ML20009E460
| ML20009E460 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 07/24/1981 |
| From: | Branagan E Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| ISSUANCES-OL, NUDOCS 8107280226 | |
| Download: ML20009E460 (28) | |
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7/24/81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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SOUTH CAROLINA ELECTRIC AND GAS Docket No.
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(Virgil C. Summer Nuclear Station
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REBUTTAL TESTIMONY OF iv ED, WARD F. BRANAGAN, JR. REGARDING CONTENTION Al Q.l. Could you please state your name and affiliation.
A.
My name is Edward Branagan.
I am a Radiological Pnysicist with the Radiological Assessment Branch in the Office of Nuclear Reactor Regulation. A copy of qy professional qualifications are attached.
Q.2. Do your responsibilities include evaluating health effect models for i
the HRC.
A.
Yes.
Q.3. What is the purpose of this testimony?
A.
This testimony is designed to address the validity of the health effect models used in the Staff Final Environmental Statement (FES) (NUREG-0719)1 and the prefiled testimony of Drs. K. Z. Morgan,2 4
Michio Kaku and Helen Caldicott served on behalf of the Intervenor, t>Sd Q.4. What is the basis for the health effect estimates in the FES?
3 A.
Health effects which could be attributed to radiation dose j
commitments associated with exposure to radioactive effluents from normal 8107280226 810724 PDR ADOCK 05000395 T
i a 4 operations and from the fuel cycle were estimated in the FES.
Potential cancer mortalities were determined by multiplying the dose commitment (in units of person-rem) by an appropriate risk estimator (in units of 0
potential premature deaths per 10 person-rem). The risk estimators used in the FES were based on models described in a National Academy of Sciences report entitled "The Effect on Populations of Exposure to Low Levels of Ionizing Radiation."5 This report is known informally as the BEIR I Report after its authoring Committee on the Biological Effects of Ionizing Radiation. The BEIR I Report consisted of a comprehensive review and reevaluation of the scientific basis of radiation exposure on humans by scientists who were eminent in their fields.
The cancer risk estimators in the FES were based on the linear non-thresnold dose responses model and the " absolute risk" projection model described in the BEIR I Report.
In the text of the FES (S4.5.5), it was noted thdt risk estimators derived from the " relative risk" model (using the linear non-threshold dose response model) would provide risk i
estimators about four times greater than those used in the text.
In I
regard to the use of the linear non-threshold model, the National Council on Radiation Protection and Measurements (NCRP) cautions that:
[L]inear interpolation between the naturally occurring spontaneous i
incidence and the incidence observed following exposure at
[
intermediate-to-high doses and dose rates generally overestimates the risk of low-LET [ linear energy transfer] radiation at low doses and low dose rates. This observation has also been incorpo ted in reports by the ICRP (1977), NCRP (1975), and UNSCEAR (1977)
All of the whole body dose to offsite individuals from exposure to radioactive effluents from routine reactor operations is due to low dose rates from low-LET radiation.
l
O.
Tne whole body risk estimators that were used in the FES are compared with risk estimators from other sources of information in.
The risk estimators that are compared in Attachment 2 include values from the BEIR I Report, the National Acadeqy of Sciences BEIR III Report which was published in 1980, the International Comission on Radiological Protection (ICRP), and the United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR). 5,7-9 These organizations, along with the NCRP, represent the views of the overwhelming majority of the members of the scientific community. The risk estimators used in the FES are consistent with the values from these other sources of information.
Q.5. What is your position on Dr. Morgan's prefiled testimony?
A.
The essence of Dr. Morgan's prefiled testimony is that there are uncertainties in the risk estimators that can be derived from epidemiological studies of persons exposed to ionizing radiation.
Dr.
Morgan offers numerous reasons to question the accuracy of risk estimators derived from epidemiological studies.
Dr. i: organ argues that:
1.
"[TJhe standaras have been based on two sources: (1) the survivors of the bombings of Hiroshima and Nagasaki; and (2) the therapeutic use of radiation, in particular the local exposures of high doses to persons suffering with the disease ankylosing spondylitis." Prefiled testimony at 2.
2.
"The data from Hiroshima and Nagasaki were taken and used without any ;orrection whatsoever for the effects of fire, blast, and a traumatic situation...." Prefiled testimony at 3.
3.
Risk estimators derived from the ankylosing spondylitis patients were based on a " select population that dies early of common diseases -- heart failure, tuberculosis, pneumonia, emphysema, chronic bronchitis." Prefiled testimony at 4.
O.
4.
"[IJt was very poor judgraent on the part of the BEIR III Committee to base their principal support on the survivors of Hiroshima and Hagasaki....
I understand frora discussions with scientists over the country that there is a paper in print (see "New A-Bomb Studies Alter Radiation Estimates", Science, Vol. 212, May 22, 1981) this month -- the issue hasn't been received by me up to the present time -- that it is published t hrough the studies and is a result of the calculations and estimates of a group at the Lawrence Livermore Laboratory in California which indicates there was a very serious overestimate of the dose in these two cities....
How it would appear that the risk is greater than the BEIR III Report would suggest." Prefiled testimony at 5,7.
5.
"Furthermore, there's a treraendous amount of data, much of it data on human exposures, which shows you get a better fit if you use the super linear hypothesis, namely when you get down to low doses, the number of malignancies per rem is greater than at large doses -
that is not only is there no low safe level of exposure, but the risk of cancer per unit of exposure is greater at low doses than at high doses." Prefiled testimony at 7.
6.
" Fortunately, we know quite a bit about the risks, perhaps the uncertainty is not spread over a factor of 10 one way or the other.
Some other risks-chemicals-the uncertainty is greater." Prefiled testimony at 17.
In regard to Dr. Morgan's testimony, it should be noted that Dr.
Morgan states that "perhaps the uncertainty is not spread over a factor of 10 one way or the other." Although Dr. Morgan does not provide a specific value for a mortality risk estimator for whole body exposure in his prefiled testimony, he has used a value of 600 total potential cancer cases per 10 person-rem in the past. 10 BEIR III has indicated that the 6
number of potential non-fatal cancers is about 1.5 to 2.0 times the number of fatal cancers.
Using these conversion factors, Dr. Morgan's total cancer risk estimator for whole body exposure implies a fatal 0
Cancer risk of about 300-400 potential deaths /10 person-rem.
In his testimony on June 26, 1981, Dr. Morgan stated that his most recent value for a total fatal cancer risk estimator for whole body exposure was about 6
900 deaths per 10 person-rem. Dr. Morgan's most recent value is higher l
than the highest values in the National Acadeny of Sciences BEIR I Report, BEIR III Report, ICRP 26 and UNSCEAR (i.e., compare Dr. Morgan's most recent value with values in attachment 2).
It is possible that no 3
Cancers Will occur because the doses and dose rates in the vicinity of the reactor are much less than the doses and dose rates at which excess cancers have been detected in human populations.
In regard to Dr. Morgan's first point, that the standards have been based primarily on data from exposure of two groups (i.e., the A-Bonb survivors and the ankylosing spondylitis patients), it should be noted that there is a substantial body of literature, in addition to studies of a
the two preceding groups, on the risks of radiation exposure at dose levels much higher than those estimated in the FES.
Some of the other major groups that have been studied include (1) radium dial painters, (2) early radiologists and dentists, (3) five different miner populations, (4) children irradiated for thymus enlargement, (5) tinea capitis patients, (6) patients receiving breast irradiation and (7) children whose notners were irradiated during pregnancy. Studies of these groups support the risk estimators that can be derived from the A-Bomb survivors and the ankylosing spondylitis patients.
For example, in the BEIR III Report, Dr. Radford, Chairman of the BEIR III Committee, stated (p. 241):
"An important question is the extent to which the Japanese data are consistent with the data from all the other studies... In general, the concordance is excellent for the major cancers where several data sets exist such as breast, thyroid and lung cancer.
Other sites show various degrees of agreeme But the most important comparison is for total cancer incidence coefficients derived for each sex from the Nagasaki Tur.or Registry data.
From data presented in the April 1979 draft, these are found to be about 2/3 as great as the sum-of-sites coefficients summarized in Table V-14.
This degree
. of concordance of results from human studies of a great range of exposure conditioits, ethnic makeup and basis for radiation exposure is truly remarkable."
Consequently, the existing data base is adequate to estimate potential health effects. The range of values stated in the literature is sufficient to characterize the risk.
In regard to Dr. Morgan's second point that the A-Bomb survivors were a select population, it should be noted that the BEIR III Report discussed this viewpoint and concluded (pp. 156,157):
"Whether the risk estimates derived from the experience of the Jaganese atomic-bomb survivors are generally applicable is best determined empirically, by applying the test of consistency with other human data. When this is done... risk estimates derived from the atomic-'
'b experience are seen to be generally consistent with those based i other human exposure. The only very marked exception is the absex.e af a carcinogenic effect among those exposed in utero....
That genetic effects have not thus far been found does not necessarily argue against the general applicability of the atomic-bomb experience:
no direct evidence of a genetic effect has been forthcoming for man, and presumptions as to the order of magnitude of any such effect (see Chapter IV) suggest that it is too small to be easily seen in samples of the size available to investigators in Japan. Nor is the absence of a general life-shortening effect any indication that the atomic-bomb experience is a dangerous basis for generalization....
The argument of Kneale and Stewart rests on observations, made in the Oxford Survey of Childhood Cancers, that many childhood illnesses and injuries are more frequent before death from cancer than in live controls, and progressively so as death approaches.
The argument that early-occurring radiation-induced cancers would not come to light because of an " exceptionally high infectia de:th rate for several years after the event" is not borne out. lnere were no major epidemics in Hiroshima and Nagasaki.
