ML20041A364

Provides Comments on Petitioner J Honiker 790105 Response & Answers Commission 790209 Questions Re Stds for Radiation Protection.Petition Should Be Denied & NRC Response Revised

ML20041A364
Person / Time
Issue date:	03/14/1979
From:	Harold Denton Office of Nuclear Reactor Regulation
To:
Shared Package
ML20041A362	List: ML20041A361 ML20041A364 ML20041A368
References
FOIA-81-408, TASK-IR, TASK-SE SECY-79-180, NUDOCS 8202220038
Download: ML20041A364 (40)

Text

{{#Wiki_filter:- - _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ I UNITED STATES e pt ij. NUCLEAR REGULATORV COMMISSION ~ '2__ Rs ~ INFORMATION REPORT ~ 9 I ) il at4 D 't.'* For. The Commissioners J s Th ru. Executive 01 rector for Operationse c F rom: Harold R. Denton, Di rector Office of Nuclear Reactor Regulation L 6

Subject:

COMMENTS ON " PETITIONER'S (HONICKER) STAFF RESPONSE..." 0F VAN. 5,1979 AND ANSWERS T0 C h COMti!SSION QUESTIONS Pu rpose: To provide staff comments on the Jan. 5,1979 Petitioner's staff response and to answer the Q questions posed in the Commi ssion questions of i. February 9,1979. Di scussi on: The staff has reviewed the petitioner's staff response w M and the Commi ssion questions. Wi th regard to the Honicker staff paper of Jan. 5,1979T the staff helieves y that it rai ses few additio-al new i ssues. In pa rti c - y ular, the Honicker response argues that no nuclear 'ue! Kg cycle imposed potential involuntary deaths are acceptable, fd ~ 0: t:.at energy conservation should eliminate the need for d a nuclear fuel ed energy addi tions, ar.d that coal 'uel ed G

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• SECY NOTE: Ref. letter from Albert Bates to S. Chilk, with enclosed f

k "Coments af the Petitioner's Staff,' dated January 5,1979. g s 3 il ll \\ 9 2 ih ( R

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l The Commi ssioners 2 r* energy can provide any energy deficit (in spite of L proven coal cycle health effects). The response f argues against nuclear fuel cycle health effects, ~p .] but claims that "there is no evidence to substantiate the claim that coal generation has" a similar impact. 5 'g The argument against any potential involuntary health effects from the nuclear fuel cycle has a thrust similar j to the Delaney clause (amendment to the Food aad Drug j Act of 1958) which flatly forbids any carcinogenic food I. additive, no matter how small the risk or how substantial the benefits. Rept esentative James G. Martin (R-N.C.) j ( plans to ask Congress this year to add a risk benefit { 1 factor to the De'aney clause so that the health risks or l economic costs of a food additive can be measured against j i ts benefi ts. The Congressional Quarterly (Feb. 10,1979) 5 4 j states that there is new prominence in Congress for econeic 1 l techniques that weight benefits of 3 proposed action d' against its expected costs or risks The staff has used the 1975 data from the American Medical g Association Ccuncil on Scientific Affairs report (Journal

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g g :i American Medical Association, 240, #20, pp. 2193-2195, D Nov. 10, 1978 ) to determine estimated public deaths from y *h energy generation. Fron the figures based on total 1975

h lC energy generation by each nethod, the public deaths for coal g;'Wg are 207-39,166; oil, 44-4,400; gas, negligible; and nuclear, 0.3-4, for total energy generation related deaths of 251-h) 43,572.

The ranges relate to uncertainties in cause-effect (93% relationshi ps primarily for emi ssions from the generati ng ( pl a nt s. In the U.S. in 1975 there were 1.892 million A7p deaths (Vital Statistics of the U.S.,1975) in a population Mg of 213 million people, 805 of which can be characterized at Qyj i nvol tnta ry. Thus, the deaths from all energy generation per represent from 0.0175-2.875 increase in total involuntary i:e risk, wi th a geonetric mean of 0.22". Nuclear energy ?g generation produces one-ten thousandth of thi s amount at the upper end of the figures, or cne-one thousandth at the ( OJ l ower end. Although we reali ze that the judgment of what J7dj is and what is not acceptable differsbetween individuals, %ghhh electricity generation clearly provides many benefits Ie and we believe that the majority of individuals would kh 6j@[ 7% W + 4y Tp [i id j kA - I' 5 {f(ff3 l fi ff$ ~ ~.- - a - ~ A m. nu bd 12

i 3 The Commissieners v I judge the benefits to outweigh these health effects 'j Costs. l Regarding the Commission questions

