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RE: Commenting on USNRC Environmental Impact Statements



Title: Message
I did, in fact, find the NUREG and the comment form on the NRC site.  Thanks.  I'll send a copy of the comments to this list.  I'll probably work with others on this.  The comment period closes April 14. (Are they in cahoots with the IRS ;-)
 
Ted Rockwell
 
-----Original Message-----
From: owner-radsafe@list.vanderbilt.edu [mailto:owner-radsafe@list.vanderbilt.edu]On Behalf Of Jerry Cohen
Sent: Wednesday, February 26, 2003 8:28 PM
To: Chilton, Milton W.; mark.hogue@SRS.GOV; radsafe@list.vanderbilt.edu
Subject: Re: Commenting on USNRC Environmental Impact Statements

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
 
-----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:


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)."