ML070790165
| ML070790165 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 03/13/2007 |
| From: | Gavin E - No Known Affiliation |
| To: | NRC/ADM/DAS/RDB |
| References | |
| 71FR76706 00026 | |
| Download: ML070790165 (8) | |
Text
[Ver-montY-zý,keeElS - F-wd: comment on dIaff SESrprM~tpT--D5 9ae From: Eleanor Gavin <elliegavin~comcast. net> /
To: <VermontYankeeEIS~nrc.gov>
Date: Tue, Mar 13, 2007 6:37 PM 0:K
Subject:
Fwd: comment on draft SEIS report, Malistop T-6D59
>To: VermontYankeeElS~nrc.gov
>From: Eleanor Gavin <ellIiegavi n~comncast. net>
Subject:
comment on draft SEIS report" Mailstop T-6D59
>PO Box 215, East Charleston, VT 05833
>1-802-723-6621
>March 8, 2007
>Chief, Rules and Directives Branch 1
>Division of Administrative Services
-77~
>Mailstop T-6D59 -
>U.S. Nuclear Regulatory Commission .)
>Washington DC 20555 i'
>1 found time to reread this amended comment and made some changes
>which are highlighted in green. I keep learning more and more on i.H
>the web. I found out that the highly respected Harvard Professor, 7))Cf
>Stephen J. Gould wrote along with Golding in the 1990s a book called 0
>Deadly Deceit . This proved beyond a shadow of doubt that
>radioactive, beta emitting isotopes that lodge in the body over a
>long time are, by far, the most powerful source of cancer causing
>radiation coming out of a reactor. That a short but high
>release, is less dangerous than a long term release such as we have
>with the huge quantities of tritiated water that have been released
>from the Illinois reactor and which was brought to the attention of
>the Atty. General of Ilinois last summer (2006). It was said in
>papers I read that these releases of Tritiated water can well be
>frequent for many reactors and that it is a real problem that has to
>be addressed somehow. Does the VErmont Yankee have released of
>tritiated water?
>Design, Construction and Installation of the First
>U.S. BWR Off Gas System,
>Vermont Yankee
>As a consultant for the Yankee Atomic organization, NUCON evaluated
>processes for a permanent off gas system for the Vermont Yankee
>plant. The NUCON recommended system was chosen for permanent
>installation. However, before the system could be completed, it was
>necessary to install and operate an interim system in order to
>satisfy USNRC licensing requirements. NUCON was given the contract
>to design, site fabricate and install the interim system. The entire
>activity from project initiation to successful operation required
>only six months. NUCON also supplied the hardware and
>instrumentation for this project and performed startup services.
>This NUCON system withstood an earthquake, lighting strike and flood
>without significant damage. ~-4 h / ' -
6Qu~6 1Z'-
~~ e9l
ILNermontYankeeEIS---FWd: comment on draft SEIS report, Mailstop T-6D59 Page2~
ILYermontYankeeElS - Fwd: comment on drafrSElS report, M~lstop T~D~9
Dear Monsieur,
le chef of Rules and Directives Branch,
Dear Mr. Richard L Emch,
Jr. , Senior Project Manager, Office of NRR,
Dear Mr. Rani L. Franovich,
Chief, Environmental Branch B, Division
>of License Renewal, Office of NRR,
>11. For your convenience, I attach my statement which was sent to
>you by overnight mail from Northern Vermont at noon, March 5,
>2007. 1hope it got in on time. I have since done more research on
>the web and found a report about the levels in strontium 90 in
>teeth. Ifyou would like to hear a synopsis of this and more recent
>reports, please go
>to: www.traprockpeace.org/tooth-fairy project.html You will see a sentence:
>"Hear the interview, ready for radio use:
><http://www.traprockpeace.org/audio/mangano~radiation.m p3>MP3 audio
>- 18:56 minutes; 3.3 mb; or for dialup connections: Real Auto
>. Then click on Real Auto:
>2. Mr. Franowich, I gave my copy of the Institute for Energy and
>Environmental Research most recent newsletter entitled "Science for
>Democratic Action" If you want to read it on line, please to to:
>http://www.ieer.org/sdafiles/index.htmlVolume 14, Number 4 (February 2007)
>Special Issue: Healthy from the Start: Building Better Environmental
>Health Standards [PDF 700kB] and especially see the excellent
>article on'Tritium
" I am more and more convinced, the more time I spend
" googling, that all the reactors in the world must find ways to
" prevent tritium from escaping. Since the escapes were uncovered in
" Illinois last summer, it is evident that this is a weak point that
" an agency (the NRC) with mission to assure the safety and security
" of nuclear power plants, must pursue vigorously. Ifthere is no
" adequate solution, these plants must not be relicensed and they
" should all decommission as soon as the grid they support has found
" through efficiency and alternative energies, ways to assure
" adequate supply to the customers.
