Reconsidering LNT 3.0
Tomorrow is a big day. The NRC will release its year long reconsideration of the Linear No Threshold(LNT) radiation harm model ordered by Trump’s May, 2025 EO. I believe this is the third such reconsideration.
Here are my predictions. The response will not say that LNT is biological nonsense. It will not acknowledge that LNT is the no DNA repair theory whose foundational premise is contradicted by well established, indisputable biology. It will not point out that the radium dial painters and the Taipei apartment dwellers clearly falsify LNT.
The response will embrace the Muller Trap and accept the false LNT or no threshold dichotomy with something like INL’s:
However, it is important to stay focused on the central issue with LNT: that all radiation exposure, without threshold, will create deleterious health effects.p[3]
It will offer the deeply flawed INWORKS study as support for LNT, and ignore the Life Span Study (LSS) of the bomb survivors on which the Japanese and American taxpayers have spent nearly a billion dollars over 70 years, despite the fact that until recently the LSS study was the NRC’s Goldstandard. What changed was the Radiation Effects Research Foundation admitted their LSS data is non-linear. It will point out that the LSS exposures were acute dose rate profiles, but LNT claims there is no difference between acute and chronic profiles. It will also ignore the Nuclear Shipyard Workers Study by far the best controlled of the nuclear worker studies.
It will not say what counts is not the cumulative dose, not the average dose rate, but the entire dose rate profile. In fact, it will never use that term. Instead it will repeatedly talk about the “dose”, implicitly accepting LNT. There will be no mention of DNA repair time. What recommendations it comes up with will be based on the biologically meaningless and medically dangerous period of a year.
It will not offer a well defined replacement for LNT. Therefore, the NRC has no way of converting an acceptable risk to dose rate limits. Despite this, it will call for some relaxation of the current limits, probably 50 mSv/y for nuclear workers and 5 mSv/y for the public, without offering a compelling argument for these numbers.
It will make a few handwaving generalizations about not requiring ALARA. But since it offers no replacement for LNT, there will be no way to do the benefit-cost analysis needed to actually tell the regulator where to stop. Whether or not ALARA is dropped in name, regulator incentives will remain unchanged and so will the regulator’s behavior.
There will be no discussion of the deadly downside of LNT, the unnecessary evacuations and exiles, the millions of lives shortened by fossil pollution, and the failure to raise billions out of poverty.
The response will end up neither endorsing nor repudiating LNT, but call for more study, preserving the status quo.
I have had no contact with the people drafting the reconsideration. This will be an interesting test of your preacher’s infallibility.


NRC now targeting 2026-07-02 for the publication of the new rules.
No idea why I expected a site that posts nonsense about radiation to have the date right. Mea culpa.
Hi Jack, I want to pick a bone with your article with respect to the fossil fuel deaths you mention. The air quality in the U.S. is very good thanks to emissions control equipment, and most of the country is in attainment for criteria pollutants. I think that applying an LNT metric to coal and gas emissions is also probably not accurate. What’s your perspective?