Replying to Robert Morris' letter regarding 40 CFR 192: In Region II we do not accept 40 CFR 192. There are cases where 40 CFR 192 results in an exposure above CERLA risk guidance and the 15 mrem/y limit. Therefore we run RESRAD on a case by case basis at each site to find a clean up level. Mark P. Winslow US EPA - Region II