Re: EPA Rules on Radionuclide NESHAPS

[gcicotte@cbvcp.com (George Cicotte)]

BTW, thanks for the NESHAPS reference.

your comment:
>
> . . . . 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
>limit, the linear threshold idea, etc. . . . . .
>
>Mack R.
>

With respect to your comment, I would like to point out that many of the 
things NRC does
in this regard are the result of having to accommodate EPA, generally by edict.
It has been my experience that when NRC wants to make things easier to 
regulate, easier
(or at least more logical) for the licensees, their leash gets shortened.  
EPA doesn't get
told not to make regulations, but NRC does.

I think if you look closer, e.g., do a boolean search of the FR, you'll find 
that NRC was 
ORDERED to come up with a memo of understanding on the 10 mrem, as the price
for being allowed to keep ALARA instead of making it a de jure limit, which 
they would
then have to classify as, say, a Severity Level III violation, which would 
REALLY be 
silly.

V/R
George R. Cicotte
(former NRC inspector)