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EPA DOCKET ID: 102RQ-RN 

1) INDEX 

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9) 102RQ-RN-3-1 

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39) 102RQ-RN-5-1 

Step 3: FOR ASRC INTERNAL USE 

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CD: 

QA: 1 

2) 102RQ-RN-1-1 

4) 102RQ-RN-1-3 

6) 102RQ-RN-1-5 

8) 102RQ-RN-1-7 

10) 102RQ-RN-3-2 

12) 102RQ-RN-2-1-1 

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16) d£2RQ-RN-2-l-5; 

18) 102RQ-RN-2-2-2 

20) 102RQ-RN-2-4-1 

22) 102RQ-RN-2-4-3 

24) 102RQ-RN-2-4-5 

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30) 102RQ-RN-4-1 

32) 102RQ-RN-4-3 

34) 102RQ-RN-4-5 

36) 102RQ-RN-4-7 

38) 102RQ-RN-4-9 

40) 102RQ-RN-5-2 

Step 1: FOR ASRC INTERNAL USE ONLY 

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Till out Continuation Sheet and go to Step 2 

Internal SFUND Box Number 35 OF 283 

Initials/Date: LDS / 3-8-2007 
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Department o, Energy lOU^-^X-hX 

Washington, DC 20585 

August 17 , 1987 

Ms. Barbara Hostage 

Response Standards and Criteria Branch 

Emergency Response Division (WH-548B) 

U.S. Environmental Protection Agency 

401 M Street, SW 

Washington, DC 20460 

Dear Barbara: 

Since my August 5, 1987, letter to you concerning the modeling 

assumptions considered in the rulemaking activities on reportable 

quantities for radionuclides, I have more closely examined the 

bases of the deposition model developed by the Nuclear Regulatory 

Commission and described in Regulatory Guide 1.111. Although I 

still consider diffusivity theory (the basis for the Regulatory 

Guide 1.111 approach) a better representation of actual atmospheric 

deposition processes, the assumptions (e.g., a vertical line 

source) and calculational techniques (e.g., finite differencing) 

used to develop the Nuclear Regulatory Commission (NRC) methodology 

make the deposition relationships presented in Regulatory Guide 

1.111 unsuitable for application to a distance of 30 meters from an 

assumed point source. The NRC approach was developed specifically 

for consideration at nuclear power plants with particular release 

characteristics and relatively large distances (i.e., several 

hundred meters and beyond) to potential receptors of interest. 

Extrapolation of relative deposition rates presented in 

Regulatory Guide 1.111 to a distance 30 meters is not advisable. 

Strictly from the standpoint of making calculations at 30 meters, 

and not considering adequacy of modeling, the use of an assumed 

deposition velocity of about 1 centimeter/second appears to be 

the only suitable, simple technique. However, as I stated in my 

letter of August 5, 1987, if deposition for the ingestion of 

vegetables and milk remains a consideration of the Environmental 

Protection Agency for the determination of reportable quantities, 

I believe the entire modeling bases for both ingestion and 

inhalation would have to be re-examined. In particular, I would 

recommend that a distance on the order of 100 meters be used for 

calculations of both air concentration and deposition. The atmospheric dispersion and deposition models used for the inhalation 

and ingestion pathways were developed to be used at and beyond 100 

meters, and field experiments have been performed to validate 

these models at distances ranging from about 100 meters to several 

thousand meters. Extrapolating these models to a distance of 30 

meters simply for the purpose of performing calculations without 

regard for the physical processes involved is bad science with 
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poor judgment. As I have stated previously, I recognize that 

non-modeling considerations may be more important in establishing 

the distance from an assumed source for the purpose of determining 

reportable quantities. However, the constraints imposed on the 

models for such inappropriate applications used should be fully 

recognized and considered. 

I hope these clarifying comments are helpful. 

Sincerely, 

€ 

James E. Fairobent 

Office of Environmental Guidance 

and Compliance