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Management of Commercially Generated Radioactive Waste - U.S. ...

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40<br />

RADIOLOGICAL ISSUES<br />

presently require at (sic.) whenever plutonium is shipped, it must be shipped in a nitrate<br />

solution. Transport <strong>of</strong> oxide powders is expressely forbidden." (147)<br />

Response<br />

On the contrary, except for less than 20 Ci amounts, the only form allowed for pluto-<br />

nium shipment is as a solid (oxide or metal) (10 CFR 71.42).<br />

Issue<br />

Several letters requested that additional information be provided on background radia-<br />

tion levels.<br />

Draft p. 2.2.1--Some baseline exposure needs to.be presented so the reader will know<br />

what increase and what risks are entailed by additional exposures. (62)<br />

Draft Appendix F-- Examples <strong>of</strong> existing radioactivity levels in the biosphere (surface,<br />

water, drinking water, air, etc.) would illustrate conditions prior to the operation <strong>of</strong> a<br />

waste disposal facility. (43)<br />

Response<br />

The discussion <strong>of</strong> natural background has been modified in order to give the reader a<br />

better feel for the existing environment in terms <strong>of</strong> the existing radioactivity levels (see<br />

final Section 3.3).<br />

Draft p. 2.2.1<br />

Issue<br />

The document neglects to mention overall guidance provided by the FRC: Radiation Pro-<br />

tection Guidance for Federal Agencies, 25 F.R. 4402 et seq. (5/18/60), for which 10 CFR 20<br />

is one <strong>of</strong> several implementing regulations. (113-EPA)<br />

Response<br />

The cited reference was added in the final Statement (see Section 3.3).<br />

Draft p. 2.2.2<br />

Issue<br />

One commenter noted that 10 CFR 20 only gives limiting concentrations. That means that<br />

a utility may put out as much radioactivity as it wants as long as it dilutes it suffi-<br />

ciently. This merely spreads the cancers throughout an entire population. It does not<br />

place a limit on how many cancers nuclear power may produce. (30)

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