ML19347D307

Affidavit Re Ed Background & Research on Nuclear Power & Specific Facilities.Certificate of Svc Encl

ML19347D307
Person / Time
Site:	Callaway
Issue date:	03/06/1981
From:	Drey K AFFILIATION NOT ASSIGNED
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ISSUANCES-OL, NUDOCS 8103120403
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DomEnr UNITED STATES OF AMERICA g, e user t' '

NUCLEAR REGULATORY COMMISSION -

-- gR 101g3) , ":-

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD E Offa eftge g &,

1 Deutung & song, In the Matter of ) y 8'jfg

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UNION ELECTRIC COMPANY ) Docket No. STN 50-483 u

)

l (Callaway Plant, Unit 1) )

. AFFIDAVIT OF KAY DREY Kay Drey, first being duly sworn, on her oath states:

1. I have been studying nuclear power for six years. I have been doing research on the planned and accidental release of radioactive materials into the environment from the uranium fuel cycle, with particular emphasis on nuclear power plants, since January, 1977. I am particularly concerned about tritium--its health effects and the fact that an estimated 410 curies would be released from the Callaway Plant into the Missouri River, the source of my drinking water, during routine operation. I am concerned about the planned and unplanned releases of radioactive pollutants into the air my family and I breathe, the water we drink and the food we eat.

I have collected and studied reports of accidents at nuclear plants, particularly those caused by human and procedural errors and by component failure. I have filed a petition to intervene in the proposed chemical decontamination of Dresden Unit One, and i

have intervened or am intervening in proceedings concerning the iss-uance of the following permits:. a National Pollutant' Discharge Elimination System (NPDES) permit by the Missouri Clean Water Commission-(MoCWC) for the Combustion Engineering uranium fuel fabrication plant at Hematite, Missouri; an NPDES permit by the l

8108120'

a MoCWC for the Callaway Plant; and a Section 404 (Federal Watek Pollution Control Act) construction permit by the Army Corps of Engineers for the Callaway Plant. I served as statewide coordinator for the successful initiative campaign that outlawed Construction Work in Progress financing for electric generating facilities in Missouri in November 1976.

Basing my testimony on recent laboratory studies and epi-demiological data which provide increasing evidence of the hazards of low-level radiation, I have appeared before the Committee on Federal Research on Biological Effects of Ionizing Radiation, National Research Council, in Washington in September 1980. (Oral and written testimony attached).

I have special knowledge about construction defects at the Callaway plant through communication with a least a dozen present or former Callaway construction workers who would be potential witnesses in the operating license proceeding. I have forwarded-allegations to NRC staff people at the Region III office (Glen Ellyn, Illinois) by letter, telephone, and in private and public meetings, and to NRC staff people at the headquarters by letter and telephone, starting in 1977. I possess extensive files concerning alleged construction defects relating to the placing of ' iron and concrete l during approximately the first ten percent of construction, and to

. certain piping placad in 1979, at Callaway.

2. I am a lifetime resident of the St. Louis Metropolitan area, currently residing in University City, St. Louis County, i Missouri, approximately 75 miles downwind from the Callaway Plant site. My sole supply of drinking water is the Missouri River, which i 2 l

woald be contaminated by radioactive pollut' ants from the Calfaway Plant if it were to become operative.

I and my family have picnicked, hiked and birdwatched along the Missouri River in Callaway County and eastward into St. Charles County several times a year for many years, that is, within a range of approximately 10 to 60 miles of the proposed plant. We have often travelled along Highway 94 to enjoy the fall colors, a display as outstanding as any in the Ozarks. My husband and I have worked to preserve riverways as recreational assets in Missouri for over twenty years, including the Missouri River, and have inspected and supported the Corps of Engineers' efforts toward riverine habitat and floodway restoration of the Missouri River.

3. Severe damage or melting of the reactor core (a Class 9 accident according to "The Safety of Nuclear Power Reactors (Light Water-Cooled) and Related Facilities," Atomic Energy Commission, W ASH-1250, July 1973) and the subsequent release of a significant portion of the isotope inventory of the core to the environment were declared to be virtually impossible by the Rasmussen Reactor Safety Study of 1975 (WASH-1400). In January 1979 the Nuclear Regulatory j Canmission withdrew its endorsement of the Rasmussen study, and two months later our nation's first Class 9 accident began at Three Mile Island.

According to the Office of Nuclear Reactor Regulation of the NRC, "the accident at Three Mile Island exceeded many of the present design bases (of engineered safety features and radiation protection systems) by a wide margin and was evidently a significant precursor of ' a core-melt accident. . . (From "TMI-2 Lessons Learned Task Force Final Report," NUREG-0585, October 1979, p.~3-5). The NRC l

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Special Inquiry Group report, directed by Mitchell Rogovin, c'oncluded that "within 30 to 60 minutes, a substantial portion of the fuel in the core--certainly the center of the top half of the core, and l

perhaps as much as half of all the fuel--would have melted." ("Three ;

Mile Island: A Report to the Commissioners and to the Public," Volume I, January 1980, p. 20).

While the probability of a Class 9 accident at the Callaway plant may remain low, the consequences could be severe for St. Louis and beyond. A report prepared for the President's Council on Environmental Qual-ity by the Center for Energy and Environmental studies at Princeton University (by Jan Beyea with Frank von Hippel; December 1980) predicts delayed cancer deaths and thyroid nodules at least as far' as 250 miles downwind ( Appendix E) and possible human occupation and agricultural land restrictions "out to distances of 1000 miles and for periods of decades after the release" of radio-activity from a hypothetical accident at the Three Mile Island I location (p. 13). "The range of genetic defects would be equal, very roughly, to the range of delayed cancer deaths." (p. 12 f n. )

In reevaluating the levels of safety afforded by safety-grade and non-safety systems based upon the Three Mile Island accident, the NRC has recently added four major " unresolved safety issues" to its list of 133 submitted to Congress initially in 1978. One of those issues is the need for hydrogen control in the reactor containment building following a-core-melt or core-damage accident. Whereas NRC guidelines -prior to Three Mile Island had anticipated that -

only from _1 to 5% of the zirconium in the fuel rod cladding would react with steam in the reactor vessel, forming zirconium oxide and 4

releasing hydrogen, apparently it is now postulated that thad figure may be at least as high as 50%. The NRC and the Advisory Committee on Reactor Safeguards (ACRS) now acknowledge the fact that new hydrogen control measures may be required to prevent the breaching of the reactor vessel and the accelerated melting of the uranium fuel. In addition, controlled filtered venting of the containment building may be required so that " combustible concen-trations of hydrogen will not collect in areas where unintended combustion or detonation could cause loss of contaimment integrity or loss of appropriate mitigating features. " (From a position paper of the ACRS Staff 'ated February 6, 1981, concerning the Degraded Core Rulemaking) . Obviously the increase in the vanting from the callaway plant of radioactive noble gases and halogens, along with other gases and particulates--even if under ideal conditions of controlled filtering--would increase the health risks of people living downwind in St. Louis and for hundreds of miles beyond.

