Hot Partical Report
Hot Partical Report
Hot Partical Report
w) ACT
DEc .:
1974
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Major GeneralW. R. S&add,W DeputyDirector (Operationand Adainlstratioa)
Defeaaa Nuclear A@acy Ueshis@en, D. C. 20305
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Lt. General Warren D. Johnson Di~nctor Defense Nuclear Agency Dr. Thomas B. Cochran Staff Scientist Draft Environmental Impact Statement
Dr. Jushu:l klcrbcrg James Marshall, Esq. Ruby G. h[~rtin, Esq. An thonv h! azzrrcchi Jf, cb c! !1
FROM:
John. , U ,).,..(
Dr CIfl, IILI l!nchot E: ]01,11ii. i. .s,,. I.>q. burance Rockfellcr J. IVillard Rousevclt ENCLOSURX David Sivc, ~sq. Dr. ~cc:-c Iioodwcll Edwin M. Zu,,merrnan, Esq.
-- Enewetak
: Radiation Standards for He+. Particles, A. R. Tamplin and T. B. Cochran, NRDC, 14 February, 1974
1. NRDC finds the Draft Environmental Impact Statement, Clean Up, Rehabilitation, Resettlement of Enewetak Atoll -- Marshall Islands, to be incomplete and inadequate. Furthermore, the proposed (preferred) clean up operation is totally inadequate to protect the health of.the Enewetak people from exposure to hct particles of plutonium which carry a high risk of producing lung cancer. The basis for these conclusions ltp=ai~ti~.m. St~P.5ZZtiS i=nl- LTT~ D=-r+iplac - -- . 1 --~~ pre~ep.t~d i~. +_h-~ ~ep~~~, .&=. -. .I ~---L.j ;.rt:.~r :i ikmpiin and I,iyself (~ilC105LiIf2) . . TtIis report is intended to-be an integral part of these comments.
2. Radiation Standards for Hot Particles, was written in support of a petition by the Natural Resources Defense Council to the Environmental Protection Agency and the Atomic Energy .Commission reql-. sting (1) a reduction of the existing radiation protection 5tandar5s applicable to the internal exposure of man to insoluble alpha-emitting hot par.tlcles and (2) the establishment, with respect to such materials, of stdndards governing the maximum permissible concentrations in air and maximum permissible surface contamination letiels in unrestricted areas. 3. The petition was filed with the AEC on February 14, 1974. It is totally irresponsible for the AEC Task Group on Recommendations for Clean Up and Rehabilitation of Enewetak Atoll to issue its report on acknowledqinq the serious implications of hot June 19, 1974, without particles as detailed in our rep~rt~ 4. It is NRDCS position that the clean up of Enewetak should meet standards (enclosure) . summarized on pages 51-52 of our report
the
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RADIATION STANDARDS
OF hlAN TO INSOLUBLE
ALPHA-E\fITfING
HOT PARTICLES.
FEBRUARY .
14,1974
,-
------w .
------
--
1 3
Iv
to Insoluble
Alpha-Emitters
. . 11
. . . . . . . . . . . . . . . . 11 . . . . . . . . . . . . . . . . . 13
Modifying The
Factors
,iot Particle
Problem
. . . . . . . . . . . . . . 18
Biological Data Related to the Cancer Risk from Insoluble Plutonium Exposure . . . . . . . . . . . .. A B
c
. 21
The
. . . . . . . . . . . . . . 22 . . . . . . . . . . . . . . 26 . . . . . . . . . ., . . . . 29 . . . . . . . . . . . . . . . . 32 . . . . . . . . . . . . . . 34 . . . . . . . . . . . . . 38
Related Related
VI
Critical A B
c
Particle
Fallout.
. . . . . . . . . . . . . . . 41 c
q
VII
: ,, Exposure
Standards
: c o
41
/ A B
c
. . . . ~. . . . . . .. . . . . 42 Public . . . . . . . . . . . 44 . . . . . . . . . 46
q q
Releases
q
D E VIII
. -
48
Hearings
. . . . . . . . . . . SO
Summary A
of Recommendations
Appendix
Appendix Glossary
to Attorneys
Gleason
This
report
is written
in support
of a petition
by
Protection
Agency
(EPA) and
the Atomic
Energy
standards
u~rticles alpha -~~~itting hot .,, with respect to such materials, concentrations
contamination
levels
restricted
the qravity
becomes
a principal
power
industry.
r While much of this report focuses narrowly on plutonium-239, ~/ the discussion is, nevert!leless, germaine to all raciionuclides in insoluble particles with a high specific activity. (The definition of specific activity and other technical terms in this report are given in the Glossary) . The- justification for focusing on plutonium has been aptly stated by the International Commission on Radiological Protection (ICRP) : of the generthe emphasis on plutonium is clearly a reflection al consensus that, in terms of amount available, projected accidental human exposurel and usage , extent of anticipated radionuclide radiotoxicity, plutonium is the most formidable [ICRP Publication 19, The Metabolism in the periodic table. of Compounds of Plutonium and Other Actnidesl pergamon press~ 1972, P.1.]
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radiation
protection
regulations
are in force
in tile United Szates today and which are at issue. This section focuses on the existinq guidelines for Pu-239 , b~t is to be understood it should meet be applied particle Section that, in this and subsequent sections,
i: .
that
the hot
Before national
,,. {,,.,. , ~,, .
,8
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reading
those
unfamiliar
and international
organizations
which
have
primary
standard<, these
,; . . . t, . ., .. ,,,. .
organizatiofis IV-presents
and
authority inherent
Section radiation
protection are
standards
identifies applied
,,$.. ., .. ,..
tions
# ,,
that
alpha-emitting # demonstrate
biological are
that
assumptions
<appropriate V. V, the
in Section
presented particle
in Section
define
a hot
in Section particles
for hot in
and summarized
,
.
. *
,, .:,
-1 .
Pluccniu.n U:.: ancl pu~~Iic !;ealth plutonium occurs in nature, althouqh in such small cf the
., ,, ,.. ..
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a pr~ctical reactors
sour~e by the
Plytonium
in nuclear
of neutrons program
To date, source
.! ,.
,,
weapons
has been
that
corme~-cial source
principal
of this commercial
material reactors of
the next
two decades.
In todays
plutonium
is produced
as a by-product
in the
production
electricity.
.
of the
tlhzt
growth /
tctal
power
industry, of will
:::Q
the year
piuconium,
.
uranium, spent
serve
as a reactor
botl_A
are
Be-covered
from
reactor The
fuel
tihey will
be recycled.
reactor
~/ The ratio of the concentrations of plutonium-239 to Katz, J.J., uranium in ores varies from 4X10-13 to 1.5x10-11. Chapter VI, The Chemistry of Actinide Elements, Methuen and co., Ltd., London, 1957, pp. 239-330. Liquid Metal Fast Breeder Reactor 3_/ Environmental Statement, Demonstration Plant, USAEC, WASH-1509, April 1972, p. 149.
.
-49
of support to recover
required
both
to provide andplutonium
raw
fuel up
and
the uranium
make
over
4 million 1970
of nuclear . Over
capacity
between this
the lifetimes in a of
installed
could
result kilograms
of approximately ,,
fuel reactors
the plutonium
is in fuel on in
At various
facilities
in the nuclear
of Pu02
In addition, accidents,
where
particularly
associated of
amounts
can be
aerosol
particles fraction
radio-
of t~e
inhaled
respiratory
the
where,
insoluble
in human .
tissue,
~/ Updated (1970) Cost-Benefit Analysis of the U. S. Breeder Four Reactor Program, USAEC, WASH-1184, January 1972, p. 34. million megawatts (MW) corresponds to 4000 nominal-size nuclear reactors -- 1000 Mw each. 5/ Some advanced veactors of the future may use carbide and nitride, rather than oxide, form. fuel in
known
.
to man.
metal site
~licronrams
imbedded
at the
wound before
Within
the
excized,
displayed
precancerous animal
is one of is
potent
respiratory
There
concentra(3 micro-
as lcv as 0.2
microcuries
kilograms doses,
of plutonium
represents which,
a flow as will
of over be
a staggering
number
cancer /
doses
by
several of
orders this
is measured
in terms
of thousands in.the
of years. nuclear
Roughly
two-thirds
of the plutonium
flowing
A Dermal C.C. and J. Langham, Lushbauch, Archives of Dermatology, ;mplanted Plutonium, 1962, pp. 121-124.
6/
7/ There are 0.061 curies per gram of plutonium-239. fro-tenths of a microcurie of plutonium-238 would have a mass of only 0.01 micrograms since plutonium-238 has a much higher specific activity, 17.47 curies per gram.
-6q
fuel . life.
cycle
will
which years
has the
year
half-
In other
of this Of iOOJ be
hazardous due
to nat~ral from
material
must
isolated
the environment
in perpetuity.
IIi.
Existinq Radiation
Standards exposure
fcr Plutonium. Lxposure standards have been established and genetic can
radiation
is known
to produce
cancer The
irradiated.
mutations
defects
in subsequent
intent
of the exposure
standards
is to limit
shown dose
to the
radiation
dose. the
The
higher
the
the effect.
Therefore,
primary
radia-
dose; maximum
This
primary
standard dose
is generally r
referred
to as the
permissible discuss
in units
of rem/yr.
We shall
.
the nature
unit
radionuclides
which
with
fallout
an individual
-7.
by internal in body
sources; tissues.
that These
intc f~d
like for as
counterparts.