(footnote omitted)
In summary, the BEIR III Report considered the " effects of fire blast and a traumatic situation" on the A-Bomb survivors, but nonetheless
used the A-Bomb survivor data to estimate risk to the general public since the A-Bomb data was supported by many other studies.
i In regard to Dr. Morgan's third point that the ankylosing spondylitis patients were a select population, it should be noted that there are other factors (e.g., differences in uoses and dose rates) that should be taken into account.
For example, the BEIR III Report (p. 355) concluded in regard to the risk of leukemia:
"It should be recognized that risk estimated at a selected point in the high-dose region may overestimate the magnitude of hazards of low-dose exposures by a factor of 2-10....The estimated risks from the atomic-bomb and ankylosing spondylitis treatment represents upper limits, in that both are derived from high-dose-rate exposures.
Consequently, the risk estimators in the FES, which are based in part on the data from the ankylosing spondylitis patients, may actually overestimate the risk, rather thca underestimate the risk, because the l
doses and dose rates to individuals in the vicinity of the Summer reactor will be much less than the doses and dose rates in the ankylosing spondylitis patients.
Dr. Morgan's fourth point was that a May 22, 1981 article in Science (Attachment 3) indicates that an overestimate of dose in the A-Bomb studies will result in a risk greater than that concluded in the BEIR III Report.11 The NRC Staff would note the following:
first, the article that Dr. Morgan referenced was in the News and Comment section of Science. Although the article referred to new dose calculations by W.
Loewe and E. Mendelson at Lawrence Livermore Laboratory (LLL), G. Kerr of Oak Ridge National Laboratory (0RNL), D. Kaul of Science Applications, Inc. (SAI), and J. Marcum of Research Development Associates, it did not l
l
reference any papers by these individuals to document the claims in the article.
Second, the NRC Staff has obtained preprinted copies of two LLL papers concerning the revised dose estimates at Hiroshima and Nagasaki and their implications concerning cancer risks.12,13 The LLL papers indicate that the May 22nd Science article is misleading in a number of important areas. The May 22nd Science article stresses that the RBE for neutrons may have to be increased. However, Straume's and Dobson's preliminary conclusion is that:
" Evidence for high neutron RBE is lacking for leukemia and breast cancer. However, data for total malignancies and for chromosome aberrations suggest that neutron RBEs increase with decreasing dose, because of the diminishing effectiveness of gamma rgs, and may reach quite high values (100 cannot be excluded.)"
t Consequently, forlotal malignancies and chromosome aberrations Straume's and Dobson's preliminary conclusion is not that neutrons are much more dangerous than has been previously thought, but rather the effectiveness of gamma rays for inducing total malignancies and chromosome aberrations is less than was previously thought.
Third, several of the principle authors, who are reevaluating the A-Bomb survivor data, have written letters to the editors of Science concerning the May 22, 1981 article (Attachment 5). These letters indicate that the May 22, 1981 article is misleading. On May 31, 1981 l
the Radiation Research Society held a workshop entitled " Late Effects Workshop Dosimetry of the Atomic Bomb Survivors." The June 19, 1981 issue of Science contained a summary of this workshop (Attachment 4).
The June 19th article was entitled "New A-Bomb Data Shown to Radiation Experts" with a subtitle " conference goers are impressed with the revised
9-picture of Hiroshima, but foresee little change in risk estimates." 14 The subtitle of the June 19th article is in sharp contrast to the Title of the May 22nd article (i.e., "New A-Bomb Studies Alter Radiation Estimates"). This article indicates that while most of the participants agreed that the new data is preliminary (i.e., it is still being evaluated), their initial reaction is that the new data will have only a small inpact on risk figures. According to the Science article Dr. Radford is of the minority opinion and:
[Hej believes that the Livermore data strengthen his argument that a linear no-threshold model is the correct one for describing the carcinogenic effects of exposure to low levels of radiation. And if this is correct, he says, the risk estimates published by the National Academy of Sciences in its 1980 report on the Biological Effects of Ionizing Radiation (BEIR) should be restated.
He thinks the risks for contracting fatal cancer from radiation should be doubled. He would fix the risk at 250 to 500 excess deaths per rad of increased radiation per 1 million people, not 100 to 250 deaths, as he says BEIR and other documents have fixed it.
It should be noted that the risk estimates for whole body exposure used in the FES were based on the linear non-threshold model of BEIR I.
Consequently, the range for risk estimators for whole body exposure used in the FES is consistent witn the views of the majority of the members of the scientific community and even the more conservative views of some minority members such at Dr. Radford.
In regard to Dr. Morgan's fifth pint that there is a tremendous amount of data to indicate that "the risk of cancer per unit of cxposure is greater at low doses than at high doses," the NCRP published an extensive report on this subject entitled " Influence of Dose and Its Distribution in Time on Dose-Response Relationships for Low-LET Radiations."
(NCRP No. 64).
NCRP No. 64 (p. 2) stated:
(
. "Although extensive data from human beings permit reasonable risk assessments to be made for exposures to intermediate to high doses of low-LET radiation, these di ta are not adequate to demonstrate conclusively that a dose rate effect either does or does not exist.
The experimental evidence...is so extensive, however, that it would be extraordinary if such dependence did got apply to the same endpoints in the human being as well."
HCRP Ho. 64 proposed the use of a dose rate effectiveness factor (DREF) for low-LET radiation in linerally extrapolating from intermediate-to-high doses and dose rates to low doses and dose rates.
The NCRP recommended that a DREF of 2 to 10 could be used to reduce risk estimates for low-LET radiation derived from either the absolute or relative risk models.
All of the dose to offsite individuals from exposure to radioactive effluents from routine operations is low-LET radiation.
Since the NRC Staff did not use a DREF to reduce risk estimates, it is more likely that the risk to individuais in the vicinity of the reactor has been overestimated, rather than underestimated, in the FES.
In summary, Dr. Morgan's central risk estimator for whole body exposure is higher than the highest values recommended by the major radiation protection organizations.
The existing data base is adequate to estimate potential health effects.
Dr. Morgan's testimony concerning the effects of radiation on human beings does not provide any substantial evidence that would change the validity of the favorable benefit-cost balance struck at the construction permit stage.
The risk estimators that were used in the FES are consistent with values that can be derived from the BEIR I Report, the BEIR III Report, ICRP, and UNSCEAR.5,7-9 The risk estimators that were used in the FES are also consistent with the
recommendations of the llCRP.6 These organizations represent the views of the overwhelming majority of the members of the scientific community.
Q.7. What is your position on Dr. Kaku's prefiled testimony?
A.
Dr. Kaku rammarized his testimony as follows:
(1) "There may be large uncertainties or hidden biases in the early radiation studies, especially the Hiroshima-Hagasaki and British x-ray patient data. (2) nore epidemiological studies, not the consensus of standard setting bodies, can determine the real dangers of low level radiation, and (3) newer studies indicate that tne standard setting bodies may have underestimated the effects of radiation." Prefiled testimony at 2.
Dr. Kaku's three points are very similar to Dr. Morgan's points.
These points have already been discussed in response to Dr. Morgan's 6 reasons for questioning the accuracy of risk estimators derived from epidemiological studies. M In summary, Dr. Kaku's testimony concerning the effects of radiation on human beings does not provide any substantial evidence that would change the validity of the favorable benefit-cost balance struck at the 1]
Tne response to Dr. Kaku's first point is in the Staff's response to -
Dr. Morgan'; points one, two and three.
The Staff's response to Dr. Morgan's first point answers Dr. Kaku's second point. The response to Dr. Morgan's fourth point replies to Dr. Kaku's third point.
e
. construction permit stage. The existing data base is adequate to estimate potential health effects. The range of values stated in the literature is sufficient to characterize the risk. The risk estimators that were used in the FES are consistent with values that can be derived from the BEIR I Report, the BEIR III Report ICRP, and UNSCEAR.5,7-9 The risk estimators that were used in the FES are also consistent with the recommendations of the NCRP.0 These organizations represent the views of the overwhelming majority of the members of the scientific community.
Q.8. What is your position on Dr. Caldicott's prefiled testimony?
A.
Although a few sentences in Dr. Caldicott's testimony may have some bearing on Contention A10, it is difficult to identify their relevence to the contention. This is epitomized by her " Conclusion" which focuses on the medical consequences of nuclear war and nuclear proliferation.
Prefiled testimony at 23-24.
In response to Dr. Caldicott's statement on page 23 that it is
" impossible to predict the magnitude of the increased incidence of genetic disease, leukemia and cancer which will result from radioactive contamination with long lived isotopes," it should be noted that Dr. Morgan's testimony and use of risk estimators in the past contradicts the preceeding statement by Dr. Caldicott.
Neither Dr. Morgan or Dr. Kaku state that the risks are " impossible to predict," but rather that there are uncertainties associated with risk estimators.
Risk estimators for exposure to radioactive materials were used in the FES.
Those estimators are consistent with values that can be derived fran the
. BEIR I Report, BEIR III Report, ICRP, and UNSCEAR.5,7-9 The risk estimators that were used in the FES are also consistent with the recommendations of the llCRP.0 These organizations represent the views of the overwhelming majority of the members of the scientific connunity.
In sumuary, Dr. Caldicott's testimony concerning the effects of radiation on human beings does not provide any substantial evidence that would change the validity of the favorable benefit-cost balance struck at the construction permit stage.
(
i
. ATTACHMENTS 1.
Professional Qualifications.
2.
Comparison of FES Whole Body Risk Estimators with Values from Other Sources of Estimators.
3.
Reference 11.
4.
Reference 14.
5.
Science, 213, pp. 6 and 8.
REFERENCES 1.