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r l provided specific answers (Enclosure 1) to those questions, insofar as they can be answered con- [4 The sidering the availability of certain references. staff reaffims its nosition that health effects from the nuclear fuel cycle are very low, both on an ) absolute basis and in a comparison with effects due to many other involuntary and voluntary societal risks. 7 We believe that the very faw fatalities that are potentially attributable to the nuclear feel cycle, ow are consistent with reasonable assurance of public health and safety requi red by the Atomic Energy Act. l.o In view of the additional facts presented in the

• • Recocrnendati on:

enclosed responses to Commission questions and of the fact that the Petitioner's Staff Comments do not refute the staff response of SECY-78-560 of October 26, 1978, g I recmmend that the Honicker petition be denied. further recmmend that the staff responn (enclosure 1 a i to SECY-78-5F0) be revi sed, cor rected, ( pdated and amended, i n accordance wi th comments that have been 4 W received by the staff and with additional comments in dj the petitinrer's staff response and be issued as an M NRC repe d, wi th external di stribution. M w / 8-2

• W pI Harold R. Denton, Directo Of fice of Nuclear Reactor Regulation s%

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Enclosure:

Wag Staff Response to Commission y Questions

• Ref. SECY nemo to EDO, subject:" Honi49r Petition", with attachment, y

SECY NOTES d dated February 9, 1979. q Per coordination with

• • Commission action on this paper is ng required.

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( g i Question 1 The staff's earlier response to the Honicker petition stressed repeateuly that it has not been scientifically established that there are any health effects from the low levels of population exposure resulting from nuclear feel cycle activities. If, hypothetically, such scientific proof became ava!'able so that the health effects calculated by the staff coeld bt regarded as .~ reliable predictions of fatalities to be causea by the nuclear fuel cycle, would the staff change its recorn:endation regarding the Honicker petition? In the staff's view, would the certainty of a small number of fatalities, as distinguished from risk, be consistent with reasonable ass.:rance of public health and safety required by the Atomic Energy Act? Cf. p.5 of Ms. Honicker's Comments. Resdonse1 The staff's response to the Honicker petition mentioned (only) twice that health effects from the low levels of population radiation exposure that result from nonnal operation of the nuclear fuel cycle have not been scientifically established or proven. ] However, the staff stated on the first page of its response that it assumes that some very low dose rate health effects can be extrapolated (on a linear basis) from data on health effech at very much higher j K dose rates. Throughout the rest of the paper the staff uses numerical

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values for the number of latent cancers that might result from ~: specific amounts of population radiation exposure, using the numeri-4 e cal conversion faciors provided by such authorities as the BEIR l Comittee, which are based on the linear non-threshold hypothesis. Usually these latent cancers were described in tha response as 4 i potentia _l, latent cancers, primarily to stress that there is only a .f 2 ;- wi) ( U

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~ statistical probability that they may occur in exposed individuals, and that there is not a one to one correspondence between low level exposure and eventual cancer. Q d 4 Since the staff has actually developed almost the entire response aliEE ( to the original petition on the basis that the health effects due to radiological releases from nuclear fuel cycle facilities may occur, it can be reiterated that the staff believes that the quentitative health effect values it has presented are acceptable. The basis for comparing the values of radiation related potential 5% health effects with the many other health effects in the nuclear [ / fuel cycle and all the effects in the coal fuel cycle for example, E as well as other societal health and mortality values was that the 3, m potential radiation related effects are small compared to known and J k T proven health effects from the other causes in both nuclear and other 1 T --J j fuel cycles and in life in general. Such other risks are apparently = ' e N. acceptable, perhaps fatalistically, in that lives lost in construction accidents, transportation accidents, mine accidents, etc., which $.1%., result in much greater numbers of real and immediate deaths than the k latent potential cancer deaths due to radiation are relatively E iN l l ) unprotested. Furthermore, the total risks are felt to be far out- " [j x ' weighed on a quantitative basis, by the benefits of the energy U e j production, particularly in the case of nuclear fueled energy pro-g 9 duction. On the other hand, under the Delaney principle, part of t a@m N_ 9 p an amendment to the Food and Drug Act of 1953, "no food additive l m M6 t e ((g shall be deemed to be safe if it is found.. after tests which are I

