- 26 the author meant by this term, and "a few picocuries of alpha activity". Page 13, lines 15-17 - "The published evidence, reviewed above, clearly indicates that a linear extrapolation to lower doses and dose rates is not conservative for internal alpha emitters." Comments: This statement is not clear about anything in it, not the “published evidence" or what is "reviewed above" that is pertinent to the statement, not the level of dose or dose rate (and associated efficiency for the effect) from which extrapolation linearly is supposed to be "not conservative", not the shape of the dose-effect curve that is regarded as nonconservative as compared with the linear one, not the meaning of "conservative", not the effect being considered in the statement, and not the kinds of alpha emitters referred to or their properties. this is a sweeping and poorly founded generalization. Again, See “wyprevious comments on the author's pages 4 and 5. Page 13, lines 17-19 - "The initial effects of alpha interactions with cell chromosomes are irreversible and thus will vary linearly with alpha dose rate." Comments: On his page 3, the author states: "When alphas interact with the chromosome or its gene in the nucleus of the cell, the dense Lonization in the track of the alpha particles give rise to closely spaced breaks which bring about a wide variety of irreversible chromosome structural changes, or mutations. X-ray and y-ray interactions give rise toa diffuse distribution of ions, resulting in widely spaced individual breaks, most of which can undergo repair by recombining without structural change. Thus permanent structural changes for x-raysand Y-rays are proportional to the square of the dose, with greatly reduced incidence