USHRC, Final Environmental Statement Related to the Operation of Virgil C. Summer Nuclear Station Unit No.1, NUPEG-0719, May 1981.
2.
Prefiled Testir.ony of Dr. Karl Z. Morgan, May 26, 1981.
3.
Prefiled Testimony of Dr. Michio Kaku Concerning the Health Effects of Low Level Radiation, May ?6, 1981.
4.
Prefiled Testimony of Dr. Helen C?ldicott, May 26, 1981.
5.
Advisory Committee on the Biological Effects of Ionizing Radiation, The Effect on Populations of Exposure to Low Levels of Ionizing Radiation, National Academy of Sciences, 1972.
6.
National Council on Radiation Protection and Measurements, Influence of Dose and Its Distribution in Time on Dose-Response Relationships for Low-LET Radiations, NCRP Report No. 64, April 1980.
7.
National Acadery of Sciences, The Effects on Populations of Exposure to Low Levels Of Ionizing Radiation (BEIR 111), 1980.
8.
International Commission on Radiological Protection, Recommendations of the International Commission On Radiological Protection, ICRP Publication 26, January 1977.
9.
United Nations Scientific Committee on the Effects of Atomic Radiotion, Sources and Effects of Ionizing Radiation,1977, United Nations, 1977.
10.
K.Z. Morgan, "How Dangerous is Low-Level Radiation?," New Scientist, p.18, April 1979.
11.
E. Marshall, "New A-Bomb Studies Alter Radiation Estimates,"
Science, 212, 900, May 22, 1981.
. 12.
W.E. Loewe, E. Mendelsohn, " Revised Dose Estimates at Hiroshima and Nagasaki," UCRL-85446, PREPRINT, October,1980.
13.
T. Straune, R. Lowry Dobson, " Implications of New Hiroshima 3nd Nagasaki Dose Estinates: Cancer Risks and Neutron RBE," UCRL-85697, PREPRINT, Narch,1981.
14.
E. Marshall. "New A-Bomb Data Shown to Radiation Experts," Science, 212, 1364, June 19, 1981.
1
Professional Qualifications My name is Edward F. Branagan, Jr.
I am a R'adiological Physicist with the
~
Radiological Assessment Branch in the Office of Nuclear Reactor Regulation.
Presently, I am responsible for evaluating the environmental radiological impacts from nuclear power reactors.
In particular, I am responsible for
~
evaluating radioecological models and health effect rodels for use in reactor licensing.
I have been with the Radiological Assessment Branch for about 2 years.
I received a B. A. in Physics from Catholic University in 1969, an M. A. in ~
Science Teaching from Catholic University in 1970, and a Ph.D. in Radiation Biophysics from Kansas University in 1976.
While completing my course work for my Ph.D., I was an instructor of Radiation Technology at Haskell Junior College.
My research work was in the area.of DNA base damage, and was sup-ported by a U.S. Public Health Service tranineeship.
My dissertation was entitled " Nuclear Magnetic Resonance Spectroscopy of Gamma-Irradiated DNA Bases."
Since joining the NRC in 1976, I have been with both the Office of Nuclear Material Safety and Safeguards (NMSS), and with the Office of Nuclear Reactor
~
Regulation (NRR).
In NM55 I was involved in project management and technical work.
I was the project manager for two contracts that the NRC had with Dak Ridge National Laboratory.
These contracts were concerned with estimating radiation doses from radon-222 and radium-226 releases from uranium mills.
As-part of my work on NRC's Draft Generic Environmental Impact Statement on Uranium Mining (DGEIS), I calculated health effects from uranium mill tailings.
Upon publication of the DGEIS, I presented a paper entitled " Health Effects of Uranium Mining and Milling for Commercial Nuclear Power" at a Conference on Health Implications of New Energy Technologies.
Since joining NRR, I have worked on several projects: (1) managed and main author of a report entitled
" Staff Review of 'Radioecological Assessment of the Wyh1 Nuclear Power Plant'"
(NUREG-0668),(2)
- rved as a technical contact on an NRC contract with Argonne National Laboratt j involving development of a computer program to calculate health effects from radiation, (3) served as a technical monitor on an NRC contract with Idaho National Enginaering Laboratory involving estimated and measured concentrations of radionuclides in the environment; (4) served as a technical monitor on an NRC contract with. Lawrence Livera. ore Laboratory con-cerning a literature review of values for parameters in terrestrial radionuclide transport models; and (5) served as a technical monitor with Dak Ridge National Laboratory concerning a statistical analysis of dose estimates via food pathways.
Presently, I am a member of the Health Physics Society and the American Associ-ation for the Advancement of Science.
f I
w 6
TABLE 1 COMPARIS0N OF FES WHOLE BODY CANCER HORTALITY RISK ESTIMATORS D
a (PER 10 person-rem) WITH VALUES FROM OTHER SOURCES OF ESTIMATES Projection Model Dose-Continuous Lifetime Responga Exposure to 1 Rad /Yr (Low-LET)
Source of Estimate Models Absolute Relative BE!R, 1980 LQ-L,LQ-L 67 169 c
1972 BEIR Linear 115 568 UNSCEAR 1977 Linear 75-175 d
ICRP Linear 100-125 d
FES Linear 135 500 a
Except where noted all values are taken from Table V-4 of BEIR III.
b For BEIR 1980, the first model is used for leukemia, the second for other forms of cancer. The corresponding estimates when the other models are used (thereby providing an envelope of risk estimates) are:
l L-L, L-L 158 403 c
Updated to 1970 U.S. population.
d Values for the FES and ICRP are taken from Ref.1 Snd 8, respectively.
l l
o N2ws cnd Commant New A-Bomb Studies Alter Radiation Estimates The basis of 15 years of radiation research may be in error; radiation toxicity may be understated Some of the most important data on g
8 the effects of nuclear radiation on hu-4 mans may be wrong. according to new f
w&C r.r -
research being done at the Lawrence l 7-- T
,,, _ D r
Lisermore wcapons laboratory in Cali-4 fornia and the Oak Ridge National Labo-y.-
,, p ratory in Tennessee. The new findings F#
3 cre far from welcome, as one consultant L
I s.
'y in this work says, for all the revisions m [ D._
"are mosing in the wrong direction"-a
'"---T-direction that will w orry the advocates of
^
u s An Forre nuclear power. Government physicists hase recalculated the data on the radia-Did it produce neutrons or mostly gamma rays 7 tion fields created by the atomic blasts at D7pticare of the bomb that Air Hiroshima Hiroshima and Nagasaki and produced some unexpected results. Their statistics factor of 6 to 10. Since the effects on epidemiologist at the University of Pitts-show that most of the cancer caused by human health remain the same, one must burgh. The risk estimates in the final those bombs came from low LET gamma conclude that the gamma rays were more report of July 1980 mere not as high as rays.* suggesting that this common type toxic than had been thought.
Radford argued they should be nor even of radiation is more hazardous than had if this research proves correct-and it as high as those in the 1972 report.
been assumed before, has survised a few peer challenges al-Neither Radford nor Rossi endorsed the The impetus for the revision comes ready--it will necessitate the rew riting of document.
primarily from Lisermore, where phys!- many basic documents on the hazards of Rossi concedes that the Livermore cists William Loewe and Edgar Mendel-radiation, including the chief attempt to calculations may do away with the evi-sohn last year used a computer to recon-defme such risks published in 1980 by dence for his theory tnat neutrons were struct the two explosions. Their fmdings the National Academy of Sciences. That responsible fc,r the high cancer incidence are being checked and complemented by study, the work of the Committee on the in Hiroshima. But he does not expect to a group at Oak Ridge 5-d by George Biological Effects of Ionizing Radiation alter his general view that the hazards of Kerr. He began work on a similar project (the BEIR report), w as fraught with con-radiation are exag; crated. Radford, in in 1977, shelved it, and then returned to troversy on this very question.
contrast, says the new Hiroshima data the task in earnest when Loewe's data Although much of the BEIR report vindicatc his position and invalidate Ros-became known. Dean Kaul of Science was released to the press in May 1979, si's. Furthermore, Radford considers the Applications, Inc., in Chicago also car-the Academy decided to recall and re-BEIR 1980 report obsolete and expects ried out some early calculations that write it because of Assension among the that the probabilities it gives for the risk sparked interest in the issue. Kerr, Kaul, authors. Some of taem, led by Columbia of dying of cancer after exposure to cmd Jess Marcum of Research and De-Unis ersity biophysicist Harald Rossi ar-gamma radiation will be doubled. Like-velopment Associates in Santa Monica, gued that the p,per overstated the can-wise, he thinks the probabilities for con-Cahfornia, have been funded by the De-cer-causing efh.ts oflow LET radiation.
tracting any form of cancer after irradia-fense Nuclear Agency to explore the Their arguments leaned heavily on Japa-tion will be quadmpled.
problem and check sorne of the old as-nese data and particularly on the thesis The importance of the new research is sumptions which have not yet been reex-that many of the cancers in Hiroshima that it completely changes the scheme of amined.
wcre produced by high LET neutron radiation doses that people are supposed Although they differ in some of the radiation.
to have received in Japan, particularly in details they stress, all of these scientists Using the old Hiroshima radiation data Hiroshima. Until now, it was thought agree that the accepted figures for high as evidence, Rossi argued that the BEIR that the Hiroshima blast was unique in LET (neutron) radiation at Hiroshima committee should lower the cancer risk that it produr i s large field of fast are grossly oserstated. For example, the estimates published in an earlier BEIR neutrons, a hv 3rm of radiation.
