Text

Answers to Amended Second Round of Interrogatories. Certificate of Svc Encl
	ML20063N751
Person / Time
Site:	Byron
Issue date:	10/05/1982
From:	Rose B; CHERRY, M.M./CHERRY, FLYNN & KANTER, LEAGUE OF WOMEN VOTERS OF ROCKFORD, IL
To:	; COMMONWEALTH EDISON CO.
Shared Package
ML20063N750	List: ML20063N749; ML20063N751;
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	ISSUANCES-OL, NUDOCS 8210070129
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{{#Wiki_filter:I = -t 7 of c]? L UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD

In the Matter of )

COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-454-0 L

                                                         )                  50-455-O L (Byron Nuclear Power Station                   )

Units 1 and 2) )

ANSWERS OF ROCKFORD LEAGUE OF WOMEN VOTERS TO AMENDED SECOND ROUND OF INTERROGATORIES OF COMMONWEALTH EDISON COMPANY Pursuant to the Memorandum and Order issued by the Licensing Board on August 30, 1982, Intervenor Rockford League of Women Voters herewith submits its answers to the second round of Interrogatories propounded herein by Commonwealt'h Edison. Introduction 1he answers submitted herein contain as much information as is available to the League as of the date of filing. However, document production by Commonwealth Edison Company (" CECO") has begun only very recently and has still not been completed. Additionally, as was noted at the August Pre-Hearing Conference in Rockford, Illinois, the League's expert witnesses were not expected to be and, in fact, were not available to the League during September except on a very intermittent basis. Consequently, they have not yet had an opportunity to examine any of the documents which have so far been produced. For these reasons and because the League's own investigation, which includes League-initiated discovery activities, is continuing, the League must state that additional facts and details may yet come to light. As these facts are uncovered, the answers herein will be elaborated upon by supplemental answers. - l 1 (E1210070129 821005 PDR G ADOCK 05000454 PDR I l

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a s Interrhatory No.1: With reference to Contention I A, (a) identify all instances demonstrating how Edison's quality assurance function is not independent of Edison's other departments; and (b) identify and produce all documents which support your answer to this Interrogatory. Response to No.1: 1(a) It is required that information in the Safety Analysis Report l (SAR) pertaining to managerial and administrative centrols be used to assure safe operation of the nuclear plant. Thus, as set forth in the " Introduction" to Appendix B to 10 CFR 50, Quality Assurance / Quality Control (Q A/QC) requirements apply to a broad range of activities at Byron such as designing, purchasing, fabricating, handling, slipping, storing, clearing, erecting, installing, I inspecting, testing, operating, maintaining, repairing, refueling, and modifying equipment, parts, and structures. Criteria I of Appendix B also requires, in- l part, that:

                           .....the persons and organizations performing quality assurance functions shall have sufficient authority and organizational freedom to identify quality problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions.                       Such persons and organizations performing quality assurance functions shall report to a management level such that this required authority and organizational freedom, including sufficient independence from cost and schedule when opposed to safety considerations, are provided."

Contrary to these requirements, the Byron QA/QC program falls to provide the required organizational independence. For example, under the current QA/QC program, the CECO " Quality Control Supervisor" reports to the " Station Superintendent" through the " Administrative and Support Services Assistant Superintendent" (see Byron SER, Figure 17.1). Thus, the required independence from cost and schedule considerations has not been achieved. 4 1-1

i i Also, the results of a recent NRC Inspection conducted March 29-31, April 1-2, 5-9,12-14, and May 11, 1982 document further violations of the independence requirements and demonstrate that despite the projected fueling date only one year away, CECO is still unwilling or unable to establish a proper QA/QC program. In the Inspection Report, the NRC cited CECO for failures to comply with language in both 10 CFR 50, Appendix B, Criterion 1, and the licensee's own topical report CE-1-A, Rev. 20, Section 1.A, and stated that contrary to those provisions:

1. On March 30, 1982 it was identified that the Quality Assurance Manager for Hatfield Electric Company, as shown in the Quality Assurance Manual, reports to the Vice President who is located on-site and has direct responsibility for cost and schedule;

2. On April 2, 198 2 it was identified that the Quality Assurance Manager for Powers - Azco Pope - as shown in the Quality Assurance Manual reports to the Project Manager who has direct responsibility for cost and schedule;

3. On April 8, 198 2 it was identified that the Project , t Construction Department of the licensee (CECO) is part of the approval chain regarding the hiring and promoting of contractor's quality assurance personnel;

4. On March 30, 1982 it was identified that the Hatfield Electric Company has been operating with a Quality Assurance Organization other than that described in their Quality Assurance manual;

5. On April 4,1982 it was identified that Johnson Controls Inc.

has been operating with a Quality Assurance Organization other than that described in their quality assurance manual; Additionally, the organizational requirements for a QA/QC program for items "important to safety" but not " safety-related" (for definitions, see Denton's November 20, 1981 memorandum) as required by GDC 1 of Appendix A to 10 CFR 50 is not described in the FSAR by CECO or reviewed by the NRC in the Byron SER. This is a significan* omission. 1-2

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a i Finally, the Institute of Nuclear Power Operation (INPO), in a September 12, 1980 report summarizing its evaluation of CECO's site activities at Dresden, noted that there existed an opportunity for the improvement of a number of CECO management practices, including management's handling of the definitions of individual responsibilities and authority, its adherence to administrative-type procedure and industrial safety policies, the effectiveness of its administrative controls on instrument setpoints, and the effectiveness of its maintenance, surveillance, and records program. Specifically, the INPO evaluation team identified two basic concerns. The first was that many of the findings showed a need for strengthened management control systems through adequate and clearly written definitions of lines of authority and responsibilities, and through additional written policies and procedures. The second was that a number of findings indicated the need for more management attention and vigor in insuring adherence to existing administrative policies and procedures. In general, the underlying cause of identified QA/QC breakdown has been the failure of responsible management to properly emphasize the in'portance of compliance with the required QA/QC measures. This pattern of failure can be documented through NRC Inspection Reports as well as internal QA/QC audits and surveillances which reveal the root cause: a lack of proper management organization and attitude. The review of Byron audits, surveillances, and E & I reports is currently underway. Following this review, the answer to Interrogatory No. I may be supplemented with additional material. 1-3 l l l l I

1(b) Documents have been identified at the point of reference in this response, in previous affidavits, and in Interrogatory responses related to Q A/QC breakdowns by Byron. All documents identified to date are publicly available, or if not, the documents have been provided by CECO. As additional documents responsive to this request are identified during the ongoing discovery process, this response will be appropriately supplemented. Interrogatory No. 2: With reference to Contention 8, (a) identify and produce the NRC studies, referred to in the second sentence of the contention, which have been carried out to identify " accident mechanisms, considered credible, which would lead to uncontrollable accidents and release to the environment of appreciable fractions of a reactor's inventory of radioactive materials;" (b) identify and produce the NRC studies, referred to in the fifth sentence of the contention, "which are not common public knowledge" but have cast doubt upon various conclusions of the Rasmussen report; (c) identify the specific conclusions of the Rasmussen report that have been questioned by the NRC studies referred to in subpart (b); (d) identify and produce a copy of the " secret NRC study" referred to in the contentions as the " unpublished document from Brookhaven National Laboratory"; and (e) identify the General Accounting Office report referred to in the contention. Response to No. 2: 2(a) Studies which have been conducted by or for the NRC which identify " accident mechanisms, considered credible, which would lead to uncontrolled accidents and releases to the environment of appreciable fractions of a reactor's inventory of radioactive materials' include the following relevant i to a PWR of the Byron design: (i) WASH-1400, U.S. Reactor Safety Study. (ii) NUREG-0400, Risk Assessment Review Group Report to the U.S. Nuclear Regulatory Commission. (iii) W ASH-7 4 0, Theoretical Possibilities and Consequences of Major Accidents In Large Nuclear Power Plants. (iv) Byron FES (Chapter 7 re Class 9 accidents). l l l l 2-1

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l I In addition, Board Notification 82-75 presents the initial results of i - the NRC's Accident Sequence Precursor Program Report. The program was ( begun as a result of one of the Lewis Committee recommendations (see NUREG-0400) following their review of WASH-1400, the Peactor Safety Study. The Precursor Program uses Licensee Event Reports to evaluate potential nuclear plant accident precursors occurring at operating reactors. These individual plant precursors are then summarized to evaluate the risk (for a particular time period) from all operating nuclear power plants. The Report covers the period from 1969 to 1979, and the estimate is between 1.7 x 10-3 and 4.5 x 10-3 per reactor year. This estimate includes contributions from three major events: (i) the loss of feedwater and the stuck-open relief valve at Three Mile Island Unit 2 (which actually resulted in severe core damage), (ii) the loss of non-nuclear instrumentation at Rancho Seco, and (iii) the fire in the cable spreading room at Browns Ferry 1. The Report was released as a progress report with the expectation that some of its conclusions might need to be changed as the report undergoes continuing peer review and public comment. This information relates directly to issues on the probability of accidents for nuclear power reactors. Since it estimates the probability to be much higher than past studies, it appears to put a different light on the issue. The results of the Precursor Program are set forth in NUREG/CR-2497. Furthermore, the plant specific Probabilistic Risk Assessments (PRA's) being prepared for the Indian Point and Zion plant sites appear to be relevant to Byron. Finally, the findings of the NRC's Interim Reliability Evaluation Program (IREP), TMI Action Plun Items II.C.1 and II.C.2, as well as the results 2-2

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 . o of the risk assessment-systems interaction, TMI Action Plan Item H.C.3 appear relevant to identifying credible accident . mechanisms. However, it should be       ;

noted that a Byron plant specific, site specific PRA and systems interaction study offers more potential Insights for Byron than the generic PWR studies referenced herein. Such Byron site specific, plant specific studies should be ! provided by CECO to the Board, the NRC, and all parties in the OL proceeding l i prior to the completion of the operating license hearing. 2(b) See the documents referred to in the response to Interrogatory

2(a); see also the January,1980 draft study performed by Sandia Laboratories for ,

the NRC titled, "Effect of Liquid Pathways on Consequer.ces of Core Melt Accidents." 2(e) The documents referred to in' the responses to Interrogatory . 2'(a) and 2(b) are themselves the best source of the response to this Interrogatory. In addition, see the discussion at paragraphs 3.4.1 through 3.4.9 4 i of the Affidavit of Richard B. Hubbard and Gregory C. Minor (a copy of which ! has previously been provided to Edison and the Staff) and see also NUREG/CR- I

0400; the NRC Statement of Policy issued on January 19, 1979 concerning the Risk Assessment Review Group Analysis of WASH-1400; NUREG-0642; and j j NUREG-0625. l l 2(d)(e) The League is endeavoring to locate, but has not yet located, its copies of the documents referred to in Interrogatories 2(d) and 2(e). The League will continue in its efforts and will produce the documents promptly when they are located. l 2-3 l r s

4 a 6 Interrogatory No. 3: With reference to Contention 19, (a) identify the "[r]ecently developed information" referred to in the first sentence thereoft (b) identify the l "Information" referred to in the third sentence thereof and which allegedly shows that " evacuation regarding Byron in an acceptable time cannot be accomplished;" (c) Identify the "other emergency measures" referred to in the eighth sentence of Contention 19; and (d) identify and produce all documents which constitute, refer or relate to the "information" identified in your answers to subparts (a) and (b) of this Interrogatory. Response to No. 3: 3(a) See NUREG-0625. As is apparent from NUREG-0625, the siting of Byron within 17 miles of the City of Rockford mandates sound and effective emergency evacuation procedures for the reasons noted therein, as is the case with a number of other plants for which construction permits were issued prior to the recent intensive NRC review - supported by (among others) the ACRS - of siting policy. In this regard, see also pages 15-17, 38-40, and 76-77 of the Kemeny Commission Report and pages 129-30 and 133 of the NRC Special Inquiry Group Report concerning the TMI-2 accident and the deficiencies revealed in then-existing emergency planning and evacuation criteria. 3-1

3(b) The Byron Station Emergency Plan Annex clearly documents the fact that, based simply upon population size and location as well as the availability of possible escape routes, Byron and its environs could not possibly be evacuated in a time period which could even approach being considered acceptable. There are a total of five recreational areas to be found within Byron's three-mile Low Population Zone ("LPZ") alone. 'Ihus, this comparatively small region may at times contain a total permanent and transient population of 1 up to 13,000 people. Similarly, the ten-mile evacuation zone ("EZ") may itself contain a permanent and transient population numbering as high as 63,000 people. Byron Station Emergency Plan Index, p. BYA 1-7. Page BYA 6-9 of the Byron Station Emergency Plan Annex contains a map of the ten-mile evacuation zone. This map shows only two tho.oughfares, German Church Road and Highway 2, which have been designated escape routes for the 68,000 people potentially within the zone at the time of an emergency requiring evacuation. Both designated escape routes are winding, two ~ te roads, t and many of the turns along Highway 2 are not even banked. ! Obviously, a 18rge number of vehicles would be traveling these two roads during any evacuation. It therefore becomes inevitable that a traffic l accident, a mechanical breakdown, or even a simple flat tire would substantialy disrupt or halt altogether any attempted evacuation under even the best of a circumstances. Furthermore, based upon the history of emergency planning, it is unlikely that the best of circumstances will obtain during an evacuation insofar as having a prepared citizenry is concerned, despite the language of Byron l Saf aty Evaluation Report ("SER"), Appendix D, p. D-21, sub-paragraph 10. [ 3-2

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Sub-paragraph 10 states "within one year before the issuance of the operating license for full power opecation [ Commonwealth Edison (" CECO") must] successfully complete a full-scale [ evacuation) exercise." Yet, when the first emergency preparedness drill was conducted at the Zion station in July,1981, Mr. Chuck Jones of the Illinois Emergency Safety and Disaster Agency stated, "It would be detrimental to have a large-scale evacuation [ drill). People would panic, there would be traffic accidents. We don't have the manpowcr here to handle that sort of evacuation. This is a controlled group and what we're testing are the agencies involved...." " Nuke Accident Planned for Byron," Rockford Register Star, August 2,1981. To further compound the problem, there is no indication on the designated escape routes, German Church Road and Highway 2, of potential bottleneck locations, steep grades, restricted bridges and roads or possible hazards caused by the adverse weather conditions which are known to occur in the Byron area such as floods, ice, snow and fog. Even the notification system proposed for use in an emergency situation is insufficient and would only further exacerbate the evacuation problem. CECO has indicated in a January 18, 1982 letter to the Nuclear Regulatory Commission Staff that the planned notification system consists of a combination of fixed and mobile sirens. CECO anticipates notifying those people within a 10-50 mile radius of Byron with either (1) existing or additional sirens or (2) mobile sirens /public address systems. Yet the Rockford metropolitan area lies within the 50-mile ingestion zone and clearly the proposed notification system would be woefully inadequate in reaching the approximately 204,000 people living in that metropolitan area. Furthermore, the southern portion of Rockford whose population will be " notified" in the same 3-3

manner as other areas, lies within the possible plume pathways which could extend 15 miles according to Byron FES Appendix F, p. F-2.A. Only one hour delay time is proposed for notification according to Appendix F. Furthermore, CECO has yet to " establish formal letters of agreement with appropriate agencies and organizations including law enforcement, ambulance services, medical and hospital support, fire departments, and state and local authorities responsible for implementation of protective measures .for the public. Byron SER, Appendix D, " Emergency Preparedness Evaluation Report," p. D-20. The implementation of an acceptable evacuation plan is simply impossible without agreements - including, because of Byron's geographic location, interstate agreements with Wisconsin - which specify the emergency measures to be provided the Licensee. Finally, the conclusion section of the Byron SER, Appendix D, lists 11 improvements which the NRC Staff itself believes are necessary to meet the planning standards of 10 CFR 50.47(b) and the requirements of 10 CFR 50, Appendix E. 3(c) Ideally, foremost among "other emergency measures" should be additional containments such as a vented, filtered containment, or other applicable design changes necessary to reduce the magnitude of the release or to lengthen the time over which a release might occur. Additionally, there should be studies conducted and any resulting 4 recommended measures for sheltering exposed and potentially exposed victims should be implemented. These measures should include the following: 3-4 l l I

I 1. The distribution of potassium lodide pills .("Kl") to all families living within the 10-mile EPZ, and the stockpiling of KI within the 50-mile ingestion zone. The value of KI as a blocking agent has long been recognized. Some 15,000 pills were distributed by the Illinois Department of Nuclear Safety in the areas around four nuclear power plants in Illinois during 1981. The FDA has recommended that KI be stockpiled near all nuclear reactors in the United States, and Great Britain has stockpiled KI around its reactors for years. Such stockpiling is necessary to ensure rapid distribution in : the event of an emergency because KI must be taken before or at the time of exposure for it to be. effective in blocking the uptake of radioactive iodine into the thyroid gland. Consequently, the stockpiling would have to be organized in a manner which would allow supplies to be located within a half- , mile of all Individuals living or working within the 50-mile ; ingestion zone. The cost of such a program has been estimate.d - to be only $.05 per person with the assumption of a three-year shelf life and an average residence occupancy figure of threc ,

persons. Many utilities now store KI on site in order to comply ;

with the requirements of NUREG-0654; i

2. All hospitals, parks, nursing homes, and recreational centers within the EPZ should have available on-site equipment capable of measuring radiation levels exceeding the standards listed in 10 :

CFR, Part 20. This equipment should include filter samplers, film badges, electronic dosimeters, and alarms activated by a prescribed radiation level; ;

3. All hopsitals, nursing homes, schools and other public .

buildings, as well as workplaces within the EPZ, should be , equipped with radiation sensors which would automatically ; disconnect the air-conditioning system when radiation levels 3 exceed prescribed limits;

i: 4. All hospitals and other health facilities within the 50-mile ingestion zone should be equipped with decontamination facilities. Mobile decontamination facilities should be provided ,

for la.rge-scale accidents, which regular facilities would be ' unable to handle; i

5. All recreational and outdoor areas within the 10-mile EPZ

    -    should be equipped with sheltering facilities capable of providing stores of non-radioactive food and water;                                         !

l 6. Radiation levels should be measured on-site and off-site by , I monitors linked to an on-site computer which would determine > l when an emergency situation had occurred based on the ' measured levels of radiation. The computer would then automatically notify every radio and television station within the 50-mile EPZ so that the media could, in turn, alert the populace; ; 3-5

7. Carefully planned, comprehensive educational material should be distributed before an emergency occurs. This material should include a map such as was suggested by the United States Environmental Protection Agency in the Byron FES, Appendix A,

p. A-21;

8. Transportation problems with the 17 schools located in the EPZ should be carefully planned because the available school buses serve more than one school and provisions would have to be made for the parents to pick up their children.

Other measures may be identified once the integrated CECO on-site and local (county and State of Blinois) off-site Emergency Plans are completed and available. However, as noted in Section 13.3 of the Byron SER, the "off-site state and local entitles within the emergency planning zones have not submitted their plans." Discovery and the League's own investigation are continuing and as more facts are ascertained, the answers to Interrogatory 3 , may be expanded by supplemental answers. 3(d) The following documents constitute, refer or relate to the [

                        "information" identified in the answers to subparts (a) and (b) of Interrogatory 3,                                                                    !

and all have been previously furnished to or by CECO or are in the public l i domain:

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Byron Station Emergency Plan Annex; !

f Byron SER, Appendices A, D and F; l i

                                           " Emergency Planning for Reactor Accidents," Jan Beyea, BULLETIN OF THE ATOMIC SCIENTISTS (December,1980);                                                                                 ,

I Letter from Eric Jones, Director of Illinois ESDA to Robert ! Ryan, Director, Office of State Programs, NRC; ; ! " Nuke Accident Planned In Byron," Rockford Register Star, i I (August 2,1981)- I Potassium Iodide as a Thyroid-Blocking Agent in a Radiation [ Emergency; Changes to L'abeling Guideline, Food and Drug i l Administation, 44 Fed. Reg. 48237 (1979); i t Potassium Iodide as a Thyroid-Blocking Agent in a Radiation

l i Emergency; Draft Recommendations on Use, Food and Drug l l Administration,. 46 Fed. Reg. 38, 189 (1981), , I 3-4

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f Potassium Iodide as a Thyroid Blocking Agent in a Radiation Emergency, 43 Fed. Reg. 58798 (1978); < " State Hands Out Disaster, Four Nuclear Areas ' Dosed'," The News-Sun (January 5,1982);

         " Emergency Plans Made Mandatory After Three Mile Island,"

Education Week (April 14, 1982); NUREG-0553, Beyond Defense in Depth; NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Nuclear Power Plants; NUREG-0696, Functional Criteria for Emergency Response Facilities, Final Report;

         " Nuclear Power and Nuclear Safety:      Illinois Style," Illinois Dept. of Nuclear Safety, News Release (January 7,1982);
         "Public Citizen Calls for Immediate Stockpiling of Potassium Iodide to Protect the Public in the Event of a Nuclear Accident," Public Citizen;
         " Stockpiling Potasium Iodide for Radiation Emergencies,"

Comments of Public Citizen Critical Mass Energy Project and Public Citizen Health Research Group on FDA's Draft Recommendations. 3-7

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1 I:terrogstory Mr. 4: l With reference to Contention 22, (a) identify all other plants where there presently exists an " extremely serious problem" of degradation of steam generator tube integrity and describe the specific nnture of the " problem"; (b) for each of the plants identified in your response to part (a) of this Interrogatory, identify both the differences and the similarities between the identified plant and the Byron plant, in relation to (i) materials in the secondary system; (ii) secondary water chemistry control, and (iii) operating procedures; (c) identify each fact which would tend to indicate the " serious problem" referred to in the first sentence of the Contention is "likely to occur at CE's Byron Plant"; (d) identify what would constitute an adequate resolution at Byron of the problem referred to in the last sentence of this Contention; and (e) identify and produce all documents which support your answers to parts (a), (b), (c) and (d) of this Interrogatory. Response to No. 4: 4(a) A detailed summary of steam generator problems and failures through November 1981 can be found in NUREG-0886, Steam Generator Tube _ xperience (Feb.1982). Byron is to be equipped with Westinghouse Model D steam generators and a list of problems arising specifically with Westinghouse steam generators is contained in NUREG-0886 under Table 1, " Operating Experience With Westinghouse PWR Steam Generators Through November 1981." Additionally, definitions of these problems and further details of each reported failure are also contained in NUREG-0886 at pages 1 to 28. Problems which have been experienced with foreign pressurized water reactor steam generators, including 19 units of Westinghouse design, are detailed in Table 4 of NUREG-0886. Table 4 contains the same kinds of information as Table l' of the report. The nature of tne problem experienced at each of the plants listed in Tables 1 and 4 is clearly identified in those tables. The reported problems consist of wastage or other wall thinning, steam corrosion cracking initiated from the inside diameter at the u-bends, fretting and denting. 4-1 I

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4(b) The Byron steam generators are described in the FSAR, Section 5.4.2 and the NRC's review is documented in the Safety Evaluation Report, pages 5-19 through 5-22. The Byron steam generators are specified to be Model

D. Tube material is Inconel-600. The secondary water chemistry control at Byron is to be all volatile treatment (AVT). The League does not currently 1 have access to the Byron operating procedures but will be obtaining whatever is available at this time through discovery.

The steam generator model numbers, secondary water chemistry , control, and tube material for all of the steam generators listed in NUREG-0886 are identified in Table 1 and/or Table 4. This material covers the steam i generators associated with 53 Westinghouse units. 4(e) The fact that steam generator problems have been, currently are, and will continue to be serious problems at Westinghouse pressurized water reactors is well evidenced by the NRC's designation of this problem as an

     " UNRESOLVED SAFETY ISSUE". This is discussed in the Byron SER Appendix C at C-9 and 10.      Further extensive discussion of this problem is contained in A February 18, 1982 memorandum by William J. Dircks (NRC Executive Director for Operations) Identified as SECY-82-72 to which was attached a February 1982       ,

Steam Generator Status Report. This information was previously provided in response by LWV to the first round of Interrogatories of Commonwealth Edison Company. j Numerous discussions of this problem and information were filed by l the parties in conjunction with CECO's Motion for Summary Disposition on l DAARE-SAFE Contentions 9(a) and 9(e). Affidavits were filed by CECO and by I l the NRC Staff as well as the Intervenors. This information discusses the problems currently being experienced and investigated on Westinghouse Model D 4-2

o . steam generators with respect to the phenomenon of bubble collapse water hammer and with flow induced vibration and tube wear. The Board's findings that the Westinghouse Model D problems are to be further considered is certainly indicative that this is considered to be a " serious problem" and certainly not one that can be dismissed at this time. Extensive documentation exists in the industry literature discussing these problems, all of which literature is readily available to CECO. 4(d) An adequate resolution of the proble'n of steam generator tube degradation would necessarily be one which reached the root ce'ases of the problem. However, such "[aln effective solution would require major changes in S.G. mechanical design, thermal-hydraulics, material selection, fabrication techniques and changes in the secondary design and operation... There are no simple corrective actions." February 1982 " Steam Generator Status Report," an attachment to February 18, 1982 Memorandum by William J. Dircks, NRC, SECY-82-72. The discovery process and the League's own investigation of the subject areas of Interrogatory 4 are continuing. As additional facts are ascertained they will be supplied by supplemental answers to this Interrogatory. 4(e) In addition to the FSAR and the Byron Safety Evaluation Report the folowing documents are relevant to and support this Contention: NUREG-0886, Steam Generator Tube Experience , I l February 18, 1982 Memorandum by Willam J. Dircks, NRC, { SECY-82-72 with Attachment February 1982 Steam Generator ! Status Report ! l NUREG-0909, NRC Report on the January 25,1982 Steam : l Generator Tube Rupture at the .R. E. Ginna Nuclear Power Plant, April 1982 N U R EG-0 5 2 3, Summary of Operating Experience with ! Recirculating Steam Generators, January 1979 , 4-3 l

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NUREG-0571, Summary of Tube Integrity Operating Experience with Once Through Steam Generator, March 1980 , November 24, 1981 Memorandum from W. J. Dircks, SECY-81-664 NUREG/CR-0175, Investigation of the Influence of Simulated Steam Generator Tube Ruptures During Loss of Coolant Experiments in Semi-scale MODI-l Systems, May 1978 All other reports and documents referenced in LWV's Response to First Round of Interrogatories of Commonwealth Edison Company with regard to Contention 22. Other documents yet to be obtained through discovery. All of the above referenced documents are in the public domain and quite likely already in the possession of Commonwealth Edison Company. Any documents not 3vailable to CECO will be supplied on request. 4-4

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Interrogatory No. 5: With reference to Contention 32, (a) specify what would constitute

       " adequate qualification methods with which to satisfy the objective of the requirement that all safety-related equipment conform to the requirements established in IEEE Standard 323-1974"; (b) identify and produce all documents which support your answer to subpart (a) of this Interrogatory; and (c) identify each factual issue which this Contention purports to raise which is not encompassed within Contentions 61 or 77.

Response to No. 5: 5(a) The concern for the qualification of safety-related equipment is broader than just that equipment be subject to IEEE 323-1974. The issuance of IEEE 323 highlighted the qualification problem for Class IE electrical equipment and the definitions and provisions in the IEEE Standard do serve to describe the scope and methods which are possible, liowever, the list of methods is not an exhaustive one because there is no single answer applicable to the qualification of all equipment. IEEE 323 sets out the overall goal of equipment qualification within the very definition of the term: " Equipment qualification. The generation and maintenance of evidence to assure that the equipment will operate on demand, to meet the system performance requirements." IEEE 323-1974, p. 8. Following this definition is the non-exclusive list of qualification methods. Qualification may be accomplished in several ways: type testing, operating experience, or analysis. These may be used individually or in any combination depending upon the particular situation. In the first, it is expected that the equipment will be subjected to the environments and operating conditions for which it was designed and its performance measured. In a test program, it is usually practical only to simulate environments and operating conditions. The limitations in such simulations, the abbreviation of exposures permitted by increasing the severity of the environment, and the validity of data extrapolations must be taken into account in the design of the test. IEEE 323-1974, p. 8. 5-1 i

Meeting these qualification requirements for Class IE equipment has always been a problem, as was noted by the NRC while designating it generic safety task A-24 in NUREG-0410 and still later in NUREG-0371, Rev. O, November,1977, TAP A-24, wherein the NRC stated: It is the NRC position that construction permit applicants for which a Safety Evaluation Report was issued after July 1,1974, are required to qualify all safety related equipment to the requirements established in IEEE Standard 323-1974, IEEE Standard for Qualifying Class IE Equipment for Nuclear Power Generating Stations.. From the conception of the standard, industry has been developing methods that will be used to qualify their equipment in order to satisfy the objectives of the standard. Certain proposed concepts and methods used by industry in addressing equipment qualification, such as testing margins, aging effects on materials and equipment, and adequacy of testing simulators, which simulate the worst case environment for the equipment have not yet been resolved. Unfortunately, the issue of what constitutes proper qualification methods is stil not fully resolved and the implementation of a resolution of A-24 is still ~ incomplete. One example of the problems with the current methods of qualification is the issue of aging. In order to account for the aging of equipment, the effects of aging must be qualified and the qualified life must be defined. The industry has had difficulty in obtaining a clear indication of

       " qualified life" and the methods for assessing aging effects are still being studied.       Two recent reports highlight the problem of the aging of electrical insulation in radiction and temperature environments.             These reports indicate that there may be a greater effect on the insulation due to long exposure to j       low level radiation than to short exposure to high levels of radiation. NUREG-t i

5-2 l

CR-2156: Radiation-Thermal Degradation of PE and PVC: Mechanism of Synergism and Dose Rate Effects, Sandia Laboratories, June 1981; NUREG-CR-t 2157: Occurrence and Implications of Radiation Dose-Rate Effects for Material Aging Studies, Stndia Laboratories, August,1981. Thus the expected reduction of qualified life due to aging effects may be greater than had been previously thought. Additionally, the resolution of the environmental qualification issue may take longer than expected. The previous deadline for complying with j qualification requirements in CLI-80-21 and NUREG-0588, Interim Staff Position on Environmental Qualification of Safety-Related Electric Equipment, July 1981 was June 30. 1982. The NRC issued a rule on June 30, 1982, 47 Fed. Reg. 28363 i (June 30,1982) which withdrew the deadline of June 30, 1982. This issue is further complicated by a proposal to extend the deadline to March 1985. . However, the Union of Concerned Scientists has taken the NRC to court asking that they reinstate the previous deadline (Nucleonics Week, September 23, 1982,

p. 6, 7.). -

Finally, there is a growing uncertainty as to whether all the necessary equipment is being qualified. The NRC in a recent memorandum established a new category of equipment called "important-to-safety." This now exists in addition to the old category of equipment called " safety-related.'" See Denton Memo, November 20, 1981,

Subject:

Standard Definitions for Commonly-used Safety Classification Terms. There is no asso ance that Byron has j classified and qualified the equipment for both the importa it-to-safety and safety-related classificatins. Given the newly-differentiated terms, the words of Contention 32, the related qualification contentions should have been written and should now be construed to cover all important-to-safety equipment.

                                                ,                                               5-3 i

As discovery and the League's own investigation continue, additional material on Interrogatory no. 5 may be supplied by supplemental answers. ! 5(b) The documents used and referenced in resporJe to Part (a) of Interrogatory 5 are all in the public domain and most are available directly from the NRC. i 5(e) Contentions 32, 61 and 72 are related but not identical. Where 61 references the TMI experience as an indication of a particular problem in the environmental range used in the qualification of equipment, and 77 refers specifically to the problem with aging and related seismic requirements, the issue in 32 is much broader in that it includes the entire issue of qualification ' methodology and its timely application for Byron. e 5-4

1 Interrogatory No. 6: With reference to Contention 34, (a) identify each inadequacy in the provision for overpressure protection at Byron; and (b) identify and produce all documents which support your answers to subpart (a) of this Interrogatory. Response to No. 6: 6(a) The primary inadequacy identified to date is CECO's apparent { failure to fully classify the pressurizer relief valves (PORV) as components important to safety in all respects. This makes the two PORV's used for low I temperature overpressure protection of the reactor coolant system susceptible to a potential common mode failure. This susceptibility is described in the SER Section 5.2.2.2, Low Temperature Operation. f CECO has proposed to overcome t!.is inadequacy by use of required f operator action following receipt of alarms indicating an overpressurization i event. Operator action following receipt of alarms could be required within 10 7 minutes if a steam bubble is present within the RCS and would be required in lesser periods of time if the system is water solid. We believe this situation is e representative of an inadequate design and should be rectified by design changes which would obviate the common mode failure susceptibility. The second inadequacy in the overpressure protection system is the reliability of PORV's during operational transients. This concern was thoroughly discussed in LWV's Response to CECO's First Round of Interrogatories under

Contention 34 and the information contained therein is adopted here by reference. The issues basically center around poor reliability of PORV's, failure of CECO to classify the PORV control system as safety-related, and the failure of CECO to fully perform the testing of safety relief valves and to qualify them under plant specific conditions as required by NUREG-0737, l

l 6-1 l

6(b) As discovery and the League's own investigation continue, material under Interrogatory 6 may be supplied by supplemental answers. All documents currently being relied on are identified in LWV's earlier response to : CECO First Round of Interrogatories, Contention 3. Those responses are j incorporated herein by reference. All should be available to CECO. Copies will [ be furnished to CECO if they are not, f f f I [ i 1

                                                                                                                 'I i

i t L I l I l t I r 6-2 i f 7

                           -         - ,.           - - . , ,--.v....   . , , -  e,.. . , . - -_.. - - . . - , ,

Interrogatory No. 7: With reference to Contention 39, (a) identify each deficiency alleged l to exist in the method of evaluating and analyzing radionuclide sediment i transport through the hydrosphere in the Environmental Report for Byron; (b) identify the relationship, if any, between the " serious and unresolved problem" referred to in the last sentence of this Contention and the findings required by 10 CFR Sections 50.57(a)(3)(i) and 50.57(a)(6); and (c) identify and produce all documents which support your answers to parts (a) and (b) of this Interrogatory. Response to No. 7: 7(a) The fundamental deficiency which is currently identifiable in the evaluation of radionuclide transport at Byron is the complete lack of any effective, field-tested methodology with which to analyze the problem. Of course, such methodology would also have to be adaptable for site-specific use which in the instant case would mean being capable of being made Byron site-specific. Without the creation of this methodology, no effective safety measures can ever be instituted, particularly since none of the numerous conditions unique to the Byron site would ever be accounted for in the measures which might be planned. Ironically, this is true despite the fact that interdictive measures are not only feasible (see "Effect of Liquid Pathways on Consequences of Core Melt Accidents," Scandia Laboratories { January,1980] [ Draft]), but are also absolutely necessary for the safe operation of the Byron plant. Unfortunately, with current construction methods and technology, once the plant is completed it may be too late to implement any of the available safeguards. This lack of a proper hydrogeologic analysis was discussed in the League's Answers to CECO's First Round of Interrogatories in response to an

Interrogatory also dealing with Contention 39. That discussion is incorporated l

herein by reference. l 7-1 4

Obviously, since no effective, field-tested methodology exists, CECO's current analysis of the Byron hydrogeologic situation is deficient, both in its theoretical basis and in the application of the theory to the on-site conditions. The theoretical basis falls because, as was noted in the League's earlier answer, CECO's "treatnMnt" in the Byron FES of the hydrogeologie situation was not based upon conditions at the Byron site, but upon NUREG-0440 which was, in turn, not based upon conditions of any real site. The FES did explain that NUREG-0440 had relied upon the "Rasmussen Report" (WAsil-1400) which had been at least partially discredited, but then the FES failed to note that the portion of NUREG-0440 on which CECO was basing its analysis of the Byron water pathways problem was one of the piccise portions which had been premised on the dfscredited findings of the Rasmussen Report. Specifically, the relevant fault lay in the Rasmussen Report's analysis of the effect of a meltdown on a river. The Report concluded that a meltdown would not result in a significant release of radioactivity into a river with a flow of 13,000 CFS. Yet the Report's own data show that the release of radioactive strontium, the isotype which poses the greatest hazards, would be 7.4 times greater than the federal limits on routine emissions allow. In addition to the inadequacies of NUREG-0440 resulting from its reliance on the Rasmussen Report, NUREG-0440 was also written before the events at TMl-2 and thus its conclusions were founded on the assumption that a very severe core melt accident was unlikely, an assumption now demonstrably incorrect. Given these " deficiencies" in NUREG-0440, it is clear that even the cursory handling of the Byron water pathways problem which has been indulged in by CECO is flawed at its very foundation. Not only does CECO lack a site-specific model for Byro . iut the generic model on which CECO has relied is virtually useless. l 7-2

Even assuming the theory itself had been sound, those significant conditions which are unique to the Byron site rendered the NUREG-0440 small river evaluation inapplicable to any analysis of the Byron site. See Byron FES, Appendix A, p. 21, USEPA Comments, Accident Risk Impact Asssessment. These site-specific conditions include the rate of flow of the Rock River, which is less than that of the river analyzed in NUREG-0440. Additionally, this rate of flow is variable. There is a dam on the e river several miles south of Byron at Oregon which slows its flow and the occurrance of ice jams, drought conditions, and pools la the river where fish kills have occurred also alter the rate of flow and could result in the accumulation of sediment and radionuclides. Furthermore, there is a toxic waste site already in existence at the Byron site and there has been no analysis of the possible synergistic effects ; which could result from a combination of radionuclides and the on-site toxic pollutants in the groundwater. See FES, Appendix A, p. A-40, " Letter from Office of Nuclear Reactor Reg."; Ill. EPA, Div. of Water Pollution, An Intensive .. Water Quality Survey of the Rock River from Rockfo'd to Byron, Illinois (May- [ October,1978) (see particularly the information on the unnamed tributary 5.2 miles upstream from Byron). NUREG-0440 pointed out that the existence of cavernous limestone under a nuclear plant could affect the rapidity of contamination of groundwater

by radioactive releases. The Byron plant rests upon porous fractured limestone. CECO has attempted to grout the site in an apparent attempt to slow the dispersal rate, but no study has been done of the long-term effects of this process. Despite these uncertain and potentially disastrous conditions, no groundwater model has been constructed according to the Environmental Statement, p. 25, 2-5; See FES, Appendix A (USEPA Comment on need to assess drinking water pathway status). 7-3

O The related question of flooding was discussed in both the FES and the SER, and both admitted that flooding could present problems at Byron.

However, no analysis has been performed of any combined flooding and seismic event, either with or without an accident. From the above discussion, it is clear that no worthwhile study of the, water pathways issue at the Byron site has been or can be performed. Txich an analysis would require, in addition to the inclusion of the conditions detailed above, an accounting for sediment interaction, residence time in water, sedimental patterns and rates, blota present and bioaccumulation, shoreline data and seasonal data. Until such a study is completed, no effective measures can be taken to elim'.aate the spread of radionuclide sediments through the Byron water pathways. 7(b) The " unresolved problem" refered to in Contention 39 is the lack of any field tested radionuclide/ sediment transport model with which to determine the effect of sediment and aquifer materials on radionuclide transport through the hydrosphere. More particularly, there is no Byron site-specific model. As stated in the answer to part 7(a), without such a model no proper assessment can be made of the full extent and the true nature of the problem at Byron. As a result, no adequate preventative measures can be adopted prior to the completion of construction which will block the release of radionuclides into the hydrosphere. Both 10 CFR Section 50.57(a)(3)(i) and Section 50.57(a)(6) require that the plant be shown to be operable without endangering the health and safety of the public. The relationship which exists between the " unresolved problem" and 7-4

these statutory provisions is simply that without the construction of a proper analytical model of the problem and without the resulting adoption of appropriate countermeasures to enable to plant to fully operate within the parameters of Section 50.57, the plant may never be licensed. This situation obtains because once the plant is completed and is ready for final licensing, it may be too late to implement the necessary safety features, even if they were to be ascertained, in order to prevent hydrospherie contamination and, hence, the plant may be forever unlicensable. 7(e) All documents used in this answer are referenced at the appropriate pojats in the text. These documents are all in the public domain or were originally furnished by CECO or the NRC and are, therefore, available to CECO. The League's investigation and the discovery process continue. Additional facts may be supplied in response to this Interrogatory or supplemental answers. I 7-5 l l

Interrogatory No. 8: With reference to Contention 41, (a) identify each safety related water supply at the Byron Station which is subject to ice build-up; (b) with respect to each safety related water supply identified in response to subpart (a) of this Interrogatory, identify the manner in which such water supply would be affected by ice buildup; (c) identify what would constitute an adequate resclution of the problem referred to in the last sentence of this Contention; and (d) identify and produce all documents which support your answers to parts (a) and (b) of this Interrogatory. Response to No. 8: 8(a)(b) The concern for ice build up is with the make up sources. Specifically, this refers to the river, the intake canal, and screen house where make up water is obtained. In view of the low flow in the Rock River, serious ice build-up is conceivable and recent winter weather conditions have demonstrated long periods of cold weather are quite probable in the area of the plant site. The on-site wells would be less subject to icing as would the cooling towers. 8(e) Resolution of this problem for Byron would include insuring that the requisite days supply of make-up water was available independent of predictable natural phenomena. , 8(d) The documents referenced are all in the public domain, available through the NRC or already in the possession of CECO. 8-1 1

   . .o Interrogatory No. 9:

With reference to Contention 42, (a) identify the new information on , low-level radiation effects referred to in this contention and (b) identify and produce all documents that refer to and support our contentions. Response No. 9: 9(a) New information on the effects of low-level radiation exposure is contained in the following recent publications by Dr. Karl Z. Morgan: 3

1. Morgan, K.Z., "The Need for Radiation Protection,"

RADIOLOGIC TECHNOLOGY 44, 6, 385 (1973).

2. Morgan, K.Z., "Yes is the Answer to Question of R.H.

Thomas and D.D. Rusick, 'Is It Really Necessary to Reduce . Patient Exposure?'", AM. INDUSTRIAL HYG. ASSN. J. 37, ! 665 (1976). l t

3. Morgan, K.Z., " Cancer and Low Level Ionizing h

, Radiation," THE BULLETIN OF ATOMIC SCIENTISTS 3_4, 4 7, ! 30 (September 1978); also Proc. 4th International Summer

School, Dubrovnik, Yugoslavia.

4. Morgan, K.Z., "The Non-Threshold Dose-Effect Relationship," given before Academy Forum of the National !

Academy of Sciences, Washington, D.C. (September 27, t 1979). [ t

5. Morgan, K.Z., "Mogliche Folgen einer Ubermassige ;

Medizinischen Strahlen-belastung in den Vereinigten Staaten i von Amerika," Rontgen-Blatter, Stuttgart (March 1974). t

6. Morgan, K.Z., " Significance of Human Exposure to Low-Level Radiation," CONGRESSIONAL RECORD, !

i Washington, D.C. (January 24, 1978). *

7. Morgan, K.Z., " Radiation Risks from Nuclear Power:

Final Round," NEW ENG. J. OF MEDICINE 303, 11, 645 : (August 1,1980).

8. Morgan, K.Z., " Appreciation of Risks of Low-Level [

Radiation Versus Nuclear Energy," COM MENTS ON : MOLECULAR AND CELLULAR BIOPHYSICS, L L 419 ! i (1980), i i l

9. Morgan, K.7s., " Risk Assessment of Exposure to Ionizing )

Radiation - Another View," presented before American ! l Nuclear Society, Miami, Florida (June 8,1981). ! l

10. Morgan, K.Z., " Medical Implications of Fallout," ['

presented at conference in Albuquerque, New Mexico (September 25-26, 1981). ; 9-1 f I _ . _ _ - . _ . _ . _ . _ . _ _ _._ _ _ . ,_, . . _ . . . _ _ , _ ~ , _ . . . . _ _ , _ . . . _ _ , . _ _ _ . _ _ _ _ - . . . . , . _ _ . _ ,

..o

11. Morgan, K.Z., " Risks of Nuclear Power Plant Accidents and Consequences on Population and Biosphere," Colloquium on Energy and Society, Paris, France (September 16-18, 1981). ,

12. Morgan, K.Z., "The Linear Hypothesis of Radiation Damage Appears To Be Non-Conservative in Many Cases,"

proceedings of IV International Congress of IRPA 2,11 (April 24-30,1977).

13. Morgan, K.Z., " Radiation Dosimetry," SCIENCE 213, 1 ,

604 (July 3,1981).

14. Morgan, K.Z., " Comparison of Radiation Exposure of the Population from Medical Diagnosis and the Nuclear Energy Industry," presented at American Nuclear Society meeting, Las Vegas, Nevada (June 18-22, 1972).

15. Morgan, K.Z., " ESC, AIF, EPI Conference on Low-Level Radiation," Conference in Dir!: son Senate Office Building, Washington, D.C. (February 10, 1978).

16. Morgan, K.Z., "The Purpose of Radiation Protection Monitoring," Proc. of IAEA Conference, Vienna, Austria (1979).

17. Morgan, K.Z., " Radiation Induced Cancer in Man,"

CONGRESSIONAL SEMINAR, John Glenn chairman, U.S. Senate, Washington, D.C. (March 6,1979).

18. Morgan, K.Z., "Redticing Medical Exposure to Ionizing Radiation," AM. J. INDUSTRIAL HYGIENE 358 (May,1975).

19. Morgan, K.Z., " Decommissioning of the Gorleben Facility," testimony before Gorleben, Germany Hearings i (March,1979).

20. Morgan, K.7., " Hazards of Low-Level Radiation,"

ENCYCLOPEDIA BRITANNICA, 216 (1980).

21. Morgan, K.Z., " Suggested Reduction of Permissible l Exposure to Plutonium and Other Transuranium Elements,"

AM. IND. HYGIENE ASSN. J., 567 (August 1975).

22. Morgan, K.Z., " Risk of Cancer from Low Level Exposure to Ionizing Radiation," paper presented before AAAS, Washington, D.C. (February 17, 1978).

23. Morgan, K.Z., "How Dangerous is Low Level Radiation?" NEW SCIENTIST (April 5,1979). -

l 9-2 l

l

24. Morgan, K.Z., "The Dilemna of Present Nuclear Power Programs," presented at hearings before the Energy Resources Conservation and Development Commission, Sacramento, California (February 1,1977).

25. Morgan, K.Z., " Significance of Human Exposure to Low-Level Radiation,"- CONGRESSIONAL RECORD (January 24, 1978). ,

26. Morgan, K.Z., " Radiation Induced Health Effects," i SCIENCE 195, 344 (January 1977).

y the American Society of RsJiologic Technologists

,The Need for Radiation Protection
Karl 2. Morgan. Ph.D.
*3 l
Atlanta. Georgia , I l
~ The amount of exposure to humans through medical uses of radiation con-tinues to be a matter of great concern to the medical and lay public. Studies in the United States show that the average medical diagnostic radiation dose >
could be reduced by a factor of ten. An optimistic note in bringing about this I reduction is seen in the leadership roles taken by radiologic technologists and
' their professional organization. One of the promising developments is the crit-icism by radiologists and technologists of their own standards. The radiologic technologist with his goals of improved and standarized educational programs and continued upgrading of his activities will play a major role in bringing - -al.out the needed improvements in diagnostic radiology. - s No c.NE wit.t. qt;ESTION that diagnostic radiogra- cerned about this because it increases the chance that they will die of some form of phy is one of the most valuable tools of the cancer, or will die an early death from non-medical profession. Howeser, many persons do rtot realize that like most conveniences, luxu- specific diseases and aging.
ries and even necessities of modern society. x Although there is evidence of some repair of rays exact a sesere price in suffering and genetic and somatic radiation damage. a cer. tain fraction of this damage appears to persist . . human lives. Over 90 per cent of the population as irreparable and to accumulate linearly dur-exposure to man made sources of ionizing ra-ing the life of an individual as indicated in diation in the United States derives from figure 1. These curves are plotted from data of medical diagnosis, and, as shown in table 1, the the International Commission on Radiological genetically significant dose (GSD) from medi-Protection (ICRP),* ' which sets the radiation cal diagnesis in the United States is much higher than that in other countries." ** We are protection standards at the international level concerned about the genetically significant on the prudent assumption that there is no ssfe I dose to our gonads because it causes some of threshold dose and that the probability of a our children, grandchildren and great-great- person dying of one of these forms of damage i increases linearly with the accumulated dose. grandchildren to be born with birth defects.
~
brain damage, and genetically related diseases Eye cataracts and acute forms of radiation and many to die an early genetic death. Like- damage such as skin erythema, acute radiation . sickness and radiation death result only after wise, we find that the somatie dose from i diagnostic radiography in the United States is large doses of radiation. The fo!!owing outline summarizes both the typn of radiation damage correspondingly higher than that in other coun- ~ tries, and many persons are particularly con-that relate more or less linearly to the ac. i cumulated dose and those which require a ! I
Presented at the Southeastern Conference of threshold dc,se before they are manifest:
Radiologic Technotngists. Durham. North Carolina.
1. Radiation damage relating more or less January 22. 1972. Research sponsored by the 1* S. linearly to the accumulated dose Atomic Energy Commission under contract w ith a. G.enetic mutat. ions (first generat. ion ,
Union Carbide Corporation. Dr. .\1orpn is Neely and recessise) l Professor. Schoot of Nuclear Engineering. Georgia b. Cancer ' including leukemia) Institute of Technology. !!c was formerly director, c. Life shortening llealth Physics Divisir.n. Oak Ridze Nationa! Labo. '
d. Other biological changes ratory. Oak Ridge, Tennence.
355
. ., m '
bray,1973 1 i cgencies such as th: USUS Lnd EPA, which e.
7. Recommend:ti:ns eI th> In.
, tre ch .rged with prov. ding i radiation . pro- ternxtions! Commission on Radiologic 11 Pro- s tection of the public, tremble when they con- ,,,,,,,, p,,,, mon Press, Niw Yrrk, ICRP Pub. No. 6 (1964).
template taking radiation protection meas- 8. McClenahan. 3. L: Wasted X. Rays. Radiology I
' ures that snight offend the medical 96:453 (August 1970). ,
j profess. ions. Only if you the publ.ic act on 9. Morgan. K. Z : The Need for Radiation Pro-tection. Radiologic Technclogy 44:385 (1973). { your own beh'llf, will you be provided good 10. Morgan, K. . Z.: Possible Consequences of j medical radiography without unnecessary Excessive Medical Exposure in the United I
' damaging radiation to yourself and your States-.-M6gliche Folgen einer ubermassigen "----
children. Do what you can to encourage medizinischen Strahlenbelastung m den Vere- . your own state to adopt legislation such as inigten Staaten von Amerika. Racargen. Biarter. Klinik und Pramis. IIc/t 3t127. Stutt- j<
!i that in the state of Illinois. Here the diag. gart (Marz 1974). -
nostic exposure limits are set at: (a) 500mR u. - What About Radiation? Afass
~
CA,st x. Ray Programs. USPHS Pub. !!96 and preferably <350 mR per abdomen (February 1965). E A.P., (b) 1400 mR and preferably <1000 12. - Chest X-Roy Screening Rec-mR per lateral lumbar spine, (c) 150 mR [h ommendations ,for TB.RD A ssociations. l NTRDA Bulletm J7, No. 9 (October 1971). and preferably <100 mR per cervical spine,
13. Gitlin, J. N., and P. S. Lawrence: Population L~
and (d) 400 mR and preferably <200 mR Erposure to X-Rays. US 1964 BRH-USPHS per A.P. skull radiograph. The unnecessary No.1519 (1964). exposure you prevent may be that to your- 3 4 - - -- -- : Recommendations of the SClf- international Commission on Radiologscal Protection, New York, Pergamon Press, Pub. References No.1 (Sept. 9.1953).
15. Bross, L D. 3.: Leukemia from Low.Izvel Ra-

1. Harting. F. H., and W. Hesse: Fischr. Ge-ichst diation. New Eng.1. Afed. 237:107 Ouly 20, ,
bled. Offent! Gesandheitswesen 30, 296: 31, 1972). 102 and 313 (1879). 16. Baum, J.: Population lieterogeneity Hypoth-
2. Morgan, K. Z and. L E. Turner: Principles esis on Radiation Induced Cancer. given orally
. of Rirdiation ProtectTon. Robeqt Kriegee Pub . e lishing Co. (1973). - , at;Hou~ston. Tex. rne'eting of the Health Physics
Society, July 10. 1974.
3. Grubb6. E. H.: Radiology 21:156 (1933). . 17. Aluller, H. J.- Radiation and Heredity. Amer.

4. Stone, R. S.: Western 1. Surg. Obster. Gynecob. 1. Pub. firalth, Sup. to Vol. 34. 1 (1964L 54:153, 201 (1946); Proteriion in Diagnostic 18. Russell, W. L.: Studies in Mammalian Radia-Radiology. Rutgers Univ. Press. New Bruns-wick. NJ., (1951). p.10; Radiology 38.619 tion Genetics. Nucleonics 23 53 Uan.1965). .
I 9. : Report of the Advisory Com. (1952). mittee on the . Biological Effects of ioni-ing
5. 4farimum Permissible Amounts Radiation. BELR Report. NAS, NRC (Novem.
of Radioisotopes in the iluman Body and ber 1972). .. blaximum Permissible Concentrations in Air 20. Morgan, K. 2.: Testimony before the S' enate and Water, NCRP Handbook 52, Nat. Bur. Commerce Committee on Bill 2067, " Reduc-I Std. (1953). tion of Unnecessary Medical Exposure," Au-
6. Transportation of Radioac-f gust 28 30.1967, Congressional Record Ser.
rive Afaterial by Pas enger Aircraft. Report No. 9449 (19688: Congressional Record Hear-l No. I to the JCAE of the Special Panel to ings before the Committee on Radiation Con-Study Transportation of Nuclear Materials, trol for Health and Safety Act Washington,
3. T. Conway, Chairman (Sept. 1974). D. C., March 8,1973. .
g. p 4
e, b...
. *},. , m /t G
e
e, . .
+ sf * . . . . . . . . . . . . ~ . . - . . * - . . - . . . . . . . . .....;.- -- e,s e' .t? -- . ,. MORGAN Il8d'0309 d ' *
W
~ .
TAsts 1 resort to unscientific arguments. For example, e csssTtcALLY sICNmCAN'T Dost (MREMS/ YEAR) FRoM %e often hear such statements as that of the wrotcAz. D ACNoS1s IN vARioUs ADVANCED cot;NTRIES highly respected Dr. Moseley of the American
.%Iti, ems / Year College of Radiology:"There are no demonstra. . Country O ble deaths from x rays."* This is like saying * . United States 95* there has never been a proven case where a J8 Pan 39 person has died of lung cancer from smoking Sweden 38 ,;&arettes. Of course, no deaths have been I Switzerland 22 Proven because the cancers are .dentIcal to i - United Kingdom 14 e se hom natural causes, and they ocem on a - New Zealand 12 statistical basis. We can show decisively, how-Norway 10 ever, that on a statistical basis diagnostic x 't . '.
Probable value is between 55 and 95 millirems / rays as well as cigarettes do cause cancer. l
>=- .
Statistical evidence is a basic requirement of ;
- all scientific proof. For example. the general l M i i i i e,- i,7 =. gas law applies only to observations on a istge g 3 i , . ,e' O'y ,,
number of gas molecules under changes of 3 pressure, volume and temperature. It does not f
/ ~C. = - //
y j indicate the behavior of t. single molecule. One I, { a, => 5_
,f / / / /
l'y / c' jf, f
/[ _ , a g
j can, of course, refer to the results of many experiments with animals exposed tolow doses of x rays as evidence of radiation damage but (- i human data in the final analysis must provide I - i f
,/ s' /'/ l I the proof we require. The following list summa.
rizes some of the more important types of
** g ,[f l =
_E,, ! human exposure experiences that are being [. :* ,/ # j "
. d8 ~ ,, j i studied and are lending support to the belief that there is no dose of radiation solow that the . . , , ~~C.*O -* l r probability of its causing a malignancy and life l = , E,1 ,J ** shortening is zero: i .=
Fig.1. Trelationship of radiation dose in humans Sources of Human Exposure Causs.ng to chronic damage radiation sickness and death. , Radiation Damage (From data of the International Commission on Radiological Protection.) 1. Radium ingestion "'Ra, "'Ea, "'Ra-(sarcoma and carcinomal
2. Thoratrast ingestion-Th0-(hepatic (1) Chromosomal aberrations tumors)
(2) Changes in blood and urine chem. 3. Thyroid diagnoses and therapy-iso. l istry topes of iodine and x rays-(thyroid (3) Areas of increased and decreased cancer) bone density 4. Ankylosing spondylitis x. ray therapy- , (4) Polynucleated cells (leukemia and other malignanciesi
2. Radiation damage requiring a threshold 5. Chest radiographs of tuberculosis pa.
dose tients-(lung and breast cancer)
a. Eye cataracts 6. X. ray exposure of in utero children-

