|To whom it may concern:
I am writing to you to ask you to delete the exemptions (section 2.4) recommendations and any documentation supporting exemptions, and also to encourage you to adopt and implement immediately PRECAUTIONARY PRINCIPLE in your framework.
Nuclear waste is hazardous - regardless of the amount, type, or form that it comes in. Our planet, its inhabitants, and our animal brethren need to feel safe, protected, and know that our fellow man seven generations from us will be as well.
I will commend you for your acknowledgement on our animal inhabitants in your reporting; however, I am disheartened to notice that you present acceptable levels of radiation they can ingest, breathe, or absorb. This is unacceptable. All of us are connected and what harms one harms us all.
I ask of you the following: To address these additional areas in the radiation levels, nuclear waste dumping, and other related items to nuclear power.
Some additional areas to be addressed include:
_setting exempt and excluded levels of radiation exposure that no longer need regulatory control (something many of us have been fighting for decades and essentially outlawed in some US states);
_discouraging projection of “collective” or population doses— preventing estimation of harm to populations now or in the future from radiation exposures—supposedly due to the uncertainty of health effects at low doses and into the future.—ex: recommending against calculations of the numbers of cancers from allowable cleanup levels from dirty bombs or from releasing radioactive materials into commerce from regulatory control or from exposures to populations in 10,000 to a million years from the proposed Yucca Mountain site if it were to be used a nuclear waste dump. Unfortunately not guessing the damage does not prevent the damage. Hypocritically, that same uncertainty does not stop ICRP from recommending actually releasing the radioactivity in its Exemption and Exclusion section;
_setting legal radiation exposure levels for animals, plants, and ecosystems—in order help radiation polluters escape liability for environmental contamination and exposure to non-human species;
_continuing to recommend the same public and worker exposures even though known cancer incidence risks have increased somewhat (by a third in National Academies of Science BEIR VII report from 8.46 to 11.41 cancers per 10,000 person rads or 100 person grays) and new (since the mid-1990s) biology indicating that radiation damages more cells in the current and future generations of cells than those directly hit by radiation (bystander effect);
_averaging radiation damage over age and gender, leaving the most vulnerable humans unprotected. This may be an improvement to protecting the hardiest members of the population but ICRP should adopt the precautionary approach and protect us all;
_continuing its precedent of disregarding radiation damage to future generations beyond the first 2 generations
_allowing “low-level” releases of radiation while claiming not to know exactly what damage is done at these doses.
_recommending use of a “representative individual” or “representative person” that is who appears to be designed to prevent anything but average assumptions in dose calculations, appears to be evolving from the standard man, the most exposed individual, the average member of the critical group, all created by the radiation establishment to enable mathematical manipulations which in many recent cases, allow more radiation contamination and reduce real public protection, prevention and precaution.
I urge you to do this in a timely manner.