[ RadSafe ] request for comments on 10 CFR 20 revisions recognizing nonradiological toxicity

[James Salsman]

I want to express deep gratitude to everyone who has acknowledged
the problems I have been discussing both on and off list over the
past several days.  I will respect requests for anonymity, but I
would like to request that anyone who wants to send me important
information and remain anonymous should please create a throw-away
webmail account to do so, and not include any personally identifying
information, in case my email ever gets subpoenaed or something.

The Federal Register published my rulemaking petition for recognition
of the developmental and reproductive toxicity of heavy metals today:

   http://www.bovik.org/du/NRC-PRM-20-26.pdf

Please send a comment before August 29th to SECY at nrc.gov with a
subject line such as:  comments on PRM-20-26 toxicity petition

I recommend that you include the following points:

1.  Current regulations ignore the developmental and reproductive
toxicity of heavy metal radionuclides, and are at present designed
only to prevent kidney failure.

2.  The reproductive toxicology profile for uranium combustion
product inhalation in humans is currently unknown with any accuracy
beyond 14 years (i.e., since the February 1991 exposures) and has
shown an increasing and accelerating tendency, consistent with the
fact that uranium accumulates in testes damaging sperm production
cells and increasing chromosome damage over time.

3.  It is completely unethical and immoral to allow any release of
a known reproductive toxin without a fully established toxicology
profile.  Doing so is reckless and negligent; to willfully allow
such releases is potentially a crime.

4.  Regulators should attempt to extrapolate the existing known
toxicology profile of heavy metal radionuclides and assume the
worst case within the projections' 95% confidence intervals, and
in an abundance of caution allow at least a two order-of-magnitude
margin of error for limiting the increase in congenital
malformations in children of the exposed to 5% after 30 years.

Sincerely,
James Salsman