, , , , , , , , , , , , , , , , , , , , ,

100 mSv per year comment here: http://www.regulations.gov/#!docketDetail;D=NRC-2015-0057
death grim reaper
Commenter Pia Jensen points out that Carol S. Marcus, Ph.D., M.D., UCLA states: “The costs of complying with these LNT-based regulations are enormous.

This raises the question of costs to whom? Who benefits? Who pays in each instance What are the costs of one extra cancer for the entire population? Who will pay for that? https://miningawareness.wordpress.com/2015/10/30/usnrc-value-of-death-update-all-tricks-no-value-of-life-no-medical-care-or-caregiver-costs/

Richardson et. al.’s (Oct. 2015) study of nuclear workers in the US, UK, France, which came out after Pia Jensen’s comment (below) was submitted, leads to an estimate of approximately 100 additional cancers per 100 people after only 10 years of 100 mSv per year exposure. (see links below comment). BEIR VII (2005) estimates for 100 mSv are an average of 80 per 100 extra cancers, over a life time, and 100 per 100 for women, well actually 101,900 per 100,000 women (see BEIR p. 312 for 1 mSv over a lifetime and multiply by 100). And, yes, people can and do get more than one cancer in a lifetime. The ICRP-USNRC currently recommended “limit” of 1 mSv per year from nuclear facilities already leads to an estimated 1019 excess (extra) cancers per 100,000 women (see BEIR, p. 213.) How is this acceptable? No benefits accrue to the victims.

What does Carol Marcus (UCLA) demand? “Worker doses should remain at present levels, with allowance of up to 100 mSv (10 rem) effective dose per year…. ALARA should be removed entirely from the regulations….Public doses should be raised to worker doses… End differential doses to pregnant women, embryos and fetuses, and children under 18 years of age.” (See Jensen below).

Carol S. Marcus, Ph.D., M.D., was and maybe still is Director, Nuclear Medicine Outpatient clinic, UCLA Medical Center, Professor, UCLA. Even though she is long past retirement age, the dangers of radiation were well-known before she even entered university. In 1950, William Russell of Oak Ridge National Labs stated: “There is no threshold dose. In other words, genetic changes may be expected at any dose, no matter how small….” A secondary petitioner is Mohan Doss, a physicist from India, who gives “support” for Nuclear Medicine, PET, CT, Radiographic & Fluoroscopic Systems at a cancer center (Fox Chase). As with Dr. Marcus, an overt conflict of interest. He’s also worked for the Lawrence Berkley (Nuclear) Lab in the US, and at the U. of Saskatchewan – Cameco uranium mining country. Mark Miller is (or was) working at the Sandia (nuclear) lab (operated by Lockheed Martin).

100 mSv also gets rid of concerns about over-exposure from medical uses of radionuclides. According to Peter Crane, former NRC Counsel, Carol Marcus was behind the fact that patients treated with radio-iodine 131 can expose anyone they meet to 5 mSv, which is 20 times greater than the US EPA limit of 0.25 mSv for the body, and 6 times the EPA’s thyroid dose. And, guess what happened after this was pushed through:
Use of radioactive iodine for treatment of thyroid cancer on the rise” Date: August 17, 2011
Source: JAMA and Archives Journals
Summary: “Despite uncertainty about the appropriate use of radioactive iodine after surgery for different stages of thyroid cancer, between 1990 and 2008 its use has increased among patients with all tumor sizes, and there was wide variation in use of this treatment among hospitals, according to a new study.http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3352591/
This is probably for multiple reasons: A probable increase in thyroid cancer from the long-term impacts of I 129 (half-life 15 million years) from nuclear weapons testing, accidents, and routine nuclear reactor emissions, which would take several decades to be seen. Iodine 131 is also emitted from nuclear reactors. And, patients exposing the general public would lead to additional cancers. Then, there is that out-patient treatment means that it is easier, cheaper, and more likely to be done.

It also “solves” this concern:
Radiation exposure exceeds 50 mSv in 2% of ICU patients“, by Mitchel L. Zoler, Frontline Medical News, November 6, 2015
Exposure averaged 7 mSv, with a median of 1.5 mSv.