b. Radiation sickness (leukemia and other malignancies) '
i
c. Skin crytherr.a 't. Prenatal x ray exposure-(leukemia and A few persons, some of them radiologists, other malignancies) wish so strongly to believe there is a threshold 8. X-ray and radium exposure of uterus to ,
or safe dose of radiation below which no radia. induce artificial menopause-(teukemia ; tion dam. ige will result in man that ti ey refuse and other cancers) i to consider the evidence, and at tirses even 9. Survivors of atomic bumbing of liiro. e l 7
't . . . a.-. . . t Vol. 44. Na 6.1973 THE NEED FOR RADIATION PROTECTICN '
387 shima and Nagasaki-(all forms of can. . cer, cataracts, brain damage, reduction *' _ ***""__ *" M "* *** *y,,[___ '" g* in organ size, change in sex ratio) yP O y,'
- 10. Radiation accidents-criticality, radio- ? = = a- .
f. graphic sources, x rays, high voltage *"""**
accelerators-(death, cancers, cataracts. I - }
r radiation burns) 5 . II. Early exposures of radiologists to j ,. x rays-(all forms of cancer and life ("- *
. shortening) j ,, ' "
12. Exposure of uranium miners-radon *
. daughters-(lung carcinoma) ^ - -
Sometimes the data' on bone tumors that Fig. 2. The per cent incidence of sarcomas and have resulted among persons who have in-carcinomas plotted separately on a linear scale gested large amounts of radium are plotted on against the median of the total skeletal dose in rads semi-log graphs, as shown in figure 2, which at on a logarithmic scale. For the notation at the top of
^ first glance seem to suggest to the nonscientist the figure. 0/42 means zero cancers among 42 persons proof of the existence of a threshold dose below . in this dose range: 2S,2C/16 means two sarcomas which no bone tumors will appear. However, if -and two carcinomas ar.iong la persons in this dose these same data' are plotted on Cartesian '* "8 '' I AN . Part H. ES. Depanant of coordinate paper, as shown m. figure 3, they Commerce Spr.ingfield, VA, July,1959-June,1970.)
seem to support strongly the hypothesis of a linear relationship between radiation dose and effect. Table 2 is a summary of data showing y,,~ag,'a
. . , a ~a ,.'*"*
the gradual increase of severity of biological [s=- , , , , , , changes as the radium dose is increased from f..e 0.001 pc. '"Ra (corresponding to an average skeletal dose of 0.3 rem /yr * 'o 5.5 pc. '"Ra
p. ,
(corresponding to 1,650 ren .). In this case, j '*- i 0.1 pc. 8"Ra (corresponding to 30 rem /yr.) is i"- *
the maximum permissible body burden for the la-
. occupational worker. , y hfany studies" 8' '8 have been conducted 8
W I , that indicate the human fetus is very radiosen. * "" "" 7,,, ,,,;" sitive, and the malignancies produced per rad of x rays may be five to eight times the rate Fig. 3 The per cent incidence of sarcomas and indicated in figure l for exposure of adults.The carcinomas plotted separately against the median data of Stewart and Kneale ' in figure 4, 8 value of the total skeletal dose in rads in linear showing a linearly progressive increase in the coordinates. For the notation at the top of the figure, 13S. 3C/25 means 13 sarcomas and three carcinomas number of cancers in children as a function of in this dose range, etc. (ANL.7760, Part !!. U.S. the number of pelvic x-ray examinations re. Department of commerce, Springfield. VA, July, ceived by their mothers during pregnancy, are ID69-June,1970.) more than " suggestive" of a linear relationship between dose and effect. The estimated aver. ' age dose per x-ray film was only 0.25 tem. Such doubtedly have prevented much misery and studies led the ICRP' to recommend that, where practicable, for women in the childbear. suffering and have saved many thousands of lives of young children. ing age x rays to pelvie and abdominal regions In this connection, it is of interest to note be administered only during the ten-day inter. val following the beginning of menstruation. thst the 19G4 U.S. Public Health Service sur. vey indicated the average abdominal x-ray skin hfembers of the medical profession who have implemented this ICRP recommendation un. dose in the United States is 0.79 rem. and that
. this dose is 0.63S rem if given under the care of # a. Deus mee.D W e. cow.. _ mi.e. w e. e em e.. 4 e eu. em ,,e.,, e,4 . , , ,,,,g, , , ,, ,
9 h
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asm '. 1 I MORGAN Motogic Technology
, 388 . g Tasta 2 sDNC-TERM EFFECTS or RADit;M IN MAN Biological Changes t%)
e Ra Body Bunien (sc) *' g, ",' g , 0.001-0.03 0.3-9 83 2f 8 0 0 0 4 0 0 0 0 0.03-0-0.1 0.1-0.3 9-30 30-90 69 l[13/// 1 3 6 6 3 90.-300 12 25 iG [2' 16
//.[/9////M O.3-1.0 6 6, 14 12 62 j 32 1.0-3.2 3.2-5.5 0 0 0 9 1 , g *Those with malignancies were listed also under previous columns.
(Data from Finkel, hiiller and llasterlik, ICRP No. 11, 19681 w .' d - of all medical doctors, and that there be
' ' questions on these subjects on the state board E e.2 g g, ,,o I l
l l
! [f /
l V i cxamination. I am pleased that The American Society of Radiologic Technologists has been working with the Bureau of Radiological Health of the y 05 w o.4 y' USPHS and other medical organizations in the E o.2 preparation of model legislation designed to
$o [t o t 2 3 4 5 6 correct these faults and to assure effective legislation that will guarantee eventually that nuvata or pacNostic x-Raf FILMS DUMG PREGNANCY all users ofionizing radiation in the healing arts have proper education, training and certifica-Fig. 4. Relationship of cancer in children to the number of pelvic x. ray examinations received by tion in its correct use. I am pleased, also, that their mothers during pregnancy. (Data from Alice in these negotiations *.he ASRT has been insist-Stewart and G. W. Kneale Ecncer, June,1970). ent that there be as much consistency as - possible in the education and training require-a radiologist, but is 1.253 rem, if given other- ments in the various states and that the standards maintained must be equal to and wise. I believe this does not mean the radiolo-preferably superior to the*se presently enforced gist carried out these abdominal diagnoses himself at about half the dose delive ed by by The American Registry of Radiologic Tech-other members of the medical profession for the nologists. It is a great encouragement, also, p,
same examination, but rather that on the that regional and state organizations of radi-ologic technobgists are beginning to take the average the x rav technologists working in lead in forming appropriate state and local hospitals and private offices of radiolo:ists Iegislation to maintain high standards in radi-were more likely to be educated and trained of gic technology and to provide adequate properly and to be certified. I think it is protection of the patient who is to be radio-regrettable that proper training and certifica. g ,phed and of his or her children who could tion of x. ray technologists is required in only three of our states-New York, New Jersey and E fer the consequences of unnecessary x. ray California *-and it is deplorable that only one u eure for many generations to come. I only of our states-California-requires education ~ equal progress was being made by other
'abers of the healing arts to nssure appropri-and training in x. ray and radiation protecticn c f training. I do not beiieve any doctor should have the right to request an x.rny examination
Kentucky now (1973) requires education, train. in an x. ray department (much less administer ing, and certification of x-ray technologists. the x. ray exposure himself) unless he has b
e
. .. ... .. . . . . - y-
.t.
Vol. 44. No. 6.1973
. THE NEED FOR RADIATION PROTECTION 389 appropriate education, training and' certifica.
have shown that at high doses of ionizing tion in the proper use of x rays. radiation the malignancy curves such as those As outlined earlier, two important sources of plotted in figures 1-3 drop off to form a human exposure causing radiation damage parabola. shaped curve, i.e., the number of o which have been under intensive study are (1) malignancies reaches a maximum at some x-ray exposure of children in utero, and (2) large dose and then declines at higher doses. survivors of atomic bombings of Hiroshima and e Another reason for some of the differences Nagasaki, Japan. As often happens in tesearch, may be due to the fact th it the Japanese the studies of children who received exposure in fetuses were exposed to both neutrons and utero during the atomic bombings of Hiro. gamma r>.ys while the study groups in the shima and Nagasaki do not appear to confirm United Kingdom and the United States were the findings of an unusually high incidence of exposed only to x rays. malignancy as found by Stewart and others o Additionally, the Japanese control group among children exposed in utero when their of. bomb survivors probably had a greater mothers received pelvic and abdominal x-ray cancer risk than normal, exposure Jablon and Kato' pointed out this e Furthermore, the average fetal dose,in the discrepancy between their studies of Japanese United Kingdom may have been greater than children and Stewart's studies of children ex. 500 millirads per examination. posed in utero. I have exarr.ined both sets of When all of these factors are taken into data and compiled the following principal account, all discrepancies in the data from the 27asons why there seems to be a difference in two tvpes ofin utero exposure disappear. the effects of the two types of radiation ex. One of the earliest sources of human expo. posure. sure that has been studied extensively is that of e First, there was an unusually high abor-occupational exposure of the early radiologists. tion and infant mortality rate in Hiroshima Table 3 summarizes some of the data collected and Nagasaki following the atomic bombings, by Seltser and Sartwell. Here it is observed and undoubtedly the children. who otherwise that these early radiologists in the age group would have died of radiation-induced cancer, had the scales tipped against their surviving Tante 3 more than two years when such malignancies ratio or DEATHS AsfoNG RADioloCisTs To Nt'sfBER usually appear. txrrerro raou ruz exernersec or o Likewise, many studies' have shown that omn4m wcasTs aso oTonwimanocowcisTs, tw during times of community disasters it is the 88 383*'1953* young children who suffer most and usually die Cause et Death of causes other thaft cancer. During such peri. Age croup Cardio-ods, incipient cancers can be mistaken very brJ I#"I'"". st * * 'cular other easily for acute infections. at Causes Disease ['," *I, e Also, we must not overlook the fact that species difference has been observed 8'in many 9 M. 1.2 1.0 1.*I animal experiments, and it should not be surprising to find different radiation responses
.j -
Ij in children in Japan, the United Kingdom and the United States, 'These data indicate the increasta death rate among radiologists compared to the control groups or e Most importantiv Jablon included in his
' leukemia other malignancies cardiovascular and study children who had received m high renal disease.and other causes of death. The in.
doses of radiation in utero, and ver:. E>hably creased death rate of radio!ogists is t hought to be the at these high doses one should expect a sharp '""'*'." of z. ray exposm. As a mann of decrease in the number of childhood r..alignan. e2P12ast' n. in the age group 50-64 there were 7.3 times as many leukemic deaths and 1.7 times as caes. (Jablon.s data included 33 chilo, ten who had received more than 300 rads while Stew- many deaths from other malignancies among the art's data did not apply to doses at the far end radiologists between 19.13.and 19ss as amoe:: the control group that did not receive occupational of the parabola.) hlarinelli' and many others exposure to x rays.
. - . . - , . . i
o *I ,
. aso -
MORGAN Ra6ologic Technology 50-64 had over seven times as many leukemias tion. llempelmann.' after examining the inci. as the control group, and death from all causes dence of thyroid cancer among children at Ann in the age group 65-79 was considerably greater Arboe and Rochester who had received x-ray than for the control group. In table 4, it is noted treatment for thymic enlargement and children
. i that tl e early radiologist *s life expectancy was in the Marshall Islands whose thyroids were . ! shortened by 4.8 years in the period of 1935-44 irradiated by "'I fallout, concluded: "The . four years in~ the period of 1945-54, and 2.9 incidence of thyroid and extra thyroid tumors years in the period of 1955-58. Studies of in the Rochester series is dose dependent, and Warren" indicate that beginning about 1960 the frequency of thyroid neoplasms is age when radiologists conformed more nearly with dependent until age 18. Some evidence is
the maximum permissible occupational expo- presented suggesting that (1) the dose response i
sure levels recommended by ICRP and, more to thyroid tumors is linear in the lower dose '
! importantly, when most of the diagnostic x ray range, and (2) there is no threshold or at least [
exposures were delivered to patients by the the threshold is below 20 rad." Incidentally, j'
x. ray technologist (and not the radiologist). _ Lewis" points out after examining data of there apparently has been no detectable life Eaenger, et al." that in the case of medical shortening of radiologists. exposure to "'I delivering rather low doses of
'Ihis, of course, suggests immediately the seven to 13 rads to bone marrow, there is a question, "What about the x. ray technolo- significant increase in leukemia among persons gist?" Unfortunately, we do not have an an- between ages 50 and 79. Other studies also have 3 swer to this question. Certainly, unless tech- indicated an increas 3d radiosensitivity in older 1 O nologists heed the warning of the experience of age groups as well as among fetuses and chil-radiologists.who operated the diagnostic x. ray ' dren, so the rule for technologists should be to machine in the early period, they can expect avoid all unnecessary radiation exposure re- I' similar damage. Of even greater importance, gardless of the age of the patient.
however, is the fact that unless technologists As pointed out here, we are concerned not avoid unnecessary radiation exposure of their only about somatic damage from ionizing ra-patients, many thousands of these patients will diation, but genetic damage that can manifest suffer consequences as indicated in tables 3 and itself in congenital defects and deaths among 4.~ our children and children yet to be born for
. Another type of malignancy-thyroid many generations. From the early genetic stud.
carcinoma-likewise appears to increase more ies by Muller" of Drosophila (flies). It was 3
or less linearly with the dose of ionizing radia- thought that genetre damage increased linearly
. T4str 4 -
bloRTALrTk or MEMBERS oF SPECIALIST NEDICAL SOCIETIES: CEATH RATE PER 1000 MEN PER TEAR, sTANDAMDtIED FOR Act Death Rate Period Agetyr.1 RadWog h Specialist Ophthalmologists and Physicians E.LT. Surgeons 35-43 6.6 1 4.61 3.3 1935-44 50-64 19.5 (71.4)* 16.1 (73.4)* 17.1 (76.2)*,
, 65-7,9 57.6 j 51.7 J 38.S -
35-49 3.51 I 3.8 1 3.51 . 50-64 1945-54 17.8 (72.0) 14.9 (74 8) 12.9
, * * * ~ ' ' - *65-79 57.9 j 39.0 h (76.0) 45.6 J l *. M1: '. .
U* ' 5$-49 2.1 2.11 2.7 1
1955-58 50-64 12.1 (73.5) I1.6 b (76.0) 9.4 - (76.4) 65-79 59.3 44.0 42.8 j
*The values in parentheses are mean ages at death.
e 9
=
_ . . . . . . . . . . '*! .- . . *~~ Vol. 44. N o. 6.1973 THE NEED FOR RADIATION PROTECTION 393 with dose, and there could be no dose rate { dependence. More recent mouse studies of Russell" (the results of which are plotted in .{., , jjiJ ]eis ..y .O.l$g D' Ly,, _ r figure 5) indicate rate independence when the dose rate is above 5.000 roentgens per hour, but j ,,, 9_.h .l[_f.i I 8.f. '.f _N j . _ g . c. 'si 2 o , . as the dose rate drops below 5.000 roentgens per hour, the mutation frequency for both oocytes j ab _p$ g ;;ki dR,[.._ 8.! @
,,3 s :
5-* g (female) and spermategonia (male) drops off g ,,, _ig !pI f8g .l. j - _ rapidly. The rate for the oocytes drops-down to y ; s ' ,! i-background levels where, presumably, there is g ,,, 5"*f *;- __ lI*4,_
- { L. . Ql Q_.__.
complete genetic repair. However. for the sper. :;
5 ) _) e. 8 mategonia. there is a drop.off by a factor of ) , ! l ! !, L f h ! !* .
about three where at 50 roentgens per hour d* d' d d d d d there is a return to dose rate independence of 85
8 " 8

c* / p.
mutation frequency at lower dose rates. Since Fig. 5. Rate dependence of point mutatiers in ' there are the two sexes in every mating, and mice. (Data from W. R. Russell. Nucleor.ics,1965.) assuming a drop to zero mutation frequency for the oocyte and a drop by a factor of three for ,., Ants 5 the spermategonia. we conclude that at least in c ,,,,,,,,,y ,, ,,s ,,,y ,3c ,, ,, x,,,, ,,,,,,37,e the case of the mouse, genetic damage below a xxroscas ratsesity arccivro er att. u.s. Porttarros dose rate of about 50 roentgens per hour is wm Tue coxstorcscos or A co.stiscots Exront one-sixth that at higher dose rates. From this. raou ait wretcAnisocsrates or 0.5 rr.a ecsr or Tur however, we must not jump to .he conclusion attowro 170 stacu rca scan (0.85 sinne/vrax) that genetic damage is zero at very low dose e,,,,,,,,,, rates. At very low dose rates. it is one. sixth as ~ consequenenor etHypuhetical great as previously considered and as at high N,djj((j'[ n['[,",[,(',I ,, dose rates, but at high dose rates such as are Types ef Radiation posure l*re=ent!y to U.S. lWa. Damage vsg
~
ordinarily used in medical diagnosis and ther. . He la n n[,roin apy, there is no reduction below previous esti. (Deaths per Induserds mates and genetic damage is dose. rate inde. ' '[.,'[" pendent. If one takes the coefficient of radiatinn dam. Genetie 1,100 to 44,000 3:o120 age as given by ICRP'
and as plotted in figure I.edem:a 500 3 1, and applies it to the estimates of dose to the '
Dyn,, ,Cx Istoico U.S. population from medical diagnosis as Thorax x rays 2 to 20 given by the USPHS." the number of deaths . other cancer 500 3 per year from medical diagnosis in the United Life shortening 1,200 8.5 States can be obtained as summarized in table
5. The lower estimate of 1,100 genetic deaths Totaldeaths(~) 3,300 to4*.000 18:o 140 per year includes only the first generation deaths while the higher figure of 44.000 genetic deaths per year includes those that will be discouraging to note that, as shown in figure 6 introduced into future generations per year as a the number of x ray visits by members of the result of recessive mutations. For comparison. U.S. population was much greater in 1970 thart estimates of risk are given for the nuclear in 1964. One encouraging observation of this energy industry. Although much has been said latest (1970) USPHS survey," however. is that, recently in the public press concerning this as indicated in figure 7, the mean ratio of beam risk, it is to be observed that it is very small by area to film area has shown a great amount of comparison, improvement (reduction) in every area except In terms of the risks from diagnostic x ray there has been only slight improvernent in exposure as estimated from popdation expo. stivate offices of radiologists at:d among public sure data reported by the UEPilS in 1961, and health agencies and other groups.
as I have summarized in table 5. it is perhaps One of the most promising developrnents 4 3...--. . . . . .
.. : s '- . _ . . . . . . . *-*---;.~._%.,w. . .. e i
1 -
. I f~ , 392 MORGAN Ra6ologk Technoiegy l .- - " ' " " 3. Heavy legal penalties for failure to do t " " ,' . . a U.' ~ y. .
l .,.o . . ~ .... radiographic examinations, but no pe.
._, nalties for unnecessary exposure of pa- . . i=. tient, '""~"""M** 4. Insurance covers most costs for x ray o '"""' examinations.
l ,, ., !"' , g , g ,,, 5. h1 ore films per diagnosis now required j a h,, than formerly.
, . m. p. 6. Shortage of trained workers leading to * ""' . ; , ' N' hasty, hazardous techniques.
l
. ; ; ; ; ; ; ; 7. Folkways and traditional rites.
l "'.'.it," = =J:"=. For good measure, I have added some of my
* **n re8s ns i excess ve patient exposure:
Fig.*6. Estimated annual number of x-rsy visits in millions in the United States 1964 and 1970. S. -ray examinations add to income of (Preliminary estimates from the USPHS 1970 x. ray doctors or the medical mstitution. exposure study.) Total visits 143 million for 1964; 175 9. Patient ignorance. Patient judges medi. million for 1970. calcompetencein termsof henumberof
x. ray examinations.

10. Radiographs are required for certain jobs
* '" (nurses, teachers, restaurant workers, , % .e _ .a u etc.). = _ , _ , , ,
11. X. ray surveys where there is little need
,,,,,,, m (mass chest x ray program).
7/2 ' _ '. . . 3,,'" 12. Required pelvimetries sometimes a rou. tine for first pregnancy. .
;;;;; la 13. Failure to use radiographs alreadyin files
m. ~
-.nn of pat.ient.
O.'ai . In 14. Failure to use tape and computer equip-
.,fui ment for storing and retrieving x. ray - . " ' " ' {a ", a a
e data.
15. X. ray examinations used for pyscho.
, Fig. 7. Estimated mean ratio of beam area to film therapy (neurotic patients). ., area for radiographte exammation by type of facility
16. Radiographs as a financial drain onlled-m the United States.19G4 and 1970. (Preliminary . .
estimates from the USPHS 1970 x. ray exposure scare and h!ed.icaid. study.) 17. Failure to observe special x. ray require-
~ ments for children and infants.
15. Use of fluoroscopy where dynamic infor-mation is not required.
recently is that a number of radiologists. tech- 19. Lack of education and certification re-nologists, dentists, and othcr members of the quirements for all who own, operate, healing arts are beginning to speak out and supervise or request diagnostic x. ray ex-criticize their own profession for its failure to aminations. give appropriate attention to reducing unneces- 20. Some medical x-ray examinations of sary diagnostic exposure of the patient. Per- questionable and bizarre benefit. to pa- 1 haps the most frank and informative article of tient, e.g., practice of some chiroprac-this type was by 11cClenahan." Listed here is a tors. summary of the main practices he emphasizes 21. Rad 4otegy not practiced as a profession as causes of excessive patient exposure: -radiologist takes orders from others l 1. Easier to order an x-ray examination and fails to exercise professional jud:- I than to think. ment. Radiologist lacks proper motiva.
2. Examinations are ordered "to rule out" tion to maximize ratio of diagnostic in-when accurate diagnosis has been made formation to radiation damage to pa.
with the nakcJ eye. tient. g~
.f
s
;
o '
= - w ;-e...- .: = -- - - - _ - .., ,d:- - -*
Vol 44. No. 6.1973
.. THE NEED rOR RADIArlON PROTECTION 393
22. Failure to establish professional rank of equiprnent, and (3) the appheation of better
" senior technologist."
diagnostic techniques. Adrian' gave strong evi.
23. Medical radiography used by insurance dence that medical diagnostic exposure in the companies and lawyers to ve,rify claims United Kingdom could be reduced when he of injury.
said, "If all radiologleal departments in the
24. Failure to maintain patient dose records.
United Kingdom employed the techniques al.
25. Failure to avoid exposure to critical tis.
ready in use in 25 per cent of the departments sue such as the central nervous system, in 1953, the population gonad dose from diag. active bone marrow, lens of eye, thyroid, etc. nostic radiology would probably be reduced by a factor of 7." This would mean, for example, a
26. Use of mass production and cookbook reduction of the genetically significant dose in procedures in radiology.
. the United Kingdom from 14 mrem / year to 2
27. Lack of appropriate state or federallegis. mrem / year. Why, then, can't we in the United lation.
States reduce our genetically significant dose
28. Medical diagnostic exposure of the popu- from the 1964 value of 55 mrem / year to 5 lation should be included as part of the mrem / year? Present forecasts are that the 1970 population dose limit of an average of 170 survey, when the final compilations are com.
mrem / year. plete, will indicate the genetically significant
29. Poor equipment and techniques.
dose is now greater than 55 mrem /yenr. Much
a. Use ofinsensitive films (slow speed). of the success we seek in reversing this trend

b. Poor developing techniques.
depends upon the radiologie technologist. I am
c. Edges of x. ray field not showing on counting very much on him and the independ.
film. ent progressive thinking ofleaders in his profes.
d. Overexposure and underdevelopment sional societies to take the necessary steps in of film.
reducing the renetic and somatic dose of the
e. Target. skin distance too short. U.S. population.

f. Improper voltage.
Another strong incentive for reducing unnee.
g. Poor coning and diaphragming. essary diagnostic exposure of the patient is that"

h. Poor timing devices.

i. Improper filters. almost every measure suggested for reducing this dose provides the opportunity for better

j. Insufficient shielding.
. radiographs and more meaningful diagnostic
k. Poor calibration of equipment.
- information. As indicated at the beginning of
1. Some imported equipment does not indicate voltage and current. this lecture, there is no doubt that the x ray is

m. Failure of radiologist to dark. adapt one of the most valuable of medical tools. We eyes.
do not know how many lives it saves each year in the United States, but we might assume
n. Use of substandard photofluoromet-arbitrarily that this number is 100.000. Some ric equipment.
might contend that there is no cause for alarm
o. Lack of adequate beam centering if diagnostic x. ray exposure is causing 5,000 to devices.
50,000 deaths a year while it is saving 100.000
30. USPHS report of 19M indicated the lives. Our argument, however, is that by better genetically significant dose from diag. use of x rays and the elimination of unneces.
nostic x rays was 55 mrem / year. The 1970 sary x. ray exposure of the patient we might estimate may turn out to be considerably reduce the radiation deaths by a factor of 10 higher. (i.e., to 500 to 5,000) while at the same time the Elsewhere I have listed some 63 ways by benefits of x rays might be doubled (i.e., save which the average medical diagnostic dose to 200,000 lives each year instead of 100,000). persons in the United States can be reduced at I believe the radiologic techno!ogist must least to one-tenth the proent values." " Most play a major role in bringing about these of these can be summarized under three head. irnprovements in diagnostic radiology. We hear ings: (1) better and more extensive education, a great cry these days c.baut the hundreds of training and certification of all members of the millions of dollars the U.S. taxpayers should l medical profession; (2) better use of modern spend to train more radiologists. Although a
+ . . We _es e e. .e.
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* ! Rad.otogic Technology 394 .
MORGAN {, sufficient supply of well. trained radiologists is hfoseley. The Wall Street Journal. VCLXXVI!!. Vital to an adequate medical program. I do not No.122 (Dec. 23.197 D. believe there is such an urgent need for addi. . Hernpylmann I ,II.: Risk of thyroid neoplasms
after irradiation in childhood. Science 160 159 t.ional radiologists. Rather. I believe we must (Apr.12.1963).
recognize the situation that exists and has 6. ICRP Publication 14: Rsdiosensitivity and Spa. existed for a long time; namely, the senior t ist Distribution of Dose. New York: Pergamon Press (1969L i* radiologic technologist has become of stature 7. ICRP Publicat,ien 6: Recommendat, ions of the
, , and matured to a senior member of the medical International Commission on Radiological Pro. .
profession. He does most of the diagnostic x ray tection. New York: Pergamon Press (15641.
! examinations and knows more about the use 8. ICRP Publication 8: The Evaluation of Risks I and maintenance of the x-ray machine than from Radiation. New York: Pergarnon Press .
9
. . does the radiologist. Why not officially recog. 9, y,b . S. and Kato. H.: Childhood cancee in ' nize this grade of senior radiologic technologist. relation to prenatal exposure to atomic. bomb then? Why not require that a technologist radiation. Lancet. p.1000 (Nov.14,1970s.
10. Lewis. E. B.: Leukemia, radiation and hyper.
qualifying for this rank complete a carefully thyr idism. Science in;454 (Oct. 29.1971L , planned four. year program rif education and ' ' P " '" training. pass a special certification examina* an .J A1 fl9 tion and then be moved into the higher medical 12.11cClenahan. J. L: Wasted x. rays. Radiology ranks? Here he would be given complete 96:453 ( Aug. 1970L
13. Sforgan. K.- Z.: Population exposure to diagnos.
responsibility for the operation. maintenance tic x rays and the , resultant damage can be and use of the diagnostic x. ray machine and reduced to 10ri of their present levels uhile at the would be, paid at a rate becom.mg of his same time increasing the quality and amount of professional rank. He would make his own diagnostic information. Testimony presented be. decisions commensurate with his responsibili. fore the Hnuse of Representatives. Washington, DC on HR 10790 (Oct.11.1967). ties and plan and carry out his own program of '"** # " #"'I Providing the best possible diagnostic radiogra. cal Exposure. Hearings before the Committee on phy with the minimum dose to the patient. Commerce. U.S. Senate 90th Congress. first Such an arrangement would relieve the need of session on S. 2067. Serial no. 90-49. p. 46 (Aug. 28,1967h expanding the number of radiologists and 15. 51uller. J. H.: 51an-his environment and would set the radiologist free to work more health. Suppl.to Amar. J.Public Health part II. e closely w.ith other members of the healing arts. 50:45 (Jan 1964).
to specialize on reading and interpreting the 16. Preliminary Estimates from the U.S. Public
x. ray films and to concentrate most of his Health Sersice 1970 N. Ray Exposure Study.
Charts for an oral presentation at the session efforts and specialized skills on x-ray and sp ns red by the American College of Radiology radioisotope therapy. I believe such a workin- at the Roentgen Ray Society meetmg Boston. team could. provide cheaper and better radi. 51A tSept. 29.1971). ology of higher professional quality and with 17. Prenatal X. Ray and Childhood Neoplasia. Divi. sion of Biology and Stedicine USAEC Repo t much less population exposure to ionizing ra. TlD.12333 ( Apr.1,1961). diation* 18. Russell W. L: Studies in mammalian radiation
. genetics. Nucleonics 23 53 (Jan. 1953).
19. Saenger. E. L: Radiation and leukemia rates.
REFERENCES Science IH;1096 (Star.19.1971L
20. Seltser. R. and Sartwell. P. E.: The inficence of

1. Adrian, G. bl.: Hazards and dose to the whole occupa:ional exposure to radiation on the mor.
population imm ionizing radiations. Ann. Oc. tality of American radiologists and other medical cup. Hyg. 9.S3 (1966). specialists. Amer. J. Epidemiol. Sl;no. 2 s1965 :
2. Argonne National Laborstory Radiological Phys. The effect of occupational exposure to radiation.
Ics Division Annual Report. ANIA760 Pirt 11 on the mortality of physicians. JAA1A 150:1046 (Dec. 196 0. O, U. S. Dept. of Commerce. Springfield. VA. (July.
21. Warren. Shields: The basis for the limit 19G9-June.1970).

3. Bennet, Clin: Bristol floods 1963. Controlled whole-body exposure-experience of radiator' survev of effects on health of local community Health Phys. 12:737 (1966L dis uv r. Brit. Sted. J., p. 45 8 I Aug. 22.1970L 22. Stewart. Alice and Kneafe. G. W. Rad

4. Gui ert. David: Statement by Dr. Robert dose effects in relation to obstetric x ra-6
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Vol. 44. Na S.1973 THE NEED FOR RADIATION PROTECTION 395 childhood caneers. Lancet, p.1185 (June 6, 25. Warren. S. and Gates. O.: The inclusion or 1970). leukemia and life shortening in mice by continu.
23. United Nations: Report of the United Nations ous low-lesel external samma radiation. Rad.
Scientific Committee on the Effects of Atomic Res. 47:480 (Aug 1971). Radiation 17:h Session. Suppl. No.16 (N5216). New York (1962). School of Nuclear Engineering
24. U.S. Public Healt h Service Publication No. 2001: Ccorgia Institute of Technology
Population Dose From N. Rays. U.S.1964 (Oct Attonta. Georgio FA132
. 1969). '
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YES" is the answer to question of R. H. Thomas and D. D. Busick, **ls it really necessary to reduce patient exposure?" .
KARL Z. MORGAN ! School of Nuclear Engineenng. Georgia institute of Technology. Atlanta. Georgia I The abose article by Thomas and Busick, result in the sasing of hundreds of thousands of
~ " ' vi " Reducing Patient Exposure to lonizing lives each year but this is no excuse for using j Radiation - is It Really Necessary?" calls for them carelessly and excessively so as to cause some comment. In this article the authors take needless loss of tens of thousands of lives each issue and apparently conclude the answer to yea r."
their question is "No, it is not really necessary to Of course there is some uncertainty reduce patient exposure." I pointed out in my regarding the magnitude of any gisen type of paper" that w hen a person has a chest x-ray the radiation damage as the dose approaches zero skin dose can be as low as 10-20 mR but it because as t stated in my article" . .as thedoses sometimes is as high as 2000mR or one may (in population studies) approach zero, the receive on'y $00-1000mR in a dental series but he probable errors apprcach infinity." Some may receive 100,000mR. We must conclude that persons would like to demand a one-for-one Thomas and Busick see no need or urgency to relationship in such indisidual cases but we are correct this disparity and would not be reminded by Heisenberg that when you
. concerned if a member of their families receised determine one parameter (such as momentum) for example 50,000mR in a dental series every with very high precision a related parameter six months. Perhaps also they would not quibble (such as position) cannot be know n. We oser the fact that invariably the larger and probably can never prove in an individual case excessive doses provide less contrast on the x-ray that smoking cigarettes was the cause of his lung film and much less medicalinformation. I guess caneer but neither can we prove that an also we can assume they find no fault with the individual electron obeys Ohm's Law. V=RI. or doctor who has a young woman x-rayed in the that a molecule obeys the General Gas Law.
pelvic or abdominal region for some trifling pv=RT. We believe in these laws because we l reason when he has reason to believe the woman believe in statistics and this kind of conviction is j may be pregnant. The principle thesis of the a requirement for all scientific judgement and y Thomas-Busick article is "the risks at low levels generalization of the laws of science. l have not been demonstrated." They repeat this Thomas and Busick quote extensively from thesis seven times in their article presumably R. D. Evans. I hase the highest regard for Dr. because they labor under the misapprehension Evans but it is well known that from time zero he that if they repeat an untrue statement often has been a staunch supporter of the threshold enough, not only they believe it but it appears hypothesis and I doubt he will ever change his credible even in a scientific publication such as views. Thomas and Busick quote from Dr. the AlliA JOURNAL. They doubt the public Evans. "As originally introduced care was should be " alarmed" to take measures to reduce always taken in protection committee reports to [ unnecessary medical exposure because medical point out that the true risk in the low-dose radiology is so beneficial and they think the domain would be expected to be between zero harmful effects are problematical. and the upper limit given by the linear non. No one questions for a moment the benefits threshold approximation." Surely they are of medical and dental radiology btit this is no aware that the word "always"in the above quote reason a person should receive unnecessary takes in far too much territory to be applied , exposure. Contrary to the complaint of Thomas during the present decade. There are a number l l and Busick that " Morgan's thesis does not of cases where these committee reports have 1 l attempt in any way to balance the benefits that taken a neutral position on this question. It i.s ! i do occur from medical uses of radiation" I fortunate they hase done so because more and l remind thern that I stated in my article " . . l more evidence today suggests that in many cases l ionizing radiation can be one of our most (and especially for high LET radiations such as a j
. valuable medical tools when it is used properly, and fast neutron interactions) not only is the i Needed medical x-rays shoold not be avoided . .. threshold hypothesis non-conservative but the l Diagnostic x-rays in the U. S. without doubt linear hypothesis may be non-conservative also. ' ' 4# ~I " '
amencan inaustna: Hygee Associahon JOURNAL 07) 11/76
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. . .y COMMENTS .
i. e. the risk per rad increases (instead of children who received in utero exposure have decreasing) at lower doses and dose rates. I will extended over many years and have indicated mention as example only two of a number of that the mortality from leukemia and other cases where such committees took a neutral forms of cancer is 509o higher on the average position and fortunately they do not now have to among children exposed to diagnostic x-ray in recant their position. The ICRP committee utero than among children not so exposed. The chaired by l_amberton* stated."It is recognized fetal dose was estimated to be between 0.3 and that factors invohed in tissue response to high 0.8 rad. It is true that some " hardshell w w" "m doses of radiation might lead to cither a decrease thresholdists" like Thomas and Busick have or an increase of the response dose ratio attempted to depreciate the findings of Stewart obtaining at low doses and dose rates." As but Stewart's Oxford studies havestood the test another example, the BEIR'" report states, and a number of writers" " have shown that if "Because a linear extrapolation model has been she erred in estimating the risk,it most certainly used in the calculation, the number of cancer was on the conservative side,"'she would have deaths attributable to any dose other than 0.1 underestimated the risk.
rem y can be estimated by simple multipli- Second, I mention the tristatestudies of Dr. cation; howeser, it must be borne in mind that Bross. He pointed out at the Congressional the foregoing estimate of mortality from Conference on Low-Level Radiation"'that radiation exposure (at 0.1 remey) may be too there are some groups in the population that high, or too low. for a variety of reasons . have an unusually high susceptibility to The reader of the Thomas-Busick article radiation damage. He said that children in his may be as puzzled as I was at their comment that study with such diseases as asthma, hives. Dr. W. D. Rowe of the Environmental eczema, allergy, pneumonia, dysentery or Protection Agency has had a " subtle rheumatic fever have shown a 5000 percent metamorphosis" of his mind as indicated by his increase in risk of leukemia as a result of
" unqualified use" of this model to calculate exposure to x-rays.
actual deaths and observe that on this model . Third, I mention the findings of Mondan et natural background radiation causes 13,000 al"'" from their examination of the records of health effects per year in the United Sates. I1,000 migrants into Israel that were Everyone agrees there must be some fine tuning administered x-rays to the head in order to
- in the application of a general model but I see control tinea capitis. They found there is a very nothing amiss in Dr. Rowe's use of this model. high risk of 6.1 X 10-* thyroid carcinomas per 4 -t.r M Apparently Thomas and Busick would object to year per child per rad. In this case the mean our stating for example that if there were an thyroid dose was only 6.5 rad. Thomas and average of x deaths from automobile accidents Busick state, "There are no convincing data to per car mile driven in the U. S. last year, we show that exposures to x-rays at this intensity expect approximately y=nx deaths in 1976 if n is (referring to 10 rad) are harmful to humans."I the number of car miles driven in the U. S. in contend these migrants into Israel are humans.
1976. Of course fine tuning should be applied to Thomas and Busick state that Rowland
- get the exact figure but this use of arithmetic does not support my observation that his does not imply there has been a subtle human 22'Ra exposure data are not in metamorphosis of mind or this use is conformance with the threshold hypothesis. O!
unqualified. course, only Rowland can say what Contrary to the seven times repeated thesis interpretation he makes of this data at the of Thomas and Busick "At the present time, no present time but being a careful researcher he has evidence is found that deleterious effects result not ruled out the linear hypothesis in several of from radiation exposures at the level of a few his publications. In fact he stated" "The rads or less." I can point to a number of studies radiation - induced carcinomas, however, seem providing strong evidence and experimental to be better fitted by an expression of the form data of statistical significance showing there are I=K De*"* in which l=carcomp,a omcodemce. harmful effects in man from medical doses of a K= constant, D= accumulated skeletal dose from few rads.1 will point to t hrec examples of human 22'Ra and D. = the dose value,1.24 x 10' rad population studies, each involving careful chosen to provide the best curve fit.1 submit that followup of many thousands of cases: this is a linear curve which is modified by the First, I mention the O.. ford studies of Dr. exponential e ""* which allows theincidence of Alice Stewart"' et al Her studies of thousands of carcinomas to begin to decrease at high doses D
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where there data demonstrate overkill from Energy, W. S. Snyder, V. E. Archer, H. M. radiation. The persons with the higher Ra Parker and I"brefuted again the claims of Evara burdens did not survive long enough to die of that his data support the linear hypothesis and cancer. This is borne out clearly in Figure 2 of later I refuted again his claims at the hearings the paper of Thomas and Busick. A much more bef are the Labor Department. Dr. Goss' ' important question is not what theory is points out many errors in Evan's analysis and supported by Rowland or Thomas or Basick or goes on to state,"Since a high proportion of the me but. "What cancer risks do the human Ra cases are still living, many of the histories are not
^ "' "^" exposure data actually indicate?" It is clear that yet complete and the higher than expected these data in Figure 2 (reproduced in paper of incidence of cer. tral nervous tumors in the A. N.
Thomas and Busick) fit best the curve L. series suggests that the range of radium
!=KD"c'"* in which n=1/ 2. In other words the induced malignancies may be wider than that curves are concave downward near the origin normally assumed." He goes on to state,"On the such that not only does the effective threshold basis of the M. I. T. and A. N. L. data and for the hypothesis (using n=2) break down but the purposes of radiological protection, there would linear hypothesis (using n=I) is non. appear to be nojustification for believing there is -
conservative for this a-radiation as I have any factor of safety in the present value of MPL pointed out."" Rowland cautioned"*' that a (0.ipCi) for "'Ra." targe fraction of the Ra cases in his study (580 in conclusion. I hase been endeavoring for out of 777 cases in 1970) are stillliving. I would over 30 years to point up the need for reducing remind our readers too that in the early studies what I consider is an excessive amount of of the survivors of the atomic bombings at unnecessary medical exposure to ionizing Hiroshima and Nagasaki many persons jumped radiation. The success that I and others have had to the conclusion that the only significant in these efforts is to say the least discouraging chronic cancer risk as a result of this radiation when w e realize the long way we still have to go exposure was certain types ofleukemia. Now,31 especially in assuring that those who use this years later essentially all types of malignancies most valuable medical tool (practioners, are making their appearance with significant dentists, x-ray technologists, etc.) have proper increases in number among the exposed education, training. certification and motivation populations. Our only conclusion is that the that enables them to properly weigh and mean incubation period for the development of evaluate the need for diagonostic radiological radiation induced malignancies in man is information against the risks of chronic
, g probably 20 to 60 years for many types of solid radiation damage. There have. been a few tumors. Thomas and Busick state "In public marked successes of recent date such as health matters prudence is necessary, but - " outlawing" the practice of marching our school contrary to Morgan's view - our experience with children into vehicles carrying portable mass x-radium dial painters tends to suggest that we ray machines; the requirment for education.
have indeed been prudent."I did not know that training and certification of radiation these authors have had experience with radium technologists in the states of New York, New dial painters but I can only hope their conjecture Jersey, Kentucky, California and the about prudence is correct. My betterjudgement Commonwealth of Puerto Rico; and the great tells me to wait and see what happens to the success in the State of illinois in setting limits of remainder of Rowland's cases (the 580 surviving x-ray exposure for some fo the more common cases). diagnostic procedures. I hope and pray the views. R. D. Evan's claim that his data on human expressed by Thomas and Busick will not delay exposure to radium support the linear progress in other states and in further hypothesis is refuted strongly by many scientists developments to reduce unnecessary medical that have evaluated carefully his arguments. exposure in many other areas while at the same Gofman and Tamplin" for example after their time improving medical radiology. evaluation of his data conclude "This analysis of the occurrence of bone sarcomas and ' carcinomas in persons exposed to radium, ,,,,,,,,,, occupationally or iatrogenically provides no ! support for any safe threshold of radiation with I. Morgan. Karl Z.: Reducing Medical Exposure to respect to carcinogensis." At the Congressional lonising Radiation. Am. Ind. Hyg. Assoc.J.36:358 Hearings of the Joint Committee on Atomic (1975).
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COMMENTS .
-2. Lamberton. l.. F. Chairman Report of the lad N Modan.11. II. Mart. D. Itaid.iti, R. Steinste and L Group on Spairal lloireurion of Ra.harmn llose. S. G. l.csin. Rada.ition - Induced licad and Nec k p,, , _ ICRP Pub.14. Pergamon Press (196H l umort I.aru rs 1. 277 (1974).
l ?/ ,' ~ ' " "' . 3. BEIR Report: The Et/ce av on Popularmni or 9. Siherman. C. and D. A. Iloff m.in. t hyroid l umor Esposurc to I ow I evcdot tom:in.e Ra,hanon. Na. Risk f rom Radiation During Childhood l'rrv. Med.
? . tional Academy of Science. National Research 4.100 (1975)
Council. Washmgton. D. C.. Nosember,1972. 10. Rowland. R. E, and P. F. Gustafson Rathoh .gi, a/
4. Stewart. A. and G. W. Kneaie: Radiation Dose Phish i l)o suon Annua / Report. Argonne National Eftects in Relation to Obstetric Lrap and Child- I ahoratory. ANI. - 7760 Part ll (June 1970).
.-, , _f .- .%. ; ,. apn1 . .~
hoed Cancers. lanrci. 1186 (1970) I 1. M or;a n. K. Z.: Suggested Reduction of Permissible v i'%w*9.jp $y 3.HI .
5. Ilolford. R. M.. The Relation Between Jusenile Sposure to Plutonium and Other Transur.snium Cancer and Obstetric Radiology. //calth Phi 3. Elements. A m. l~J.1/3g. A nor. J. 36 567 (1975).
2A 153 (1975). 12. Gofman, J. W. and A. R. Iamphn:1 he Questmn of y .y. 6. Landau. E.: llealth Effects of Low-Dose Radiation. Safe RadiationThresholds for Alpha EmittmgIlonc
;H .Q;4'h, ? !!t? Problems of Assessment. Int.1. Environ. Stud. Seekers in Man. //calth Phis. 21:47 (1971).
I p,F ' 7 ' , ! 6.51 (1974 L 13. Congressional llearings of Joint Committee on
~ 7 Bross. I. D.: Testimony at the Congressional Con- Atomic Energy on Ra.harion E.iposure of Uranium f2 2, ? 7 ~; b, ' .f C ,'
a xv., ference on Low Lesel Radiation. Senate Office Miners. Part 2, p.1216 (May 9 - August 10, 1967)
, Building. Washington, D C. Proceedings in prep- 14. Goss S. G.: The Malignant Tumor Risk from aration (May 4.1976). ' . Radium ikx!) Buidens. //calth Phrs. 19 731(1970). .
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'f l ,d a u (Cf f Tile NON-TIIRESl!OLD DOSE /EFFECT RELATIONSilIP by Karl Z. Morgan School of Nuclear Engineering Georgia Institute of Technology Atlanta, Georgia 30332 . l For this brief discussion I am oversimplifying the dose /effect rela-tionship of ionizing radiation and making use of the simple logrithmic I expression, i
n , E(effect) = Constant x [ Dose (rem)]n = CD L i l for human exposure below a few hundred rem as indicated in Fig. 1. It follows that when n > 1 and approaches 2 or 3 this approximates the thres-hold bypothesis; when n = 1 ve have the linear hypothesis and when n < 1, e.g. when n = 1/2, we have the non-threshold hypothesis where as indicated in Fig.1 the slope of the curve or the effect per rem is greater at low j doses than at high doses. j In the few ninutes I have I will discuss only somatic effects and in particular radiation induced malignancy, but as indicated by Fig. 2 !
~
some of the same arguments can be applidd to genetic damage. Here it is noted that the early work of Russell suggested the genetic damage to mice * (and presumably to man) per roentgen at low dose rates and low doses is ! only about 10% of that at high dose rates and high doses, but more recent publications suggest that'maybe the mutation frequency curve turns back ! up at very low dose rates near natural background and perhaps we are not ' warranted in making use of this 10% factor for genetic mutations. [ Prior to about 1960 most health physicists and radiobiologists sub- . scribed to the threshold hypothesis but since that time an overwhelming Civen beford the Academy Forum of the National Academy of Sciences, Washington, D.C., September 27, 1979.
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number of studies--many of them at low doses--have failed to give evidence of a safe threshold dose btit rather have supported a non-threshold dose / effect relationship. Also, during this period a number of studies (and - especially studies of human populations) have suggested the risk of cancer from low exposure is much greater than it had been considered to be some years earlier. As a result of these developments ICRP in 1971 concluded "the ratio of somatic to genetic effects af ter a given expos'ure is 60 times greater than was thought 15 years ago." During this period national and international standards setting bodies (such' as NCRP, AEC, FRC and ICRP)
. ' ' discarded' the " threshold hypotliesi's in favor of the linear' hypothesis; how-ever, many of those respohsible for this change maintained this provided I a generous factor of safety ' t low a doses and dos'e hate's ahd some even. .. .
vent so far as to make the fclse statement tl at there ver.e no data on low .
' ^ ~ . Icvel human exposure. These persons for unexplained reasons fail to recog-nize low exposure studies involvin.g m. any thousands' of subjects such as' ,
z . . for, example: 1) Studies of. Stewart.and Kneale of -cancers' in children - who had received in utero e'posure x (doses'from 0.2'to 0.8 rem to fetus), 5
2) Studies of Mancuso, . Stewart and Kneale of radiation workers at Hanford,' '-
Washington (average' dose ab[iut 1 rem); 3) The Tri-State Studies of Bross 6
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(doses < 1 r'em) and 4) Studies of Modan et al.7 ~ o f thyroid' carcinoma in perso irradiated for tinea capitis (average thyroid dose 6.5 rad). There are many reasons uhy some people still cling to the threshold
. hypothesis, why the risks of low level exposure are of ten underestimated and why many ' scientists fail to recognize that in many cases not'only does the linear hypothesis fail to provide a generous safety factor but it actually is nonconservative, i.e. n < 1. A few of the reasons for this divergence of opinion and'why the linear hypothesis of ten' underestimates s . .
the cancer risk are:
1. Overkill. 'At high doses the cancer incidence curve drops over
'pa'rabola shaped (as shown by Curve B in Fig.' 3) because many of tho' animals do not live long enough to die of cancer. However, this '
l overkill effect begins at intermediate doses such that if one extra-polates this curve from intermediate exposure levels as shown in Fig. 3 to zero without appropriate correction for overkill the cancer risk (as shown by Curve A) is underestimated. l 4 4
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2. 'Sh' ort follow-up of both animal and human studies can only under-estimate the cancer risk, r pecially for those cancers that have a very long period of in;'bation.

3. Animal vs human st iles. Man's oncogenic response in many ,
respects is significant iy different from that of test animals. For example his ovarian tumor response has long been known to be less than that of some strains of mice and one voeld expect'his ' ' response to bone marrow tumors and myelogenous leu 4 emia to differ considerably from that of animals in which all the 'oone marrow remains *
, . active (red 'instead of partly yellow) during the entire life.
Warren and Gates found very'large differences'in carcinogenic resportse even among , strains of the same animal, e.g. a large life ,
- * * ~
shortening and leukemia incidence in one strain of mice and essentially no such obserabic effects on another strain of mice for the same dose.
4. Short life-span animals with life spans ranging from 5 to.20 ' years are of necessity used to simulate the effects of rndiation'on man
'with a 70 year life span-this in spite of the fact that the, latent - . period of some cancers in man is 30 to 50 years. It is generally accepted that oncoganesis and the cancer incubation (latent) period relates to the time since an exposure was received, yet sometimes the simplifying assumption is made that the malignancies developing.
in a fraction of the' nnimal's life span following radiation exposure relates to the malignancies that would develop in man in the same fraction of his life span following the same dose. ,
5. Cell sterilizatiion. Many studies' (Fig.14) are made on" human and animal populations where the organ doses are so large that cell sterili-zation destroys preferentially those weak cells uhich are most likely to develop'into cancer cells (they present a large cross section'for.
~
cancer initiation) and extrapointion of these data to zero dose
. seriously underestimates the' cancer risk at low doses. A classic example of this type. of bias is the use by standards setting bodies (NCRP, ICRP, UNSCEAR) of very high thyroid doses of I311 to human subjects in estimating the risk of low doses of 131 1. Perhaps some-one should have reminded these organizations that a > carcinoma 6
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6. Heterogeneity of population. The widely publicized paper showing f
an increase of statistical significance in the incidence of cancers i of bone marrow, pancreas and lung in relation to the recorded radiation +
! exposures of Hanford radiation workers was published while-I was editor- f in'-chief of the' journal HEALTH PHYSICS and one of the criticisms I 4
received most often for publishing this paper (in spite of the fact ,
.that it was reviewed by four very capable reviewers) was these, data ,[ ' i t are useless because there are too many uncontrolled variables-sick, t i , persons on drugs, fat, slim, black, white, young, old, chemicci hazards, [
L
' genetic, differences, smokers, non-smokers, etc. I can hardly imagine-4 a more ridiculous ~ criticism. The authors of this . work did, correct for. I sex and internal dose and the other variables are being takec into -
account as fast as possible on a greatly reduced operatiing budget, but ! t
. _ I interpret these critics were saying essentially one should ignore i r
these human data and instead base our standards for low level exposure . [ on anihal studies where all these variables can be controlled. The : cancer coefficient for this Hanford population was higher (7 to 8 x 10-3
. radiation induced cancers per person rem) than that of other studies, 'f .so what should we do? Should we continue to base our standards on [ ' t , the data from the survivors of the atomic bombings of Hiroshima and !
Nagasaki or on'the cancer incidence of ankylosing spondylitis patients I treated with x-rays when as shown in the following.they seriously l underestimate the cancer risk? Man is not an inbred, caged animal; I
, he is a dukes mixture of almost everything one can imagine. This [
is the kind of human study we so badly need and what the Hanford study l 1
'was except for one exception-th'c " healthy worker snydrome." This ; -is a healthy group (several cuts above the average) and one that is *
{ under the best of medical care. Maybe when we und.erstand better the
}
t healthy worker syndrome we can explain why workers with 5 rem or . !f s more of recorded dose had an increase in longevity of 10 years. l'-
, Maybe this is why the workers had a high incidence of myelomas and
! a low incidence of leukemias?
i l
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l i I believe it is the heterogeneity of a human population that .
'causes' a higher incidence of mal'ignancies per rem at low doses than at high doses in so many studies (i.e. E = cD" in which n < 1 and [
6 of ten n = ,1[2) . Studies of Bross seem to confirm the existence l of subgroups in the population that are more susceptible to. radiation induced malignancas'and the-influence of cocarcinogenistic dB f synergistic factoro. For example he found a very large increase in f cancer risk (i.e. by 5000%) for children who received in utero-x-ray ;
. exposure and later. developed certain respiratory, diseases. .
7. Damage to the iemune surveillance system er man's reticuloendothelial [
system by ionizing radiation probably is an important reason why his dose
~
[ M response in so many cases follows the relation E = cD . Normally this I immune system holds in check all sources of foreign protein including i small colonies or clones of cancers in situ (cancers before they can f be chemically recognized). However, radiation damages the ability' of ; these scavanger cells to recognize virus and, bacteria as well as qs cancers in situ so as shown by Fig. 5 there is a large increase in *!
~
ron-cancer deaths per rem and a low increase in cancers per rem for f i those exposed to high radiation doses and a low increase in non-cancer deaths per rem and a high increase in cancers per rem for those exposed f to low radiation doses. . This, of course, is because of the short incuba- - tion period of many of the common disease's such as pneumonia which i develop fast when a large fraction of the immune surveillence: cells have been damaged or destroyed by, high radiation doses. TI,ie weak persons who are most likely targets for death by cancer are taken
. . i early by a disease like pneumonia before they'have time to die of ;
t cancer. Tnis undoubtably is one reason why the data on the survivors '
~
i of th'c bombings of Hiroshima and Nagasaki fend to s6pp6rt the relation ! l l l E = cD and why at the same time they underestimate.the risk of cancer l viz. nost of the cases under study received intermediate to high doses. l I have long been and ' continue to be a strong supporter of the studies of the survivors of the bonbings of Hiroshima and Nagasaki ' < t (i.e. while I was director of the Health Physics Divisign of ORNL i vc were in charge of the dosimetry for this study). I consider it 9 . i
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~/A;d. aaL I unfortunate, however, that this d,ata .is' being misused by ICRP, NCRP, .
UNSCEAR, BEIR-I & II and other standard setting bodies. They ignore completely the factors 1-7 discussed above. The ABCC data identified the radiation induced cancers as A in Fig. 6 (i e. the difference in
- cancers per rem among the blast and fire victims and the low exposure group as controls). Idsally they' should have identified C (i.e. the ;
difference in cancers per rem among. the blast and fire victims and blast and fire victims that received no. exposure as controls). Practi ' i cally, at best an effort should be made to correct for fire, blast and other traumatic influences of death, sickness, disease, hunger, etc. 9
'Kneale and Stewart have shown that a year or more before cancers dev-eloped .to the point of clinical recognition among the children in the ABCC study they were showing signs of being abnormally sensitive to infection and Kneale has shown that the terminal phase of preleukemia is associated with a high risk of dying of pneumonia. However, long before this and in the early period after the events associated with '
the bomb explosion it would be the weaker and those more prone to develop cancer later on that succumbed to death from the radiation syndrome. Thus the stronger and less cancer prone survivors became the population upon whom cancer risk to a normal population is being
. judged by the. standards setting agencies. Rotblat 11 based the cancer ,
risk on B in Fig. 6 (i.e. the difference in cancer incidence per rem among early entrants into Hiroshima who were exposed to fallout and neutron induced activity and late entrants who received essentially no radiation exposure. Neither of these groups was subjected to fire, blast and trauma that existed shortly after the blast. He found a
, leukemia risk of 1.6'x 10-4 leukemias per person rem which is 8 times .
that commonly assigned to the Hiroshima survivors of the atomic bomb-ing and is more in line with values found in other population exposure , groups mentioned above. The other human population that is extensively used or rather mis-used by these standards setting bodies in determining the cancer risk" coefficient is the group of ankylosing spondylitis (AS) patients that is. treated with large local doses of x-rays to the spine. As shown in Fig. 7 - the incidence of cancer per rem (A) in this AS group was
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s. REFERENCES-
1. Russell, W.L., " Studies in Mammalian Radiation Genetics," Nucleonics,
. . 23, 53, (Jan.196.5) . . . 2. Lyon, Mary.F., D.G. Papworth and R.J.S. Phillips, " Dose-Rate and .
Mutation Frequencey after Irradiation of House Spozmatogonia," . Nature New Biology 238,101 (July 26,1972) . .
3. Internhtional Commission on Radiological Protection, working paper ICRP/71/L:C-4 (1971)

4. Steward, Alice M. and G.W. Kneale, " Radiation Dose Effects in- '
Relation to Obstetric X-rays and Childhood Cancer," Lancet 1185 (June 5, .197.0)
~
5. Mancuso, T.Y., Alice M. Steward and G.W. Kneale,'" Radiation Exposure ~
' of Hanford Workers Dying from Cancer and Other Causes," Health Physics, 33, 5, 369 (Nov. 5, 1977) -
Bro'ss, I.D.J., " Leukemia fro:a Low Level RadiatI.on," New England 6. Journal of Medicine 287 (July 20,1972)
7. Mondan, B., D. Baidatz,-H. Mart, R. Steinitz and C.L. Sheldon, .
" Radiation Induced Head and Neck Tumors ;" Lancet 1,, 7852 (1974)
8. Warren, Shields and C.' Gates, "The Inclusion of Leukectia and Life
. Shortening of! Mice in Contiinuous Low-Level External Canna Radiation,"
Radiation Research 47,;480 ,(August 1971) ,',
9. Kneale, G.W. and' A.M. Stewart, " Pre-Cancer and Liability to Other -
. Diseases," British J. of Cancer, in print. ~
10. .Kneale, G.W., "The Excess Se'sitivity of Pre-Leukemics to Pneumonia:
~
n A Fodel Situation for Studying the Interaction of an Infectious . Disease with Cancei ," British J. of Preventivs and Social Medicine 25 , 152-(1971).
~ ~
11. Rotblat, J., "The Puzzel of Absent Effects," New Scientist 476 (August 1977) eQ*
15 l
I c> - . ;m 3- Sonderdruck R6ntoen-BlEtter 6 Klinik und Praxis 4 Schnfileitung: Prof. Dr. Werner Teschendorf, Kuln l 27. Jahrgang Stuttgart, im M3rz 1974 Ileft 3 i Rontgen-Bl. 27 (1974)127 146 O Georg Thieme Verlag Stuttgart M5gliche Folgen einer uberm5Eigen medizinischen Strahlen-belastung in den Vereinigten Staaten von Amerika
K.Z. Morgan I
i i t O e i
'L - - . - - . _
L- _ - _ - _ _ _ _ _ _ _ - - _ _ _ _ - _ _ _ _ _ _ - - _ - _ _ _ - _ _ _ _ _ _ _ _ _
i -e f r
. 127 i r
. - t i R6ntgen-Bl. 27 (1974)127 146
O Georg Thieme Verlag Stuttgart M61iche 9 Folgen einer Oberm58igen medizinischen Strahlen- !
belastung in en Vereinigten Staaten von Amerika
f r
? , { , K.Z. Morgan l i
Zusammenfassung Summary Die Anwendung ionisierender Strahlen in der l The use of .onising rays in medicine provides the ! Medizin stellt heute den gr66 ten Anteil der Expo. greatest portion of exposure today to sources of i
sition durch kunstliche Strahlenquellen sowohl artificial rays both for the individual and for the ;
Tur den einzelnen Als auch die gesamte Bev61ke- total population. In addition, it has been known
. rung. Es ist zudem seit langem bekannt, da6 auch i for a long time that esen the radiation doses die Strahlendosen biologische Wirkungen hervor- !
necessary to obtain a picture satisr actory for rufen k6nnen, die in der R6ntgendiagnostik erfor- [ i assessment purposes can also produce biological ; derlich sind, um ein ausreichend zu beurteilendes effects. The results of research in recent times ; 3 Bild zu erzeugen. Forschungwrgebnisse in neuerer
~
have aho shown that leucaemias and tumours Zeit haben auserdem gezeigt, dan auch nach l induced by the radiation appear after investiga- t 4 Untersuchungen,bei denen der F6tus im Mutter-tions in u hich the fetus has been exposed to ad- I
~ {i leib einer zusstrbchen Strahlung augewtzt wird, ditionalradiation within the womb. !
durch Strahlen induzierte Leukamien und Tumo- For this reason the usefulness of such examina-ren auftseten.
tions mr .t be set against the risks associated with '
i Injedem Falle ist deshalb der Nutzen, den solche them in each case. ] Untersuchungen bringest, dem damit serbundenen Risio gegenbbertustellen. In the United States of America attempts are ! being made to protect patients from unnecessary In den Vereinigten Staaten von Amerika gibt es radiological examinations. The measures needed : Bestrebungt:i, Patienten vor unn6tigen R6ntgen- for this purpose are discussed in detail and sug-untersuchury n zu bewahren. Die hierzu erforder-gestions given for keepirg the exposure to radia- ; lichen Ma6nahc,en werden im einzelnen bespro-
- tion as small as possible for the individual, in spite '
i chen und Anre; men gegeben, trotz der standig of the constantly increasing number of examina-i zunehmenden Zahi uer Untersuchungen die Strah- tions. lenexposition fur den einzelnen so gering wie m63 - .} g a lich zu halten. i f < 4 , I. Medi:inische Strahlenbelastung i Einleitend m5chte ich betonen, dab es keinesfalls meine Absicht ist, den Wert der R6nt. i genstrahlen in Diagnostik und Therapie in Zweifel zu ziehen, went. sie indiziert sind und ,
' fachgerecht angewendet werden. Ich glaube, dab R6ntgenstrahlen und andere ionisierende t
Strahlen zu einigen der bedeutendsten Ililfsmittel der modernen Medizin geworden sind, ! dab sie jedoch, wie viele h5chst nutzliche oder wichtige Dinge in unserer nodernen Ge-4 sellschaft (z.B. Sex, Autos, Drogen und Atomenergie)infolge Unwissen!' cit, Nachlussig- ; - keit, Sorglosigkeit sowie Fehlen einer ausreichenden Ausbildung und der richtigen Moti-1 vierung huufig miBbr5uchlich neewandt werden. i ( in den Vereinigten Staaten und einigen anderen hochentwickelten Uindern stammen etwa i { 90% der gesamten Einwirkungen kunstlich erzeugter ionisierender Straldung aus medizini-
?
Vorgetragen auf der 7. Jahrestagurig des Fachverbandes fnr Strahlenschutz e.V. am 21. Murz 1973 in Bern/Schweiz, s a, e
s l 3-1 4 4
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128 k.4 st rpa scher Diagnostik und Therapie. Tabelle 1 zeigt, dab der n5chstgroSte Anteil dem Fallout
, ' on Kernwaffen (ca. SM zuzuschreiben ist, und dab in den Vereinigten Staaten der An-l teil durch die Kernenergie, die so siel Auseinandersetzungen verursacht hat, nur etwa j 0,004% betr5gt. In Tabelle '2 sind einige der wichtigsten durch medizinische Anwend mg i son R6ntgenstrahlen und Radiopharmaka verursachten mittleren Jahresdosen pro Person i zusammengestellt, wie sie von dem Bureau of Radiological liealth bei einer Erhebung im 1
Jahre 1964 ermittelt wurden. Endgultige Angaben und SchluBfolgerungen aus der vom effentlichen Gesundheitsdienst der Vereinigten Staaten im Jahre 1970 durchgefuhrten i
' I medizinischen Erhebung (3) wurden noch nicht ver6ffentlicht. Die Anzahl der j5hrlichen R6ntgenuntersuchungen nalun jedoch im Sechsjahreszeitraum von 1964 bis 1970 folgen-dermaBen zu: R6ntgenaufnahmen von 105 Stillionen aef 129,5 51illionen, Zahnaufnah-men von 53,6 51illionen auf 67,5 h!illionen, Durchleuchtungen von 10,5 Atillionen auf 1;,7 51illionen, das bedeutet eine Gesamtzunalune der Anwendung diagnostischer Verfah-ren von 24%. Diese gewaltige Zunahme der Zahl der R6ntgenuntersuchungen in den Ver-einigten Staaten, die mit einer Steigerung der Kosten verbunden ist, erscheint in einer i Zeit, in der in vieler Ilinsicht eine Verschlechterung der Qualitut der medizinischen Lei-I
, stungen eingetreten ist, schwer vertretbar zu sein (Tabelle 1). I Tabelle 3 zeigt, daS die genetisch-signifikante Dosis der Bev61kerung der USA betriichtlich j uber derjenigen in vielen anderen hochentwickelten L5ndern liegt. Warum diese Dosis in i den Vereinigten Staaten sehr viel h6her ist als beispielsweise in England, ist nicht bekannt. I Sicherlich sind an der st5rkeren Exposition in den USA folgende Ursachen beteiligt:
! 1. Die Angewohnheit vieler Xrzte und Kliniker, automatisch R6ntgenaufnahmen anzuord-nen.
2. Die grosz 0gige Kostennbernahme durch Krankenkassen und die Gesundheitsfiirsorge-
, programme.
3. Die Tatsache, daS sich die amerikanischen Xrzte wenig darum kummern, die Patienten-exposition so gering wie m6glich zu halten.

