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We strongly encourage opposition to the new technetium production facility even late. The US NRC has accepted pro-nuclear comments 10 months late. The US NRC does as they please but it is important to submit for the public record. The facility is located in Missouri but use will be throughout the country, and technetium impacts the environment for millions of years and in this context cannot possibly be justified in anyway, and is not really necessary with ultrasound and MRIs. By working its way into waterways technetium 99 will impact the oceans and world. Short-term exposure to Tc 99m can include family members, passers-by, and where patients stay in hotels: hotel cleaning people and others staying in the hotels. These may include pregnant women. Long-term exposure once it degrades to Tc 99 includes everyone and everything. Technetium discharges from nuclear reactors-reprocessing and waste should also be opposed.

NUCLEAR REGULATORY COMMISSION [Docket No. 50–609; NRC–2013–0235] Construction Permit Application for the Northwest Medical Isotopes, LLC, Medical Radioisotope Production Facility Docket ID NRC–2013–0235 Carol Gallagher; telephone: 301–415–3463; email: Carol.Gallagher@nrc.gov

To our chagrin we typed December 30th as the deadline for comments rather than December 29th. https://www.federalregister.gov/documents/2016/11/09/2016-27058/construction-permit-application-for-the-northwest-medical-isotopes-llc-medical-radioisotope. Nonetheless, we hope that some will still submit comments by means of email (or letter), so that it becomes part of the public record. Disposable emails would still allow anonymous comment (or pseudonymous). If you choose to use a pseudonym please make certain that it is a common name.

It is noteworthy that the US NRC unfairly accepted comments almost one year late by those promoting increased public radiation exposure by the nuclear industry of 400 times that allowed by the US EPA, and 100 times that allowed by the US NRC: https://www.regulations.gov/docket?D=NRC-2015-0057 Deadline was in November 2015 and they accepted comments until in August 2016 without making a public announcement that they were accepting comments late.

Reasons to Oppose:
With increasingly sophisticated ultrasound (sonogram) and MRIs, there is no reason to continue use of lethal radioisotopes, such as Technetium 99 m, which becomes long-lived Technetium 99: https://medlineplus.gov/ultrasound.html Even without ultrasound and MRIs, there can be no justification for medical tests which damage the environment for millions of years, thus causing more illnesses in people and animals, long after the person undergoing the test is dead. These include, but are not limited to, life-shortening cancers which would not otherwise occur. Everyone is going to die and it is unethical to shorten the lives of additional people for a medical test which may or may not even be life-saving for one individual.

The short-term risks of Technetium 99 m are high for the patient and unacceptably high for family members, and the general public, who aren’t even warned of their exposure. These innocent victims include pregnant women and their unborn children. Furthermore, it becomes Technetium 99 with a half-life of 211,000 years, meaning it will stay radioactive for millions of years, impacting future generations. It is continually building up in the environment from both medical uses and radioactive discharges from nuclear reactors, processing and waste, which should also be stopped. From the environment, it increasingly enters into the bodies of humans, plants, and animals. Contamination is invisible so that it is impossible to avoid it.

According to wikipedia, citing documentation from the US FDA, NIH, and academic papers: “Diagnostic treatment involving technetium-99m will result in radiation exposure to technicians, patients, and passers-by. Typical quantities of technetium administered for immunoscintigraphy tests, such as SPECT tests, range from 400 to 1,100 MBq (11 to 30 mCi) (millicurie or mCi; and Mega-Becquerel or MBq) for adults.[64][65] These doses result in radiation exposures to the patient around 10 mSv (1000 mrem), the equivalent of about 500 chest X-ray exposures.[66] This level of radiation exposure carries a 1 in 1000 lifetime risk of developing a solid cancer or leukemia in the patient.[67] The risk is higher in younger patients, and lower in older ones.[68] Unlike a chest x-ray, the radiation source is inside the patient and will be carried around for a few days, exposing others to second-hand radiation. A spouse who stays constantly by the side of the patient through this time might receive one thousandth of patient’s radiation dose this way.“. http://en.wikipedia.org/wiki/Technetium-99m And, after the Technetium 99m enters the environment, it will be dangerous for millions of years, in the form of Technetium 99. http://www.accessdata.fda.gov/drugsatfda_docs/label/2008/019785s018lbl.pdf; https://dailymed.nlm.nih.gov/dailymed/index.cfm; J Am Coll Radiol. 2008 Feb;5(2):126-31. doi: 10.1016/j.jacr.2007.07.020 “Suboptimal awareness of radiologic dose among patients undergoing cardiac stress scintigraphy” Bedetti G1, Pizzi C, Gavaruzzi G, Lugaresi F, Cicognani A, Picano E. https://www.ncbi.nlm.nih.gov/pubmed/18242529
Fahey, Frederic H.; Treves, S. Ted; Adelstein, S. James (1 August 2011). “Minimizing and Communicating Radiation Risk in Pediatric Nuclear Medicine” (PDF). Journal of Nuclear Medicine Technology. 52 (8): 1240–1251. doi:10.2967/jnumed.109.069609.

