NOTE TO DOCKET

Date:		March 30, 2006

From:		Ray Clark, Team Leader

		Yucca Mountain Standards Project

		Radiation Protection Division, EPA

To:		Docket OAR-2005-0083

	Rulemaking:  Revisions to Yucca Mountain Public Health and
Environmental Radiation Protection Standards (40 CFR Part 197)

Subject:	Meeting Summary of the March 27, 2006 meeting with

the Alliance for Nuclear Accountability

The purpose of this memorandum is to document the attendees and
discussions at a meeting between Environmental Protection Agency (EPA)
staff and representatives of the Alliance for Nuclear Accountability
(ANA) on March 27, 2006, to discuss issues raised by ANA regarding
EPA’s proposed amendments to Public Health and Environmental Radiation
Protection Standards for Yucca Mountain, NV.  Other topics related to
EPA’s radiation protection programs and responsibilities, but
unrelated to Yucca Mountain, were also discussed, but are not summarized
in this memorandum.

The attendance list for the meeting is attached.

The first issued raised by ANA was the proposed post-10,000-year
radiation dose rate limit – 350 millirem per year (mrem/yr).  The ANA
representatives urged that we lower that limit, particularly it noted
that in the past any level higher than 15 mrem/yr was unacceptable. 
Even the dose restriction of 100 mrem/yr from all sources is less than
the proposed limit for Yucca Mountain.  The ANA said it would send a
report by Dr. Mike McNally that explores the cancer risk from 350
mrem/yr (a purported 1/14 for men and 1/10 for women).  EPA responded
that we would like to see the supporting documentation promised by ANA
and that we are considering the dose rate limit.

The second issue was EPA proposing not to extend the ground-water
protection standards’ compliance period past 10,000 years.  It should
be extended because the ground water will be more contaminated after
10,000 years.

The third issue was compliance with Executive Orders.  The ANA believes
that EPA’s efforts at Tribal consultation did not fulfill Executive
Order 13175.  The EPA responded that meetings had been held and that
comments were formally accepted from Tribes until the end of 2005.  The
EPA asked how releases from Yucca Mountain could affect tribes when
there were no known tribes living in the likely pathway of the releases.
 The ANA responded that they could live there in the future.  The ANA
also questioned whether EPA had paid sufficient attention to radiation
impacts on children, pregnant women, and the elderly (Executive Order
13045).  EPA responded that its risk values take both genders and all
ages into account.  However, we will address the issue further in our
response-to-comments document.

The ANA questioned why EPA had not held hearings in the Reno/Carson City
area.  EPA responded that a potential of small attendance and limited
resources resulted in a decision not to hold hearings other than in
Amargosa Valley, Las Vegas, and Washington, DC. 

The ANA voiced concerns that nearly all of their mass mailing submittals
were not listed in the docket.  The EPA responded that it was the Docket
Section’s policy to post a representative version of identical letters
and then list a count of the number received.  Some members of ANA
voiced further concerns with that policy and that they have never had
success trying to contact anyone in charge of dockets.  The EPA then
said that it would find a contact and forward it to Joni Arends (that
was completed on 3/29/06).  The ANA said that some people had added
personal comments to the form letters.  The Agency committed to
examining all individual submittals.

