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Category:Rulemaking-Comment
MONTHYEARML16081A4652016-03-21021 March 2016 Comment (072) of Beatrice Blake on ANPR-26, 50, 52, 73, and 140 - Regulatory Improvements for Decommissioning Power Reactors ML16085A3132016-03-18018 March 2016 Comment (154) of Sandra and Charles Kosterman on ANPR-26, 50, 73, and 140 - Regulatory Improvements for Decommissioning Power Reactors ML16053A5152016-02-17017 February 2016 Comment (037) of Emma Stamas on ANPR-26, 50, 52, 73, and 140 - Regulatory Improvements for Decommissioning Power Reactors ML12200A2592012-07-16016 July 2012 Comment (180) of Peter Samal on PRM-50-104 Regarding Emergency Planning Zone NRC-2012-0046, Comment (285) of Aliston Macmartin, Et Al on PRM-50-104 Regarding Emergency Planning Zone2012-07-12012 July 2012 Comment (285) of Aliston Macmartin, Et Al on PRM-50-104 Regarding Emergency Planning Zone ML12181A3082012-05-31031 May 2012 Comment (158) of Barbara Tiner on Behalf of the Selectboard of the Town of Leverett, Ma on PRM-50-104, Regarding Emergency Planning Zone NRC-2009-0554, Comment (9) of Mark Leyse on Petition for Rulemaking PRM-50-95 Requesting the NRC to Order Vermont Yankee to Lower the Licensing Basis Peak Cladding Temperature in Order to Provide a Necessary Margin of Safety in the Event of a LOCA2011-07-30030 July 2011 Comment (9) of Mark Leyse on Petition for Rulemaking PRM-50-95 Requesting the NRC to Order Vermont Yankee to Lower the Licensing Basis Peak Cladding Temperature in Order to Provide a Necessary Margin of Safety in the Event of a LOCA ML1033402512010-11-24024 November 2010 2010/11/24-Comment (4) of John C. Butler, NEI, on New England Coalition PRM-50-95 Requesting the NRC to Order Vermont Yankee to Lower the Licensing Basis Peak Cladding Temperature in Order to Provide a Necessary Margin of Safety in the Even ML0929309822009-10-19019 October 2009 2009/10/19-Comment (26) of Mary Lampert, Et. Al., on Behalf of Pilgrim Watch on Rules PR-50 and 50, Enhancements to Emergency Preparedness Regulations. ML0909005812009-03-26026 March 2009 Comment (1) of George J. Silvestri, Jr. on ANPR 171, Variable Annual Fee Structure for Power Reactors ML0904802662009-02-0505 February 2009 Comment (141) of Elizabeth Adams on Pr 51 Consideration of Environmental Impacts of Temporary Storage of Spent Fuel After Cessation of Reactor Operation, and Pr 51 Waste Confidence Decision Update ML0904800492009-02-0303 February 2009 Comment (122) of Randy Kehler Pr 51 Consideration of Environmental Impacts of Temporary Storage of Spent Fuel After Cessation of Reactor Operation, and Pr 51 Waste Confidence Decision Update ML0904402452009-01-29029 January 2009 Comment (44) of Scott Ainslie on Pr 51 Consideration of Environmental Impacts of Temporary Storage of Spent Fuel After Cessation of Reactor Operation, and Pr 51 Waste Confidence Decision Update ML0904403152009-01-28028 January 2009 Comment (37) of Sally Newton on Pr 51 Consideration of Environmental Impacts of Temporary Storage of Spent Fuel After Cessation of Reactor Operation, and Pr 51 Waste Confidence Decision Update ML0707906372007-03-19019 March 2007 Comment (50) Submitted by Sally Shaw on Massachusetts Attorney General'S PRM-51-10 Re Amend 10 CFR Part 51 - Spent Fuel ML0707906462007-03-19019 March 2007 Comment (52) Submitted by Joseph A. Parzych on Massachusetts Attorney General'S PRM-51-10 Re Amend 10 CFR Part 51- Spent Fuel ML0707906552007-03-19019 March 2007 Comment (54) Submitted by Scott Ainslie on Massachusetts Attorney General'S PRM-51-10 Re Amend 10 CFR Part 51 - Spent Fuel ML0707906712007-03-19019 March 2007 Comment (58) Submitted by William C Pearson on Massachusetts Attorney General'S PRM-51-10 Re Amend of 10 CFR Part 51 - Spent Fuel ML0707906742007-03-19019 March 2007 Comment (59) Submitted by Eleanor I. Gavin on Massachusetts Attorney General'S PRM-51-10 Re Amend of 10 CFR Part 51 - Spent Fuel ML0708103842007-03-19019 March 2007 Comment (64) Submitted by Paul A. Gaukler on Behalf of Entergy Corp. on Massachusetts Attorney