Re[3]: SEDIMENT AND REGS

[michael_coogen@ccgw1.hq.dla.mil]

     You are probably right.  The limits are established to reduce the risk 
     and the reduction of the risk is politically driven by public opinion 
     and politics....science is not required...mike coogen


______________________________ Reply Separator _________________________________
Subject: Re[2]: SEDIMENT AND REGS
Author:  radsafe@romulus.ehs.uiuc.edu at ~GW1
Date:    1/16/96 11:18 AM


     As I am not sure who responded to my response (or as the old WWII joke 
     goes -- Who dat say who dat when I say who dat?), if I am not 
     mistaken, and I frequently am, the EPA started all this with a 
     proposed rule change establishing this "limit" at 10 mRem/yr., to 
     which the NRC responded, then tried to demit, then had to re-respond 
     and I think there is even some dialogue that a fraction of the 100 
     mRem/yr. {no value set in this} might be acceptable.  When all the 
     dust clears, and the baby elephant is born, we will probably find a 
     new, no-basis in risk assessment or fact, regulation that is almost 
     impossible to assess, measure, or live with.  I wonder how this will 
     effect agreement state processes, where 100 mRem/yr is a fact of life?
     
     Any one out there feel free to comment.
     
     R.R.Goodwin 
     Ohio Department of Health
     Ronald_Goodwin@Ohio.Health.Gov
     
     "If you judge, investigate."  -- Seneca  or as Billie Jean King said, 
     "Be bold.  If you are going to make an error, make a doozie, and don't 
     be afraid to hit the ball!"
     
     
______________________________ Reply Separator _________________________________
Subject: Re: SEDIMENT AND REGS
Author:  radsafe@romulus.ehs.uiuc.edu at Internet 
Date:    1/16/96 10:57 AM
     
     
If 10 mren/yr is 0.00114 microR/hr then 15 mrem/yr is 1 1/2 times or 0.00171 
microR/hr which is equally unmeasurable.  Why do we have to reduce the dose 
down to that level when populations are living, with no adverse health 
effects, in areas many times greater than the the proposed limit would amount 
to?   I would like to see a cost/benefit for cancer reduction by going to 15 
mrem/yr vs 100 mrem/yr or even 1000 mrem/yr.
     
     
>     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?? 
>     
>
>
>
     
Charles (Tommy) Thomas
Los Alamos National Laboratory
TSA-11 MS K557
Los Alamos, NM  87545
505-665-1185
chatho@lanl.gov or chatho@roadrunner.com 
The above are my thoughts
and, likely, not those of LANL