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"] W ' appropriate for the evaluation of the safety of food addhives to induce cancer in man or animals". In this circumstance, no benefits h to man, however large, can over balance the possible.isks of 2 cancer production, no matter how small. It should be noted that there is current congressional activity to change the Delaney 4 clause so that the health risks or economic costs of a food additive canbemeasuredagai$stitsbenefi's,onacase-by-case, substance-f__ i by-substance basis, The certainty of radiation caused cancer dcaths, at the levels cal-1 culated for the nuclear fuel cycle, would not change the staff's con-g _5 clusion or recommendation regarding the Honicker petition, since the ( number of deaths and their effective societal cost are far outweighed by the benefits. ~ It should be pointed out that the " Comments..." paper stresses that ( the NRC' staff response compares (Table 10) certain yoluntary assumptions of personal risk such as smoking cigarettes, and driving 51 7W a car with involuntary risks such as living near a coal-fired plant hdd i[ M or a nuclear-fueled plant. It argues that regulatory bodies srch as ( the NRC should not be permitted to impose risks (involuntary) upon h h people who have no choice regarding the imposed risk. The staff Ia 1 $j s has not broken down the risks associated with either nuclear-fueled W ?* Yi$f[ energy production or some of the other public risks it cites as examp M into those aspects that are voluntary and those that are a involuntary. It has not identified those that are regulated in S$d rfM "l k D kh 9e

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Question 2 What can be said about the comparison between long-term health effect estinates for the nuclear fuel cycle and for the coal cycle if dose commitments are calculated for varying periods ranging up to the full period of toxicity, based on an assumption of stable world population and no geologic catastrophes? Response 2 The staff has calcula'ed population dose comitments associated with the releases of radioactive effluents from certain activities in the uranium fuel cycle that are set forth in Table S-3. The estimated involuntary 100 yr environmental dose comitment to the U.S. popula-tion from radioactive gaseous and liquid releases due to these portions of the fuel cycle is given on page 14 of the original staff response (SECY-78-b60) to the Honicker petition. The staff has also calculated radiological impacts associtted with radon-222 releases from mining and milling operations, including emissions from stabilize) mill [ tailings and from unrecla:med open pit mines. The over 600 man-rem l per year estimated total body 100 yr environmental dose commitment j t: the U.S. population associated with the model 1000 MWe LWR is g i equivalent to 0.00002% of the natural background total body dose to the U.S. pct:ulation over the same period. j The total dose commitments due to radon-222 from unreclaimed open pit cines and stabilized tailings piles for a 100-1000 year release period, + as presented in Section 5.7 of the Final Environmental Statements for recently reviewed nuclear power plant applications, would be as follows: .[ ~ $f 1 ?, ' la

, Releas] Time Span . Curies Population Dose Cocnitments in Han-rem Total Lung (Bronchial Body Bone Epithelium) 100 years 3,800 98.6 2.568 2,056 500 years 23,090 590 15,800 13,300 1,000 years 90.800 2,360 62,000 50,000 Using risk estimators of 135, 6.9 and 22.2 cancer deaths per million man-ren for total body, bone and lung exposures, respectively, the estimated risk of cancer mortality due to nining, milling and active tailings emissions of radon-222 would be %out 0.11 cancer fatalities per RRY. When the risk due to radon-222 emissions from stabilized tailings over a 100-year release period is added, the estimated risk of cancer mortality over a 100-year period is unchanged. Similarly, a risk of about 1.2 cancer fatalities is estimated over a 1000-year release period per RRY. When potential radon releases from reclaimed and unrechimed open-pit mines are I included, the overall risks of ra6n induced cancer fatalities j per RkY would range as follows: 0.11-0.9 fatalities for a 100-year period / 0.19-0.57 fatalities for a 500-year pertsd 1.2-2.0 fatalities for a 1000-year period To illustrate: A single model 1000 MWe LWR operating at an 80% i ) capacity factor for 30 years would be predicted to induce between 3.3 and 5.7 cancer fatalities in 100 years, 5.7 and 17 in 500 years, I and 36 and 60 in 1000 years as a result of releases of radon-222. el g' n c : ~. g y. ,ymp. qpq 7;>5 y yk'k. N*mg){f,M7el,[W.

