Re: RE: Threshold

[BLHamrick@AOL.COM]

Just FYI - EPA does NOT have limits for "decommissioning."  EPA defines the CERCLA process in 40 CFR 300, and discusses that the lead agency should CONSIDER the risk range 1E-4 to 1E-6 during the feasibility phase prior to cleanup, when establishing appropriate criteria, WHERE THERE ARE NO APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs).



EPA has stated that a risk of 3E-4 (as they calculate 15 millirem per year) is WITHIN the risk range of 1E-4 to 1E-6.  EPA has also stated that the risk range includes, BUT IS NOT LIMITED TO, 1E-4 to 1E-6 (see OSWER 9272.0-15P).  They have imposed dose limits under certain other circumstances, such as at Yucca Mountain (15 mrem/yr), in the NESHAPS rule (10 mrem/yr), and other specific cases, but they DO NOT have a decommissioning dose limit.



In addition, the EPA has never amended the published federal guidance issued in 1960 by the Federal Radiation Council, advising that public doses should be maintained below 500 millirem per year.  This is still the "official" federal guidance.



Just wanted to clarify.



Barbara



<<I was talking about the current regulations for current NRC licensees, not

BRC.  And the EPA limits are for decommissioning. 



-- John 



-----Original Message-----

From: Ted de Castro [mailto:tdc@xrayted.com]

Sent: Friday, April 19, 2002 12:47 PM

To: Jacobus, John (OD/ORS)

Cc: radsafe@list.vanderbilt.edu

Subject: Re: Threshold





are you SURE??



As I recall the original BRC proposal was for 1 mR/year!  And aren't

there EPA limits of 10 or 15 mR/year?>>

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