Abstract
In response to the three petitions by Carol S. Marcus, Mark L. Miller, and Mohan Doss, dated February 9, February 13, and February 24, 2015, respectively, the Nuclear Regulatory Commission (NRC or the Commission) has announced that it is considering assessing its choice of dose–response model, the Linear No-Threshold (LNT) model, for exposure to ionizing radiation. This comment is designed to assist the Commission in evaluating the merits of a review of the default dose–response model it uses as the basis for the Standards for Protection against Radiation regulations. It extends the petitioners' argument in favor of reexamining the default hypothesis (LNT) and taking consideration of low-dose hormesis for two main reasons: 1) Failure to review the LNT hypothesis may jeopardize the NRC's mission to protect public health and safety; and 2) The National Research Council's guidelines for choosing adequate defaults indicate that the choice of low-dose default model is due for a reevaluation.
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