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

A Forbes author suggested on Monday that everyone read the EPA draft. Better to believe the 985 scientists, as well as the Trump-Pruitt track record. The 985 scientists address some of the lies: https://miningawareness.wordpress.com/2018/05/20/nearly-1000-scientists-tell-trump-pruitt-epa-dont-restrict-epas-ability-to-rely-on-science-comment-by-may-30th

It is important to know that the US FDA allows more radiation in US food than any other country in the world, among those with limits. Clean air and water are even more critically needed, so that some people will still be spared life-shortening cancers.

Here is a big lie deception in the EPA document, probably the most important one: “there is growing empirical evidence of non-linearity in the concentration-response function for specific pollutants and health effects“. https://www.regulations.gov/document?D=EPA-HQ-OA-2018-0259-0006
[Update note – linearity, in this context, means increased dose leads to increased risk. Their underlying non-linearity argument is that there is some safe dose of pollutants.]

It doesn’t say which pollutants! Which health effects? Over what time period is the exposure? How long does it take for the effects to appear? Is the effect acute? Chronic? Do the pollutants accumulate in the body? If the pollutants don’t degrade in a timely manner, they accumulate in the environment.

As explained, further below, by the National Institute of Health (NIH), it is far more complicated than Trump-Pruitt’s EPA would have everyone believe. Are their distortions lies? They can be considered both lies of commission and lies of omission, intentionally designed to confuse and deceive.

And, for radioactive materials, what the Trump Pruitt EPA document says is a patent lie. In stark contrast to what the Trump Pruitt EPA alleges, for exposure to ionizing radiation there is growing empirical evidence of linearity, supporting BEIR’s “no safe dose” of ionizing radiation. In short, increased dose is increased risk. Furthermore, many radioactive materials are heavy metals which are chemically toxic, as well as radiologically toxic. They also stay in the body for various periods of time, sometimes for decades. Lead is a well-known heavy metal, which accumulates in the body.

“FINAL OMB CONCLUSION DRAFT 4/23/2018
Page 6 of 16 “As a case in point, there is growing empirical evidence of non-linearity in the concentration-response function for specific pollutants and health effects…. EPA should also incorporate the concept of model uncertainty when needed as a default to optimize low dose risk estimation…. various threshold models across the exposure range….” https://www.regulations.gov/document?D=EPA-HQ-OA-2018-0259-0006 EPA already incorporates uncertainty. Trump Pruitt’s EPA want to use uncertainty against public health.

This undertaking appears to have been spear-headed by Calabrese’s SARI group. A whole paper was written about these lies and distortions: “Conceptual analysis and special-interest science: toxicology and the case of Edward Calabrese” by Kristin Shrader-Frechette Received: 18 December 2008 / Revised: 1 October 2009 / Accepted: 23 July 2010 / Published online: 20 October 2010, Synthese (2010) 177:449–469. https://www3.nd.edu/~kshrader/pubs/ksf-2010-calabrese-synthese.pdf

A health physicist also explains Calabrese et al.’s game and the links to the tobacco industry: https://miningawareness.wordpress.com/2018/05/20/hormesis-advocates-dodge-scientific-rigor-with-special-pleadings-ties-to-tobacco-industry-koch-brothers-exposed-by-chp-emeritus-us-epa-comment-deadline-may-30th/

Here’s what the NIH says:
“The procedures used to extrapolate from high to low doses are different for assessing carcinogenic effects and noncarcinogenic effects:

Carcinogenic effects in general are not considered to have a threshold and mathematical models are generally used to provide estimates of carcinogenic risk at very low dose levels. Noncarcinogenic effects (for example neurotoxicity) are considered to have dose thresholds below which the effect does not occur. The lowest dose with an effect in animal or human studies is divided by safety factors to provide a margin of safety.”

Noncarcinogenic Risk Assessment…

The critical toxic effect used in the calculation of an ADI, RfD, or MRL is the serious adverse effect that occurs at the lowest exposure level. It may range from lethality to minor toxic effects. It is assumed that humans are as sensitive as the animal species unless evidence indicates otherwise….

Assessment of Noncancer Toxicity Effects

While the Agency for Toxic Substances and Disease Registry (ATSDR) does not conduct cancer risk assessments, it does derive Minimal Risk Levels (MRLs) for noncancer toxicity effects (such as birth defects or liver damage). The MRL is defined as an estimate of daily human exposure to a substance that is likely to be without an appreciable risk of adverse effects over a specified duration of exposure. For inhalation or oral routes, MRLs are derived for acute (14 days or less), intermediate (15–364 days), and chronic (365 days or more) durations of exposures.

Assessment of Acute or Short-Term Exposures

Risk assessments are also conducted to derive permissible exposure levels for acute or short-term exposures to chemicals. Health Advisories (HAs) are determined for chemicals in drinking water. HAs are the allowable human exposures for 1 day, 10 days, longer-term, and lifetime durations. The method used to calculate HAs is similar to that for the RfDs using uncertainty factors. Data from toxicity studies with durations of length appropriate to the HA are being developed…” https://toxtutor.nlm.nih.gov/06-003.html (Emphasis our own.)

