Re[2]: Solubility

[Al_Jackson@pmlmail.engin.umich.edu]

Radsafers,

I made the following comments to NRC regarding the sanitary sewer rules...

As far as I can tell they were ignored.

I do not believe that NRC used a reasonable basis for excluding insoluble sewer 
releases.  For example, how is solubility defined?  Any solution will 
precipitate when present in sufficiently high concentrations (such as at a waste 
water treatment plant).  I believe that the regulatory limits which govern the 
release of radioactive material should be based entirely on the expected 
radiation dose equivalent to the public.  Insoluble radioactive materials will 
tend to accumulate at waste water treatment plants along with other insoluble 
non radioactive materials such as heavy metals.  Sludges from a waste water 
treatment plant are currently handled with care since they present pathogenic 
and chemical toxicity risks.  This process of trapping pollutants is precisely 
how a good waste water treatment plant should work.  I sense that detection of 
radioactive materials at a waste water treatment plant is somewhat of a public 
relations problem for NRC since its rules allowed detectable releases.  

I do not believe that rules should be based on detectability, a perception of 
the public opinion, or on convenience to the Commission.  A sufficiently 
sophisticated radiation detection system could detect even low level "soluble" 
releases.  Furthermore, detection limits are likely to improve over time.  This 
makes basing a limit on detection a moving target.   Secondly, public opinion is 
difficult to measure and bound to change.  Finally, convenience to itself is a 
self serving and unreasonable process.  Ultimately, NRC is a servant of the 
public.  I think that NRC should base these release concentrations on modeling 
which uses the Federal Radiation Council (or other commonly accepted) dose 
limits.  This modeling should be reasonable without reliance on unnecessary 
conservatism for unusual scenarios.

I support the exemption for patient excreta based on my belief that this reduces 
medical care costs and improve care.  US Medical care costs are already among 
the highest in the world.  This exemption permits interaction with the patients 
family.   This interaction has enormous benefits to the patients happiness which 
can speed recovery.  Secondly, this allows the patient to return more quickly to 
employment which may be essential to their well being.  Thirdly, patients are 
extremely difficult to control and this would create virtually insurmountable 
challenges to licensees.  This could result in hospitals avoiding providing 
nuclear medicine care since it entails legal risks.  Finally, extremely strict 
controls over patients could infringe upon a patient's constitutional rights.  

I think that NRC should grant exemptions to waste water treatment plants for 
material released into their systems.  Otherwise this would result in enormous 
costs with little possible benefit.

-Alan M. Jackson, MS, CHP

Disclaimer:  The opinion expressed is mine alone.