ML070370377

Comment (55) Submitted by Margaret Gundersen on Shaws PRM-51-11 Re Application of National Academy of Science BEIR-VII Standard to Dose Radiation Calculation

ML070370377
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	02/05/2007
From:	Gundersen M Fairewinds Associates
To:	NRC/SECY
Ngbea E S
References
71FR67072 00055, PRM-51-11
Download: ML070370377 (5)

Text

PRM-51-11 DOCKETED (71 FR67072)

M q u.,er_,*,

USNRC Faire~wi(

s Associate, I no February 5, 2007 (4:45pm) 3 76 Apptetrepe Po&t Road,, B bU*ti%-om, VT 05408 OFFICE OF SECRETARY Phone 802 -865 -9955 & Faxc802-304-1051 RULEMAKINGS AND fairewinds(dmac.com ADJUDICATIONS STAFF February 5, 2007 US NRC SECY(anrc.mov 301-415-1966 RE: Docket NO. PRM-51-11 Comments In Support Of PRM-51 Petition for Rulemaking PRM-5 1-11 requests that the NRC prepare a rulemaking that will require that the NRC reconcile its generic environmental impact statement (GEIS) for nuclear power plant operating license renewal applications with the National Academy of Sciences Health Risks From Exposure to Low Levels of Ionizing Radiation: Biological Effects of Ionizing Radiation (BEIR VII) Phase 2 Report.

It is time for the NRC to do a complete review of the radiation exposure issues. My work as a paralegal in the nuclear safety arena has shown me again and again that the standards currently used are wholly inadequate.

I have read numerous MD expert witness reports and epidemiological studies from all over the world, and the data clearly shows that the health risks from exposure to low levels of ionizing radiation is not being calculated in a meaningful manner that protects the health and safety of the citizens of this country. Clearly, the NRC is doing an incredible disservice to any families living within at least 50 miles of any nuclear facility by applying a model that is outdated and no longer has any scientific validity.

In addition to working as a paralegal on several federal nuclear cases, I have also served as a paralegal in nuclear safety hearings before the Vermont Public Service Board. In n 0.1e.= ~ '-

listening to the testimony and writing deposition questions for the cross examination of witnesses, it was patently clear that Entergy's Vermont Yankee repeatedly massages and recalculates the radiation release data in an effort to meet or beat the fence line boundary radiation prohibitions. My research has shown that a similar shell game is conducted by utilities throughout the country under the supposedly health protection oversight of the NRC.

I have worked with families whose children have died and other families who have children dealing with years of chemotherapy becausethe NRC did not do its job of protecting the public from ionizing radiation releases from nuclear power plants. Do your job now and revise the ionizing radiation models to levels that protect the health of the general public. Our children's lives are at stake.

Please contact me if you wish any further information or testimony.

Sincerely, Margaret Gundersen, Certified Paralegal Cc: Sally Shaw Senator Bernie Sanders Senator Patrick Leahy Congressman Peter Welch Vermont Senator President Pro Tempore Peter Shumlin Vermont Speaker of the House Gaye Symington Page 2 of 2

- Nt-iL l-~uIemaKIng ~snaw beIr VII LI~

Page 1 1,,SECY NRC Rulemaking Shaw Be.irVI1 EIS P~age71 i From:

Margaret Gundersen <fairewinds @ mac.com>

To:

<SECY@nrc.gov>

Date:

Mon, Feb 5, 2007 4:23 PM

Subject:

NRC Rulemaking Shaw Beir VII EIS OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF Please note my support for PRM-51 -11 Petition for Rulemaking Sincerely, Margaret Gundersen

/-

/Margaret Gundersen Certified Paralegal Fairewinds Associates, Inc 802-865-9955 - office 802-304-1051 - fax 802-238-5053 - cell fairewinds @ mac.com <mailto:fairewinds @ mac.com> /

H///

CC:

Sally Shaw <acer8sac@comcast.net>

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