Proceedings of a congressional seminar on low-level ionizing radiation


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Proceedings of a congressional seminar on low-level ionizing radiation a report
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vii, 135 p. : ill. ; 24 cm.
United States -- Congress. -- House. -- Committee on Interior and Insular Affairs. -- Subcommittee on Energy and the Environment
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Ionizing radiation -- Congresses   ( lcsh )
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Bibliography: p. 113-124.
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Also available in electronic format.
Statement of Responsibility:
transmitted by the Subcommittee on Energy and the Environment of the Committee on Interior and Insular Affairs of the U.S. House of Representatives, Ninety-fourth Congress, second session.
General Note:
At head of title: 94th Congress, 2d sesion. Committee print.

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University of Florida
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Full Text

94th Congress COITTEE PINT
2 d Session jT





Printed for the use of the
Committee on Interior and Insular Affairs

79-7670: WASHINGTON : 1976


JAM A. .HALEY, lorida, JAr

AROLD T. E HNSON, Caliornia Mer

MORRIS U AronaAM STE A ris o
PHILLIP BURTON, California DON H. CLAUSEN, California

LLOYD D, Wyoshington KEITH G. BLIUS, Kansas

RON DE LUGO, Virgin Islands
PAUL E. TSONGAS, Massachusetts
BOB CARR, Michigan
LMs MCELVAIN, General Counsel
HENRY R. MYERS, Special Consultant on Nuclear Energy Matters
MICHAEL C. MARDEN, Minority Counsel

SM[ORRIS K. DALL, Arizona, thai ran
BR, Michln SAM STEIGER, Ariz ona
LUGO, Virgin Islan MANUEL LUJAN, JI., New Mexico
N ER, tna : STEVEN D. SYMMS, Idaho


JO PV Pensylvania

STANLEY E. ScovILLE, Staff Counslel
MICHAEL B. METZ, Minority Staff Counsel

NOTE.-The first listed minority member is counterpart to the subcommittee chairman.


uLm s, WASS. AL .N WASHINGTON, D.C. 20515
MEMER. N. JAESP. I.M)iJOwSN. C November 23, 1976
Pe N DE LA O. V.t.

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U.S. House of Representativesadia-

Washington, D.C. 20515ect widespread
interest, I am making the transcript available to all


w I~ Chairman f

C WY. A J.)A CALIF. November 3, 1976

The Honorable
James A. Haley, Chairman
Committee on Interior
and Insular Affairs
U.S. House of Representatives
Washington, D.C. 20515

Dear Mr. Chairman:

Transmitted herewith is the transcript of a symposium
organized by the House Environmental Study Conference for
the purpose of discussing the effects upon people of "low
level" ionizing radiation. People are exposed to such
radiation from both artificial and natural sources. Of
considerable concern is the extent to which radiation
produced by artificial sources is a hazard to human health.
This question has been a matter of public debate for more
than three decades. As the transcript makes clear, experts
remain in substantial disagreement with regard to the
nature of these risks.

Meetings such as those organized by the Environmental
Study Conference helpto delineate the areas of agreement
and to indicate those aspects of the problem which deserve
additional research. While the Subcommittee on Energy and
the Environment was not involved in the organization of the
conference (and views presented therein do not necessarily
reflect views of Subcommittee members) I am forwarding the
meeting record because I believe it will be exceedingly useful
to both experts in the field and to non-experts who wish to
obtain a sense of the controversy.


Morris K. all, Chairman
Subcommittee on Energy and
the Environment



Introduction . . . . vii

I. Opening Statements by Sen. Gary Hart and Dr.
Karl Morgan .. . .. .. . . . ... 1

II. Low-Level Radiation, What Is It and What Are
Its Major Sources? . . . . . . . 7

III. Health Effects of Low-Level Radiation, What Are
They and When Do They Appear? . . . . . . 9

IV. Dose-Response Relationships, Linear or Non-Linear? . 20

V. Protection of Special Groups . . . . .35

VI. Federal and State Responsibilities in Regulation,
Monitoring and Inspection . . . . . 49

VII. Current Radiation Protection Standards, Responsibility,
and Scientific Basis .. . . . . . . . 75

VIII. Health Effects of Radiation, Is the Data Base
Adequate for the Determination of Standards? What
Research Is Needed? .. . . . . . . 84

IX. Health Effects to Occupational and General Populations
Exposed to the Present Federal Standards . . . 95

X. The Cost-Benefit Theory of Federal Radiation Standards,
Is It a Proper System? What Are Alternative Systems? 101

XI. Specific Recommendations for Congressional Hearings,
Legislation or Othr Actions . . . . . 109


Selected Bibliography on Effects of Low Dose Radiation
on .n . . . . .. .. . . . . 113

Glossary of Radiation Health Terms . . . . . . . 125

Addition to the Testimony of Dr. Victor E. Archer, M.D.
from a Letter to Mr. Bruce Myles, April 1, 1976 . . . 129


Addition to the Testimony of Dr. Edward S. Martell,
Unresolved Health Effects of Internal Alpha Emitters .. .. 130

Recommendations Made to the Environmental Study Conference,
Submitted to the Record by Dr. Rosalie Bertell . . . 133

Letter Submitted to the Record by Dr. Bernard Cohen . 135

-vi -


On May 4, 1976, a panel including scientists and public
health officials presented a wide spectrum of views on the health
effects of low-level ionizing radiation during a one-day conference
aimed at informing Congressional Members and their staffs on this

The conference was organized by the Environmental Study
Conference, at that time composed of a bipartisan group of 165
House Members, and the Environmental Policy Institute, a non-
profit research center. The purpose of the meeting was to provide
insights into a question increasingly asked by the public: how
harmful to health, if at all, is the low-level ionizing radiation
from the nuclear fuel cycle, medical x-rays, and other artifical

Members of the House and Senate co-sponsoring this confer-
ence included Representatives Richard Ottinger, Gilbert Gude,
James Jeffords, and John Seiberling, and Senators Gary Hart,
Abraham Ribicoff, Edward Brooke,and Jacob Javits.

The following pages contain a transcript of the meeting,
edited and reorganized by the Congressional Research Service.


Digitized by the Internet Archive
in 2013


MAY 4, 1976


Washington, D. C.

The Conference met, pursuant to notice, at 9:35 a.m, in room
1202, Dirksen Senate Office Building, Hon. Gary Hart presiding.

Present: Senator Hart (presiding).

Senator Hart. Ladies and gentlemen, I think we are prepared
to proceed with this discussion this morning. I am sorry that my
friend Dick Ottinger, Congressman from New York, will not be able
to be with us for the opening of today's conference. However, it
is my understanding that he will be in and out throughout the day,
hopefully rather frequently. It was primarily through the coor-
dination of the Environmental Study Conference, which Congressman
Ottinger chairs, that this forum was originally originly oganized.
The conference today is the first Congressional effort in
several years to review the health effects of low-level ionizing
radiation fro nuclear power facilities, medical and dental x-rays
and other sources.

The purpose of the conference is to provide a Congressional
forum for the discussion of recent research findings which indi-
cate the need for closer scrutiny of Federal programs designed
to protect the public from radiation exposure.

The conference is co-sponsored by the Environmental Study
Conferene, a group of about 165 members of the House, Representa-
tives Ottinger, Gude, Jeffords, and Seiberling, and Senators
Ribicoff, Brooke, Javits and myself.
Our speakers represent a wide range of views on the health
effects of low-level radiation and the extent to which the pub-
lic and occupational subgroups are and will be protected from
low-level radiation.

The questions surrounding low-level ionizing radiation are
becoming increasingly salient as pressures mount for this nation

to turn to nuclear power as an answer to our energy shortage. As
this industry expands, many more citizens will be exposed to high-
er levels of radiation.

As we know, humanity has always been exposed to naturally oc-
curring background radiation. Dr. Gofman, the co-discoverer of
plutonium, has estimated that this naturally occurring radiation
causes approximately 19,000 extra cancer deaths annually, and be-
tween 58,000 and 0,000 genetic deaths per year in this country

With these figures in mind, it seems almost unbelievable that
government policies could advocate the existence of artificially
produced radiation, with its consequent cost to human life. How-
ever, this has happened, and the average American is exposed to
almost twice the radiation that occurs naturally.

We can do little about background radiation, but we can, and
must, curb that radiation produced by man. Current regulations
permit exposures of 170mrem annually. A disturbing consequence
of every individual receiving this dose could amount to about
32,000 extra cancer and leukemia deaths every year, according to
Drs. Gofman and Tamplin.

As if this exposure were not enough, employees of nuclear in-
dustries are, in my mind, incredulously exempted from those regu-
lations. They can legally receive radiation at levels thirty
times that of the general population -- an exposure which has been
calculated to increase the risk of leukemia and cancer by 5 per-
cent every year, and to significantly lower life expectancy.

Our investigations today, however, should not limit itself
to the more glamourous issue of radiation from nuclear industries,
which amounts to only a small percentage of the total threat to
human health. Radiation from medical and dental x-rays accounts
for an estimated 3,000 deaths per year from various forms of can-
cer and genetic'damage, according to the International Commission
on Radiological Protection. The Commission also estimates that we
may be introducing approximately 30,000 extra deaths into future
generations each year from genetic effects. The National Academy
of Science, the BEIR Committee, and the Medical X-ray Advisory
Committee all agree that radiation from diagnostic x-rays can be
significantly and easily reduced.

Federal regulations are intended to define the quantity of
exposure that the human body can safely accumulate. But since
any accumulation produces biological damage, these standards are
ultimately based on an arbitrary bureaucratic decision about how
many adverse health effects, a euphemism for deaths, we will put
up with -- the so-called "acceptable costs."

The hard questions are not being asked. My colleagues and I
have asked all of you to participate in this forum to address and
hopefully shed new light on these very important questions.

What are involved here are not mere statistics, but people
-- individual human lives. And it is ultimately these people, and
we as their elected representatives, who must make these hard

decisions. We must be sure that these decisions are based on the
facts, with full knowledge of the possible consequences. It is
the facts which must be aired in forums like this, and not con-
fined to the obscure publications of myriad Federal agencies.

I am confident, and I am sure my colleague, Congressman
Ottinger is confident, that this conference will mark an impor-
tant stage in the dialogue that must take place as pressures for
nuclear acceptance mount.

As for the time-table this morning, we will be meeting from
9:30 until just after 12:00 o'clock, taking a break for lunch and
continuing at 1:45 until approxiamtely 4:30, or until we have ex-
hausted the subjects at hand.

Chairing the conference will be Dr. Karl Morgan, Professor of
Health Physics at the Georgia Institute of Technology, one of the
pioneers in radiation protection.

I am now pleased to let Dr. Morgan introduce our panelists
and further explain the format.

r. Morgan. Good orning.

The panel consists of persons who are well-known in this
field and many of us have formulated opinions through the years.
I am thinking that perhaps I need a larger gavel here to cut
some of us off if we really get tangled up close in some of these

Beginning on my left, Mr. Taylor, I do not believe is here.
George Taylor is scheduled to be with us. He is the executive
secretary of AFL-CIO.

Dr. Frank Collins, consultant on occupational safety for
the Oil, Chemical and Atomic Workers on my left.

Dr. John T. Edsall, Professor Emeritus of Biology at Harvard
University, and Chairman of the VI International Conference of

Dr. Irwin Bross has been director of the biostatistics at
Roswell Park Memorial Institute for Cancer Research i Buffalo,
New York, for over 17 years.

Dr. Rosalie Bertell, research associate at the Roswell Park
Memoral Institute.

Dr. Victor Archer, who is medical director of the U.S. Pub-
ic Health Services, National Institute for Occupational Safety
and Health, Salt Lake City, Utah.

Mr. Seymour Jablon, currently associate director with the
Medical Follow-up Agency of the National Research Council, Nation-
al Academy of Sciences and staff officer for the Radiation Effects
Research Foundation. He also served previously as Chief of the
Department of Epidemiology and Statistics of the Atomic Bomb Casu-
alty Commission and is a consultant to the BEIR Report Advisory

Dr. Edward Martell, now with the National Center for Atmos-
pheric Research, Boulder, Colorado and formerly attached to the
Strategic Air Coand as an advisor on high altitude fall-out.

Dr. Victor Bond, associate director in life sciences at
Brookhaven National Laboratory, Upton, New York since 1967 and
formerly a member of the BEIR Report Advisory Committee.

Dr. Ernest Sternglass, Professor of Radiology at the Univer-
sity of Pittsburgh.

Leo Goodman is a consultant in atomic energy safety. He has
not arrived yet. (He arrived later.)

Dr. Charles Richmond is associate director of biomedical and
environmental sciences, Oak Ridge National Laboratory, Tennessee.

Dr. William Ellett, Criteria and Standards Division of the
Environmental Protection Agency, Office of Radiation Programs.

Dr. Bernard Shleien, Office of Medical Affairs of the Bureau
of Radiological Health, Food and Drug Administration. He pre-
viously spent 16 years with the Public Health Service's radiation

Dr. Mark Barnett, associate director of the Bureau of Radio-
logical Health's Division of Training and Medical Applications.

Dr. Roger Mattson, director of NRC's Division of Siting,
Health and Safeguards Standards.

Dr. Helen Caldicott, a pediatrician who for several years was
director of cystic fibrosis research at Adelaide Children's Hos-
pital, Adelaide, Australia and who is currently conducting clini-
cal research in cystic fibrosis at the Boston Clinic.

Dr. Bernard Cohen, director of the University of Pittsburgh's
Nuclear Physics Laboratory was not able to be with us. (Material
has been included in the Appendix.)

I do not see Dr. John Gofman. He is Professor Emeritus of
Biomedical Physics, University of California at Berkeley, and
Chairman of the Committee for Nuclear Responsibility. (Sickness
prevented his attendance. Material has been included in the Ap-

These are the panelists. Several have not yet arrived.
Hopefully they will be with us shortly.

I would now like to explain the procedures we are proposing
to follow. The purpose of this conference is to address the ques-
tion of low-levels of exposure to ionizing radiation, sources of
this exposure, measures to reduce and control this exposure, the
biological consequences of this exposure, the radiation protection
standards and their adequacy and research programs designed to
answer some of these questions.

The staff of the Environmental Study Confernece, of which
Congressman Ottinger is Chairman, has prepared a list of 17

questions which address this subject, and I am sure in answering
these questions, we will raise some new ones and that we will not
be expected to solve all of the issues or to provide answers to
the questions which will completely satisfy all of the proponents
and opponents of nuclear energy.

I hope, however, Senator Hart, we will clarify some of the
issues and enable members of Congress and their staff to better
understand the problems and what action, if any, should be taken
to bring about appropriate corrections.

We have a very tight schedule, and in order to stay on sche-
dule and finish by 5:00 o'clock this afternoon, I have been asked
to rigidly limit the time of each speaker to three minutes response
to any question, with the exception of question number 5, where we
will allow 5 minutes for each speaker.

I will read each question as we come to it, and call upon
members of the panel to respond in the order of their names as now
listed on our provisional agenda. Please stay within these time
limits, and at the close of the morning session and at the after-
noon session there will be fifteen minute periods for questions and
comments from the floor, and especially from members of Congress
and their staffs. And those of you in the audience, when you have
questions or responses, please state your name so that it can be
recorded on the record.

Mr. Myles has handed me a paper in which it has been requested
that a few definitions be given. While some of the audience is
assembling, maybe I can attempt a few quick definitions.

First of all LET, the linear energy transfer, in simple terms
(not as a college professor defines it), relates to the density of
ionization, to the number of ion pairs along the track, a linear
path, or a straight portion of the path of an ionizing particle.
To those of you with physics background, it is essentially the same
as stopping power or it relates to specific ionization.

It defines how thick the track of ions is. In the case of
alpha particles, as an example, in one centimeter of air, you
would probably have about ten thousand ion pairs along that track,
whereas for a beta particle or an electron you would have something
like a hundred ion pairs per centimeter of air.

For that reason the alpha particles, if they are given off in
living tissue, are much more harmful than the lower LET radiation
from beta and gamma radiation.

Then there was a question of what are daughter products. It
so happens for many of the radioactive materials, when they decay
radioactively, they decay into another radioactive daughter, may-
be a succession of daughters which are radioactive, decaying on
down until eventually you arrive at a stable product where the
half-life is very long.

Then there is the question about ionizing and nonionizing
radiation and why exclude nonionizing radiation from our discus-
sion. When I was approached to chair this meeting, that question
came to me immediately because it so happened, and I believe it is

true, that the risk of nonionizing radiat
not greater in som respects i ion.

When we speak of ionizing adiation, we n thos t s
that can tear loose the electrons from the atom wit which they
are associated leaving a plus and minus charge, i.e. the positive
ion and the negative electron.

In the case of nonionizing radiation, you are talki a t
some type of radiation that does not have enough energy per unit,
particle or photon, to bring about the separation of the electrons
from the atom. There you are speaking of something like visible
light, ultraviolet, microwave radiation, radiation, mechanical
radiation such as sonic, ultrasonic and infrasonic radiation.


Low-Level Radiation, What Is It and What Are
Its Major Sources?

r. rgan. We come now to the first question which has been
ered by the staff, namely, What is low-level ionizing radia-
tion and what are the major sources about which we should be con-
:c .- -... ....

I will attempt an answer t tthis question to lead off this

There is no agreed upon definition of low-level ionizing
radiation exposure. Rather than list all of the definitions and
take a weighted average, or be indecisive, I am going to be arbi-
trary a perhaps a bit dictatorial and define low-level radia-
tion exposure in the case of the radiation worker as that which is
likely to result in a dose that is equal to or less than the max-
imm permissible occupational dose values as recommended by the
National Council on Radiation Protection and Measurements and as
sumrized in the NRCP Report No. 39, 1971.

Thus, low-level dose for the radiation worker will be taken
as the dose which is equal to or less than 75 rems per year to
the hands, 30 rems per year to the forearms, 5 rems per year to
the whole body, gonads, lenses of the eye and red bone marrow,
15 rems per year to all other body organs.

With this as the boundary conditions of occupational expo-
sure, and one-tenth of these values as limits for non-occupa-
tional exposure and 170 millirem per year as the maximum average
for the population as a whole, we can, in the discussion that
follows indicate whether or not these levels are satisfactory or
whether they should be changed.

I would like to express the opinion at the outset that these
levels are satisfactory only so long as they are considered as
upper limits that we strive not to reach, and when we operate un-
der the philosophy that we must avoid unnecessary exposure and
keep both occupational and non-occupational exposures as low as
practicable and as low as readily achievable.

The second part of the question is What are the major sources
of low-level exposure?

The answer is given in the BEIR report as of 1972 for the
average whole body exposure in the U.S. and the values are much
the same today, namely, natural background, about 100 millirem per
year; medical and dental, 73 millirem per year: fall-out, 4 milli-
rem per year; occupational, about 0.8; nuclear power, 0.003 milli-
rem per year; and nucler power extrapolated into the year 2,000,
less than 1 millirem per year.

Do any of the panelists which to add to this definition of
low-level exposure? (There was no response.)


Now, we will take this as the boundary condition of our de-
finition. By boundary, I mean low-level s defined a tse val-
ues or any values less than these val to tese


Chapter III

Health Effects of Low-Level Radiation,
What Are They and When Do They Appear?

r. Morgan. We come to the second question that has been
sugeste e have not indicated names of those on the panel who
would like to r e n, but I welcome you to do so. I will start
out ith an attepted answer to the question -- What are the
health effects, known and suspected, of low-level ionizing radia-
tion? When do these effects show up?
My answer would be, present medical techniques are not suf-
ficiently sensitive to detect any immediate effects of these low-
level exposures. The consequence of low-level exposure is that
the perso hasa greater risk than otherwise of having a malig-
nancy, depending on the age of the person, sex, magnitude of dose,
type of radiatio, body organ radiated, kind of malignancy and so
forth. The malignancy may manifest itself in one to two years,
or after, say 50 to 80 years, and in the vast majority of cases,
a cancer resulting from radiation exposure is indistinguishable
from one originating from other causes.

