40CFR141-comment

[Les Slaback <lester.slaback@nist.gov>]

Recall that during the 10CFR20 revision process NRC resisted numerical
increases in MPC/DAC values, but eventually went with consistency with dose
limits, although in most cases they got their way by decreasing the dose
limit.  While EPA has a tendancy to be more arbitrary hopefully logic will
overcome.  The primary limit is a dose number.  The concentration is simply
a derived value.  But contrary to the NRC rules where the dose number can
always be used EPA made the concentration number a mandatory value thereby
creating the inconsistency as modeling technology/data improved.

One might ask- Does this constitute a case of science that does not match
an agency's predetermined position with the anticipation of what will be
the rationale they will use to get around the science? [sorry, my cynical
side is peeking out.]

>        [Charp, Paul]  The rumors I have heard is that the regulation is
>still in limbo.  Also, I have heard that EPA headquarters as determined
>that even if data support an increase in the standard, e.g., 60K pCi/L
>for H-3 from the current 20K pCi/L, the increase will not be allowed;
>only a decrease.

Disclaimer:  the above are the personal musings of the author, and do not
represent any past, present, or future position of NIST, the U.S. government,
or anyone else who might think that they are in a position of authority. 
Lester Slaback, Jr.  [Lester.Slaback@NIST.GOV] 
NBSR Health Physics 
Center for Neutron Research 
NIST 
Gaithersburg, MD  20899 
301 975-5810