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It is unfortunately not an exaggeration to say that the proposed 100 mSv put forth by the US NRC is a mass extermination protocol. The doings of the USNRC and DOE have become so far-fetched, and out of control, that it is difficult to believe even when you read it with your own eyes. Online historical documents, especially Congressional Hearings, suggest that they have been mostly out of control for 70 years, but people were unable, or had difficulty, accessing the information. This 100 mSv protocol appears an attempt to legalize and expand their deadly, nefarious, activities. It is also preparation for an imminent nuclear disaster in the US, and avoidance of clean-up by the public and private sector.

Besides the ties described below, by Robert Applebaum, the US Air Force has provided Ed Calabrese, and the U. of Mass-Amherst, at least $3.2 million from 1997 to 2018, apparently to show that so-called “low doses” of radiation and chemicals are good for you. That is taxpayer money which could be used for Social Security-Medicare, or building new bridges. On October 19th, John Kerry signed a memorandum of understanding with Spain for still ongoing remediation activities due to the US Air Force accidentally dropping a few nuclear bombs in Spain, causing plutonium and americium contamination: https://en.wikipedia.org/wiki/1966_Palomares_B-52_crash At the former McClellan Air Force Base in California: “The Air Force retains the responsibility for cleanup of contamination in the groundwater and in soils deeper than 15 feet, including low-level radioactive contaminants.http://yosemite.epa.gov/opa/admpress.nsf/2dd7f669225439b78525735900400c31/566d870b14b1cb4685257e07005b78cf!OpenDocument

While according to the decade old BEIR VII model, the proposed 100 mSv would lead to an additional 1% per year (excess) cancer risk (80% over an average life-time), subsequent studies of nuclear workers suggest that this number is much higher. A recently published UK-US-French nuclear worker study puts excess cancer DEATHS at 51% per Sievert (1000 mSv), using a 10 year time lag. This is the amount of radiation exposure proposed for the general public over only one decade (10 years)! Thus the effects may become evident very quickly. According to BEIR the cancer rates are approximately double, meaning 100%. The deaths have 14 to 15 year life-shortening effects, so there is no retirement. What the government saves in Social Security will be more than lost with increased Medical Costs. Private insurance has limits to coverage. Who will pay? Furthermore, in the 15 country nuclear workers study the risk was much, much higher, making the new 3 country study appear conservative. This new study-evaluation gives a rate of 4.8% excess deaths per 100 mSv (48% per 1000 mSv), excluding leukemia. If it is lagged for 15 years, rather than 10, the numbers increase further: “The estimated rate of mortality from all cancers excluding leukaemia increased with cumulative dose by 48% per Gy” [in this context Sv] “lagged by 10 years.” (Richardson et. al.-BME, Oct. 2015) When they lag for 15 years, (Table A-1), the number jumps to 58% per Sv (Gy) for all cancer, and 54% for all cancer other than leukemia. See: https://miningawareness.wordpress.com/2015/10/22/nuclear-worker-study-affirms-that-low-doses-of-radiation-are-deadly-increased-cancer-risk-much-worse-than-previously-believed/

November 19th 100 mSv per year comment deadline: http://www.regulations.gov/#!docketDetail;D=NRC-2015-0057
It is important to note that there is nothing “low dose” about 100 mSv. It is actually the start of medium dose.

Robert Applebaum is a Certified Health Physicist, CHP, Emeritus. It is indeed good news that not all of them are mad! The Emeritus probably means that he is retired. Yellow highlight-red underline was added.
ML15229A221 Applebaum 100 mSv LNT Comment p. 1 email deleted
ML15229A221 Applebaum Comment 100 mSv LNT p. 2
On page 3 he ends by saying: The petitions should be promptly denied as the U.S. NRC has serious matters to attend to. http://pbadupws.nrc.gov/docs/ML1522/ML15229A221.pdf (Otherwise p. 3 is the same as his last sentence below, with which we respectfully disagree – and explain why below.)

