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Milton,
You make an interesting suggestion.
Suppose, by some bureaucratic miracle, the EPA,
and NRC were to accept the HPS position and rescind all policies and
regulations based on calculation of risk (health effects) to those receiving
doses below 5.0 rem/a or 10.0 rem/lifetime. The implication of such a change
would likely be profound, if not revolutionary.
First, the concept of collective dose
would be abandoned, and ALARA would be on shaky ground. The practice of
estimating the number of cancer cases resulting from radiation related events
would be halted. Limitations such as cleanup regulations calling for levels
<15 mrem/a would seem ridiculous. Imagine that! Many, if not most
radsafe professionals would need to seek employment elsewhere.
In today's emailbag, a message from Les
Aldrich claims that it is our responsibility to not scare the public with
warnings about hazards that do not exist. Considering our current policies
and regulations, I thought that was our raison d'etre.
Nice try Milton, but it ain't going to
happen.
Jerry Cohen
----- Original Message -----
Sent: Wednesday, February 26, 2003 12:26
PM
Subject: RE: Commenting on USNRC
Environmental Impact Statements
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
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:
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 в 10-4 fatal cancer
per person- 25
rem) (Eckerman
et al. 1999)."
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