RE: 95 Neshaps

[GROUP RADIATION 415-744-1048 <RADIATION@epamail.epa.gov>]

          From:  Shelly Rosenblum
          
          EPA Region 9 / A-1-1
          75 Hawthorne Street
          San Francisco, CA 94105
          415-744-1047
          
          
          The Radionuclide NESHAP is still in force.  There are no changes 
          in reporting requirements.  If you follow the guidance and 
          determine that you don't have to report, then you do not have to 
          send *anything*, but you should keep a record that  you did 
          evaluate and had made that determination.
          
          EPA is still working on agreements with NRC that would provide us 
          with a firm legal basis for recision.
          
          Have people had any problems with us?  We are currently working 
          with some of the larger radiopharmaceutical manufacturers that 
          have such a large annual inventory that demonstrating compliance 
          by the methods in our guidance is somewhat more difficult.  We 
          are working these problems out.  I believe that we have been 
          quite cooperative with the licensees that have made an honest 
          attempt to contact us.
          
          
               	    	      Shelly Rosenblum