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compliance with NESHAPS report
i looked at 40CFR61.104(b) which reads
facilities emitting radionuclides in an amount that would cause les than 10% of the dose standard in para 61.102, as determined by the compliance procedures from 61.103(a) are exempt from the reporting requirements of 61.104(a)
61.103(a) states
compliancewith the emission standard in this subpart shall be determined through the use of either the EPA computer code COMPLY or the alternative requirements of Appendix E.
Appendix E states (second paragraph of section 1.Purpose and Background
First, a facility can be found in compliance if the quantity of radioactive material possessed during the year is less than that listed in a table of annual possession quantities.
Section 2. Table of annual possession quantity can be used IF
1. No person lives within 10 meters of any release point, and
2. No milk, meat or vegetables are produced within 100 meters of any release point.
Table 1 - Annual Possession Quantities for Environmental Compliance
lists radionuclides and annual possession quantities in CURIES (yes, Curies) per year in gaseous, liquid/powder or solid forms.
If you look at the most probable
the limits are
(liquid/powder)
C-14 290 (CURIES!)
H-3 15,000
P-32 170
S-35
OOPS - P-32 17
S-35 75
I plan to look at what i had this past year in each of those categories (isotopes) and see if i'm "in compliance" by this method. It'll save a lot
of extra work, and i'm thinking a lot of other academic users
would be in the same category
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