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Moeller, Dade W.*

doi: 10.1097/HP.0b013e3181ae8ab3
Lauriston S. Taylor Lecture: Special Submission

The Yucca Mountain high-level radioactive waste repository is designed to contain spent nuclear fuel and vitrified fission products. Due to the fact that it will be the first such facility constructed anywhere in the world, it has proved to be one in which multiple organizations, most prominently the U.S. Congress, are exercising a role. In addition to selecting a site for the facility, Congress specified that the U.S. Environmental Protection Agency (U.S. EPA) promulgate the associated Standards, the U.S. Nuclear Regulatory Commission establish applicable Regulations to implement the Standards, and the U.S. Department of Energy (U.S. DOE) design, construct, and operate the repository. Congress also specified that U.S. EPA request that the National Academy of Sciences (NAS) provide them guidance on the form and nature of the Standards. In so doing, Congress also stipulated that the Standards be expressed in terms of an “equivalent dose rate.” As will be noted, this subsequently introduced serious complications. Due to the inputs of so many groups, and the fact that the NAS recommendations conflicted with the Congressional stipulation that the limits be expressed in terms of a dose rate, the outcome is a set of Standards that not only does not comply with the NAS recommendations, but also is neither integrated, nor consistent. The initial goals of this paper are to provide an independent risk/dose analysis for each of the eight radionuclides that are to be regulated, and to evaluate them in terms of the Standards. These efforts reveal that the Standards are neither workable nor capable of being implemented. The concluding portions of the paper provide guidance that, if successfully implemented, would enable U.S. DOE to complete the construction of the repository and operate it in accordance with the recommendations of NAS while, at the same time, provide a better, more accurate, understanding of its potential risks to the public. This facility is too important to the U.S. nuclear energy program to be impeded by inappropriate Standards and unnecessary regulatory restrictions. As will be noted, the sources of essentially all of the recommendations suggested in this paper were derived through applications of the principles of good science, and the benefits of “thinking outside the box.”

* Dade W. Moelller and Associates, Inc., 257 River Island Road, New Bern, NC 28562-3669.

For correspondence contact the author at the above address, or email at

(Manuscript accepted 15 May 2009)

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