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The staff believ:;s that it does n:t make any sense to carry the calculations beyond 1000 years, since neither population, stability cf tallings piles or cancer induction (or cures) would appear to be predictable for longer periods. All present estimates of the coal fuel cycle are based on relatively irmdiate impacts (e.g; pneumocon!osis, cardiovascular failure, etc). There have been no long-tem impact assessments of the coal fuel cycle other than possible induction of a " greenhouse effect". Since coal combustion releases literally millions of tons of toxic trace metals and organic materials into the atmosphere each year, these materials have the potential for produciag health effects by uptake througi drinking water ar.d food pathways for very long periods of tim 2. In addition, these are stable el ments. If the same assumptions used by the staff in'trea' ting long-lived radioactive trace metals were applied, the stable trace metals would remain in I the biosphere forever, with calculated health effects approaching infinity. Clearly, such calculations have little meaning and only servo to obscure real problems in need of solution today. Other areas of concern result from long-tem questions such as l subsidence of underground coal mines, acid mine drainage and disposal of flue gas desulfurization sludge and fly ash. In the case of acid mine drainage, acidification of streams can gradually dissolve toxic trace metals from stream sediments, making them j available in drinking water and foods from irrigation and watering R 4

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of live-stock. However, we are not aware that anyone has been able to qu=ntify any of the potential long-tem impacts of stable elements from the coal. Only in the case of radon emanation from coal ash have any long tem comparisons between the coal and nuclear fuel cycles been attempted, and these estimates are very uncertain since the long-tem radon emanation rates from fly ash depend on decisions on disposal methods which have yet to be made. However, current coal ash riisposal involves covering ash piles with no more than a few feet of earth. Estimates by the staff assuming the radon emanation from the fine fly ash is about the same as from uranium mill tailings indicate that with implementa-tion of the latest NRC staff position on disposal of uranium mill tailings (currently being made a condition of licensing) there may not be a great deal of difference in radon emanation in the coal and nuclear fuel [ cycles over the next 1,000 years. Over longer periods, how:::ver, surface disposal of coal ash will almost certainly lead to much earlier failure of stabilization (due to weathering, etc.) and radon release rates from caal ash may become greater than from uranium mill tailings. In addition, over periods on the order of 100,000 years, mest of the Th-230 and Rn-226 in uranium mill tailings will have decayed away while those nuclides will remain in equilibrium with U-238 in coal fly ash for periods in excess of 100,000,000 years. l ) ew.w

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l ....Qu.... ion 3 a; est Do the staff's estimates of future fossil fuel cycle health effects i take into account a possibility of significant technological improve-ments in effluent control or other foreseeable reduction in environ-mental and safety impacts?

Response

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== Question 4 ff Please coment on the Sternglass paper in Environmental Chemistry M ? cited on p. 40 of Ms. Honicker's coments? 4w y _M ,1 , :, P

Response

m ~a 7 ) The staff has reviewed the Sternglass article in Environmental ' $n Chemistry cited on p. 40 of Ms. Honicker's comments. The staff response ? a b,y, M

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to Principle 5 dealt with potential radiogenic cancer. The Sternglass LM ss, l article (Chap. 15 " Radioactivity") is filled with Sterngiass's 9 ,*'X M {%.dji _ r g. 4.. hypotheses of radiation effects from low-level radiation. k,., These hypotheses, which have not been well received by responsi-M8,$1 ble professionals in radiation protection, are unusable =r3 --4llE 4.,y$$ j 6< for radiation protection purposes. In brief, Sternglass has extra- -sill _m r s ::.. f g;m*,.h polated a few studies (dealing largely with non-living materials, or p.gR$n in vitro anucleate cells) to potential effects of whole body irradia-y $c)W's tion at very low doses. Sternglass concludes that it is only at high ] p = ?;. W hif-dose-rates that DNA damage leading to radiogenic cancer is of importance; = >x; ;s ? [..@ at very low dose-rates Sternglass believes indirect chemical effects g / hND on cell membranes are of most importance, leading to reduced iccune d r _2 @q,pf responses and increased susceptibility to other comon diseases. W t -e P @i@ rb $ MN Figure 4 of the Sternglass article (attached) shows a power function w eQM k@ relationship between " doubling dose" and dose-rate. Interestingly g gh enough, Sternglass's hypotheses would irdicate that for carcinogenesis 2 .v., -dii g...s. related to DNA damage, the " doubling dose" would be many orders-of-k% F3 % 4 magnitude greater than the staff or BEIR estimates (i.e; Sternglass's 4 -a m ~ curve shows cancer doubling doses on the order of 10,000 rads) for a P h 4 Q y ' ).. ' L " Yfis. 2 NT.h,$f 2eu 4 we n.; r d% <9 m'. ;,yyn;,, n. Mq . + w,, Jun@y. ~m w,F,m w* W<.,y,pWy; 7p;;?::i. Ow 7.e.'p p..,-x y w

