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

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28<br />

Most <strong>of</strong> the argument on the RSS report centered on low dose rate,<br />

low LET radiation. Alpha radiation dose response curves are usually The genetic effects estimates attributed to the BEIR report and<br />

characterized as both linear and dose rate independent (BEIR, 1972; EPA in Table E.3 are not comparable to those given in the 1977 UNSCEAR<br />

UNSCEAR, 1977) or as possibly providing underestimated effects at low report since they assume a 30-year reproductive generation time. To<br />

doses (Martin Brown, J., "Linearity vs. Non Linearity <strong>of</strong> Dose Response compare the BEIR and EPA estimates with those <strong>of</strong> UNSCEAR, the BEIR and<br />

for Radiation Carcinogenesis," Health Physics, 31, pp.231- 2 4 5, 1976; EPA estimates should be multiplied by a factor <strong>of</strong> about 0.6 to adjust<br />

Archer, V.E., Radford, E.P., and Axelson, 0.; "Radon Daughter Cancer in for a 30-year population generation vs. the current, approximately<br />

Man: Factors in Exposure-Response Relationships," Health Physics 50-year population generation. More recent EPA estimates have been<br />

Society Annual Meeting, June 1978). No reports except the RSS report adjusted for the current population generation (EPA 520/1-76-010), to<br />

consider a threshold curve a viable concept, yield 200 genetic effects, close to the UNSCEAR 1977 estimate.<br />

129. (Page E.4, Table E.1) A column in Table E.1, headed 131. (Page E.9, Table E.4) The column titled "Mays(19)" may contain an<br />

"Environmental Protection Agency," purports to be the risk estimates error. Mays, et al. (reference 19) estimated 200 bone cancer<br />

used by EPA. They are actually averages for various risk models used<br />

by EPA in reports and therefore are not directly comparable to the<br />

deaths/10 person-rads. Using a 0 <strong>of</strong> 10, this would be equivalent to<br />

20 bone cancer deaths/10 6 other risk estimates in the table.<br />

person-rem. In a contemporary paper (Mays,<br />

C.W., Estimated Risk from 39 Pu to Human Bone, Liver and Lung,<br />

The estimates<br />

<strong>of</strong> 54 leukemia death person-rem listed in the<br />

The estimates <strong>of</strong> 54 leukemia deaths/000 person-rem lis ted in the<br />

pp. 373-384 in Biological and Environmental Effects <strong>of</strong> Low-Level<br />

Radiation Vol. II, IAEA, Vienna, 1976), Mays estimated (again assuming<br />

table were extracted from EPA 520/9-73-003-B (reference 4). As stated a Q <strong>of</strong> 10) 20 lung cancer deaths, 20 bone cancer deaths and 10 liver<br />

in that report (p. A-14), the risk conversion factors are average<br />

values for absolute and relative risks in the BEIR Report, 1972.<br />

cancer deaths per 106 person-rem.<br />

Moreover, they apply only to the dosimetric models used in EPA report EPA in its guidance on transuranium elements (EPA 520/4-77-016)<br />

520/9-73-003-B. provided an analysis <strong>of</strong> the health impact <strong>of</strong> exposure to transuranium<br />

elements in the environment which includes both risk and dose-rate<br />

The EPA risk for thyroid listed in Table E.I, 15 thyroid cancer estimates for a cohort <strong>of</strong> 100,000 exposed since birth. This guidance<br />

deaths/10 6 person-rem, is referenced to EPA 520/4-76-017 is supplemented by technical reports, Technical Report EPA 520/4-78-010<br />

(reference 6). That risk estimate cannot be found the cited reference. and Technical Note CSD-78-1, which provide background information for<br />

However, on p. 96, ibid., it states "...., a population age weighted the basic guidance document. Since the health impact calculated in<br />

value <strong>of</strong> 60 thyroid cancers per million rems to the thyroid was used." these reports is based on lifetime exposure and risk coefficients for<br />

A similar risk estimate is shown in Tables 45 and 46 <strong>of</strong> EPA report specific organs, the results are not directly comparable with Table E.4<br />

520/9-73-003-C, Environmental Analysis <strong>of</strong> the Uranium Fuel Cycle. but they are a more realistic estimate <strong>of</strong> health impact from<br />

Part II - Nuclear Power Reactors, 1973. Note that these thyroid risk transuranium elements in the environment.<br />

estimates refer to cases, not fatalities,-and so do not fit into<br />

Table E.I. 132. (Page E.10, paragraph 6) Although BEIR, 1972 did not provide a<br />

risk estimate for skin cancer, the 1978 Stockholm meeting <strong>of</strong> ICRP<br />

130. (Page E.7, last paragraph and page E.8, Table E.3) Newcombe's suggested if a skin cancer risk is required, an estimate <strong>of</strong> 1 fatal<br />

estimate <strong>of</strong> ten genetic effects based on a normal incidence rate <strong>of</strong> cancer per 106 person rem could be used. Averaging the risk<br />

0.1 percent for autosomal dominant disorders has not been supported by estimates in UNSCEAR, 197 , the skin cancer incidence is around<br />

other studies. Current incidence estimates are about 1 percent 0.5 cases per year per 10 person-rem; with a 6 percent mortality<br />

autosomal dominant and X-linked disorders, the estimate in UNSCEAR, this would be about 2 fatal skin cancers per 106 person-rem. The<br />

1977. 1977 UNSCEAR Report suggests alpha risk might be higher.<br />

29<br />

133.(Appendix F) The description <strong>of</strong> the geology at the bottom <strong>of</strong><br />

page F.2 would be improved if there were some indication <strong>of</strong> the depth<br />

<strong>of</strong> the basement rocks and <strong>of</strong> the general nature <strong>of</strong> the overlying rocks.

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