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 think that the basis is that one could 
     receive dose from multiple sources, so to control to 100 mrem/y, the limit 
     is to be set 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