ML20003G308
| ML20003G308 | |
| Person / Time | |
|---|---|
| Issue date: | 03/25/1981 |
| From: | Goller K NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | Harold Denton, Minogue R, Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE), Office of Nuclear Reactor Regulation, NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20003G307 | List: |
| References | |
| NUDOCS 8104290015 | |
| Download: ML20003G308 (5) | |
Text
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l DSI COMMENTS ON DRAFT STAFF PAPER h
INTERIM RADIATION RISK ESTIMATORS p.1 of Commission Paper, Item 1:
Item 1: While it may be true these estimators would be conservative for populations with greater natural resistance to cancer, we would be hard pressed to identify one if asked. This could also be misconstrued to imply that differences in spontaneous cancer rates among different nations are due to greater natural resistance.
In most cases, we believe the differences simply reflect different competing risks rather than resistance to cancer (e.g., people who die of malaria, dysentery, cholera, tuberculosis, etc., don't live long enough to die of cancer).
Item 2: Suggest changing to read: "The interim cancer risk estimators... (i.e.,
the means of the relative and absolute cancer risk projections for the Linear-Quadratic dose-response model }".
p.2 of Commission pacer, Item 3:
Suggest changing to read; "...which do not generally require detailed age-specific population dose-effect :cmputations.
Examples are generic assessments such as 10 CFR Part 51, Appendix A, environmental impact statements, and generic accident impact scenarios such as generated by the NRC CRAC Code. Other occasions, etc...
These interim values would not be the most appropriate way of quantifying potential risks to certain populations whose age, sex and ethnic proportions were significi.ntly differ-ent from the current U.S. population, or subsets of the U.S. population (e.g., children l
or the_ elderly). Those situations would require special considerations.
1 p.(i), paragraph 6: Suggest changing to read: "In addition, the risk estimators for exposure to low-LET radiation developed from BEIR-III,..."
p.(1), paragraph 7: Suggest changing to read:
...(2) exposure from ages 20 to 64.
Whil e....they should be minimized...."
l 810429o 0 6
o
. add title: " Attachment 1".
add authors to Attachment 1:
R. L. Gotchy, M. Parsont, and C. A. Willis.
delete " geometric" from " geometric means".
-, p.1:
p.2,-1 st. Ta bl e: Suggest modifying to read:
">25 rems **" with footnote;
"**D is the average dose to the population (rems)." " Genetic Risks: Suggest adding: "Due to the wide range of the values, the geometric mean is used to avoid serious upward biasing of the estimate.
p.3.-Equation: Move times synbol up 1 line, p.4 -Ta bl e : 1st. column for lymphoma should read:
"2.6_" and 4th, column should read "2.0".
6 p.5,-Table on Lung Cancer Deaths per 10 Person-Rem (High LET) should be corrected as shown in Enclosure 6 Attachment 1 in order to reflect January,1981 changes in BEIR III.
-3rd line below table should read:
...about 69 lung cancer mortalities..."
p.6,-Suggest changing to read:
"for example: for continuous high LET radiation exposure of males and females (both sexes combined) in the..., the thyroid cancer mortality --- would be calculated as 7.0 x 2.4 717_.
Similarly, for lung exposure to Rn-222 progeny, the mortality risk would be calculated as 28 x 2.4 67 (as compared to 69 by the previous method).
l, p.7, Table V-4: delete asterisk from title.
1 l, to Attachment 1: delete " CAW" from figures (credit is given on p.1 of I ).
. Enclosure 3, to Attachnent 1, p.1: Section 3, total mortality for males from chronic exposure; delete decimal point before 84.1.
p.4, of Enclosure 3; should read:
K (males) = 77.0_ and K (females) 1393
=
=
(10.86
)(1.397) p.7, of Enclosure 3; should read:
" females: 145(10.86) = 1 575".
2 p.4, of Enclosure 6 to Attachment 1:
2nd. line should read: "(same assumption made by BEIR III);
6 4th. line from bottom should read:
..110 deaths per 10 person-rem.
F_ rom Ta bl es V-17... "
2nd. line from bottom should read: "the absolute risk projection model 6
would be 134 deaths per 10 person-rem (i.e., 3 568 deaths from leukemia 2
6 and bone cancer + 5,,827 deaths from all other cancers per 70 x 10 person-rem).
p.5, Enclosure 6:
3rd. line should read (due to January,1981 changes in BEIR III Tables V-17 and V-20); "(36pfl0)(31) = 103 lung cancer..."
