July 25, 2016


To:  EPA

RE: PAG Letter on Move to Increase Radioactivity in Drinking Water

      Environmental Protection Agency (EPA) Notice: Draft Protective Action Guide for Drinking Water after a Radiological Incident

From:  Dr.  Anne Lee Tomlinson Maziar, Longmont, Colorado, http://envinfo.org/



To Whom It May Concern:

I strongly oppose the increase of already too high allowable amounts of radiation in the drinking water or any other water.  Everyone in the US is already exposed to way too much radiation from past nuclear accidents, nuclear weapons production, nuclear weapons testing, nuclear accidents, nuclear waste disposal sites and all the accidents in those locations, nuclear experiments such as linear accelerators, cell phone towers, cell phones, high electrical power lines, radar, depleted uranium all over the place, and ionospheric heaters such as HAARP.  The ongoing accident at Fukushima is killing the plankton and the entire fuel cycle of nuclear energy and other nuclear technology is causing climate heating and is causing more and more methane to melt and enter the atmosphere.   The present China Syndrome at Fukushima has also contributed to depletion of ozone in the upper atmosphere and allowing more and more harmful UV rays to reach people on earth.  

The radiation drinking water standards MUST NOT be increased.  To increase the levels will cause great loss of life and even further dumbing down of human IQ.(1)(2)(3)(4)(5)(6)(7)  Every nuclear energy plant releases harmful radiation into the atmosphere, land, and water.  This is especially true when nuclear fuel is periodically changed and the reactor cap is taken off to allow the old fuel to be removed and the new fuel loaded into the core.  All reactors much be shut down, but especially the old reactors.  Increasing the radiation levels allowed during a nuclear accident will only encourage reactor owners to falsify safety tests and allow extremely dangerous old reactors to keep running because the reactor owners would not be so responsible for allowing much higher radiation levels in drinking water during a nuclear accident.  If there are much higher levels of radiation in drinking water, there are sure to be extreme exposures to the air and land as well.  Nuclear power plants are only built to last 20 years.  This is an extremely expensive throwaway.  But, of course, all the nuclear waste can’t be thrown away, but will plague future generations, if there are even any future generations left after all the irresponsible people have even allowed nuclear technology to exist.


I will now discuss 3 issues.  A)  There is no such thing as radiation hormesis, B) Internal exposure to radiation (which includes drinking water) is much, much more lethal than exposure to external radiation, C)  the extremely huge variation in the specific activity and lethality of various radionuclides and their biological pathway and accumulation in nature and in humans.


A)  There is no such thing as radiation hormesis

Radiation has many different harmful effects.  The effects happen at the atomic level.  One atom of plutonium destroys  one cell from which cancer, for example, grows.  One tenth of one millionth of a gram of plutonium inhaled is lethal.

“…Here are just some of the Dangers of low-dose radiation and increasing
exposures could increase these Dangers

• Cancers
• Cell damage
• Gene damage
• DNA damage, single-strand breaks, double-strand breaks, unwinding
• Damage to the mitochondrial function and mitochondrial DNA
• DNA lesions
• DNA genomic instability
• Leukemia
• Cell mutations
• Gene mutations
• Chromosomal aberrations
• Heart disease, diabetes, circulatory disorders, neurological damage
• Stochastic effects
• Somatic effects
• Bystander effects
Transgenerational effects
• Tissue-reaction
• Cataracts
• Tumors
• Liquid Peroxidation
• Cell Cycle Arrest
• Apoptosis
Aplastic Anemia and Myelodysplastic Syndromes

“Please remember that there is so much damage caused by radiation, and how varied each individual's response to radiation exposure can be. This is why the best radiation-protection-model should be to expose people and all life to as little radiation as possible….”


Many studies and many researchers have explained why there is no nuclear radiation hormesis:  Radiologist Herbert Abrams (8)(9), https://miningawareness.wordpress (10), Dr. Helen Caldicott (11),  Dr. John Gofman (12)(15)(25)(26)(28),  Mitchel Cohen (13), The National Council on Radiation Protection and The Department of Health and Human Services (14), Kai Rothkamm and Markus Löbrich (16),  WashingtonsBlog (17), Barcinski (18), K. Maruyama (19),  Chris Busby (20)(24)(29), Jay M. Gould (21), Anders P. Møller and Timothy A. Mousseau (22), Yu. I. Bandazhevsky (23),  Richard R. Monson, the panel chairman and a professor of epidemiology at Harvard's School of Public Health (27), and many, many other expert researchers.

