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Draft p. C.2<br />

Issue<br />

51<br />

RADIOLOGICAL ISSUES<br />

The paragraphs ending the section on "Background" and initiating "As Low As Reasonably<br />

Achievable Application" reflect some bias and a lack <strong>of</strong> candor in describing the use <strong>of</strong> risk<br />

coefficients in radiation protection. Almost all government agencies, particularly the EPA<br />

but including the NRC and the OSHA, have used or are using risk coefficients to estimate<br />

impact <strong>of</strong> radiation exposure. The ICRP (Reference 11, draft Appendix C) has gone entirely<br />

to a risk-based radiation protection system, using estimates <strong>of</strong> risk in optimizing radiation<br />

protection. ICRP has stated, "These risk factors are intended to be realistic estimates <strong>of</strong><br />

the effects <strong>of</strong> irradiation at low annual dose-equivalents (up to the Commission's recom-<br />

mended dose-equivalent limits)" (ICRP Publication No. 23, 1978). The NCRP (Reference 15,<br />

draft Appendix C) seems to stand alone in its position discounting the use <strong>of</strong> linear, non-<br />

threshold risk coefficients in radiation protection. (113-EPA)<br />

Response<br />

Risk factors were used in extimating health hazards, but only -to the extent that the<br />

incidence <strong>of</strong> cancer and genetic effects could be related to doses to population groups.<br />

Draft p. C.3, Table C.1<br />

Issue<br />

While the table is titled "Comparison Chart <strong>of</strong> Radiation Standards," it then lists<br />

"Standards or Criteria" and references ICRP and NCRP values or reports. ICRP and NCRP<br />

reports are recommendations or suggestions which may or may not be adopted or modified and<br />

adopted by national regulatory agencies. The references to ICRP and NCRP should be deleted<br />

from the table.<br />

It should be noted, however, that there are ICRP reports pertinent to health effects.<br />

ICRP Publication 26 (Reference 11, draft Appendix C) and ICRP Publication 27 ("Problems<br />

Involved in Developing an Index <strong>of</strong> Harm," 1977), both provide recommendations on<br />

"acceptable" numerical risk estimates for radiation workers. (113-EPA)<br />

Response<br />

Because the work <strong>of</strong> NCRP and ICRP should be identified, the column heading has been<br />

changed to include recommendation; ICRP 26, 27 and 28 has been added under health effects.

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