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11 I dose-rates that are fractions of background dose-rates. In fact, sir:e the supposed relationship is a power function, and the risk is inversely proportional to doubling dose, Sternglass's curves shows the risk of radiogenic cancer would be orders-of-magnitude lower than estimated by the Staff. On the other hand, since the doubling dose for indirect effects on cell membranes approaches zero as the dose-rate approaches zero, we have the unlikely situation where the health effects (supposedly froa indirect chemical action) would approach infinity as the dose-rate tpproaches zero. However, in the real world, such conditions cannot exist, since the dose-rate in any experimental situation can never be less than background. Therefore, { radiation effects at dose-rates which do not significantly affect the background dose-rate (about 100 mrem /yr) cannot be proven or r disproven by experiment. 1 A The st'aff also notes that even if increased susceptibility to i' 1 infectious disease were a result of low-level radiation (which is 1 q H, highly doubtful), such " health effects" would generally be responsive O s, W to existing medical treat:ent and would nct be as severe as the 7 q A h 4 potential cancer mortalities discussed by the staff. While Sternglass ~j 8 argues that reduced irmunity will also result in increases irt cancer, j ) U d and all other diseases associated with aging, his argument is not e J, } strongly supported by relevant evidence either in his article or j h s elsewhere, q k' q$ J a 1 a 'Y l

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13 l[ 0 Question 5 I What evidence is there that " susceptible individuals" exist who "may be grr.atly affected by even extremely minute exposures in addition to natural background radiation", as contended by s Ms. Honicker's Principle 97 f

Response

There is no evidence that ' susceptible individuals" exist who "may be greatly affected by even extremely minute exposures in addition g I N to natural background". Even the highly controversial work of Brosr s I and Bertell can't support that claim. However, the staff generally i 1 supports the notion that susceptible individuals do exist relative [, to ary given biological stress. Sicple examples are demonstrated by yM common allergic responses to various pollens and urban pollutants The Y.gj (e.g.; sulfates, nitrogen oxides, ozone, cigarette smoke, etc). 8 most credible demonstration of hypersensitivity to' irradiation (j$,,y (doses many times background) that the staff has readily at hand O y.! comes from the work of Hempelmann, et al. Thet work indicates a much higher risk of thyroid cancer among Jewish individuals (3-4 fold [w jg greater than non Jewish, and 17 fold higher for youa, adult i.16 v'# Jewish females). kh i-p.- 88 .M. k I et al, "?;eoplasms in Persons Treated with X-rays in L. H. Hempelmann, iirvey in 20 Years", J. flat'l. Cancer Inst., 55, Ml; Infancy: Fourth S -t

g rio. 3, 519-530. (September,1975).

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14 Question 6

• Please coment on the assertion by Pohl quoted on p. 43 of the Coments. How would Pohl's predicted radon emission be affected if tailings are disposed of in accordance with the standards recommended by the staff in the draft GEIS on uranium milling?

Response

Dr. Pohl asserts that if all potentially available uranium ore were mined, and the mill tailings left as assumed in the Magno and Gotchy affidavits, thr:n radon emissions would result in a long-tem increase in the natural radon background by aporoximately 2%, Pohl's assertion depends critically upon the long-term radon-release rate predicted for the tailings piles. To account for uncertainty about long-term stability. the Magno and Gotchy affidavits (and hence Pohl's calculations based thereon), assume a rather arbitrary scenario of tailings i:olation deterioration. In order to provide a conservative upper bound of potential releases, the stabilization for all tailings piles was assumed to deteriorate after 500 years to release about 100 euries/0.8. GW(e) yean. This rate is about 100 times the rate if the pile were disposed of in accordance with the standards recommended by the staff in the draft GEIS on uranium milling. Thus Pohl's assertion, if ediusted to reflect the GEIS standard for tailings stabilization, would be reduced from 2% to about 0.02%.of natural background. x e r

