US Chamber of Commerce backs the weakening of radiation safety standards
US Chamber of Commerce Nov 19 15
Re: Docket Nos. PRM-20-28, PRM-20-29, and PRM-20-30; NRC-2015-0057; Linear No-Threshold Model and Standards for Protection Against Radiation; Federal Register Vol.80, No.120 (Tuesday, June 23, 2015)
radiation hormesis is a phenomenon in which low doses of ionizing radiation can be beneficial, stimulating the activation of repair mechanisms and other adaptive responses that protect against adverse effects not activated in the absence of ionizing radiation…….
“….. Many of the Chamber’s members are adversely affected by the reliance by federal agencies on the “linear no-threshold” (LNT) model and the extremely conservative effect the model has on estimated risk. Moreover, the LNT model exaggerates the estimated benefits of excessively stringent regulatory standards. Given longstanding concerns about the suitability of the LNT model as a default for regulatory decision-making, the Chamber strongly supports the changes to application of the LNT model sought in the three petitions for rulemaking referenced above.
radiation hormesis is a phenomenon in which low doses of ionizing radiation can be beneficial, stimulating the activation of repair mechanisms and other adaptive responses that protect against adverse effects not activated in the absence of ionizing radiation…….Department of Energy (DOE) Low Dose Radiation Research Program In 1998, funding was appropriated to establish the Department of Energy’s Low Dose Radiation Research Program.16 The goal was to move radiation research into the 21st century with the new tools and methods now available. …….
Economic consequences of the LNT model Because the LNT model produces inflated estimates of cancer and non-cancer risk, decisionmakers are often misled into selecting unnecessarily costly and burdensome regulatory approaches that yield no greater safety than less-stringent alternatives.25 Government- owned facilities containing small amount of very low-level radioactive materials, for example, may not need to be addressed the same way that a facility with higher-level materials must be. Billions of dollars of taxpayer funds may be wasted to meet LNT-driven standards for managing low-lever radioactive materials. The LNT model’s continued unquestioning use in low-level radiation situations must be critically assessed and reevaluated, on at least a case by case basis……..
the Chamber urges the Nuclear Regulatory Commission to grant the three petitions for rulemaking referenced above and make the appropriate regulatory changes regarding application of the LNT model to low-level exposures to ionizing radiation. http://pbadupws.nrc.gov/docs/ML1532/ML15323A502.pdf
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Linear No Threshold model tested and found to be accurate:
Thanks so much, Abe. I missed this important new message from Goddards Jouranal