5th line should read: "about 71 deaths per 106 person-rem".
- 14th. line should also read:
... calculations are shown below."
p.6, Enclosure 6:
0 7th. line should read:
... (38_ deaths per 10 person-rem)."
17th. line should read:
...in the Tabl e S_-3 H_ earing..."
--g v
g
. p.7, Enclosure 6: Table should read (also change in Attachment 1 summary):
BEIR III and change footnote ** to read:
... EPA data from Dr. W. Ellett, 38 1 03 (Oct. 5,1980), and Federal Policy 71 Council Task Force Position Paper on 39 94 Radon in Structures," p.17 (Aug.15, 66, 1980).
39 99 69, p.7, paragraph 2 should read:
"While it is encouraging that the lung cancer mortality risk estimators..."
p 3, paragraph 1, '.ine 8 should read:
... probable exposura.. 3 times that from exposure to outside air alone,"
p.8, last line should read:
... lung cancer in 1930...on the order jt[ 45 years."
p.8, end of footnote needs enclosed parenthesis.
p.9, line 9, should read:
... risks to current populations. Although it is not possible to correct for such factors directly, it is possible to make some statistical corrections for the differences 16 age distributions for the 1930 and current U.S. populations. Data published by the American Cancsr Society are age standardized to the 1940 U.S. population. Therefore, corrections in lung cancer risk, due to different age distributions,can be made by simply multiplying the estimate for the 1930 U.S. population by the ratio of the 1976 and 1940 lung cancer rates:
.. {
. l8.9(males) + 64.0(females)/10 persons,13(1.2) deaths 13 lung cancer deaths (14.9(males) + 54.7(females)/10persons 106 5
106 person-rem person-rem
= 16 deaths 106 person-rem Clearly, a 20% increase does not change the conclusions regarding the upperbound risk of lung cancer from low-level radiation."
p.9, line 15, shculd read: " reasonable and prudent to use..."
line 16, should read:
...could be about a factor of 2."
line 17, should read:
" higher or_a factor of 2 lower."
footnote, should read: " Colonial Times to 1970 Part 1,"
2 p.10, paragraph 1, line 2, should read:
...uous exposure to, low LET radiation f rom... "
p.10, paragraph 1, line 3, should read:
...the average value of 69..."
Memo from Parsont and Gotchy should be preceeded by a page titled "Attactinent 2 - Background Information Leading to Proposed Interim BEIR III Risk Estimators. - Memorandum from R. Cunningham (August 12, 1980). - Memorandum from Parsont and Gotchy (October 22, 1980). - Memorandum hem Parsont (December 10,1C80."
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,7 UNITED STATES e
g NUCLEAR REGULATORY COMMISSION y
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>; j WASHINGTON, D. C. 20555
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March 25, 1981 MEMORANDUM F0h: Harold R. Denton, Director, NRR <
Victor Stello, Jr., Director, IE Robert B. Minogue, Director, RES John G. Davis, Director, NMSS G. Wayne Kerr, Director, SP Howard Shapar, Director, ELD FROM:
Karl R. Goller, Director Division of Siting, Health and Safeguards Standards, OSD
SUBJECT:
OFFICE CONCURRENCE ON INTERIM RADIATION RISK ESTIMATORS Enclosed for office concurrence is an Information Paper transmitting to the Commission a set of Interim Radiation Risk Estimators based on BEIR-III to be used by the staff (Enclosure 1).
This action is part of a staff initiative begun in 1979, and delayed until the publication of BEIR-III.
The drafts of both low LET and high LET estimators were circulated previously for staff, EPA and industry coment. Enclosure 2 transmitted the low LET portion and Enclosure 3 tran:mitted the high LET portion. Comments received on those drafts as well as recent BEIR-III corrections are reflected in the Enclosure to the Commission Paper.
Please provide concurrence and additional comments, if any, to Mike Parsont.
050, by April 3,1981.
/L/R&dL Karl R. Goller, Director Division of Siting, Health and Safeguards Standards Office of Standards Development
Enclosures:
As stated cc: Dr. William Mills, EPA E. Conti, OSD
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