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[Update: Comment Deadline was extended to August 16th.]
Since the Trump-Pruitt EPA is quoting Calabrese, this appears to be a renewed push to increase the radiation exposure to the general public from nuclear facilities, mining and the oil and gas industry, by 400 fold – from 0.25 mSv per year, to 100 mSv per year. This not only would mean a huge increase in life-shortening cancers, but also increases in cataracts, heart disease, and strokes (and at younger ages). The impacts won’t just be on humans, either, but animals and plants. With a 400 x increase in exposure comes a 400 x greater risk. This is a no-brainer supported for many decades by scientific evidence.

The most important thing to retain from the 2015 three country study of nuclear workers by Richardson et al. is that it supports the linear no threshold model (LNT) for ionizing radiation, as does the US BEIR report. That is, there is no safe dose of ionizing radiation and increased radiation exposure is increased risk. The 2015 study shows association between protracted very low dose exposure to ionising radiation and cancer deaths. Although high dose rate exposures have been presumed by many “to be more dangerous than low dose rate exposures, the risk per unit of radiation dose for cancer among radiation workers was similar to estimates derived from studies of Japanese atomic bomb survivors.” (Richardson et. al., BMJ, Oct 2015). When they speak of low dose, in this study, it is a cumulative median average of 4.1 mSv over the course of the workers’ career (on average 12 years), only slightly above the current US EPA limit.

According to the BEIR VII estimates, the approximately half of those who die from cancer due to radiation exposure will have had their lives shortened by 14 to 15 years, meaning little or no retirement.

The Trump-Pruitt EPA quotes from Calabrese who wants to increase radiation exposure by at least 400 x the US EPA limit (100 x the NRC-International limit) and got his start working for the tobacco industry. Calabrese – covered at length in this blog – is nothing but pure evil. He’s lying about LNT.


New York AG Schneiderman was leading the charge to protect the public and was suddenly hit, the same day, with unproven allegations of abuse: https://miningawareness.wordpress.com/2018/05/08/new-york-attorney-general-tries-to-protect-people-environment-from-100-fold-increase-in-radiation-and-other-toxic-dangers-gets-accused-of-abuse/

The Richardson et al., 2015, study of nuclear workers estimated that approximately 209 of 19,064 deaths from cancer, other than leukaemia, “were excess deaths associated with external radiation exposure” from the work environment. In the cohort, 257,166 workers were exposed to radiation at work with a median cumulative exposure of 4.1 mGy (= mSv for gamma external exposure). The median follow-up was 26 years, and median length of employment was 12 years. The median age was 58 years. At the time of the study, 19,064/257,166 exposed to radiation at work had died of cancer, other than leukemia, or 7.1%. Of these, they estimate that 1% were excess cancer deaths due to radiation exposure at work. The cumulative median average of exposure at work was 4.1 mSv (median years of work was 12 years), which is then an average of 0.34 mSv per year. This is slightly above the 0.25 mSv per year exposure limit for the general population from radioactive discharges from nuclear facilities allowed by the US EPA, and below the 1 mSv per year US NRC/international limit for exposure of the general population to radioactive discharges from nuclear facilities. The estimated excess cancer deaths, excluding leukemia, from work exposure, according to the study, were 209/257,166 or 0.08%. Based on the the 4.1 mGy (mSv) median cumulative dose, excess deaths from cancer per mSv would be an estimated 0.02%. As cancer rates are roughly double, then cancer rates would be approximately 0.04% per mSv. Excess deaths from cancer per 100 mSv would be 2% and cancers approximately 4%. This is roughly in line with upper bounds of the earlier BEIR report of approximately 3% cancer rate per 100 mSv exposure. Excess deaths from cancer per 1000 mSv (Sv) would be 20% and cancer rates would be approximately 40%. This is a conservative interpretation. The risks may be much higher. If internal hi-LET radiaton is included the risks are definately much higher. And, any excess risk is too high. Nuclear power is unnecessary and the charges for nuclear waste are high enough to store and monitor it properly, the for profit operators just don’t want to.

Calabrese, cited by Trump-Pruitt’s EPA, has pushed for a 100 mSv exposure for the general public, per year, or 400 times the US EPA limit of 0.25 mSv. Based on the above calculations based on Richardson, et al., 10 years of the 100 mSv promoted by Calabrese would then lead to around 20% more cancer deaths and 40% more cancers in exposed populations. 30 years of 100 mSv (3000 mSv) would lead to approximately 60% more cancer deaths and 120% more cancers (recall that people can get cancer more than once and more than one type.). 40 years would be 80% more cancer deaths and 160% more cancers. These cancers would be those appearing within an average of 26 years. More could appear later. These are what BEIR calls “life-shortening” cancers.

