RE: NCRP Releases Report No. 146

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

Thanks for the correction. I agree with you.

 

I should have said, "There is no longer a 15 mrem versus 25 mrem

question."

 

What we found documented was that EPA backed away from using dose in the

late 1990s and attempted to show that 15 mrem/year was about 3 x 10^-4

lifetime cancer incidence for a 30-year exposure. With Federal Guidance

Report No. 13 abandoned dose for Superfund purposes. EPA does have dose

in earlier regulations like the Safe Drinking Water Act. 



- Dan Strom 



The opinions expressed above, if any, are mine alone and have not been

reviewed or approved by Battelle, the Pacific Northwest National

Laboratory, or the U.S. Department of Energy.



Daniel J. Strom, Ph.D., CHP 

Environmental Technology Directorate, Pacific Northwest National

Laboratory 

Mail Stop K3-56, PO BOX 999, Richland, Washington 99352-0999 USA 

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

	From: BLHamrick@aol.com [mailto:BLHamrick@aol.com] 

	Sent: Tuesday, November 23, 2004 5:31 PM

	To: Strom, Daniel J; radsafe@list.vanderbilt.edu;

riskanal@lyris.pnl.gov

	Subject: Re: NCRP Releases Report No. 146

	

	

	

	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