds should have almost completely replaced the use of x-rays and radionuclides, but strangely have not. And, unfortunately, the need for nuclear workers and the need for safe standards will remain due to the nuclear waste.

Here is a comment from Mr. Pelligrino’s apparent antithesis. A comment from the capital of cancer alley, Baton Rouge, Louisiana. This is probably a family company, because other Bonvillains are listed online as working there.
Bonvillain comment
They probably can’t, or don’t want to, afford to purchase safer technology, and so just want to allow more of their workers to risk cancer. Couldn’t they rent equipment? The workers are already at risk due to location, and may well have been exposed to the nuclear waste, reportedly burned unfiltered, along with other hazardous waste, by Rollins Environmental Services in N. Baton Rouge, under the tender eye of the US DOE, who cited “National Security”, as a reason for not mentioning that shipments had radioactive waste. This doesn’t, however, explain why Rollins was burning other hazardous waste unfiltered. (There were even Congressional hearings on this in the 1990s).

From “Health Risks from Exposure to Low Levels of Ionizing Radiation: BEIR VII – Phase 2” p. 312 “TABLE 12D-3 Lifetime Attributable Risk of Solid Cancer Incidence and Mortality“, which gives incidence; mortality, exposure scenario per 100,000: For those exposed to 10 mSv per year from ages 18 to 65 (47 yrs) exposure-induced cancers for males is estimated to be 3059 (deaths 1700) and female is 4295 (deaths 2389). Thus, the average is 3677 per 100,000 (3.7%) with an average of 2045 deaths or 56%. Multiply the cancers by two to get 20 mSv and by 5 to get 50 mSv. Multiply by 3.6 for 36 mSv.

The US NRC’s 1 mSv per year throughout “life” (defined as 70 years; however, US life expectancy is 79 and it is 81 for women) for the general public: exposure-induced cancer risk for men is 621 (deaths 332); for women is 1019 (deaths 497) for an average of 820 per 100,000 over 70 years or 11.7 per mSv. Thus, for 100 mSv it would be 1170 per 100,000 or 1.2%. For 81 years it would be 1% for both genders. 1.2% for women. The death rate of those with cancer, in the BEIR estimates, is around 51%. This is exposure-induced cancer risks for the general public from nuclear power and waste! There are safe alternatives!
Nuclear Blasphemy, 70 Yrs is Enough Campaign