4. Unzureichende Ausbildung und Fehlen einer P:sfung von Xrzten und medizinischem lhlfspersonal, die der amerikanischen Bes61kerung R6ntgenstrahlen verordnen und verab-reichen.
Tabelle 4 gibt einen AufthluS darnber, warum die Strahlenbelastung durch die medizini-i sche Diagnostik in den USA uberm3Sig hoch ist. Es ist schwierig, eine stichhaltige Erkli-rung dafiir zu finden, warum die Oberfl5chendosis bei einer Lungenaufnahme sowohl l 10 mrem als auch 2000 mrem betragen kann. Wenn die Xrzteschaft behaupten k6nnte, ' mit 2000 mrem erhielte man mehr oder bessere Informationen, wure das wenigstens eine schwache RechtfertigunE. Aber das Gegenteil ist der Fall. Fast ohne Ausnahme ergeben i h6here Expositionen weniger brauchbare und detaillierte Informationen; mit anderen Wor-l ten, die Bildqualitut wird schlechter. Dasselbe gilt fiir Zahnaufnahmen. Fragt einmal ein aufgeklurter Patient den Arzt, ob eine weitere R6ntgenaufnahme tatsuchlich notwendig ist oder warum eine kurzlich in einem nahegelegenen Krankenhaus aufgenommene Filmserie nicht genutzt wird, erhult er vom Arzt, der den Anschein erwecken m6chte, stets recht zu haben, eine ablehnende Antwort. Oftmals fuhlt sich der Arzt durch die AnmaSung eines 1 Patienten, der es wagt, sein Urteilsverm6 gen und sein Wissen in Frage zu stellen, sogar be- 1 leidigt. Diese IIaltung ist besonderr bei den Xrzten oder Zahn5rzten ausgepr5gt, die nber l keinerlei Kenntnisse aus dem Gebiet des Strahlenschutzes und der Strahlenbiologie ver- 1 fligen. I 4 h .. .
. . , , , . . . . i -
. I \tqhAc I el inf sine r sAim.4 :gt n medismmhen Sirablenbelastung 129 Tab. I Abshatrungen der phrbshen Ganikorperdm dursh Strahlencinwirkung aus kunsthchen Quellen in den Wremigten Staaten (1970) (1) l
Duithwhmtththe Prozent Quelle Dosistentung (mrem /Jahr) 4 5.01 Radioaktiver Fallout 0,004 Kernenergie 0,003
Medizinische Diagnostik 72t 91,48 Radiopharmaka 1i 73 0,8 I,00 Berufhche Strahlenexpoution 2,51 Verwhiedene Ursachen 2 79,803 100.000 Tab. 2 Geschatzte mittlere Jahresdosen pro Ptrx>n der Gesamtbevolkerung der USA Art der Expostion Mittlere Jahredosis pro Person der Geumtbev6ikerung der USA (mrem)
R6ntgenJiagnostik 1954: Genetach4:gnifikante Dous 54,6 Conadendosis 83 Knochenmarkdous 59 Schikid:bsendosis durch: Untersuchungen des Kopfes und llalses 6,9 Untersuchungen des Brustkorbs 19 44 Untersuchungen der /.ahne 18 i Diagnostiuhe Anwendungen von Radiopharmata 1966: Schilddrssendosis durch: ' Schilddrusenfunktmnstest mit 131J 101 Schilddrssenuintigraphic mit 131J 101 Andere Untersushungen mit 131J 2,7 f Gehirnszintrgramme mit 99mTc 1,2 '$ Schilddrasenuintigramme mit 125J 0,7 [' Andere Verfahren 3 l . + Gonadendosen durch alle Radionuklide I
~
bei Funktionstesten und Szintigraphien ~ 1,0
- Ganzkbrperdosen durch alle Radionukhde bei Funktionstesten und Szintigraphien ~ 1,0 Knochenmaskdosis durch alle Radionukhde bei Funktionstesten und Szmtigraphien ~ 0,5 Genetisch-sigmfikante Dosis durch:
R6ntgendiagnostik in der Medizin und Zahnhetliunde (1964) 55 Strahlentherapie mit R6ntgenstrahlen (1966) $ , Strahlentherapie mit Radiopharmaka (1966) 0,6 61 Diagnostiwhe Anwendung der Radiopharmaka (1966) 0,26I Schilddru endosis durch: R6ntgendiagnostik an Kopf und lials (1964) 6,9 I an Brustkonb und norax (1964) 19 269 R6ntgendiagnostik in der Zahnhedkunde (1964) 18 Diagnostische Anwendungen von Radiopharmaka (1966) 225 I I f Anmerkung: Die obigen Werte sind aus den Berichten Eber die Erhebung des USPilS (2) von K.2. Morgan i rusammengefaSt. b
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E i 130 K.7, .mrpn
Tab. 3 Jahalkhe genetiwh 'irnifikante Dosis der Besoikerung durch meduinische Strahlencsposition**
l l Besolierung von: Genethcisigndi. Besolkerung von: Genetiwh-signifi-L I ka'nt.: Dosts kante Dosis in mremla in mrcm/a Buenos Aires, Argentinien 37+ Norw egen 10+ Finnland 16,8 ++ Schs eden (1955) 38'+ Dsnemark (1956) 22' Schw eiz 22+ Deutschland (Bayern) 13,70++ Alexandria, V.A.R. 7+ g Frankreich 58+ Jugoslawien (Slowenien) 9,13 + + Rom, Italien 43+ Kairo V.A.R. 7+ Japan (1960) 26,5 + + Gro6britannie n (Sheffield) 8,6++
, Niederlande 20,0 ++ Gro6britannien (1957) 14*+ } Neuseeland (1969) I t ,69++ Vereinigte Staaten (1964) 54,6* (35,5) 4.
i
Werte aus "Besb!kerur gsdosis durch Rontgenstrahlen. USA.1964" US Public licalth Serviec Verbffenthchung No. 2001. Okt. I969 (Brown u.a.)(4)
A Wert in Klammern ist eine Schatzung bei der Erhebung des USPilS (1970) i3)
+ Werte aus dem UNSCEAR-Bericht, Suppl No.16-A/5216 (1962)(5) ++ Werte aus dem UNSCEAR-Bericht, Suppl No. 25-A/8725 (1972)(6) ** Es wird geschhtzt, da6 die signifikante Organdosis fur die meisten Organe das zwei- bis dreifache der genetisch-signifikanten Dosis bet:3gt (5,7. 8)
Tab. 4 Obliche Eintrittsdosen (in mrcm) bei Runtgenaufnahmen in den USA t Bereich der Werte
. Durchschnittswert
[ Lungenaufnahme in Oak Ridge Nat. Lab. (1972) 10 - 20 15 Lungenaufnahme in den USA 10 - 300 45' Lungenschirmbildaufnahme 200 - 2000 504' Zahnstatus in den USA 1000 - 100 000 20 000* Abdomenaufnahme, ausgefnhrt von Radiologen 636' Abdomenaufnahme, ausgefiihrt von Nichtradiologen 1253* Diese Durchschnittswerte werden einem Bericht " Population Exposure to X-rays, U.S.1964" von J.N. Girlin und P.S. Lrwrence, llEW-PilS 1964 (2) entnommen. l - K0rzlich suchte ich einen neuen Zahnarzt auf und fragte ihn nach der Empfindlichkeit des von ihm verwendeten Filmes. Aus seiner Antwort entnalun ich, das er nicht verstand, wovon ich sprach. Ich fragte ihn, warum er nicht, wie von der Amerikanischen Zahnutzte-vereinigung empfohlen, den langen offenen Tubus sowie auSerdem eine rechteckige Vor-derblende im Tubus verwende. Ich erhielt die unglaublich dumrne Antwort, dies sei nicht notwendig, weil die von seinem Ger5t abgegebene R6ntgenstrahlendosis geringer sei als die, die man bei einer kurzen Sonnenbestrahlung im Freien erhielte. (Wahrscheinlich wuSte er nicht, dab UV-Strahlung nicht gleich R6ntgenstrahlung ist.)
# In diesem Zusammenhang scheint die Frage angebracht, warum sich so viele Zahnurzte in den USA nicht an die Empfehlungen der Amerikanischen Zahn5rztevereinigung halten (9): "Radiologische Untersuchungen sollten nicht automatisch bei jeder routinem5Bigen zahn5tztlichen Kontrolle durchgefilhrt werden."
Eine uhnliche Frage muSte Xrzten, Amts5rzten des 6ffentlichen Gesundheitsdienstes und Trugern 6ffentlicher Gesundheitsprogramme gestellt werden. Warum warteten sie bis 1972, j ehe sie die im Jahre 1965 ausgesprochene Erk!5nmg des Public licalth Service der USA l l 1
- + - - _ - . - . - . . . - . - _
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'[ ' " -U - - . _. _ _ _ _ _ _ _-__m _ _ _ __ _ -_ _ - - - -
Stag!nhe Folycn ciner sbermetgen nudizinhchen Strahlenbelastung 131 beachteten 00): "Rontgenreihenuntersuchungen des Brustraumes sollten nicht an allen Besolkerungsgruppen vorgenommen werden, sondern sich nur auf die Gruppen innerhalb von Gemeinden beschr5nken, bei denen eine hohe Tuberkuloschhufigkeit bekannt ist." Befolgt wurde diese Erk15 rung ers't 1972, nachdem die " National Tuberculosis and Respiratory Disease Association" festgestellt hatte (!1): "R6ntgenreihenuntersuchungen bei allgemeinen Bev61kerungsgruppen mit mobilen R6ntgeneinheiten sind zum Nachweis von Lungenerkrankungen nicht effektiv und sollten eingestellt werden. Gesellschaften for Tuberkulose und Krankheiten der Atmungsorgane sollten R6ntgenreihenuntersuchungsver-fahren des Brustkorbes nicht mehr routinemSBig durchfuhren."
2. Fdgen medi:inischer Strahlenexposition Sch5digungen durch R6ntgenstrahlen sind nichts Neues. So beobachtete Crubbe (12), ein liersteller Crooks'scher Rdntgenr6hren in Chicago, cine bis zur Ulieration fuhrende Sch5di-gung des linken llandruckens als Folge einer im Januar 1896 erhaltenen R6ntgenexposi-tion. Wegen der starken Schmerzen suchte er bereits am 26. Januar 1896, also fast genau
+
3 Wochen nach R6ntgens erster 6ffentlicher Bekanntgabe seiner Entdeckung der X Strah-len, am 4. Januar einen Arzt auf. Seit dieser Zeit ist es durch die Anwendung dieser gro6-artigen Entdeckung zu vielfaltigen Strahlensch5digungen gekommen. Erst seit kurzem ist man jedoch in der Lage, eine Beziehung zwischen einigen der Sp5tfolgen, wie z.B. vielen Formen von Krebs, teratogenen (MiEgeburten, Mi6bildungen), embryologischen, f6talen und genetischen Sch5digungen und einer Strahlenexposition, die Jahrzehnte, ja sogar Gene-rationen vor ihrem Manifestwerden erfolgte, aufzudecken. Obwohl man gewisse Zweifel an der Richtigkeit einiger Ver6ffentlichungen haben kann, die auf eine Zunahme der mis-
' bildungen bei Kindern hinzudeuten scheinen, wenn es zu einer Strahlenexposition vor der L Empf:ingnis gekommen war, steht es auSer Frage, dab eine Bestrahlung des befruchteten '
Eics und des menschlichen F6tus zu serschiedenen Arten von Mi6bildungen und sonstigen teratogenen Wirkungen rdhren kann. Der menschliche F6tus ist w5luend des ersten Schwan-gerschaftsdrittels gegen ionisierende Strahlung am empfindlichsten. Mit einer gewissen Sicherheit kann man jedoch davon ausgehen, da6 die Leibesfrucht in allen Stadien der Schwangerschaft st5rker strahlenempfindlich ist, als der Mensch in allen anderen Entwick-lungsstadien, Rugbh(13)stellt fest: "Wenn das menschliche Becken zwischen dem 10 und
42. Tag (der Schwangerschaft) bestrahlt wird, k6nnte man erwarten,eine MiBbildung zu
)
entdecken, wenn die Dosis mehr als 25 R betragen hat" und "es ist am besten, befruchtete menschliche Eizellen, Embryos oder F6 ten keiner unn6tigen ionisierenden Strahlung auszu-setzen, solange nicht betr5chtlich mehr gesichertes Beweismaterial vorliegt." Wachstumsverz6gerungen (14) scheinen nach den Beobachtungen an Oberlebenden der d Atombombenabwiirre in 111roshima und Nagasaki einer der vorherrschenden Folgen der Strahlenexposition von Foten und Kleinkindern zu sein. Mehrere Beobachter berichten auch Ober ein vermehrtes Auftreten von Mongolismus nach R6ntgenbestrahlung. Nach Ucbhida und Chrtis (15) fnhrt wahrscheinlich "Verklebung oder Non-distunction von Chromosomen w5hrend der meiotischen Zellteilung zu Oberz5hligen Chromosomen (z.B. triploiden Formen) in jeder somatischen K6rperzelle des Mongoloiden." Diese Autoren zogen aus ihrer Untersuchung an 81 mongoloiden Kindern den SchluS, dab ihre Daten "sehr stark auf einen Zusammenhang zwischen dem Auftreten von Mongolismus und einer Strahlenbelastung des mUtterlichen Abdomens hindeuten." Wohlgemerkt, bei diesen Fal-
len betrug die Dosis nur einige Rad.
I t i .. _. . _ _ _ _ - - . . . _ _ . - - k . e e
132 K.4 \tmpn
t 1 ' j i 12l
{ 4 fto' .- j oc __ _ _ --
/
o3 _ .__ _ . _. _g j 0'
-I Abb.1 Anzahl der R6ntgenfilme for dugno-8 j02-- ) sthche Stafinahmen ushrend der Schwanger-k !
o. _ _ _ _ _ _ _ _ ___
_ . _j shaft (nach Abec Stewart und G.W. Kneale, o i 2 3 & s s Lancet, Juni 1970) Eine der beunruhigendsten Beobachtungen war in den letzten 10 Jahren das starke Auf. ~ i treten son Leuk 5mie (und anderer Krebsformen, besonders Tumoren des sentralen Nersen-
; systems) bei Kindern, deren Mutter wahrend der Schwangerschaft mit R6ntgenstrahlen untersucht worden waren.
{ Es gibt viele Untersuchungen bber die Auswirkungen der Pelvimetrie; die meisten weisen auf ein geh5uftes Auftreten maligner Erkrankungen bei Kindern hin, die in Utero bestrahlt
, worden waren. Eine sehr sorgfaltige stammt von MacNahon. Er besichtet, da6 nach den ! ersten Untersuchungen von ,tlice Stewart im Jahre 1953 etwa 12 weitere Arbeiten uber i die Beziehungen zwischen Pehimetrie und anderen Straldenexpositionen in Utero und l Krebs bei Kindern seroffentlicht wurden. Er kam zu dem SchluS, daS, obwohl es positive ! und negative Ergebnisse gab, eine Ber0cksichtigung aller Ergebnisse, bewertet nach der Zahl der untersuchten F511e, darauf hindeutet, das die Sterblichkeit an Leuk 5mie und an anderen Krebsarten bei Kindern, die in Utero durch Runtgendiagnostik exponiert wurden, um 40% h6her liegt als bei nicht exponierten Kindern. Er gibt an, da6 w5hrend der ersten . zehn Lebensjahre das Risiko derartig exponierter Kinder, an Krebs zu sterben, bei 1 :2000 liegt. Wenn also alle Frauen w5hrend ihrer Schwangerschaft im Jalue 1973 eine Pelvimetrie erhielten, wiirde das etwa 2000 Todesflille pro Jahr in den Vereinigten Staaten bedeuten.
Diese Zahl ist gering, jedoch nicht so gering, wenn zufallig das eigene Kind eine Zahl in
. dieser Statistik darstellt. Die Untersuchungen von Stewart und Kncale (1970)(17) nber
{ die Wirkungen einer diagnostischen R6ntgenexposition bei Kindern ist besonders eindrucks-j soll. In Abb. I sind einige ihrer Ergebnisse aufgetragen. Sie st0tzen sehr stark die Annalune
) einer linearen Beziehung zwischen Dosis und Wirkung bis hinunter zu wenigstens I rem, j
sielleicht sogar bis 0,25 rem. In neuerer Zeit haben einige Autoren Taylor (1972)(18) l betont, das diese Angaben aus Oxford nicht mit denen vonlablon u.a. (19) Obereinzu-
! stimmen scheinen. Diese haben Untersuchungen Ober die Wirkungen der Bestrahlung bei Kindern, die als F6 ten die Atombombenabwurfe in lliroshima und Nagasaki uberlebten, j gemacht. Eine genauere Analyse beider Untersuchungsergebnisse deutet jedoch darauf hin, i daS es keine Widersproche gibt. Offensichtlich stinunen die Daten aus Oxford und aus i Japan vollkommen mit dem Gberein, was zu erwarten ist. Erstens sollte daran ednnert werden, daS nur Kinder, die 51ter als 2 Jahre sind, ein hohes Risiko einer Krebserkrankung im Jugendatter aufweisen, und da6 es eine hohe S5uglingssterblichkeit unter den in Uteru bestrahlten Kindern (43%) und eine sehr hohe Fehlgeburtenrate gab (Miller 1969) (20).
i So kam es bei vielen Kindern, die in Utero eine Strahlensch5digung erhielten, zu einem Abort oder sie Uberlebten die Zweijahresgrenze nicht, nach der sie an einer malignen Er.
krankung h.itten sterben k6nnen. Das heist, viele Kinder, die nach dem zweiten Lebens.
jahr an einer malignen Erkrankung gestorben wuren, aber in Utero groSe Strahlensch5di- , gungen erlitten hatten, Oberlebten diese Zeitspanne nicht. l l , l 1
.- - _ . _ 1 - , 1 e
L_ _
I i l l Wglalie li4 n cines uh rma6ign mufitiniwhen StrahlenbcIntung 13.1 Zweitens geht aus sicien Untersuchungen (Iknnet 1970)(21) hersor, da6 wshrend ei.'er allgemeinen Katastrophe Kleinkinder und alte Leute am haufigsten erkranken und deshalb aus sersshiedenen GrUnden, einschlic61ich Krebs, sterben. Es ist bekannt, dab in solchen Zeiten beginnende Krebserkrankungen h5ufig als akute Infektionen fehldiagnostiziert werden. Eine weitere M6glichkeit (sielleicht jedoch eine unwahrscheinliche) besteht darin, da6 Neutronen einen Teil der Strahlenbelastung bei den japanischen Oberlebenden der Atom-g -; bombenabwurfe verursachten, und dab sie frUhe Todesfalle durch andere Ursachen als maligne Erkrankungen begUnstigt haben. Es k6nnte auch sehr wohl sein, da6 et betrucht-liche Artunterschiede zwischen diesen beiden Populationen gibt. Solche deutlichen Art-unterschiede wurden z.B. bei Tieruntersuchungen festgestellt, die von Ivarren und Cates (22) und vielen anderen durchgeruhrt wurden. a, g g,'y nswo nums nam
*5a i .s g 70 . . .
g 60 - J 50 E t.0 - Abb. 2 Prozentuale llaufigkeit vor, Sarko- $ 30 men und Karzinemen dargestellt Gber den 3 y Medianwert der Gesamtskelettdosis in rad s 20 - r in bncuen Koordmaten (nach R.E. Rowland et al., ANL-7760, f 10 d 3 { e 00 -* 4-Teil II, Argonne National l_aboratory, Ar- Oi -" 50'00 000 10 %000 20.000"25.c00 gonne,111 (Juli 1969 - Juni 19700 (23) Gesamicosis ( red) Am wichtigsten ist m6glicherweise die Tatsache, da6 die Daten von Jablon sich auf 33 japanische Kinder beziehen, die eine Strahlenbelastung in utero von mehr als 300 rad er-halten hatten. Man muS sich fragen, ob die Daten son Stewart auf diese Bev61kerungs-gruppe Uberhaupt angewendet werden sollten, weil diese Dosen so hoch waren, da6 sie wahrscheinlich an das 5uSere Ende der Parabel Uber die ll5ufigkeit von Ixuk5 mien fallen, j 5hnlich wie es bei den in Abb. 2 dargestellten Kurven von Rowland (23) fiir Sarkome und Karzinome der Fall ist.Mrinelli(24) und viele andere Forscher haben in ihren Ver6ffent-lichungen darauf hingewiesen, da6 sich die Linearit5t dieser Kurven nicht bis in hohe Dosis-bereiche fortsetzt, obwohl es eine lineare Beziehung zwischen der Dosis und den Wirkun-gen auf Tiere bei niedrigen Dosen geben kann. Man kann nicht mehr als 100% der Tiere durch Bestrahlung 16 ten. Bei den h6heren Strahlenpegeln (z.B. denjenigen, die die Kinder
; erhielten, die Einzeitdosen von mehr als 300 rad in Iliroshima und Nagasaki bberlebten) . k6nnen siele der bestrahlten Personen, noch bevor sie an Krebs zugrunde gehen, an ande-ren Ursachen sterben.
Stewart hat auch die Vermutung ge5u6ert, dab die Kontrollgruppe der Oberlebenden der Bombenabwiirre in Iliroshima und Nagasaki wahrscheinlich ein h6heres Krebsrisiko auf-wies als eine normale Population, was wiederum dazu anregen wurde, jede beobachtete Strahlenwirkung zu serkleinern. Schlie61ich wurde noch vorgqbracht, da6 Stewart vic!!eicht mit einem selu niedrigen Wert fiir die durchschnittliche Fetaldosis durch Beckenmessungen
, in Gro6britannien gerechnet hat. Wenn man diese Korrektur vornimmt und den niedrigsten bei der Untersuchungsreihe in Oxford von Stewart gefundenen Koeffizienten verwendet und eine Korrektur von 0,5 an den Werten vonlablon vornimmt, um die Dosis am Fetus i i +
s e m i e p- +
j 134 . K.Z. Storpn et aus der llautdosis zu erhalten, wiirde man erwarten, da6 man bei der japan
, die in utero mit 40 bis 299 rad bestrahlt wurde, zwei Krebsfalle findet. Tats 5chlich nur einer festgestellt. Keine KrebsGile w5ren in der Gruppe zu erwarten, die zwischen 0 und 39 rad in utero erhalten hatte. Da die Strahlenbelastung rur die Gruppe, die m 300 rad erhielt, wahrscheinlich am nuSeren Ende der Parabel liegt (vgl. Abb. 2) ebenfalls keine Krebsf511e mehr zu erwarten, und es wurden auch keine b sichts der Unsicherheit bei den Da'en und der kleinen Zahl der wnhre wurfe in utero bestrahlten Kinder scheint es tatsschlich eine gute Obereinstim l schen der Zald der Krebsfalle, die bei den in Japan in utero bestrahlten Kindern beo tetgeben.
zu wurden und den Kindern in der Oxford-Studie, die diagnostisch exponiert wurden Aus dieser Diskussion scheint hervorzugehen, dab es mehr als nur eine Annahme i - eine lineare Beziehung zwischen der Knochenmarksdosis und der Leuk 5mich5uf selbst bis zu einer so niedrigen Dosis wie I rem oder weniger bestehen kann. Xhnliche 3 Beweise werden vielleicht zu gegebener Zeit fdr anderc Krebsarten zur Verfdgu
//emplemann (1968) (25) z.B. schlo6 aus seinen umfangreichen Untersuchungen, auf zu 20einen weiten rad) erstreckten: Dosisbereich in menschlichen Schilddrnsen (von 120 "1. Die Beziehung zwischen Dosis und dem Auftreten von Schilddrusentumoren ist in niedrigen Dosisbereichen linear,
2. es gibt keinen Schwellenwert oder er liegt zumindest unter 20 rad."
Die BEIR-Kommission (1972)(1)hebt hervor, dab das Risiko,'durch Strahlen Krebs zu erzeugen, fdr jnngere Personen in der Bev61kerung gr6Ser zu sein sch ~ ( weist darauf hin, dab die von Saenger u.a. (1968) (26) getroffene Feststellung, e
! kein erh6htes Risiko eines Schilddrosenkrebses durch Applikation von Jod 1 durch gerechtfertigt ist, da6 sie keine eindeutige Zunalune von Schilddrusenkn . n j bei Patienten mit flyperthyreose fanden, die mit Jod 131 behandelt wurdm.
es zumindest zwei Grunde: f; 1. war ihr Beobachtungszeitraum zu kurz und -
2. w0rden sie bei diesen hohen Dosen am HuBeren Ende der Parabelliegen, wie l reits far Leuk 5mie geschildert und Idr Knochentumore in Abb. 2 dargestellt wurde.
j AuSerdem haben einige Autoren Criffiths und Ballantine (1973) (27) die Objek ser Untersuchungen in Frage gestellt. Angesichts dieser Auseinandersetzungen nber die Wirkungen ionisierender Ausma6 der Sch5digung fdr den Menschen, die Frage, ob die Dosiswirkungs niedrigen Dosen und Dosisleistungen linear ist, ob Strahlenschutznormen ange und inwieweit Mafinahmen zu einer starken Einschr5nkung unnatiger Strahle wiinschenswert sind, hat die National Academy of Science die BEIR Kommis setzt. Sie hat ihr zur Aufgabe gemacht, die Gefahren der ionisierenden Strahlun fleranziehung neuerer biok,gischer Daten unter besonderer Ber0cksichtigun baren Informationen nber die menschliche Strahlenbelastung erneut abzusch5tze Kommission machte darauf aufmerksam, da8 cs vier M6glichkeiten gibt, das ge Risiko auszudrncken: a) Das Risiko im Ver/altnis zur natiirlichen Grundstrahlung Eine kiinstliche Strahlenexposition unterhalb des Pegels der naturlichen Gru ist keine Rechtfertigung fdr ihre Anwendung an sich und 158t auch nicht die Annahm , a
-- M .W'. , MM e
m g
\~ ,, 'a .
R e
l
- l t
lj i sf opbche lila n cins t inbermnign inolainkh.1 Str.,hk nlu t. tung 135 4 das eine derartige Strahlenesposition sernachussigbar oder harmlos ist. "Sie wird zuGtz-i liche Wirkungen benorrufen, die in ihrem Ausma6 geringer und in ihrer Art nicht anders A sind als diejenigen, denen der Mensch wShrend seiner gesamten Geschichte ausgesetzt war a und die er hat ertragen kunnen"(1). , b) Risikoabschit:ungen fiir spe:ifische genetische BcJingungen Aufgrund von Untersuchungen an der Maus und der Drosophila und bis zu einem gewissen l Grad aach von Beobachtungen an menschlichen Populationen "wird geschutzt, dab die I j Dosis zur Verdoppalung der Mutationstate beim Menschen bei Dauerbestrahlungen etwa im Bereich zwischen 20 und 200 rem liegt. Es wurde berechnet, dab die Wirkung son - l 170 mrem /a in der ersten Generation zwischen 100 und 1800 F511e schwerer dominanter oder X-cluomosomengebundener Krankheiten und Sch5digungen pro Jahr hervorrufen wnrde (unter Annalune von 3,6 Millionen Geburten j5hrlich in den USA). Ist ein Gleichgewicht erreicht, das sich nach mehreren Generationen einstellt, wurden diese Zahlen etwa das Fnnffache betragen. Ilinzu k5me eine geringere Anzahl, die durch i Chromosomenaberrationen und rezessive Krankl.eiten verursacht wsre"(1). Es sei hinzu-l gefdgt, da6 die oben erwahnte Zahl von 1800 Mutationen pro Jahr mit einer groben Be-
, rechnung nbereinstimmt, wenn man Daten der ICRP (1966)(28) auf die gesamte Bev61-tl -
kerung der USA anwendet, n5mlich 2x 10 5 l'c#"t rem '""}t Person "t'ti " . x 2 x 10,8 (Personen)
; x 0,170 (@) = 700 Mutationen j in der 1. Generation pro Jahr. ; c) Das Risiko im l'erhultnis zur gegenwurtigen Quote schwerer k6rperlicher SchEdigungen Zu der :T'er (b) aufgefidaten Sch5digungen, die durch Defekte einzelner Gene und Chiomo- ~
somenaberrationen serursacht werden, kommen noch angeborene Mi6bildungen und konstitu-
, , tionelk ":ankheiten, die teilweise genetischen Ursprungs sind. Die Gesamtzahl aller geneti-i schen Mutationen (e' schlie61ich der unter (b) aufgefuhrten) in einer im Gleichgewicht be-findlichen Bev61kerur 3d er USA durch 170 mrem /Jahr wurde zwischen 1100 und 27000 i pro Jahr gesch5tzt. Diese h6here Zahl k6nnte teilweise mit den Schutzungen der ICRP (28) l verglichen werden, das die Gesamtzahl von Mutationen im Gleichgewichtszustand das l
i 40fache der in der ersten Generation auftretenden betragen wnrde, d.h. 40 x 700 = 28000 pro Jahr in einer stabilen Besdikerung der USA, die llunderte von Jahren mit 170 mrem / Jahr belastet wurde. d) Das Risiko, ausgedr5ckt als "allgemein schlechter Gesundheits:ustand"(Orcrallillhealth) Dies wird als das am gnnstigsten faSbare MaB fur die genetische Sch5digung betrachtet, da "schlechter Gesundheitszustand" die oben erwhhnten Kategorien enth51t, sich jedoch nicht auf sie beschrunkt. Es wird geschutzt, das zwischen 5 und 50% von Gesundheitsbeeintr5ch-j tigung der Mutationsrate proportional sind. Auf dieser Grundlage und bei Annahme von -
, 20 rem als Verdoppelungsdosis fiir genetische Mutationen wurden die 170 mrem /Jahr oder 5 rem /30 Jahre genetischen lebens: $ x 100% x(dO) bis d0g = 1,2 bis 12%
des schlechten Gesundheitszustandes einer Bev61kerung verursachen. Es wird angeregt, da6 l i die Normenausschusse mit flilfe von Sch5tzungen nber die finanziellen Kosten fur eine 1,2- 1
; bis 12prozentige Zunalune des schlechten Gesundheitszustandes (einschlieBlich der Krank- l l heiten, k6rperlicher Fehler und Sterbefalle) den Preis ausrechnen, den die Gesellschaft fur l
l t I t i1 1I k_ , ._ - . M 9
' u- - - .
136 NI %;..n 170 mrem /Jahr zahlen muS und ihn gegen den zu erwartend der Bevolkerung.Jahr ist der son der ICRl'(2M und des FRC (3 j , e Grenzwert fur die Belastung interessanterweise betdgt die gesamte genetisch i i i sche Strahlenexposition 61 mrem rahlung (d/Jahr
h. medizini- + natU 3
Fallout 3 mrem /Jahr + alle anderen, einschlie61ich r g 100 mrem!Jahr + berufliche E [ die Grundstrahlung bei dem von trahlenexposition Jahre oder 170 mrem e der (CRP und festge ren Grenzwert von S rem /30 i Kosten einsparen, wen /Jahr ausgenommen sind, k6nnte die G n sie diese 1,2 bis Krankheiten. geistigen und k6rperliehen Gebrechen 12 % an schlechtem , Gesundheitszu ' n,(Mi6bildu { I rung der Vereinigten Staaten serringern , i ionen Bev61ke- wUrd i um die terrestrische Komponente der naturlichen Grundstrahlun
' gr66te Kostencrsparnis k6nnte jedoch dadurch erreicht erabzusetzen. Die werden da diagnostische Strahlenexposition in der r.
Medizin verringe man die unnutige t Der Bericht der BEIR Kommission erh5itet die oben erw ih oder sogar gr6Ser sein k6nnen . e Revolkerungals ebensodie genetisch gros l Tabelle 5 stellt eine Zusammenfassung der Risikoabsch5tzung dar. I en der Beir-Komrnission Tab. 5 Rhikoabschhtmqcn der !TIR-Kommiwien bei ei geretach-sigmfikante Doys son 170 mrem!Jahr ner stalIilen Bevolkerung der USA fbr eine Gesamtzahl pro Jahr konstitutioncile Krankheiten, Sterbefalle uswSchwere karperlich Atiecmein schlechter Gesundheitszustand I100 bis 27 000 t,2% bis 12% derjenigen in Krebs (Todesfhne/Jahr) den USA I 3000 bis 15 000 dab genetische Risiken einerstverst5ndlich in der Il6he d e Exposition angenommen, von Pop i tischen Risiken. Diese Annahme kann jedoch n asnicht ie soroa-15er natQrl risikos akzeptiert werden. Aufgnmd e von zugege sch5tzung des Krebs-j der Wirk;mgsprinzipien muS festgestellt werden , nvollkommes. dabn Kenntnissen die Tu Strahlensch5digung einer oder mehrerer K6rperzellen morentstehung als Folgenicht einer
! Es wurden Risikoabsch5tzungen angestellt, die auf dieser Voausgesch j
bei denen !incare Extrapolationen der raussetzung Daten von beruhenOberlebende und i in Iliroshima und Nagasaki, bestimmtere Patientengruppen di thn der wurden und von beruflich strahlenexponierten Gruppen erapeutisch behandelt vo, rg i Berechnungen aufgrund dieser Daten nber exponierte enommen wurden. Derartige Perso dab eine zus5tzliche Strahlenexposition r der Bev61kerung de USA in II6he von 5 rem /30 i
?
l
' ' ' ' ' " ~ '
f 3 e a
Wpht hs l't@cn em< r 6 N ima i n n nudizinmben Strahl.nbelvtung 137 j Jahre (durchschnittlich 170 mrem!Jahr) ann 5hernd 3000 bis 15000 T Krebs jahrlich verursachen kunnter . . Die Kommission halt eine Zahl von 6000 Krebs. l todesfallen jalulich far die wahrscheinlichste Sch5tiung, was eine Zunahme von ca. 2% der spontanen Sterbeziffer durch Krebs und eine Zunahme von etwa 0,3% der Gesamt. sterbeziffer durch alle Ursachen bedeuten wurde"(1). Weiterhin heist es in Bericht: " Die gegenw5rtigen Richtwerte son 170 mrem /Jahr entstanden aus dem Demd-hen, die so/ialen Erfordernisse gegen genetische Risiken abzuw3 gen. Es scheint, da6 d
$ Erfordernisse auch mit wesentlich geringeren durchschnittlichen Strahlenexpositionen u einem niedrigeren genetischen und somatischen Risiko, als es in den gegenwartige St lenschutzrichtlinien (FRC 1960-1961) (30) gestattet ist, erfullt werden kunnen. Darum ist der gegenw3rtige Richtwert unn6tig hoch. Die Belastung durch die Strahlenanwend der Medizin und Zahnmedizin sollte nach demselben Prinzip behandelt werden. Um den I Bereich, um den Belastungen olme Beeintr5ehtigung des Nutzens herabgesetzt werden L6n nen, sind sie ebenfalls zu hoch"(1).
l 1 Dye BEIR Kommissmn faSte ihren ?:0 Seiten langen Bericht mit speziellen Beobach
! und Empfeldungen rus:munen, son denen einige fauten:
j a) nichtStrahlenexpositionen, gestattet werden. son denen kein entsprechender Nutien zu erwarten ist, sollten l l b) Die Offenthchkeit nub gegen Strahlung geschutzt werden,jedoch nicht soweit, das a ' ihre Stelle eine noch gr6 Sere Gefahr tritt. Man sollte Geld zur Verringerung der Strahlen l
' risiken dort ausgeben, wo die gr66te Risikoverringerung pro DoUar erwartet werden ka c) Auch rur die Einzelperson sollte ein oberer Grenzwert rdt kunstliche nichtmedizinisch Strahlenexposition festgelegt werden, und zwar so, dab das Risiko einer schweren som schen Sch5digung sehr gering ist.
d) Der Grenzwert fur eine kunstliche nichtmedizinische Strahlenexposition der Allge bev61kerung sollte wesentlich emiedrigt werden. e) Die medizinische Strahlenexposition kann und sollte dadurch betr5chtlich verrin werden, dab sie auch auf klinisch indizierte Verfahren in bester technischer Durch mit einwandfrei betriebener Apparatur beschr5nkt wird. l ~ Folcende Punkte sollten ber9cksichtigt werden: falls nicht eine echte Wahrscheinlichkeit besteht, Krankhei festzustellen.
2. OberprUfung und Genehmigung der Strah!eneinrichtung und Zusatzausinstung.

3. Angemessene Ausbildung des Personals und entsprechender Nachweis darQber. E denschutz (besonders eine Abdeckung der floden) v.ird ausdrucklich als einfache und se wirkungstoUe Methode zur Reduzierung der genetisch signifikanten Dosis empfohlen Eine weitere Diskussion der Folgen einer medi7inischen Strahlenexposition ist hier nicht mehr erforderlich. Die Risikoabschutzungen der BElR Kommission, wie sie in Tabell: 5 eine Belastung der Bev61kerung der USA mit durchschnittlich 170 mrem /Jahr) zusammen.
gefaSt wurden, so!!cn aber no:h mit den in Tabelle 2 zusammengestellten Daten rdr die medizinische Strahlenexposition verglichen werden. Es ist nicht bekannt, wie hoch die diagnostischen Strahtenanwendungea dem Patienten verabfolgte .
.-.,,-.ew.cr.--.e-- - --P96"d"PU' M*W N M '* M*U 9
1 *-
13S K.L. wrpn 4
) ; durchschnittliche Gan/kurperdosis der Resulkerung der USA aus medizinischen Str j ilueden im Jahre 1964 war, ebensowenig ist sie infolge der unvollstandigen I?rhe t das Jahr 1970 bekannt. Aus einem Vergleich mit Erhebungen in anderen lim I doch mit Sicherheit zu erwarten, das sie gr6Scr als die Gonadendosis ist. Die ges durchschnittliche Conadendosis durch medizinische Strahlen<1uel nicht ver6ffentlicht. Sie kann jedoch auch auf etwas 6ber 90 mrem 1,esch5tzt werde i dab die Ganzk6sperdosis wahrscheinlich mindestens 100 mtem betrug. Die Ga t t dosis im Jahre 1970 unterscheidet sich wahrscheinlich nicht sehr sta 1964, da die Anzahl der R6ntgenaufnahmen betr5chtlich zugenommen hat. Es kam zu einer Abnahme der genetisch signifikanten Dosis bei Af5nnern (durch Anwendung loka 1 Abschirmung),jedoch zu einer Zunahme der genetisch signifikanten Dosis bei Frauen. Da-i mit betragen die Folgen einer medizinischen Strahlenexposition fdr die BesnWerung der I USA sicherlich mindestens 607 derjenigen, die fur 170 miem/Jahr angegeben wurden.
I Anders ausgedrUckt heist dics, aufgrund der ifnearen Beziehung zwischen Dosis und Wir. i kung, die sich aus der vorbcrigen Diskussion ergibt, und auf der die Daten in Tabelle 5
! beruhen, L6anen wir folgern, dab zum gegenw5rtigen Zeitpunkt durch die Anwendu ioni.ierender Strahlung in der Meditin (meistens R6ntgemtnhlung in der Diagnostik) eh e mindestens so schwere Sch3digung der Besb!kerung verursacht wird, wie sie Tabel Tab. 6 %ndestabschattungen der Sch.idigung durch medizinishe Strafdenewition in den (;SA Geurntuhl pro Jahr Schwere k6tperliche Gebrechen, angeborene Sfibiklungen, konstitutianelle Krankheiten. Todesrslie usw. 660 bis 14 000 A!!gernein whiccl.ter Ge<undheitvustand 0,7% bis ??e des in den USA batchenden Wertes Krebs (Todesfilte/Jahr) '
1800 bis 9000 ' 3 Eiirige ermruigale Entwicklungen in den USA In letzter Zeit gibt es einige ermutigende Entwicklungen, die zu einer Verringerung medizinischen Strahlenesposition der Bev61kerung der USA filhren. Dazu geh6 ten z.B.: I I a) Es gab nachdrockliche und in gewisser Weise auch wirkungsvolte Erklarungen der n nalen Gesellschaft fiir Tuberkulose und Erkrankungen der Atemwege und des uffentlich Gesundheitsdienstes der Vereinigten Staaten, da6 R6ntgenreihenuntersuchungen des B raumes, abgesehen von Gebieten, in denen eine groSe Tuberkulosch5ufigkeit zu verzeich-nen ist, nicht weiter durchgefdhrt werden sollen.
) Die mittlere llautbelastung pro Aufnahme bei R6ntgenuntersuchungen des Thorax nahm f ebenfalls ab (z.B. von 86 mR im Jahre 1964 auf 58 mR im Jalue 1970 be heitsbehurden und von 34 mR auf C4 mR in Privatpraxen).
b) Die jdhrliche genetisch signifikante Dosis durch diagnostische Verfahren sank von
. 54,6 mrad im Jalue 1964 auf 35,5 mrad im Jalue 1970. Diese Abnahme beschr5nkt sich ! ganz auf die Dosis an den !!oden, da in dieser Zeit die juhrliche genetisch signifikante j Dosis bei M5nnern (meist infolge lokaler Abschirmung), von 45,5 mrad auf 22,0 mrad zur0ckging, wshrend sie bei Frauen von 8,3 mrad auf 12,5 mrad und beim F6tus von mrad auf 1,0 mrad anstieg. Die Gonadendosis durch diagnostische hfaBnahmen im Jalue 1964 betrug 143 mrad fdr den Mann und 26 mrad fdr die Frau oder durchschnittlich 84 mrad.
t 4
- . - ~ ~ ~ ~ , . . ..-e--.m~-.,--w p n, e, , -,,,,,,n_. ._n,, .,. ,
e. 9 e r- s-
. - - , . - . _- . ~ . . - . .. - Eghae I ob n dm Armt4 gen mutumia n sir.,t& A taung 139 ; c) Das Verh51tnis zwischen der Hsche des Nutntrahlenbnndels und der FilmfLiche unk l
son 3,3 auf 2,3 in Paivatprasen, son 2,8 auf 1,6 bei piivaten Gruppen, son 2,0 auf 1,8 2 bei Gesundheits5mtern, son 1,9 auf 1,3 in Krankenh5usern und von 1,8 auf 1,4 in Privat-praxen son Radiologen. Am st5rksten wurde die genetisch sigmtikante Dosis durch dia-l gnostische Verfahren im Sechsjahresecitraum bei den R6nigenuntersuchuraen der Lenden-
; wirbels5ule sertingert. Diese Untersuchungen machten 40% der genetisch signifikanten
' Dosis im Jahre 1964 aus,jedoch nur noch 16% im Jahre 1970. I Einen weiteren Fortscluitt im gleichen Zeitraum bedeuteten die freimntigen und offenen g Kritiken durch prominente Mediziner in medizinischen Zeitschriften hinsichtlich mi6-t br5uchlicher Anwendungen von R6ntgenstrahlen in der Diagnostik. Einige der zusammen-fassenden Atheiten uber dieses ~lhema stammen von folgenden Autoren: Swan (31), McClenalun (32), h'arren (33), Stewart und Kncv/c (34), Ilrook und Sie renwn (35), l , Sut/weland (36),Ik/l und loop (37) und Kissick (38). I Vielleicht die beste M6glichkeit, auf die wertvolle Selbstkritik, Ehrlichkeit und Offenheit j einiger Mitglieder der Xrzteschaft hinzuweisen, mit der sie die Aufmerks:nnkelt auf unbe-j friedigende Bedingungen und die Notwendigkeit von Verbesserutten bei der Anwendung
; von R6ntgenstrahlen in der Diagnostik lenkten, besteht darin, aus dem Antikel von i McClenalun (1970)(32) zu zitieren: "Jeder, der heutzutay in einer sielbeschdftigten Klinik neben einem Runtgenger51 steht, a wird innerhalb einer Stt.ade zu den folgenden Oberlegungen kommen: ! 1. Eine R6ntgenuntersuchung anzuordnen, ist leichter als nachzudenkeh. Das trifft beson-
' dets auf gmSe Ausbildungsst:itten mit Forschungsverpflichtungen zu.
' ' ,' 2. R6ntgenuntersuchungen werden regclatiBig durchgefuhrt, auch wenn eine genaue Dia-4 gnose mit dem bloSen Auge, dem Ohr oder dem Finger gestellt werden kann. Dieses Ver-
; faluen wird als "AusschlicBverfahren" bezeichnet.
3. Es gibt schwere gesetzliche Strafen flir jeden, der es vers 5umt, eine Runtgenuntersuchung anzuordnen, gleichgultig, wie geringfiigig die Verletzung oder Krankheit war. Es gibt keiner-
! lei Strafen flir leichtfertige oder st5ndig wiederholte R6ntgenuntersuchungen.
4. Fast jeder ist in irgendeiner Art son Versicherung, die fiir die Kosten von R6ntgenauf-nahmen aufkommt. Das bedeutet, da6 die Kosten nicht 15nger abschreckend wirken.
I 5. Zwar haben technische Verbesserungen die II6he der Patientenexposition pro Film ser-
' ringert, jedoch werden jetzt zur Diagnosestellung mehr Filme als fruher ben 6tigt, i 6. Qualifizierte Arbeitskr5fte sind knapp. Anforderungen von R6ntgenleistungen nelunen zu, gleichzeitig schwindet die Zahl der Radiologen und R6ntgenassistenten, was zu hasti-gen und gefalulichen Techniken fuhren kann. ; 7. Im Volk verwurzelte Vorstellungen und andere traditionelle Riten, eine zweifelhafte j Rationalit5t, ftihren zu h6herer unn6 tiger Strahlenexposition der Patienten und zu sinn- 1 ' i loserer Vergeudung als die meisten son uns ahnen."(32)
I Der Sinn und die Waluheit jeder der obigen Beobachtungen ist vermutlich eindeutig tmd
^,
braucht nicht weiter kommentiert zu werden. Jedoch sollten vielleicht einige unterstStzende j Beobachtungen erw5hnt werden: 1 i Beispielsweise geht McCkiulun weiter auf Punkt I ein: "Einige Assistenten und einige Chef 5rzte ordn'en automatisch eine Serie von R6ntgenuntersuchungen emeut an, wenn ein j Patient ihr Krankenhaus betritt, selbst wenn er eine Woche alte Filme mitbringt, die die Diagnose eindeutig erkennen lassen" (32).
. j !
i t t
= v em s e t **.
W (
*M;" M***WF**"e "^8"*ese+
9 aw y, asar g g_ , w p- yensierter* F a-we ar ^ *' T c w s I e
l
! 10 A L %,n , #ctl und hm;> (19 M)(37) unte streichen diesen Punkt, indem sie eine Gruppe son Patien-ten erw5imen, bei denen die Ausbeute sehr gering war (eine Fraktur bei 435 R6ntgenunter- ! suchungen) und kommentleien: "R0nt ;enuntersuchungen t in dieser letzteren Gruppe h5tte man aufschieben oder ganz wegfallen lassen kunnen, ohne da6 sich das auf die Versorgung ! des Patienten nschteilig ausgewirkt h5tte."(37).
I Ilinsichtlich Punkt 2 hat eine Anzahl von Xrzten auf die geringe Ausbeute bei Rnntgenauf-nainnen des Schi!cis hingewiesen;Suthcrl.md (1970)(36) sagt z.B.: "Hei den Sch5defauf. g ; nahmen in der seilieger Jen Studie rei;;te sich die geringste Obereinstimmung zwischen kli-nischen und radiologhchen Befunden. Lediglich eine krankhafte Ver5nderung, ein Ilypophy-4 senadenom, wurde unter 70 angeordneten Aufnalunen nachgewiesen"(36). liinsichtlich Punkt 3 wird allgemein ancikannt, das irgend etwas geschehen rnuB, um die -
! Androhung gesetzlicher Strafen fur Xute 7u mildern, die auf R6ntgenaufnalanen ser/ich-ten, wenn sie sich dason nur wenige nutzbringende infonnationen sersprechen. Die Juristen k0nnten bei der I.usung dieses Problems sielleicht helfen, wie sie es auch in anderen ahnli-chen Fallen schon getan haben. Beispielswcise verhinderte der "Verj5hrungsparagraph" in verschiedenen Staaten den Bezug einer Arbeitnelancrentsch5digung, denn der Anspruch auf eine Entschld:yng entfallt, wenn er nicht inncrhalb von ein paar Ja!uen nach der durch die briuniche 15tigkeit scrumchten Verict/ong geltend gematht wurde. Ganz offensicht-lich btraksichtigen diese Gesctze die Moglichkeit strahicninduzierter maligner Erkrankun-gen, deren durchschnittliche f atenzzeit 10 bis 30 Jahre betr5gt, kaum oder gar nicht. Der SoaderausschuS f6r Atomenergierecht der Amerikanischen Rechtsanwn!tevereinigung beriet uber diese Angelegenheit und schlug 1968 vor, " die Laufzeit zur Geltendmachung eines Anspruches sollte nicht eher beginnen, als bis der Besch5ftigte weiB oder aufgrund sorgfal-t tiger Cbeilegungen wissen mu6te, dab 2
a) er verletzt ist; b) es eine mogliche Beziehung zwischen der Verletzung und der Tutigkeit, bei der die - Strahlenbelastung erfolgte, besteht und c) er eine Sch5digung eilitten hat; oder im Falle des Todes des Besch5ftigten sollte die Uruficit fur die Geltendm::chung eines Anspruches nicht ser dem 7.citpunkt des Todes beginnen." l j Vielleicht kann man den 6ffentlichen Gesundheitsdienst der USA dazu bringen, um Unter-stUtzung dieses Ausschusses zur Milderung der angedrohten gesetzlichen Strafen nachzu-suchen, wenn der Arzt das vermeidet, was er mit Recht als unn6tige Strahlenbelastung des Patienten ansicht. Wie in Punkt 'I a 'egt wurde, er brigt sich durch die M6glichkeit, die Kosten fur eine R5ntgenar e ei <utreiben (oder sogar einen Gewinn zu erzielen), die Frage, ob bei ein 'ine f46ntgeaaufnahme gemacht werden soll oder nicht. Kissick (1970) (3';i a- h, " die Bemuhungen um die Gesundheit in den Vereinigten Staaten, ein 60- .ai ; r-Unternehmen rnenschlicher Dienstleistungen, befinden sich in einem i Krisczustand, nr ;hre Fortsetzun2en in ihrer bisherigen pluralistischen, unabhsngigen
! freiwilligen Weise in Fry stellt".
Kosten fur medizinische MaGnalunen kunnen nicht im gegenw5rtigen Tempo weiter stei- . gen, w5luend die Qualit:it der medizinischen Versorgung, wenn uberhaupt, dann nur ge-ringfugig verbessert wird. l l i I t
..---._ ---- - - --~=- ~ - ,-,-.. .--_7..._ .
n-, . ,e 4 e
i Myn. tw r. tu n una Anng.< n ma,,;nigyn s,,,3,cn,w,,n,,ng ,4l j Es ist sthwer /u serstehen, waimn jetzt mehr filme pro Untersushung erforderlich sind, es sei denn, man scihineet Punkt 5 mit Punkt 4. Vielleicht dnd heute mehr Wiedeiho-lungsaufnahmen erforderl.ch, was durch Punkt 6 erkladich ware. Brook und Stevenson (1970) [35] stutzen Punkt 6,indem sie aufgrund threr Untersuchungen betonen,"nur 37 von 98 Patienten, die runtgendiagnostisch untersucht wurden, wuBien, ob der Befund not-mal oder pathologisch war, tod nur 14 von diesen 38 Patienten m4 einem pathologischen R6ntgenbefund schienen anger wssen therapeutisch behandelt worden zu sein" [351. Viel-leicht gibt es kein besseres rBeis id fdr Punkt 7 ah die Tatsache, auf die Nadcr (1968) { [39] 6ffentlich hingewiesen hat, dab nsmlich sicle R6ntgenassistenten in den Vereinigten Sta;. ten bei Patienten mit schwarzer IIautfarbe eine h6here Dosis verabreichen. Ein noch allgemeineres Beispiel ist die neurotische Patientin mit niedriger Schmerzschwelle,' die ohne R6ntgenaufnahme nicht zufrieden ist. Der vielleicht beste Ratschlag an den Arrt in diesem Fall lautet: Bei der Frau als Teil der erforderlichen Psychotherapie R6atgenauf-nahmen vorrunchmen, aber ohne in shalten. D:e.Liste von 3fcClinabhan, in der er die GrUnde anthhrt, warum heutzutage Patienten uber-maSige medizinische Strahlenexpositionen c halten,licBe sich noch um eine Reihe von Punkten erweitern. Einige dason sind in Tabelte 6a zusammengestellt. Der viel!eicht cifrigste und standhafteste Verfechter von Reformvodagen zur Reduziemng unnd!!ger klinischer Strahlenbelastungen in den Vereinigten Staaten war der verstorbene Senator EL Bartictt. Er legte den Gnmdstein for das Public I.aw 90 602 (18.10.1968), da> cinen Zuutz zum Geset/ tber den offentlichen Gesundheitsdienst darstellt und for den Schutz der 6ffentlichen Gesundheit gegen Strahlenemission aus elektronischen Erzeu- ' q gern sorgen soll. Das Gesetz soll alle elektronischen Erzeuger ionisierender oder nicht ionisierender, clektromagnetischer oder Teilchenstrahlung oder jeder Strahlung in' Schall , L Infraschall- oder Ultiaschallbereich uberwachen, die zu einer UbermaBigen Strah!cnbe!utung r und m0glichen Sch5digung des Menschen fhbren k6anten. Es nbertr5gt dem Gesundheits-minister die Befugnis und Verantwortung, dafur zu sorgen, dab Runtgengerste, Fernschge-r5te, Mikrowellenheide, Ultraschallgeriite und alle anderen derartigen Ger5te und ihre Bestandteile so hergestellt, montiert und angewandt werden, dab jede Oberm5Bige Strahlen-exposition von Besch5ftigten und Bev61kenmg vermieden wird. Es venlangt vom Gesund-heitsminister, geeignete Durchfuhrungsbestimmungen fdr die Oberwachung von Anlagen, die Strahlen erzeugen, aufzustellen und diese Normen durchzusetzen und wenn notwen-dig, neue Normen zu entwickeln. Er soll Forschung, Entwicklung, Ausbildung und betrieb-liche T5tigkeit so planen,leiten, koordinieren und unterst0tzen, das die Strahlenbelastung der Bes61kerung durch unn6tige Straldung auf ein Mindestma8 beschrankt wird. Er soll bei der Ausarbeitung staatlicher Programme fdr die Ausbildung und Pr6 fung so mitwirken, das die sachliche Zust5ndigkeit derjenigen sichergestellt ist, die Strahlenquellen anwenden oder fdr die Obesprufung und Bescheinigung ihres ordnungsgemsSen Betriebes und ihre Anwendung verantwortlich sind. Entsprechend dem Public Law 90-602 wurde ein speziel-ler Sicherheitsausschus gegr0ndet, der die Strahlensicherheitsnormen Uberproft und fur ihre Neufassung, falls eine solche wnnschenswert erscheint, Empfehlungen gibt. PL 90-602 gilt f6r importierte Anlagen genauso wie fur im Lande hergestellte und enth51t entsprechende A u sfuhrungsbestimmurgen.
4. VerbessemngsvorschUge j'ir die USA Trotz der Fortschritte, die wir bei der Reduzierung unn6 tiger medizinischer Straldenexpo-sitionen in den USA gemacht haben,liegt noch ein weiter Weg vor uns. Ich habe schon L
_ _ . _ _ _ . _ _ - _ _ - . ~ e
142 K.4 Wrpn Tab.62 Wdtere Gr6nde tus cine Lbumatsge Strahlenapmition der Patienten (Purkte 1-7 sind im fest aufgezahlt).'
b. R6ntunaufnahmen vergreSern das Einkommen son Xriten oder msdisinischen Institutionen.

9. Der unaufgeklarte Patient beurteilt hrzthches K5nnen nach der Zahl der R5ntgenaufnahmen.
j 10. R6ntgenaufnahmen sind in bestimmten Berufen obligatorhch (Krankenschwestern, Ixlacr, Arge-
$ stellte in Restaurants usw.). } 11. Es werden R0ntgenLberwachungen durchgefithrt, fur die nur eine ganz geringe Notwendigkeit be-i steht (R5ntgenreihenuntersuchungsprogramme).
12. Beckenmessurgen werden manshmal routmem Lig bei Erstschwangerschaft r.rgefordert,
, g g' , 13. Bereits in Patientenakten vorliegende R5ntgenaufnahmen werden nicht benutit.
l 14. Magnetbander und Cornputer zur Speicherung und Wiederauffindung von R6ntgendaten werden nicht benutzt.
15. R5ntgenaufnahmen werden als puchotherapeutische Ma6nahme durchgefhkrt (neurotishe Patien-ten).

16. Gesundheitsvmorge- und Obe:wachungsprogramme waden zur Erstattung der Gsten far R6nt.
genaufnahmen in Anspruch genommen. ,
17. Die spuisilen 1:sfordanisse bei R6ntisnaufn.ihn.cn son Kindon und S:iuch ten werden nicht be-t achtet.
! 18. Es scrdrn Durchleuchtungen durchgefbhrt, wo Informationen Ober Bewegungsabhiufe nicht erfor-5 deilich sind.
19. Die Ausbiktung ist nungelhaft, und es besteht auch kein Zwang zur Ausbildung fiit alle, die tant-
, gendignostiwhe Ger:ite bes;tz.:n, anwenden,6berwachen oder entsprechende Untusuthungen g
, e nor d nen. ! i
70. Es werden manthmal R0ntgenaufnamen angefert:gt, die fur den Patienten von fugthhtm und }
l unverstindhchcm Nutzen sin.1 bzw. scin wilen, z.B. Praktiken einiger (hue;uktiker. *
21. Die Radiologie - ' nicht als Beruf ausgesbt - der Radiolege fD?ut die Anordnungen anderer aus chne sein fach!;ches l'rteihverm6 gen einzusetzen. Er (Uhlt sich nicht veranlaSt den diagnmtischen
; Nutien gegenLber der Strahlenuhidigung abzuwsgen.
22. Es wurde ver<iumt, den Dienstgrad eines "leirenden R6ntgenassistenten" cinzufshren.
-~ 1
23. Med:dnische R6ntgenaufnahmen werden son Venicherungsgeathchaften und Juristcn angefordert, 3 um ScNdensersatzanspriiche zu kliren.
[ 1- 24. Aufnichnengen Eber die Patientendmis werden nicht aufbewahrt. l 25. Es wird vers 3urnt, die Bestrahlung kritischer Gewebe, wie z.B. des zentralen Nerven ystems, des l aktiven Knochenmuks, der Augentinsen, der SchilddrGse usw. zu vermciden. l i 26. Mawnproduktion im Kochbuchverfatuen in der Radiologic.
27. Es fehlt cine ausreichende staatliche oder bundesstaatliche Gesettgebung.

