15 v. 25? EPA does not use millirems under Superfund

["Strom, Daniel J" <strom@PNL.GOV>]

RADSAFErs,



It has been brought to my attention that EPA doesn't use millirems in

its decisions to clean up Superfund sites, and that the EPA approach

differs from that of the NRC under its license termination rule. 



The EPA begins with risk goals of 1E-6 to 1E-4 lifetime cancer incidence

for individuals as the residual risk from a Superfund cleanup (which

includes risks from residual chemicals and radioactive materials). EPA

then applies 9 balancing and modifying factors and criteria, in concert

with public and other stake holders, to arrive at Record of Decision

about a remediation plan, economic and social factors being taken into

account. EPA doesn't use 15 mrems, and essentially never has. EPA uses

Federal Guidance Report 13

(http://www.epa.gov/radiation/federal/docs/fgr13.pdf) intake to risk

coefficients.



NRC, under its license termination rule, sets a dose constraint for

unrestricted release of 25 millirems per year (which millirems include

cancer incidence, cancer mortality, and heritable ill-health) to a

likely maximally exposed individual, and then pushes for additional

cleanup until the result is ALARA.  Given the social and economic

considerations in ALARA, it may not surprise anyone that EPA and NRC may

often wind up in the same place using these two vastly different

approaches.



A guy named David C. Kocher has published these ideas in several places

over the past few years; all are accessible to HPs.



In my view, a really competent and diverse group of folks on an NCRP

committee has recently drafted a report on all of this, and I encourage

RADSAFErs interested in this topic to read it when it appears in June of

2004.



- Dan Strom

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