To The NRC:
Yesterday the Nuclear Regulatory Commission (NRC) held a huge hearing (about 700 online attendees at its peak) regarding "rethinking" LNT ("Linear, No Threshold") and ALARA ("As Low As Reasonably Achievable"). The hearing was held because of Trump's Executive Order (EO) 14300 Section 5(b) directing the NRC to "reconsider" the LNT model.
Advocates for abandoning LNT and/or ALARA made a number of false and misleading statements, for example implying that people with opposing views think that every radioactive decay will cause cancer. LNT doesn't suggest that, and nobody thinks that way.
More importantly, the NRC's own presenter completely ignored several important aspects of the nuclear fuel cycle and concentrated entirely on the effluent from operating reactors when discussing the potential impacts of keeping, or not keeping, LNT.
Left out were all other pathways for radiation impacts: Mining, milling, processing, transporting, etc., as well as accidents, terrorism and managing/moving the waste... forever.
The inclusion of accidents, terrorism and caring for the nuclear waste for centuries (as most people can now see is virtually inevitable) or millennia (a far more reasonable expectation) is important when considering LNT because all LNT discussions at the meeting were regarding radiation above "background" levels (which, depending on who is using the term, may or may not include man-made radioactive debris from weapons testing and use, or from the thousands of nuclear spills, meltdowns, fires, unintentional (and intentional) releases, and accidents that have already occurred -- many small, but some very large (Chernobyl, Fukushima, Three Mile Island, Santa Susanna, Windscale, etc. Also, more than half a dozen nuclear subs (mostly Russian) have also been lost to the environment).
As several meeting attendees pointed out, the effects at extremely low levels are impossible to measure meaningfully, firstly because "background radiation levels" vary by an order of magnitude or more around the world, and people move, and life-time low-level exposures are extremely difficult to track.
Also because, as mentioned yesterday, about 40% of all Americans will get cancer at some time during their lifetime (I'm ahead of the curve on that score, having had two cancers, one a "solid" cancer (bladder cancer, removed surgically) and one a blood borne cancer (Mantle Cell Lymphoma, removed with chemotherapy).
None of the discussions yesterday considered the effect of "LNT" and "ALARA" on someone like me, who has had perhaps a dozen different highly radioactive medical treatments over the years.
The point is: At extremely low levels, around "background" (whatever that means), SO WHAT if Hormesis really is a thing! (Not that there are any serious indications that it is.) But for those so sure it is, let them take a "sunshine pill" of strontium (for their bones, I guess) every day if it makes them happy! There's certainly plenty of radioactive waste to spare.
Using "background levels" of radiation as the standard dosage, above which there might -- or might not --be harm might be appropriate for some people. But millions of us get far more radiation (at least at some point in our lives). People living near Chernobyl. People living near Hanford, Washington, or West Valley, New York, or Rocky Flats, Colorado, or downwind of the Nevada Test Site.
And people like me.
When we're NOT talking about "background levels" of radiation, it's a GIVEN that higher radiation doses increase the risk of cancer. This is indisputable, and as an example, my personal risk factors are already increased by the radiation treatments I have received, from tooth x-rays (well known to be less-than-harmless) to CT-SCANS and PET scans and whatever else the doctors ordered. But my other choice was basically premature death -- and cavities.
When it comes to nuclear power, there are many other choices. There are better ways to generate electricity. For instance, a distributed system such as rooftop solar is far more resilient and NEVER poisons the earth with a meltdown.
During yesterday's meeting, LNT and ALARA were only considered regarding the amount of nuclear material that can be released from operating reactors, NOT from the clear and present danger ANY increase in radiation causes to individuals like myself, which includes tens of millions of Americans, if not hundreds of millions. And also not considered were additional radioactive doses from the lifecycle of the nuclear material, the potential for catastrophic accidents or terrorism, acts of Mother Nature, etc..
As noted by scientist Mary Olson during yesterday's NRC hearing, radiation protection limits are based on "reference man" who is a theoretically constructed healthy adult male.
Not a woman. Not an infant. Certainly not a fetus. And not a cancer survivor.
Also excluded from any discussion by the NRC or any pro-nuclear speakers during the hearing was the FACT that nuclear "waste" is PRODUCED by nuclear power plants: That is, uranium straight out of the ground is not nearly as dangerous as the witch's brew of fission and activation products created by nuclear bombs and nuclear reactors. Besides, if left in the ground, uranium tends to stay there. After a meltdown, it (and its fission and activation products) go everywhere.
In a word, the main product -- the main output -- of the nuclear industry is nuclear waste, NOT electricity -- that's just a fleeting byproduct.