29. Die Strahlenexposition der Bes51kerung durch med;zinische MaBnahmen ist nicht Teil der Betulke-rungsgrenzwerte son dmchuhnittlich 170 miem!Jahr.
l l j 29. Ausrintung. Mataialien und Techniken entsprechen nicht dem neuesten Stand,
; a) Vowenddng unempfindlicher Filme, i b) schlechte Entwicklungstechnik, ,' c) Einblendung des Strahlenfeldes ist auf dem Film nicht si_htbar, .
[ d) Oberbelichtung und Unterentwicklung des Films, c e) Fokushautabstand zu kurz, f) ungeeignete Spannung, g) Anwendung ungeeigncter Tubtste und unzureichendes Ei,blenden, h) schlechte Schaltuhren, r 3 i) unzureichende Filter, j) unzureichende Absch'rmung, l k) nicht ausicichende Oberpr0 fung der Ger5te, ! !) bei einigen importierten Anlagen fehlt Anuige von Spannung und Stromsts1ke, l 1 m) nicht ausreichende Dunke! adaptation des Radiologen, n) Verwendung von umul'inglichen Durchleuchtun;scinrichtungen, o) fehlen geeigneter Zentrienorrichtangeri. l t i
-.._ _ _ _ -a.,m.-- em m.esm m- - ~e-= > - v w - = ~*. w n v = mm^- s vo *~~A"" *~~~-% ~ ~"'R"~*
e e,-: l
-l l
WA bc 1..to n se Armen mat einen stuhtebe . rrang in bei Anhorung wr dem Kenpeb P0] darauf hingewiesen, daS wir in den USA eine durchschnittliche mediziniwhe StrahLnbelastung encichen kunnen, die weniger als 10'1 der gegenwittigen bet:3gt. Um dines Ziel zu erreichen, sind folgende Schntte notwendig: a) Verbesserte Ausr0 stung b) Ausbddung und Prufung aller derer, die die meditinische Anwendung ionisierender Strahlung am Mens (hen anordnen oder dmchfibren c) Bessere Techniken und eine sprechende Indikationsstelhaig son seiten aller Mediziner, damit die Strahlenbtlastung des Patienten auf den minimal m6glichen Wert reduziert wird. Public Law 90 602 stcitt einen gewaltigen Fortschritt in Richtung dieses Zieles dar. Doch gibt es in dieser Ilinsicht rmth siel mehr Verbes<.crungsmnglichket n, tnit denen die Pati-entenexposition in reduricien ist. Ein Teil des Problems liegt darin, dah hinsichtlich der unter (b) und (c) crwamten 7icle sicle der m6gtichen Verbesserungen nicht oder nicht richtig ungewendet w -den. So gibt es z.B. automatische Einblernhorrichtungen, die jedoth in vielen Fallen iht serwendct werden: Hildverstniker, die die Durthleuchte 3s-dosis auf weniger als l'.I. herabsetzen kunnten, sind zwar im Gebrauch,jedoch werden oft die erforderlichen zus;iv!khen MaBnahmen nicht durchgefLhrt, so das eine so weitgehende 3 m61iche Redu/ierung w1 ten realisiert wint hhn5vte kunnten die gegenwartige Patienten-dasis auf weter als b herab1ct/en, wenn sic cine mhteckige Pr5zisinnscinblendungsvor-skhtungycruen&n warden, aber weniger als PA tun dies. Es gibt automatische Entwick-tungsmasthinen iljr Zahnfibne, die, wenn sie cinw.mdfrei betrieben werden, die schlechte Gewohnheit ausmeven k6nnten, Fi me Lbeaubclichten und untenuentwickeln (die mit Sicherheit zu einer unn6tigen Belastung dcs Patienten und zu einer schicchten Filmquali-tat fuhrt). Doch haben victe Zahn5ute nur geringfcgige Verbesserungen ihrer Tecimiken . vorgenommen. Vielicicht am recb.tandigsten sind wir im Augenblick hinsichtlich des Zie- - i les Nr. b. Nur im Staate Kalifornien wird verlangt, dab in den medizinischen Fakultaten cine Unterweisung im Strahlenschutz (und vieticicht ein wenig in Strahlenbiologie)erfolgt, und dan Fragen Lber dieses Gebiet bei den staatlichen Priifungen gestellt werden. In der Mehuahl der Falle in den Vereinigten Staaten weis der Arzt, der bei seinen Patienten eine Rantgenaufnahme anfordert, tatsachlich nichts uber die Wirkung dieser Strahlenex-position und scheint auch nicht in der Lage zu sein, dieses Problem von einem wissen-schafdichen GesichtspurAt aus zu Ltrachten. Er weiS vielleicht, daS 200 bis 400 rad j 3 Rnntgenstrahlung erforderlich sind, damit ein Mensch mit einer hohen Wahrscheinhchkeit an den Folgen einer Strahlenkrankheit stirbt. Jedoch scheint er in den meisten Fallen nicht dar0ber informiert zu sein, das eine Ganzkurperdosis von 5 rad mit einer Wahr-scheinlichkeit von 1:2000 dazu fuhrt, das ein Patient viele Jahre sp5ter an einer strshlen-
' induzierten malignen Erkrankung stirbt. Vielleicht ist er auch der Meinung, das es ein teringes Risiko ist, weil der Tod wahrscheinlich 20 hhre sp5ter ohnehin cintreten wurde, so das diese Maglichkeit vernachlustigt werden kann. Wenn diese Strahlenexposition jedoch 4
2 Malionen Patienten scrabreicht wurde, so ware zu erwarten, dab sie zu 1000 Todesfallen durch Krebs fuhrt. Unser Land wartet irnmer noch auf eine fuhrende Pers6nlichkeit wie den verstorbenen Senator Bartictt, der trotz vorauszusehender Opposition von seiten der American Edical Association, American Dental Association und des American College of Radiology die Bdligung einer Gesetzgebung durchsetzt, die das Problem der bberm:iSi-gen Strablenbelastung der Bev6!kenmg durch medizinische Strahlenquellen dadurch an der Wurzel packt, das sie eine wirkungsvolle Ausbildung und Prufung aller Xrzte, die ioni. i sierende Strahlen bei ihren Patienten anordnen oder anwenden, erferderlich macht. I t 1 1 l
.i ~_ - _ . _ . _ _ -Nw q ,-w - -ee I
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4 IM LL Mmpn I Abwhtief.end sei anf etwas hingewiesen, was bisher vielleicht ah die ennutigendste Ent. wicklung auf diesem Gebiet angesehen werden kann: i hn Senat und im KongreS liegen Gesetzentwnrfe vor, die einen Zusatz zum Gesetz nber i den offentlichen Gesundheitsdienst darste!!cn und die Bevolkerung vor unn6tigen Belas-tungen mit ionisierenden Strahlungen durch medizinische Mafinahmen schntren sollen. i Der spezielle Zweck dieses Geset/cs ist es, eine angemevene Ausbildung der R6ntgenmi-t stenten dadurch sicherzuste!!cn, daS Kriterien und Mind <stanforderungen fur die Zulmung als Ausbildungsst3tte aufgestellt werden, Mindestanforderungen fhr die Anerkennung als R6ntgenassistent festgelegt werden, und da8 der Staat die Zulassung als Ausbildungsstatte und das Retht, R6ntgenassistenten an/uerkennen, erteilt. Sollte ein US-Stait sich nicht wllknnunen an dieses Pmgr:unm halten, h-itle der Gesundheitsminister die Hefugnis, cin. i eugeifen. ich glaube, da es mit dieser Gesetzesvodage3 m61ich ist, cine gegenwiirtig bestehende enertnigliche Situation, n5mlich, das nur die Staaten New York, New .fersey, i Kalifomien, Kentucky und das Commenweahh of Puerto Rico diese Ausbildung und Pai-1 fimg wn R6ntgenassistenten verlangen, abzuuhaffen. Fihrt ein Kind mit dem Schulbus, so haben wir die Gewi6heit, dab der Fahrer einen FUh-ierschein besitet. Wiid eine R6ntgenaufnahme :mgeoninet, kann sie in 3 umerer Staaten van ciner lhlf kraft angefertigt werden, die keinen Pehhigong nachweis braucht, und die des!alb eine grdSere Gefahr darstellt als ein Besfalner, der nhht we:S, wie man d.e Ihem-sen des Schulbusses richtig bethrigt. 1 Es sind noch sthr viel mehr Fortschritte n6tig, bevor unsere Ziele erreicht weiden k6nnen. Die Einrichtungen mnssen weiter serbessert werden. Sie massen in noch h6herem Malte a automatisicit sein und dadurch bedien ings- und funktionssicherer. Beispielsweise sind auto-matische Eiablendevorrichtungen aasg reichnete technische Entwickhmgen, aber sie m0ssen auch richtig angewendet werden, andernfalls sind sie keine Verbesserung. Typische Beis eindeutiger Verbesserungen, die schon vor Jahren bei der medizinischen Ausnistung hdtte i sorgenommen werden mUssen, sind unter anderem auch:
1. Eine Vorrichtung, die cine Inbetriebnahue der R6ntgenr6hre verhindert, wenn der Zen-trs!strahl nicht auf die Kassettenmitte ausgerichtet ist.
} 2. Ein Dosismonitor, mit dessen Iliffe der R6nigenapparat nach Eircichen einct vorher festgelegten Dosis am Film (und damit am Patienten) abgeschaltet und diese Dasis aufeiner PatRntenkarte vermerkt wird (sog. Belichtungsautomatik).
Ich bin der Meinung, dab unser Bureau of Radiological liealth (das jetzt dem Landwirt. schaftsministerium eingegliedert ist) fur den Fortschritt zu lobcn ist, den es bei der Durch-setzung des PL 90402 gemacht hat; et sollte jedoch mehr Mut entwickeln, um sich von den Srzthchen Veieinigungen, wie der American Medical Association, der American Dental Association und dem American College of Radiology unabhiingiger zu machen. Es ist nicht richtig, dab diese Organisationen cincn derartig starken EinfluS auf diese und andere Regierungsbeh6tden aus.iben, die die Belastung der Bev61kerung mit ionisierender Strah-lung tberwachen und zu reduzieren versuchen, wenn die X rzteschaft selbst hauptverant-wortlich fur die UbermaBig groBe unn6tige Belastung der Besolkerung ist. Das Bureau of [ Radiological 1!calth soitte sich von dem EinnuS aller interessengruppen freimachen und l eine Gesetzgebung unterstntien, durch die die Ausbildung und Prufung nicht nur der R6nt-genassistenten, sondern auch aller Xrzre erfordedich wird. Ins Deurs.he bbertragen von Dipl.-Chersetzerin H. G5nther, Dundesgesundheitsamt Berlin, Abreilung fDr Strahlenhygiene. I I
,f g,,%.egn e ,6 en4*r'(D-** zW A $grwger ut e v - -he,,J--W9m '" * .' ' * *- 'T*#"
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W ghsht l'oisn cinct uNow r en mJi/imben St N ntshstung 1-15 8 litualid
+
{ l Rgort of the khiwry Conunittee on the Dio- Forum 1970-1971. A.It Khne, Jr., editor j logicali ffccis ofloninng Radiation's B1IR 1:SAI C-LID 25h57 (1972) . j Report-Nat. Acad. Sc., Nat. Res Council (Nov. 19 lablon. S.31. and II. Kato: Childhood Cancer in . j 1972) Relation to Prenatal 0xpo<ure to Atom Bomb i 2 Gittirr,1.N. ark! P.S. Inrencc " Population Radiation", Lancet, p.1000 (Nov.14,19 70) lhposure to 1 Rays". US 1964 HRil-USPils 20 31dlcr; R.W.: "Ddayed Radiation Lffects in ; {
< No.1519 Atmnic-Ibmb Surnon", Science 166(1969) 3 heliminary statements wrarding cxpected 569 , l s rewlt, from the 19 70 BRil-USPils mdical 21 Benner. C.: Dristell loods 1968. Controlled Sur- +
Survey (chats. f raphs and tal les from BRil vey of Effects on licalth of local Community staff frescatatiem at meeting in Boston. Man. Disaster, Brit. WJ. L. p. 454 (Aug. 22,19 70) in 1971. San Fr inciwo, Cabf. in 1972 anc.
22 S. bbren amt O. Guta IN Indaction of Lcu-Miami Pach. Florida in 1972) Lemia and Lih Sbutenia 14 ' dice ley Contin-4 fron n, M.I. (l 96), y oject dirator, "Poput.- unus and I ow-Lcwl firtmal Gem.na Radia-
, tion Dose from % Rays United States 1964". tion, R ad. Res 4 7, 4 50 ( A ug.1971) 1 IILW-Ilis (Octcher 1969) 23 Row!.md, R.E.; "Same ibw-Response Rdation- } 5 Reports of the United Nations Scientific Com- ships for Tumor insidense in Radium Patients". e j mittee on the Lffects of Atomic Radiations Radiot Ph> s. Div. Annual Report ANL-7760, Part 2, p.1 (1970) j Sup. No.17 A/383S (1958), and Sup. No.
i 16 A/5216(1962) 24 Mv/Mii, L.D.: "Fsthmtet of Radiation Induced 4- 6 Report of the l'rited Nat4ns S&ntFic Com- leukemia Risk in En". ANL RWio. Phys. Div. l i mittee on the rifats of Atornic Radiation. Annual Report, ANI. 7760, Part 2 (19 70) .
< "lonizing Reliation: I cvels and Effects". 25 /I mj tenwn, LJL: Ri k of Ihy: 'il Nec plmas l Vol I. No. 25 A/8725 (1972) after in adiation in thudhood, Ssicnte 160, ! 7 frctre, S. (1973): "% e Are Being Tooled with 159 (Apnl 1968)
? j These ' Genetically Significant Doses' from 26 Saenger, E.L and E.A. Tomplins: "Results
; Diagnostic XRay", wheduled for publication of a Bu. Rs.liot llealth Survey of Effects of
, in IIcalth Physics about June 1973 Medical Use of 138 1. Publis!wd in several S Adrian Committee (1966),"!!azards and Dose pulications of IIEW-PAS-bRil (1969 72) to the % hole Population from Ionizing Radia- 27 Unffirf r,r J. and R. ILilentine;"Sdent Slaughter", 4 tions". Annals of Occupational 11)gicne 9 Regnery Pub., Chien,o, llUnois (1973) (1966) 83 28 "The Evaluation of Risks from Radiation" 9 Bulletin and liighlights J. Am. Dental Assn. Report of the Intemational Commission on 76, No. 2 (Feb.1968) Radiological Protection, ICRP Pub. 8 (1966) 10 "What about Radiation" Mass Chest LRay Prs- 29 Recommendations of the International Com-grams "LSPil5 Pub. I196, Feb.1965 mission on Radiological Protection. ICRP
. 11 " Chest LRay Sacening Recommcadations Pub. No.1 (Sept. 9,1958) l ! for TB-RD Associations",NTRDA Bulletin 30 FRC Rgorts (196041J. "Badground Mate-57, No. 9 (Oct.19 71) rial for the Desclopm.ent of Radiation hotec- ~l , 12 Grubbe, E.H.: Radiology 21 (1933) 156 tion Standards", Staff reports of the Federal l 13 Rugbh.R.: "Effect$ of Ionizing Radiation on Radiation Protection Council, Rep. art Nr.1, I the Developing Embryo and Fetus. "IIEW. May 13,1960 and Report No. 2 (Septem-BRif Seminar Peper No. 007 (1969) ber 1961) 14 BeMy,1.I. :end W.J. B?ot " Stature of Adults 31 S.:gan. L.A. f1971): "Medicai Use of Radia-Exp3 sed in Childhood to the Atomic Bornbs tion", J. Am. Med. Assn. 215, (Wrch 1971) ; of Hiroshima and Nagasaki". ABCC Tech. Rep. 32 NcC7enubhan.1 L. (1970):" Wasted XRay" l 35 (1971) 71 Penn. Medicinc 72,1076103 (Nov.1969);
15 Uchida, J.A. und E.I. Curtis: "A Possible Asw- also reprinted in Radiology 96,453456
, ciation between Maternal Radiation and Mongo. (Aug.1970) lism". Lancet pp. 848-850 (Oct.14,1961) 33 Warren, S. (1966): "The Basis for the Limit 16 MacMahon, Brian: "XRay Exposure and Mali. on Whole-Body Pxposure-Experience of Radio-gnancy". J. Am. Med. Assn. I fs3 (1963) 721 Icist ", IIcalth Phys. 12, 737 741 (1966) 17 Stewart, Alice and G.W. Knecle: " Radiation 34 Stewart, A. and G.W. Knccle (1970):"Radia-Dose Effcets in Relation to obstetric LRays tion Dose Effects in Relation to Obsteric X- . and Ch!!dhood Cancers", Lancet 1 (1970) 1185 Rays and Childhood Cancers", Lancet, pp.
IS Taylor, LS.: "What Do We Know About Low- 1186-1188 (June 6,1970)
){
Level Radiation", Environmental and Ecological I h
~j I.
I
. i i
1 d
m . _ .. a . a . I i 146 K2. Matpn 1' <
~
, 35 /1 rod RJ/. and 'R.T. Stcrcns<m (19 70):
"Ef fettivenen t f Patient Care id an Emer- 13431354 (Jan.. June 1970) '
gency Rooin", lhe New I: ngl. J. of Med. 39 Erpn, K.Z.: Testimony before the Senate 283,17,904-907 (Oct. 22,1970) Commerce Comraittee on the full 2067,"Re. 1
! 36 Suthuland, CR. (1970): " Agreement be- duction of Unnecccmry Medical Exposure",
tweca Clinical ani Radiotogical Di.ignosis", (August 28-30,196 7), Congrenional Record _ thitish Mrd. J. 4,212-214 (Ott.1910) Scri.d No. 90 49 (1968); Congrenional Re-cord licatings before the Conimittee on
,- i 37 IMF, R.S. ml 1.h'. Lorp (19 7 !): "The Utility and l'utihty of Radiog.shie Stuti rumina. R diation Contaul for llealth and Safety Act. -'
s I Washington, D C. (Manh 8,1973) I' tion for Trauma", the New Engl. J. of Med.
'S4, 5, 216-239 (Feb. 4,19 7 I) 40 Nadar, R. (1968): " Wake Up America, Unufe 38 Kiukt, W.L. (1970): lleifth-Pelicy Directions X-R ays", l.adies llome Journal 85,126 (May 1968) t for tl:e 1970's, The New rog. J. er sicd. 282, - l'rof Dr. K.:ri Z. .tivrun, Tct.ws!ofNara. g' -""""E .
At!ana Gcurgia JJJ32;g;S.4
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yU iVp THE MEDICAL IMPLICATIONS OF FALLOUT
by Karl Z. Morgan School of Nuclear Engineering and Health Physics
Georgia Institute of Technology 1
il
We do not have any direct information which can serve as a guide in describ-
[ ing the medical implications of fallout that can be expected over the United i States in case of a nuclear war with the Soviet Union. The fire ball did not reach the ground when our weapons of the order of 1/100 MT were detonated at Hiroshima and Nagasaki. In an all out war we can expect weapons of 1 to 10 MT to be employed (100 to 1000 times more powerful). Modern weapons which are so much more powerful and which would be used in large numbers would make the nuclear holocaust of the two Japanese cities seem mild by comparison. Single weapons of 100 MT probably would not be used extensively because a cluster of ten independ- i ently targeted 10 MT weapons would be far more destructive. We have some information on weapons fallout from our military blunders during our atmospheric testing of nuclear weapons in the South Pacific when the I people of the Marshall Islands were showered with weapons fallout and when the Japanese fishermen on the Fukaryer Maru were injured from the fallout (one died
.with symptoms of the radiation syndrome). The natives un Rongelap, one hundred miles from the detonated weapons at Bikini Atoll, received an estimated total body dose of 175 roentgens of gamma radiation and 2000 rads of beta radiation to the feet. The children who went swimming fared much better than the - others because they washed the fallout dust from their bodies. Epilation, erythema and i
i
Presented at conference on Medical Consequences of Nuclear Weapons and Nuclear l War, Albuquerque, New Mexico, September 25-26, 1981 l
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1esions were observed on those who did not rammin indoore cr wash themselves frequently. A number of the exposed persons developed thyroid nodules. In some cases these developed into thyroid carcinomas which were treated surgically. Some of the cancer deaths most certainly were casued by this fallout. Some other effects were slight growth retardation among the children, miscarriages, incom-plete recovery of pripheral blood elements, and permanent scars. However, using this experience to estimate what we should expect from fallout in a nuclear war is like studying a mosquito bite to estimate the consequences of a rattle snake bite. The fallout on persons in Utah and other states downwind from the Nevada test site and the increase in malignancies, especially leukemia, which appear to be caused by this exposure provides us with a very mild suggestion of what we can expect as one of the long-range forms of damage to the survivors of a nuclear war. The pattern of fallout depends very critically on the weather conditions, , the mega-tonage of the weapon, its height of detonation, and in a few cases, the seriousness of the fallout may be greatly enhanced if a nuclear power plant and
! associated or similar facilities are encompassed by the fireball. It is very probable that some of the weapons will be detonated near ground or over water in order to greatly increase the amount of fallout. This fallout area would be deprived of use during the critical period and yet would be preserved for later occupation when the enemy invaded the country. For a ground (or near ground) burs t a large crater would be formed, and the excavated and vaporized material would condense,into dust particles of various sizes. The several hundred fision
! products, transuranium products and neutron-induced radionuclides would attach themselves to these dust particles and fallout due to the force of gravity; the large particles falling out over a distance of a few tens of milee and the small particles of a few microns in diameter would be carried hendreds of miles, the
. 2
distance increasing with the megatons of the weapon and with the wind velocity. The gases and submicron size particles and radionuclides with relatively long-lived gaseous precursors would be carried into the troposphere (40,000-60,000 feet), and the smallest particles and gases would be ejected into the strato-sphere (>60,000 feet) where they would remain from months to years and be carried around the earth many times before settling to the ground. Fig.1 from V. N. Lewis (Sc. Am., July,1979) shows the sequence of events that would follow the detonation of a 1 MT weapon above the Empire State Building in New York; first the fireball at 1.8 seconds, then the reflected blast with outward winds at 180 MPH, followed by the characteristic mushroom cloud and upward vertical winds of 275 MPH at about two minutes. Fig. 2 from S. A. Fetter and K. Tsipis (Sc. Am., April, 1981) shows this l mushroom cloud moving with the prevailing wind. For comparison we have shown in the lower figure the moving cloud in a 15 MPH wind following a major accident at a 1000 MWe nuclear power plant; an explosion which breaches the containment vessel I and releases one-third of the reactor's radioactive material. This would amount to 1.5 x 10' Ci one hour after release and would be only 1/1000 the activity of radionuclides released in the 1 MT weapon cloud in the upper part of the figure. I Note that the height of the 1 MT weapon cloud is 60,000/200 = 300 times higher than the cloud from the 1000 MWe plant accident, and the distance of travel of the fallout cloud is far greater. It should be emphasized that although a major nuclear power plant accident would be an extremely grave disaster, it is hardly comparable to the calamity in terms of immediate deaths and destruction caused by a 1 MT weapon. This is because under no circumstances can a nuclear reactor explode with a force that is comparable to that of a nuclear weapon, even if there were brittle fracture of the reactor containment vessel, i.e., no deaths from blast, overpressure or burns. However, I must not fail to point out that in 3
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many reeptets tha fallout froa a 1000 MWe recctor accident in which one-third of the reactor inventory of radionuclides is released would be potentially more dan-gerous over a long period of time than the fallout from a 1 MT weapon. Fig. 3 from Fetter and Tsipis compares the total radioactivity (Ci) of a 1000 MWe accident releasing one-third of the reactor radionuclide inventory with that of a 1 MT weapon. At time zero (not shown here) the weapon has over 3000 times the curies of activity released by this reactor, but at about four days the activi-ties are about equal, and at five years the curies of activity on the countryside would be over one hundred times greater from this reactor accident than from the 1 MT weapon explosion. There are a few modifying factors that must be noted: (1) the fallout from the weapon probably would kill more people because of greater difficulties in providing dose rate information, limitations to evacuation and medical care, (2) in either case there could be release of transuranium radio-nuclides which could make the countryside uninhabitable for centuries, (3) as shown by Fig. 4-6, the worst accidents considered possible by the Rasmussen report (WASH-1400) of 1975 would not release one-third of the 1000 MWe reactor inventory. Here it is noted, for example, that the highest release of Ba and Sr radionuclides is ten percent (i.e., for a BWR category two cccident). The Brookhaven report (WASH-740) of 1957 gave values of probability of a reactor accident and severity of accident that were considerably higher than values in the Rasmussen report. However, I believe both reports underestimated the risks as shown by Figs. 7 and 8, and I would not go on record as supporting these reports. Here we note that the probability of the TMI-2 accident turned out to be three chances per 1000 reactor years, while the estimates were one to ten chances per 10,000 reactor years by the Brookhaven report and five to fifty chances per million reactor years by the Rasmussen report. Also, in view of the fact that a $25,000,000 class action suit has been settled under the Price-7
7 FRACTION OF CORE INVENT 0lY RELEASED CATEGORY XE+KR ORG I I Cs+RB TE+SB BA+SR Ru(A) LA(B) PWR-1 0.9 6x10-3 0.7 0.4 0.4 0.05 0.4 3x10-3 9x10-7(c) 1(E) ~ PWR-2 0.9 7x10-3 0.7 0.5 0.3 0.06 0.02 4x10-3 8x10-6(c) 1(E) PWR-3 0.9 6x10-3 0.2 0.2 0.3 0.02 0.03 3x10-3 4x10-6(c) , 2(E) PWR-4 . 0.6 2x10-3 0.09 0. 0.4 0. 0.3 5x10-3 3x10-3 4x10-k
^
5x10-7(c) 2(E) (A) INCLUDES flo, RH, IE AND CO, (B) INCLUDES ND, Y, CE, PR, NB, AM, GM, Po, NP AND Z::, (c) PROBAPILITY PER REACTOR YEAR, (E) WARNING TIME FOR EVACUATION (HRS). Rg 'l 8 e
FRACTION OF CORE INVENT 0R REI FASED CATEGORY Xe+Ka ORG I I Cs+Rs TE+Sn BA+SR Ru(A) LA(B) PWR-5 0.3 2x10-3 0.03 9x10-3 5x10-3 1x10-3 6x10-4 7x10-5 7x10-7(c) 1(E) PWR-6 0.3 2x10-3 8x10-4 8x10-4 1x10-3 9x10-5 7x10-5 1x10-5 6x10-6(c) 1(E) PWR-7 6x10-3 2x10-5 2x10-5 .1x10-5 2x10-5 1x10-6 1x10-6 2x10-7 4x10-5(c) 1(E) - PWR-8 2x10-3 5x10-6 1x10-4 5x10-4 1x10-6 1x10-8 0 0 4x10-5(c) N/A(E) PWR-9 3x10-6 7x10-9 1x10-7 6x10-7 1x10-7 1x10-ll 0 0 4x10-4(c) N/A (A) INCLUDES Mo, RH, IC AND CO, (B) INCLUDES ND, Y, CE, PR, NB, AM, CM, Pu, NP AND ZR, (c) PROBABILITY PER YEAR PER REACTOR, (E) WARNING TIME FOR EVACUATION (HRS) Fig 5 9 0 9
O i FRACTION OF CORE INVENTORY RELEASED CATEGORY XE+KR ORG I I CS+RB TE+SB BA+SR Ru(A) LA(B) BWR-1 1 7x10-3 0.4 0.4 0.7 0.05 0.5 5x10-3 1x10-6(C) 1.5(E) f% BWR-2 1 7x10-3 0.9 0.' 5 0.3 Q'.1 ' O.03 4x10-3 6x10-6(C) 2(E) BWR-3 1 7x10-3 0.1 0.1 0.3 0.01 0.02 3x10-3 2x10-5(C) . 2(E) BWR-4 0.6 7x10-4 8x10-4 5x10-3 4x10-3 6x10-4 6x10-4 2x10-6 R5 5x10-4 2x10-9 6x10-11 4x10-9 8x10-12 8x10 44 1x10-4(C) N/A(E) (A) INCLUDES MO, RH,TC AND CO, (B) INCLUDES ND, Y, CE, PR, NB, AM, CM, PU, NP AND ZR, (c) PROBABITIY PER REACTOR YEAR, (E) WARNING TIME-FOR EVACU-ATION (HRS) Fig 6-10
TYPE OF RISK DUE TO TMI-2 ACCIDENT - - MADE EY: AMOUNT OF Risx PROBABILITY OF ACCIDENT BROOKHAVEN REPORT 10-3 TO 10-4 PER REACTOR YEAR PROBABILITY OF ACCIDENTS RASMUSSEN REPORT 5x10-6 TO 5x10-5 pga REACTOR YEAR ACTUAL RISK OF ACCIDENTS CALCULATION: 1ACC/300 RY 3X10-3 PER REACTOR YEAR NOBLE gas RELEASED NRC STAFF
& CONSULTANTS 1.2x10 7 CI ,
NOBLE GAS RELEASED SEO IAKESHI 4.5x10 7 CI RADIOI0 DINE RELEASED NRC STAFF
& CONSULTANTS 16.7 C RADI0 IODINE RELEASED Se0 TAKESHI 6.4X10 CI TOTAL BODY DOSE TO NRC STAFF POPULATION & CONSULTANTS 1600 TO 5300 PERSON REM TOTAL-BODY DOSE TO POPULATION SEO TAKESHI ;>16200 PERSON REM THYROID DOSE TO NRC STAFF POPULATION & CONSULTANTS 1060 PERSON REM Fig. 7.
11
TYPE OF RISK DuE TO TMI-2 ACCIDENT I' LADE BY: AMOUNT OF RISK induced CANCERS NRC STAFF (EXCLUDING THYROID) & CONSULTANTS 0.15 TO 2.4 CANCER DEATHS l~NDUCED CANCERS AUTHOR OF THIS (EXCLUDING THYROID) PAPER 15 CANCER DEATHS INDUCED IHYROID NRC STAFF CANCERS & CONSULTANTS ? COST OF TMI-2 TYPE BROOKHAVEN <1,000,000,000 IN 1981 ACCIDENT . REPORTS . DOLLARS
' COST OF TMI-2 TYPE RASMUSSEN REPORTS <150,000,000 IN 1981 ACCIDENT DOLLARS COST OF TMI-2 TYPE AUTHOR OF THIS ACCIDENT REPORT > >10 9 DOLLARS COEFFICIENT OF FATAL NRC STAFF < 2x10-4 PER PERSON CANCERS & CONSULTANTS REM COEFFICIENT OF FATAL 2x10-4 TO 3x10-4 PER ,
CANCERS BEIR-III REPORT PERSON REM COEFFICIENT OF FATAL AUTHOR OF THIS CANCERS PAPER 9x10-4 PER PERSON REM COEFFICIENT OF FATAL CANCERS G0FMAN (1981) 4x10-3 PER PERSON REM INDUCED GENETIC EFFECTS NRC STAFF 0.06 TO 5.44 PER PERSON
& CONSULTANTS REM l . l l
FLg 8 o O 12
Andsrcen Act and the General Public Utilities Company (parent company of Metro-politan Edison) presented a damage claim against the Nuclear Regulatory Commis-sion for $4,000,000,000, I believe the cost of the TMI-2 type accident in dollars was underestimated by at least an order of magnitude by the Brookhaven report and by a factor of seventy by the Rasmussen report. Fig. 9 (from Fetter and Tsipis) shows the fif teen mph wind fallout patterns from a 1000 MWe reactor accident releasing one-third of its activity (i.e., 108 times the activity reported released by TMI-2). Here the two-rem isoplath line reaches from Racine almost to Detroit, while if a 1 MT weapon were detonated over Racine, the two-rem isoplath line reaches three tiems as far (i.e., to Scranton, Pennsylvania) as shown in Fig. 10. The figure at the right shows the two-rem isoplath line extending four times as far as for the 1000 MWe reactor accident. This is for the case in which the fireball reaches the reactor and vaporizes it. i ! All these patterns are those' that develop a week after the incident, and the isoplath lines are the doses a person would get if located there for one year. It is clear from the above that the 1 MT weapon explosion is much worse than _ the maximum credible reactor accident. In the event a 1000 MWe reactor core were in the fireball, the fallout deaths from a 1 MT weapon explosion could be increased severalfold. Perhaps the fuel storage pools at the reactor and the 1 waste storage tanks at the weapons reprocessing plants present a much greater risk in this respect than the reactors themselves because they are not protected with six feet of concrete, and their activity is mainly from radionuclides of much longer half-life than that fresh out of the reactor. While I emphasize the detonation of a 1 MT weapon is far, far worse than a ' conceivable reactor accident, I do not wish to convey a feeling of complacency. Although the risk of a major reactor accident is relatively quite small, it is not zero, and each nuclear power plant must have an adequate and workable emer-13
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gency plan. I have indicated that the risks seem to be much greater than the estimates of the Rasmussen report and somewhat greater than assumed by the Brookhaven report. Figs. 11 and 12 summarize some of the risk estimates of a 1000 MWe plant from the Rasmussen report. Just to focus on the early fatalities, as did the Rasmussen report, can seriously distort the seriousness of the medical problems associated with a nuclear power plant accident. Jan Beyea (Nucl. Policy Alternatives, Princeton U. , September 7, 1979), for example, gives us a much better perspective of the TMI-2 accident. TMI-0 in Fig. 13 indicates that there were zero to four deaths caused by the accident as reported (i.e., ten percent of noble gases released). Designation TMI-l through TMI-5A indicate a much more serious situation had more of the noble gases, iodine and Cs escaped. Fig. 14 shows the consequences had TMI-2 been operating much longer than three months at the time of the accidnet. It is to be noted that in this case the delayed deaths might have been up to 60,000 and that there might be 450,000 persons with thyroid nodules. Fig. 15 shows the areas contaminated to three levels: 10, 50 and 100 rem per year for the three types of accidents (left to right: (1) major accident with one-third of radionuclides of a 1000 MWe reactor released, (2) a 1 MT weapon detonation, and (3) the reactor in the fireball. If the annual dose limit were set at 100 rem in time of war, we would expect no cases of the radiation syndrome for those who received this dose at a relatively uniform dose rate over a year, 2 but the denial area would be 18 and 680 mi in cases (2) and (3), respectively. If at that time we had 100 reactors operating at 1000 MWe which were within the fireball of a 1 MT blast, this would restrict the use of 680,000 square miles except for overlap due to clustered reactors. Thus, ten percent of the area of the U. S. might be restricted from use by only 100 nuclear bombs detonated close to our reactors. 16
9 PROBABILITY' PER REACTOR
. MAGNITUDE OF EFFECT FOR EACH 1000 MWE REACTOR YEAR CORE MELT ACCIDENT 5x10-5 . ACCIDENT CAUSING 1 EARLY FATALITY 4.5x10-7 ACCIDENT CAUSING 10 EARLY FATALITIES 3x10-7 ACCIDENT CAUSING 100 EARLY FATALITIES 10-7 ACCIDENT CAUSING 1000 EARLY FATALITIES 10-8 PROBABLE WORST ACCIDENT (3500 EARLY FATALITIES 10-9 ACCIDENT CAUSING 1 EARLY ILLNESS 7x10-6 ACCIDENT CAUSING 10 EARLY. ILLNESSES 5.3x10-6 ACCIDENT CAUSING 100 EARLY ILLNESSES 2x10-6 ACCIDENT CAUSING 1000 EARLY ILLNESSES 3x10-7 ACCIDENT CAUSING 104 EARLY ILLNESSES 2,x10-8 ACCIDENT CAUSING 1 GENETIC EFFECT PER YEAR 1.5x10-5 ACCIDENT CAUSING 10 GENETIC EFFECTS PER YEAR 3.5x10-6 ACCIDENT CAUSING 100 GENETIC EFFECTS PER YEAR 1.5x10-8 Fig. II- .17
i . j' , i l l .
.q ~
PROBABILITY
..P.ER : REACT.0R . . MAGNITUDE OF' EFFECT FOR EACH 1000'MWe REACTOR' YEAR' ACCIDENT-CAUSING DAMAGE OF 10 6 DOLLARS .
4.5x10-5 ;
' ACCIDENT CAUSING DAMAGE OFDOLLARS 109 :7.5x10-7 ~
ACCIDENT CAUSING DAMAGE OF 1010 DOLLARS 4x10-9 ACCIDENT CAUSING 1 LATENT CANCER DEATH PER YR... 2.5x10-5
~
ACCIDENT CAUSING 10 LATENT CANCER DEATH'S PER YR 1'2x10-5 ACCIDENT CAUSING 100 LATENT CANCER DEATHS PER YR .2x10-6
; ACCIDEjQ_,CCAUSING 200fLLATERT_ CANCER DEaIBS PfjLYR _ W10,-9 ; ACCIDENT CAUSING 1 THYROID N0DULE.PER YR 3.3x10-5 ACCIDENT CAUSING Id0 THYROID N0DULES PER YR 1.5x10-5 ;
ACCIDENT CAUSING 1000 THYROID N0DULES PER YR 1.7x10-6 . ACCIDENT CAUSING DECONTAMINATION AREA 0F 0.1 SQ MI 5x10-5 - ACCIDENT CAUSING DECONTAMINA' TION AREA 0F 1001.6x10-6 SQ MI
! ACCIDENT.CA_U_ SING DECONTAMINATION _ AREA.0E1000_S.0 ._3x10-7 MI i
ng.ia. j . L j 18 - l .
m DELAYED IHYROID AREAS RE . CANCER. NODULE QUIRING DE-ACCIDENT DEATHS CASES TEMPORARY CONTAMINATIO DESIGNA - RELEASES TO LOW LOW AGRICULTURAL OR LONG-TERK TION ATMOSPHERE HIGH HIGH RESTRICTIONS RESTRICTIONS: THI-0 10% OF NOBLE O - 0 0 GASES (SIMI- ( i LAR TO ACTUAL ACCIDENT) RELEASES GREATER THAN ACTUALLY OCCURRED TMI-l 60% OF NOBLE 1 0 0 GASES 25 ' THI-2 5% 10 DINES 3 200 25,000 MI 2 0 PLUS 60% 350 27,000 N0BLE GASES TMI-3A TMI-2 PLUS 10% 15 200 25,000 MI 2 75 MI 2 l l OF Cs 2000 27,000 ' 3,700 MI 2 2 THI-4A 50% OF Cs 100 650 MI 12,000 3,500 175,000 MI 2 2 TMI-5A "PWR2" RE- 200 1400 Mi hgASEWL"e eie 23,000 450,000 Fig./3. 19
e DELAYED THYROID AREAS RE-CANCER N0DULE QUIRING DE-ACCIDENT DEATHS CASES TEMPORARY CONTAMINATIO DESIGNA- RELEASES TO LOW LOW AGRICULTURAL OR LONG-TERM TION ATMOSPHERE HIGH HIGH RESTRICTIONS RESTRICTIONS. CONSEQUENCES ASSUMING THE REACTOR CORE HAD BEEN IN OPERATION FOR MUCH LONGER THAN 3 MONTHS (MATURE CODE) TMI-38 TMI-2 PLUS 65 200 25,000 MI 2 550 Mi 2 10% OF $5 8500 27,000 THI-4a 50% OF Cst 440 18,000 M1 2 4300 M1 2 48,000 THI-58 "PWR2" RE- 550 3,500 175,000 MI 2 5300 M1 2 LEASE 70% 60,000 450,000 I RELEASE Fig. /$.
/
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Radioactivity R following a nuclear detonation drops off as: I
-1.2 R = ct ;
4. ;
in which t = time since the detonation and C = constant provided the induced i activity is negligible and there is no partition of the radionuclides. Thus,
-1.2 since t = 1/t, we have a simple means of estimating the dose at any time if we know the dose at some earlier or later period of time. For example, if the dose ,
i rate R g in ' the fallout area is 300 rem per hour at t g = 6 hours after the detonation, the dose rate R w uld be: 2 i R =R 1.2 = 80.3 rem /hr 2 g (t,)l1.2= 300 \18) for t =2 18 hours after the detonation and this is approximately f , t g
=R
-l R 2 1 (tlf2/t )= 300{(18j6)j l (
= 100 rem /hr Fig. 16 shows the effects of whole body irradiation of the average adult by a single dose or ute eMainistered over a few days. These affects most likely would be expected were the dose delivered to the trunk of the body. Chromosome aberrations can be detected at doses as low as one rem. Vomiting and nausea are !
the conaton consequences of all large doses. Erythemia may appear some time after 4 the exposure (several weeks) for doses above 300 rem. Exposure to beta radia-tion, in this case, delivers its dose to a skin depth of about one centimeter and i JO is particulcrly effective in producing erythemia and epilation, and at high doses (greater than 300 rad) it may cause cataracts. Fig. 17 and 18 give the general picture of what the medical doctor can ' expect following a high exposure, i.e., at low doses damage is pronounced in its suppression of the formed element of the blood, at intermediate doses (200 to 1000 rads) the damage is to the CI tract, while at high doses (greater than 1000 rads) damage to the CNS begins to appear. The midlethal dose ranges between 300 , l l 22 l
- - - - - , , ---,-m--- , , , - ,,,- vv r- m . -y-n g- < , ---
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R = c&sa.sw22 jh = $ske. i C = een/Lt efit Ri = z o o n-M. 6;t, = n f, \ /, 2 -
& 8 /.2 0 R. = .
Su i ~si) = 360 7fy = 86.3Ahn/g, 4 4 =.e/tusf x d d M r. at Ra ~ R $d = 3eo % =^ws Rg4 ' 9
.9 s g.
23 '8 e _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
I L T I P f t t v l TABLE 3. [ robs;ble Shors. 'Tern . .Efe, cts of Acade Whole Boh
' Irradiation. . .- .. w - . :. . ...-- .J . %n De e . * :. .. ., Tmeen.ss Errem .** / ' ~
t
. t .~ & s . 1 - i.. .' *.
e s. So No d,vi
seest20 eLes, emps p :bar mJa.a ble d ebs.* V llalaca ; e 6.i to,ab eldari.s.loy,escap eJ er. m n. ,eri it.ana.or. 3 2 . 110 V.-lei., a ma
. .s raa.aii se, deads ansicip. sed. .an.= M i da5.,.s.a
s. . .a nsd .Inno b .a.t ry.p i
180 = 220 Vominiar a ma
for about I dar. fallowed by other rymp.
I was s4 r>J.ani.e 4:tanns in abeus 50% es persens; no
&asha anticipassd. I 220 se 330 !
Vendetes & na ea is nearfy n!! prisen on les day. Ionowed
' by other spoptens of r=Jiar.oo s;ca6ess: abeaut 20*'. I deathe wish.e 2-6 wk. after espesure; ausvs ors convales- t eint for about 3 sne.
40D :.50(i V ,nisi s a news. Is all pen n. en Ina d.y. fano-ed by ,
other sympterre el radatise aidaess; aba a 50% of da atha Mahie I a wi.; eWrors convalexans for abous 6 roe. 350 te 730 Voeniday & Aa ea la all penenn !dda 4 hr. after empo, sure lohowed by other sympsess of radi. ties n;ciness; op se 100% deasha; few eenivers soevalecess for above 6 . sie. 8000 I
. Vome nidsurvivm.
s A maunca in su periors withis 1-2 bs.; prskabir ' M
Is.eJp4CItatMest AMs twsue1}$ alt)fj 40 pertens dga.l t.6LP G A wk.
e Fig ./7 l 1 I i l 24
, e , 6 e i 1 - i t
. .s
Darnage e
.5:' \, w GI T N,~~ ~ \, Damage ' ,o s-s -
RCNS t . n Damage ~ Qi
--- > . ~ . - ~ ~ * -_ . ,s . ,, . , . . . _ ,) /0 . .0 }., , ,O00 / 6, 4 19 -
J os e ( Revn) l ow t g.
.4 \
25 l
f and 500 rem depending on the age and health of the person and whether or not medical care is available. Probably in time of war the MLD would be about 300 rem. Fig.19 shows the differential blood count following a single exposure to a , large dose of radiation. The initial rise in the leukocyte count is observable only over the first few hours. The lymphocyte count is the most responsive to dose. 4 I will not discuss treatment of persons exposed to radiation because I do not wish to be accused of practicing medicine. The above discussion has been in reference to dose equivalent (rems). It should be kept in mind that when absorbed dose (rad) units are given we have (F#g. 20) dose equivalent (ren) = absorbed dose (rad) QN, and QN is set equal to 1 for external exposure to x, gamma and beta radiation. For neutron dose, QN is a function of the type of effect, energy of the neutrons and the time over which the dose is delivered. As a rule of thumb QN is approximately equal to two for acute exposure to fast neutrons and twenty for chronic exposure. It commonly is taken as 2.5 for thermal neutrons. This may be important if neutron bombs are used in a nuclear war. For internal dose Q = 1 for B+,
~
8,
~
e , x and Y radiations,10 for alpha and 20 for recoil atoms. N = 1 if parent element is Ra and for X and gamma radiation and for all organs exept bone. It is 5 for bone in all other cases ( a, B+, B , recoils). The body burden of a radionuclide is given by 5.4 x 10
-5 mR .
9" f 2EQN D* in which R= average , dose rate (rem /y), m = mass of organ (g), E = HeV of radionuclide and2 f is fraction in organ of that in total body. For illustration the above equation is applied to Pu-239 in Fig 20. k 26
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$% M 4 % a i ~ = ak %a g & g$f Q %%~ ~& i %). sI . ,t V e GDy 4s : g :
I g e s2 e a R ds " I o% 4 a m %}p' jk o
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o CALCULATION OF MAXIMUM PERMISSIBLE BODY BURDEN OF PU-239 FOR THE OCCUPATIONAL WORKER From ICRP Publication No. 2: T Critical body organ is bone m = 7 x 10 g. R = 30 rem /y, f 2= 0.9 E,= 5.16 MeV, Q = 10, N =5 E = = 3 4
=
0.088, Qr" ' r"
'5.4*x 10-5'mR 9~
f EQN 2 5.4 x 10 7 03.,.30' ~ 9" *
M 0.9[(5.16 x 10 x 5) + (0.088 x 20 x 5)]
But Q is now taken as 20 instesd of 10 so
'5.4 x'10-5 , . 7 x 103 x'30 '
9" = . = .02 pCi 0.9[(5.16 x 20 x 5) + (0.088 x 20 x 5)] Fig. 21 29
. e .
My principal interest during the past decade has been the induction of various types of malignancies by ionizing rad?.stion. As shown in Fig. 8, there is a very wide variation in estimates of the totc1 fatal cancer-risk coefficient as follows:
-4 By NRC staff and censultants: less than 2 x 10 per person rem 3 x -4 By BEIR III: 2 x 10 10 -4 By myself: 9 x 10 per person rem By J. Cofman: 4 x 10 -3 per person rem ~
From Hanford Study: 6 x 10 to 8 x 10~ It is to be noted that the BEIR III value will have to be raised by a factor of two because of a dosimetry error in the Hiroshima and Nagasaki atom b7mb survivor data (see K. Z. Morgan, Science, August 7, 1981). Finally, Fig. 22 indicates there is no solution to a nuclear war except prevent it by disarmament. I would like to close by saying I hope and pray this time we do not give up in our efforts to prevent a nucicar war. After Hiroshima and Nagasaki, I and many of my scientist associates spent many months traveling about the country giving lectures and trying to gain support for outlawing nucicar weapons, for strengthening the United Nations and eventually forming a world federal govern-ment. I worked with some of the leading scientists and sat around the fire with Einstein in his home discussing how we might bring this about. Senator Koeffer was our political leader, but we were before our time. When Koeffoyer died an early death, we gave up the fight in deep discouragement and frustration. National sovereignty, or the right to wage war, kill our neighbor and have the glory of being killed ourselvee was more important than sanity. Now we must organize and enlarge our efforts at home and draw in our supporters from abroad in a worldwide effort to save the human species. With God's help wc can, and this time we must succeed. . 30
g ,t ,.g g g g g puro n g g w e g g e n p 3 e c a n e m e g u.c a y y AMERICAN DEATHS IN PAST WARS $ = m,m pante IN A NUCLEAR WA ~' u!.u.:. y+i: - .;.,ay.ig:..s ,:.n y?e H h,an nu,a,ggg..mpgum?oo PRR 0 a n a,w.n nu a n n a a n,. n n ,, n ., n A. L ,,' u2RMM . m w$.arnusums.,a.ausamun@u
- RRM9 SE W 8 tSRB2 BB!%t HjJDJ2MBUUl@,UDtuuj$i"my M1H2 ,242DRMM$y!B3Dit98Dsa222% 'RRRU M RO U1 W W JtRBR WeBUjaMB!&
isHi NHn 3 o @ 3 tuR M ] " M n.v sys, war . . - *nn, nn yVy'['Q" A.n ..n.s.s a ss.y uvan v.ar "g 1"^ ^ "ggy _
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EMUUsLttumL&2nn!LAH2;'22 912$ wwi % ' Rt Unnuttu2ndMUD 2UUUR1 nnunnmcanannn aunnan - uqun.12, r. . ww11 in ,u,n M3 - s.-.Qld;Mjd.M M,12M.MM A AA R M3G.'.M3 n uttmRU " munt q gthaty WLy w ee- .
"H HUN.,&$,ER VietnamY ANRAM , ., 4 -
__ tRQkRUM
., , ,n ., -. Rt .m , n .
SOVIET DEATHS
$ = m,m PNP fe IN A NUCLEAR W; IN PAST TNARS MhSM%%MAMMhMhDA%ic.hSMM!dhh S ^ ^3 A 9 4 Wnnannnannnnn"$$$Nkk$ODMN$M wpy J go0MA ananadannnannnnnannnunnnun mm M z.
5,sg.gfja y .u_x: i,: y l$$$U?U$y&$.kRL,$j$$$$$$$$$$$) Cs.ys .l War ww:.vuas sd a n n g n a n ga n 2 nRatunuR$nM1U nn B2DDD11 n g nTp@a: n a n J.9 j g - h g (i 3$ .a w\ . M^xdhi?J.jaisigin:,hm\ .}M MJAhc
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^ ^ ^ ^ ^ ^ ^ ^ ^ a n ^ ^ h a d a d o ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ :i 3 ^ ^ ^ ^ ^ ^
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&jN[gg&nly}sb3^MS%hM tstgj j etsseguaggtssutgessa ^^ E 6anninn$s ah 6 HaahnTA E 6u nnT^I ^ ff H f f ff n'Y'+'$USMU) 3g a i ^MunhahianvidiawxuAMuutaia c0nnN n
( RfSU. .. u 'fanO^~ p H p N va'mdhr'J:Hn,p.5.as H H r Hn ac'.h n an n n n Mddadann nnn QnannnQ Ha na A M A n : n .-i ". A ' .t .s ,u o ,.dj$3 Ah
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w a ,d'2d . rgg, g,2 113,000.
-31,700,000 , . *cstimate by U.S. National Security C
yog. 3n No. I1 CORRLSPONDENCL
'83 6 !* RADIATION RISKS TRONI NUCLEAR POWER: Ahrens et al stated:"If not ingested or inhated and if kept at a } INAL ROUND dntance, nuclear wa.tes wi:: not cause cancer."Ilow can or.e tha!-
i I % de E4 terr In the Afay 22 issue of theJamat. Dr. Arthur C. lenge such a simplistic statement? Translated, it misht well f.ase j , scad;"IIman is not exposed to radiation, man will rat ha.c cancer Upton of the National Cancer Inst;rute empressed the opinion that Chivian et al., writir:g in the October 4,1979, issue, emaggerated she caused by radiation." Expoiure to radiodti e isotopes can or.If ot-risk of cancer af;er ihe Three h!;te Island incident when they sta.ed. cur by ingestion, by inhalation, by intravenous injactba. or by '
")*arl Z. h! organ, a founder of the science of health physics, es- p,ox;mity to the source to thac the isotopes act as an externat source
of radiation. "If kept at a distance": What cfistance? A thousand g timates there witt be 50 excess cancer cases in the area surroundini e
Three hiite Island." :nites away? !f so, their statement is indisputable. lf the dista nce is I j This figure of 50 cases was an off-the-cuff estimate. On the bau. s Inrh, and if some children in llanford, Washington, are p!ayin5 of early reports, I had estimated that.the total effective snan.cem near an eroded receptade that has nuclear waste Icaking from it, i dose would be about 10*; accordingly, I expected at least ux deaths the probability that they wi!! have leukemia or cancer wi:1 depend t I on the dose that they receise and their leukemogenic or carcinogen-from radiation-induced cancer. I indicated that some federal agen- ~ l j cies had initially made lower dose estimates,which had been forced ic threshold. f to increase from time to time, and that further increases could be Comervatives who believe that caution is warranted perhaps expected. Also, they had applied one of the lowest risk estimates more for our offspring than for ourselves look on the Three Sh!e Is-that they could find
cases per man-rem. I stated that if one land accident as a near disaster, rather than an encoura3 ing dem-
, used the study of Afancuso et al.' on risk estimates of cancer in ra* onstration of the " safety" of nuclear plants. Not all of us wou!d ' make the sharp separation of nuclear energy from nuclear weapons diation workers at the Hanford dump in Washington, one might ex-pect not six but about 50 cases of radiation-induced fatal oncer that Ahrens et al. insist t,n. Their experts agree that " nuclear power i , from 10* man-rems. is a small addition to the problems of proliferation of nuclear wea- . The low risk estimate of 10 ' was ba,ed mostly on data m surve" pons." But it is not small enough to prevent India, hardly the most ' ' techno!osica!!y advanced nation, from building and testing a ther-wors of the atomic bombings ofI firoshima and Nagasaki and on pa-tients with ankposing spor t!:;is treated by arradiauon. I do not nonuclear weapon. A recent artic!c in Scient,' notes that with large-l ' , beliese that these data are as applicable to mhabitants near Three scale repmcessing of nuclear fuel urder consideration," safeguards blile Island as are the data of the llanford study on a normal popu* technology is not evohing qu!ckly enough to detect agor .iiversion lation, because thejapanese, m addition to radiation, suffered from of weapons-grade plutonium." A!<hou3 h "150 tons of plutonium a terrible holocause that weakenei their immune systems. As a would be processed.~ annually,...it requires only 8 kiloyams or less result,large numbers died of common diseases, such as pneume to create a bomb."Such prospects must concern anyore who thinks rua, that have a much shorter latency period that cancer's. Rot- about the relation between nuclear power and therrnonuclear wea-blat' compared Icukemia in a Japanese group who had entered Iliroshima early after the enplosion and had received a large dose it may well be true that the Three h!ile lsland incident cannot be from neutron-induced radioactmty with 1;ukemia in a group wh imphcated in the pr'oductiori of a considerable number of t eo-
had entered later, after radiation had rnostly disappeared. lie found plaims within the next few decades. Its central importance to vi-c was as a major signal, a warning, a message that the nuclear es-i a risk of leukemia that was nine times that reported forJapanese l
who survived concurrent somung radiation and fire, blast, and dep- tablishment, with all its assurances and its apologists, must be rivation. The squation is essentially the same for patients with siewed critically and cautiously by those who believe that exposure l spondylitis: they are sick people sufferms from a disease, and,like to radiant energy should be a oided unfess there is potential enedi-the Japanese groups, many do not suruve to die of a malignant cal benefit to be deriwd. i process. It may be true that the total. body dose to the population livin5
}frastar L Asaws. .\!.D.
Boston, StA 02115 liarvard hiedical School
within 50 miles (83 km) of Three h!ile Island could be only 3300 rnan. rems; if so, I would estimate the number of cases of fatal can- *5mith RL Reprocessn3 plans may pose weapons threat. Science.1930; I -
cer to be between two and 20. Ilawever, the number of nonfatal ##-
! cases of cancer may be about three times the number of fatal cases, owing to a disproportionate number of cases of skin cancer from the l br5e beta duse. Ifnfortunately the beta dose could not be encasured 80: We do not like to prolong controversies in these columns by the meters avallable when the rrdioactive clouds passed over the and ordinarily would not have published this fourth and final round neighboring population. Some of the beta radiations from the noble ofletters. Ilowever, the subject is important, and these two letters l 5ases have ranges in excess of I cm of tissue; therefore clothing seem to us worth brin $i ng to our reader's attention. Those in- 1 t could not provide adequate protection. To these estimates of risk, of cerested in further information on the subject oflow.lesel radiation !
j ' course, must be added the risks of thyroid carcinorna from radioio. should consult the so-called ILEIR !!! report on"'!he Effects on I e dine. Populations of Exposure to Low Lesels of Ionizing Radiation,** , l I agree with the implication of the title of Upton's Ictter - that recently retcased by the National Academy of Sciences. - En. ; tadiation risks from nuclear power should not be exa5gerated. I too *
' am working for survivat of nuclear power, but I do not believe that this can be accornplished if risks are underestimated or if some risks ,
l are not e cn taken into consideration. WOh!EN IN h!EDICINE Te de Edizer: In response to your editorial "flere Come the l Kant. ~l.. h!oncAN Women"(.\!ay 29 issue): It's about time!
. Atlanta, CA 30332 .
Georgia Institute of Technology g i Karntzes hlavru, R D.
, I, blancuso T, Stewart A. Kneate G. Radiation capo.ures of planford Brighton, AfA 02:35 '
workers dying fmm cancer and other causes. I!cafth Phys. 1977; 33 349 St. Elizabeth's !!aspital
) 2. Rotbfat J. The inks for radiation workers. Batletin of Atomic Science.
September 1978.
; I 7e de Erhler: I was interested to read the comments on women {'
physicians. First of all, you enentioned that women dottors Nor!. Te de Tats: "The two letters on radiation risks from nuclear fewer hours on the aserage than do their male colleagues "llistor. power by Uptun and Ahrem et al in the h!ay 22 issue were fasci-ically, society has expected women phy sicians to fulfill i:s capecta-l nating. They opressed a 200 per cent difference in the estimated tions of the woman as wife, rnother, and hostess as well as career -
; rad;ation dose. Ahrens o al. noted a radiation do.e of "1000 l person. Indeed, I have )ct to rocet a middie-aged atten&ng ph>Si- }
person. rems," and Upton noted one of"3300 person rems" from l -l Three h!ile Island. ' clan who can claim that he did at Icast half the shoppics. laundry.
! carpooling, and cooking for his growins family.
I
i . .n.p .y . . . . . . . ; pa _. . .
, ' / ).. g . _ ._ . . . . _ _ . _ . . - . . . . _ . . - . . . . .._
y i r J, l t y ; 1.1.\\1. Illi.4 MPi M!. i%
. ._ . l __ . _ -. - 1 - - -
__ _ RISKS.SF NU_ CLEAR JOWER PLANT ACCIDENTS.AND. 3
. _, , _ l CONSEQQENCES 0N PORULATION AND BIOSPHERE
._ ._ ._ _ _ ..l ._ ._ -
j 4__ _ __ _Karl_Z . Morgan __
~ ~' ~~
i,
, - - ~ ~ - School of Nucicar En in-~ii_ erin 8_an3 Heafth 'Physr_es
_. _ _._ceorsia institute of Technotosy_ _ _ _g __
!. _ _ _' T _. _ _ Atlanta, Georgia, USA t ! i l
l 1 t l ABST.1ACT ' I t i Any estima'tes of probabilities of major nucicar power plant accidents are perforce
! only conje'ctures because we have had only 25 years of experience with commercial ! LWRs and less than 10 years experience with breeders. There have bee'n two major efforts in' the US to determine these probabilities - the Brookhaven report (1957) and the Rasmussen report (1975). The Brookhaven report provided a ba' sis for the Price Anderson Act which is a source of irritation in the US. Many considered the Bro:skhaven report exaggerated the risks and so the Rasmussen report 18 years later j was warmly received. Ilowever, shortly before the TMI-2 accident following several ; -
i near misses of serious reactor accidents, the US Nuclear Regulatory Commission : l* disengaged itself from support of the Rasmussen report. The LMFBR was a badj choice of a breeder reactor primarily because of weapons proliferation' and health e
<ffects. ,The US has 73 power reactors operating at this time so the probability j of a THI-2 accident would be once in 270 to 2700 years using the Rasmussen repo'rt ,
j valde of one in 20,000 to 200,000 per6reactor yeag. The Rasmussen report est,imate
; of a ' core melt accident of 5 x 10 to 5 x 10 per reactor per year do,es not "
compare well w k h tbe 3 300 power reactor years experience at the time of th'e TMI-2
]y accident or 3 x .t0 accidents per reactor year. The Brookhaven report. estimates P of accident,and risk probabilities come closer to this crude estimate from TMI-2.
The USNRC claims there was very little early release of noble gas and iodine ; h radionuclides and so begins its risk estiimates at 7:00 a.m. rather than at 4:00 l a.m. when the accident actually began. The early activity of the short lived [ radionuclides of n,oble gases and iodine were orders of magnitude greater than that r of Xe-133.and I-131 on which most of the dose estimates are primarily based. [. Several sources of Gata suggest the population dose was greater than the USNRC estimates!and early leakage of these short lived radionuclides may be 'the answer. 4 The USNRC estimates of risk of cancer and genetic mutations from given doses of 4 radiat ion , are low - probably by an order of magnitude - because of uncorrected .
'I biases in data based on survivors of Hiroshima and Nagasaki bombings and on the x '
j ray dose given to patients suffering with ankylosing spondylitis. i If nuclear 1 power is to be successful, we must be more honest and candid with the public and
'l find a way to prevent minor incidents from escalating into major accidents -mostly l because of failure of the human element. -
l . ? a l
~
KEYWORDS
/
Accidents, PWR, TMI-2, Noble Cases INTRODUCTION , Perhaps at the outset of this discussion I should explain that I am not an anti-nuka (a person fanatically opposed to nuclear power) nor am I a nuclear zealot like most of those in the nuclear and nuclear related industries. Many of the i,nti-nukes are poorly informed and have a case of radiation phobia such that they fear 1 mrem per year from a nuclear power plant far more than they fear 200 mrem from a completely unnecessary medical diagnostic procedure and they often ignore the risks of hydrocarbons, NO , SO* , CO, CO 2 and particulates from a fossel fueled-plant. The typical nuclear z*ealot, on the other hand, underestimates the radia-tion risks by more than an order of magnitude, gives half-truths and often resorts
;o cover-up and even censorship of information in order not to " frighten" the public. Members of this clan are often very arrogant and seem to take the attitude that " father knows what is best for the stupid public." They are .
ekillful in obtaining industrial and government support and in manipulating figures that minimize the total cost of nuclear power because they " overlook" some of the costs such as research, enforcement, radioactive waste, decommissioning, accidents, etc. I am for nuclear energy but not at all costs or at the expense of other sources of energy. I think we have made and continue to make many serious mistakes and improper choices in nuclear energy. I think some of the nuclear power plants are of poar design and poorly located and are unsafe. I believe some of them should be shut down for safety reasons, and because of high occupational exposures and potential high exposure to large populations. I will do all I can to make nuclear power operations (including the entire nuclear cycle) as safe as possible and will try to understand and make clear to others the total risks associated with ionizing radiation so they can cake some meaningful energy choices. A few of the nuclear operations go all out to support safety while others do the opposite.
,Much of this discussion is perforce hypothetical and consists of conjectures, suppositions and assumptions regarding what might happen in case of a major accident at a nuclear power plant. This is because nuclear power is relatively new and only one accident at a nuclear power plant (TMI-2) has resulted in very serious consequences. There have been more serious accidents in research reactors
{ and in plutonium producing reactors but they are not under discussion at this
; conference. Table 1 summarizes the early nuclear power operations emphasizing , that we have had only two decades of nuclear power plant experience and less than one decade experience with modern 1000 MWe reactors and experimental LMFBR's.
Here it is noted na first commercial nuclear power plants began operating at 50 1
; TABLE 1 i ; Date of l First Power Reactor Identification Operation Mwe Country and Type li Sept 1956 Each 50 UK Calder Hall (1-4)-GCR
j Nov. 1958 Each 50 UK Chapel Cross (1-4)-CCR
! Dec. 1958 Each 100 USSR Siberian (1-6)-LGR ! }; Apr. 1959 40 France Marcoule C2 (Card)-CCR l
! June 1973 1100 US Zion 1 - PWR Dec. 1973 233 France Pheonix (Card) - LMFBR 1973 350 USSR Shevchenko (BN-350)-DIFBR
FMe in the UK in September 1956 and were followed shortly by operations in the USSR and France. All the early plants were operated at .relatively low power levels and it was not until June 1973 that in the US the first plant was operated at more than 1000 MWe. It was a PWR of the type with which we are mostly concerned in this conference. Some of us also have serious reservations concerning the commercial operation of LMFBR's and the first of these is the French Phoenix which began operating commercially in December 1973. The US has in operation or various stages of construction a total of 177 nuclear power plants.with (over half of the world's FMe nucicar power capacity) but to date our operating experience is far too limited to make estimates of risk of major reactor accidents that have statis-
, tical significance. This limited experience does not provide us with an adequate basis of judging the frequency or severity of major nuclear power accidents which have been reckoned to take place only once in more than a million years per reactor. Rasmussen (1935) gives a probability of a PWR core melt category-1 accident as only 9 x 10 per reactor year.
t There have been two major studies in the US of the probability and consequences of
' nuclear power plant accidents; the first WASH-740 by a group at Brookhaven Na-tional Laboratory (1957) was prepared primarily to serve as a basis for the controversial Price-Anaerson Act which provides for ir.demnification in case of major nucicar power plant accidents. This Brookhaven report received widespread criticism from representatives of the nuclear industry which claimed it had ~
seriously exaggerated the risks by assuming greater re1 cases of radioactivity to the environment than were likely or possible, made inadequate provision for evacu-ation, of the exposed population and included other assumptions that led to esti-mates of numbers of deaths and illnesses that were too high by about two orders of magnitude. As a result a much more costly and elaborate study was conducted involving over 70 man-years of effort and an expenditure of four million dollars. - This is referred to as the Rasmussen report (1975). This report which arri"ed at
, much less severe consequences of a major nuclear power plant accident than WASH-i 740 is summarized in Table 2 along with comparative values from WASH-740. It was TABLE 2. Comparison of Consequences from Accidents in ; a 500 MWr ( 160 MWe) Reactor as Calculated in the Brookhaven Report and as Predicted in j the Rasmussen Report (1975]
1 i WASH-1400
Wash-740 Parameter Peak Peak Average Acute tubs

3,400 92 0.05 Acute 111nesces* 43,0g 200 0.01 Total Dollar Damage 9 8 1x10 Approximate Chance 1.7g10 5.g10 10 10 per Reactor I *These values should be multiplied by 6 to obtain
{ acute deaths and illnesses for a 1000 MWe power
reactor j **The Brookhaven value g gf $7x10 for 1957 dollars t was converted to $1x10 1973 dolars for comparison j with 1973 values in the Rasmussen report (1975). Both i the Brookhaven and Rasmussen values listed here should
! be multiplied by 1.6 for conversion to 1981 dollars.
i All values in this table should be escalated upward i to apply to modern nuclear power plants of 1000 FMe or more.
l A
warmly welcomed at first by the US Atomic Energy Commission and members of the f nuclear power community. For a period of 2 to 3 years it was used as the Bible which provided " reliable" estimates of the probabilities of reactor accidents of various magnitudes and furnished the "best estimates" of risks and consequences.
However, there were many close calls with power reactors operating in the 900 to 1100 MWe range; accidents such as the multi-million dollar Brown's Ferry (1067 MWe BUR) accident on March 22, 1975 and the accident at the Davis-Besse 906 MWe PWR in September 1977. The Brown's Ferry accident was caused when an inspector used a candle to check air leaks and started a fire in the insulation in a control cable channel. Perhaps it is a bit ominous that the Davis-Besse plant was one of the 8 " PWR's manufactured by Babcock & Wilcox Co. operating in the US at the time of the TMI-2 accident and TMI-2 also was one of these 8 B and W reactors. Also the Dtvis-Besse accident, like the TMI-2 accident, was due to a feedwater transient.. I
, believe this series of accidents was responsible for the fact that the US Nuclear Regulatory Commission a few weeks before the TMI-2 accident indicated it was -
disenchanted with the Rasmussen report and no longer based its risk estimates on
! the report. It should be recalled that the General Public Utilities Corp., the i parent company of Metropolitan Edison (the operator of TMI-1 and TMI-2) presented a damage claim of $4 billion against the US Nuclear Regulatory Cocsission because this government agency allegedly failed to make utilities aware of implications of how this chain of events at the Davis-Besse plant could lead to an accident of the TMI-2 type which occurred March 28, 1979. As expected, the NRC has r1jected responsibility for the TMI-2 accident and as a result GPU has announced it will ~
sue the NRC (Note: Buch passing is not limited to children each of whcm, for exampic, accuses the other of stealing the cookie; it takes place also between large utilities and powerful government agencies). Persons interested in a quick review of the major nuclear power plant accidents that have occurred in thn world are referred to a publication of Bertini (1980). Twenty-nine such accidents are described which meet one or more of seven severity criteria: (1) caused death or significant injury, (2) released significant offsite radioactivty, (3) core damage, (4) severe equipment damage, (5) caused inadvertent criticality, (6) a
; precursor to a potentially serious accident or (7) resulted in significtnt re-Covery Cost. ,
l Es t hnates of Probability of a Nuclear Power Plant Reactor Accident as Given in i Rasmussen Report The Rasmussen report (1975) used the method of event tree analysis to define i certain system failures whose probabilities were needed to determine the risk. Then the fault tree method was used to estimate the majority of these failure probabilities. Care was taken to include the various co= mon modes of failure,
, i.e. events are not necessarily independent and a single failure may increase the l probability of one or more additional failures or what causes one control or safety device to fail can cause others to fail also. After the fault trees were '
j quantified, the event tree quantification stage combined the individual fault i tree probabilities to obtain the accident sequence probabilities. All the calcu-l 1ations were based on the typical present day 1000 MWe power reactor of the PWR
' and BWR light water reactor, LWR types. The differences in effetcs/ probability curves of the PWR and BWR were less thaa the inherent uncertainties so the average j results could be applied to either type of reactor system in common use in the US i (in the US 65% of power reactors in operation or under various stages of construc-
{ tion are PWR's and 34% are BWR's). Table 3 is a summary of the risks of various
; types of power reactor accidents as obtained from Fig. 5-3 and Fig. 5-8 of the ! main Rasmussen report, (1975). )
I i
, . ; -j , f I '
l f . TABLE 3. Probability of Risks of Various Magnitudes Associated with Nuclear Power Reactors as Given in the Rasmussen Report (1975) . i Probability ! per Reac-Magnitude of Effect for Each 1000 MWe Reactor tor year .
-5 '
Core melt accident 5x10 l i - Accident causing i early fatality 4.5x10_7 : Accident causing 10 early fatalities 3x10_7 i 7 Accident causing 100 early fatalities 10-
Accident causing 1000 early fatalities 10,8 Probable worst accident (3500 early fatalities) 9 10 I
-6 i Accident causing 1 early illness 7x10 -6 Accident causing 10 early illnesses 5.3x10 -6 Accident causing 100 early illnesses 2x10,7 j
, Accidentcausing10g0earlyillnesses 3x10
-8 l Accident causing 10 early illnesses 2x10 1 I
1.5x10 -5
~
Accident causing 1 genetic effect per year -6 i Accident causing 10 genetic effects per year 3.5x10 i
-8 ;
Accident causing 100 genetic effects per year 1.5x10 6 Accident causing damage of 10 dollars 4.5x10-5 3.3x10 -5 7 Accident causing damage of 10 dollars ~
Accident causing damage of 109 dollars 1.2x10_ !