Some scientists believe that exposure to ionizing radiation
results in aging or life-shortening due to non-specific effects
and hae suggested that life-shortening may be on the order of
l0- life spans per rem. This would, in the case of a 70-year
human, correspond to 2, days life-shortenipg per rem exposure of
the total body.
I think from this we recognize that epidemiological studies
of very large populations exposed to these low-levels of radia-
tion for many years would have to be conducted in order to demon-
strate effects f low-level xposure. For example, n the BEIR
hypothesis, a thousand persons exposed to 5 rem per year, to the
total body, for thirty years, would be expected to result in only
an increase of about 15 cancers above normal and an average life-
shortening if there is a non-specific life-shortening -- of
each person of a little more than one year.

Would some panelists like to respond to this?

Dr. Bertell. I would just like to point out some of the
results hidden behind the hypothesis of life-shortening, which
I think is now a viable and testable hypothesis.

Life-shortening means that the person is vulnerable to the
diseases of agi at an earlier point So I would like to in-
clude in our consideration of radiation effects such things as
diabetes mellitus, cardiovascular disease, stroke, hypertension
and even sicide, cataracts, a whole slew of things which we nor-
mally connect with aging.
Dr. Morgan. Thank you very much. Are there other comments?
Yes, Dr. Bross.

Dr. Bross. I would like to respond. I think the figures are


79-767 0 76 2

somewhat obsolete. I think tt the actual effects are substan-
tially larger. What has happened is, as we do more research we
find larger effects.

Years ago, Alice Stewart-i had found a 50 percent to 100 per-
cent increase in leukemia in the children whose mother had x-rays
of the fetus during pregnancy We found 50 percent when we first
analyzed the Tri-state survey, which is the basic source of data
that we have been using. While this was large enough to confirm
the earlier reports, it did not convince the radiologists who had
not been previously convinced. However in 1970, the Department
of Biostatistics at Roswell, looked more closely at childre who
were defined by their medical histories as "susceptibles."/ The
diseases in this included asthma, hives, eczema, allergy, pneu-
monia, dysentery and rheumatic fever.

In the susceptible children, we found a 500 percent increase
instead of a 50 percent increase. In our latest analyses, using
a procedure which is still more sensitive and gets down to the
persons who are actually affected by the radiation, we get a 5000
percent increase in leukemia.

What I think is that the previous analyses of the data have
not brought out the problem clearly. This whole matter needs to
be reconsidered.

I think the scientific evidence of cumulative genetic degra-
dation we are prepared to produce will indicate the need for sub-
stantial reduction in the currently permissible exposure levels.

Dr. Morgan. Thank you, Dr. Bross. Other comments? Dr.

Dr. Caldicott. I would just like to mention the genetic
effect on future generations. We can extrapolate from animal
experiments, but we know the human species is the most sensitive
species to radiation. We have already had radiation around, ar-
tificial radiation, for about 50 years. We know that background
radiation during the centuries has produced us because of survi-
val of the fittest, in that the mutations which have been good
have survived, the bad mutations have died. We know that the
majority of mutations occurring now are deleterious or bad, and
produce disease. We do not know the effects of low-level radia-
tion on the gonads, the testes and ovaries where the new gener-
ations are to be produced, because it will take many generations
to assess this damage, and by then it will be too late.

There are two forms of mutations or damage to genes and eggs
and sperm. One is dominant, which would be seen in the next
generation. One is recessive, and may be carried by people
through generation to generation, such as cystic fibrosis where
one in twenty of us carry this gene. This disease is a common
fatal disease of childhood. We all carry hundreds of such dele-
terious recessive mutations.

Much is unknown about the long term effect of radiation on
human beings. Time will provide the evidence, i.e., hundreds of
years; we will have to wait and see.


Dr. Morgan. Are there other comments? Mr. Jablon?

Mr. Jablon. I would just like to comment on some of the re-
marks that have been made.

The largest study that I know of involves essentially an un-
selected population, the studies of the survivors of Hiroshima
and Nagasaki. We have, of course, paid a great deal of attention
to the problem of trying to identify specific effects of rather
large doses, not small.

There has not been to date, and the studies have now been
going for thirty years, any evidence of cardiovascular disease
being affected by the acute doses.

The chronic effects have largely been in the area of cancer

Dr. Morgan. Dr. Bertell?

Dr. Bertell. I would like to respond to Mr. Jablon on the
Hiroshima data. I have looked at that quite carefully. What he
said was correct, but this is a sensitive point. He referred to
acute doses of radiation, which I believe are at least over 200
rad. I am interested, and I think this conference is interested,
in low-level effects; diabetes mellitus and cardiovascular disease
were significant at the lower levels.
There is a built-in assumption in the study on the Hiroshima
data, anything that shows up at a low level should show up worse
at a higher level. I think this is false to the biological pic-
You are dealing here, as far as I can see, with an overkill.
If the cells are destroyed, they are sloughed off from the body.
They do not continue to live within the body and produce misin-
formation and reproduce themselves within the body.
The effects at the low levels are different from the effects
at the higher level. We cannot say, because something was not
more acute at a high level, therefore it did not occur as a radia-
tion related thing.

Mr. Jablon. May I respond to that?

Dr. Morgan. Dr. Martell has asked for the floor.

Dr. Martell. In the context of the last comment, you might
let him go ahead.

Mr. Jablon. I would like to respond in two ways. First, I
would like to refer back to something Dr. Morgan said in his ini-
tial statement.

Dr. Morgan stated that the effects of low-level radiation
were certain things. I am sure he would agree that this is infer-
ential. Nobody, in fact, has ever demonstrated that cancers do
occur at the kind of low levels we are talking about today.

It seems reasonable to believe that we can extrapolate from
effects observed at high levels to what might be found at low

I see that Sister Bertell is shaking her head; no doubt she
will have something to say about that.

In any case, to assume, then, that an effect on the cardio-
vascular system will occur at low levels of radiation when it is
not observed to occur at high levels depends on something other
than human data to substantiate it, and we can all have our own
opinions about what is at work here.

Dr. Morgan. Dr. Bertell?

Dr. Bertell. There are three fuzzy ideas that go around
about radiation, first that all exposure is harmful, secondly,
that genetic damage is observable bu itt cannot be connected
specifically with certain diseases, and thirdly that there is a
nonspecific generalized effect similar to aging. This is the
kind of vague hypothesis which I tried to address by measuring
what I call the aging effect, because I do not know what else to
call it, but apparently within the human body we have a biofeed-
back system or have certain chemicals which enable us to respond
to change in our environment.

As we grow older, our responses are less perfect, or we are
less able to take care of some kinds of homeostatic adjustments.
From the measurements which I did in the Tri-state study, you can
find a comparable effect from radiation.

In other words, I am talking about something that happens
to you when you are exposed to radiation and which is comparable
to what happens to you when you live over the period of a year
exposed to natural background radiation or whatever else you are
exposed to.

I think what we are dealing with here is not a question of
exposing the whole population and noting that a few people get
cancer. What we are dealing with is the fact that everybody gets
an effect. You have some kind of an insult on the human body
that is measurable, and this happens to everybody, all groups.

Your risk of cancer, leukemia, of perhaps many other things
is increased, and that is where the chance element comes in, but
it is a secondary effect.

Some of this is clear and can be proven. It indicates a
need for further research and research along this line, because
if we do not ask the right questions, no matter now long we study
and look at the data, we are not going to get the answers out of

What I am proposing here is not that all of the questions
are answered, but that there is a new technology available. It
is viable, promising, has already given some results, and needs
to be broadened.
We need to apply this to the data available. We need to ask
better questions.

Dr. Morgan. Dr. Sternglass?
Dr. Sternglass. There is very serious concern that what we
have just heard about the possibility of a generalized aging ef-
fect that would affect heart disease has in fact happened during
the period of nuclear testing. I would like to show that on one
slide in just a minute. (See Figure 1.)
This is a plot of the disease called arteriosclerotic heart
disease, identified by the International Disease Classification
Number 420, for the period 1945 to about 1970.

It shows the mortality rate per 100,000 for the states of
New Mexico, Utah, Georgia, Texas and Illinois.

As you can see, also from the data for the U.S. average,
there was a very sharp and unexplained rise starting about '48
when this classification of disease was introduced. It sharply
rose and peaked just exactly at the time of the end of nuclear

You can see from the dots marked U.S. 410-13 that it has come
down very rapidly since then. This is now supported by animal
studies that show that animals given high doses of radiation and
cholesterol together develop a high incidence of arteriosclerotic
heart disease.
I suggest it is this kind of synergistic effect between rad-
iation and cholesterol that is totally unexpected which is some-
thing that we must absolutely look into.

The same increase and decline in heart disease we have now
seen in Europe and we have in England and Wales, in proportion to
the amount of strontium 90 deposited from north to south, just as
for New Mexico, Utah, and Georgia where we find there is an in-
creasing amount of rainfall and a proportionate increasing amount
of strontium 90 in the milk.

Until we have fully resolved this kind of a possibility, that
arteriosclerotic heart disease may be produced by a combination of
dietary chemicals and radiation, I think to go ahead with the
major reliance on nuclear energy with associated emissions of nu-
clear plants could be a disaster for our nation.
Dr. Morgan. Dr. Archer?

Dr. Archer. About the figures that Dr. Sternglass was show-
ing us; it occurred to me that this sort of situation can result
when the composition of the population is changing. A lower birth-
rate could well appear on some of the mortality charts. That in-
creases death rate and things.

Dr. Sternglass. I will commen on that.

We examine this by age group as well. Each age group shows
it independently. Furthermore cancer in Japan and heart disease
in the U.S. has come down sharply again in recent years, and the
same kind of pattern occurred in countries with very different


400 U- U
Mortolity Rote for' "I:; O
Arterlosclerotib I S
Heart Diseaose MISS UR
(420) +./^ MISSOURI
300 / (410- 13)
00 / I us
300 / U. S.
o 2 .... '
0 \




1940 45 55 6MEXIC '65 75


1940 '45 '50 *55 '60 "65 "TO "75

Figure 1

economic and socia economic factors. It is a worldwide pheno-
menon, the sudnri and sudden declines in arteriosclerotic
heart diease assciat with the onset and decline of nuclear

I do not mean by any means to claim that this proves beyond
a shadow of a t what I am saying. We are dealing with un-
known amounts of alpha emitters that may be getting into the ar-
teries. We know from animal studies and recent human studies of
women who had eed to post-operative radiation treatment
for breast tum that a number have developed arterial compli-'

This has been published in Radiology (Consequences to Radi-
ologists and Medical Specialists), recently. We know that radia-
tion is indeed able to induce arteriosclerotic heart disease in

Dr. Morgan. Dr. Bertell?

Dr. Bertell. Many of the already published radiation arti-
cles also include cerebrovascular disease. For example, in the
anky lsing spondylitis study, class D, which was not supposed to
be in any wa associated with the disease itself, had a signifi-
cantly igh rate of occurrence among the people. This disease
class D included the cerebrovascular and other circulatory dis-

The article to which I think Dr, Sternglass just referred
showed cnsequences of exposure to ionizing radiation for medi-
cal specialists and radiologists. Mortality from cancer, cardio-
vascular-renal disease, and all other causes combined were in-
creased in societies with high exposure to radiation.

This is across the board. It also occurs in Hiroshima and
Nagasaki data but primarily at the low and moderate exposure
levels, not at the high exposure levels.
Dr. Morgan. Mr. Jablon?

Mr. Jablon. For deaths from vascular lesions of the central
nervous system -- strokes, that is to say -- I do not know just
what was meant by low dose, but at the lowest range we have, which
is zero to nine rads, the mortality in Hiroshima was 74 percent
of the Japanese standard and in Nagasaki 95 percent.

So in both cases, it was lower than the Japanese national

In nejther city, is there any radiation group that signifi-
cantly differed from any other group in terms of mortality from
that cause.

For diseases of the circulatory system in Nagasaki, there
are no significant differences. In the zero to nine rads group
th mortality ratio was 93 perent of the Japanese standard; ten
to forty-nine rads, 113 percent. This is up a little bit, but
the differences were not statistical significant. In Hiroshima

also there are no differences: zero to nine rads 85 percent; ten
to forty-nine rads, 80 percent; fifty to nnety-nine rads 100 p
cent of stanf rd Japanese mortality.

I do not see any evidence in these data of any effect on the
circulatory systems.

Dr. Morgan. Dr. Bertell?
Dr. Bertell. What I am quoting i study of mortality of A-
bomb survivors by Beebe, Kato, and Land There were deaths from
allergic diseases, endocrinre system, metabolic and nutritional
diseases. Then there is a good deal of discussion, 53 deaths from
diabetes among Hiroshima males; 49 deaths from the entire sample
for 1962-66.

They go on to discuss the significance of the linear trend,
then they rule it out as radiation related because it did not oc-
cur at higher doses.
The deaths occurred primarily in the age group from 40 to 59
at the time of bombing. The increased risks of death for diabetes
mellitus, cerebrovascular disease and heart disease were striking.
That was where I took the information from: Radiation Research,
Volume 48, pages 613 to 649.
Mr. Jablon, I would like to say just one word about that.

You know that there is, I think a statistical fallacy based
on the principle, that if you give an event of low probability
enough chances to happen, it going to hpp, i appen eventually.

You are talking about a report where some twenty different
causes of death were examined. They were examined separately
for two cities and for two sexes, That multiplies the comparisons
by 4.
Now we have 80 comparisons and there are 5 age groups, which
makes it 400, and there are several different radiation exposure
groups which can be contrasted within each of the 400; not to find
some significant differences in that mass of data merely by chance
would be incredible. There would be something suspicious if it
did not happen.
Therefore, when one finds an occasional discrepancy, one has
to examine it to see if it makes any sense, whether it is consis-
tent by city, by sex, by dose or something of that sort. Other-
wise, you do not know where you are.
Dr. Bertell. I guess what I think is really remarkable about
a possible occasional discrepancy is that it also agrees with what
we found in the Tri-state data. It agrees with what was in sever-
al other studies.
I think that was a criterion which the Commission used it-
self. They said they had performed thousands of tests and the ul-
timate test would be in agreement with other bodies of data,


Dr. Morgan. Dr. Bross?

Dr. Bross. I believe hat the discussion has rather charac-
teristically gone off to the direction it eternally takes. It has
dealt with an abstract issue. But this is a public health issue
and it should be dealt with by this panel as such.

The stateet has been made that there is no evidence of hu-
man beings exposed o lowevel radiation. I would say that our
data is entirely based on diagnostic x-rays which are at this
level or lower. We are not, and let me emphasize this, we are
not extrapolating from very high levels to very low levels. We
are talking about atual data on human beings exposed. In order
to make this clear, I will say a little about where this data
comes from.

It is coming from the Tri-state data on a population base of
13 million people in designated parts of three states. Nearly
all the households with cases of leukemia during a three-year
period and a random sample of households in the same area were

The persons interviewed were asked about diagnostic expo-
sures and their exposures were validated against hospital records.
These costly and arduous procedures, including the double-blind
interview, and a first-rate staff, headed by Dr. Abraham
Lilienfeld, assured that these data are just as valid as any data
produced by animal study.

The study size is 13 million persons, not 13 mice. The re-
source that we have here was, in fact, mentioned in the BEIR
Reprt and then ignored. This information gives a clear picture
from actual data of the hazards of persons exposed to low-level
radiation. And in fact, if anyone takes the trouble to look at
the published-- I emphasize published -- literature that I now
list, there are now one dozen papers, published in quality sci-
entific journals.

We are not talking about abstract issues. We are talking
about public health issues. We are not talking about hypothe-
tical data; we are talking about real people being killed by radi-

Dr. Morgan. Dr. Bond?

Dr. Bond. Dr. Bross, I shall simply add that what data were
available at the time that the BEIR deliberations were made were
taken into account. You indicated that your material was re-
ferred to in the BEIR Committee Report -- I can easily give you
chapter and verse -- and it was taken into account in the deliber-
ations of that Committee.

I have also of your data with rpect to potential ef-
fects on unborn children. They also were taken nto account.
You have published these in the open literature, and they have
been criticized. I have the criticisms that indicate that the
data do not necessarily prove the conclusions that you drew, and
that re are other conclusin possible from the data.


Dr. Morgan. Dr. Bertell?

Dr. Bertell I would Just like to te again, we are
really dealing with opinion but hard ata, and not only th Tri-
state data, which I know I have spent five years with and feel
pretty conversant with, but also if you take a lok at the r
published data from the Hiroshima and Nagasaki and also from other
studies, you will find that much was reported at low-level as
unexplainable, and it is in there It is n the published re
ports. This effect was disregarded since it did not become worse
at higher doses.

We need to take a new look at that whole body of data which
is being quoted as supporting standards which I think are no
longer admissable.

Dr. Morgan. Mr. Jablon.

Mr. Jablon. I just wanted to say in response to some remarks
about hard data that, in fact, there re very few hard data that
are pertinent to radiation effects in man. We do not make experi-
ments on men.

Every one of the studies that has been cited has been an ob-
servational study. You look at it and try to squeeze out of the
data, the best information you can get. You never know whether
the persons who have been radiated are like other persons, or dif-
fer from them in other respects than the radiation.

I would like to say also that, on the issue of pre-natal
radiation, the Tri-state Leukemia Study, a very good study, is
far from the only study in that field. In fact, data from various
studies, including one by Dr. Lilienfeld,S/ whose name was men-
tioned, are rather contrary.

Just what the picture is there is not entirely clear.

Dr. Morgan. I think we had better go on to the next ques-
tion. Dr. Bross?

Dr. Bross. I believe there is an issue here before the group
as a whole that they should recognize. We are being challenged,
insofar as our epidgmiological studies are concerned, by persons
who not working in this line.

In the study in Japan, for example, the control was taken as
under 10 rads, and this is what we are talking about, the under 10
rad exposure.

The point I want to make is this. I have half a dozen major
epidemiological findings to my credit, not in this field alone,
but in others. If we are going to put this on the basis of who
knows more about epidemiology, a gentleman that you have heard
from or me, I think we should put our records in evidence.

Dr. Morgan. Dr. Archer?

Dr. Archer. I would like to state here that the answer to
the problem of very low levels of background radiation can only

come through epidemiological studies and studies of extremely
large populations. This approach is feasible because in our
natural state, as we live in the world, the background radia-
tion differs in different places.

These differences in background radiation, from which we
can demonstrate differences in effects, both genetically and by
cancer incidence provide the best approach. I think one of the
problems with this approach in the past has been that we have
not been measuring our background radiation properly, so we have
not been able to contrast proper groups.
May I have my first slide, please?

We have a new approach, I think, which promises to give us
some more real information at background levels of radiation.
This slide is a map of the United States with countours across
it, which are the countours of the measurement of the horizontal
component of the geomagnetic forces of the earth.

The center of the horizontal component is somewhere near the
southern end of the Hudson Bay. These are the contours of in-
creasing horizontal geomagnetic force.

The measurements are in gaimas, or gauss. The effect of
this force on background radiation, especially cosmic radiation,
is rather fundamental, because this force extends beyond the at-
mosphere for thousands of miles.

