IEER
Science for Democratic Action Vol. 4 No. 4
Calculating Doses from Disposal of High-Level Radioactive Waste
Section V: Professor Pigford's Dissent
The central points of Pigford's dissent (in Appendix E of the report) are as follows:
- The committee majority has abandoned the subsistence farmer scenario which is the surest, most conservative method for protecting all future populations. It is in conformity with the recommendations of the ICRP. It is also the radiation protection method of choice worldwide, including in the United States, Britain, Sweden, Switzerland, Finland, and Canada. He cites the British National Radiological Protection Board's advice, for instance, according to which the critical group would consist of people "at the place where the relevant environmental concentrations are highest, and [who] have habits such that their exposure is representative of the highest exposures that might reasonably be expected."
- "There is consensus that the subsistence-farmer approach is consistent with the critical group concept." Pigford cites several examples, including one in which the U.S. Nuclear Regulatory Commission used a subsistence farmer family of three as the critical group.
- The probabilistic critical group approach recommended by the majority "is demonstrably less stringent in protecting public health than the subsistence farmer approach." The example of the farming community in the Amargosa Valley used by the committee majority would contain part-time farmers, but "the full-time subsistence farmer will not be found on that distribution." The probabilistic critical group method is not in conformity with the recommendations of the ICRP.
- The method is subject to manipulation because it permits arbitrary choices of parameters such as population characteristics and sizes of subareas. Such choices could lower the calculated doses which would provide "an illusion of safety, but with a serious loss of credibility."
- The "[c]alculational techniques described in Appendix C are not mathematically valid."
In a later explanatory note, Pigford noted that the method "would introduce unjustified and unprecedented leniency in public health protection from radioactive waste." He concluded that the "probabilistic exposure scenario will be perceived by many as a disguised means of reducing the calculated individual doses below the high values (ca. 10 rem/year) that were presented to the committee. Better repository design is the proper means of obtaining low doses, not by nonscientific policy fixes. Policy makers must reject pressures for short-term expediency and economy, lest, by enacting policy that compromises scientific validity and credibility, it undermines public confidence and puts an end to all further nuclear development and research." (8)
Indeed, the calculational procedure set forth by the committee majority could allow for the exclusion of the subsistence farmer entirely (see below). In that case, the NAS committee would extend the definition of people with "unusual habits" from those whose diet consists almost entirely of clams to subsistence farmers, which is one of the most common occupations in the world today.
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Revised March 21, 1996