" Tritium is hard to remove from emissions. There must be
" invented a cost effective way to remove it and isolate it from the
" environment for the 12.3 half life and double that. In fact it
" should be isolated from the environment for 250 years, or 20 half-lifes.
" Women, embryos, fetuses, babies, toddlers and young
" children have more water per mass unit in their bodies than the
" 30 year old Caucasian male. Up until recently, since Tritium is a
" type of water, it was assumed that it would spread out equally in
" the body and thus the targeted ionization of cells in any specific
" organ of the body would be low. But it turns out that Tritium goes
" to areas where the percent of water that fills any given space is
" the highest. All human life evolved from the sea. The ova and
" embryo are filled with water, the fetus floats in water. The
" Tritium passes the placenta and enters these structures at one time
[VermontYankeeElS - Fwd: comment o-n diaff-SEIS rep-ort, Majisto T-6D59 _P-age 3
" or another of their development. Tritium isotopes have an affinity
" for the nucleii of cells and they lodge right near them,
" irradiating the DNA inside the nucleii. The DNA is
" damaged. Later, up to five to ten years later, the child can
" develop leukemia.
" As for the Strontium 90, that too is rising around
" reactors as statistics show. It lodges in teeth and near
" bones. The marrow of bones produces the cells (T cells, etc) that
" form the Immune system. The immune system is the body's defense
" against colds, the flu, asthma, cancer, etc. If it is weakened,
" these diseases may be expressed, or in the case of colds and the
" flu.. there is less defense and once contracted less T cells to
" fight the infection. If the T Cell's DNA is affected, it is
" possible that these cells would attack functioning tissues as if
" they were the enemy, and this would manifest itself as one of the
" many horrible, chronic auto-immune diseases such as Multiple
" Sclerosis. I have not read the latter anywhere but it stands to reason.
" This opens the field very wide. Reactors are amazing
" things but -unfortunately they are not cost effective and Wall
" Street knows this. They are being forced to operate longer to pay
" for their decommissioning and/or the safe storage of waste,
" etc. It seems right perhaps to have them run a bit longer, but
" only if you can be 100 percent sure that the emissions of Tritium,
" Strontium 90, radioactive Cesium and Iodine, etc. are prevented
" from being exhaled from the emission stacks. Is there a way this
" can be done?
>3. When reactors shut down the amount of leukemia in young children
>goes down.
>4. Here is the part that could well pertain to the Vermont Yankee
>and Strontium 90. even though it is based on other reactors.(
>Joseph Mangano and associates have had 21 peer reviewed articles
>accepted in scientific journals including Lancet.)
>1 took the following from:
> International Journal of Health
> Services March, 2006
>A SHORT LATENCY BETWEEN RADIATION EXPOSURE FROM NUCLEAR PLANTS AND
>CANCER IN YOUNG CHILDREN
> Joseph J. Mangano, MPH, MBA
>1 tried but could not cut and paste the graphs that went along with it.
>"The second part of this report examines the effects of radioactive
>emissions, as detected in the bodies of children. The average
>Strontium-90 concentration in baby teeth was measured for over 4,000
>American children, most residing near nuclear power plants. The
>ratio of Sr-90 per gram of calcium at birth in each baby tooth was
>measured in a radiochemistry laboratory, using a scintillation
>counting technique.
>Average Sr-9O concentrations were analyzed by the birth year of the
i[VermontYankeeEIS - Fwd: comment on draft SEIS report, Mailstop
[VermontYankeeElS Fwd: comment on drafFS~ElS7eport, Majistop T-6D59 T-6D59 Page 4 I
___fagýe
>tooth donor, since much of the Sr-90 uptake in deciduous teeth
>occurs during pregnancy and early infancy. Temporal trends in Sr-90
>averages were compared with trends in cancer incidence for children
>under age ten in counties near nuclear plants with the largest
>numbers of teeth. These plants include Suffolk County NY (near the
>Brookhaven National Laboratories); Monmouth and Ocean Counties NJ
>(near the Oyster Creek plant); and Putnam, Rockland, and Westchester
>NY Counties (near the Indian Point plant). The correlation between
>these two trends will be assessed using a Poisson regression
>analysis testing the hypothesis that they are related. Linear and
>quadratic correlations will be tested, using the actual value,
>square root, and fourth root of Sr-90 averages.
