ML20037B517
| ML20037B517 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 02/18/1972 |
| From: | Dumelle J ILLINOIS, STATE OF |
| To: | Schlesinger J US ATOMIC ENERGY COMMISSION (AEC) |
| Shared Package | |
| ML20037B515 | List: |
| References | |
| NUDOCS 8010140631 | |
| Download: ML20037B517 (14) | |
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,4 STATE or ILLINols PDLLUT2 DN U DN'P H D L 13 DA R D 3o9 Wtsr WaswsNorom StattY suite 300 Davs o P. Cu m n e r, c.,...
CHICAGO. ILLINotS 6 o606 Tus e-o SAMUEL R. Atomaces s's.vos.saro JACQs C. DUM ELLE RicMamo J. Kas s tL sa-uct T.La-Tom.s.
February 18, 1972 Dr. James Schlesinger Chairman Atomic Energy Commission Washington, D.C.
Re: Dresden Nuclear Plants
Dear Dr. Schlesinger:
The attached statement by Illinois Representative Harold Katz and Dr. Edvard Radford is cuite disturbing.
Dr. Radford (see page S-4 of his statement) Oceputes the dosage to people one mile northeast of the Dresden, Illinois nuclear p3 ants (near Morris, Illinois) as being 6E0 millirens per year.
Ta.1 dosage is far above the new 5 mr AEC standard and also ahove the old 170 mr standard.
I would ask that you immediately have your staff check into Dr. Radford's computation and, if verified, cause the radioactive emissions to be drastically reduced.
l ory truly yours, f
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BEFORE Tile POLLUTION CONTROL EOARD
.0F TIIE S TATE OF ILLINOIS
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Application of General Electric )
Cor.pany For a Pernit to Opc ato )
PCB 71-238 Its.'tidwest Fuel Recovery Plint )
SUPPLDIE"TAL STATE"E::T OF UA11
';'O MAXE F.On_
DEFI.f1"_S ?.:;D CE cTAIN TI:E NATURE OF Ti:5 TE3TI 50:32 TO a.; ADDUCED IF ITS PLTI'210 i Ti. 1:72E:NE::E AND M5TICH TC RTO.;E:1 R;00.~O IS ALLOUED Now cones the Intervonor, ILLI::OIS CO:G: UNITY ACTION PROGRRI of the INTERNATIONAL UNI')N, UNITED AUTOMOBILE, AEROSPACE AND AGF.ICULTURAL IMPLEMENT WORKERS UNION OF AMERICA, UAW, a voluntary ascociation of one and a half million nonbors, ar.d, in response to the order cf the Pollution Centrol Board of the State of Illinois of January 19, 1972, that it specify in greater detail the general nature of the testimony of Dr. Edward P. Radford that would be adduced if the record is reopened to permit him to testify, statas as follows:
1.
The present state of the record does not contain adequc data upon which the Pollution Control Board of the State of Illinoi could nahe a reasoned decision as to whether the operation of the Miducst Fucl Pmovery Pleut (MFRP) involves a sig;nificant public health hazard, 2
The location of the MFRP near the vicinity of Drcsden 3 g
II imd III wa : a sericas environ.chtal cistake ni.nce the conbincil inpoe t on thn_f_rce involyci <ChQhroc c,perating nucle.:r reactgre in t.orns cf rr..!icactivity alreadv cxece/s e :isting Fe.!cral standarc
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3 The record 1.[ deficient in.not includi,ng alcquate meteorological data upon uhich the commission could set.
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This is particularly unfortunate since tho existence of the thrco reactors does provide an ideal experimental situation for the naki of extensive acteorologi:a1 findings of critical impcrtance in the evaluation of th-. public' health problen presented. The record should certainly contain facts concerning vind speed, direction, frequency of staile conditions, and actual-radiation doses from the Dresden plant that reach surrounding connunities.
A perfect opportunity is presented for determining the persistence of the plune under the atmospicric conditions there existing. The record is seriously deficient it containing no such data.
