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

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Draft p. 2.3.5, Table 2.3.4<br />

Issue<br />

Response<br />

45<br />

RADIOLOGICAL ISSUES<br />

This table is obsolete. Use natural background as summarized in NCRP-45. (113-EPA)<br />

Data from NCRP-45 (NCRP 1975) were used in the final Statement.<br />

Draft p. 2.3.5, Table 2.3.4<br />

Issue<br />

One commenter noted that the 130 man rem/yr is at variance with the 102 man rem/yr in<br />

BEIR I. (8)<br />

Response<br />

In final Section 3.3 natural background is given as 65 to 125 man rem/yr depending on<br />

location in the country. These values were obtained from NCRP-45 (NCRP 1975). The value<br />

in Table 2.3.4 was taken from an EPA document. However, EPA in commenting on the draft sug-<br />

gested use <strong>of</strong> NCRP-45 as more appropriate.<br />

The discrepancy with BEIR I was not investigated.<br />

Draft p. 2.3.5<br />

Issue<br />

One commenter noted that in discussing radioactivity DOE states "Presently the linear<br />

theory is unproven at low levels. For this reason, health effects numbers at low levels<br />

must be stated as a possibility, with another possibility being zero."<br />

DOE does not mention the treatise <strong>of</strong> Dr. Karl Z. Morgan, noted health physicist,<br />

entitled "The Linear Dose is Non-Conservative" which suggests that low doses rather than<br />

having linear health effects result in a higher number <strong>of</strong> health effects than had previously<br />

been considered and higher than linear anticipates according to the BEIR report. The stud-<br />

ies <strong>of</strong> Dr. Morgan should be included in DOE's section on radioactivity, especially when the<br />

theories at the opposite end <strong>of</strong> the spectrum are given recognition. (See p. 2.38 re N. A.<br />

Frigerior and R. S. Stone).<br />

Also Dr. Ernest P. Radford, chairman <strong>of</strong> the BEIR Committee, testified before Congress<br />

(Feb. 1978) that his Committee had erred in 1972 in setting radiation standards and that in<br />

certain cases, the permissible limits were set at least 10 times too high. He said: "The<br />

human data obtained from populations exposed to highly ionizing radiation such as alpha

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