P.1 

OAR Box 1103 

Prepped by RyanDugan 

Document Number: 

119) IV-D-25 

Docket Number: 

A-83-41 

Printed 4/11/2008 1:50:52 PM Sheet 119 of 174 
P.2 

•_••, . 0_.*-_9./95 15:36 EPfl REGIONAL COUNSEL ATLANTA,Gfl. 

...to »'«* 

** _____* 

X w<* 

UNITED STATCfc ENVIRONMENTAL PROTECTION AGENCY 

REGION 

_ 4 9 COUBTI AMIS 

IV 

ft*l f-CET. N.E. 

ATLANTA. OCOROli *v 30S0 3 

Feb. 21, 1995 

MEMORANDUM 

SUBJECT: PR 12/23/94, j"Federal 

Exposure of the General PuJbliCn 

Radiation Protectio n Guidance for 

FROM: 

TO: 

Paul Wagner, jChief, 

Office of Radiation 

Allan Richardson, Deputy 

Criteria & Standards Division 

Director 

, ORIA, 6602J 

we have reviewed the December 23, 

Federal Radiation protection Guiaainde 

Public. Our office appreciates rece 

very important for the 

with you ana others in 

reports before Lhey are in FR 

specific comments: 

regional 

ORIA HQ in 

The 

, 1994 Notice on the new 

tor BxpbBure of the General 

iving several copies. It is 

_ ation office to be involved 

evaluating! and reviewing these 

following are my general and 

radiation 

and 

exposures 

reference 

As stated in the "Summary 

is emphasized to ensure 

Although, T, as heialth physics 

to this principle,! in EPA's 

regulations, such las the current 

Site Cleanup Standards", 

avoided. In other! words, the 

specifically being told that 

place in ORTA's regulations, 

Protection Guidance it is not 

encouraged and emphasized. 

ORIA to the other parts should 

this notice. Hither eliminate 

include it in current rulemakinjg 

above. 

On p.66415, 2nd column, the 

doesn't include gliobal fallout, 

column, iBt sentence, It does, 

to much in the overall background 

significant at areas around nuqlear 

Nevada Test Site. 

On p.66415, top of 3rd column, 

exposure in flight, are airline 

considered general public? 

SSL' §r£b 

: ~ / 

throughout the notice, ALARA 

are well below the RPG. 

professional know and adhere 

radiation protection 

rulemaking for "Radiation 

to ALARA is specifically 

regional radiation offices are 

ALARA principle has no 

yet here in this Federal 

referred to, it is 

from one part of 

be dealt with starting with 

references to ALARA or 

s such as the 196 mentioned 

the 

and 

only 

Consistency 

definition Of natural background 

whereas on p.66427, 3rd 

Although this doesn't amount 

of 300 mrem/yr, it is 

weapon sites like the 

in reference to radiation 

piloca, attendants, etc. 

Rec ent ourvcyo, studies, Health 

PrlntwS on ftoeyclea Paper 
P.3 

i . 

01/19/95 15:36 EPfl REGIONAL COUNSEL ATLANTA,GA. 003 

Physics Journals, have shown 

over l rem/yr, yetj they haven-' t 

workers due to the' natural 

their radiation exposures at 

been defined as radiation 

sour;e of the radiation. 

On p.66417, bottom; of 2nd columh 

"preponderance of scientists", 

is best, and EP A should use it. 

what groups or individuals 

would doubt DOE, DDD, or NRC woiild 

the Health Physics; Society, as 

Elect and former director of ORfCA 

Health Physics chapters and 

linear model no longer has su* 

organizations and fellow federal 

Ignored. Please indicate which 

support the linear model. 

inVol untary 

On p.66422, bottom of 2nd colutnp 

other risks, voluntary or 

justification for any particula^ 

risk". We would like to note t 

rulemakings such as the NESHAP 

on the philosophy that radiatiojn 

facilities is an involuntary 

dose limit8 that Resulted (10 

says that because a 

:hink that the linear model 

Better support for exactly 

this is needed here. I 

believe this, as well as 

evidenced by the Presidentwho is visiting all local 

evidence that the 

These people and 

agencies should not be 

scientists or groups who 

beli sve 

pro aiding 

ppart 

says that "existence of 

is not a 

incremental radiation 

lat some of ORIA's 

Radionuclides, rely heavily 

exposure from nuclear 

thus justifying the low 

em/yr) . 

risk 

rrtri 

On p.66423, bottOni of 2nd columjn 

I mentioned earlier. This 

contradicts the current no 

rulemaking. 

On p.66424, bottom of 1st 

for man-made radionuclides. 

Radium or alpha-emitters limite 

discussion 

-ALARA. 

again emphasizes ALARA, as 

in "Recommendation 4" 

policy of the 196 

colunjn, refers to 40 CFR 141 only 

is there no mention of 

(141.15)? 

Why 

Concerning the "Request for Coameats" questions 

For #1, 100 mrem is 

federal agencies' 

consietent 

regulations 

For #5, I don't know the 

weighting factors may 

allowed under the old 

iodines to thyroid, 

factors vs. uncertainty 

studied further. 

For #7, until all agencies 

change, the old units should 

consistency but because the 

usually forget that health 

other radiation workers aire 

with ICRP and other 

and orders. 

Specifics, but the use of 

higher organ doses not 

organ limits, e.g. 

ion for weighting 

arid underestimation should be 

allow 

crit ical 

Cons_ derat 

and state regulations 

remain, for not only 

regulators and professors 

physics technicians and 

used to and familiar with 
P.4 

ai'19.'95 15:37 EPA REGIONAL COUNSEL ATLANTA,GA. __-. 

3 

the current units, Changi ig 

confusion and may compromise 

exposure. Remember not 

reads health physics journja 

units should he included ii 

evsryone 

them will cause massive 

safety and unwarranted 

has a masters and 

Is. Nonetheless, the Si 

parentheses. 

For #8, ecological risks and dose limits should be 

addressed and not ignored. Superfund is certainly not 

ignoring Lhem. They arc currently addressing 

ecological risks for chemicals, etc., and are 

continually asking for radiation ecological assessments 

and acceptable dose levels. Using current ecological 

reports and limits from iDCE Orders and NCRP guidance is 

not enough. Jt only targets aquatic organisms (1 

rad/day). And doesn't have much technical support. 

Perhaps a list of adequate references of ecological 

studies involving radionuclides would help. 

We appreciate the opportunity to 

recomrnendatione. Should you or 

contact Jon Richards at #404/347 

continent on these proposed 

others have any questions, please 

3595,ax_.69Rfl.