79

Bertell

April 15, 1988
Page 20:
(The

paragraph 3, line 2:

reference

Kerr,

references page 62)

The external
137,

with

1980

radiation dose

0.66

MeV

is

not

given

i nh

is primarily due to

gamma radiation.

The conver

rems from external gamma radiation would be:

1 R = 0.98 rem (Radiological Health
Handbook, Jan. 1970, US Dept. H,E, and
reduction
I
do
not
accept
an
arbitrary
calculations
of
external
radiation
by
30%
multiplication by 0.7)

the

esium
ion to

-)
all

{i.e.

It should also be noted that the external rac jation
dose one metre above the ground is inappropria re for
children.
Page 23:
Reduction

of the estimated 30 year transuranic whole
body dose from 350 mSv (35 rem) in Lessard 1983, to 0.2
mSv (0.02 rem) in Kohn 1988, requires formal sci ntific
explanation.
The Lessard 1983 findings were b ed on
actual urine measurements, not assumed diets.
Page 28:
Dr. Bertell does not accept the 30 year dose tab
on page 40 because of scientific flaws noted
previous pages.
This includes but is not limi
the Kohn reduction in external doses and i
attributable to transuranics without proper sci
evidence.

Page

30 Para.2

lation
n the
ed to
dose
ntific

Line 2,ff£::

The 250 urine samples have apparently already under
gone laboratory analysis.
There is no justif cation
for taking a random sample to collate This job should
be properly entered in computer together with p ace of
residence at the time of the testing.
The range should
be reported and the average
not the median sh uld be
used.
There is no justification for using a popplation
median
to
calculate
&
bad
collective
dose.
It
statistical practice.
level
If the lower detectabl
poses

a

problem

it

could

be

lowered.

At

an

rate,

urine
samples
with
below
detectable
amounts
of
plutonium could be combined and the combined sample
could be counted to obtain an average to be distfibuted
over the samples.

Select target paragraph3