RE: Commenting on USNRC Environmental Impact Statements

["Chilton, Milton W." <chilton@NV.DOE.GOV>]

Title: Message

Mark, you might want to check out the Health Physics Society position papers. They have come out with a position on this and as I recall they do discourage the use of individual doses of less than 10 REM in calculating health effects.

 

However, my impression is the recommendation has not been implemented to any extent within the nuclear industry and especially DOE. I imagine that 1) People are unaware of the recommendation; 2) The old assumptions are hardwired into the assessment process and no one has tried/or been able to change the assumptions used; and 3) The easy way to ?prove? conservatism is to continue to use the LNT approach.

 

Best of luck.

 

 

Milton Chilton, CHP

NNSA/NSO

Emergency Management Coordinator

702-295-5755

chilton@nv.doe.gov

 

-----Original Message-----
From: mark.hogue@SRS.GOV [mailto:mark.hogue@SRS.GOV]
Sent: Wednesday, February 26, 2003 11:51 AM
To: radsafe@list.vanderbilt.edu
Subject: Commenting on USNRC Environmental Impact Statements

I'm interested in commenting on a recent NRC Environmental Impact Statement (released for public comment) and would like input from Radsafe on the following:

The EIS I'm looking at is
"Environmental Impact
Statement on the
Construction and
Operation of a Mixed Oxide
Fuel Fabrication Facility at
the Savannah River Site,
South Carolina"

It has the number NUREG-1767.

It includes the following note: "c: Latent cancer fatalities are calculated by multiplying dose by the Federal Guidance Report 24
(FGR) 13 health risk conversion factor of 0.06 fatal cancer per person-Sv (6 × 10-4 fatal cancer per person- 25
rem) (Eckerman et al. 1999)."

The question is this: Is the process of  calculating deaths in this fashion really a mandate to the NRC? I would think that in light of much discussion to the contrary, that a threshold value should be used.

Please, I am not trying to start a rant on LNT. If anyone can help me research this a bit, I would just like to make a helpful and useful comment to the NRC.

Mark G. Hogue, CHP
mark.hogue@srs.gov
"But we surely overrate the usefulness of what we like to call "stimulation" and underrate the need for time, peace of mind, mature reflection." -  Susan Haack

"DISCLAIMER: The opinions expressed are mine and do not necessarily represent Westinghouse Savannah River Co. or the United States Department of Energy."