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

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47<br />

RADIOLOGICAL ISSUES--<br />

(J. F. Franmeni, Jr;, editor,. Academic Press, New York, 1975). Little support is given.for<br />

the assertions in the referenced paper.<br />

In a more complete-report by the same author (N. A. Frigeri.o, K. F. Eckerman, and<br />

R. S. Stowe, "Carcinogenic Hazard from Low-Level, Low-Rate Radiation," ANL/ES-26, 1973)<br />

where all methods and assumptions are given, there are several flaws. A major flaw is the<br />

assumption that "all forms <strong>of</strong> cancer show-very similar doubling doses and closely similar<br />

increases in mortality rate per rad". This assumption is made contrary to the evidence in<br />

ICRP, UNSCEAR, BEIR, and other reports that variations in the susceptibility <strong>of</strong> tissue to<br />

induction <strong>of</strong> different forms <strong>of</strong> cancer by irradiation are quite large and not necessarily<br />

related to the marked variations in natural incidence <strong>of</strong> the diverse types <strong>of</strong> cancer.<br />

There are also problems in the statistical analysis in ANL/ES-26: misuse or misinter-<br />

pretation <strong>of</strong> the t-statistic, failure to-use Scheffes'.test or calculations <strong>of</strong> variance<br />

ratio to check the significance <strong>of</strong> the series <strong>of</strong> t-tests, and use <strong>of</strong> gross averages in the<br />

analysis.<br />

In reality, the paper can be shown to be erroneous by inspection <strong>of</strong> Frigerio et al.'s<br />

source <strong>of</strong> cancer mortality data, NCI Monograph 33, Patterns in Cancer Mortality in the<br />

United States: 1950-1967. In Monograph 33, Burbank presented an analysis <strong>of</strong> Dynamic Geo-<br />

graphic Distribution for each cancer. The complex pattern <strong>of</strong> increasing and decreasing can-<br />

cer mortality by state and cancer show that factors other than background are the major<br />

driving force in cancer mortality rates and that natural background radiation is not.<br />

Indeed, in a later publication (A. P. Jacobson, P. A. Plato and N. A. Frigerio, "The<br />

Role.<strong>of</strong> Natural Radiations in Human Leukemogenesis," Am. J. Public Health, 66, p. 31-37,<br />

1976), a more reasonable major conclusion was reached: "It appears that conditions rela-<br />

tive to populations and.their environment could mask a radiation effect, if in fact one is<br />

present." (113-EPA)<br />

Response<br />

References 25 and 26 were deleted.<br />

Draft Section 2.3.3<br />

Issue<br />

Several commenters suggested that a discussion <strong>of</strong> the observed health-effects caused<br />

by differences in natural radioactivity between different regions or states should be<br />

included in the Statement. (10, 198)<br />

Response<br />

The general public is probably too mobile to permit development <strong>of</strong> the epidemiological<br />

data in quantity and certainty in order to identify effects at these low levels. However,

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