et AAEC
C~s
-15-
.
on
eS
The recoamendations of the ational Council on Radiation Protection
and Measurement set forth in I, and the recenmendations of the International
Comnission on Radiological Protection set forth in III, are explicit in
offering no guidance.
II is a discussion of the hot particle problem taken from ihe
report cf an ICRP Task Group.
official guidance.
It is not. intended to give dispositive
The discussion is useful commentary, but inconclusive.
The very conditional statement made in the first and second sentence of Il
(41) is not generally convincing.
‘
With regard to the previously cited method of risk estimation
described in the first sentence of 4.6.5, that section continues with the
following supportive references:
“This approach has been used by the Environmental
Protection Agency in recent reports on the potential
health consequences of the nuclear fuel cycle.o
The approach leags to estimates comparable to those
of Gavankar® following Thompson et al’ based on
linear non-threshoid extrapolation Of observations
°
on beagle dogs administered 239Pu0 aerosols."
As to the first, consensus in error may provide amiable agreement amongst
federal agencies, but seems hardly a desirable basis for decisions involving
the public healh and safety.
The observations on beagle dogs are discussed
further on 4. G- 7 and deserves separate consideration.
It requires pathological optimism to find reassurance in the
-results of the now completed Hanford beagle experiment.
Dogs were given
initial aerosol burdens of approximately 1-10 microcuries of Pu
239
0.
By
Nine years post-exposure the lung cancer response was virtually saturated
and multicentric origins were noted in some dogs.
Those receiving larger
ws.
lung burdens greater than 10 microcuries died of pulmonary insufficiency
within 4-1/2 years.
Twenty-one dogs survived for more than 4-1/2 years,
An