-6Page 4, lines 3-24 - "There is an increasing body of published
experimental evidence that reflects this t pd.
"Speiss and Mays 622) observed that for
Ra alpha radiation induced
bone sarcoma in man, the tumor incidence per rad approximately doubled
for a four-fold increase in the spacing of ““‘*Ra injections and that the
observed incidence of bone tumors s per rad in children was nearly twice
that for adults.
Upton et al. 23) show a significantly higher incidence
of tumors in mice for a given neutron dose at more protracted periods

of exposure. Moskalev and Buldakov(24) showed that fractionation of
the administered
Pu dose over larger periods of time increased bone
tumor induction. The higher tumor incidence per rad for the smaller
lung burdens of crushed 239pu0, microspheres observed by Sanders
seems best explained by the limited alpha irradiation of large numbers
of cells by numerous very small, mobile particles of low acticity Bor
particle (see below).

Hamsters subjected to low alpha doses from

10p

distributed quite homogeneously in the bronchiolar-alveolar region
show a marked increase in the lung tumor incidence per rad at very
low doses and dose rates\*’/?, And the incidence of bronchial cancer
in uranium miners reflects a higher tumor risk per rad at the lower
doses(2®) for this, jow dose rate exposure group. The tobacco radioactivity results

+)

indicate a significant tumor risk for the cumulative

alpha radiation dose from 1059 in insoluble particles in the bronchi
of smokers, involving much lower dose rates."

Comments:

Here the author indicates that "there is an increasing body of
" published experimental evidence that reflects this trend", i.e.,

referring to "marked inverse dose-rate vs. risk relationship."
Then the author cites various reports to support this.
It is well known that fractionation or protraction (reduction
of dose rate) of doses that as intensive doses are in the range of
high doses that are relatively inefficient (per rad) for carcinogenesis (i.e., in the declining part of the dose-incidence curve
following the peak at the most efficient dose level), owing
to excessive cell sterilization or destruction, will increase
the efficiency of such doses,

It is also well known that

fractionation or protraction of a dose that as an intensive
dose is in the rapidly rising portion of a dose-squared doseincidence relationship (an efficient dose) will reduce the

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