BEIR VII points out re “hormesis”:
Much of the historical material on radiation hormesis relates to plants, fungi, algae, protozoans, insects, and nonmammalian vertebrates (Calabrese and Baldwin 2000). For the purposes of this report on human health effects, the committee focused on recent information from mammalian cell and animal biology and from human epidemiology...” (p.332)

Your comment need not be long. If it is too long it will need to be uploaded as a pdf. Remember to put the docket number. Pia Jensen’s interesting comment, which includes information on bioaccumulation, etc., is actually most relevant for the current 1 mSv NRC limit, or even the 0.25 mSv EPA limit.
100mSv per year is so over the top in danger, that adding bioaccumulation, etc., as discussed by Pia Jensen, is probably simply the difference in cancer for everyone in several years, vs. 10 years. There is nothing low-dose about 100mSv. It is the beginning of intermediate dose. And, this is 100 mSv per year! However, her piece was written before the new Richardson, et. al. study was published. There are references, as well. Nonetheless, the repercussions of 80 additional cancers per 100 people, in a lifetime, estimated under BEIR VII (2005) for 100 mSv per year can not be borne by society, either financial or socially. If the Richardson et. al. estimates are accurate, it would lead to a total social and economic implosion, worse than the plague years.

Docket ID NRC–2015– 0057 10 CFR Part 20 Comment Tracking Number: 1jz-8jzp-hc8u

Linear No-Threshold Model and Standards for Protection Against Radiation [Docket Nos. PRM–20–28, PRM–20–29, and PRM–20–30; NRC–2015–0057]

Comment submission by Pia C. Jensen, retired researcher and former elected official (Cotati, California 1996-2000), regarding Nuclear Regulatory Commission (NRC) rule-making pursuant to 10 CFR Part 2.802 and petitioners’ requests that the NRC amend 10 CFR Part 20, Standards for Protection Against Radiation with regards to Linear No-Threshold (LNT) hypothesis versus Hormesis.

Petitioners Marcus; Miller; and Doss et al. (Doss on behalf of Scientists for Accurate Radiation Information) address standards for evaluating and responding to radiation exposures. To be specific, they seek to change the standard from LNT to a hormesis model based on what they describe as extensive volumes of research arguing that beneficial effects “may” be derived from low dose exposures to radioactive materials and that the LNT model could result in inappropriate management of populations in the event of radiologic disasters requiring evacuation. Also proposed are the elimination of ALARA guidance (As Low As Reasonably Achievable) [22] from regulations and ending differential doses for pregnant women, embryos and fetuses, and children under 18 years of age [50,51,52].

Prior to addressing petitioner’s arguments for changing the current rule LNT model to a hormesis model, I would like to note that I have no financial or other material interest in this proposal. My motivation is simply to see that the most protective model for managing and evaluating radiation exposure risk is in place for the protection of all people (of all ages & conditions) near and far from nuclear power plants, research sites, waste depositories, and uranium and thorium mining and processing facilities. On the flipside, it is interesting to note that the petitioners are financially motivated with regard to hormesis and radiation research and development. Also of interest is that many of petitioners Marcus and Miller comments are nearly completely identical verbiage [50,51].

[She outlines the request, which may be seen in the original.]

Pia Jensen continues:
B. Response to petitioners’ statements and requests.

Petitoners’ Marcus, Miller, Doss et al. (MMD et al.) address two radiation exposure models [50,51,52] without citing recently published extensive research by Klervi Leuraud, David B Richardson, Elisabeth Cardis, Robert D Daniels, Michael Gillies, Jacqueline A O’Hagan, Ghassan B Hamra, Richard Haylock, Dominique Laurier, Monika Moissonnier, Mary K Schubauer-Berigan, Isabelle Thierry-Chef, and Ausrele Kesminiene: Ionising radiation and risk of death from leukaemia and lymphoma in radiation-monitored workers (INWORKS): an international cohort study [3]. This is an important study refuting some claims made by petitioners’ MMD et al. and which, more specifically, “provides strong evidence of positive associations between protracted low-dose radiation exposure and leukaemia.” Other important studies completed since 2011 are also ignored by MMD et al.. Some of these papers are in References below my comments.

MMD et al. do not sufficiently address proven differences between people of varying ages, gender, status of health, or fetal susceptibility to ionising radiation. Not all people, especially the unborn, are created equally and do not respond equally to radiation exposures, at any dose level, internal or external. Women, children and fetuses in particular evidence greater responses to low dose ionising radiation than other members of society [4,5,6,7,25,31,32,34,35,36,37].

