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The deadline was extended to August 16th, 1159 pm Eastern Time. Comment here: https://www.regulations.gov/docket?D=EPA-HQ-OA-2018-0259
As explained in the US Congress on September 2016, by Dr. Weatherwax, Ph.D. in biochemistry: “To date, there are no studies that have been able to establish with sufficient certainty a threshold level of radiation below which a risk of cancer is zero, despite decades of research in this area. In the absence of sufficient data to the contrary, the LNT model continues to be the accepted, albeit conservative, standard on which current radiation worker protection standards are based. Current National and International bodies (National Council on Radiation Protection and. Measurements, NCRP; International Commission on Radiological Protection, (ICRP) continue to recommend the use of the LNT.” http://docs.house.gov/meetings/SY/SY21/20160921/105345/HHRG-114-SY21-Wstate-WeatherwaxS-20160921.pdf

A 2015 multi-country study of nuclear workers showed increased cancer rates at very low doses – a cumulative median average of 4.1 mSv over the course of the workers’ career (median average 12 years). Thus, average per year exposure was only slightly higher than the US EPA official limits for the general public and much lower than the US NRC and international limit: https://miningawareness.wordpress.com/2018/05/09/trump-pruitt-nuclear-hit-job-on-the-epa-american-people-may-increase-radiation-exposure-by-400x-how-quickly-will-everyone-die

The US DOE was calling 100 mSv low level. 100 mSv is much higher than 4.1 mSv!

August 16th, 2018 comment deadline: “The proposed rule includes a provision allowing the Administrator to exempt significant regulatory decisions on a case-by-case basis if he or she determines that compliance is impracticable because it is not feasible to ensure that all dose response data and models underlying pivotal regulatory science are publicly available… The agency requests comment on whether these exemptions are appropriate….” Comment to Trump-Pruitt’s EPA here: https://www.regulations.gov/docket?D=EPA-HQ-OA-2018-0259 No this isn’t “appropriate”! It is the antithesis of the precautionary principle: “The [precautionary] principle implies that there is a social responsibility to protect the public from exposure to harm, when scientific investigation has found a plausible risk. These protections can be relaxed only if further scientific findings emerge that provide sound evidence that no harm will result.” https://en.wikipedia.org/wiki/Precautionary_principle

Calabrese, who spent much, or all, of his career pretending that chemicals, cigarettes and radiation are safe, is quoted in the Trump-Pruitt EPA news release on this topic, while spouting big lies. He was behind the 2015 push to raise the public exposure limit to radiation to 400 x greater than the US EPA currently allows. On April 24th 2018: “Dr. Edward J. Calabrese, Professor, Environmental Health Sciences, University of Massachusetts: “The proposal represents a major scientific step forward by recognizing the widespread occurrence of non-linear dose responses in toxicology and epidemiology for chemicals and radiation and the need to incorporate such data in the risk assessment process.” https://www.epa.gov/newsreleases/epa-administrator-pruitt-proposes-rule-strengthen-science-used-epa-regulations

Noelle Metting complained to Congress alleging that she was persecuted by the US DOE. See the bogus: “U.S. Department of Energy Misconduct Related to the Low Dose Radiation Research Program “, December 20, 2016 Staff Report Committee on Science, Space, and Technology Chairman Lamar Smith. [1] The true root of her complaint is apparentally the cancellation of her useless program, whose sole purpose seems to have been a hopeless attempt to prove that radiation is good for us. This “Low Dose Radiation Research Program“, led by her for 13 years, apparently attempted for almost 20 years to prove that radiation is good for us and failed. Why? Because exposure to ionizing radiation can never be good.

In fact, as outlined in the report, it appears to be Noelle Metting who has wanted to confuse and mislead Congress that there was useful research to do in this almost two decades long wasteful program, which was finally to be closed.

Already 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…

Ionizing radiation in the form of X-rays was known almost 100 years ago to induce genetic damage which could lead to cancer. Anyone alive who thinks that radiation is good for living beings has been grossly failed by their education.

Taxpayer money would be better spent in attempts to prove the earth flat, than to further invest in the “Low Dose Radiation Research Program“. And, x-rays are actually less dangerous than ionizing radiation from radioactive materials.

There is no safe dose of ionizing radiation, largely because of mostly irreparable double stranded DNA damage. And, the risk associated with exposure to man-made radiation is totally unnecessary.

In 1946 Muller was awarded the Nobel Prize in Physiology or Medicine, “for the discovery that mutations can be induced by x-rays”… The Nobel Prize, in the wake of the atomic bombings of Hiroshima and Nagasaki, focused public attention on a subject Muller had been publicizing for two decades: the dangers of radiation. In 1952, nuclear fallout became a public issue; since Operation Crossroads, more and more evidence had been leaking out about radiation sickness and death caused by nuclear testing, and Muller was one of the foremost experts. Muller—and many other scientists—pursued an array of political activities to defuse the threat of nuclear war...” https://en.wikipedia.org/wiki/Hermann_Joseph_Muller

Calabrese and his mignons want people to believe that no research has been done since 1946, when nothing could be farther from the truth! When we talk of BEIR VII, it’s because that was the seventh report! See, for instance, anthropologist Peter Wood citing Calabrese. They call themselves National Association of Scholars (NAS), apparently to confuse people into thinking that they are the National Academy of Science (NAS): https://www.regulations.gov/contentStreamer?documentId=EPA-HQ-OA-2018-0259-0039&attachmentNumber=1&contentType=pdf

There is nothing “low” about the 100 mSv called low dose by this program. Rather, it is the beginning of medium dose, according to BEIR. According to BEIR VII, 100 mSv leads to an approximately 1% excess cancer rate. A more recent government funded study (2015) suggests that the risk may be much worse. Nonetheless, 1% per 100 mSv is bad enough. Funding for the 2015 study came from the US CDC; Ministry of Health, Labour and Welfare of Japan; French IRSN; French state owned nuclear companies AREVA and EDF; US National Institute for Occupational Safety and Health; USDOE; and Public Health England: https://miningawareness.wordpress.com/2018/05/09/trump-pruitt-nuclear-hit-job-on-the-epa-american-people-may-increase-radiation-exposure-by-400x-how-quickly-will-everyone-die/

But, Metting wants to up the figure to 150 mSv, i.e. 150 times the internationally recognized maximal annual exposure level from nuclear facilities and waste and 600 times the US EPA limit. In short, she appears a dangerous ideologue: “One of the staffers asked Appellant [Metting] if she believed 100 mSv was a reasonable level to define as a “low dose.” Metting “responded that she believed 150 mSv might be more appropriate, but that the LDRRP defined “low dose” as 100 mSv.” [2] A quick search for Noelle Metting and Mark Miller shows us that he links to her work. Miller wants to send people back to Fukushima at radiation levels high enough to induce radiation poisoning! https://miningawareness.wordpress.com/2015/08/18/sandia-us-nuclear-lab-found-quick-easy-solution-for-radiation-at-fukushima-chernobyl-other-contaminated-zones/

The bogus hearings and report called “U.S. Department of Energy Misconduct Related to the Low Dose Radiation Research Program“, December 20, 2016 Staff Report Committee on Science, Space, and Technology Chairman Lamar Smith.[1] further unveils the lie that Republicans are interested in saving money. The Republicans supporting her cause have received donations from those interested in perpetuating the creation of radioactive waste. Patronage or Idiocy? All of this is squealing for money to further fund. ideologically driven “research”, in conjunction with Congressional stupidity and/or Congressional campaign funding. It appears furthermore a witchunt against Dr. Weatherwax who is doing renewable energy research.

Obviously, Metting is probably mad that her worthless fat-cat job was cancelled. Even college flunk-out paper pushers in US agencies get paid more than teachers or professors if they sit there long enough.

In fact, as outlined in the report, it appears to be Noelle Metting who wanted to mislead Congress that there was more research to do! Yes, the public needs to know the impacts of radiation from Fukushima and other ongoing nuclear discharges. So, tell them the impacts by testing sediments and air. Spend the money to install an adequate number of monitors and do testing instead of doing BS research trying to prove it is safe. It’s not safe. Proper measurement and reporting by the US EPA would give Americans an estimate of what cancer rates to expect due to Fukushima and other radioactive discharges into the environment, whether intentional or unintentional, legal or illegal, routine or due to an accident.

The US National Academy of Sciences has stood by the fact for over half a century that there is no safe dose of ionizing radiation. Increased exposure is increased risk. While government agencies linked to the pro-nuclear world have struggled to prove that radiation is good for you, only the opposite has been proven.

Exposure to ionizing radiation over the years has been demonstrated to be much worse than experts previously admitted. Even from a statistical point of view they keep “discovering” that nuclear is more deadly than initially thought.

However, the following is all anyone really needs to know to understand that continued discharges of radioactive materials into the environment are unacceptable:
Clustered DNA damage, which is impossible, or almost impossible, to properly repair, 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

Thus, despite at least 18 years of effort trying to show the contrary, the US DOE was finally forced to admit: “To date, there are no studies that have been able to establish with sufficient certainty a threshold level of radiation below which a risk of cancer is zero, despite decades of research in this area. In the absence of sufficient data to the contrary, the LNT model continues to be the accepted, albeit conservative, standard on which current radiation worker protection standards are based. Current National and International bodies (National Council on Radiation Protection and Measurements, NCRP; International Commission on Radiological Protection, (ICRP)) continue to recommend the use of the LNT.

