Re[3]: Status of NRC/EPA 25 vs 15 mrem criteria

[Jeff.Lively@DOEGJPO.COM (Jeff Lively)]

That is interesting, especially in light of the fact that in EPA region 8, the 
decision was to ratchet down an already negotiated criterion to 15 mrem based on
the newly published OSWER directive.  This in spite of the language in the OSWER
directive which provided for "grandfather" exclusion at CERCLA sites that had 
other criterion previously negotiated.

Without a debate about the appropriateness of 10,15, 25 or any other annual dose
based "standard", the thing that perverts justice and thwarts and real progress 
in dealing with the cleanup issues (be they risk or politically based) is the 
lack of a STANDARD.

We spend countless hours in frustration and untold dollars chasing an ever 
vacillating target.  At some point, we must wake up to the fact that without 
some consistent regulatory framework, the frustration will continue.  And I know
first hand that it is just as frustrating for logical minded regulators as it is
for those who are trying to comply.

Jeff Lively
Health Physicist
MACTEC-ERS
(970) 248-7780
jeff.lively@doegjpo.com


______________________________ Reply Separator _________________________________
Subject: Re[2]: Status of NRC/EPA 25 vs 15 mrem criteria
Author:  joseph_guido@radian.com (joseph guido) at Internet
Date:    3/20/98 6:15 PM


     We are in the process of negotiating cleanup criteria withen region 9 
     epa and they are telling us that the 15 mrem is not applicable for the 
     CERCLA site we are working on.  Funny thing is that the OSWER 
     directive that referances 15 mrem as 'generally protective ... " came 
     out of region 9 epa ... go figure.

     joseph guido
     health physicist
     radian international



______________________________ Reply Separator _________________________________
Subject: Re: Status of NRC/EPA 25 vs 15 mrem criteria
Author:  radsafe@romulus.ehs.uiuc.edu at INTERNET 
Date:    3/20/98 7:06 AM


I have a copy of  EPA's OSWER No. 9200.4-18,  signed August 22, 1997. 
Subject:  Establishment of Cleanup Levels for CERCLA Sites with Radioactive 
Contamination 

This document presents guidance and applies only to CERCLA sites, the 15 
millirem per year EDE is stated as "..should generally be the maximum dose 
limit for humans...".  

Does anyone have other references?

Claude Wiblin, CHP