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Comment by tonight, 1159 US Eastern Time (NY-DC time zone) https://www.regulations.gov/docket?D=EPA-HQ-OA-2018-0259 Docket ID: EPA-HQ-OA-2018-0259 The Trump administration is setting up total environmental contamination by the petroleum, chemical, mining, and nuclear industries with this EPA proposal.

In March of 2017, SARI sent a letter to then Trump EPA head Pruitt demanding that “the EPA’s risk-based radiation regulations be revised as above, as soon as possible“, and signed by Mark Miller, who is retired from Sandia National Lab (Lockheed Martin), and others. At least 39% of those signing on with Miller are foreigners! By what right do they demand that the US EPA poison and kill Americans? See names at bottom of blog post.


Calabrese, the “Godfather” of radiation is good for you, aka “hormesis”, is mentioned in the EPA news release for this EPA proposal. Miller appears to have gone to work for SARI and is promoting Calabrese’s work, as supportive of the EPA proposal – most recently on August 10th: http://web.archive.org/web/20180816025931/https://radiationeffects.org/?s=Calabrese

The proposed rule EPA is revealed by Mark L. Miller, to be part of a larger game-plan to use (evil) “magical thinking”, so that governments, utilities, and the nuclear industry can choose whatever radiation level they want to define as safe in order to have”Dramatically reduced operating expenses • Dramatically reduced cleanup expenses” In true Orwellian style, he calls this “science-based“! Yes, and war is peace; love is hate; freedom is slavery, and nuclear fantasy is science-based – Not! His criminal presentation was paid for by the US taxpayer, since he was still working for Sandia National Lab (under contract to Lockheed Martin). In it he says “Increase Standards by X (pick a number between 10 and 1000“, like it’s a fun game! One can imagine the response choral of “Health Physicists” mindlessly repeating “pick any number“, and too stupid to see that they are doing themselves out of jobs. If any radiation exposure number will do, no need for people to monitor the exposure level. No more need for the euphemistically named “Health Physicist” with origins in the Manhattan Project.

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/

Mark Miller envisions people at Fukushima living with exposure levels of 20,000 mSv (i.e. 20 Sv) per year, which is 20,000 times higher than the already high level (1 mSv per year) forced upon the general population in most places from exposure to nuclear facilities. It is 80,000 times higher than that forced upon Americans by the US EPA. (The US EPA officially permits 0.25 mSv per year exposure to the public from nuclear facilities, and 0.75 mSv for thyroid dose.) Miller even envisions return to the Chernobyl exclusion zone! Not for himself, apparently, just for everyone else! Mark Miller, now retired, has solar panels on his own roof. As of March 2017, his address is still listed as this house:

One page from Miller’s 2011 presentation:

Some information on chronic radiation disorder from exposure. For external dose, 20 Gy and 20 Sv would be approximately equivalent, i.e. 20,000 mSv.
http://www.icrp.org/docs/Tissue%20Reactions%20Report%20Draft%20for%20Consultation.pdf
http://www.health.gov.au/internet/publications/publishing.nsf/Content/ohp-radiological-toc~ohp-radiological-13-overview

100 mSv over a lifetime already gives at least 1 in 100 excess cancer rate, above and beyond other causes. According to the US taxpayer funded BEIR 2006 report, in a population of 100,000 people, 1 mSv per year, over an “average” lifetime, means that an estimated 1019 women per 100,000 will get cancer and 621 men per 100,000 due only to this exposure. Taking into consideration the more recent Richardson et al., 2015, study of nuclear workers, BEIR’s upper bound, which is three times higher (3 in 100 per 100 mSv), appears more likely the lower bound risk estimate. https://miningawareness.wordpress.com/2018/05/22/the-big-lie-deception-in-the-trump-pruitt-epa-document-comment-deadline-may-30th/

This excludes background, medical exposures, food exposures, environmental build-up, or other sources of cancer. Multiply by 100 to find the result of 100 mSv per year: 101,900 excess cancers for women in a population of 100,000. 62,100 excess cancers for men, in a population of 100,000 (62%). Almost half of women will die of life-shortening cancers (15 years younger than average) and 31% of men will die (14 years younger than average). (BEIR, p. 312; p. 279) No retirement. Retirement will be in heaven or hell.The risk depends on both sex and age at exposure, with higher risks for females and for those exposed at younger ages.” (BEIR, p.8) [See References.]