When the electrically charged particles from cosmic radia-
tion arrive, they are diverted and their paths are partially
directed by this horizontal geomagnetic field. By using this
force as our guideline and choosing our populations for compari-
son, I think there is a good chance that we can learn more about
the effects of background radiation.

Slide two, please.

This gives the frequency contours of neonatal deaths fro.
congential anomalies based on a report of Dr. Wesley in 1960.-
These contours across the United States show the highest rate in
the north eastern part, and lowest rates towards the southern
part of the nation.

Slide three, please.
This slide shows a similar geographic pattern for leukemia.
It does not correspond exactly with horizontal geomagnetic force.
lines, but it has a resemblance.

Slide four, please.

This slide shows distribution of cancer of the stomach.
Again, you can see the same contours of death rates for cancer of
the stomach which corresponds roughly to geomagnetic force lines,

Slide five, please.
This shows distribution of breast cancer. These contours

Slide 1


o, ,o o


4 coo

Slide 2


5.2 4.9 5.5 5,

5.0 4.94.7 5. 4 5.6 5 5 5.5
4.3 5.4 5.4.
5.,2 5.3 5.6

4.5 5.4 5.4 5 3

S ..
5. 7w 3's 4.5 4.7

S4.5 .2

Slide 3


I 7.5

7 167 .7 7 .0 8.2 .7 t2
S.5 7.9 7.6 '

31 7 7.2 7.


S7, .3 6.9 6.7

^ \)7
7;3i 6m9

Slide 4

11.7 12. 7"

6 1.2 s 1,61,
13. 10.1
10.3 12.4

10. 8152.59

10. 1.3 1129 12.08
8.8.5 0 1

10.5. 8.6 7.6

9 4

9.0 8.0
7 .6

Slide 5

25 30
25 .[
24 223 27
21 -24 27 273
22 27
23 25 25 2
25 21
23 24 22.20

-- -- -r- 20 19
1 21 18 20,
..19 1

are similar to te to preceding slides, especially in the east-
ern part of the U.S. The pattern is less consistent in the west-
ern states, because the West was settled ter, and many of those
persons who are dying there grew up in the East where the geomag-
netic levels (and cosmic radiation) are higher.
That is all of the slides.
Essentialyhat I a trying to point out is that in past
studies what has been measured as background radiation is mainly
gamma radiation. That does not differ very much over the nation.
In fact, the hige level of gaa radiation is in Colorado which
does not have the highest rates for congential anomalies or cancer

I think what we have been overlooking in these background
measu s are the particles. There are a lot of nuclear par-
ticulates in the cosmic radiation which have been discovered since
earlier studies were made, and these particles are the components
of coic radiation that are influenced by the geomagnetic fields.
Some of these particles are ten to over 100 times as efficient in
producing chromosome injuries as gamma rays are.

1/ Stewart, A., Webb, J. and D. Hewitt. Survey of Childhood
Malignancies. British Medical Journal. v. 1. 1958: 1495-1508.

2/ Gibson, R.Q., Graham, S., Lilienfeld, A.M., Bross, I. et al.
Leukemia in Children Exposed to Multiple Risk Factors. New
England Journal of Medicine. v. 279. Oct. 1968: 906-909.

3/ Bross, I. and N. Natarajah. Leukemia from Low-Level Radia-
tion; Identification of Susceptible Children. New England
Journal of Medicine. v. 287. July 1972: 107-110.

4/ Beebe, Kato, and Land. Study of A-bomb survivors. Radiation
Research, 1971: 613-649. (The fourth report in a series.)

5/ Dimnd, E.L., Schmer1er, H., and A.M. Lilienfeld. The Rela-
tionship of Intra-Uterine Radiation to Subsequent Mortality
and Development of Leukemia in Children. American Journal of
Epieiology. v. 97. Ma 1973: 283-313.
6/ Wesley, J.P. Backround Radiation as the Cause of Fatal Con-
genitl formations. International Journal of Radiation
Biology. v. 2. 1960:97-118.


79 0 O 63

Chapter IV
Dose-Response Relationships, Linear or Non-Linear?

Dr. Morgan. Let us go on to the next question.

Question 3: Do these effects that we are talking about in-
crease linearly with increasing dose?

I believe data suggests that the cancer risk can in a sim-
ple way be expressed by an equation such as, R, the risks, equal
a constant, C, times the accumulated dose, D to some power, N in
other words:

In the case of low LET radiation, for example, X, gamma and
beta radiation, the accumulated dose,, must be corrected for
repair of damage over time, as pointed out by Dr. Bond in which
it does appear in most cases that N is equal to or greater than
1, suggesting the greater efficiency of multiple hits.

In the case of high LET radiation, however, such as alpha
and fast neutrons, there seems to be little or no repair and best
fit curves are obtained when N is less than 1, indicating the
damage per rem is greater at lower doses.

Dr. Baum (J. Baum, Health Physics Society, Houston, Texas,
1974) and many others have shown that in the case of human ex-
posure to radium the best curve fit for cancer induction is when
N is equal to 1/2. Thus, for high LET radiations, such as those
from plutonium 239, the linear hypothesis underestimates the risk.

In a recent paper,'/ I gave five additional reasons why the
linear hypothesis as now applied is nonconservative. I might
summarize as follows:

1 Extrapolations are often made to zero of effects on
animals and man, and they are sometimes extrapolated from the
high dose descending portion of the parabolic curve where there
would be overkill.

2 Estimates are made from exposures to animals of short
life spans, and for a man (as pointed out in the BEIR Report),
out to only about twenty years. Of course, other data over the
remainder of man's life would have to increase the slopes of
these curves or the risks per rem.

3 A uniform population is usually assumed taking little
account of the age distribution and the disease patterns, as Dr.
Bross has pointed out.

4 There is cell sterilization at the higher doses and so
it is somewhat risky to extrapolate from these doses because you
would underestimate the risk at low doses.

5 I think quite important is the fact that recent data
from Drs. C.W. Mays and H. Spiess on radium 224, a bone surface

like plutonium and other actinide elements, indicate that the can-
cer risk increases with protraction of the dose. This is just the
opposite of what we have observed from low LET radiation.

In summry, I would state that it is my opinion that the
linear hypothesis is always nonconservative for high LET radia"
tions. Usually it is nonconservative for in utero exposure of
children to low or hig LET radiations, but in some cases of adult
exposure, it is probably conservative for low LET radiation.

I am sure I have provoked a lot of discussion.

Dr Morgan. Dr. Sternglass.

Dr. Sternglass. I would like to say that at the recent hear-
ings by the EPA on radiation standards for the nuclear fuel cycle
I presented evidence obtained by many people in the literature
that at the very low dose rates that we are talking about, we are
dealing predominantly with a different biological mechanism than
we are dealing with at the high dose rates.

The recent data by Dr. Petkau-/ show that as the dose rate
decreases, it takes less and less dose to break a cell membrane.
This evidence was not available at the time of the BEIR Report.

What it means is simply this, that for somatic, not gene-
tic situations, we are now faced with a whole new problem, namely
the fact that when cell me1 anes are injured as a result of
indirect chemical effects the data of Dr. Petkau both for free
membranes and his new data on micro-organisms and mice, show
clearly that the lower the dose rate is, the less it takes to
break a membrane.

As a result, one is led to a non-linear effect at low doses,
which is opposite to what we had expected in the past. In fact,
the curve of response versus dose goes up much more rapidly at
the origin to the degree that this leads to an under-estimate of
biological effects of very low doses usi g a linear extrapolation
of something like a few hundred, possibly as much as a thousand-

Now recent studies have shown that anes are involved in
the functioning of the immune system of the body. One of the
most mportant things about the immune system is that it not only
defends the bdy against viruses and bacteria, but we now know
from reent e e published in the last few years, that the
immune system also detects and controls cancer cells.

Thus, we are faced with e evidence that cell mebrane
damage is sibly the controlling one in cancer induction at low
dose rates, while at high dose rates, the controlling process
seems to be direct damage to the DNA.

This means that we now have a mechanism that we did not have
before that can explain not only the very large increases in in-
fant mortality, but also the changes in heart dsease and cancer
all over the world following the period of lear testing.
These kinds of data were simply not available before Dr.

I- $6i "": *,L 'i~w

Petkau's data and the recent studies on animals at low dose rates
became available.

I agree with the Chairman, Dr. Morgan, that we have evidence
that protracted radiation at both low and high LET in some circum-
stances may be more effective in producig thn w expe

It is precisely to this point that I wod like to adress

I would like to show, very briefly, with the help of a couple
of slides, the nature of the evidence that indicates that we have
such a problem. (See Figure 2.)

Now, this is the data of Dr. Petkau which shows very clearly
that, as you go down in dose-rate from right to left, the dose
required to break a cell mbrane declines. In fact, it takes
3,500 rads to break a membrane with a brief pulse of medical x-
rays. But it takes less than one rad to break it at one millirem
per minute.

Therefore, as one goes down towards background dose-rates, it
is more easily broken. Thi s hasnow been shown also in living
organisms by Dr. Petkau contrary to what Dr. Bond has said.

Secondly, I would like to show that a much greater than ex-
pected effect at low doses and dose-rates also has been recently
confirmed in animals studies for polonium, published by J.B. Little
and co-workers3/. (See Figure 2.) It shows at very low doses
the risk of cancer goes up very sharply near the origin, then
levels off at high doses, exactly as one would expect for a mem-
brane-type effect.

It shows that only towards higher dosage is the curvature of
the dose response curve concave upward.

If one extrapolates from the high doses, as we have in the
past and as was done in the BEIR Report, and draws a straight
line to the origin, one greatly underestimates the effect that
would occur at very small doses near zero, and this has now been
found in a number of animal studies, including that of Dr.
Sanders at Battelle-Northwest Laboratories and other animal stu-
dies. (See Figure 4.)

The fact that it can also be seen in human populations is
perhaps most strongly illustrated by the changing cancer rates in
Japan between 1920 and 1965 or '70. (See Figure 5.) Here we see
that between 1920 and 1950, during the period of enormous increases
in industrial and chemical pollution and the addition of food
additives, there was no significant rise in cancer, and that the
rise in cancer began within three to four years after Hiroshima
and the huge tests in Siberia that dropped heavy radioactive fall-
out on Japan.

Furthermore, the upper line shows what happened to the U.S.
non-white population that includes, of course, Japanese, Chinese,
Indians and Negro populations in this country. It shows an enor-
mous, sharp rise beginning a few years after the fall-out began



- :

U 10 *-

o 1


0.001 0.01 0.1

D OSE RATE (rod /min)

Data of A. Petkau, Health Physics 22,
239 (March, 1972)

Figure 2
0 ,.? . ^ ... .'.
Q T l.^ 1**"** **. ^

u (J.B. LITTLE et ol. Science
SMoy 16, 1975, Vol. 188, p.737)

. 4 0 0::
<0 /A

Tz / IL
< 20- Ol/e4

o 30- < -.



0 100 200 300

Figure 3

(C.L. SANDERS, RAD. RES. , 540,1973)

40j 4- LOG D



2 20


0 1 00 200 300 400


i, ... .*.-. . Figure 4
f. ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~~i' "^i ^'1 i.I ;^r .' *:" ..

idYi "'* ( ^W~W~ ~ ~~"E9

all ages, all sites, rate per 100,000 o
( M. Segi et al.,
Japan Cancer Society) :-.
TEST / 80 c
(NOV. 1972 ) MORTRIUM /
z / o
0 60
-- U.S.
0-7 10
0 /
O JAPAN / -20
o0 H-BOMB z
_O i00 --*^- -// (HIGH ALIITUUE) ^0
2 o 100A *4 0 %

I- -AI


SI~st NEADA 2nd
0, I I I I
1920 '30 '40 '50 '60 '70

Figure 5

to come down, with doses that were never much greater than 20 to
50 millirems per year, showing a brief decline four to five years
after the test moratorium, and rising again following.the second
increase in fall-out from the second test-series.

Furthermore I just received data from Japan, from Dr. M.
Segi in Japan, that shows that beginning in about 1970-71, cancer
rates have begun to turn around in Japan, halting their rise sud-
denly and actually beginning to drop for prostate cancer, leuke-
mia and other cancers of relatively short latency period.

In fact, I will show you the case of how dramatically one
cancer in particular rose, which medicine has been unable to treat
successfully, namely cancer of the pancreas. (See Figure 6.) It
shows that it was completely level and horizontal during the time
of the worst chemical pollution between 1930 and 1945 and then
shot up 1200 percent in a mtter of a few years.

Anyone who can say that this does not suggest the possi-
bility that we seriously underestimated the effect of very small
levels of radiation does so at the risk of disregarding public

I would like to point out what I think is sometimes not
clearly understood. I fully agree with you that at this moment
diagnostic x-rays are the source of the greatest x-ray exposure
to our population. However it now appears in the light of the
new evidence of greater effects at the very low dose rates, that
at the rates of environmental radiation, we are experiencing a
phenomenon for which we were not prepared by our studies of medi-
cal x-rays. It is suggested that because medical x-rays are given
at a very high dose rate, they may have a much smaller somatic
effect for a given dose. I would just like to illustrate this
with one slide here that I believe makes it clear how this error
came about, since we did not have any of this experimental infor-
mation until about three or four years ago. (See Figure 7.)

What I have here is a plot of the so-called critical doubling
dose in rads going from 1/1000th of a rad up to 100,000 rads as a
function of dose rate, where the dose rate is given in rads per
minute. In the middle we have about one rad per minute. For the
bomb radiation, we have about a thousand to ten thousand rads per
minute. For fall-out, we have about 1/10,000,000th of a rad per

All of our previous standard-setting and all of our medical
experience is based on the assumption that the genetic damage is
dominant and that the dose needed to double the normal incidence
is about 10 to 100 rads, and that this applied to cancer also,
Most importantly, it was assumed that this was essentially inde-
pendent of the dose rate.

However, our medical experience only extended roughly from
10-3 rads per minute up t the A-bomb radiation rate of a few
thousand rad per minute, but the portion of the curve between
10-3 and 10-7 rads per minute had remained essentially unexplored
either in human or animal studies. It was only in the last few
years that Dr. Scott and other researchers began to investigate

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what happens at the extremely low dose rates for which we had no
medical data.

What I am now suggesting on the basis of this new data is
that the cell membrane damage seems to be coming into dominance
at these low dose rates and that this could explain why we were
misled by our relatively fortunate experience with medical x-rays.
In fact, when I wrote my book in 1971, I was absolutely convinced
that linearity was the best possible choice to make for estimating
the likely effect of background radiation. But in view of these
new discoveries of membrane damage and its relation to the immune
process, I seriously question whether medical radiation is indeed
the greatest source of our biological damage, although it is cer-
tainly true that it is the greatest source of our exposure. But
it is given at a very high dose rate and this, I believe, is cru-
cial and needs much further investigation.

Certainly the fact that in Japan for 30 years between 1920
and 1950 the cancer rates did not rise throughout the period of
growing use of medical x-rays as Dr. Segi's data shows, I believe
indicates that medical diagnostic x-rays, although they are large
in dose, fortunately are not the biggest source of our cancer

Dr. Morgan. Dr. Richmond?

Dr. Richmond. I think I would like to respond to the comment
that was made by the previous speaker, Dr. Sternglass.

The public has been exposed very often to claims that there
are increases in infant mortality, of various diseases, cancer,
etc., as a result of releases of materials from nuclear facilites.

I think that the record clearly states that in every case
where this allegation has been-made, investigations followed by
responsible state or Federal agencies did not support the alle-
gations. They were all found to be false.

Dr. Sternglass. That is not the case. As a matter of fact,
Dr. Morgan was present at one of these hearings. All that could
be said was that it was not possible to decide with the particular
data in a single situation whether or not the observed rises and
declines in cancer rates and infant mortality were, in fact,
definitely associated with radioactive releases.

Dr. Morgan. Dr. Bond?

Dr. Bond. I would like to state, in response to Dr. Stern-
glass, that the data to which he referred, by Dr. Petkau were ob-
tained on non-living materials. It is difficult enough to extra-
polate from lower living materials to man, let alone from non-liv-
ing material.

With respect to his responses to Dr. Richmond, I would like
to say I have in front of me a single document.4/ It is a sum-
mary of responses to ten years of allegations that Dr. Sternglass
has made. The overall conclusions from detailed analyses of the
same data that he has used with respect to infant mortality are

that, without exception, the conclusions Dr. Sternglass has drawn
with respect to infant mortality were not supported by the data
presented by Dr. Sternglass.

Dr. Morgan. Dr, Mattson?
Dr.Mattson. Mr. Chairman, I think we should try to get back
to the agenda, and the issue at hand today. People have said sev-
eral times around the panel that the issue is a public health is-
sue. The primary oncrn of this blic health iss is the set-
ting of radiation standards to protect people.

What we ha heard in this opening dialogue is the nitty-
gritty of th scientific research It is important research, but
the daloue does not help us get directly to the question of
whetr the standards are any good.
I thought that I ought to say something on this, because this
is my job as a reulator, as a protector of public health and
safety ad one who works with standards. These are the kinds of
decisions we mak in anday out. Given the tens of thousands
of reports b eople liket reviewed by the BEIR Committee and
by o e today, how do we come to a consensus of scien-
tific opinion of h o protect people from low levels of radia-

I thin Dr. Mgan said it well at the start of this question.
There is no hard, direct evidence of a link between health effects
and low-level radiation. Despite that, radiation standards today
are set assuming that there is a direct relationship.

That is what the linear hypothesis all about. We use a
linear doseeffects dependence, that is, the same number of ef-
fects per unit of dose that is obse for high level radiation.
We continue to study that dependence. There are millions of dol-
lars of research going on in the kinetics of cancer, carcinogene-
sis And dialogue continues day by day. Even with this ongoing
research, we prudently assume such a linear relationship in the
standards that are set today.
Dr. Morgan. I would ike to take prerogative as the Chairman
to respond to the exchange of information or statements between Dr.
Sternglass and D r. Richmond.

Dr. Sternglass was orrect in his response with reference to
the Shippingport reactor. I happen to have been a member of the
Governor of Pennsylvania's Committee to look into the allegations
of Dr. ass referencing the increased incidence of ailments
in the population as a consequence of this operation.

My interpretation as one member of this committee was that
there were no data, no evidence, of statistical signifcance that
the operation of this reactor had resulted in these effects claimed
in the allegations of Dr. ternglass. But, on the other hand, the
data were so poor and the information colleced from environmental
monitoring as far as hea physics was concerned were of such poor
quality, and there were so many corrections to these data and the
biological effects, it was impossible to rule out the fact that there
may have been a relationship between environmental radiation exposure

from the Shippingport operation and an increased death rate in the

Dr. Morgan. Dr. Bond?

Dr. Bond. In 1972, two very extensive studies were made by
two groups, the United Nations Scientific Coittee o the Effect
of Atomic Radiationsand the BEIR Committee of the National Acad
emy of Sciences. It was made well-known that these studies were
going to be done, and information was solicited from all scien-
tists -- from anyone who wished to submit information.
These two groups studied the same bodies of evidence. In
some ways they came to the same conclusion; in some ways, to dif-
ferent conclusions. They studied both the genetic and somatic ef-
fects, and they took into account the various effects that have
been mentioned so far in the conversation today.

In the UN Report it was recognized what has been know for de-
cades, that radiation does produce long-term effects, such as can-
cer. It was shown that quantitatively one can draw deductions
with respect to effects in the high dose and dose rate ranges. It
was stated that the data were insufficient to allow one to extra-
polate or, more accurately, interpolate with any degree of accur-
acy to effects at low doses and those rates.

