Protection of the Environment under Different Exposure Situations

Draft document: Protection of the Environment under Different Exposure Situations
Submitted by Katharine E. McLellan, Department of Energy
Commenting on behalf of the organisation

Line  220 Paragraph  (g)  This paragraph could be read to contradict the concept of Environmental Reference Level  (ERL) cited on page 5, paragraph (d) line 186.  This section should include a clarification that the Commission does not consider ERLs or even  DCRLs to be dose limits but rather evaluation criteria that under certain circumstances may be exceed such as those noted in paragraph f above. Line 236     There is a misspelling of a word  “intsdcavernational.” 

Glossary:  The following additions need to be made to the glossary:

                  Environmental media

                  Environmental Reference Level

                  Site Assessment

Line 342   Source   The definition of source needs to be redefined within the context of this document.  It          appears that a definition was taken from another document not applicable to this document and reused in the incorrect context.

Line 561  The statement “…the Commission notes that radiation exposure is often not the dominant impact to biota…” should be further explained.  Suggest adding “for example the removal on large quantities of slightly contaminated top soil from a large area could have significant irreversible effects on the ecosystem that are far greater than potential radiological impacts of the contamination.”

Line 869 Paragraph 52 This paragraph should be revised upon consideration of the revised definition for the source which should be changed to reflect the basis of the document as an environmental document and not a medical, research or education source.  As it stands now the paragraph is contradictory to the current definition.

Line 877   Correct the misspelling of the word “furure”

Line 1082 to 1089.  This discussion uses the term “dose standard” to describe the U.S. Department of Energy requirements and process which might be confused with dose limits.  Suggesting clarifying that the referenced standards establish a graded process for demonstrating environmental protection that range from use of simple screening criteria where possible to and ecological evaluation of the impacts when the simpler methods are not sufficient.  The standards do not include dose limits and but like the ERLs  are screening criteria to identify the need for further evaluation.