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

Draft p. 3.1.144
Issue
50
RADIOLOGICAL ISSUES
Define "health effects" and assumptions for "translating" 1.8 x 108 man-rem into
1.8 x 10 4 to 1.4 x 105 health effects. (208-NRC)
Response
Health effects are defined in Appendix E, Volume 2 of the Statement; 100 to 800 health
effects per million man-rem equates to 1.8 x 104 to 1.4 x 105 health effects for 1.8 x 10 8
man-rem.
Draft Appendix C
Issue
This appendix is grossly unsatisfactory. It concentrates heavily on doses to indivi-
duals and does not appear to recognize that more recent standards, although they may be
expressed in terms of dose to the maximum individual, have population dose as part of their
basis. Among such regulations are:
1. Limitations on releases of effluents from power reactors (Appendix I to 10 CFR 50);
2. The uranium fuel cycle standards (40 CFR 190); and
3. The drinking water standard (40 CFR 141).
The limitations on releases of 8Kr, 129I, and transuranic elements, in 40 CFR 90, are
explicitly based on population dose.
The general thrust of this appendix is that population dose is not a.concept suitable
for radiation standards. This is incorrect because the concept of ALARA usually involves
balancing the cost against the reduction in population dose. It is perhaps.significant that
this appendix does not include any of the BEIR reports but limits itself to the 1969 report
of the National Academy of Sciences. For currency, the appendix should consider additional
references (e.g., References 1, 2, 10, and 16 from Appendix E) to bring the appendix up to
1977 at least. (113-EPA)
Response
DOE does not agree. The development presented in-final Section 3.3.2 and Appendix C
is based on individual dose which is a matter of historical record. No attempt was made to
suggest that at very low doses and dose rates that population doses are not of major
interest in exposure control.