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