ML19318D230
| ML19318D230 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/16/1980 |
| From: | Drey K External Citizen/Individual/Media (Affiliation Not Assigned) |
| To: | Ahearne J NRC COMMISSION (OCM) |
| References | |
| RTR-NUREG-0662, RTR-NUREG-662 NUDOCS 8007080226 | |
| Download: ML19318D230 (4) | |
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515 We t Print Avenue
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d University City, MD 63130 g.Q(
June 16, 1980 j
Dr. John Ahearne, Acting Chairmen, and Members, U.S. Nucisar Regulatory Commission Washington, D.C. 20555
Dear Ccionissioners:
I am writing as a citizen, housewife, and mother to express my concern about the Nucisar Regulatory Commission's decision to allow Metropolitan Edison to release an estimated 57.000 curies of krypton-85 into the environment from Three Mile Island. I can well appreciate the fears you must have about the amount of destruc-tion the essential safety equipment inside the plant has already experienced and is continuing tu experience. Harold Denton was quoted in an Associated Press story on June 9, 1980, se saying, "Each day there are things going on inside the plant that we can't account for."
I understand speed is of the essence if a criticality acci-dont is to be averted. However, I would urge you to take careful note of the health hazards of radioactive noble gasse, including krypton, before you decide how best to proceed.
The claims that noble gases are not hazardous and that the quantities proposed for release are not significant are contravened by the following facts:
A. Some facts about the health hazards of noble gasess
- 1. If inhaled er swallowed. noble cases can cause ohvsical harm while passing through the body or if entrapped within it.
i While radioactive noble gases may not chemiem11v interact with the body (that is, form chemical compounds in the body), they can obvsically interact. They give off physical energy as radiation, in the form of particles. The radiation is able to penetrate body tissues. It can kill a call (such as when gamna radi-ation used in cobalt therapy kills cancer and nearby healthy cells), or if the radiation hite a DNA molecule in a body cell, it can initiate a process of mutation that eventually over a period of years could lead to cancer.
t A sadioactive particle has weight, a d since it is moving, has velocity - that n
is, it has energy and momentum. If it bumps into a DNA molecule in a call, depending on its speed, weight, and the angle at which it hits, and depending upon the spot at which it hits along the length of the DNA molecule (that is, which gene or part of a gene it hits), the particle's impact can give rise to a more or less serious mutation. Any change in the structure of a DNA moleculo is called a mutation.
The physical energy of the radioactive particle can change the structure of DNA, just as when a car that is standing still is hit by a car in motion. If the par-
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ticle mutates a gone that produces an enzyme that is not particularly vital to the cell's machinery, the damage may not even be noticeable. On the other hand, if it j
mutates a gene important to cell function, very serious manifestations can occur -
particularly cancer and other life-shortening diseases (e.g., diabetes, or circu-
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latory, respiratory or muscular diseases).
t Gene "A* may produce Enzyme "A" which produces homaglobin (a protein which goes into red blood cells and carries oxygen). However, a small percent of genes are operator or repressor genes. Such a gene manufactures an enzyms (i.e., protein) that does not carry out a body function per se.
Rather, it exerts control over a group of genes within that same cell. In fact, it may control as many as a dozen or more other genes and may even control a whole metabolic pathway. For example, when a person eats starch, it is broken down step-by-step into a fuel type the body can use. At each step there is a different enzyme which was manufactured by a specific gene. Gene *3" may manufacture the first enryme in the pathway. If that gene mutates because of damage fran radiation or from a chemical, the first step in the pathway can be blocked. However, in some cases the body has secondary i
pathways, and thus may be able to get around the one blocked step. An operator or repressor gene, on the other hand, may produce an enzyme that simultaneously t
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turns on or off a number of different genes, each of which manufactorse an enzyme that controls one of the steps in a metabolic pathway, such as for the breaking
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, down of starch. When a gene of this type is mutated in an egg or sperm cell, such 3
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a large segment of the metabolic pathway may be blocked that the body cannot crin.
pensato, and a very serious health effect results.
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l An operator or repressor gene may also control cell grcwth and replication. If
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Dr. John Ahearna, Chairman, and Members of the NRC June 16, 1980 the gene is damaged, the cell can begin to grow out of control. Eventually it may show uo as cancer, perhaps years later.
If the particle emitted by the noble gas atom hits DNA in a cell that develope into a seem or an eco cell (i.e., a reproductive cell or a precursor of a repro-ductive cell), the particle can cause a mutation whia:h can manifest itself as a ceaetic defect in the, offspring for generations.
Some of the above may be considered speculative within the relatively new field of molecular biology. Few scientists, however, would deny that a radioactive parti-cle emitted by a nobis gas or other atom is capable of causing mutation of a ONA molecula.
- 2. Some noble ces isotooes 11so have hazardous deuchter creducts:
Solid decay products (the isotopes into which the gases are transformed as they give off radioactive particles) may be radioactive themselves and thus continue to emit radioactive particles and rays, or they may be stable. Solid daughter products can collect on dust in the air or can settle on vegetation or un grasses to be con-sonned by cattle. Or if noble gases have been inhaled or swallowed, they can decay into solid daughter products while within the body, i
A daughter product can be both chemically and physically harmful. That is, it can becme involved in chemical reactions within the body (determined by whAch kind of chemical element it is and thus by its particular chemical properties), and, if it is radioactive, it can emit energy in the form of particles and gamma rays. If the daughter product is radioactive and becomes incot,2 rated into the body by replacing a stable element, it can continue to irradiate neighboring tissues and organs for l
years, depending upon its half-life.
4 Some of the daughter products of the noble gases xenon and krypton, which l
are released routinely from nuclear power plants, are notoriously toxic both chemical-ly and radioactively. Two noble gas daughter products, strontium-90 and cesium-137, 4
I along with radioactive iodine, were considered to be the most hazardous products in fallout from the atmraphoric atom bomb terts in the Pacific islands and in Nevada / Utah during the 1950's and early 1960's.
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- a. Krvoten davahter creducts: The only isotope of krypton I have seen mentioned I
among the materials presently tracped within the reactor building dcme at Three i
Mile Island has been krypton-85, which decays to rubidium-85, a stable isotope.
However, it must be evident that not only krypton-85, with a half-life of 10.76
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j years, but other shorter-lived krypton isotopes, as well, have already been re-leased from TMI to the atmosphere since the accident began 14 months ago, and l
in fact would have been released routinely since the initiation of the plant's operation. The same would be true of xenon, another radioactive noble gas which
.J is created by the fissioning of uranium, and is released readily through fissures and miniscule openings in the uranium fuel rod cladding, and ultimately to the environment. And m gn, including argon-39 with a 265-year h.31f-lifel Those radioactive krypton atms which decay into radioactive rubidium in turn, then, decay into strontium. In the body strontitan behaves chemically like calcium and therefore is easily incorporated into bone. Once there it can con-tinua irradiating nearby tissues and bone marrow for the rest of the irradiated person's life. Krypton-90 has a short half-life of 33 seconds, and may therefore quickly decay to levels undetectable by most typical power plant monitoring systems. But it is present nevertheless. It decays to rubiditan-90 with a half-life of 2.9 minutes, and then becomes the notorious, high-energy beta particle emitter, strontium-90, with a half-life of 29 years! Strontium-89, whi s emits an even more powerful beta particle, has s half-life of 52 days and is a daughter d
product of krypton-89. Both krypton-89 and xenon-138 were mentioned as having i
been released to the environment during the accident at the Crystal River reactor in Florida on February 26, 1980. They are also, of ourse, released routinely.
A daughter product of the krypton isotopes with atomic mass numbers 74 through 79 is radicective bromine, an extremely toxic chemical that can burn eyes, skin, lungs or any tissue it touches.
- b. Xeacn dauchter creducts: An estimated 13 to 34 militan (I) curies of xenon-0 3 were released from Three Mile Island within the first nine days of the accident.
Xenon-133 has a half-life of 5.27 days. Ancther important isotope, xenon-137, was t
Dr. John Ahearne, Chairman, and Members of the NRC June 16, 1980 also no doubt releasad. It has a half-life of 3.9 minutes. That is, after about four minutes, half a gram of the xenon will have decayed into cosim-137, another infamous atom bomb fallout substancs with a half-life of 30 years. Sci-4 entists estimate that a radioactive material loses its radioactivity after from ten to twenty half-lives.
The behavior of cesium in the body is like that of elements such as sodium and potassium which perfoUn important bodily functions. In other words, when cesium enters the body it tends to concentrete in the liver, spleen and muscan tissues, j
just as cotassium does, and, if radioactive, igrediates those organs with pene-trating high-energy game rays and with beta particles. When incorporated into the body in an insoluble form, radioactive casius particularly affects the lung, stomach and intestines.
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Another example of a xenon i W.c Mat yields daughter products known to be o is xenon-143. The decay chain of this particularly harmful to human t,.
s isotope includes cesium 143, bariw143, lanthanun-143, cori so-143, and praesodymium-143, the latter deczying into stable (non-radioactive) neodymium-143.
One of those chemical elements, cerium, has only recently been recognized as an especially toxic byproduct of nuclear fission, and particularly the cerium
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isotopes 141, 143, and 144 As stated in the recent National Council on Radiation Protection and Measurements DCRP) Report No. 60s "These three isotopes, all of which are beta emitters, are abundant products of nuclear Ussion reactions and i
have moderately long radioactive half-lives." (Physical. Chemical. and Biolooi-cal Procerties of Radioceriun Relevent to Radiation P-otec. ion Guidelinest f
issued December 19783 page 1).
Cerium is now known to produce " irradiation of internal organs, especially the lung, liver, skeleton, and gastrointestinal tract."
