re: re:dose from airborne emissions

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

Maybe I didn't make myself clear about what the 0.1 mrem/yr dose 
represents from a regulatory standpoint. The 0.1 mrem/yr number is not a 
regulatory limit, nor a standard. Its merely a cutoff , set by EPA, and 
adopted by us, defining the difference in emission monitoring 
requirements. It simply ensures that a "major" emission source ( a 
potential to emit of > 0.1 mrem/yr  TEDE to the MEI) adequately monitors 
its airborne effluents. The potential to emit is based on release 
fractions supplied by EPA or good engineering judgement or other methods 
acceptable to EPA or the regulatory agency. Conservatisms are built into 
the process to account for uncertainties, which can potentially be large.
Since its not a regulatory limit per se, I assume that addresses your 
question. The actual limit or standard is 10 mrem/yr from each facility. 
The fear of implementing regulations for such a program is not increased 
on the part of the public. I've found that its significantly reduced. Its 
mostly fear by the industry about being regulated more than they  would 
like to be.
For private companies, its often as simple as running the COMPLY code, 
which may take up to a half hour to run and assurances that controls are 
in place and that the effluent is monitored, or exemptions if the COMPLY 
results are low enough. Its not at all hard to regulate, and provides a 
great deal of assurance to the public, at least in this state. Can't 
speak for any others.  Hopefully this explanation clarifies your 
misconception about what the 0.1 mrem number is intended for.
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