EPA Rules on Radionuclide NESHAPS

[Mack Richard <MRICHARD@WPO.IUPUI.EDU>]

Last week, Melissa (Woo) mentioned something about the EPA and the
reopening of a proposed rule to rescind the NESHAPS for radionuclides
for non-power reactor licensees (these rules have already been
rescinded for power reactors).  I strongly suggest that radsafers
download a copy of this proposed rule - there have been some
interesting agreements made between the NRC and the EPA. 
Specifically, the NRC has apparently agreed to adopt an ALARA
"constraint level" of 10 mrem for radionuclide emissions.  

As I read it, this constraint level means that if you exceed it, you will not
be cited for a violation.  However, you will be required to implement
procedures to reduce the effective dose from emissions to less than 10
mrem and provide assurances that future emissions will remain ALARA
(i.e. less than 10 mrem).

I have some problems with this.  The NRC has consistently stated that
ALARA levels are not intended to be "de facto" limits.  The
aforementioned NRC proposal seems to deviate from that contention.

I am certainly in favor of eliminating dual regulation of radionuclide
emissions.  However, the sacrifice may be great and unjustified.  10
mrem - gimme a break!!  Kind of sheds still another light on regulatory
limits, the linear threshold idea, etc.

To download the proposed EPA rule from the Internet, go to
"http://www.epa.gov/epahome/EPAFR-Search.html"; and enter a search
query for NESHAPS.  You will obtain a list of documents, two of which
deal with radionuclide NESHAPS.  Download the one that says "Score:
349, Bytes:  32813."

Mack R.

"My employer rarely understands me, so they certainly won't be
responsible for what I say"