Re: evolution of regs? -Reply

["Wesley M. Dunn" <WDUNN@brc1.tdh.texas.gov>]

> Date: Wed, 8 Feb 95 11:37:11 -0600
> From: Al Tschaeche <ant@pmafire.inel.gov>
> Subject: Re: evolution of regs? -Reply
>
> OK.  So how do we get it "fixed"?  Clearly we must respond to the EPA's
> request for comment.  But -- what is the appropriate replacement for the
> linear hypothesis?  We need to "help" the regulators with an alternative,
> not just say the linear hypothesis is wrong.
>
> Al Tschaeche, e-mail: ATSCHAEC@INEL.GOV
>


Several things are also being missed (note: I haven't started my
review yet, so these are general comments):

1) the linear/no threshold is being used to extrapolate to
population doses.  It is inappropriate to set the HYPOTHETICAL
maximally exposed individual's limit to the calculated limit for
AVERAGE population dose.

2) There are NO observed radiation effects at low doses (e.g., < Rem
quantities); and

3) The only observed chronic radiation effects are at very high
doses (e.g., Uranium miners and non-human studies)

Wes****************************************************************
Wesley M. Dunn, C.H.P., Administrator
Licensing Branch                        512-834-6688
Texas Bureau of Radiation Control       512-834-6690 (fax)
1100 W. 49th Street                     wdunn@brc1.tdh.texas.gov
Austin, Texas  78756
*****************************************************************