Trump-Pruitt-EPA’s “The FINAL OMB CONCLUSION DRAFT 4/23/2018” appears anxious to give themselves a false semblance of seriousness by saying in a couple of places “The National Academies noted…” without pointing out what is most relevant to this, which is that “The National Academies” BEIR VII report (ca 2006) took into consideration Calabrese’s “dose-response” lies-wishful thinking. They allowed him to speak about “hormesis” and rejected it: https://www.nap.edu/read/11340/chapter/1. https://www.nap.edu/read/11340/chapter/19#335 And, so Calabrese pretends that BEIR hasn’t done anything since 1956, which is another patent lie. He participated in the 2006 one.

The 2015 three country study of nuclear workers by Richardson et al. adds more support to the linear no threshold model (LNT) for ionizing radiation. It is also supported by the National Academy of Science BEIR VII (ca 2006) 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 ionizing radiation and cancer deaths. 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 of 0.25 mSv. See:
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/
https://miningawareness.wordpress.com/2015/12/19/another-look-at-the-recent-low-dose-radiation-exposure-study-inworks/
The lead petitioner on a S.A.R.I. letter to Scott Pruitt in March 2017 was Mark Miller. The S.A.R.I. letter-petiton seems to have morphed into the current petition. Mark Miller proposes levels of radiation exposure which are so high that people may get radiation poisoning, which is an acute condition, which may lead to death in the very short term: https://miningawareness.wordpress.com/2015/09/08/proponent-of-radiation-is-good-for-you-has-solar-panels-on-his-own-roof-mark-l-miller-of-lockheed-martin-run-sandia-national-lab/
https://miningawareness.wordpress.com/2015/08/18/sandia-us-nuclear-lab-found-quick-easy-solution-for-radiation-at-fukushima-chernobyl-other-contaminated-zones/

https://miningawareness.wordpress.com/2015/02/26/plutonium-trojan-horse-in-the-body/
https://miningawareness.wordpress.com/2017/01/28/us-epa-hid-details-of-huge-radiation-increase-for-drinking-water-in-a-nuclear-accident-increase-violates-safe-drinking-water-act-arguably-illegal-a-couple-of-hours-left-to-oppose-private-nuclear-w/
https://miningawareness.wordpress.com/2016/07/22/gina-mccarthy-says-let-them-drink-radioactive-water-100s-and-1000s-of-times-the-legal-limit-or-dehydrate-gina-and-moniz-dance-the-nuclear-waltz/
https://miningawareness.wordpress.com/2016/07/08/us-ramping-up-for-imminent-nuclear-accident-wants-americans-to-drink-radiation-contaminated-water-comment-deadline-25-july-2016-11-59-pm-dc-time/
https://miningawareness.wordpress.com/2015/02/26/plutonium-trojan-horse-in-the-body/
https://miningawareness.wordpress.com/2015/07/22/du-has-pu-plutonium-1-kg-enriched-uranium-makes-7-kg-plus-of-du-waste-us-nrc-comment-deadline-24-july-2015-11-59-pm-dc-nyc-et/

THE END GAME ISN’T FOR THE TAXPAYER TO SAVE MONEY BUT TO MAXIMIZE THE PROFITS OF PRIVATE NUCLEAR WASTE COMPANIES LIKE ENERGY SOLUTIONS, PARTLY OWNED BY TRUMP FUND-RAISER/LARGE DONOR, DOUG KIMMELMAN WHO RECENTLY PARTNERED WITH RUSSIAN OLIGARCH LEN BLAVATNIK’S ACCESS INDUSTRIES TO BUY CALPINE. LIKE HOLTEC, ENERGY SOLUTIONS IS PRIVATE AND IT IS ALMOST IMPOSSIBLE TO GET INFORMATION ABOUT OWNERSHIP OR ANYTHING ELSE. It is also to deal with the next nuclear disaster, which is imminent, by saying everything is ok. For the non-radioactive toxins, it saves corporations clean-up money for spills, etc.

Nuclear power stations produce radioactive waste continuously. And, once nuclear power stations are shut-down the often radioactive rubble must go somewhere. EnergySolutions’ owns ZionSolutions: “ZionSolutions is using a rip and ship process that will reduce the labor intensive separation of contaminated materials and transport the facility in bulk to the EnergySolutions disposal site in Utah and to WCS in Texas“ https://www.nrc.gov/info-finder/decommissioning/power-reactor/zion-nuclear-power-station-units-1-2.html
https://miningawareness.wordpress.com/2017/01/26/nuclear-rip-and-ship-radioactive-waste-dilution-lethal-underbelly-of-private-nuclear-waste-revealed-in-us-lawsuit-against-trump-large-donors-corp-comment-deadline-friday-11-59-pm-et-ny-dc-time/

Richardson et. al. 2015 BMJ INWORKS p. 4 showing data is skewed with most very low dose. Note the very last sentence – over 10,000 people in the lowest category of exposure.


Richardson et. al. 2015, Figure S1. Relative rate of all cancer other than leukemia by categories of cumulative colon dose less than 100 mGy, lagged 10 years in INWORKS.

Adjusted Richardson et. al. 2015, Figure S1. Relative rate of all cancer other than leukemia by categories of cumulative colon dose less than 100 mGy, lagged 10 years in INWORKS.
https://miningawareness.wordpress.com/2015/12/19/another-look-at-the-recent-low-dose-radiation-exposure-study-inworks/