Radioactive
in the thyroid
gland
in the same
fashion
strontium naturally
or calcium occurring
accumulate
counterparts
radioactive that
iodine
will
a dosage that
qland
is many
times
to the other
strontium
and ca~cium
of the
uneven
not
for individual
In this whole
report body
be referr$ng
to the maximum
~>ermissible
as a matter have
secondary These
or derived
standards which
been
developed.
limit more
radionuclide easily
concentrations than
are often
employed two
the primary
We shall
examine
secondary
standards
in this
-8q
report; maximum
~he maxi,num permissible permissible amount man concentration of a given that will
lung
burden
(MPLB)
in air
(MPCa) .
size
at the maximum
permissible in air
obtaining. .
a !4PLD by
the air. to recognize to all and that the MPLD is the and standards standards
it applies
radionuclides
and are specific are related -. and to the Table ployees . . form. of the (ICRP)!
.
for a radionuclide.
of a radionuclide
radiation
I lists
standards to Pu-239
apply
of 15 rem/yr
is includ~d
on Radiological
on Radiation
Protection
Measurements
-,.
)
the Federal
. Radiation
Council
. ., ;,,
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8/ ICRP Publication 9, Recommendations of the International ~ommission on Radiological Protection (Adopted September 17, Pergamon Press, New York, 1966, p. 14. . 9/ NCRP Report No. 39, Basic ~CRP Publications, Washington, Radiation Protection Criteria, D. C.; Jan. 15, 1971, p. 106.
1966) ,
..
,.
q
-911
(FRC)lO.
is included radiation
in the standard
ICRP 12 .
and is also
in Table
I only
regul~tions. in ICRP
213 which I.
in Table
The MPLB
is also included
MPLD14.
in either of FRC,
the recenmenda-
tions
of ICRP,
guidelines
In sur.nery, in IableI the MPCa is consistent to all with forms the MPLD
applies apply
of ionizing to Pu-239
specifically
in insoluble
The 10/ FRC Report No. 1, O=. cit., p. 38. tr~ferred to EPA. tioiisi.ed aad i=s d~~i~~
.
FRC
has
been
11/,ICRP Publication 2, Report of Committee II on Permissible ~se for Internal Radiation, Pergamon Press, New York, 1960. [Appeared in Health Phvsics, Vol. 3, Perqamon Press, June 1960.]
12/
.
13/ 14/
2, Og. _it. c
Evaluation Mann, J.R. and A.R. Kirchner, ~llowing Acute Inhalation of Highly Insoluble Physics, Vol. 13, 1967, pp. 877-882.
15/ The MPLB could apply to most other alpha-emitting since the alpha particle radionuclides with long half-lives, energies do not differ appreciably from the Pu-239 alpha energy.
TABLE
to Pu-239
Form*
uCi/ml
of symbols.
guidelines
for Pu-239
that
apply
exposure
public here.
and sample.
exposure
by a factor for
the.guidelines ,. p~rentheses
.-
in Table ib . These
recommendation
recommendations incorporated
at this
tiIL]e/been
regulations.
1
16/ NCRp Report No. 39, ~.
-11q
Apply
0.0005 3X10-13
(0.00017) (10-13)
uCi uCi/ml
The MPLD
values
in parentheses
refer
latest values in
recommendations parentheses
of the NCRP.
The MPLB
correspond
recorn.rn.endaticns.
IV.
Calculating
the Dose
Due
to Insoluble
Alpha-Emitters
The purpose of this section is to examine the assumptions . ,. inthe radiation standards above that ar$ inappropriate when applied aerosols . review used of basic definitions the dose. Equivalent or the radiation emitted energy by a radionuclide cells in of radiation dose-and the factors to insol<~ble of Pu02. alpha-emitzing assumptions particulate are introduced such as a
The
through
Dose
an X-ray
passes
through
tissue
it transfers
to the
these
tissues.
produces
of the
The rad~~tion to or
is the of
the absorption . .
of 100 ergs
energy
qr=m
of material)
,,
In addition (high energy particles it was produced magnitude example, produce X-rays . . .
to X-rays, beta
radionuclides
emit
gamma
rays
X-rays),
particles
(electrons),
and alpha
(helium
nuclei). that, .
while
various such
biological .
tiias
the same
For would
that
radiation
10 times it was
as many found
deposits
5 times
efferti~.e radium
particles
from
differences absorbed
of the observed
permissible
are given
is given
in rem .
in Tables
I and
II.
The
of 11, A Review of the Radiosensitivity Perqamon Press, New York, N. Y. , 1967, p. 21.
.-13q
b; multiplying to correct
the absorbed
in rad by modifying
for these observed differences in the magnitude the magnitude of the :f the effect. As a consequence, will be the same for a given DE regardless of radiation. of the
effect ~zture
factors
are employed.
Factor
accounts various
effects
is the Distribution
Factor
(DF) effects
in an organ.
to bone
by using
(to account
effectiveness
(to
.
of alpha
particle
irradiati~nl
and .a DF=5
19
account
distribution would
of Pu in the bone) thus induce from the same the X-rays 1 rad.
rem
of cancers
in bone that
absorbed
dose
be 50 rad while
from
Pu-239
would
be only
18/
NCRP ICRP
Report
No.
&.; cit.,
p.
p.
81.
21.
19/
Publication
-14q
In obzainlng
.,,
r, ,. .
t!~e derived
values was
in Tables employed.
MPLB
and MPCa
for Pu-239,
a QF=1O
im~li~s, which
emit alpha
C2ilCer
radiation, X-rays.
10 times
in inddcing
.,,. , .. ,:, .. ... .,.
.,.
Although
tissue
plutonim assigned
particles to these
no DF value
particies
.,,..
DF=l was er,plc~zd in :Ietermining t,hederived ,, and II. Ideally, the DF should be determined of the observed nonuniform for example: DF = Number Number Since direct . of cancers of cance~s data effects in an organ following with the
values
in Tables
., ..: ,.
radiation
of the tissue
radionuclide;
(l~onuniform irradiation) (uniform irradiation) are not available, Pu-239 we it is particles present a DF=l from
e>:perinental
necessary collateral
shall that
the big~~gi~;~
suggests
grossly underestimates the DE for insoluble particulate of d Pu-239 and, consequently, that the derived standards, MPLB and ;\!PCafor this radionuclide, are greatly in error.20 In fact,
.
it will that
be shown
that
data use
strongly
suggests
for such
particles
a DF=115,000.
20/
alpha-emitting
actinides
.
q
-15-
uefore discuss
turning first
data
to
around
of Pu02 need to be
by the collateral.
radiobiological
studies.
of Pu-239
occurs
because,
when
an alpha a range
particle (produces
particle
damage)
tissue. only
In other
words, of in-
irradiate
a volume
enclosed
from
of this /
About
of the
This
delivered . refraining
of Tab+e
field
Since range
is longer
in the larger.
of irradiated a detailed
tissueis
Professor
Geesaman
analysis
of plutonium
-16q
particle last
irradiation
of deep
respiratory
in Table
III describe
using
-The dose
to the entire
organ From
2 of Table
III it is
significant dose
to note
that
PF=l, than
:~~ticle
varies one
by more averages
on whether
the dose
lung or calculates
it on the basis
of the tissue
1
.
I
,
(1 u in diameter,
0.4
Ug
1000
gz
65
ug
19 Ug
730,000
0.0003
4000
11,000
21/ Geesaman, Donald P., An Analysis of the Carcinogenic Risk ~om an Insoiuble Alpha-Emitting Aerosol Deposited in Deep Respiratory Tissue, UCRL-50387 and UCRL-50387 Addendum, Lawrence Livermore Laboratory, Livermore, Calif., 1968.
-17q
It would , in Table ,
take
53,000
particles
illustrated results as
III to reach
the MPLB
of 0.016
in i5 rem/yr Table
III ifidicates,
at a dose
indicates,
theSe
localized is this
irradiation. intense
but localized
carcinogenic
than
to, greater
appropriately, particle
lack
for dealing
problem.
-
22/ ~Geesaman, /
Donald
P., UCRL-50387,
pp.
8, 15.
23/ Langham, Wright H. , The Problem of L~rue Area Plutonium CGntanin2t10n, 11. S. Dept. of H. E. 1;. Public }+ealth , Services, Seminar Paper No. 002, Dec. 6, 1968, p. 7.
Based on 25/ Geesaman, Donald P., uCRL-50387, pp. 8, 15. ~esamans model for a lung at one-half maximum inflation. Geesaman estimates a total of.68 alveoli at risk, each 8X10-6 cm3 in volume, and deep respiratory zone tissue density of 0.12 g/cm3. 26/ 27/ See footnote 23. mass of a standard radiation man = 1000 of
g.
Based
on a lung
field
the 53,000
-186
c.
The
Hot Particle
to recognize
respect
of t!!e lung
alpha-emitters
plutonium
In its Publication
9, the
states:
to show ...In the meantime there is no clear evidence biological with a qi~cn mean absorbed dose, the wheth;u, risk associated with a non-homoqeneous distribution is than. the risk resulting from a more greater or less diffuse distribution of that dose in the lung.29 In effect, to the risk the MPCa particles. The NCRP with respect offers and the ICRP is saying that there is no guidance in the lung, as hence
exposure for
insoluble
plutonium
and
similar
statement
to these
particles:
.,. /
(210) The NCRP has arbitrarily used 10 percent of the ~cltc~,e of the cr~an 2s the si~~.i.ficlnt ?olIur.e fc~ irradiation of the gonads. There are some cases in which choice of a significant volume or area is virtually meaningless. For exa~le, if a single particle of radioactive material fixed in either lung Gr lyn?h no~e Y.cy be carcir,oqenic, the averaging of dose either over the lung or even over one cubic centimeter may have little to do with this case.30 This hot particle community. problem The is also following wel-l recognized is extracted in from a
the bloloqical
29/
30/
ICRP NCRP
cit.,
p.. 4. 79-80.