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The record does not contain evidence upon which a coun evaluation can be nado of the atequacy of the sand bed filter syst the critical 1cnt filter system hich is design.ed t,o take c,at particulates before they go up the stack. The record is incomplet in failing to contain the charactaristics of the systca as it has.
operated at Savannah River or any other location The assumed l
efficiency and adequacy fin,Is no sur port in ev{dence in the record l
The question of what radioactive nai.crial uill be clininatef frc.m l
the particulate natter that will be' 'enitted froia the stack is l
of such great inportance in evaluating the plant's radicactive impact on the area that supperting (ata should be required to be presented, 5,
The efficacy of the iodine containment system is not estchlished by adequate scientific cvidence in thc.rocord s C.
h'ith regard to the contaimacnt vaults for high level waste materials, the record is dificient in failing to include the experience at Savannah River (S.C ) and Ilanford and such other 3
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cxperience as may demonstrate thd characteristics on 2 results of this nethod of centrinment of high level uantes s I
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The monitoring systch as contemplated by the order is wholly inedequate. The env1.ronmental inpact of MPRP is largely unknown due to the uniqueness of nucicar fuel reprocessing plants.
The Board proposes to rely upon monitoring' done by the applicanti but it can be fairly said that.the record for accuracy for operatin compenics generally has bcon shown to be extremely bad with regard to monitoring radioactivo discharges. Particularly in view of the existing probica of radioactivity in the area, the very closest chech should be 1:cp t on the radioactivity enanating from the plant, and this most decidedly shoull not be the responsibility of the General Electric Company whose interests may be adverso to the public in the nonitoring prpgram. The General Electric Co=pany should be surcharged on a per to of fuel processed basis so that the State nay carry on an alcquate monitoring program to protect its citizens who live in that general arca 'frca the kncun hazards of radioactivity, as more fully described in the, attached Statement.
8 Edward P. Radford, M.D.
(Harvard University, 1946),
whose studies have included work at the Mass 7husetts Institute of Technology, is Professor of Envir: nmental 1:cdicino at the Johns 1:opkins University School of 1 rgione and Public He'alth.
Dr. Radford is a member of the Natio1al Academy of Sciences Conmittee on the Biological Effects of Ionizing Radiation, which is advisory to tha Federal Environmental Protection Agency con-cerning proposed changes in standard 1 of radiation exposure.
He is also chairman of th* Power Plant and !!unan Health and Welfarc l
l Studies Group, the Department of ne tural Recources, Stata of l
Maryland, and a nerber of the connittee on Pouer Plant Siting, l
National Academy of Encincering, His najor acadenic interests l
i include radiation carc.inogenesin, povement of inntopos in the biosphere, and enelroruacate.1 healt h,'l particularly air pollutic effects on man, P -
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Attached hereto and made a part hereof is a digest of sece of the testimony that will be elicited from an examination of Di, Ita6 ford if the Eoird sees fit to reopen the record for this purpose.
UAU ILLI!!OIS CO::" UNITY ACTION COUi:CIL
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gj FJ.TZ & FRILD;i4N 7 South Dearborn Street Chicago, Illinois 60603 312/263-6330 9
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SUlriAPY OF SC'tC OF Tile TESTIMCMY 'IO DE PRES *;trrED Br?O31: ILLIUDIS POLLUTION CO:rrR*JL DOf.itD liEARING CO!;COR'*I::C TIIC MIDL~JST FUEL RECO*/URY PLAUT N2 ?! ORRIS, ILLIMOIS Edward P. Radford, 21.D.
Professor of Environnental Medicine Johns I:ophiss University School of firgi'ena and Public IIcalth 1.
I currently teach radiation effects at Johns Hopkins, and some of my resecrch in the past has dec1t with radioir.ctopes in'the biost.here. I am also a racaber of the ;;ational Acade.ay of Sciences Committee on Biological Ef fects of Ionizing R diation, which.is reviewine the scientifi-basis of radiatio.. standards.
I appear as a private citizen concerned with assuring that the great increcsc in electric pcwcr' capacity occurring in<the next decade be achieved without publ.ic health con:2;uen:en to the pceple living near the power plants anS r(lated facilitics.
2.
The !!idwest Fuel Recovery Plant 'is the first coracreial nuclear fuel reprocessing plant to use the nc..' to:hnology described alttady to the Board. As such, thera is only a partial basic for determining the environmental effects of the plant in quantitative terms.
It is regrettalic that the Board has had only vaguely documented statements by the Company concerning the potentials releases of radionuclides from the plant, and that the health inplications of tha plant have been presented only by witnesses
' called by tac corpany, The concultant vitn-as are highly cerpoten' but the overall as ser.s: tent.of the heal th hannr-24 or le.ek of then at the E: orris -Dros<'on conple:< has been doan pri nril.y by crployces of tha Conpany, I submit that this has resulted in a presor.tntion to the Board that is inco; pleto, 3
The record of nucleer pc.rcr crorations to date indicates that both for reactors ar.d for fuel rcJrm c L L". fo 'ilitice r C"3 4
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operating companics have had inexact or incorrect information concerning the actual relc asos of radionuclidos from their plants.