Therefore, following BEIR estimates, due to a lifetime of 100 mSv per year ALONE, almost ALL of the population will get cancer or leukemia, of which approximately half will die – on average at or about retirement.

For 50 mSv per year, estimate of excess cancer rate drops to 51% of women and 31% of men. Slightly under half of the women with cancer will die, and more than half of the men with cancer will die of life shortening cancer. This supposes that the radiation is not accumulating in the environment, which it is. This excludes medical exposure and historic exposure. It excludes exposure in food, which the FDA has as sky-high and is a topic in and of itself.

Furthermore,”In the case of in utero exposure (exposure of the fetus during pregnancy), excess cancers can be detected at doses as low as 10 mSv“. (BEIR, p.6) 100 mSv per year over 9 months is 75 mSv. 50 mSv per year over 9 months is 37.5 mSv.

Mark L. Miller’s presentation shows that the true agenda is to make people live in radioactive environments, such as Fukushima and Chernobyl. New nuclear disasters, including from nuclear waste, are imminent. This is his quick fix solution, proposed in April of 2011. Frighteningly, he speaks on radiation testing (and has been involved in radiation remediation, according to his Linked-in page). “GPS-COUPLED GAMMA (GPS/GAMMA) SURVEY SYSTEM: DON’T LEAVE HOME[LAND] SECURITY WITHOUT IT! SAND Number: 2012-0628C Mark Miller, CHP, Sandia National Laboratories Chuck Farr, Environmental Restoration Group, Inc. http://www.sandia.gov/about/environment/environmental_management_system/sandia_new_mexico_environmental_management/_assets/documents/GPS-COUPLED%20GAMMA%20.pdf As, or more frighteningly, Carol Marcus says, on Linked-in, she is a “Consultant in emergency medical planning for radiation events,…

The true agenda is revealed below. Miller has a US government lab (Sandia) and US government agency (NNSA) stamped on his presentation, suggesting that he is speaking on behalf of US government opinion. The funny part remains that he is rallying Health Physicists to do themselves out of jobs!

Beware! Miller puts Hitler and Goebbels to shame. But, then, he has to. His plan will kill everyone and not just Jewish people; political dissidents, etc., as in Nazi Germany.

Moving Radiation Protection to a More Science‐Based Foundation: – A Call to Action! Mark L. Miller * , CHP *Sandia National Laboratories (dated April 2011) Sandia is a multiprogram laboratory managed and operated by Sandia Corporation, a Lockheed Martin Company, for the United States Department of Energy’s National Nuclear Security Administration under contract DE-AC04-94AL85000.” (p. 1)
Moving Radiation Protection to a More Science‐Based Foundation: – A Call to Action! Mark L. Miller, p. 1 Sandia-NNSA

On page 2 he seems to contradict himself: Does he want higher than 50 mSv per year or 100 mSv per lifetime? Or, maybe he intends for all to be dead in 2 years?
ALARA = As Low As Reasonably Achievable
ALAR = As Low As is REAL *
Can anyone suggest a better, “stickier” acronym?
* “Real” is anything > 5 rem (50 mSv)/year or 10 rem (100 mSv)/lifetime – HPS PS010 ‐

Moving Radiation Protection to a More Science‐Based Foundation: – A Call to Action! Mark L. Miller, p. 2 Contradiction

0.1 Sv is 100 mSv. This is NOT the public exposure allowance. The worker exposure limit for the US NRC is 50 mSv and significantly above the ICRP recommendation of 20 mSv per year for workers exposed to radiation. http://www.nrc.gov/reading-rm/doc-collections/cfr/part020/part020-1201.html
Moving Radiation Protection to a More Science‐Based Foundation: – A Call to Action! Mark L. Miller, p. 3
This is false. The dose limit is NOT 100 mSv (0.1 Sv): “ALARA = As Low As (is) Reasonably Achievable Which means making every reasonable effort to maintain exposures to ionizing radiation as far below the dose limits 10 rem (0.1 Sv) as practical, consistent with the purpose for which the licensed activity is undertaken, taking into account the state of technology, the economics of improvements in relation to state of technology, the economics of improvements in relation to benefits to the public health and safety, and other societal and socioeconomic considerations, and in relation to utilization of nuclear energy and licensed materials in the public interest.