., pp.
-19q
paper
by Professor
Donald
P. Geesaman:
So there is a hot particle problem with plutoni~~~ in t!:e Lu;lq, ana tile ;hbt ;Jartlcic prO~~.~1~ -s :Iot as to the risk. undersL~Gd, and +Jcre is rlo guidance I donk think there is any controversy about that. s Let :-.7; q~ote to ;:ou f~~;n Cr. K. Z . :.lorqan tcstin;ony ;Tear be fare the Joint CJr.mittce on in Jc.::!:r~r:- t!lis n Atomic Energy, U.S. Congress. [a] Dr. K. Z. Morgan . , is one of the United States two metiers to the main Committee of t!~e International Commission on RadiLIoqical protection; he has been a member of the comof mittee long~r tcan anyone; and he is director Health Physics Division at Oak Ridge National LaboraThere are many things about radiation tory. I quote: exposure we do not understand, and there will continue to be uncertalnci.es until health physics can provide This is why a coherent theory of radiation damage. some of the basic research studies of the USAEC are so and Tamplin have pointed important. D. P. Geesaman out recently the-problems of plutonium-239 particles and the uncertainty of the risk to a man who carries such a particle of hiah specific activity in his lungs. :,t che sa::: hea~i:ig, in response to the committee s inquiry about. priorities in basic research on the biological effects of radiation, Dr. M. Eisenbud, then Director of the New York City Environmental Protection Administration , in part replied, For some reason or other the Darticle problem has not come upon us in quite. a little while, but it probably will one of these . days . We are not much further along on the basic 2 question of whether a given amount of energy delivered to a progressively smaller and small&r volume of tissue This is another is better or worse fcr the recipient. calculate the dose way of asking the question of how you when you inhale a single particle. [b] He was correct; the pro~lem has come up aqain.
,.
[a]
,.. . .. ., 1.
Standards for Reactor Siting, Morgan, K. Z., Radiation in Environmental Effects of Producinq Electrical Power presented at Hearings before the Joint Phase 2. Testimony Committee on Atomic Energy, 91st Congress, 1970. Washington, D. C., U. S. Government Printing Office. Eisenbud, M. Panel Discussion. In: Environmental Effects of Producinq Electrical Power, Phase 2. Testim~y presented at Hearings before the Joint Committee on Atomic Energy, o 91st Congress, 1970. Washington, D. C. , U. S. Government
\,-
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[b]
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-20q
In the context of his commcnc it is interesting refer to the National Academy of Sciences , National Research Council report of 1961 on the Effects of Inhaled RadioactiT~e Particles. [c] The first sentence reads, ~he potential !lazard due to airborne radioactive particulate is probably the least understood of the hazards associated with atcmic weapons :ests, vrcd~ction of radioelements , and the
expa.rLdi~Cj use o~ ndclear erlerCj>7 for Fotier prUduct~CJII.
to
.-.
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J . !. . .,
1,
A decade later that statement is still valid. Finally let me quote Drs. Sanders, Thompson, and Bair from a paper qi.enby them last October. [d] Dr. Bair and his colleagues ha~e done, the most relevant plutonium iJonuniform irradiation oxide inhalation experiments. of the lunq from deposited radioactive particulate is than uniform exposure (on a clearly more carcinogenic total-lung dose basis) , and alpha-irradiation is more carcinogenic than beta-irradiation. The doses required for a substantial tumor incidence, are very high, however, if measured in proximity to the particle; and, again, there are no data to establish the low-incidence end of a do>e-effect curve. And there is no general theory, or data on which to base a theory, which would permit extranolatior. of tb.e h.iqb.i~fl~ . e+ -Aw+.in- of . uA..k, . Snm-n yA k&.. the cur-re into the low incidence region. I agree and I suggest that in such a circumstance .it is appropriate to view tk.e standartis with extreme caution.31 .
:9 . . . ,.
?,.
,,.
* ., i
[c] . ,. /
u. S. NAS-NRC Subcommittee, Effects of Inhaled Radioactive Particles. Report of the Subcommittee on Inhalation Hazards. Committee on Pathologic Effects of Atomic Radiation. National Academy of~ Sciences - National Re~~ar~h cg~:~cil, ~~as~inqt-n, D. C. 19610 Publication
848.
,, .., ,.
NAS-NRC/PUB-848,
1961.
[d]
Sanders, C.L., R.C. Thompson, and W.J. Bair, Lung Cancer: .Dose Response Studies with Radionuclides. In: Inhalation Carcinoaenesis. Proceedings of a Biology Division, Oak Ridge National Laboratory, conference held in Gatlinburg, Tennessee, October 8-11, 1$)69. M.G. Hanna, Jr., P. Nettesheim, and J.R. Gilbert, eds., U. S. Atomic Energy Commission Symposium Series 18, 1970.
pp. 285-303. (CONF-691001) .
Geesaman, Donald P. , Plutonium 31/ and Public iiealth, Lawrence Livermore Laboratory, Calif. , GT-121-70, April 19, 1970, reproduced in Underground Uses of Nuclear Eneray, Part 2, Hearings before the Subcommittee on Air and Water Pollution of the Committee on public works, U. s: Senate, gist Congress, Znd Session August 5, 1970, pg. 15#)-J532. ~.,~.u-. ,, ,,,;V= x,.- :-$+:; . ~ ..., : j~y- :; . . :*+ . b%;, .,. :$:. ~ ;.. ,.. i, ,,,,, , : -1 :Xq$%j$;;.::: :, ~~: ~.:; ,,, ,, . ,,~gg:. ,., , 41!$!F .=% +- U.,. -.-.
-21q
comments,
referenced
by Geesaman,
can be added
of Dr. A. B. Long:
there is an u~-qent need to ciispcll the sense of secur~ty and certainty that the present limits for the maximum permissl~ie lur,g burden and the nti:<im.d;n permissible air ccnccr.zration bri:;g . . . the pubiic should be informed of the uncertainties that exist . in these limits. 1132
v.
Biological
Data
Related
to Cancer
Risk
from
Insoluble
Plutonium, Particles We have result at very We said that shown that insoluble alpha-emitting They particles can irradiate fatal. suggests
radiation. organismdata
or organ strongly
biological
a DF=l
underestimates
the DE
greatly cancer
in error. induction
We now d by
intense
relevant
.
in judging constitute
or not risk.
insoluble Geesaman
particles and
a unique
analyzed
the pertinent
experiments,
and what
32/
Long,
A.B.,
OQ .
.
q
-22-
analysis
33
, which
has become
hypothesis.
performed in rat
a number
of
induction
study
carcinoma
exposed penetra1.
various are
of maximum
The dose
response
curves
reproduced high
in Figure doses
the response .
at sufficiently per
(1000post was
rat by when
It was
that
to a skin curves
depth
of 0.27
became
continuous
,.
</
Geesaman,
D.P.,
UCRL-50387
Addendufl,
O-.
cit.
34/ Albert, R.E., F.J. Burns, and R.D. Hei~ach, The effect of penetration depth of electron radiation on skin tUmOr formation in the rat, Radiation Res. 30, 1967, pp. .
51S-S24.
~ 35/ Albert, R.E., F.J. Burns, and R.D. Heimbach, skin damage I and tumor formation from qrid and sieve patterns of electron and beta radiation in the rat, Radiation Res. 30, 1967, pp. S25-540. 1
36/ Albert, R.E., F.J. Burns, and R.D. Hei~ach, The ~sociation between chronic radiation damage of the hair follicles and tumor formation in the rat, Radiation Res. 1967, pp. 590-599.
-23-
depth
is near
the base
of the hair
comprises
he deepest layer,
it was suggestive .
carclnoqenesis. that
The most
suggestion
gained - .
of the tumors
rat was
of atrophied
hair
in this
remarkably
damage
to and When
exposures
geometrical induction
effects
were
observed: was
most
notably
in the sieve
qeometry
suppressed
was,again
consistent hair
with
the reduction
in damaqe
7
as characterized
by atrophied
To summarize
.
of cancer and
was
observed
intense
doses
of radiation, or
the carcinoqenesis
proportional architectural
to the unit
damage
of a critical
of the
tissue,
follicles.
> ,.,
% .?:
,...
-,9... -. .
.-,+., ,,
-24.
8
A
I
~
7 6 I
O,cfimnl
1.65 mm
m 0.75mm e 1.40mm
.
data) 1
(iuppl
dots)\
o
DC3cC!0.27~ ~r~~ Fig. 1.TulllGr incidencewiih respectto ;uY!~cedose at GO ::ec~s011 three Pcnet:-atio:l depths o{ e~cctrcns. Fig. 2. Tumor Incidencewith respect to the dose at a depth oi o.~~ ~rn in the skin at 80 weeks ior thrct penetration ciep!hs electrons. of
. ..
Source
of Figures:
Albert,
Res.
