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Mark--
I
wouldn't say it's a mandate as much as it is precedent (particularly in DOE
venues). If you look at the NRC 'Preamble to Standards for Protection Against
Radiation' (56 FR 23363, May 21, 1991) you will find that the NRC invoked a
(now) superceded set of risk conversion factors for their rulemaking analysis.
Regardless of the numerous arguments about the reasonableness of making the
leap from dose to cancer risk in the LNT region that the proposed MOX
installation would operate, I'd recommend you spend your time commenting on
other aspects of the DEIS. IMHO, that would be a more effective contribution to
the NEPA process (e.g., was the off-spec fuel production alternative properly
dismissed?). I did notice that the MOX DEIS cancer risk conversion
factors have been raised slightly over the previous generation used by both the
NRC and DOE (refer also to DOE's May 1993
"Recommendations for the Preparation of EAs and EISs").
Cheers.
Rick
Orthen
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