[NukeNet] Petition for rulemaking--please comment
MoJo
mollypj at yahoo.com
Tue Jan 23 14:08:10 CST 2007
Correction, Third parragraph should read NRC, not TVA. Sorry, Jeannine
Dear All,
Please comment on this and forward it to your own internet contacts, please. This gets to exactly what I have been screaming about since the Hartsville Nuclear Plant Intervention hearings, where TVA opposed putting filters on the ventilation systems of the turbine buildings and the reactor buildings, on what was supposed to have been the world's largest nuclear power plant.
Instead of calculating the dose to a one year old child drinking milk from a cow that would have grazed near that plant, using the then in force guideline 1.42, that calculated a dose of 335 mrems per year, when the allowable dose to the thyroid was 15 mrems per year, TVA devised their own calculation model, TVA model 2, that brought the dose down to 11.1 mrems. How convenient.
Instead of TVA enforcing their regulations, they ABOLISHED GUIDELINE 1.42 AND ESTABLISHED A NEW GUIDELINE 1.109, THAT IS STILL BEING USED TODAY. They brought the dose down to 1.1, another 10 fold deduction I have been begging for people to examine these guidelines to see how they did it. Sally points out two things.
(1) Instead of using a 1 year old child, they substituted a "standard man" who is far more resistant to radiation than women, children, and especially fetuses.
(2) They do not consider ingested radiation. This is criminal. Ingested or inhaled radiation is hundreds of times more dangerous than surface radiation.
This is the secret to the the nuclear revival. This is how the government gets away with calling nuclear plants "emission free."
This must be stopped. Thanks Sally for taking this stand. I will support you l00%. Please, everyone, do the same.
Jeannine Honicker
---------------------------------
----- Original Message ----- From: Sally Shaw
To: Dolph Honicker
Sent: Tuesday, January 23, 2007 11:26 AM
Subject: Petition for rulemaking--please comment
PLEASE ACT NOW AND DISTRIBUTE WIDELY:
Please tell the NRC to approve a petition for rulemaking that
would improve radiation protection standards at older reactors. Your
comments are needed by February 5, 2007. Please see the Talking Points
below for more detailed information to help in writing your comments.
FEDERAL REGISTER SUMMARY: The Nuclear Regulatory Commission (NRC) is
publishing for public comment a notice of receipt of a petition for
rulemaking which was filed with the Commission by Sally Shaw. The
petition was published in the Federal Register on November 20, 2006, and
has been assigned Docket No. PRM-51-11. Include PRM-51-11 in the subject line.
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.
For background and summary of BEIR VII committee, see Monitor article
at: http://www.nirs.org/mononline/nm632.pdf
SEND COMMENTS:
Please include PRM-51-11 in the subject line of your comments.
Mail: Secretary, U.S. Nuclear Regulatory Commission, Washington, DC
20555-0001, ATTN: Rulemakings and Adjudications Staff.
E-mail to: SECY at nrc.gov. If you do not receive a reply e-mail confirming
receipt of comments, please contact the NRC directly at (301) 415-1966.
Submit via website http://ruleforum.llnl.gov.
Fax to: Secretary, U.S. Nuclear Regulatory Commission at (301) 415-1101.
Find Federal Register notice HERE:
http://www.epa.gov/fedrgstr/EPA-IMPACT/2006/November/Day-20/i19568.htm
TALKING POINTS:
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."
(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: 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.
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-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."
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.
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 the 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).
Petitioner's Request
The petitioner requests that the NRC prepare a rulemaking that would
require that the NRC reconcile its GEIS 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 GEIS 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 GEIS, including early fatalities, latent fatalities and any
injury projections based on this information.
incorporate by reference: your favorite source of new information on the harmful effects of low level radiation, or use the following references:
http://www.ieer.org/reports/badtothebone/index.html
Bad to the Bone:
Analysis of the Federal Maximum Contaminant Levels for
Plutonium-239 and Other Alpha-Emitting Transuranic
Radionuclides in Drinking Water
Arjun Makhijani, Ph.D.
