Re: RE: Threshold

[damm01@GOODNEWS.NET]

> 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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> 

Whatever name you give, when the regulator says 15 mrem IT IS 15 mrem. I can 

remember very well other groups using the term voluntary. If you did not 

volunteer - you were dropped. I am sorry, but that is not voluntary - look in 

any dictionary. The same applies to this so called risk.













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