Re: dose from airborne emissions

[Al Tschaeche <antatnsu@pacbell.net>]

Conklin, Al wrote:
> 
> 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. 

We understand that.  But, are you required to accept the EPA number?  Or
could yours be higher?

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. 

Since when is a "major" emission source one with the potential to emit
radioactive material that will result in an annual TEDE to the maximum
exposed individual??  I would think a "major" source would be one that
might result in a 10,000 mrem per year dose.  Even that dose is unlikely
to measurably injure any human.

Why must we spend money to monitor such a small "Potential" increment to
the 300 mrem per year natural background???

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.

Even if they are, the highest doses are so low as to be insignificant!

> 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. 

The public is frightened more and more by government agencies telling it
that low doses are harmful which is what one does by implementing
regulations such as this.  In my experience with the public, any
radiation, no matter how small, is harmful and must be avoided.  That
erroneous idea is fostered by regulations such as this.  We need to tell
people that low doses are not measurably harmful so they won't be
irrationally fearful and force governments to spend more and more of the
public's money for no measurable benefit.

Its
> mostly fear by the industry about being regulated more than they  would
> like to be.

And in so regulating, it costs the American people megabucks for no
measurable benefit.

> 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. 

Just because it is easy to do does not make it reasonable to require.

Its not at all hard to regulate, and provides a
> great deal of assurance to the public

What is the public assured of vis-a-vis real, measurable health and
safety to themselves?  Please tell us the real dollar value of such
assurance.  See below for another related request.

, 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.

To me the number is intended to spend money for no benefit.  Would you
please supply hard data on radsafe that demonstrates 0.1 mrem per year
or 1 mrem per year or 10 mrem per year or 100 mrem per year or 1000 mrem
per year actually causes any real, measurable harm to any human, even a
foetus?

Al Tschaeche antatnsu@pacbell.net

> 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