Comment to EPA here by August 16th: https://www.regulations.gov/docket?D=EPA-HQ-OA-2018-0259

While it has become popular to talk about ROS damage from radiation (e.g. Timothy Mousseau), ROS occurs in everyday life in contrast to radiation induced clustered DNA damage which is unique to radiation-damage and nearly impossible to correctly repair: https://en.wikipedia.org/wiki/Reactive_oxygen_species. Clustered DNA damage is considered a signature of ionizing radiation: “clustered DNA damage sites, which may be considered as a signature of ionising radiation, underlie the deleterious biological consequences of ionising radiation…ionising radiation creates significant levels of clustered DNA damage, including complex double-strand breaks (DSB)” See: “Biological Consequences of Radiation-induced DNA Damage: Relevance to Radiotherapy“, by M.E. Lomax et. al. Clinical Oncology 25 (2013) 578-585. “The formation of clustered damage distinguishes ionising radiation-induced damage from normal endogenous damage: https://cordis.europa.eu/pub/fp5-euratom/docs/non_dsb_lesions_projrep_en.pdf More here: 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/

This blog spent time picking Richardson et.al. (2015) apart in the past. The cancer rates may be much higher: https://miningawareness.wordpress.com/2015/12/19/another-look-at-the-recent-low-dose-radiation-exposure-study-inworks However, this time we opted to simply base the evaluation upon the text itself. We used the more appropriate median, rather than the mean. As they admit, the exposure is skewed with most of the exposure toward the low end, making the median all the more appropriate.

Notes re Radiation and Eyes-Heart

Excerpted from Dr. Timothy Mousseau: “… eyes are very sensitive to radiation. And it turns out that…the stem cells, maybe you didn’t know this, your, the lens of your eyes is completely being, is being grown all the time. There’s new layers of cells being put down all the time and at the back of the posterior portion of the lens. And the stem cells that generate these clear cells for the lens are very sensitive to radiation. And so if they’re damaged as a result of the radiation they end up making opaque cells. And so it’s very easy to see this signal of radiation damage in the form of a radiation cataract and noticed in many of the atomic bomb survivors but also in people who work around x-ray machines in the medical field or in other, nuclear industry….” See: https://miningawareness.wordpress.com/2015/10/13/biological-consequences-of-nuclear-disasters-from-chernobyl-to-fukushima/

According to the US FDA, and others, “More recent studies suggest that the lowest cataractogenic dose in people is much less than these values, is statistically compatible with no threshold at all, and that increasing dose is associated with an increasing prevalence of cataracts.” (USFDA) https://miningawareness.wordpress.com/2015/06/22/no-dose-of-radiation-is-safe-for-the-eyes-any-dose-can-cause-cataracts-usnrc-comment-deadline-today-11-59-pm-ny-dc-et-one-minute-to-midnight/

0.5 Gy (Sv) would be 500 mSv for external gamma exposure – 5 years of what Calabrese-Trump-Pruitt apparently want.

The ICRP says: “… a ‘threshold dose’ of 0.5 Gy is proposed here for both cardiovascular disease and cerebrovascular disease on the basis that this dose might lead to approximately 1% of exposed individuals developing each disease in question. Nevertheless, there are notable uncertainties in determining risks of these diseases at this level of dose.” (p.292) https://miningawareness.wordpress.com/2015/06/20/heartless-us-nrc-ignores-icrp-concerns-re-radiation-risks-to-cardio-cerebrovascular-systems-comment-deadline-monday-22-june-1159-pm-one-minute-to-midnight-ny-dc-et/

This puts lens changes at 200 to 500 mSv:
The lens of the eye is one of the most radiosensitive tissues in the body (Brown, 1997; Ainsbury et al., 2009). When the radiosensitivity of various eye tissues is compared, detectable lens changes are noted at doses between 0.2 and 0.5 Gy, whereas other ocular pathologies in other tissues occur after acute or fractionated exposures of between 5 and 20 Gy” (ICRP, 118, p. 117). https://miningawareness.wordpress.com/2015/06/22/no-dose-of-radiation-is-safe-for-the-eyes-any-dose-can-cause-cataracts-usnrc-comment-deadline-today-11-59-pm-ny-dc-et-one-minute-to-midnight/

500 mSv:
An approximate threshold dose of around 0.5 Gy has been proposed for acute and fractionated/protracted exposures, on the basis that this might lead to circulatory disease in only one to a few percent of exposed individuals, although the estimation of risk at this level of dose is particularly uncertain.” p. 304, ICRP 118.

About Calabrese and the 100 mSv: https://miningawareness.wordpress.com/2015/10/23/hormesis-advocates-dodge-scientific-rigor-with-special-pleadings-ties-to-tobacco-industry-koch-brother-exposed-by-chp-emeritus-november-19th-comment-deadline-looms/
For additional information on Calabrese, type Calabrese in the search window of our blog.

Unfortunately, Richardson et al. have made no effort to make their study understandable, even for those with good backgrounds in research methods and who take the time to pick through it. The exception is that they do make clear that it supports the linear no threshold dose.
Richardson et al: “Risk of cancer from occupational exposure to ionising radiation: retrospective cohort study of workers in France, the United Kingdom, and the United States (INWORKS)” BMJ 2015; 351 doi: http://dx.doi.org/10.1136/bmj.h5359 (Published 20 October 2015, CC- BY- NC: http://www.bmj.com/content/351/bmj.h5359

Click to access ricd026856_updated_data_supplement.pdf