“One possible reason why genetic effects from low dose exposures have not been observed inhuman studies is that mutations in the reproductive cells may produce such significant changes in the fertilized egg that the result is a nonviable organism which is spontaneously resorbed or aborted during the earliest stages of fertilization.
~ U.S. Nuclear Regulatory Commission [36]

MMD et al. consider the currently used model, LNT, to be overly simplified, when in fact, their proposed model, Hormesis, is far more simplified and resembles a “one size fits all” philosophy without taking into account vastly different responses people have to radiation exposure, nor do they account for the wide variety of types of radioisotopes which people may be subjected to. In fact, MMD et al. are negligent by not discussing the fact there is no 100% effective technological or human controlled “regulators” or filters to manage radioisotope quantities (or quality) that people may be exposed to in the event of catastrophic events resulting in agency’s raising legally allowable limits [19,46], or even during “normal” leaks from nuclear power facilities. Additionally, the US Environmental Protection Agency’s monitoring stations are either underfunded, broken, or taken offline resulting in an inability to effectively determine quantity and quality of radioactive emissions in those locations not being monitored (reference: Addendum B – Environmental Dimensions Inc., RadNet, FBO Contract). As of 1 June 2015 only 37 of 124 radiation monitoring stations were functioning. While the EPA and NRC may not be concerned that they are not fulfilling their mandates to protect populations and environments, growing public concern exists which federal regulators should sincerely take note of [14,23,24,26,27,28].

MMD et al. discuss perceived beneficial effects as though their “one size fits all” proposal will result in absolute and standardized responses by all people, all the time. It is simply not possible to predict or control, en todo, full impacts of radiation exposures among vastly different populations [11,15,17],. In fact, serious limitations exist and “general scientific consensus is currently in favour of the LNT model as the most appropriate dose–response relationship for radiation protection purposes at low doses.” [41]

MMD et al. do not sufficiently address variances in types of radiation and related toxic gas exposures that people, both workers and citizens, may be subjected to in cases of employment hazards, project failure (Hanford [43,44], for example), or catastrophic events such as Three Mile Island, Chernobyl [42], and more recently, Fukushima with its multitude of daughter products emitting from Tokyo Electric Power Company’s facilities into the Pacific Ocean and the world’s atmosphere every day since March 2011 [45,47]. Even if radiation exposures could be limited to a controlled low dose, negative impacts will still occur. Petitioners’ are asking the NRC to do the impossible – approve of changes based on a myth that nuclear related events are containable with regard to the amount and type of radiation people and ecosystems are subjected to. Petitioners’ requests read like an act of desperation to curry favor for the nuclear industry.

In the body of their presentations, MMD et al. cite a few studies to support their claims, when, in fact, research done regarding the effects of ionising radiation upon the environment and carbon based life is not thorough with regards to global medical and ecological implications related to how radioisotopes are transported around the world. For example, multiple countries (Austria, Sweden, Finland, Norway, Slovenia, Poland, Romania, Hungary, Switzerland, Czech Republic, Italy, Bulgaria, Republic of Moldova and Greece) experienced increased rates of diseases related to the Chernobyl event in 1986 and Fukushima’s releases are currently transferring around the world by jet streams, rain, ocean currents, and biotic transference via flora and fauna (bio-accumulation). Extensive documentation on radioisotope deposition and health impacts are presented by researchers, agencies, and organisations utilizing data from sources such as the Comprehensive Nuclear-Test-Ban Treaty (CTBT http://ctbto.org/publications/) and publications presented by Greenpeace: The Chernobyl Catastrophe Consequences on Human Health [1], but are not cited by the petitioners. In fact, the vast majority of research referenced by the petitioners were published pre- 2012 and, unethically, Doss has a propensity for self-citing, including unpublished opinion [obviously not peer-reviewed] [52].

MMD et al. neglect factors of bio-accumulation and bio-magnification or, bio-concentration, with regards to man made radioisotopes entering ecosystems and up-take by flora and fauna, resulting in increased radioisotope capacity to cause human health damage as the isotopes move through the food chain. Petitioners neglect important issues of bioaccumulation or bio-concentration which are factually evident as presented in studies on the impacts of radioactive releases near nuclear facilities. In particular, the Department of Energy contracted research on aquatic environment near the Savanna River site in South Carolina which demonstrates bio-concentration in local flora.[33] Long-term deposition in ecosystems is an important part of the equation in radiation protection, especially for hunters and those who purchase or gather commercially available and wild foods [48,49].

MMD et al. reference radiation research involving mice. Pigs, aka, swine, are historically the only animal used in research to accurately determine potential biological impacts of various compounds due to their physiological similarities to humans [29,30]. In fact, at least one study conducted by researchers at MIT was debunked by Ian Goddard in 2012 [9.] Petitioners’ use of mouse research is flawed because mice and humans do not share the same, critically important, biological responses to radioisotopes [8,9,10].