30,
515-524,
Figures Addendum,
UCRL-50387
-25q
carcinomas
and
sarcomas
in rats radia-
exposure
of the skin
to ionizing
Cancer
induction Even
experiments.
and Glucksmann
for rabbits, ,, sheep, and s}~ine were 38-41 the small number of animals . Despite at Hanford
relationship for 37/ Withers, H.R., The dose-survival irradiation of epithelial cells of mouse skin, Brit. J. Radiol. 40, 1967, pp. 187-194. 38/ Hulse, E.V., Tumours of~the skin of mice and other cf Tice usir.g ~iayei ef~ects L: SXZCL-r.Ql Lets irzadiaticn 90Sr and ~2P, Brit. J. Cancer 16, 1962, pp. 72-86. 39\ Boag, J.W. and A. Glucksmann, production of cancers-in ~ts by the local application of Beta-rays and of chemical in Radiobioloqy, J.S. Mitchell, -arcinogens , ?roaress . B.E. Holmes, and C.L. Smithl eds. Proc@etiings Of the ~~ur=~~ International Conference on Radiobiology held in Cafiridge, Oliver and Boyd, 1956, pp. 476-479. Edinburgh, 14-lq August 1955. ? Grcss effects of beta rays Georqe, L..%. and L.K. ~~stad, 43/ Biology on the skin, Hanford Atomic Products Operation, Research Annual Report for 1956, H1f-47500, 1957, pp. 135-141. . 41/ Georqe, L.A. II, R.L. Pershinq, S. Marks, and L.K fibrosarcoma in a rabbit following beta fistad, Cutaneous Hanfozd Atomic Products Operation, Biology irradiation, Research Annual Report for 1959, HW-65500, 1960, pp. 68-69. 42/ Ragan, H.A., W.J. Clarke and L.K. Bustad, Late effects Battelle-Northwest Laboratory Annual of skin irradiation, Report for 1965 in the Biological Sciences, BNWL-280, 1956,pp. 43/ Karagianes, M.T. , E.B. Howard and J*L =rthwest Laboratory Annual Report for 1967 of Biology and Mcdicinej Vol. If Biological 1968, pp. 1.10-1.11
13-14.
-26
P32 plaque
surface an average
of 16,000
rad
from which
larger
mammals
intense
radiation that
obseroccur .
incidence
does
doses. radiation of animals frequency of the subcutaneous by Pu-239 of cancer has and
lnductlon to tell
what
these
experiments
trying
interpretation
of these unit
a critical
architectura~
1 I
a hair the
follicle)
is irraciiated
at a sufficiently
I ,
chance This
canc~rous as the
is approximately Geesaman
10-4.
known
Related the
Human
abova
experiments .
it is pertinent
to ask whether
is more
: ,..
Induction 44/ Sanders, C.L. and T.A. ~ackson, of Pu02 Activity, and Sarcomas From Hot Spots Vol . 22, No. 6, June 1972, pp. 755-759.
, ,+ ,
r, ,,
45/
Li.sCO, Herman,
,..
~Y !
361-363.
i,
:!..
..
&
-27-
sensitive
to such
intense
localized
radiation.
c. c.
as the result The particle on
T ~.k:~hbauch rcpcrtcd
of residual :ontained Pu-239 0.08 Ug
a puncture uci)
of U-239 of the
Commenting the
the histological
examination
authors of
to the into
area
of ionizing
present. therefore
and effect
relationship the
of these was
findings, minute,
, seemed
obvious.
Although Their
lesion
~.!-.z changes
,,. :. ,.,
,. *.. ,, ... . ., .,. ,>
.!
in it were epidernal
. se-~~r~. cytologic
si~ilarity
changes,
of course, a lesion
of the ultimate
fate of such
,:!; * ,, .. ,. .,
than
0.1
produced
tissue. There
very
smaller This
of PU-239 lesion
have
produced
changes.
precancerous irradiates
that
a single
particle and
a significant cancer. .
(critical)
volume
tissue was
is capable
of inducing
The Lushbaugh
46/
Lushbaugn,
C.C.
and J. Langhamt
~~
? PPo
461-464
-28i
t!le total
nunaer treatment
of punct~re of such
47
The
so that
total
by plutonium
Theru~cre
suggest
insoluble
ulutonium that
of cancer
#
induction
in man
qreater
1/1000
In other 4
words,
a critical
susceptible would
as analyzed case
by Geesaman
A second that of
of plutonium .
particle not
is
He was
associated
AL . LLULAL-. A..uti-i.~ ~lJt ~:,?~~ ~reiq,ht ]1.an?.ler ~ ~~ho oacied, un.1 U.LC -..elm-w <-,-7,,CLW.. t . rotated leaking arid reloadefd a crate carboy of Pu-239 that was . contaminated by the He
solution
which
an infiltrating eventually
sarcoma
resulted
this
cdse
worker, cancer
was
induced with
unfortunate
contact
Pu-239
to a lawsuit,
/i
(d
b, ,.
in Puncture Wounds, 47/ Vanderbeck, J.N., Plutonium ~nford Laboratories Operation, July 25, 1960.
HW-661
!, !!
I
, .,
PRIVACYACTMATERIA~REM~vED ~
-29-
This
suit
was
eventually in t!lis B
A discussion
of the evidence
case by one of the aut!!ors is presented of this report. two cases, drawn from the
in the Appendix
These
relatively suggest
small that
number PU-239
of individuals
so contaminated,
strongly
that
a sinqle dose
particle
is capable
of delivering of tissue
radiation
tc a critical
volume like
irradiated probability
an atrophied as 1/1000)
as high
of becoming
cancerous .
c .. Related
The a hiqhly repairable ,. skin
Lunc
experiments dose
disruptive mammalian
to a snail frequent
pcrtio;. G:
tissue one
carcinoqenesis. is essentially
per that
anikal
to expect
substances
to induce
cancers
and rats
48
to derive experiments
any characteriza.
of carcinoqenesis
Cember,. H., Radioqcnic lung cancer, Progress in fiperimcntal rumor Research, F. llotiurqcr, ed. New York, l{afner Publishing Company, Inc. , Vol. 4,, 1964, pp. .251-303.
48/
>U
~~l~ti JII The wo~k involving deep of Laskin~ respiratory curve was e: ~t tissue, for lmq
nac ~gec:fi~ll~i
demonstrate a source does 49 .A RU-106 tlsdue . in the bronchi bronchial of rats, and
implanted to arise
obser!~ed
from
tine response
response at 0.008
a substantial
approximately and a S1OWI over three orders of tur.or incidence d source intensity.
first-year from
bronchial were
collowed .
death
it was
the tumor at death. cancer 106 rad fortified of Sr-90, rats . was
incidence
increased dose .
with
the dose a of -
an accumulated aPProximacely
the
incidence beads
. two-thirds with
glass and
TU7C r S
experiment
Cerber
particles.
J.H. Nelson, B. Altshuler, 49/ Laskin, S., M. Kuschner! N. lunq in rats exposed ~rley and !4. Daniels, Carcinoma of the of intra-bronchial ruthenium16 pellets. to the beta-radiation Cancer Inst. 31, relationships, J. Natl. Dose response 1. 1963, pp. 219-231. ~rom a RU106- coated Altshuler, B. , Dosimetry . 50/ Radiation ResQ Z 1958, ~p. 626-632. ~llet,
q
platinw
J,.. ,, . v. % >.. -
..,,-,,.,-
-31q
a burden
.
range
to 50 uCi 51 .
the observed
tumor
incidence
fluctuated
between
and 0.3
All of these
., ,
lurl;experiments level
exposures
damage
is Bairs was
study
52-!j4 . beagles ,
Exposure
of 0.25
u or 0.5 u median
diameter; that
Twenty
survived Many
exposure
cancer. The
of these
cancers appeared
multicentric
cancers injury.
in conjunction
lung
of the disease
is small,
it appears
tha,t
of exposure
of lung span.
durinq
the normal
,.
5~/
Cember,
H., o~.
~.
Cldrket Lon9-term 52/ Bair, W.J. , J.F. Park, and W.J. Battelle Memorial Institute study of inhaled plutonium in dogsf (Richland) , AFWL-TR-65-214 , 1966 (AD-631 690) .
. .
53/ Park, J.F., W.J. Clarke and W.J. Bair, Chronic effects Battelle-Northwest Laboratory ~ inhaled 239Pu02 in beaqles, Annual Report for 1967 to the USAEC Division of Biology and Sciences, BNWL-714, 1968, Medicine, Vol. I, Biological PP 3.3-3.4.
in Beagle Dog Studies with Park, J.F., et al, Proqress ~ansuranium Elements at Battelle-Northwest , Health Physics, 6, June 1972, pp. 803-81O. vol. 22, No.
54/
time,
since
the
pathological
response
is saturated
experiment, tie
L~~~~itUde
in a dog
showing
0.2 uCi. of cf
this would .
burden
which
by orders
nagnitude
of cancer. tissues, t of
may,
per particle
in the neighborhood
1/1000 to 1/10,000.
VI ;
Critical
ParticleActivity
hich
cancer per
As the particle .
size
activity
is reduced indeed,
surroufiding size
at sufficiently expect
or specific
activity,
one would
of cancer
in rat
indicates
in the dose
1,000
55
suggests before
particular unique
level
of tissue response
carcinogenic
occurs.
experiments
t PP
515-5
-33-
Laskin,
a significant suggesting
carcinogenic a comparable
response sensitivity
in the lung
rem,
5L that the tissue repair of lurlg tiswe . Gcesalozn indicates 57 time in the lung is of the order of one year . It therefore seems appropriate that but this not necessarily enhanced cancer . irradiate rem/yr t}~c s.drr:d~ldinq conservative, risk occurs to accept particles
as guidance
when
lun,g ~is=~e
or more.
