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

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Draft Appendix H<br />

Issue<br />

136<br />

RISK PERSPECTIVES<br />

This appendix could well be omitted. Many <strong>of</strong> the hazard indices quoted are <strong>of</strong> no value<br />

as indices, and no information is available to enable one to select which, if any, <strong>of</strong> the<br />

indices are useful.<br />

Although purporting to be a basis for determining the "hazard index," the material as<br />

presented in the appendix does not even approximate the potential hazard. The MPC is<br />

derived on the basis <strong>of</strong> dose to a "critical organ" rather than on the risk related to a<br />

given intake <strong>of</strong> isotope. The cumulative risk from intake <strong>of</strong> isotopes should be used as.the<br />

basis for deriving a comparative "hazard index" since organ sensitivities are the controll-<br />

ing factor as noted in ICRP-26. (113-EPA)<br />

Response<br />

The intent was to indicate the variety <strong>of</strong> hazard indices that were available. Since<br />

there is no critical review <strong>of</strong> these indices then use is marginal. The revised appendix<br />

notes that--"Although each hazard index has merit for a particular set <strong>of</strong> conditions, the<br />

provision <strong>of</strong> simple measures <strong>of</strong> hazard can confuse rather than clarify. For this reason<br />

hazard indices are infrequently.used in this Statement and dose and associated health<br />

effects are presented instead."<br />

Issue<br />

One commenter requested that the concentrations <strong>of</strong> plutonium in waste should be related<br />

to the natural radioactivity <strong>of</strong> the rock excavated for disposal. (6)<br />

Response<br />

For perspective on concentrations <strong>of</strong> plutonium the reader is referred to Figure 3.4.1.<br />

In the strictest use <strong>of</strong> concentrations (i.e. grams/cc <strong>of</strong> total rock) comparison <strong>of</strong> the<br />

plutonium content to say 0.2% uranium ore is not an improvement in clarity. This fails to<br />

recognize the need for pathways to man for the material to be significantly toxic.<br />

Issue<br />

A commenter stated that a mistake <strong>of</strong> the Statement was to rely solely on the technique<br />

<strong>of</strong> risk assessment as a criteria for safety decisions. (167)<br />

Response<br />

As noted in a previous response, impacts are presented from a consequence standpoint<br />

first. The document also identifies other criteria in Section 6.2 (in addition to radio-<br />

logical impacts) that the "decision-maker" would consider in evaluating the various disposal<br />

options.

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