Dr. John Gofman:

“It is not a question any more: radiation produces cancer, and the evidence is good all the way down to the lowest doses."


“Health Effects of Prenatal Radiation Exposure.” by Pamela M. Williams:

“Ionizing radiation includes particles and electromagnetic radiation (e.g., gamma rays, x-rays). In utero exposure to ionizing radiation can be teratogenic, carcinogenic, or mutagenic. The effects are directly related to the level of exposure and stage of fetal development….

“The risk of cancer is increased regardless of the dose….”



The following are graphs which show that there is no threshold where radiation is harmless or beneficial:  http://envinfo.org/index_files/image006.gif

image006Section A,



Fig. 14_E

Appendix I: Dr. John Gofman, Radiation-Induced Cancer from Low-Dose Exposure









Figure 14-F


These two graphs are from:







Another figure:  http://envinfo.org/index_files/image009.png




Section A, Appendix I:  Aaron Datesman, A Tiny Revolution.




Another figure:  http://envinfo.org/index_files/image012.jpg




Section A, Appendix III:   Prof. Chris Busby: Nuclear Radiation, Kierkegaard, And The Philosophy Of Denial




Another graph can be found here:

20 Years After the Chernobyl Accident: Past, Present and Future,  edited by E. B. Burlakova,, p. 71.







B) Internal exposure to radiation (which includes drinking water) is much, much more lethal than exposure to external radiation.

“Aspects of DNA Damage from Internal Radionuclides,” by Chris Busby:


“…The curent radiation risk model is insecure for internal radionuclide effects.  Massive evidence exists from epidemiology and published studies of the effects of internal radionuclide exposures that the effects of location, chemical binding or affinity, temporal decay patterns and transmutation of internal radionuclides can have much greater or lethal effects on cells than are predicted by the absorbed dose model.  These data have been published since the 1950s but ignored for the purpose of radioprotection.  Many critical research issues should have been pursued but have not been.  It is recommended that those issues and studies highlighted in this contribution are seen as a priority.”


See also Christ Busby (30) and Dr. Catherine Euler (31).


 C)  the extremely huge variation in the specific activity and lethality of various radionuclides and their biological pathway and accumulation in nature and in humans.

Discussing the many factors that determine the lethality of a radionuclide requires information from physics, chemistry, and biology (32)(33)(43).  In physics, for example, there is a huge variation in specific activities of radionuclides.   Is the radionuclide natural or artificial (man-made)?(38)   Is its radioactivity alpha, beta, or gamma rays.   There are a large number of biological processes which determine how lethal a radionuclide in an individual or how fast the person will die.(40)(42)  Radiatiion is bioaccumulative and acts in synergy with other toxins such that altogether the whole is greater than the sum of the parts.  The internal pathway of a particular radionuclde will determine which cells of which organs or bones, etc., the radionuclide will damage.  How long the radionuclide stays in the body as well as what happens when that radionuclide takes up the space for a nutrient needed for life.

For example, Plutonium-241 has a specific activity of 1.1E2 compared to the specific activity of Potassium-40 (8.54E-10) (34).  In addition, Plutonium-241 emits alpha-particles and never leaves the body, following the pathway of iron (35).   Potassium-40 has a biological half-life of 30 days.  A single particle of Plutonium-241 which weighs one tenth of a millionth of a gram is lethal for everyone.(41)   Most actinides (artificial radionuclides) have many times the specific activity  of Plutonium-241.  Bismuth-212’s specific activity is 1.5E7.   Plutonium-241 is 192 billion times more radioactive than Potassium-40.  Steven Starr says about Cesium-137 and Strontium-90:

“…Long-lived radionuclides such as Cesium-137 are something new to us as a species. They did not exist on Earth in any appreciable quantities during the entire evolution of complex life. Although they are invisible to our senses they are millions of times more poisonous than most of the common poisons we are familiar with. They cause cancer, leukemia, genetic mutations, birth defects, malformations, and abortions at concentrations almost below human recognition and comprehension. They are lethal at the atomic or molecular level.

