Re: dose from airborne emissions

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

I respect your opinion on a regulatory limit, such as 0.1 mrem/yr. I also 
understand why you feel the way you do. 0.1 mrem/yr is a very low number. 
I also admit I don't know anything about the Ohio EPA nor any alleged 
abuses by them.

With that in mind, however, I would respectfully disagree with your 
comments about whether such a program could or should work. Maybe the 
citizens of Ohio trust the federal government more than they do in 
Washington, where the Department of Energy (Hanford) has a checkered past 
in dealing with the public on their exposures (Don't get upset, Hanford 
people. You're doing orders of magnitude better now than you used to). 
The public simply doesn't  trust them. They barely trust us, but we are 
considered independent. The public also translates that distrust to the 
entire nuclear industry, unfairly, but they do.
It's true that a single individual has no choice but to delegate a 
protective role to their government. But, the closer the government is to 
them (the more local), the more trust they are willing to give them. At 
least that's my experience (which has been extensive, when it comes to 
dealing with public concerns on radiation exposure for the last 11 
years). Fernauld, in Ohio, I believe has had some similar problems.

I disagree that such a limit causes more harm than good. I've been 
running this program for 9 years, and it has been very positive. We've 
been able to "prove" on numerous occasions, that the public was not being 
harmed, when they wouldn't believe the facility. At least it has been 
proof acceptable to the public. We've been able to verify the low 
emissions coming from those facilities. We've put to rest numerous 
allegations, the recent when their was an explosion at Hanford's 
Plutonium Finishing Plant. Our report of no releases of plutonium became 
the bottom line with most people and the press.

We have no problem with the 0.1 mrem/yr cutoff for NESHAPs verses 
nonNESHAPs sources. If you are careful in how you administer the program, 
its not hard to make it clear that that level is very conservative. Its 
not hard to enforce, because with any controls whatsoever, 0.1 mrem/yr is 
easy to accomplish.  We've never had the public look at 0.1 mrem/yr as 
safe verses unsafe. (Well, maybe never is too strong. You do have some 
individuals who view "any" exposure as dangerous. But its not a huge 
problem, and the vast majority of the public are satisfied.) Their fears 
are allayed, for the most part. I believe that is a "worthy" cause, and 
if administered carefully, an effective use of dollars, because it heads 
off a lot of fear and public backlash.

 But then, maybe Ohio  is different. And,  maybe Ohio EPA has other 
problems that are not related to this one issue. By your note, it sounds 
like it. 
Its good to debate these things , however.

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