Institute for Energy and Environmental Research
August 2005
from which the following was excerpted:
B. Bone dose estimation, present-day dose conversion factors
Scientific understanding of radiation doses and harm from intake of radionuclides has advanced
considerably over the years. Regulations have also evolved to some extent, though at a slower pace.
Specifically, in the 1970s, the International Commission on Radiological Protection (ICRP) published
ICRP 26 and ICRP 30 followed by ICRP 48 in 1986. The scientific work in these publications was
incorporated by the EPA into Federal Guidance Report 11 in 1988. The doses from alpha-emitting,
long- lived transuranic radionuclides in the new guidance issued by the EPA are much higher than
those estimated by NBS 69 methods.....etc
ALSO
http://www.ieer.org/campaign/report.pdf
Science for the Vulnerable
Setting Radiation and Multiple Exposure Environmental Health
Standards to Protect Those Most at Risk
Arjun Makhijani, Ph.D.
Brice Smith, Ph.D.
Michael C. Thorne, Ph.D.
October 19, 2006
You could simply say you support the petition for rulemaking, Docket PRM-51-11, and request that the NRC incorporate by reference the Arjun Makhijani et al. reports (titled above), Rosalie Bertell's book, No Immediate Danger: Prognosis for a Radioactive Earth by Rosalie Bertell 1985, and Helen Caldicott's 2006 book Nuclear Power is Not the Answer
along with the research of Alice Stewart which demonstrated the damaging effect of radiation on the fetus. Ask that radiation standards be revised to protect the MOST VULNERABLE, not averaged to "reference man".
Correction, Third parragraph should read NRC, not TVA. Sorry, Jeannine
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__,_._,___ Dear All,
Please comment on this and forward it to your own internet contacts, please. This gets to exactly what I have been screaming about since the Hartsville Nuclear Plant Intervention hearings, where TVA opposed putting filters on the ventilation systems of the turbine buildings and the reactor buildings, on what was supposed to have been the world's largest nuclear power plant.
Instead of calculating the dose to a one year old child drinking milk from a cow that would have grazed near that plant, using the then in force guideline 1.42, that calculated a dose of 335 mrems per year, when the allowable dose to the thyroid was 15 mrems per year, TVA devised their own calculation model, TVA model 2, that brought the dose down to 11.1 mrems. How convenient.
Instead of TVA enforcing their regulations, they ABOLISHED GUIDELINE 1.42 AND ESTABLISHED A NEW GUIDELINE 1.109, THAT IS STILL BEING USED TODAY. They brought the dose down to 1.1, another 10 fold deduction I have been begging for people to examine these guidelines to see how they did it. Sally points out two things.
(1) Instead of using a 1 year old child, they substituted a "standard man" who is far more resistant to radiation than women, children, and especially fetuses.
(2) They do not consider ingested radiation. This is criminal. Ingested or inhaled radiation is hundreds of times more dangerous than surface radiation.
This is the secret to the the nuclear revival. This is how the government gets away with calling nuclear plants "emission free."
This must be stopped. Thanks Sally for taking this stand. I will support you l00%. Please, everyone, do the same.
Jeannine Honicker
---------------------------------
----- Original Message ----- From: Sally Shaw
To: Dolph Honicker
Sent: Tuesday, January 23, 2007 11:26 AM
Subject: Petition for rulemaking--please comment
PLEASE ACT NOW AND DISTRIBUTE WIDELY:
Please tell the NRC to approve a petition for rulemaking that
would improve radiation protection standards at older reactors. Your
comments are needed by February 5, 2007. Please see the Talking Points
below for more detailed information to help in writing your comments.
FEDERAL REGISTER SUMMARY: The Nuclear Regulatory Commission (NRC) is
publishing for public comment a notice of receipt of a petition for
rulemaking which was filed with the Commission by Sally Shaw. The
petition was published in the Federal Register on November 20, 2006, and
has been assigned Docket No. PRM-51-11. Include PRM-51-11 in the subject line.
