Re[2]: SEDIMENT AND REGS

[michael_coogen@ccgw1.hq.dla.mil]

     When you regulate or you have to do is convinced yourself that it is 
     right.....Is that not right?


______________________________ Reply Separator _________________________________
Subject: Re: SEDIMENT AND REGS
Author:  radsafe@romulus.ehs.uiuc.edu at ~GW1
Date:    1/16/96 10:32 AM


>     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.