Both reports came basically to the same conclusion with re-
spect to the effects of high doses and dose rates. I will not
give the derived risk coefficiencies, since they are well-known.

The BEIR Committee did use so-called linear extrapolation to
obtain what is considered to be an upper estimate of what might
happen at low doses and dose rates. I am speaking entirely of low
LET radiation; not high LET radiation.
They did use so-called linearity, a straight line, between
effects obtained in high doses and dose rates and background ef-
fect, at zero dose.
In this group it was discussed extensively that recovery oc-
curs in all known biological systems. It was actively discussed
in the BEIR Committee Report Group, whether or not a dose rate
factor should be incorporated into the risk estimates. It was de-
cided that they should not, because, on the basis of purely human
data, one could not make a definitive statement whether dose rate
effects obtained, or did not obtain, and, in the Committee's esti-
mation, animal data were not sufficiently developed.
Since that time, a large amount of animal data has become
available, and the current discussions in the scientific community
generally are that, on the basis of animal data and not contradicted
by other data, one should in fact, introduce a dose rate factor.
This would reduce the effects predicted in the BEIR Report.
The BEIR Committee Report has been discussed extensively, and
its findings in general have held up. It is one of the best com-
pendia of radiation effects data, in my estimation.
Thank you.


Dr Martell. My comments are directed to some of the re-
'rks that Dr. Bond made regarding the inadequacy of the BEIR
Report. To keep the record straight,I tpo ou t when
the BEIR Report was prepared, no adequate consideration was given
to the role f internal emitters, particularly ernal alpha

S"ot p icle" hypothesis had not b discussed. This
hypothesis involves some rather serious implications about cancer
risks plutnum which are only now being consi d d. This
was not upon in the BEIR Report. I have raised ad-
ditional questions with respect to the cancer risks for insoluble
alpha emitting particles of moderate activity in human soft tis-
s~e. This issue has also never been discussed.

The whole question of cancer risks which are associated with
Internal ala eittrs has been averaged awa by averaging organ
burdens and alpha doses without considering the micro-distribution
of lpa emitters in soft tissue and the possible consequences.
In this connection, the real issue is whether or not a multiple
mutation process may be applicable to internal alpha emitters in
the chronic exposure case. If it is, we have seriously underesti-
mated the health effects of internal alpha emitters.
This omission extends to genetic effects as well, particular-
ly because in the BEIR Report it was assumed that internal emitters
contribute only 18 percent, uniformly, to the gentically signifi-
cant background radiation dose. Anyone who has looked at the in-
i ity ion in human organs finds that there
are wi variations for natural and artificial radioactivity. We
now fi, publications over the last several years, that pluto-
nium is present in the gonads at concentrations relatively high
for sot tissue or with a distribution that wll give rise to
even higr radia n doses to the sperm. And it has been known
for some time that for 210, in smokers, there is a much 0
higher c trtion in the sper than lsewhere in the gonads.
I suggest that internal emiters an their microdistribution in
gonads, and alpha emitters in particular in the sperm and the ova,
are a serious and almost completely neglected subject. If you
read Chapter VI of the BEIR Report, you get the impression that
only a few pe t or lessof human genetic effects are to
radiation and that the rest are somehow due to nonradioactie mu-
tagens. However, it is likely that alpha emitters and other in-
ternal radioisotopes play a very important role in accounting
for the remainder of the genetic effects in man.

Dr. Morgan. Dr. Richmond?
R I wouldli to respondto some ofthe com-
ments that wee just brought up by my colleague, Dr. Martell.
Two item, seifcally, one in refer e to our alleged lack
of knowledge or state of ignorance about non-uniform distributio~n
of plutonium and actinide elements in man. I think that this can
best be summarized by what is currently known as the hot particle
hypothesis that was submitted to several government agencies about 2

,t -,;,.- ~~ii~~l~~I -27-

years ago in the form of a petition to lower he standards for occu-
pational exposure, actually by a factor of 10, about a hundred-
I will just read to you -- there is quite a bit of literature
available on this -- some of the organizations that have studied
this question and have not been able to support the hypothesis.

This means that they have not found it scientifically valid
to support the hypothesis that there is a serious defect in the stan-
dards. Alternatively, they have condoned the current means of cal-
culating radiation standards. These include the National Radiolo-
gical Protection Board of the United Kingdom, and the Biophysical
Society of the United States.

These reports were all published or are available to the public.
The National Radiological Protection Board in the U.K. I mentioned.
There are numerous documents that have ben written and assigned to
the literature. I will not go into all of these, as there are a
great number. There have also been Federal hearings by the Environ-
mental Protection Agency held in 1974 that considered this issue.

The Medical Research Council of the United Kingdom has reviewed
the issue. The National Council on Radiation Protection in this
country has reviewed the issue. The Nuclear Regulatory Commission
has reviewed the issue. The National Academy of Sciences is current-
ly reviewing the issue.

I think a very good summary is published in the Federal Regis-
ter, Volume 41, Number 71, April 12, 1976. (See Appendix.) This
was a rejection of a hypothesis by the Nuclear Regulatory Commission.

The other issue brought up related to our lack of information,
allegedly again, on plutonium and actinides in gonad tissue. I again
refer to the time-honored mechanism of scientists that we publish in
the literature. Here is a recent article on the concentration of
plutonium and actinide elements in the gonadal tissues of man. This
is published in the Health Physics Journal. Our esteemed Chairman
has been associated with the journal for many years.

In summary, this shows that there was not a selected concentra-
tion of plutonium in gonadal tissue, including samples obtained from
people. We do understand the effects of radiation, including high
LET, highly ionizing radiation, on gonadal tissues.

Thank you.

Dr. Morgan. Thank you. Dr. Caldicott?

Dr. Caldicott. I am not so sure how we are going to set stan-
dards, or how the present standards will represent what will happen
in the future when we proceed with nuclear fission and the breeder
reactor and produce massive quantities of fission products. We know
we lack a lot of the stuff already. We know two years ago in Hanford,
Washington there was a leakage of 115,000 gallons of highly radioac-
tive waste products into the soil.

We know where it is, but we cannot stop it. It is approaching a
river -- I cannot remember the name of the river -- the Columbia river.

e know that these fission products are concentrated in the
food cycle; radioactive elements are all concentrated in the food
cycle, in milk in particular. We know that babies drink milk.
We know that 3 microcuries of plutonium deposited in the lung,
which is a small amount, over a period of one year will produce a
radiation of the total lung of 2,000 rems.

I do not think that is a low radiation, but it is a small
amount of plutonium.

This recent paper suggests that plutonium is concentrated in
the gonads compared to the lung and absorbed from the lung, not the
gut, by a factor of 2. It is concentrated in the gonads by a fac-
tor of 2.

I really do not quite understand by the standards we have now
how we are going to control and monitor this when we indulge in
breeder reactors for future generations.

Dr. Morgan. Any further comments on this question?

Dr. Richmond?

Dr. Richmond. You have raised many points. I will only stick
to the last one.

You mentioned that there is evidence that there is a concen-
tration of plutonium in the gonads relative to the lung. I happened
to write that paper, and that is not the conclusion. It is one that
you can draw from it, but the point, the conclusion, was made that
there was no selective concentration of plutonium in the gonadal tis-

It is quite interesting that the data show that there is no con-
centrating mechanism in the soft tissues. There can be a concentra-
tion in the lymphatic tissues because of the pathway by which the
plutonium gets from the lung to the regional lymph nodes. But there
is no appreciable concentration in soft tissue.

If you look at statistics of the situation, for example, some
people have looked at that particular set of data and made, I think,
wrong conclusions -- if you stop to think about it, all the material,
if inhaled, is in the lung at some time and at some later time it is
somewhere else. So the level in the lung decreases while it is in-
creasing in other tissue.

I would argue that point very seriously. That is all.

Dr. Morgan. Dr. Martell?

Dr. Martell. Thank you.

I would like to add a comment with respect to the critique of
the linear hypothesis that Dr. Karl Morgan made.

I think he has made an excellent statement to indicate why high
LET radiation, for several reasons, may involve higher effects at

79-767 0 76 4

very low levels and why it is not c ervive ere ver
low doses of radiation.

In this connection, a study that I have been carrying out, in
cooperation with two other research groups shows that insoluble
alpha emitters are resent in cigarette smokers' lungs.

And the small amount of alpha activity involved can only contri-
bute to cancer induction in smokers if a multiple mutation process
is involved. However, if a multiple mutation procss is i led,
the linear hypothesis would be seriously in error and we could have
very much higher risks fr longer exposures to very small burdens of
insoluble alpha emitting particles.

This arises from the fact that, for a multiple mutation process,
one has a self-proliferation of the singly mutated cells taking place
continuously, so that the risk of getting a second particular change
in the same cell is proportional to that number of singly tated cells
only some of which have been directly induced by radiation, but each
of which will have proliferated according to the mitotic activity of
the cells being irradiated.

As we all know, the mitotic activity is higher for cells in some
organs, and higher in the young. Therefore, the cancer risk will
increase very significantly for the chronic exposure case, and the
earlier such exposure begins, the earlier the effect and the higher
the risk.

Dr. Morgan. Dr. Bertell?

Dr. Bertell. I would just like to add here that sometimes the
phrasing of the question is misleading and I would submit that the
question: "does radiation have a linear dose effect," is too sim-
plistic for the type of thing with which we are dealing.

In the first place, there are multiple effects, and in the
second place, I think we are dealing with different biological mech-

Unless we refine the question and say: "is this particular
mechanism linear," or: "is this particular result appearing in a
linear fashion," we are obscuring the public health question.

Dr. Morgan. Thank you.

Dr. Archer?

Dr. Archer. Yes.

May I have my sixth slide, please?

I have been engaged in studying uranium miners for more than
twenty years now -- not quite that long, but when we first set Feder-
al standards for them in 1957, I drew an exposure response curve for
lung cancer with all the data we had at the time. Exposures were un-
certain, and the populations were not well defined. We made estimates
of exposures and populations, and drew some curves which I extrapo-
lated to zero dose and zero response. I suggested this be used for
setting the standard.




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It was rejected because first the points were somewhat uncer-
tain. Secondly, there was very little information down at the lower
end of the curve. In the years since then we have gathered quite a
bit of information which strengthens the lower end of the curve.

Slide seven on the screen represents some relatively new data
on people who have been exposed to radiation of alpha particles from
radon daughters in ground mines. The points with the "X" on them are
from American studies of underground uranium miners. Of the other
two sets of points, one is from Czechoslovakian uranium miners, and
the other set of points is from Swedish iron and lead mines.

There were fairly good exposure measurements for all three. This
is in the low exposure range, from zero to about 600 Working Level
Months (equal to 1000-1500 rads). You can see that the line goes up-
ward to the right into the thousands of Working Level Months.

The incidence, that is the cancer death rate for lung cancer, is
given on the left axis. The up and down marks give the standard er-
ror for each one of the points. I have drawn one line through the
points by eye. There appears to be an upward bulge near the bottom
end of the curve.

The exposure-response line is straight (linear) except that it
appears to have an upward bulge before it comes down to zero, al-
though the points are sufficiently uncertain that we cannot be com-
pletely sure of that.

Slide eight please.

We took these sets of data and analyzed them with a linear re-
gression analysis. This slide gives the curve resulting from that

One of the other things I should point out, I subtracted the
expected or background lung cancers from all the points. The numbers
of these "expected" cancers are not precise, but reasonably good.
What we are dealing with in these slides are those cancers attributed
to the exposure. The two outside lines in this slide are the 95 per-
cent confidence limits. The lower 95 percent confidence limit barely
reaches the zero point.

Since we are making the curve linear, that little bulge near the
bottom pushes the lower end of the curve up, so it looks as if the
point at which the regression line intersects the ordinate is con-
siderably above the zero point, which I am sure it cannot really do.
The bulge at the lower end of the curve may or may not be real. If
it is real, it means that at very low dose rates, alpha particles
are more efficient in producing chromosome damage than they are at
higher dose rates.

Thank you.

Dr. Morgan. Dr. Bross?

Dr. Bross. In order to be clear on a point, which is an excel-
lent one, which Dr, Bertell made: The effects I want to talk about
are the accumulated genetic degradation and the relationship, the

Slide 7



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question of linearity, with rpect to cumulative genetic damage.

We k that radiation produces minute damage points in the
delicate biochemical structure, of the genetic material of hu-
man cells. We know this very well from h n data, hat is, from
clinical studies at the kilorad level where the radiation produces
multiple damage points. This prtiular damage is immediately vis-
ible because a cell cannot reproduce effectively. As were mentioned,
multiple hits are required to block the actual reproduction. Where
you get only a few hits, which must be the case for the cells to
ei r sw up as cancer in human beings who are exposed to radia-
tion, or in he children of at person, then you have to have, in
oth cases, a genetic change.

Then you have a different situation.

Incidentally, the reason that kilorad doses are used to treat
cancer are not that they fry cells alive, but that they produce
havy genetic damage. The damage points are roughly proportional to

Howev in low lw evel radiation, you get all the damage showing
up, if you are lucky or unlucky, in the subsequent generations. Where-
asif you get into heavier damage, heavier concentration of damage,
you simply block reproduction and you do not have this effect showing
Dr. Morgan. Dr. Sternglass?

Dr. Sternglass. Briefly I would like to show why this is exact-
Swhy the leukemia rate in Japan appears to have gone up so very much.
I would like to show these slides to indicate what damage in the early
fetal stage, which we all agree is the most sensitive, can do if it
hpens drig the critical time of cell division. (See Figure 8.)
This is~taken from Dr. Segi's data on the rise of the incidence
Scancer mortality, both leukemia or cancer mortality of all types
SJapan for the 1940 to 1965 period, and this is per hundred thousand
children, age 5 to 9 years.

You can see that before the bomb, 1935 to '40, there was essen-
tially no rise, in fact possibly a slight decline, in the incidence
Sleukemia and childhood cancer mortality. This age group of five
nine-year-olds for which Dr. Segi gives the data is the one that
Dr. S art found to be most responsive to x-rays during pregnancy
in her extensive epideiological studies in England.

You can see that suddenly, within a matter of a few years, ex-
actly as we have seen in the case of diagnostic x-rays during preg-
nancy, or within about five years there is an enormous rise in can-
cer, essentially a 200 percent increase in the first two d nd a half
years beginning in 1950, When the number of low-altitude A-bomb
tests leveled off and the high-altitude H-bomb tests began, the can-
cer rates leveled off. Then, following typically on the order of
five to six years after the second test series, there was another
peak, and the latest data show that the cancer rate has begun to come
down again, which is exactly what you would expect.


for 5- 9 Yr. old males
in oil of Japan
0 ( From M. Segi et al., Japan Cancer Society)
S7 (277CASES)- 600 %
0 2 nd
z H..

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W 5 -400 -J

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0 I I I,
1940 '50 '60 '70

Figure 8

This, therefore, is one way to show why we have so underesti-
mated the effects of fall-out, because the exposure happens during
the earliest times, during the time when the fetus is most sensitive.

But not only does cancer increase, but there have been changes
also in the ability to fight infections, which radiation is known to
be able to affect. (See Figure 9.)

I am showing here a plot of pneumonia and influenza mortality
in the U.S., again for infants who received radiation in the fetal

We can see here for the entire period 1940 to 1975 first the
sharp drop up until 1945 to 1950 and then a levelling off of mor-
tality rates, actually rising again during the time of greatest fall-
out in 1956-57.

Finally, a renewed drop in mortality rates took place after the
end of testing that has now begun to approach what one would have ex-
pected if there had not been a period during which the fetus was ex-
posed to enormous amounts of internal isotopes.

We are dealing here with a total number on the order of 9,000
to 10,000 infants per year during the 50's. This is clearly not a
small statistical change. The rate is now dropping down again, so
it had not reached its lowest possible level during the 50's.

One could not say that our penicillin and our drugs had done
all they could. In fact, during the last few years, the pneumonia
and influenza rate has resumed its rapid decline.

SThis suggests that the most serious effect of low-level radia-
tion in terms of total numbers is not the induction of cancer, but
really the effects on the immune system of the human body.


8 6

MORTALITY (0- yr.)
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D < U.S.-U.S.S.R. TEST
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Figure 9

1/ Morgan, Karl Z. Suggested red of permissible exposure to
plutonium and other transuranium elements. American Industrial
S ociation Journal, v 36t 975: 567-575.

2/ Petkau, A. Effect of 22Na on a Phospholipid Membrane. Health
Physics, v. 22, March 1972: 239-244.

3/ Uitle, J., et al. Lung Cancer Iu in Hmters by Low
Doses of Alpha Radiation From um-210. Science, v. 8,
May 16, 1975: 737-738.

4/ Yulish, Charles B, et. al. Low Level Radiation: A Summary of
Responses to Ten Years of Allegations by Ernest Sternglass in
Proceedings of the Fifth Intertional Conference on Science and
Society. Herceg-Novi, Yugoslavia. Charles Yulish Assoc. New
York. July 9, 1973.

5/ United Nations Scientific Committee on the Effect of Atomic Rad-
iation. Report to the General Assembly: Ionizing Radiation:
Levels and Effects. Vols, I and II. New York. United Nations
Publications. 1972. (E 72-IX-17).

6/ Radford, E.P. and E.A. Martell, "Polonium-210: lead-210 ratios
as an index of residence times of insoluble particles times from
cigarette smoke in bronchial epithelium", Proceedings of the
Fourth International Symosium on Inhaled Particles and Vapours,
Edinburgh, 22-26 September 1975, Pergamon Press, Ltd., and
Martell, E.A., "Tobacco radioactivity and cancer in smokers",
American Scientist, 63, 404-412, July-August 1975.

~~* ""^

*l Ii

Chapter V
Protection of Special Groups

Dr. Morgan. Going on to question four, What are the various
subgroups besides the general population whose exposure to radia-
tion deserves a special attention, such as uranium miners, workers
at operating reactors, repiocessing plants, etc.?

Dr. Caldicott?

Dr. Caldicott. I would like to point out as a pediatrician
that there are sections of the community who are far more sensi-
tive to the radiation than others and to these individuals you
cannot apply the linear hypothesis necessary. Infants are 11
times more susceptible to radiation than adults. Older children
are four times more sensitive to radiation.

Children who have asthma between the ages of one to four
have 3.7 times the risk of developing leukemia from radiation.
Children who have allergic disease and who have had inter-uter-
ine x-ray exposure have 24.6 times the chance of developing leu-

The reason that children and fetuses are so susceptible to
radiation is because the cells are rapidly dividing, and it is
these rapidly dividing cells that are sensitive to radiation.
Extrapolating from this, the fetus in the first three months is
the most sensitive organism in the human life cycle to radiation
because all of the organs of the human being are being formed in
the first three months of gestation.

There are several effects that can occur from radiation
during this period. There can be damage to the developing or-
gans. There can be congenital heart disease or various congen-
ital deformities.

This is caused by somatic mutation or mutation in the de-
veloping cell that is formed in that particular organ.

The fetus can be damaged by a mutation within its gonads,
the testes or the ovary, which therefore transmits this mutation
to future generations. There can be damage from another point of
view, from a carcinogenic point of view, in that one of its cells
may be damaged and the regulator gene that controls the rate at
which that cell divides is damaged and the cell may divide.
Hence, the fetus is extremely sensitive to radiation.
Dr. Morgan. Dr. Bond?
Dr. Bond. I certainly agree with what has been said. This
has been recognized for a number of years. It is taken into ac-
count very extensively in the BEIR Committee Report and by other
groups that have to do with setting of standards. Physicians and
others are admonished to keep radiation exposure to the fetus to a
minimum, and actually the exposure standards for the fetus con-
tained in the mother who is a radiation worker are more restric-
tive than for the adults.

