Re: Nuclear Waste, Science, & Politics and 40 CFR Part 197

[RuthWeiner@AOL.COM]

As long as we are on this topic:


A number of RADSAFE posts have criticized the cost of the Yucca Mountain 

characterization.  In the promulgation of 40 CFR 197, we have a wonderful 

example of how the cost escalates through no fault or action of the project.


In what is nothing more than overt pandering to the anti-nukes, the surface 

distance from the repository at which the release standard takes effect was 

reduced from 20 km to 18 km.  Anyone at all familiar with performance 

assessment will recognize that this change requires considerable 

recalculation and rewriting of the results, review by the contractor, review 

by DOE, etc. to show that the standard can be met 2 km closer.  And if you 

can't show it, some design refinements might be required.  At an approximate 

cost to DOE of $100/hour, I would (very crudely) estimate the cost of this 

change to be between $50,000 and $100,000, if nothing is changed in the 

design.  Moreover, the cost is not proportional to the magnitude of the 

change (unless it were significantly less than one km -- a change that 

wouldn't have required any action). Five km requires as much recalculation as 

2.  


What is the cost of this change buying us?  Nothing at all.  Does anyone 

really think that the analysts want to do this recalculation?  Don't be 

silly!  If EPA had taken the comparatively scientific approach of 40 CFR Part 

191 they would have recognized that a less-than-order of magnitude change is 

well within the bounds of the uncertainty of any performance assessment and 

would have stuck to order of magnitude estimates to begin with. 


For that matter, when one considers the range of uncertainties involved, the 

"new" 15 mrem/year standard is no different from the "old" 25 mrem/year 

standard. 


Very clearly just my own opinion, and possibly not shared by anyone else.


Ruth Weiner, Ph. D.

ruthweiner@aol.com