Re: Release Concentrations

[avest@magnus.acs.ohio-state.edu (Albert Lee Vest)]

Peter Fundarek writes

>The AECB, our regulatory agency, has 
>developed these generic maximum release concentrations for 
>licensees who do not develop their own derived emission 
>limits.

I hope they continue to *clearly* communicate this intended use for "generic
MRC's".  Some of the regulatory guides I've been exposed to (which contain
numbers *suggested* for use) have such statements in the fine print, where
nobody seems to notice them!  The suggested numbers then become, de facto,
regulatory limits.

>I am looking at the impact of this new document on 
>a potential for a delay and decay facility in the 
>university. 

The MPC's you included are a step in the right direction!  The fact that
there's a separate limit for each nuclide indicates someone trying to apply
science, and it's great to see government doing that.  I would love to be
applying these criteria to our decay-in-storage endeavors, rather than use
the superstitious "hold it for ten half-lives, then make sure you can't
detect anything" rule.

The MPC's you presented were only for short-lived, "delay and decay"
nuclides.  Are there also MPC's for EVERY nuclide one might use - just as
there are ALI's for every imaginable nuclide in Appendix B of USNRC's 10 CFR
Part 20?  I can't think of any reason for *not* including longer-lived
nuclides.  Surely there is a point at which a little activity doesn't make
the waste any more of a health hazard than it would be without the activity.
Besides, space in a low-level waste disposal site is precious and expensive.
Isn't it wasteful for government to allow, much less require,
trivially-contaminated waste materials to occupy space in such hard-won
(meaning politically, administratively) waste facilities?

I'll return the soapbox to its rightful owner now.

Albert.