In many cases the releason are indeed insignificant, but in others they are not.
Gnly the surveys carried out by the U.S.
public I!calth Service have termitted scientists to evaluate which plants are releasing amounts chich nay have health uignifican It is L.y strong contention tlat the evaluation of the health significan:o of the Morris-Dresden plants should be based as much as possible on actual tcanurements' of environmental contanination and on actual operating data, rather than on calculations nade by the Conpany, Fortunately strdics of the Drcsden I plant and the Ecst Valley plant have Secn carried out, and there should be availabic sono data fron fuel reprocessing carried out at Hanford and Savannah River, alth> ugh such data have not been presented by the company.
4 In assessing the health s'ignificance of relebscs frcn MF RP, tuo points must be kept in nii d ' First, so far as the people living in Ncrthern Illinois are con:erned, especially those in the principal downwind directions, it is the total contribution of radiation exposure fron all nuclotr power sou, recs that is k
important.
In other words, evaluaticn of radiation exposures from the Dresden plants nust be considered in relation to the.
MFRP releases. Because of their proainity and the prevailing winds,.the LaSalle plants under construction might also contribute radiatinn exrosure to peep 3e in the Mnrris-Cha'nchnn orca, but they are likel to he small anri vill not be consinnr-1 further i
in this discussion.
The second point of inportance is to put the health nignificance in percpective
- y evaluation of the cancer richs s
fron whole body radistinn exposure in that. Met.ine co:p7nere to 1000 nrcn per yccr eculd incrossa the cancer rink to thc inJ.ividual s _ ;..
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by 4% to 20%,
The range 'c:: pressed in these figurcs' is principally due to our unecrtainty in the Cesrce to which the risk is lessened by having the radiation exposure stretched out over long periods of tinog but it also includes such factors as whether the individual s nokes cigarettes or not.
Now I would not consider this at acceptable risk frcm environmental contamination, nor does the AEC, since the n:ximum individual exposure permitted under current regulations is 500 nrem per year.
On the basis of the linear hy,3cthesis, a lifetime exposure to 1 mren per year would increase the cancor risk to the individual by 0.004t to 0.02%.
I personally censider such small additional risks are negligible, and I belicyc that any reasonable person should agree,. The problen arises when exposures are between these two extremes, one acceptable and the other clearly not accoutchie.
At 10 nrem per year, the added ca';cer risk is 0.04% to.2%.
In 'this ange it is a natter of judgnent what constitutes an acceptable risk, and I personally belicve that the risk at 10 creu per year is acceptable, but not the risk at 100 nrer. per year.
Cancer is to' devastating a disease, and even a 1 to 2% increased risk that can be avoided should he, when that risk is not incurred for the direct benefit of the individual him self.
5 The exposure data, from Dresden I, II and III that I have availabic is based on.the U.S.P.H.S.
survey of Dresden I done in 1968, and discharge data provided by Connonwealth Edison for 1969 and previcus years. I:y calcalations indic'tc.th:.: in 1963 the ratio fc: expeca,rc at about I nile in the northeast d irecti on, to potcr produce] in 0.2 to 0.3 nrca per year por I'Wo.
In 1969 the noble cases released wcrc three times greater, even
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though the c2 cctric cdtput was not r.uch higher por 1969, therefort s
I catirtate the abrve ratio to be 0 1 to 0.7 :trem per yccr por 'G:c.
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The uncertainty is the correct f,igure lies as auch in the uncertaintics in actual releases as it does in the lack of noteorological data In ;968, Kahn and associates.had no. actual r
meteorological data for 2resden and used Argon,no Mational Lab i
data instead. Their studies ~also showed that actual releases at the stack were about 50% ' igher than were reported by the h
Company fron off-gas delay line neasurenents in the plant, an'd in a,ddition that the nixture of xenon and krypton isotopes varied considerably from day to day.
Finally the sharp rise in radio-activity in 1969 has been ascribed to greater _ leakage fron new fuel rods inserted during refu1111ng at that time.