On page 4 he says: “• (High LET Radiation to be considered separately)“. This apparently means that dangerous internal (High LET) emitters, ingested in food, as well as radon, will be added as extra exposure on top of the 100 mSv plus. Thus, the 100 mSv appears to be only external radiation. This will quickly bring the cancer rate up to 100% for men.

On page 7 he says:
Prolonged Effort Key to Success
[…]
• The Public Will Understandably Question ANY Change
• End Point Is Worth the Effort!

FOR WHOM? SO MANY WILL HAVE CANCER THERE WILL BE NO CARE-GIVERS. THE “HEALTH PHYSICS” PEOPLE HE’S SPEAKING TO WILL BE UNEMPLOYED IF “ANYTHING GOES” FOR RADIATION EXPOSURE.

JUST PICK A NUMBER HE SAYS! WOW! ISN’T THAT FUN! AND SO “SCIENCE-BASED” OF HIM! Did he invest his retirement in crematoriums or caskets?
Page 8:
Example proposal: Increase Standards by X (pick a number between 10 and 1000)
Benefits • Technically Justifiable cost/benefit (REAL)
• Underscores “little to fear” in public eyes
• Dramatically reduced operating expenses
• Dramatically reduced cleanup expenses

Moving Radiation Protection to a More Science‐Based Foundation: – A Call to Action! Mark L. Miller, p. 8

Page 9: “Real‐World Example: Fukushima Environmental Cleanup Considerations: • 50,000(+) displaced residents
8,000,000 Bq/kg versus 8,000 Bq/kg for Cs‐contaminated soil or ash disposal 5,000,000 Bq/kg versus 5,000 Bq/kg for Cs‐contaminated soil (agriculture, Japan Food Sanitation Law)
• 1000 X less restrictive foodstuff release
• All Environmental Exposure Pathways

Moving Radiation Protection to a More Science‐Based Foundation: – A Call to Action! Mark L. Miller, p. 9
Page 10:
Moving Radiation Protection to a More Science‐Based Foundation: – A Call to Action! Mark L. Miller, p. 10
RESRAD Example

p. 11 : Example: Fukushima
Moving Radiation Protection to a More Science‐Based Foundation: – A Call to Action! Mark L. Miller, p. 11
Note 1 mSv per year up to 1 Sv per year (i.e. 1000 mSv per year!) 20 mSv/y up to 20 Sv/yr (i.e. 20,000 mSv per year) With this 20 Sv, 20 Gy if external, he may be setting some people up for Acute Radiation Syndrome and death: https://en.wikipedia.org/wiki/Acute_radiation_syndrome If the rate is 20,000 mSv evenly distributed through the year, then more likely Chronic Radiation Syndrome and definitely cancer, cataracts, and infertility.

HE WANTS PEOPLE TO PICK A NUMBER OUT OF THE HAT FOR EXPOSURE LEVELS AND THEN SPEAKS OF SCIENCE? LET’S SEE WAR IS PEACE, LOVE IS HATE, MAGICAL QUACKERY IS SCIENCE? NOT!!!!
On p. 12 he says:
Thoughts
• Established Science, not Established Policy
• Science, not Ideology
• Precautionary APPROACH, not Principle!
(Patrick Moore, Greenpeace Founder)
• Don’t Demonize or Romanticize

THE CULT-LIKE, ORWELLIAN, NATURE OF HIS PLOT IS INCREASINGLY CLEAR!

THE PRONOUNCEMENT OF HIS TARGETS WHICH INCLUDE THE EPA AS WELL AS THE NRC:
On p. 13 he says:
Multilateral Involvement Essential
• HPS, ICRP, NCRP, IAEA,
• DOE, NRC, DoD, EPA (Regulators)
• Medical Profession
• Family
• Activists
• Students (K thru Grad School)
• Others?

HERE’S THE FUNNY PART: “IT STARTS WITH US, THE HPS“! ARE THEY FOOLISH ENOUGH TO DO THEMSELVES OUT OF JOBS?
p. 15
These isopleths with uSv/h X 1000 Could be reduced and the area could be re‐occupied!, p. 15
From page 16:
Multi‐faceted Approach Essential
• Technical Research and Publications • Blogs/Websites … • Papers • Personal Conversations • Peer Support and Constructive Criticism • Newspaper Submittals • Engaging/Educating the Press • Engaging/Educating Naysayers • Many Others

THE RADIATION PROTECTION COMMUNITY RIDICULES THE TRUTH AND ARE OPPOSING THE TRUTH. WHEN WILL THEY ACCEPT THE DANGERS OF IONIZING RADIATION?
On p. 17 he says
Schopenhauer said: “All truth goes through three stages.
1. First it is ridiculed.
2. Then it is opposed.
3. Finally it is accepted as self‐evident.”
At what stage is the Radiation Protection Community?

