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"In what is nothing more than overt pandering
to the anti-nukes,----"
> Government officials must listen to what
anti-nukes and other assorted crazies
have to say, but where is it written that their
irrational ideas must be taken seriously,
much less, reflected in policy.
"What is the cost of this change buying us?
Nothing at all. "
> That's true only if you consider
the public good. The bureaucrat gets
$50-100K
more funds to administer, and the contractor
gets the money.
"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"
> That's true, but what's your point? Are you
suggesting that EPA standards
ought to be rational. WOW, what a radical
concept!
----- Original Message -----
Sent: Thursday, June 07, 2001 9:05
AM
Subject: Re: Nuclear Waste, Science,
& Politics and 40 CFR Part 197
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
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