40./  %

KAy DREY /

STATE OF MISSOURI )

)SS '

CITY OF ST. LOUIS )

Subscribed and sworn to before me this ' / day of March,

&mh NOTARY PUBLIC KENNETH M . CHACKES My Commission expires: NOTAty run:c 5;r;I 0; utssougt SI.LOUG CO.

M1 COMMISSION Wiiis SIL 281984 5

1: aos: Fein: Avcnue University City, MD 63130 Septemes: 8, 1960 N

Dr. Russell H. M rgan, Chairman, and Memcers Coev-ittee on Federal Research en 31clegical Effects of g 00CK W 9

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Icnizing aaeiation  ; MAR 1 o tggt > -9

)

!!atienal Research Ccuncil - 2 2101 Constitution Avenue g C*Se of the Sessary

• m,q 4 s,me, Washington, D.C. 2C418 Bracar the Gentlemen and Mesdames: <n G 1

I as submitting this latter as a bcusewife and nother, and as a =itizen who has been studying nuclear pcwer fc: six years. The mere I 1sarn accut what is kncwn and net kncwn about :sdiatien and nuclear pcwer, the more convincac I beccme that all facil-ities that a s creating new radicactive materials shculd be snut dcwn as scen as pessi-bis, except these used fc medical purpcses. I believe that available nuclea engi-nee:ing, scientific and medical research talent and funds shculd be directed tcward trying to rescive a p=blem that is perhaps unrescivable: the need te keep these per-manently toxic radicactive wastes we already have cut cf the bicsphere per anently.

Unless a: until answers can be fcund fer the cid wastes, I believe no mere shculd be created.

, I realiza the abcve paragraph c=ntains cencerns that are net new to you. Althcugh I do not have a list of the other members of your committee, I kn=w that Dr. Russell Mc:gan, f:: one, has been t_ying since at least the 195C's t bring =auti:n and ebje:-

tivity to bear en ques ,iens of :sdiatien standards and health resea=h, an effort which unfertunately has been largely unsuccessful. (This was des::ibed, for example, in an April 1979 a.-ticle by Walter Pincus cf the 'deshineten Pest abcut a report Jr.

Mc:qan had submittad in Cet:ber 1958 to the U.S. surgecn general.)

l Throughout this letter I shall cite fa:ts and qucte f=m d:cuments which aise are i

net new to yeu. That is because I believe these materials are relevant te yeur ap-peinted task. The U.S. Ccngress has c=ntinued to allcw 1cng-lived seu=es of icnizing radiatien to be created and dispersed into the envi :nment years after scientists had learned that these scu=es wculd zer:ain permanently hazard =us. I believe that the rationale fc the decisions and indecisi:ns mace in the early years of nuclear pcwer gener:-

! tien should be presented t A eri=a's citi: ens bef::e similar i::eversible decisiens are made fc the future.

Cr to quote three dicta en nuclear waste disecsal presented by 'dciman and Ge==an of the At=ic Energy C:er.issi:nt Divisien of Engineering at Oak Ridge:

o The p cblem of the discesal of radicactive wastes is still one cf the mest im:::: ant 0:nfrenting the industry, even thcugn greet p=gress has been made in identifying *he issues and in i :::ving the results ATTACHMENT 1 (written testimony)

l

\

i FREIR, 9/i/50 (1- I 1

i I

maximum internal radiatien deze if present in the air c: water: SCC millirem,s a l

yes; to a nearby member of the general public, as per Section 105 and Appendix 3, '

Tacle II -- or 5 rems a year to a werker, as pe: Table I and the Nati:nal Sureau of i

Standards' Handbook 69: l "The maximum pe==issible average cencentratiens of radi:nuclides in air and water are dete: mined f cm biological data wnenever such data are available, or are calculated on the basis of an averaged annual dose of .. 5 rems when the genads or tne whcle body is the critical organ." (from " Maximum Permissibla 3ody Su.-dens and Maximum Ps mis-sible Concentrations of Redienuclides in Air and in Water for Cccupa-tional Exposure," Handbook 69, June 1959, p. 5)

In Other words, althcugh the maximum concentrati:ns ;ermitted in air and water for the 27D isotopes now listed in the NRC's 10 CFR 20 Appendix 3 may differ f:=m one another by the most minuts amounts, the differences may not be much more than cenjec-ture. And yet these c=ncentrations form the basis fc: the NRC's negotiaticns with its licensees in determining each facility's firm cperating limits - how much radio-activity may be released to the envi =nment and how much may be allcwed t: leak within the clant before a shutdown for repairs is required.

"In spite of the enormous amount of wo:k which has been done by this subcomittee (of the ICRP and NCRP), the p colem of developing maximum permissibla-concent:stions of radionuclides is still rendered difficult because of the relatively limited direct experience with the action of the radiation f:cm radienuclides en human tissues. The contents of this Handbcok are based on what is believed to be the best informatien avail-acle and it is to be expected that as cur knewledes increases the numeri-cal quantities presented in this :s;crt will be in a state of centinueus modificatien." (J) big,,, pp. iv-v; emphases added)

-To what extent has this centinuous modificatien occurred? To what extent has the requisite research on the health effects of specific isotopes been perfc:med en which to base any modification? Apparently not enough According to the "Repcrt of the Interagency Task Force en the Health Effects of Icnizing Radiatien," June 1979:

"The largest animal pcpulation studied to date is c=mprised of 250,000 mics, an enormeus peculation te maintain under laterat: y ccnditiens.