neutron radiation at a distance of 1180 repon in 1972. Instead, the committee Neutron radi k isnsidered more meters from the epicenter of the blast raised the risk estimates. Rossi consid-dangerous than low LET radiation, a appears to have been overestimated by a cred this an alarmist move and withdrew category that includes x. rays, electrons, his support from the document. In the and gamma rays. Its singular presence in end, the Academy felt compelled to Hiroshima was said to make the cancer
- ne term; *h 1 ET' and "high 1.ET* (for lancar energy transfer) refer to the phpKal quahty of write a repon that efrectively split the risk found there anomalous. Most of the
'Ur'gInsYtraYefs NNt" YrIe'.*Ni$e'$ difference between Rossi's point of view radiation people encounter is not of this e
c electroni, samma ran, and s-rays. High LET radia-and that of his chief adversary, the com-kind. The wastes from nuclear reactors, UuoDe'a"*i E n"e7rfa'n2p* rnai
- mittee chairman, Edward Radford, an for example, emit gamma rays. Thus, a SCIENCE. VOL 212. 22 MAY 1961 900 00 4 8073 119522-0400501.009 Copynght e 1981 AAAS
number of scientists has e alwap consid-he number of.vutrons thought to hase more sense for the Department of Ener-cred liiroshima a special, high-risk cose, been present is now so small that one g) or the Nuclear Regulatory Commiu and in studying the peacetime hazards of must account for their elTeos b) increas-sion to pay for this uork., and "the radiation. the) hase discounted wme of ing the estimate of their potency. The electric power peopic redly should be the cancer data from that city.
resultant killing power of neutrons is interested," according to Auton. It is As it happcos, the cancer mortahty " incredible," Auton says. Industrial important that the new research be credi-data from liiroshima are the most valu-safety rules would hase to be resised, ble. Auton agrees that it would be best if able in the world. Unhke the data from reducing esposure limits for neutron ra-the sponsor were an independent group Nagasaki, the) are abundant enough to diation to one tenth of the present limits, not awociated with the wcapons pro-res cal a clear relationship beiw een doses For cri:icaljobs, companies would hase gram or the nuclear industry.
of radiation receis ed and ill effects. That relationship is defined by a linear equa-
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tion: an increase in dose abose the natu-
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ral background raJiation correlates with "i
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radiation. no matter how small, directly M [--
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to low LET radiation. It is too early to w.~617.g,, /.(,"y d f., A' //
us w me s.ay precisely what that pattern willlook hke, because now the doses must be Hiroshima.1945 recalculated for each radiation victim.
Some comerc huildms sunned thr blair.
But most of the researchers who spoke to Srience said the new data would prob-to employ ten times as many people.
Arthur Upton, the former director of ably increase the risk estimates for gam.
On the other hand, the health physics the National Cancer Institute and an ma radiation.
community may abandon the Rossi prin-espert in radiobiology, has followed this Radford, an adsocate of this point of ciple and conclude that nearly all the controsersy closely since he learned of view, claims that the argument oser Hi-cancers in fliroshima were produced by the new bomb data last fall. It is an roshima and its mortality data has been a gamma rays, not neutrons. That news important issue, he says, and should be distraction from the main body of scien-will not be welcome either.
the subject of more research, sponsored tific evidence. He says the 1980 BEIR Auton wishes frankly that someone by a neutral scientific organization such report miscalculated in emphasizing else were funding this research, w hich he as thejoint U.S.-Japanese Radiation Ef-mortaht, data so heavily, for death cer.
thinks is important for future health and fects Research Foundation. If the new tificates do not give a very accurate energy policy. His othce is doing it be-dose estimates are correct, Upton says.
reading of the number of cancers or ca= 'nobody else was interested."
"I am not sure one can substantiate the esen cancer deaths in a community. Rad-The controsersy has been brewing for at Rossi thesis." It may remain important ford thinks it was a mistake to pay so least 4 years, for that is how long it has for rrdiobiology, for there are differ-much attention to Rossi's theory about been since a gosernraent consultant first ences in the way that plants and animals deaths in Hiroshima, for he claims the ea%ed %us questions about the valid-respond in the laboratory to high and low theory is contradicted by "90 percent" ity c..e Hiroshima data. According to LET radiation. Upton agrees with Rad-of the epidemiological data on record. Auton, howeser, it was just 5 months ford that the new data greatly strengthen He is pleased that the Hiroshima data ago that he was approached by Harold the argument that there is no " safe" eray now look consistent with a!! the Wyckoff, chairman of a special commit. level of exposure to radiation, in that tee assigned to study this question for every incremental bit of exposure in-rest.
"The implications are far reaching for the National Council on Radiation Pro-creases the chances ofinjury, health regulation and nuclear po cr in tection and Measurements. It is a rrivate One of the curious aspects of this this country in general," sai,s David organization that collects and publishes research is the manner in which it was Auton, a physicist in the office of target radiation risk information. Since no oth-published. The record serves as a com-and damage assessment of the Defense er agency would fund the research Av.
pelling argument for declassifying as Nuclear Agency. His office is funding ton says, he agreed to have the Defert, much as possible of what is done at the research at Oak Ridge that may con-Departnient pick up the tab for worn government labs, for many of the as-firm the new dose estimates. As he de-being done at Oak Ridge, and thus come sumptions in this case might h;ve been i
scribes the situation, the health physics up with some answers for Wyckofi. The challenged sooner had the t nderlying community faces a nasty dilemma. if the funding began about a month ago.
data been available for scrutiny.
new bomb data are accurate. On one "This work is of marginal interest to The Rosetta stone of Japanese radia-hand, the standard-setters may adhere to us and we really can't afford to spend tion dosimetry is known as T63D. u hich Rossi's principle, which maintains that very much money studying civil ef.
stands for tentative dose estimates com-man) of the cancers produced in Hiro-fects," Auton says, but it is important to piled in 1%5. The figures were assem-shirra were caused by fast neutrons. But resolve the uncertainties. It might make bled by physicist John Auxier of Oak 901 22 M AY 19tti
Ridge in a painstaking analysis of mea-classified because it described in detail > cars of reserrch on health effects in surements made during and after the the makeup and radioactise output of the hpan, wcre ne.sr described in detail, in Japanese bl.ws, intersiews with the Little Boy (iiiroshima) and Fat Man 1977. howeser. the gosernment pub-bombardiers, and a test esplosion in the (Nagasaki) bombs. Ausier's methods of lished a quasi. technical narrative by Nesada desert. Some of his work was computing the doses, which underlie 15 Ausier (khihan, Energy Research and Deselopment Administration.
TID 27080) gising some additional informa-j tion on Ausier's methods.
Technology Transfer Reappraised As questions about these figures arose in the iate i,7o s. the Naiienai councii on Radiation Protection (NCRP) asked Transfer of technology from ;ndustrialized countries to descloping coun.
Ausier tojustify his estimates with more tries emerged ii. the 1970's as a hight) charged inue in the so-called North-supponing information. After working South dialogue. Less-descloped countries protested that control of technol-on this project for seseral months, Aud og) by the industriAized North keeps them in a state of technological ier esplained that he could not reproduce dependence.
all the data because some had been lost.
A report'just issued by the Organization for Economic Cooperation and He esplained to Science that when Oak Deselopment (OECDs in Paris questions major anumptions on which the Ridge was reorganized in 1972, he was technology transfer debate has been conducted. It argues that technology moved frem one place to another, and l
transfer has been mutually beneficial for industrialized and for deseloping his old classified files were left behind in countries, or at least some of them.
his laboratory. Ausier say s that the rec-The repon notes that technology transfer has helped a group of **industri-crds division at Oak Ridge made a mis-alizing" deseloping countries to participate, on stronger terms, h the world take in shipping the files: the valuable trading s) stem. These include Brazil, Mesico. South Korea Taiwan, Hong data were sent to the shredder.
Kong, and Singapore.
The NCRP continued to ask for confir-
'Ihe ry ort's main challenge to the notion of technological dependence is mation of the T65D numbers because its assertion that " technological mone'ies are temporary," that change is they had become important in the debate propelled by a " technology cycle." New technology introduced in one on the hazards of radiation and because country is transferred under tight control first to other deseloped countries new data were becoming asailable. In and then to less-deseloped countries. As licensing and sale of the technolo-1976 the Los Alamos Scientific Labora-gy spreads, it becomes standardized.
tory in New Mesico, a deapons design Proof that this process is working is seen in the rise in imports by center, released an estimate of the radio-industrial countries of manufactured got Js from descloping countries.
actise output of the Hiroshima bomb for Morcos er, some induurializing coumries are themsch es esporting technol-the first time. The figures wcre not pub-ogy, mostly in the form of turnkey plants and equipment, fished, but gis en in a private letter to C.
Feeaback from technology transfer also afrects industrial countries. The P. Knowles of Research and F.dop-impact has been most conspicuous in the decline of traditionalindustries, ment Associates, who was trying to help notably clothing. footwear, and light manufacturing. that hase faced off-the Defense Nuclear Agency pin down shore competition. Loss of jobs has created a protectionist backlash that the precise er.plosise power of the Fat includes enticism of technology transfer. But, says the report, technology Man bomb. This is one of the key uncer-transfer has benefited the United States and other OECD countries by tainties in the record; some say the blast creating (. ; ort markets for their capital-goods industries during a period of equa!ed the power of 12.5 kilotons of slow growth.
