ML090640367

Comment (8) E-mail Regarding Iplr Dseis

ML090640367
Person / Time
Site:	Indian Point
Issue date:	02/13/2009
From:	Public Commenter Public Commenter
To:	Division of License Renewal
NRC/NRR/DLR
References
73FR80440
Download: ML090640367 (3)

Text

IPRenewalCEmails From: Judy Allen [judya814@comcast.net]

Sent: Friday, February 13, 2009 9:44 AM To: IndianPointEIS Resource

Subject:

"Reference Man" issue Hello NRC person -

I live 14 miles from Indian Point in Putnam Valley, NY and though we get no electricity from Indian Point, we are still subjected to the emissions and radioactive releases permitted by the NRC.

Following is the study I presented at yesterday's meeting about Indian Point in Cortlandt. There was only one "Reference Man", the 20-30 year-old white male, in the entire audience yesterday.

Study faults regulators for relying on reference man radiation dose standard http://www.diagnosticimaging.com/nuclear/article/113619/1364527#

By James Brice A study from the Institute for Energy and Environment Research indicates that U.S. radiation exposure regulations and compliance assessment guidelines often underestimate the risk of radiation for women and children because they are based on standards of a "reference man," a hypothetical 20- to 30-year-old white male.

At least three federal agencies -- the Environmental Protection Agency, Nuclear Regulatory Commission, and Department of Energy -- still use reference man criteria to guide radiation dose regulations and compliance assessment, according to the IEER.

"The use of the reference man standard is pervasive in U.S. radiation protection regulations and compliance guidelines," said IEER president Arjun Makihjani, Ph.D, the report's author. "This is wrong because it often fails to adequately protect groups other than young adult males."

A woman is 52% more likely than a man to develop cancer from the same radiation doses, according to Makihjani. Children are at greater risk than adults. A female infant has about a seven times greater chance of eventually developing cancer than a 30-year-old male from the same radiation dose.

Pregnant women and the developing fetus are particular vulnerable, but noncancer reproductive effects are generally not part of the U.S. regulatory framework for radiation production, he said.

The institute noted that the House Committee on Oversight and Government Reform queried the EPA in May 2008 about its continued use of the reference man standard. In its response, the EPA admitted that it was still used in some guidelines, despite falling out of favor among regulators.

The report recommends that compliance with radiation protection always be estimated by calculating doses for those at the greatest risk. It calls for a significant reduction in the maximum allowable dose to the general public from 100 mrem per year to 25 mrem per year. It also recommends a revamping of EPA guidance documents to reflect doses received by men and women of all ages.

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Other recommendations include tightening radiation protection standards for women who are exposed to radiation in the workplace and publication of an official federal guidance on in utero dose estimation methods.

Furthermore, I received the following note from a friend after the meeting. Apparently you are already aware that "Reference Man" is outdated, but have taken no action to change the measurement parameters to include women and children. For an agency whose mission is FIRST to "Protect public health and safety", this is a matter I don't believe you can continue to ignore.

Arjun Makhijani PhD of IEER has spoken widely on this, as well I have submitted testimony to the NRC in the past. In fact there is correspondence on record between me, Chairwoman Harriet Cornell and Director Blough of the NRC. This info is cited in a study put out by IEER.

The NRC is well aware of the faults with "reference man " as a threshold for acceptable limits. It should not come as a surprise to anyone there. It is good to raise the issue again and again, as it cuts to the core of the issue.

Thank you for the opportunity to provide input to your Environmental Review.

Judy Allen 24 Seifert Lane Putnam Valley, NY 10579 845 528-6643 H 914 382-1193 C 2

Federal Register Notice: 73FR80440 Comment Number: 8 Mail Envelope Properties (26D87235-0449-485F-8E37-BD3DA72E707C)

Subject:

"Reference Man" issue Sent Date: 2/13/2009 9:43:57 AM Received Date: 2/13/2009 9:43:59 AM From: Judy Allen Created By: judya814@comcast.net Recipients:

"IndianPointEIS Resource" <IndianPoint.EIS@nrc.gov>

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