Dr. Ellett. Is that true? I thought that this was not true,

Dr. Bond. It is a recommendation -- it is a firm recommenda-
tion of the NCRP.

Dr. Ellett. The NRC did not change the recommendation.

Dr. Morgan. Please speak into the microphone.

Dr. Bond. Let me say that the recommended standards apply to
the fetus, which of course, of necessity, applies to the mother.

Dr. Morgan. Dr. Ellett, did you wish to comment?

Dr. Ellett. Yes.

We will get into this later, but it might help to clear
things up a little bit now.

When we say standards, we have to be careful about what we
mean. Dr. Bond referred to recommendations from the NCRP. These
are recommendations, not standards. They have not been implemen-
ted by standard-setting agencies, that is as far as I know.

Let us be careful today, because we are dealing essentially
with a lay audience. In referring to a recommendation by NCRP --
let us say "recommendation." When we say "standard," let us re-
fer to something that is law, i.e. legally binding.

This is, in a sense, a governmental hearing to see how infor-
mation can be used by the Congress. I would not like them to have
a false impression that things exist that do not exist.

Dr. Morgan. Dr. Mattson?

Dr. Mattson. Dr. Morgan, one brief comment.

Dr. E.lett properly said that the ICRP and the NCRP have made
recommendations regarding the dose to the fetus being limited to
some lower number than the occupational exposure limits for adults,
since the increased radio-sensitivity of children which we are dis-
cussing here today has been pretty well accepted by radio-biolo-
gists for some years now.

Present Federal radiation standards do not now contain such
a provision. Such a provision was recommended by the Atomic Ener-
gy Commission in January, 1975. It was put out for public comment
at that time.

In following through on that recommendation, the people I
work for have issued a guide to females employed in the nuclear
industry, the people that we license, telling them of this in-
creased radio-sensitivity of the fetus should they become pregnant
and advising them of the actions that are available to them under
You can well imagine that there are other competing interests
in this nation with respect to discrimination in employment of

women, if there were different radiation standards, and with re-
spect to invasion of privacy. There are several points of law
that act very strongly in this field, one being the Supreme Court
decision on abortion; the other being Title VII of the Civil Rights
Act of 1964.

Thank you.

Dr. Morgan. Thank you, Dr. Mattson. Dr. Archer?

Dr. Archer. I think we can summarize these special subgroups
exposed to radiation fairly quickly.
If we skip the entire population, who are exposed to back-
ground radiation, ignore the exposure of everybody to radiation
from nuclear reactors and a little bit of nuclear fall-out, we can
summarize occupational exposures quickly.

There are a number of occupational groups who are exposed to
radiation, and in the past, there have been considerable numbers
of over-exposures. These were mostly among medical radiologists,
x-ray technicians, dentists, and dental technicians. There have
been a number of studies showing excess cancer amongthese groups.

But, with the advent of modern radiation protection tech-
niques and controls, it is my feeling that few of them are being
really overexposed any more. Uranium miners are another group
that has been overexposed in the past; we now have an exposure
standard for them which gives them substantial protection. I am
not at all sure that the mine operators can reduce exposure much
more than they have done.

There is still some risk for uranium miners, I think, just
as there is some risk in all radiation exposure.

Luminescent dial painters are another exposed group. They
formerly used radium for painting dials on watches, clocks, etc.
and developed many bone cancers as a result. Introduction of good
handling techniques and a switch to tritium has eliminated this

In the practice of medicine in the past, some patients have
been overexposed to radiation. The most noted ones are those who
were injected with solutions of radium or thorium for various rea-
sons. Thorotrast (containing thorium) was used as a medium for
x-ray contrast. Those radioactive substances are not being used
anymore. However, there are some physicians, especially dermatol-
ogists, who use x-rays to treat some nonmalignant diseases. Such
treatment sometimes results in worse disease than the patient ori-
ginally had.

It seems to me that this overexposure is unnecessary. In
the past, some patients, like tuberculosis patients with gastro-
intestinal symptoms, have received overexposure to x-rays. There
is little overexposure now of tuberculosis patients. For some
types of gastrointestinal symptoms, it is still standard to order
a gastrointestinal series of x-rays periodically. That has be-
come unnecessary now in many cases because there are better tech-


niques for investgating disorders of the esophagus, stomach, duo-
denum and colon. I am referring to the flexible fibieroptic endo
scopes. Workers in plants reprocessing uranium fuel are about the
only persons in the nuclear industry who are likely to be current-
ly overexposed.

Dr. Morgan. For the record, Dr. Archer, I wonder if you
would indicate to us how many casesof carcinoma among uranium mi-
ners have occurred?

Dr. Archer. I can tell you about our study group of uranium
miners./ We do not know how many uranium miners there are. We
have estimated that there have been somewhere between 15,000 and
20,000. We have about 4,000 of them in our study group.

In the study group, there have now been 170 lung cancers.
Over half of those are of the small-cell undifferentiated type.
This type is much more frequent among uranium miners than other

Mr. Goodman. I would like to ask if any studies are being
made of the populations in the vicinity of the mill tailings?

Dr. Burr. Offhand, I do not know of any.

Mr. Goodman. May I recommend such?

Dr. Burr. You may. We have had studies in some of the high
background areas in South America. We have not been able to do
studies in comparable areas in India. India has been doing studies

Mr. Goodman. If we may return to the United States --

Dr. Burr. We are continuing studies of uranium miners, I
did not mention this.

This work now is devoted more towards studies of sputum cy-

Mr. Goodman. Some fifteen years ago, Schubert and Lapp re-
ported in their book some 5,000 low-level plutonium exposures at

Is anything being done, epidemiologically, about those work-

Dr. Burr. The Transuranium Registry involves the plutonium
workers. This is the study that has been going on a number of
years and is a follow-up study, and does involve the Hanford work-

I mentioned that more recently we have initiated, at the Los
Alamos Laboratory, an epidemiological study of the plutonium work-
ers that will be more extensive.

The answer to your question is yes.

Dr. Morgan. Are there any further questions?

Ii. "* ~ \I

Thank you very much.

Was there anybody else from ERDA?

Dr. Burr. May I say a word? We have not had studies of pop-
ulations in the vicinity of mil tail ings. We have certainly had
a lot of work assessing the various mill tailing sites and there
has been a study at Grand Junction --

Mr. Goodman. I made recommendations about that in '65 that
were totally ignored.

Dr. Ellett. The Registry has come up several times today. I
understand the participation in this is voluntary. I have no idea
what kind of voluntary compliance you have with this. Is it 10
percent of the workers involved, or 1 percent?

The figures I saw were quite low.

Dr. Burr. I would like to pass that question on to Dr. Marks.
Would you come to the microphone and comment on this matter, Dr.

I introduced him before as a pathologist. He is also the co-
ordinator for our Human Studies.

Dr. Marks. The level of participation varies, greatly from
one facility to another. The representation is very high in the
Hanford plant and lower at other plants.

Dr. Ellett. Could you give us the number, sir?

Dr. Marks. At Hanford, of 2367 employees identified as trans-
uranium workers, the Registry obtained releases for access to the
employees' health physics and medical records on 2174.

They have obtained agreements from 525 of that number in ad-
vance of their deaths to have autopsies performed on them at death.
The problem with autopsy permissions is that this is a very sensi-
tive subject and necessarily voluntary. Many people have a pre-
judice against making arrangements in advance to have autopsies
performed after their deaths.

At Los Alamos, health physics and medical record releases
have been obtained for 259 workers, and autopsy permits obtained
on about half of those.

At Rocky Flats, 1772 transuranium workers are identified.
There are record releases on 1611 of those and advance autopsy
agreements on 173.

Dr. Ellett. Could you give us Savannah River?

Dr. Marks. Savannah River formerly were not participating
in the program. The Savannah River plant is now an active parti-
cipant in the Registry, but we do not have figures on the current
status of enrollment of the plant employees in the Registry.
Does that answer your question?


Dr. Morgan. Thank you. Dr. Bross, I believe perhaps you
could direct most of your responseto the special groups where
there are concurrent insults and the effects that may suggest
some synergism between these relationships?
Dr. Bross. I think that all of us are exposed to x-rays
or other radiation from various sources. I think the problem
is cumulative genetic degradation rather than a single exposure
-- as that you have mentioned.

The problem is really more difficult than is recognized be-
cause in addition to people who are obviously exposed there are
other groups in the population that have unusually high risk.
For example, patients who go to a physician who practices defen-
sive medicine and uses x-rays against malpractice. Or young wo-
men under 50 who have enrolled in a radiological surveillance
program which is intended to reduce the deaths from breast can-
cer, but (in this group under 50) may have just the opposite ef-

Then there are patients who go from one doctor to another
with obscure maladies and get a whole new series every time, be-
cause there is very little provision for transfer of information,
and so on. These are groups which are difficult to protect un-
less you deal with the whole problem of controlling the sources
of radiation that are being given to the population. To con-
clude, I would just like to mention one problem: It is so easy
to overlook one group of risks when you are concerned with an-

We haldtalked here about the protection of pregnant women
in the NRC proposals. For the benefit of the group, there are
instructions to the persons who are in a managerial capacity to,
essentially, give a warning. The statement concludes that you
have to take risks. You should protect yourself against this,
just as you should not smoke, nor climb stairs during pregnancy.

In focusing on pregnant women, for example, the directive
ignores the fact that women who are not pregnant can also be ex-
posed to radiation. They will also have, in their children, a
markedly increased risk of leukemia. There is also, of course,
the question of whether the pregnancies are known or not.

The problem is not as simple as it might look, and it real-
ly requires some persons or groups who would have a direct mis-
sion for this purpose.

Dr. Morgan. Dr. Shleien?
Dr. Shleien. Just some comments on what has been said in
the last few moments, in an attempt to distill some of the
thoughts in the statements.

Everyne is in agreement that unnecessary radiation should
certainly be avoided. In speaking about particular groups that
have been mentioned, the Bureau of Radiological Health of the
FDA is carrying out some investigations relative to those you
have mentioned.


79-767 0-76-5

For example, the treatment of benign diseases with radia-
tion, a practice which has been decreasing, is now under invest-
igation, under contract with the Bureau at the Nation Academy of

The problem of mammography screening has also come to the
attention of the Bureau of Radiological Health, and its Medical
Radiation Advisory Committee has issued recommendations with
which we generally are in agreement.

Dr. Morgan. Would you state the recommendations for the
record, please?

Dr. Shleien. The recommendations are:

"Women of all ages should receive annual physical
examinations of the breast and be taught breast
self-examination. For asymptomatic women the
first, or baseline, mammographic examination
should be performed between the ages of 35 and 40.
A second mammographic examination should be per-
formed in 3 to 5 years unless indications of in-
creased natural breast cancer risk for an indivi-
dual warrant more frequent examinations. Subse-
quent mammographic examination of women who re-
main asymptomatic should depend upon reevaluation
of the patient's personal risk status, the current
understanding about the efficacy of mammography,
and evaluation of radiation risks. After age 50,
annual or other regular-interval mammographic ex-
aminations should be performed."

Dr. Bross. May I say one thing on that?

I agree with the recommendations, but the programs are not
operating this way.

Dr. Shleien. I do not understand that.

Dr. Bross. The NCI, the National Cancer Institute, has
screening programs that do not operate according to those guide-

Dr. Morgan. Dr. Caldicott?

Dr. Caldicott. Being a clinician, I feel that we do prac-
tice defensive medicine and that we take x-rays in case we might
be sued sometimes; we take x-rays without thinking of performing,
sometimes, an adequate clinical examination and x-rays are not
monitored as to dose, particularly in the pediatric field. Some
children have packets and packets of x-rays, dose of x-ray and
radiation on each x-ray is not recorded and therefore we do not
know the amount of radiation that these children have had.

I think this is very important, not only may it be a risk
for those children later -- later in life. You must not forget
it takes from five to fifty or forty-five years for a cancer to
develop. Those children may live long enough to develop their

It may also affect those children's gonads, once again, the
testes and the ovaries.
The fact that was pointed out about fertile women in indus-
try also applies to fertile men in industry. I have here a paper
on thirty autopsies that were performed by the U.S. Transuranium
Registry. This is a registry that registers all men -- I guess
they are mostly men who have worked in the transuranium industry
for the last 30 years, 20,000 workers. This is the first report
of the first 30 autopsies of these people.

Eleven out of thirty died of cancer, which is an incidence
of 37 percent. The normal incidence in the population of cancer
in n autopsy population is 17 percent.

Three others died of suicide, and two of suspected suicide,
and almost all the rest died of arteriosclerosis of some form or
another and Dr. Martell has reported that arteriosclerosis may
be related to the deposition of alpha emitting particles within
the blood vessels.

This is hard data that actually workers in the transuranium
industry are dying from results of radiation.

Dr. Morgan. Could this report of these toxic cases be pro-
vided for the record?

Dr. Caldicott. Yes.

Dr. Morgan. Dr. Archer?

Dr. Archer. I have read that report which just has been
mentioned, and as an epidemiologist, I felt I could not make any-
thing out of it without knowing the age distribution of the pop-
ulation that one is dealing with. You cannot very well say what
the ratio between cancer and other diseases should be, even what
the causes of death might be, unless one knows the age distribu-
tion of the group.

Dr. Morgan. Dr. Richmond?

Dr, Richmond. I would like to suggest that perhaps some of
that information may be made available for the record of the
hearing, because that is not, as I recall, the conclusion of the

Dr. Caldicott. We do have the age distribution.
Dr. Archer. Pardon me, perhaps I did not make my point
clear. One has to know the distribution of the population from
which the deaths are drawn, not just the ages of the persons who

Dr. Richmond. I would like to make a general comment, too.
We may be missing our responsibility to convey basic information
to the audience.

We have a very varied, I am sure, group of people here. One,


I think we have to be very careful to state, where we are talking
about generalizations. We have been talking about the effects of
radiation on the developing embryo. This has been taught in reg
ular biology classes, general classes, for decades, It is coon

It is also common knowledge that the same biological causes
for the increased sensitivity also make the developing embryo
sensitive to many biological insulting agents.

It is not unique to radiation, I would like to make that
point clear.

Two additional points: One, we have been awre of this. It
is factored into the standards. It is a generalization, a biolog-
ical generalization.

I would also like to call attention to the fact that we
should not overlook the obvious, that is, if you are born today,
your lifespan is decades longer than people who were born earlier
in this century. Also, the statistics are at hand to show that
there have been dramatic changes for the better in infant mortal-

I suggest we do not cloud the issues with too many techni-
cal details and avoid the obvious things, that we have to be sure
the public understands.

Dr. Morgan. Mr. Barnett?

Mr. Barnett. Since we are still talking about population
groups which need extra protection because of extreme vulnerabil-
ity to radiation, we should not exclude the embryo and the fetus.

In this connection, our Bureau has a project at the Massa-
chusetts General Hospital which is testing the feasibility and
effectiveness of requiring that referral slips for abdominal
x-ray examinations of young women indicate the pregnancy status
of the patient. It will be interesting to see if this pilot stu-
dy results in a lower number of these examinations being ordered,
and perhaps an increase in the number of pregnancy tests as well.

One more comment on this type of protection. We feel it is
very important to educate the patient to volunteer information
about pregnancy to the clinician. One of the most important
things the patient can tell the physican is, "Doctor, I think I
may be pregnant." This will affect his decisions, not only
about the ordering of x-ray examinations, but also drugs that
may affect the fetus as well.

Dr. Morgan. Dr. Bertell?

Dr. Bertell. There are several things that have been inti-
mated, for example that some of the problems of the past are no
longer with us, and one of these problems is the radium dial
painters. In a booklet from the Bureau of Radiological Health,
it is estimated that these dial workers receive 12.1 rads per
year -- external, whole body dose of radiation.2/


It was a trgc situati. Yet, if you look at the present
regulations for workers in the industry~, while they are generally
under 5 rad, there are exceptions they can go to as much
as 12 rad a year. It is permitted under certain uating cir-

I would just point out that this 12 rad permitted, on occa-
sion for nuclear workers is exactly t s exposure which was
so tragic in the radium dial workers.

Dr. Ellett. Could you straighten us out on the difference
between rads and rems? The radium workers were getting some-
thing like 12 reins, or 12 rads?

Dr. Morgan. I am not sure what the estimate of rad or rem
was to radium workers. I think it was in the neighborhood of 12
rem per year.

Dr. Bertell. Yes, for external gamma radiation, the rad and
rem are essentially the same. It is the external radiation in
the nuclear industry, which can go up to 12 rad, that is compar-
able to the 12 rem the radium dial workers received.

Dr. Ellett. The radium worker with internal alpha?

Dr. Bertell. Rem-wise it is the same, 12 rem.

Dr. Ellett. I thought doses for radium workers were in
terms of rem, were largely the same as at the start of their ex-
posure, and 12 rad radium alpha is 120 rem, not 12 rem.

Dr. Morgan. Mr. Jablon had a comment in reference to the
BEIR Report.

Mr. Jablon. There seems to be some question about just what
the effective doses were in the radium dial painters, and the
BEIR Report quotes Rowland's studies as follows: "No sarcomas or
carcinomas have been seen below the total accumulated bone
dose of 500 rads,"_3/ and I would remind you that for an alpha em-
itter, 500 rads would be the equivalent of 5000 rems.

Dr. Bertell. For the sake of clearing the record, concern-
ing our previous discussion of the radium dial workers, I would
like to point out that my first statement referred to a yearly
exposure and I compared it to a yearly exposure of a worker in a
nuclear plant.

I think whn r. Jaln responded, he talked in terms of a
cumulative dose ver a n r of years, and I think it should be
very clear that we were talking about two different measures.
Dr. Morgan. Are there any other comments? Dr. Sternglass?

Dr. Sternglass. I would like to add that it is widely be-
lieved that only a fraction of a millirem is the dose to the pub-
lic from nuclear plants, I have here in front of me the New York
State Health Department report entitled, "Environmental Radiation
Effects of Nuclear Facilities in New York State,"4/ in which, for


Indian Point Station, Unit 1, the annual average dose in milli-
rens, due to halogens and particulates alone for 1972 is given at
62 millirems at the boundary, and there are many other plants
that have levels on the order of 10, to 20, to 30 to 50 millirems,
just due to the halogens alone.
Therefore, we cannot assume safely that when the plants are
such that everybody will be living within 50 or 60 miles of two
of them that the doses will be a tiny fraction of a millirem.

Dr. Morgan. We will take questions from the audience. Please
identify yourself, if you wish to make a comment.

Mr. Kepford. I am Chauncy Kepford. I live in York, Pennsyl-

It has been stated there have not been controlled human ex-
periments with controlled radiation exposure. I disagree. There
are thousands of workers who have worked in the plutonium indus-
try. There was an entire division of U.S. Army troops that
marched off across radioactive ground immediately after an atom
bomb test in 1954 or '55.

Where are the health records of all these people?

Have they been followed up?

In the industry today, if one looks at the old Atomic Energy
Commission Reports of worker exposure, at least numbers 1, 2, 4,
5, and 6, the years 1968 through 1973, one finds a radically in-
creasing incidence of worker exposure and overexposure to radia-
tion. That is about 5 rem per year.

My question is, where are these follow-ups? The fact that
we have film badges that record exposure is one thing. Unless
the health data of these people that have been exposed to radia-
tion are followed, there seems to be very little need whatsoever
to record their exposure in the first place.

