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Letter Report
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From page 1... ... ~ This National Research Council report should be referenced as follows: National Research Council, 1999, Comments on Proposed Radiation Protection Standards for Yucca Mountain, Nevada by the Board on Radioactive Waste Management: Washington, D.C., National Research Council-Board on Radioactive Waste Management. 2 64 Federal Register 46976~7016 (August 27, 1999) Read the entire page →
From page 2... ... The Boarci's objectives in preparing this self-initiated letter report are the following: (1~ to provide a comparison of the technical bases for Yucca Mountain standards recommended by the TYMS report with those proposed by EPA in its draft 40 CFR Part 197 (the "proposed standards"~;6 and (2) where differences are noted, to provide comments on how EPA's draft standards could be changed to make them consistent with the recommendations in the TYMS report. Read the entire page →
From page 3... ... EPA appears to agree with this conclusion. However, some parts of EPA's proposed standards are inconsistent with this conclusion, most notably with respect to estimation and consideration of collective doses, design alternatives to reduce carbon-14 releases from the repository, and a standard for protection of ground water as a resource. Read the entire page →
From page 4... ... TECHNOLOGY-BASED STANDARDS. The TYMS report recommended against imposing repository subsystem performance requirements in the Yucca Mountain standards. Read the entire page →
From page 5... ... Rather, the determination of acceptable risk levels is a policy decision established through the rulemaking process and is based on the risk that the public is willing to bear from potential radiation releases from a repository. Once the level of acceptable risk is established, then a numerical standard (e.g., a dose standard) Read the entire page →
From page 6... ... EPA points out in reason #4 that it was directed by the Energy Policy Act to develop a "dose-based standard." In fact, as noted at the beginning of this report, Congress directed EPA to develop standards that "prescribe the maximum annual effective dose equiva tent to individual members of the public ...." In the Board's view, this directive does not prohibit EPA from basing such a standard on acceptable risk as determined through the rulemaking process. In other words, the TYMS report's recommendation that the form of the individual-protection standard be based on risk does not preclude EPA from expressing the numeric value of the standard in units of risk and in derivative units of dose, so long as the risk value is clearly understood as the underlying basis for the proposed dose standard. Read the entire page →
From page 7... ... The Board strongly recommends that EPA adopt an explicit risk-based individuatprotection standard for Yucca Mountain. Read the entire page →
From page 8... ... 50) lists protection levels in terms of annual dose limits, annualized individual-risk limits, or both, that have been established in the United States by either the USNRC or EPA for a variety of different activities, some similar to and others quite different from the activity associated with Yucca Mountain. Read the entire page →
From page 9... ... upon the unique characteristics of the area around file Yucca Mountain site. Read the entire page →
From page 10... ... we believe that ground water protection for the Yucca Mountain site should focus upon the protection of the ground water as a resource for future human use. it is the genera/ premise of this propose/ that the individua/-protection standard would adequately protect those few current residents closest to the repository. Read the entire page →
From page 11... ... Therefore, the TYMS committee did not consider it necessary to comment on the need for a ground-water standard such as that established in the Safe Drinking Water Act and used in 40 CFR ~ 91: 40 CFR 191 includes a provision to protect ground water from contamination with radioactive materials that is separate from the 40 CFR 191 individua/-dose limits. These provisions have been added to 40 CFR 191 to bring it into conformity with the Safe Drinking Water Act, anc/ have the goa/ of protecting ground wafer es a resource. Read the entire page →
From page 12... ... Given that most if not all of the estimated exposure to radiation from the Yucca Mountain repository is estimated to be through consumption and use of contaminated ground water, the proposed ground-water protection standard appears to duplicate provisions of the individual-protection standard. However, because the ground-water standard does not necessarily apply at the same location as the individual-protection standard, its application to Yucca Mountain lacks overall consistency and coherence. Read the entire page →
From page 13... ... policy choice and should be acknowledged as such. Given that the proposed EPA standard requires that the performance of the disposal system be examined after 10,000 years if the peak dose is calculated to occur then, there may be little practical difference between the TYMS report's recommendations and the proposed EPA standards. Read the entire page →
From page 14... ... We a/so believe that ca/cu/ations of this type might be informative in the sense that they can provide usefu/ insight into the degree to which the ability of a repository to protect public health would be degraded by intrusion. For these reasons, to address the human intrusion issue on an aclequate basis, we recommend that ... Read the entire page →
From page 15... ... CONCLUDING OBSERVATIONS. The Congress recognized the special role of the National Academies in providing scientific advice to EPA for use in establishing radiation protection standards for Yucca Mountain. Read the entire page →
From page 16... ... EPA's requirement that collective dose be estimated and considered is inconsistent with both the TYMS report and with EPA's conclusion that additional standards are not needed to protect the general public. Further, EPA's urging of DOE to seek design alternatives to reduce gaseous carbon-14 releases, even when individualdose limits have been satisfied, is also without a firm scientific basis and could be interpreted as an attempt to apply ALARA, which was rejected by the TYMS committee because it lacks a scientific basis. Read the entire page →

From page 1...

... ~ This National Research Council report should be referenced as follows: National Research Council, 1999, Comments on Proposed Radiation Protection Standards for Yucca Mountain, Nevada by the Board on Radioactive Waste Management: Washington, D.C., National Research Council-Board on Radioactive Waste Management. 2 64 Federal Register 46976~7016 (August 27, 1999)

Letter Report Pages 1-16

Letter Report
Pages 1-16