[ RadSafe ] Stack Emission Limits - Clarification

[BLHamrick at aol.com]

To all,
 
A kind, brave soul pointed out that in my earlier message, I had relied on  
the wrong ALI for Cs-137.  I kept thinking something was wrong, and  re-checked 
the math, but never went back to the source.  I had pulled out  the ingestion 
ALI, not the inhalation ALI.  
 
So (recognizing the limitations of converting ALI's to dose), indeed you  
cannot meet the time-averaged annual concentration limit in 10 CFR 20, Appendix  
B and exceed a 100 millirem dose to a member of the public:
 
(2E-4 uCi/ml x 1 min) + (0 uCi/ml x 525,599 min)]/525,600 min (per  year) =  
3.8E-10 uCi/ml, which exceeds  the 10 CFR 20, Appendix B  effluent limit for 
Cs-137 (which is 2 E-10 uCi/ml).
 
Now that I think about it, Otto's question may have been more along the  
lines of this:
 
Say, I release 2E-4 uCi/ml x 1 min, at an exhaust rate of V/min, so I  
release 2E-4 x V uCi total.  Then, I run my exhaust the rest of the year  with no 
releases at a rate of U/min, such that the final "annual" concentration  is:
 
(2E-4 x V)/[(V x 1 min) + (U x 525,599 min) < 2E-10 uCi/ml, which will  be 
true if my ratio of U/V is high enough.
 
I thought there was language in the regulations about using the  
"time-averaged" annual concentration, but I can't seem to find it.   That would prevent 
the "bulk" averaging of total activity over total air volume  that would result 
in Otto's original point.
 
Thanks for listening.
 
Barbara L. Hamrick