Accident causing damage of 1010do11ars j Accident causing damage of 10 dollars 7.5x10_9 4x10 i
Accident causing 1 latent cancer death per year -5 { 2.5x10 l
; Accident causing 10 latent cancer deaths per year 1.2x10[5 6 Accident causing 100 latent cancer deaths per year -
Accident causing 1000 latent cancer deaths per year 2x10_9
5x10 Accident causing 1 thyroid nodule per year 3.3x10 -5 Accident ' causing 10 thyroid nodules per year 2.5x10 -5 j Accident causing 100 thyroid nodules per year 1.5x10[5 j Accident causing 1000 thyroid nodules per year 1.7x10_6 Accident causing 8000 thyroid nodules per year 9 ,
10 i
-5
Accident causing decontamination area of 0.1 square mi 5x10 Accident causing decontamination area of I square mi 4x10 -5

Accident causing decontamination area of 10 square mi 1.8x10[56 ;
.i Accident causing decontamination area of 100 square mi 1.6x10 Accident causing decontamination area of 1000 square mi -6 3x10 .
'i A principal objective of this conference is to evaluate various estimates of the probability of occurrence of nuclear power reactor accidents and the- harmful [ consequences. Thus we would like to know actually how unreliable were the esti-mates - of the Brookhaven report (1957) and how accurate and reliable are the l {' estimates of the Rasmussen report (1975) that replaced it. I will not presume to [ answer these questions because I am not a sage or prophet '.-- perhaps a Gypsy [ i fortune-teller would give a better answer -to these questions which I am sure even !
. Solomon ' would hesitate to try to answer. The difficulty comes not. so much in '{ =; evaluating the failure probabilities of man made equipment but rather the almost !
. ! impossible task of out guessing what man might do when faced suddenly with a j variety of choices some of which he must make post- haste and other choices- that i might spell. disaster if taken in improper sequence. I am one of those people who believes we could have safer operation of nuclear power reactors if they were J j[ operated by ec.uputers rather than have us depend on " highly skilled" reactor
L
. .s i operators. TMI-2 would never have resulted ien serious consequences if its opsra-
- tion had bec1 left to the computer. The difficulty with human operators is that they often take corrective measures which make macters worse and they take reme-dial measures to keep the generators on line when there is a very weak indication the reactor should be scrammed. I believe in the rhort run the computer may not chalk-up as many MWHs on line as the human reactor operator but perhaps over the reactor lifetime fewer serious outages and mistaker would result. The computer would not likely be as cost conscious as the reactot- operator, This inferiority of the human compared with the computer is because there is a limit to bow fast the human brain can recall and process information no matter how intelligent, how calm and well trained the person may be. For example, the skilled reactor operator may without warning suddenly face 50 different possible courses of action. He cannot be certain of choosing the best of the 50 choices because it wou13. take at least seconds to follow through in his mind's eye the ultimate consequences of each course. Thus literally he must make a snap judgement since he has only seconds to decide. The computer on the other hand has all this figured out for it in advance in a calm and unhurried environment where hopefully every conceivable combination of events was carefully evaluated to the end point and if there is doubt, it scrams the reactor. The computer has the advantage of having compressed into milliseconds what its master thought through over a period of days or weeks and it very seldom " forgets" its instructions. It, of course, is not infallible but I believe with proper computer backup it would make safer choices more often than the hurried, excited and perhaps confused reactor control operator during a serious emergency. I believe for nuclear power. to be acceptable there is no question but that we must find a way to stop minor events or small incidents from escalating into major Class IX accidents (i.e. core melt accidents of categorys PWR-1 through PWR-7 in Rasmussen report (1975)). None of the PWR categories in the Rasmussen report (1975) corresponds very closely with the TMI-2 accident but the mean of the probabilitys per reactor gar of a core melt accident of cate-goriesPWR-3throughPWR-7isabout5x_jG and in the general case of a core melt the conservative estimate of 5 x 10 per reactor year is given. Thus on the average we might have expected an accident of the TMI-2 type only once in 20,000 to 200,000 years per reactor or we would expect such an accident among the 73 power reactors we now have operating in the US only once in 27 to 2700 years. Thus it seems we were very unlucky at TMI-2 or perhaps the Rasmussen estimate is not sufficiently conservative and unless effective remedial measures are taken, we can expect serious accidents with power reactors at a relatively high frequency among the more than 500 power reactors operating or under construction in the world at the present time. Perhaps one would like to place the blame specifically on the B and W type PWR's but I,believe in some respects they are actually safer than those manufactured by other companies. Perhaps in some ways the BWR's are safer than the PWR's as suggested by the Rasmussen report (1975) (which gives th4 probability per reactor gar of accidents causing one early fatality as 1.2 x 10 for the BWR and 6.2 x 10 for the PWR) but as indicated above this report states 4 this difference is not of statistical significance. The Rasmussen prediction of a TMI-2 accident is a bit better if we consider the 300 reactor years of power
; reactor operations in the US, i.e. one such accident every 70 to 700 years but '
this is little consolation. f In the case of breeder power plants we have much less experience than with LWR's because at the present time only 4 such reactors are operating commercially. Our (US) first breeder reactor experience was disappointing. Fermi, an experimental breeder, was completed in 1966 and failed spectacularly in its initial steps of Operations; it suffered a partial core melt. I believe there is no way in which
; breeders can be made safer .than the safety capability of LWR's. In fact from the
{ very advent of these porgrams I have opposed the LMFBR principally for two reasons: (1) I believe their widespresd deployment would increase greatly the r I
? .
4 risks of nuclear weapons proliferation. In this age of hijacking and clandestine operations the fresh fuel for these plants would be an extremely tempting prize of l unlimited blackmail value. The plutonium in this fuel could not be used to make as ef ficient weapons as are made from weapons grade plutonium because of the high percent of Pu-238 and Pu-240 although this percentage is less in the DiFBR re- j l cycled fuel than in the LWR fuel. However, even weapons of 50,000 T destructive-ness serreptitiously planted in Washington or New York a few months af ter the ;
'. hijacking of a reactor fuel shipment could present the president of the US with the most serious case of blackmail our country has every imagined. Such weapons could be fabricated in only a few weeks following a hijacking of LMFBR fresh fuel if rather simple preparation had been made prior to the hijacking, (2) The second reason I oppose LMFBR is because it operates on the Pu-cycle and its inventory of ! Pu and transplutonic radionuclides imposes an unacceptable radiation risk. There i are many other reasons why I have opposed DiFBR such as the positive void coef- ; ficient in the Na-coolant of some designs, its high cost, long doubling time and . Iow breeding ratic and its relative inefficiency compared with some other breeding I systems. I believe all DIFBR's should be located only in areas remote from large populations and should be supervised by and under the control of the United , Nations or a greatly strengthened IAEA. Breeders operating on the Th-U-233 cycle i circumvent many of the .indesirable features of the UEBR. This is because the U- ! 233 fuel contains enough U-232 and U-234 that the intense gamma radiation would ! seriously i pede a hijacking and clandestine operations Icading to weapons fabrica-tion and U-233 dilution with U-238 would greatly extend the time for effective and i successful serreptitious operations. And I believe in this unstabic world- ; society more time for man to learn how to live together in peace is important. ' Tabic 4 is data from Pigford (1974) which emphasizes why the LMFBR is more dangerous from the standpoint of proliferation and the accir.aulation of dangerous 3 ' transuranic elements. For clandestive weapons fabrication the U1FBR reprocessed fuel presents less problems of heat generation, spontaneous fission and dilution l because of the lower percentages of Pu-238 and Pu-240 than in the LWR which is
uranit=x fueled. It is important to note that fresh fuel for the UfFBR or LWR do I
not emit intense radiation from fission products. The first DIFBR loading is
; likely to be that from the LWR's with the composi tion of Pu isotopes as shown in j Table 4 and the first reloadings woald be like that shown for the LMFBR. ! TABLE 4. Comparison of Spent Fuel from a 1000 MWe LWR and a UIFBR with 1
Values of Relative Ha::ard of the Given Radionuclides , i ll Activity Activity ll I! Isotope of Fuel Reprocessed of Fuel Reprocessed
% by Weight of Pu in % by Weight of Pu in l llalf-lives (a)(b) yearly yearly Reprocessed Reprocessed
{ Relative (Ci g for (Ci/yh{or llazard LUR U!FBR fuchfor LWR fuel g U!FBR Pu-236 4 -6 0.85x10 0.9 0.007 10 l 2.85(ag t 3.5x10 t - Pu-238 4 5 7.57x10 2.68x10 1.8 0.77
! 86.4(a l 4.3x10}0(b) ; 152 I Pu-239 3 5 8.89x10 0.81x10 59.3 66.9 j 24,360g),
(. {.5x10 a
'h l}
TABLE 4 (cont) 4 1.00x10 5 Pu-240 1.29x10 24.0 22.4 6,580(f(b) 1.2x10 3.8 6 Pu-241 3.10x10 1.34x10 11.1 6.1 13.2(a) ~
-(b) 3.2 Pu-242 37 292 3.8 3.8 ' 5 3.79xig0((")
7.1x10 b
-2 6.2x10 3 4 Am-241 6.25x10 3.71x10 - -
460(Q(b) 2x10 16 2 Am-242m 1.10x10 1.87x10 - - 152(a)
-(b) 50 2 3 An-242 1.10x10 1.87x10 - -
1.8x10~ (a)
-(b) - ~#
7.5x10 2 3 An-243 4.74x10 1.07x10 , _ 3 7.95x10 (a)
-(b) 0.97 5 6 ; Cm-242 3.13x10 1.10x10 _ _
0.447(g)(b) 7.2x10 2.4 2 2 Cm-243 1.09x10 8.31x10 _ _
, 32(a) ; -(b)
45 4
' ', Cm-244 6.78x10 2.65x10 4 _ _
l i 18.1(a)(b) 1.4x10 32
(1) From T. H. Pigford (1974)
(2) From K. Z. Morgan (1964) Estimates of Consequences of a Power Reactor Accident as Civen in Brookhaven and
.j Rasmussen Reports j
The Brookhaven report (1957) considered various types of serious nuclear power plant accidents and consequencos in 3 cases: (1) the contained case, (2) the j volatile release case and (3) the 50% release of all fission products case. In
-j case 1 the report concluded there would be no lethal exposure and no injurys if
, t
there were evacuation in 2 hours but 6 injuries for evacuation in 24 hours. In [
. case 2 where all the volatile fission products and 1% of strontium were released j the Brookhaven report concluded there would be 2 Icthal exposures for the tempera- I ture lapse weather conditions and 900 if there were a temperature inversion at the ;
time of the release. The assumed injuries for these two weather conditions were : 10 and 13,000 respectively. For case 3 it concluded there would be no lethal exposures for a hot release (as shown in Table 2) and 3400 for a cold release; the ; assumed injuries for these two meteorological conditions were 0 and 43,000 respec- t tively. All these values were for a small nuclear power plant of only 500 MW t # ' 165 FNe so they should be multiplied by 1000/165 = 6 for comparison with the i values applying to a modern reactor or those given in the Rasmussen report (1975). ' The estimates in the Brookhaven report of probability of release were simply opinions o; knowledgeab1_g expertg. These estimatgs of thy risk of accidents-5Per to 10 for case 1, 10 to 10 for case 2 and 10 to yeagperreactorwere10 1 10 for case 3. It is to be noted that these risk estimates are much larger than ! those of the Rasmussen report (1975) summarized in Table 3. The Rasmusen report (1975) considered 9 categories of accidents for the PWR and 5 ! categories for the BWR. Both categories PWR-1 and BWR-1 refer to the largest I releases of radionuclides of any of the categories and result in stem explosions ' and rupture of the reactor with eventual leakage from the reactor building. There i is cote melt in categories FWR-1, 2, 3, 4, 5, 6, and 7 and BWR-1, 2, 3, and 4. ~! Table 5 gives the Rasmussen probabilities of release, the warning time for evacua- f tion and fractions released of core inventories of some of the radionuclides which l are considered to present the greatest threat of radiation injury and death to the , neighboring co=munity. TABLE 5. Su= nary of Accidents Involving the 1000 FMe Reactor Core L Category (d) Probability per year per reac- l tor l Warning Fraction of Core Inventory Released l Time (e) Xe+Kr Org I I Cs+Rb Te+Sb Ba+Sr Ru(a) La(b)
~3 ~3 PWR-yd) 0.9 6x10 0.7 0.4 0.4 0.05 0.4 3x10 , 9x10 - ; (e) -3 -3 0.9 7x10 0.7 0.5 0.3 0.06 0.02 4x10 l
' PWR-2fd) l 8x10 ! ,! 1(c)
~3 ! 0.9 6x10~ 0.2 0.2 0.3 0.02 0.03 3x10 ! ' PWR-3fd)
, 4x10 [
} 2(e) -3 ~3 ~b f PWR-yd) 0.6 2.x10~ 0.09 0.04 0.03 5x10 3x10 4x10 5x10 i 2(e) 2x10~ 0.03 9x10 ~3 5x10 ~3 1x10 -3 6x10 -4 -5 PWR-yd) 0.3 7x10 7x10 l 1(c) ,
0.3 2x10~ 8x10
~4 8x10 -4 1x10 -3 9x10 -5 7x10 -5 1x10 -5
PWR-6fd).
6x10
} 1(c) i
! 4
TABLE 5 (cont) .
~
2x10
-5 2x10 -5 1x10 -5 2x10 -5 1x10 -6 1x10 -6 2x10 -7 PWR-7jd) 6x10 4x10 1(c) ~ -6 -4 5x10 -4 1x10 -6 1x10 -8 )
2x10 5x10 1x10 0 PWR-8{d) 4x10
'N/A(e) -6 7x10 ~
1x10~ 6x10
~
1x10
~
1x10
~II '
3x10 O 3 PWR-9fd) fr/lo ~
-3 1 7x10 0.4 0.4 0.7 0.05 0.5 5x10 BWR-ifd) 1x10 . 1.5(e) -3 ; 1 7x10~ 0.9 0.5 0.3 0.1' O.03 4x10 BWR-2{d) 6x10 2(e) ~ ~3 1 7x10 0.1 0.1 0.3 0.01 0.02 3x10 BWR-3fd) 2x10 2(e) 0.6 7x10 -4 8x10 ' ~
5x10
-3 4x10 ~3 6x10 -4 6x10 ~4 BWR-4{d) 2x10 2(e) , ~4 2x10 ~9 6x10 ~II 4x10 -9 -12 ~IO 5x10 8x10 8x10 BWR-5{d) 1x10 N/A(e)
(a) Includes Mo, Rh, Tc and Co (b) Includes Nd, Y, Ce, Pr, Nb, Am, Cm, Pu, Np and Zr (c) Frou reference Rr mussen (1975) (d) Release category (e) Warning tire for evacuation s
! . Underestimate of Power Reactor Accident Probabilities and Risks by the US Nuclear i R_cgulatory Commission and its Contractors in the Brookhaven and Rasmussen Reports i
i As pointed out above, a principal motive that led the US Atomic Energy Commission
, to have the Brookhaven report prepared in 1957 was to provide a better basis for . indeminification in case of nuclear power plant accidents than was available from ! the actual reactor experience. Experimental reactors such as the Idaho Falls SL-1 l reactor which exploded on January 3,1961, and killed three operators and the i plutonium production reactor at Windscale, England, which caught fire on October ! , 10, 1957, releasing tens of thousands of curies of radioactive contamination into i the environment did not provide the kind of basis the USAEC or the utilities l wanted for encouraging insurance companies to insure power reactors at a reason-l able rate. They were disappointed, however, with the Brookhaven report because ; the estimates of risk were considered to be far too large. Insurance companies 8
had had no actuarial experience with power reactors and were not willing to insure j these plants and the US government was providing strong support for advancement of
, nuclear power so did not want to see them lapse and become museum pieces. The ! Brookhaven report (1957) as indicated in Table 2 provided a peak liability of ten !. billion dollars. With this information in hand the US Congress passed our Price-j Anderson Act which releaves the nuclear power industry of any liability claims ;. .beyond $560 million dollars. This means that for the peak eccident a person in 1
.., . 1 O:* , . . _ _ . . . _ . )
I _he US can collect only 3.5 cents on a 1981 dollar or 15 cents on a dollar if the cost of a 1000 MWe reactor accident is 6.25 times that of a 160 MWe reactor accident. It is noteworthy that the insurance companies whose main business and specialty is evaluation of the probability and consequence of an accident were so apprehensive about the nuclear risks that the Act had to be written to provide that they would be held liable for only 100 million dollars of the cost and the ; American taxpayer is left holding the bag to cover the remaining 460 million i dollars. Needicss to say the Price-Anderson Act is a source of considerabic ! resentment by many of us in the US. If nuclear power is as safe as heralded by the ! nuclear zealots, why can't it stand on its own feet the same as other industries? l It is bad enough for us taxpayers to have to underwrite the costs of nucicar j research, enforcement of regulation, misleading publicity (propaganda) and in-surance of this kind but why shouldn't we at least receive full compensation for any damage we sustain from a major nuclear accident? Surely there can be no justification for putting major reactor ac'cidents in the same category as " acts of God" that have limited liability coverage in some cases. The Braokhaven report (1975)haslittletosayaboutprobabiligiesof_gnaccident like the TMI-2 acci-dent but does give the probability of 10 to 10 of an accident that following a , core acit, would release significant amounts of fission products outside the ' reactor vessel but not outside the containment building. If this applies to the TMI-2 accident, they hit it within an order of magnitude because at the time of f the accident (March 28, 1979) the US had chalked up about 300 reactor years and j based on gis 1 accident (awful statistics) the probability turns out to be 1/300 nil-2 type accidents per reactor year. The highest Rasmussen value of or 3 x_g0 5 x 10 core melt accidents per reactor year on the other hand, is off by a , factor of 60. So the sagacious Brookhaven wise men made a much better prediction (or guess) in 1957 than the Rasmussen team in 1975 with all their computers and ' sophisticated forests of fault trees they employed. Regarding consequences of the TMI accident it is too early to make a good esti-mate. I believe the principal difficulty is that estimates of the US Nuclear Regulatory Commission and its consultants of the radionuclide relcues and popu- ' lation dose (person / rem) appear to be too low and probably the estimates made by Takeshi (1980) of Kyoto University, Nuclear Reactor Laboratory, are closer to fact. The values listed for comparison in Table 6 indicates the wide disparity of risk estimates. , TABLE 6. Estimates Relating to Risk to a Population as a Result of a Nuclear Accident Type of Risk Due to D11-2 Accident !- Estimatn Made by: Amount of Risk
-4 Probability of Accident Brookhaven report 10~ to 10 yggr -5 Probability of Accidents Rasmussen report 5x10 to 5x10 per reactor year Actual Risk of Accidents calculation:
_3 lacc/300 ry 3x10 per rea,: tor year Noble Cas Released NRC Staff
& Consultants 1.2x10 Ci 7
Noble Cas Released Sco Takeshi 4.5x10 Ci Radioiodine Released NRC Etaff
& Consultants 16.7 q Radiciodine Released Seo Takeshi 6.4x10 Ci , Total Body Dose to NRC Staff Population & consultants 1600 to 5300 person rem
.- - - = _ - _ _ . r-TABLE 6 (cont) , Total Body Dose to o Population Se# Takeshi * .
216200 person rem / l Thyroid Dose to NRC Staff Population & Consultants 1060 person rem g Induced.p> Cancers NRC Staff (excluding thyroid) & Consultants 0.15 to 2.4 cancer deaths /. Induced cancers Author of this (excluding thyroid) paper 15 cancer deaths i Induced thyroid NRC Staff cancers & Consultants ? Cost of TMI-2 type Brookhaven reports < 1,000,000,000 in 1981
. accident dollars i Cost of TMI-2 type Rasmur,sen reports < 150,000,000[in 1981 accident dollars .t Cost of TMI-2 type Author of this
, accident paper > > 10'_go11ars [ Coefficient of fatal NRC Staff < 2x10 per person cancers & Consultants rg Coefficient of fatal 2x10 to 3x10 4 per. cancers BEIR-III report person rem Coefficient of fatal Author of this cancers paper 4 9x10 per person rem Coefficient of fatal
~3 cancers Cofman (1981) 4x10 per person rem Induced genetic effects NRC Staff 0.06 to 5.44 per person & Consultants rem There are numerous reasons in addition to those given by Takeshi why one might doubt the accuracy of release and risk values given by the US-NRC and its consultants. For example, there were 3 monitors off scale in the vent stack in , the early period of the accident and others did not operate properly. Their i estimates of population dose hagan at 7:00 a.m. on March 28, 1979, but the l' eccident actually began at 4:00 a.m. and the dose rate from radionuclides of l iodine and noble gases of short half life was hundreds of times higher than that of those of long radiactive half life (e.g. initially the activity of Xe-138 was over 400 times that of Xe-133). It is easy to understand why they considered only the 5 noble gases (above the solid line in Table 7) because the environ-mental program did not get underway before 7:00 to 8:00 a.m. and after 4 hours
, TABLE 7. Relative Percents of Kr and Xe at Various Times after Reactor Shutdown i . Radionuclides
Half-life Percent Kr and Xe Activity Present at Various Times l Yield Oh Ih t 4h 8h 32h 40h 30d ly I
Xc-133 0.186 0.957 3.35 6.69 39.97 53.5 98.5 - l: 5.65d 6.62% ' L Xc-133m - - - 0.40 1.93 2.48 0.02 - 2.2d
, 0.166%
Xe-135 2.65 12.65 35.72 53.88 57.9 43.9 - - i 9.1h 6.3% 1
. TABLE 7 (cont)
Xe-135m 1.53 0.48 - - - - - - 15m 0.1% , Kr-88 4.87 19.60 33.1 25.19 - - - - 2.8h 3.57% Xe-131m - - - - - 0.11 1.22 - ( 11.9d 0.025% ! Kr-85( - - - - - - 0.25 100 10.7y I 0.293% { Kr-85m 0.73 3.75 8.38 9.29 0.50 - - - 4.Sh 1.0%- Kr-87 8.83 26.7 19.2 4.54 - - - - f 1.3h 3% Xe-138 81.1 36.1 - - - - - - 17m 6% , (1) Percents assuming equilibrium; the actual percents would be somewhat less for Kr-85. the other radionuclides listed in Table 7 made only a small contribution to the population dose. However, during the'first hour they contributed almost all the ~ dose from the radioactive cloud passing over the country side unless there were ! some unspecified hold up in release at the disabled reactor. Even at the close of this first hour Xe-138, Kr-87 and Kr-85m were contributing 67% of this noble gas dose and af ter 4 hours Kr-;;m and Kr-87 were contributing 28% of this dose. The wind during. this period was blowing at about 2 miles per hour in the west and , north-west direction or in general toward Harrisburg, the center of which was *
about 12 miles away. Thus people in the direction of the nearest large city must have received considerable dose from the intense gamma emitting radionuclides Kr-
', 87 and Xc-138 during this early period -- a dose that apparently was not taken into account. Some of the reports suggested the population dose was due mostly to ,
Xe-133 but this was true only if most of the dose was delivered 40 hours or more [ after 4:00 a.m. on March 28, 1979. Of course, after a few months essentially all j the dose from the escaping noble gases was due to Kr-85. Fortunately TMI-2 had I [: operated only a few GWe months at the time of the accident so the Kr-85 inventory , was far below saturation. The short lived radioisotopes of iodine present a ; similar prob 1cm to that of the noble gases. Here again the big question is the j i hold up. thne provided by the wet and otherwise damaged charcoal filter system. ' The reports of the NRC consultants state that most of the radiciodine released from the TMI-2 accident was I-131. If there were no appreciable hold up by the' .t damaged filters, the activity of the I-133 (20.8h, yield 6.9) would exceed that of
.' 1-131 (8d, yield 3.07) and during the first few hours the activity of I-132,1-133 l
plus I-135 would be far in excess of that of I-131. Noble gas and radioiodine < could have 1 caked from the TMI-2 facility from a number of places yet the official j ' reports claim no significant release except via the plant vent. The USNRC (1980) ,
concluded "that no relationship can be este'lished between the operation of TMI or j the accidental releases of radioactivity and reported health effects" in spite of j the fact that of 96 farms containing between 9000 and 10,000 herd of livestock c
s b a N ; .. ' there were 11 ~ farms reporting problems characteristic Sf radiation 'sickn[sU Recent studies (Field, Field, Zegers and Steucek, 1981) however, lead me to question this conclusion of the USNRC and its estimate of only 16.7 Ci of I-131 , release. This group mcasured the I-131 concentration in thyroids of voles trapped
at three ef ter the sites in the vicinity accident) and found of TMI-2 I-131 in between thyroidsApril of all 6 and 16,1979, those animals. (9 .to These 19 days , !
animals are particularly well suited as monitoring " instr iments" because they ^ have a very limited home range (< 0.66 ha) and they consume a variety of vegeta- i tion equivalent to 1/3 their body weight per day. They found the mean I-131 i concentration in the thyroids of voles at the site III (1.9 km from TMI-2) was i 1860 pCi/g.* Assumin g person had this I-131 concentration I eptimate his dose j rate would be 4.3 x 10 Q = 8 rem /y. Of course, I-129 (1.7 x 10 y) was at a low : concentration in the melted fuel elements because of the short time the reactor I had operated. I believe with so many radiation detection instruments.paralized l from high doses and others operating erratically I cannot accept the claim that there were no significant airborn releases during the first 3 hours ofithe acci-dent. Federal and state officials acknowledged they could not gauge exactly how much radioactive material escaped to the environment and that there'are some unanswered questions about the releases so u. is doubtful ye will ever know all ! i that went on during these first very critical and hectic 3 hours. Perhaps if more cancers than expected show up in the exposed population 20 to 30 years from now we ; will have a better answer to some questions being asked. It is unfortunate the ! first measurements from the air were not made a least within the first hour of the i accident. Ihe aerial monitoring of the cloud did not get underway until'4:00 p.m. l March 28, 1979, (12 hours af ter the accident began). Such measurements made early ; would have told not only where the cloud went but its radionuclide composition and 3 provided a more reliable method of estimating the population dose. We should have ! ' learned a lesson from the British during their Windscale accident (October 10, , 1957). They found early information provided by flights of small aircraf t was ; ! very valuable. The TLD meters at 20 TMI stations provided a very unsatisfactory i : basis for estimating the population dose from a passing cloud of radioactivity. ! This was especially true since during the first day only 2 of the stations were at , any time anywhere near the passing cloud and it was this early radioactive cloud 1 that delivered most of the total body dose to the population. When two TLD meters ! were placed at the same station, the readings often differed by a factor of two or more and on a given day the TLD readings at various stations differed by factors
; of several hundred. Thus it is very likely some persons received doses several - '
I hundred times that recorded at the 20 stations. ;
, None of the utility TLD's measured the beta dose during the early period. The NRC l contractors made a weak effort to estimate the beta dose but mostly that from Xe-t 133 (go.346), Xe-133m (e 0.198, 0.227), Xe-135 (#0.92, E 0.214) and 1-131 i
1 ( 0.806, 0.606) and they estimated the dose at 70 m below the skin surface. j They should have considered the higher energy 1 .as from the noble gas and iodine
; radionuclides with high beta energies, e.g. Kr-85m ( B 0.82), Kr-87 (B 2.8), Xe- ; 138 (B 2.4), I-132 ( B 2.12) and I-133 (g l.27). Also, they should have considered i the dose at lesser depths where much of the melanin of the skin is located because j malignant melanoma, unlike basal cell and squamous cell carcinoma, is the kind of radiation induced skin cancer that has a poor response to medical treatment and is ! very of ten fatal. Beta rays of Xc-138 which had the highest of the nobic gas j activities in the early period, for example, have a range in soft body tissue of } about I cm or a range in air of about 10 m. Thus they delivered dose not only to l the melanon of the skin but to the lense of the eye, some of the lymph nodes and 3
male gonads. Thus cataractagenesis and tumors of the lymph nodes as well as genetic mutations could be the consequence. { I I
. __ - __ - - _ - _ - - =- - - _ - . . _. - ... _
If the General Public Utilities is successful in collecting its damage claim of 4 billion dollars from the USNRC, the Rasmussen estimates of cost of a nuclear accident such as that of TMI-2 are off by more than a factor of 25 for this one account alone. Already a consolidated class action complaint filed under the i Price-Anderson Act is being settled for $25 million and with the passage of time ! e can expect individual damage claims to escalate the costs into the billions of i doliars. Although this TMI-2 accident was far less severe by orders of magnitude in terms of injuries and deaths than the peak accident hypothecated by the Brook-haven report (1957) (i.e. no acute deaths vs 3400 hypothecated) the final cost may be close to the $10 billion shown in Table 2. It is likely that much of the costs of a nucicar accident will be hidden. For example, electric bills in the IMI-2 area have increased 30 percent and it is reported that Metropolitan Edison Co. has
. requested a rate hike of $76.5 million and proposed that every consumer of nuclear power throughout the US be billed 100 per month to help defray the cost of the . ; accident.
I I Long Range Risks of a Nuclear Accident As indicated above there are both the short range and long range causes of damage, j- inury and deat:h from a nuclear power plant accident. The original Rasmussen i report (1975) did not give adequate consideration to the long range dose / effects and especially the contribution by Cs-137 and as a result underestimated.the population dose by a factor of 25 as pointed out by the American Physical Society
. (1975) LWR Safety Study. Fortunately this correction was made in the final , report. Because of the relative recoteness of most nuclear power plants I believe '
l the number of injuries and deaths from a major accident will be far greater from i the long range effects than from those of short range. Table 8 from the Rasmussen i ):! , TABLE 8. Relative Importance of Various Radionuclides for Health Effects Following A Nuclear Power Plant Accident
' Radio- Early Effects Late Effects ! i nuclide . Inhalation Inhalation i ! '
CD GD BM L GI Th T GD BM L MB 'O T Z
, Te-122 1 2 2 2 2 1 2 -
2 2 2 2 2 22 i Cs-134 - - 2 1 - - 2 2 2 1 2 2 2 16
! I-131 1 2 1 1 -
2 1 - 1 1 1 1 1 13 l I-133 2 2 1 1 1 1 1 - 1 1 - 1 1 13 [ 1 i 1-135 2 2 1 1 1 1 1 - 1 1 - 1 1 13 .j I-132 2 2 1 1 - - 1 - 1 1 - 1 1 11
; Ba-140 -
1 2 - 2 - 1 - 2 - 1 1 1 11 Cs-137 - - 1 - - - 1 2 1 - 1 2 2 10 ' l Sr-89 - - 2 - 1 - 1 - 2 - 2 1 1 10 i 2-Substantial contribution to dose { 1-Small but important contribution to dose !i CD-Cloud Dose L-Lung Dose MB-Mneod Bone Dose
!I GD-Cround Dose Gd-CIT Dose 0-Other Dose
{ BM-Bone Marrow Dose Th-Thyroid Dose T-Testes Dose ,
i

j report (1975) lists the radionuclides that are considered to be of greatest concern both for short and long rance consequences. I believe weighting factors j much larger than 2 should be given to I-131 and Cs-137 so that they would come

g first in this listing. Also there are accident scenarios in which relatively "a large amounts of actinide radionuclides escape into the environment and these
,1 could cause very serious environmental contamination lasting over many centuries.
ai Hany studies have shown that-when these elements contaminate the environment, ;
1 -
.{
natural as well as commercial chelating agents in the soil increase their uptake i f rom the soil by roots of plants by orders of magnitude. Even the use of chlorine in water from city reservoirs can increase the human uptake of these radionuclides by two to three orders of magnitude. Standard agricultural practices will not greatly modify the distribution of these elements in the soil, hence they would have only a minor effect upon uptake by crops planted for human consumption. Then too there is the worldwide genetic and somatic problem due to the release of C-14 and H-3 into the environment. The studies of the Heidelberg (1978) group have shown that the USNRC and its consultants, the authors of the Brookhaven and Rasmussen reports and those preparing risk estimates for environmental impact statements of the utilities have in many cases used questionably low and unrealis-tic values for factors that go into the calculation of dose to man, i.e. transfer from soil into plants, from fodder into animal products, from the GI tract into the blood, from blood into the various body organs and for the biological half lives in these organs. In some cases there may be serious special problems such as co-58 and Co-60 bound in vitamin B-12 or radioiodine damaging the thyroid of
; the fetus during its early development. In any case when there are large releases ; of radioiodine there will be many cases of the thyroid nodules (as shown in Talbe 3), a large number of cases of thyroid diseases Icading to some serious conse-quences and numerous thyroid carcinomas. Among those highly exposed survivors of a nearby major nuclear power plant accident there will be lenticular opecities (some of which may develop into cataracts), chromosomal aberrations in the peri-pheral blood lymphocytes, impairment of growth, microcephaly, mental retardation and an increase in all forms of cancer with the possible exception of chronic lymphatic leukemia. Many of the cancers will be benign and about half of the cancers will respond successfully to medical treatment but all can be costly in terms of medical bills and suffering and expensive law suits. The peak period for maximum anomalies from exposure to the fetus is about age 20 to 25 days. Unfor-tunately, some women may not realize they are pregnant during the period of maxi =um radiosensitivity of the human. Some have criticized :he governor of Pennsylvania for calling for evacuation of pregnant women living nearby during the TMI-2 accident but I feel this was a very wise move and after many costly cases I
have been settled in court I suspect these same critics will abrade the governor for not calling the evacuation earlier after 4:00 p.m. on March 28, 1979. I One type of damage that is seldom considered is psychological in nature (e.g. anxiety, stress, mental breakdown, suicide). A $375,000 stress survey of pregnant l' mothers during the TMI-2 accident has shown this to be a matter of considerable important and the insurance companies may hear more from these mothers in the days
) ahead.
i j There have been many reports addre= sing the generic question of risks associated
j with accidents at nuclear power plants. One of these reports which I found of l
j particular interest and value was prepared by Beyca (1979) of the Program on t Nuc1 car Policy Alternatives at Princeton University. This report considers the l TMI-2 accident where releases were of various hypothetical magnitudes as indi-
cated in Table 9. This report is of great interest because it indicates what we i might expect in terms of long term consequences if a TMI-2 type accident were to j l progress to various stages of severity. The higher risks are related almost
'j entirely to higher releases of radioactive cesium. t n 1: - l I
.+, .. . TABLE 9. Srm2 Ling-Tarm Contsquincas of,l_typothatical Accidents at Three Mile Island'"'
(Not including any early illness or deaths which might be associated with high doses to unevacuated population a few tens of miles from the reactor.) Delayed Thyroid Temporary Areas Requiring Cancer Nodule Agricultural Decontamina-Accident Deathe ** Cases *'* Temporary tion or Long - Designa- Releases to low low Agricultural term tion Atmosphere- high high Restrictions Restrictions THI-0 10% of noble 0 - 0 0 gatas (simi- 4 lar to actual accident) RELEASES GREATER THAN ACTUALLY OCCURRED TMI-1 60% of noble J 0 0 gases 25 TNI-2 5% Iodines 3 200 253 0g 0 0 NSieghses 350 27,000 mi TMI-3a TMI-2 plus 10% 15 200 250gg g5 3 of CE 2000 27,000 mi mi TMI-4a 50% of Ce k) 100 37gg 6g0 3 12,000 mi mi TMI-Sa "PWR2" Re- 200 3,500 14g0 17g,gg0 lease with 23,000 450,000 mi mi CONSEQUENCES ASSUMING THE REACIOR CORE HAD BEEN IN OPERATION FOR MUCH LONGER THAN 3 MONTHS (MATURE CORE)
} TMI-3b TMI-2 plus 65 200 250gg 3 5g0 10% of Ce 8500 27,000 mi mi , TMI-4b 50% of ce k) 440 180gg 43g0 l 3 48,000 mi mi i THI-5b "PWR2"gge- 550 3,500 53g0 17g,gg0 t lease 60,000 450,000 mi mi ! 70% I Re-i lease ~
l Footnotes for Table 9
a) All ac'cidents are assumed to take place under " typical" meteorological condi-j tions. Wind shifts and changes in weather neglected. Health effects are
} totalled for people living beyond 50_ miles. ? b) Cumulative total over a 75 year period after the accident. The range of I
genetic defects would be equal, very roughly, to the range of delayed cancer deaths. { c) The low number is for the most favorable wind direction (Eastern Maryland), f assuming the most optimistic coefficient relating dose to health effects, and 1
.I i
( -
. /
4 l , TABLE 9 (cont) ' and evacuation out to 50 miles. (Without evacuation, the lo. umber would be ! a factor of 2-5 higher depending on the accident.) The high number is for the least favorable wind direction (N.Y.C./ Boston) and assuming the most pessimistic coefficient relating dose to health effects. (Evacuation is also assumed out to 50 miles, but has a small impact on the high results.) d) Reduce high value by a factor of about 4 to obtain the prediction which wculd result using the Rasmussen Study Model. Multiply by 4 to obtain
; the prediction which would result using health effects coefficients based on data of Mancuso, Stewart and Kneale. ;
e) Cumulative total over a 25 year period after the accicent. A blank entry implies a small number. f) Details given in reference report, Beyea (1979). g) Milk restrictions (Beyea 1979). Much of this area would be water for a wind from the west. h) First year crop restrictions. (Harvested food not suitable for cl i1dren. ) Much of this area could be water for a wind from the West. i) A JWR2 accident as defined in the Rasmussen (1975) Study. A core melt l with breach of containment due co overpressure. j) This number possibly could be reduced in half if massive decontamina- ' tion or relocation efforts were undertaken in urban areas to avoid low-level radiation doses. k) Assumes only Cs released to e=phasize that Cs dominates long term consequences. i, Genetic Consequences of a Nuclear Power Plant Accident The evaluation of genetic damage resulting from a nuclear poter accident has been almost neglected in the various accident reports and I will have very little to say about it here because I like the others realize how little we know in a quantitative set.s e about the genetic risks from radiation exposure of a human population. Beyea in Table 9 note (b) simply states the genetic defects would about equal the number of delayed cancer deaths. I react strongly against state-ments of some nuclear advocates who imply the genetic risk is negligible by reminding us that no genetic effects have been observed among the offspring of survivors of atomic bombings of Hiroshima and Nagasaki. First of all the popula-tion is too small and the time too short and second, there have been some observed genetic effects. The sex ratio change was in the direction one would expect (i.e.
more daughters than sons of exposed fathers) but the results so far (1974), are i not of statistical significance. The Neel-Kato-Schull (1974) study examined dominant genetic diseases among these Japanese survivors; diseases which may be expected to cause death early in life in children before the age of 17. They found a very significant elevation in these diseases among children whose parents re-ceived radiation exposure. Several animal studies have indicated an increase in chromasomal aberrations where both rearranged chromosomes do not have the normal gene content. This can result in genetic mutations of equal or greater genetic damage than those resulting from single gene mutations. Down's syndrome resulting from an extra representative of chromosome 21, has been reported in some studies of human populations to relate to exposure to ionizing radiation. If we are con-i cerned about the quality of the human race, we should be most concerned about the non-visibic mutations; mutation which cannot be easily detected in animal studies
, . but which relate to man's superior abilities, his originality, his resilience, his mental vigor, etc. It was this kind of radiation damage that mostly. concerned Dr.- i
a Muller (1964), the great geneticist. Perhaps at the present time there is no
'better source of information for estimating the genetic risk from exposure to ionizing radiatin than the BEIR-III (1980) report. The reader is referred also to BEIR-I (1972) and the UNSCEAR report (1972) for detailed information. Many of our common diseases relate to our genetic inheritance and so any contribution radia-tion exposure makes either to dominant or recessive mutations places a serious added burden on our children and on future generations. Some of the values of genetic risk given in the above reference reports have been reduced by as much as a factor of 10 to take advantage of the lower risk estimates at low doses and low dose rates. However, one should be cautious in using these reduced values because some publications (Lyon 1972) suggest these reductions are not warranted and they certaintly would not be applicabic in cases of high exposure and high dose rates.
The BEIR-III report adopts rather arbitrarily the overall genetic risk coeffi-cient of 0.004 to 0.02 genetic mutations per rem or a doubling dose of 50 to 250 rem. Thus if this is applicable to the estLuated total body population dose due to the TMI-2 accident this would correspond to (1600 to 16,200) x (0.004 to 0.02) or 6.4 to 324 genetic mutations introduced into the population by this accident. Table 3 from the Rasmussen report indicates the probability of a_guclear power plant accident which causes 100 genetic effects is only 1.5 x 10 ggr reactor year and one causing 10 genetic defects has a probability of 3.5 x 10 so again the Rasmussen report does not seem to fi"d confirmation within many orders of magnitude. Consideration of the genetic risks becomes especially important in terms of gene-tic damage to the world population in the case of H-3, C-14 and P-32 which are incorporated in DNA in the germ cells. Here transmutation to other elements in the cell neucleus (i.e. H-3 to He-3, C-14 to N-14 and P-32 to S-32) as well as local ionization contribute to the genetic damage. The Risk of Radiation Induced Cancer Perforce, during the early period most of the studies on the effects of low-level exposure were conducted on inbread animals rather than on man. These animal studies in many cases grossly underestbnated the cancer risk to man because of the greater radiosensitivity of man, because man is a heterogenous animal and because many types of cancer have long incubation periods that are longer than the life span of most experimental animals; cancar incidence, of course, relates to time eince a given exposure and not . fraction of life span. Most human studies cover ! periods less than ten to twenty years, so additional cancers appearing af ter completion of a study can only increase the risk estimate. In recent times it has
been possible to conduct a limited number of extensive epidemiological studies of humans exposed to low icvels of radiation (Oxford in utero x-ray exposure studies l of Stewart and Kneale (1970); studies of Modan Baidatz, Mart, Steinitz, and Levin (1974) of persons whose scalps were x-rayed for ringworm; studies of Hanford j radiation workers by Mancuso, Stewart and Kneale (1977); etc.). These studies i reveal a cancer risk that is ten to fif ty times the risk suggested from many of the animal studies or as indicated by studies of survivors of atomic bombings of
{ Hiroshima and Nagasaki and of ankylosing spondylitis patients treated with x-
) rays.-
The folly of placing reliance on animal experiments was emphasized by a study of
; Shicids Warren and Cates (1971). They exposed two strains of mice to identical , regimes of x-ray doses. In one strain there was a high incidence of leukemia and ; significant life shortening while in the other strain of mice there was hardly any ; observable effect.
I l
I t
)
Unfortunately, - the standards-setting bodies have accepted two human studies (i.e., Japanese bomb survivors and spondylitis patients) as though they were the . inspired word and have not attempted to evaluate the dose esimtates or to examine their seriousges 1 (Morgan 1981) believe the dose to the Japanese survivors t' was :t '@
' = that assumed in the BEIR-III report (1980). Thus the cancer risk estimate must be increased. The most significant of the biases introduced by the standards-setting bodies and especially by the BEIR-III report and our recent General Accounting Office (GAO), (1981) report result from failure to account for after-effects of fire, blast and a traumatic situation faced by the Japanese survivors. The physical injuries along with conconitant pain and mental anguish resulted in a weakening of the immune (reticuloendythelial) system such that they could no longer fight off the ravages of common diseases; as a result many died early before cancer manifest itself. The weaker members who already had a large probability of developing cancer or had cancer in stiu were the first to die of connon diseases. Many of those who survived these early diseases succumbed later to cancer; leukemias reaching a peak incidence during a period of six to eleven years. Later, and even now, all other types of malignancy (with the exception of chronic lymphatic leukemia) have been on the increase. A somewhat similar bias -
exists in the case of patients with ankylosing spondylitis. These are sick persons suffering with a painful and serious disease such that studies of Radford, ! Doll and Smith (1977) indicate they too die early of common diseases-during the j usual latency period of most cancers. Kneale and Stewart (1978a, 1978b) have i shown that persons with in situ cancer have a propensity, a large cross section - i for, or are in grave danger of dying from secondary infections and accidents j, before malignancies are diagnosed clinically. This is shown to result from the j' fact that the precancer state is associated with lowered immunological compe-t
tence.
! There are, of course, ways of correcting the biases from fire, blast, etc.; but i this was not done in the case of Hiroshima and Nagasaki. Mortality patterns have been studied in - a number of cities following ordinary bombing, fires, floods, - ! earthquakes, etc. In many cases the increased death rate from common causes in !- the year following the disaster was much greater than during the year before it, , , and in every case the death rates were higher among the weaker segments of the
] population. It is difficult to appreciate the fact that the national and interna-ll tional standards setting bodies have leaned over backwards to try to depreciate
,j and discredit the Mancuso-Hanford study (Mancuso, 1977) where the dosimetry was
i the best in existence anywhere and did not faret out large errors in dosimetry in
!i the Japanese data (their hallmark reference). In addition, even the critics !.! agreed there was a singificant increase of two malignancies-cancer of the pan-creas, and multiple myeloma relating to Hanford radiation exposures. t
l. In the simple case, risk of cancer from lowglevel exposure to ionizing radiation i may be given by the relation P(d) = a + bd in which P(d) is the probability of
! succumbing to a malignancy from a dose d(rem), and a, b and k are constants. When } k = 1 we have the linear hypothesis, when k > 1 we have the threshold hypothesis ij (because at low doses the error bars overlap the abscissa), and when k < 1 we have 'i the superlinear hypothesis. Baum (1978) was one of the first of a number of ; researchers to show that k < 1, or the superlinear relation gives the best fit for j a number of malignancies among the survivors of Hiroshima and Naga_saki bombings ! (i.e., k = -0.5 for all malignancies at Hiroshoma; k = 0.8 for acute leukemia at l Nagasaki, k = 0.86 for leukemia at Hiroshima, and for the combined cities k = 0.19 l for lung cancer, k = 0.35 for stomach cancer and k = 0.5 for female breast cancer.
j It should be noted that since recent investigations (Morgan, 1981) show the dose a to the Japanese bomb survivors was less than assumed by Baum and by BEIR-III f (1980) and -GA0(1981) Connittees, the values of K are less than the values shown l ; above or superlinearity in now more pronounced. A series of papers (Baum, 1973; l]i . l
-~ - _ _ _ ,_ _ _ . _ _ _ _ - . . _ . _ _ . . . _ _ _ _ . _ _ ___ -_ _ _ , _
Parker, Balsky, Yamamoto, Kawamoto and Keehn, 1973; Silverman and Schmitz-l . Feuerhake, Muschol, Batjer and Schafer, 1978) strongly suggests that the induc-tion of thyroid carcinoma at. low doses of ionizing radiatica is more serious than was thought a decade ago and that k < 1, or it too may be best represented by a superlinear relation to dose. - In their analysis of the ankylosing spondylitis data on x-ray induced leukemia the GAO (1981) concluded, "All mixed models tested did much better than the linear model, and the unusual square root-cubic model did the best of all." Since at doses less than 100 rem their cubic term ' contributed < 1% to the cancer risk, P(d), this means that at low doses the best fit related to k = 0.5 or P(d)a d.
g. The CAO (1981) report concluded that for the Japanese survivors, " Dose-response curves that were square root, linear, quadratic or cubic-at low levels all gave acceptable fits for at least one set of data" and that " highly sensi* *va groups at t
low doses could lead to dose-response curves for the entire population that show larger effects per rad at low than at high doses", i.e., a superlinear relation-ship. The BEIR-III (1980) . Committee stated, "the existence of exquisitely i. sensitive subgroups of suitable size conceivably would produce a dose-response curve that showed a greater effect per rad at very low doses than at high." I believe there is strong evidence from studies of Bross (1972) and'others for the i existence of such radiosensitive subgroups in a heterogeneous population of humans that may not be apparent in a group of the usual homogenecus inbred animals i that are studied to find dose-effect relationships and that the results of such , animal studies can and have led to false assumptions about human populations. Many scientists in examining the information on the effects of low level exposure
. to ionizing radiation have concluded the coefficient of risk of cancer as used by i .
the standards setting bodies and as applied in the foregoing discussion are too i low. I agree with these scientists but in view of poor statistics in most cases I. and biases and errors in dosimetry that have not been corrected I am unable to fix
,l fimly on a specific number at this time. For the pres _eyt, however, I am using the general value applied to a mixed population of 9 x 10 lethal cancers per person I
' ' rem and twice this number for the total cancer risk. Gofman (1981) gakes an ~ excellent review of the cancer risk in man and arrives at 3.8 x 10 lethal i'; cancers per_ gerson rem. The value from the Hanford Stduies is slightly larger (v 7.5 x 10 lethal cancers per person rem) Govgrnment officials in the US used l; i the lowest risk estimate they could find (1 x 10 lethal cancers per person rem)
; immediately af ter the TMI-2 accident presumably to " play down" the risks. If the ! super' linear relationship-holds to every low doses, the risk of small increments
[j to population dose emy be even greater than the Hanford value. Unless man is to lI have the burden o_f 4 Proof for his own safety, we cannot afford to use a smaller l ; value than 9 x 10 lethal cancers per person rem. I
)! REFERENCES i'
l American Physical Soc. (1975). Study group on light water reactor safety. Rev.
} Modern Phys. 47, Suppl. 1 !l 1 l .; Baum, J. W. (1973). Population heterogeneity hypothesis on radiation-induced can-cer, Haalth Physics 25, 97 ?.
( BEIR Report -(1972). The effects on populations of exposure to low levels of j ionizing radiation. National Research Council. Washington, D.C. 8 l- BEIR Report (1980). The effects on populations of exposure to low levels of [ ionizing radiation. National Research Council. Washington, D.C. i w
Bertini, H. W. (1980). Descriptions of selected accidents that have occurred at nucicar reactor facilities. Oak Ridge Nat. Lab. ORNL/NSIC-176 Beyea, J. (1979). Some long-term consequences of hypothetical major release of radioactivity to the atmosphere from Three Mile Island. Program on Nuclear Policy Alternatives, Princeton Univ., Princeton, NJ Brookhaven (1957). Theoretical possibilities and consequences of major accidents in large nuclear power plants. A report prepared by staff members of Brookhaven National Laboratory and its consultants. USAEC-WASH-740 Bross, I. D. J. (1972). Leukemia from low-level radiation, New England J. Med., 287:107 Field, R. W. , E. H. Field, D. A. Zegers and G. L. Steucek (1981). Iodine-131 in thyroids of the meadow vole (microtus Pennsylvanicus) in the vicinity of TMI nucicar generating plant. Health Phys. 41, 2, 297 GAO Report to the Congress of the U.S. (1981) Problems in assessing the cancer risks of low-level ionizing radiation exposure. 2 Gofman, J. W. (1981). Use of Gofwan's doubling dose estimating low-level radia-tion risk and response. Health Phys. 41, 1, 204 Heidelberg Study (1978). Radiological assessment of the WYHL nuclear power plant. Dept. of Environmental Protection of Univ. of Heidelberg, Germany Kneale, G. W. and A. M. Stewart (1978). Precancers and liability to other dis ea ses. Br. J. Cancer Kneale, G. W.; A. M. Stewart; and T. F. Mancuso (1978). Reanalysis of data relating to the Hanford Study of the cancer risk of radiation workers, Interna-tional Atomic Energy Agency Conference, Vienna, Austria i Lyon, M. F.; D. G. Papworth and R. J. S. Phillips. Dose rate and mutation frequency after irradiation of mouse spermatognia. Nature New Biol. 238, 101 Mancuso, T. F.; A. M. Stewart; and G. W. Kneale; (1977) Radiation exposure of Hanford workers dying of cancer and other causes. Health Physics 33, 5, 369 j Modan, B; D. Baidatz; H. Mart; R. Steinitz; and S. G. Levin; (1974) Radiation-induced head and neck tumors. Lancet, 23, 277 , I i Morgan, K. Z. ; W. S. Snyder and M. R. Ford (1964). Relative hazard of the various l radioactive materials. Health Phys. 10, 151 i Morgan, K. Z. (1981). Radiation dosimetry. Science 263, 4508, 604
; Muller, H. J. (1964) Radiation and heredity. Amer. J. Public Health, Sup. Vol. . 51, 1 I Neel, J. V. ; H. Kato and W. L. Schull (1974). Mortality in the children of atomic j bomb survivors and controls. Genetics 76,, 311 l Parker, L. N.; J. L. Belsky; T. Yamanoto; S. Kawamoto; and R. J. Keehn (1973).
Thyroid car'cinoma diagnosed between 13 and 26 years after exposure to atomic { radiation, ABCC-Tech. Report 5-73 I
. e e Pigford, T. H. (1974). Radioactivity in plutonium, americeum and curium in nuclear reactor fuel. Univ. California, Berkeley, CA Radford, E. P.; R. Doll; and P. G. Smith (1977) Mortality among patients with ankylosing spondylitis not given X-Ray therapy, New Eng. J. of Med. 296, 11, 572 Rasmussen, N. C. (1975). Reactor safety study. An assessment of accidental risks in US ccmmercial nuclear power plants. USAEC-WASil-1400 Schmitz-Feuerhake; E. Muschol; K. Batjer and R. Schafer (1978). Risk estimation of radiation-induced thyroid cancer in adults. IAEA-SM-224/712 Silverman, C. and D. A. Hoffman (1975). Thyroid tumor risk from radiation during childhood, Preventive Medicine 4, 100 Stewart, A. M. and G. W. Kneale (1970). .Radiction dose effects in relation to obstetric X-Rays and childhood cancers. Lancet, 1186 Takeshi, S. (1980). NRC's gross underestimation of the radioactive releases and population doses during the TMI-2 accident. Kyoto Univ. Nuc1ccr Reactor Labora-tory. U. S. Nuc1 car Regulatory Co=misr ion (1980). Investigations of repcrted plant and animal health effects in the Tl.ree Mile Island area. USNRC-NUREG-0738 and USEPA-EPA 600/4-80-049 USNSCEAR Report (1972). Ionizing radiation: levels and effects. UN, New York Warren, S. and O. Gates (1971) The Inclusion of leukemia and life shortening of mice in continuous low-level externals gamma radiation. Rad. Res. 47,, 480 i
lY ,, ,. qig ASSOCIATION INTERNATIONALE DE RADIOPROTECTION b# INTERNATIONAL RADIATION PROTECTION ASSOCIATION IV" CONGRES INTERNATIONAL IVth INTERNATIONAL CONGRESS _i p: - ' : .:, _ s ,_ : ~. .-$ . , , .. u s . _ _ , A? . :n : a-A:~c - R ECU EIL DES COM MUN;CATIOMS ! i I VOLUME 2 - Mardi 26 avril et mercredi 27 avril
/
PROCEEDINGS VOLUME 2 - Tuesday April 26th and Wednesday April 27th I PARIS 24-30 AVRIL 1977 - t
,.. 4 .e . . . . . . . - .. .
f
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N*451 - Tite LINEAR HYPOTHESIS OF RADIATION DAMAGE APPEARS TO BE NON-CONSERVATIVE 12: KuY CASES . Karl 1. 1: organ
. School of Nuclear Engineering Georgia Institute of Technology Atlanta, Georgia 30332. USA The purpose of this paper is to express a word of caution to those members of the International Radiation Protcetion Association (IPJA) and to members of the International Commission on Radiological Protection who seen to believe ,
our present levels of caxicun permissible dose (MFD) for occupational workers and dose limits (DL) for cenbers of the public are ur.necessarily Io and should be increased. At the same time, I would caution persons in the 1 United States who are advocating that present levels should be reduced by an order of magnitude. Likewise I wish to discourage some members of 1RPA froa ; repeating their claim that the linear hypothesis, upon which we base our present radiation protection standards, is overly conservative. I believe present values of }7D are satisfactory, but only because in indus-try and in the vast majority of nuclear energy programs these values are considered as upper li=its so that on the average exposure to radiation of workers does not exceed 10% of :tPD. T,his practice has developed as a result of the prbuciple of ALARA (exposures As Low As Reasonably Achievable). k*e r e the day to cope when occupational exposures are averaging 50 to 80" of the ITD, I would be first to urge a reduction in present MPD. In.this connection . I deplore the fact that some nuclear power plants and fuel reprocessing plants in the United States have ignored the principle of ALERA, have adopted the practice of " burning out" employees by using " expendable" temporary employees, and have exceeded 1000 can-res/y at some of the power plants. It is unfortu-mate, also, that for the cost part the medical profession ignores the prin-ciples of ALARA for patient exposures. I do not believe, however, that the solution to these problems is to lower MPD and CL by an order of magnitude, . for then nany health physicists would feel ebligated to reduce exposures to 12 or less of our present values; this could deprive us soce great benefits that can be expected from proper use of ionizing radiation. For example, 1 believe present average occupational exposure of 5 to 10: MPD = 250 to 500 mrem /y to total body does not present an unreasenable et unusual occupational - risk. We might expect this risk to be of the order of 500 x 10-3 xF10-* c/rea ' x 40 y = 6 chances of cancer from occupational exposure per 1000 radiation workers. The lorg range genetic risk bould be about the same magnitude as somatic risks, and I consider this acceptable in comparison with risks in safe occupations. However, I would consider a 6% cancer plus a 6% genetic risk too high. 'l feel the same about not changing population DL so long as present practice limits this on the average to 1 css than 10%. With the denise of the treshold hypothesis, the linear hypothesis has gained s acceptance as the basis for setting radiation protection standards and this has Icd some health physicists to decry its use and cake incorrect claims:
1) The linear hypothesis halds only in the high dose range, 2) There are no human exposure data indicating radiation da: age due to low doses (ionizing ,
or non-ionizing), and 3) The linear hypothasis is always overly conservative in the low dose range. Regarding claim number 1. ju't s the oppost. *s true. In the high Jose range the linear hypothesis always breaks down c.. suse one cannot cause deaths in over 100% of exposed popuistion and a maxi s a effect is reached at some in-termediate dose because at higher doses the animals do not survive long enough to JLe of' effects under stuJy. It is true that for low LET radiation
- Il 4
of
o f .
* . -- - - - ~ ~ ~
f the linear hypothesis is of ten conservativo for low doses administered to . aninals because time is allowed for cell repair and cell replacement. How- ' ever, studies of production of leukemia as a result of in uteral x-ray exposure 1.2, and exposure to young people 3,4,5, as well as some studies on old animals, suggest that very young and very old acmbers of a pcpulation are radiosensitive and the linear hypothesis, as applied to them, is non- - conservative even for low LET radiation. Many evaluations og6,7,8,9,10,11 cancer production from high LET radiation of hu=ans as a consequence of body burdens of radium indicate that if there is departure from the linear hypo-thesis in the low dose range it is in the direction of core cancers produced per rad at low doses than at high doses and that protraction 12 of time over which dose from 224 R a is delivered to patients increases rather than decreases the risk of cancer. Regarding claim number 2, there are many publications reporting harmful ef-fects of low exposures to both ionizing 1,2,3,4 and non-ionizingl3.14 radia-tions, so I can only conclude those who repeatedly claim such data do not exist cust completely discount the validity of such studies. I do not agree that findings of these studies can be ignored and believe the validity of some of the findings is sufficiently substantiated that we must take seri-ously enforcement of the principle of ALARA. It is easy to understand why there are adherents to claim 3, and why many d,isciples of the old threshold hypothesis are reluctant to abandon belief that if one does not exceed a threshold dose there is no risk of radiation damage, or if the dose is kept below a threshold value, the rate of repair can keep pace with the rate of danage produced. It is true in many cases, and especially fur low LET radiati,on, the rate of rcpair cay Reep up with the ra te. of Jarage. In some cases also the avera;e incubation period for ' certain malignancies nay be longer than expected remaining life. However, we should not take too cuch cor. fort in such observations because each person differs in response to radiation such that the only safe assumption is that no dose can be so low, that the probability of radiation damage is zero. Generally accepted theories of damage lead to the eccelusion that a given type of radiation damage fres a given type of exposure is simply a matter ' of chance, Ey this we rean that of the millions of photons and alpha parti-cles that 1cose energy in an organ of our body each day; there is always the rcnota chance that one of these vill damage a cell in such a way that it survives, but only to reproduce itself in its perturbated forn and that in tine there developes a clone of perturbated cells which is identified as a malignancy. The fact that there is no " safe" level of radiation exposure is not a unique type of risk--we all know, for exa:ple, there is never a trip in a Faris taxi that is " safe." .
;;ow that we have discarded the threshold hypothesis, let us sunmarize reasons why in sone cases use of the linear hypothesis to estimate risk at low doses is not a conservative assumption as follows:
1. Overkill at high doses. Most estinates of risk fres raJiation expo-sure are based on linear extrapolation of ef fects at high doses down to zero dose. Often with such extrapolation insufficient account is taken cf overkill and that in no case can more than 100?. of the i anicals be killed by radiation. Sometices one sicply determines the best 1 cast-squares line which will pass threugh the (0,0) point.
Sone points used in deternining the slope of this line may be on the bend of the curve where the antaals are injured by large doses of I radiation such that they do not survive long enough to die of the effect under study. .
2. Short fo11ow-up period of human studies. Most studies 15 of effects 12
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of ionizing radiation on nan extend over only a small fraction o. his life span. If one determines the slope of curve of thyroid carcinoma risk vs x-ray dose and the followup peried is only 7 years; studies of population until all have died would increase the slope of curve and risk estieste.
3. Fractional life span ant-al studies. Sometimes comparisons are cade between f etal da. mage during tirat trimester of a nouse and datage we might expect during first trimester of a woman.or a comparison is made over If fe cf animals having a life span of 20 years with expected effects over life span of nan. Since in many cases da age from rs- .
diation exposura nay relate more closely to what happens in a given number of years following ex;osure rather than what happens over a certain fraction of the aninals' life span, such extrapolations to . man can only 1 cad to underestinates of risk.
4. Radiosensitivity dif fers a .ent animal species. Many studies have emphasized the risk of extrapolating data on ef fects of radiation exposure from one animal to another or to man. Differences in metabolism, turnover rate CI tract uptake, skin perspiration, blood circulation, nitotic index, etc., can have a marked ef fect on anisal response to a given dose of ionizing or non-ionizing radiation. An
/ examination of data leads ce to conclude that more of ten than not this kind of extrapolation to man results in an underestination of . risks.
5. Heterer,enettv of human population. The vast rajority of studies of ef fects of radiation exposure are carried out with imbred animals.
. Radiation ecology programs cust be extended to animals in the wild if we are to slculate effects we expect from low doses to human pop-ulations. Studies cf Bross16 have indicated that risk of leukeata as
a consequence of in utero x-ray exposure increases by 5000% if the child had diseases such as asth =a, hives, eczema, allergy, pneumonia, dysentary or rheumatic fever comp.ared with the child without this ex-posure and history of such disease. In accessing population risk of '
lov levels of exposure we need to know dose response for young and old, male and f emale, sick and well, f at and slim, the person of average eating habits and the one with peculiar eating habits, etc.
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When we have such data, our esti=ates of risk from lov 1cvel exposure will increase.
6. Cell steritization. It is well established that as old age is ap-proached, the ptrcent of abnornal cells in the body increases; for
example, the percent of chru=ososal aberrated cells ' increases with age of an aniaal. It is connonly believed that some types of malig-nancies develop as a result of a series of changes that take place

in the 46 chronosones that comprise the nucleus of a normal sosatic cell in man. Sometimes certain of these changes may*be the result of genetic cutation conveyed f rom one's parents. Thus, we have a scattering of cells and clones of cells which have one or more ab-normalities, and may present a much larger cross-section for the [
production of a malignancy than a normal cell. It may be that the etiology of cancer is sinitar to throwing of a series of switches such that cancer cannot develop.unicss all switches are thrown. Children born in a family with one of switches" thrown genetically have a higher cancer risk than average children and persons who have been exposed to higher levels of carcinogens have note high . cross-section cells that are likely targets for the origin of a ma-
. lignancy. When studies are conducted on animals exposed to high doses of radiation, cell sterilization may take place such that cany cells that are likely targets for development of a malignancy are ,
destroyed. Thus, such data points at high exposure levels would tend to* reduce the sinpe of the curve that is extrapolated to zero dose
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r and may result in an underestimate of risk at low levels of exposure. REFERENCES - (1) STEWART, Alice, KNEALE, C.V. , " Radiation Dose Effects in Relation to Obstetric X-Rays and Childhood Cancers," Lanset, 1185 (June 6, 1970) (2) BROSS,1.D.J. , NACHIMUTHU, N. , " Leukemia f rom Low Level Radiation," New Englsad Journal of Medicine 287, 107 (July 20, 1972) (3) PODAN, B. , BAIDATZ, D. , STEINITZ, R. LEVIN, S.C.." Radiation-Induced , Read and Neck Tumors," Lancet, 277 (Tebruary 23, 1974) (4) SILVERMA'*, Charlotte, HOFFMAN, D.A., " Thyroid Tumor Risk from Radiation During Childhood," Preventive Medicine 4, 100 (1975) (5) E0 ICE, J.D..Jr., MONSON, R.R., " Breast Cancer Following Repeated Fluoroscopic Exa=1 nations of the Chest " Bureau of Radiological Health, Pils, HEW, Rockville, MD 20S57, (Dece-ber 1976)
"~f(6) COFMAN, J.W., TAMPLIN A.R., "The Question of Safe Radiation Tresholds for Alpha Emitting Bone Seekers in Man," Health Physics 21, 47, (1971)
(7) BAUM, J.W., " Population Heterogeneity Hypothesis on Radiation Induced Cancer " Health Physics j[5, 97 (August 1973) (8) ERO'4N, J.H., "Linearity vs. Non-Linearity of Dose Respons for Radiation carcincgenesis," Health Physics 31, 231 (September 1976) (9) LAN3Au, E., " Health Ef fects of Low-Dose Radiation: Problems of Assess-nent," Intern. Journal Environoental Studies 6, 51 (1974) (10) licLTORD, R.M., "The Relation Eetween Juvenile Cancer and Obstetric l Radiology " Health Physics 18, 153 (Febr:ary 1975) (11) CRAIC, A.C., " Alternatives to the Linear Risk Hypothesis," Health
'~~' Physics 31 (12) MAYS, C.E!, 81 (July , SPIESS H.,1976)
GERSPACH, "Skdetal Effects Following Ra Injections into Humans " Symposium on Biological Effects of Injected 22*Ra and Thorotrast, Alta. Utah (July 21-23, 1974) (13) WOT.LD HEALTH 0?.GANIZAT10N et.31., "31ologic Ef fects and Health Hazards
of Microwave Radiation," PrececJings of an International Symposium-Warsaw 15-18 October 1973 Warsaw Foland: Polish Medical Publishers, (1974)
(14) CARPENTER, R.L., "An Experimental Study of the Biolrgical Ef fects of Micrcwave in Relation to the Eye, (RADC-TD1-62-131) Criffiss Air Force
Base New York; Rome Air Development Center: (February 1962) ,.
(15) The Effects on Populations of Exposure to Low I.evels of Ientzing Radiation, a report of the Advisory Committee on the Biological Effects of Ionizing Radiations (BZ1R-Report), National Academy of Science, NRC page 89, (Novenber 1972) (16) B2025,1.D.J., "ProceedinSs of the Congressional Conference en Low Level Rad.'ation," Senate Of fice Buildin3, Washington, D.C., (May 4,1976) l . f I e l , 14 . e g e m we o e
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v _? !t COMPARISON OF RADIATION EXPOSURE OF THE POf ULATION FROM V MEDICAL DIAGNOSIS AND THE NUCLEAR ENERGY INDUSTRY ** by Karl Z. Morgan Neely Professor School of Nuclear Engineering Georgia Institute of Technology Atlanta, Georgia 30332 U.S.A. Linear Vs. Threshold Hypothesis All chronic forms of radiation damage with the possible exception of radiation-induced cataracts appear to increase more or less linearly with the accumulated dose of ionizing radiation. Even in the case of cataracts, the International Commission on Radialogical Protection (ICRP) points out, "Possibly no one has sought to see if senile cataract in man is augmented or accelerated by exposure to radiation, and a synergistic interaction of radiation and age must remain a possibility until the investigation is made." Although there is known to be some repair of both genetic and somatic forms of radiation damage (at least in the case of x, y and S radiation), there appears to be some component of damage which is irreparable' and accumulates throughout the life of the individual in proportion to the integrated dose. When radiation passes through a cell of the body, three things are possible: (1) it passes through without any energy loss; (2) sufficient energy is lost to cause the death of a cell or at least to prevent it from further cell division, and (3) the cell is damaged in such a way that it survives and may become the precursor of a malignancy or some other form of chronic damage or may be repaired. We have no concern about the death of a few thousand cells because they are readily replaced. Each somatic cell of our body contains a nucleus which normally has 46 chromosomes, and each of these might be thought to represent an immense library of information, giving instructions to the cell regarding not only all the actions it must take in the future but actions of many successive generations of daughter cells. When ionizing radiation has passed through this nucleus or library of information of a surviving cell, more commonly the damage is so slight that it is repaired or the body is able to tolerate the aberration. It is only
Presented at the Americcn Nuclear Society meeting, Los Vegas, Nevada, June 18-22, 1972.

