Interim Fed. Guidance Report #13, Part 1

["Otto G. Raabe" <ograabe@ucdavis.edu>]

June 26, 1998
Davis, CA

There is still time to send EPA your comments about the Interim Version of
Federal Guidance Report No. 13, Part. Comments are due to EPA by June 30.
Send your comments to Lawrence G. Weinstock, U.S. Environmental Protection
Agency, Radiation Protection Division, 501 3rd Street NW, Washington, DC
20460.

I have recommended that EPA withdraw this report and substitute a
dose-based report that utilizes the best modern dosimetry but without the
questionable risk models. It is not just that EPA used linear no-threshold
models, but also that there is no assurance that their specific models are
either appropriate or accurate since no human data for the some 100
radionuclides were used to formulate the models. Also the report says it is
intended to provide risks for absorbed doses less than 0.2 Gy! For a low
LET radiation delivered to the lung, for example, this would be an
effective dose of only 24 mSv. In fact, EPA cannot prove that there exists
any non-zero risk for any of the radionuclides listed in FGR 13 for
lifetime effective doses smaller than 100 mSv.

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