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

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CONSEQUENCE ANALYSIS
are found in references 1-7" (p. 1.4), is not sufficient. GETOUT (p. I.10) should be
briefly discussed as well. (113-EPA)
Response
There is some confusion as to the basis for the analysis in the Statement. The mate-
rial of Appendix I was extracted from an earlier report but the methods of Appendix I were
used for the slow groundwater transport analysis. No emphasis on geologic media was
intended. Contamination of an aquifer by salt may preclude use of the aquifer for domestic
purposes.
Draft Appendix I
Issue
The criterion for public acceptability of 120 millirems per year to the maximum indivi-
dual is not defensible, and population dose needs primary consideration. If the approxi-
mately three million people who could be supported by the river were each to receive
120 millirems per year, the population dose would be 350,000 person-rems per year or approx-
imately 70 health effects per year using the BEIR-whole body estimate. Although all the
postulated three million people would not receive the maximum individual dose and although
these nuclides would not produce whole body doses, there is no reason to believe that the
concentration of nuclides in the river would decrease substantially as the nuclides moved
down river. (113-EPA)
Response
Although the suggested scenario results in 70 health effects/yr which relates to 7 x
105 health effects over 10,000 years the probability (using EPA's value of 4 x 10 -7 )
reduces the mathematical expectation of societal risk of less than one health effect over
10,000 years. Regardless, the criterion stated was developed for a referenced report. DOE
agrees that population dose from the events considered here should be controlling.
Draft Appendix I
Issue
The analysis uses unquoted sorption equilibrium constants. These are probably the
Battelle desert soil values which may be unreasonably high. The text on p. 1.6 refers to
"three miles of western U.S. subsoil," which is reminiscent of the Battelle "desert soil."
These sorption constants are not necessarily typical of all soils and rocks and, in any
case, should be listed in tabular form. (113-EPA)