Work sponsored by the U. S. Atomic Energy Commission under contract with the Union Corbide Corporation.
Formerly Director, Health Physics Livision, Oak Ridge National Laboratory, Oak Ridge,' Tennessee. j
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in the exceptional case that serious damage or disorder is introduced into this library of information in the nucleus of the cell such that it is still able to survive and reproduce but without adequate instructions for future cell division. Thus, we believe radiation tends to increase the entropy of the system, and on this type of reasoning it is difficult to imagine how oil radiation damage could be completely reparable. Having examined the vast amount of experimental evidence of the effects of radiation on many forms of living organisms, including man, the International Commission on Radiological Protection and the National Council on Radiation Protection have concluded that the only prudent assumption is that there is a linear relationship between dose and effect, and all exposure to ionizing radiation even at the level of maximum permissible exposure involves some risk. In other words, no dose of ionizing radiation can be so low that the probability of damage--even serious damage such as leukemia--is zero. However, the ICRP(2) states that in its best judgment the probability of severe somatic or genetic injuries at recommended permissible exposure levels is negligible, and any effects which ensue more frequently are limited to those of a minor nature that would not be considered unacceptable by the exposed individual and by competent medical authorities, and any severe somatic injuries resulting from exposure to individuals at the permissible exposure levels would be limited to on exceedingly small fraction of the exposed group, and effects such as shortening of life-span which might be expected to occur more frequently would be verf slight and would be hidden by normal biological variations. Fig.1 gives the coefficients suggested by ICRP for chronic forms of damage to man which are assumed to relate linearly to the dose, and, in addition, I have plotted curves for radiation sickness and acute radiation death. These latter two curves become asymptotic to the ordinate at { l about 20 and 200 rem, respectively. The mid-lethal dose (50% lethality) is thought i 1 to occur in man at about 400 rem, and at high doses all the curves reach soturation. - The curves for radiation sickness and radiation death apply only to the case where large doses are delivered over a short period of time, whereas the other curves apply to relatively low doses and dose rates. Because of very limited information relative to the effects of ionizing radiation on man, the values of coefficients given in Fig.1 must be considered only as first approximations. Table i summarizes some of the types
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TABLE 1 TYPES OF DAMAGE RELATING MORE OR LESS LINEARLY TO THE ACCUMULATED DOSE
1. Genetic Mutations (1st generation and recessive)

2. Cancer (including leukemia)

3. Life shortening ,
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F of damage which vary more or less linearly with the dose and types of damage which are thought to require a threshold before they make their appearance in man. Early studies of Muller of Drosophila (flies) seem to suggest complete linearity between dose and genetic damage and no dose-rate dependence. The more recent, very fine studies of RussellI } (a speaker at this symposium) have shown, however, there is at least a slight kink in the curve (by a factor of 1/6) at very low dose rates. In Fig. 2, I have made a rough plot of some of Russell's data showing that of high dose rates there is no dose-rate dependence, but when the dose rates drop to about 5,000 R/hr, there is a precipitous decrease in the mutation frequency, both for exposure to the oocytes and spermatogonia of the mouse. In cose of the oocytes, the curve drops rapidly into the background region where in effect there may be complete repair. In the case of the spermatogonia, however, he found a decrease by a factor of three or four, and the curve leveled out again on another plateau with no evidence of further decrease with reduced dose rate. Thus, since there are the two sexes and a reduction by a factor of three for the male, we use in our estimates of risk a reduction by a factor of 1/6 in the risk estimate from radiation exposure at very low dose rates. However, I do not believe we are justified in assuming any further deviation from linearity other than a slight reduction perhaps by a factor of two because of a low dose-effect. In other words, we might be justified in on over-all reduction in on estimate of the risk by a factor of 1/10 for very low doses and dose rates for the mouse and possibly in the case of man. However, I do not see any possibility of a complete reversal of the low of entropy and the complete repair of all radiation damage to o surviving somatic l cell or germ cell at very low levels of exposure. Oddly enough, some persons seem to feel that lock of a " scie" exposure level is on exception to the general rule or a unique situation, and there must certainly be a threshold or safe level of exposure to radiation below which there is no risk. For example, we are occustomed to thinking it is completely safe to take one aspirin per day and that such a dose is below a threshold at which there is any risk whatsoever. I submit, however, that almost all, if not all, insults to which mon is subjected probably present some risk even at very low levels of exposure. For example, as we go about our daily tasks, there is some risk of being struck by lightning. For the past number of years, there have been official reports
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of persons exposed to I rem would be expected to develop cancer as a consequence of this exposure. I am inclined to believe that sometimes the public is misled by the manner in which we present our data. For example, in Figs. 3 and 4, we have given plots indicating the risk of bone sarcomas and carcinomas from various levels of accumulated dose from body burdens of radium. In this case, Rowland et al have presented their data properly so as not to be misleading. In Fig. 3, they plotted their data on a semi-log graph. Seeing only this, the non-scientific observer might conclude that there is a threshold at about 80 rod for carcinomas and 800 rad for sarcomas for these forms of radium-induced concer. However, another observer when looking in the same report at the some data which Rowland plotted also in Fig. 4 m ig h t conclude et low doses there is a linear relationship and no dose so low that the risk of concer is zero. I believe a typical example of a case in which the non-scientists were misled occurred following testimony of a number of scientists at the 1967 Congressional hearings regarding deaths which have occurred from lung carcinoma among uranium miners who worked in the Colorado Plateau. At these hearings (8) in 1967, Dr. Gehring, Acting Surgeon General of the Public Health Service, made on estimate of the risk of lung carcinoma that might be expected among 10,000 exposed underground uranium miners based on the linear hypothesis. Representative Holifield replied, "I think your assumptions relating to the straight-line theory and the threshold theory are subject to the most vigorous opposition . . . I consider (them) to be non-scientific on the basis not that I am a scientist but on the basis of the weight of evidence that has been before this committee for a long time." To the contrary, I believe Gehring would have the support of most of the scientific community in' applying the linear hypothesis to his data. Since that time, a more recent report on concer among these miners lends stronger support to the linearhypothesiseven down to the 120 WLM level of exposure of these miners.1
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t believe we must be very careful in presenting our data in order not to mislead the public. I do not b'elieve at the present time we have--or in the foreseeable future we will have--sufficient information to prove whether the linear hypothesis or the threshold hypothesis applies at very low doses and dose rates because as the dose opproaches zero the number of animals required to obtain a point on the curve l showing a given effect approaches infinity for reasonably low probable errors. I do not believe the question can ever be answered by animal studies, much less from observations on man. In the long run, I believe our answer must be derived from the development of a coherent theory which explainsoII mechanisms of radiation damage. Since this takes us beyond the foreseeable future, I would like the present to be in conformance with the low of entropy and assume that when a very large disruptive force has been applied to the nucleus of a surviving cell, the end result is most likely a disorganization of the intricate strteture and seme residual damage. There are many experiments which seem to lend strong support to the linear hypothesis and to the conclusion that as the dose is increased not only does the probability of serious damage increase, but there is a gradual progression of events pointing to the imminence of impending crises as indicated under item 4 of Table 1. In Table 2, I have simply drawn a wide band diogonally across the table of dato prepared by Finkel et al. You will note this includes the summation of most of the numbers in the table suggesting a gradual progression as one increases the body burden of radium from no effects, to minimal, to mild, to moderate, to advanced, and finally to malignancies. You will note, also, the progression toward serious symptoms seems already to have begun even in the range of a permissible body burden of 0.1 pCi of radium-226. In terms of dose rate, the body burden of 0.1 pCi of radium-226 as applied to the occupational worker corresponds opproximately to 30 rem /yr when overaged over the entire skeleton and about 15 mrem /yr to the endosteal tissue of the bone. Endosteal tissue is currently considered by ICRP to be most critical in terms of radiation-induced bone tumors. The 0.1 pCi of radium-226 is one of the two principal hollmarks or reference standards to which all levels of maximum permissible exposure are referred or from which they are derived. This level of 0.1 pCi of radium-226 was set by the U. 5. Advisory Committee on the
P I l Tcble 2 LONG-TERM EFFECTS OF RADIUM IN MAN Ro Body Burden Average Bone Biological Changes (%) (pc) Dose (rem /yr) None Minimal Mild 1 Moderate Advanced Molignant* 0.001-0.03 0.3-9 Y 92 8 0 0 0 0 0.03-0-0.1 9-30 3[ 13[ M 0 0 0.1 -0. 3 30-90 6D 6 N [6 6 3 0.3-1.0 90-300 12 25 <25 16/ /_22 ' A 16 1.0-3.2 6 6 1[ 12 h2/ 32 3.2-5.5 0 0 0 9 1 5
*Those with malignancies were listed also under previous columns.
l l (Data from Finkel, Miller and Hosterlik, ICRP No. 11, 1968) l l l 1
Safe Handling of Radioactive Luminous Compounds in 1941. } The other reference standard was the early exposure of radiologists who were thought to have averaged in the neighborhood of 15 rem /yr of exposure. Seltser and SortwellO3) indicated that radiologists in the period 1935 to 1958 in the age group of 50-64 had seven times the leukemic incidence of members of the medical profession who were not exposed to x-rays and that their average life was shortened approximately five years. If one applies the coefficients of ICRP as plotted in Fic. I to these data, it con be shown'14) that this overage exposure in terms of leukemic risk or of life shortening was on the order of 15 to 30 rem /yr. Perhaps it is a coincidence that we arrive at these some numbers both in relation to leukemia risk and life shortening of radiologists, but i believe it does provide some evidence the t the effective dose to the active bone morrow and other, more important body tissues of early radiologists was not as large as some persons have thought and probably overaged no more than 30 rem /yr, our present dose limit to the bone of the occupational worker. Although some representatives of the American College of Radiology, the American Medical Association and the American Dental Association seem to go to great pains to indicate that medical exposure to patients is harmless and of no consequence, I believe the record speaks for itself and to the contrary. For example, we recall the follow-up study of AlbertO6) of patients treated by x-rays for tinea capitis (or ringworm). In this case, among the 4,000 member study group there were nine times as many malignancies and four times as many mental disorders among the children whose tinea capitis was treated with x-rays as among those for whom other treatments were used. Although the dose to the brain in this case was fairly large, probably about 100 rod, the average dose to other tissue such as the active bone marrow where many of the malignancies originated was very small. Sigler and other investigators at Johns Hopkins University carried out a study involving 216 families, each with a Mongoloid child, living in the city of Baltimore. Their investigations revealed that mothers of Mongoloid children had received seven times as much x-ray exposure as the group of control mothers. Studies of Court-Brown and bnll of a large number of persons suffering with ankylosing spondylitis whose
-5 i spines were treated with x-rays have indicated a coefficient of about 2 x 10 i
leukemios per rod delivered to the active bone marrow (approximately the figure given in Fig.1). A study of Doll and Smith of 2,000 women whose ovaries were irradiated for artificial menopause indicated that mortality from leukemia os a result of irradiating these small volumes of tissue was six times higher than would otherwise be expected five or more years offer treatment. They concluded, "The results are therefore consistent with the hypothesis that the risk of leukemia induction is proportional to the total energy absorbed in the marrow." The work of Hempelmann (a speaker at this symposium) is particularly impressive in that it lends strong support to a linear relationship between dose and effect down to relatively low doses. He states, l "The incidence of thyroid and extra-thyroid tumors in the Rochester series is dose dependent, and the frequency of thyroid neoplasms is age dependent until age 18. Some evidence is presented suggesting that (1) the dose response to thyroid tumors is linear in the lower dose range, and (2) there is no threshold or at least the threshold is below 20 rod." Present evidence see ns to show that the most sensitive members of the population are probably the fertilized ovum and the fetus. The curve of radiosensitivity as a function of age is probably an inverse parabola because there is some evidence of an increasing radiosensitivity also with advancing age. For - example, l.ewis offer examining data published by Saenger et al points out that in the case of medical exposure to iodine-131 delivering rather low doses of 7 to 15 rod to bone marrow, there is a significant increase in leukemia omong the persons in this study between ages 50 and 79. Regarding exposure to younger members of the population and, in particular, in utero children, some of us believe this to be a very serious matter. For example, Hammer-Jacobsen(23) points out that relatively firm ~ measures are taken in Denmark which suggest the need for therapeutic abortion in cases where the fetal doses are estimated to have exceeded 10 rem. Because of concern for what we believed to be excessive fetal exposure, Muller and I, beginning about 1959, worked very hard toward obtaining on ICRP recommendation which would discourage unnecessary medical diagnostic exposure to unborn children. As two of the 13 members of ICRP, we were rather proud when in 1964 ICRP(24) come out with the recommendation. that diagnostic exposure of women in the childbearing age to ionizing radiation be limited to the 10-day interval following the onset of menstruation except in those cases where
the immediate x-ray was needed because of illness of the woman. Muller and I were disappointed, however, when some months later we read in the Bulletin of the American College of Radiology, "ACR differs with international body . . . The College agrees with the minority opinion taken in the ICRP that the problem is neither so simple nor so serious as the Commission statement might indicate. College members Robert S. Stone of San Francisco and L. 5. Taylor of the National Bureau of Standards, Washington, D. C., sit on the ICRP and among those taking the minority position . . . ." In spite of such opposition to this recommendation, I believe it has been one of the more important developments toward reducing unnecessary risks throughout the world from diagnostic x-ray exposure. We were pleased that the American College of Obstetricians and Gynecologists (20 recognized the risk of in utero exposure when it stated, "The risk of radiation injury is real . . . and physicians should avoid the use of routine pelvimetry and routine radiologic examination of the abdomen throughout the prenatal era." There have been many studies on the effects of pelvimetries, the vast majority of which have indicated on increased incidence of malignancy among children who received in utero exposure. One of the more careful survey studies was carried out by MacMahon(2D in which he reported that ofter Alice Stewart's original observations in 1953, some 12 studies of the question of the relationship' between pelvimetry and other x-ray. exposure in utero and concer in children have been published. He pointed out that although there were positive and negative findings, a combination of the data from all of them weighed according to the number of cases studied, indicated that the mortality from leukemia and other forms of concer is about 40% higher among children exposed to diagnostic x-ray study in utero than among children not so exposed. He indicated that over the first 10 years of life of the child the risk amounts to about one concer death per 2,000 children so x-rayed. This may seem o small number, but if all women received pelvimetries during pregnancy in 1970, this would amount to about I 2,000 deaths per year in the United States. Again, this is a small number but not so small if one's child happened to be one member of this statistic. The studies of l Alice Stewart (28 (a speaker at this symposium) of the effects of diagnostic x-ray exposure on children are particularly impressive. Fig. 5 is a plot of some of her dato
e - y 1.4 m_ Cr 1.2 b ., (j i.0 - y 4 o 0.8 / , o f v; \
$ 0'6 /
6 d 0.4 #
/
l tu o 0.2 m: l o 0:3 ! O 1 2 3 4 5 6 NUMBER OF DIAGNOSTIC X-RAY FILMS DURING PREGNANCY ] ! (Dat~a from Alice Stewart and G.W. Kneale, Lance /, June 1970) Figure 5 l L
which lend strong support to the suggestion of a linear relationship between dose and effect at least down to 1 rem and perhaps as low as 0.25 rem. Of recent date, some members of the medical profession have delighted in pointing out that Alice Stewart's data are not consistent (29 with that reported by Jablon(30) on the effects of in utero exposure of children who survived the atomic bombings at Hiroshima and Nagosak!. I have been interested for many years in both studies and consider them among our best sources of data indicating the effects of radiction on man. In fact, our Health Physics Division at Ook Ridge has been responsible for determining the dosimetry of the survivors at Hiroshima and Nagasaki. Having examined both sets of data, I con only conclude there are no inconsistencies in the results, and the two sets of data are completely in line with what one might expect. In Table 3, I have listed some of the 1 reasons why there is on apparent difference in the two sees of data, i.e., there have not been as many cancers observed in the children who survived in utero exposure at Hiroshima and Nagasaki as one might expect from casual application of the Stewart data. First, we should recall that only children of age greater than two have a high risk of juvenile concer, and there was a very high infant mortality among in utero exposed children and a very high abortion rate.(Thus, many children who received , in utero domoge from radiation exposure were aborted or did not survive the two-year period to die of a malignancy, i.e., many children who received sufficient in utero radiation damage to otherwise be programmed to die of a malignancy of ter age two did not survive this period. In the second place, many studies have indicated that during the time of community disasters it is the young children and older people who suffer most and die of a variety of causes including cancer. It is well recognized that during such periods incipient cancers are often very easily mistaken for acute infections. Another possibility (but I believe an unlikely one) is the fact that neutrons were present as a component of exposure to the Japanese survivors of the atomic bombings, and this may have favored early deaths from causes other than malignancies. It could well be that there were species differences of considerable importance in these two populations. For example, marked species differences have been observed' in animal studies carried out by Warren and Gates (33) and by many others. I believe, most important of all, the Jablon data included 33 Japanese children who had received
I - Table 3 SOME POSSIBLE REASONS WHY ALICE STEWART'S X-RAY DATA DIFFER FROM JABLON'S JAPAN DATA
1. Only children of age greater than two years have a high risk of juvenile cancer. Infant mortality was 43% among in utero children who received high exposure, and there was a very high abortion rate among them. In utero initiated cancers concurrently with other body insults tipped scales for early~ nonmalignant death.

2. In most catastrophic situations (floods, war, disease, starvation), children and older people suffer most.

3. Neutron irradiation at Hiroshima and Nagasaki.

4. Japanese children may differ from European children, and/or European children may be uniquely exposed to a co-carcinogen.

5. Jablon data included 33 children who received greater than 300 rod. Stewart's data do not apply to doses at the for end of the parabola relating leukemia to dose.

6. Incipient cancers during the bomb aftermath were likely mistaken for acute infection.

7. Japanese control group of bomb survivors probably had a greater cancer risk than normal controls.

8. It has been suggested the average fetal dose in the United Kingdom may have been greater than 500 mrod per examination and perhaps about 800 mrod.

9. The Japanese exposures above 300 rad probably were on the for side of the parabola relating leukemi= to dose. Thus, perhaps no concers would be expected, and none were observed in this range. Among Japanese exposures from 0 to 39 rod, no cancers were observed and none were to be expected.
Among Japanese exposures from 40 to 299 rad, Stewart's minimum coefficient (correcting Jablon's data for fetal dose) would predict two cancers and one was observed. Thus, the two sets of data are in good agreement. ______2__.-___ _______________._____.
in utero exposure of more than 300 rod. I do not believe Stewart's dato con be opplied to this population group because it would seem likely their doses were so high that they would fall at the for end of the parabolo for leukemic similar to the curves shown in Fig. 4 for sorcomo and carcinc,mo. Morinelli and many othe investigators have Indicated in their publications that although you may have a linear relationship i i between dose and the effects on animals at low doses, the curves connot continue l
~
l this linearity indefinitely. In the first place, one cannot ktil more than 100% of l the animals from radiation exposure, and at the higher exposure levels many of the ' animals may begin dying of other causes before they have time to die of a malignancy. Stewart has pointed out that the control group of bomb survivors in Hiroshima and Nagasaki probably had a higher concer risk than a normal population which, in turn, would tend to reduce any observed effect of radiation. Finally, it has been suggested - that perhaps Stewart may have used a low figure for the overage fetal dose from pelvimetries in the United Kingdom. Making this correction and using the minimum coefficient found by Stewart for her Oxford study group and applying a correction of 1/2 to the Joblon data to obtain the fetal dose from the skin dose, one would expect to find two concers among the Japanese in utero exposures in the range of 40 to 299 rod, and one was found. No concers would be expected in the group exposed in utero to O to 39 rod, and because exposures probably were on the for side of the parabolo for the group receiving exposures greater than 300 rod, no concers would be expected. In view of the uncertainties in the dato, I consider this perfect agreement between the number of concers observed among the in utero exposed children in Japan and the diagnostically exposed children in the Oxford study. Comparative Radiation Risks From the above discussion, I believe it seems reasonable to assume the validity of the linear hypothesis for the purpose of making comparisons of risks from medical diagncsis and the nuclear energy industry, if one knows the overage or effective dose to the critical body tissue, it then becomes a simple matter of multiplication to determine the deaths caused each year from these two sources of exposure. In previous publications, I have attempted to use the dato published in the UNSCEAR reports ' and in the U. S. Public Health Service reports to estimate the x-roy doses to various body l
organs from medical diagnoses and multiply these values by the appropriate coefficients, as indicated in Fig.1, to determine the number of deaths per year. However, the 1970
.wvey of the Public Health Service has now been completed, and the data are in the process of final analysis, so I will simply use their most recent estimate that the genetically significant dose to the U. S. population from medical diagnoses may have dropped from 55 mrem /yr to 36 mrem /yr. I will further make the opproximate enumption that the effective somatic dose is three times this 36 mrem /yr. This probably is not for wrong, but it is the best that con be done until additional info, motion from the survey becomes available. In the case of the nuclear energy industry, Struxness and I made some estimates two years ago of the upper limit of the dose from all nuclear sources (occupational exposure of the nuclear power plant employees, occupational exposure of national laboratories and other AEC contractors and employees, exposures at chemical processing plants, and environmental exposure from all of these sources but excluding the lung carcinoma deaths resulting from exposure to uranium miners in the United States) and concluded the overage dose could not be in excess of 1/2%
of the exposure limit of 170 mrem /yr. Subsequent studies of the problem suggest that it is definitely less than 0.5 mrem /yr. Therefore, the comparative estimates of risk - from the nuclear power industry and from medical diagnostic exposure are given in Table 4 where it is assemed the upper limit of exposure is 0.5 mrem /yr in the nuclear energy industry and is 36 mrem /yr and 3 x 36 mrem /yr for the genatically significant dose (GSD) and somatic dose, respectively, from medical diagnose aking these estimates, the coefficients for genetic damage in the case of medical diugnostic exposure were taken to be six times those indicated in Fig. I because of the high exposure rate. From these results, the contrast as shown in Table 4 is very striking. The number of deaths in the nuclear energy industry would be 11 compared to 3,000 from medical diagnosis each year. The corresponding figures are 40 and 33,000 when one considers the highest estimate of deaths introduced into the population each year as a result of recessive mutations. From such a comparison, I do not wish to leave the impression that we have no concern for possible chronic demoge to the population from the nuclear power industry, for we must do all possible to further reduce the dose and the possible effects on man. I would emphasize, however, that if one is truly concerned
Table 4. Consequences of Present United States X-Ray Diagnostic Exposures Compared With Those of A Possible Population Exposure of 0.5 Mrem / Year From The Nuclear Power Industry
l Medical Exposure

Nuclear Power Industry Types of Radiation Damage (deaths /yr) at 0.5 Mrem /Yr (deaths /yr)
Genetic (First Generation) 700 1 f Genetic (Future Generation)6 30,000 30 Concer** 2,000 10 Total Deaths /Yr ~ 3,000 11 Deaths introduced into Population Each Year ~ 33,000 40 8
Assume population of 2 x 10 in the United States.

Assume medical GSD of 36 mrem /yr at a high dose rate.
" Assume effective somatic dose is three times the GSD.
AUpper limit of estimate of risk from recessive mutations.
r i
' obout radiation effects on mon of man-made radiation, most of his efforts could better l L
be spent in reducing unnecessary diagnostic exposure. . Excessive Medical Diagnostic Exposure There is no question that enedical diagnostic exposure is one of the most' valuable f of all medical tools and should be made use of when there is on indicated need and f the expected benefits are greater than the radiation risks. However, there is j overwhelniing evidence that this exposure in the United States is excessive. Many ; of the x-ray diagnoses are unnecessary, of no benefit to the patient and of questionable value to the doctor. Those x-rays which are given could be corried out in such a way that the overage patient absorbed dose (rem) would be less than 10% of the present ; value; the overage enugy dose (gram . rem) would be less than 1% of the prcsent i value, and the genetically significant dose (GSD) would be less than 0.1% of the ! present values received in the United States. Table 5 summarizes some dato indicating , that the GSD in the United States is higher than that in other advanced countries. As ; stated above, preliminary estimates from the 1970 U. S. Public Health Service survey I indicate the GSD may have dropped since 1964 from 55 to 36 mrem /yr. There are , ; indications,(40) also, that there have been similar reductions in the other indicated , countries. Adrian(41) of the United Kingdom stated that if all the radiological departments in the United Kingdom employed the techniques in use already in 25% of , I the departments in 1958, the population gonod dose from diagnostic radiology would probably be reduced by a factor of 7. In other words, he has indicated that by this simple procedure the dose could be reduced in the United Kingdom to 2 mrem /yr. 1 Following the 1964 survey, the U. S. Public Health Service (38) stated, "Reskiction o the x-ray beam to on area no larger than that of the film size would result in o I reduction of the GSD from 55 to 19 mrem / person /yr." In Congressional testimony ( 2 and in a number of publications,(43-45) I have listed over 100 ways by which the ; diagnostic exposure in the United States could be reduced to less than 5 mrem /yr. You may ask why is the genetically significant dose in the United Kingdom and other advanced countries less than that in the United States. We cannot give on occurate onswer to this question. Some radiologists have suggested we may have better , l . 1 i
) . . , - . - , -- . = - - ,._. -
r.-. . , . . , _ - . . . .- . ~ , . , _~.-- . . , . . _ .
Table 5 4 Genetically Significant Dose (mrem /yr) from Medical Diagnosis , in Various Advanced Countries i -l United States 55* j Japan 39 l Sweden 38 , 1 Switzerland 22 , United Kingdom 14 i New Zealand 12 l l
\
Norway 10
*The 1964 survey of the USPHS reported the GSD as 55 mrem /yr. Preliminary estimates from the 1970 '
survey indicate it may have dropped to 36 mrem /yr. t n i l t
- a n .,.e-.~, . - -
O e medical practice in our country. This may or may not be true, but it goes without question that they have had medical physics and radiation protection programs in some of these countries much longer than in the United States. In fac' during the period beginning with World War 11 a number of leading medical physiasts (health physicists) were imported to this country. Some of these countries have had effective programs for inspection and upgrading of equipment and diagnostic techniques for many years--something that is still lacking in most of the United States. I believe, also, members of the medical profession in some of these countries have a greater : knowledge and appreciation of the genetic and somatic risks of medical exposure i and a stronger motivation to avoid its excessive use. Probably the best evidence i that unnecessary and excessive diagnostic exposure is being delivered to our population derives from an examination of the wide range in values of exposure for a given diagnosis as shown in Table 6. Here it will be noted that the overage skin dose from a chest I x-ray when delivered to employees of our Laboratory (Oak Ridge National Laboratory) by a certified x-ray technologist using modern techniques and equipment is only 15 mrem, whereas a U. S. Public Health Service survey indicated the average in the United States for a chest radiograph was 45 mrem, and when using the photofluorographic technique the overage was 504 mrem. Our studies have shown a range in skin dose from photofluorograms of between 200 and 2,000 mrem. The , spread in dose values is even greater in terms of energy dose (gram . rem) and GSD. For example, Penfil and Brown and others have shown the x-ray beam cross- . i sectional area to film area for chest x-rays in the United States ranges between l 1 and 4.1. Even worse, there are many chest x-rays made which should be avoided. For example, in 1965 the Public Health Service stated, " Mass chest x-ray j programs should not be given to all population groups but instead should be focused on groups within communities where the incidence of tuberculosis is known to be high." As seen in Table 6, there is a similar variation in the skin dose from a dental series. Unfortunately, the energy dose variation is much greater because only about I 1% of the dentists are using the long, open-ended cones with rectangular collimation. I has pointed out that the long, open-ended cones The American Dental Association are preferable to the stubby, pointed, plastic cones. The long, open-ended cones can ; b d
. .. . -. ._._,_ _ - = - . _ - . .. .. . . _ . . .
C Table 6 ^ Common Diagnostic X-Ray Exposures (Mrem to Skin) in the United States Range Average , Chest X-Ray at ORNL 10-20 (15) Chest X-Ray (Photofluorographic) 200-2000 (504) Chest X-Ray (Radiographic) 10-300 (45) . Dental X-Ray Series 400-100,000 (20,000) i i e i
.+
i i ? 9 e
.j'
. 1 O -O such that the cross-be provided with a precision rectangular collimator sectional area of the beam is essentially the some os that of the film. This device, also, provides a metal backing behind the film to limit the amount of the beam possing on into the critical tissue of the body and is constructed in such a way that retakes will not be necessary because of film cutting (improper alignment).
Another promising device for limiting the cross-sectional area of the x-ray beam to more or less the area of the file is the automatic collimator.I ) Surveys of the Public Health Service (33 indicate that for dental x-rays in the United States the ratio of beam cross-sectional area to film area is greater than 6.8 for 2.1% of exposures, 3.8 to 6.8 for 18.4%,3.2 to 3.8 for 35.7%, and less than 3.2 for 43.8%. It is hard to understand why about 99% of the dentists are using a beam with a circular, cross-sectional area when tFe film is rectangular. The portion of the beam beyond the area of the film not only unnecessarily exposes the patient but produces additional x-ray scattering onto the film so that the image of the teeth suffers from loss of resolution and detail. Public Health surveys ( } have indicated that most of the dentists do not even have a thermometer in their darkroom although specifications for best results in developing dental films indicate the temperature control of , developing solutions should be maintained within a few degrees. Until recently, most of the dentists were using slow-speed dental films. For e'xample, in 1967 65% of the dentists in New York City were still using slow-speed films, and 72% were still using mechanical timers which were inadequate for fast-speed films. I do not have the statistics on the present situation in New York City, but I understand in this respect dental exposure hos improved considerably. I believe with this observation we should keep in mind that the medical surveillance program in New York City is very likely the best in the United States. As with chest x-ray f programs, many unnecessary dental x-rays are given. The American Dental Association has said, " Radiologic examinations should not be used as on automatic port of every periodic or routine dental examination." [n other words, dental and chest x-rays should be given only where there is an indicated need and not as a routine procedure unless there are unusual circumstances. Even then they should be given only when using the best of techniques with modern equipment. I believe, for example, if a person has reached the age of 50, it is a good investment l l I
4 to have on annual chest x-ray but not if the skin dose is greater than 50 mrem. Similarly, if a person has something wrong with his iow that cannot be diagnosed adequately from visual inspection, he should have o dental x-ray, but, hopefully, the single exposure dose would be less than 1,000 mrem (the mean exposure per film for dental x-rays in the United States in 1964 was 1,140 mrem), and the ratio of beam arco to film area would be close te one. Unfortunately, many of our well meaning city fathers and public school officicc aften sponsor mass chest x-ray and dental survey programs that are not warranted. In 1964 over 1/4 of the non-institutional civilian population in the United States was exposed to dental -rays. In the case of dental exposure, os with other sources of population exposure, more attention should be given by our state and federal public health agencies to new sources or types of exposure which become commonplace before any of us give consideration to possible excessive exposure. For example, in 1971 the International Commission on Radiological Protection colled attention to the new radiation protection problem posed by the use of intro-oral x-ray tubes in dental radiography. With the present trend to use tubes of decreasing diameter, the radiation dose at the surface of the tube may amount to 50 to 100 rod or even reore per exposure. It indicated that such uses clearly should be depreciated and that if appropriate filtration were used with extra-sensitive films, the doses could be reduced by on order of magnitude. The mo't s important steps toward reducing unnecessary medical diagnostic exposure are summarized in Table 7. Of these, education, training and certification are by for the most important. Only the States of New York, New Jersey and California require education, training and certification of x-ray technologists who operate most of the x-ray equipment in the United States, and only one State, California, requires that there be courses on x-ray and radiation protection offered in the medical schools and that there be questions on the state board examinations on these subjects. I am sure it is almost inconceivable to you that in all 50 of our states a person is required to have o driver's license before he can operate a school bus, but, in the case of x-roys, the only requirement is how to press the red button on the machine and hope the timers and other equipment operate properly. Even some of the better x-ray departments do not have meters with which they con calibrate 4
]
O o Table 7 IMPORTANT STEPS TO REDUCE UNNECESSARY MEDICAL. EXPOSURE TO X-RAYS
1. Education, Training and Certification Requirements (a) Presently required of doctors only in Galifornia (b) Presently required of x-ray technologists only in New York, New Jersey and California (c) Establish a grade of senior x-ray technologist

2. Improve Techniques (a) Require better techniques in developing x-ray films (b) Require edges of x-ray field to show on film (c) Require dark adaptation of eyes even with improved fluoroscopy

3. Reduce Number of Diagnostic X-Roys (a) Transfer x-roy filn:s from one doctor to another (b) Limit requirements of insurance companies for medical x-rays (c) Discontinue and/or curtail certain types of medical x-rays 4 Use Better Equipment (a) Require use of long cones with rectangular collimation for dental x-rays (b) Forbid use of medical x-ray machines unless equipped with proper meters (c) Require use of patient shields and lead oprons

5. Require Records of Patient Exposure (a) Require a permanent record of dose for each patient exposure (b) Furnish patient with record of x-ray exposures (c) Obtain information to aid in avoiding exposure of fetus

6. Increase inspections -
(a) Inspect all medical x-ray machines and associated equipment annually
~(b) Inspect techniques used in medical diagnoses annually !
(c) Post conspicuously a dated inspection record for each x-ray machine i and its use ; t ; 9 I I b 4-
the x-ray beam. Even worse, most of the diagnostic x-ray equipment in the United States is owned and operated by non-radiologists who have little or no training in its use. Fortunately, the x-ray workload of this equipment by practitioners, chiropractors, osteopaths, etc., is relatively low. It seems to me unthinkoble that a practitioner or his secretary without training and certification in the proper use of x-rays would be allowed to operate these machines and almost as unocceptable that a doctor would be permitted to prescribe on x-ray for his patient when he has no education, training and certification in its use and is not able to weigh the benefits against the risks from such an examination. There is a bill in Congress, S.426, sponsored by Senator Randolph which is designed to require oppropriate education, training and certification of all x-ray technologists. I hope this bill has successful passage through Congress and that it will be followed by other legislation which will require similar education, training and certification of all members of the medical profession. I think it is important we establish a grade of senior x-ray technologist and give him complete responsibility for the calibration and operation of the diagnostic x-ray machine. He should complete a minimum of four years of specified education and training and be given a special certification examination. I Such a professional grade of technologist could assure much better and safer x-ray diagnoses and would save the public many millions of dollors by obviating the need for thousands of additional radiologists. Regarding the improvement in techniques, little more need be said except perhaps to give oaother example where poor techniques are used which result in the overage exposures being many times who't they should. Surveys of the Public Health Service (53) have indicated that most dentists in the United States overexpose x-roy films and j underdevelop them. This assures on image of the teeth on the film but guarantees the l patient will be overexposed and that the film will be of poor quality. I have over 200 letters in my file from persons from all over the United States who apparently t have received on excessive number of diagnostic x-rays. For example, I have a letter from o medical physicist dated January 13, 1971, which states, "A pediatrician brought up the fac; that he was furious because Radiology had taken 22 chest x-rays of one of his patients (on infant) behveen October 2,1970, and November 30, 1970. l l
When the matter was brought to the attention of the Radiology Department, the radiologist replied it was not the responsibility of the X-Ray Department to keep track of the times a patient is x-rayed and that if an order comes down for an x-ray, they will give it." Hopefully, there are very few departments where the head radiologist takes this attitude. However, where this is the case, he is not practicing radiology but rather doing the job of an unqualified technicion, taking orders for the mass production of x-rays. Regarding the need for better x-ray equipment, we may add, for example, to what hos been stated above the results of a survey by the Public Health Service of x-ray facilities within the Bureau of Prisons during 1968. In this survey, they found, for example, the improper cone was used and that the proper cone was not available in 20.6% of the medical x-ray machines surveyed, and the timers were inaccurate and/or gave non-reproducible results in 68% of the dental x-ray machines. Regarding item 5 in Table 7, the matter of keeping records of patient exposure, I readily concede there will be some problems, but the principal problern is that of the reluctance of members of the medical profession to change established practices. They point out the difficulties and time-consuming efforts in making these measurements - and recordings, but there have been several publications pointing out how this could be done mechanically while taking very little additional time of the medical man or the x-ray technologist. For example, Hurst et al have described a recording ionization chamber which con be adopted to any diagnostic x-ray machine. The recording of the dose would be made automatically on a card containing the name of the individual, type of exposure, target-skin distance, kyp, filtration, and exposure area. It is difficult to understand why such equipment is not already in use in this day of computers and information retrieval devices. One can walk into on airport and in a matter of seconds receive information on the availability of airline connections in any part of our country. Such information should be equally retrievable regarding on individual's entire exposure history. This information should be stored in such a way that the doctor by pressing a few buttons would have it displayed before him. It is well known that natural background radiation exposure and medical exposure are not included as components of the ICRP upper limit of 500 mrem /yr to the individual .c
t or 170 mrem /yr overage to the population. I firmly believe medical diagnostic exposure should be included as part of this 170 mrem /yr limit for the overage population exposure. If this were done, greater attention would be given to weighing . t L the benefits against the risks by members of the healing arts os well as by those concerned with the future of the nuclear energy industry. I think it goes without saying that more frequent and more thorough inspections of medical facilities and practices by properly qualified state public health organizations would go a long way toward improving the equipment used for medical diagnosis, upgrading the techniques employed and assuring proper education, training and certification of all those ; involved. In order to accomplish these objectives, we will require cooperation at all . levels of society and government beginning with widespread education of the public not to fear radiation but to give it proper respect; not to avoid a needed diagnosis or i x-ray treatment, but when it is required to seek the best medical advice and make use of those medical facilities most likely to deliver the minimum dose consistent with the radiographic information needed. In order to reduce unnecessary medical diagnostic i exposure, it will require the concern and active assistance of many professional groups and especially of those knowledgeable in matters of radiation exposure (such as health physicists, nuclear engineers, radiologists, x-ray technologists, etc.). Even the legal profession will have on important part to play in these efforts because many x-rays are given not for the benefit of the patient but to protect the doctor from possible legal ! implications and to establish legal claims in case of on accident. I believe in legal matters the Special Committee on Atomic Energy Law of the American Bar Association con be of considerable benefit. For example, in 1968 it was instrumantal in correcting a serious disparity in many state laws which applied the statute of limitations to claims 1 for radiction injury. Prior to this committee's decision, in order to lay claim for radiation injury a claimant would have to establish thathe received radiation injury within a period of about five years offer his radiation exposure in order that his case be given legal consideration. The recommendations of this committee were adopted by the House of Delegates and have been instrumental in modifying state laws and their interpretation such that a person receiving chronic demoge from radiation (i.e., , more then five years of ter radiation exposure) may e#/ct to receive just compensation
I a 1 through court procedures. I have information concerning persons who have been required by insurance companies to receive 10 to 30 x-ray exposures in order to establish the existence or cause of rather minor injuries from automobile accidents.
It seems to me that such use of x-rays is not acceptable, and the Public Health Service should seek the assistance of the Special Committee on Atomic Energy of the American Bar Association in avoiding such misuse of x-rays. Perhaps the picture I have pointed so for regarding the misuse and excess of medical diagnostic x-rays appears a bit discouraging, but there are some signs of' slow progress as indicated in Table 8. Some of us were instrumental in the passage of Public Law 90-602 which has given important authority to the Surgeon General to bring about some of these corrections. However, in order to implement some of the things discussed in this paper, it will be necessary for the various states to pass a number of laws, and here is where all of us as concerned citizens !hould come into the picture. Perhaps one of the most encevreging recent developments is that radiologists themselves are chiding and rebuking their profession in their own publications because of unnecessary and harmful patient exposure. For example, Table 9 is a summary of some of the comments made in a paper by Dr. McClenahan entitled " Wasted X-Roys." Here, he is saying that the ordering of a radiogram has become more or less a mechanical and foregone conclusion even when there is no question about the diagnosis or need for on x-ray. Such practice is justified in the eyes of the doctor because it rules out some finite or remote chance that something else was overlooked (and I might add that it odds a significant cost item to the bill). A number of papers in the medical journals, however, have pointed out that these low yield x-ray diagnoses should not be conducted, not only because of possible damage to the patient, but, also, because they add substantially to the soaring cost of medical care. Drs. Bell and loop point out there are certain types of examinations, for example, where
~
only one fracture in 435 radiographic examinations yielded positive results and even in this case the information was not needed in the treatment of the patient. They point out further that if x-ray examinations of this type would be deferred or omitted, such a strategy on a national scale potentially could result in a yearly saving of 15 million dollars in health care. Brook and Stevenson reported on the outcome a
I' -. Table 8 FAINT SIGNS OF PROGRESS IN REDUCING UNNECESSARY ! MEDICAL EXPOSURES
1. Passage of Public Law 90-602 in 1968.

2. Several states have pending legislation designed to reduce l
medical exposure.
3. Genetically significant dose from medical diagnosis may have been reduced from 55 mrem /yr (1964) to 36 mrem /yr (1970.
l 4. For the first time, radiologists are chiding their profession because of unnecessary patient exposure. i
)
Table 9 SOME PRACTICES CAUSING EXCESSIVE PATIENT EXPOSURE
1. Easier to order on x-ray than think.

2. Exercise " ruling out," i.e., order x-rays when occurate diagnosis has been made with the naked eye.

3. Heavy legal penalties for failure to x-ray but no penalties for unnecessary exposure of patient.

4. Insurance covers most x-ray costs.
l ,
5. More films per diagnosis now required than formerly.

6. Shortage of trained workers leading to hasty, hozordous techniques.

7. Folkways and traditional rites.
G
of 141 emergency room patients who were given various diagnostic x-ray procedures and found that these examinations resulted in effective medical care for 27%, ineffective core for 60%,andneithereffective nor ineffective for 13%. Dr. Sutherland(60) reported skull x-ray examinations showed the lowest incidence of clinical radiological agreement in his study. Only one lesion, o pituitary adenoma, was detected in 70 requests from the medical department. Dr.Sagan(0N was particularly forthright and effective in some of his comments regarding the need for improvement in medical diagnosis. Regarding Dr. McClenohan's reference to folkways and to regional rites, probably he had in mind the prevalent practice until a few years ago, when brought into the limelight by Nader,(62) of -ray technologists in our country giving more exposure to black patients than to white patients. In fact, one of the textbooks commonly used for the training of x-ray technologists recommended this as a general procedure. McClenahan in his article goes on to point out that many x-rays are given for psychological reasons because the doctor wishes to satisfy the patient. I agree this is on important use of x-ray diagnosis and should be continued, but in such case there is no need to turn on the high voltage on the x-ray machine--perhaps odd a buzzer that could be activated. . Fig. 6 summarizes some of the foregoing discussion, emphasizing again the relative insignificance of exposure in the nuc! ear energy industry in comparison with that from niedical x-ray diagnosis. I, for one, believe the potential for population exposure as a result of accidents with nuclear power plants is much more important than the risk of exposure from their routine operations. However, even when we take this into account, the risk again becomes relatively insignificant. In this case in which I consider what I believe are the worst credible consequences of a nuclear accident, I estimate the overage i3 umber of deaths, per year would be about 25, and I believe a more reasonable figure would be three. These figures were obtained by what I consider to be on appropriate scaling and adjusting of some of the factors given in the earlier major accident report, WASH-740.(63) In this case, I applied risk estimates to
~4 1,000 MW(e) power reactors having a probability of 10 occidents per reactor per year. I assumed in this case 25% release of iodine and 100% release of noble gases (or a few 100 million curies), and concluded the exposure, at least with proper 4
i DEATHS / YEAR IN U.S. (NOT INCLUDING DEATH BEYOND ist. GENERATION) O 1000 P.OOO 3000 ,000 7 ww/mww/ww/ MEDICAL X-RAY DI AGNOSIS AT PRESENT - 3000,
/ //########/### ////
x-MEDICAL X-RAY DIAGNOSIS IF SIMPLE N
'/,//ffM7MH~ 77M/7M/7/77777 CORRECTIVE STEPS WERE TAKEN - 300 2 PRESENTLY RELATED TO FOSSIL FUEL POWER PLANTS- ? >50,000 h, ' L. , s o NUCLEAR POWER INDUSTRY IF IT DELIVERED (s O.s mrem /y TO POPULATION - 11 NUCLEAR POWER PLANT ACCIDENTS d~WOeeT AeeUMPT,0Ns - Es MOST REASONABLE ASSUMPTIONS -3 Fig. 6
f 6 preparations, could be maintained at less than 2.5 x 10 man-rem to the total body 6 and 30 x 10 man-rem to the thyroid. This would correspond, for example, to an average of 10% of the USAEC accident design doses (i.e.,10% of 25 rem to the total 6 body and 10% of 300 rem to the thyroid to 10 people). Using the coefficients given in Fig.1, this would correspond to 500 deaths. If we have on average of 500 operating nuclear power plants of 1,000 MW(e) over the next 20 years, this corre: ponds to one accident or on overage of 25 deaths /yr plus a possible 100 to 150 genetic deaths introduced into future generations. Certainly, from post experiences one would expect more likely the release of something between a few thousand curies, and this amount representing a worst possible accident, and on this basis I rather arbitrarily arrived at what I believe is a more reasonable upper figure of three deaths /yr. Table 10 compares the risks from medical diagnosis and the nuclear energy industry with the risks of dying from other causes. Here it will be noted that ! even on the worst assumptions regarding risk from the routine operations and accidents in the nuclear power industry, we should be more concerned about reducing the risk from getting struck by lightning. However, these low reactor risk estimates assume continued isolation of nuclear power plants and on adequate health physics program .. in each of them--something which is not necessarily assured by present plans. Finally, referring again to Fig. 6, we should keep in mind that in choosing nuclear power we do so offer comparing the risks in die use of fossil fuels. We know for less about the risks from chemical environmental pollutants such as hydrocarbons, oxides of nitrogen, oxides of sulphur and particulates than about radiation risks, but the evidence is rather clear that they lead to an increased incidence of chronic bronchitis and emphysema i and seem to relate to many other diseases. Furthermore, we must not overlook the fact which was pointed'out by Martin et al that the radioisotopes discharged from a modern cool plant exceed in quantity and toxicity those discharged from some of the more modern pressurized water reactors. I agree with them that it is fair to say the risk in terms of the fraction of ICRP population dose limit is at least 400 times greater in the case of the fossil fuel plant than the pressurized water reactor plant. Considering, also, the 1,600 year half life of radium-226 (the principal l radionuclide of concern with fossil fuel plants) in comparison with the short-lived
1 1 Table 10 Radiation Risks on the Linear Hypothesis (Deaths /Yr)* Medical Diagnosis 3,000 (30,000) Nuclear Energy Industry Routine at 0.5 mrem /yr 11 (40) Accidents *
Worst Assumptions 25 (150)
More Reasonable 3 (15) i Deaths Per Year From Other Causes in 1967 Heart Disease 721,000 Concer 311,000 Stroke 202,000 All Accidents 113,000 Struck by Lightning ~ 100 l
*Volues in parentheses are upper limits of genetic deaths introduced into the population each year on the overage. ** Figures do not include acute deaths from blast and '
radiation sickness.
tritium and the fact that the residence time of tritium, the noble gases, and iodines in the local environment is for less than that of radium, the relative radiation risks are probably at least on order of magnitude greater than this figure of 400. F e
e References 4
1. Radiosensitivity and Spatial Distribution of Dose, ICRP Publication 14, Pergamon
, Press, New York (1969). l 2. Recommer.dotions of the International Commission on Radiological Protection, ICRP Publication 1, Pergamon Press, New York (1959).
3. The Evaluation of Risks from Radiation, ICRP Publication 8, Pergamon Press, New York (1966).

4. J. H. Muller, " Man--His Environment and Health," Suppl. to Amer. J. Public Health, Port II, Vol. 50, No.1, p. 45 (January,1964).

5. W. L. Russell, " Studies of Mammalian Radiation Genetics," Nucleonics, Vol. 23, No.1, p. 53 (January,1965).

6. ' Accident Facts, National Safety Council, Chicago, Illinois,1970 and 1971 Editions.

7. R. E. Rowland et al, "Some Dose-Response Relationships for Tumor Incidence in Radium Patients," Radiological Physics Division Annual Report, ANL-7760, Part 11, p.1, U. S. Department of Commerce, Springfield, Va. (July,1969-June,1970).

8. Hearings Before the Congress of the United States on Radiation Exposure of Uranium Miners, Ninetieth Congress, Ports I and 2, U. S. Government Printing Office, Washington, D. C. (May, June, July and August,1967).

9. F. E. Lundin, Jr., J. K. Wagoner, V. E. Archer, Radon Daughter Exposure and Respiratory Cancer Quantitative and Temporal Aspects, Monograph No.1, i U. S . Dept. of Commerce, Springfield, Va. (June,1971).

10. A. J. Finkel, C. E. Miller, and R. J. Hosterlik,"Long Term Effects of Radium Deposition i.n Man: Progress Report," Health Division Gamma-Ray Spectroscopy .
Group Semiannual Report, ANL-6839, p. 7 (1964).
11. A Review of the Radiosensitivity of the Tissues in Bone, ICRP Publication 11, Pergamon Press, New York (1968).

12. Safe Handling of Radioactive Luminous Compound, National Bureau of Standards Handbook 27, U. S. Government Printing Office, Washington, D. C. (1941).

13. R. Seltser and P. E. Sartwell, "The Influence of Occupational Exposure of Radiation on the Mortality of American Radiologists and Other Medical Specialists,"
. Am. J. Epidemiol., Vol. 81, p. 2 (1965); "The Effect of Occupational Exposure to Radiation on the Mortality of Physicians," J. Amer. Med. Assoc., Vol.190, p.1046 (December,1964),
i
I
14. K. Z. Morgan, " Maximum Permissible Levels of Exposure to Ionizing Radiation,"
Radiation Dosimeg, Proceedings of the International Summer School on Radiation Protection, held in Covtot, September 21-30,1970, Boris Kidric Institute of Nuclear Sciences, Belgrade, Yugoslavio (1971).
15. Statement of Dr. Robert Moseley reported in article by David Gumpert, The -
Wall Street Journal, VCLXXVill, No.122 (December 23,1971).
16. R. E. Albert, " Follow-up Study of Patients Treated by X-Roys for Tineo Capitis,"
Amer. J. Public Health, Vol. 56, p. 2114 (December,1966).
17. A. T. Sigler et al, " Radiation Exposure in Parents of Children with Mongolism Down's Syndrome)," Bulletin Johns Hopkins Hosp., Vol.117, p. 374 (1965).

18. W. M. Court-Brown and R. Doll, " Mortality from Concer and Other Causes After Radiotherapy for Ankylosing Spondylitis" Brit. Med. J., Vol. 2, p.1327 (1965).

19. R. Doll and P. G. Smith, "The Long-Term Effects of X-Irradiation in Patients Treated for Metropathia Haemorrhogica," Brit. J. Radiol., Vcl. 41, p. 362 (May, 1968).

20. L. H. Hempelmann, " Risk of Thyroid Neoplasms After Irrodiotion in Childhood,"
Science, Vol.160, p.159 (April 12,1968).
21. E. B. Lewis, " Leukemia, Radiation and Hyperthyroidism," Science, Vol.174, p. 454 (October 29,1971).

22. E. L. Saenger, " Radiation and Leukemia Rates," Science, Vol.171, No. 3976, p.1096 (March 19,1971).

23. E. Hammer-Jacobsen, " Therapeutic Abortion on Account of X-Ray Examination Durino Pregnancy," Danish Med. Bulletin, Vol. 6, p.113 (1959).

24. Recommendations of the International Commission on Radiological Protection,
, ICRP Publication 6, Pergamon Press, New York (1964).
25. American College of Radiology Bulletin, Vol. 20, No. 5 (May 15,1964).

26. "Arrerican College of Obstetricians and Gynecologists Adopts New X-Ray Policy," American College of Radiology Bulletin, Vol. 20, No. 9 (September,1964).

27. Brian MacMahon, "X-Ray Exposure and Malignancy," J. Amer. Med. Aac.,
Vol.183, p. 721 (1963).
28. Alice Stewart and G. W. Kneale, " Radiation Dose Effects in Relation to Obstetric X-Roys and Childhood Concers," Lancet, p.1185 (June 6,1970).

29. American College of Radiology, X-Ray Examinations . . . A Guide to Good Practice, U. 5. Governrnent Printing Office, Washington, D. C. (1971). ,

30. S. Jablon and H. Koto, " Childhood Concer in Relation to Prenatal Exposure '
to Atomic-Bomb Radiation," Lancet, p.1000 (November 14, 1970).
31. R. W. Miller, " Delayed Radiation Effects in Atomic-Bomb Survivors,"
Science, Vol.166, p. 569 (October 31, 1969).
32. Glin Bennet, " Bristol F'loods 1968. Controlled Survey of Effects on Health of Local Community Disaster," Brit. Med. J., p. 454 (August 22, 1970).

33. S. Warren and O. Gates, "The Induction of Leukemia and Life Shortening in Mice by Continuous and Low-level External Gamma Radiation," Rod. Res.,
Vol. 47, p. 480 (August,1971). l
! 34. L. D. Marinelli, " Estimates of the Radiation-Induced Leukemia Risk in Man,"
Argonne National Laboratory Radiological Physics Division Annual Report, , ANL-7760, Port 11, U. S. Dept. of Commerce, Springfield, Va. (July,1969 - ! June,1970). ;
35. Report of the United Nations Scientific Committee on the Effects of Atomic Radiation,13th Session, Suppl. No.17(A/3838), United Nations, New York (1958). _

36. Report of the United Nations Scientific Committee on the Effects of Atomic Radiation,17th Session, Suppl. No.16(A/5216), United Nations, New York (1962).

37. J. N. Gitlin and P. S. Lawrence, Population Exposure to X-Roys, U. S.,1964, USPHS Publ. No.1519, U. S. Gov. Printing Office, Washington, D. C. (1966).

38. Population Dose from X-Roys, U. S.,1964, USPHS Publ. No. 2001, U. S. Gov.
Printing Office, Washington, D. C. (October,1969). 1 ' 39. K. Z.Morga~n and E. G. Struxness, " Criteria for the Control of Radioactive
Effluents," Proceedings of the Symposium on Enviror mental Aspects of Nuclear l
Power Stations, held in New York, August 10-14, 1970, IAEA-SM-146/10, . ! IAEA, Vienna (1971).
40. J. C. Matthew and H. Miller, " Radiation Hazards from Diagnostic Radiology,"
Brit. J. Radiol., Vol. 42, p. 814 (1969).
41. G. M. Adrian, " Hazards and Dose to the Whole Population from lonizing Radiations,"
Annals of Occup. Hyg., Vol. 9, p. 83 (1966). 4
l i
42. K. Z. Morgan, " Reduction of Unnecessary Medical Exposure," Hearings before the Committee on Commerce, U. S. Senate, on S.2067, Serial No. 90-49, p. 46, '
90th Congress,1st Session (August 18, 1967); K. Z. Morgan, " Population Exposure to Diagnostic X-Roys and Resultant Damage Con Be Reduced to 10% of Their Present Levels While at the Some Time increasing the Quality and Amount of l Diagnostic Information," testimony presented before the U. S. House of Representatives, Washington, D. C., on H. R.10790 (October 11, 1967).
43. K. Z. Morgan, "Why the 1968 Act for Radiation Control for Health and Safety is Required," Radiology (June,1971).

44. K. Z. Morgan, The Need for Standardization Procedures in the Application of !
lonizing Radiation to Medical and Dental Patients, Seminar Paper No. 003, Clearinghouse for Federal Scientific and Technical Information, Springfield, , Va. (June,1969).
45. K. Z. Morgan, " Adequacy of Present Radiction Standards," presented before the Environmental and Ecological Forum, Silver Spring, Md., Jan. 20, 1971, and to be published by the USAEC Office of Information Services (1972).

46. R. L. Penfil and M. L. Brown, " Genetically Significant Dose to the United States Population from Diagnostic Medical Roentgenology,1964," Radiol., Vol. 90,

p. 209 (February,1968).

47. What About Radiation? Mass Chest X-Ray Programs, USPHS Publ.1196, U. S. ,
' Gov. Printing Office, Washington, D. C. (February,1965).
48. American Dental Assoc. Council on Dental Materials and Devices and Council on Dental Research, " Radiation Hygiene and Practice in Dentistry. IV," J. Amer.
Dental Assoc., Vol. 76, p. 363 (February,1968). i
49. R. G. Winkler, " Influence of Rectangular Collimation and Intraoral Shielding on Radiation Dose in Dental Radiography," J. Amer. Dental Assoc., Vol. 77, '
No.1 (July,1968).
50. D. D. Weissman and G. E. Longhurst, " Clinical Evaluation of a Rectangular Field Collimoting Device for Periopical Radiography," J. Amer. Dental Assoc.,
Vol. 82, p. 580 (March,1971).
51. F. M. Medwedeff and W. H. Knox, " Radiation Reduction for Children," The i Journal of the Tenn. State Dental Assoc., Vol. 42, No. 4 (October,1962).

52. R. L. Walchle, H. F. Stewart and J. M. Morel, Development and Evoleation of on Automatic Collimator for Medical Diagnostic X-Ray Machines, MORP 68-9, U. S. Gov. Printing Office, Washington, D. C. (1968).
a e,
53. D. R. Chadwick, "USPHS Division of Radiological Health Program in X-Ray Protection," presented at the Public Health Conference on the Use of X-Roys in Medicine and Industry, University of Miami, Coral Gables, Fla. (April 13-15, 1966).

54. " Bulletins and Highlights," J. Amer. Dental Assoc., Vol. 76, No. 2 (February,1968).

55. L. C. Seabron, Radiation Safety Surveys of X-Ray Facilities Within the Bureau of Prisons During 1968, BRH/DEP 70-19, p. 7, USDHEW, Public Health Service, Rockville, Md. (July,1970).

56. G. S. Hurst, Norbert Thonnard and Karl Schneider, "A Recording Exposure Control for X-Ray Machines," Health Physics, Vol. 21, No.1, p. 91 (July,1971).

57. J. L. McClenahan, " Wasted X-Rays," Radiology, Vol. 96, p. 453 (August,1970).

58. R. S. Bell and J. W. Loop, "The Utility and Futility of Radiographic Skull Examination for Trauma," The New England J. of Med., Vol. 286, p. 236 (February 4,1972).

59. R. H. Brook and R. L. Stevenson, " Effectiveness of Patient Care in an Emergency Room," The New England J. of Med., Vol. 283, p. 904 (October 22, 1970).

60. G. R. Sutherland, " Agreement Between Clinical and Radiological Diagnosis,"
Brit. Med. J., Vol. 4, p. 212 (October 24, 1970).
61. L. A. Sagan, " Medical Uses of Radiation," J. Amer. Med. Assoc., Vol. 215, No.12, p.1977 (March 22,1971).

62. Ralph Nader, " Wake Up America, Unsafe X-Roys," Ladies Home Journal, Vol. 85, p.126 (May,1968).

63. Theoretical Possibilities and Consequences of Major Accidents in large Nuclear Power Plants, WASH-740, Division of Civilian Application, USAEC, Washington, D. C. '(March,1957).