“They emit radiation, invisible forms of matter and energy that we might compare to fire, because radiation burns and destroys human tissue. But unlike the fire of fossil fuels, the nuclear fire that issues forth from radioactive elements cannot be extinguished. It is not a fire that can be scattered or suffocated because it burns at the atomic level—it comes from the disintegration of single atoms….

“Highly-radioactive fission products such as Cesium-137 and Strontium-90 emit 10 to 20 million times more radiation per unit volume than does Potassium-40. So which one of these would you rather have in your bananas?...

“2 grams of cesium-137 has more radioactivity than 20 tons of Potassium-40…” (36)

For pathways of cesium, see (44) and (45).


Birth defects are also varied by different biological processes.  The birth defect of the cyclop child in Chris Busby’s video was caused by an enriched uranium nanoparticle internal exposure in the mother traveling through her body through the lymphatic system and the placenta to the fetus late in the pregnancy causing a teratogenic birth defect.  (37)(38)

Here is a photo of a baby whose life has been destroyed by nuclear radiation:  http://envinfo.org/index_files/image010.jpg




This photo is from:

On human health on exposure to radiation


Here is another photo of a deformed baby:  http://envinfo.org/index_files/image003.jpg  



1This photo is from

This photo is from the website:

Iraqi Birth Defects Are Much Worse Than Hiroshima





Another photo:  http://envinfo.org/index_files/image005.jpg





This photo is from the website:

American Tragedy - Part 3 - US Kills Soldiers, Civilians and Veterans Slowly Through Depleted Uranium Contamination!



Please cry for all those whose lives have been and who are currently destroyed by nuclear radiation and LOWER the amount of radiation allowed in drinking water both before and after a nuclear emergency.  Protect our land, water, and air.  It is all we have.  And we must leave the world a better place than we found for future generations.  Say NO to all increases.




Dr. Anne Lee Tomlinson Maziar, http://envinfo.org/

(1)  “…IQ DECLINE IN EUROPE - HUMAN COST OF DEPLETED URANIUM POISON DUST FROM WARS IN IRAQ, YUGOSLAVIA, AND AFGHAN:             In Ukraine few people are aware that nuclear weapons are not just indiscriminate killers (WMD) of the targeted ethnic Russians, but also all Ukrainians, non-citizens, Christians, Jews, Muslims, and all living things on and off the battlefield throughout Ukraine and across all borders.  Radiation respects no borders [FIG. 5(a)], no socio-economic class, and no religion.  It is an equal opportunity killer.  For example, [FIG. 5(b)] presents UK govt. data on uranium levels detected in the British atmosphere from 1998-2003, from depleted uranium, 4th generation nuclear weapons, and other lethal weapons used by US and UK forces in Iraq and Afghanistan.

P FIG. 5(a): RADIATION-CAUSED DECLINE IN IQ BY COUNTRY: FROM BOMB TESTING, AND IN NUCLEAR CONTAMINATED WAR ZONES: Bomb testing contamination lowered IQ in Ireland and Portugal. NATO attacks on Yugoslavia with DU caused the greatest decline in IQ in areas of heaviest fighting (darkest red areas Bosnia and Herzegovina, Montenegro, and Albania). Wars in Iraq and Afghanistan contaminated the eastern Mediterranean and US [FIG. 8]. And Chernobyl had a large effect on Eastern Europe. The U.S. has the highest rate of mental illness in the world (26% of the population) due to 1300 nuclear bomb tests the US govt. conducted in Nevada [FIG. 13].

Source: MAP: http://www.theapricity.com/forum/showthread.php?70485-Interesting-Map-about-Europe-s-IQ;  “Intelligence: A Unifying Construct for the Social Sciences, R. Lynn and T. Vanhanen (2012).  https://lesacreduprintemps19.files.wordpress.com/2012/08/intelligence-a-unifying-construct-for-the-social-sciences-richard-lynn-and-tatu-vanhanen.pdf 




(2)  Chernobyl's Subclinical Legacy: Prenatal Exposure to Radioactive Fallout and School Outcomes in Sweden, by Douglas Almond, Lena Edlund, Mårten Palme