IV
. to Give a Dose of
and Size
(u)
59
. . .,,
,
56/
57/
58/
P.,
activity
given
by Lanqham,
W.H. I
., ., .:. .
AS
Seen
Ci-cnT-ib!e
an alpha
Cccsamans 0.02
lun~ pCi
a pCi
particle
with
between
is required tissue.
t~ give
a dose
of 1000
rcm/yr
to irradiated
lung
isotopes
as the
report,
will which
imply
a particle
at least tissue.
limiting
is insoluble
in lung A.
Exposures at Rocky Flats . The AEC has a plutonium facility associated with its . This nuclear wea~or.s ?ro~ram at Roc-ky Fiats, Colorado.
,..,. .,
. ,:!, * i
facility Chemical
is operated Company.
under
contract
to the
AEC by
The employees,
the environment
60-62 /
particles as a result of the operation here of this the plant. information It is, therefore, pertinent r to examine
60/
Mann,
J.R.
and A.R.
Kirchnev,
0~.
cit.
61/ Poet, S.E. and E.A. Marten, Plutonium-239 and ~ericium-241 in the Denver Area, Health Physics, Vol. 1972, pp. 537-549.
of Plutonium Information 62/ Richmond, Chet, Transcript ~etinq of the Advisory Committee on Reactor Safeguards, Los Alamos, N. Mex., 5 January 1974, pp. 319-320.
23,
-.. .
. . ,V:! ,,, . . ..
~..
\ ., .. . .,
;5,,\
:. . ,,, ,. .,
facility
and
to relate
this
to the hot
particle
problem.
..
,
R. A. Kirclmer fire
discuss
. . .
at Rocky working
Flats
,., .,.
1965.63
!,
were
time
.,, /
the
These counter
employees
placed
in a whole
t9 determine
their
Mann
reported
only
exposed
llPLBof 0.016
V presents .
25 employees.
and Kirchner of the
estimated
fraction hot
activity of hot
(uCi)
particles
the number
particles
represents.
,.
63/
Mann,
J.R.
and
R.A.
Kirchner,
0~.
~.
-36b
Flats
Number of
Hot Particles
1 3 19
*
Mann and Kirchner presented the lung burdens as number of MPLB. These have been converted to uCi in column two using l?PLB=O.016 luCi. (For the groups with 3 and 19 cases, we selected the midpoint.of the reported range.) The hot particie buriien in coi~n~. :hree -,~?asstin.ated by n.~ltiplyinq e the tatal burden by 0.i7, the fraction of the activity on particles above. 0.6 u, and 0.70, the fraction of initial deposited activity that was involved in long term retention in the lung. Based on particle size data reported by Mann and Kirchner, we estimate the averaqe hot particle activity is ~~ ~ !d&- .24 p~i. U ;..= ::~ntiefs c: llct particles in the last coiulr, were obtained by dividing the hot particle burdens in column ,three by the average hot particle activity (0.24 pCi) . r
Allowinq
.
a risk
equal
per
hot are
suggests in Table
individuals high
exposures
V stand
a very
of developing unity. In
cancer respect,
in the experiments
-37. reported by Park, et al, the beagle developed dog with the smallest
64
lunq burden, highest burden i.e. , 0.2 uCi, lung cancer. to the lowest V, the in labie V is comparable
The
; beacjle G:.:~Gsuz.2 ~he lcI/est exposure cases order with lung buzdens less that tine, in the 0.024 than the
19 an
of naqnit~de suggest
lowest
We would
this none
is potentially of these
a serious has
situation. developed
since
and there
is uood
latent
and the development In the beagle associated may be and these dog
than
the lowest
lunq.burden The
with
a latent in man
latent
period
longer
at these
nurher
involved. be expected
individuals to this
Dertinent
data
relative
particle
cancer give
over
the next
these warrant
exposures modifyinq
the
the critical
particle
activity.
64/ 65/
Park,
J.F.,
Physics, p. 320.
OQ . cit.
p. 805.
Richmond,
Chet,
-3u-
B.
exposed latest
66
The
kc ke free
of lung cells
cancer
of several
subjects the
is not
netaplastic
incipient
or actual
lung
indicates
that
a heavy
smoker .
(3 packs/day)
and undoubtedly
subjects
future. lung
not be of
to find
cancer
a group
subjects. vivo
Daring
the latest
examination lunq
of these burdens
measurement
of the plutonium
r
conducted
:.?iththese
~es,dlts: i
An average MDA for a 2000-sec counting time is about 7 nCi if one uses the 95% confidence level.67 For the 68% confidence level and a sim-ilar counting time , the comparable value is about 3.5 nCi.
et al, Manhattan Project Plutonium Year Follow-Up Study of Selected Cases. detectable amount.
to the minimum
-39q
Positive counts were obtained for 14 of 21 persons measured. These counts sugqested chest burdens ranging However, in no case did the from 3 to about 10 nCi. est.inatcd chest b~-:dcn excccd the !.D?\ thfi 95 con~t Spven of the 14 CCL .jccts with pc.sltive fider.ce levei. chest counts had estimated chest burdens of 7 nCi or greater and may be considered (at the 68% level of confidence) to have statistically significant chest burdens of from 7 to 10 nCi.68 Since the plutonium is still in the lung cavity, 27 years
post-exposure
, it is ccrrect form
it was
in the insoluble
and hence
here.
69
initial
subjects
data
if we knew
size
at the time
This
miaht
larger of the
plutonium
fires
where
most
on particles 70
in the
si?e
range
??uch-of the
contamination
68/
Hemplemann,
L.H.,
Op.
cit.,
p. 474.
p. 7.
Kirchner,
,.
-40q
Manhattan liquid
workers
resulted
from
aspiration the
of droplets much
of larger
solltions of plutonium
into
air wherein
At the same time, the activity particle sizes would result. . less of the plutonium in the particle would be considerably than that that for a particle of Pu02. For example, body and it is stated burdens that 1-40 this g/liter of
plutonium occurred
with measurable . the recovery operation in with solutions H202 hood. was
working
containing being
nitrate
to which in an open
added
with in con-
stirring
This
resulted
fizzing-and
of droplets
into
the
a factor in this
of 100). study
the
particles
do not
are delivering
dosages
lower
71/ Recall from Table IV that a 0.07 pCi, the limiting would qive a dose of 1000 rem/yr ~tivity for a hot particle, to the surrounding tissue in a lung inflated to 1/2 maximum. 72/ Of the particles of an inhaled aerosol that are deposited in the deep respiratory zone of the lung, virtually all are less than 5 u in diameter- [Geesaman, UCRL-50387, 0~. cit., p. 3]. from the 40 q/liter solution would correspond A 5 u droplet roughly to the limiting activity of a hot particle.
!,..
.,. ,..
.. .
, ,.
.4..
:,.- .. , .. . aii!f
>! ,.,-.
.,@J:
..;,
t.
~.
-41-
surrounding c
tissue
(roughly
10 rem/yr).
Another
of human
weapon
tests.
weapon that
contain
.< ., ,.. ,
Y.
.,
workers, smaller
in these
particles
,.. ,
in hot
particles.
,, .,. ,.
VII
Exposure Thus
Standbrds
the existinq
,, ,,
!. ...-
that
particle
respiratory between
1/1000
health
associated
with
exposure
quideline?s
standards or lunq
particle
exposure between
by equating types
of cancer vs.
induction
of exposure
(uniform assessment
grossly
non-uniform) associated
recent irradiation of
of the
risk
with
.
q
-42man was performed Biological Effects by the NAS-}IRC Advisory of Radiation. to as the BLIR Their Committee report, on the in
published
1972, is referred
i,
Report.73
A.
Occupational Exposure The existing occupational exposure body irradiation is 5 rem/yr that and
whole
the BEIR
Report
estimates
exposure lead
of an individual
to 5 rerrJyr w6uld
between 4.5x1O
75 lo-3/yr. individual Allowing l/lC,000
-4
and 2.3x10-3/yr.
estimate
74
Their estimate to the is 3x10-5/yr. 76 of cancer 15 rem/yr
a lung
exposure
of cancer induction between 1/1000 and . particle, Table V presents the maximim permissible
radiation
standards
exposure.
values
in Table
V represent
in the MPLB.
A hot particle
of Pu-239
limit activity contains only 0.07 pCi while the MPLB for . ,.. occupational exposure is 1.6x104 pm. Thus the
73/ NAS-NRC, The Effects on Populations of Exposure to ~w Levels of Ionizing Radiation, (BEIR Report) , NAS-NRC, Washington, D. C. , Nov. 1972.
-43q
Gu~dance Lung
E!niLters,
l?~rmissible
Particle
77
4.5X10-4 10-3
0.9
2. 4.6
10. 23.
2.3X1O-3
2.3
represent
a of of be used
of the existing
by a factor
1O,O(-IO. It is recommende&
the effects together particle emitting
..
the best
estimate
of uniform a risk
exposure of cancer
Committee
with
of 1/2000
per hot
particles.
and
is not
!lFL?B
for occupational
of alpha-
77/ The number of particles required equal to that from uniform radiation.
