Re[2]: dose from airborne emissions

[Ruth Weiner <rfweine@sandia.gov>]

     My dim recollection from my days dealing with air emissions might be 
     some help.  Check out 40 CFR Part 60 (I think, or 61) on the Internet; 
     this is the EPA air standrd for offsite dose for (I think) federal 
     facilities.
     
     More to the point: years ago in Florida we passed some regional 
     ambient air standards (nothing to do with radioactivity, mind) that 
     were more stringent than the EPA standards.  EPA told us in no 
     uncertain terms that they will not enforce any standards but their own 
     -- the state or region is on its own if it wants to get more 
     stringent.
     
     Any change in any state air standard (ambient or emission) has to be 
     submitted to EPA for approval as a change in the Air Quality 
     Implementation Plan (AQIP).  The AQIP becomes part of 40 CFR Part 52.  
     Since this is a rule change, everybody has another shot at it in a 
     much wider forum than just Ohio.
     
     Have you discussed this with (a) the regional EPA office? (b) the 
     pertinent state legislative committee?  (c) your member of Congress?  
     Sometimes these things can be headed off at the state legislature 
     level (they hold the purse strings, after all).
     
     Ruth F. Weiner
     Transportation Systems Department
     Sandia National Laboratories
     Mail Stop 0718
     P. O. Box 5800
     Albuquerque, NM 87185-0718
     505-844-4791
     505-844-0244 (fax)
     rfweine@sandia.gov
      
     Only my own opinion, of course!!



______________________________ Reply Separator _________________________________
Subject: Re: dose from airborne emissions
Author:  csmarcus@ucla.edu at hubsmtp
Date:    1/6/98 3:33 PM


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