I agree a lot with the sentiment of the CIEH position.
The range of changes to the 'CLEA SR GAC' approach put forward in the C4SL documents fall into two broad types:
1. Those consistent with the ethos of GAC calculation (e.g updating the AC inhalation rates from Draft USEPA to final USEPA).
2, Those that represent a 'riskier' departure from the Ethos of GAC calculation (e.g 'default' ELCR reduced from 1:100,000 to somewhere in the region 1:10,000 to 1:50,000, with the Generic C4SL Position at 1:50,000)
Type 1 changes are just updating our science base and could/should be adopted for GACs calculation and should be acceptable in the planning regime.
Type 2 changes (IMO) need wider debate before adoption in planning regime as the 'default' position.
Chris Dainton
Peak Environmental Solutions
http://peakenvironmentalsolutions.com/
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