This study has produced useful informatien en the biological e#fects cf radiation. Ncnetheless, even this animal pcpulati:n is not large encugh te provide cenclusive informati:n on low dose effects. Also, response patterns very f:=m soecies to scecies, leaving uncertain the question how study results shculd be. applied te humans." (pp. 30-31)

2. How many racicisotopes have already been found t: he mere hazardous than was suspected back in the 1950's when the maximum permissible c=ntaminant levels (new fcund in Appen-dix 3) were first published? For example:

a. TRITIUM:

j 2ecause no ecenemically feasible way exists t: remove tritium f::m the cc= ling

! water and steam disenarged fr:m a nucles: : wer :lant, NAC licensees are n t recuired 1

I gi -v-w- +- e - ,

.-byyy y. ev yv3 -g m- -

es.w ---' - - - - - - - - -

FRE!R, 9/@/80 -

to remcve ie. Im;c: tant questiens, then, include: H:w much tritium is created per year per 10CO-megawatt : actor, and how much of that diffuses th cugh the ceramic pellets and fuel cd cladding into the ecoling water and ultimately into the environment? Fellowing cc::sspendence with Dak Ridge Natienal taberatory, Westinghouse and cthers, I am convinced that no cne :eally has the answers.

Some of the ways.t:itium is procuced in nuclear reacters are the fc11cwing:

(1) as a tertiary fission product; some diffuses through the cladding into the ccclant; (2) when boren absorbs neutrons produced by the iission p;ccess; boren e is often used in cont ci rods, and beric acid is int cduced inte the cociant water in pressurized water reactors fc: the purpcse of absorcing neutrons to control the rate of the nuclear reaction; and (3) as a result of neutron capture a

by deuterium.

I am always surprised, by the way, when I am reminded of how recent our knowledge is abcut nuclear physics: The discovery of tritium as a fission product was only first reported in 1959, two years after Shiepingpert, the first commercial nuclear reactor, became operative - and 14 years after the first atomic bomb was exploded in New Mexicc.

The estimates of the amount of tritium released routine A f cm a nuclear facility range g:satly.

! (1) Connonwealth Ediscn, fc example, repcrted to the NRC that the tetal amount released into Lake Richigan during 1977 f =m Zion's two 1000-megawatt Westinghouse reacters was 724 curies. After being

sprimanded in 1977 by the NRC for nct reporting its releases of tri-tium, Comed changed its estimates fe: 1974 f:cm 2.3 curies to 274, and for 1975 from 40 curies to 1030. The amcunt published for 1976 sas 747 curias. (" Radioactive Materials Released faom Nuclear Fewer Plants - 1977," published in January 1979 as NUREG-0521).

t I de not know whether the tritium rkleased with the centinucus

! flow of ecoling water (e.g., ccoling tewer blewdewn) is monitored and l

l repcrted to the NRC, or whether enly that amcunt that is released in batches f cm tanks. Or is all the tritium perhaps estimated, including l that in the batch' releases? As with neble gases, I' understand tritium f

i monitcring takes time and sensitive laborate y equipment, a ecmbinatien l

l I would imagine is not feasible fc centinuously flcwing effluents.

(2) At an Internatienal At=mic Energy Agency semina: held in Vienna in 1969, it was estimated by U.S. Sureau of Radielegical Health scientis's t that a 1CCO-MWe pressuri sd water reacter wcule release spereximately 70C0

FE*R, 9/8/80 -

curies per year, based on releases f cm three reacters which at that time were still using stainlass-steel-clad ::ds.

There seems to be some decate abcut hcw mu=h and at what rate tritium diffuses through zi:cenium aH oy cladding. In a personal communication f cts Westinghouse I was t:1d that " fuel : ds are clad with zircionium alloy and tritium diffuses th:cugh this alloy whether there are defects in the cladding or not." (February 23,1979)

The NCRP report entitled " Tritium in the Envi cnment" says just the opposite: "it appears that tritium is released only through defects in zirconium au cy clad fuels. Defects in zircenium aucy cladding are infrequent...." (Report No. 62, issued in fiarch 1979; p.11)

I suppose the estimatesof the quantity of tritium released to the environment and the amount to which workers a:s exposed artimportant cnly tc the extent that tritium is perceived as a health hazard. Here, too, the scientists do not seem to agree.

(1) One health physicist at Cak Ridge, for example, said to me on the tels-phone: " Tritium is no big deal; all it can do is dest:cy a DNA molecule."

Another here in St. Louis said he would be perfectly happy to d: ink tritium everyday in his erange juice.

(2) In 1949 the Naticnal Bureau of Standards g:cuped tritium in the middle range of three as being " moderately dangercus." (Handbeck 42, " Safe Handling of Radioactive Isotopes"). 3y 1964, bewever, perhaps after scientists had begun to realize that tritium was a fissien product and thus was slated to be a comon byproduct of nucisar pcwer, tritium was relegated to the lowest of four levels of hazard f cm absc:ption into the body. (Handbcok 92) ,

(3) Other scientists, however, have sericus cencerns about tritium. In a list of radiation research p cjects funded by the Nati:nal Cance Insti-

, , tuta in 1977, for example, the fonowing cescription appears of a study at the Un:.versity of Chicage Scheci cf Medicine (O. J. l4ewissen, princi-pal investigator):

"The carcinogenic potency of tritium has been decu. entad in newbern mice fellcwing administratien of tritiated thymidine at varicus dese levels. ... ?!c data exist en a ;=ssible carcincgenic potency cf other tritiated precurscrs ncr of tritiated water. No data are available for the cessible 1:n te:-- texicity of tr'itia-ted water. The need f : additi:nal data is c vicus in view of the release of tritiated water frem nuclear pcwer reactc:3 anc nu-clear fusi :s;:rocessing plants wni:h will :e in :::erati:n in the future. Our current research sh=wed tnat tritium f:cm ::itiated

_~ , _

.FREIR, 9/0/80 4

, water is ca 'ia11v stained in the er anie : eenent of al'1

-creans tested in neweern, juvenile, as well as adult mice."

