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Draft Appendix C<br />

Issue<br />

52<br />

RADIOLOGICAL ISSUES<br />

The discussion <strong>of</strong> the "as low as reasonably achievable" principle in this appendix is<br />

misleading in that it treats ALARA dose levels as fractions <strong>of</strong> maximum permissible dose<br />

levels for individuals. Instead, ALARA is primarily an analysis <strong>of</strong> risks to an entire<br />

affected population and <strong>of</strong> the cost-effectiveness <strong>of</strong> reducing that population risk. While<br />

ALARA individual dose limits can be derived for specific activities (e.g., operating nuclear<br />

power plants), the most basic ALARA judgement concerns the cost-effectiveness <strong>of</strong> reductions<br />

in overall population risk (e.g., $1,000 per man-rem, Appendix I). (208-NRC)<br />

Response<br />

The use <strong>of</strong> fractional dose levels is meant to be a practical approach to the ALARA<br />

philosophy. As inferred in the final paragraph, Appendix C.1 (and in agreement with the<br />

commenter's suggestion), use <strong>of</strong> the ALARA philosophy should be cognizent <strong>of</strong> dose reduction<br />

factors, cost effectiveness considerations, and should typically be evaluated on a case by<br />

case basis. The intent <strong>of</strong> the existing wording and use <strong>of</strong> ALARA does not appear to be in<br />

conflict with generally accepted definitions <strong>of</strong> ALARA.<br />

Draft p. C.4<br />

Issue<br />

One commenter noted that the Regulatory Guide "Calculational Models for Estimating<br />

Radiation Doses to Man From Airborne <strong>Radioactive</strong> Materials Resulting from Uranium Milling<br />

Operations" contains many errors and that these errors.might be carried through into<br />

Appendix C. (30)<br />

Response<br />

Subject guide was not used in Appendix C.<br />

Draft p. E.1<br />

Issue<br />

The bias in selection <strong>of</strong> reference is obvious. While the last sentence quotes the NCRP<br />

and its dislike <strong>of</strong> linear nonthreshold risk and its use in radiation protection, to maintain<br />

balance the ICRP's use <strong>of</strong> risk factors as realistic estimates (see comment on Appendix C,<br />

p. C.2) for radiation protection and their use in ICRP Publications 26 and 37 should also<br />

be documented. EPA's policy statement, 41 F.R. 28409 (1976), should also be noted.<br />

(113-EPA)

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