[ RadSafe ] EPA revision to 40CFR190

[Brennan, Mike (DOH)]

The original EPA Standards were based on the assumption that there would be a robust spent fuel reprocessing industry that would be releasing gaseous fission fragments to the air.  This is why they used "activity per gigawatt" release limits.  However, no reprocessing; no releases (accidents don't count under these standards).  

To my mind the most interesting change they are looking at is to go to "risk based" standards.  I see some non-trivial technical challenges.  If you decide your risk standard is going to be one-in-a-million (a choice that is hard to defend from at least three directions that I see), then you are faced with the fact that there are no instruments or lab analysis that produce results in "risk".  So you have to go to activity, measured by field instruments or more likely in the lab.  The results in CPM or pCi/some unit then have to have a bunch of assumptions applied to get to "risk".  If I were being cynical I would say that the best argument for risk based standards is that you can change the assumptions to get the dose/activity levels desired.

-----Original Message-----
From: radsafe-bounces at health.phys.iit.edu [mailto:radsafe-bounces at health.phys.iit.edu] On Behalf Of Johansen, Kjell
Sent: Wednesday, August 06, 2014 10:56 AM
To: 'radsafe at health.phys.iit.edu'
Subject: Re: [ RadSafe ] EPA revision to 40CFR190

In June I attended a workshop at which the EPA made a presentation about revising Part 190 with respect to current science.  When I asked whether the revision would still use LNT which is not scientific because it extrapolates into areas in which no negative dose response has been documented, I was told that the EPA would be using LNT.

Just my own thoughts and may not reflect the opinions of my company.

Kjell Johansen
Sr. Nuclear Chemistry Analyst
Point Beach Nuclear Plant -NextEra Energy
6610 Nulcear Rd
Two Rivers, WI 54241
Phone 920-755-6869
kjell.johansen at nee.com

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