Re: NCRP Releases Report No. 146

[BLHamrick@AOL.COM]

In a message dated 11/23/2004 2:39:42 PM Pacific Standard Time,  

strom@PNL.GOV writes:



EPA

does not use dose! There never really was a "15 mrem versus 25  mrem

controversy," since EPA doesn't use millirems.





This is not quite accurate.  In May 1994 EPA issued a draft  regulation, 

"Radiation Site Cleanup Regulation," which included the 15 millirem  per year dose 

standard, as well as the 4 millirem per year limit of dose from  drinking 

water, which is still a dose standard, as are the air emissions  standards.  They 

abandoned this rulemaking in 1996, according to the  Government Accounting 

Office, "after other agencies objected to [the proposed  standards]."

 

In addition, NRC's original License Termination Rule (59 FR 43200, August  

22, 1994) included a 15 millirem per year limit.  EPA commented on this  

proposed rule, agreeing that 15 millirem per year was an acceptable  criteria.  When 

the final rule was published, July 21, 1997 by NRC, the  criterion had become 

25 millirem per year, and the sparks began to fly.  In  an attachment to an 

August 22, 1997 Office of Solid Waste and Emergency  Response memorandum, the 

EPA takes NRC to task for not providing appropriate  justification for the 25 

millirem per year criterion, then goes on to state that  at the outside 15 

millirem per year is acceptable.  

 

There definitely was a 15 millirem vs. 25 millirem controversy.  It's  very 

well documented.

 

Barbara L. Hamrick