ML19289B975
| ML19289B975 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Haddam Neck, 05000236 File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 10/06/1978 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Ribicoff A SENATE |
| Shared Package | |
| ML19261A242 | List: |
| References | |
| NUDOCS 7810140036 | |
| Download: ML19289B975 (2) | |
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UMTED STATES NUCLEAR REGULATORY COMMISSION h
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v OCT 0 61978 '
Docket Hos. 50-245 -
50-336 and 50-213 bThe Honorable Abraham Ribicoff United States Senate Washington, D. C.
20510
Dear Senator Ribicoff:
This is in response to your request of September 11, 1978 for our comments regarding Ms. Hannum's letter of Septaber 2,1978 which expresses concerns about nuclear power.
.The enclosed copy of the Millstone Nuclear Power Station Final Enviromental Statement describes the areas of major concern to Ms. Hannum in considerable detail. There is a large amount of infomation available on releases from nuclear power plants in Ms. Hannum's locale. Specifically, semi-annual radioactive ef-fluent release reports and the radiological enviromental moni-toring reports for the Millstone facilities are available for review in the Local Public Document Room, Waterford Public Library, Rope Ferry Road, Waterford, Connecticut.
We have examined the concerns raised by the Dr. Sternglass report and his testimony presented last February at the Congressional seminar on low-level radiation with respect to the Millstone station. Our evaluation established that there was no causal relationship between the nuclear plants' operation and somewhat elevated levels of radioactivity in the milk from dairies near the Millstone station. It should be noted that the leveis of radioactivity in the milk taken fra the Millstone area, even before Millstone Nuclear Station was operated, have always ex-hibited a higher concentration than the milk in the Hartford area. These levels appear to result frm fallout from atmospheric weapons testing. The fallout. levels are somewhat a function of regional weather patterns.
Dr. Sternglass' conclusions have been reviewed by the Enviromental Protection Agency, the NRC and an NRC consultant from the University of California - Davis.
Copies of these evaluations are enclosed..
With respect to Ms. Hannum's concern about radioactivity in the milk she drinks, the EPA conducts.its own Enviromental Radiation Ambient Monitoring System (ERAMS) for the purpose of detemining that the intake of radionuclides from all sources in milk consumed
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by major urban oopulations is within established safe. levels for human consumption. The NRC assures that effluents released from mruting reactors ane carefully controlled and monitored. Based on ecue review of the available information including Dr. St.ernglass':
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reports, we have concluded that the somewhat elevated levels of radioactivity in the milk have nat been caused by the operation of the Hillstone or Heddam Neck Stations.,_
Sincerely, (signed)
Winism J. Direks T.:-
Deputy Executive Director for operations
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DISTRIBUTION n-i-
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~ Central Files (Millstone 1, 2 and Haddam Neck)
EEB Reading W. Regan H. Denton
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Enclosures:
E. Case OCA 1.
Millstone Nuclear Power Station EDO 0 ELD Final Environmental Statement
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dated June 1973.
. R. Minogue SECY
' K. G ller 2.
Letter of Chairman Hendrie to E. Lont1 Congressman Dodd transmitting NRC's evaluation of report of Dr. E. J.
R. DeYoung V. Meore Sternglass, dated January 18, 1978.
3.
Letter of H. R. Denton to Congressmag. StelloB. Grimes Dodd transmitting additional NRC evalu-ation of allegations raised by Dr. E. J.
G. Knighton D. Bunch Sternglass, dated July 27, 1978.
L. Barrett 4.
Letter of Douglas M. Gostle (EPAQ to J. S Congressman Dodd transmitting EPA's
_ Eh r ED0-04528) evaluation of report of Dr. E. J.
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>+ernglass, dated August 9,1978.
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PE Boyd PDR l_The Honorable Christopher J. Dodd EDO Crutchfield EEB/Rdg United States House of Representatives Dircks Groff Washington, D. C.
20515' Rehm Case Minogue Shapar
Dear Congre'sman Dodd:
Levine Ertter (ED0-02850)
At the request of the Nuclear Regulatory Commission, Dr. Marvin Golhan, an NRC consultant, performed an additional review of the allegation raised by Dr..Sternglass concerning the level of strontium and cesium in the en-vironment around nuclear facilities in Connecticut. Dr. Golttaan's con-clusion is supportive of our previous review of this subject, which was provided to you by letter dated January 18, 1978 from Chairman Hendrie.
Dr. Golean is presently the Director of the Radiobiology Laboratory, University of California-Davis and is retained by the WRC as a scientific consul tant. Dr. Goldman is a member of the National Council of Radiation Protection (NCRP) and the New York A' cademy of Sciences. Additionally, Dr. Goldman has served on advisory committees for the Food and Drug Ad-ministration's Bureau of Radiological Health and the National Academy of Science's Ad Hoc Committae on " Hot Particles " Dr. Golcksan's expertise in the area of environmental radioactivity and radiobiology is further exemplified by his being the recipient of the AEC's E. O. Lawrence Award for 1972 for contributions to the " understanding of the effects of bone-seeking radionuclides, in particular, the quantitation of the metabolic, dosimetric and carcinogenic characteristics of long-term strontium-90 exposure."
We consider the enclosed evaluation of the Sternglass report a fulff11 ment of our commitment to you to examine in detail the findings of Dr. Sternglass.
Most radiobiologists assume that there is some risk associated with any radiation exposure, regardless of how small. We feel the risks from expo-sure to the very low levels of radiation associated with the routine opera-tion of nuclear power plants such as those in Connecticut are extremely small in relation to the other competing risks associated with living a useful and satisfying life. Nevertheless, we recognize that such judgments are valus judgments, and others may not always agree with our perception of the risk involted.
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RETYPED PER H. DENTON - SEE Harold R. Denton, Director ATTACHED YELLOWS FOR PREVIOUS Office of Nuclear Reactor Regulation OCx CONCURRENCES
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Enclosure:
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,p31,197 TO:
U. S. Nuclear Regulatory Commission FROM:
Dr. Marvin Goldman Recent reports of Dr. Ernest Sternglass regarding radioactivity and RE:
health statistics around nuclear facilities in Connecticut.
I was asked to serve as a consultant to the Nuclear Regulatory Commission in this matter and to review and comment upon two reports by Dr. Ernest Sternglass.
One is " Strontium-90 Levels in the Milk and Diet near Connecticut Nuclear Power Plants," dated October 27, 1977, and the other appears to be testimony dated February 10, 1978 for a Congressional seminar and is titled " Cancer Mortality Changes Around Nuclear Facilities in Connecticut." Although I am Director of a large radiobiology laboratory at the University of California, the views ex-pressed herein are entirely my own and in no way imply any endo,rsement or assess-ment by the University of California or the Federal agencies who support the Laboratory's research.
For the past 27 years I have been engaged in radiobiologic research related to the dosimetry, metabolism and pathology of radionuclides.
In particular, a major effort involves studies of radiostrontium and its effects.
Dr. Sternglass alleges that levels of strontium-90 (physical half-life of about 28 years) and cesium-137 (physical half-life of about 30 years', around Haddam Neck and Millstone Point nuclear power plants have been increasing mark-edly as a result of plant emissions and that these levels pose a " serious threat to human health."
I do not agree with these conclusions.
In reviewing the information avail-able to me I conclude quite the contrary. There are several reasons that prompt I
me to seriously question the validity of Dr. Sternglass' conclusions.
k One central factor relates to the well known fact that Sr-90 and Cs-137 are 9
long-lived fission products resulting from the fissioning of fertile elements such as U-235 and Pu-239. Furthermore, it is also well documented that as a
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result of r.tmospheric weapons testing (especially some 15 years ago) that the a
entire land surface of our planet is, to a variable and frequently measured degree, contaminated with low levels of these (and some other) radionuclides, f
It is also known that when uranium-235 is fissioned, a host of radionuclides of
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varying half-lives are generated. This is true of both weapons related fission-ing and of nuclear fuels in an operating reactor. One additional fact that j
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ss seems to have not taken into account is that recent fission product 7-
-.ill contain short lived radionuclides as well as long-lived radionuclides.
a 7($on of short-lived radionuclides will decline-with time after fiss
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lived. species may be detected in environmental
- -f. j ate times only the long-es. - This ability to "date" the radioactivity, or at leas dnt origin is an important and relatively " fool proof tool."
That Sr and Cs both exist in freshly produced fission products in the form of several isotopes is fortuitous and significant. Generally speaking, consider-ably more "short-lived" Sr-59 (half-life %50 days) is produced and to a limited extent released than th tlenger-lived Sr-90.
In terms of relative activity, de-pending on sampling time, t sout 5 pCi of Sr-89 might be released for each pCi of Sr-90. Thus even correcting for the decay of radioactivity from " release" to incorporation into the food chain (e.g., milk and other locally produced food stuffs), there must be some Sr-89 present in foodstuffs with Sr-90 of recent origin. The nuclear plants do record the annual totals of both strontium iso-topes released and do record the levels in their periodic environmental samples.
If this is true, my question is where is the Sr-89? The methodology seems to be sufficiently sensitive to have picked this up following some Chinese atmospheric weapons tests; both Sr-89 and Sr-90 (e.g., 10/5/76 pamples of milk which also showed 8 day I-131) were measured.
Furthermore, the alkali earth element cesium is represented by shorter-lived isotopes, particularly the 2.1 year half-life Cs-134 This isotope is released along with the Cs-137 from nuclear reactors in very small quantities (e.g.,1972 Millstone 16.4 Ci Cs-137 plus 8.8 Ci Cs-134). The activity ratios are similar -
about the same number of microcuries of each isotope released annually.
Since their respective decay emissions are sufficiently different, any detector sensitive enough to identify one can distinguish it from the other - their gamma ray and r
beta particle energies are different. 'Ihus, I must question the conclusion that the Cs-137 measured in food stuffs was recently released from the nuclear plant in question.
If so, where was the Cs-134? There are no pathways to man which separate these two isotopes of the same element. The element cerium will behave like cesium whether it is Cs-137 or Cs-134 The element strontium will behave like strontium whether it is Sr-90 or Sr-891 In light of the frequent sampling schedules, it is not possible for the short-lived radionuclides to have decayed to non-detectable levels relative to those measured for the longer-lived isotope. Thus, I am forced to conclude that the only explanation for the data shown is that whatever the nuclear plants re-leased was completely masked by the " background" level of Sr-90 and Cs-137 from fairly old atmospheric deposits, i.e.,
earlier weapons tests.
The Sr-90 and Cs-137 shown in national monitoring data varies from place to place and with time.
In food stuffs, some of the variation is related to the degree of fresh foliar deposition on vegetation and. cattle forage as well as root uptake from soil depasits.
In addition, the local rainfall pattern may " wash on or off" varying amounts of atmospheric fallout on vegetation surfaces, as well as leaching more deeply into the soil that which was deposited on the surface.
Globally, millions of dollars have been spent on studying and quantifying these phenomena and their variations. Depending on how one calcalates a mean or average value, individual samples may vary by ten fold i repeated sampling N60 026
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i d t jcernglass seems to have not taken into account is that recent fiss on p Mr7s"willcontainshorclivedradionuclidesaswellaslong-livedrad f
fissioning 9e fraction of short-lived radionuclides will decline with time a t d in environmental and at late times only the;1ong-lived species may be,detecte This ability to. "date" the radioactivity, or at least confirm it is of recent. origin is an imporant and relatively " fool Proof tool."
samples.
That Sr and Cs both exist in freshly produced fissio'n' products in the formG of several isotopes is fortuitous and significant. ably more "sholt extent released than the longer-lived Sr-90 pending on sampling time, about S pCi of Sr-89 might be released for e Thus even correcting for the decay of radioactivity from " release" to incorporation into the food chain (e.g., milk and other locally produced food Sr-90.
stuffs), there must be some Sr-89 present in foodstuffs with l
topes released and do record the levels in their periodic environmental samp e origin.
If this is true, my question is where is the Sr-897 sufficiently sensitive to have picked this up following some Chinese atmosphe weapons tests; both Sr-89 and Sr-90 (e.g.,10/S/76 samples of milk which also showed 8 day I-131) were measured.
Furthermore, the alkali earth element cesium is represented by shorter-lived This isotope is released isotopes, particularly the 2.1 year half-life Cs-134.
along with the Cs-137 from nuclear reactors in very small quantities (e.g.
Millstone 16.4 Ci Cs-137 plus 8.8 Ci Cs-134).
Since about the same number of microcuries of each isotope released annually.
ii their respective decay emissions are sufficiently different, any detector sens t ve enough to identify one can distinguish it from the other - their gamma beta particle energies are different.the Cs-137 measured in food stuffs was in question. If so, where was the Cs-134? There are no pathways to man whi The element cesium will behave separate these two isotopes of the same element.The element strontium will behave like cesium whether it is Cs-137 or Cs-134 like strontium whether it is Sr-90 or Sr-89!
In light of the frequent sampling schedules, it is not possible for the short-lived radionuclides to have decayed to non-detectable levels relative those measured for the longer-lived isotope.
the only explanation for the data shown is that whatever tie fairly old atmospheric deposit.s, i.e., earlier weapons tests.
- Ihe Sr-90 and Cs-137 shown in national monitoring data varies from place to In food stuffs, some of the variation is related to the place and with time.
degree of fresh foliar deposition on vegetation and cattle forage as well as root In addition, the local rainfall pattern may " wash on uptake from soil deposits.or off" varying amounts of atmospheric fallout on veget as leaching more deeply into the soil that which was deposited on the surface.