(em:hases added)

(4) In research at Lawrence Livermore Labe:atory, Debson and Cooper fcund that "a SCG dec: esse in the number of ge:m es11s can be expected in a femala mouse exposed c=ntinuously during develcpment t: ac=:cximately 2 mic ccuries of tritium per =U T*ter of bcdy water." (Radiatien Research 58,91-100, 1974). A report on these findings in tha LLL Newsline.

October-November 1974, included the following:

"'Cccupational exposure is of much greater c=ncern to me,' Dobson noted, pointing out that even small amounts of tritiated water vapo:

in the workplace can pack a powerful c=ncentrated dose becausa it has not yet had the chance to become diluted in the environment. ...

"'But whether c not the human female is as vulnerable to tritium as the mouse,' he said, 'we have a warning here. 'ie . have found at lasst one population of marrsnelian eens that is extremely sensi-tive to radiation effects at remarkably low levels of tritium.'"

(5) In the ineantime, while the debate continues over its relative biological affectiveness, tritium is routinely and accidentan y being released into the envircrvnent - such as into Lake Michigan f:cm each cf its nine reacters.

It seems i enic that while scientists today at Argonne Natienal Labor-atory blame the tritium fcund in Laks Michigan on fancut f:cm atom bomb tests, back in the 50's and 60's scientists f:cm the sare laborato:y were busily denying that fallout from atmospheric testing could ever be signi$-

icant.

So far no one has proven that drinking tritiated water is a good idea.

Would it be unreasonable to require that the producers of nuclear electri-city and hones of tritium prove it is safe befe're they are allowed to bur-den our planet with even more? Scme of the tritium being c sated today win still be areund irradiating living people and things at' the end of the

.21st CenturyI l -

b. NCELE GASES:

Not only are licensee? anowed to release tritium in great quantity to the anvironment,'but they may release radicactive noble gases in quantity, as well. The total amount of radioactive gases ancwed to te sleased te t,

he atmosphere fran the two-reseter Zicn clant in Illineis, f:: sxampis,-is

. 60,CCO microcuries (a little ever one-twentisth of a curis) per sec=nd -

with a maxi::um per year of 300,0C0 e.uri e.s.

-In aedition, I believe that :nly since about July 1979 has the ?;:C~a:-

FREIR, 9/8/B0 l i

tempted to set limits on the concentration of dissolved end cntrained neole gases allowed to be released in liquid racwaste affluents during the cutine operatien of a nuclear facility. According to the NRC's Draft Radic1cgical Effluent Techni- l cal Specifications designed to standardize permissible releases and monitcring, 0.00C4 mic ccuries of noble gases per mi!1111ter may be released. INUREG-0472 and 0473). For a 1000-maigewett pressurized wate: reacter, which discharges about 5,000 gallons of cocling water per minute to a river er lake, this concentration could mean the release of 1800 curies of nchie gases per year in the liquid effluent alone.

I am submitting a copy of a letter I sent to the Nuclear Regulatcry Commissicn on June 16, 1980, regarding the venting of krypton f:cm Three Mile Island. The health hazards of the noble gases as described in my letter are a far cry from the traditional description of radioactive nchie gases (aside f:cm redon) as being inert and virtually harmless to human beings. I had help with my letter from pro-fessors of physics, biochemistry, cance: biclogy, radiatien safety, and microbiol-ogy. Other questions about noble gases which need research, beyond those in my letter, includes (1) the accuracy cf the state-of-the-art tacW^gies desigWo~to-monitor noble gases dissolved or entrained in the liquid effluents at nuclear power plants,and noble gases released to the atmosphere; (2) the health effects of xenon; (3) the reason (s) why more inert gas is taken up by the adrenal than by any other tissues (referred to by W. P. Kirk in his review of krypton literature and hazards, an EPA publicatien, Jan.1972, p. 22);

(4) the extent to which noble gases may dissolve in bcdy fluids or fat, enabling them to bec=me distributed to varicus parts of the body,

,oc-fust the lung.

c. TECHNETIUM-99:

"Recent experimental data suggest that the c=ncentratien facter for uptake of Tc by vegetation from soils may be twe'to three c ders of magnitude higher than the 0.25 value currently being used in radio 3cgical assessments. ... Data on the uptake and retenti:n of Tc in humans are also necessary te increve the reliability of dose cenversion factors for specific c:;ans and varicu. age g cups. ... It is impc=c-ent to note that the predomine nt chemical forms of 9o 'Tc released to the envircnment have net been determined." That is the way a pa=e: =uclished in June 1975 by the CCE/ Uni =n Carcide Oak Ridge Naticnal La:cratcry begins, and the rest is no more

FREfR, 9/Q/80 ,

9a reassuring. The titia of the paper alene says a g::st deal: " Assessment of 'Tc Releases to the Atmosphere - A Plea fc: Applied Research." (ORNL/TM-6260)

Technetium-99 has a half-life of 210,CCO years and is known to be texi= enough that the CRC Handbeck of Che-ist:r and Physics (1973-1974) advises that it be handled in a glove box. Instead, here in Misscuri at our nation's eldest corrrnercial uranisan fusi fabrication ;ilant, an unexpected batch of 50C0 gallons of technetium-contan:Lnated liquid wastes was filtered through an inn exchange c=1umn and then was allowed to be dumped into the two site evaperati n pends. (The pends were closed to additional dumping in February 1979.) As night have been expected, the discharged technetium migrated to a monitoring well within a matter of months, and no doubt will have visited lots of other wells and aquifers, etc., before it abandons its i::adiating ways.

d. CERIUM AND CAR 3CN Af.'D ZIRCONIUM:

There are ether radionuclidss created in nucles: react =rs ab=ut which only minimal information seems to have been available at the ti.s the Appendix 3 limits were calculated. For example, carbon-14, es:ium-141,143 and 144, and an ever-growing list of cor :sien products. One of my favorites is zi:= onium-96 whi n until a few years ago was thought to be stable but now is creditad with having a half-lifs of 7 3.6 x 10 years. In addition, new facts ebeut some popularly researched i materials have been accumulating. Fer example, it new appears as if plutenium, if ingested in chlorinated drinking water, can be absc: bed by the gast: intestinal tract. It is not, as previously thought,'just an inhalation hazard to the lungs.

e. "TECHNCLCGICALLY E!.hANCED NATURAL RADIATICN" - that is, uranium and therium and other naturan y radioactive materials which are mined f:cm deep within the earth, enabling them to enter the biosphere in the form of breathable dust, sludge, radon gas, etc.

Enhanced, indeed!:

An isotope with a controversial biological effectiveness and with a half-life far shc tar than that of Z:-96 is uranium-238. Its half-life is enly 4.5 b *:n f

years. Feu cwing a spin of uranium yen ow cake en a highway here in St. L:uis during ~ ush hcur ene evening in January 1979, I telephened Dr. John Gofman in Califcznia and was teld by him that a milligram (a 30/1CCCth cf an cunce) of uranium-238 is sufficient to cause lung cancer. Is it true that the efficial URC pcsition remains that uranium is enly chemically texic, net :sdicactively se? hich assess-ment is cc:: set?

And why does:'t the public hear scre about pc1:nium-210 as a maj:: ha:s_-d of uranium min tailings piles? Can anyene even c:mprenand what the fell = wing fact means?: . A gra= cf 1u:=nium-210 gives off 155 ::"':n al:ha ;:arti 1:s ::: se:end,

ThilA, 9/5/ 50 -9 or the equivalant of SCCD curies. How much pc1:nium-210 washed into the Rio Puerco Rive: with the 1,100 tons of centaminated debris and 1CO m3=n gancas of radicactive wats: when the dam at the Church Rcck, New Mexi=c, uranium a4" 5: ke in July 19797 Apparently bcdy scans perfc==ed at Los 21amos en flavajo child-ren who had played in the river snortly after the " incident" began indicated that somehow the children,had managed net to inhale c swallow any detectable amount of radicactivity. Similar tests perfc ned by Unicn Carbide at Cak Ridge - on a man who had worked here in St. Louis County for nine weeks in 1970 in a warehouse saturated wan -to-wall and floor-to-ceiling with uranium cre and exide residue dust, etc., wearing either no mask or just a paper cone - also :egistered nega-tively last year. And two St. Louis eni1=:en who had played in the same warehouse and on the piles of mill tailings, when tested at Oak Ridge last year, were given the same clean bin of health. A question I have asked receatedly te no avail is:

Has any federa n y-funded radiation lab ever found a mamme: of the gene:31 public - or a worker, for that matte - whose bcdy scan indicated that he or she had indeed been exposed to a detectable amount of alpha-emitting radioactiv-ity?

3. If the new 25 millirem radiation standards for the public a:e reascnable, how can society condone standards that aH ow a worker to be expcsed to 650 times that amount?

The radiatien dose guidelines established in 1959 by the Federal Radiation Council had set the maximum dose for a person living near a nuclear facility at 5CO =# D 4-ems, and the legal average dose for the U.S. population at 170 m ems. That is, each NRC-licensed facility was allowed to release an a munt of radioactivity to the air and water that could expose a persen living nearby to an annual dese of SCO minirems.

~

As of December 1,1979, however, the legal standards changed. According to the EPA's new uranium fuel cycle standards - 40 CFR 190 - no member of the general pub-lie may be exposed to more than 25 minirems of radiatien a year fr:m the planned releases of radioactive was*es f: m the enti e natien's c=mmercial nuclear power in-dustry.

New standards have not yet been promulgated for wc kers. A wc ker is still

" entitled" to be expcsed to 12 rems every year cf exte-nel (gamma) radiation until he reaches his maximum lifetime occupaticnal external-radiatien dose quota (his age, j . minus' 18, times 5 reme) - according te 10 CFR 20.101(b) . Cver and above that he may breathe c: swallcw an additional internal-radiatien c=se of 5 rems' wc:th =f racio-active air and steam - ac=c ding to 10 CFR Part 20 Secti:n 1C3 cnd Appendix 3, and j

l:35 Handbcok 69 (as per page 3 of this letter).

l 4. What genetic effe:ts might the pcpulati:n ex;ect if wc:kers centinue te be

F5f.M. 9/8/80 -1G-allowed to be exposed to 17 :sms per year? '

i Cne of the mest incredible documents I have read ab=ut the risks and benefits  !

of Euclear power is the International Comission on Radielegical P:ctacti=n's .

" Report of Cemittas II on Permiethle Dose for Ints:nal Radiation (1959)." l

" Genetic effects manifest ti.?mselves in the descendants of exposed individuals. The injury, when it appears, may bs cf any dag:se of severity f =m, inconspicuous to lethal. A slight injury will tend to c= cur in the descendants for many generati:ns, whereas a severe injury will be eliminatad recidly through the early death of the individual car:ying the defective gene. Thus the sum total of the effect caused by a defective gene until it is eliminatad may be con-sidered to be roughly the same. The main censideratien in the cent:ci of genetic damage (apart fran aspects of indivicual misfortune) is the burden to society in future generations impcsed by an increase in the proportion of individuals with deleterious mutations. Fran this point of view it is inunatarial in the icng run whether the defective genes are introduced into the general poc1 by a few individuals who have received large doses of radiation, or by many individuals in whom smaller doses have produced cc::sspondingly fewer mutations.

However, even in this case it is desirable to limit the dose received by an individual." (p. xv)

"The decision of the ICRP (1956) to set the average external occupa-tional exposure at 5 rems /yes: (co::ssponding to 0.1 rem / week) is not applied to internal dose calculations except in the cases of radio-nuclides that are dist:ibuted rather uniformly th: ughout the body or are concent:ated in the gonads. The purpose of limiting the average weekly tctal body dose (0.1 rem) te ene-third of the former maximum weekly dose (0.3 rem) was to lessen the possible incidence of certain types of sematic damage, e.g. radiation induced leukemia and she: ten-ing of life span, which are considered to result primarily from total bcdy expcsure. Chviously, the sducti=n in the gonad dese was intend-

ed to lower the incidence of deleterious genetic mutatiens that will give rise to effects appearing in future generati

ns." (p. 4)

5. What birth defects, if any, might a nucisar wc:ker and his ,c her spouse expect their children to have?

Is there federal ssearch under way, for examels, en bi:th defects suffered by children of the Department of Defense and At:mic Energy Cemissien persenrel who were expcsed t: radiatien during the atmospheric tests cf 1945 t 1962? C: suffered by child:sn born in Utah c: Nevada during or afts: the Nevada tests?