sa l 'Some long-term deterioration of the stabilization of at least part of the tailings piles can of course be expected, but is difficult to predict as discussed in previous staff coments. The staff is recomending conservative measures to be taken in the disposal of mill tailings to assure their long term stability. These include returning tailings to mine pits ur placing them in specially excavated pits below grade to eliminate expoure of the tailings to the natural erosion processes which can disrupt them. On the basis of the proposed technical requirements for tailings disposal the staff's judgement is that the failure scenarios postulated by Gotchy and Magno are extremely conservative. Nevertheless, to account for uncertainty which still exists, the draft milling GEIS arbitrarily assumes a ten percent failure of the isolation areas. The resulting GEIS calculations of radon release apply to a somewhat different ~ set of input parameters (about industry size, total production, etc.), but.to compare with Pohl's assert;cn, the results can be normalized to show that the equivalent average-release rate for all tailings piles increases to about 20 Ci per 0.8 GW(e) year urier this degradation. This rate is about 20 times the rate if the pile were disposed of in accordance with the standards recomended by the staff in the draft GEIS on uranium milling. Pohl's assumptions (based on the Gotchy and Magno calculations) that the long tem, average, release-rate, source-term increases to about 100 Ci/0.8 GW(e) year is therefore too high by a factor of about 5 times when l compared with this GEIS assumption. l 1 l 1 W i 1 k h f.'l.jh lt f;ft Y h, " a dic/ d55631% W,sn.nwoma*n&~, igC"e"n^ .vnson hWWhMW" O 4

= 16 p n Finally, in extrapolating the assumed tailings piles radon source j teras out to millions of years, in addition to the many uncertainties f N irnplicit in such projections, Petitioner's staff should be cautioned d t' that the initial uranium-238 content of the tailings piles, not the initial thurium-230 content, becomes the controlling source tem for generating p l< those daughter isotopes leading to the future production of radon gas. 91 About 90% or more of tae U-238 content of the ore is removed in the t I milling process. l

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Question 7_ Does the staff agree with the EPA estimates, cited on p. 62 of'the staff's response and on p. 50 of Ms. Honicker's comment, that "about 200 health effects" have occurred in the world population to date from cumulative nuclear industry releases of C-147 Are these " health effects" fatalities? What estimate can be given of the number of future fatalities which will result from these C-14 releases during their total toxic lifetime?

Response

The staff would agree that, to a first approximation, "about 200 health effects" may have occurred in the world population as a result of C-14 releases. As noted on p.63 of the staff's response, these are estimated potential healtn effects *; that is, they may or may not Potential is a critical tem here, since biological data occur. from animal studies have clearly demonstrated that the cellular repair does occur, and that health effects (mortality and morbjdity, and genetically related effects) are dependent not only on dose, but { also on dose rate. Such studies have also clearly established that i i in animal populations and human cellular studit s, the Observed effect: decrease with decreasing dose rate. Because of the limited data on i human responses, BEIR fiCRP, ICRP, fiRC and EPA, among others, have f prudently assumed that the risk of biological effects is independent I of dose rate (i.e; the linear dose response hypothesis). As a result of the repair evidences, however, many life scientists believe the 4 actual risks of irradiation at small fractions of background radiation

• EPA defines health effects as all fatal and non-fatal diseases primarily

[ related to radiogenic cancer. Some EPA reports have also included p genetic effects. The 200 health effects would primarily be latent fatal cancers. 6 h ts l I i? RfQs f fQ Rh&ShWQgy,A.gQ S R. f. Q. nQQW3Clf*:WER% n;*] i .n' g:.;.. ;g m:w,L ppt.m s~- .w &,, ;3 p.m g g2n . ;p. . _.., ;w ; a m; v - yn 9.s.. w;u-v <.

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IU dose rates are smaller than would bc calculated assuming the linear hypothesis, o i in addition, the staff does not feel that anyone has provided truly meaningful estimates of health effects in the world's population. That is because the risk estimators in the SEIR report are primarily applicable to advanced nations where competing risks would permit the complete expression of health effects. For example, cancer is primarily a disease of old age. A ma,jor factor in the increase of a cancer in the so-called civilized world has been the prevention or cure of numerous diseases which had been causing much reduced life expectancies (i.e; people died of other diseases long before the onset of cancer). Therefore, EPA and other estimates of C-14 induced health y effects in today's world are likely to be higher than more realistic .k assumptions would support. - S$Q ~ e-m ,A .. u Finally,.many life scientists believe that the likelihood of F@ $ +) prevention and of cure of many types of cancer within the next D 100 years (or less) make crystal-balling " future fatalities" over bj Ybh periods of thousands of years a misleading and unproductive effort. te

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Question 8 ~ Is the Killough and T'll assessment of C-14 health effects referred to by Hs. Honicker on p. 54 related to the Oak Ridge model mentioned by Dr. Gotchy at the S-3 oral presentatic.:7 S-3 Tr. 161. Does the staff regard the Killough and Till calculation as reasonable? 4 3

Response

1 1 Yes, the reference to the Killough and Till assessment of C-14 health effects referred to by Ms. Honicker on p. 54 h related to the ORNL model mentioned by Dr. Gotchy at the S-3 cral presentation. The referenced assessment is an expansion on earlier work

• used by the staff to update the carbon model used in the GESMO hearings and in responses to corrrnents during the S-3 hearings.