General'S PRM-51-10 Re Amend 10 CFR Part 51 - Spent Fuel ML0707301562007-03-0707 March 2007 Comment (15) of Sunny Miller on Behalf of Traprock Peace Center on War with Iran and Hazards at the Vermont Yankee Reactor ML0703703822007-02-0505 February 2007 Comment (57) Submitted by Maure Briggs-Carrington on Shaw'S PRM-51-11 Re Application of National Academy of Science BEIR-VII Standard to Dose Radiation Calculation ML0703703772007-02-0505 February 2007 Comment (55) Submitted by Margaret Gundersen on Shaw'S PRM-51-11 Re Application of National Academy of Science BEIR-VII Standard to Dose Radiation Calculation ML0703700752007-02-0303 February 2007 Comment (43) Submitted by Louanne Wilson on Shaw'S PRM-51-11 Re Application of National Academy of Science BEIR-VII Standard to Dose Radiation Calculation ML0703006382007-01-28028 January 2007 Comment (31) Submitted by Judy Davidson on Shaw'S PRM-51-11 Re Application of National Academy of Science BEIR-VII Standard to Dose Radiation Calculation ML0702603832007-01-24024 January 2007 Comment (26) Submitted by Hattie Nestel on Shaw'S PRM-51-11 Re Application of National Academy of Science BEIR-VII Standard to Dose Radiation Calculation ML0701805132007-01-13013 January 2007 Comment (5) Submitted by Art Hanson on Shaw'S PRM-51-11 Re Application of National Academy of Science BEIR-VII Standard to Dose Radiation Calculation ML0701805182007-01-13013 January 2007 Comment (9) Submitted by Sidney Goodman on Shaw'S PRM-51-11 Re Application of National Aacdemy of Science BEIR-VII Standard to Dose Radiation Calculation ML0700804062007-01-0505 January 2007 Comment (9) Submitted by Nina Keller on Massachusetts Attorney General'S Petition for Rulemaking PRM-51-10 to Amend 10 CFR Part 51 ML0700804092007-01-0505 January 2007 Comment (10) Submitted by Lea Wood on Massachusetts Attorney General'S PRM 51-10, Regarding to Amend 10 CFR Part 51 ML0636300322006-12-24024 December 2006 Comment (5) Submitted by Alliance for Nuclear Responsibility, Rochelle Becker on Massachusetts Attorney General'S PRM-51-10 Regarding to Amend 10 CFR Part 51 ML0636300292006-12-22022 December 2006 Comment (3) Submitted by Claire Chang on Massachusetts Attorney General'S PRM-51-10 Regarding to Amend 10 CFR Part 51 ML0626502212006-08-30030 August 2006 Comment from David R. Lewis of Pillsbury, Winthrop, Shaw and Pittman on Massachusetts Attorney General'S Petition for Rulemaking PRM-51-10 to Amend 10 CFR Part 51 (August 25, 2006) ML0523604462005-08-23023 August 2005 Comment (5) Submitted by James Marc Leas Supporting Andrew Spano'S Petition for Rulemaking PRM-54-02 Re Amendment to 10 CFR Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants ML0523604372005-08-23023 August 2005 Comment (4) Submitted by Ed Anthes, Nuclear Free Vermont by 2012, Supporting Andrew Spano'S Petition for Rulemaking PRM-54-02, Amendment to 10 CFR Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants ML0327514662003-09-22022 September 2003 Comment (3) of Michael J. Colomb Re Proposed Generic Communication; Method for Estimating Effective Dose Equivalent from External Radiation Sources Using Two Dosimeters ML0323904982003-08-19019 August 2003 Comment (12) Submitted by Entergy Nuclear Operations, Inc., Michael R. Kansler on Proposed Rule PR-50 Re Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors ML0312800402003-05-0505 May 2003 Comment (16) Submitted by Energy Nuclear Vermont Yankee, James M. Devincentis, Supporting and Endorsing Comments Submitted by NEI Re Revision of Fee Schedules; Fee Recovery for Fy 2003 JPN-03-001, Comment (36) Submitted by Entergy Nuclear Inc., J. Knubel, Re Petition for Rulemaking PRM-50-79, Protection for Day Care Centers and Nursery Schools in Radiological Emergency2003-01-15015 January 2003 Comment (36) Submitted by Entergy Nuclear Inc., J. Knubel, Re Petition for Rulemaking PRM-50-79, Protection for Day Care Centers and Nursery Schools in Radiological Emergency 2016-03-21
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SECY - Improve radiation protection standards at older reactors.
