[ RadSafe ] NRC ACMUI meeting on Marcus/Miller/Doss petitions

[Peter Crane]

Fellow RADSAFERs:

Some time ago, the NRC's Advisory Committee on the Medical Uses of Isotopes (ACMUI) established a subcommittee to consider the rulemaking petitions filed earlier this year by Carol Marcus, Mark Miller, and Mohan Doss et al., and that subcommittee has now issued a draft report, which will be discussed in a public teleconference on October 28. The ACMUI recently sent out an email with three attachments:  the Federal Register notice announcing the receipt of the three petitions; the draft report of the subcommittee; and the comments that I submitted in advance of the October 28 meeting. I can't do attachments to a RADSAFE posting (that much I have learned) but I can provide links to the subcommittee report and to my comments, as well as paste in the ACMUI notice about the teleconference. I hope this works, and is consistent with RADSAFE's rules of the road.

As will be seen, the subcommittee does not recommend abandonment of the LNT as the basis of regulation. My own view is that the NRC should, as the petitions request, initiate a rulemaking proceeding, but that instead of being limited to the issues raised in the petitions, it should include a reexamination of the 1997 deregulation of nuclear medicine.

-- Peter Crane, NRC Counsel for Special Projects (retired)

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1. ACMUI Meeting notice: 
Advisory Committee on the Medical Uses of Isotopes
TELECONFERENCE AGENDA
Wednesday, October 28, 2015
2:00 PM – 4:00 PM (EST)
OPEN SESSION

Agenda:  Discuss the ACMUI Subcommittee Report on the Review and Comments of Petitions for
Rulemaking (PRM)-20-28, 20-29, and 20-30, “Linear No-Threshold Model and Standards for
Protection Against Radiation” 

2. ACMUI subcommittee report: http://pbadupws.nrc.gov/docs/ML1528/ML15287A494.pdf 

3. Peter Crane comments: 
C:\Users\Owner\Documents\2015.CommentsOnMarcusPetitionSeptember25FINAL.pdf