.
to give
78/ Source: BEIR Report, Op. cit., p. 91. The MPLPB ~rrespondinq to a lung can~r =k of 3X10-5 due to 15 rem/yr 156] are 0.03, 0.06 lunq dose [BEIR Report, 0~. cit., p. and 0.3 for assumed particle~sks of 1/1000, 1/2000 and 1/10,000 respectively.
-44. emitting particles. sents implies radionuclides This in the deep respiratory of 0.14 zone pCi is 2 and repreThis Moreover, 115,000 that .to
corresponds of 115,000
to a MPLB
a reduction
MPLB.
it requires a value
of 3.5x10-16 is not
uCi/ml
it is determined
the piutonium B.
Ex~osure
public) Such
e::~jcsu~e.
limit at this
be 9.2
narficles.
on the
average
be contaminated Obviously
by a particle
would
In fact,
particles,
be an overexposure. and .
recommendations
admonitions
of the FRC, ICRP and NCRP. Under certain conditions, sach as widespread radioactive contamination of the environment, the only data available may be related to average contamination or exposure levels. Under these circumstances, it is necessary to make assumptions concerning the relationship between
-43avcrage
COU!2Cj 1
anfl maximum
doses.
that the majority of individuals do not vary from the average by a factor greater than three. Thus, we recommend the use of 0.17 rem for yearly whole-body exposure of average ponul.ation qrnuns. (It is noted that this ;ui~ic is also ~n essential agreement with current recom.menitiLions of the NCIU? and the ICRP.) It i: critical that this guide be applied with reason ~and ]udc~,~~nt. Especially, it is noted that the use of the iverage figure, as a substitute for evidence concerning the dose to individuals, is permissible only when there is a probability of appreciable homogeneity concerning the distribution of e dose within the population included in the average. $9 Strict the ambient While adherence air to these should guidelines be zero could implies that
standard
a variety
a slight
deviation
guidelines implicit
in the
is a workable solution since . Of lung burfl~n: c~~ ~,e fr~~cio:.al g~an:~~ie~. recommend that the and hot MPLPB for members lung of the burden C:
, a factor
79/
FRC
Report
No.
1, ~.
Had we based the standard on a 1/10,000 ~rticle (See Table V), the MPLPB would have particle and this problem would not exist.
80/
risk been
per one
.,
,. . .. . .. . ., ~. J. ,. ., . ..- *. ,.
-46q
particles exposure
implies
that
the
existing
MPCa
to Pu-239
should
ci 115,GG0 that
to a value
of 9x10 19 is not
uCi\ml
is determined
the plutonium
in hot
particles.
c.
There zations release
EXDOSUR
are no direct
orqaniwith of
regardir,g
an acceptable
of radioactivity sites
in an accident. 81 reactors,
purposes site
for nuclear
and preparing
safety
analysis
adopte-d specific
criteria.
(surrounding
area)
must
. .,
(1) An exclusion area of such size that an individual located at any point on its boundary for two hours immediately following onset of the postulated fiission product release wo~ld not rece}ve a total radiation dose to the whcle body dose in excess of 25 rem2 or a total radiation in excess of 300 rem2 to the thyfoid from iodine expcsure .
81/ Fish, B.R., G.W. Keilhalte, W.S. Snyde-r, and S.D. swisher, &apter 7 of early draft version of B.R. Fish, al, Calcuet lation of Doses Due to Accidental Released Plutonium from an (Nov. 1972), p. 128. LMFBR, ORNL-NSIC-74 This chapter was deleted from the final version at the direction of AEC-Division of Reactor Development and Technology because it was judged to be not directly applicable to the objective of the study, and the information base from which it was developed was already available in other documents. AEC-DRDT further stated that it was not removed because of the quality of the work.
,,
The whole bo5y dose of 25 rem referred to above corrc:pozds :~umerically to the once in a lifetime accidental or emergency dose for radiationworkers which, according to NCRP recormncndations may be disreqarde.d in the determin-ition Qi their radiation exposure status (see LJBG iiuntibo~k neither its use 69 dated June 5, 1959) . However, nor that of the 300 rem value for thyroid exposure guides are as set for~:h in these site criteria constitute intended to inpl~~ that these nurbcrs ior emerqency doses to the public lirLits acceptable Rather , this 25 rem under accident conditions. whole body ~alue and the 300 rem thyroid value have been set forth in these guides as reference values, which can be used in the evaluation of reactor sites with respect to potential reactor accidents of exceedingly low probability of occurrence , and low risk of public exposure to . radiation.
criteria
to the
case
These
are also
applicable
J. ,,, ,
,.
.. .. ,, f..,
,, .
First, the wording of sections 100.ll(a) (1) clearly limits the application to }he irradiation of the whole body and the thyroid; no other organ or tissue is mentioned or in~lied. Furthermore, only fission products in general and iodine in particular are Finally, footnote (2) identified as reference substances. states unequivocally that the guides are not to be considered as acceptable limits for emerqency doses to the public under accident conditions.82 Without addressing body whether and
300
the rem
guideline to the
,. ,. ,.
)-$
82\
Ibid,
p. 129.
-48q
be considered accidents
,,
as acceptable
limits,
or whether under
design these
basis
evaluated
criteria we in
are
of exceedingly
of occurrence,
y,::;:
l. -
,
.!
recommend order
that
10 CFR
as follows
, .:/ , .
..
to establish
a hot
particle
is equivalent
,, .. . .
7, .,, ,
to the risk
..4
associated
with
25 rem whole
.
irradiation:
,:,,
.,-
,. . ,
(1) An exclusion area of such size that an individllal located at any point on its boundary for two hours immediately following onset of the postulated fission product or other radionuclide release would not receive a total radiation dose to the whole body in excess of 25 rem2 or a total radiation dose in excess of 300 rem2 to the thyroid from iodine exposure, or receive a lung particle burden in excess of 10 hot ~articles.3
(Unchanged
from original
text)
. ,, /
is a particle that contains sufficient activity to deliver at least 1000 rem/yr to the surrounding lung tissue. For isotopes having half-lives greater than one year, this would correspond to particles containing at least 0.07 pCi of alpha activity. r We also recommend particle under that similar criteria be established facilities not
3A hot particle
limiting
.
hot
releases 100.
for nuclear
now covered
10 CFR
D.
Surface
number
of means,
traffic,
or animal
movements,
-49q
an accident particles,
wherein
surfaces
are
contaminated
with
hot to
to have
a stanclard to arnly
that
can be resuspended
from
has been
subject
of a number
experiments
of a resuspension RF (m-l) =
factor
RF is defined
concentration concentration
R. L. Kathren
values. 83
has
reviewed
the data
obtained
He indicates
to values an ~
to 10-11 although
indicates
that,
is appropriate.
that m-l
of the Danish
scientific
85
We would
th,at
interim acceptable surface Kathren, R.L., Towards ~mination levels for environmental Pu02, BNWL-SA-151O, Northwest Laboratory, Richland, Washington, April 1968,
83/
84/
85/
Ibid,
p. 4.
The Thule DeliberaLangham, Wright H., o~. cit., p. 5. ~ons refer to the deliberati~ following the accidental crash of a B-52 bomber carrying nuclear weapons near Thule The. high explosives in the Air Force Base in Greenland. weapons detonated and dispersed the plutonium.
-50q
the value
selected the
by Kathren ambient
be used when
to determine
ground
contamination MPCa
to the ambient
recornm(.=nde~in the pre~!iaus section, missible of 9X10-8 In areas be shown E. surface uCi/n~. where
we obtain
for hot
particles
an RF greater
to apply, As Low
be altered
appropriately.
as Practicable that
on our
of the
that
be kept
guidelines that
without~delay convene
the
appropriate
.
hearings as low
to determine
constitutes particles.
as practicable
to hot
86/ This value is derived as follows: The recommended MPCa ~r hot particles is 9x1o-18 uCi/ml which corresponds to 9X10-12 uCi\m3. The maximum ground contamination level, using RF=10-4 m-l, is 9x10-12/10-4 = 9x1o-8 uCi/m2.
-51-
VIII
Summary The
of Recommendations rer~mm~.da tion.; aDply a hot particle activity lung to alpha-emitting as a particle at least isotopes 1000 having to 87 activity.
fcllcwinq where
>.. ,
tissue.
half-lives particles
gre~ter containing
v~ould correspond
at least that:
It is reccnx,ended
1.
For
occupational = 2 hot
.
exposure
MPLPB MPCa
for Pu-239
MPLPB MPCa
=-0.2
hot
for Pu-239
q? These particulate would consist of compounds of Pu and the other actnides which fall into Clas~ Y material. in the ICRP would be retained for Task Group Lung !!odel. These materials ~C~p ~ublicati~n 19, ~~. cit., See zor example, years in the lung. Since only particles in the size range of 5 u and below in P. 6* diameter would be deposited in the deep respiratory tissue, this in effect sets an upper limit for the particle size of interest If the half-life is less than or close to 1 year the limit here. of 0.07 pCi can be adjusted upward through appropriate calculations. 88/ This FIPCa applies for particles containing 0.07 pCi of For particles containing more than 0.07 pCi the K-239. For particles MPCa could be increased proportionately. containing less than 0.07 pCi the existing MPCa=4x10 11 pCi/ml The hlPCa for hot particles of other isotopes would apply. and mixtures of isotopes should be established on a similar basis with consideration given to the half-life of the isotope. 89/ Ibid.