Globally, millions of dollars have been spent on studying and quantifying these Depending on how one calculates a mean or phenomena and their variations. average value, individual samples may v 2 %0 027
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Mik Cs-137 in April.vs. May 1976 for U. S. cities). The time trends
^7[ific levels have shown me no' significant levels which I feel can be-
$puted to plant releases. On the contrary, the data strongly indicate that
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,Sr-90 and Cs'-137 measured in-food pathways samples are almost all', if not ancirely, the result of atmospheric weapons test fallout.
A fatal flaw in Dr. Sternglass' analyses is the manner of selection of data. One cannot select a particular sample as meaningful unless the other accompanying radionuclides are all present and the environmental pathway moni-toring is consistent. n us, for milk _to contain nuclear plant Sr-90 and Cs-137, it must also have the other nuclides, Cs-134 and Sr-63 (and I-131 I might add).
These findings would have to be confirmed by air ani liquf d samples and the plant monitors would also have to have shown "down stream" increases.
I do not find support for these requirements and conclude that the local measurements are reflections of the local temporal wescons fallout situation.
Another problem of apparent misinterpretation of data relates to the re-porting of cancer death rates. Connecticut probably has one of the best state tumor registries in the country and I would imagine. that the State officials may have their own ana1Yses of the trends of cancer mortality.
I reviewed the gen-eral statistics on cancer published annually by the American Cancer Society in its " Cancer Facts and Figures." For example, it' was of interest to note that in the United States, overall cancer mortality has steadily risen from about 160 per hundred thousand in 1970 to about 170 per hundred thousand in 1975. The ACS published annual Connecticut rates which are generally in agreement with these values.
I did not check on the State registry as I wished to determine whether the State was following a different trend than the Nation. Tht data for both Connecticut and the U. S. show increases which are largely influenced by the increases in both sexes of lung cancer related to cigarette smoking.
If Sr-90 was indeed increasing, and it does not appear to be the case, its deposition in the body would incur an increased dose to bone and marrow. Strontium is an alkaline earth element which concentrates in skeletal mineral as does calcium, j
about one thousand fold greater than in other tissues. Extending this hypothetical situatien further, one might have expected an increase in bone cancer u.d *1eukemia g
were serious skeletal and marrow irradiation resultant from radionuclide burdens.
i There is no data in support of this.
I calculate that between 1 and 3 mrem per t
j year is absorbed by adults and children respectively from milk containing a con-stant picoeurie of strontium-90 per liter.
If I accept a milk concentration of i
about 10 pCi Sr/ liter, this would account for about 10-30 mrem per year to bone 90 ard about 3-10 mrem per year to marrow. This value is close to that which we all receive from the traces of radium present in our drinking water.
What health effec:s might result from skeletal irradiation associated with Sr-90? The National Academy of Sciences estimates that about 0.2 bone cancer deaths per year would be expected per population of one million per rem absorbed.
His would translate in a Connecticut population of about 3 million to 0.6 bone cancer deaths per year per rem and also to 0.6 cases times 0.03 rem (30 mrem) or 0.018 cases per year attributable to the Sr-90 skeletal dose. Using these conservative estimates, one would predict about 1 such death every fifty years consequent to a 30 mrem bone dose added to the State 50 year total of 1000 to 2000 deaths from this disease (I estimate a bone cancer death rate of about 1
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,.,800 per year in Connect:icut; i.e., about 30-40 per year). 'Ihere are j ays of calculating radir. tion cancer risks, but I. included this example
, pc the risk per absorbed dc se question in perspe.tive and in a ' form which It is,not possible.for.Sr.,90' body.
j, frequently used by exper< s in this, field.
wrdens derived by ingestion to induce cancers f n.other organs to the exclusion of bone and marrow since the rac'ioelement concentrates so preferentially in skeletal mineral.
In conclusion, I have not found support for the contention that the Connect-icut nuclear plants have released sufficient radionuclides (Sr-89, 90 and Cs-137, 134) to hsve caused significant radiation exposure of -he population; such expo- _
sures are a minute fraction of those attributed to atmospheric nuclear weapons tests..Furthermore, the radiation doses associated with Sr-90 (from all sources) are very significantly below those associated with observable unanges in cancer risk. As a final note, it is generally accepted by the National Academy of Sciences that bono cancer risks from prior radiation would be accompanied by a latent period of about 15 years, and not six years.
I can only conclude that the variations in health statistics presented by Dr. Sternglass, if correct, are associated with events totally unrelated to *,he operation of the nuclear power plants in Connecticut and that there is no evidence-to support the allegation that these plants have posed a " serious thrett to human health."
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