ML19350D702
| ML19350D702 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/06/1981 |
| From: | Kreger W Office of Nuclear Reactor Regulation |
| To: | Bross I ROSWELL PARK MEMORIAL INSTITUTE |
| References | |
| NUDOCS 8105180420 | |
| Download: ML19350D702 (6) | |
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Dr. Irwin Bross h
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Dear Dr. Bross:
I have been asked to respond to the letter you sent to President Reagan dated March 12,1981. In that letter you stated that "NRC overregulation will cause the death of many human beings" resulting from the planned cleanup of TMI-2. You commented that the planned cleanup of TNI-2 could be avoided by entombing the facili ty.
You also suggested that the risks to the TMI-2 decontamination work-force may be much larger than estimated by the NRC if cancer incidence data on the nuclear subnarine workers of Portsmouth Naval Shipyard are used to estimate health effects and that the risk estimates NRC used in the Programmatic Environ-mental Impact Statement for TMI-2 (NUREG-0683)I were based on "out-of-date" data.
Except for the consideration of the data collected at Portsmouth Naval Ship-yard, all of your concerns and comments are addressed either specifically or indirectly in the Programmatic Environmental Impact Statement for TNI-2 decontamination.
In the summary section of NUREG-0683 the reasons for not entombing the facility as you suggested, and going ahead with the cleanup are highlighted. Two summary points that relate directly to your concerns regarding the reasons for the cleanup are quoted below:
"The Cleanup operations will remove sources of potential radiation exposure that currently pose risks to the health and safety of station workers and the public. Radiation sources are present in the form of airborne con-tamination, wastewater contaminated by radioactive materials during the accides t, plateout of radioactive material on building and equipment sur-faces, contauinated sludge, contaminated filter cartridges and demineralizer resins, and damaged fuel. As long as water with radioactive substances in it is allowed to occupy sumps and tanks, there exists a small probability of leakage into the groundwater and subsequently into the Susquehanna River.
The contaminated water is also a source of direct radiation to workers requiring access to the building to perfonn critical maintenance (e.g., repair of nuclear instrumentation) or other repair to maintain the reactor in safe shutdown conditior.s."
if" Final Programmatic Environmental Impact Statement related to dec.ontamination l
and disposal of radioactive wastes resulting from March 28, 1979, accident at l
Three Mile Island Nuclear Station", Unit 2, NRC Report - NUREG-0683, USNRC Washington, D. C.
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Dr. I. Bross.
"The feasibility of partial cleanup alternatives in which the reactor building would be sealed with some or all of the radioactive sources left in place was examined.
It was found that all such alternatives including taking no action other than maintaining the reactor in safe shutdown condition, either would not eliminate the potential risks or would convert part of the TMI-2 site into a long-tenn or permanent waste repository."
Extensive reasoning leading to these summary points are given in the text and appendicies of NUREG-0683.
We believe that your statement that "the death of many human beings will result" from the cleanup of TMI-2 cannot be supported. The Final Programmatic Environ-mental Impact Statement (NUREG-0683) concluded that 0.3 to 1 additional cancer deaths attributable to exposure to radiation may occur among the entire work force engaged in cleaning up TMI-2. We cancer death risk estimates made in that report were based on information compiled by the National Academy of Sciences's Advisory Committee on the Biological Effects of Ionizing Radiation (BEIR-I) 1972.
Appendix Z of NUREG-0683 contains information which details the numeric bases of the cancer death risk estimators that were used, including a perspective on the uncertainty associated with estimating radiation induced health effects.
The latest report by the National Academy of Seignce's Advisory Committee on the Biological Effects Ionizing Radiation (BEIR-III), suggests that the cancer risks may even be smaller than those estimated on the basis of BEIR-I by a factor of about 2 or 3.
Thus, we cannot agree with your suggestion that the NUREG-0683 estimates are based on "out-of-date" infonnation and the suggestion that up-to-date information would result in much larger risks.
To place this in perspective, it is expected that over 1000 workers will be involved in the cleanup effort. On the basis of U.S. cancer statistics, about 200 individuals out of a population of 1000 could be expected to die from cancer from causes unrelated to the TMI cleanup. Thus, the maximum increase in cancer death in the workforce population is about 1 part in 200.
y BEIR-I, Comittee on the Biological Effects of Ionizing Radiation.
"The Effects on Population of Exposure to Low Levels of Ionizing Radiation,"
National Academy of Sciences, Washington, D.C.,1972.
3_/ SEIR-III, Committee on the Biological Effects of Ionizing Radiation.
"The Effects on Population of Exposure to Low Levels of Ionizing Radiation,"
National Academy of Sciences, Washington, D.C.,1980.
Dr. I. Bross Regarding the Portsmouth Naval Shipyard data (PNS), these data were geviewed by the National Institute for Occupational Safety and Health (NIOSH). NIOSH's study was undertaken in response to a Conggessional directive, after a study by Najartan and Colton, published in May 1978, reported a five-fold increase in mortality due to leukemia and a two-fold increase due to all cancers among workers employed in the maintenance of nuclear submarines at the shipyard.
