The wheels are in motion for an official review of radiation protection regulations at the US Nuclear Regulatory Commission. Doctors who are radiation health specialists are challenging the NRC’s use of the linear, no-threshold (LNT) dose response model as the basis for those regulations and the associated direction to maintain radiation doses As Low As Reasonably Achievable.
On June 23, 2015, the NRC issued a request for comment on three petitions for rulemaking (PRM) that have been grouped together in a single docket – NRC-2015-0057 Linear No-Threshold Model and Standards for Protection Against Radiation; Notice of Docketing and Request for Comment. The petitioners include Dr. Carol Marcus, a Professor of Radiation Oncology, of Molecular and Medical Pharmacology (Nuclear Medicine), and of Radiological Sciences at the David Geffen School of Medicine at the University of California-Los Angeles; Mr. Mark L. Miller, a Certified Health Physicist; and Dr. Mohan Doss, Medical Physicist, Associate Professor, Diagnostic Imaging, Fox Chase Cancer Center on behalf of Scientists for Accurate Radiation Information (SARI).
Disclosure: I am a member of SARI and a signatory on Dr. Doss’s petition. Since he listed names alphabetically, mine is at the top of the list of signers.
The NRC docketed the petitions on February 20, 2015 (ML15051A503), February 27, 2015 (ML15057A349), and March 16, 2015 (ML15075A200), and assigned Docket Numbers. PRM-20-28, PRM-20-29, and PRM-20-30, respectively.
Here are some important instructions regarding comment submission from the regulations.gov comment web site:
Submit comments by September 8, 2015. Comments received after this date will be considered if it is practical to do so, but the NRC is able to assure consideration only for comments received on or before this date.
You may submit comments by any of the following methods (unless this document describes a different method for submitting comments on a specific subject):
- Federal Rulemaking Web site: Go to http://www.regulations.gov and search for Docket ID NRC-2015-0057. Address questions about NRC dockets to Carol Gallagher; telephone: 301-415-3463; email: Carol.Gallagher@nrc.gov. For technical questions contact the individual listed in the FOR FURTHER INFORMATION CONTACT section of this document.
- Email comments to: Rulemaking.Comments@nrc.gov. If you do not receive an automatic email reply confirming receipt, then contact us at 301-415-1677.
- Fax comments to: Secretary, U.S. Nuclear Regulatory Commission at 301-415-1101.
- Mail comments to: Secretary, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, ATTN: Rulemakings and Adjudications Staff.
- Hand deliver comments to: 11555 Rockville Pike, Rockville, Maryland 20852, between 7:30 a.m. and 4:15 p.m. (Eastern Time) Federal workdays; telephone: 301-415-1677.
Note: On the day this post was written, the person listed under FOR FURTHER INFORMATION was Solomon Sahle, Office of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission, Washington DC 20555-0001; telephone: 301-415-3781, email: Solomon.Sahle@nrc.gov. It is possible, but unlikely, for the contact person to change. End note.
I recommend reading each petition; they are full of important information. Here is a sample from the beginning of Dr. Marcus’s letter.
I am submitting this petition for rulemaking pursuant to 10 CFR Part 2.802. The petitioner requests that the NRC amend 10 CFR Part 20, Standards for Protection Against Radiation, based on new science and evidence that contradicts the Linear No-Threshold (LNT) hypothesis, a model that has served as the basis for radiation protection regulations. I will present scientific data as reported in study after study to justify that safety regulations and policies should no longer be derived from the LNT model in order to ensure these requirements are more risk-informed. This ultra-simplistic concept assumes that all radiation absorbed doses, no matter how small, have a finite probability of causing a fatal cancer. The lower the quantity of radiation absorbed dose, the lower the probability of cancer induction, but the probability is never zero, let alone negative (i.e. beneficial or hormetic). The rate of radiation delivery is irrelevant, and all absorbed doses are additive; this is demonstrably false as evidenced by the practices of radiation oncology and of radionuclide therapy. Use of the LNT assumption enables regulators to feel justified in ratcheting down permissible worker and public radiation levels, either through actual dose limits or use of the “as low as reasonably achievable” (ALARA) principle, giving the illusion that they are making everyone safer (and creating ever- increasing workload for themselves and their licensees). There has never been scientifically valid support for this LNT hypothesis since its use was recommended by the U.S. National Academy of Sciences Committee on Biological Effects of Atomic Radiation (BEAR I)/Genetics Panel in 1956. The costs of complying with these LNT-based regulations are enormous. Prof. Dr. Gunnar Walinder has summed it up: “The LNT is the greatest scientific scandal of the 20th century (1).”
On the other hand, there is a vast literature demonstrating no effects or protective effects at relatively low doses of radiation. The literature showing no effects supports a threshold concept, in which radiation below a certain level is of no concern because it causes no deleterious effects. The literature showing protective effects supports the concept of hormesis, in which low levels of potentially stressful agents, such as toxins, other chemicals, ionizing radiation, etc., protect against the deleterious effects that high levels of these stressors produce and result in beneficial effects (e.g. lower cancer rates). To properly characterize risk at low radiation doses, a range of health outcomes, including beneficial or zero health effects, must be acknowledged.
Please take the time to submit thoughtful comments and make sure that they are submitted before the deadline so that they will be considered during the NRC’s post-comment period deliberations.
Similar petitions need to be submitted to the Environmental Protection Agency (EPA), which is the regulatory body that has the assigned responsibility of determining radiation protection standards for the general public. It would be a terrible shame to have the excellent work that these petitions represent fail to make the necessary impact because of jurisdictional challenges.