-52.
3.
For
accidental
exposure = 10 hot
(10 CFR
100.ll(a)
(l))
MPLIB (2 hours
particles
4.
For MPSC
unrestricted = 1 hot
particle/m2
90
to determine as low as
5.
Hearings
should
be convened
practicable
rcqulations.
. / .-
~/ This value is meant for guidance with respect to decontamination of an unrestricted area that has been contaminated with hot particles. In areas where an RF greater or less than 10-4 m-l could be shown to apply, the MPSC could be altered appropriately.
A Organizations
SeLting Roles
and Their
which recommends basic radiation criThe organization teria and standards at the international level is the on Radiological Protection (ICRP) . International Commission auspices of the Second It was established in 1928 underathe During the early In~ernatio,na~ CfJ::IgrL55of Radiology. primarily with period and until 1950, the ICRP was concerned recommendations desicned to provide protection to members of the medical profession in their diagnostic ar.d therairom radium. peutic use of X-rays and gamma radiation However, since the advent of atomic energy, and radiation it has extended its efforts to include uses on a large scale, studies of radiaticn protection matters covering the whole It works together with its gamut of radiation applications. the International Commission on Radiation sister commission, ~lnits Measurements (ICRU) ,and relies on the ICRU for backorl :adiatiori measdre:ielnts. ground k~Gi~5~qC The Nation~l Council on Radiation Protection and . (NCRP) was organized in 1929, a year after the Measurements ICRP, as a combined effort of several radiation protection committees in the United States to consolidate their voice at meetings scattered efforts and to present a unified The ICRP and NCRP are private groups whose of=the ICRP.1 recommendations are purely advisory. r In 1934 the NC2.Iad~~ted the simple level of 0.1 dose. In roentgen per dayl m,e~~s~~ed in air aS the tolerance 1940, it recommended a permissible body burden of 0.1 microThe latter standard, still in gram for ingested radium. to an average dose- to the skeleton effect today, corresponds of about 30 rem\yr or a dose to the critical endosteal tissue out to a distance of 5-10 microns of about 10 rem/yr.
. .,,, . ,, ,
,..
-,!.
Committee 1/ Initially the NCRP was known as the Advisory in 1946 the name was changed on X-rays and Radium Protection; Radiation Protection and Measureto the National Committee on a Federal charter and took ments , and in 1964 it received its present name.
-A2-
In 1949, the maximum permissible dose for radiation It was lowered again was lowered to 0.3 roentgen per week. as the permissible dose for radiation in 1957 to 5 rem\*,r This stfind~rd is still in effect. workers. The AEC has also played a significant role in setting authority However, the AECS regulatory radiation standards. over materials was, and still is, limited by the Atomic EnergY Act of 1954, as amended, to source, by-product, and sPecial llefore the Federal Radiation Council nuclear material. standards, (FRC) was forr.e~, :lle ;.E2, when setting radiation of the NCRP, generally follo~ied :lcse!.y the reconwendations which in turn paralleled the ICRP recommendations.
.
,, .. .
d
, -, ,,, ,
,.<: ,,
.. .
In 1959, after the advent of the atomic age had aroused public fears over fallout from nuclear weapons I the U. S. government, because of uncertainty of government influence over radiation protection standards, organized the FRC. It was authorized by Congress to .. .advise the president with respect to radiation matters directly or indirectly for all federal agencies affecting health, including guidance in the formulation cf radiation standards and in establishment and execution of ~rccra~.s in cooperation with the states. . .2 The f-inal authority with respect to radiation standards rested Such a subordinate not with the FRC but with the President. agency as the AEC , for example, had to make its rules, e.g. , compatible with the overall those governing licensed reactors, guides developed by the FRC. the 1950s the ICRP and NCRP continued to . Tnrouqhout ,tevise and refine the basic recommendations concerning Standards were permissible radiation exposure standa~ds. recorrunended for some non-occupational groups and for the whole ~.i~.Xi;JU,T population. permissible body burdens and maximum permissible concentrations of radionuclides in the air and in Most of these water were recommended as secondary standards. recommendations were incorporated by the FRC and the AEC. and its duties were transfel-lt-tl In 1970 the FRC was abolished Since that time, the setting of population to the EPA. Population standards, exposure standards has resided in EPA.
.,. .
Material for the Development 2/ FRC Report No. 1, Background Go~rcrnment Printing Office, of Radiation Protection Standards, Washington, D. C. , Play 13, 1960, p. 1.
-A3... ...
,, ...
,.., . :.
.
, ,,
..
,. ..
.,, ,.
in this case, mean exposure to persons. outside the fence Criteria, required E:- liter.sed) facilitiy. of an :~EC (cr :, ~+- 2 v,4,- for plant cmeration and design b.nrl.-.i&*ti, to neet L!lese Hence, present responsibility for remained with the AEC. health effects resides in EpA~ while the asses ??. ent of technology to control emissions res~onsibi li::v for developing The Office of Management and Budget (OMB) resides in AEIC. in a recent letter to EPA and AEC clarified the delegation of responsibilit-] bet%:een these agencies for promulgating that may be emitted regulations to limit the radioacti.;ity OVB s~at~d: IrdustrY from f~~ili:i..~ i- ~~.~ ~:~eT-Y;:;Cr AEC should proceed with its plans for issuing urzr,l~m fuel cycle standards , taking received fran all into accol~.ct .L ~.ie connents . EPA; that EPA should dissources , including continue its preparations for issuing, now for types of or in the future, any standards facilities; and that EPA shculd continue, under its current authority, to have responsibility for setting standards for the total av,our.tcf ?.ti~.tition the cer.eral ep.vironrienh iv. from all facilities combined in the uranium which fuel cycle, i.e. , an ambient standard would have to reflect AECS findings as to. 3 the practicability of emission controls. There axe other agencies ar.i groups which are concerned with radiation standards and ,in some cases have regulatory These include, but are not limited to, the ~authority. and Welfare, Department of Department of Health, Education National Standards Labor , Bureau of 31ines , the American institute, and state agencies. :he radiation standards of For the most part these organizations are not at issue here. they play a secondary role, or where applicable, follow the guidance of the NCRP, EPA and AEC.
Train
and Chairman
Ray
APPENDIX
B for
Statement
Submitted
to Attorneys
Re:
by :
, et al vs. NUMEC
Arth)dr R. Tamplin
The foil-owinu is my analysis of the oriqin of Mr. Ed~~-ard resulted in his :~leasons S05? tl~~dc sarco~l:l that ultimately death and of the Consultation Report, submitted by Dr. Niel Wald, dated Jan. 29, 1973. unleaded , rotated, and loaded a crate con(Pu-239) SO~JtiO~. -:inina 3 le:ki~.o z::?JO;05 ?lLtoniCx-239 ,, This could not have occured without contaminating? the palmr The question is : surface of his lerc hand, which was bare. to develop a ...d this Pu-239 c~r:ta~,ination cause with sarcoma? Since radiation inci~ced cancers are identical it is necessary to consider those that occur spontaneously, the relative chances that the cancer was spontaneous or Pu-239 induced. . The United States Vital Statistics, record a death rate for malignant neoplasrris (othez than melanoma) of the skin in Sines e upper extrcn.it-? c: less thm one per ~.illion per y~~r. and .synovial sarcoma is a rare form that often metastasizes its ,occurrence rate is certainly hence has a poor proanosis, less than the total skin cancer death rate of one per million Thus it is highly unlikely that anyone who handled per year. this crate would spontaneously develop this sarcoma on the . =aninated ha:.d (less th.a Gr.2 chalice in a r.iilicn) . . ,Now let us consider what the chances are of the developcontamination Qf the ment of cancer as a result of plutonium data :ron plutonium skin . Experimental contaminated animals ::-.onstr~te that injection of 1 microgram of Pu-239 into the skin of rats promptly produced cancer in up to 5% of the animals tumors are fibrosarcomas. (Exhibit 1) . The particular Now the analysis done by LASL indicated that the Pu-239 This concentration was about 160 micrograms per milliliter. is reason to suspect, since the volume of liquid was reduced, But setting that the Pu was actually more concentrated in 1963. aside, one drop would be expected to contain between 8 and One-one hundredth of a milliliter 16 microcjrams of Pu-239. (a very small amount of liquid). would have been sufficient to
,.
,.
.. ..
PRIVACY ACT MATERIAL REMOVED ,.., ... ,+. .. .,. . ., f., . .-..j(; . >,.,.,,.,/ . i .. ~ ,. ..f b;::: ,: a, )$:.; ..;),:! ; .. . .. .,.,., $.::;, :,; .(..: ;:, .. , ,:, ,.., . . ~ ,. * - / ,. ,,
b,. . ,. . ,.
,.