This is, in fact, why commercial nuclear reactors were constructed in the first place: To produce plutonium for bombs, which instead became nuclear waste along with all the fission and other activation products produced along with the plutonium.
Some of the most common fission products created by nuclear reactors (or nuclear bombs), such as strontium, cesium and tritium, mimic useful atoms in the body until the moment they decay. A rough estimate is that, pound for pound, used reactor fuel is about a million times more hazardous than "fresh" reactor fuel that has never been in a nuclear reactor, never undergone criticality.
So it's fair to say that the main product produced by nuclear reactors is highly toxic nuclear waste.
After 80 years of splitting atoms for one reason or another, there is still NO solution to the waste problem -- other than the proposal to truck it into a tunnel on stolen Indian land somewhere. Yucca Mountain was assuredly that place for nearly a quarter of a century before it was abandoned for mostly geological and engineering reasons, along with enormous political opposition -- opposition ALL such places will get if America EVER gets close to choosing a destiny for its growing, glowing nuclear waste pile.
Producing nuclear waste is a crime against all future living things. Plutonium and many of the fission products of nuclear reactors either do not exist in nature or are so extremely rare as to make even the rarest of the so-called "rare earth" elements seem positively plentiful in comparison. Many of the man-made radioactive products do not behave chemically anything like "background radiation" (external vs. internal or even bone-seeking, for example).
Another problem with simply looking at LNT as it pertains to the damage it causes versus any supposed benefit it might have for society is that the person harmed is rarely the one who benefits -- which is unfair. It might be someone a thousand years hence who is harmed by the radioactive waste produced today, which was used to light a light for one fleeting moment of time.
Nuclear-generated electricity has never been anything close to "too cheap to meter" and instead is, was and always will be the most expensive form of energy ever devised -- but much of the payment -- in cancer, leukemia, and other illnesses -- is deferred to others, later in time and place.
Those harmed will not be able to identify the assailant who harmed them, which will be us -- this generation -- but we will all be long dead many generations ago. The poisons we produced in nuclear reactors today will still be harming others, generations from now.
Renewables can easily replace nuclear power and are cheaper, cleaner, safer, and pose no threat from terrorism or anything else. Small accidents, certainly. Those can happen at a wind farm or anywhere else. But no other energy source besides nuclear can render "an area the size of Pennsylvania" uninhabitable from ONE SINGLE ACCIDENT. Only nuclear can do that. And nuclear WILL do that, again and again, until we shut them all down.
So: LNT or not (and even if Hormesis is a thing) there is no doubt that large doses of radiation from accidents are inevitable -- along with smaller doses to large populations and tiny doses to huge populations of people and other living things.
LNT and ALARA (or Hormesis, for that matter) never has accounted for those inevitable accidents. Japan thought it couldn't happen there. Russia thought it couldn't happen there. England thought it couldn't happen there. And here in America we keep beating our heads against the wall, pretending it won't happen AGAIN here.
It will.
LNT is only a statistical model -- an approximation. Flaws -- real flaws -- in its basic assumptions can appear to make other approximations make sense if you pick and choose your data carefully (that is, poorly, or selectively) enough. For example, nuclear plant workers are generally well-paid, have good health care, and retire early compared to many other people. They are an unusually healthy cohort. Their higher allowable radiation doses are rarely exceeded or even approached, so there is essentially no reliable data from them. And there is enormous incentive to hide data by the corporations involved.
The most reliable data available (such as it is: More studies still could be done and have been proposed) indicates that LNT is a good approximation. It also indicates that Hormesis is a dream of the nuclear industry, and that the current standards should be tightened, not loosened in any way. Too many inevitable events are ignored.
Ace Hoffman, Carlsbad, California USA
The NRC will continue to take WRITTEN comments (no deadline, but ASAP is better!) at these emails:
ed.Miller [at] nrc.gov AND david.Garmon-Candelaria [at] nrc.gov
Note added July 26, 2025:
Daniel Hirsch, Founder and President of the Committee to Bridge the Gap, has passed away. His presentation at the same hearing that my comments in this blog respond to was brilliant, and I've posted a brief obituary and images of his pdf in the next blog post here:
https://acehoffman.blogspot.com/2025/07/dan-hirsch-has-passed-away-his.html
Contact information for the author of this newsletter:
Ace Hoffman
Carlsbad, California USA
Author, The Code Killers:
An Expose of the Nuclear Industry
Free download: acehoffman.org
Blog: acehoffman.blogspot.com
YouTube: youtube.com/user/AceHoffman
Email: ace [at] acehoffman.org
Founder & Owner, The Animated Software Company