Dr. Morgan. Dr. Burr, perhaps you would give a very quick

Dr. Burr. I would just comment that we do have studies of
the health and mortality of workers. I will touch on this later
when I talk about some of the programs that ERDA has. We have
tried to take advantage of the information that is available.

There are other studies among which the Transuranium Regis-
try has been mentioned. This is a follow-up of plutonium workers.
I will touch on that briefly, too.

That is probably sufficient for now.

Dr. Morgan. Dr. Bertell?

Dr. Bertell. Maybe Dr. Burr could answer this. If you are
not collecting data on chronic diseases, what do you expect to
see when you analyze the data on exposure? Is there any place at


all in industry where the medical record of the employee shows
the medical history of offspring, so that, should there be gene-
tic damage which shows up in the offspring, it will be noted? Is
any industry recording this so that it can be analyzed?

Dr. Burr. To take your second question first, I do not be-
lieve so. There are, of course, genetic studies associated with
the studies in Japan, and these include studies of the F-1 gener-
ation, but to my knowledge I am not sure there is anything that
would be comparable to what you have in mind.

The first question was on chronic diseases. Some informa-
tion of this nature is obtainable from the health and mortality
studies. I do not say it is available in an analyzed form at the
present time.

Dr. Morgan. Yes Ma'am?
Ms. Villastrigo. My name is Villastrigo. I am with the Wo-
men's Strike for Peace. Dr. Caldicott made a very important
statement here that I think the panel should deal with a little
bit more carefully in the next few hours. She said we are enter-
ing into a plutonium economy that has only just begun.

One of the problems with the plutonium economy that has not
been dealt with is in areas where weapons production is going on
today in many parts of the country. People around those areas
are being exposed to radiation, including the testing areas like
Nevada. I would particularly point to the Rocky Flats area where
many people have been recently exposed to the very plutonium
economy we are talking about.

Rodger Rappaport in his book, "The Great American Bomb Ma-
chine," published some time ago, has dealt with this issue of the
weapons producing areas where is absolutely dangerous to live
because of low level radiation.

I would like to know whether any studies have been made with
regard to the people who live in those areas and the levels of
radiation that those people are being exposed to and whether we
can ever get any kind of information about that?
Dr. Morgan. Does the panel care to respond?

Dr. Ellett. I will respond in part.
EPA is doing a special study for Rocky Flats, looking at
plutonium samples. They are also looking very carefully at cat-
tle who are slaughtered. They feel that cattle will have much
higher doses that people since they are putting their breathing
apparatus much closer to the ground. We hope from this study to
get some kind of information that is based on more than data on
the air around Rocky Flats and find what is getting into humans
and animals in that area.

Dr. Morgan. The gentleman in the yellow coat?
Mr. Swann. My ame is Mark Swann. I live near some nuclear


plants in Pennsylvania.

I am wondering whether it is feasible to have small epide-
miological studies made around individual plant sitings. It seems
that we would not be involved with large programs and in the
event of accidents, small accidents, I am assuming, we would be
able to measure where w started from.

It seems to me if we spend money on trying to figure out the
mechanism of the radiation injuries and the damage we will just
waste time, and we should try to find out what kinds of things
are happening.

I assume you would have to have a test area also.

Would it be fair to have the cost of such a program at least
shared by the nuclear interest who, after all, are making money
out of the enterprise?

I would like Dr. Bross to answer.

Dr. Morgan. We have on our panel some of the country's lead-
ing epidemiologists. I will give only one of you an opportunity
to respond.

Dr. Bross. This is a feasible study and we have tried re-
peatedly to set it up in one place or another, including York and
other places.

There is a great interest in talking about these things.
When it comes to doing them, and more particularly funding them,
there is a sudden diminishment of this kind of interest.

You have heard of the very large sums of money that are go-
ing into a reactor program, breeder reactor program, and other
programs including high energy physics programs. For a very small
amount of that money you could run one of these health surveil-
lance systems, but nobody is interested.

Dr. Morgan. Dr. Collins, representing the labor union, I
would like to call on him to make a statement.

Dr. Collins. We have been hearing a lot about cost benefits.
We have radiation standards for workers which are considerably
higher than for the general public.

As I sit here today, I have a feeling of disquiet at 5 rem
per year upper limit. The members of the Oil, Chemical and Atom-
ic Workers, many of them workers in the nuclear fuel cycle, have
also a feeling of disquiet which they have made evident to us.

The National Resources Defense Council last September filed
a petition that the occupational exposure limit be reduced by
tenfold to .5 of a rem per year for workers under 45 years of age.
At that time, our union supported their petition.

At the present time, I would like to reiterate the position
of our union that the limit for whole body radiation should be set


by NRC at 0.5 of a rem in any year, 0. of a r in any quarter,
and (age 8)x.5 for a long tie cc lation.

The National Council for Radlo ic P rection, in noting
the enorus susceptibility of pregnant o to radiation, re-
commended that only half of 1 rem in any year be given to a preg-
nant woman.

Of co e, u present stadas she may very well receive
considerably more than that before she even knows she is pregnant.
At that time, the proposal to extend the N recomndation for
pregnant females, the NRC expressed it was unwilling to make a
special case or pregnant women on the grounds that it would be
sex discrimination, the right to privacy and depriving them of
the right to work.
The proposal, is that we extend the standard for pregnant
n to all workers. We agree with NRC that in terms of admin-
istering a plant, it uld be very difficult to make a special
case for one particular class of workers. The reduction of radi-
ation exposure limits should be extended to all.

Our union is also very concerned about the internal emitter
problem. The very fact that alpha radiation is shortrange makes
it very danerous inside the body. Ithas a radiological, bio-
logical effectiveness (RBE) of 10 and its short range leads to
heavy radiation of the body cells adjacent to the emitter.

Pure alpha emitters are very difficult to detect outside of
body. The inaccuracy of bioassay monitoring is conceded by
everybody whose papers I have read.

We need tightened standards of airborne radiation.

Our union has no immediate proposal, but is studying air-
borne radiation hazards with the purpose of preparing definite
recommendations for new standards.
Dr. Morgan. Thank you.

/ Archer, V.E., Gillam, J.D., and J.K. Wagoner. Respiratory
Disease Mortality among Uranium Miners. Annals of the New
York Academy of Sciences. v. 271. 1976:280-293.

2/ Mogliss, A.A. and M.W. Carter. Public Health Implications of
Radio-Luminous Materials. Bureau of Radiological Health.
Food and ug Admnistraion. ocille, Maryland. July
1975. (HEW-FDA-76-8001).

3/ Coittee on the Biolocal Effects of Inizing Radiation,
ational Academy of Sciences. The Effects on Populations of
Law Levels of Ioniig Radiation. Washington, .C. N.A.S.
November, 1972. p. 132.
4/ Terpilak, Michael S., and B.L. Jorgensen, Environmental Radi-
ati Effects of nuclear facilities in New York State: v. 15,
no. 7, Radiation Data and Reports. EPA, July 1974:375-400.

Chapter VI

Federal and State Responsibilities in Regulation,
Monitoring and Inspection
Adequacy of Present Monitoring Programs

Dr. Morgan. Let us go on to the next question, question num-
ber five. What is the responsibility of the Federal and state
government for protecting the public and those arious subroups
from harmful amounts of radiation? Who is responsible for moni-
toringand inspecting the major emitters of low-level ionizing
radiation, and is this monitoring adequate?

Dr. Shleien?

Dr. Shleien. The Bureau of Radiological Health of the FDA
has the responsibility for the control and monitoring of electron-
ic products that emit radiation. This responsibility is defined
in Public Law 90-602. Although the Bureau is responsible for
various types of radiation, this conference is limited to ioniz-
ing radiation.

Some of the standards that the Bureau has issued are: A
performance standard for diagnostic x-ray systems and their major
components; a standard for television receivers; a standard for
gas discharge cathode ray tubes; a performance standard for cabi-
net x-ray systems, including x-ray baggage inspection systems.

In addition to the issuance of standards, we also collect
and monitor information relative to medical radiation dose. Most
of the medical radiation dose information presently available has
been from the Bureau. Two programs in this area are being car-
ried out.

One was the exposure to x-rays in the U.S. population, the
XES study!/; the other program is the NEXT study (National Expo-
sure to X-Ray Trends). This system monitors the means and the
extremes of x-ray doses from specific x-ray procedures.

In addition, we have a large research program involved in
the study of radiation bioeffects.

Some of the projects that we have supported under this are
the Alice Stewart study in fetal exposure. There is the largest
ongoing long-term exposure study on beagle dogs being performed
at Colorado State. The tinea-capita studies2), particularly the
one carried out in Israel, is a large population and is an at-
tempt to extend the curve for dose response to lower dose levels.
Linked to this study is one in animals to determine the relative
carcinogenicity of radio-iodines versus external radiation.

The last aspect of our program that I would like to mention
is one dealing with improvement of radiation practices. I think
that I will leave that to Mark.

Mr. Barnett. Bernie mentioned one of the responsibilities
at the Federal level is to set standards for and monitor the per-

formance of machines that produce radiation. Complementing that
are our programs to improve the individuals who use those ma-
chines, upgrading the practices of physicians, radiologic tech-
nologists and dental personnel who apply x-rays to humans. These
programs are essentially educational in nature.
For example, we have developed a learning system for medical
students and residents in radiology which teaches them the basic
principles of radiation practice and which is now being used in
approximately one-third of U.S. medical schools.

Likewise, we have a training program for x-ray technicians
that is used in almost half of the 1100 or so x-ray technology
schools in the country.

We also have the responsibility to set guidelines or recom-
mendations which are gradually being published in the Federal
Register on good x-ray practices, including the use of gonad
shielding to protect patients from the genetic effects which were
alluded to earlier in the discussions.

We have recommendations underway on such issues as the irra-
diation of pregnant women from diagnostic x-ray examinations and
the use of quality assurance programs at medical facilities to
assure the best possible radiographs with the lowest possible
patient exposure.

We also have a responsibility to educate consumers about
medical x-ray protection. Again, our programs to educate both
health professionals and consumers are complimentary to our pro-
gram of setting standards for and monitoring the performance of

Dr. Morgan. I would like to ask the question, when can the
Bureau of Radiological Health assure us that all tt llhe x-ray tech-
nologists are educated, trained and certified in the use of x-ray
equipment and there is similar knowledge and educational require-
ments of the medical doctor who prescribes these x-rays?
Mr. Barnett. We feel the improvement is taking place with
respect to the knowledge of the individuals who use radiation.
It is true that we presently lack uniform criteria for educating
and assigning credentials to either individuals who prescribe or
apply radiation to people, and some sort of consistent credential
standards are probably needed.

Several states now that license radiologic technologists,
use regulations that are often not compatible with each other, so
there is a need for uniformity there, too.

Dr. Morgan. I have been prodding the Bureau for years to
get on with this. Perhaps our next speaker from the Bureau will
indicate this job is underway, or maybe EPA will get on the job.

Dr. Ellett. I will get to that on your time, not mine. I
would like to respond to the listed question which is, what is
the responsibility of the Federal-state governments in the pro-
tection of the public from radiation.


I have looked at this. To some degree, it is very much a
mixed bag on who has the responsibility for what. I think the
public needs a greater understanding of what the responsibilities

I will start with the EPA responsibilities. EPA inherited,
under a Presidential reorganization plan that set up EPA, the re-
sponsibilities of the Federal Radiation Council. I think the
Federal Radiation Council's responsibilities have been somewhat
misunderstood. Everybody says that their standards follow those
of the FRC. Well, FRC did not establish standards. FRC provided
guides to Federal agencies. They defined guides as a radiation
dose that should not be exceeded without careful consideration
for the reasons for doing so.

That maybe sounds strange now, but in the context of 1960,
when this was prepared, it was in a different era and I do not
think that it was particularly poor guidance at that t time. There
may be some question of whether it needs updating or not. I am
not prepared to respond to that right now.

The FRC also recommended that all exposures always be ac-
companied by a benefit and that all exposures should be con-
trolled so as to be as low as practical. I think that most of
the arguments that are being made today on radiation standards
are not on the question of what the basic guides are or how basic
standards are established (by other agencies and by EPA), but
whether these standards call for doses that are truly as low as

To continue with what EPA's responsibilities are, under the
plan that set up EPA, they were given the responsibility for set-
ting both levels of radioactivity (quantities and concentrations)
and doses in the general environment. This standard setting
authority was created under the Atomic Energy Act and applies on-
ly to materials covered under that act. We believe where these
responsibilities come from (their legal basis) is very important
to what a Federal agency does. EPA can also set standards in
special situations like for drinking water. That responsibility
was assigned by Congress. In general, however, EPA has not set
radiation standards, rather it provides guidance to other Federal

Radiation standards are set by other regulatory agencies,
such as the NRC which provides standards for licensed material,
materials produced in atomic energy reactors, etc., that make
materials defined by the Atomic Energy Act.

ERDA is not thought of as a standard-setting organization,
but I assume they set as many standards as anyone in the country.
They set standards for all of their contractors. This is essen-
tially a part of their contracts.

ERDA has books of regulations that are known as their manual
chapters for radiation standards. This controls what the expo-
sures are for a large fraction of the occupational field. These
standards are within the FRC guides.

When we get down to state governments, the state situation

seems to be somewhat less clear. It looks as if states have some
esponsibility for settg the exposure standards for
radioactivity, but one interpretation of the Minnesota decision
by the Supr Court, in which th Supreme Court did not review
the appeal court's decision, was that the states were pre-empted
fro saying anything about radiation hazards from materials cov-
ered under the Atomic Energy Act (Northern State Power Company v.

Control of natural radioactivity is the responsibility of the
states. In the past there has been a reluctance, perhaps, on the
part of the Federal government to look closely at hazards from
natural radioactivity. The only Federal guidance out is on radon
exposures to workers in underground uranium mines.

There was a second part of this question, who is responsible
for monitoring and inspecting the major emitters of low-level
radiation? Is this monitoring adequate? It asks for various
agency representatives to describe the number of persons and bud-
get devoted to these responsibilites
EPA has the responsibility, that was transferred by law from
the Public Health Service by Executive Order to collate, analyze
and interpret data on environmental radiation levels. We obtain
the data from NRC and from ERDA that they receive from their mon-
itoring programs, which I am sure they will describe to you.

We have some information from the states published by EPA.
EPA also has its own monitoring network called the Environmental
Radiation Ambient Monitoring System and it performs work in its
laboratories for the states and for its own special projects on
what environmental levels are.

This is not a large program, but it is a major program in
terms of EPA radiation funds. Our '77 budget calls for 40 posi-
tions being devoted to this type of monitoring, collation and
publishing of the information on background radiation and $760,000.
This is roughly a quarter of our total budget for radiation in the
the agency.

Of the $760,000, about $350,000 is for our environmental
monitoring system which, by the way, is not at every reactor but
it is in places in the general environment. We usually pick sam-
pling stations so they are fairly close to some nuclear facility,
but the system covers large metropolitan areas as well, and other
selected places, so we have a large geographical distribution.

We also are doing about $500,000 worth of special field stu-
dies this year. This program is concerned with places where an
environmental problem has been identified.

We are also spending $225,000 on mnitoring of non-ionizing
radiation. This is the only Federal program for non-ionizing rad-
iation regulation in the country. I will not go into details of
our program.

Dr. Morgan. The last part of the question was, is this ade-
a? Do you need more money in EPA, or is this an adequate pro-

Dr. Ellett. I am not in the position to discuss adminis
trative budgets. I think, really, the panel and the public have
to decide what is adequate and what is not adequate. We have
twenty active stations to sample radioactivity in air at the
present time; another fifty-four on inactive status.

We have twenty stations in the counry that look for pluto-
nium and uranium particles in the air. We have twelve that look
for krypton.

We sample a grand total of fifty-five surface water sources
and seventy-six drinking water sources, and, in conjunction with
the states, we also look at the interstate carrier systems, water
supply to trains and things like that, up to a level of two hun-
dred samples per year. It does not seem like an overwhelming pro-

Dr. Morgan. I dare say some of the panelists later will
have some opinion on whether it is adequate.

We have now heard from the Bureau and the Environmental Pro-
tection Agency. We will now hear from NRC.

Dr. Mattson?

Dr. Mattson. NRC gets its authority for regulation from
three basic places, the Atomic Energy Act of 1954, the National
Environmental Policy Act of 1969 and the Energy Reorganization
Act of 1974. Our responsibilities are very broad and quite
unique, I think, in Federal Regulation, as to the detailed
authority granted to us in controlling the users of source mater-
ial, byproduct material, and special nuclear material, as they
were defined in the Atomic Energy Act. These responsibilities
include the safety of facilities handling these materials, the
exposure of the public for normal operation of these facilites,
the exposure of workers within these facilities, the use of by-
product and special nuclear materials as radioisotopes in nu-
clear medicines and industrial applications.

Because our authorities are rather broad with these three
types of materials, we also run into interfaces with other ag-
encies. In that regard, we have consistent regulations with
the Occupational Safety and Health Administration of the Depart-
ment of Labor, the radioactive materials transportation functions
within the Department of Transportation, the Food and Drug Admin-
istration, the people seated on my left, the Environmental Pro-
tection Agency, and the United States military.

Of most importance to today's discussion is our responsi-
bility in regulating the nuclear fuel cycle, the production of
electricity from uranium. The lines of responsibility there
are very clear. As soon as uranium ore leaves the mine it comes
under our regulations and stays there, right through its use,
its reprocessing, and its disposal as waste.

We have regulatory responsibility for the material from the
time it leaves the mine.
Some of our responsibilities have been delegated to the


states under an agreement states program spoken of in our regula-
tions. Approximately half the states in the United States parti-
The kinds of authority that are delegated are those pertain-
ing only to byproduct materials and source materials of less than
a critical mass. Special nuclear material is kept for Federal

These regulatory authorities go to the states, when a pro-
gram proposed by a state is approved by NRC. One of the base re-
quirements of those programs is that they have compatibility
with the Federal regulations.

As has already been said, there is pre-emption by the Fed-
eral government of radiation standards setting for byproduct,
source, and special nuclear material.

Now as to how our system works. Basically, our system of
regulation is divided into four functional areas. We write stan-
dards in the form of regulations. Title 10 of the Code of Fed-
eral Regulations contains NRC regulations.

We license individual facilities as they fall under these
regulations. We do a case-by-case review for each new reactor,
processing plant, uranium mill, whatever.

We inspect the operation of those facilities against li-
censed conditions which are specified as a matter of contract,
if you will, with the Federal government. "Contract" is not the
right word; I should explain that.

License conditions are a matter of law, i.e., enforceable
under law, within those license conditions are contained the pri-
mary requirements for monitoring by our licensees. That is,
rather than the Federal government monitoring each facility case-
by-case, we require as a matter of license, for each facility,
that the licensee do the monitoring. We require effluent moni-
toring, environmental monitoring, and monitoring of the people
who work in the facility. All of this monitoring is specified
along stringent lines contained in our regulations.

In addition, we inspect the operation of each facility
against its license conditions to see that the licensee is doing
the monitoring. In addition we audit in the sense of independent
measurements to confirm licensee measurements. Not at all facil-
ities all of the time. but as a sort of spot check.

Our success with monitoring has been very good. I might
note that there have been a number of states who have become in-
volved in third-party monitoring, if you will, in addition to
the licensees and the NRC. States have said they want to keep
track of the emissions from various fuel cycle facilities. We
encourage that, in fact, we have a program for some partial
funding of that though the Federal government.

It has worked very well in the past, it goes back some
twenty-five years, way back to Shippingport.


As a summary on the budget question that has been raised,
we have, in fiscal '76, some 2,200 people in the Nuclear Regula-
tory Commission with a budget of $218 million this year.