At the Citizens' Hearings en "adiati:n Vi=tims in April 1930 in Vashingt:n, O.C.,

I ints: viewed at least 35 ef the victims - pecple exposed to at=m beme tests, the daughter of a Hanford research scientist, a Savannah River plant wc:ker, etc. - and asked many of them if their children had been healthy at birth. I heard abcut child-ren wh= were bczn dead (and whose autcpsies revealed nothing); chreni=, painful skin diseases and strange set: ring; a chil: whc was b: n with0ut an ese:hagus, and wh:

died 21 mon *.hs later; another who was be:n with his stemach partly cicsed, pausing projectile vomiting the first year; many miscarriages; another child who had a fibrous mass (never identified) attached to the base of her seine; a miscarried i - brightly-colored fetus that icoked like a cross between a sesherse and a toad

(=4=4 % to stories tcld by iia:shall Islanders); a sen who at age 32 sudcenly began having numeness of his hands and legs, etc.

I came away from the fcur-day hea:ings as angered at the silence of the medi-cal profession as I have been at the silence of the federal government. In sevesal cases a veteran or other victim mentiened that althcugh a docter had told him or her that a particular disease c: pechlem was quite likely to have been caused by exoosure to radiati=n, none of the doctors - not one - was willing to p cpose this etiology in writing.

6. Are nuclear workers being provided adequate protective c.lething?

In response te a latter I had sent to the Naval Sea Systems Command asking about the anticontamination clothing worn by men exposed to cobalt-60 on t1uclear submarines, the Director of ths Nuclear Technelegy Division w: cts as folicws:

"Nosaal clothing or plastic materials win shis1d beta radiatien from cobalt 60 which is the predominant nuclide present in radio-active wc:k in Naval nuclear propulsien plants. These materials and cotton coversu s referred to as anticentaminatien cJething, shield cobalt 60 beta radiation because this very low energy radi-l ation (0.3 nillion electron volts) dcas not penetrate the materials.

l The anticontamination clothing used in this work is shnilar to that

! us sd throughout the nuclear industry. Its effectiveness in shielding cobalt 60 beta radiation is due not to any uniqueness of the clothing, but due to the nature of the low level radiation involved." (July 3, 19"C)

When I asked Dr. Karl Z. Morgan whether he agrees with the above, he said that

the cobalt-60 beta has a range in material of "many times the thickness of the anticontamination clothing." (July 24, 1980) I wculd also like te knew about the l cobalt-60 gama radiation. If cobalt-60 is the main isetcpe found in the accumula-tien cf ec

csion products (crud) inside primary ecolant systems coast-te-ccast,

. and is respcnsible fc: creating the prchibitively high radiation ficids in which workers must nevertheless perform maintenance tasks, how is it pessible that plastic (e.g., nylon) coversus wculd be encugh to shield a werker? 'dhen I first learned l

l fran a nuclear power plant pipefitter that his " protective" clothing consisted of a nylon jump-suit, skivvies, his street shoes with cotton bcoties and rubber bocts over that, a cotton cap, and rubber gloves - all taped " air-tightly" with paper i tape - I was incredulcus. I stin am.

7. How accurately a_e the workers' radiatien de.ses menitered?

a. When a person is surrounded by radiaticn sources, apparently one littis film badge ". .

~

on his chest cannot tell the whole story: '

4 In the Wm'1 St met Journal of September 4,1980, it was reported that 73 pos-sible cases of overexposure were discoversd at the San Onofre nuclear power plant in California. This did not ha.ppen because of an ac:ident or because the radiation fields within the plant suddenly became hotter. It's that each of the workers at this 436-megawatt,12-year-cid plant began wearintf multiple badges - that is, a film badge on his head as well as at chest level. The men had been working under the steem generator tube pipes through *iich the highly :sdioactive primary cooling water flows. The maximum permissible worker dose to the whcle body c: the head is three rems in any 13 consecutive weeks. When the additienal badges were worn, it was d'scovered that the workers allegedly experienced between 3 and 5 rems, and some as much as seven reme. The concieding paragraph of the article quotas a professor of occupational health and safety as saying the exposure "wculdn't have any biclogi-cal effect" and "is about the same as having three or fou X rays in a hospital.' If

~

accurately quoted, I believe the professor's c=nunents are highly misleading.

b. Nuclear power plants lack effective neutron monitoring:

In a memo distributed within the NRC by Glenn W Zimmer of the Cffice ;f Stan-dards Development, dateG January 25, 1978, Mr. Zimmer wrote that "persennel at some ccrunercial power reactors are receiving some neutron exposure which heretofore has i

been unknown. Apparently these expcsures have gone unnoticed because of the insde-quacy of the neutron measurement techniques employed, and insufficient kncwledge of this field. I understand that neutron exposures of up to a few hundred m4114 ems in a relatively short period of time (a few hours or days) are pessible...."

c. They also lack effective beta monitoring:

Although icng recognized as highly toxic, apparently ruthenium has been causing unexpected monito:ing probisms at nuclear facilities. It was disecvered at l

the DCE/ Exxon Idaho Operations Office in Idaho Falls that workers were being exposed to ruthenium but that no one had :sslized it because ruthenium has an unusually high l

beta-to-gerrrna ratio (that is, virtually no gamma). A special dosimeter capable of monitoring beta radiation had to be created. It was interesting for me te learn from a French physicist last week that in France, too, they have fcund ruthenium to be a new proolem - in this case at La Hague, the reprocessing plant.

The abcvs compilation of concerns about ionizing radiation represents only a portien cf the list I had outlined for you. .Because we cannot have nuclear powered electricity withcut creating and releasing radiation to the envi cnment, and withcut exposing wc kers to deses almost certain to shorten their lives and to threaten the' health of their descendants, I would urge you to leck beyond our natien's energy reeds to give full weight to the burcens this exceedingly hazardous technology imposes uoen all future generations.

