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RE: Commenting on USNRC Environmental Impact Statements



Excellent Doug.  Using language similar to yours, that's the route

'enlightened' NEPA documents map out to address the scientific uncertainties

underpinning radiogenic cancer risk estimates. IMHO, there's nothing wrong

with that route as it lays the cards on the table.  Right or wrong, the

reality is there are few NEPA documents published at the truncated

(surrogate) dose level. Understanding that, it's preferable and far more

productive to, for example, identify improvements that result in more

reliable estimates of dose likelihood and magnitude.  That's what a NEPA

document manager really wants to have in-hand to enable decision makers to

compare alternatives fairly and select the environmentally-preferable

alternative.



Rick Orthen







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