NBER Working Paper No. 13347 (August 2007)
Japanese atomic bomb survivors irradiated 8-25 weeks after ovulation subsequently suffered reduced IQ [Otake and Schull, 1998]. Whether these findings generalize to low doses (less than 10 mGy) has not been established. This paper exploits the natural experiment generated by the Chernobyl nuclear accident in April 1986, which caused a spike in radiation levels in Sweden. In a comprehensive data set of 562,637 Swedes born 1983-1988, we find that the cohort in utero during the Chernobyl accident had worse school outcomes than adjacent birth cohorts, and this deterioration was largest for those exposed approximately 8-25 weeks post conception. Moreover, we find larger damage among students born in regions that received more fallout: students from the eight most affected municipalities were 3.6 percentage points less likely to qualify to high school as a result of the fallout. Our findings suggest that fetal exposure to ionizing radiation damages cognitive ability at radiation levels previously considered safe.”


(3)  “…I think that it is by now beyond doubt that ionizing radiations at all levels involve serious risks to health, causing increased chances of cancers, leukemia and genetic effects. There is no threshold: a little, however little, causes some increased risk, and more causes more risk. There is no level that fails to be potentially harmful. From that point of view the existence of an official so-called "permissible level" is misleading. A "permissible level" of radiation only has meaning in cost benefit accounting; and that would mean more if the costs and benefits involved the same parties. Unfortunately they usually do not: one group -- workers, general public -- commonly bear the costs; and another, quite different group -- ownership, management, government -- shares the benefits. Having to deal with a lot of official talk about "permissible levels" of radiation at the time of Three Mile Island, I took to saying, "Every dose is an overdose." I believe that to be true as a statement, not necessarily of overt effect, but of risk.”

George Wald, “Introduction,” Secret Fallout.


(4)  “…By 1953, it was already known that many of the radioactive elements (called isotopes) created by an atomic explosion, once they entered the atmosphere in the form of tiny fallout particles, would contaminate food, water, and air and thus find their way into the human body. What was not widely known, however, was the extent to which these isotopes became concentrated in various body organs. Inside the body, they behaved just like their nonradioactive natural counterparts. The isotope strontium, for instance, which is similar to calcium, settled in bones and teeth. Radioactive iodine behaved like regular iodine, seeking out and concentrating in the thyroid gland, an organ which is vital in regulating the growth and functioning of the human body.

“It was in the case of iodine that some of the most alarming discoveries were made. In the early 1950s researchers found that iodine became concentrated in the milk of cows that grazed on pasture contaminated with fallout. When people drank the milk, the iodine began building up rapidly in their thyroid glands. Since the thyroid gland is small in size, the concentration was very heavy. Measurements revealed that in any given situation the radiation dose to the adult thyroid would be as much as a hundred times the external dose from the fallout in the outside environment. But far more important were the results of extensive studies conducted at the University of Michigan and published in 1960. These showed that the radiation dose to the thyroids of unborn children and infants was ten to one hundred times higher than that to the adult because of the greater concentration in the smaller thyroids. This discovery held serious implications for the health of the children of Troy. It meant that the doses to their thyroids might have been as much as a hundred to a thousand times higher than those estimated by Dr. Clark and the AEC scientists, who had only considered the overall dose from the fallout in the external environment.“  Sternglass, Ernst.  Secret Fallout.


(5)  “A researcher says a drop in Scholastic Aptitude Test scores among teens in seven states is attributatlb to radioactive fallout from nuclear tests that entered their milk when they were infants.

“Ernest Sternglass, professor of radiological physics at the University of Pittsburgh, Monday said SAT scores had dropped as muck as 18 percent in Utah, North and South Dakota, Oklahoma, Wyoming, Colorado and Iowa….”

(6)  Fallout and SAT Scores: Evidence for Cognitive Damage during Early Infancy
Ernest J. Sternglass and Steven Bell
The Phi Delta Kappan
Vol. 64, No. 8 (Apr., 1983), pp. 539-545
Published by: Phi Delta Kappa International
Stable URL: http://www.jstor.org/stable/20386800

(7)  This Is Only a Test? Long-Run Impacts of Prenatal Exposure to Radioactive Fallout, by Sandra E. Blac.

8)  “…Even low exposure to X-rays, gamma rays increases cancer risk, study finds
Radiologist Herbert Abrams was among 16 international experts on the National Research Council committee…”

(9)   No Safe Dose:  Any radiation exposure, no matter how little, can cause cancer”

“There is no safe level of exposure to radiation , only legally ‘allowable’ or ‘permissible’ doses.  Every federal agency that regulates industrial releases and medical uses of ionizing radiation warns that any and all exposure to external or

internal radiation doses, no matter how small, increases one’s risk of cancer….


