COMMENTS ON ICRP 2005 RECOMMENDATIONS FROM CONCERNED CITIZENS FOR SNEC SAFETY Dear ICRP Members: Concerned Citizens for SNEC Safety (CCSS) is a citizens group founded to help protect residents living near the Saxton Nuclear Experimental Corporation Reactor Site during and after its decommissioning. Our observations of this process show that the operations of this plant and earlier decommissioning work were severely flawed because of incorrect assumptions about the dangers and problems of handling radioactive materials. Early in the decommissioning process we were told by the "experts" that the original operators hadn't done things right, i.e. the new way that the "experts" would be using, but that now everything would be handled correctly. Today, people at the site are working to clean up the mistakes made by those earlier "experts" who told us they knew how to do the job. To us, this history makes it clear that "experts" are too easily convinced of the breadth of their own knowledge and thereby leave local residents to suffer the potential and real consequences of the "experts" activities. We think you are making the same kind of mistake with the proposed 2005 Recommendations. Our specific concerns include the following: 1. Our experience at the Saxton Site shows that use of a supposed "safe" threshold to effectively deregulate radioactive materials can lead to many future nightmares and high costs. Exclusions, exemptions or deregulation of man-made radioactive materials should not be allowed. 2. It appears that your proposed recommendations have not taken into account significant recent research regarding the risks of exposure to "low" levels of radiation. This research should be considered in determining dose limits. 3. You should not base the recommendations on exposures to a "standard or reference man." It is clear that radiation affects different people in different ways and rather than basing risks on the effects on the strongest person the risk should be based on those most sensitive to the effects of radiation. 4. Exposure to radiation produces many effects beyond fatal cancers and genetic abnormalities. It is also true that there are synergistic effects with other toxic agents. All of the hazardous effects of radiation exposure should be considered in determining dose limits. 5. Internal exposures to radiation have much greater effects than you are currently considering and they should be fully evaluated in determining dose limits. 6. We all experience radiation from many individually unknown sources, both routine and accidental. All of these sources of radiation should be accounted for in setting dose limits for the known exposures which you are considering. Therefore we urge you to reconsider your proposed recommendations and to not lower dose limits to either the general public or workers. Thank you for your consideration of our comments. Please keep us informed of your progress. Sincerely, Ernest Fuller Vice-chairman, CCSS 1427 Kearney Hill Rd Six Mile Run, Pa 16679 USA