Re: dose from airborne emissions

["Conklin, Al" <awc0303@hub.doh.wa.gov>]

It sounds like Ohio wants to regulate under identical standards that are 
in 40 CFR 61. An offsite dose of 0.1 mrem/yr potential to emit is the 
cutoff for a NESHAPS facility verses a non-NESHAPs facility. Every state 
has that right under the federal Clean Air Act. Although subpart I 
(non-federal) was rescinded, the states have the right to enfice their 
own similar standards. It doesn't sound stupid to me. Facilities need to 
be regulated, and trust for the feds doing it for the states is not real 
credible for the public. The public needs to be assured they are 
protected. There is no problem with the feasibility of enforcing such a 
standard. I do it in Washington State. It doesn't have to be expensive, 
depending on how extensive the permitting is. For our private licensees, 
we fold it into the Agreement state license for very little cost. The 
"big" licensees are the federal facilities (subpart H of 40 CFR 61), and 
they definitely need nonfederal oversight, and the credibility that that 
oversight provides. 

I deal heavily with the public and have to constantly balance their fears 
and concerns (which are very real to them) with good health physics 
practices. I can do that by showing them what we do to ensure the doses 
are really what the facility says they are. It works just fine. It saves 
a lot of trouble and pre-empts lots of unsubstantiated allegations. Not 
stupid nor uninformed to me.


Allen W. Conklin
Head, Air Emissions & Defense Waste
Division of Radiation Protection
Department of Health
P.O. Box 47827
Olympia, WA  98504
Work - (360) 586-0254
Fax    - (360) 753-1496
Internet :  awc0303@hub.doh.wa.gov