-i32. There is little reason to doubt produce sarcomas in animals. or even more that this small amount of liquid (0.!)1 milliliter) palm. In t!lis i>..~r.d its way belcw :!le 5Gr:-FiC!3 of event, his chance of developing cancer would be one in twenty. This is at l;ast 50,000 times higher than his chances of de~sloni:-;.; is o;-rIn other words , the evidence L:le cancer s~ontaneou~l~{. whelminq in favor of the tumor resulting from Pu-239 contamination. The above relative probability is based upon data from than .Lnimals. It i~ quite possible that man i~ more sensitive the biol~gical :ni~als to cancer inducticn by P1~-239 . In fact, Exhibit 2 evidence strongly suggests that man is more sensitive. This nodule is a case report of a nodule removed from a man. Commenting on the histological .~ntained only 0.08 uq of ?u-239. e:,~+~nation of t-e l~~ion , the a~lt~~ors st~.~n~ ,T5@ qut@r~,di~graphs showed precise confinement of w-tracks to the area of maximum damage and their penetration into the basal areas of where epithelial changes typical of ionizing the epidermis, The cause. and effect relationradiation exposure we~e present. Althcagh the ship of these findinqs, th~refore, seemed obvious. lesion was minute, the chanq~s in it were severe. Their . similarity to known precancerous epidermai cyroloaic c:nanqes, Gf course; raised the question of, the ultimate fate of such a lesion should it be allowed to exist without surgical intervention. . . In this case, less than 0.1 ug of Pu-239 produced precancerous chanqes in human tissue. The dose to the surrounding tissue was very intense. There is every reason to believe .~;cta smallar c .Q:ntitf: c: ?u-239 would !-.avepzo:~ced similar changes. . . . d When I consider the above human and ?nimal data toqether with the relative probability of 50,000, I can come to no other .Inciusion than that this sarcoma was a direct result of the . contamination of left Dalm by Pu-239.
.
Turning now to Dr. Walds Consultation Report, it can be stated that he has presented no evidence to disprove the claim that this sarcoma was caused by Pu-239 contamination. I shall discuss Dr. Waldts report in the order that it was written. According to the Division of Inspection Report submitted by Anson M. Bartlett on April 11, 1963, pages 29-30, the January 19 examination was conducted not on , but on The single urine and feces his home, clothing and automobile.
.
-B3.,
camnlcs collected s?.lbsenuent to January 20 qave negative g is that no l-.2sults. The only thir. that this demenstr~tes Even following the indetectable level of PU-239 was found. jection of l.mqe volumes of Pu-239 solution into the skin and -;uscle of animals, the Pu-239 is slowly absorbed and appreciable 1 oreup to 70%, remain at the site of injection. V fractions, over, of the quantity absorbed only a small fraction appears in the urine or feces (see paqe 3, Exhibit 3 and Exhibit 4) . case we are concerned with only a very small .. ~ --o~~n,eof sol.~tion and. P~-~e we should not be s~rprised if we .1----urine or feces obtain negative results in an individual sample. (See also Exhibit 5) The physical exa~.i:lation performed by Dr. Roy E. Albert One would expect no on January 23, 1963, has no relevance. overt signs of radiation injury at this early date from the Ole are concerned sm,all quantity of PU-239 which is at issue here. here with the long tern e ffects, not the acute effects. as recorded by Dr. Wald The medical histor:] of , he -~nears to be accur~.t.e, ~-.~~.;e~ler emitted the concl~sior.s for Special Surgery of the Pathology Report of the Hospital wherein the unanimous opinion of the pathologists was stated to be that this lesion was a synovial sarcoma. The negative findin~s in the feces and urine in April of findinus in the 770 are of no more yele-~ance than the similar . . The whole body counter has a detection January 1963 samples. At issue here are quantities limi,tof 0.3 u Ci of PU-239. below 0.06 u Ci and, hence, well below th- detectable limit.
!, ,. ,
,!
There are three reasons for setting aside the negative . First, findings in the initial tissue removed from no evidence of atypical since the pathologist report indicated it is quite possible that this mass was or malignant changes, Recall here that the histoloqy of unrelated to the sarcoma. the small nodule in Exhibit 2 showed severe chanqes that resembled Third, the site of contamination was precancerous changes. not necessarily removed with the mass or it could have trimmed
from the mass prior to production of the paraffin blocks and slides . Consider here that the nodule in Exhibit 2 was only eventually Since 1/10 of a millimeter in diameter. developed an infiltrating soft tissue sarcoma, and this original tissue removed showed no atypical change, there is no basis for PRIVACY MATERIAL REMWED ACT
,.
-B4-
assuminq that the origin of the sarcoma was included in this tissue mass .
The negative results on the clavicle specimen are also flhe issue here is a small quantity of Pu-239 equivocal. ~hct rem~i;,ed l{;c:.lized in t!le pahmar area cf the left hand. Tilis boricspeci:~cll indicates ol-i~Ythat the amount of systemtoo small to be detected in this bone ically absorbed Pu-239 was specimen. None of these clinical findings are able to set aside the sarcoma was a direct strong possibility that The most likely course result of the plutonium contamination. -f events is that a small quantity of the PU-239 solution in the tissue below (less the 0.01 millilite~) was deposited This may hate occured through a small cut palm. The body then reacted to this material as a or via a sliver. Eventually, a lesion foreign body, and encapsulated it. This nodule similar to that discus-sed in Exhibit 2 developed. progressed beyond the precancerous stage to become an inThe chances are some 50,000 filtrating soft tissue sarco~a. ~~,i~ fa=hion th zn ~e.v.el-ma ~.-A n AuyLu ?iT&CS greater that +h~ sarcma ..AL .kat it o~cured I think spontaneously.
.
to point out that all df the information relevant to this case was available in 1963. been informed of the potential cancer risk Had subsequent to the incident, he could have informed his physicians.
that it is important AS a result they would probably and tli.e tradeqy could have been d have treateci him more cautiously substantially mitigated. r
-B5-
..
Lisco, Herman, et al, RadiOIOgy~ VO1. 49 1 NO* 31 Sept. 1947, pp. 361-363. Lushbaugh, C.C. # et all ~ch~ Oct. 1962, pp. 461-464. Vanderbeck, J. W.t Hw-66172# C)wration, JUIY 251 1960~ s, .,;-. . .. ..- ~,, Matsuokal Mr. , et all Health Of DermatO109Y~ .
HNAford =boratories
010 86,
physics~
VO1O
22/ June
.. ,
1972~
~~.%lsco;:-~erman Walter E. Kesiekeski, American J. and ; - of Pathology, Vol. 29, No. 1, Jan. - Feb. 1953~ pp. 305321* .,,, ~ :. # .,.>.
-.:,
... ,. .-
,.. < ,,
,.. . ,+
is
Ci:
..., .
Curie:
fordAbsorbed Dose.
:!-
A modifying-factor used in calculating dose equivalent which accounts for nonuniforrnd&E~ibution of radiation. - ,, . .:~&,; ; The product of absorbed doseD, quality factor (QF) , dose distribution factor (DF), and other necessary modifying factors (The dose equivalent is-numerically equal to the absorbed dose <n rads multip~ied by The the appropriate modifying factors). unit of dose equivalent is the rem. t ;. :... ::.-..-:.- .. . .,~. . Environmenta~ Protection Agency.<, .&.,. ,, Federal Radiation Counc~l.:.heheFRC has . been aBolished, andits-,,f~ctionq taken over
. .
*<..
.-.
. ,. *..
V,.
.:? ..*.. .
Dose Equivalent:
,
4 ... ;:%.,>.,:.
.-
.- . .
,.
,
..
Abbreviation Half-life:
for gram. . ~~
Time r~quired for a radioactive substance to lose 50 percent of its activity by radioactive Each radionuclide has a unique halfdecay. life.
.
..-: B
!
--b
%.
.. .. iiiliikf.+.-. .:.., c
-.
, -- .;..
Millilitegi,= 0.001 liters. -.,.. - :<: .. . ,..+~.;.; .-. Maximum:peti~ss ible concentration (of a radionuclide) in air. The average corlcentration above background of a specific radionticli.de to which an individual can ,.- be exposedw~thout exceeding the guidelines.
~pcw ~.,.
Maximum @>errnissibleconcentration (of a radionucl$~ej. in water.- ~(See definition above. ) .j~::;j~~-... .,,. .-. ,,:. ,, , .: . ,;:, -..,. .:. ,; , ,:,:*.>=. . . Maximum pek~ssible lungburden. .,.. ,$. Maxixyunp&missj.ble lung dose. . . National Council on Radiation Protection and Measur~em&ts. ..: . .
,.
Abbreviation for picocurie, which is onemillionth-of. a microcurie, or 10-12 curies. -., [:,<., ~ Jr%& .+..::, . ,- .j,. -,. ,,. . :<~F:~&@j:~+$;;~:;. ~ --;,;::---:;:-:-?. f ;..:. -. which i= . Abbrevlat~o~for Quallty Factor, ., . . . assignedon the basis of a number of con.. . . . , .:;~j,&i: .<.
- .. =>.,. . .
pci : ----
mences
Radionuclide:
.$ .+ * . ,., , .,.. . ..
+---
:*
-.
~+
-. -
--, . .
1 ,
..>.
.:*
.-,
..
-.--$p==q
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.-.
&
-i
v==---Q-
.. . . . . ..
.4
.-
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?-
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the ~-:~ > of dos~ e@valent~:~@en appropriate modifyin-g factors are used to calculate dose equivalent one rem is the - quantity of any type of io,n$zing radiation which when absorbed infi-fil~@roducesan
effe-t equivalent to the absorption of at the one rad of X- or gamma-radiation place of interest.
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Roentgen:
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The quantity of X- or gamma-radiation such that the associated corpuscular emission per 0.001293 grams of air produces, in air ions carrying one electrostatic unit of electricityof either sign. For the . purposes here, the roentgen is roughly equivalen~:to *the. rad. .:;-:. :
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Specific tictivity: Total radi~$c~lvity of a givenmaterial (isotopet$lement8 or compound) per 9ram of the material -- curies/9rame
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Ug: