Re: Release Concentrations

[JMUCKERHEIDE@delphi.com]

Albert Lee Vest (avest@magnus.acs.ohio-state.edu) writes:

> 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.

I agree with the IDEA that limits be established by the isotope (and even the
form of the isotope -- applying science). It was my impression from the
numbers however, that these were rather low values. Does anyone know the basis 
for converting to potential exposures that this numbers came from? Is there
any public health benefit associated with these limits vs concentrations 2 or
10 times the reported values? Did the assessment include a pathway analysis? 

> 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 guess my reaction to the idea that government is "wasting" hard-won waste
facitiy capacity, is that government is generally committed to such waste as a 
means for enhancing its role and authority and funding; that more
"hard-to-win" capacity means more government role and authority and funding,
whether contributing to public health and safety or not (e.g., EPAs radon
mission notwithstanding the unambiguous scientific evidence that radon in home 
concentrations has zero health consequences, and perhaps a negative
correlation (B. Cohen, HPJ, Feb 95, and in a series of increasingly
well-developed and unambiguous data sets since 1988; and hard lifetime data on 
spa workers and surrounding populations in Japan, Europe, China, etc; and that 
the lung cancer histology in miners only in unventilated mines, who smoked, at 
exposures >1000 times home radon levels, which MAY be associated with radon,
is a different lung cancer histology in the rare lung cancers in the
non-smoking population). 

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

Just had to jump on it in passing.

Regards, Jim