Re: Release Concentrations

[JMUCKERHEIDE@delphi.com]

Chris Davey <cdavey@med.phys.ualberta.ca> wrote:
 
> On Thu, 6 Jul 1995 JMUCKERHEIDE@delphi.com wrote:
> 
> > 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. 
> > > 
> > 
> > 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? 
> > 
> Quoting from C123: "the sum of all doses from all radioisotopes via all 
> methods of release does not exceed 50 uSv in a year for a member of the 
> critical group."

Inconceivably unbelievable !
How do they set the "mix" to set individual radionuclide numerical limits if
they are not site/facility source-specific? 

> Yes, pathway analysis was done, but soooo conservatively.

That's for sure.  Does anybody have a dose comparison to the "radionuclide
releases" from drilling a well (i.e., discharging radium, etc, plus radon,
with decay products, both the short-lived and the committed dose from the
20-year half life series), from "routine operation"?  How about mining?  oil,
gas, coal?  What if we applied the same limts to these "man-made" discharges
of radioactivity to the environment?  Does anybody have a statement to the
public that "we will spend $xM of the public's money to prevent a release of
radioactivity to a limit at a tiny (0.xxx) fraction of the discharge from a
well?  compared to what's in the river?  compared to burning coal?  or other
practical numbers (not to mention compared to medical uses? 

I would be very grateful for a source of such a comparison.  Is anyone in a
position to work up some numbers? We could do a "technical review" on the list 
to find valid comparisons and sound analysis. 

> > I guess my reaction to the idea that government is "wasting" hard-won waste
> > facility 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
> > 
> Believe it or not, the AECB does not have quite the same reputation for 
> being power-hungry that you (Jim) alude to for the government 
> organizations south of our border.  Of course, this document may change 
> that perception.
> 
> Thanks for you comments,
> 
> Chris Davey
> RSO CCI Edmonton, Alberta

Chris,

Yes, I always thought AECB was more technically sound. But the politics of an
issue can drive technical considerations to generate irrational numbers with
"no choice". 

I know I come out pretty strong on this matter, but I don't actually believe
MOST government personnel or agencies take a blantant approach on this.  I do
believe there are a very few who do.  I do believe however, that MANY others
get "sucked in" to some rationale, with generally good faith, often responding 
to some political will and set up situation, that results in the premise that
expects to continually ratchets the requirements, and the costs, and meets an
unspoken need that the US EPA does blatantly, ie, "if the reg does not require 
some new action (cost), it is not an effective regulation". Need or health
does not enter into the consideration in most cases, often blaming the
legislature (and often ignoring the testimony that the administration and the
agency top management provided that caused the legislature to so act). 

Thanks for your background on the calculational basis. Do you know where the
"mix" comes from? 

Regards, Jim Muckerheide