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Mark:
Can you tell me
where the request for comments is posted? It takes me forever to find
anything on the NRC site. And when does the period for public comment
close? I'd like to prepare a brief comment, not only citing the ANS and
HPS Position Statements, but also citing NCRP-121 that says not to do
that.
I also want to point
out that grading plants by how low their collective dose is, inhibits inspectors
from doing a proper job, leading to such problems as the Davis-Bess
corrosion.
Thanks, I'd
appreciate it.
Ted
Rockwell
-----Original Message-----
From: owner-radsafe@list.vanderbilt.edu [mailto:owner-radsafe@list.vanderbilt.edu]On Behalf Of Jerry Cohen Sent: Wednesday, February 26, 2003 8:28 PM To: Chilton, Milton W.; mark.hogue@SRS.GOV; radsafe@list.vanderbilt.edu Subject: Re: Commenting on USNRC Environmental Impact Statements Milton,
You make an interesting suggestion.
Suppose, by some bureaucratic miracle, the EPA,
and NRC were to accept the HPS position and rescind all policies and
regulations based on calculation of risk (health effects) to those receiving
doses below 5.0 rem/a or 10.0 rem/lifetime. The implication of such a change
would likely be profound, if not revolutionary.
First, the concept of collective dose
would be abandoned, and ALARA would be on shaky ground. The practice of
estimating the number of cancer cases resulting from radiation related events
would be halted. Limitations such as cleanup regulations calling for levels
<15 mrem/a would seem ridiculous. Imagine that! Many, if not most
radsafe professionals would need to seek employment elsewhere.
In today's emailbag, a message from Les
Aldrich claims that it is our responsibility to not scare the public with
warnings about hazards that do not exist. Considering our current policies
and regulations, I thought that was our raison d'etre.
Nice try Milton, but it ain't going to
happen.
Jerry Cohen
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