Newly proposed Yucca Mountain Dose Limits

Dear Radsafers: I really wonder just what the NRC has in mind when they state that the geologic repository system at Yucca Mountain must conform to the following, when people in and around the test site can also be under the provisions of 10 CFR Part 20.1402, as state below the proposed repository regulations:

Proposed Part 63 regulation: The regulations direct that, after high-level waste has been placed in the repository and the facility has been permanently closed, the repository system should ensure protection of the public in a manner consistent with the EPA standards. The standards provide that the engineered barrier system should be designed to work in combination with natural barriers so that, for 10,000 years following disposal, the expected radiation dose to an individual would not exceed 15 millirems total effective dose equivalent per year. Consistent with EPA policy, a separate standard is also established for groundwater at 4 millirems per year to the whole body or any organ. (The average individual exposure from natural background radiation in the United States is approximately 300 millirems per year total effective dose equivalent.)

Can be found at: http://www.nrc.gov/OPA/gmo/nrarcv/01-108.html

§ 20.1402 Radiological criteria for unrestricted use

A site will be considered acceptable for unrestricted use if the residual radioactivity that is distinguishable from background radiation results in a TEDE to an average member of the critical group that does not exceed 25 mrem (0.25 mSv) per year, including that from groundwater sources of drinking water, and the residual radioactivity has been reduced to levels that are as low as reasonably achievable (ALARA). Determination of the levels which are ALARA must take into account consideration of any detriments, such as deaths from transportation accidents, expected to potentially result from decontamination and waste disposal.

If you think about it, far more sites though out the US (including Nevada) and a larger population will be under the higher constraints of 10 CFR Part 20.1402 than those under the proposed 10 CFR 63 for one site.

I also do not know why the yearly exposure limit for member of the public, from a thing that is designed to last 10,000 years (which we have no historical experience with, unless you evaluate rocks), should not be a fraction (greater than 25 percent) of the average background exposure to an individual in the US and that would not exceed that received by a person in the highest background rate in the US. Based on EPA's theory no one should live in Denver, CO, since their (EPA) regulations are derived at a location near sea level. Also, how can a congressperson vote on such a regulation when they work in an area with enhanced radioactive background greater than the EPA limits cited for the repository.