Much of the research and studies referenced by MMD et al. conclude that more research is required to fully understand hormesis. This is important to note when considering the history of the nuclear industry in general and conflicting information representing an industry based on an incomplete science (reference: Addendum A). Claims by nuclear proponents are often made without having gone far beyond theoretical and experimental stages of nuclear energy production or medical uses involving radiation. The science is scientifically and publicly acknowledged as incomplete. Hence, populations should not be subjected to more theoretical experimentation because people with vested interests in their chosen field of employment want to relax laws intended to protect the public. Statistically significant data supporting petitioners’ claims, such as can be found in meta-analysis, simply does not exist. I challenge Marcus, Miller, & Doss et al. to produce meta analysis of significant consequence that supports their claim that hormesis is substantially better than the current LNT model for protection of human and animal populations and ecosystems.

MMD et al. contend that in areas of higher radon exposure, lower incidence of lung cancer exists. This is another fine example of how the petitioners’ cherry pick information from decades old research conducted by sole authors to support their claims. Since researchers cited by MMD et al. (Bernard L. Cohen and Bobby Scott) produced their limited research on radon, multiple studies have been produced by multiple authors [38,39,40]. Those studies clearly debunk Cohen and Scott’s claims. Doss actually goes so far as to cite their own, unpublished research, to support their claim. On a personal note, I find petitioners’ practice of citing outdated, limited, and unpublished research highly unethical and worthy of further investigation for they would like to convince the United States government to change federal rules based upon their claims, which are easily proven false.

MMD et al. focus primarily on just a few types of deleterious effects that may arise from radiation exposures, disregarding other critical biological responses such as organ damage, musculo-skeletal and connective tissue system response, brain dysfunction, respiratory disease, hormone dysfunction, infectious diseases, non-malignant conditions of the blood vascular system, autism, digestive system dysfunction, early and excess mortality, and genetic heredity of damaged DNA resulting in a wide variety of birth defects. Impacts upon flora, fauna and plant seed stock are also ignored by MMD et al. [1,3,4,5,6,7,12,13,15,18,20,21,32,33,36].

Arguments in favor of hormesis appear to be strongly financially related [50,51,52]. With the hormesis model in place, researchers benefit and the nuclear industry in general benefits because they won’t be burdened [16] with what petitioners consider to be excessive costs to manage known and unknown impacts of ionizing radiation during normal and catastrophic events. Changing rules intended to protect populations for economic reasons ignores the purpose of agencies charged with medical and environmental protection.

While I personally believe that no dose is safe based upon historic and ongoing effects from Chernobyl and depleted uranium exposures in Fallujah, I do believe that the LNT model is the best known model because it takes into account the differences between people and recognizes that distance of populations from nuclear facilities during releases does make a difference with regards to medical implications of exposed populations. A hormesis model, on the other hand, rejects known variations of medical consequences of exposures as well as the fact there are no effective controls for the quality or quantity of isotopes released during events.

Mothersill and Seymour contend that “previously held views about safe doses or lack of harmful effects cannot be sustained” in Radiobiology and Environmental Security [32] supporting the idea that exposing populations to radiation is complex, unpredictable and without merit. There is no thoroughly researched scientific basis for using a hormesis model.

I call on the Nuclear Regulatory Commission to reject, outright, petitioners’ requests to change any part of 10 CFR Part 20, Standards for Protection Against Radiation because their proposals are inconsistent with known facts, both recent and historic, and will result in greater risks to populations and ecosystems worldwide, if their requests are enacted.

Changing the current LNT model to a hormesis standard may also expose the Nuclear Regulatory Commission to unnecessary legal challenges at the expense of tax payers for neglecting their federal mandate to protect public health and safety and the environment (http://www.nrc.gov/reading-rm/doc-collections/nuregs/brochures/br0256/). Petitioners’ sense of urgency does not constitute valid reasoning for changing the current rule. But, it does evidence their desire to fast-track changes so their collective may avoid deeper scrutiny of nuclear industry practices and performance in general. It appears they just want industry to be left “off the hook” in the case of emergencies and worker exposures. For example, in 2012 it was reported that south eastern United States experienced “anomalously high” depositions of radioiodine (I-131) and polonium (210Po/210Pb) after Fukushima’s massive explosions as reported in Depositional fluxes and residence time of atmospheric radioiodine (I-131) from the Fukushima accident [2]. Full impacts of TEPCO’s disastrous events will not be completely understood for at least another 10-40 years. No rushing of nuclear proponents’ desires ought be made because the physics of nuclear incidents are not yet well known and outcomes take time to manifest. Acting hastily on behalf of nuclear proponents will likely expose the NRC to harsh scrutiny, judgement, and credibility challenges worldwide.

