EPA Radiation Protection Guidance

["Jim F. Herrold" <HERROLD@UWYO.EDU>]

In light of today's posts to radsafe regarding NESHAPS and other regulations, I
was wondering if anyone had seen the EPA's _Federal Radiation Protection
Guidance for Exposure of the General Public_ in the Federal Register, 12/23/94,
page 66414. It is very interesting reading. In summary, they are proposing to
reduce the maximum allowable risk of cancer five-fold from any Federally 
regulated activity involving sources of radiation by replacing the current 
allowable dose to members of the public by a single effective dose equivalent 
of 100 mrem/y from _all sources_ of ionizing radiation that are created or 
inhanced by human activities. Sources include not only industrial, defense-
related and scientific operations, but also: mining, waste disposal, 
transportation, CONSUMER PRODUCTS (like thorium mantles and smoke detectors), 
x-ray generators, etc. "Decisions on what exposures are appropriate candidates
for reduction through regualtion have been and will continue to be based on
legislative mandates and decisions by regulatory agencies."

Supposedly these recommendations do not apply to accidents, medical patients or
occuptional exposures. However, in a footnote they say a "useful test for
determining whether individuals should be considered workers or members of the
public is whether or not their presence in the exposure situation in question
is wihtin the scope of their employment."

Because exposure to the public will most likely be from a number of sources,
the recommendation reads: "authorized limits for sources should be established
to ensure that individuals and collective doses in current and future
populations satisfy the objectives of this guidance. These limits may be
developed for categories of sources or for specific sources. Authorized limits
for sources should normally limit doses to a fraction of the RPG for all sources
combined." These limits will be established by a "responsible authority."

The EPA expects "that these proposed recommendations could be implemented
relatively easily, since most of them are already, in large part, in effect."
They give the new 10CFR20 as an example. My copy of those regs still says (with
ALARA considerations) that 100 mrem (not a fraction thereof) is the limit
individual licensees are allowed to give members of the general public in one
year. The EPA goes on to say "the anticipated costs of implementing these 
recommendations are primarily those that would be incurred by the various 
agencies in modifying their own regulations..." and "... there are few direct 
implementation costs involved here." Hmmmmmm...

Here's another interesting quote from the notes:

"Assessments and records appropriate to the origin and magnitude of expected
doses and the exposed population should be performed and maintained to
demonstrate conformance with requirements which implement these
recommendations." Who is going to do this? Sounds like more work to me.

They are asking for comments before February 21. I think they summed it up
quite well themselves: "Under current guidance the average member of the public
now receives, from all the sources to which that guidance has consistently been
applied, only a very small dose - less than 0.01 mSv (1 mrem) in a year."

And: "As exemplified by the performance of many facilities over the past two
decades, doses to the public usually can be maintained far below authorized
limits through responsible and skillful control of radiation sources."

Obviously, the ALARA concept is working to keep exposures to the public far
below authorized limits. Do we need lower limits? Why don't we just set the
limit to zero and get it over with?

Obviously, these are my observations and mine alone, and do not express the
opinions of the University of Wyoming.
                                     
Jim Herrold, RSO