Consequenses of repeal of Rad NESHAPs

[barberj@m4lp.com (Jerry Barber)]

     Hello Radsafe,
     
     I am currently looking at our air effluent program, and am wondering 
     what the full ramifications of the "Clean Air Act: Radioactive 
     Materials Airborne Effluents Dual Regulation Resolution....." are on 
     our program.  I understand (think I do!) that the 40 CFR 61 Appendix I 
     "standard" of 10 mrem is now a "constraint" value, and that reports 
     are now only required at this level (instead of at 1 mrem).
     
     However, 40 CFR 61 provided a great deal more information (which I 
     assume is still relevant?).  The EPA regs specified how stack velocity 
     profiles were to be performed, sampling (ANSI N13.1-1969), and 
     activity measurements (Method 114); as well as Quality Assurance 
     requirements.  My question is, "are the above referenced portions of 
     the EPA regs still applicable to me?"  
     
     Maybe this is covered in the preamble to the new rule published in the 
     Federal Register, but I haven't muddled through that yet!  Please send 
     responses to me directly unless you think they are of interest to the 
     entire list.
     
     Thanks,
     
     Jerry Barber
     M4 Environmental
     1000 Clearview Ct.
     Oak Ridge, TN 37830
     (423) 220-7673
     barberj@m4lp.com