Lastly, petitioners note that conflicts of interest [10] may exist with NRC practices. This is one point on which we concur, though for different reasons. I recommend that the U.S. Government Accountability Office (http://www.gao.gov/), POGO: Project On Government Oversight (http://www.pogo.org/), and Transparency International – The Global Anti-Corruption Coalition Against Corruption (https://www.transparency.org) conduct deep audits of relationships between the NRC and nuclear promoting entities such as the Organisation for Economic Cooperation & Development, the International Atomic Energy Agency, the Nuclear Energy Institute, and even General Electric Corporation’s CEO, Jeffrey Immelt for apparent undue influence upon federal decision-making with regards to nuclear energy, radiation monitoring, and oversight and guidance (reference: Addendum B).

Perhaps the petitioners’ would like to plunge the world back into a 1950s mindset, but, it is obvious that the rest of the world, those with no vested interest in nuclear energy, would prefer to advance, safely.

Note: Additional related references in Addendum A and Addendum B submitted to compliment my comments.


Pia C. Jensen Salto, Uruguay

Many uncertainties remain. In particular there are still very few estimates of non-cancer mortalities attributed to Chernobyl, while long latency periods for development of cancers (in some cases greater than 40 years) inevitably mean that new cases are likely to emerge well into the future.

~ The Chernobyl Catastrophe Consequences on Human Health
[Emphasis our own. Pia Jensen bibliography and link to original appear after the two links below]

Regarding Richardson et. al. study and commentary, which were published after the above comment:

Pia Jensen:

1. The Chernobyl Catastrophe Consequences on Human Health Greenpeace, Amsterdam, the Netherlands http://www.greenpeace.org/international/Global/international/planet-2/ report/2006/4/chernobylhealthreport.pdf Revised version. Published May 2006.

2. Depositional fluxes and residence time of atmospheric radioiodine (I-131) from the Fukushima accident Department of Marine Science, University of Southern Mississippi, 1020 Balch Blvd., Stennis Space Center, MS 39529, USA. Journal of Environmental Radioactivity (Impact Factor: 3.57). 05/2012; 113:32-6. DOI: 10.1016/j.jenvrad. 2012.04.003.

3. Ionising radiation and risk of death from leukaemia and lymphoma in radiation-monitored workers (INWORKS): an international cohort study Klervi Leuraud, David B Richardson, Elisabeth Cardis, Robert D Daniels, Michael Gillies, Jacqueline A O’Hagan, Ghassan B Hamra, Richard Haylock, Dominique Laurier, Monika Moissonnier, Mary K Schubauer-Berigan, Isabelle Thierry-Chef, and Ausrele Kesminiene Published 22 June online by Lancet Haematol 2015; 2: e276–81; http://dx.doi.org/10.1016/ S2352-3026(15)00094-0.

4. A possible association between fetal/neonatal exposure to radiofrequency electromagnetic radiation and the increased incidence of Autism Spectrum Disorders (ASD); Kane, Robert C.; Medical Hypotheses , Volume 62 , Issue 2 , 195 – 197.

5. Radiation and Children: The Ignored Victims Nuclear Information and Resource Service 1424 16th Street NW, #404, Washington, DC 20036;202.328.0002; fax: 202.462.2183 http://www.nirs.org/radiation/radiationandchildren.pdf.

6. Strong effects of ionizing radiation from Chernobyl on mutation rates Published 10 February 2015 Møller, Anders Pape & Mousseau, Timothy A.; Scientific Reports 5, Article number: 8363doi:10.1038/srep08363.

7. Genomic Instability Induced by Ionizing Radiation Streffer, Christian; Universitätsklinikum Essen, 45122 Essen, Germany PS-1-3.

8. Comparative biology of mouse versus human cells: modelling human cancer in mice Annapoorni Rangarajan and Robert A. Weinberg December 2003 | VOLUME 3, pp. 952-959.

9. MIT No-Evacuations Study Debunked Goddard’s Journal, Ian Goddard 5 June 2012 https://www.youtube.com/watch? v=e8YFe6Q08M8&list=UUA7edtxeTs7NZ6KEhmHdXbQ&index=1&feature=plcp

10. A Radioactive Conflict of Interest, Robert Alvarez 25 June 2012 http://www.huffingtonpost.com/robert-alvarez/mit-radiation-study_b_1623899.html

11. Biological Research on Low Doses, Operational Issues in Radioactive Waste Management and Nuclear Decommissioning An International Summer School 6th edition Giovanetti, Anna; ENEA UTBIORADCR Casaccia Rome, Italy, 8-12 September 2014, ISPRA JRC (Varese, Italy).

