Tell US Nuclear Regulatory Commission (USNRC) to come clean on radiation safety standards!

Protect children from radiation. DEMAND NRC extend time for comments, show us the documents!

The US Nuclear Regulatory Commission (USNRC) is rewriting its radiation regulations using documents that are not open to the public. Industry, however, has access to these documents.

These potential regulations will affect workers and the public, including vulnerable children.

This goes against open and democratic principles of governance. NRC has taken a number of years to write its potential rule even with full access to these documents. NRC should, therefore, not expect us to be able to obtain, read and assess the basis for this rule in a few short months.

NRC must turn over the documents and extend the comment deadline, giving us the resources and time needed to comment properly. TELL THEM SO.

SIGN this letter

November 12, 2014 - Posted by Christina Macpherson | ACTION

4 Comments »

People still need to complain-comment at the NRC site itself and ask for extensions.
Current deadline is Nov. 24th. The NRC has really inane questions like “how the prevention of cataracts should be viewed in comparison with the potential formation of cancer or other adverse impacts; and the impacts of a change in the dose limit for the embryo/fetus to 1 mSv (100 mrem).” Cataract “surgery” involves removal of the old lens and adding an artificial one. In the case of babies with cataracts researchers now say contact lens as safer! US NRC comment link: http://www.regulations.gov/#!documentDetail;D=NRC-2009-0279-0067 http://www.regulations.gov/#!docketDetail;D=NRC-2009-0279
The only intelligent thing is the mention by the NRC that mSv is less precise than mrem and should be carried out several decimals. For example 25 mrem is 0.25 msv. I guess the Beyond Nuclear petition is referring to the ICRP documents? It is true that only the draft ICRP is available for free in English and this may also be a problem if governments are using the draft and not the final, as the drafts versions may give less protection. The final copies are available at a university library most likely or can be bought and as they say corporations generally get them as part of a pre-paid subscription. They are very long – like 1,000 pages. The US EPA uses the ICRP as well. They are copyrighted so can’t even be shared online. The ICRP final documents ARE available for free in many other languages besides English! Why doesn’t Beyond Nuclear make a petition on their on web site? I’m sure that Change.org is one of the ones which you sign and get your e-mail junked up and sometimes unsubscribe and still get them. More than one person has mentioned that they do not sign for this reason and some other organizations make their own online.
The major misleading thing which the NRC does in relation to the ICRP is that the ICRP makes clear that 1 mSV is to be from ALL sources and the NRC leads people to believe that it is per source. But, 1 mSv is very, very high.

Comment by miningawareness | November 13, 2014 | Reply
Sorry this is the link: http://www.regulations.gov/#!documentDetail;D=NRC-2009-0279-0067 I think it still has the questions re the cataracts, though the set up is confusing. Deadline 24 Nov. Comments can be anonymous.

Comment by miningawareness | November 13, 2014 | Reply
Title: “Limitations of the ICRP Recommendations for Worker and Public Protection from Ionizing Radiation” by Rosalie Bertell, Ph.D., GNSH

http://www.ccnr.org/radiation_standards.html

Thanks to Gordon Edwards, Ph.D of the Canadian Coalition for Nuclear Responsibility.

Comment by Dud | November 13, 2014 | Reply
Another US NRC question: “Q1-4: Should the public dose limit of 0.5 mSv (50 mrem) continue to be the basis for the effluent concentration limits for the radionuclides in 10 CFR part 20, appendix B, Table 2, Columns 1 and 2? Should it be reduced or otherwise modified?”
http://www.regulations.gov/#!documentDetail;D=NRC-2009-0279-0067

According to the ICRP, 2007, for facilities with long-lived radionuclides the limit to the public should be 0.1 mSv (10 mrem) per year. Not 1 mSv (100 mrem) but 0.1mSv (10 mrem): “planning assessments should consider whether build-up in the environment would result in the constraint being exceeded, taking account of any reasonable combination and build-up of exposures. Where such verification considerations are not possible or are too uncertain, it would be prudent to apply a dose constraint of the order of 0.1 mSv in a year to the prolonged component of the dose attributable to the long-lived artificial radionuclides” (p. 105, ICRP 103, 2007) Even this standard is insufficiently protective because the long-lived nature of many radionuclides means that they constantly are building up in the environment. It is also a maximum limit and not a minimum. 0.1 mSv is actually too high a number, but it is significantly under the US EPA’s 25 mrem (0.25 mSv). There needs to be strict, serious, limits and testing for ALL radionuclides which may be emitted from nuclear facilities into air, soil AND water. The 10 CFR Ch 1, Pt. 20, App. B lists almost 100 elements which may be radioactive and many isotopes of each of these (50 pages). The limits are based on diluted quantities of radionuclide “effluents” emitted by each site. Since the sites are waterways the NRC encourages dilution as the solution! There need to be true limits, preferably none. It is still important for people to write something to the NRC, even one sentence. They need to write something original, however, so that it gets posted – if the letters look like repeats they don’t post them. (The NRC still hasn’t corrected this error on their web site even though they visited our post over a month ago: http://miningawareness.wordpress.com/2014/09/04/the-dangerous-us-nrc-typo-making-low-level-radioactive-waste-more-radioactive-than-allowed-at-wipp/ )
Sorry to put so much but it is important. Thanks for reminding us of this most unpleasant comment period-topic.

Comment by miningawareness | November 13, 2014 | Reply