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Submitted by Judy Treichel, Nevada Nuclear Waste Task Force
   Commenting on behalf of the organisation
Document Recommendations
The Nevada Nuclear Waste Task Force has worked on issues specific to the proposed nuclear waste repository at Yucca Mountain, Nevada for more than twenty years. Our primary task is that of representing the public who have concerns about radiation exposure and the damage that could occur to health and the environment. An important aspect of the Yucca Mountain project is that if a repository is developed, it would be done despite the strong opposition of the people of Nevada. Because there are times when the public is exposed to radiation without their consent or knowledge and even despite their objections, it is essential that regulators, especially the international agencies, have strict, protective rules.

The recommendations being proposed by ICRP would not increase public safety and/or human health, but rather would heighten the levels of distrust and fears of the people who rely on regulators to protect them. Organizations and citizens who pay attention to issues regarding radiation will tell you that we are not overly protected or TOO safe. There is NO justification for deregulating any sort of radioactive material or exempting it from regulation. The Nevada Nuclear Waste Task Force opposes any exclusions and/or exemptions in the proposal.

A point raised in the recommendations is that ICRP lacks “certainty” about the effects of low dose radiation to populations. Of course, rates of cancer and/or other radiation induced conditions can rise or fall but no one can tell who will or will not be harmed. We do know that those most at risk are small children and fetuses. When they are simply averaged into a large population, their risk is not reduced. It should be the goal of any proposed change to regulations to reduce risk by reducing the amount of radiation released to the environment. Uncertainty should trigger caution, not justify disregard.

Any regulations established by international regulators, or changes to existing regulations, will almost certainly be adopted by other agencies. For that reason it is imperative that the standards of the ICRP be as protective as possible.