12. The impacts of permanent irradiation on the flora of the eastern ural radioactive trace Pozolotina VN, Antonova EV, Karimullina EM, Kharitonova OV, Pustovalova LA Radiatsionnaia Biologiia, Radioecologiia / Rossiiskaia Akademiia Nauk [2009, 49(1): 97-106] Journal Article, Research Support, Non-U.S. Gov’t, English Abstract.

13. Assessment of radiation impact on Stellaria graminea cenopopulations in the zone of the Eastern Ural Radioactive Trace Russian Journal of Ecology V. N. Pozolotina, E. V. Antonova, E. M. Karimullina 23 November 2010, Volume 41, Issue 6, pp 459-468

14. Public health activities for mitigation of radiation exposures and risk communication challenges after the Fukushima nuclear accident Tsutomu Shimura, Ichiro Yamaguchi, Hiroshi Terada, Erik Robert Svendsen and Naoki Kunugita Department of Environmental Health, National Institute of Public Health, 2-3-6 Minami, Wako, Saitama 351-0197, Japan. Published by Oxford University Press on behalf of The Japan Radiation Research Society and Japanese Society for Radiation Oncology, Accepted February 16, 2015.

15. Understanding the Health Impacts and Risks of Exposure to Radiation Taylor A. Choi, Sylvain V. Costes, Rebecca J. Abergel Reflections on the Fukushima Daiichi Nuclear Accident 2 December 2014, pp 259-281.

16. Examples of regulatory costs for nuclear energy development Rod Adams December 7, 2011 atomicinsights.com/examples-of-regulatory-costs-for-nuclear-energy-development/

17. Radiation Basics Prepared 8/99 by Cindy Folkers, Nuclear Information and Resource Service, 1424 16th Street, NW, #404, Washington, DC 20036. Phone: 202-328-0002. Fax: 202-462-2183. E-mail: nirsnet@nirs.org. Web: http://www.nirs.org/radiation/ radiationbasics.pdf.

18. The toxicity of engineered nanoparticles on seed plants chronically exposed to low-level environmental radiation E. Karimullina, E. Antonova, V. Pozolotina, A. Tokarev, S. Minko; Russian Journal of Ecology, 28 May 2015, Volume 46, Issue 3, pp 236-245.

19. Radiation: The Myth of the Millirem Nuclear Information and Resource Service 1424 16th Street NW, #404, Washington, DC 20036;202.328.0002; fax: 202.462.2183 http:// http://www.nirs.org/factsheets/mythmilliremfctsht.pdf.

20. Compilation of Radiation Studies Showing Health Effects Compiled by Cindy Folkers & Mary Olson on 4/24/98, Nuclear Information & Resource Service, 1424 16 th St, NW Suite 404, Washington, DC 20036 (202)328-0002 http://www.nirs.org/radiation/radchart.htm.

21. “Hormesis”—An Inappropriate Extrapolation from the Specific to the Universal DEBORAH AXELROD, MD, KATHY BURNS, PHD, DEVRA DAVIS, PHD, MPH,NICOLAS VON LAREBEKE, MD, MPH; INT J OCCUP ENVIRON HEALTH 2004; 10:335–339 VOL 10/NO 3, JUL/SEP 200, pp. 335-339.

22. ALARA: The History and Science of Radiation Safety Michael Baumer http:// large.stanford.edu/courses/2015/ph241/baumer2/ March 14, 2015 Submitted as coursework for PH241, Stanford University, Winter 2015.

23. Weaknesses in EPA’s Management of the Radiation Network System Demand Attention Report No. 12-P-0417 19 April 2012 http://www.epa.gov/oig/reports/ 2012/20120419-12-P-0417.pdf.

24. RadNet Air Monitoring: Functioning Beta Stations listed by date and operational status http://www.enviroreporter.com/radnet-air-monitoring.

25. Radiation Dose Effects in Relation to Obstetric X-Rays and Childhod Cancers Alice Stewart, G.W Kneale Department of Social Medicine, University of Oxford, United Kingdom Volume 295, Issue 7658, 6 June 1970, Pages 1185–1188 http://www.sciencedirect.com/science/article/pii/S0140673670917824.

