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

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58<br />

RADIOLOGICAL ISSUES<br />

Transuranium Elements in the General Environment. Since this Guidance has appeared only for<br />

comment and has not been <strong>of</strong>ficially promulgated, it seemed inappropriate to cite it as an<br />

<strong>of</strong>ficial EPA position. In any case, the risk factors proposed by EPA in that document dif-<br />

fered only marginally from the Mays factors (e.g., 250 bone cancer deaths/10 6 personrad<br />

versus 200 bone cancer deaths/10 6 person-rad).<br />

Draft p. E.10<br />

Issue<br />

Although BEIR, 1972 did not provide a risk estimate for skin cancer, the 1978 Stockholm<br />

meeting <strong>of</strong> ICRP suggested if a skin cancer risk is required, an estimate <strong>of</strong> one fatal cancer<br />

per 106 person rem could be used. Averaging the risk estimates in UNSCEAR 1977, the skin<br />

cancer incidence is around 0.5 cases per year per 106 person-rem; with a 6% mortality this<br />

would be about two fatal skin cancers per 106 person-rem. The 1977 UNSCEAR Report sug-<br />

gests alpha risk might be higher. (113-EPA)<br />

Response<br />

The EPA correctly notes that, although the BEIR Committee considered numerical esti-<br />

mates <strong>of</strong> skin cancer risk unwarrented, as quoted on page E.10, data have been published from<br />

wh-ich such estimates could be derived. While UNSCEAR-77 discussed these data, it did not<br />

put forward a single risk factor. The ICRP .at its 1978 Stockholm meeting did, as noted by<br />

the EPA, suggest a risk factor <strong>of</strong> one fatal skin cancer/106 person-rem, primarily because<br />

their weighted system <strong>of</strong> dose evaluation was logically incomplete without such a number.<br />

Although it would be possible to estimate fatal skin cancer incidence employing the ICRP<br />

risk factor, the EPA has not suggested that this be done. It seems more instructive to call<br />

attention to the general lack <strong>of</strong> significance <strong>of</strong> radiation-induced skin cancer than to pro-<br />

duce numerical estimates <strong>of</strong> infinitesimal risk.<br />

Draft Appendix E<br />

Issue<br />

There is no mention <strong>of</strong> recent findings by the British National Radiological Protection<br />

Board or American National Academy <strong>of</strong> Sciences which were reported in the May 19, 1979 issue<br />

<strong>of</strong> the "London Economist." (104)<br />

Response<br />

Appendix E contains reference to the bulk <strong>of</strong> recent literature regarding the relation-<br />

ship between radiation exposure and possible latent health effects. It is believed that the<br />

material presented is in essential accord with the findings <strong>of</strong> the American National Academy

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