Re: SEDIMENT AND REGS

[RONALD GOODWIN <RONALD_GOODWIN@health.ohio.gov>]

     Let me venture a statement on why.  First, during ops, the general 
     public is not invited to have picnics and build houses on the 
     licensees property.  Second and most important, we are talking about 
     D&D releasing the property for unrestricted use.  If the dose limits 
     are going to be higher based on ram left on site, then certain 
     restrictions will apply to the property, including deed restrictions, 
     access restrictions, etc. 
     
     The RegBody is doing good by having a much lower dose limit apply to 
     areas that have been decommissioned and released to the general 
     public.  Let's look at another aspect.  15 millirem per year is going 
     to be somewhat, but not a lot, easier to determine than the EPA 
     proposed 10 millirem per year, which if you calculate based on 24 hour 
     occupancy for 365 days per year (worst case basis) the total dose rate 
     allowable after D&D will be .00114 microR per hour.  Does your meter 
     measure so fine?  Occam's razor would hang over our head with a limit 
     such as this.
     
     R.R. Goodwin
     Ohio Department of Health
     Radioactive MAterials Safety
     Ronald_Goodwin@Ohio.Health.Gov
     (614) 644-2727


______________________________ Reply Separator _________________________________
Subject: SEDIMENT AND REGS
Author:  radsafe@romulus.ehs.uiuc.edu at Internet
Date:    1/16/96 8:58 AM


     
     DEAR RADSAFERS
     
     THERE HAS BEEN SOME DISCUSION ON THE RADSAFE NET ABOUT REGULATORY 
     LIMITS CHANGING FROM 100 MREM/YR TO POSSIBLY 15 MREM/YR. THE QUESTION 
     I POSE TO EVERYONE ON RADSAFE IS THIS,
     
     HOW DO YOU EXPLAIN TO THE PUBLIC THAT REGULATIONS SUCH 10 CFR 20 AND 10 
     CFR 835 THAT ENFORCE A 100 MREM PER YEAR FOR LICENSEES DURING 
     OPERATIONAL PERIODS IS NOW GOING TO BE ONLY 15 MREM/YR DURING 
     DECOMMISSIONING.   IN MY OPINION, IT APPEARS THE REGULATORY BODY IS 
     SENDING A CONTRADICTORY MESSAGE TO THE PUBLIC.  IF I WAS LIVING NEXT TO 
     A LICENSEE AND WAS EXPOSED DURING THE OPERATIONAL PERIOD TO A LIMIT OF 
     100 MREM/YR, WHY IS IT NECESSARY TO REDUCE IT TO 15 MREM/YR AFTER THE 
     FACILITY IS CLOSE? WAS THE 100 MREM/YR NOT A "SAFE" LIMIT??