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.
For background and summary of BEIR VII committee, see Monitor article
at: http://www.nirs.org/mononline/nm632.pdf
SEND COMMENTS:
Please include PRM-51-11 in the subject line of your comments.
Mail: Secretary, U.S. Nuclear Regulatory Commission, Washington, DC
20555-0001, ATTN: Rulemakings and Adjudications Staff.
E-mail to: SECY at nrc.gov. If you do not receive a reply e-mail confirming
receipt of comments, please contact the NRC directly at (301) 415-1966.
Submit via website http://ruleforum.llnl.gov.
Fax to: Secretary, U.S. Nuclear Regulatory Commission at (301) 415-1101.
Find Federal Register notice HERE:
http://www.epa.gov/fedrgstr/EPA-IMPACT/2006/November/Day-20/i19568.htm
TALKING POINTS:
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."
(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: 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.
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-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."
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.
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 the 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).
Petitioner's Request
The petitioner requests that the NRC prepare a rulemaking that would
require that the NRC reconcile its GEIS 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 GEIS 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 GEIS, including early fatalities, latent fatalities and any
injury projections based on this information.
incorporate by reference: your favorite source of new information on the harmful effects of low level radiation, or use the following references:
http://www.ieer.org/reports/badtothebone/index.html
Bad to the Bone:
Analysis of the Federal Maximum Contaminant Levels for
Plutonium-239 and Other Alpha-Emitting Transuranic
Radionuclides in Drinking Water
Arjun Makhijani, Ph.D.
Institute for Energy and Environmental Research
August 2005
from which the following was excerpted:
B. Bone dose estimation, present-day dose conversion factors
Scientific understanding of radiation doses and harm from intake of radionuclides has advanced
considerably over the years. Regulations have also evolved to some extent, though at a slower pace.
Specifically, in the 1970s, the International Commission on Radiological Protection (ICRP) published
ICRP 26 and ICRP 30 followed by ICRP 48 in 1986. The scientific work in these publications was
incorporated by the EPA into Federal Guidance Report 11 in 1988. The doses from alpha-emitting,
long- lived transuranic radionuclides in the new guidance issued by the EPA are much higher than
those estimated by NBS 69 methods.....etc
ALSO
http://www.ieer.org/campaign/report.pdf
Science for the Vulnerable
Setting Radiation and Multiple Exposure Environmental Health
Standards to Protect Those Most at Risk
Arjun Makhijani, Ph.D.
Brice Smith, Ph.D.
Michael C. Thorne, Ph.D.
October 19, 2006
You could simply say you support the petition for rulemaking, Docket PRM-51-11, and request that the NRC incorporate by reference the Arjun Makhijani et al. reports (titled above), Rosalie Bertell's book, No Immediate Danger: Prognosis for a Radioactive Earth by Rosalie Bertell 1985, and Helen Caldicott's 2006 book Nuclear Power is Not the Answer
along with the research of Alice Stewart which demonstrated the damaging effect of radiation on the fetus. Ask that radiation standards be revised to protect the MOST VULNERABLE, not averaged to "reference man".
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
"I do not believe that nuclear power is worth it if it creates radiation. Then you might ask me why do I have nuclear powered ships. That is a necessary evil. I would sink them all. I am not proud of the part I played in it. I did it because it was necessary for the safety of this country. That's why I am such a great exponent of stopping this whole nonsense of war. Unfortunately limits’ attempts to limit war have always failed. The lesson of history is when a war starts every nation will ultimately use whatever weapon it has available." Further remarking: "Every time you produce radiation, you produce something that has a certain half-life, in some cases for billions of years. I think the human race is going to wreck itself, and it is important that we get control of this horrible force and try to eliminate it." Adm. Rickover - testimony before Congress
Molly Johnson
6290 Hawk Ridge Place
San Miguel, CA 93451
---------------------------------
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