I did leave out a functional category in that regard, con-
firmatory research. We do some research at NRC of a confirmatory
Unless there are further questions on the budget, I would
just as soon leave it at that.
Dr. Morgan. Do you consider that your program is adequate?

Dr. Mattson. For now, yes, sir.

Dr. Morgan. Dr. Caldicott?

Dr. Caldicott. As a pediatrician, and if we proceed with
nuclear power as it seems that most people around this table
think is a good idea, can you guarantee that in a hundred years
or 500 years the standards that you are talking about now will
be conformed to, both in America and throughout the world, be-
cause I do not come from America?

Dr. Mattson. The operating life of the facilities we are
licensing with this particular standard is over 30 years. You
are talking about waste management, is that what your concern is?

Dr. Caldicott. Waste management from breeder reactors.

Dr. Mattson. We have no standards for the licensing of
breeder reactors at the moment.

Dr. Caldicott. Are we going to have standards of radiation
acceptable to the population when breeder reactors come into be-

Dr. Mattson. I do not believe we have licensed a breeder
reactor yet.

Dr. Caldicott. Are we planning to?

Dr. Mattson. There is one that has applied for a license.
Yes, ma'am.

Dr. Caldicott. Are we planning to go ahead with the breeder
reactor program?

Dr. Mattson. I think we talked about that this morning and
the role of NRC in that regard to make independent judgments re-
garding the safety and environmental impact of reactors for which
people file an application. That is quite a different question
than are we going ahead with the breeder reactor program.

Dr. Morgan. Dr. Bross.

Dr. Bross. I would like to start with the statement which
was made by Dr. Mattson and others, in which he said, in effect,
there is no human data on the low-level effects, genetic effects.


We have a Tri-state Survey and we have information and the
results in the children of their various health hazards. In this
comment, following up this particular group would almost be a di-
rect answer t fhe specific kind of study it asks for.

The pint is, if the members of the regilatory agency sit-
ting here before you are going to say, there Is fn data -- this
is not a question of science, it is a question of fact: is there
data or no data?

There is in our files, in our records, material in comput-
able, usable form. It is a matter of fact, whether there is data
on this or not. There is data. What we have here is a simple
refusal on the part of the regulatory agencies to look at the
data, to think about the data, to use this data. I publicly chal-
lenge the NRC to set up an adversary science hearing. I will come
down to argue this point. They can present any experts they wish
against me or against our side. We will thrash out whether or
not we can show clear-cut genetic effects from low-level radiation
on the order of 1 rad.

We will carry on this debate so members of the public can
understand what we are talking about, not esoterically.

Now I think, if we don't use the data we have, it does not
really do much good to set up an elaborate system for collecting
data. I have been in public health for 25 years, all the way
back to the smoking and lung cancer issue. It was always: We
need more data. We don't do anything about cigarettes. We are
going to get more data.
I do not think this is the way to solve the problem. I do
not think obscuring the issues by bringing in cost factors and
making a big mess of things is helping, either.

There are human beings exposed to risk. The question is:
Are they going to have diseases, are they going to die, as a
result of this kind of exposure?

That is the issue. It does not involve a lot of costs. The
question is: Are there a lot of people who are going to get
killed? If so, we do not want to do it.

Let me say that I strongly support a program for getting
better data and I think this has come up several times for low-
level radiation hazards.

I support it with the intent that it is going to be used to
do somethitng aout these hazards and not as a method of simply
delaying public action. We know what to do right now.

Dr. Morgan. Dr. Mattson, you have been thrown the glove.
Will it be pistols, or will it be swords? Do you care to re-


79 -767 7 -6

Dr. Mattson. First of all, I do not think I said that there
were not any human data. I think that the conclusions drawn from
the data were not hard evidence of a direct link between low-lev-
el radiation and health effects in man. We have heard people
discuss both sides of that issue all day today.

I assure you, Dr. Bross, you need not throw down a gauntlet
to have an ear in my office.

Dr. Morgan. He has suggested that there be a public hearing.
Maybe you might consider that also.

Dr. Mattson. There are procedures for obtaining fomal hear-
ings by the NRC. I am sure you are aware of them. They are called
Petitions for Rule-Making and Requests for a Hearing. I certain-
ly, as an individual, am not empowered to grant such a request on
behalf of the Commission.

I repeat, my telephone line is open, my door is open. If you
want to discuss this subject, bring in the data. We are there to

Dr. Morgan. Dr. Burr?

Dr. Burr. I am Dr. Burr from ERDA. I will comment briefly,
because ERDA's role has been touched on already.

ERDA does retain the responsibility for its contractors and
our environmental monitoring budget for ERDA contract operations
is approximately $6 million a year. This involves about 450 people,
including both ERDA and contract personnel.

The data is gathered, reviewed and published. Dr. Burr has
a set of information from the recent environmental monitoring pro-
gram that we would like to leave with the committee.

Dr. Morgan. Thank you, Dr. Burr. Dr. Burr, we will receive
it. We will now hear from Dr. Archer in reference to NIOSH.

Dr. Archer. The major governmental agencies dealing with
radiation have already been heard from. There are three others
that have some concern.

One is the Mine Enforcement and Safety Administration --
MESA. The other two are the twin agencies created under the Oc-
cupational Safety and Health Act. They are the National Insti-
tute for Occupational Safety and Health and the Occupational
Safety and Health Administration, NIOSH and OSHA.

MESA, the Mine Enforcement Safety Administration, gets their
authority from a special metal mine act which gives them author-
ity to control all hazards in mine operations. It is mines they
are concerned with, and they have a very active program for mea-
suring the concentrations of radioactive material in essentially
all mining operations. They concentrate on radon daughters in un-
derground mines.

The law which created NIOSH and OSHA has provided very wide


powers for these two agencies: for NIOSH to investigate prob-
lems and OSHA to enforce standards. They have very wide powers
to look into and control occupational hazards. However, the law
also puts in an exception, it excepts those sita tions where au-
thority has been delegated to other agencies.

In this case, nearly all of the authority for radiation pro-
tection has been delegated to other agencies; both NIOSH and OSHA
are concerned very little with it. The one study that NIOSH re-
tained was the study of uranium miners. We retain this for his-
torical reasons. The Public Health Service got into that study
at a time when none of the other agencies were interested in it.
Thank you.

Dr. Morgan. Thank you. Dr. Bertell?
Dr. Bertell. I think we are talking here about protecting
the health of the public and when I think about protecting the
health of the public, the first thing I wondered about is how
healthy are the people?

I look back at the OSHA form which has to be filled out by
employers. If you have an occupationally-related illness, you
have to report this at least in the state of Vermont within 72
hours. Unless you received more than a 50 rad dose and got im-
mediately sick from radiation, that is, within 72 hours, there
is no obligation to report radiation-related disease.

I read Dr. Lassiter's reporti/ -- he is from OSHA. He gave
this report at a meeting of the New York Academy of Sciences in
March 1975. He said the OSHA reporting form from employers picks
up 2 percent of the medically-diagnosed, occupationally-related
disease, 2 percent. This is not watching people. This is not
seeing what is happening to the people in the occupational situ-
Reports in industry need to be kept only five years. Again,
you have eliminated a whole slew of diseases.
You do not have a cumulative record that moves with the
worker. If he changes employment, he starts all over again.
We say we are very interested in people exposed to medical
radiation. We have done several extensive studies on the doctor,
the physician radiologist. Dr. Vilma Huntpoints out that no
studies have been done on women who are the x-ray technologists.
We brought up Women's Lib a few minutes ago.

I think there is something radically wrong with a monitoring
program when we do not look at the people and say, are they sick?

I just finished reading a report on the uranium mineworkers.
It says in this group of 25 there were no cases of lung cancer.
They told you nothing else about the people, are they sick, what
is the matter with them, have they died of anything?
I just think that the important issues are being lost in a
whole lot of paperwork.

Dr. Morgan. Thank you. I think t s very important to
have this on record. Certainly, many of us have been made aware
of this statute of limitations for example, it does not provide
adequate protection. Dr. Richmond?

Dr. Richmond. I would like to respond to that t comment
that was made. I believe you meant plutonium workers, not uran-
ium workers.

Dr. Bertell. Yes.

Dr. Richmond. I know of at least three places where that
information is published, including the open literature and the
details are given as to the causes of death.

I would like to also mention that that particular group of
individuals was studied since 1944, during the war years when
the first nuclear weapons were developed. These people were stu-
died and they are still being studied today.

For the record, this is a published, scientifically reviewed
document. Available evidence -- I encourage you to read it.

Dr. Bertell. Could I have the reference?

Dr. Richmond. I think I have a copy with me. I will give
it to you personally.

Dr. Bertell. Thank you.

Dr. Morgan. Could you provide this for the record also?

Dr. Richmond. I would be very pleased to. (See Appendix)

Dr. Morgan. Dr. Mattson?

Dr. Mattson. May I interject briefly on something Dr. Ber-
tell said?

It should be clear for the record that people who are ex-
posed to radiation as a matter of their work are monitored with
devices that measure radiation. We do not depend on workers re-
porting to their management they have been sick. We require un-
der law that they report exposure to radiation.

I believe that is the case for other agencies as well. The
2 percent does not apply to radiation.

Dr. Bertell. Excuse me. There is a differnece between re-
porting how much radiation you are exposed to and what diseases
later occur, to see if there was a correlation. Those are two
different questions.

Dr. Morgan. Dr. Archer?

Dr. Archer. Perhaps I could add a bit of clarification to
this matter of reporting.

A number of state occupationa laws do have provisions for report-
ing diseases ated to occupatit of the states have simi-
lar l aws.,

But, as a rule, about the only conditios that are reported
under these laws are accidents, se they are obviously rela-
ted to work. Sometimes acute disass, things that happen right
on the job, are reported. Any chronic disease or long-delayed
diseases are rarely or never reported. The primary reason for
this is that nobody recognizes them as occupational disease. Even
if a doctor thinks a chronic disease might be occupationally re-
lated, he cannot be sure of it.
The only way that one can really be sure of the etiology of
these diseases is through epidemiological studies. The method of
reporting occupational disease for chronic or long-delayed dis-
eases just does not seem to work.

Dr. Morgan. Dr. Caldicott?

Dr. Caldicott. Do any of those studies show people with ter-
minal diseases injected with plutonium?

Dr. Mattson. May I respond to that?

Dr. Morgan. Dr. Mattson?

Dr. Mattson. People who work with radioactive materials
such as plutonium which are dangerous as internal emitters are
working in an environment where the routine operation is one of
total confinement of those internal emitters. Only in unusual
circumstance such as maintenance or accidents or incidents do
the internal emitters become airborne within the working envi-

When that happens, the workers put on respirators. They
are monitored by health personnel very closely when that happens.
For example, swabs of mucus, or internal measurements are made.

Dr. Morgan. Dr. Caldicott?

Dr. Caldicott. When you put people on respirators, it does
not necessarily remove the plutonium particles nor the bronchial
swabbing or bronchial lavage. It may remove some; it may not re-
move all of it.

I would like to address myself to the responsibility of the
Federal and state governments for protecting the public. We are
about to embark on, it seems, a plutonium economy, not just now,
but for future generations for hundreds of thousands of years.

By the year 2020, we will have produced 30,000 tons of plu-
tonium. There would be 100,000 shipments of plutonium per year
on the highways of the United States, it is predicted. We know
that plutonium is one of the mot toxic, carcinogenic substances
we have ever known, such that a millionth of a gram will produce


state governmnt, is to work out regulations and reports right
now, but we cannot predict what future generations and societies
will do with this plutonium and what will happen to it, and what
will happen to future generations of children and also -- that
is just the year 2020, what about the year 2050, what about the
year 3000, if we keep on with nuclear power?

I would suggest, as a pediatrician that this is the biggest
public health hazard we have ever known, bigger than malaria and
smallpox because the potential damage to the genetic building
blocks of life is immense.

I would suggest that the responsibility of the Federal and
state governments is to stop producing nuclear power plants and
plutonium now. We are already contaminated with plutonium, all
of us, from fall-out. We do not know what the danger is yet.

We need large epidemiological studies. We do not know of
the dangers to other generations. Is it up to us to prove it
is dangerous or for the industry that wants to proceed to prove
that it is safe?


Dr. Morgan. As Chairman, I would not ask the panel to re-
spond to this. I am sure that it would take the rest of the
week to adequately respond, but we have promised the audience
that we would give them a chance to make a comment or ask a


Mrs. Brackman. I am Selma Brackman, a coordinator for some
sixty-odd peace organizations in the United States. The name of
our coalition is the Coalition for International Cooperation and

Over the last year, we have addressed ourselves to a peace
ballot on which we have two propositions that will be afforded
to every major candidate and one of them says that the United
States should enact stringent legislation to prevent pollution
of the oceans and the atmosphere, and the second is that sub-
stantial public funds should be used to develop nonnuclear ener-
gy, including solar and geothermal energy and where possible in
cooperation with other nations.

Now the question this morning was, how much authority should
the states have as contrasted to the Government, the Federal Gov-

As a coordinator for another coalition in Vermont, we found
that Vermont is the first state in the United States to say to
the Federal government, we reserve the right to veto the restric-
tions or the permission that the Federal government has given for
the siting of a new nuclear reactor.


of years during the summertime and the Yankee Vermont power re-
rt t d r
actor has ume s blasts, the ntifition that
goes on at this table wherein some of the gentlemen state, we
will not allow it -- well, it has been allowed. Not by you, not
by me, not by anybody, but it just happens.

These overdoses that come out, we do not know for ten or
twenty or thirty or forty years what is going to happen to the
people who live, what is going to happen to the workers there.
None of this comes out in the newspapers.

I think it is high time tht some investigation to that ef-
fect is made, that the very real problems that are not even ad-
dressed here to the effect that the radiation problem occurs and
there is nothing we can do afer a certain point.

We are not all omnipotent, and we must realize that.

Dr. Morgan. Mr. Goodmn.

Mr. Goodman. It so. haens that the Governor of Vermont
asked me to come up and advise him about that plant when the ap-
plication was first filed, and I told him in my judgment it was
the wrong kind of plant and at the wrong place at the wrong time.

It was the State of Vermont that passed the regulation to
permit central Vermont to sell the bonds to proceed with the con-
struction of the plant, so I say to you the responsibility is not
just in the Federal government.

Dr. Morgan. Thank you. Other comments?

Mr. Laitner. My name is Scott Laitner.

There has been an increasing nu of statements suggesting
that we do not know all that much about the effects of radiation,
particularly at low-level doses and dose rates. It seems to be
a case where the more we find out, the more kinds of cause and ef-
fect relationships there seem to be.

This raises a question, I think Dr. Morgan pointed it out
very well. The object seems to be that we should allow minimum
exposure to radiation regardless of the source. My question now
becomes, Why is it, looking in terms of manmade radiation or man-
produced radiation effects; Why is it we always seem to be look-
ing at nuclear power as given, rater than etermining how we can
do without nuclear power, recognizing the potential dangers?

Why is it that regulatory agencies always seem to accept
these things as given, whether in terms of medicine, or in terms
of power production, and then try to balance the cost-benefit ra-

Dr. Morgan. We will assume that Dr. Mattson wold feel
that this has bee answered or has been responded to frequently
in the open litature Do you have any further comments?


Dr. Mttson. I would challenge that there s sch an ass -
tion by the Nuclear Regulatory Comission. NRC is an id dnt
regulatory agency charged with licensing the use of byproducts,
sources or special nuclear material. If there is n o nuclear p
wer industry, we do not license anything.

If people propose facilities, and they are safe, we license

Dr. Morgan. The next person?

Ms. Salzman. My name is Lorna Salzman, and I am Mid-Atlantic
representative of Friends of the Earth. I have two brief ques-
tions. The first is: Why is the assumption made, in setting
radiation standards, that workers are not part of the public?
Worker standards for radiation exposure are different from the
public exposure standards.

I assume the workers in the population do reproduce with non-
workers, and that therefore the genetic risks to them from radia-
tion would be reflected eventually in the population at large.
This seems to be an inconsistency in the Federal standards and I
would like to have an explanation.

Second, if the risk is as minimal as you say, why are the new
proposed EPA standards considerably higher for workers than the
public? Why not make the standards for workers the same as for
the public?

Dr. Morgan. Dr. Richmond, would you respond?

Dr. Richmond. I am not at all certain why you are directing
the question to me.

Ms. Salzman. Perhaps I am in error. I believe you are the
one who played down the risk to workers.

Dr. Ellett. I would like to respond to the EPA part of it.

Dr. Richmond. I will answer the question, though.

Dr. Morgan. Would you like to give a brief response?

Dr, Richmond. Very briefly, yes.

Especially in regard to the first question you asked, there
is a difference purposefully built in the regulations and standards
to make the distinction between the worker and the person in the
general public because, as is true with any endeavor, there is
some risk associated with any kind of employment. That is a well-
known fact.

There is a biological principle here: there is no such thing
as a free lunch. Everything you do has a risk associated with it.

The assumption is that the radiation dose associated with em-
ployment is relatively higher than that which you would expect the
general population to assume. There is also a statistical argument


that thIe lwering of the standard by roughly a factor of 10 al-
lows for dif ences in age, et cetera, in the ge neal popula-
tion, because the people who are employed are generally in bet-
ter health and are given physical examinations. So that there
is a reason, obviously, behind this.
I hope you did not get the impression that I am minimizing
risk from radiation.

Ms. Salzman. I got that impression.

Dr. Richmond. My feeling is that we have been extremely
fortunate. In fact we realized that early in this century. Be-
cause of things like the young ladies who painted the radium
dial watches, these adverse effects were reported in the mid-
1920's, decades before plutonium and actinides were discovered.

We realized fully -- this was before my time, obviously --
that there are serious effects associated with radioactive ma-
terials. I think that early perception of the danger has been
one of the things that has kept the record extremely good be-
cause there is no documented evidence of any plutonium occupa-
tionally associated disease.

Ms. Salzman. Would you say there is a gene flow between
the workers in the industry and nonworkers?

Dr. Richmond, I do not think that requires an answer.

Dr. Morgan. Dr. Ellett, you had a response?

Dr. Ellett. Could you reword your question? I think you
have things upside down. When we are talking about the proposed
EPA regulations, they are lower than that for occupational ex-

Ms. Salzman. Not for reprocessing plants,.

I believe it is 75 millirems. Is that the dose for indi-
vidual workers in reprocessing plants?

Dr. Ellett, As far as I know, EPA has proposed no regu-
lations for occupational exposures at all. They have proposed
limits for people living in the vicinity of nuclear facilities,
a uranium fuel cycle that would include reprocessing plants.
These limits are quite a bit lower than the 500 mrem/y indivi-
dual limits of 170 mrem/y limits for populations that we have
been using so far.

The reason that these are lower is that these are based
on cost studies that show that these limits are practical.

I do not want to leave the impression that EPA limits are
higher. They are the lowest of any limits that have been pro-
posed. I must point out that these are proposed limits, not
Federal standards.


Mr. Augustine. name is Bob Augustine. I am the staff
rsearcher for the National Intervenors. We are a coalition of
156 citizens' groups.

There are a number of things that I am concerned about be-
cause we have not dealt with them today. They come under the
purview of this conference.

First of all, in connection with the NRC standards, they
apply only to what are called planned releases and n to un-
planned releases, which are accidents and leaks. We do not know
how many curies have been released in unplanned releases. If it
has been anywhere near approaching the figures that have been
released in planned releases, we have only been monitoring half
of them.

