Re: EPA Radiation Protection Guidance

[Al Tschaeche <ant@pmafire.inel.gov>]

I have perused the EPA proposal and offer the following comments to those 
who might be moved to respond to the EPA's request to comment.
1.  The EPA uses the "linear hypothesis" to determine the cancer risk 
from low levels of radiation.  That hypothesis has come under some 
criticism in recent months and years.  It might be worthwhile for all of 
us to comment to the EPA to hold off on promulgating this proposed rule 
until both the Health Physics Society and the NCRP have completed their 
evaluations of whether the hypothesis should continue to be used or 
whether some other hypothesis is appropriate as a basis for setting 
radiation protection standards.
2.  The Health Physics Society board of directors, at its meeting on 
January 29, 1995 in Charleston, SC voted to refer a petition by Wade 
Patterson that asked the HPS board to reevaluate the hypothesis, to the 
HPS Scientific and Public Issues committee, currently chaired by Ken 
Mossman.  I don't know how long Ken will take to complete the evaluation, 
but it does seem as though the EPA should wait to see what comes of it.
3.  The NCRP (National Committee on Radiation Protection and 
Measurements) recently set up a committee to do a similar reevaluation.  
Art Upton is chair.  The EPA should certainly wait for this committee to 
complete its work before promulgating the proposed guidance.
4.  I urge all those who are interested in this subject to get the EPA 
document, 59 FR 66414 12/23/94, and, if necessary, request and extension 
of time to submit comments.  This is too important an issue for the EPA 
to rush into.
Al Tschaeche, INEL phone 208-536-3383, e-mail: ATSCHAEC@INEL.GOV

On Tue, 7 Feb 1995, Jim F. Herrold wrote:

> 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 
>