Oral Tectimony - ct a public meeting Sept. 15r, 1950, hold by tha Cc.raittoa on Federal Research on Biological Effects of Ioni:ing Radiation, at the Natienal Academy of Sciences in Washington, D.C.m Dr. Russau H. Morgan, Chairman. e My name is Xay Drey. I am here speaking as a housewife and mother, and as a citi:en who has spent the past six years studying and fighting against nuclear pcwer. I appreciate the opportunity to speak before yeu. The purpose of my trip to Washington f:cm St. Louis, Missouri, is to mentien some of those areas of ionizing radiatien researen which I have found either to be the mest repleta with centradictc.y scientific data - c the mest lacking in scientific cata at an.

Because the creation of new sources of ionizing radioactivity en our planet today is primarily caused by uranium fuel cycle facilities operated fc the generatien of nuclear powerec electricity or of nuclear armaments, I shan t.y to c qanize my laundry list of research needs in terms of the stages of the uranium fuel cycle.

I shan start with the front and of the fuel cycle - with questiens about the health effects of uranium and therium as they are dug up out of the depths of the earth and b cught into the biosphere - into potential contact with peopla and our human food chain.

1. Regarding alpha radiatient Is uranitan yenowcake only chemicany toxic, c is it also radictoxic? Is it cc: rect that one milli :sm t of uranium-238 is encugh to cause a lung cancer in humans? If that is an exaggeration, what amcunt is enough?

2. If it is correct that plutonium ingested within chlorinated water is more : adily absorbed by the gastrointestinal' tract, making it not just an inhalation hazard to the lungs as previcusly believed, to what extant may this also be true of uranium and other alcha emit-tars? This is impcrtant to anyone who drinks chlorinated Misscuri River water, for -W ,-.

because of the quantities of uranium mill tailings that have er=ded and spi Had into the Missouri River and its tributaries since at least the 1950's.

3. How much radioactivity is released to the envirenment f:cm uranium cenversien, enrichment, and fabricatien plants? What impact, if any, are evaporation pends at these sites having on the ground water?

l l 4. Would epidemiologic studies of workers at the Paducah, Kentucky, enrichment plant; the Hematita, Missouri, fuel iaerication plant; the former Mallinckrodt Manhattan Project and uranium plants in St. Louis; and other front-end fuel facilities indi=sta an increased incidence of multi =le myeloma, cancreatic cancer, and lung cancer comparable to the increases indicated by the data on wc:k us at Hanford, Washingten? Is it cc: rect, as I heard in l

testimony by BatteH e scientists in Washington in February 1978 ,that evidenes of an increase in multiple myelcma and pancreatic cancewhos-been fcund not only by Mancuso and his couengues, and by Milham, but by the Batten s researchers as well7

5. Can alpha radiation contaminatien be accurately assessed by means of the type of whole body scans available at Oak Ridge and Les Alamos?

l

6. Can radiation hazards associated with spined uranium yen owceke on a highway c: with leached uranium mill tailings in a creek c: river bed be adequately monitored with a Geiger counter?

7. I understand that Native American women are cencerned about the inc:sesed incidence of birth defects among children bc n near uranium mines and mills. In my written testimeny I list seme of the birth defects I heard abcut f:cm een who were execsed to sdiation f:cm at:m benb tests. In additien to the establishment of cance tumc registries, anc the ccuecticn of~epidemiolcgic data on workers execsed t radiation (and, I might add, to c;her hazardcus substances) in the wc:kplace, isn't it also essential tc begin accumulating data en eniltren ATTACHMENT 2 (oral testimony)

---i c ve r

rnG n committco, 5spt. 15,liSGs Key 0:ey, c cl scstmeny - p. 2 bc n with serious birth defects, including data about their parents' wc k histeriins? Or would this make the nucles: industry and the federal government tco vulnerable to compen-sation claims?

8. Regarding the back end of the uranium fuel cycle: How much radicactivity is being re-leased into the envi cnment as a :ssult of the routine cperatien o f nucisa: power plants?

What impacts are the gaseous, liquid and particulate effluents having on the water, sedi-ment, and bentnic 'ccmmunities of our lakes and rivers, and on fish and water fowl higher up in the fcod chain? What are the impacts en dairy food, fa:m p:cduce and meat, and on the air we breathe? -

9. Should the NRC not be required to change its 10 CFR Part 20 Appendix 3 maximum permis-sible concantratiens now that the EPA's new uranium fuel cycle standards are the law?

The NRC's concentratiens in air and wate: - which many technicians, state health officials, s.nd so forth er.eneously think are the so-called " safe" limits - are based en a pemissible

slease of 500 milli: ems of :sdioactive wastes allcwed to be released per each NRC-licensed facility. The new EPA standa:ds, 40 CFR 190, however, limit the planned releases to 25 millirems f:cun the entire nation's comercial nuciser industry.

10. How reliabis is the whols concept of the millirem or :sm in relaticnship to cu:ies, as translated in the field by the nucisar industry? In the handling of racicactive wastas, i

to ecmpare the c W .on exercised by the medical p cfession with the casualness of the nuclear industry is tind-beggling. The entire Washingten University, 3arnes and Jewish hospitals' medical center in St. Louis has on hand for use by the :ssearch and therapy

scientists, physicians and technicians a total of no mors than nine curies of radicischepes in unsealed sources at any one time - and any sealed sou

ce fcund to be laaking as much as fifty nanocuries (that is, 50 billionths of one curia) must be taken out of service for

spair at ones.

Compare that with the following emissions f cm the Millstone Unit One reactor near New London, Connecticut in 1975: 3 cillion curies of radicactive xenen and krypten we:s released into the air and 63 curies of iodine; 80 curies of tritium,18 curies of icdine, 199 curies of firsien products (including 146 curies of cesium 137 and 134), and 170 mil 11 curies of alpha emitters ws s released into Long Island Sound. Mcw was that transla-tad into a m4114 sm dess? Northeast Utilities said that a person living at the plant boundary (drinking the water and b sathing the air) wculd have e 16 a'i#:em dese fer the year; a person living 1y miles away would have a dese of six millirems; and a person abcut 5 miles f:cso the site would have about a 3 millirr,a dese. If one were to calculate the number of curias allowed to be released within the NRC's 500 m{114 em permissible dose on i the basis of the numbers of curias Isleased f cm M111stene One in 1975 (that is, these

! which were translated into 16 milli sms for the year) - the ame'unt wcu'.d be staggering.