64. J. E. Martin, E. D. Harward and D. T. Oakley, " Comparison of Radioactivity from Fossil Fuel and Nuclear Power Plants," unpublished Public Health Service report (November,1969).
I L l
.._________________.________j
#am .. .l; . , ) b /1 ESC, AIF, EPI Conference on Low-Level Radiation Are the Current Standards and Guidelines for Low-Level Radiation Adequate to Protect Public Health?
What Are the Current Standards? by Karl Z. Morgan Neely Professor School of Nuclear Engineering Georgia Iastitute of Technology Atlanta, Georgia 30332 If I attempted tc summarize all the standards, guides and recocmendations on radiation protection that have (or intend to have) some influence in providing protection of radiation workers and members j of the public, it would take most of this morning session. Even if I were able to do a thorough job in such an effort, I do not believe it would contribute importantly to the question of adequacy of radiation protection standards which we are eager to begin disucssing at this Congressional Conference. I will, however, indicate briefly what are our basic radiation standards and how they have been developed. At this ( Conference we will limit our discussions to standards as they relate to l ionizing radiations; however, some of us are acutely aware of the need for a similar Conference to deal with non-ionizing radiation (sonic, l ultrasonic, infrasonic, light ultra violet, infrared, microwave, radio l frequency and very long wave radiations). i These introductory comments vere made by the Panel Moderator, Dr. Karl Z. Morgan. This Conference,was held in the Dirksen Senate Office Euilding, Washington, D. C. 20515, February 10, 1978. 1 s-
_.-.A.
.. A At the outset it must be recognized that the most important, most . influential, and universally applied standards are not laws or regulations or even codes of practice. They are simply recommendations of the International Commission on Radiological Protection (ICRP), the , National Council on Radiation Protection (NCRP) and publications of the National Academy of Sciences - National Research Council ench as recommendations in the so called BEIR report. -
There are many Covernment agencies which get into the act of setting,
, interpreting and enforcing radiation protection standards and this,is part of the problem. For example there are many Case-Agency situations, a few of which are:
TABLE I Case of Exoosure Responsible Government Agency
1. Exposure in uranium mines B,ureau of Mines, Labor Dept., NRC, PHS, DOE, EPA, State Agencies ,

2. Population exposure in EPA, BRH, HER, DOE, NRC, State Agencies
' city 51 miles from a nuclear reactor
3. Transportation of radio- DOT, EPA, NRC, DOE, State Agencies active materials

4. Permanent disposal of EPA, DA, DOE, DOT, NRC, ICC, State Agencies radioactive vaste

5. Dangerous or ineffective use DOE, HEW, HUD, NRC, OSHA, NIOSH, of radioisotopes, e.g. State Agencies Am-241 in smoke detectors

6. Excessive medical exposure EPA, BRH, State Agencies (up until of members of public recently essentially no control) k l
J . 2 1 3 .
.. q; , - As indicated in testimony I gave before Congressional hearings last week,( } since 1950 there have been quantum drops in the maximum permissible exposure.(MPE) levels by a factor of 10 for occupational exposure (from 52 R/y to 5 rem /y) and by a factor of 300 for members of the public (from 1.5 rem /y to 5 mrem /y). As a matter of fact, these jumps are much larger in some cases because it is generally recognized from both theory and experiments that there can be no safe level of exposure to ionizing radiation in the sense that tba risk (e.g. the risk of causing cancer) is zero and no MPE can be set so low that the risk is zero. As a consequence the philosophy of keeping exposures As Low As Reasonably Achievable (ALARA) has been adopted by ICRP, NRC, EPA, the EEIR Committee, etc. Thus, if the dose from color TV or from a luminized watch or a smoke detector can be kept reasonably at or near zero, this is what should be done and for such products the drop -
in MPE bacomes essentially infinite (i.e. down to zero). Unfortunately, i l our government Agencies often are faced with an after-the-fact situation l and cust set appropriate levels for plutonium and americitim in the environ =ent due to cessy and unsatisfactory operations at a plant in Rocky Flats, Colorado. Or the State of New York, DOE, NRC, etc., must set specific standards (or make choice of the evils) that are applicable to the West Valley Reprocessing Plant (about 30 miles from Buffalo, NY). The priacipal radiation standard we are here to discuss (or debate) today is the occupational MPE level of 5 rea/v to the total body and by implication we may refer to 'he numerous environmental levels of 0.5 rem / (max), 0.17 rem /y (av), and operational levels of NRC such as 0.003 rem /y for liquid effluents, 0.01 rad /y for y-gaseous effluents, 0.015 rem /y *
.3 V
a . . a .
. o for radioiodine and particulates, etc. We would be seriously remiss in our discussions were we to fail to consider internal dose from radioactive materials deposited inside the body or values of maximum permissible body burden, q(pC) and corresponding maximum permissible concentration, MFC (pCi/cc), for the various radionuclides in air, water and foods. At the present tfsa values of q are based on the amount of tha radionuclide in the total body that would under equilib-rium conditions or in 50 years result in the limiting occupational dose rate R (rem /y) to the critical body organ. The values of MPC are the concentrations of the radionuclide (pCi/cc) in air or water (including that in food) that would af ter 50 years of occupational exposure (40 hrs /wk with 2 wks/y vacation) result in a body burden q or a dose rate R to the critical organ (see Table II for present values of R of MPE). For most l- radionuclides equilibriu= is reached in' days or weeks; for example, exposurc '
to the MPC of I-131 for 50 days results in a dose rate of 29.69 rem /y to the thyroid (99% of the ITE of 30 rem /y for thyroid) because the effective l half life of I-131 is only 7.6 days while exposure of Pu-239 for 50 years results in a dose' rate of 30 rem /y to the bone but only 16% of equilibrium
,i is reached because the effective half life of Pu-239 in human bone is 197 years. It is for this very reason that it would be unfortunate for an employee to deposit a total body burden of Pu-239 in his body because than with no additional intake of Pu-239 he would receive a dose to the skeleton of 30 rem /y essentially for the rest of his life.
One of the most unfortunate recent developments in the setting of l standards for exposure to ionizing radiations is that ICRP has issued its report ICRP No. 26(2) in which it is recommending weighting factors, W ,
f .
~
4 a .
). , ~. .
. I .' which I interpret will result in large increases in the present ICRP values of MPE (or R) and in all values of q and MPC except where ,the radionuclides are rather uniformly distributed throughout the. body (i.e. they are total body seekers). The table below summarizes these values. -
TABLE II Organ Present value of Values.of W New Values of MPE or R (rem /y) in ICRP No. 26 MPE or R (rem /y) total body 5 1 5 gonads 5 0.25 20 breast 15 0.15 32 red carrov 5 0.12 42 lung 15 0.12 42 thyrdid 30, 0.03 167 bone 30 0.03 167 skin 30- -
.re=ainder 15 0.3 -
17 I should say that it was only yesterday after many. months effort that I finally received a xerox copy of ICRP No. 26 so'my interpretation above may be in error. . . \ - I consider this report a retrograde step of the ICRP because it comes at a . time when their own reports emphasize that the cancer risk is 10 to 20 times what we considered it to be 15 years ago. This change was made in an effort to remove the inconsistency that the NPE for total body has ~ been the same as that for gonads and red marrow. What ICRP should have done is normalize on an MPE of 5 rem /y for gonads and red marrow and set the MPE for total body at some value less than 5 rem /y. I sincerely hope
!CRP, BEIR, NRC, EPA, etc. , in this country will raise strong objection -
to this move of ICRR and reject these new values which would tend to increase q und MPC.
-; 5 .
t t.
. . o.
Finally, we must keep in mind that according to the linear hypothesis it is not the values of annual MPE which we set that limit the annual risks of cancer and genetic mutations but the annual population dose (man.ren/ year). This is why I have been skeptical about the effectiveness of lowering the MPE. For example, most of the National Laboratories of DOE, EPA, BRH, etc., maintain individual exposure levels at less than 5 to 10% of the MPE. However, operations like West Valley and many of the nuclear power plants have not been able to stay below the individual values of MPE without hiring more people on temporary basis and spreading out the dose. This practice is called " burning out employees." This always increases the population dose (man.ren/y) because on hot operations, much of the dose i is on entering and leaving the hot area and because temporary employees are not as familiar with the risks or skilled in the job. I consider this practice i= coral. I hope in our discussions today we will provide 4 the Congress of the United States a better basis for setting radiation protection standards. , l
, REFERENCES .
1. K. Z. Morgan,'" Significance of Human Exposure to Low-Level Radiation," .
presented at the hearings on Low-Level Exposure before the Subcommittee on Health and the Environment of the Committee on Interstate and l Foreign Commerce of the Congress of the United States, Washington, D. C., January 24, 1978. .
2. Recommendations of the International Commission on Radiological Protection, ICRP No. 26, Pergamon Press (1977).
O e O e e 6
i. . ~
/
31. j.' t Reprint from i .
" ADVANCES IN RADIATION PROTECTION MONITORING" l
l l \ l .
~ .
l l i i-4' I INTERNATIONAL ATOMIC ENERGY AGENCY VIENNA,1979 l l 1
- '~ . % 9 i
g .*A %$ j
. . .;.:, - i ' . .I c, w : ' ~. - [ * :. .
1-'~ ...,l. , 1 ; ' .. .. h.
o . I AE A.SM.229/139 Invited Paper THE PURPOSE OF RADIATION PROTECTION MONITORING K.Z. MORGAN School of Nuclear Engineering, Georgia Institute of Technology, Atlanta, Georgia, United States of America Abstract i
, Tile PURPOSE OF RADIATION PROTECTION MONITORING.
In the early period (1942-1960)of nuclear energy programmes with which I was associated, most radiation protection standards seem to have been formulated on the assum[ tion that there is a threshold dose of ionizing radiation below which no radiation damage is expected to resu!r in the lifetime of the exposed individual. It was in this climate of opinion that health physics began as a profession, and levels of maximum permissible exposure (MPE) to external
'y sources of radiation, maximum permissible concentrations in air, water and food, and maximum permissible body burdens of radionuclides inside the human body were set and enforced. Some of the levels of MPE were quite high in comparison with present standards but, fortunately, the health physicists at the nationallaboratories in which most radiation workers were employed were very conservative; in most cases the average annual exposures were less than 10% of the MPE levels. Ilowever, there was not much concern with the man-rem concept, as exemplified by rather high levels of radioactive waste discharged from the plants or placed in temporary holding facilities - where there was a likely possibihty of seepage into the environment. This situation was understandable and justifiable at a time when the purpose of radiation protection monitoring was simply to prevent individuals from exceeding a threshold dose. The period of the recent past up to the present time (1978) has been one in which there has been a gradual change from the concept of a threshold dose hypothesis to the linear hypothesis. In this period the International Commission on Radiological Protection (ICRP) ar.d the national standards setting bodies have pointed out that the levels they have selected are based on the linear hypothesis, but in most respects they leave us with the impression that this is most probably a conservative assumption, subject to revision when better data become available. Also, during this period, the concept of exposure As law As Reasonably Achievable ( ALAR A) was neveloped.
Ilowever, some parts of the nuclear industry began to experience difficulties in living within the MPE levels and ignored the principles of ALARA. In spite of strong evidence that the risk of radiation injury at low levels of exposure is related more to the man-rem dose than to the MPE of individuals, they resorted to the pseudo solution of spread ng out the dose from " hot jobs" by hiring temporary employees or to a practice commonly referred to as " burning out of employees", This practice is frowned on by the United States Nuclear Regulatory Commission and, hopefully,it will soon be discontinued by better conformance with ALARA. The period of the present and into the future seems to portend an increasing awareness that no level of exposure to ionizing radiation can be so low that the risk of radiation injury is zero. Thus, tlie purpose and mission of health physics must be that of ALARA, and of balancing the benefits against the risks, and of choosing the energy sources for which this balance is most favourable to all mankind.
,6 ,
MORGAN IAEA.SM.229/139 7' useful to have a quick answer to th isotopic abundance of radionuclides of energy K 30 kV) X-rays. SinClar mstruments could be dev loped for X, y,c # strontium, caesium, iodine, cobalt. plu* onium, americium, etc. Some nuclear and neutron area surveys and for air sampling. If such instruments had been reactor power plants are using simpk C 7g BIS counter to assess the neutron avaitalde to the Radiological llealth Service Department of the State of Georgia dose when it is well known this 3 n only provide some estimate of the in 1972 when the nuclear reactor site near Dawsonville, Georgia [2], was total neutron flux I N(E), whi mber of terms in the well known decommissioned, much adverse publicity could have been avoided. niutron dose, Dn ( m), equal hiicrodosimetry, too, would require better instrumentation. There is an increasing need to know the local dose in body organs, such as the absorbed dose
- at the third bifurcation of the bronchus, the dose in lymph nodes, the dose to the l endosteal tissue of bone, etc.
Dn = 1.602 X 10' Ni oij(E) EE._eijN(E) Qej Nj t hiuch of thisSymposium is devoted to a discussion of desirable characteristics i j E of radiation detection or measuring instruments, so here I will only list what ! l consider to be some of the more important or essential characteristics of an l l instrument that is to meet the purpose and requirements of a well developed Also many plants either provide no neutron personnel nionitoring or are using health physics programme. Typically one requires: the NTA photographic emulsion which may be as useful as no monitoring at all. Although it has been shown by Sohrabi and Morgan [l] that personnel monitoring 1. Survey meters that are easy to read and not likely to be misread. with polycarbonate foils that are processed by the electrochemical etch technique 2. Meters that are energy independent over the range for which they are used. provides a sensitivity of more than 10 000 times that of the NTA fila and does 3. Survey and personnel monitoring instruments that are rugged. not lose information due to track fading, only one company in the USA is 4. Instruments that can be zero set in the operating area. providing this type of neutron monitoring service and it has only a few customers 5. Instruments that can be decontaminated easily. I for this service. 6. Instruments that operate properly under weather conditions to which they j are exposed. l
7. Pulsed instruments with a short time constant.
Underground uranium mines 8. Instruments whose readings are not affected by external electric or magnetic fields or by light and temperature changes. Underground uranium mines are still operated without adequate personnel 9. Instruments whose sensitivity can be adjusted easily during calibration, monitoring of 222Rn in spite of the fact that several promising metering systems 10. Instruments whose cost is low. have been developed. Maybe most of the fault is with mine operators and the 11. Instruments that are convenient to use: low weight, small size, easy to carry, miners themselves; but perhaps if more reliable, convenient and cheap radon etc. personnel monitors were provided, they would be in common use. 12. Instruments with a low zero drift.
13. Instruments giving the desired accuracy in measurement of absorbed dose.

14. Instruments that are not excessively geotropic with a small parallax error.
15 An instrument that, when it fails, should failsafe so that the operator can be Decommissioning confident that it is operating properly at all times. aue es s u lau a 1 ng mea ama ty p Decommissioning of nuclear facilities is becoming a specialized, very common
17. Instruments should have proper range settings.
cnd important health physics operation. Especially adapted instruments would
18. Instruments should respond essentially to one type of radiation at a time.
improve these operations. llcre, for example, .mstruments are needed that can be
19. Instruments should not loose information due to leakage or track fading.
used to survey rapidly and with precision very large areas. The US Bureau of Radiological llealth developed an instrument of this type consisting of an array From the above list it is recognized that no health physics instrument is of thm wmdow Geiger-M0ller counters operated m such a manner that the output perfect but, as seen from papers presented at this Symposium, many instruments response was only that from the GM counter detecting the highest dose rate. are in use that can and should be improved to provide a more reliable radiation This mstrument was used for rapid survey of TV sets to measure beams oflow _; ; d W,
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10 MORGAN I AE A.SM 22i/ID II plus the results of a number of epidemiological studies on the effects of exposure Without question there is a wide variation in the susceptibility of persons , to low levels of ionizing radiation have resulted in " quantum" drops in the levels for the development of cancer. Burch [8] suggests that t' %)opment of l of 51PE. For example, the oc:upational blPE was reduced by a factor of 10 by cancer may require a series of random events in a single cei. .. . body, like ICRP from 1950 to 1956 (from ~ l R/ week in 1950 to 5 rem /a in 1956) and the throwing electrical switches that are connected in series. For example, one switch exposure limit for members of the public was reduced by a factor of 300 from may be thrown genetically in certain families and other switches may be thrown 1952 to 1974 (NCRP suggested 1.5 rem /a in 1952 and the USERDA suggested by bacteria, viruses, chemicals, radiation, etc. As a person gets older his body 5 mrem /a near a nuclear plant in 1974). contains more and more surviving cells with one or more switches thrown and an The situation in this early period (1942-60) has resulted in surprisingly few nereasing number of sites in the body where a malignancy may first manifest overexposures (e.g. few occupational exposures in excess of the total body h1PE itself. Studies by Bross [9] lend strong support to such a series of events and of 5 rem /a). The main problem was that a philosophy based on the threshold indicate that certain diseases may throw one of these switches in many cells of the hypothesis strove to keep individual exposures below the MPE but did not body such that there is a synergistic relation between these diseases and exposure address adequately the question of population exposure (i.e. man rem). Because to low levels of radiation. Ile [101 found that the risk a child will die of leukaemia of this,it is extremely fortunate that most health physicists have been conservative increases 5000% if the child received medical in-utero X-ray exposure and had a in setting radiation exposure limits for operations under their supervision and in disease such as asthma, hives, eczema, allergy, pneumonia, dysentery or rheumatic fev ; most large operations the average annual doses have been kept below 10% of Alany studies indicate that middle aged persons are less susceptible to the AlPE. radiation induced cancer or that it is the young persons [9-19] and the older { persons [5,19,20] that are most radiosensitive. Such studies suggest to some ' of us that when we have a " hot" job that must be performed, perhaps we should select healthy middle aged persons for the task; and certainly we should not give
4. PURPOSE OF RADI ATION PROTECTION h!ONITORING DURING Ti1E these assignments to women who could be pregnant.
PRESENT PERIOD As indicated above, many studies [7,21-26] have indicated that in the case of man the linear hypothesis is non-conservative. Since 1960 a vast amount of human exposure data have been accumulated Many times we hear the rather careless statement that there are no data which lend strong support to the non-threshold hypothesis. I say non-threshold showing a significant increase in radiation related malignancies in man at low rather than linear hypothesis since much of these data [7] suggest the linear doses. If we are willing to define low doses as the annual occupational h1PE hypothesis is non-conservative at low doses and dose rates especially for high-LET values, this statement is untrue. Stewart and Kneale [l1,271 have shown that the radiation. This is somewhat in contradiction to the ICRP, which implied in early risk ofleukaemia is about 3 X 10'* leukaemias per man rem and the total cancer publications (in which it based itsstandards on the linear hypothesis) that it was risk is about 6 X 10-* cancers per man rem down to doses in the range of 0.2 to most probably making conservative assumptions. Thus, the threshold hypothesis 0.8 rad for in-utero exposure. Modan et al. [17], and Silverman and lloffman is no longer tenable and there is no so-c t safe level of exposure. No dose of [18] have shown that the risk of thyroid carcinoma is about 1.2 X 10" thyroid ionizing radiation can be so low that the risk of radiation damage (even damage cancers per man rem down to 6.5 rad. Mancuso et al. [19l report a risk of several such as fatal cancer) is zero. The risk is simply one of chance tha one of the types of cancer among IIanford workers that is about 70 X 10-* cancers per billions ofionizing particles (photon, a, #, neutron, etc.) that strikes the body man rem for doses in the range of 1 to 2 rad. These doses (0.2-0.8,6.5 and during a small exposure will produce a change in a single cell of the body such 1-2 rad) are the lowest for which studies of statistical significance oflarge human that it survives in its perturbated form to grow into a clone of cells that 5 to populations have been conducted and for which a non-threshold hypothesis l 30 years later is diagnosed as a malignancy. Even with a small dose of X-rays applies - they should not be construed as the doses at which the linear hypothesis l of one rad, about 2.2 X 10' photons /cm2 strike the body, so it is simply a matter breaks down for those malignancies in man. Present evidence suggests that the j of chance that one of the many damaged cells survives to become the precursor non-linear hypothesis probably holds down to zero dose and that the relationship l of a cancer. Thus, radiation risk is similar to other common risks in everyday life. between cancer induction, C, and dose, D, is given by the simple equation: For example,like the risk we take when we ride in a taxi - the more and the longer C=M the trips we take, the greater the risk; but only one taxi ride in an unlucky person's life could be the one that takes his life. m which n < 1 in most cases of human exposure. Studies of Baum [21] indicate M_ i
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[ .. M _GAN I AE A SM.229/13, 15 l7j MORGAN, K.Z., **The linear hypothesis of rtdiation damrge apperts to be non-l31l MORGAN, K.Z., Reducing medical exposurs to ionising radiation, Am. Ind. flyg. Assoc. conservit:ye in many c ses**, Proc. 4th Int. Congr. IRPA t Pzris,1977), I RPA (1977) J. 36 (May 1975) 358. [8] BURCil, P.R.J.," Age and sex distribution of some idiopathic non-mabgnant conditions [32] GOLDEN, J.C. Effect of a change in regulatory lirmts for occupational radiation exposures of manpower requirements and radiation dose (man rem) experiences at a nuclear power in man , Radiation and Conditions in Man, Radiation and Ageing (Proc. Colloq. Austria: LINDOPAND, P.J., SACIIER, G.A., Eds), Taylor & Francis (1966) I 17. station Commonwealth Edison Co.(16 Dec.1975).
- l33) INTERNATIONAL COMMISSION ON RADIOLOGICAL PROTECTION, Recommenda-( Also see Chapter II and references in text of Principles of Radiation Protection tions of the ICRP,ICRP Publication 26, Ann. ICRP 13,Pergamon Press, Oxford (1977).
(MORGAN, K.Z., TURNER, J.E., Eds), R.E. Krieger, Publisher (1973).) [9] BROSS,l.D.J., Leukemia from low-level radiation, New Engl. J. Med. 287 (22 Jul.1972) 107. [10j BROSS,I.D.J., Proceedings of a Congressional Seminar on Low-Level Ionizing Radiation, Itouse of Representatives 94th Congress, reprinted by and available from the Fnvironmental DISCUSSION Policy Institute,317 Pennsylvania Ave. S.E., Washington, DC 20003. [Il] STEWART, A., KNEALE, G.W., Radiation dose effects in relation to obstetric X-rays and childhood carcer, Lancet (5 Jun.1970) 1I85. gggg g p g gp g g [12) M ACM AllON, B., X-ray exposure and malignancy, J. Am. Med. Assoc. 183(1963)721. recommendations) values for design and planning. At present they are the lower
- [13j BEIR Committee, The effects on populations of exposure to low levels of ionizing limits of a forbidden region: while doses above the limits are automatically radiation, Natl. Acad. Sci, and Natl. Res. Council (Nov.1972). forbidden, doses below the limits are not automatically permissible. In this
[I4l IlEMPLEMAN, L.II., Neoplasms in youthful populations following X-ray treatment in sense the limits are only boundary conditions for the optimization requirement infancy, Environ. Res. 1 (1967) 338. ( A LAR A, i e. as low as reasonably achievable). [15] IIEMPLEMAN, L.II., Risk of thyroid neoplasmas afterirradiationinchildhood, Science 160 1 (1968)159. [16] ALBERT, R.E., SilORE, R.E., Follow-up study ofirradiated tinea capitis cases, Pusented concept of ALARA and for the emphasis it now places on it. I am pleased that at 100th annual meeting of the Am. Public Ilealth Assoc.(1972). our Nuclear Regulatory Commission (NRC) and some of our agencies such as the [17j MODAN, B., M ART, II., BAIDATZ, D., STEINITZ, R., LEVIN, S.G., Radiation induced Environmental Protection Agency emphasize the importance of the ALARA head and neck tumors, Lancet 1(23 Feb.1974) 277. concept. For example our NRC has attached a dollar value of $1000 to the [18) SILVERM AN, C., llOFFM AN, D.A., Thyroid tunor risk from radiation during childhood, man rem and stipulated that modificationsin equipment or its use should be Prev. Med.4 (1975)100 [19] MANCUSO, T.F., STEWART, A., KNEALE, G., Radiation exposures of llanford workers made if a man rem can be saved by the expenditure of $1000, even though dying from cancer and other causes,Ilealth Phys. 33 5 (5 Nov.1977) 369. individual exposures are far below the MPE values. It is to be noted that,if the [20] LEWIS, E.B., Leukemia, radiation and hyperthyroidism, Science 174 (29 Oct.1971) 454. overall cancer risk is 6 X 10" cancers per man rem this corresponds to $1700000 [21j BAUM, J.W., Population heterogeneity hypothesis on radiation induced cancer, llealth per cancer prevented. Phys. 25 ( Aug.1973) 97. For purposes of design, operation and control, however, we must provide [22l CRAIG, A.G., Alternatives to the linear risk hypothesis,llealth Phys. 31 (Jul.1976) 81. values of maximum permissible exposure (MPE). I hope ICRP will not make use [23] BROWN, J.M., Linearity vs. non-linearity of dose response for radiation carcinogenesis, Ilealth Phys. 31 (Sep.1976) 231. [24j IIOLFORD, R.M., The relation between juvenile cancer and obstetric radiology,llealth for the occupational worker or members of the public will be increased. This is Phys. 28 (Feb.1975) 153. of specialimportance with reference to permissible body burden or MPC in cases [25l LANDAU, E.,llcalth effects of low-dose radiation: Problems of assessment, Int. J. where a radionuclide has a large local concentration in a single body organ. Environ. Stud. 6 (1974) 51. B. LINDELL: Mr. Morgan's problem with the new ICRP recommendations [26] GOFMAN, J.W., TAMPLIN, A.R., The question of safe radiation thresholds for alpha and the retention of the 5 rem annual dose limit is probably due to the la;k of emitting bone seekers in man,Ilealth Phys. 21 (1971) 47. guidance on the application of the recommendations in the new ICRP Publication 26. [27] STEWART, A., Low dose radiation cancers in man, Adv. Cancer Res. 14 (1971) 359 [28] ROWLAND, R.E., FAILLA, P.M., KEANE, A.T., STElINEY, A.F., Dose Response ICRP has clearly stated that continued work over many years near the dose limit Relationships for Tumor Incidenca in Radium Patients, Argonne National Laboratory, would mean work which cannot be classified as " safe"in the same sense as in Radiot. Phys. Div. Ann. Rep. ANL-7760 (July 1969-June 1970), Part 11, US Dept. of occupations which are usually considered safe. Such high doses would only be Commerce, Springfield, VA (1970). acceptable (just as less safe non-radiation work such as construction work, mining, [29] ROTBLAT.J., The puzzle of absent effects, New Sci. (25 Aug.1977) 476. hich4ca fishing, etc. are accepted even though they are not " safe") if(i) the [30] MORGAN, K.Z., Risk of cancer from low level exposure to ionizing radiation, accepted pr.n tice is /mtif7cd and (ii) the protection is optimized so that, below the dose for publication Bull. At. Sci., Sep.1978. h'*. It is not reasonable to improve protection further. I I L a.. s,
4 A t A-SM.2 29/ 8 39 I# 4 In most cases of radiation work, however, it will be found that it is not ilms the average dose per man-day was far lew at nationallaboratories than at reasonabic to accept doses near the limits. As a result of optimization assessments, nuclear power plants. At these power plants 39.5% of the dose was from special therefore, authorities would be expected, for various purposes, to set authorized maintenance and 31.7'1 from routine maintenance in 1976. A large fraction of the operationallimits below the ICRP dose limits. Without this extra limitation, man rem dose al the PWRs was from "Co and 58Co exposure from steam Mr. hlorgan's concern is understandable. The confusian arises from the fact that generator repair and inspection. while much of the dose at the BWRs was from ICRP has not yet issued the application recommendations. work around the recirculation pumps and clean-up systems fuel-handling equipment, K.Z. MORGAN: We willlook forward to the publication by ICRP of etc. I think the principal fault with power reactors is that they were not designed recc,mmendations on the application of dose limits and of the concept of ALARA, with the principle of ALARA in mind. Inadegaate prousion was made for Regardless of what we call the values (e.g. maximum permissible exposure, dose maintenance, repair and inspection to keep the man rem dose ALARA. In contrast limits or radiation protection guides), we must have limits for proper control of to the situation at nuclear power plants, at ORNL each piece of equipment, each radiation exposure. reactor, each project was carefully planned - from its initial design stage to its In the early period, when most exposures were at large laboratories such as grave - with ALARA in mind. Oak Ridge National Laboratory or liarwell,it was easy for the average exposures E IlOFERT: In view of what has beer, said and referring specifically to the in health physics programmes to be limited to less than 10% of the MPE. Now, example of the increased leukaemia rate among American shipbuilders, none of however, with certain difficulties en tered at many of our reactors (such as whom received a dose of more than 40 rem during their working life, would you the build-up of 58Co and
Co in tl .. generator of the PWR), many workers advocate a limit for a " working-life dose"? It is indeed a fact that it is always are averaging close to the MPE of 5 Le a. In fact the exposures are so high that the same relatively small number of radiation workers who receive the high doses manufacturing company employees and temporary employees are called in to in a nuclear establishment.
share the exposure and reduce that received by the local power plant operators K.Z. MORGAN: Perhaps the Chairman would care to respond to that? (the practice referred to in my paper as " burning out of employees"). Now that D. BENINSON (Chairman): The purpose of the ICRP dose limitation system we all recognize the risk of radiation-induced cancer to be much greater than regarding occupational exposure is to limit tbc risks resultingfrom the occupation, was once considered the case, I believe it is very important that ICRP should not irrespective of other types of risk or of risks that might be experienced in the take any action that might increase individual or population dose. future when working in the same or other radiation occupation. The selection G. COWPER: You have suggested that more effort has been made at of annuallimits instead of working-life limits ensures that the safety of the national nuclear energy re.,carch establishments than at other institutions to limi' occupation is maintained at the prescribed level, ave age dose levels to a small fraction of the maximum permissible vames. Y. NISillWAKl: We are very grateful to you for giving us such a comprehensive Ilowever, this apparent success may be due only to the fact that at such institutions introductory Iceture. liowever, because the paper covers a wide field of radiation nearly all the workers, no matter how slightly they are exposed to radiation, are protection, I noticed a fe>. points which may need some clarification. Firstly, required to wear dose-meter badges and records of their trivial exposures are you state that neutron pasonnel monitoring with polycarbonate foils processed available. by the electrochemical etch technique provides a sensitivity more than 10 000 times K.Z. MORGAN: I am sure that to a certain extent what you suggest is true; greater than that of NTA film. Ilowever, according to our limited experience, at some of the nationallaboratories everyone is monitored with a film badge and a cellulose nitrate would be more sensitive than the polycarbonate for detecting fast considerable fraction of these personnel receive little or no radiation exposure. neutrons directly by counting the etched recoil track:.on the plastic foils. If we flowever. I believe we should expect the radiation risks to be much greater at these use fissile materials with high neutron fission cross-sections placed in contact with laboratories than at a nuclear power plant because of the great variety of radiation the plastic foils and count the etched tracks of fission fragments on the plastic sources and the unpredictable nature of research. In 1976 the average man rem foils after neutron irradiation, a much higher sensitivity would be obtained. For dose at a nuclear power plant operating in the USA was 1200. The average number what range of neutron energy did yo btain such a high sensitivity and what of employees in each plant was about 600 so the average dose was 2 rem. On the particular methods did you use? other hand, large national laborshries with over 6000 employees (e.g. Oak Ridge K Z. MORGAN: The increased sensitivity by a factor of 10' refers to the National Laboratory and Argonne National Laboratory) were averaging less than rmo of the sensitivity obtained when measuring absorbed dose (rad) with our a total of 1000 man rem. In some of the power plants half of the exposure was r A .uiunate foil electrochemical etch technique to that obtained when measuring to temporary employees who were hired on a short-term basis for " hot" operations. O " s ! .f. a wnh NTA films. When NTA films are used to measure neutron dose, w
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e a s r r s mon aer anas pe rots u nl s eih t s ai c t s s t o c a ol or b se u p h r e o ae c wr t f scb e u ed t t nt f pfoe o fn ie wa c e emIwupay e heihs a s d s nt c e ud t 8 h ows p u jTdf h e io d oh s of o l g t od t toh n lc let Tk t h ai a osd h u le c a t t on 1
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disturbances of these complex switching circuit systems. Using this assuraption,it f was shown by means of symbolic logic and target theory that various dose-response t curves for cell mutations could be explained quite consistently. The paper was published sometime later in the Japanese Journal of Radiation Researchi,2, but it appeared t.nfortunately with some misprints in the symbolic logic notation. The full text was published in a limited edition as a Monograph 3 by the Musashi institute of Technology Press in Tokyo in 1960. I think I gave a copy to Turner of Oak Ridge when he visited me in. Tokyo about 15 years ago, but I shall be very glad to give you a full reference to my papers on this subject if you are interested. { K.Z. MORGAN: This is indeed most interesting. I'm sorry I missed seeing these articles in Japanese journals, and would appreciate it very much if you would send me reprints of the papers. As you know, many theories have been proposed to explain carcinogenesis. I think it is almost certain that a malignancy has its origin in a series of random events such that we have no way of knowing which photon or ionizing particle will throw one of the switches in a cell of our body that survives in a perturbed form to be the origin of a cancer. In some cases or for some types of malignancy all the switches in this chain of events may be within a single cell or within the nucleus of tha cell and these switches may be connected in series, while in other cases, as you pointed out, the switches may be connected in a parallel-series arrangement. Some of the switches that may be connected in parallel are for example: damage to blood supply of the cell, changes in immune response, damage to cell wall, etc. The point that should be emphasized here is that, if cancer develops in this manner, there is no safe level of exposure to ionizing radiation and the situation is simply one of risk which increases with the amount of radiation exposure. The problem becomes one of balancing the risks against the benefits and of avoiding all unnecessary exposure. It is for this reason that ICRP and many radiation control agencies now emphasize ALARA. The question then is not: "What is a safe level of exposure? " Nor is it: "Is there a risk from low-level exposure? " The question is simply: "llow much risk is acceptable from a given exposure? " This question is thus similar to a question such as: "llow much risk is there in a given trip in a taxi? " NISillWAKI, Y., Biophysicalinterpretation on the biological actions of radiation (1):
Correspondence between the relay-contact system and the gene-enzyme and some discussions on the target theory, J. Radiat. Res. (Chiba, Japan) 21 (June 1961) 42-60.
2 NISIIIWAKI, Y., Biophysical interpretation on the biological actions of radiations (II): On the examples of the type-analysis of the dose-survival and the dose-effect curves, J. Radiat. Res. (Chiba, Japan) 2 2 (Sep.1961) 98-123. 3 NISillWAKI, Y., BiophysicalInterpretation on the Bi- togical Actions of Radiations, Bull At. Energ. Lab. Musashi Inst. Technol. I 1, Monogr. (Dec.1960) pp. 231. l
b f- ,
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g 3d .. ijl g, Radiation Induced Cancer in Nan by . Karl Z. Morgan Neely Professor . School of Nuclear Engineering Georgia Institute of Technology Atlanta, Georgia 30332 A - Introduction Following the invitation of Senator. John Glenn, Ch'irman a of the , Subcorraittee on Energy, Nuclear Proliferation and Federal Ser' vices, I have hurriedly prepared this review of some of the less understood aspects of radiation induced cancer in man. This also is a brief review of the report of the Interagency Task Force on Ionizing Radiation (ITFIR)' dated February 20, 1979. Also, at the suggestion of J. Weiss, Staff Director of this Subcot:mittee, I am submitting a few of my . papers on this subject to be entered into the Record and used as references in this discussion. These papers are as follows:
~
l. "What is the Misunderstanding All About?" by B. L. Cohen and response of K. Z. Morgan and J. Rotblat, Bulletin of ,
Atopic Scientists, 53-59, February, 1979.
2. " Cancer and Low-Level Ionizing Radiation," 'by K. Z. Morgan, i Bulletin of Atomic Scientists, 30-41, September, 1978.

3. "The Linear Ilypothesis of Radiation Damage Appears to be Non-Conservative in Many Cases," by K. Z. Morgan, Proceeding IV International Congress of the International Radiation Protection Association, Paris, Prance, Vol 2, April 26-27, 1977. s

. 4. '.' Suggested Reduction of Permissible Exposure to Plutonium and I
!, Other Transuranic Elements," by R. Z. Morgan, Amer. Industrial _ l Ilygienc Assn. Journal, 567, August, 1975. i i *
, Presented to the Subcommittee on Energy, Nuclear Proliferation and i Federal Services at the invitation'of Senator John Glenn, Ohio, Chair-man, U. S. Senate, March 6, 1979.
A _, .._-.y ~ . - , , ,, , . - - , , - . _ m,-.v..m__ r,., , ..m,,
B - Comments on the Report of the ITFIR, February 20, 1979 In general, I believe these are useful reports uFich help the reader to focus more clearly on some of the major issues, to better understand
~
these problens, and to appreciate the difficulties in obtaining early, definitive answers to questions about the effects of low-level exposure of man to ionizing radiation. I have, however, a few criticisms of this report. . Throughout the text there is failure of the ITFIR to appreciate the fact that there is an abundance of evidence to show that in many and perhaps cost cases of low level human exposure to ionizing radiation the cancer risk per rad is greater than at high levels of exposure. Some of the evidence is summarized in reference 3 above. The reports cention that 78% of research in the U.S. on human' studies in this area is supported by DOE. It would have been useful and nost appropriate for ITFIR to express an opinion of whether this is good or bad, unfortunately it failed to do so. I believe the way DOE (and its predecessors, ERDA and AEC) handled the Hanford study (moving it inhouse when it appeared it could provide the wrong answers) emphasizes that other government agencies would be more appropriate for this responsibility. It usually is not the best choice to ask the fox to find out who is killing the chickens! In the early period when other government agencies did not . appreciate these problems, it was appropriate and was to the credit of AEC that is took the initiative in fostering the.se research prograns,
~
but now times and the clicate have changed. It is to the credit alco of DOE that so,cuch of _its research budget in"these areas has been on basic studies and on pathuays. It may ucll be as ITFIR suggests, we will never know the effect of low level exposure of man to ionizing radiation because as the dose approaches zero, the required number of subjects for the study approaches infinity if the answers ar- to be of statistical significance. Thus, in tfa long run the answers we seek in a coherent theory of radiation damage may come only from an understanding of the basic mechanisms of radiation damage. It may be of interest to note in passing that the AEC uas not always interested in radiation ecology (or pathways research). ! Over a quarter of a century ago E. G. Struxness of OitNL, Orlando Park of i Northwestern Univers,ity, and I fought long and hard with the AEC to obtain i I i 2
eP _ G e % a support for these programs which have now proven so. rewarding. It is unfortunate that the ITFIR fails to point out in more detail , why some of the data that were used by the BEIR committee, the UNSCEAR, the ICRP, the UCRP, the FRC, and more recently by EPA, DOE, NRC, BRH, etc. in estimating risks of low-level exposure to ionizing radiation, seriously underestimate the radiation risk. I discuss this below. Throughout the text, ITFIR uses a risk coefficient of only 10
-4 fatal cancers per person rem. This is the UNSCEAR value for fatal cancers but its value for total cancers is 2 x 10~ cancers per person rem.
Unless there is an urgent requirement to give more business to the doctors and to take medical care more expensive, it seems we should try to reduce
. the total cancer risk. I doubt seriously many women wish to have their breasts recoved or that people delight in living without their thyroids! ~
There are many data which suggest the risk coefficient for man should be
~
at least as large as 6 x 10 s.ncers per person rem. The data of Bross suggest it is about 3 x 10~ cancers per person rem for children with respiratory diseases (see reference 2, ab'ove) while the Hanford data of
-3 ~
Mancuso, Stewart, and Kneale suggest a value of about 7 x 10 cancers per person rea. Thus, it seems a bit presumptuous for ITFIR to use the value of 10' without'some qualification. One is forced to recognize the bias j .of the ITFIR when he reads on page 37, "If studies of inadequate size are perforced, not only are their results likely to b'c inconclusive, but they may also mislead by producing exaggerated risk e'stimates." The reader is disappointed to realize that the ITFIR does not appreciate that it is equally likely the results might underestimate the radiation risk. The IT' FIR seems to cast doubt that the risk, R, could be given by an.cquation R = CD" (where C and n are constants) in which the power of dose, D, or n < 1 because in such a case one night have to assume more than 1% of the natural cancers are caused by backgroun,d radiation. It is surprising that ITFIR places any confidence in this 1% guesstimate when so much evidence would set the value >. 30%. j-i: 1 g-If
!. 3 i l
I l It is disappointing that ITFIR points out that " Studies of possible interactions between ultraviolet and ionizing radiation have suggested no obvious synergism" and yet, does not mention.the recently discovered ' synergism between UV-h (280-315 nm) and UV-A (315-400 nn) . The ITFIR is to be commended for recommending a more universal record keeping systen to record radiation exposures. I did all I could to encourage and boost the efforts of Charles Eason of the AEC in his efforts . to establish such a systen some two decades ago. Unfortunately, it was strongly opposed by the A'm erican College of Radiology and the Health Physics Society and got only lukewarm support of the AEC. We tried to have it , include records of all exposure - medical, occupational, internal, external, etc. The ITFIR is to be commended for encouragingt ' he federal support of epidemiologic studies of human populations exposed to ionizing radiation. I have two comments on this: .
1. Unnecessary duplication nust be avoided. A case in point is the fact that NIOSH has been charged with the responsibility to investigate the observation that 'there scEms to be an ' increase .
of statistical significance in the incidence of leukemia of radiation workers at the Portsmouth Navy Shipyards. In the neantine DOE, not wanting to be outdone, has given a contract for a duplicate study to John Hopkins University.
2. There are many population groups that look promising but af ter a more careful investigation they would be hopeless. As an example, many years ago Libby of the AEC wanted to study the effects of cosnic radiation on populations at various altitudes.
I discouraged such studies not only because of the obvious biases due to changes in oxygen tension, UV radiation, lung volute, etc. but for the fact that the very nature of the radiation under study not ~ only changes in intensity with elevation but its i composition changed. For example, at sea Icycl cosmic radiation l consists approximately of 84% muons, 14% clectrons, and 1% cach i' of neutrons and protons while at 10,000 feet it consists approxi-1- mately of 45% muons, 32% electrons, 13% protons,and 9% neutrons. 4
~
Since the dE/dx or LET of these radiations differ considerably and in an unknown way for various forms of cancer and because terrestrial background differs from place to place, I. felt such a study would not be fruitful or worthy of taxpayer support. , . c Now I wish to 'omment on some specific topics as follows: C - Uhy Some of the. Data Used in Setting Radiation Protection Standards Grossly Under astimate the Radiation Risk of Low Exposure Some of the reasons for this underestimation of radiation risk are given in references 1-4 above, but I rish to expand on this briefly. Two of the most important studies on which our present radiation risks are based are 1) the studies of patients treated with large localized doses of ionizing radiation for ankylosing spondylitis, and 2) Japanese survivors of the bombings of Hiroshima and Nagasaki. Both of these studies grossly underesticate the radiation risk, esp'ecially for low exposure. The ankylosing spondylitis patients (ASP) are a select group in which the increased cancer ris'k A in Fig.1 uns estimated as the difference between the cancers per rem identified in the ASP's and the general popu- , lation as determined from national statistics. Cancers identified per rem A A among the ASP's , o a g A E
n. .
0 o N \[ g General population as controls 3u N tn Unitradiated ASP's as I Controls Fig. 1 Cancer risk should be given by B instead es A Faw .k. tent.
o , Unfortunatley, this was a bad choice because ASP's have been shoun to have a lower risk of dying of cancer than the national average because the disease itself reduces the chance they will survive the long incubation period of cancer. The control group should have been the unirradiated ' ASP's so that B rather than A represents the true cancer risk. A similar situation exists with the ris'k estimates of the radiation exposed survivors of the atomic bombings of Iliroshima and Nagasaki. In this case the lower exposed (internal) group was taken as controls to give risk A as shown in Fig. 2. However, this group was exposed. Rotblat, comparing early entrants with late entrants into the blast area found B much greater than A. Although a group of blast victims not exposed to radiation should be used to obtain C, such a group unfortunately is not available. Cancers Identified per ren in Early Entrants A Cancers Identified per rem in Blas't Victims A A Fig. 2 Cancer risk should be given by C rather than g - by A. The B may be a close 9 approximation to C. A B U C o. E 8 c 0
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D - Damage to Surveillance Immune System in Relation to Long Latency _ Period for Cancer Results in a Higher Cancer Risk per rem at Lou Doses than at High Doses of Ionizing Radiation This is-shown clearly in Fig. 3. Man's surveillance immune system or reticuloendothetial systems normally holds in check sources of foreign protein including mutant somatic cells or those that are potentially malignant. However, when the body is irradiated there is some loss in immunological competence. This has exactly the same effect on pre-cancer cells and on bacteria and viroses associated with diseases such as pneumonia. Houever, the latency period for these diseases is much . shorter than for cance.r and the latency peric.d for the development of a malignancy increases with decreasing dose. as shown in Fig. 3 so that the cancers per rea are greater at low doses than at high doses. As indicated by the references ab' ave, this seems to be true for all exposure to high LET radiction (a and neutron) and for low LET radiation (x, y or S) in the case of fetal radiation and for expoaure of old persons. In other words, curve C in Fig. 4 see s to provide the best fit in these cases. Cancer Induction as a Function of Dese of Io,ivir? Radiation This figure is a plot of equation
from 0 to 100 rem
. E =kD% (!)
lit which E = cancer risk (percent of persons 3.0 with cancer) as a result of exposure to a dose
. D(rem) ofionizin; radiation.
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$ p+s aged persons that are exposed to law LET -
C, g,g p (linear en:rgy transfer) radition.
, .s *[ gr . , Recent hernan studi-s sug;:st that Cas: C, u 1.5 4,s y or some o:her cerve for which n < 1, app?ies E A toleukemia among the you:2 and the o d and j'; g C Cf S[ perhaps to most oth:r forr':s of cancerirr:. ,t y
ge gardt:ss of the age of the p:rson. In su:h g 0.9 Y,+, p cases the risk per person. rem is grest:r at low g 40 doses than at hi;h dos:s. t C / Curves A, B and C are given prirnar!!y for j 0.6 ,
' . illustration, but ca:h curve app:ars to b:
applicable in certain cases. Perh2ps it is of l * ~ j 0.3 e[6 . interest to note that for a dose of I rest the cancer risk is 0.03 p:rcent by th: lin:ar
.. hypothesis (curve A) and 3 x 10-* percent 0 . (negligible) by the threshold hypothesis O . 20 40 - . (0 ., , 80 100 (mve Bb ,
f
' Fig. 4 Dose of Ionizing I',ndiation (rem) 8
o - . * . . , , m O This figure is taken from reference 2 above. There is, of course, always some repair of cell damage caused by exposure to ionizing radiation. This may explain why the low leukemia risk among middle-aged persons where perhaps curve B provides the best fit. In deciding why h2 :an data fit curve A, B, or C it is very important to take into proper account the [ " healthy worker syndrome" such as was the case with the Hanford warkers. In the case of children, passive leukcmia may be mostly a teratogenic defect.following fetal radiation exposure. It may be true that leukemia is a somatic disease in adults which requires more than one insult (as ' suggested by Burch) before it can develop. Thus, in the case of adult workers with the healthy worker syndrome at Hanford, leukemia follows - curve B and has not as yet been a problem. In the case of children, Bross found a synergistic relationship between respiratory disease and radiation exposure which resulted in an increased leukemia incidence of about 5,000%. Here curve C would seem to give the best fit. E - Uncertainties Regarding Values:of Internal Dose I believe some of the values of maximum permissible body burden, q, and maximum permissible concentration of radionuclides in air (MPC)a and _ in water (MPC) as published by ICRP and NCRP are very much too high or non-conservative. In stating this I do not intend to be critical of ICRP and NCRP because I was chairman of the Internal Dose Committee of both of those organizations where the present' standards (ICRP No. 2, 1959 and NCRP No. 69,' 1959) were published. The FRC guidelines and the NRC per-missible levels in 10CFR20 are based on these standards. I believe they were based on the best data available in 1959 but much new cata h' ave been made available over the past two decades. I will limit this discussion to 'Pu but similar comments might be in order regarding other elements and their radioisotopes. When we selected the present value for Pu or (MCP)w = 5 x 10~ pCi/cc 4 water for occupational exposure 168 hours per week or 5 x 10 pCi/t and suggested a valuc of (MPC)" = 1/30 (MPC)" " = 1.7 x 10 pCi/t as an upper limit for drinking water of members of the public, we thought that 239 Pu , would be in the Pu(iv) state where the . fractional uptake from the GI tract was found to be 3 x 10-5 Recently, however, an article by Larson and Oldham -(Science 201, Sept.15,1978) indicates that for chlorinated water 9 ,
. . . e . .
o 4 . . e the state is Pu(VI) so the fractional uptake probably should be about 239
0.3. Therefore, the Pu value for chlorinated water used by members of the public should be
-5 1.7 x 10 x 3 x 10 /0.3 = 0.17 pCi/1.
These values corresponded to a calculated average bone dose of 1 rem per year. In Carl Johnson's letter to Gip Wilson of Bloomfield, Colorado, he reported that "a composite sample of finished water at Bloomfield for
- April of last year (1977) indicated levels of 3.03 pCi of Pu, Pu per liter." This is about 20 times the permissible limit. I would estimate the cancer risk to be 1 c 2 70/2 x 3.03 (pC1) 0.17 (trem) = 6.2%
1 pCi 10~4 (pers. rem) 10 risk of canceh o' f bone or liver over a lifetime use of such water. Since 1 the average cancer risk of everyone in the U.S. is about 20%, this repre- . sents a 30% increase in can cr risk of such pc sons.. This added risk migh't be acceptable because of certain advantages in living in such a [ community,but one should not overlook the fact that in reference 4 above I point out the present (tIPC) values may already be too high by a factor of 240 for other reasons. - In closing, I would like to point out that although I am an emeritus member of ICRP, I cannot refrain from saying I believe the ICRP made the greatest mistake of'its history when last year it adopted values of w (weight factor) which will have the effect of increasing most of the IEC , values. This comes at a time when it acknowledges the fact that the cancer risk is much ' greater than ue believed it to be two decades ago. I under-stand some of our government agencies are considering rejection of this ICRP No. 26 report and I believe this is a very wise move on our part. f f' t
1---- Reducing Medical Exposure to Ionizing Radiation KARL Z. MORGAN School of Nuclear Engineering, Georgia institute of Technology. Atlanta, Georgia 30332 i
9 i
;= The author discusses the dancers of indiscriminate and uninformed use of medical x ray facilities. Ile points out a lack of effective standards, controls and practices to minianire exposures to x ray and to present the excessise use of diaenostic x ray examia.ations. A lid of practices whereby an indisidual can minimize his possible exposures to x. rays is presented. Several approaches to the question of acceptable exposure levels are considered.
I Introduction reported cases of lens cataracts and radiation ; AMAGE FROM IONIZING RADIA. deaths.
, TION was first observed among' the Reductionsin Levels of Pennissible ,
pitchbknd miners of Saxony and Bohemia Exposure j about 500 years ago. It is recorded that these I miners died of a so called " mountain illness" Through the years there have been many reductions in levels of maximum permissible U after 5 to 10 years of underground mining.8 lt was not until after Becquercl's discovery exposure to ionizing radiation. Rather, one of ionizing radiations from natural unanium should say there were reductions in tolerance that it was realized these early cancer deaths levels for during the early period it was gen-among pitchblend miners were due to ex- erally believed there was a safe threshold posure to and inhalation of the daughter ' dose below which there would be no radia-tion' damage. So long as this tolerance dose f, products of 22:Rn from the uranium con. ( r thresho!d) was not exceeded and there ! tained in the ores associated with the pitch.
~
b!cnd. were no sign of skin erythema, it was as-
After Roentgen publicly announced his sumed no radiation damage would ever mani- f discovery of x rays on January 4,1896, man fest itself. Some of the early tolerance levels was not long in finding out about the harm- were very high in comparison with present ful effects of these rays. In fact, only 23 values. For example, Rollins2 4 in 1902 sug-days later Grubbe,2 3 a manufacturer of gested an occupational exposure level which Crookes tubes sought medical aid for serious corresponded to about 10 R/ day. It is ree-radiation barns on his hands. During the next ognized that this value is over 700 times the few decades hundreds of cases of radiation present day maximum permissible occupa
, damage-mostly as a result of medical ap. tional exposure, MPE, of 5 rem / year. It is t plication of x-rays-were reported in the fortunate there were very few persons that literature. This early reported damage from were occupationally exposed in this early 4 the medical use of x-rays consisted mostly period and the x-ray tube voltages in use of skin eithyema which in many cases pro. were relatively low. Even as late as 1925 gressed to ulceration and in some cases re. Mutscheller and Sieveret2 4 suggested an i
sulted in cancer. In a few cases there were crythema dose which corresponded to about i 12nouer wen,oria: 1.ecture sivca .i stanford univer-Mwa x hehpam er, septemt=. 27 m4. occupational MPE. 358 . l
-4_ ..- _ , - , m . . . ._ . .
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o . 359 American industrial Hygiene
Association Journal
' Dere have been corresponding reduc- a resounding yes. Medical diagnostic expo-tions in exposure limits for members of the sure in the U.S. is 2 to 10 times that in most advanced countries of the world and in many :
public. For example in 1952, the In'terna-tional Conimission on Radiological Protec- respects our medical benefits per do!!ar spent , tion,ICRP,2.5 suggested a value of 1.5 rem /y on medical care are not better or worse than in these other countries. Tnis average medi-and this is over 300 times the present guide of 5 mrem / year as suggested by the U.S. cal exposure in the U.S. could easily be re-duced to 10% of its present level by the ap. Atomic Energy Commission as an exposure
' limit for persons living near a 1000 MWe plication of better techniques, in the use of improved x-ray equipment which is operated light water cooled nuclear power plant.
only by medical and paramedical personnel
.i Perhaps no one at the present time can with proper education, training, certification, - give an accurate answer to the question, "Will there be further reductions in permis- and motivation. Our medical institutions are in financial difficulties and in many cases sible exposure levels in the years ahead?"
x-rays are given to patients to provide needed I suspect the ICRP and the National Council on Radiation Protection, NCRP, will make revenue. Often x-rtys are required of the some minor adjustments in the present dose p.tient before he can be admitted to a hos-
'.j pital, before he can take a new job, or before j limits to the various body organs in an at-he can settle claims resulting from an auto-tempt to make them a bit more internally mobile accident. It is a sad commentary on consistent, but otherwise I do net e:.pect our society and a serious infringement on the changes. There will be many chang: next year in the ICRP values of mar.imum permis-civil rights of an individual that in many cases he is forced to have these x-rays (many sible annual intake of the various ra'iio- of which he knows are completely unneces-nuclides, but these changes reflect new data applied to more sophisticated metabolic sary) or suffer serious financial loss, lose models rather than basi: changes in organ his job, or be deprived of zieeded medical dose limits. Also, there will be many enangs and dental care. The same situation seems in radiation regulatians, cades of practices to be developing in the excessive use cf and laws, but these change: will refie:t for radiopharmaceuticals. This situation is ag-the most part an effort to update tiiem so gravated by the extreme ignorance of the ' that they conform to the current philosop*ay average medical man or doctor who knows of keeping radiation exposures cf members absolutely nothing about the harmful effects of the public "as low as practicabic." For of ionizing. radiation on man and yet is pre-sumed to weigh the benefits against the risks example, present regulations permit Pas-sengers and crew of airplanca to be exposed when he prescribes an x-ray for his patient.
I think there is a serious flaw in the recom-at .the rate of 10 mrem /hr which is not at all consistent with the AEC "as low as prac- mendations of NCRP and ICRP in that all their radiation exposure limits exempt medi-ticable" guide of 5 mrem /y for persons liv-cal exposure--even those from routine diag-ing near a nuclear power reactor. The panel of the Joint Committee on Atomic Energy" noses-from any regulatory control on the thesis the doctor knows best and can weigh (of which I am a member) has just recom-mended this limiting dose rate in passenger the benefits of the diagnosis against the ra-aircraft be reduced to 1 mrem /hr nt any diation risks. Unfortunately, the medical
" crown" does not compensate for ignorance peint in the aircraf t, i.e. at floor level.
and stupidity of the average medical doctor Are Medlen! Exposures in the U.S. or dentist. Some of the finest and most com-Excessive? petent people in the world are members of the medical profession. Ilowever, collective-Thi: question can be answered only with I W *"FD . y WF MUMP M g 9$ WSt % . ..
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5 May,1973 \ t r ly, as represented by their professional or- For years it has been possible to obtain a
! ganizations, they seem to be far more inter-dose to the patient from diagnostic x-rays.
csted in maintaining a high income, an un-good chest x-ray with a skin dose to the pa-questioned authority, and h. wing a blank tient of 5 to 10 mrem, yet even today many check which permits them to expose the patients are subjected to doses of several patient to any amount of ionizing radiation. thousand mrem. For many years it was Often there is displayed an arrogance which known that mass chest x-ray programs in L ., , leaves the impression that the American the U.S. were almost worthless. For example, Medical Association American College of in 1965 the United States Public Health Raalology, American Dental Association, Service" urged that they be discontinued 5a etc. are far more interested in convincing the yet it was only in 1972 that a halt was public they have an unblemished record and broughtt2 to the practice of driving a truck hase made no mistakes than in preventing up to our schools and marching our chil-radiation damage to the patient. For exam- dren through to be x-rayed much the same ple, when the ICRP7 first recommended that as we brand sheep except the x-ray is more a radiological examination of the pelvis and abdominal regions of a woman in the child-harmful to the child than the brand is to a sheep. It would be interesting to know bearing age be limited to the 10 day interval how many of these children, as a conse-following the onset of menstruation unless 4 quence of this radiation exposure, later de- '
) the examination is of impcrtance in connec-I veloped cancer of the lung, breast, or thyroid, tion with her immediate illness, the ACR or how many cases of leukemia resulted.
i and some of its members were the first to l object to this recommendation and use ridic- Table I also indicates the wide rance in j ulous arguments against it. skin dose from the usual series of d' ental x-rays. Perhaps one could justify slightly { The sad state of medical diagnostic radiol- larger doses in some cases if better radio-l ogy in the U.S. was emphasized by Dr. Mc- [. graphic information were obtained, but just
Clenahan8 when he enumerated some of the the contrary is true. Almost always the high-l reasons for excessvie patient exposure as follows: er doses result in less detailed radiographic l information. ~
g' *1.,lt is easier for the doctor (and I might t add m many cases the nurse) to order an Which Is More Tenable, the Linear or the j x. ray examination than to think. Threshold Ilypothesis? i a
2. Examinations are ordered "to rule out'* '
when accurate diagnosis has been made with As the population doses of ionizing radia- { the naked eye. i 3. Ileavy legal penalti:s for failure to do tion are reduced i1 any animal or human . I radiographic examiaations, but no penalties for - study, it requires a larger and larger popu- { unnecessary exposure of patient. lation (and correspondingly greater expense) - { 4. Insurance covers most costs for x. ray
; cuminations. to obtain Information ,on the effects of this .
{.
5. More films per diagnosis now required radiation and as the doses approach zero than formerly. the probable errors apEroach infinity. There-i 6. Shortage of trained workers leading to j
huty, hazardous techniques. fore, it will never be possible to show experi-
7. Folkways and traditional rites." mentally whether the linear or the threshold
, in another publication' I have added to hypothesis applies at very low doses. It may,
[
; however, be possib!e some day to develop a the list 28 other important reasons why the j use of ionizing radiation in medical diag-coherent theory of radiation damage which j will answer this question. "mes in the U.S. is excessive. ; he data" given in Table I emphasize the As mentioned above, during .the early
period the threshold hypothesis of radiation fact that thete is unaccessary and excessive damage was commonly accepted and as a g
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36l American industrial Hyl iene Associa!!on inva s! - TABLEI Common Diagnostic X. Ray Exposures (mrem to skin) in the United States ' Range of Values- Average 10 20 15*
' Chest x. ray at ORNL (radiographic) 10 300 45*
Chest x-ray in U.S. (radiographic) 200 2000 504h Chest x-ray in U.S. (photofluorographic) 20,000b .
, 1000.I00,000 ;
Dental x ray series in U.S. ,
Abdomen (radiograph):
6366 Given by a radiologist 1,2536 .
Given by others !*
Average chest x. ray dose delivered at Oak Ridge National Labo atory
.. j.
(1972), . bThese average values were given in the report " Population F.xposure i to X. Rays U.S.1964," J. N. Gitlin and P. S. Lawrence HEW-PHS 1964 j (13). i }_ 4 I be detectable only by statistical methods ap-consequence in the early period reference plied to large groups" was made to " tolerance dose" and " threshold erythema." The exposure was ' considered When a photon of high energy radiation 3 safe and no ill effects were expected so long enters the human body, one of four things as the tolerance dose rate and dose were is likely to happen: (a) it wi!I pass through not exceeded. During the past 25 years, how- the body without hitting anything, (b) it ever, there has accumulated a preponderance hits some part of a cell in the body and ' of evidence which indicates there is no safe causes damage but the d.amage is completely , I threshold dose and in fact both experimental repaired. (c) it hits,a cell of the body caus-and theoretical evidence seem to indicate ing its destruction or damages it such that '7 ) ' there is no dese or dose rate of ionizing it' cannot reproduce i@!f, and (d) it is radiation so low that the risk of radiation damaged and survives to produce a clone cf
;[
damage is.zero. Perhaps the' best way to Perturbated cells which eventually is' diag-emphasize-how the present philosophy of , nosed as a cancer. , , , j l "as low as practicable" evolved is to refer Every noanal living cell of tfie human ' back to the 19581CRP" description of the ' boby his a nucleus in which are M6 chromo-l i i " permissible dose" which was as follows: i somes (with exception of germ csis which
, "Ihe permissible dose for an individual is contain only 23). Each of the chromosomes that dose, secumulated over a long period of carries the genes which in combinations cor- ~
time or resulting from a single exposure which respond to milh.ons of books instructing the in the light of present knowledge, carries a cell what to do under k great variety of 3 negligible probability of severe somatic or r l genetic injuries; furthermore, it is such a dose situations (e.g. when to reEroduce, when that any effects that ensue more is.:quently are to Produce certam essential chemicals, how limited to those of a minor natuic that would large an organ should be, etc.). When radia-l not be considered sunacceptable by .the ex-( poaed individual and by competent medical tion e,nters this cell it is like a ' madman en-authorities. Any severe somatic injunes, such , tertnf, the libtsry and destroying pages from e as leukemia, that might result from. exposure . thoisands of books in this " cell library." In of individuals to the permissible done would be limited to t.n exceedingly small fet.ctior ,of tinyhysicsmworld this corresponds to an t
.the exposed group; effects such as shortemns increase of entropy of the system, an in- - of life span, which might be expected to occur trodtiction of static or a loss of organiza- - more frequently, would be very slight ,and would, likely be hiiden by noitnr.1 bMsgi:al ti&One chance in a million this randorn variations. "the permiscible doses can, there- change in the nucleus of a cell may be of fore, b: czpccted to pro.tuce effects that could -
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3(*. m y,1975 benefit to the race-thus evolution-but gnay act independently, others collectively from a practical point of view for the in '. and some' synergistically with one another. dividual the risk of cell damage is over- Cancer probably is brought on by a series of whe! ming so that all radiation exposure must events and may be triggered finally by such be considered potentially harmful to the cell things as virus, ~ bacteria, chemicals, radia-and to the individual. tion, etc. Perhaps the developments leading Many people seem not to understand why to the onset of cancer are like throwing sev-
.( there isn't a " safe", level of radiation expo- eral switches in series-nothing happens sure and we must explain to them that dam- until all switches are closed. One of.these age-even serious damage-from radiation switches may be an inherited factor, another
exposure is merely a matter of chance like j most other things in life. Often medical doc-tors and representatives of their professional . .
7 7,.,; ; organizations make the .*oolish and most ,
- e. ~' k -t ,
ridiculous defensive statement that there has J. / '
. ..~ }= l never been a case where a person has suf- , // .l fered from a diagnostic exposure-they say /' ' ;' ,' . . j, 8;h there is no evidence. In making such a state-l" ,~ 1 /
ment they belie themselves and prove they y / , l' j are not scientific in their thinking. The ! ., -
.i fa /> ,'" sl j' jl
{, scientist that accepis the General Gas Law f # ff l s I (PV=RT) or Ohm's Law (V= RI) inust f" *'
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believe in statistics. Exposure to high energy radiation is like running blindfolded across a highway on
',,, ,, # (7 TidC,, j '*ll 8
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which cars are moving at a high rate of < ' - speed. If we are hit, we can be just as dead Figure 1. Relationship of radiation dose In hu-mans to chronic damage radiation sickness and P whether we try this foolish crossing during rush hour or after midnight. In like manner, death. (From data of the International Commission n Radiological Protection.) radiation exposure even at the permissible level can cause our death but the risk at this ; level ts so small in comparison to other risks that we willingly accept it but we keep in mind that the higher the radiation dose and [" pp ; the greater the number of exposures, the y ,,. .. y greater the risk. Thus, in ai' areas except where the medical patient.is involved, we I
.j e ~- }'
have developed the philosophy of keeping I radiction exposures as low. as practicable } ' and permitting no radiation exposure unless j It 4 the benef;ts exceed the risks. It is true there e-g " is repair of many of the body cells that are .
; damaged by radiation but there is always , , , . . ; some residual body change which may in Figure 2. The per cent incidence of sarcomt.s and carcinomas plotted separately on a linear ses!c !
I time manifest itself in one or more forms against the median of the total shcle:al,8.xe in rads of radiation damage such as cancer. on a logarithmic scale. (ANL-7760, Put 1:, U.S.
'llere are many insults .m man,s environ- Depanment of Commerce, Sprin:;fie!d. */A, kly, ment which can cause body damage. Some 19 9. June,1970.)
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America,r ladustrial Hygiene Anx .stio..n. loc .~
. - 363: ~ ~
a virus . infection, and the final triggering . cancer (sarcomas and carcinomas) as a
. event might be a radiation exposure. function of the accumulated dose from ra- ' "* Figure 1 indicates that the threshold hy- ,, , dium deposited in the human body (mostly 4
pothesis a' pplies to such things as radiation among radium dial painters).' 'Ihe non-
; sickness and acute radiation death from large ' scientist may not appreciate the fact that the curves do not suggest threshold doses at doses of radiation delivered over a short pe-riod of time of not more than a few days about 80 rads for carcinomas and about 900 i while the incidence of such things as genetic rads'for sarcomas because the abscissa is l damage, life shortening and cancer produc- a logrithmic scale. When the same, data are i tion seem to relate, more or less, linearly to replotted by Rowland on a linear scale as ,
the accumulated dose.' in Figure 3, it is clear that at low doses there ; ! Sometimes data are presented in such a is no suggestion of a deviation from the way u to suggest to the non scientist that linear hypothesis.Ihe curves in Figure 3 , 2 the threshold hypothesis applies. For exam- bend over at the higher doses because the ,
plc, Figure 2 is a plot of the incidence of radiation exposure causes death in many l
of the persons before they have time to de- I l -
; velop cancer. l Figure 4 is a plot of a typical set of data' l
[ ,,,,,,,,, , that seem to support the linear hypothesis j '+- o- . The fetus is probably the most radiosensitive g Fa- member of the population but there are 9 j ,.- " many data which suggest that' older people also have a high radiosensitivity. Jablon L' ' i e ... J ,.. pointed out that his data on the survivors
) ,,_, of the atomic bombings at Hiroshima and jg m , Nagasaki, Japan do not seem to support Alice Stewart's findings in her Oxford study , , e , , , ,
of the effects of in utero exposure. However, = i Fisure 3.me per cent incidence of sarcomes I have shown that there does not appearto [ and carcinomas plotted separately against the me- be any inconsistency in these two sets of hu-
< dian value of the totat skeletal dose in rads in man exposure data.so g linear coordinates. (ANIA' 60. Part II. U.S. De.
i partment of Commerce, $pringfield, VA, July. There is good evidence also that tife radia-1964. June,1970.) tion insult does not act independently of other human insults such as chemical con-taminants and diseases (especially respira-g tory diseases such as asthma). Table II in-
'8 -
j l dicates that th:re are special groups in the 8o population who are far more radiosensitive I o.a o.s J
/j than the average member of the public.15 For example, children of age 1-4-had 3.7 , c.e times the risk of developing leukemia if they .
f 3 ,,, / " had allergie disease and 24.6 times the risk 6,/ if they had both allergic disease and had re- f , l o. e a 4 s of ceived intrauterine x-ray exposure. Figues 4.'Relatiomhip of cancer in children to . the number of pelvic x ray examinaGons received Is lhe Linear Hypothesis Conservative? by their r.aothers duries preensacy. (Data from
i Alice Stewart and O. W. Kneale, Iances, June. Often .ti .ts stated in the literature that the j 1970). liacar hypothesis, as ptesently applied, is a I
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364 May, I975
TABLE II ..
Relative Risks of Leukemia and Probabilities According to Age, Exposure to intrauterine Radiation and Indicators of Susceptibility A8e . Intra. - Relative Risk P Value
"I"'
Exposure Group Group Group Group Group Group Group Group yr O C B A O C B A g,4 f No 1.0 1.7 2.6 3.7 - 0.06 0.01 0.0009 1 Yes 1.5 2.8 8.2 24.6 0.14 0.01 0.0002 0.003 3,9 ['No 1.0 1.2 2.2 4.4 - 0.64 0.09 0.005 ( Yes I.3 1.3 1.8 5.4 0.73 0.62 0.47 0.01 f 10 14 f No 1.0 1.0 1.6 2.4 - 0.91 0.37 0.17 ( Yes 1.1 0.83 '4.3 9.5 0.83 0.68 0.06 0.005 3 14 f No 1.0 1.4 2.2 3.5 - 0.11 0.003 0.0001
-l
( Yes I.4 1.7 4.1 8.4 0.16 0.06 0.0001 0.0001 Group A: Children with allergic diseases (e.g. asthma and hives) ! I Group B: Children with bacterial diseases (e.g., pn:umo:da, whooping cough and dysentery Group C: Children with childhood virus diseases (e.g. chicken pox and red measles) Group O: Children not in groups A, B, or C. very conservative assumption. During the ' 3. The linear hypothesis assumes that l'ast few years, however, many studies have [ man is a uniform and more or less homo- Lt. indicated that this probably is not true in geneous population. It applies to the averag: general and that at very low doses and dose man and may not be sufficiently conserva-rates somatie damage per rad probably is tive for the fetus and for old people. It usually greater than would be assumed on never takes into consideration special grcups . the linear hypothesis. There are many rea- such as shown in Table II. sons for this, some of which are: 4. There may be cell sterilization at inter-1.. The linear < hypothesis is based on ex-trapolations to zero dose of effects of radia. mediate and high doses. By this we mean {, there may be many cells in the body which tion on humans at intermediate to high are likely targets to become precursors of a. doses. The points used on the curves at high clone of cells which are malignant but they doses may be on the down part of the curve are killed by the higher doses. In other ' as explained above and shown in Figure 3, words, these cells may already have two of 1.c. from the portions of the curve where a the " series cancer switches" closed and a large fraction of the highly exposed died of low dose of radiation would likely close the other types of radiction damage and did not ! last switch in the' final s*cp toward cancer ' survive to die of the radiation effect under production. A high dose, however, might ; study. kill most such cells as it does in radiation
2. The extrapolations are made on human therapy which is used to destroy a cancer.

