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To the Editor:
In their comment on Yucca Mountain radiation standards, Robert and Susanne Vandenbosch give insufficient attention to the context in which such standards are applied (P&S, January, 2009).
When NRC applies safety standards, the usual practice is to make conservative assumptions about what is unknown. As one looks into the more distant future, uncertainties grow, and therefore an increasing number of conservative assumptions go into predictions. To some degree, this makes the resulting predictions more conservative. In a standard that unavoidably represents a compromise among competing public policy goals, testing more conservative predictions against less stringent thresholds is a reasonable way to arrive at consistent compromises. One can surely disagree with EPA's judgment about the degree of change in conservatism over time, but the Vandenbosches are wrong to dismiss the entire concept as illogical.
In regulating chemical wastes, EPA has chosen (with a few exceptions, mainly one for deep well injection of hazardous wastes) to require predictions only for 30 years into the future. Furthermore, in my experience the models used to predict exposures to chemical wastes are applied with much less conservatism than the models used for radioactive wastes.
Our society has unfortunately a long way to go to reach full sustainability in its waste disposal activities. Nuclear energy is much farther along in that quest than fossil fuel use, chemical production, and many other industrial activities. We should insist on steadily improving standards of waste management in all of these areas, but we need to be realistic in what we ask for. If we strangle nuclear power with unsatisfiable demands and cause coal or oil to be used instead, we are making the perfect the enemy of the good.
Disposal Safety Inc., Washington, DC
This contribution has not been peer refereed. It represents solely the view(s) of the author(s) and not necessarily the views of APS.