TNT. and o'hers say it may has e been as By focusing on the industrializing countries, the report ofTers a ~lectis e potent as 15 kilotons. Sescral people in view of the problems facing deseloping countries. It does note in passing the weapons and biophysics community that for the poorest countries, the cost ofimported oil, trade deficits, and soon obtained copies of the letter, in-1 I
foreign debt make the outlook bleak. Esen for the industnalizing countries, cluding Kerr at Oak Ridge and Kaul at the burden of energy costs, deficits, and debt hase " led to pessimism Science Applications. Using the new regarding future financing of deselopment."
data and computer techniqJes not avail-The rrport was prepared by the stafT of OECD, w hich is essentially a club able when Auxier did his research. Kaul of governments of western industrial nations plus Japan. OECD serves as a and Kerr in separate projects came up data gathering and intergovernmental policy-planning org3nization. It is, with numbers that were at odds with the therefore, not surprising that the report assesses technobgy transfer mainly 765D results.
from the sellers' point of siew.
Kerr's laboratory is the best equipped in broad terms, what the repon's authors say is occurring is a major and best funded for this expensive com-re*,tructuring of the international industrial system. For the industrial puter work. Kaul says, and for that rea-countries an " adaptive strategy" is counseled. With a two-way trade in son it has been given the primary respon-industrial products now established, the North can retain its comparative sibility for reviewing the old numbers.
advantage only by keeping its "innovatory capacity" at a high level.
Kerr's task is complicated by the fact Pressure to transfer R & D activities to developing countries will build as that he is in a sense Auxier's successor their scientific infrastructures strengthen. The report borrows from Lewis at Oak Ridge and works just down the Carroll to observe that industrial countries must " keep running to stay in ha!! from this senior official whout work the same place."-JOHN WALSH he has been asked to review.
Auxier, meanwhile, says that his data
%wth South Technolotv Transfers: The Adjnsiments Ahrad. Organaaten for Econornic Cooperaten and Desciorrnent. Pans.198L $12.
are the best available, not likely to be 902 00%40'31105:2@0:sou.500 C,spynght C 1981 AAAS SCIENCE. VOL 212,22 MAY 1981
resiwnists. Hn judgment is widely re-it. Earlier controsersies hase taught him argues that there is no esiJence showing spected. As the grand old man in this to mote cautious!) in matters as impor-that neutrons were present in significant field, he is in a position to induence tant as this, and he still thinks there quantities in Hiroshima.
funding decisions on new research. Aus-could be some weaknesses in the new Loewe, Kerr, Ausier, and others in ier told Scieme there is no need for an bomb data.
this controsersy will present their argu-independent resiew of the discrepancies This stalemate esisted for sescral ments at a meeting sponsored b) the between his data and Kerr's, espressing years until the summer of 1980 when Radiation Research Society on 31 Stay in an op;nion which may hase made it ' oewe decided to rework the calcula-Minneapolis. Auton calls it "the begin-difficult to ge the present resiew start-tions. He started the project because the ning of an important dialogue " one ed. Auton. the Defense Nuclear Agency old Hiroshima data and Rossi's recent which he probably will not be able to ofncial who makes the funding deci-warnings about the potency of neutrons attend because the new Administrat on siens, says that he has great respect for worried people in the lab. Lisermore has reduced the bureaucracy *s trasel al.
Ausier's work. a respect based as much scientists are insolsed in weapons re-lowances. But Auton hopes the meeting on Ausier's standing in the community search and are frequently esposed to will lead to a general and independent as on his abilit) to " drag out corrobora-neutron radiation. They wanted to know resicw of the issues. "If the wcapons tise data."
more about the dangers. Loewe's inses-folks" make it a strictl> internal project.
Kerr has neser published any of his tigation, completed lut October, found he says, "I just hase a concern that work outside the laboratory, he says, both the Hiroshima data and Rossi's nobody will beliese the results."
because he prefers to be " timid" about principle to be unsubstantiated. Loewe
-Euot MAR 5H ALL Science Adviser Post Has Nominee in View The job, turned down by several candidates, may now be offered to a man who is not a member of the science establishment Such concerns are abruptly dismissed The choice of science adviser to Presi-Tv r-
=-c--
du
- Reagan has been narrowed down to
]~
by Keyworth's supporters. Although he a smgle candidate: George A. Oa9
/
" lacks obvious credentials, that doesn't Keyworth, a 41-year-old physicist from mean he will not do a superb job." say s one. N,new scofTs that "he has all the the Los Alamos Scientific Laboratory, Although the job had not formally been right credentials-all he doesn't hase is 20 years membership in the club." In a K{
offered to Keyworth as of tHs writing, j
telephone interview with Science, Ag-Administration ofhcials espect an an-g j
nouncement by the end of May, but 9
./-s~
new also said that he thinks much of the caution that something could still go MJ unease about Keyworth is simply due to awry esen at this late stage of the selec-the fact that he is an outsider "If you get a bunch of chickens together and you I
tion process.
put in a new rooster, they start clucking When Keyworth's name came up as a p
,g and running around," he remarks.
potential candidate late in Arni,it drew
)
/
As for Keyworth's shortage oflinks to a misture of surprise and unease from I f' % /-
I the scientific establishment, Agnew says
+
the scienti6c establishment. The surprise h'
that " defense will be the thrust of this
/
stems from the fact that Keyworth is i
e M
i,.
?
Administration, and somebody who has virtually unknown outside his field. And
.~
the unease is related to the fact that his
$'[y,7 g,y the respect of the people in tFe defense
,ynea labs is needed." He adds: "For the past candidacy was being vigorously support-
- *## D.
ed by Edward Teller, the so-called "fa-four years, you hase had a geologist in ther of the hydrogen bomb." and Harold charge, and the defense community has Agnew, president of General Atomics "a s ery good scientist who is a lot broad-sutTered."
and former director of Los Alamos. Both er than his backg cund would indicate."
How did somebody from outside the are w ell know n for theit haw kish defense His background does not, howeser, traditional ranks of candidates for sci-views.
include sersice on the usual round of ence adviser get selected? Keyworth Those who know Keyworth describe government science committees. Hence says he was approached about the job him as smart and personable. His re-he has little experience with federal sci-carly in April, and "it came as a surprise scarch has been concerned mostly with ence policy and has made few links to to rne." The post uas formally offered in nuclear structure and low-energy nuct tr the scientific establishment. "He doesn't March to Arthur Bueche, head of re-reactions, and for the past 3 years he bs provide any channel between the nat;on. search and development at General Elec-directed the physics division at Los Ala-al bcientific) community and the White tric, but he was forced to turn it down for mos. One scientific colleague Arthur House " complains one veteran of sci-personal reasons. Seseral other people Kerman of MIT, describes Keyworth as ence and gosernment affairs.
were subsequently sounded out about SCIENCE, VOL. 212. 22 M AY 1981 0048075310522w03500300 Copynght c IWI AAAS 9M
N.;ws cnd Comm:nt New A-Bomb Data Shown to Radiation Experts Conference goers are impressed with the revised picture of Hiroshima, but foresee little change in risk estimates Afinneapolis. Physicist William Loewe afeasurements (NCRP), said, "I would to complete the research quickly and spoke at the annual meeting of the Radia-strongly disagree with anyone using this shore up the $100 million investment in tion Research Society here on 31 hlay data to determine risk coctlicients." It is Japanese data.
and gase the first public presentation of too carb to do that, he said.
Second, Jablon said, "I think it's go-the work he and Edgar hiendehohn have Locwe agreed that it would be wrong ing to be absolutely necessary in this done at the Lawrence Livermore Na-to draw broad conclusions based on his murky situ 0 tion that any dosimetry sys-tional Laboratory. They have drastically preliminary work, but he did tell the tem that is finally decided upon be rea-revised the estimates of radioactive fall-Afinneapolis Tribune that he thought the sonable in terms of biological influences out from the Hiroshima and Nagasaki new data will have a negligible impact on that we know about.... And since the atomic bombs. The most important sin-risk figures. Others, such as Warren Sin. problem is of wider scope than merely gle fmding they reported was that no clair, president of the NCRP and an physics. perhaps it w ould be advisable to neutron radiation of any statistical signif-organizer of the meeting, were stronger consider adding some biological exper-icance was present at Hiroshirna, sug-in their denunciation of Radford, sug-tise to the [NCRPJ task force."
gesting that nearly all the bomb-related gesting that the new Livermore data may Third, Jablon said, "I think that the cancers were produced by gamma rays.
esen make radiation look less harmful way this whole problem developed is If correct, this means there are no good than before.
very unfortunate. Afost of us, certainly I, human data for judging the toxicity of If the sponsors of the meetint; were heard about the problem... by word of neutron radiation.
unhappy with the way Loewe4 work mouth. The next thing was to receive The audience was receptive, and sev.
was presented to the public, other mem-pieces of paper w hi;h w cre not for publi-eral old hands said they found Loewe's bers were as unhappy with the way the cation, quotation, or citation.... I am work impressive. Na general consensus information had been circulated (or not told the Japanese Diet is about to have a was reached on whether or not Loewe's circulated) within the community. Per-debate on the subject, and still there is data should replace the old estimates of haps the most outspoken was Seymour nothing published thet one can point to atomic radiatior prepared in 1%5 by Jablon, the National Academy of Sci-and rebut or accept or whatever."
John Autier of the Oak Ridge National ences' staff officer for joint U.S.-Japa-NCRP President Sinclair responded Laboratory, nese research on late effects of atomic by saying that there was already one Afost of the participants agreed on one radiation. He is a veteran observer, biologist on the NCRP task force, and thing, howescr: they were unhappy with Jablon rose during the general discus-that he would consider adding more the way the news of the possible revision sion to make three points. The NCRP when an attempt is made to extrapolate j
health effec *t from the bomb data, One 1
~ ~ - -
-~
of the physicists who has been at work J
j uGiven the unique experience at Hiroshirna...
on the problem the longest, George Kerr or oak Ridge National Laboratory, said i
it really is appalling to think that we that he thought the data had not been stand here,36 years later, debating or, pubHshed sooner because they were not strong enough to stand up to peer re-i ders of magnitude in the doses," Seymour view. crwo relevant papers have now JablOn said.
b"" 5 b*i"*d ' "'"' Nd" * '
techm. "l notes:
ca
" Revised dose esti.