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PRM-51-11 DOCKETED (71 FR67072) USNRC From: "Sidney Goodman" <gizmogink@mindspring.com>
January 16, 2007 (3:17pm)
To: <SECY@ nrc.gov>
Date: Sat, Jan 13, 2007 1:22 PM OFFICE OF SECRETARY
Subject:
Improve radiation protection standards at older reactors. RULEMAKINGS AND ADJUDICATIONS STAFF D
To: the Secretary of the NRC. - SECY@nrc.gov From Sidney J. Goodman, P.E., M.S.M.E.
158 Grandview Lane, Mahwah, NJ 07430
Subject:
PRM-51-11 Comments.
Improve radiation protection standards at older reactors.
I request that the NRC prepare a rulemaking that will require that the NRC reconcile its generic environmental impact statement for nuclear power plant operating license renewal applications with current scientific understanding of the health risks of low-level radiation, including but not limited to those discussed in the National Academy of Sciences Health Risks From Exposure to Low Levels of Ionizing Radiation: Biological Effects of Ionizing Radiation (BEIR) VII Phase 2 Report.
I request that the NRC prepare a rulemaking that would require that the NRC reconcile its GElS for nuclear power plant operating license renewal applications with the National Academy of Sciences (NAS)
Health Risks From Exposure to Low Levels of Ionizing Radiation: BEIR VII, Phase 2 which was released in 2005. The petitioner asserts that the GElS relies upon an earlier NAS report, the BEIR V, released in 1990. According to the NAS Web site, the BEIR VII updates the information contained in the BEIR V and draws upon new data in both epidemiologic and experimental research.
I request that NRC consider the NAS BEIR VII report as new and significant information and recalculate certain conclusions set forth in the GELS, including early fatalities, latent fatalities and any injury projections based on this information.
- 1) Protect the most vulnerable: 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/030909156X/html/550.html)." (excerpted from http://www.ieer.org/comments/beir/beir7pressrel.html)
- 2) Recognize *allowable* levels are not safe: The NRCs "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 of ionizing radiation.
- 3) Consider radiation damage from inhaling or ingesting radionuclides: The NRC does not consider the effects of internal radiation from ingested or inhaled alpha and beta emitters. The amount of polonium-210 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, *it is unlikely that a threshold exists for the induction of cancers... Further, there are extensive data on 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.*
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 T1,mplakJ= SIy-Ol(al SE70,1-0 0
SEýCY - Improve radiation protection standards at older reactors. F measurement and monitoring should include all forms and pathways, not just gamma at the fence line.
Radiation limits should include accidental releases as well as planned emissions.
BACKGROUND FROM FEDERAL REGISTER Entergy Nuclear Operations, Inc. (Entergy) submitted an application for renewal of Operating' License No.
DPR-28 for an additional 20 years of operation at the Vermont Yankee Nuclear Power Station (VYNPS). The VYNPS is located in the town of Vernon, Vermont, in Windham County on the west shore of the Connecticut River immediately upstream of the Vernon Hydroelectric Station. The operating license for VYNPS expires on March 21, 2012. A notice of receipt and availability of the application, which included the environmental report, was published in the Federal Register on February 6, 2006 (71 FR 6102). Subsequently, the NRC published a "Notice of Intent to Prepare an Environmental Impact Statement and Conduct Scoping Process" on April 21, 2006 (71 FR 20733). The NRC will prepare an EIS related to he review of the license renewal application.The applicable NRC regulation, 10 CFR 51.95(c), required that the NRC, in determining whether to grant a renewal of a nuclear power plant operating license, prepare an environmental impact statement (EIS).
The regulation provides that this EIS supplement the NRC's baseline, generic EIS issued in 1996, NUREG-1437, "Generic Environmental Impact Statement for License Renewal of Nuclear Plants" (May 1996)(GEIS).
Sidney Goodman gizmogink@ mindspring.com EarthLink Revolves Around You.
cAtemp\GW)00001.TMP Page 11t I. "
tm\G}OO1.M Pag 1 i Mail Envelope Properties (45A92344.E1D : 1 : 56861)
Subject:
Improve radiation protection standards at older reactors.
Creation Date Sat, Jan 13, 2007 4:17 PM From: "Sidney Goodman" <gizmogink@mindspring.com>
Created By: aizmogink@mindspring.com Recipients nrc.gov TWGWPO02.HQGWDO01 SECY (SECY)
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