Re: Commenting on USNRC Environmental Impact Statements

[RuthWeiner@AOL.COM]

I am going to respond in two parts


In a message dated 2/26/03 1:20:10 PM Mountain Standard Time, mark.hogue@SRS.GOV writes:


> 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)." 



There is something wrong here.  The factor usually used is 0.0005 LFC/person-rem, although EPA is trying to push through 0.000575.  5E-4 LCF per person-rem = 0.05 LCF/person Sv.


> 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. 


"Deaths" -- actually called "latent cancer fatalities" (which should be "latent fatal cancers"...) are calculated this way in every NRC and DOE EIS or EA.  It was a mighty struggle to get DOE to report doses along with LCF -- for a while they just reported LCF.  It is the same old mindless use of the LNT.  But there is hope!!  NRC/NRR, the research branch of NRC, is beginning to examine the possibility of a threshold.  Can any NRc person comment on this?  I heard it about third hand and maybe just want to believe it.


Ruth


Ruth Weiner, Ph. D.

ruthweiner@aol.com