I j
-- mates at Hiroshima and Nagasaki." by l
Loewe and Stendelsohn, and 'lImplica-l was reported, and they wcre annoyed by has known since 1976 that there might be tions of new Hiroshima and Nagasaki l
the inte:pretation given by University or flaws in the Japanese data, he pointed dose estimates: Cancer risks and neutron Pittsburgh epidemiologist Edward Rad-out. "Afeanwhile, the EPA is busy set-RBE." by Tore Straume and R. Lowry ford, who has said that it may be neces-ting [ occupational radiation] standards; Dobson.)
sary to double or quadruple the risk other people interested in standards have Radford, who is not a member of the j
figures for getting cancer after esposure been making noises. It really is urgent Radiation Research Society, skipped the to radiation (Science,22 51ay, page 900).
that we get on with this job.... Given meeting. He expressed disappointment, I
i Speaker after speaker echoed the theme the unique experience at Hiroshima and however, at tiie attitude that "we can't l
sounded early in the meeting, that not Nagasaki and the tens of millions of say anything until we have everything in enough work has been done to permit a dollars w hich have been spent trying to hand," as he described it. According to conclusion such as the one Radford accumulate the human biological data, it Radford, that attitude can be used to reached. Harold Wyckoff, chairman 01 a really is appalling to think that we stand delay reaching any conclusion: "It's task force created in 1976 expressly to here. 36 years later, debating orders of what the tobacco industry did for years resiew this problem for the National magnitude in the does." He pleaded with the epidemiological esidence relat-Council on Radiation Protection and with federal officials present to gise aid ing cancer to smoking. They just said, i
IW 0036-8075 810619 !W500.5Go Coppight c 1981 AAAS SCIENCE VOL. 212.19 JUNE 1981 i
Well that last study wasn't perfect, so which, he cl:ims, is to minimize the paper, Rossi said he considered it just "v, interesting exercise," no more. He w c'!! ignore it.' "
dangers of rtdiation.
believes that if the Lisermore data tre
'The net effect of the new research, liara!J Rossi is a Columbia Unis ersity RWfard insists, is not hard to summa-biophysicist who cha!!cnged Radford's correct, they will make it impossible to views as alarmist when both were serv. say an> thing conclusive about neutrons nie: the radiation data for the two cities of throshima and Nagasaki are now like-ing on the BEIR committee. (Radford in Hiroshima.
was the chairman.) Roui argued that the An important cascat tipplies to all of ly to come out looking scry similar, the recent work on radiation in Japan:it "You can state that as a general princi-hazards of gamma radiation were exag-ple," sap Radford, "and I do state it.
gerated, and he cited the Japanese bomb does not include corrections for changes That being the case, they confirm the data to support his case. As part of this in the shielding prosided by build ngs or t
fact that it was primarily gamma rays thesis, Rossi put forward the idea that by body tinue. According to Jess Mar-iM produced the cancers, and that the many of the fatal cancers at Hiroshima cum, a contractor for Oak Ridge for a review of the data, significant resisions had been caused by neutrons, not gam-neutrons, for all practical purposes, con-induted so little that the>'re not impor-ma rays. Neutron radiation is found rare-of the Lisermore dose estimates may be tant "
Radford belieses that the Lisermore data strengthen his argument that a kn-AccOrding tO Jess Marcum, s,ignificant car no-threshold model is the correct one for descr;bing the carcinogenic effects of reyjgjOns Of the l_ivermOre dose estimates I
esposure to low lescIs of radiation. And may be neCOSSary befOre one can reach j
if this is correct, he says, the risk esti.
mates published by the National Acade*
a CONC!USIOn abOut toxicity, j
m) of Sciences in its 1980 report on the Biological Effects of lonizing Radiation (BEIRahould be restated. He thinks the ly in nature, and as a practical matter it is necessary before one can reach a con risks for contracting fatal cancer from radution should be doubled. He would of concern only to people exposed to sion on toxicity. Ma j
fis the risk at 250 to 500 excess deaths nuclear weapons and the innards of oper-spent abou per rad of increased radiation per I mil.
ating nuclear plants. Rossi's work ing by buildings and has discovered that the estimates of garnma doses in many lion people, not 100 to 250 deaths, as he prompted the NCRP to send out a spe-cases will have to be lowcred. In the area says BEIR and other documents ha.e cial advisory to wenpons laboratories fised it. Radford would also hke to see warning them that their safety standards of interest,1000 to 1700 meters from the the risks stated in terms of cancer inci-might be inadequate because neutrons epicenter of the bla lates that indoor gamma ray doses will dence, not mortahty, so as to recognize might be more dangerous than had been have to be reduced by a little more than that real injury is done by cancers w hich thought. That was 3 years ago, do not necessanly kill. Including these Loewe and Mendelsohn were swept 60 percent. The net effect, he believes.
into this debate in 1979 because they will be to make gamma doses for individ-l figures, Radford says, would make it worked at Lisermore, a. weapons lab, uals in Hiroshima about the same as in l
necewary to further raise the main risk and were concerned about the NCRP the old estimates produced at Oak Ridge l
coefficient used in the BEIR report.
Loewe did not discuss Radford's inter-advisory. Livermore did not change its in 1%5, while the lower than the 1%5 figures.
safety standards, but it did finance some In addition, George Kerr of Oak Ridge f
pretation at the meeting, except to say computer work by Loewe and Mendel-is recalculat that he could not understand how such views could be supported. Loewe said sohn, who attacked the evidence for he did not see how one could draw a Rossi's thesis. Their calculations, now body tissue for certai straight line through the old or new radi-made public, do not demonstrate that such as the ation effects data. Indeed, two scientists neutrons are safe. They simply show that on. Marcum reports second hand (Kerr from Lisermore who have been working neutrons were so scarce in the Japanese is in Europe) blasts that one cannot rneasure their ef.
final adjustment may be to produce no in conjunction with Loewe, Tore Straume and R. lmwry Dobson. presented a paper fccts with accuracy. At the same time, change in the the Livermore work significantly in-the two cities, but to increase slightly the suggesting that the new bomb data may f
lower the risk estimates for low doses of creases the estimate of gamma radiation risk for breast ca in Hiroshima and slightly decreases the into agreement with U.S. medical data gamma radiation. They, too, were skep-on breast cancer caused by x-rays. If tical of all that Radford had said.
gamma radiation in Nagasaki.
true, this is an " extraordinary conclu-So many variables have been cited in Using this data, Dobson and Straume this controversy that it may be worth-hase made preliminary new estimates of sion," Marcum says, because it will gis c while explaining just which data belong the toxicity of gamma and neutron radia-credibility to to whom. Radford, first of all, has done tion. Their paper concludes, among oth-Imewe, Marcum, and Kerr, as well as to no new research on this issue. He is an er things, that if one uses the total cancer the Japanese epide epidemiologist with strong opinions on deaths as a guide, low doses of gamma One of the few things that is clear in all the subject, and he has seized upon radiation look less harmful than before. this is that Liverm (Other statistical guides produce differ-irreversibly toppled the status quo. It Loewe's work as fresh evidence to sup-l ent results.) They also suggest that it also seems clear that the federal govern-port his view that many documents un-p derstate the hazards of low-level radia-may still be possible to blame the small ment would be well I
tion. Radford also says that in defending number of neutrons in Hiroshima for the work necessar this outlook he is working against the many of the cancer fatalities. Asked mate of radiation dosimetr professional bias of health physicists, about this part of the Straume-Dobson quickly as pmsible sus 19 Jt'NI: 1981 l
9 e
y*
=T--
m w N gw
-,r
--+y-e r,-
tosie than had been thought." lie faih Io I
mention thit the reduction in neutron p
l dose was cecompanied by a substantial l
increase in gamma dose, w hich counters that argument. The following example illustrates that point:
a[ b ^b C I b
.m..
ihre a...
a.
.a : UI.w.ta.
Tmue re Est e-Neu-Gamm.
mates trons ray s T6.5D' O.54 1.9
^
Radiation Estimates thing like it, is deemed to be the most LLNLt 0.064 7.7 likely after probing scrutiny by the scien-
'Tenuine d.ne emmates comruled in tvco.
g The article by Eliot Marshall on the tific community. But the usefulness of M*,"' " " *""#" "'*"# * * *
{r estimates of radiation dose received by the Iliroshima-Nagasaki data for the pur-the sursivors in Iliroshima and Nagasaki poses of radiation protection is not chal. For Nagasaki, the T65D estimates have (News and Comment,22 May. p. 900)is lenged by this dispute concerning the shown a predominant gamma dose.
g essentially accurate concerning what dosimetry, not are the actual linear risk Therefore the radiobiological effects ob-p~.
various people base said about the situa-estimates affected appreciably.
served in Nagasakp - ve previously been tion, but it gises an erroneous view of As Af arshall makes clear in his article, attributed solely to gamma radiation. Al-
{
the implications. It is unfortunau that, the workers at Livermore reexamined though different, to first order our gam-t although the revisions proposed by Wil-the Iliroshima-Nagasaki dosimetry at ma dose for Nagasaki is similar to that of L
liam Loewe and Edgar Afendelsohn at this late date under the impetus ofliar. T65D. Thus any conclusions drawn in the Lawrence Livermore National Labo-a!d Rossi's contention that the risks from the past concerning the radiobiological hi ratory of the T65 dosimetry have been neutrons are larger than had previously effects of gamma radiation in Nagasaki
(
widely circulated in summary form, they been supposed. Since the weapons labo-could not change significantly on the i
i hase not been published and therefore ratories have a real stake in the question basis of our new dose estimates alone. In
[,, j has e not 3 ct been subjected to the scruti-of the magnitude of risks from neutrons, addition, leukemia data for Iliroshima b i ny of the scientific community.De Liv-and hence the appropriate exposure lim. now tracks the Nagasaki experience i,
ermore revisions r,re being publicized its, they cannot be regarded as disinter. when plotted against our dose values (1),
t.