In the conclusions of the N10SH study it is stated that " excesses of deaths due to malignant neoplasms...were not evident in civilian workers at PNS..."
This finding is in disagreement with results of Najarian and Colton.
The NIOSH study went on to conclude that "when observed leuksia deaths at the shipyard were compared with expected deaths, derived from the United States white male population rates, no excess was found. No relationship between exposare to radiation and mortality from any cause was observed among the PNS population when compared to the United States white male population."
It should be pointed out that the NIOSH study neither vindicated nor implied a relationship between low-level radiation and cancer. There are several problens with using the PN* data at this time to develop radiation-induced cancer risk estimators. One problen is that an insufficient time period may have elapsed for most of the radiation workers to expect to see increased cancer incidence. Another problen is that the number of workers at PNS that received radiation exposure is relatively small, resulting in a statistical sample that is not totally adequide.
The NRC staff has been in communication with members of the group who performed the NIOSH study of the PNS data and who attended the March 17, 1981, meeting that you referred to in your letter. We have been informed that no new infor-mation was reported at the March 17, 1981, meeting that changes the conclusions of the NIGSH report.
In summary, we believe (1) that the cleanup of TMI-2 shculd progress as expeditiously as reasonably possible to reduce the potential for future uncontrolled releases; (2) that the risk estimates presented in the Programmatic Environmental Impact
- 4) Rinsky, R.
A., et. al., "Epidemiologic Study of Civilian Employees at the Portsmouth Naval Shipyard" U. S. Department of Health and Human Services, National Institute for Occupational Safety and Health (NIOSH), Bureau of Radiological Health, Rockville, Maryland. December,1980.
5/ Najarian, T., and Colton, T., " Mortality from Leukemia and Cancer in Ship-yard Nuclear Workers". Lancet 1: 1018-1020, 1978.
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v Dr. I. Bross Statement are conservative (over estimates) on the basis of the latest information on radiation induced health effects; and finally (3) that the cleanup activities at TMI may result in a small potential increased cancer mortality to the entire cleanup work force.
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William E. Kreger, Assis nt Director for Radiation Protect on Division of Systems Integration m
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March 12, 1981 2
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President Ronald Reagan s
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,. bear Mr. President:
Although you campaigned against regulating corporations to
/ ' death, you are letting the Nuclear Regulatory Ccamission (NRC) do just f
this to the utility at Three Mile Island Unit 2 (TMI-2).
What is far I
worse, NRC overregulation will cause the death of many human beings by insistence on an unnecessarily costly and dangerous " clean-up" plan.
While NRC claims that the " clean-up" will not even cause one death, this estimate is based on out-of-date high-dose data and faulty q
extrapolation. If instead the latest scientific data on the nuclear
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~, submarine workers at the Portsmouth Naval Shipyard (PNS) is used (reported C
MarcQ7,~1981) the picture is entirely different. There will be around e
100 lung cancer deaths in the " clean-up" workers.
Round numbers will be used to keep the calculations simple and the common-sense approach clear. Assuming a 15-year latent period for lung cancer, there are 16 lung cancer deaths among PNS workers with lifetime exposures of 0.5 rem or more. - Calculations from U.S. vital statistics by CDC/NICSH show that only 8.23 deaths would be expected in this series. The approximately 8 excess deaths occurred in roughly 5000 person years. This is about equivalent to 1000 nuclear workers expeced durinry 1959-1962 getting lung cancer in the 5 years 1973-1977 Since the doubled risk of these workers would continue for at least 10 more years, there would be at least 3 x 8 = 24 cancer deaths in this series.
Since probably 4000 " clean-up" workers at TMI-2 would be M" h*-
exposed to radiation doses as high or higher than those of the 1000 PNS
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- workers (whose lifetime exposures averaged only about 5 rem), at least 4 x 24 = 96 lung cancers would result from the " clean-up".
Note that NRC permits 5 rem annually. In addition to these deaths, there would be radiation-induced deaths from other causes among the " clean-up" workers
-as well as a substantial number of deaths in the general population from environmental contamination when the radiation is removed from the containment. All of these deaths and disabilities will be caused by NRC regulations because thare is a much better way to decommission TMI-2.
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Pr:sid:nt Ronald Re gan
- March 12, 1981 Page 2 The method is called " entombment" and consists of immobilizing the radioactivity in TMI-2 in concrete and leaving it in the containment.
This would keep the radiation out of the anvironment.
It would also keep the workers out of the containment at TMI-2 since most of the jcb can be done by remote-controlled equipment. The immobilized radiation isn't likely to hurt anyone until the whole installation crumbles to dust in a few thousand years. The costs of entombnent would be about one-tenth of " clean-up" costs.
Unfortunately NRC is determined to decommission TMI-2 by the rule book even though this is going to cause the very public health disaster that was so narrowly averted in the original TMI-2 accident.
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.J. Bross, Ph.D.
i.ctor of Biostatistics IDJB/mak CC: Open I
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