Re: EPA Radiation Protection Guidance

["Russ Meyer" <CMEYER@brc1.tdh.texas.gov>]

> Date:          Wed, 8 Feb 95 11:29:44 -0600
> Reply-to:      radsafe@romulus.ehs.uiuc.edu
> From:          Al Tschaeche <ant@pmafire.inel.gov>
> To:            Multiple recipients of list <radsafe@romulus.ehs.uiuc.edu>
> Subject:       Re: EPA Radiation Protection Guidance

> 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
> >


you're right on the mark, Mr. Tschaeche,  our comments to the EPA
will be the same.  Adolph Hitler was credited with the statement "
If you yell a lie loud enough and long enough, someone is bound to
believe you".  I wonder if that works for the thruth also?>


Russ
cmeyer@brc1.tdh.texas.gov
(512)834-6688