ML070180513
| ML070180513 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 01/13/2007 |
| From: | Hanson A - No Known Affiliation |
| To: | NRC/SECY/RAS |
| Ngbea E S | |
| References | |
| 71FR67072 00005, PRM-51-11 | |
| Download: ML070180513 (3) | |
Text
II.SECY lstrongly urge the NRC to approve a petition for rulemaking (Docket No. PRM-51 -11) that would improve radiation proPage 1J PRM-51-11 (71FR67072)
From:
Art Hanson <hansona@lcc.edu>
To:
<SECY@nrc.gov>
Date:
Sat, Jan 13, 2007 12:08 AM
Subject:
I strongly urge the NRC to approve a petition for rulemaking (Docket No. PRM-51-11) that would improve radiation protection standards at older reactors.
Dear Secretary,
U.S. Nuclear Regulatory Commission, Washington, DC DOCKETED 20555-0001, ATTN: Rulemakings and Adjudications Staff:
USNRC I strongly urge the NRC to approve a petition for rulemaking (Docket No.
January 16, 2007 (3:17pm)
PRM-51 -11) that would improve radiation protection standards at older reactors.
OFFICE OF SECRETARY RULEMAKINGS AND The NRC should Exercise Precaution:
ADJUDICATIONS STAFF
- 1) Protect the most vulnerable: Tell the NRC to exercise precaution by accounting for more vulnerable populations in their standards. Since no level of radiation dose is safe (see BEIR VII quote below), the best precaution would be no exposure. However recognizing and regulating for vulnerable populations is a start.
"In BEIR VII, the cancer mortality risks for females are 37.5 percent higher. The risks for all solid tumors, like lung, breast, and kidney, liver, and other solid tumors added together are almost 50 percent greater for women than men, though there are a few specific cancers, including leukemia, for which the risk estimates for men are higher." (Summary estimates are in Table ES-1 on page 28 of the BEIR VII report prepublication copy, on the Web at http://books.nap.edu/books/030909156X/html/28.html.)
The BEIR VII report estimates that the differential risk for children is even greater. For instance, the same radiation in the first year of life for boys produces three to four times the cancer risk as exposure between the ages of 20 and 50. Female infants have almost double the risk as male infants. (Table 12 D-1 and D-2, on pages 550-551 of the prepublication copy of the report, on the Web starting at http://books.nap.edu/books/0309091 56X/htm l/550.html)." (excerpted from http://www.ieer.org/comments/beir/beir7pressrel.html)
- 2) Recognize 3allowable 2 levels are not safe: Tell the NRC that their "allowable" levels of radionuclides are NOT conservative or protective enough. They are based only on the obsolete "standard man", a healthy, white male in the prime of life, and ignore the more vulnerable fetus, growing infant and child, the aged, those in poor health, and women who are, according to the BEIR VII report, 37-50% more vulnerable than standard man to the harmful effects pf ionizing radiation.
- 3) Consider radiation damage from inhaling or ingesting radionuclides: NRC does not consider the effects of internal radiation from ingested or inhaled alpha and beta emitters. The amount of polonium-21 0 that recently killed a former Russian intelligence officer was considered by IAEA and NRC to be of the lowest possible risk because they failed to-account for internal radiation damage.
- 4) Recognize there is no safe dose: Further, regarding low dose radiation, the BEIR VII panel has concluded, 3it is unlikely that a threshold exists for the induction of cancers... Further, there are extensive data on
~Fempa4-~5cYSEC
SECY - I strongly urge the NRC to approve a petition for rulemaking (Docket No. PRM-51 -11) that would improve radiation proPage2 radiation-induced transmissible mutations in mice and other organisms. There is therefore no reason to believe that humans would be immune to this sort of harm. 2 Demand that the NRC protect all members of the public from all types of excess radiation exposure from nuclear power and its fuel cycle, gamma, alpha, beta, neutron, particulate, fission products, noble gases, etc. and that measurement and monitoring should include all forms and pathways, not just gamma at the fence line. Argue that their radiation limits should include accidental releases as well as planned emissions.
Sincerely, Art Hanson 1815 Briarwood Dr.
Lansing, MI 48917-1773
Iic:\\temp\\GW}O0001.TMP Page___
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Subject:
I strongly urge the NRC to approve a petition for rulemaking (Docket No. PRM-51-11) that would improve radiation protection standards at older reactors.
Creation Date Sat, Jan 13, 2007 12:07 AM From:
Art Hanson <hansona@lcc.edu>
Created By:
hansona@lcc.edu Recipients nrc.gov TWGWPO02.HQGWDOO1 SECY (SECY)
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