As explained above, US government funded BEIR VII (2006) suggests that a 10 mSv exposure leads to a 0.1% (1 in 1000) risk of a life-shortening cancer above and beyond the already high risk (i.e. “excess” cancer risk).

BEIR VII best estimate is that per 100 mSv exposure that 1 in 100 people, i.e. 1%, would get a life-shortening cancer, that they wouldn’t otherwise get. (This is understood to be 1,000 excess cancer cases per population of 100,000). The exposure and risk is cumulative over a lifetime.

Analysis of a more recent government funded study (2015) suggests that the excess cancer risk may be 15 times or more greater than the BEIR estimate – a 1.5% excess cancer risk from a 10 mSv exposure alone (15 in 1000), rather than the 0.1% risk estimated by BEIR VII. The excess cancer risk from 100 mSv exposure would thus be 15% (15 in 100, i.e. 15,000 excess cancer cases per population of 100,000). The radiation exposure hazard is cumulative over a life-time and is certainly at the root of most cancers. See: https://miningawareness.wordpress.com/2015/12/19/another-look-at-the-recent-low-dose-radiation-exposure-study-inworks.

Regardless, it has been known for over half a century that there is no safe dose of ionizing radiation. One track of ionizing radiation can set off the events leading to a life-shortening cancer, or other mutation-related health problems. This has been readily admitted by the US nuclear labs themselves, at least until recently.

The DNA damage caused by ionizing radiation is uniquely bad:
https://miningawareness.wordpress.com/2016/12/24/on-the-unique-dna-damage-done-by-ionizing-radiation-nuclear-materials-and-on-metting-hultgren-et-al-misleading-the-us-congress-in-this-matter/

Thus, these nuclear medical tests are high risk for the patient, those who come into contact with them, including hapless passersby, as well as the environment and future generations. It should go without saying that the same is true of the nuclear industry.

According to Barnaby et. al. (1999): “Tc-99 becomes concentrated offshore in seaweed, winkles and mussels. A concentration factor of 120,000 has been reported in seaweed and one of 650,000 has been measured in the green gland of lobster. It may be necessary to reassess the risk to human health following the ingestion of the relevant isotopes, including Tc-99, because of the possibility of radiation induced genomic instability, as well as the cancer risk.“ Is technetium-99 (Tc-99) radiologically significant? (Barnaby F, Boeker E.Med Confl Surviv. 1999 Jan-Mar;15(1):57-70.http://www.ncbi.nlm.nih.gov/pubmed/10218003 )

All other things being equal, a safer test is preferable to a riskier test, and a less expensive test is preferable to a more expensive test. Guess what? With respect to “all other things,” nuclear and sonographic cardiac stress testing are essentially equal… Guess what else? Sonographic cardiac stress testing is safer than nuclear cardiac stress testing because it does not use carcinogenic ionizing radiation, and sonographic cardiac stress testing is significantly less expensive than nuclear cardiac stress testing. As such, Highmark’s preference of sonographic cardiac stress testing over nuclear cardiac stress testing is appropriate.” Read more here: “Restricting nuclear cardiac stress testing in favor of stress echocardiography“, by Adam Rothschild, MD, March 24, 2011 http://www.kevinmd.com/blog/2011/03/restricting-nuclear-cardiac-stress-testing-favor-stress-echocardiography.html. Also available here: http://blog.doctrelo.com/2011/01/the-american-college-of-cariologys-cardiac-stress-testing-appropriate-use-criteria-answer-the-wrong-question/ (Emphasis our own).

See more: https://miningawareness.wordpress.com/2016/12/21/tc-99m-becomes-tc-99-which-stays-in-environment-for-millions-of-years-medical-and-non-medical-production-should-be-banned-comment-deadline-30-december-2016/
https://miningawareness.wordpress.com/2015/11/11/radioisotopes-program-was-cover-for-avoiding-liability-claims-from-vets-human-radiation-experiments-expanding-the-agenda-to-all-americans-with-100-msv-per-year-proposal-of-cancer-for-all-comment-d/
The US NRC apparently allows a greater public exposure to medical radioisotopes than other countries. Peter Crane has been one of the only people warning of this problem: https://miningawareness.wordpress.com/2015/10/25/is-petition-for-increasing-public-exposure-to-radiation-a-usnrc-inside-job-retired-nrc-counsel-carol-marcus-wrote-another-petition-at-the-request-of-nrc-staff/
https://miningawareness.wordpress.com/2016/02/17/us-radiation-release-rule-for-i-131-patients-allowing-high-public-exposure-comes-back-on-hospital-er-causing-panic/
https://miningawareness.wordpress.com/2015/07/20/patients-nuclear-reactors-routinely-release-radioactive-iodine-into-sewers-environment-comment-deadline-1-tonight-11-59-pm-us-eastern-2-sept-1st/

NB: If a doctor recommends a test that uses ionizing radiation there is usually an alternative, in our experience. We recommend that you research and inform yourself of your options in advance so that you can make an educated decision.
Radioactive Effluents NRC or EPA drawing