>The specific methodology to calculate Sr-90 concentrations for each
>tooth has been described previously (66) (67). Teeth from Suffolk
>County were analyzed using a Wallac WDY 1220X Quantulus low-level
>scintillation spectrometer, while a Perkin-Elmer 1220-003 Quantulus
>Ultra Low-Level Liquid Scintillation Spectrometer was used for other
>teeth. In addition, the method used to clean teeth before testing
>differed between Suffolk and other teeth; a more sophisticated
>preparation for non-Suffolk teeth, plus use of a different counter,
>allowed more Sr-gO to be detected. However, results for each area
>are internally consistent, allowing Sr-90 patterns and trends to be analyzed.
>Sr-90 results are compared with cancer incidence diagnosed in
>children age 0-9 who resided in counties near nuclear plants at the
>time of diagnosis. Cancer registries from the states of New Jersey
>and New York provided counts of incident cases, while the U.S.
>Census Bureau counts and inter-censal estimates for resident
>population were used. Three-year moving averages, rather than
>individual years, are used for both Sr-9O and cancer rates, to
>increase statistical power of the comparison.
>RESULTS
>1. Three Mile Island
>In the 34 downwind (north and northeast) counties closest to of
>Three Mile Island, the SMR for cancer in children age 0-9 rose 23.8%
>(0.87 to 1.08) from 1979-1983 to 1984-1988, the periods 1-5 years
>and 6-10 years after the accident. The crude cancer mortality rate
>age 0-9 in the 34 counties increased 3.6%, compared to a national
>decline of 16.4%. Because the number of local deaths in each
>five-year period (127 and 135) was relatively small, the rise in SMVR
>is of borderline significance at p<.09. (Table 4) While the SMVR for
>leukemia fell from 0.95 to 0.88, the ratio for all other cancers
>combined rose from 0.83 to 1..17, statistically significant at p<.03.
>Table 4
>Change in Standard Mortality Ratio (SMR), Children Age 0-9
>After the 1979 Accident, 1979-1983 vs. 1984-1988
>34 Counties North/Northeast and Closest to Three Mile Island
>SMR (Deaths)
>Type of Cancer 1979-1983 ,1984-1988
1'rVerm e6loýe-eEISý--FW& comment on dfaft-SlEfg -report, MiiksýtoT 6D59 Pagepj IFVermontYankeeElS - Fwd: comment on di~frSETS report, M~iIstoF5T-6D59 rage ~
>% Change SMVR
>All Cancers Combined 0.87 (127) 1.08 (135) +23.8 p<.09
>Leukemia 0.95 (48) 0.88 (35) - 6.8 p<.90
>All Other Cancers 0.83(79) 1.17 (100) +41.0 p<.03
>Source: U.S. Centers for Disease Control and Prevention,
>http://wonder.cdc.gov, underlying cause of death. Uses ICD-9 codes 140.0-239.9.
>2. Chernobyl
" From 1986-1990 to 1991-1995 (1-5 years and 6-10 years after the
" accident, the SMVR for cancers age 0-9 in the 18 states with the
" most fallout from the Chernobyl accident rose from 0.97 to 1.06, a
" significant increase (p<.02). The crude cancer death rate age 0-9
" declined 6.6% in the 18 states, compared to a reduction of 14.0%
" elsewhere in the U.S. The SMVR rise for leukemia (0.90 to 1.01)
" exceeded that for all other cancers (1.00 to 1.07). Neither
" increase achieved statistical significance (p<. 10 and p<. 13). (Table 5)
>Table 5
>Change in Standard Mortality Ratio, Children Age 0-9
>After the Chernobyl Accident (May/June 1986), 1986-1990 vs. 1991-1995
>1 8 States With Sites With Highest Average 1-131 Measurements
>SMR (Deaths)
>Type of Cancer 1986-1990 1991-1995 % Change SMR
>All Cancers Combined 0.97 (1501) 1.06(1466) + 8.7 p<.02
>Leukemia 0.90(434) 1.01 (422) +11.5 p<.10
>All Other Cancers 1.00 (1067) 1.07 (1040) + 7.0 p<. 13
>Source: U.S. Centers for Disease Control and Prevention,
>http://wonder.cdc.gov, underlying cause of death. Uses ICD-9 codes 140.0-239.9.
