Re: 95 Neshaps

[pward@iastate.edu]

Pat Beyer, at the Medical College of Wisconsin asked the following:
> 
> Is the requirement for NESHAP reporting still inforce?
> 
> If Yes : Does anyone know if they are planning to repeal it?
> 
> Are there any reporting changes (style or format)?
> 
> and 
> 
> Has any body reported any problems from the EPA with thier 94 submissions?
> 

Although the National Environmental Standards for Hazardous Air Pollutants
(NESHAPs) has been in effect for some time (40 CFR 61 et seq), Sub-part I
(that's an alpha "I", not a roman numeral 1). had been stayed by a court
orderfor quite awhile.  Entities covered by Sub-part I are U.S. Nuclear
Regulatory Commission and Agreement State licensees and non-DOE federal
facilities.  There were numerous legal issues involving the Sierra Club, 
the Natural Resources Defense fund, and application of the U.S. Supreme 
Court doctrine originally from the "Vinyl Chloride" decision.

Unfortunately, that stay expired at the end of 1993.  All entities covered
by NESHAPs Sub-part "I" were supposed to have evaluated their off-site
radionuclide emissions and have reported there compliance status to the
appropriate EPA regional office by March 1, 1994.  Requests for extension
for up to ninty days were pretty much being given routinely (or so I heard).

Determining compliance with NESHAPs Sub-part I can be fairly easy or fairly
difficult, depending on your individual radioactive materials program.  The
first step was to get a copy of the EPA's COMPLY computer code and enter
the pertinent data.  The code is available from the U.S. EPA's regional
offices and from the EPA headquarters in Washington.

NESHAPs compliance is being included in license inspections.  Most licensees
are in compliance, but you  have to document it.

Paul Ward
pward@iastate.edu