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

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directed toward a water supplier and applied to monitoring and
corrective treatment regardless of the source of the contamination. Annual Exposure in Millirem/year
The Draft Environmental Impact Statement relates to activities of Bone GI
persons whose contamination of the environment is being limited. SourceGonads Lung Surface arrow Tract
Gonads Lung Surface Marrow Tract
11. (Page 2.2.4, Line 6): This should be corrected to read: (b) Gross 28 28 28 28
alpha particle activity (including radium-226 but excluding radon and Cosmic 7 8 07 0.7
uranium)--15 pCi/1. Cosmogenic 0.7 0.7 0.8 0.7
- Terrestrial 26 26 26 26 26
12. (Page 2.2.5) Under "Clean Air Act Amendments of 1977" the text Inhaled -- 100
states: "The administrative and legal problems arising from the Radionuclides
potential conflict with NRC regulatory authority and procedures in Body 27 2 60 2 2
originating in the Atomic Energy Act of 1954 have not been resolved. TO 80 180 120 80 80
However, it is unlikely that existing EPA radiation standards will be TOTAL
changed, although administrative requirements may." This statement is la i The use of
presumptuous and does not reflect the major effort underway at EPA to 17. (Page 2.3.6, Section 2.3.3, 2nd paragraph, last line) 00
develop regulations under the Clean Air Act, as amended. The text the Congressional Research Service (reference 23) estimate of 200,000
should be revised in the Final EIS. defective children per year does not agree with current estimates of
9.5 percent to 10.5 percent incidence of genetic disorders in newborn
13. (Pages 2.3.2 and 2.3.3, Tables 2.3.1 and 2.3.2) Both of these (see UNSCEAR 1977, p. 519). The UNSCEAR estimates suggest that this
tables are taken from an obsolescent reference (ORP/CSD 72-1). More estimate of 200,000 is at least a factor of 2 low.
appropriate references would be EPA report ORP/SID 72-1 (reference 21, i o inni o iain
Section 2.3) with the cosmic ray doses augmented by the new information Estimates of malignancies occurring ach year ar tter otained
in HCRP Report 045 (reference 10, Section 2.3). from the American Cancer Society annual publication "Cancer Facts and
Figures--19xx." For example, estimates have been: 395,000 deaths,
14. (Page 2.3.4, Section 2.3.2.2, 2nd paragraph, last three lines) 765,000 cases of cancer--1979; 390,000 deaths, 700,000 cases--1978;
The dose estimates for radon are obsolete. Currently, dissolved radon 385,000 deaths, 690;000 cases--1977; etc.
in the body would give a dose of about 2 to 3 mrem/yr and the range of 18. (Page 2.3.6, Section 2.3.3, 3rd paragraph, last sentence) The use
estimated dose from inhaled radon and daughters at 0.7 pCi/liter would of Frigerio and Stowe as a referenouldould be put in context. Aside
be 130 mrem/yr to 1800 mrem/yr. See United Nations Scientific of Frigerio and Stowe as a reference should be put in context. Aside
beComit tee o te E cts of Atomic Ra/ onSeRepo S (UNaCE or 1977
from using the same obsolete reference
Cor
of natural background
a mittee
used in
on the Effects of Atoic Radiaquestion, Report UNSCR for 1977 this DEIS which inflates the probable difference in background between
areas of the country, the authors neglect to consider the potential
15. (Page 2.3.5, Section 2.3.2.2, Table 2.3.3)-The data in this table effects of other carcinogens in the work place and the environment.
is obsolete, see UNSCEAR 1977 or NCRP 45 for urrent data. Some of these problems are highlighted in multiauthor sections on
"Demographic Leads to High-Risk Groups" and "Environmental Factors" in
16. (Page 2.3.5, Section 2.3.2.2, Table 2.3.4) - This table is the volume Persons at High-Risk of Cancer (J.F. Franmeni, Jr., editor,
obsolete. NCRP 45 summarizes natural background as follows: Academic Press, New York, 1975). Little support is given for the
assertions in the referenced paper.
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In a more complete report by the same author (N.A. Frigerto, K.F.
Eckerman, and R.S. Stowe, "Carcinogenic Hazard from Low-level, Low-rate
Radiation," ANL/ES-26, 1973) where all methods and assumptions are
given, there are several flaws. A major flaw is the assumption that
"all forms of cancer show very similar doubling doses and closely
similar increases in mortality rate per rad." This assumption is made