>3. Counties Near Nuclear Plants (startup before 1982)
>The SMVR for all cancers in children dying before their 10Oth birthday
>in the most populated 20 areas near nuclear power plants cited in
>the 1990 National Cancer Institute report increased, for 17 of the
>20 areas, from 1-5 to 6-10 years after plant startup. Table 6 shows
>the total Standard Mortality Ratio rose from 0.99 to 1.18.
>Because of the large number of deaths in each period (587 and 590),
>the change was statistically significant at p<.003. Only one of the
>20 changes near individual plants (Shippingport) was statistically
>significant. The increase in SMVR for leukemia (1.00 to 1.22)
>exceeded that for all other cancers (0.98 to 1.15). Both increases
>achieved statistical significance (p<.03 and p<.05, respectively).
>Thank you for adding this comment to the one you received by mail.
>1 thank you for all you do to keep the nuclear plants as safe as
>possible, and where found impossible, to decommission them and
>provide for the long term isolation from the environment, which
>basically means all contact with water and even in some instances air.
>Sincerely,
1,Výe~i~o~ntY~ank~eeElS - Fwd: c-iomm~ent -on draftSE ls rep-ort, M--il-stop T-_D-5_9 P~age 6
>Eleanor 1.Gavin
>RN retired,
>PS..l am a mother and grandmother. I am the wife of Dr. Paul H.
>Gavin, retired nuclear engineer for
>Combustion Engineering/AseaBrownBoverilWestinghouse, in Windsor,
>Connecticut.
>PPS We are the parents of three Professors: civil and environmental
>engineering at Duke; researcher, in molecular biology in the field
>of immunology, specifically Rheumatoid Arthritis, at AmGen, in
>Seattle; and paleo-ecologist at the Univ. of Oregon inEugene,
>OR. Our second son has Ryder's Syndrome, an auto immune disease-and
>our third son's wife has cherubism, a genetic disease of the jaw
>bone which continues to grow and may need an operation if it presses
>on veins and nerves. Both these diseases, as far as we can find
>out, never existed in the parents or ancestors of these, our
>children. The couple with Cherubism will not have children because
>it was so hard for our daughter in law growing up and they do not
>want to inflict this on any human being. She is now an OB - GYN and
>enjoying caring for mothers and delivering babies. All three sons
>and their wives are interested in seeing the reactors being
>decommissioned unless the statistics can be ameliorated and unless
>they are allowed to have independent assessments of their
>engineering, their safety and their security on a regular
>basis. They and we understand that an Agency, must have guide
>lines, but this is a Democracy and people have a right to demand
>independent oversight, hear both sides and decide on their own if
>they want to see these old reactors to be pushed to 120% more power
>and to be pushed beyond their original licensing period.
>PPPS That reminds me. Both Paul and I are curious what you mean
>when you said at the meeting in the Montpelier Pavillion Bldg. that
>the original licensing was made "short" i.e. 40 years for economic
>and anti-trust reasons, that they are really constructed to run for
>60 years, on average.
" PPPPS Our whole family is grateful for Paul's gainful employment
" in this area, which would not have been possible without the
" devotion and indefatigable efforts by nuclear engineers to exploit
" this type of energy, as responsibly as they could. But now we
" would like them to be put to bed as soon as possible. Maybe in a
" century or so there will be new way of handling ionizing
" radiation. Adult males do tolerate well a certain background
" level, but we are finding for -- women, ova, embryos, fetuses,
" babies, toddlers and children -- that going beyond that in a
" targeted area of the body, i.e. receiving low level beta radiation
> over a period of time is extremely dangerous and should be avoided
" at all costs. Women now have a 58% greater chance of coming down
" with cancer.. One of 8 women contract breast cancer.. both of these
" are very substantial increases and they happened in a time span of
" a few decades, I believe. I think it is only over the past 4
" decades that this kind of epidemiology has been done so assiduously.
>1 realize there are other factors, mainly hazardous substances, some
>are even natural, that depress the immune system and make a body
I[Venýýothank~&eEIS--F~w-d: comment on d1a-ftSE[S T--6D-5-9
-repoft7,M-ailstop P-agie 7,
>more sensitive to cancer. I realize that people are getting
>radiation if they fly a lot. But all those areas have to be addressed too.
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Subject:
Fwd: comment on draft SETS report, Mailstop T-61)59 Creation Date Tue, Mar 13, 2007 7:36 PM From: Eleanor Gavin <elliegavin @comcast.net>
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