re: re:dose from airborne emissions

[DamschenGA <damschenga@mkf.ornl.gov>]

Al,

How do you enforce the 0.1 millirem standard? Wouldn't the error band be far
greater than 0.1 millirem when attempting to calculate the off-site dose to
a member of the public from just about ANY measurable emission of
radioactive material? It's just a guess, but I'd bet that moving across town
or spending an extra hour a week in the basement would change a person's
annual dose more than 0.1 mrem. This raises the question of what purpose is
being served by setting a regulatory limit that low. If it's really
protection of the public, do you require a warning label on gas stoves to
inform the public that using a gas stove instead of an electric one may
increase their radiation dose more than 0.1 mrem/yr? Are contractors
required to warn people that finishing their basement and using it as a
family room may increase their dose more than 0.1 mrem/yr?

Also, I don't think the cost question had to do with the state's cost in
implementing the standard. Even though I'm not directly involved in the
issue (I teach radiation safety) I'm VERY concerned with what you might
consider an indirect cost of such regulations - the cost of overcoming the
fears that are fostered by rules like this one. The initial anxiety that I
frequently see when showing an orange Fiestaware plate, a shaker of salt
substitute, or a gas lantern mantle to a group of visitors or a class of
potential radiation workers is not relieved by a regulatory limit of 0.1
mrem/yr POTENTIAL dose. If anything, it is increased by such regulations,
and leads to confusion and distrust of either the regulators or the HP
profession when the student realizes that regular usage of any of these
unregulated items would probably result in a dose >0.1 mrem/yr.

My job would be MUCH easier if the regulations were based on good science
and were truly designed to be protective of the public health. I have made
the point before that money spent remediating ANY "hazard" that presents a
lower risk than that posed by the greatest identified risk to the public is
wasted and condemns one or more people to die sooner than they would have if
the money had been spent to remediate the primary hazard. Therefore,
spending ANY money to ensure emissions do not pose a potential dose of 0.1
mrem/yr is wasted money, whether or not it meets anyone's definition of
"expensive." In the view of the "anti-" crowd, the dollars not spent to
reduce ALL radioisotope emissions to the most restrictive regulatory level
they can find are blood money - and they are very adept at telling the
public that the thirty pieces of silver are in our hands.

I don't mean to be strident, but I deal with the effects of regulations like
a 0.1 mrem/yr potential dose limit on a regular basis, so my tolerance level
for such things is very low. I really am curious though, how DO you: 1)
justify a 0.1 mrem/yr potential dose limit, and 2) enforce such a rule?

-Gary Damschen
damschenga@mkf.ornl.gov

These opinions are mine and not my employer's. All other disclaimers apply.