NRC Cleanup Rule

["ERIC GOLDIN" <goldinem@songs.sce.com>]

     Regarding the "acceptability" of the NRC's position on residual 
     radioactivity standards vice the EPA's position, keep in mind 
     that the NRC, in its' usual fashion has attempted to carefully 
     and deliberately factor costs into the decision.  While there 
     probably is no realistic difference between health effects at 25 
     mrem/yr (the NRC rule) or at 100 mrem/yr (NCRP recommendation), 
     there are other issues that must be considered.  For example, 
     there are many scientific disciplines that rely on extremely low 
     level analyses of trace radionuclides (C-14, tritium, Cl-36, 
     etc.) in the environment.  If we permit leaving a formerly used 
     site to remain contaminated such that residual radioactivity in 
     the environment prevents such studies, then we've done ourselves 
     a true disservice, irrespective of trivial risk estimates.
     
     The NRC's cost studies during the (extensively publicly involved) 
     decommissioning standards rulemaking showed that cleanup of a 
     site could be cost-effective well below 100 mrem/yr, hence their 
     original draft standard of 15 mrem/yr.  After careful 
     consideration of public comments on cost/benefits and the special 
     cases of hard to detect isotopes, the NRC settled on 25 mrem/yr 
     (to be determined with typical conservatism).  Perhaps a poor 
     analogy:  Although I don't believe used motor oil is really as 
     hazardous as the State of California would like us to believe, I 
     am not going to pour it in my backyard.  For the same reason, we 
     should attempt, after considering costs and benefits, to clean up 
     our human-made activities as best we can.
     
     My opinion only.
     Eric Goldin, CHP
     goldinem@songs.sce.com