Re: decommissioning of nuclear faciliti

[JMUCKERHEIDE@delphi.com]

Radsafers,

Forwarded for info re NRC 15-30 mrem/yr cleanup standards from NRC Chairman
Shirley Jackson's remarks below: 

Regards, Jim Muckerheide
jmuckerheide@delphi.com
============================

Oh well, I guess I'll have to be the first in line to recover my tax dollars,
plus a slice of those billions, as I consult on how to achieve such
ridiculously low exposure levels.

>>> Michael Fox <foxy1@owt.com> 12/13/96 01:17pm >>>

Mike Baker:
Thanks for the information.  This is an example of what we should all be
questioning.  What on Earth are we doing with exposure limits set at 10-30
mrem/yr?  What is the health basis for this, the cell biology basis?  Where
on the planet can we observe harm to humans, plants, and animals at these
levels?  Once we understsand these, then the debate gets even more
interesting.  How many billions are the taxpayer/consumer being asked to
pay to achieve these levels?  For what reasons?  With more than 500,000
cancer deaths/yr  occurring in the U.S. isn't it obvious that there are
many more potent carcinogens out there causing observable (as distinct from
statistical), than radiation?  Radiation cleanup standards at DOE sites are
being promulgated at 15 mrem/yr.  Why?  Spokane County residents get an
AVERAGE 1500 mrem/yr from radon alone (with no observable lung cancer
excesses).  Sure money is to be made, bureaucracies are to be expanded,
reputations enhanced, political careers advanced, but what are the actual
observable health benefits of these low exposure limits to the taxpayers
and consumers? Not a thing.  We must stop the pretense (and the enormous
waste) that there are observable benefits.
Mike Fox

>I thought some of you may find this two paragraph cut from
>a recent speech by Shirley Jackson interesting.  Note the
>dose criterion for decommissioning of nuclear facilities.
>
>Mike Baker    ...   baker@groves.neep.wisc.edu
>
>-----------------------------------------------------------------
>
>             "TAKING THE FINAL STEPS IN PROMULGATING
>          A DEFENSIBLE DEACTIVATION, DECONTAMINATION AND
>                DECOMMISSIONING REGULATORY REGIME"
>
>                                BY
>
>                DR. SHIRLEY ANN JACKSON, CHAIRMAN
>                U.S. NUCLEAR REGULATORY COMMISSION
>
>                                TO
>
>             THE THIRD ANNUAL NUCLEAR DECOMMISSIONING
>                      DECISIONMAKERS' FORUM
>              LANSDOWNE EXECUTIVE CONFERENCE CENTER
>                       LANSDOWNE, VIRGINIA
>                        DECEMBER 10, 1996
>
>In formulating and promulgating its final rule on radiological
>criteria for license termination, the Commission will give
>particular consideration to:  (1) an all-pathways dose criterion
>in the range of 15 to 30 mrem per year; (2) inclusion of specific
>alternative criteria for certain facilities; (3) elimination of a
>separate groundwater standard; (4) the appropriate application of
>ALARA based on the dose criteria selected in the final rule; (5)
>a greater reliance on institutional controls; and (6) the
>appropriate value of the maximum dose limit permitted if
>restrictions should fail.
>
>Let me take a moment to discuss two of these items -- the all-
>pathways dose criterion and the separate groundwater standard --
>in further detail.  With regard to the inclusion of a separate
>groundwater standard in the NRC's final rule, at this point, the
>Commission is reluctant to include such a requirement, based on
>information currently before us, because a separate groundwater
>standard has not been justified on either a technical basis or a
>cost-benefit basis.  The Commission believes that adequate
>protection of the public can be provided by the establishment of
>an all-pathways dose criterion that limits the amount of
>radiation a person potentially can receive from all possible
>sources at a decommissioned site, including doses received from
>drinking water obtained from groundwater.  Based on information
>and data currently available to the Commission, a separate
>groundwater standard appears to have minimal additional safety
>benefit compared to an all-pathways dose criterion.  Furthermore,
>the costs associated with this benefit appear to be unreasonably
>large.  The Commission believes that compliance with an
>appropriate all-pathways standard would satisfy the Atomic Energy
>Act requirement to protect public health and safety.
>
>-------------------------------------------------------------------------