FGR-13 and H-3 -Reply

[MICHAEL S FORD <MFORD@pantex.com>]

>>> "Pilt, Aadu" wrote on Fri 24 Jul 98  12:59 >>>
Radsafers:

There has been much discussion of the "evils" of FGR-13 and how
it purports to give risk coefficients "per Bq
ingested/inhaled/exposed"

Well, I'm not convinced that this is any different from the approach
taken by the IAEA etc. in the Basic Safety Standards....

... So I conclude that all FGR-13 does is multiply the IAEA dose
conversion factors by the IAEA risk coefficient (for all intents and
purposes).  We do this all the time anyway. What's the big deal?

Dr A A Pilt
Emergency Measures Ontario

aadu.pilt@jus.gov.on.ca
>>>>>>>>>>>>>>>>>>>>>>>>

Dr. Pilt,

The problem with FGR No. 13 is that expressing mortality risk on
the per atom level -- with no mention of a threshold -- is absurd.

You are correct.  The math works out very nice, but the principles
behind the math (extending down to per atom exposures) are built
on sheer conjecture with multiple contradictory data sets
demonstrating that even the math is wrong at such low levels.

Much the same way that EPA established radon limits based
almost entirely on what the technology was capable of (not a
safety-based level),  the stated intent FGR No. 13 is to "promote
consistency in assessments of the risks to health from radiation by
Federal agencies and others and to help ensure that such
assessments are based on sound scientific information."  

In essence, EPA has generated this report to make their math easier
and more consistent.  Unfortunately, EPA has ignored the problem
that when you reduce these concepts down to absurd levels,
"sound scientific information" supporting radiation-induced fatal
cancers does not exist.

On the individual level, the mortality risk factors are insignificant. 
The problem comes in with collective dose calculations where
these insignificant risks are summed up to create fictitious dead
people out of real populations.  

When the public reads a government risk assessment and finds
that 1 or 2 people (out of a million, say) are going to die because of
a particular operation, do you think they find that comforting, let
alone fully understand the underlying assumptions and
probabilities?

Persons (or relatives of persons) claiming injury will attempt to
force the government, state, municipality, or business to prove that
they were not in fact THAT fictitious dead person(s).  The effort and
money expended just trying to cover your backside to address this
liability become a BIG negative for some operations.  Too much to
handle for others.

As scientists and engineers, we understand these complications. 
*In general*, the politicians and the public do not.  So when the
EPA decides to express exposure to radioactive material in terms of
DEATH PER ATOM (which is way the headlines will read), we'd
better make darn sure there's more than supposition and
hypothesizing behind the numbers.

v/r
Michael
*************************
Michael S. Ford, CHP
Texas Radiation Advisory Board
Address:
Radiation Safety Department
Battelle Pantex
Amarillo, TX
806.477.5727 phone
806.477.4198 fax
mford@pantex.com
*************************

Quote along the lines of Bernadette's thread today:  

"I know this now.  Every man gives his life for what he believes. 
Every woman gives her life for what she believes.  Sometimes
people believe in little or nothing, yet they give their lives to that
little or nothing.  One life is all we have and we live it as we believe
in living it.  And then it is gone.  But to sacrifice what you are and
live without belief, that's more terrible than dying."

Joan of Arc