“As committee member Herbert L. Abrams of Harvard said, ‘There appears to be no threshold below which exposure can be viewed as harmless.’  Current evidence suggests that any exposure to radiation poses some risk, i.e. there is no level below which we can say an exposure poses no risk.’

National Council on Radiation Protection


“... ‘every increment of radiation exposure produces an incremental increase in the

risk of cancer’….


U.S. Nuclear Regulatory Commission


“’[T]he radiation protection community conservatively assumes that any amount of

radiation may pose some risk for causing cancer and hereditary effect, and that the

risk is higher for higher radiation exposures. A linear no-threshold dose-response

relationship is used to describe the relationship between radiation dose a

nd the occurrence of cancer. ... any increase in dose, no matter how small, results in an

incremental increase in risk.’…”


10)  Nuclear Worker Study Affirms that Low Doses of Radiation are Deadly: Increased Cancer Risk Much Worse Than Previously Believed
“…A former USNRC Counsel has commented that this 100 mSv proposal will make the US the laughing-stock of the world. As the 100 mSv would mean extermination of the US population …
“The new study appears to show that the risk is much, much higher, as high as 10%! After 10 years of 100 mSv this would be 100%!…
“Most nuclear workers were men, whereas radiation risk for non-leukemia cancers is higher for women. Children and the unborn are at higher risk, as well. …
“Furthermore, the nuclear effluent “standard” excludes consideration of accumulation in the environment and within the body!,,,
“This ignores build up in the environment; it excludes greater impacts on women and children; it excludes internal doses. This is excess cancer deaths and not excess cancer rates. Excess cancer rates (incidence) will be higher – probably double.]…
“There is no threshold and no safe dose. Even by removing outliers showing more risk (e.g. Canada), and apparently keeping ones which show less risk, the proof remains overwhelming – there is no safe dose of ionizing radiation and increase dose is increased risk.]…
“It is about cancer and not about other diseases induced by radiation.
“A BELIEF IN HORMESIS (aka some radiation is good for you) IS WISHFUL THINKING. HORMESIS IS DEADLY BS. …”


(11)   “…All radiation is dangerous, whether it is natural or man-made. There is no “safe” amount of radioactive material or radiation. ‘The U.S. Department of Energy has testified that there is no level of radiation that is so low that it is without health risks’, reports Jacqueline Cabasso, the Executive Director of the Western States Legal Foundation. (full article)
“It takes only one radioactive atom, one cell, and one gene to initiate the cancer or cell mutation cycle.” (Helen Caldicott, Nuclear madness: what you can do). Hence, any exposure increases risk of cancer or genetic damage….”

(12)   “…The call to permit higher levels of radiation exposure only makes sense if there is unmistakable proof that a threshold dose must exist for the onset of irreversible radiation injury. This means that the damage produced by doses below this threshold are flawlessly repaired. One hidden assumption in this conjecture is that all people in the population have equivalent immune systems and that there is not a range in immune response between people. If such a range is admitted, then radiation protection standards must address the most vulnerable among the population or the value judgment must be made explicit that these people should be put at heightened risk of radiation induced illness so that the rest of the population can benefit. But there is a deeper problem with the conjecture of perfect repair. Evidence exists that the immune system makes mistakes when repairing DNA lesions. In chapter 18 of his book Radiation-Induced Cancer from Low-Dose Exposure, Gofman presents a powerful argument for why irreversible genetic damage, and thus cancer induction, can occur at even the lowest levels of exposure. His argument is based on the fact that the cellular mechanisms for repairing carcinogenic injuries do not operate flawlessly. Thus, “repair” is at the heart of the threshold issue:…

 “’The radiation-induced cancers arising from the unrepaired lesions at low doses do not wear a little flag identifying them as any different from cancers induced by higher doses of radiation, or induced by causes entirely unrelated to radiation. Therefore, threshold proponents cannot argue that the cancers arising from the lowest conceivable doses of radiation will somehow be eliminated by the immune system or any other bodily defenses against cancer. Such an argument would require the elimination of cancer in general by such defenses. Instead, we observe that cancer is a major killer (roughly 15-20% of many populations). So the proposition would lead to a non-credible consequence, and must be rejected. This means that repair is the key’ {6}.

