Draft document: Recommendations
Submitted by Marvin Lewis, n/a
Commenting as an individual

I had commented upon the first round ICRP report, and had been hopeful of the many issues raised therein: greater knowledge of effects, need for more public involvement, and clearer data development. I am no longer hopeful of improvement of radiation protection to the public coming out of ICRP work. This present recommendations puts profit to global corporations ahead of protections to the public Through the semantics of 'risk assessment.' NRC Commissioner Peter Lyons in his 8-23-2006 address explains how to put the profit of licensees ahead of the radiological protections to the public by quoting ICRP recommendations which in themselves are invitations to the nuclear industry to put profit ahead of protections to the public: "Collective dose is mainly an instrument for optimization, for comparing radiological technologies and protection procedures.Collective dose is not intended as a tool for epidemiological risk assessment and it is therefore inappropriate to use it in risk projections based on epidemiological studies. This is a very limited viewpoint. Collective dose is used BECAUSE THERE ARE NO OTHER DATA TO WHICH LARGE GROUPS SUCH AS THE PUBLIC CAN BE ASSIGNED. What Peters and the ICRP is saying is that since large groups are difficult to assign doses and responses radiologically, therefore, the nuclear industry can put whatever dose it wants into the public and be free of the consequences. I do not agree and I wish that I could say respectfully as the NRC is an agency of the government to which I am loyal. There are many other problems with the ICRP recommendations. specifically are the 'exemptions.' Every licensee wants exemptions. Every licensee says his particular waste or process will not be a danger to the health and safety of the public. A very few of them are actually true. Fewer still believe they need do nothing more than get Through the hoops that the agencies: NRC, DOE, IAEA put on them . I have worked in labs and on welding floors. I know what the attitude is. I have been in Board rooms and in the Halls of Congress. I know what the attitude is. The attitude is the easiest way to meet the requirements even if that isn't the spirit and the law and the way to protect the health and safety of the public. That brings me to a very sore problem that the ICRP, industry and government seem to ignore completely: MONEY! Katrina, the 29 Depression, and Yucca Mountain Repository and many many others have shown that money is not the panacea which we all think. The health and safety of the public must be put above the profitability of global corporations. Very truly yours, Marvin Lewis