26. Tell EPA to keep mobile radiation monitoring lab for nuclear accidents in western U.S. org2.salsalabs.com/o/5502/p/dia/action3/common/public/? action_KEY=20657#.VX8R16Xl6zg.twitter.

27. “Dangerous Decision” Could Leave Californians Vulnerable After Nuclear Disaster http://www.nbclosangeles.com/video/#!/on-air/as-seen-on/Dangerous-Decision-Could-Leave-Californians-Vulnerable-After-Nuclear-Disaster/307088581.

28. EPA plan to move radiation lab out of Vegas draws protests 24 June 2015 http://www.reviewjournal.com/news/las-vegas/epa-plan-move-radiation-lab-out-vegas-draws-protests.

29. Why the swine http://www.superpig.it/en/background/why-the-swine.html

30. Swine as Models in Biomedical Research and Toxicology Testing Michael M. Swindle, Veterinary Pathology 2012, 49(2) 344-356; Medical University of South Carolina, Department of Comparative Medicine, MSC 777, 114 Doughty St, Charleston, SC 29425-7770 vet.sagepub.com/content/49/2/344.full

31. Deconstructing Radiation Hormesis Mossman, Kenneth L. Arizona State University, Tempe, AZ 85287-3501 Health Phys. 80(3):263–269; 2001 http://www.groenerekenkamer.nl/ grkfiles/images/Mossman.pdf.

32. Implications for human and environmental health of low doses of ionising radiation Radiobiology and Environmental Security Carmel E. Mothersill, Colin B. Seymour pp. 43-51 Department of Medical Physics and Applied Radiation Sciences, McMaster University, Hamilton, L8S 4K1, ON, Canada.

33. Radiological Bioconcentration Factors for Aquatic,Terrestrial, and Wetland Ecosystems at the Savannah River Site (U) G.P. Friday, C.L. Cummins, and A.L. Schwartzman Prepared for the U.S. Department of Energy under contract no. DE-AC09-89SR18035 pbadupws.nrc.gov/docs/ML1016/ML101600579.pdf.

34. Health Effects of Prenatal Radiation Exposure PAMELA M. WILLIAMS, LT COL, USAF, MC, David Grant Medical Center, Travis Air Force Base, California STACY FLETCHER, CAPT, USAF, MC, Ehrling Bergquist Clinic, Offutt Air Force Base, Nebraska Am Fam Physician. 2010 Sep 1;82(5):488-493. http://www.aafp.org/afp/2010/0901/p488.html.

35. The Impact of Radiotherapy on Fertility, Pregnancy, and Neonatal Outcomes of Female Cancer Patients Jennifer Y. Wo, M.D. and Akila N. Viswanathan, M.D., M.P.H. http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2865903/Int J Radiation Oncololgy Biology / Physics 2009 Apr 1; 73(5): 1304–1312.

36. Biological Effects of Radiation USNRC Technical Training Center Reactor Concepts Manual http://www.nrc.gov/reading-rm/basic-ref/teachers/09.pdf

37. The Impact of Uterine Radiation on Subsequent Fertility and Pregnancy Outcomes BioMed Research International Wan Tinn Teh, Catharyn Stern, Sarat Chander, and Martha Hickey http://www.hindawi.com/journals/bmri/2014/482968/ Volume 2014 (2014), Article ID 482968, 8 pages.

38. Residential radon exposure and risk of lung cancer in never smoking women María Torres Duran, Alberto Ruano Ravina, Isaura Parente Lamelas, Virginia Leiro Fernandez, José Abal Arca, Carmen Montero Martinez, Carolina Pena ALvarez, Javier Gonzalez Barcala, Olalla Castro Añon, Antonio Golpe Gomez, Cristina Martínez, Maria Jose Mejuto Martí, Alberto Fernandez Villar and Juan Miguel Barros Dios, ERJ September 1, 2014 vol. 44 no. Suppl 58 P2734.

39. Geographic variation in radon and associated lung cancer risk in Canada Perry Hystad, Michael Brauer, Paul A. Demers, Kenneth C. Johnson, Eleanor Setton, Alejandro Cervantes-Larios, Karla Poplawski, Alana McFarlane, Alan Whitehead, Anne-Marie Nicol journal.cpha.ca/index.php/cjph/article/view/4002.