“Gofman’s analysis proceeds by first reviewing nine reputable low-dose studies: the Nova Scotia Fluoroscopy Study, the Israeli Scalp-Irradiation Study, the Massachusetts Fluoroscopy study, the Canadian Fluoroscopy Study, the Stewart In-Utero Series, the MacMahon In-Utero Series, the British Luminizer Study, the Harvey Twins In-Utero Series, and the Israeli Breast-Cancer in Scalp-Irradiation Study. These studies involved a range of exposures from 9.0 rads down to 0.1 rad which Gofman translates into 12 tracks per nucleus per exposure down to 0.29 tracks per nucleus.  His argument is that if flawless repair exists at some threshold dose, every carcinogenic lesion will be successfully undone below that dose and no excess cancers will be induced. However, in every study an excess of cancers was in evidence. Gofman summarizes the conclusion of this line of reasoning as follows:

“’1. One primary ionization track is the least possible disturbance which can occur at the cellular level from ionizing radiation. Without a track, there is no dose at all.
2. Every primary ionization track has a chance of inducing cancer by inducing carcinogenic injuries; it needs no help from any other track.
3. This means that there is no conceivable dose or dose-rate which can be safe, unless (A) the repair system always successfully undoes every carcinogenic lesion, when the dose or dose-rate is sufficiently low, or (B) every failure of the repair system, at low doses, is always successfully eliminated by some post-repair defense system.
4. Human epidemiological evidence shows that the repair system for radiation-induced carcinogenic lesions has a failure rate even under minimal strain.
5. Observation and logic show that the post-repair defense systems (for instance, the immune system) cannot possibly be perfect with respect to providing a safe dose or dose-rate of ionizing radiation. 

“’It follows that there is no safe dose or dose-rate of ionizing radiation, with respect to induction of human cancer. The risk is related to dose, right down to zero dose..’…”


“[6] Gofman J.W. Radiation-Induced Cancer from Low-Dose Exposure: An Independent Analysis. San Francisco: Committee for Nuclear Responsibility; 1990. http://www.ratical.org/radiation/CNR/RIC.

Dr. John Gofman, CHAPTER 15
Radiation Risk by Age and Sex, from the Cancer-Rate Ratio Method

March 12, 2011

“…This minute amount – one trillionth of a Curie – is much less than the present reporting limit used by the EPA of 15 picocuries per liter of milk – even though, as we have shown, such small amounts, far below the government’s reporting requirements, have drastic health ramifications. In fact, concentrations of one to 10 picocuries per liter of milk occur routinely during normal operation of commercial nuclear reactors under existing radiation standards. It therefore appears that the existing standards for allowable radiation – based on observing the effects of short exposures to high doses of external X-rays and gamma rays that occur in medical uses and the direct flash of bomb-radiation – have vastly underestimated the risk of low-level, chronic exposures. [See Figure 7]

“Figure 7. Dose-response curve: Percent increase in mortality as a function of Iodine-131 levels.
Thus, the rapid rise of serious biological effects at very small doses followed by a levelling-off at higher doses explains the present underestimate of low-dose effects, which are based on a linear extrapolation from studies done at high doses. The new studies following Chernobyl and Three Mile Island not only point to the dangers from nuclear accidents but explain the unexpectedly large increases of infant and total mortality rates in areas near nuclear reactors observed in recent years.

 “These results imply that the effects of releases of radioactivity into the environment are thousands of times more serious than presently calculated on the basis of cancer risk to adults from short external X-rays and gamma radiation exposures….”

(14)   Radiation Is a Carcinogen: Any Exposure Can Cause Cancer”

“There is no safe level of exposure to ionizing radiation, only legally "allowable" doses. Types of ionizing radiation include gamma rays, beta and alpha particles, and X-rays emitted by radioactive elements — like the iodine-131, cesium-137, strontium-90 and even plutonium-239 — that have been spewed into the air and the sea in huge quantities by the triple reactor meltdowns that began in Japan last year, and that are dispersed to the air, water and to dump sites in smaller amounts by the everyday operation of nuclear power and medicine.
“Legally permitted releases of radiation — from landfills, power reactors, research reactors, production reactors and accidents — increase the so-called "background" level of radiation to which the public is exposed. This is allowed in spite of the fact that every federal agency that regulates commercial or industrial releases and medical uses of radiation warns that any and all exposure to either external or internal doses, no matter how small, increases one's risk of cancer. 
The National Council on Radiation Protection says, "every increment of radiation exposure produces an incremental increase in the risk of cancer."

