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The Symposium
Pages 8-18

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From page 8...
... Yucca Mountain is far from a license application as DOE commences investigation of the geology of the mountain. At this point, the Yucca Mountain Project faces many stumbling blocks before it can tackle the intricacies of the USNRC licens.
From page 9...
... . The Standard is unnecessarily stringent compared with similar standards for disposal of hazardous chemical waste, especially considering the level of unavoidable background radiation that exists, both naturally occurring and man-made.
From page 10...
... PROBABILISTIC RELEASE STANDARDS VS. INDIVIDUAL DOSE LIMITS Much opposition was expressed to EPA's selection of probabilistic re
From page 11...
... Another reason given to support annual dose limits to individuals is the difficulty of determining the relative merits of any specific site by using the EPA probabilistic release limits. Various groups found insufficient EPA's explanation of how the generic standards were derived from the upperbound population health risk goal; they requested that further clarification of the limits be provided and, if probabilistic release limits are to be retained, that these limits become secondary to a primary annual risk or doselimit standard.
From page 12...
... Second, EPA points out that probabilistic limits on total releases over time from a repository present a quantitative standard against which the criterion of success may be more readily measured. Use of individual annual dose limits over long time periods would complicate the analytical task, again probabilistically, by requiring predictions of environmental events, human behavior, and exposure pathways to people on a year-by-year, multigenerational basis.
From page 13...
... On the other hand, some speakers suggested that the Standard is not too stringent with respect to acceptable levels of risk, and might even require tightening, in view of both increased estimates of health effects from low doses of radiation and improvements in waste containment theory and technology. EPA explained at the symposium that public acceptance is an important factor in setting regulatory limits, and the agency is confident that the requirements are perceived by most people as adequately protecting human
From page 14...
... Dan Reicher, of the Natural Resources Defense Council, suggested that if the existing licensing approach is abandoned the process might have to be started over with a new set of potential repository sites. He said that otherwise the public would perceive any effort to alter the regulatory process as an attempt to protect the current potential sites—WIPP and Yucca Mountain from possible failure under the present Standard.
From page 15...
... At the symposium, Curtiss emphasized the significance of the discrepancy between the EPA release limits and the USNRC subsystem criteria specifying geological and container limits. The USNRC's methodology is deterministic, specifying quantitative criteria for multiple barrier performance, while the EPA's Standard is probabilistic, based on CCDFs for containment limits.
From page 16...
... RESOLVE conducted preliminary interviews with EPA, USNRC, DOE, the Edison Electric Institute, the Electric Power Research Institute, and the Natural Resources Defense Council. Although EPA was eager to enter into negotiated rulemaking, RESOLVE could not recommend that they take that action.
From page 17...
... The European representatives acknowledged that their countries will likely have the same problems as the United States in convincing the public to accept a repository, but public opposition is building more slowly. Another major difference among the programs is that the United States is the only country using a population risk concept and radionuclide release limits instead of limits on individual doses or risks to members of the public.
From page 18...
... In the absence of a generally accepted public health and safety goal for the Standard governing geologic repositories, major concerns to be resolved include whether the regulatory agencies, in striving for health and environmental protection, can require the applicant to do less than the maximum that is technically feasible, and whether standards/regulations for disposal of HLRW should be promulgated to balance safety/risk and cost.


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