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Management of Commercially Generated Radioactive Waste - U.S. ...

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E.2<br />

levels derived by linear extrapolation from data obtained at high doses and dose rates, as<br />

actual risks, and <strong>of</strong> basing unduly restrictive policies on such interpretation or<br />

assumption" (NCRP 1975, p. 4).<br />

( a )<br />

An alternative approach involves direct comparison <strong>of</strong> the estimated radiation doses<br />

from CWM activities with the more accurately known radiation doses from other sources. This<br />

avoids the most uncertain step in estimating health effects (the dose-effect relationship)<br />

and provides a comparison with firmly established data on human exposure (i.e., the exposure<br />

to naturally occurring radiation and radioactive materials). Some people prefer to judge a<br />

risk's acceptability on knowledge that that risk is some certain fraction <strong>of</strong> an unquantifi-<br />

able, but unavoidable, natural risk, than to base this judgement on an absolute estimate <strong>of</strong><br />

future deaths that might be too high or too low by a large factor. Because <strong>of</strong> these judg-<br />

mental problems it is the practice in this Statement to compare estimated radiation exposure<br />

from CWM activities with naturally occurring radiation exposure as well as to indicate esti-<br />

mates <strong>of</strong> cancer deaths and genetic effects.<br />

E.1 LATE SOMATIC EFFECTS<br />

Recently much literature has dealt with the prediction <strong>of</strong> late somatic effects <strong>of</strong> very<br />

low-level irradiation. This literature is not reviewed in detail here because it is recent<br />

and readily available. Instead, the various dose-effect relationships that have been pro-<br />

posed are briefly considered and justification is given for the range <strong>of</strong> values employed in<br />

this Statement.<br />

Two publications have served as the basis for most recent efforts to quantify late<br />

( b )<br />

somatic effects <strong>of</strong> irradiation. These are the so-called BEIR Report, issued in 1972<br />

by the National Academy <strong>of</strong> Sciences as a report <strong>of</strong> its Advisory Committee on the Biological<br />

Effects <strong>of</strong> Ionizing Radiations (NAS-NRC 1972); and the so-called UNSCEAR Report, a report<br />

to the General Asembly by the United Nations Scientific Committee on the Effects <strong>of</strong> Atomic<br />

Radiation, most recently revised in 1977 (UNSCEAR 1977).<br />

Both the BEIR and UNSCEAR Reports draw their conclusions from human effects data derived<br />

from medical, occupational, accidental, or wartime exposures to a variety <strong>of</strong> radiation<br />

sources: external x-irradiation, atomic bomb gamma and neutron radiation, radium, radon and<br />

radon daughters, etc. These observations on humans were, <strong>of</strong> course, the result <strong>of</strong> exposures<br />

to relatively large total doses <strong>of</strong> radiation at relatively high dose rates. Their extrapolation<br />

to the low doses and dose rates <strong>of</strong> concern to us is acknowledged by the BEIR Report as<br />

"fraught with uncertainty" (p. 7). The BEIR Report concludes, however, that the assumption<br />

<strong>of</strong> a linear relationship between dose and effect, extending to zero dose with no threshold<br />

dose below which no effects are predicted, "in view <strong>of</strong> its more conservative implications,...<br />

(a) EPA commented that this paragraph reflects a bias on the part <strong>of</strong> the authors. However,<br />

the NRCP quotation was chosen because it represented the negative point <strong>of</strong> view, and it<br />

was the purpose <strong>of</strong> this paragraph to reflect that point <strong>of</strong> view.<br />

(b) A version <strong>of</strong> this report is in progress.

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