I conclude that under the most up-to-date conditions, with a stack height of 90 meters, the Dresden plants shou 12 produce from noble gas discharges a radiation dose at one nile of 0.4 mren per year por ML*:, but *...:re is's factor of ncarly two uncertainty in either direction (higher or louer). Extrhpolation if this figure to the three reactors can be done by assuming the same stack height and ccaparabli operative conditiens.
The total capacity of Dresden I, II and III is about 1900 :.We, i
and on the asst =; tion 6f operation at 90% of capacity the power l
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generated would be 1700 nt:c per year.
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this load the dose tc peopic at one :lle to the northeast uccid be i+
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-600 cren per year.
On the basis of projections of the about Oak Ridge National Laboratory for dispersion in the plume, the
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dose at Channahon would be about h'alf or 390 nren per year, g
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and at 20 kn (Jolic ti g ab out one.-tr alf th, or about 55 pren per yea:
s still an unacceptchle c::rnsore in. y opinion.
In shorte in ny
. opinion,cVen without the addition of MFR?g.the raliation c::pocure is already excessive in the vicinity,of the reactors affec'ing peepic not only to the northeast but also in other directions wherc l
the vind direction ec:nmonly blous.
'io neet uhat I believe arc currentJy acceptablo - tan'ards of radiatien eurosure to th< tj en ere l t
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being donc for Dresden II and III) or reducing the power levels.
It is clear that the decision to locate the MFRP adjacent to these largo reactors was a great mistake,
- 6) The radiation e:'posurcs from MFRP are more difficult tc assess, since with a few ex cptions, such as krypton, the amount of various isotopes actually released from this process are not known, especially over long periods of operation. I agree with Dr. Whipplc and with the Comp 1ny's Environmental Report that the skin dose from krypton-85 rele tses is not likely to be great, although on netcorological groun(s I assign greater uncertainty than they irply. The risk of car cer from skin irradiation is not known at this time with any certsinty for nan, particularly in relationship to synergistic action of ionizing and ultraviolet radiation on the skin. For the o'dcr isotopes handled.at MFRP, there is inadequate basis presented by the Ccmpany to deter-nine the amounts and the health sigsificance of the expected releases.
Tritiun has been discussed at considerable length by Dr. Cronkite, and it is significant that his estimates of the dose from this isotope differ somewhat from those of the company's representatives. There are some areas of disagreement between ny analysis and that of Dr. Cronkite concerning the tritium hazard, which I believe are somcwhat greater then he has indicated, but they are less inportan' tr.an the fact that the tritium distribu tien pattern is so poorly knovn for discherges of this ragnitude an tritiated water vapor, The' only comyarab1c experience with tritiated water vapor releases hae been at Savannah River, and unfortunately the dita availabla thare arc incenclusive bccausc a substantial part of the tritium has been directly diccharged S ~
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4 It is apparent that extensive determinations of as a liquids trit.ium in the environs will have to be undertaken if the plant.
bjgins operating.
I shall mention :nly a fe: of the other isotopes which Iodine 129 containment will may add to the above expo.ures.
s because it is now known that this long-lived isotope be important, has accunulated in the vicinity of the Ucst Valley, hew York plant and therefore will build up ;yrogressively as long as the plant operates. Iodine containment systens 99.9% effective have been described and the Ccapany should supply the appropriate data.
The Special Studies Group of the Environnental Protection Agency, using this containment figure, hcs estinated that the thyroid dose fron iodine isotopes from a MFRP type of plant at two miles would he about 25 nren per year, half frcn Il29 and hcIf frca To these thyroid doses are added those fron whole body I131.
irradiation, tritina and other intirnal enitters.
If containnent techniques are as effective as hoped for isotopes such as cerlun, strontium and Cesium should not the MFRP,
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constitute a significant' heal';h problen, but again it is worth cmphasizing two points. First, the region will have to be nonitored to detect if releases are present, and, second, an accidental release could result in rapid dissenination of l rge amounts of these and other nuclides',' in concentrations that could be inportant, An inportant special problen at nrnP is containnent 7.
of the hipha-e.itting cle:,ents plutoninn and the honyy actinides In order to nec+. th, design specification ancricium and curius, f or non -volatile. alpha-eni t t img clencnts, contr.ireant of all but about lx10"7 of the cicnents process.md vill have to be achieved, that. is, the r entnin~nnt svn rf..s u!.l.1 have to provent any nore e
tht.n one-tenth part per uillion of fh, fuel processed from crrg:
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Whether the commercial o?crations can achieve this result with this technology is not clear, but such a high degree of contain-nont is not assumed by the auth' ors of ORNL Report No. 4451,
" Siting of Fuel Repro ces sing Plants and Waste Management Facilities,"
The prob 1cm from these ele,cnts is that they becone entrained in evaporated drop}et nuclei, adsorbed on larger particic and when released will attac1 to soil and other particles.