“The Department of Health and Human Services warns that ‘Ionizing radiation is invisible, high-frequency radiation that can damage the DNA or genes inside the body….

Some patients who receive radiation to treat cancer or other conditions may be at increased cancer risk.’…"




(15)  What Is Factually Wrong with This Belief: ‘Harm from Low-Dose Radiation Is Just Hypothetical — Not Proven’”, by  John W. Gofman, M.D., Ph.D.
Fall 1995

“…c. The menace to health involves the genetic damage which is unrepaired, unrepairable, or misrepaired. The "troublesome trio."

“d. When the damage is complex — for example, when the opposite strands of the double helix have been broken — pieces of the DNA double-helix sometimes end up in the wrong place, or become permanently lost. These failures of repair are not in dispute. …

“i. The explanation for residual, post-repair damage is not a lack of repair-capacity or time, but rather an inherent inability of the repair-system to fix certain complex injuries to genetic molecules….

“o…In Gofman 1990, we developed the method and the evidence in detail. Full presentation takes 70 pages [http://www.ratical.org/radiation/CNR/RIC/contentsF.html#section5]
— not suitable for a journal. We wanted to know if the threshold issue, for ionizing radiation, could be settled. Our analysis proves, by any reasonable standard of scientific proof, that there is no safe dose or dose-rate of ionizing radiation.“ f. Ionizing radiation has demonstrated beyond any doubt its ability to break both strands of the DNA double helix at the same time. This ability has made it "famous" among toxic agents as a chromosome-breaker. (If only one DNA strand breaks, the other strand holds the chromosome together.)…”

(16)   Evidence for a lack of DNA double-strand break repair in human cells exposed to very low x-ray doses,” Kai Rothkamm and Markus Löbrich*
Proceedings of the National Academy of Sciences of the United States of America
PNAS, vol. 100 no. 9 (2002) 5057–5062.


(17)  Low-Level Doses of Radiation Can Cause Big Problems

(18)   Barcinski 1975.
M.A. Barcinski et al, "Cytogenetic Investigation in a Brazilian Population Living in an Area of High Natural Radioactivity," Amer. J. of Human Genetics 27: 02-806. 1975.

(19)  Maruyama 1976.
K. Maruyama et al, "Down's Syndrome and Related Abnormalities in an Area of High Background Radiation in Coastal Kerala [India]," Nature 262: 60-61. 1976.

(20)  BNES, 2002
High Risks at Low Doses
Chris Busby, Green Audit, Aberystwyth, UK

(21)  Deadly Deceit: Low-Level Radiation High-Level Cover-Up Paperback – April, 1991
by Jay M. Gould (Author), Benjamin A. Goldman (Author)

(22 )  Anders P. Møller, Timothy A. Mousseau. The effects of natural variation in background radioactivity on humans, animals and other organisms. Biological Reviews, 2012; DOI: 10.1111/j.1469-185X.2012.00249.x

Cited by::

 (23)  Radioactive Cesium and the Heart: Pathophysiological Aspects, by Yu. I. Bandazhevsky

(24) Christopher Busby (2013). Aspects of DNA Damage from Internal Radionuclides, New Research Directions in DNA Repair, Prof . Clark Chen (Ed.), ISBN: 978-953-51-1114-6, inTech, DOI: 0.5772/53942. Available from: http://www.intechopen.com/books/new-research-directions-in-dna-repair/aspects-of-dna-damage-from-internal-radionuclides

(25)  Radiation-Induced Cancer From Low-Dose Exposure
John W. Gofman, M.D., Ph.D. 1990.