Q),M., p. 77). These biomedical effects, as well as the pathways by which scluble ceriun in particular becomes a part of the human foco chain, ere discussed in the NCRP report.
B. Some facts about the magnituda of the estimated (!) nunber of curies proposed for release in June 1980 fras TMI:
One of the most extraordinary and disturbing documents I have read regarding the i
Three Mile Isisnd accident is the April 12, 1979, memo issued by Mr. Lake Barrett of the f#C's Envirorenantal Evaluation Branch. As you know, according to the memo entitled " Preliminary Estimates of Radioactivity Releases from Three Mile Island,"
Mr. Sarrett and his colleagues estimated that approximately 13 million curies of xenon-133 had been released within the first nine days of the accident - that is, j
from 4:00 a.m. on March 28 through April 5, 1979. According to the same memo, i
l Lawrence Livermore Laboratory provided a "very rough estimate" on April 4 of the release rate as being from 20 to 50 curies per second of xenon-133. To quote f A:s page 3 of the Barrett memo: "This corresponds to 14 million to 34 million curies j
of Xe-133 through April 5 which is consistent with the NRC estimate of 13 million."
I realize that the above quantities refer to the estimated release of only one isotope (atomic weight of 133) of only one element (xenon) during only the first nine days. Surely other isotopes of xenon were released during that period and subsequent.
ly, as were other radioactive materials that escaped past the saturated filters in the form of gases, particulates and steam. Even e w, months after shutdown, it has been l
estimated that sore 65 isotopes in addition to krypton-85 are trapped in the reactor building d me, voiting to be vented. The quantities and types of isotopes released can only be estimated since, according to testimony presented to you on June 21, 1979, by Albert Gibson, all the radiation monitors at TMI went off scale the first morning, and at least one important filter that had been removed for analysis that day at 8:00 a.m. was lost (" misplaced"). (from testimony, Public Meeting Briefing on Facts of TMI Radiological Sequence, pp. 47-52).
Although no one really knows the magnitude of the Isleases those first days, or since, j
it seems to me that any physician or scientist associated with a medical institution would be incredulous if told that as much as 13 to 34 million curies of radioactivity
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had been released to toe environment. Corpare the abase with the caution exercised j
by the personnel at the Washington University Medical Center here in St. Louis i
- 1. The total amount cf radioactive material present at the medical center at any one time is aporoximately 28,015i curies - all but about nine curies of which is in sealed containers. This amount includes
- a. Two teletherapy units - one with 12,000 and one with 10,000 curies of ccbalt-60.
The radiation source it totally sealed except for intervals o*
few minutes or
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'Dr' John'Ahearne, Chairman, and Membora of the NRC.
June 16, 1980 less when a columnated beam of game radiation is released to kill cancer cells in a patient - a dose of perhaps 1000 reds.
- b. Three irradiators with 2000 curiss of cesium-137 each - used for irradiating laboratory animals, grafting tissues, etc. Also totally sealed.
- c. Anotbar 15t curies used for diagnosis, research, implants and therapy - of which only about 9 or 10 curies are unsealed sources. All the research laboratories associated with Washington University share about five curies a year. Scientists, physicians and technicians work with picocurie amounts (trillionths of a curia), nanocuries (billionths), microcuries (millionths) or,at the most, millicuries (thousandths of a curie).
- 2. Scene additional facts to help put the 13 to 34 million curia release into perspectives
- a. It costs Washington Urtiversity and associated institutions $160,000 a year to have from four to five curies of radioactive wastes shipped for burial to one of our nation's three remaining commercial low-level radioactive waste dumps (in Nevada, South Caroline or Washington),
- b. At the very most en natimated ten mil 11 curies - 10 thousandths of one curie -
of radioactivity may be accidentally released in any one year to the environment frca the entire Washington University Barnes Hospital, and Jewish Hoscital facilities.
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- c. It is recomended in a memo dated December 8,1978, from the Washington Univer.
sity Division of Radiation Hazards that anyone who routinely works with I
radioactive iodine-125 (half-life of 60 days) in quantities of more than 500 microcuries have periodic thyroid scans.
- d. If a cotton swipe rubbed along an accessible surface of a esaled ra(iation source indicates leakage of fifty nanocuries (that is, 50 billionths of one curie, or one-half of a microcuria) or more, the unit must be take9 out of I
service for repair at once.
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The people who generate the public relations messages for the nuclear industry have e
i been saying since March 28 or 29,1979, that the Three Mile Island accident demonstrates t'at the TN! safety systems worked and that the radiation was contained. Please speak the truth to the American people, particularly to those who are unfortunate enough to l
live downwind of TMI - and to others who share the same atmosphere and the same planet, ii Sincerely.
Mrs. Leo Drey (Kay) l cc: President Jim y Carter i
Governor Richard Thornburgh The members of the Kameny Comission who j
issued a dissenting opinion.
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