The emissions reported for y ms tone One in 1975 were not the ssult of accidents. They were clanned releases curing the cutine operatien of the plant. In the event of an "inci-dent" c: unplanned := lease, the emissions c:uld total as much as a 6i :sm dose c mere for a member of the public befors a licenses would be requirsd to notify the NRC immediately of the release, accc: ding to 10 CFR 20.403(2) - that is, "The release of radioactive material in concentratiens which, if averaged over a pericd of 24 hcurs, would exceed 5,0C0 times the limits specified for such materials in Appendix 3, Table II."

Is the conservatism 'of the medical institutions warranted, or net?

I salize that many of tne cuestions I have listad this me:nin; ars related to radiatien l

surveillancs, rather than to the biolegical effects of raciatien. I feel, hcwever, that it is impc: tant to point cut the fact that significant cuantities of :sdicactive materials are being Isleased to the envircnment f:cm nuclear facilities in c: der te enecurags the l investigati=n of the health effects of these sleases. Centrary to the p;cncuncements of

the nuclear industry that the releases to the envircnment from nuclear fccilities are insignificant "less than a 5-milli em annual Jose" - I believe that the releases are very significant indeed. To complete toy list:

11. Wat are the pctential health hazards associated with sene of the radioisctopes re-leased to the environment in great quantity f m nuclear facilities?

a. For example, tritium or radioactive hyd: gen: Ee:ause there is no technologicany

, feasible way to remcve tritium from a nu= lear plant's affluents, tritium is not re-quired to be removed. Important questiens, then, include: In a typical tncusand-watt nuclear plant, how much tritium leaks out thrcugh the ceramic uranium penets, through the fuel rod cladding,.and into the primary c= cling water? Hcw much is then discharged into the air and water? Five thousand ganons of water a minute are to be released from the Ca n away plant near St. Louis into the Misscuri River, and ancther 15,000 gallons per minute as steam and vapor into the air. Hcw many curies of tritium will

. be included? Is this c ntinuous flow monitored by the licensee, and the tctal number of curies reported to the PJRC - or is cnly that tritium repc:ted which is released in batches from the hold-up tanks? What is the accumulation of tritium in Lake Michi-gan, for example, where there are al: ady nine operating reactors, and in which the wate: ture-over occurs only once in a hund:sd years?

A new question was posed to me this past week by a professor of physics at Washing-ton University in St. Louis - Den Solef. Because tritium has a nucleus with a mass three times greats: than the ordinary hyd:cgen present in our bcdy cells, Dr. Solaf l wanders if this extra mass could perhaps change the manner in which tritium forms com-l pounds, and the manner in which tritium is transcorted through the body - that is, the ease with which it could permeate through ce u membranes and meve through capil-

[ laries. He wonders whether, contrary to the pecular theory that tritium is dispersed l

unifo:mly throughout the human body, as is natural or light hyd:cgen, it may instead concentrate in certain organisme. Is research currently under way on these questions?

b. And noble gsses: In a recent article in the Chiesee Tribune by Casey Eukro (April 7),

the fc uowing descri: tion was included of ncble gases: "Reacters give off so-csiled

'ncola gases,' which are radioactive but do not react with other matter. If inhaled, they are usuaH y pr:mptly exhaled, say nuclear experts, and are not likely to cause physical damage. One of them, Krypten, c:uld cause skin cance: in high enough doses."

In a letter I had sent to the NRC on June 16, 1980, regarding the venting of krypten from Three Mile Island, I discuss the health hazards of noble gases based on their physical properties (as cpposed to their relative chemical inertness), and based on their solid daughter p;cducts. A reporter from Scieace magazine told me a few weeks ago that he had never read anything like that before acout ncble gases. Neither have I. I

! submitted a copy of my June 16 letter along with my written testimony to your comittee on September 8. Is the material in my letter about neele gases ac= urate, er not?

12. As a nuclear plant bec=mes older - esen after only five years or less of coeratien -

the pi,.ing, valves, redctor vessel, steam generat:r tuces, and cther pa-ts beccme encrusted witn radi= active cer.esien p:: ducts which not only cle; up the works (causing leaks and shutdowns and a loss of effective power), but cause seri=us radiation hazards fer the men l

who work on maintenance, the rapiscement of parts, and .efueling. Because of the high :sdia-l tion fields at one :lant, for example, caused by the buildup of c balt-c0 and other radi=ac-tive materials, it tock700 men eight mcnths to repair a react = vessel outlet pi e connecticn, a repair which in a coal-fired plant would have taken 25 men abcut two weeks, ac=ording to Bernard Verna, a columnist in Nuclear Mews (f:vemoer 1975, p. 52). The gamma dese rate cf a piece of crud that measured only 4 square centimeters and whi:h was remcved frern Incian l

Point Cne near flew Yc:k City measured one rem an hour! In ::da := clean cut the cc :csi:n p::cucts,.the nuclear industry is planning t: use enslatin acents. Is it possible that the c =oination of the chelating agent solvent with racicactiGe materials c:uld act synergisticaH y, causing a healtn hazard for the dec=ntaminatien wc:kers?

.tk. %l you A- U c//re M 1%.

d UNITED STATFS OF AMERICA ,

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

UNION ELECTRIC COMPANY ) Docket No. STN 50-483-OL

) .

(Callaway Plant, Unit 1) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Amended and Supplemental Joint Petition to Intervene" and " Affidavit of Kay Drey" have been served on the following by deposit in the United States mail, first class, this 6th day of March, 1981.

James P. Gleason, Esq., Chairman Atomic Safety and Licensing Board j.

G &

513 Gilmoure Drive @ ,

Silver Spring, MD 20901 '

DOCKETO Gerald Charnoff, Esq. US C -2.

Thomas A. Baxter, Esq.

Shaw, Pittman, Potts & Trowbridge

': b S E f Q )g gf -['

A .

S- Ogg g -

1800 M. Street, N.W. 3 Washington, DC 20036 N 7

Mr. John G. Reed c) e Rt. 1 Kingdom City, MO 65262 Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, DC 20555 Docketing and Service Section Office of the Secretary U. S. Nuclear Regulatory Commission -

Washington, DC 20555 Henry J. McGurren, Esq.

Office of the Executive Legal Director U. S. Nuclear Regulatory Commis sion Washington, DC 20555 Kenneth M. Chackes Chackes and Hoare