instead by individuals whose statements ested parties. As Marshall says, the rec-We therefore fail to see how our work concerning thect are unfortunately, ord of this controversy is a compelling can be a basis for assigning a greater
. r l
sometimes in error. Dus, Edward Rad-argument for bringing the data into the hazard to gamma radiation than was the ford, in a recent statement to the Envi-public arena through the traditional case for T65D. (Ilow ever, see below for f
ronmental Protection Agency concerning modes of open publication and peer re-additional discussion.)
iQ,,
the proposed Federal Radiation Protec-view and discussion. It is unacceptable We believe that definitive conclusions t
tion Guidance for Occupational Expo-to base discussion of important public concerning the implicatio,s of our new sures, stated that "... there is indica-policy decisions, such as occupational doses with respect to radiobiological ef-l tion from the new evaluation that the exposure limits, on rumor. hearsay, and fccts cannot be draw n until further work nl gamma ray doses in both cities have privately circulated, privileged docu. has been completed. The data base con-been os crestimated in the 1965 data, and ments, taining information on the individual Jap-i for this reason the risk estimates previ-Sr.ntova JABloN anese survivors must be revised to re-
{
ously derived even on the linear dose. Advisory Committee on the Radiation flect our new estimates. In addition, a J.*
response hypothesis are too low" Rad-E,fects Research Foundation, recalculation of gamma building trans-3 ford is wrong on both counts: Loewe and National Academy ofSciences-mission factors [they might be reduced 1
Afendelsohn assert that the gamma dose NationalResearch Council, by a factor of roughly 1.6 (2)] and body
[]
in Iliroshima was grossly underestimat-Washington, D.C. 20418 transmission factors appear to be impor-ed in the T65 dosimetry, while the gam-tant. Such new calculations would in-
[
G ma doses in Nagasaki and the neutron We wish to comment on hfarshall's crease the gamma radiation risk, in pro-f doses in both cities were overestimated. article dealing with our new estimates of portion to any decrease of the transmis-
.]
The net result of all this is that the risks the Iliroshima and Nagasaki radiation sion factors.
m i for cancer, per rad, estimated on the doses (really free-in-air kermas). Of con-We also wish to correct the following linear hypothesis, change very little.
cern to us is an inference drawn by statement in hlarshall's article: "This Radiobiologists and students of radia-Marshall and by some of the persons stalemate existed for several years until tion carcinogenesis have been intensely whom Atarshallinterviewed and quoted; the summer of 1980 when Loewe decid-interested in the contrast between the this inference in turn sets the tone for the ed to rework the calculations." A cor-effects of high LET and low LET (linear entire article. We take esception to rect statement v.ould be: " Unaware of energy transfer) radiation because of the statements that our results show gamma ongoing uork at Oak Ridge National p
hght that might be cast on the nature of radiation is much more harardous than Laboratory,in 1978 Loewe and Mendel-tJ the intracellular event that results in a previously assumed, sohn carried out u hat they believed to be
[ 1, cancerous cell. This discussion will have Marshall states that our much lower the fint calculations of Ilirosnima and j
to begin again from square one if the neutron dose estimates for Iliroshima Ngasaki doses to hase an air giound
>a j Lisermore dosimetry resision or any-imply "that the gamma rays were mere interface explicitly included. In August I $
6 SCIENCE. VOL. 2I3 1s
19.sn...t 6 r d.tif>ing significant criors h hl'. in cl. itis e tw'o; ic..! t h,in, s.c o.
N.3.n..Li. J h6 it.. u e to v.hfiJDA,
i in pres sous c.dcolations ciscwhere and wmpared to low I.I. T r..Jiationl is lack-sariations ma) o. cur has not >ct been j
,f f estabinhing aprcornent of their own cal-ing from the new dose-response curses estabinhed and depends on the desice
}
culations with in situ data at Iliroshima, for leukemia and breast cancer (in both r.nhation output. atmospherie condi-the) presented their results in a prelimi-cases cunes foi the two cities are not tions, and local shiciding. To date. only i
nary but detailed report which receised significantly dificient from each others. the cliccis of the foemer suo parameters l
uide picad dntribution.'
In the c.ne of tot..I nubgn.mcies. how es-h.nc been irnesty.iicd by Science Appli-
- 1. t m r. t! -
Mim. Inc. t L1 !:i.'s Ltion.d I.A.
Y. it i r su 1: la. u n cr. e; Lin. m Mi s t.i t mu s, enus..a cn 1.
cn i.
,ct i.. on.
J 1.+ wnce Ln cim.nc Nw 1.nu re m c Liisimosc National deaths in siiroshim.i than m N.casaki at tion.il 1.aborator ).
Laboratory. Unh e r3ity of Cuhfm nia, an) risen dose. If the e difTerences are a it may well be asked why the T65D Liwimorc 94550 result of the larrei neutron component in estimates are being questioned now.15 Iliro.hima (the new dose estimates still years after the> publication. The reason ner,re,in, show more neutrons in Iliroshima than for this is that the T65D values were 8 w. E. Loeme and E. Mendelsohn. "Remed derised almost wholly from measure-
~
$iOrNie7e"$NrNI),Yn7,g" in Nagasaki). the data suppest that the 4
d.. e einmees av Huo h.ma and Narasati RHE of neutrons inercases uith decreas-ments made during field tests of w capons h
raio y. Lhermore. Calif.; //ralsh th)s.. in ing dose (because of the decreasing er-and other radiaiion sources in ihe 1950 s I
- 2. Secum. -Hou e anenasiion t.ctors ror radi. fcctiveness of gamma rays) and may and early 1960's. As such. claims of
'$r"NEN"Ide.$a$n'NIIef.Nir",' $"Ch quite high '..duen interestingly, a substantial accuracy could be made fo i$
si;nificant fraction of the A bomb-relat-them at a time when purely analytical 2.5 m3 mai ed cancer deaths would appear to be methods of predicting device radiation
-JE' A number of conclusions in Marshall's the result of neutron radiation [this was output. transport and shielding effects I
article do not follow from the new dose also found for the earlier T65 doses were in their inf.mey and their results
['
estimates for Iliroshima and Nagasaki (5)].
subject to considerable uncertainty.
bj calculated by Loewe arid Mendelsohn.
R. LOWRY DOB50N Since that time considerable advance-g:
We have recently reported (1) an anal-Blomcdical Sciences Division, ment has been made in the desclopment ysis of the biotopicalimplications of the Lawrence Lircrmore National of an.d>tical techniques and the physical r-new doses.The Loewe.Mendelsohn esti. Laboratory Unircralty of Cahfornia, data required fs their use. Within the mates U) were combined with published Lit ermore 94550 last 5 years t is advancement has
[',
biomedical data from the Japanese A-Tont STRAUME reached the sta:.c at which the dose
[
bomb sunivers U) and dose response //a:ords ControI Department.
measurements made during the atmo-relations were analyzed for several ma-Lawrence Lircrmore National spheric tests can be reproduced analyti-
{~q jor effects, including leukemia, breast Laboratory cally to within the uncertainty of the measurements themselves. The claim by 7~
cancer, and total malignancies. What the f' I combined data show can be summarized Rossi and Mays (1) that the risk ofleuke-
"d"'""'
- 1. T. Suaume and R. L. Dotwon. Ifruftle fins. in mia from neutron cNposuc should be as fo!!ows.
press. R. L. Dobon and T. Siraume Rudar.
raised by a factor of 10 based on current 7
e The mortality data for leukemia and Res.. Abstr.. in rnsi.
me and E. Mendelsohn, //colr4 A bomb sunivor epidemiology and the F
total malignancies show dose response 2.g,E.
f curves for low LET (linear energy trans-L G. W. Beebe. H. Kato. C. E. Land. Radiar.
T65D estimates provi :d the impetus for T una E
fer) that are clearly sigmoidal in shape;
- '/J3.,N" '3$("f Tg,oi sg rr's. E the reanalysis of survivor dosimetry, us-n O
the data cannot be fitted adequately by Nashimon. Y. Tsup. J. Norf. Cam er last. 62.
ing state-of-the-art analytical techniques, IH7 (1979); A. A. Ama. T. Soruns. T. Honda.
linear regressions. The carcinogenic effi-M. Itoh. S. Niriishi M. Ciaki, J. Radiar. Res.
and precipitated the current controver-I i(
ciency (effect per unit dose) of gamma 3ll,32jlj [,sj,,,,,_;,,;_ gu,,,,,,;,,,,,
l9 sy,
,,riion rubriccri..n 26 trers.imon. osrord.
State of the. art analytical methods 4
f rays is less at low doses than it is at high k
doses. In the case of breast cancer inci-
,3l,"l,;,P i; ei nn,nfj and data may be used successfully to 10; red a g
produce highly accurate dose recon-Report (United Nations. New York.19ns. p$ structions for Japanese A dence, although the situation is not so N,jj((j"dl,^((/[,3,,#'j""f"',[M*Ma
~.I clear, the data are again well fitted by a t
d r soences, washington D c.,
vors. Ilowever, current results from
- 5. N'onal ^ca emy o.I koNi. Radiar. Ars. s4. 395 civito).
such efforts must be considered incom-sigmoidal (linear-quadratic) curve.
t" 1
e Because of statistical uncertainties plete and prefir*:.y. J!any elTects.
in the A-bomb-survivor data, the dose-J response curves are still unable defmi.
