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OCR for page 187
APPENDIX F
THE COMMITTEE CHAIR'S PERSPECTIVE ON
APPENDIX E
ROBERT W. FRI
In Appendixes C and D, we have presented alternative approaches
that EPA might wish to consider in selecting an exposure scenario to be
user} in calculating compliance with the standards. As noted in Chapter 3
of the report, these approaches differ chiefly in the assumptions ant!
calculational methods used in estimating the exposure of future persons
who might be near the repository site. However, there is little scientific
basis for predicting events far into the future, such as where people will
live, and so developing an exposure scenario for testing repository
compliance with the standards is inherently a policy choice.
Throughout our report, we have avoided making recommendations
that involve policy choices on the grounds that there is by definition a
limited scientific basis for selecting one policy alternative over another.
We have instead tried to use available technical information and judgment
to suggest a starting point for the rulemaking process that will lead to a
policy decision. As noted in Chapter 3, a majority of the committee
considers the approach of Appendix C to be more clearly consistent with
the technical criteria that clefine the critical group in the exposure scenario,
and therefore believes that EPA shouicl propose an approach along the lines
of Appenclix C. The committee recognizes, however, that other approaches
might meet these criteria.
I believe that, in his personal statement, Dr. Pigford has become an
advocate for a particular choice. He clearly prefers the approach of
Appendix D and presents arguments both for his position and against the
alternative. He is of course entitled to make this argument. It is important,
however, to understand that the argument being presented is fundamentally
a policy argument rather than a scientific one.
Nevertheless, the issue raised here is an important one. Dr.
Pigford advocates an assumption that results, in his words, in calculating
" .the extreme of the actual closes in the entire population". In contrast,
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188
YUCCA MOUN7CAINSTANDARDS
Chapter 2 of the report adopts the basic principle of the International
Commission for Radiological Protection that the standard should avoid
". . tan extreme case defined by unreasonable assumptions regarding factors
affecting dose and risk". Although Appendix D ant! Dr. Pigford postulate
a subsistence-farmer scenario based on cautious, but reasonable,
assumptions (as described in Chapter 2), some members of the committee
believe that the approach Equivocated by Dr. Pigford could become just such
an extreme case.
Determining when the assumptions in an exposure scenario pass
from cautious to extreme is thus a crucial issue in the rulemak~ng process.
As such, it requires the fieriest ant] most open public discussion.
Representative terms from entire chapter:
approach equivocated
