In answer to your request for public comment on Uranium Mill Tailing Regulations: Conforming to EPA Standards (49 FR 46418 and 50 FR 2293), I submit the following:
Uranium mill tailing piles are rarely located within populated centers; at a distance of one mile or more their health hazard due to radon daughters transported by radon gas is quite insignificant compared with the very same health hazard in energy efficient homes and offices. For the latter case, the National Council on Radiation Protection has published estimates equivalent to 264,000 deaths by lung cancer in the present US population (or roughly 3,700 deaths per year) due to changes in home ventilation,(1) though individual scientists estimate the number to be up to six times higher.
The EPA regulates this health hazard when it is caused by uranium tailings, but has issued no regulations for the identical type of, but vastly larger, health hazard when it is due to energy conservation. The lopsided ratio of the two hazards, plus the discriminatory procedure of regulating a hazard not by its effect on public health, but by its originator, is one of the cases in which the EPA does not regulate for public health and safety, but for polishing its image and pleasing the lobbies misleadingly labeled as "environmental"¾a mockery of public trust of which your commission is not innocent, either.
If the NRC does not wish, on this occasion, to become an accomplice to the EPA's negligence in protecting public health, I propose that the NRC inform the EPA that NRC regulations of the radon hazard will be adapted to EPA's as soon as the latter are made complete and meaningful by addressing the genuine hazards posed by radon, and are not limited, as they are now, to cases that have little significance for public health in comparison, and therefore serve little else than political posturing.
P.B.
1. Evaluation of occupational and environmental exposures to radon and radon daughters in the United States, NCRP Report No. 78 (National Academy of Sciences, May 1984), p. 165.
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Vol. 12, No. 7
Newsletter: Access to Energy Newsletter Archive Volume: Issues Issue/No.: Vol. 12, No. 7 Date: November 29, 2004 01:59 PM Title: Gratitude and contempt
Copyright © 2004 - Access to Energy Newsletter Archive
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