On p. 18 he says:
Let’s Get Going!
It Matters.
Let’s not wait ALAP (As Long as Possible).

The criminality of Mark Miller is heightened by the fact that he is around the age that he wants everyone else to be dead. His colleagues, Carol Marcus of UCLA (who should know better as an MD), and Mohan Doss who is a physicist from India, rather than a biologist, are well past the age when they want everyone else to be dead! Marcus and Doss have a clear conflict of interest because they work in the field of radiology, though they are so old they could afford some ethics for a change, but maybe got too much radiation onto their brains: https://miningawareness.wordpress.com/2014/03/14/alzheimers-disease-and-ionizing-radiation/ Perhaps peering over the edge of “average” death they have decided to take everyone else with them? They certainly cannot take money with them. Based on his linked-in page, Miller seems to be around 65 years old (entered undergrad in 1972); Marcus is pushing 80 (entered university in 1957), and Mohan Doss in between (entered university in India in 1968). Doss looks much older. Miller could be older. Following their 100 mSv protocol, half of women, and vast numbers of men, will die at around Miller’s age due to the 100 mSv per year alone. Since, there are other exposures, i.e. medical and food, probably death at age 65 (or less) will be the new normal. Under Miller’s more extreme protocol, of anything goes, longevity will probably drop much further. His proposals may even lead to Acute Radiation Syndrome and almost immediate death: https://en.wikipedia.org/wiki/Acute_radiation_syndrome Or, at least, chronic radiation syndrome. We will probably be speaking more and more of multiple cancers starting at younger ages and fewer children being born to exposed groups, and more disabled children, leading to the destruction of many cultures and ethnicities. There are more fair and ethical ways of doing birth control. There will be no one to care for the sick and dying Did Mark Miller, Carol Marcus, and Mohan Doss invest their retirement monies in crematoriums perchance?

References
Beir VII: Health Risks from Exposure to Low Levels of Ionizing Radiation“, 2006: “Summary Notes: LAR includes deaths (mortality) or incidences (morbidity) of cancer that might have occurred without exposure but occurred at a younger age because of the exposure (i.e. risk of untimely death). This life-shortening is about 14 years for men and 15 for women, meaning that there will be no life after retirement:. (pp. 277; 279) Weighting for US sex ratio of .97 (https://en.wikipedia.org/wiki/List_of_countries_by_sex_ratio), per 100 mSv, the BEIR report gives a 1.142% chance of cancer or leukemia for the general population. In utero exposure excess cancers may be detected as low as 10 mSv. Around half of these will die of life-shortening cancers. “TABLE 12D-3 Lifetime Attributable Risk of Solid Cancer Incidence and Mortality” (p. 312) gives cancer and death rates for men and women exposed to 1 mSv per year for a lifetime. BEIR is available for free online.

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
https://miningawareness.wordpress.com/2018/05/13/usdoe-spent-18-years-and-over-a-quarter-of-a-billion-dollars-but-failed-to-prove-low-level-radiation-is-safe-because-its-not-may-30th-comment-deadline-re-dangerous-trump-pruitt-epa-proposal/
Radiation can cause brain-damage and dementia; may cause Alzheimer’s: https://miningawareness.wordpress.com/2014/03/14/alzheimers-disease-and-ionizing-radiation/

In March of 2017, SARI sent a letter to Scott Pruitt at the EPA, which appears to have been spun into this recent proposed rule. While Calabrese didn’t sign this letter, these are his long-time colleagues, and his finger prints are all over it, including Miller promoting Calabrese’s ideas on the SARI web site.
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/

While hating to publish their lies, the SARI letter to Pruitt is an important part of the public record.






This post is an update-rewrite of a post for an earlier NRC proposal, which was based on petitions from Miller, Marcus, and Doss. Marcus actually submitted her 2015 comment-letter to the NRC for the EPA 2018 proposal! https://miningawareness.wordpress.com/2015/08/18/sandia-us-nuclear-lab-found-quick-easy-solution-for-radiation-at-fukushima-chernobyl-other-contaminated-zones/