The licensee monitoring program, which is what the NRC
has, was not any good at Kerr-McGee, not any good at Shipping-
port, and its spotcheck program has not revealed these. What we
are going to do about these, I do not know.

Maybe one of the things we can do is improve the penalties.
If you look at the penalties for breaking all of the rules, they
are not sufficient deterrents for that kind of action.

The NRC standards also do not take adequate account of the
ability of animals and plants to reconcentrate the materials
that are released in nuclear power plants.

There have been studies done that show that these factors of
reconcentration by animals and plants would be thousands of times,
40,000 times more than the concentration in the water.

These things are not taken into account in the setting of
NRC standards.

There is a little bit of study done on the cow-milk path-
way and a couple of others, but there are literally thousands of
pathways where nuclear emissions from nuclear plants can get into
human bodies. With licensee facilities, the lack of health phy-
sicists is a scandal. The inadequacy of the film badge program
for protection of workers is another one.

If you are a worker and you work near a pipe that has a
crack in it and there is a stream of gamma radiation that does
not hit you in the chest, the badge won't show it and you won't
know until the cancer develops.

When you talk about monitoring adequacy, what we need to
know is what is being monitored and how extensively, how many
monitors there are around each plant, and what do they monitor?

We have to check on all of these things. What would the
improvements in the monitoring system cost? Who would have to
pay for them?

Furthermore, I would like to know, since we have some FDA
people here, if radioactive contamination of fish and other foods

occurs, what confidence can we have that the FDA would be able
to detect it?
Dr. Morgan. I don't think we can answer all of these ques-
tions. I will give Roger a minute to expound.

Dr. Mattson. I will be brief and go through these.

Plann unann n nlanned releases are all reported to the NRC.

Mr. Augustine. They are not monitored. Unplanned releases
occur where you do not have a monitor.

Dr. Mattson. If it is a nonaccident situation or abnormal
occurrence in the operation of the facility, that occurs through
the same effluent stream that the planned release would occur.
As for the unplanned release in the case of an accident, there
are monitoring capabilities for that, emergency monitoring capa-

As to the question of fines, I think that history shows in
recent years the stiff appltiffer li ion of fines, perhaps somewhat
differently by the Nuclear Regulatory Commission. I really was
not prepared to address that today, and maybe there is some food
for thought in what you say there.

As to the question of reconcentration of radionuclides by
the various pathways and fish, we do consider that. Those are
considered in our calculation models.

You mentioned thousands of pathways and we only treat two
or three. You are basically right, but we treat more than two or
three, that is an oversimplification. In order to choose the
dominant pathways there have been literally thousands of path-
ways studied by which radionuclides leave facilities and reach

Some of the research ongoing at ERDA continues to address
these. We have confirmatory research at NRC continuing to ad-
dress these pathways.

As to the lack of health physicists, we recently changed the
regulatory guidance on the qualifications of health physicists on
all operating facilities in the nuclear fuel cycle, in fact, all
the licensed facilities under the NRC purview.
Dr. Morgan. It is not just applied to power reactors?
It applies to the reprocessing plants?

Dr. Mattson. Yes, sir.

As to film badging being inadequate -- maybe the Bureau of
Radiological Health would like to chime in here. We are about
to havea public meeting on film badge qualification testing,
something that is needed to be done.

People have seen the need for this for years. They have


tried a number of routes. The most recent try was half a dozen
years ago. The data are now conclusive. It is not working as
well as people hoped it would. We are talking about indepen-
dent qualification laboratories of some sort, working with BRH
and the National Bureau of Standards.

The things that you mentioned concerning monitoring, the
radionuclides you talked about, are all monitored. I do not have
them all written down here. I cannot repeat them. I recognized
them as you read them.

We have a definitive set of guidelines on environmental and
effluent monitoring for nuclear power plants and a similar set of
guidelines is under development for fuel cycle facilities. We do
not now have an operating commercial reprocessing plant in this
country, but we have recently changed our regulations with regard
to the gathering of reporting and monitoring data for that kind of
facility as well as other fuel cycle facilities, if that is the
point you are making.
Dr. Morgan. Another question.
Ms. Allen. My name is Judy Allen from Virginia.

I am particularly concerned with the shifting state and Fed-
eral responsibility, what may be an illusion of protection.

I would ask Dr. Mattson about the total care that you say is
given in the nuclear fuel cycle. A Charlottesville Council-per-
son wanted to inquire about transportation of nuclear waste and
contacted the state of Virginia, and was told by the state of Vir-
ginia that these waste transport vehicles were monitored by the
NRC and monitored by DOT,

We contacted NRC and were told that your responsibilities
stop at the utility site border, that you no longer are respon-
sible for that transportation, so there is no monitoring.

In fact, at the Department of Transportation we were told
that they set standards for the 30-foot drop container but that
they also do not do monitoring.

Could you give us some idea of the kind of protection that
we are afforded in the transport period when the NRC and the DOT
seem not to monitor, but the state seems to think they do?

Dr. Morgan. Dr. Mattson?

Dr. Mattson. The Department of Transportation is right.
They do certify the container for transport and the criteria
against which they certify it are contained in their regulations.

The NRC is also right. Once it leaves the site boundary it
is outside of our jurisdiction. But that does not mean that in
between nobody is watching it.

As far as the licensing of the facility, the applicant has
to state to the NRC "this is how I am going to take care of my


wastes, as th are rated year by yer. We are going to ship
t I am going to: s them down the following railroads, down
the following highways, they will be received at the following
reprocessing plants, and so on."

That statement by a license applicant is reviewed by NRC
from a safety and environmental standpoint.

Dr. Morgan. Dr. Caldicott?

Dr. Mattso. M I finish my answer?
NRC's monitoring of that shipment would occur as the shipment
left the facility, probably under license requirement on the own-
er or operator of the facility and then monitoring would pick up
again when it is received at another NRC licensed facility, which
it always would be.

Dr. Caldicott. Could I ask, I believe there have been three
autopsy series in the transuranium workers. The first 30 have
been reported; have the others been reported? If not, how could
we obtain this information, because I do think it is relevant to
the discussion.

Dr. Burr. Dr. Marks, our pathologist, tells me 50 have been

If you are interested in learning more about the others, of
course, they will be reporte. He might speak to you at the break,
if you like.

Dr. Morgan. I will take just one more question from the

Mr. Millerd. My name is William Millerd. I am from the
Center for Science in the Public Interest.

I do not know whether the questions this afternoon will oc-
casion any further discussion of the hot particle controversy. If
they don't, it would be very unfortunate to leave Dr. Richmond's
remarks as the record of that controversy.

In particular, I am referring to his characterization, for
instance, of the Biophysical Society's comments on the NRDC's
(Natural Resources Defense Council) position.

The AEC and ERDA erroneously characterized the Biophysical
Society as agreeing with their position that the standards should
not be changed, whereas in fact only one of the six reviewers
so stated in their comnts. Four others agreed that the evi-
dence is available that will lead to a lowering of the standards.
Two of them actually said the standards should be lower. Two
others made other estimtes of the degree to which the standards
should be lowered, agreeing only that the NRDC in asking for a
reduction by 105 may have been exaggerated. But one of their own
estimates suggested a lowering of the standard by 104.


Nonetheless, I think that the discussion this morning is a
gross mischaracterization of the state of the controversy. Since
there are so many here, including Dr, Richmond, who are involved
in this controversy, if that issue comes up again, I think it de
serves a mch more thorough discussion.

Dr. Morgan. In view of the lunch hour that already has
passed, I would like to indicate that after lunch we are going
to make some minor modifications in the order of questions, but
certainly we will discuss the role of the independent scientific
community and what recommendations are to be made that are speci-
fic for Congressional hearings and for action.


Dr. Morgan. It has been requested that we get back for a
few moments to question 5 and focus particularly on the last part
of that question.

I directed it to one or two of the panelists. The question
is, namely "Is this monitoring adequate?"

Seymour, I am not sure that you responded to that. Do you
feel that as far as the uranium mining and so on are concerned,
is the monitoring adequate, are the funds adequate?

Dr. Archer. Yes, I think the monitoring and the funds are
adequate to control the situation reasonably. As far as uranium
mining in particular is concerned, it is only recently that the
standard has been fully enforced. We are gradually getting down
to it.

Now that it has reached, and it is kept reasonably well, I
think that the risk in the future will be greatly reduced and
probably less than the risk of cigarette smoking.

Dr. Morgan. As far as the Bureau of Radiological Health is
concerned, I believe its attention is directed more at the manu-
facture of devices such as color television and so on. I believe
I asked the question before. I will repeat: Do you feel that
the monitoring of such devices is adequate from your point of

Dr. Shleien. As you mentioned, we do have a compliance pro-
gram. Under Public Law 90-602, that is an enforcement program.
I think the question might relate more to the monitoring of doses
of radiation during medical procedures.

I have already mentioned some of our earlier programs, the
x-ray exposure program where we initially evaluate the gonad
dose. We are now in the process of evaluating bone marrow dose.

In addition, we have a system of monitoring where the maj-
ority of the states are now employing the system developed for
specific examination.

Dr. Morgan. Has the 1970 report officially come out yet?


Dr. Shleien. The report i completed and at the
printer. The report on bone marrow doses / is in the process of
being prepared.

Dr. Morgan. Dr. Ellett, do you wish to comment on the ade-
quacy of this program?

Dr. Ellett. I believe I did previously.

Dr. Morgan. You have already covered that pretty well. Dr.
Mattson, did you want to make any other coents on the adequacy?

Dr. Mattson. The people from BRH and EPA mentioned a long
list of special studies concerning monitoring. There was some-
thing I left out in response to this question this morning. I
indicated this morning that for particular facilities each li-
censee is required to carryout a rather extensive monitoring pro-
gram for the plant, I.e., effluents from the plant and environ-
mental levels outside the plant.

In addition to that, there are specific studies of a generic
nature which are done by the Nuclear Regulatory Commission. I
have one under my wing at the moment on uranium ore dust in mills
which is a modest study, about $50,000 a year, I think.

I was not prepared today to list all such studies of that
kind that are carried on by NRC from time to time. As particular
questions are raised, or particulr issues come into focus, there
are a number of such studies done by our confirmatory research
people or by our inspection and enforcement people or by the stan-
dards development people that I represent.

Dr. Morgan. Thank you. Dr. Sternglass?

Dr. Sternglass. I uld just like to take a couple of mo-
ments to point out with regard to the question of adequacy of
monitoring that I was shocked, and I believe you were too, by the
evidence that emerd at the Shippingport hearings that everyone
agreed that the knowledge of just exactly what came out was not

The monitoring was, to say the least, extremely poorly done,
and in some cass ere were contradictions between reports of
operators who cl that gases were allowed to leak out without
being adequately reported.

There were claims that the plant had zero release. At the
same time, other people found a sizable quantity of strontium 90
around the plant and in the fish and in the milk around there,
and this raised the whoe question of the adequacy of the monitor-
ing of our nuclear facilities.

I believe that this is a very serious matter in the sense
tat people are talking about hundreds and hundreds of these
plants with much closer distances to population enters and areas
where milk, cheese and other food is produced sent all over
the country.


If the monitoring is not improved, I think that we are in
very serious trouble.

Dr, Morgan. Thank you. Mr. Goodman?

Mr. Goodman. I think the overall test is really what hap-
pens to the human beings that are involved.

For some period of time, over a twenty-year period I have
made a study of accidents in the atomic industry, the releases of
radiation exposure. I have offered in recent years on a number
of occasions a list of 500 individuals who were exposed or sub-
ject to radiation. I believe that there ought to be an epidemio-
logical study of the health records of these 500 individuals.

I do not know of any comparable study that has been made on
an overall basis. The workers who work in the industry who have
been exposed ought to be the subject of an adequate medical stu-
dy and I have the names here. I entitled this list simply, "In-
dividuals Involved."

If any of you want a copy, I would be glad to supply it,

Dr. Morgan. Would you furnish one for the record?

Mr. Goodman. I shall.

Dr. Morgan. Thank you.

From my own experience working in national laboratories, I
am under the impression that the monitoring and the care for the
health and safety of the employees in the neighborhood is what I
would term adequate. However, I believe that there have been
some areas under the judisdiction of the Atomic Energy Commission
and perhaps now, NRC, that miss the mark of meeting the standard
that I would say is even minimum.

I am thinking at the moment of the hearings last week, for
example, on the Kerr-McGee Cimarron, Oklahoma plant. I feel very
strongly that they broke all the rules of radiation safety. I
feel the same way about the West Valley Plant, chemical repro-
cessing plant in upper New York. I feel that even some of the
nuclear power plants have not had something that would approach
an ideal health-physics organization where you have personnel of
sufficient qualifications in charge of the safety of personnel.

I would be quick to say, however, that I think that the AEC
and the NRC and ERDA compared to some other industries have done
a remarkable job in keeping track of radiation risks. I only
wish that the fossil fueled power plants industry would do a
little bit as good with reference to the oxides of sulfur and
nitrogen, hydrocarbons and other insults in the environment.

I certainly argue, however, that there are some areas under
the jurisdiction of NRC that can improve.


Dr. Mattson. Dr. Morgan, may I respond to that?

Dr. Morgan. Yes, Dr. Mattson.

Dr. Mattson. I would like to say quickly, that the past re-
cord of monitoring facilities and specifying what environmental
data should be taken, what absolute data should be taken, or how
absolute exposures are monitored and tracked has shown evidence
of weaknesses in the system.

I would like to call your attention to some recent changes
in that regard, both in our regulations and in our regulatory
guides, that speak to these problem areas and ask perhaps that
you personally, at least, would reconsider some of those views
in light of this very recent information.

Dr. Morgan. I am not sure what you have in mind. The plant
I refer to in Oklahoma is not in operation, but it seems that it
took the NRC a long time for it not to be in operation.

Dr. Mattson. I was referring, sir, to the more generic
guidance on monitoring. I was not referring to the Kerr-McGee
facility. I am sorry if I misspoke.

Dr. Morgan. I see, I intended to compliment you when I in-
dicated that in terms of radiation risks we have done a good job,
if we make our comparison to the chemical industry and other haz-
ards in the environment. I would, since you request me to do so,
mention also that when Drs. Gofman and Tamplin, some years back,
suggested the lowering of permissable levels of radiation expo-
sure by an order of magnitude, you went them one better and low-
ered them even more, in fact you lowered them by two orders oof
magnitude. I certainly compliment you and your predecessor, the
Atomic Energy Commission that subscribes, not t some fixed level,
but to exposures as low as practicable (ALAP) and as low as rea-
sonably achievable (ALARA), but I think that we can still point
to some operations that you should ride herd on more to improve
your record and your image in the public eye.

Dr. Bross?

Dr. Bross. I believe that the public very often are given
reassuring statements on monitoring. If the statements are true,
they can be taken in a broad sense or a narrow sense.

The statements on monitoring can be confined to the quality
of physics involved in the monitoring process. However, if the
monitoring is doing any good, it should be affecting death rates
and doing something to protect the public.

A monitoring system that may look good on paper may not, in
fact, be worthwhile in practice.

Every time you look at details on monitoring, you get a
shock. In the effort mentioned about mammography, the is
an effort to take a look at what actually is being delivered to
women who are getting mammography. It ranges all the way from


79-767 0-76-7

300 millirems to hundred times that.

It is a staggering range. This is, in al practice, a
monitoring system that might be considered adequate in terms of
its aper perforance and structure an s forth is one thing.
But a monitoring system that is doing its has to work in the
field, and protect the field.
This is what I think the real issue is here.

Dr. Morgan. Dr. Caldicott?

Dr. Caldicott. How can we insure that monitoring will
sufficient when, as I mentioned, by the year 2020 there ud be
100,000 shipments of plutonium on the highways of this country
and if there are accidents, who is going to be around to monitor?

What happens to the people who are exposed, where will the
plutonium be dispersed, in the wind and so on? And what will
happen to people exposed to this released plutonium over thou-
snads of years, number one.

Number two, I have here the statement by Hubbard, Briden-
baugh, and Minor, GE engineers who resigned recently from the
nuclear industry in California, they state, some of the design
defects and deficiencies alone create safety hazards. This is
within nuclear power plants throughout the United States.

"For example, the possibility of failure of the Mark I sup-
pression containments. But the one most important point, and
the point that we want to emphasize to this committee, is the
cumulative effect of all design defects and deficiencies in the
design, construction and operation of nuclear power plants makes
the nuclear power plant accident, in our opinion, a certain

The only question is when and where. These men were top
people in the industry, for many years. I wonder what differ-
ence monitoring will make then.

Dr. Morgan. Dr. Mattson?

Dr. Mattson. Mr. Chairman, I would just note that Dr.
Caldicott is referring to the testimony of the three persons
which was the subject of congressional hearings that were just
concluded recently by the Joint Committee on Atomic Energy. I
do not recall the chairman of the committee's precise words in
summarizing those hearings but they were something to the ef-
feet that he had heard the story from one side and he had heard
it from the regulatory side. He said that he personally was con-
vinced that the regulatory system was working properly.

This is not in debate today. The three people from GE had
nothing to say concerning this dialogue today on low-level radi-
ation. We are talking about the narrow subject of monitoring as
it applies to low-level radiation.

If we get too far afield and start talking about accidents


d what we do in low probability evnts of a hi potential con-
sequence we will have to go back and revise everything that every-
said today. We intentionally cted or earlier remarks
to normal oeaton, routine this tht happened with low level
I think we ought to stick to the subject.

S/ Bureau of Radiological Heath. Food and Drug Administration.
Population Exposures to X-Rays: United States, 1970. Washing-
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(in progress).


Ch p e VI I"*" *' "*r
Current Radiation Protection Standards
Responsibility and Scientific Basis

Dr. Morgan. I believe we had better go on to question 6. Let
me state the question, and I will take a crack at one of the ans-

Who must set the current radiation protection standards for
public and occupational groups and what data are these standards
based on?

First of all, I would like to indicate that for many decades
the National Council on Radiation Protection and Measurements
(NCRP) and the International Commission on Radiological Protection
(ICRP) have set what sometimes are referred to as standards for
protection from ionizing radiation through their numerous publi-
cations, but these, as has been indicated, are recommendations. I
underline the word "recommendations."

Although these are not laws or official regulations or codes
of practice, they in fact serve in many instances the function of
regulations and codes of practice. In many cases, for example,
the regulations that exist, the codes of practice are based speci-
fically on these recommendations.
The first official guides at the Federal level in the United
States, to my knowledge, were set by the Federal Radiation Coun-
cil whose functions have now been taken over by the Environmental
Protection Agency. There are many government agencies that have
responsibility at the present time for setting radiation guides,
standards, codes of practice, regulations. I might mention among
others the former Atomic Energy Commission, now the NRC, the En-
vironmental Protection Agency, the Bureau of Radiological Health,
the Public Health Service, HEW, FDA, DOT (Department of Transpor-
tation), et cetera.
And of course, each branch of the military has its own regu-
lations and the states and a number of local governments have
regulations to control and assure radiation protection and to
set standards.

And, addressing the second part of the question, by far the
principal source of excessive and unnecessary population exposure
is, in my opinion, medical and dental x-rays. With proper educa-
tion and training, motivation, and certification, and with the
use of improved equipment, I believe that this exposure could be
reduced to less than 10 percent of its present level.
Even a 2 percent reduction in medical exposure would reduce
population exposure more than could be brought about by completely
eliminating the nuclear industry to the end of this century. The
present radiation protection standards wherever possible are based
on human experience -- the cause and effects of excessive exposure,
most of which comes from excessive medical exposure.
However, in many cases, essential data are missing. In such
cases, one must rel oer on animal studies. The most important human