Marshall generally associates those such as those of ra liation free-field vari-
{-
tively to demonstrate either the presence named in his article on Japanese A-bomb ations on the character orlo or the absence of low LET " threshold" survivor dose estimates with the propo-have yet to be determined. The scientific b
doses for human malignancies.
sition that the likely outcome of dose community will require substantial proof P
e Risk coefficients for leukemia and reassessment will be to increase the risk of the accuracy of the analytical tech-breast cancer are consistent with gener-of cancer ascribed to exposure to low niques before accepting results of such b
ally accepted values (4) at low doses. LET radiation. I wish to disassociate methods in lieu of the largely empi b'
The low LET coefficien* for total malig-myself from this thesis.
T65D salues. The programs to produce
{-
nancies, howeser, appears lower than The reanalysis of the Japanese dosim-this information are just how beginning.
Dr AN C. K Aut the earlier estimates (4). Only at high etry is a complex task, affecting not only do es. above those relevant to radiation the net, tron dose but the gamma ray dose Adiam ed Ter/mology Division.
)
E protection standards, do the risk coeffi-as well. Esidence piesented to date sug-5< /cm r App /h arioris. /nc.,
', } o cients tror certain malignancies. for ex-pests that, while estimaics of neutron Si haumlinry. //linoi. 60195 y
I ample, leukemia) become si;nificantly doses at both cities ma)
~ case.the p,,o,,,,
r t higher.
estimate for the linoshm.a vnma ra)
,, n n g,,;,g c g, jf,,,,,,,.;, g e Clear esidence for high neutron dose may increase rebtise to that at tics SCl[NCt. VOL Oli 11 s
S
k I*
4-21 e
4*
Calculated dose commitments to a maximum infividual from Summer statknko eration&c dee/.O d*-c/
Table 4.10 i
cn/c uhtal r e
/ s 4/
g pu/sc, 4
f
-AU da a t; t{.;... g ;gu g
- mii,iiiyi par
,....-~~r..
s 4
Calculated 2e i n objective?.desss va/vcf Saukeher-}.1 0$u're'$ve k
r(Me/f//t 3
Liquid effluents 0.05 J
Dose to total body from all pathways, 5 Dose to any organ from all pathways, 5
0.06 S
C.26
}
Non-tritium releases C:/y,;/u. 7 5 Ci/yr/ ='t j
7 Noble gas effluents (at site boundary 0.23 Gamma dose in air, millirad yea 0
0.57 Beta dose in air, millirad ye
.h20 Dose to total body of an i dividua 5
0.14
,e 0.42 Dose to skin of an individual M 15 d
j g
Radiolodine and particulates {Yb' b
8 m all pathway) 15 0.75 Dosetoanyorganfro/yr/.v [f' 1 Cf /y.-/=it 0.07 3
I-131 releases
(:
" Guides on design objectives proposed by the NRC staff on Feb. 20, 1974 4
From U.S. Atomic g
consider doses to individuals from all units on site.
Energy Commission, "ConcluC ng Statement of Position of the Regulatory Staff," Docket No. RM-2, Washington, D.C., Feb. 20, 1974, pp. 25-30 pub-3 lisheci as Annex to Appendix I to 10 CFR Part 50.
4 Carbon-14 and tritium were added to this cotegory.
b
- t Annual total-body population dose commitments in the year 2000 Table 4.11 U.S. population dose commitment (person-rem per year)
Category v.
a l
Natural background radiation 27,000,000 Summer station operation b
1300 Plant workers i
General public l,
Radioiodine and particulates 27 1.1 Liquid effluents 0.8 Noble gas effluents 7
Transportaticn of fuel and waste i
Calculated using the average U.S. background dose (102 millirems per a
year) in U.S. Environmental Protection Agency, Natural Radiation Exposure in the United States, Report ORP-SID-72-1, June 1972, and year 2000 pro-jected U.S. population from the U.S. Dept. of Commerce, Bureau of the Census, Population Estimates and Projections, Series II, Series P-25, l
No. 541, February 1975.
DThe average reactor annual dose is 410 person-rem.ss,ss Particular l,
high as plants have experienced average lifetime annual doses asFor purposes of conserv 1300 person-rem.
l higher value in this assessment.
l 7
.r I
4-22 4.5.2.2 Dose comitments from radioactive liquid releases to the hydrosphere Radioactive effluents released to the hydrosphere from the Summer station during normal operation
{
will result in small radiation doses to individuals and populations. The hRC staff estimates of the expected liquid releases listed in Table 4.12 and the site hydrological considerations discussed in Sect. 2.3 of this Statement and summarized in Table 4.13 were used to estimate radiation dose commit-ments to individuals and populations. The results of the calculations are discussed below.
Radiation dose commitments to individuals The estimated dose commitments to the maximum individual from liquid releases at selected offsite locations are listed in Tables 4.8, 4.9, and 4.10.
The maximum individual is assumed to consume well above average quantities of the foods considered and spend more time at the shoreline than the average person (see Table E-5 in Regulatory Guide 1.109).
l Radiation dose commitments to populations Annual radiation dose commitment from liquid radioactive releases from the Summer nuclear station are estimated for two populations in the year 2000: (1) the population within 80 km (50 miles) of the station (Table 4.9) and (2) the entire U.S. population (Table 4.11). Dose commitments beyond 80 km (50 miles) are based on the assumptions discussed in Appendix 8.
For perspective, annual background radiation doses are given for the population within 80 km (50 alles) of the site j
(Table 4.9) and for the entire U.S population (Table 4.11). The total body population' dose to the population within 80 km (50 miles) of the site frca liquid radioactive releases from the Summer l
Nuclear Station (i.e., about 1 person-rem) is a small fraction (less than 0.001 percent) of the corresponding population dose from natural background radiation (i.e., about 105,000 person-rem).
The total body population dose to the entire U.S. population from liquid radioactive releases from the Summer nuclear station (i.e., about 1.1 person-rem) is an even smaller fraction (less than 0.00001 percent) of the corresponding U.S. population dose from natural background radiation (i.e.,
about 27 million person rem).
l Table 4.12 Calculated releases of radioactive materials in liquid effluents from the Summer station l
Nuclide Ci/ year Nuclide Ci/ year Corrosion and Acivation Te-129m JG-S M Produch Te-129 M G84 8
Cr-51 1.1E-4 I-130 1.9E-4 Mn-54 1E-3 Te-131m SE-5 Fe-55 1.1E-4 1-131 IE-1 Cc-58 SE-3 I-132 3.8E-3 Fe-59 6E-5 Te-132 9.4E-4 Co-60 8.8E-3 I-133 5.7E-2 i
Zr-95
- 1. 4 E-3 I-134 1E-5 l
Nb-95 2E-3 Cs-134 2.1E-2 l
Np-239 4E-5 I-135 8.3E-3 Cs-136 2.7E-3 Fission products CS-137 3E-2 Br-83 4E-5 Ba-137m 5.7E-3 Rb-86 2E-5 Ba 140 IE-5 Sr-89 2E-5 La-140 1E-5 Mo-99 2.8E-3 Ce-144 5.2E-3 Tc-99m 3E-3 All others 4E-5 l
Total except Tritium 0.26 i
Ru-103 1.4E-4 l
Ru-106
- 2. 4 E-3 1
Ag-110m 4.4E-4 Tritium 360 l
l Read as 1.1 x 10 *.
a l
l
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the ilatter SOUTH CAROLINA ELFCTRIC & GAS Docket No. 50-395 COMPANY Virgil C. Summer Nuclear Station, Unit 1 j
CERTIFICATE OF SERVICE I
I hereby certify that corrected copies of REBUTTAL TESTIMONY OF EDWARD F.
BRANAGAN, JR. REGARDING CONTENTION A10 in the above-captioned proceeding have been served on the following (indicated by a +) by deposit in the United States mail, first class or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Comission's internal mail system, this 24th day of July, 1981. Copies were served on the Board and parties during the hearing on July 2, 1981.
Herbert Grcssman, Esq., Chairman Brett Allen Bursey Atomic Safety and Licensing Board Panel Route 1, Box 93-C U.S. Nuclear Regulatory Comission Little Mountain, South Carolina 29075 Washington, D.C.
20555
- T Joseph B. Knotts, Jr.
l Dr. Frank F. Hooper Debevoise & Liberman l
School of Natural Resources 1200 Seventeenth Street, N.W.
University of Michigan Washington, D.C.
20036 Ann Arbor, Michigan 48109 Randolph R. Mahan, Esq.
Mr. Gustave A. Linenberger S.C. Electric & Gas Company Atomic Safety and Licensing Board Panel P.O. Box 764 U.S. Nuclear Regulatory Commiscion Columbia, S.C.
29218 l
Washington, D.C.
20555 *
+ Atomic Safety and Licensing Board
+ George Fischer, Esq.
Panel Vice President and General Counsel U.S. Nuclear Regulatory Comission South Carolina Electric and Gas Washington, D.C.
20555
- Company P.O. Box 764
+ Atomic Safety and Licensing Appeal Columbia, South Carolina 29202 Panel U.S. Nuclear Regulatory Comission Richard P. Wilson, Esq.
Washington, D.C.
20555
- Assistant Attorney General S.C. Attorney General's Office
+ Docketing and Service Section P.O. Box 11549 Office of the Secretary Columbia, South Carolina 29211 U.S. Nuclear Regulatory Comission Washington, D.C.
20555 *
+ Mr. John Ruoff P.O. Box 96 Jenkinsville, S.C.
29065 un Counsel for NRC Staff
. _ _ _