The DOE Low Dose Radiation Research program is ending in FY 2016 with a substantial record of fundamental research that has been disseminated in the primary research literature. Despite the program’s many research accomplishments, there are no definitive research results sufficient to revise the linear no-threshold model for cancer caused by low dose radiation exposure, and BER’s Biological System science portfolio continues to shift more towards bioenergy, biodesign, and environmental microbiology missions. Funding levels for the Low Dose Radiation Research program have been steadily decreasing since 2012, with $1M appropriated to complete the program in FY 2016.” (Dr. Weatherwax to Congress)

Dr. Weatherwax has a real eduation – in biochemistry. And, she is thus probably able to work outside of the nuclear industry if need be. The whining worker in question, Noelle Metting allegedly wrote a dissertation about “Radiation-Induced Mutagenesis and Cell Cycle Perturbation“. Thus, her area of expertise appears to be narrowly contingent upon continued funding. But, where is her dissertation?

In fact, we only find the following very narrow in scope and rather useless looking article – based on the abstract – where she is not even first author. If she wrote her dissertation on this topic shouldn’t she be a first or second author? Satin G. Sawant, Gerhard Randers-Pehrson, Noelle F. Metting, and Eric J. Hall (2001) “Adaptive Response and the Bystander Effect Induced by Radiation in C3H 10T½ Cells in Culture“. Radiation Research: August 2001, Vol. 156, No. 2, pp. 177-180. She appears a US lab employee piggy backing on other researchers: “Adaptive Response and the Bystander Effect Induced by Radiation in C3H 10T½ Cells in Culture” Satin G. Sawanta, Gerhard Randers-Pehrsona, Noelle F. Mettingb, and Eric J. Halla aCenter for Radiological Research, Columbia University, New York, New York bPacific Northwest National Laboratory, Richland, Washington

Dr. Weatherwax statement:
Testimony of Associate Director Sharlene Weatherwax Office of Biological and Environmental Research Office of Science U.S. Department of Energy Before the Committee on Science, Space, and Technology U.S. House of Representatives September 21, 2016

Mr. Chairmen, Ranking Members, and Members of the Subcommittees, thank you for the opportunity to appear before you today to discuss the Department of Energy’s (DOE) Low Dose Radiation Research Program and the decision to end the program in FY 2016.

My name is Dr. Sharlene Weatherwax, and I am the Associate Director for Science in Biological and Environmental Research (BER), in the Department of Energy’s Office of Science. My formal education and PhD are in biochemistry, and I have been with the Department for over 15 years, first in the office of Basic Energy Sciences and then in BER. The Low Dose Radiation Research Program is one portfolio element within BER’s Biological Systems Science Division.
[…]
“In addition to these major efforts in bioenergy-related research, BER has also managed a basic research program in Low Dose Radiation Research since 1998. At that time there was ample evidence from atomic bomb survivor studies to clearly indicate a statistically significant linear response between observed human health effects (cancer) and radiation at relatively high doses but no statistically significant data available at the low doses (less than 100mSv) more commonly experienced by most people. The low dose program was developed to specifically address what if any effects low doses of radiation could have on human health below 100mSv4.

Over the past 18 years the program has provided new technological advances and fundamental scientific understanding of the mechanisms cells use to sense, repair and adapt to the impacts of low dose radiation. Research investigations have included a number of critical biological phenomena induced by low dose exposure including adaptive responses, bystander effects, genomic instability, and genetic susceptibility. The program has supported the development of systems genetic strategies, including the role of epigenetics in integrated gene function and response of biological systems to environmental conditions, with a goal of translating molecular-scale effects of low dose radiation to whole model organisms. The program outcomes and data are available to the community and other interested agencies through peer-reviewed scientific publications…. The total amount of funding that the DOE Office of Science has devoted to the Low Dose Research Program from its inception is over a quarter of a billion dollars.

The program was not intended to address regulatory policy but rather to advance the fundamental science of radiation impacts on biological processes. The Environmental Protection Agency and the Nuclear Regulatory Commission (NRC) bear the responsibility for establishing generally applicable and legally enforceable standards for the protection of human health and the environment from radioactive materials. EPA standards set protective limits on the radioactivity in soil, water and air that comes from human use of radioactive elements. The NRC licenses and regulates the Nation’s civilian use of radioactive materials to protect public health and safety and promote the common defense and security. The NRC sets dose limits for both members of the public and workers in the nuclear industry.

Current radiation protection standards are based on the presumption that any exposure to radiation presents some risk of cancer to the exposed individual. That is, the relationship between cancer risk and radiation exposure is linear and there is no threshold level of radiation below which there is not some risk of cancer. Any changes to the current protection standards would require strong and compelling evidence that a higher amount of radiation is safe.