While the staff believes the Killough carbon model is adequate to describe the behavior of C-14 in the environ.2ent for periods up to perhaps 1,000 years, no_ carbon model can realistically predict C-14 [ cycling over periods of thousands of years. For example, if a " greenhouse effect" or an ice age occurs, mixing of C-14 in the ocean (the carbon sink) will be greatly effected. When one adds to that uncertainty the even greater uncertainties in population n.;deling, it is clear such assessments are no longer good science.

• G. G. Killough, "A Diffusion-Type Model of the Global Carbon Cycle from the Estimation of Dose to the World Population from Releases of Carbon-14 to the Atmosphere", ORNL-5269 (1977).

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• • • 9 Question 9_

Please coment on the assertion on p. 54 of Ms. Honicker's ccments regarding adequacy of f4RC's monitoring of waste treatment systems. Response 9_ In response to the need to improve models used in the evaluation of radwaste system performance and reliability, fiRC actions have included: (a) institution of an In-Plant Measurements Program being conducted for the fiRC's Office of fluclear Regulatory Research on behalf of the Office of fluclear Reactor Regulation. This program is presently obtaining measurements of process and effluent streams at operating nuclear power stations. Measurements have been completed at 5 operating reactors and are currently being made at one other. This program will provide additional data con-cerning equipment and system performance and also provide addi-y tional data used in the calculational models for liquid and . N S gaseous effluents. J (b) review of data collected and analyzed by the Electric Power Research Institute (EPRI). These data irclude measurements completed by EPRI at three operating boiling water reactors (BWRs) J and four operating pressurized water reactors (PWRs). This measurements program has provided additional data concerning the level of releases in gaseous effluents and has identified ] specific sources of gaseous release so as to provide more thorough evaluation of treatment methods. ,g }$ .. N gg;7 mgggggg hj~ w.,. g %m : a_ g ;a',' %bym q; way

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(c) implementation of the new Radiological Effluent Standard TechnicalSpecifications(RESTS). These RESTS require that liquid, gaseous and solid radwaste equipment installed at power If plants be cat,able of performing their specified function. they are not capable of performing these functions, the utilities will have to submit a report specifying what equipment is not functioning and the reasons for the malfunction. In this way, fiRC will be made aware of systems and equipment which are operating poorly and can consider these factors in its licensing process. (d) revision of models used in the evaluation of gaseous and liquid effluents being released into the environment surrounding faci-lities. These revisions are based on data collected in the In-Plant Measurements Program as discussed in (1) above and in ,~ the EpRI program as discussed in (2) above. These revisions are also based en specific measur: ment programs designed to measure such variables as coolant radioactivity levels, system leakage, charcoal performance, and releases made as a result of anticipated operational occurrences. We have also considered, in preparing and verifying our models, data which was collected by the utilities and reported to the I;RC in semi-annual effluent release reports (SERR). Based on independent verification of the methods used by the utilities in collecting the data for the SERRs, the NRC considers that the data in the SERRs provide r 6 e d lQLQ qs k / ( ' j Ui-y ;; w: v i.? % il Q R Q f $ l.j g q % $ e$ q q h, @s. r a p lf,L y y Q n ~.~ w - xM ' 2n "1*N c b o

a good indication of the actual release. The release of the effluent calculational model for BWRs was issued January 1979, as NUREG-0016 Revision 1. The revision of the model for PWRs will be completed in 1979. In conclusion, the flRC has made efforts to verify system performance and effluent models by the use of various in-plant measurements programs and utility data. In addition, the new fiRC Radiological Effluent Standards Technical Specifications shculd provide a better indication of systems which are not functioning properly. With these efforts, the f1RC has the capability to know how much radio-activity is being released tc the environment and it also has the capability to make reliable and realistic calculations of these 4 releases. 6 a 1;$: s qi'O G*$f h/

