Sediment

[David_B_Dave_Ottley@rl.gov]

     It seem as though the original question has been somewhat lost in a 
     discussion of the proposed 15 mrem/y cleanup limit.  I do believe that this 
     will become the limit.  I believe that its basis is that one could receive 
     dose from multiple sources, so to control to 100 mrem/y, set the limit at 
     some fraction of this.  This is not new as many current DOE/NRC requests 
     are evaluated by comparing a dose assessment to a "few mrem" criteria.
     
     As to sediment or soil limits:  Commercial reactor sites (NRC 
     licensees) use the environmental technical specification limits for 
     LLDs as free release limits.  These are very conservative.  Here in 
     the DOE world it is not as clear.  My particular employer uses what 
     has become known as "moratorium limits."  These were established to 
     define when hazardous waste is mixed waste.  The basis of these limits 
     is a "no-rad-added" or indistinguishable from background philosophy.  
     These LLDs are also low but not as low as the NRC's.  This is like the 
     release of material and equipment with potentially surface 
     contamination.  The 5000 dpm/100 cm2 limit is instrument performance 
     based (reasonably achievable LLD).  I believe that we will change to 
     risk based, using the 15 mrem/y when it is adopted, and that at that 
     point our numbers will increase somewhat.
     
     P.S. I tried responding to meg_macleod directly on this subject but it 
     wouldn't go.  If you'd like to correspond, contact me.
     
     Thank you and a standard disclaimer
     David_B_Dave_Ottley@Rl.Gov