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

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The general thrust of this appendix is that population dose is not
113. (Page 3.6.25) Several ports have banned the shipment or receipt a concept suitable for radiation standards. This is incorrect because
of spent fuel. Does the proposal include use of dedicated port the concept of ALARA usually involves balancing the cost against the
facilities? reduction in population dose. It is perhaps significant that this
appendix does not include any of the BEIR reports but limits Itself to
114. (Page 3.6.26) What is the range of error in the results of the the 1969 BEAR reports of the National Academy of Sciences. For
"unverified, theoretical model" in projecting impact? currency, the appendix should consider additional references, e.g.,
references 1, 2, 10, and 16 from Appendix E, to bring the appendix up
115. (Page 3.6.30, first paragraph) Is the $15 million mentioned for to 1977 at least.
R&D costs? If not, what costs does that figure represent?
121. (Page C.2, 1st and 2nd paragraphs) The paragraphs ending the
116. (Page 3.6.31) Again we find the semantic difference between ocean section on "Background" and initiating "As Low As Reasonably Achievable
dumping and sub-seabed emplacement. "Dumping" and "Dump" should not be Application" reflect some bias and a lack of candor in describing the
in quotation marks. It is defined in the Marine Protection, Research, use of risk coefficients in radiation protection. Almost all
and Sanctuaries Act of 1972 as a disposition of materials. This government agencies, particularly the EPA but including the NRC and the
misleading section should be corrected in the Final EIS. MSHA, have used or are using risk coefficients to estimate impact of
radiation exposure. The ICRP (reference 11) has gone entirely to a
117. (Page 3.6.32, third paragraph) The sixth option should be risk based radiation protection system, using estimates of risk in
clarified. Considering the dollar input, what is the intent and what optimizing radiation protection. ICRP has stated, "These risk factors
will be the output? are intended to be realistic estimates of the effects of irradiation at
low annual dose-equivalents (up to the Commission's recommended
118. (Section 3.6) Somewhere in this section several other matters dose-equivalent limits)" (ICRP publication No. 28, 1978). The NCRP
should be briefly considered: (reference 15) seems to stand alone in its position discounting the use
How deep would the projectiles be sent? What distance beneath the
of linear, nonthreshold risk coefficients in radiatioh protection.
Ssediment surface, and how far from the rock beneath? What about the 122. (Page C.3, Table C.1) While the table is titled "Comparison Chart
concept of recovery, if unforeseen dangers are found to exist? of Radiation Standards," it then lists "Standards or Criteria" and
references ICRP and NCRP values or reports. ICRP and NCRP reports are
119. (Page 4.12) Figure 4.4.1 had been omitted. It should be included recommendations or suggestions which may or may not be adapted or
or the reference to it should be removed. modified and adopted by national regulatory agencies. The references
to ICRP and NCRP should be deleted from the table.
120. (Appendix C) This appendix is grossly unsatisfactory. It
concentrates heavily on doses to individuals and does not appear to It should be noted, however, that there are ICRP reports pertinent
recognize that more recent standards, although they may be expressed in to health effects. ICRP publication 26 (reference 11) and publication 27
terms of dose to the maximum individual, have population dose as part ("Problems Involved in Developing an Index of Harm," 1977), both provide
of their basis. Among such regulations are: recommendations on "acceptable" numerical risk estimates for radiation
workers.
1. Limitations on releases of effluents from power reactors
(Appendix I to 10 CFR 50); 123. (Appendix D) While the calculational models employed may be
adequate, in light of the uncertainties inherent in the input data, they
2. The uranium fuel cycle standards (40 CFR 190); and are not state-of-the-art, as claimed. For example, the calculation of
3. The drinking water standard (40 CFR 141).
the 5 cm gamma dose as the total body dose for air immersion could be
improved by the use of an existing code which specifically yields organ
doses. Again, while the DACRIN code used employs the TGLD model, it
The limitations on releases of krypton-85, iodine-129, and does not explicitly treat the daughter products formed after inhalation
transuranic elements, in 40 CFR 190, are explicitly based on population
dose.
as do more complete codes.