LAUSR

Dear Editors: I DID VERY much enjoy reading the article by Feinendegen and Cuttler (2018). Although they did present their facts correctly and succinctly, I would like to offer an alternative, if not supplemental, perspective on their work. They mentioned the fear from genetic changes at nominal doses but only addressed radiogenic carcinomas. A related topic of fear not evaluated is that of radiogenic mutations from a parent that are passed on to progeny. As far as this concerns Homo sapiens, the literature has shown no measured traits are observable (NRC 2006). That some animals have demonstrated weak tendencies to incur genetic mutations (Ryabokon and Goncharova 2006) suggests that if it could occur in humans, it would be above the lethal dose, explaining why it has not been seen in children of the atomic bomb survivors (Neel and Schull 1991). Given the levels of radiophobia in developed countries even at small dose levels (Myslobodsky 2001), it is worthwhile to point out on this topic that the literature demonstrates how carcinomas have been with us almost from the beginning of modern animal life insofar as they are found in dinosaur bones, indicating it is an ancient disease common to life on this planet (Capasso 2004; Dunn 2012; Vincent 2010). The authors pointed out the dangers from radiophobia but did not elucidate how this is such a drastic departure from their recognition of no medical effects being observed at low and nominal doses as there are clearly acutely severe psychosocial and psychosomatic effects. As an example, in stark contrast to both the World Health Organization (WHO) and United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR) findings that no measurable radiogenic medical effects are expected to the public from the entire Fukushima release (WHO 2013; UNSCEAR 2013, 2015), the evacuation of populations has alone resulted in over 2,000 deaths (Hayakawa 2016) in addition to the host of substantial documented radiophobic medical conditions such as increases in being overweight, hypertension, and diabetes (Hasegawa et al. 2016). In addition to these, the literature is clear that the psychosocial effects from radiophobia have resulted in substantial increases in suicides in populations exposed to small anthropogenic accidental doses (Rahu et al. 2015). The conclusion is stark and overwhelming that radiophobia is altogether lethal, having taken many thousands of victims already. In this sense, the promotion of radiophobia could verywell be unethical if not immoral. Given that discrimination of the facts in this case results literally in life or death for so many individuals, it is difficult to overstate its importance and hence is the basis for this letter. My comments above do not necessarily contradict the authors’ but rather are intended to highlight details not addressed in their work. Still, as a former as low as reasonably achievable (ALARA) program coordinator myself, I would like to offer another alternate perspective on the utility of the linear no-threshold (LNT) theory in the industry (only as far as ALARA is concerned). I have heard many in our industry criticize ALARA as being an outcome of LNT itself. This may be true in some sense, but the utility of a rigorous ALARA program should not be overlooked as we shed the LNT model for more empirical and accurate risk paradigms. It would be negligent not to monitor nuclear operations with at least the same rigor as any other industrial endeavor to implement continual improvement and quality control. A few representative indicators unique to a nuclear facility include worker dose, off-site releases, contamination events and their extent, etc. There are certainly many more indicators that could be trended to assess the operator’s ability to control radioactivity and so evaluate potential opportunities for improvement. In a very legitimate sense, this is really all an effective ALARA program is: a quality control tool when properly handled by a competent health physicist. Safety issues are, by definition, separate from ALARA (which would be addressed through the unreviewed safety question process) and so ALARA should not address safety, even in its current form. If LNT is updated with more accurate models, ALARA might change both its name and limits, but the process and workings should still be present. Thiswould serve tomaintain the highest level of quality in operations and throughput. Without this, radiological operations would literally be out of control in a statistical sense. The same considerations apply to facility free-release limits. The current regulatory limits assume that a member of the public can be exposed to multiple free-release vectors in any given year. Whether this is from transportation, medical patients, hospitals, nuclear facilities, well logging, or other industrial radiography operations, all such doses are cumulative. Increased limits would be appropriate, but even