Re: 15 or 25 mrem per year?

["Phil Rutherford" <email@philrutherford.com>]

The MOU to which Ray refers, specifies soil concentrations for a risk level of 10-4 for both suburban residential and industrial use sceanarios.  The EPA does not agree to 25 mrem/y in the MOU.  The soil concentrations were calculated with the EPA's Preliminary Redmediation Goal (PRG) Calculator.  The PRG Calculator usually defaults to 10-6 risk level (point of departure for CERCLA Superfand cleanup process).  Therefore the EPA is effectively agreeing in this MOU that 10-4 risk levels are fully protective of public health.  That's a big win for those of us who are facing activist/legislator/EPA pressure to cleanup to 10-6. 



If you are a LNT believer, then 10-4 risk would be equivalent to ~ 5 mrem/y (non isotope specific), not 15 mrem/y (risk of 3x10-4) and not 25 mrem/y (risk of 5x10-4).  Of course none of us believe the LNT model should be applied at these low levels anyway ... right???



Phil Rutherford

email@philrutherford.com

www.philrutherford.com

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

  From: Raymond A Hoover 

  To: jjcohen ; Redmond, Randy (RXQ) ; radsafe@list.vanderbilt.edu 

  Sent: Wednesday, February 11, 2004 2:29 PM

  Subject: Re: 15 or 25 mrem per year?





  Considering all the uncertainties in the calculations, it should not make a bit of difference.  Of course the folks at the EPA would then insist that conservative is better.



  Actually, I think on at least one occasion EPA has agreed to 25 mrem. On October 10, 2002, NRC News No 02-120 was released in which the NRC announced that that the NRC and EPA had reached an agreement in which the EPA agreed to defer exercise of authority under CERCLA Act for the majority of NRC facilities to be decomissioned.  This I have taken to mean that they are not going to argue with the NRC.  The copy of the MOU I have doesn't get specific on doses, so presumably the NRC number is the controlling one.  However, there is a table of permissible contamination levels for radionuclides in soil.  How the numbers were devied is not stated.



  jjcohen <jjcohen@PRODIGY.NET> wrote:

    From a practical (health and safety) standpoint, what difference would it

    make whether a 15 or 25 mrem/yr limit is applied? Just curious------



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

    From: Redmond, Randy (RXQ) 

    To: 

    Sent: Wednesday, February 11, 2004 11:15 AM

    Subject: Authorized Limit(s) for Annual Dose from Release of Property





    > Need a quick answer and have failed to find it through a search (too many

    > hits and too little time) - Did the NRC and EPA ever settle on an

    authorized

    > limit for annual dose for release of real property? 25 millirem per year?

    > EPA still pushing 15 millirem per year?

    >

    > Thanks,

    >

    > Randy Redmond (32458)

    > Radiological Control Organization

    > BWXT Y-12 L.L.C.

    > Oak Ridge, TN

    > 865-574-5640

    >

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