Re: Fed. Guidance Report 13

[tmohaupt@wright.edu]

Otto,

Thanks for the heads-up notice about the Federal EPA Guidance Report 
# 13 - Part 1.  How can we get a copy of the report to review?  How long
is it?  I agree that this issue needs to be addressed and reason 
applied.  I'm glad they didn't use BEIR VI tactics for promulgation.

Date:          Mon, 09 Mar 1998 10:27:03 -0600 (CST)
From:          "Otto G. Raabe" <ograabe@ucdavis.edu>
Subject:       Fed. Guidance Report 13
To:            Multiple recipients of list <radsafe@romulus.ehs.uiuc.edu>
Reply-to:      radsafe@romulus.ehs.uiuc.edu

March 9, 1998
Davis, CA

An issue that will be attracting attention is the release by EPA of the
Interim Version of Federal Guidance Report#13-Part 1, "Health Risks from
Low-level Environmental Exposure to Radionuclides."  The comment deadline
is June 30, 1998. 

This report establishes radiation risk coefficients for mortality and
morbidity for about 100 radionuclides to be used by all federal agencies
for their regulatory programs and when conducting environmental impact
assessments, etc. Federal Guidance Report 13 is an attempt to codify the
linear-no threshold risk model by assigning a numerical cancer risk to
every single inhaled or ingested becquerel for every major radionuclide! 

The cancer-induction dose-response relationships for every internal emitter
that I have studied are all very non-linear with an effective threshold at
surprising high doses. Among the U.S. radium cases the lowest dose to the
skeleton that led to bone cancer was in excess of 10 Gy, 200 Sv or 20,000 rem!

EPA will use this report to generate smaller and smaller dose limits that
will be expensive if not impossible to meet and yield no actual societal
benefits. The NRC is upset about this report since they were supposedly
co-sponsors. 

Health Physicists should review this Interim Report and submit comments to
EPA by June 30. Also, send comments to your congressional representative
and Senators, and to the President and his science advisors.

Otto
		*****************************************************
		Prof. Otto G. Raabe, Ph.D., CHP
                [President, Health Physics Society, 1997-1998]
		Institute of Toxicology & Environmental Health (ITEH)
		     (Street address: Old Davis Road)
		University of California, Davis, CA 95616
		Phone: 530-752-7754  FAX: 530-758-6140 [NEW AREA CODE]
		E-mail ograabe@ucdavis.edu
Tom Mohaupt, MS, CHP
Wright State University
Radiation Safety Officer

Voice:  (937) 775-2169
E-mail:  tmohaupt@wright.edu