Since nearly all have long physical half-lives, they will accunulat in the vicin :.y and may be inhaled as radioactive particles.
In the soluble form, the analysis of the Special Studios Group indicates that the. dose to the respiratory lymph nodes fro.m a_n MFRP type plant could be 420 mrei for a year's exposure at two
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niles (dose delivered over 50 yelrs). I am also concerned with inhalation of insoluble forms tha' " hot" particles'nay irradiate bronchial epithelium with high 3ccal doses. Under these conditions a few particles may deliver relatively high dosos fron the highly effective alpha radiation. There a: e no data that will permit estinates of risk frcn this scurce Lt.t it is known fron Rocky Flats data that local recycling in dust occurs. It is significant that the extent of local contanination from plutonium at the, Rocky Flats plant was largely unknown until local groups investigated thi problem on their own af ter the Rocky Plats fire.
8, The MFRP will calcine'high level vastes and store them as solids under water in tanks on site It is known that s
sinilar tanks holding liquid wastes at r.anford and at Saiannah t
. River have cracked end relcaned radioectivity into the ground.
There is no statenont by the Company of the Icycls of activity in the,1_i g expected in these tanks, Such data should be su;2 plied along with test evidence on uhich they conc}ul-that cracking of the high level waste tanhn vill not occur.
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9 To summarize exposures from P.FRP to the population in the regica of the plant, n number of tissues (skin, thyroid, lung tissues) can be expected to accumulate significant radiation dose
'(10 to 100 mrem per year, and " hot spot" doses frem alpha emitter of unknown extent)..In costrast to the Dresden exposures which are to the schole body, these doses are not strictly additivc but because of the radiosensitivity to cancer of the thyroid and,lungr they can be considered partially s,o.
The Board should recognize that t?e uncertaintics in these dosos are very great, and the estimates could be ofi by as much as a factor cf 10 in either direction.
- 10. In view of the inevf.tability of constructica of MFRP and the importance of monitoring its effluents by an independent agency, I recommend that a surchsrge per ton of fuel processed be paid by the Conpany to the f.tTte, the funds to be used to obtain equipment and personnel to provide ra0iological surveillanc of this plant. In this way, these othar areas of the country benefitting from this plant vill help pay for assuring the safety of the citizens of Illinois living in the vicinity of the plent.
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Edward F.
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Whether the comnarcial o?crations can achieve this result with this technology is not cle ar, but such a high degrec 'of contain-acnt is not assumed by the auth' ors of ORN$ Roport No. 4451',
" Siting of Fuel Repro ces sirg Plants and Waste Kanagement Facilities,"
The problem fron'those elements is that they become ent'ained in evaporated droplet nuclei, adsorbed on larger partici and when released will attac't to soil and other particles.
-Since nearly all have long physical half-lives, they will accumula in the vicin :y and may be inhaled as radioactive particles.
In the soluble form, the analysis of the Special Studios Group indicates that the dose to the respiratory lymoh nodos from a.n
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MFRP type plant could be 420 mrci for a year's exposure at two
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miles (dose delivered over 50 yejrs). I am also concerned with inhalation of insoluble forms.that " hot" particles'may irradiate bronchial epithelium with high locc1 doses. Under those conditica a few particles may deliver relativcly high doses from the highly effective alpha radiation. There are no data that will permit a
estimates of risk frca this source br.t it is known from Rocky l
Flats data that local recycling in dust occurs. It is significant l
that the extent of local contamination from plutonium at tho Rocky Flats plant was largely unknown until local grcups investigated th; problem on their oun after the Rocky Flats fire.
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The MFRP will calcine high level vastes and store them as solids under water in tanks on site, It is known that
.sinilar tanks holding liquid wastes at Eanford and.at Savannah l
. River have cra. eked and relea,ed roAioectivity into the, ground.
l There is no state mnt by the Company of the IcVels of activity inthe1.j;yji;1expectedinthcoc. tanks, such data should be supplied along with test evidence on which they concJuSn that cracking of the high icvel waste tnnhs will not occur, i
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