The “EPA Radiogenic Cancer Risk Models and Projections for the U.S. Population” book describes EPA’s methodology for estimating cancer risks from radiation exposure based on the National Research Council’s 2006 report “Biological Effects of Ionizing Radiation (BEIR VII),” as well as on other updated science. The book calculates cancer risk estimates separately by age at exposure, sex and potentially affected organ. Its risk estimate methodology reflects the scientific consensus of the BEIR VII committee and presents the scientific basis for the estimates. The book takes into account recommendations made by EPA’s Science Advisory Board (SAB), which completed its review in January 2010.

The SAB relied on advice from its Radiation Advisory Committee panel of non-EPA scientists chosen for their objectivity, integrity and expertise in radiation science and protection; additionally, the book has undergone an extensive peer review process, which included opportunities for the public and stakeholders to provide comment (https://www.epa.gov/radiation/blue-book-epa-radiogenic-cancer-risk-models-and-projections-us-population#tab-1). EPA risk assessment regarding other cancer-causing exposures also follows the linear no-threshold (LNT) methodology in the absence of mode-of-action and/or biological data to the contrary as a public-health-protective measure5…..

To date, there are no studies that have been able to establish with sufficient certainty a threshold level of radiation below which a risk of cancer is zero, despite decades of research in this area. In the absence of sufficient data to the contrary, the LNT model continues to be the accepted, albeit conservative, standard on which current radiation worker protection standards are based. Current National and International bodies (National Council on Radiation Protection and Measurements, NCRP; International Commission on Radiological Protection, (ICRP)) continue to recommend the use of the LNT.

The DOE Low Dose Radiation Research program is ending in FY 2016 with a substantial record of fundamental research that has been disseminated in the primary research literature. Despite the program’s many research accomplishments, there are no definitive research results sufficient to revise the linear no-threshold model for cancer caused by low dose radiation exposure, and BER’s Biological System science portfolio continues to shift more towards bioenergy, biodesign, and environmental microbiology missions. Funding levels for the Low Dose Radiation Research program have been steadily decreasing since 2012, with $1M appropriated to complete the program in FY 2016….” https://www.energy.gov/sites/prod/files/2016/11/f34/9-21-16_Sharlene_Weatherwax%20FT%20HSST_0.pdf

Supposed bio of Noelle Metting. We could find her dissertation neither under her name, neither by title in google scholar. Why does anyone need a degree in “radiation biology”? A more objective degree would be biology-biological sciences or biochemistry. Hear that squealing nuclear pork: “Dr. Noelle F Metting is a Radiation Biologist, currently working for the Department of Energy Office of Environment, Health, Safety and Security within the Office of Public Radiation Protection (DOE/EHSS/AU-22). Formerly, she worked in DOE’s Office of Science, Office of Biological and Environmental Research (DOE/SC/BER), where, from the year 2001 until December of 2014, she managed DOE’s Low Dose Radiation Research Program. For the previous 20 years, she worked at Pacific Northwest National Laboratory as a laboratory research scientist. Dr. Metting earned a Master of Science in Radiological Sciences from the University of Washington, and a Doctor of Science in Cancer Biology from Harvard University, with a doctoral dissertation entitled Studies of Radiation-Induced Mutagenesis and Cell Cycle Perturbation.” http://docs.house.gov/meetings/SY/SY21/20160921/105345/HHRG-114-SY21-Bio-MettingN-20160921.pdf

Lamar Smith of Texas received funded by Honeywell Lockheed workers: https://www.opensecrets.org/politicians/contrib.php?cid=N00001811&cycle=2016 However, it appears more likely that his concerns are due to the petroleum industry: https://www.opensecrets.org/members-of-congress/contributors?cid=N00001811&cycle=CAREER&type=C However, he may have some connection to uranium mining in Texas and/or the west Texas nuclear dump (WCS).
https://miningawareness.wordpress.com/2015/07/27/fracking-fluids-become-more-radioactive-over-time/

Related:
Holtec comment extended: https://www.nrc.gov/reading-rm/doc-collections/news/2018/18-018.pdf

Problems with Shimkus bill: https://sanonofresafety.files.wordpress.com/2015/10/commentshr3053nwpa2017-06-23final.pdf
Shimkus bill: H.R.3053 – Nuclear Waste Policy Amendments Act of 2017
https://www.congress.gov/bill/115th-congress/house-bill/3053/actions
https://sanonofresafety.org

Notes:
[1] “U.S. Department of Energy Misconduct Related to the Low Dose Radiation Research Program December 20, 2016 Staff Report Committee on Science, Space, and Technology Chairman Lamar Smith
https://science.house.gov/sites/republicans.science.house.gov/files/documents/Staff%20Report%20-%20DOE%20Misconduct%20-%20Related%20to%20the%20Low%20Dose%20Radiation%20Research%20Program_0.pdf

[2] https://science.house.gov/sites/republicans.science.house.gov/files/documents/HHRG-114-SY20-SY21-WState-NMetting-20160921.pdf