Applicability of Public Dose Limits to Individuals on the Nevada National Security Site
Historically all persons working on the Nevada National Security Site (NNSS) were considered subject to worker dose limits when calculations of potential dose from the air pathway were conducted to demonstrate compliance with Title 42 United States Code (USC) Chapter 85, “The Clean Air Act,” and Title 40 Code of Federal Regulations (CFR) Part 61, Subpart H, “National Emission Standards for Hazardous Air Pollutants (NESHAP).” Calculations were also conducted for the all-pathways potential dose to demonstrate compliance with U.S. Department of Energy (DOE) Order DOE O 458.1 Chg. 3, “Radiation Protection of the Public and the Environment.” The need to evaluate environmental air sampling locations and past regulator questions about the existence of persons potentially subject to public dose limits being on the NNSS drove this assessment (letter from EPA [U.S. Environmental Protection Agency] Region 9 to DOE/Nevada Operations Office, dated September 3, 1999). This assessment also supports determining those persons subject to public dose limits from the all pathways perspective. A person that is a member of the public is subject to public dose limits.