The short version of his comment:
This is a Comment on the Nuclear Regulatory Commission (NRC) Proposed Rule: Linear No-Threshold Model and Standards for Protection Against Radiation

PRM 20-30 states that Dr. Mohan Doss is acting on behalf of SARI and “supports and supplements” PRM 20-28 submitted by Dr. Carol Marcus. It should be noted that Doss, Marcus and Mr. Mark Miller (who submitted PRM 20-29) are all members of SARI.

The additional reference material submitted by Dr. Marcus was authored by other SARI members.

LNT is not a hypothesis. It’s an explanation which ties together many tested hypotheses. It’s a scientific theory. Those who feel compelled to attack a scientific theory (evolution, anthropogenic global warming, LNT, etc.) will often attempt to denigrate it by referring to the theory as a “hypothesis”.

Scientific theories cannot be proven true, but they must be falsifiable. Since scientific theories cannot be proven to be true, they are frequently subject to attack by those with non-scientific agendas. For example, the scientific theory of evolution is supported by many tested hypotheses, but is constantly under attack by some who feel the theory threatens aspects of their religious beliefs.

The theory of LNT was strongly attacked in the late 20th century, when it was unclear what the primary carcinogenic components of cigarettes were. In addition to possible chemical carcinogens, tobacco was known to include naturally occurring radioactive isotopes. It was also recognized that naturally occurring radon progeny could attach to smoke particles and be inhaled deeply into the lung. Regulation of second hand smoke was particularly threatening to the cigarette industry.

The Tobacco Institute (TI), a trade group representing cigarette manufacturers, funded a small group of people with science degrees to manufacture and disseminate misinformation in order to slow regulation of cigarettes and second hand smoke.

One beneficiary of TI funding was the late T.D. Luckey, who proposed that radiation was beneficial. He called this process “hormesis”. In promoting his propaganda he actually employed the pseudo-science of homeopathy as being supportive: http://giriweb.com/luckey.htm.

Ultimately, science prevailed and the TI disbanded. However, it was widely recognized by some Libertarians that the TI’s tactics had been very effective at creating public confusion and slowing the regulatory process.

T.D. Luckey went on to start the International Hormesis Society with another former TI funding beneficiary Edward Calabrese.

The talking points of the petitions contained within this docket are essentially a resurrection of the propaganda originally manufactured by Luckey and others and perpetuated by Calabrese.

It should be noted that Calabrese is an “expert” with the Libertarian Cato Institute, which was originally called the Charles Koch Foundation (one of the Koch Brothers), and it exists to manufacture and disseminate anti-regulation propaganda.

The SARI petitioners are attempting to short-cut the rigors of science with their petitions, a fallacy known as special pleading. Though the petitioners appear to have scientific credentials, they are conveniently bypassing the scientific process and are engaging in rhetorical tactics (letters, petitions, and website). The SARI petitioners should have learned at the high school science level, that a scientist must produce evidence (hypothesis testing) which is accepted by the scientific community in order to overturn a scientific theory. The petitioners are free to publish their evidence to contradict the theory in the peer reviewed scientific literature. Should any of the authorized scientific consensus bodies change their conclusions based on this new evidence, the U.S. NRC would be compelled to consider revising its regulations.

However, modern scientific consensus bodies with the legal authority to draw conclusions on radiation effects are all unanimous in regards to LNT. Since LNT is the scientific consensus theory, the U.S. NRC has NO choice but to implement regulations based on that accepted theory.

One of the most ardent efforts to disprove LNT was undertaken by the U.S. DoE Low Dose Radiation Research Program. After spending a decade and over $200 million, they failed to find any evidence to contradict LNT.

The petitioners make unsubstantiated claims regarding LNT leading to the irrational fear of radiation. We don’t determine our science based on its consequences – that would be logically fallacious. Scientific rigor comes first, and then we try to understand and manage the consequences.

