Re: 15 or 25 mrem per year?

[William V Lipton <liptonw@DTEENERGY.COM>]

Before this thread gets completely out of hand, I suggest that anyone wishing to

comment, first read the MOU, to which a previous Radsafer thoughtfully provided

the link.



Some key excerpts:



III.  "... as EPA indicated in the Federal Register notice announcing the policy

of CERCLA deferral to NRC, if EPA 'determines that sites which it has not listed

as a matter of policy are not being properly responded to, the Agency will

consider listing those sites on the NPL [Superfund list]'  (see 48 FR 40658)"



V.C.2:  "For NRC-licensed sites at which NRC determines during the license

termination process that there is radioactive ground water contamination in

excess of EPA's MCLs, or for which NRC contemplates either restricted release

(10 CFR 20.1403, or the use of alternate criteria for license termination (10

CFR 20.1404), NRC will seek EPA's expertise to assist in NRC's review of a

decommisioning or license termination plan..."



V.C.3:  "NRC will defer to EPA regarding matters involving hazardous materials

not under NRC's jurisdiction."



The bottom line:



1.  EPA maintains jurisdiction for non NRC-licensed, hazardous materials at a

site being decommissioned.



2.  EPA reserves the right to assert CERCLA [Superfund] jurisdiction over NRC

licensed materials.  It is especially concerned about sites being released under

the restricted or alternate criteria.



3.  If decommissioning a site, it would be foolish to attempt license

termination without meeting the MOU, Table 1 criteria.  Also, this MOU appears

to make the use of restricted release or alternate criteria impractical.



The opinions expressed are strictly mine.

It's not about dose, it's about trust.

Curies forever.



Bill Lipton

liptonw@dteenergy.com



HP Dean wrote:



> Bill,

>

> > Note:  Keep in mind that the NRC limit includes all pathways, while the

> EPA

> > limit is pathway specific.

>

> Since the NRC limits only deal with radioactive materials, it begs the

> question as to whether or not the EPA risk assessment ignore chemicals as

> well when they are dealing with radioactive materials, or is some total site

> risk calculated?

>

> Since many site involve both toxic and radioactive materials, maybe someone

> out there can comment on EPAs total site risk concept, if one exists.

>

> Dean Chaney, CHP

>

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