Re: Radionuclide in Sediment -Reply

[Craig D Brown <CBROWN@envc.sandia.gov>]

John Stephens wrote:

   " One is risk based, the other based on best available
technology like detection limits.  Jim Webb mentioned
NRCs detection limits, an excellent source.  On the other
hand, Paul Charp mentioned 40 CFR 196 was 15 mrem (per
year?), a risk based limits.  Why isn't this
100 mrem/yr?  And does 10 CFR 834 say anything about
the limit?"

10 CFR 834 is not specific about a cleanup standard.  Like
DOE Order 5400.5 it gives a primary dose limit of 100
mrem/yr.  Unlike 5400.5, it does not dictate the use of
DOE/CH-8901 which currently requires cleanup to 30
mrem/yr.  10 CFR 834 requires the use of "approved
models" and does not give a dose limit other than the 100
mrem.  I'm not sure if there has been coordination between
10 CFR 834 and 40 CFR 196, although DOE is rumored to
have taken part in some of the up-front work on 40 CFR 196.

Craig D. Brown
cbrown@envc.sandia.gov