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RE: COGEMA Says No to LNT



Kai,

I am sorry that you are so confused.  First of all, the HPS is not a

government or regulatory agency.  Second, the original post concerning the

Cogema involved its compliance with laws and regulations, not those of the

HPS which is a professional society.  Third, the report comes from the IEER

which is not noted for its pro-nuclear stance and presents a very disjointed

report.  



My impressions are that if Cogema is going to operate in the US, it will

have to follow our regulations  Doses to workers should be ALARA with a TEDE

of 50 mSv and exposures to the general public are to be less than 1 mSv per

year.  The IEER report implies that the company set a de minimis of 3 mrem

and quotes Roger Clarke of the ICRP that at low doses, there should be no

regulatory concern.  (I would interpret this as meaning that the any risks

are too small and exposures have "zero impact" on normal health, e.g.,

living to 80 years of age.).  Then the report says that there is

disagreements with other agencies such as the NCRP, CDC/NCI and UNSCEAR,

which say the current data suggest that some cancers do not depart from a

LNT relationship, and that over relationships could exist.  Again, I have

not problem with these comments as I view them to be biological concepts and

not statutory laws and regulations.   Then, the report goes into some weird

analysis involving that 3 mrem exceeds the ALI for I-129.  I use the term

"blowing smoke."  Finally, the report reviews various studies and claims

that were made against Cogema operations in France.  What these have to do

with operations under US regulations is unclear since I do not see any

significant, if any, violations of French or international laws.



My conclusion is the IEER report is a typical snow job that is trying to

raise warning signs and arouse the population to block the planned

processing of MOX fuel.  I must say, it is well researched.  I just think it

should be reviewed with a critical eye.



-- John 

John Jacobus, MS

Certified Health Physicist 

3050 Traymore Lane

Bowie, MD  20715-2024



E-mail:  jenday1@email.msn.com (H)      



-----Original Message-----

From: Kai Kaletsch [mailto:info@eic.nu]

Sent: Monday, May 13, 2002 3:28 PM

To: William V Lipton; Jacobus, John (OD/ORS)

Cc: RadSafe

Subject: Re: COGEMA Says No to LNT





Sorry folks. I guess where I get confused is where in this whole thing is

"rulemaking" or "change in regulations" an issue?



The way I understand it is that Cogema, in some impact statement, has chosen

to follow HPS guidance (or similar: 3 mrem vs. 5 rem?) on how to calculate

impact. Then there was some unrelated stuff thrown in (not in the Cogema

report, but in the IEER report discussing the Cogema report) about iodine

and some unrelated other Cogema issues. I would like to ask you again: Has

Cogema violated any laws or regulations by following HPS guidance on how to

assess impacts?



Feel free to re-type the entire HPS position statement. This doesn't change

the fact that HPS specifically instructs NOT to calculate a collective

impact from small individual doses.



Kai



----- Original Message -----

From: "William V Lipton" <liptonw@DTEENERGY.COM>

To: "Jacobus, John (OD/ORS)" <jacobusj@ors.od.nih.gov>

Cc: "Kai Kaletsch" <info@eic.nu>; "RadSafe" <radsafe@list.vanderbilt.edu>

Sent: Monday, May 13, 2002 12:14 PM

Subject: Re: COGEMA Says No to LNT





> John - As usual, you said it better than I could. Let me add:  (a) As you

> stated, this is a position statement, not rulemaking.  Although I largely

agree

> with this statement, I feel strongly that rulemaking must consider inputs

from

> all interested parties, and am highly suspicious of any party which feels

he has

> a monopoly on "scientific truth," whatever that is.  (b)  Kai seems to

have

> overlooked other parts of the position statement such as, "The possibility

that

> health effects might occur at small doses should not be entirely

discounted."

> Regardless of "scientific truth," I am strongly opposed to any change in

> regulations which would allow unnecessary dose or widespread contamination

of

> the environment.

>

> The opinions expressed are strictly mine.

> It's not about dose, it's about trust.

> Curies forever.

>

> Bill Lipton

> liptonw@dteenergy.com

>

> "Jacobus, John (OD/ORS)" wrote:

>

> > Kai,

> > I am not sure what you mean by "the "megalomaniac on a mission from God"

in

> > the HPS."  I do believe that the HPS position statement is a position

> > statement.  It has nothing to do with the violation of any law or

> > regulation.  Remember, there is still free speech, and the HPS is

exercising

> > its option to make a statement.  I believe that their statement is

valid.

> > With regard to COGEMA, I believe that the issue is whether or not they

> > violated a law or regulation, which is a little different.

> >

> > By the way, the whole quote from the HPS is

> >

> > "In accordance with current knowledge of radiation health risks, the

Health

> > Physics Society

> > recommends against quantitative estimation of health risks below an

> > individual dose of 5 rem in

> > one year or a lifetime dose of 10 rem in addition to background

radiation.

> > Risk estimation in this

> > dose range should be strictly qualitative accentuating a range of

> > hypothetical health outcomes

> > with an emphasis on the likely possibility of zero adverse health

effects.

> > The current philosophy of

> > radiation protection is based on the assumption that any radiation dose,

no

> > matter how small,

> > may result in human health effects, such as cancer and hereditary

genetic

> > damage. There is

> > substantial and convincing scientific evidence for health risks at high

> > dose. Below 10 rem

> > (which includes occupational and environmental exposures), risks of

health

> > effects are either too

> > small to be observed or are non-existent."

> >

> > -- John

> >

> > -----Original Message-----

> > From: Kai Kaletsch [mailto:info@eic.nu]

> > Sent: Monday, May 13, 2002 12:16 PM

> > To: William V Lipton; Jacobus, John (OD/ORS)

> > Cc: RadSafe

> > Subject: Re: COGEMA Says No to LNT

> >

> > John and Bill:

> >

> > Do you disagree with the position statement by the "megalomaniac on a

> > mission from God" in the HPS?:

> >

> > ( http://www.hps.org/documents/radiationrisk.pdf )

> >

> > "In accordance with current knowledge of radiation health risks, the

Health

> > Physics Society recommends against quantitative estimation of health

risks

> > below an individual dose of 5 rem in one year ."

> >

> > Isn't that what the report claims Cogema did? Is the HPS position

statement

> > in violation of any US laws or regulations?

> > . . .

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