[Date Prev][Date Next][Thread Prev][Thread Next][Date Index][Thread Index]
Re: SEDIMENT AND REGS
> 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
... and after ...
> 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??
100 mrem/yr is certainly safe enough. But the "regulatory body" is only
trying (IMHO) to interpret the "mixed message" we as a profession are
sending it. Imagine a professional reg-writer (or a committee of such)
reading "Specific Recommendations" 4. and 5. of the HPS' "Position Statement
on Radiation Standards for Site Cleanup and Restoration", May 1993. I can
just imagine them looking for one neat number and seeing "mean annual TEDE
to the critical group ... 25 mrem", and "assessment screening level of 5
mrem annual mean TEDE to the critical group", getting confused by the
"contradictory message", and splitting the difference, arriving at 15 mrem.
Not having anything else to call it, this 15 mrem amount becomes a
"regulatory limit."
That's not what *we* see when we read those paragraphs, of course. We focus
on "... ensure that no individual is likely to receive an annual TEDE
exceeding 100 mrem", and see the rest for what it is - a
screening/assessment system aimed at optimizing protection gained and effort
expended.
This sounds like the topic NRC had a "participatory rulemaking" BBS set up
for not long ago. Is that still going on? Maybe it's not too late for us
to clarify our message.
Albert Lee Vest The Ohio State University
Health Physicist Room 103 1314 Kinnear Road Bldg
(614)292-1284 1314 Kinnear Road
avest@magnus.acs.ohio-state.edu Columbus OH 43212
My employer did not review or approve this message.