Re: Draft EPA rules

["Russ Meyer" <CMEYER@brc1.tdh.texas.gov>]

> Date:          Thu, 23 Feb 95 15:32:02 -0600
> Reply-to:      radsafe@romulus.ehs.uiuc.edu
> From:          "Mays, Mark" <maysm@wrigem.wpafb.af.mil>
> To:            Multiple recipients of list <radsafe@romulus.ehs.uiuc.edu>
> Subject:       Draft EPA rules

>
> I had read that EPA was proposing regulations 49 CFR Part 193,
> "Environmental Standards for Management, Storage, and Disposal of Low-Level
> Radioactive Waste".  Does anyone have any insight?


Yes, Mark,
    Here's my two cents worth.  The regulations 40CFR193 set a
maximum dose limit to the average member of the critical group of 15
millirem per year.  This number includes the 10 millirem/year
allowed under 40CFR61 subpart I, and the proposed 4 millirem/yr from
drinking water.  Leaving 1 millirem from external sources.  The rule
applies to any processor or storage facility for rad waste as well
as the disposal site.  This, at least implies, that if a licensee is
forced to amend his license for interim storage of radioactive waste
until a disposal facility is opened he will have to comply with the
above limits and I suppose become a permitee of the EPA, as well.
Apparently, the rule presupposes that these kinds of facilities are
not currently regulated, by totally ignoring the fact that they are
aleady issued licenses by either the U.S. Nuclear Regulatory
Commission or an Agreement State and are required to comply with
existing radiation exposure limits specified in those entities'
regulations.>














Russ
cmeyer@brc1.tdh.texas.gov
(512)834-6688