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Re: Thanks



> One other question - Being a small use school, and working on the
> NESHAPS required report, HOW is everybody getting their releases ie
> the stack concentrations (Ci /cu m).  We don't have enough to event
> monitor (We do not use much), and our calculations show only minute
> quantities of nuclides go up the vent hoods.  I would like to know
> what the Standard Method (consensus?) for Calculating this is. We use
> some I-125 but we do not go by an annual limit, but a possession
> limit.  Thanks again.

The dose to the public is supposed to be calculated using the EPA
program called COMPLY.

 You may want to take a look at 40 CFR 61.105(b) which states that
'Facilities emitting radionuclides in an amount that would cause less
than 10% of the dose standard in 61.102, as determined by the
compliance procedures from 61.103(a) are exempt form the reporting
requirements of 61.104(a)

61.102(b)gives the emission limit for iodine as an emission 'that
would cause any member of the public to receive in any year an
effective dose equivalent of 3 mrem/year'

If you have little use it should not be too difficult to demonstrate
that the dose to the public from your emissions is less than 10% of
the allowed limit.  My guess is that your public exposure due to
airborne emissions is very close to 0.

Give your local EPA regional administrator a call. He or she will
probably refer you to a State agency or an air quality tech.  You
will probably be able to work something out that is not too
burdensome.









______________________________________________________________________

Name: Edwin Jackson
EFJ@ASBHR
Environmental Coordinator
Brigham Young University