40. Differences in Lung Cancer Mortality Trends From 1986–2012 By Radon Risk Areas in British Columbia, Henderson, Sarah B.; Rauch, Stephen A.; Hystad, Perry; Kosatsky, Tom, Canada Health Physics: May 2014 – Volume 106 – Issue 5 – p 608–613 journals.lww.com/ health-physics/Abstract/2014/05000/ Differences_in_Lung_Cancer_Mortality_Trends_From.10.aspx

41. What are the risks from medical X-rays and other low dose radiation? B F Wall, BSc, , G M Kendall, PhD, , A A Edwards, MSc, , S Bouffler, PhD, , C R Muirhead, PhD, , and J R Meara, FFPH, Health Protection Agency, Radiation Protection Division, Centre for Radiation, Chemical and Environmental Hazards, Chilton, Didcot, Oxon. OX11 0RQ, UK 2005 http://www.birpublications.org/doi/abs/10.1259/bjr/55733882?journalCode=bjr.

42. What Three Mile Island, Chernobyl, and Fukushima can teach about the next one Edward Moore Geist April 28, 2014 thebulletin.org/what-three-mile-island-chernobyl-and-fukushima-can-teach-about-next-one7104.

43. Knowing Endangerment: Worker Exposure to Toxic Vapors at the Hanford Tank Farms September 2003 The Government Accountability Project (GAP) http://www.hanfordchallenge.org/cmsAdmin/uploads/2003_Knowing_Endangerment_002.pdf.

44. Hanford Tank Vapor Assessment Report Savannah River National Laboratory October 30, 2014 SRNL-RP-2014-00791 srnl.doe.gov/documents/ Hanford_TVAT_Report_2014-10-30-FINAL.pdf

45. Measures against increased environmental radiation dose by the TEPCO Fukushima Dai-ichi NPP accident in some local governments in the Tokyo metropolitan area, T. Iimoto, H. Fujii, S. Oda, T. Nakamura, R. Hayashi, R. Kuroda, M. Furusawa, T. Umekage and Y. Ohkubo Radiation Protection Dosimetry 2012 rpd.oxfordjournals.org/content/early/ 2012/08/25/rpd.ncs224.short 46. 250 mSv: Temporary Increase in the Emergency Exposure Dose Limit in Response to the TEPCO Fukushima Daiichi NPP Accident and Its Decision Making Process Shojiro Yasui Journal of Occupational and Environmental Hygiene Volume 12, Issue 4, 2015 pp. D35-D42 http://www.tandfonline.com/doi/abs/10.1080/15459624.2014.989366#.VZ_90be07M0.

47. Long term behavior of radioactive plume of TEPCO FNPP1 released 134Cs and 137Cs in the North Pacific Ocean through the end of 2014 Aoyama, Michio; Tsumune, Daisuke; Tsubono, Takaki; Hamajima, Yasunori; Kumamoto, Yuichiro EGU General Assembly 2015, held 12-17 April, 2015 in Vienna, Austria. id.3132 adsabs.harvard.edu/ abs/2015EGUGA..17.3132A.

48. Radiocaesium activity concentrations in macrofungi from Galicia (NW Spain): Influence of environmental and genetic factors M.A. Garcíaa, J. Alonsoa, b, M.J. Melgara, Ecotoxicology and Environmental Safety Volume 115, May 2015, pp. 152–158.

49. Radioactivity studies on farm raised and wild catfish produced in Mississippi, USA J. Billa, F. Han, S. Didla, H. Yu, J. Dimpah, O. Brempong, S. Adzanu Journal of Radioanalytical and Nuclear Chemistry May 2015 doi: 10.1007/s10967-015-4159-5.

50. ML15051A503 Marcus pbadupws.nrc.gov/docs/ML1508/ML15083A002.pdf

51. ML15057A349 Miller pbadupws.nrc.gov/docs/ML1508/ML15083A003.pdf

52. ML15075A200 Doss et al pbadupws.nrc.gov/docs/ML1508/ML15083A004.pdf

Addendum A: List of news found via google searches regarding radiation exposures (LNT v Hormesis) https://drive.google.com/file/d/0B7PbzAzkdGjNUGdQcFZ4NVg0YjQ/view? usp=sharing

Addendum B: Nuclear Energy Enshrined in Public Law through Finance, False Science, Intimidation, Lack of Ethics and Special Appointments https://drive.google.com/file/d/ 0B7PbzAzkdGjNUnVYNXhzQl9vUHc/view?usp=sharing

Original here: http://www.regulations.gov/contentStreamer?documentId=NRC-2015-0057-0043&attachmentNumber=1&disposition=attachment&contentType=pdf

Link to original and appendices here: http://www.regulations.gov/#!documentDetail;D=NRC-2015-0057-0043