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RE: 15 or 25 mrem per year?



An interesting note to this discussion and one that emphasizes Bills point

below, Several years ago (around 1997) I was working on a decommissioning

project and had to develop site release criteria that would satisfy bith NRC

and EPA regquirements at the time.  I started by treating them seperately

and developed limits using the best NRC guidance at the time (i.e., DandD

and RESRAD codes using all pathways and 25 mrem/yr).  I then developed a set

of limits for my nuclides of concern using the best EPA guidance (EPA Risk

Assesment Guide Part B if I remember).



Anyway, in the end, the isotopic limits using NRC Guidance (all pathways)

and the 25 mrem/yr WERE MORE RESTRICTIVE (i.e., lower) than the EPA limits

using EPA guidance and the 15 mrem per year. Note - I think there was one

out of about 5 or 7 nuclides where the EPA limit was less.  



Ever since then, I could only laugh at the endless debate between 15 and 25

mrem per year (and try not to think about my tax dollars being wasted on the

issue).



We are spending millions over pennies in my opinion.



Jim B 



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

From: William V Lipton [mailto:liptonw@DTEENERGY.COM]

Sent: Wednesday, February 11, 2004 3:39 PM

To: jjcohen

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

Subject: Re: 15 or 25 mrem per year?





>From a practical (regulatory/legal) standpoint it makes a big difference.

You

could terminate your NRC license, but still have EPA designate your facility

as

a NPL (Superfund) site.  Big $$.



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

limit is pathway specific.



The opinions expressed are strictly mine.

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

Curies forever.



Bill Lipton

liptonw@dteenergy.com



jjcohen 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) <redmondrr@Y12.doe.gov>

> To: <radsafe@list.vanderbilt.edu>

> 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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