ML070370075

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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
ML070370075
Person / Time
Site: Vermont Yankee Entergy icon.png
Issue date: 02/03/2007
From: Wilson L
- No Known Affiliation
To:
NRC/SECY
Ngbea E S
References
71FR67072 00043, PRM-51-11
Download: ML070370075 (3)


Text

I 116EUY- Docket Number PRM 51 -11 I

Paue lii PRM-51-11 (71 FR67072)

From: LucialLouAnne Wilson <lucia@sover.net>

To: <SECY@nrc.gov>

Date: Sat, Feb 3, 2007 10:35 AM DOCKETED

Subject:

Docket Number PRM 51-11 USNRC As a citizen living within 10 miles of the Vermont Yankee nuclear plant, February 5, 2007 (10:40am)

I most sincerely urge you to be guided by the petition of Sally Shaw, Docket Number PRM-51 -11. I am extremely concerned about the dangers from OFFICE OF SECRETARY low level radiation as well as higher releases when accidents occur. The RULEMAKINGS AND relicensing of this older plant, which we all believed would be closed ADJUDICATIONS STAFF in 5 years, would be an extremely dangerous and short sighted move. I urge you to deny Entergy's request for a 20-year extension on their license.

Below is the gist of Sally Shaw's petition; please give it your utmost attention.

The petitioner requests 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.

Exercise Precaution:

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."

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 1/550. html)." (excerpted from http://www.ieer.org/comments/beir/beir7pressrel.html)

2) Recognize "allowable" 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 of ionizing radiation.

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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, "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."

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.

The petitioner requests 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. AND OTHER RECENT SCIENCE! The petitioner asserts that the GElS relies upon an earlier NAS report, the BEIR V, with was 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. The petitioner requests 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.

Thank you for making wise decisions in this matter.

LouAnne Wilson No virus found in this outgoing message.

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Docket Number PRM 51-11 Creation Date Sat, Feb 3, 2007 10:42 AM From: Lucia/LouAnne Wilson <lucia@sover.net>

Created By: lucia@sover.net Recipients nrc.gov TWGWPO02.HQGWDO01 SECY (SECY)

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