Institute for Energy and Environmental Research
Science for Democratic Action Vol. 4 No. 4The NAS committee majority proposes to set aside the concept of setting secondary measurable standards in favor of limiting the risk to a critical group as defined in a new way (see below for further details). The principal argument for such a standard is that it directly addresses the thing we most want to limit: risk of damage to health, including cancer risk. In fact, the NAS committee is explicit that it does not include the current goal of protecting ground water as a resource in its recommendations. The report states that the current EPA regulation for high-level waste disposal,
If the EPA adopts the committee's proposal, there would be no explicit limits to the contamination of groundwater as such. It would be legally permissible for water to become highly contaminated, depending largely on the way the critical group was selected. The consequent radiation doses to some of the people using contaminated water could be very high."40 CFR 191, includes a provision to protect ground water from contamination with radioactive materials that is separate from the 40 CFR 191 individual-dose limits. These provisions have been added to 40 CFR 191 to bring it into conformity with the Safe Drinking Water Act, and have the goal of protecting ground water as a resource. We make no such recommendation, and have based our recommendations on those requirements necessary to limit risks to individuals." (p. 121)
The possibility of very high radiation doses, far above allowable limits, from consumption and agricultural use of water contaminated by a high-level waste repository at Yucca Mountain is real. Since water is scarce in the area, there is only a relatively small volume available (compared to other repository locations) to dilute leaking radionuclides (pp. 27-28 of the NAS report). A 1983 National Academy of Sciences study on repository disposal of nuclear waste estimated that peak doses could range from a low on the order of one rem (perhaps less) to about 1,000 rem per year depending on assumptions about the behavior of the waste and water travel time. (7) More recent studies done by Sandia National Laboratory and INTERA, both Yucca Mountain Project contractors, also estimate that peak doses from using water contaminated by a Yucca Mountain repository could be high. (See centerfold.)
Institute for Energy and Environmental Research
Comments to Outreach Coordinator, Pat Ortmeyer: ieer@ieer.org
Takoma Park, Maryland, USA
Revised March 21, 1996