T. OL Pflaum

The following table summarizes some selected fatality rates and risks.
Activity

~

Fatality Rate*

Risk

All industries (1976)

14

1.4 x 1074

Construction (1976)

57

5.7 x i074

4.9

4.9x10°

5.6

5.6 x 107°

NTS (1965-1981 average)

27

2.7 x 1074

Enewetak cleanup

70

7.0 x 1074

At work (1980)

State of Nevada

DOE & Contractors

(1978-82 average)

*Par 100,000 worker-years.
¢

Because of the great variability in the data, and the requirement to
interpolate and extrapolate, it is essen
1 that a careful _unce
j
Analiuls ve made by EPA. This analysis is neces"
Oo ensure confidence that
the risk of cleanup does not exceed thegrisk from leaving the contamination

undisturbed; which may be as low as 10
22.

or lower.

Imaginary Versus Real Deaths!
The models used to assess the health effects (i.e. radiation-induced

cancer fatalities) on the Enewetak people during the planning phase estimated
< 3 health effects (cancer deaths) over 30 years with no cleanup and no

restrictions on island or food usage.

An analysis of the total radiation dose to the returning people of Enewetak
after the cleanup leads to the conclusion that there might be an additional
0.926 deaths in 30 years from cancer caused by radiation. This is compared to
the two persons who died in course of the three-year cleanup.
The uncertainty which is inherent in cancer-risk estimates is graphically
illustrated in Table V-4, page 147 in the 1980 BEIR report in which the
|
expected number from continuous exposure of one rad per. year to a population
of 1,000,000 ranges from zero to 568,

The risk estimates of cancer deaths as required by the proposed EPA standard
(maximizing risk estimates) give hypothetical, or imaginary deaths as compared
to the real deaths which do occur in construction projects. The fact is that
no increase in cancer rate has been, nor can be, identified at the dose levels
comparable to background radiation levels.

Select target paragraph3