Re[2]: SEDIMENT AND REGS

[Ruth Vandegrift <Ruth_Vandegrift@health.ohio.gov>]

     I do believe that this topic has been adequately if not professionally 
     addressed by Dr. E. Gail de Planque (previous NRC Commissioner) in her 
     paper entitled "In Search of...BACKGROUND".  Her views are identical 
     to those that I am seeing identified by so many of the RADSAFERS.  If 
     you are interested, her article appeared in "Radiation Protection 
     Management" Vol. 12, No. 3 (May/June 1995) pp. 23 - 32.
     
     Additionally, Dr. de Planque did not agree with the NRC's adoption of 
     the rule containing a constraint level to 10 mR/yr for air emissions 
     of radionuclides.  This was expressed as her "separate views" in a 
     letter issued by Ivan Selin to Ms. Carol M. Browner - USEPA - RE: 
     Proposed Rescission of 40 CFR 61, Subpart I.....
     
     It is gratifying to see that some people recognize the difference 
     between what a true health and safety issue is AND what it is not.
     
     As a side bar, another excellent article is from the same publication 
     and is entitled "Are Radiation Risks Real Below 0.001 Sieverts per 
     Year?" by Allen Brodsky.
     
     These are my personal views and not those of my employer...etc....
     
     R. Vandegrift
     rvandegr@health.ohio.gov


______________________________ Reply Separator _________________________________
Subject: Re: SEDIMENT AND REGS
Author:  radsafe@romulus.ehs.uiuc.edu at Internet
Date:    1/16/96 12:54 PM


You wrote: 
>
>     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. 
     
What ever happened to ALARA? It may cost only $100,000 to reduce 
residual exposure to 25 mrem/year and $10,000,000 to reach 15 
mrem/year. Is this justified when that exposure difference from 
naturally occuring doses may vary that much within a one mile radius of 
the site? I am not against cleaning up after activities using 
radioactive materials are completed, but let's not get rediculous. The 
public does understand common sense, what makes them leary is all the 
fighting among the so called professionals.
     
It is my opinion that 100 mrem/yr is a reasonable maximum if cleanup 
activities go as far below that level as possible based on cost to 
reach the lower dose rate. Each D&D activity should be reviewed and 
approved by the appropriate licensing agency. This is especially 
important when licensed activities in the past were based on higher 
limits and, now out dated, acceptable practices.
     
     
>...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.
>
     
Note: the above dose rate units should be mR/hr not microR/hr.
     
First off, the only people who occupy a land site 24 hours per day, 365 
days per year are in pine boxes. Second, with all the wild worst-case 
parameters that will be ass-u-me-d, you might as well say return to 
background. An unrealistic expectation.
     
Edwin L. Wright, CHP
elw1@ix.netcom.com