Re: dose from airborne emissions

[carol marcus <csmarcus@ucla.edu>]

At 01:30 PM 1/6/98 -0600, you wrote:
>Dear RadSafers:
>
>I just found out that the Ohio EPA is proposing to change airborne
>emissions rules to require permitting any facility "having radionuclide
>emissions to the ambient air that...would cause a member of the public to
>receive in ay year an effective dose equivalent of 0.1 millirem/year...."
>Current OEPA regulations do not mention radionuclide emissions at all and
>the OEPA currently does not deal with radiological regulation in Ohio.
>Ohio is not an NRC Agreement State.
>
>The EPA has scheduled a public hearing on their proposed rule change for
>this Friday.  I plan to attend and to submit testimony in opposition to
>this standard.  Because of the short notice, I would appreciate any solid
>information I can include in my testimony with respect to the feasibility
>of monitoring and enforcing such a standard, comparisons with other
>industrial emissions (for example, radon from natural gas plants, C-14 from
>wood-burning plants, etc.), and so forth.  I have many of the basic
>references and will be going through them, but I also realize that many
>minds working together are much better than mine in isolation.
>
>I know that this standard is stupid, uninformed, costly, and all that.
>That's why I'll be testifying against it.  So please don't go into all
>that, for the sake of other list members.  Please send any thoughts you
>might have directly to me (karam.1@osu.edu) or post them if you think them
>to be of general interest.
>
>Thanks in advance!  I will be happy to make available a copy of my
>statements to anyone who may be interested.
>
>Andy
>
>
>Andrew Karam, CHP  (karam.1@osu.edu)
>The Ohio State University Office of Radiation Safety
>1314 Kinnear Road
>Columbus, OH  43212
>(614) 292-1284 (phone)
>(614) 292-7002 (fax)
>
>

Dear Andy:

The Federal EPA turned radionuclide NESHAPS over to NRC a couple of years
ago, after NRC was forced to promise to essentially enforce a standard 1/5
as much as Part 20.  This is just for materials licensees in NRC and
Agreement States; reactors are not subject to 1/5 the standard.  This mess
has a long and sad history of dumb people at EPA, at NRC, and EPA's
contractor.  In any case, in Ohio, NRC has jurisdiction at present, and the
public is protected by a wide margin of safety.  There is no need for OEPA
to try to dual regulate what has become a national standard, or rather, a
national double standard.  If you don't want to tell OEPA how stupid they
are, ask them why NRC's radionuclide NESHAPS are not sufficient, and pont
out that the average American gets 200 mrem a year from airborne emissions
due to radon.  This is associated with hormesis, not harm.  Good luck.

Ciao, Carol Marcus