Re: 15 or 25 mrem per year?

[BLHamrick@AOL.COM]

In a message dated 2/11/2004 2:30:37 PM Pacific Standard Time, 

ray2hoover@YAHOO.COM writes:

Actually, I think on at least one occasion EPA has agreed to 25 mrem.

Yes, it was the West Valley Demonstration Project in NY.  I have copies 

(somewhere) of the letters from EPA affirming the acceptance of the criteria at 

this site if anyone is interested.



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.

What the MOU actually does is provide criteria, which, if met, requires the 

NRC to consult with the EPA.  The EPA agrees that it "expects" to defer to 

sites not exceeding these criteria, but doesn't really bind the EPA to anything.

The copy of the MOU I have doesn't get specific on doses, so presumably the 

NRC number is the controlling one.

The MOU includes concentrations of radionuclides, which generically 

correspond to a dose of 5 millirem per year at a residential site.

  However, there is a table of permissible contamination levels for 

radionuclides in soil.  How the numbers were devied is not stated.

They appear to have been derived from the EPA's Preliminary Remediation Goals 

calculator.



Barbara L. Hamrick, CHP, JD