(26)  Dr. John Gofman, A Nuclear Researcher
Who Refuses To Lie About Radiation Dangers
“…In 1970 they were concerned that there was no threshold level below which doses of ionizing radiation to the human body were safe. By 1990 Dr. Gofman had proved this beyond reasonable doubt. In other words, there is no safe dose. Even one track of ionizing radiation passing through the chromosomes in a cell's nucleus can cause damage, leading to cancer, leukemia or genetic defects.
“Gofman and Tamplin concluded that the 'permissible' extra dose from proposed nuclear power plants in the United States, if reached, would cause approximately 32,000 extra cases of fatal cancer each year. (Subsequent evidence indicates that this estimate is too low.) Though they had not opposed nuclear power at the beginning of the research, they now proposed a five year moratorium in constructing any new plants to allow for public debate and some serious thinking.
“The AEC regarded these findings as heretical: such results would jeopardize the nuclear industry. Unlike some scientists, who, to protect their careers and programs, compromised their professional integrity, Gofman refused to dismiss his research results. In 1972 the AEC stopped his funding and the research project was ended. He returned to his original office at the University of California at Berkeley and to research work on cancer and chromosomes. He also took time to assist in lawsuits; for example, he was a lead witness in the Karen Silkwood case and in the trial of the Downwinders in Utah in 1982-84 .
“He became increasingly unhappy that what he did not do on the health effects of radiation did not get done. Only a small coterie was doing research, Rosalie Bertell, Ernest Sternglass, Alice Stewart, and all had difficulty getting funded. Since 1985 he has devoted his time to research and writing, and in reply to the many trial-related requests from lawyers, activists and others, Gofman says "When enough people wake up so that a lot of people are doing research and writing on the health effects of radiation, then I'll be available to do lawsuits." Meanwhile his papers did not get published in professional journals, while researchers whose papers supported safe dose levels appeared extensively. So Gofman decided to publish his own books and papers on the subject through the Committee for Nuclear Responsibility (CNR). Among these are his elaboration of the Law of Concentrated Benefit Over Diffuse Injury (that diffuse injury processes get ignored when industries look at costs versus benefits) and his specification of essential Rules for Research. …”

(27)  Study: No Radiation Level Safe
June 29, 2005
"…’The scientific research base shows that there is no threshold of exposure below which low levels of ionized radiation can be demonstrated to be harmless or beneficial," said Richard R. Monson, the panel chairman and a professor of epidemiology at Harvard's School of Public Health….”

(28)  Section A, Appendix I: Dr. John Gofman, Radiation-Induced Cancer from Low-Dose Exposure http://www.ratical.org/radiation/CNR/RIC/index.html

(29)  Professor Busby's presentation - European Committee on Radiation Risk (ECRR)  Radiation Risk: the New Era Begins.


(30) Chris Busby


(31)  Dr. Catherine Euler, Document: NRC-2015-0057-DRAFT-0140

Comment on Fr Doc # 2015-15441


with attachment ECRR 210 Recommendations of the European Committee on Radiation Risk



(33)  Breakthrough Cancer-Killing Treatment Has No Side-Effects, Says MU Researcher

New chemistry could cure human cancers when funding is secured, April 03, 2013


(34)  Specific Activities


(35)  Cellular contamination pathway for plutonium, other heavy elements, identified, August 26, 2015 by Julie Chao

“…Research led by Berkeley Lab's Rebecca Abergel, working with the Fred Hutchinson Cancer Research Center in Seattle, has found that plutonium, americium, and other actinides can be transported into cells by an antibacterial protein called siderocalin, which is normally involved in sequestering iron….”


(36)  https://ratical.org/radiation/Fukushima/StevenStarr.html

(37)  Chris Busby: Cyclop child and the cause of congenital anomaly and cancer in Iraq


(38)  The Cause of Congenital Anomaly and Cancer in Fallujah Iraq is Identified As Enriched Uranium From Novel Weapons Systems Deployed by the US.


(39)  3. How can different types of ultraviolet radiation affect health?


(39)  [Measurement and evaluation of natural and artificial UV radiation]


(40)  The Interaction of Nuclear Radiation with Matter


(41)  More Dangerous than Uranium?


(42)  Cell Damage Expressed as a Health Problem


reprinted with permission from
No Immediate Danger, Prognosis for a Radioactive Earth, by Dr Rosalie Bertell

 (43)  Hazardous isotopes


 (44)  Direct accumulation pathway of radioactive cesium to fruit-bodies of edible mushroom from contaminated wood logs


(45)  Excretion of Cesium Through Potassium Transport Pathway in the Gills of a Marine