data which in general relate human damage 5. For many types of radiation damage '
such as bone cancer for observation periods the best fit curve is a plot of equation E = l , ci no'more than nbout 20 years. Many of CD* in which E = effect, C = constant, the conclusions are based on studies of ani- D = radiation dose, and n = constant. For mais of life spans.less than 10 years. Since the linear' hypothesis n = 1. In soine cases
man lives for more than 70 years, the slopes n > 1 indicating lesser damage at low doses i of these curves can only increase as more but in many cases the best fit to expedment-human data are accutaulatr<l over his entire al data is obtained when n < !. Daumt6 life span. recently showed a best fit for cancer induc-a.-.o . -
l e e o
Ar.ser;cen industrial Hygiene Association Joured 365 tion 'vhen n -= %. In such case the linear - The studies 3' which inrtcated human can- . hypothesis would be non-conservative. cer risk from exposure to ionizing radiation l Is Geneth Risk Still the Limiting Form of is much greater than formally considered W.Indon Dranage? were primarily: (a) studies of ankylosing spondylitis patients treated with x-rays, (b) In the early period and following the gene- studies of children expc<ed in utcrally to ti: studies on flies by Muller" it was gen- x-ray diagnosis, and (c) studies of survivors crally considered that genetic damage to of the atomic bombings at Hiroshima and ene's children and to future generations from Nagasaki, Japan. As a consequence of these - exposure to ionizing ra'diation was far more findings, the Intemational Commission on se:ious than damage to oneself (or somatic Radiological Protection (ICRP) in 1971 damage). Two things have happened which pointed out that "the ratio of somatic to have changed this belief: (a) Genetic risk genetic effects after a given exposure is 60 now appears to be less of a problem and times greater than was thought 15 years (b) Cancer risk in man now appears to be ago."In view of these developments the Na-10 or more times greater than was consid- tional Academy of Sciences formed the . ere.d to be the case 10 to 15 years ago. committee on the Biological Effects of Ioniz- ! Russell 18 showed that the genetic risk of ing Radiation (BEIR) and asked it to evalu-Jonizirg radiation was less than had been ate the radiation risk to man. It too came out su gested by earlier studies on flies. His with the conclusion that perhaps soraatic i i mouse studies indicated that for radir. lion risk from exposure to ionizing radiation is exposure at low dose rates the number of i greater than the genetic risk. It should be , i po!nt mutations from exposure to the sper- pointed out, however, that this committee L matogonia were about % as frequent per gave very little consideration to the risk rad as at high dose rates and in the case of from recessive mutations, to damage beyond females there appeared to be complete re- the first generation, and the burden to so-covery of any radiation damage to the ciety from the non-visible mutations. When occytes. Also, he found that low doses of this is done, it may well be that the genetic radiation produced less genetic damage per risk as claimed by Muller is far greater than rad than high doses. The overall result is the somatic risk from exposure to ionizing (" i, that exposure at low doses and at low dose radiation. rates (as might be expected at permissib!c levela of population exposure) is now con. Are Low Level Exposures Such ns Those in si.iered to produce about 1/10 the genetic Medeal Magnosis Harmful? damage that would be produced per rad at The consequences of low level exposure 1.igh doser and high dose rates. to ionizing radiation on the linear hypothesis TABLE III Summary of !!EIR Comrnittee Estimates of Risk to a Stable f U.S. I'opulation frorn 170 mrem /y ' Serious disab;lities, cor:se: ital
, abnormalities, corudt.nional 1100 to 27,000 (660 to 14,000)*
diseases,' death, crc. Overall ill 1 ealth 1.2 to 12% of thatin U.S. (0.7
' 10 7% )*
Cancer (deaths / year) 3000 to 15,000 (l800 to 9000)*
*The va!ues in parea:heses are crude extrapo!avix:s (by K. 7. htorgan) of the DEIR dsts givias estimates of the risk to the U.S. perulation from tireser.t medical exposure.
e e
,w
-. -_ -- . - ~._ _ _ ._. _ _ _ ,
o- e-
. i May,1975 ean best be summarized from data given in Wedical radiation exposure can and d.culd be the BEIR report ' and as shown in Table III.
1 reduced considerably by limiting its use to Here I have applied the BEIR linear hypo- clan cally indicated procedures utilizir:g effi-cient exposure techniques and optimal opera-
thesis to,obtain crude estimates of the pres. . tion of radiation equipment. consideration cat risk to the U.S. population from medi- should be given to the following:
! U """i*d*" # 'h* , . calexPosure (mostly diagnostic). # '*d'*d " ' '
.Some persons would like very much to public survey purpose "".t. unless these is reasonable probability of sisnificant de-believe that the linear hypothesis is very y '**, ,
conservative but as pointed out in the BEIR M*[nsing of radiation and - ancillary equipment, report and as indicated above, just the DAPPropriate training and certification of + reverse may be true. Thus it becomes involwd pusonnel. Gonad , shielding (espe- ! 4 yery iniportant .to maintain radiat,on t ceally shielding the testes) is strongly rec- ., ommended as a simple and highly efficient exposures as low -as practicable and nog way to reduce the Genetically Significant L I to p-rmit any exposure (such as excessive Dose?
.; l diagnostic exposure to x-rays when they are not needed for one's health) unless the bene-How Can We Itedece U=-n -y Medical Exposure?
fits are considered to exceed the overall .
!i s -
risks. We have much to learn about the risks Obviously this question must be answered t from chronic exposure to ionizing radiations differently for each person and cach profes-t
but maybe it is somewhat reassuring that we spnal gro,up. The. doctor, x ray technologist, n i know far more about the effects of ionizing dentist, chiropractor, etc. can improve his I '
radiation on man than about the effects of education and training and make use of bet-non-ionizing radiations, chemical pollutants,- ter c9uipment while emp!oying the best of food additives, insecticides, common drus;s, $t echniques. To begin with he can follow the L etc. It was with this in mind that the BEIR , hundreds of dose reducing measures that ; Committee warned that levels of exposure many have suggested (for example, the 73 to ionizing radiation should indeed be kept ways to reduce medical exposure which I
' as low as practicable but pot at the cost of gave in Congressional testimony).3 Those m'aking so'me other risk greater such that the in research and industry can look into ways -
i overall risks arc increased. that x-ray equipment can be further de- , ] It should be kept in mind also that ioniz- vel ped and improved. This would include ing radiation can be one of our most valuable n t only the development of sophisticated [ medical tools when it is used properly. x-ray equipment (for example the pulsed < L Needed medical x-rays should not be avoid- nu r scopic equipment that provides instant , i image display), but the improvement of ed but efforts should be made to confirm
' their need.in terms of the risk and if x-rays many simple dose reducmg devices such as >
a're called for, they should be given with the f r example: (a) an arrangement such l minimum absorbed dose (rem) and energy that the x-ray tube cannot be operated unless
, i
dose (gm-rem). Diagnostic x-rays in the the center ray is centered to the cassette . ;
j and (b) a dose device that would operate
, U.S. without doubt result .in the saving of i , -
, hundreds of thousands of h,ves each year, but the x-ray machine to deliver a predetermined i this is no excuse for 'using them carel ssly does to the film (and to the' patient) and i and excessively so as to cause the needless reconi this dosc on a patient I.D. card. . j .
- loss of tensof thousands oflives each yearc Each individual in his own case can seek i out'the best medical advice when x-rays are I The BEIR Committee also gave specific needed. Specifically, some of the dcte reduc- !
recommendations regarding medical expo- ing actions each of us can take i.re for ex- ' sure as follows: ample:
, [
e i
-e -' w y e*m- s + m- . *-2 ,e , -e+ +- ,e. - - - % *rr - % . --v----,m- g - = , -ye--- - -T --r1 -+- - - -
,e e' l
AmsrMS li.dustrial Hygiene Association kurnal 367
1. Don't have dental x-rays unless there questions, phene the office of radio-is a spccific individual necd. logical safety oi your state for the in.

2. Seek out a dentist that uses the long formation.
open-ended cone with rectangular 15. Support your state office of radiologi-
, collimation on his X-ray machine. cal health so that it interfaces with
3. Find out the speed of films used by you as well as with members of the the dentist and avoid dentists that medical professions. See that this use slow speed film. organization has adequate manpower -

4. Find out if the x-ray technologist is supported by the operating funds it certified. Refuse the medical x-ray needs.
unless taken by a certified technolo- 16. Bring about appropriate legislation gist or a radiologist. at all levels.--city, state, federal-to
5. Never permit a chiropractor to x-ray provide adequate radiation protection ,
you and in general avoid the practi- of the medica' patient. Only the states I tioner who takes x-rays. of New York, New Jersey, California, <
6. Ask to wear a lead apron or other and Kentucky require education, l shielding. training, and certification of x-ray '

7. Avoid x-rays using the photofluoro- technologists. Do everything possible graphic technique. to make this <ertification mandatory ;

8. Refuse fluoroscopic examinations ex- in all the states. The Randolph bill ;
cept by the specialist (radiologist) that would bring this about has' ( using image amplification techniques. " lingered in waiting" for a long time E Find out if he dark adapts his eyes. in Washington and now is attached
9. Wear gonad shields for pelvic and to Kennedy's Health Professions Ed-abdominal examinations. ucational Assistance Act of 1974 as

10. Insist that x-rays be transferred and S-358,5. Give this your strong support.
not repeated except where absolutely Similarly, only the state of California is necessary. requires training in health physics ~ - e 11. Incist on substituting the tuberculin and radiobiology in its medical I test for the chest x-ray unless the schools and questions on the state tuberculin test is' positive. board examinations on these sub-
12. Take legal action if necessary to jects. Unfortunately, the future of this avoid x-rays " required" to satisfy in- California law may be in doubt be-surance claims. cause of opposition by members of -
. 13. Refuse x-rays in the pelvic and ab- the medical profession. Give this law i '
dominal regions if there is the pos- your strong support and bring about [ sibility of pregnancy unless the x-rays similar (or better) legislation in all
, are urgent for your health. the states. Without doubt if the doctor
14. Ask the x-ray technologist or dentist or dentist is to decide whether or not . I
. that delivers the x-rays (or the radi- you should be x-rayed, he should
[ ologist) how much skin dose is de- know how to evaluate the risks and livered by each x ray you receive. weig'a them against the benefits. Keep a permanent record of each The medical professions have not only x-ray you (or your young children) been dr.agging their feet in the matter of pa- - receive, recording also the type of tient protection from unnecessary medical x-ray, area of body x rayed, and the radiation but have in many cases opposed i energy,(kev). If the x-ray tecimol- measures for improvement. They are a pow-
, ogist or dentist enncot answer your erful political force against whien government 9
h
r 1
-l j -ee o n . \
l l 368 . May,1973 agencies such as t'e USHS and EPA, which 7. . ~
~: Recommendatiotis of the'Iti-are charged with providing radiation pro- innational Commission on Radiological Pro ,
tection of the public, tremble when they con- tection. Pergamon Press, New York, ICRP
, Pub. No. 6 (1964).
template' taking radiation protection meas-
8. McClenahan, J. L: Wasted X. Rays. Radiology ures that might offend the medical 96:453 (August 1970).
professions. Only if you the pubh.c act on 9. Morgan. K. Z.: The Need for Radiation Pro-your own behalf, will you be provided good tection. Radiologic Technology 44:385 (1973). io, y ,7,,n, g, z,. Poss:ble Consequences of
~
medical radiography without unnecessary Excessive Medical Exposure in the United damaging radiation to yourself and your States-M5pliche Folgen einer ubermassigen children. Do what you can to encourage medamaschen Strahlenbelastung m den Vere-in;,,,n 3,,,,,, yon am,,jg , 33,,,y,,. your own state to adopt legislation such as slotter. Klinik tmd Praris, neft 3:127, Stutt-that in the state of Illinois. Here the diag. gart (Marz 1974). . nostic exE*sure limits are set at: (a) 500mR I I. , IYhat About Radiation? Afais and preferably <350 mR per abdomen Chest X. Ray Programs. USPHS Pub. Il9o (February 1965). A.P., (b) 1400 mR and preferably <1000 12. g mR per lateral lumbar spine, (c) 150 mR
Chest X. Ray Screening Rec-ommendations for TB-RD Associations. i i
and preferably <100 mR per cervical spine, NTRDA Bulletin 37, No. 9 (October 1971). f and (d) 400 mR and preferably <200 mR 13. Gitlin, J. N., and P. S. Lawrence: Populatwn
per A.P. skull radiograph..The unnecessary Ergosure so x. Rays. Us 1964 nnH.USPHS '.
No.1519 (19641. I exposure you prevent may be that to your- 14. self. internatw, nal Recommendations of ,the I Commission on Reatofor:tcal t., ~ Protection, New York, Perramon Press, Pub.
"#88 No.1 (Sept. 9,1955).
1. Ilarting. F.11., and W. Hesse: Vischr. Gerichit 15. Bross, I. D. J.: Leukemia from Low-Ixvel Ra-Afed. Offenti Gesundheitswesen 30, 296; 31, diation. New Eng. J. Afed. 287:107 Uuly 20 19721.
102 and 313 US79). .
2. Morgan, K. Z., and J. E. Turner: Principles 16. Baum. J.: Population Heterogeneity H)poth-of Radiation Protection. Robert Kriege Pub- esis on Radiation induced Cancer, given orally lishing Co. 0973L at Houstoa. Tex. meeting of the Ilealth Physics "
Society. July 10,1974
3. Grubbd, E.11.: Radiology. 21:155 (1933).

4. Stcne. R. S.: DYestern J. Surg. Obstet. Gynecob. 17. Muller, H. J.: Radiation and Heredity. Amer.

' J. Pub. Health. Sur. to Vol. So, I (1964L
$4:153, 201 (19tG); Protection in Diaenostic '
Radiology. Rutgers Univ. Press. New Bruns- 18. Russell, W. L.: Studies in Mammalian Radia-wick, N.J., i1957). p. 70; Radiology 38:639 l
19. tion Genetics. Nuclconics 23tS3 Can.1965). ;
(1952). ..
Report of the Advisory Com.
$. mitter en the Diological Effects of lonizing Alasimam Permissible Amounts of Radioisotopes in the Human Body and Radia: ion. BEln Report, NAS, NRC (Novem. ~ , ber l972).
Alasimum Permissible Concentrations in Air i and Water. NCRP Handbook 52, Nat. Hur. 20. Morgan, K. Z.: Testimony before the Senate Std. (1953), Commerce Committee on Bill 2067, "Redu - '
6. __ Transportation of Radioac- tion of Unnecessary Medical. Exposure," Au- .
tire Material by Passenger Aircraft. Report gust 28 30,1967, Congressional Record Ser. i No. I to the JCAE of the Special Panel to No. 90-49 (1963); Congressional Record Hear. Study Transportation of Nuclear Materials, ings before the Committee on Radiation Con- ' J. T. Conway, Chairman (Sept. 1974). trol for IIcalth and Safety Act, Washington, D. C., March 8,1973. l l
.e
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DECO}efISSIONING OF THE GORLEBEN FACILITY . A. Introduction
1. Attention given to decommissioning by Gorleben planners It is difficult to believe or understand why so little consideration has been given to the subject of decommissioning by the Gorleben planners.
One must conclude that the subject has been seriously neglected or considered to be of very minor importance, or perhaps a subject that can be addressed when the time comes to decommission the plant 30 to 40 years from now. Sections 1.6, 2.6, 3.6, 4.6 and 5.6 of the Safety Report devote nine pages (lines double spaced) to the subject of decommissioning but each of the five parts of the report is simply a repetition of only a broad outline of the subject so that it corresponds essentially to less than one page (lines single spaced) of text on this subject when one might expect to find at least a 300 to 400 page discussion. Then, too, there is reference in the material provided for committee review to the so called Decommissicning Center but there is no discussion in this report of the subject of decom-missioning. To persons w.x are familiar with the importance of careful planning for decommissioning of such plants in the design stage and long before construction begins the subject of Decommissioning is very conspicuous in all the Gorleben reports, projects, reviews and evaluations because of its omission from mate)ial provided to t i International Review Committee.
! 2. Proper time to consider decommissioning I V l One of the cardinal rules of health physfcists.throughouttheworld ,
(and members of the Fachverband fur Strahl schutz in this part of Europe)
; is that all well conceived.and properly lanned' programs involving potential high level exposure to ionizing radiat on must be carefully planned in considerable detail well in advance o every stage of development of a .l program. This includes stages of c neeption, design, construction, ! operation, maintenance, and d .missioning with special attention given during early stages of iception and design. It is only because of this Preliminary report Committee 8 on Decommissioning (members: Lindstr6m,
' l Resnickoff and chai an Morgan) January 5, 1979. i I t i
e,,
.~ " cradle to the grave" type of health physics responsibility that nuclear . ; power has been considered to be acceptably safe and 1979 is no time and Gorleben is no place in which to change this basic philosophy. Everything
. that goes into a hot cell, a nuclear reactor or any operation involving high level radioactive material, must be so planned and designed that it i can be removed and disposed of in terms of minimum cost in man. rem and in I dollars.(marks) at the conclusion of the operation. This is true especially in respect to the hot vaste, tanks, floor drains, pumps, air ducts, piping, . l )' 1 etc. at Gorleben. i 3. Maior goal of a well planned and acceptable radiation protection
;. program Since many studies during the past few decades have nhown that all I
ionizing radiation exposure is potentially harmful and that the probability
of chronic radiation damage (e.g. cancer or genetic mutations) increases approximately linearly with the accumulated dose, there is no dose so small that the risk becomes zero. Thus the question is not, "What is a safe dose of radiation?," but, "How much dose or consequent risk of harm .
f is acceptable in terms of the overall expected benefits of the operation?" As a result we have developed the philosophy of balancing the benefits i against the risks and keeping all exposure as low as reasonably achievable , } (ALARA). Sometimes we permit the immediate objective to confuse or obscure what should be the major long range goal or objective of n large operation. , For example the objective of a high level radioactive waste facility such as Gorleben is sometimes stated to be the 1. solation.of radioactive waste i from man and his environment as long as possible. This may fall far short i of what should be the objective or major goal, namely to isolate and dispose of the waste in such a manner that the total dose, integrated over infinite time and space and for all people is a minimum. Generally the two objectives l can be quite different because often most of the man rem dose is not from
-integrating low population doses over thousands of years but from some of i -Recent studies indicate that at low doses the' cancer risk per rem is greater than at high doses. Therefore in many cases the linear hypotheses is non-conservative. (See K. Z. Morgan,, "The. Linear Hypothesis of Radiation Damage Appears to be Non-Conservative in'Many Cases'" Proceedings of IRPA, , .Vol. 2, Paris, France (April 1977).
[v ,
1. :
3 - the methods of decommissioning and long range disposal that do not take . into sufficient account the large' occupational and environmental short term exposures associated with such operations in terms of. man rem and often the internal dose is seriously underestimated or improperly accessed. In carrying out this calculation special care must be taken to consider dose commitment and not just annual dose. For example, 239Pu with a radio-active half life of 24390 years and a biological half life in the human , skeleton of 200 years continues to irradiate the skeleton of a man at the rate of about 30 rem /y all the rer.t of his life if he happens to deposit in his body a so called maximum permissible body burden of 0.04 pCi of which 907. is localized in the skeleton. Thus the major goal of the Gorleben decommissioning operation should be to minimize { { { D(t)*D(p)*D(s)dtdpas where D(t), D(p), D(s) are dose functions related to time, persons exposed and all space respectively and this integration must give careful consideration to internal dose and especially that received by those engaged occupationally in the decommissioning operation. Also, decommissioning must be considered as it relates to each part of the cycle of operations at Gorleben because it is not an independent variable that can be treated in isolation.
4. Cost of decommissioning As suggested by the above discussion the success of a decommissioning operation in terms of minimizing cost when expressed in man rem and dollars depends critically on whether or not sufficient ctention has been given to the problem from the beginning of the operation. Actually all the costs can be expressed in dollars if one considers each man rem to correspond to. ,
$1000 (1974 dollars) as is done for example by the Nuclear Regulatory Com- .
mission of the U.S. Also the cancer risk can be estimated by using the t overall cancer risk coefficient as 6x10-4 cancers / man ren which corresponds 1 to 1000 $/ man rem x 6x10-4 er
= $1.7 x 106 / cancer. One is reluctant to place a dollar value on a human life (especially if its his own life) but maybe the value of a human life has become more stable than the dollar or an ounce of gold.
3 i
}
-9 .
Only a few serious efforts have been made to estimate the costs of de- . commissioning a reprocessing plant. The U.S. Nuclear Regulatory Commission report (NUREG-0278) estinates the costs to range from $58 to 81 million dollars (1978 dollars) for a reprocessing plant such as the Barnwell, g South Carolina plant in the U.S. if it were constructed and operated with detailed consideration given to decommissioning. The estimated costs 1n , man. rem range between 80 and 523. The lower values in man. rem are for the layaway plan and the higher values are for immediate dismantlement while the higher values in dollars are for layaway with deferred' dismantlement after 30 years and the lower values are for immediate dismantlement. No data are available on the costs for entombment although this might be the cheapest method botn in terms of man rem and dollars. These estimates are for a plant that has given considerable consideration to decommissioning beginning with the conception and design stages of the plant and where eventual decommissioning was given consideration in all parts of the daily operations. A good example of the decommissioning costs for a plant that was designed and operated with very little consideration to eventual de- ! commissioning is the West Valley plant, New York, U.S.A. This was a far smaller operation than Barnwell or the proposed Gorleben reprocessing facility but still the estimated cost is $800,000,000 (in 1977 dollars) so the cost for,Gorleben decommissioning would be well in excess of $10 9 unless appropriate attention is given to decommissioning in all stages of this operation. The situation at West Valley is particularly serious be-cause the state of New York, which is on the verge of bankruptcy was lef t
" holding the bag" when the former operator pulled out. The total decom-missioning cost probably would be less than $20,000,000 if appropriate attention had been given at West Valley to this problem. It is to be i hoped that the State of Lower Saxony will profit from this sad experience of the State of New York lest it too wakes up and finds it has an expensive ,
white elephant on its hands or a bear by the tail it would like to let , loose but dares not do so. i i B. Types of decommissioning that should be considered t There are several types of decommiesioning of a reprocessing and waste i disposal system that should be given serious consideration before choosing 4 ,)
.! J' e ...
which is most appropriate for Gorleben. The choice could well be a codbi-
nation of these types and plans for decommissioning should not be so rigid that they cannot be changed as conditions 'in the plant change (e.g. due to accidents or new types'of reactor fuel to be reprocessed) and as regu-lations and safety standards are modified. It is especially important that detailed plans for decommissioning be taken into careful account in the conceptual and design stages of the program. These types may be classified .
as:
1. In-place entodbment (for example, pour reinforced concrete over the process and operating buildings thus encasing them and their contents as a perpetual monument.

2. Complete dismantlement and removal of all radioactive components and unconditional release of the facility to public or private use without any restrictions on its future use.

3. Mothballing or protective storage. This includes removing all equipment that is highly contaminated *(tanks, pipes, mixers, columns, etc.) to hot cells or other storage areas within the facility and sealing them off from access by welded steel plates and securely locked doors. Most of these operations would be con-ducted by the use of remote control equipment to reduce occupational exposure. The process buildings and all operating areas would be made inaccessable to the public. Alarms would be installed for protection from fire and intrusion and to give warning should
, radiation levels increase. Guards would be stationed around the t
clock in process buildings and operating areas to guarantee security - and to sound the alarm in case of fire, explosion, utility mal-
. function, etc. The storage tanks would be emptied completely and removed. All the site area outside the buildings would be released for public use provided this did not compromise security. Uncon-l taminated offices, lunch rooms, medical facilities, counting rooms, and administrative buildings could be released to public use. There i
would be no intention of ever using the facility again for fuel re-l processing and waste disposal. Plans would be laid for complete i ! decommissioning of the facility (i.e. complete dismantlement of l' 1; 1 5
c. processing buildings and ' removal of all contaminated materials from the site or perhaps for entombment at a later date). This would be done after 10, 30 or maybe after 100 years or more. . The rationale for choosing the mothball procedure is that a delay in complete decommissioning results in a reduced dose (man rem) to the population and to the occupational workers , although it does increase the dollar cost.
4. Layaway is similar to mothballing except that much of the equip-ment is just deactivated or placed in a standby condition.. There are fewer welded access ways, there are more alarm systems and a tighter guard surveillance force is required. The total site remains inaccessible to the public. It might be possible to put the facility to some future use as a nuclear operation but such ccnversion would be very expensive and rather unlikely. The most likely ultimate choice would be entombment or decommissioning as with the case above (i.e. deferred dismantlement) .
C. Advantages of eacP type of decommissioning
1. In-place entombment.~
In general this method has been frowned upon and it was not even con- ' sidered in the NUREG-0278 report. Some of the reasons for this are: (1) This choice is not easily reversible at some later date, (2) If radio-active contamination' leaked from this monument at a later date, corrective measures might be very difficult, (3) To many people such a monument would be a constant reminder of an unsolved problem, (4) This land might needed at a-later date for a more useful purpose, (5) This could place at. ,, fair burden or a' dangerous temptation on future generations; it is not fair that people living thousands of years hence should be required to pay our debts. In spite of these objections entombment might be the method of choice be- , cause it probably could be carried out with the least occupational exposure of the four methods under consideration in this review and as a consequence might meet the basic requirement of a decommissioning opera, tion, namely
' '~ t -
tominimizethedoserelation,[o,pps o ,loD(t) D(p)*D(s)dtdpds. I,
~ '6 ,
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- in n
________._m_ -
a l ,. .. In the employment of the entombment method of decommissioning of a . reprocessing facility such as Gorleben, one o# the early steps would be to drain all radioactive vaste tanks and flusn them thoroughly. All filters, chemicals, resins, liquids, etc. should be treated in the usual manner and placed in perpetual storage in the salt repository along with the other high level radioactive vaste. The high level waste tanks would be disintered, reduced to the smallest possible volume by means of remote . operations and dropped into the process ouilding. This building in turn, along with all its contents would be demolished to a heap of rubble. The twisted steel could be cut by the use of remotely operated torches. The radiation workers would be encased in pressure suits. After the volume of this material had been reduced to a minimum, it would be mixed with concrete and made into a pyramid or similar monument. Steel for reinforce-ment would be added as needed to make a monument of high resistance to weather, tampering by man, earthquakes, etc. If entombment is selected, it will call for careful planning before the Gorleben plant is built and will require the development of special equipment and carefully thought out and innovative demolition techniques that can be conducted with a mini-mum of direct human contact, with very little dust and water runoff during demolition and will call for the development of new ideas and new types of remote control equipment and operations. The effectiveness of the use of the demolition ball, placed charges of explosives and nets and the mixing of the final rubble with concrete can be increased if plans are made for the use of entombment in the conception and design stages and long before construction of Gorleben begins. The actual number of curie years con-tained in the monuments resulting from entombment could and should be kept
very small and consist mostly of radionuclides in the crud of pipes, sumps and demolished tanks, contamination in cement floors, valls and shielding materials from normal operations, spills and accidents and contamination accumulated in ventilation. ducts, fans, motors, crains and general repro-cessing and waste handling equipment that was used in the hot cells. 'With proper design of the plant in its present stage and with carefully planned operations af ter construction there need be very little residual contami-nation from long lived radionuclides such as 238,239,240,241,242Pu, 241,242m,243Am, 235,238U, 237Np, 129 1 , 90Sr, 137Cs, 99Tc, etc. There 7
1- _ _ _ _ _ - _ _ ________ -
-ll !
I 1, would be a.small amount of induced activity due to (a,n) reactions and from 244 Cm neutron activity (especially from reprocessing of M0X fuel). Most of the high level wastes would be removed in the tank solutions and liquids used for flushing operations, in the resins, fuel element jackets and small hot cell components that would be removed before demo- - ' , lition operations began and disposed of in the salt formation in the usual manner.
2. Complete dismantlement.
This type of decommissioning is the only m2thod that removes the prob-lem over a short period of time so that it is "out of sight, out of mind." Also, as indicated above, it is the cheapest of the methods in dollars except perhaps for entombment for which no cost estimates are available. This method has a serious disadvantage in that it leads to the highest costs in man rem (estimated in :NUREG-0278 at 523 man rem) . This might be acceptable, however, because at $1000 per manr'em this would be only
$523,000 (1978 dollars) and would correspond only to a 30% risk of one
, radiation induced cancer and about the same amount of genetic risk. All these risk estimates in NUREG-0278 must be taken with considerable skepticism, however, because they apply only to a well planned operation in an almost perfectly designed plant from the standpoint of decommissioning , in which everything goes according to plans and in which there are no accidents. This method of decommissioning is without doubt the most hazardous of the four methods in relation to occupational and environmental exposu?e and since such operations can never be conducted with perfection, it would be pradent to assume this method as applied to Gorleben probably would be more hazardous by at least an order of magnitude than these estimates or would result in at least three radiation fatalities and three Renetic mutations'. If no prior detailed plans were made for decommissioning as seams to have been the case with West Valley, this method could easily lead to far greater risks, e.g. 30 radiation induced fatilities and 30 genetic mutations. Unlike the Barnwell operation for which the EUREG-0278. estimates were made, the Gorleben plant does offer an especially attractive feature for i k.
.- - .-.e -. -.a --+.==s --u,+ i s-- u a . - .. .+-s - - - , - . - s s ~ .ae..- - - , , ,s ' . +
this method of decommissioning, namely Gorleben is a combination reproces-sing and radioactive waste disposal facility, all on the same site. Thus- ,
' it is suggested that Gorleben might be modified from its present design in such a'way that th< waste disposal facility could continue in operation until all the reproces.. ng plant and waste tanks were completely decom-missioned, taken apart and buried in the underground salt formation. Then,
section by section the waste facility could be disassembled and taken into the salt formation. In a sense the salt dome would act like black holes; in outer space---everything top-side would disappear (hopefully forever) into the hole in the salt. The final step could be to fill all remaining 4
4 cavities and shafts of the salt mine with reinforced steel and concrete , r ! (i.e. an underground monument) . ,
3. Mothballing or protective storage. "
As indicated above, both mothballing and layaway offer the advantages 3 of extra time and this in turn allows an opportunity for additional research and the development of improved methods of final dismantlement or entombment 4 and at the same time it permits appreciable decay of the relatively short-lived radionuclides such as 89,90Sr, 91y, 95Zr, 140Ba. 134,135,137Cs, i 103.106Ru, 93m,95Nb, 93'go,126Sb, 127m,129mTe,. 140Ba, 141'144Ce, 143Pr, etc. However, time is no panacea for the unobtrusive disappearance of the more dangerous radionuclides because many of the radionuclides have daughters ' . of longer half life. For example among the fission products we have ) 129 Te(33.6d)0,,129I(1.57x107 y) and 147 Nd(ll.06d)8-+ 147Pm(2.62y) and among the actinide elements 241 Pu(13.2y)8-e 241Am(458y), 238Pu(86.y)"-+ 234U(2.47x' [ 10 57), 243Cm(32y)"--, 2 39Pu(24,390y), 244Cm(17.6y) L 240Pu(6580y), 242Cm b (162.5d)"-+ 238Pu(86y) etc. T':.e radioactive decay of 232U(70y) is bad be- ! cause it is the daughter of 236 Pu(2.85y) and. leads to' the ingrowth 'of i granddaughter radionucledes that emit very energetic y-radiation. - Over
a much longer. period of time (thousands of years) 243Am(7380y), 239Pu .
l (24390y), 226Ra'(1600y) and its daughter products and 1291 in succession become-the major contributors to the radiation hazards in PWR and BWR fuel. For the first 200 years there is a rapid reduction by three orders of magnitude in the levels of radioactivity in spent fuel from a. light water-reactor, but over the next 10,000 years only a slow drop in radioactivity l l L 9 I o
, , - , - . - , _ m ~ _.. - --._.,,_._._...-,,-_.-u. - _ _ . . , .-4 -
? e by about two orders of magnitude. ,Thus, if the eventual plan is to remove ,
all above ground radioactive contamination, complete dismantlement should be undertaken during the first 200 years and preferably during the first 100 years because little would be gained by a considerably longer delay.
.The breakdown in dollar costs (in millions of 1978 dollars) and in
- man rem as given in NUREG-0278 for this method of decontamination is 1
Initial costs. . . . . . . 19 Occupational. . . . . . . 81 Care costs for 30 years. . 4 Public. ......... 11 Final dismantlement. ... 44 , 92 man rem Total $67M i. Because of the complete disfunction of equipment and the low radiation risks after mothballing, surveillance and guard expenses are minimal (only $140,000/ year). Thus if final dismantlement were delayed for 100 years instead of 30 years, the additional cost would be only ten million dollars (see Fig.1) . This mothball method has an advantage over the layaway arrangement. in that most of the area and buildings (except the contaminated process and waste disposal facilities) could be released to public use. The l income from the use of these areas could more than offset the care costs - - ! and if dismantlement is delayed for 100 years, its costs might be consid-erably cheaper than immediate complete dismantlement or entombment. Certainly if the contamination levels have dropped by a factor of three l or four hundred during a 100 year delay period, all radiation exposures (occupational and environmental) and the dollar costs of final dismantle-ment can be reduced drastically. Also with appropriate design of Gorleben j, and properly developed operating and decontamination procedures it should [ be possible to remove most of the more bothersome rcdionuclides during l the early stages of decontamination so that the costs of decommissioning (in dollars and in man rem) will be materially reduced. l I
4. _ Layaway j i
Perhaps the principal advantage of layaway over mothballing or pro-tective storage is that it does not exclude the possibility of using the i-
, 10 - ~ ( )'
7 ~ r facility.for a nuclear operation in the future or even setting most of the old plant back into operation at some future date. I,ayaway could be carried out in such a way that it consists of the first steps of mothballing (see Fig. 1). It includes dra'ining all tanks, other containers, pipes, etc. of their radioactive contents and thoroughly flushing them with various , cleaning solutions without damaging their integrity. All reactor fuel and casings, resins, air filters, c1 caning and flushing solutions would be removed and along with other radioactive caterial in the waste facility would be processed, encased in glass and deposited in the geological salt formatio'. n Highly contaminated sumps in the, floors, plenums and fans in the air vent system, etc. could be replaced. The equipment in the hot cells of the reprocessing facility would be left intact. It might even
- be' practical to layaway the reprocessing facility and leave the waste disposal facility in full operation. It is certain that the time will come when the fuel reprocessing plant will have to curtail its operations.
This will come about 'as a result of one or more of the following circum-stances: {
l. Accidents (major or minor) which indicate the operation does no't provide adequate occupational or environmental safety

2. Routine operations which do not provide adequate occupational or environmental safety, e.g. releases of high levels of radioactivity into working areas or into general envrionment

3. Development and enforcement of more stringent safety standards by the State or Federal Government

4. Deterioration of equipment and facilities as a result of accidents or from normal ware and tear. This would include fires, earthquakes, fall of aircraft, etc.

5. Encroachment of neighboring populations
'6. Objections of the people to such nuclear operations
7. Changes in types of nuclear power reactors and in their fuel requirements

8. Development of other equipment and techniques that are more efficient and that provide greater safety
. 9. Other types of power (fusion, solar, fossil fuel, geotherm, biomass, etc.) become preferable due to less costs (in dollars or in safety)
10. International developments (treaties, agreements, vars, etc.),
l_ . 11
Conception J. Desipa .
, e Constructico l t.
Operatio: O Maintenance ( l Accidents
} Routine ( ' ~ . , ,~ ***i %/ A#
l Deco'c=issiccing L_. b i 1 1 1 Entonb ent . Dismantlement j M:thballing Layaway 4 + 1 2 3 4 after 30 to 100 years a, v Entorbcent Dismantlement a fb after 1 to 100 years
.I Ento =bsent Dismantlement {Mothballing Operations 4 4 4c fd after 30 to 100 years ,,
1 1 Entorbrant , Dismantlement hca 4bh Fig. 1. Time Sequence of Events at Gorleb.en. From this chart is is seen there are nine possible sequences of events (1,2,3a,3b,4a,4b,4ca,4ch,4d[) 'if all the plant is decommissi.onei in the sz=e way. It is likely, however, that the reprocessing plant will be deco =nissioned by one method s.nd the vaste facility by another. In such case there would be 9x9 c-- 81 possible sequences of events.
N Therefore, deconsissioning of Gorleb.en is not something that may have to be considered at some time in the futura b at rather it is something thz: must be and vill be carried out in the fct.2re. The breakdown in dollar costs (in zil.licas of 1978 dollars) and i=. man rem as given in NUREG-0278 for the ~ayaway =rethod of decommissioning i l is Cec .2pational. Initial costs. . . .... 18 .. ... . 69 Ca-a costs for 3 years. . 20 Inblic. . . . . . .. . . 11 Total 80 mza. rem _.4-a' 2 dis =antlenent. ... 43 Total $81E Un'ess there were believed to be sre pessibility that the Gorleben reprocessing plant and/or the waste dis os.al facility would be returned. to use as a nuclear facility at some futura date, it is almost cert'ain ths.: layaway veuld not be chosen as the meth-d of deco =sissioning because as seen ab ve it saves only 12 man. rem ove- the nothball procedure (i.e. 92-80 min-res) and its cost for 30 year da.fer:ent of complete dismantle-- ment is SL4M greater (i.e. $81-67P' thm =othballing. Also the care ecsts would be f ar greater than for moth'i su q, (i.e. 5680,000/y compared v'th
$140,00:/7) so that if final dismantle::ent ware delayed for 100 years in-stead of 30 years, the additionai ccst voc1d be $48M. It seems possib e also tht: the cost in man rem might act"ily be greater than for moth-balling because the radiation areas wod.d not be as secure (i.e. passage ways wo:ld be locked instead of welded and there would be a risk tha one of the guards night unlock a doer a-d enter an area where he would ,
recei.e a large exposure. If there vers s.oss uncertainty regarding whether the plant or some part of it mi;ht be used for nuclear operaticos in the future, it would seem reasona.ble to fellow a layaway plan and then as shot- in Fig.1, one of four choices ceuld be =ade at a later date. For exa2gis, if there were a serious shutage of oil and natural gas af ter a 20 par layaway at Gorleben, thi pla could be put back into operati= again much faster and at less cest than building a new plant althougi che efficiency of this renovattd plant would not be as great
- as that cf a new plant.
4 D. Conclusions Decommissioning of Gorleben is not something that might be needed in the future but something which definitely will be required and must l be provided. The cost of decommissioning in dollars or in nan. rem will be greater i by saveral orders of magnitude if proper plans for its eventuality are l not nade in all stages of development of Gorleben--the conceptual and design stages being the most important. The major goal of a well planned decommissiIoning operation is not to remove and isolate a nuclear plant from man and his environme.nt as long as possible or to remove it completely but it is to discontinue the operation in such a way that[ f [ D(. ).D(p).D(s)dtdpas is a minimum when the licit of t is the time when D(t) becomes insignificant. Special care cust be taken to consider dose commitment when applying this formulation to internal dose. All radionuclides do not present the same hazard or radiation risk per curie year when they are in the human environment. Therefore, special attention should be given to the relative hazard, H, of the various radio-nuclides in providing radiation protection to occupational workers and rechers of the public during decommissioning operations. Several attempts have been made to list the radionuclides in accordance with their relative hazard. One such attempt (K. Z. Morgan, W. S. Snyder and M. R. Ford,
" Relative Hazard of the Various Radioactive Materials," Health Physics 10, 151, 1964) lists values of H for some of the radionuclides of interest as given in Table I. It is to be noted that some radionuclides such as 23E Pu, 241 Am or 244 Cm are far more hazardous curie-for-curie than others such as 87Rb, 232Th or 238U. /
The. types of deomrdssioning maybe classified as entombment, complete dis =antlement, mothballing and layaway. Depending on circumstances and objectives the order of preference in Fig.1 is probably 1st choice: 3 + 3b (Mothballing + dismantlement) 2nd chtice: 2 (Immediate dismantlement) 3rd choice: 1 (Entombment) 4th choice: 4 + 4c + 4cb (Layaway + mothballing + dismantlement) 1A L
1-i It is very probable that the reprocessing plant and the radicactive ' h vaste disposal facility will.not be decommissioned at the same time or i in the same way. In such case there would be 81 choices for decom-missioning as shown in Fig. 1. t 4 % i. i r, i f 1 b. 4 I r e } f 2 1 i ll N 3 15 I _
. . . - . . -- . . . . ~- - . . _ ~
h TABLE I. Relative Hazard of Airborn Radionuclides on a Curie Basis *
. adio-Radio- Radio-Nuclide T H Nuclide T H 85Kr 10.76y 2.5x10-5 103Pd 17d 3.9x10-4 144Nd 2.4x1015y 4.4x10-13 86Rb 18.7d 4.3x10-3 105Ag 40d 3.6x10-3 2.62y 147Pm 4.5x10-3 87Rb 4.8x1010 y 3.7x10-11 125Sb 2.71y 1.1x10-2 147Sm 1.05x10ll y 7.7x10-9 85 Sr 64d 2.8x10-3 125 Te 58d 2.3x10-3 151Sm 87y 4.5x10-3 89 Sr 52.7d 1.1x10-2 127mTe 109d 7.1x10-3 210Pb 139d 2.33 90 Sr- 27.7y 226 Ra 1.01 129I 1.7x107 y 2.9x10-6 1602y 1.00 4
90 Y. 64h 2.9x10-3 131I 8d 3.4x10-2 232Th 1.41x1010 y 1.68x10-6 91Y 58.8d 9.1x10-3 131CXe 11.8d' 1.7x10-5 232U 72y 10.5 93Zr 1.5x10 y 6 9.2x10-7 133Xe 5.3d 2.0x10-5 235U 7.1x108y 4.85x10-7 952r 65.5d 9.1x10-3 1350s 3x106 y 2.8x10-7 238U 9 4.51x10 y 1.37x10-7 93mNb 13.6y 2.4x10-3 136Cs 13.7d 1.7x10-3 237 Np 2.14x106 y 4.91x10-3 95Nb 35d '2.9x10-3 137Cs 30y 2x10-2 238Pu 86.4y 152 96Tc 4.35d 1.2x10-3 134Cs 2.0y 2.5x10-2 239Pu 24,390y 1.04 97mTc 91d 1.9x10-3 131Ba 12d 8.3x10-4 240 Pe 6580y 3.84 97 Ic 6 2.6x10 y 3.6x10-5 140Ba 12.8d 6.7x10-3 241Pu 13.2y 3.23 93 Tc 2.12x105 y 8.6x10-6 141Ce 32.5d 1.8x10-3 241Am 458y 15.9 103 Ru 144 Ce 39.5d 3.5x10-3 284d 4.5x10-2 243Am 7.95x103 y 9.74x10-1 106 Ru 368d 5.3x10-2 143Pr 13.59d 1.6x10-3 244Cm 17.6y 32.3 1
~
16
Appendix
+
I. Sources of Information on Decommissioning of Nuclear Facilities A. General Discussion The early project reports and scientific publications before 1960 are almost silent on the subjact of radioactive waste disposal and a similar vacuum in research and general or specific information on decommissioning of nuclear facilities continues even to the present date. Serious consideration to the problems of radioactive waste dis-posal was given by the small research group at Lyons, Kansas, U.S.A. (a program of Permanent Disposal of High Activity Waste, HAW, in Bedded Salt conducted by the Health Physics Division of Oak Ridge National Laboratory, ORNL, Oak Ridge, Tennessee, U.S.A., Karl Z. Morgan, Division director) and by the small group working in the Asse salt mine in the Federal Republic of Germany (Placement of Medium Activity Waste, MAW, in a Salt Dome Formation) prior to 1970. At present some studies are underway on permanent disposal of RAW in the Konrad Mine, F.R.G. and exploratory studies are underway in the U.S.A. However, only during the past year (1978) has research gotten underway by a few groups that have published a handfull of reports on deommissioning of nuclear facilities. It is difficult for this writer (KZM) who has striven for the s,uccess of the nuclear power industry since early 1943 to appreciate this lack of interest and absence of support of research in these two vital parts of the nuclear industry. In considerable measure it is the lack of research, development and visible progress in areas such as reactor safety, pro- , liferation resistance, radioactive vaste disposal and decommissioning of nuclear facilities that has brought about strong and effective national and international opposition to nuclear energy. This has been the cause ( of considerable frustration and discouragement to the writer (KZM) who i for 35 five years has striven to make nuclear energy one of the safest of all industries. Our early HAW studies in the Kansas salt mines were supported with less than enthusiasm by the early U.S. Atomic Energy Com-mission--in fact they were begun only because I and my associate, E. G. Struxness, realizing their vital importance, bootlegged or diverted other 17
programfundsintothesestudies$ddmanyyearslaterwhenourSalt research showed great promise this waste disposal program b,ecame a political issue and all support in the ORNL Health Physics Division was discontinued. Only during the past two years have serious programs of study, research and on the spot investigation in the area of decom-missioning gotten underway at Battelle Pacific Northwest Laboratory, BPNL, and at ORNL (e.g. one of the writer's students' is doing his Ph.D. research on decommissioning of Nuclear Facilities at the present time in cooperation with the ORNL group). Hopefully, in a few years there will bu some better numbers from actual field data on decommissioning and fewer guesses regarding the effectiveness and appropriateness of various methods of decommissioning of various types of nuclear facilities.- Unfortunately, to the'present time almost all the studies on decom-missioning have been limited in application to nuclear power plants-- and in particular to LWRs (PWR and BWR)--so that there is a serious paucity of information on the decommissionir.g of nuclear fuel reproces-sing plants and radioactive waste disposal facilities. B. Source of Information on Decommissioning of Nuclear Power Plants Recently several reports have been published on Decommissioning of Nuclear Power Plants. Although these reports do not address the question of Decommissioning of Nuclear Reprocessing Plants or Decommissioning of Radioactive Waste Disposal Facilities (the subjects of interest here), they do provide some useful general guides cnd certain specific data that have application to these last two stages (back end) of the nuclear cycle. In preparing this report some of the more useful documents of reference are those relating to LWRs and are as follows:
1. Recommendations for Nuclear Facility Design with Special Regard ,
to Decommissioning Potential, by H.V. Eyss, H. Kofahl and D. Leven GRS-A-110 (February 1978).
2. Technology, Spfety and Costs of Decommissioning a Reference Pressurized Reactor Power Station, NUREG/CR-0130 (June 1978).
18 i 4
1 l
3. Technology, Safety and Costs of Decommissioning a Reference Pressurized Water Reactor Power Station, by R. I. Smith, G. J.
Konzek and W. E. Kennedy, Jr., Battelle Pacific Northwest - Laboratory, Volumes I and II, NUREG/CR-0130 (June 1978). C. Sources of Information Relating to the General Problems of Decom-missioning and to Those Which are Specific to Nuclear Reprocessing Plants Some of the more useful documents of reference in this area are: -
1. Technology, Safety and Costs of Decommissioning a. Reference Nuclear Fuel Reprocessing Plant, NUREG-0278 (October 1977).

2. Decommissioning and Decontamination of Nuclear Facilities, a report prepared for the Subcommittee on the Environment and the Atmosphere of the Committee on Science and Technology, U.S. House of Representatives, 95th Congress (February 1978).

3. Plan for Reevaluation of NRC Policy on Decommissioning of Nuclear Facilities NUREG-0436, liarch 1978.

4. Studies of Decommissioning a Pressurized Water Reactor and a Fuel Reprocessing Plant, Discussion Material for the Advisory Committee on Reactor Safeguards, Battelle Pacific Northwest Laboratories, K. J. Schneider and R. I. Smith, July 26, 1978.

5. Standards and Guidelines Pertinent to the Development of Decom-
~
missioning Critetia for Sites Contaminated with Radioactive Ibterial, ORNL, by H. W. Dickson, ORNL/0 EPA-4 (hugust 1978).
6. Sections from the Gorleben Safety Report (1.6, 2.6, 3.6, 4.6, 5.6) a total of about one page (1978).

7. Situation der Entsorgung der Kernkraftwerke in der Bundesrepublik Deutschland, Section 6 (11 pages), (!!ovember 30, 1977).

8. Decommissioning Criteria for Nuclear Facilities, U.S. Federal Register, Vol. 43, No. 49 (March 13, 1978).

9. Termination of Operating Licenses for Nuclear Reactors, USAEC Regulatory Guide 1.86 (June 1974).
19
. -. . .. . . - = - - . ...
,. s. , II. Some Comments on the Proposed'Gorleben Plant Based in Part on the ' Above Sources of Information ! A. Reasons why Much of the Published Data May not Apply to Gorleben
~
and Shortcomings and Difficulties Likely to Develop During the Decommissioning of Gorleben .
1. The studies by the BPNL Rroup apply only to a limited extent to Gorleben because they are based on the Barnwell Nuclear Fuel Plant
- (BNFP) and the assumption that decommissioning has bedn given ap-propriate attention in all stages of the reprocessing plant develop-ment--conception, design, construction, operation (routine and ac-cident), maintenance and decommissioning. This is not the case with Gorleben. L 2. Gorleben is the only plant of its type which incorporates both I reprocessing and waste disposal at a single site. This provides ! some very substantial advantages to Corlebenbut it could be a handi . t t cap if a major accident in the reprocessing plant, put the waste disposal facility out of operation for a long time.
3. None of the published data take into account the unique' problems introduced at Gorleben when it begins reprocessing mixed oxide (MOX)
! fuel. Some of these problems relate to security (proliferation),
neutron dose, activation products, large increase in the more dangerous-f trans Pu-239 radionuclides, etc.
4. Entombment need not be followed necessarily by dismantlement.-
I In fact I believe entombment should never be considered if there-is any reason to believe it must be followed at a later date by dismantle-ment. As can be seen from Fig.1 one may choose either en1 ombment or.: . dismantlement but neither is to be followed by the other. As shown,
~
i entombment may follow by any one of four routs: -1, 3 + 3a,'4 + 4a~or ! 4 + 4c + 4ca and in all cases it is the terminal or final step..
5. Dose estimates are grossly underestimated in some of the reports for the various methods of decommissioning. Insufficient account is
_taken of internal dose and of dose commitment. The annual permissible'
' dose commitment corresponds to the intake of a long lived radionuclide- -
_(where T =rb T T /(T + Tb )) such that the integrated dose to.the
q. , , , ,
T 20-
?.. . .
i / r, r ,.. _, Y* ag, f %. ~ {f ,a -
- i t 9, ' -p
critical body organ over the'unsuing 50 years-is'e.q'ua1 p numerically to the limiting dose rate for that body organ. / '* ~
, "' i ?m 8, ,
6. Insuf ficient account is taken of dhe se, rious W. stakes __tnade by_ r previous operations luch as the West, Valley, New York', commercial reprocessing plant and the Cimarron Kerr-McGee fuel fabriE$ tion ~
plant near Oklahoma City, Oklahoma. For example, West Valley made s a routine immoral practice of burning out of employees (giving a temporary employee the limited dose in a,t'cw days) and the Kerr- , McGee plant at Cimarron had almost daily, incidents of personnel con- - tamination. These two operations went otic of operation in consider-ablepartbecausethehdidnotlearnfromtheirownmiscakesand certainly Gorleben will,,want,to profit by avoiding these same mis-takes and showing now hob such serious mistakes can and will be avoided. Both West Valley and Cimarron are faced with very dif-ficult and expensive decommissioning operations that,Gorleben should
. strive to avoid with great passion. ,
7. The salt dome waste repository may be filled (reach its maximum capacity) prior to the shutdown of the reprocessing facility for de-commissioning. Space should be set aside and reserved in the salt repository to accommodate all the HAW, MAW and LAW of the facility including all buildings, structures, equipment, tanks, broken concrete,'
pipes, etc. that contain residual radioactive contaimination.
8. Insufficient attention has been given to the problems of airborn dust and water runoff during the decommissioning operations. This can be serious especially during entombment or dismantlement. -
Following a large chemical explosion in one of the reprocessing tanks at ORNL while I was, director of the Health Physics Division there I found it necessary to take immediate and rather unusual measures to hold down the transuranic contamination in the vicinity. For example, we covered the roads and grounds that were contaminated with a heavy-layer of tar and the contaminated buildings were sprayed with especially selected paint. Some months later the roads, and other tarred areas, ; were taken up with the nic of jackhammers, demolation balls and backhoe l
; 21 i l 4
4
=
l b diggers, dropped into plastic bags and hauled off to the radioactive . waste disposal facility. Then the buildings were taken down, piece by piece, (using additional quick drying sprayed paint as needed), placed in plastic bags and hhuled off to the radioactive waste disposal facility.- All water runoff was collected, treated and - disposed of. The airborn pollution during the use of the demolition ball, jack hammers, shaped charges of explosives, grinding, sandblasting, surface polishing, etc. can be expected to be especially dusty opera-tions and are certain to increase the risks of large internal dose to occupational workers and possibly to members of the general public. The core common ameliorating measures that have been used will not be summarized here because none have been adequate or completely satis-factory. There is a pressing need for new and innovative methods such as the use of enclosures made by large air pressure supported tente to contain the dust and the digging of deep trenches about the' facility to catch all the water runoff from the surface ar.d that which percolates more slowly a few meters below the surface.
9. Housekeeping.
' Far more needs to be said in the Gorleben reports about daily routine housekeeping operations. These relate very critically to the buildup of contamination, radiation exposures of radiation workers - and members of the public and to the success of final decommissioning operations. .
'10. Health Physics Organization. Very little is said about the Gorleben Health Physics organization--its size, education, training.
and experience requirements, instruments (portable, monitors for buildings, -hot cells, cooling pond, tanks, etc. , area monitors, total body counter, etc.), types of surveys, kinds of records, and action . 11evels. It is important that detailed emergency plans be developed and that education programs be provided for personnel at all levels-of the organization. In order for the Corleben program to be suc-cessful, -health physicists must have their imput and raake their 22
. , - 's .
4 imprint at all stages of plant development--conception, design, construction, operation, maintenance and decommissioning. The Federal Republic of Germany has many very capable health physicists i in the Fachverband fur Strahlenschutz so one might expect to see
- more imput from them in the various Gorleben reports. The experi-enced Gorleben health physicists must be retained during the last three years of plant operation and be given a major role in all .
decommissioning operations. i II. Maximum Permissible Exposure Levels. There seem to be some naivety in setting the radiation standards and too much willingness to accept the antiquated levels set by the Intcrnational Commission on Radiological Protection, ICRP. For example, the internal dose values of NPC in ICRP Pub 2 were published l in 1959 while I was Chairman of the ICRP International Dose Committee and more recent data are available which have not been used in the
Gorleben reports. Also, some of the more recent ICRP recommendations should be looked at critically. For example, it is doubtful some of the countries (e.g. the U.S.) will accept the values of Wi given in 4
ICRP Pub 26 because in many cases they would result in higher values of MFC at a t$me when ICRP and many other agencies are pointing cut and emphasizing that the risk of radiation induced cancer is much greater thsn it was considered to be a decade ago and the quality factors for a-radiation and neutrons is considerably greater than it was believed'to be when ICRP Pub 2 was published. There is strong evidence that the maximum permissible body burdens of Pu and the trans- , plutonic radionuclides are too high by several orders of magnitude. Such refinements of the permissible exposure levels will result in 4 higher dose estimates during decommissioning operations than given [ -in present BPNL reports and Corleben reports and this should necis-sitate the implementation of more stringent radiation protection. I measures.
12. Reducing surface contamination. ' Surface contamination is one of
-the major problems to be faced during the decommissioning of Gorleben.
23 I _m
1
, ., i I
1 l 4 The best way to ease this problem is to prevent it. More should be j said in the reports about the kinds of surfaces (steel, aluminum, nickel, cement, tile, glass, plastic, iron, etc.) that will be
~
exposed to potential surface contamination and how this contami-nation can be prevented and removed with minimum occupational exposure. Some paints are to be preferred over others beccuse they resist surface contamination, others are chosen because they wear long and are cleaned easily while peelable paints and plastics are used frequently because techniques have been developed to re-move them quickly by remote equipment. Because of poor surface properties some materials such as tars, concrete and iron should be avoided for surfaces that are liable to be contaminated. New ideas are needed of ways to reduce the surface and near surface contami-nation that must be reckoned with at the time of decommissioning, Inner surfaces of pipes and tanks should be so treated and inclined that they will accumulate a minimum of crud, rust and scale.
13. Simplifying job of dismantlement of massive components. Some components of a reprocessing plant are difficult to reduce to small pieces during decommissioning operations so they can be disposed of in the salt disposal facility. Thick reinforced concrete walls and floors'and large waste disposal tanks can present some rather t$ough jobs; especially when their surfaces are badly contaminated.
i When concrete has to be used, holes should be provided for explosives
; when the day of decommissioning arrives. Systems should be developed i to improve the spallation of concrete by the use of heating systems.
Ways should be explored to avoid the use of thick reinforced concrete. i For example the use of double walled steel plates for hot cells with I innerspace filled with iron balls and fine sand might be examined. During decommissioning a vacuum system could be used to remove this iron. ball-sand mixture. Luygs and lif ting rings lef t on all heavy l[ .; equipment will aid in their removal with remotely operated rigs. i 14. Drawings, Plans and Records. All the original drawings and plans-
; must be retained and detailed records must be kept of.all changes ~. f in design, new construction, underground hot lines, etc. Several i
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very serious and near serious accidents have occurred at some of the reprocessing operations in the U.S. because poor records were kept of where new lines were added and what each was used for.
15. The 129I problem. It is estimated in NUREG-0278 that 1297 would be the principal contributor to annual dose, as a-result.of:
decommissioning.the reference reprocessing plant (Barnwell in this
' case). Gorleben plans to procesa and retain the 129I but histori- ,
- cally past reprocessing operations in the U.S. have experienced dif-ficulties in removing all the radioiodine. . Detailed consideration should be given to the three chemical forms of iodine-organic, in-organic and metal-organic--with special attention to the organic forms. There is another solution to.this problem--isotopic dilution. Isotopic dilution can be used as a substitute or partial solution for methods of 129I removal (filters, caustics, Ag, Cu, cryogenics, etc.). Mixing 129 I with stable, iodine (127 I) is the only known - reducing thyroid exposure from 129I that is taken
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i absolute way of into the body and it offers many practical as well as theoretical advantagas which should be considered carefully in Gorleben planning.
16. Disposal of 3H. Presumably it is planned to use deep well dis-

posal for the HTO. First of all measures should be taken to assure that all the 3H is in the oxide. form (water). It would be ideal to '
dispose of the HTO in deep wells at ihe Gorleben site but this may not be a possibility. In such case the HTO would be accumulated and shipped to a suitable site for disposal elsewhere. Shipment of radioactive water (T = 12.26y) is always a very risky business and , should be avoided because this turns out to be the major source of ! population exposure in the BPNL study of decommissioning a fuel re-i proccacing plant. One method of disposing of the HTO might be to use it in making cement blocks which could be stored in the salt formation. The formation of 3 He, OH, H 2 , 02 , etc. in the concrete blocks would not be expected to damage them appreciably over a few , half lives of the 3H. If there are large accumulations of HTO in , r storage tankt at Corleben at the time of decocmissioning, the above ' methcJs of disposal might be considered rather than shipping the HTO. - 25 '
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17. When should decommissioning begin and what are the first steps?
Plans for decommissioning should begin in the conception and design . stage of Gorleben and be continued through all other stages (construc-tion, operation, maintenance decommissioning). NUREG-0278 says the active planning and preparation stage of decommissioning should'take place during the last two years of operation of a reprocessing plant. . Because of the size of Gorleben and its dual operations'(reprocessing and waste disposal) this active and vital part of decommissioning should get under way at least three years before planned shutdown. ' The program that should be conducted during this first stage of de-commissioning depends very nuch upon which of the decommissioning paths shown in Fig. 1 are to be followed. The path in Fig. 1 to be followed must be determined by a cost benefit analysis (in reference
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to man rem and dollars). In any case some of the activities of this three year phase, just preceding plant shutdown are:
a. Assemble and train the decommissioning staff. Members of the regular operations staff are preferable to new employees although some new blood is desirable,

b. Plans and procedures are prepared.

c. Safety and safeguards analysis reports and an environmental impact evaluation are prepared.
l d. Application is made for a modified license and it is approved.
e. Quality assurance program is established.}}

ML20063N751

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