It is a LACK of understanding of LNT, which leads to irrational fear. The predictions of LNT are that even after relatively large radiation doses, the increase in expected cancer incidence (which will be mostly realized decades in the future) is very small. (A longer email comment has also been sent)
ID: NRC-2015-0057-0188 Tracking Number: 1jz-8knx-4h3i
Date Posted: Oct 6, 2015 RIN: Not Assigned
Submitter Name: Robert Applebaum
http://www.regulations.gov/#!documentDetail;D=NRC-2015-0057-0188

We respectfully disagree with the last statement, which somewhat spoils two otherwise brilliant pieces. While it is important to understand that low doses of ionizing radiation are not a guaranteed death sentence, which is probably his point, it is difficult to see how even the 1 mSv which the nuclear industry is allowed to expose the general population to is acceptable. For risk to be acceptable it must be chosen by the person, and there must be some benefit. A smoker may get joy from smoking which outweighs the risks. Someone forced to breathe second hand smoke does not get joy from it, nor is there always choice, as when a smoker walks down the street in front of you, so that he doesn’t have to smell the smoke but you do. Mr. Applebaum may also have some medical uses in mind. If you break a bone, for instance, an x-ray may be required. In this case there is a benefit and there is usually some choice. Today most medical uses of ionizing radiation are unnecessary. There are new technologies (MRIs, Ultrasounds), which may have been unavailable when Mr. Applebaum trained, since he seems to be retired. They have also improved over time. Unfortunately doctors appear to be increasingly trying to force outdated, often unnecessary, tests upon people, which involve ionizing radiation.

There is no choice with radioactive effluents from the nuclear industry and its wastes. This risk is forced upon a mostly unknowing public. According to BEIR VII, over a lifetime, 1 mSv of nuclear industry effluents leads to 1% excess cancer risk. The impacts are stochastic, i.e. random. You might dodge the radioactive bullet, but you might not. And, based on the recently published study of UK, US, and French nuclear workers, this excess risk of cancer from 1 mSv, over a lifetime, is approximately 10% (5% deaths). The earlier nuclear workers study, which included 15 countries, found the risk was over double that – 10% cancer deaths, so approximately 20% more cancers, and an additional 19% deaths for leukemia (and the incidence rate would be almost double for it too)! “Our estimates suggest that a cumulative exposure of 100 mSv would lead to a 9.7% (1.4 to 19.7%) increased mortality from all cancers excluding leukaemia and a 5.9% ( − 2.9 to 17.0%) increased mortality from all cancers excluding leukaemia, lung, and pleura compared with background rates. The corresponding figure is 19% ( < 0 to 84.7%) for mortality from leukaemia excluding chronic lymphocytic leukaemia.” “Risk of cancer after low doses of ionising radiation: retrospective cohort study in 15 countries” by E Cardis, et. al. BMJ. 2005 Jul 9;331(7508):77. http://www.ncbi.nlm.nih.gov/pubmed/15987704 (full text free online).

Remember that the above is for the currently recommended 1 mSv per year. The NRC proposal is for 100 x more – 100 mSv per year.

Is it acceptable to be exposed to ionizing radiation from the nuclear industry with no benefits and no choice? As with second hand smoke, the answer is clearly no. In this wikihow on “Avoiding Being Shot” the emphasis is on avoidance! It doesn’t say stand in front of the bullet and hope for the best! http://wikihow.com/Avoid-Being-Shot

Odds of being struck by lightening in your lifetime (Est. 80 years) are 1 in 12,000 (1/12,000) http://www.srh.noaa.gov/jetstream/lightning/lightning_faq.ht
US Lifetime odds of dying in a Motor Vehicle Crash are 1 in 112
Assault by Firearm 1 in 358
Keep in mind these odds are statistical averages over the entire U.S. population and do not necessarily reflect the chances of death for a particular person from a particular external causehttp://www.nsc.org/learn/safety-knowledge/Pages/injury-facts-chart.aspx

Chances of getting cancer (above and beyond current cancer risks) from 1 mSv per year over a lifetime are approximately 1 in 100 according to BEIR VII; 1 in 10 according to the new research. For the proposed 100 mSv per year it is 1 in 10 for the first year of exposure. 100 out of 100 in 10 years. Based on the earlier study the excess risk for 100 mSv is approximately 20% or 1 in 5 for cancer other than leukemia, and death from leukemia is 19%. Thus leukemia incidence per 100 mSv would seem to be close to an astounding 35% (slightly less than half die).

Robert Applebaum’s shorter piece is here, as it appears online. It is difficult to decide which is better so both are posted.
http://www.regulations.gov/#!documentDetail;D=NRC-2015-0057-0188 Applebaum short comment