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n l Question 10_ y -Please coment on the Sandia estimate of consequences of a spent fuelWhat is t v t Coments at 55. 6 accident in an urban setting. l of such an accident? i ( i E Honicker Staff Comment, p. 55 j "Sandia Laboratories now estimates that a single spent fuel accident q l 'g in an urban setting could result in $700 million in property damage, f {y, $2 billion in decontamination costs,1,200 early fatalities, 7,600 early 3 i i With the construction of .M4 morbidities, and 10,000 latent cancer deaths. jg[j away-from-reactor, away-from-repository regional spent fuel storage _ fj.c facilities, the transportation requirements for spent fuel will double. [h states still allowed transportation of spent fuel m b (7 As of January 1, 1979, 50 ,i The NRC counted 280,000 radioactive shipments b A +h through dense urban areas. h;$k Qi through New York City in 1975." bb,y",5 x +. s.@ W s v.s M!!i;E Response 7 The impact numbers presented by Petitioner's staff as a sumary of a mjp gy .s. e r%*., %pt(;$ Sandia Laboratories estimate of a single spent fuel accident represent in ' fy M: {WW2 i fact a compilation of estimates from several different types of transportat on

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QgW scenarios and these are addressed i.n turn below, g'#j The first impact, $700 million in property damage, is the only one which i pM9 In the draft urban study SAND 77-1927,3, e Em 4 corresponds to a spent fuel accident. A yfg w{Qwt a Working Draft Statement," jf" Transport of Radionuclides in Urban Environs:Sandia Laboratories (May 19 .ywq g@ ' ~ gg Transportation Accidents Involving Radioactive Materials in Urban Areas. SAND 77-1927, I Q1 c.l:M.J Table 4-13, p.120. e m IT v um % y'nggggggg_Aggg{0 s..g g?g}? I

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1 I JLb a table (Table 4-13) is given which lists the decontamination costs of As noted in Table 4-13, the health $w an accident as 700 million dollars. M .v effects of this accident scenario are estimated as zern early fatalities, Decontamination a six early morbidities, and ten latent cancer fatalities. c l l } costs include clean-up costs, evacuation costs, income losses, and some The capital outlays for replacement of equipment and raw materials. analysis contains many assumptions, all of which are explained in an 3d earlier supportive study, NUREG-0170.2/ Table 4-13 presents the estimates / b bilities Of consequences of high-severity accidents, regardless of the pro a l Our estimate indicates the probability of the accident e f of occurrence. scenario under discussion, a truck accident, is four high severity N For the year 1975, in which 12 [g W accidents per 100 million shipments. j spent fuel shipments in New York City occurred, the frequency would be j d$ i h five high severity accidents per ten million years. W b': The second number given in the comment, $2 billion ir decontamination ( i I costs, refers to an aircraft accident in an urban setting involv Sg a p+ 1 wM The labels for the two numbers M shipment of plutonium rather than spent fuel. \\ \\ Both the $700 million for a hign severity urban Q should not be different. f. {, spent fuel accident and the $2 billion for a high severity urban plutoniumy L j { accident represent combined clean-up costs, evacuation costs, income l k losses, and some capital outlays for replacement of equipment and raw >m$ As with the hig:,.;everity urban spent fuel v W materials, as discussed above.

.3 l

V 7 [ \\ !" Final Environmental Statcaent on the Transportation of f 1 y i d d Regulatory Commission (December 1977), Chapter 5, " Impacts cf Transportat on 1 9 f j Accidents," Table 5-11, p. 5-39 f f. ] y 7 V 3gg p.y i ggggjg]-{flwn,m. - ~y~y:w g ,3y.,yng.,,ggymg f qw .g n. y, p y g-,, y m g, g4.y ,s;p r + zmpg, we,p< :pa,;,,9, M M Mid M p.m. y f, m y,f g g, % v j f;, .,u jy s.. .c yg c massa mwamgw,ymyggy

3 zu &X accident, the probability of a high severity urban plutonium accident is M, y! quite small, at most on the order of one high severity accident per billion air kilometers. It should also be pointed out that air ship::ents tpr.a gr,t of platanium must now use much higher integrity packaging than is assumed p.gd V in t.his calculation. gg f The third, fourth, and fifth impact given in the comment refer to jN. 1*$~ t:(id) the calculated peak health consequences of a highly effective act of u 11 s.itetage directed toward the largest authorized size of spent fuel rail g[: cask in an urban setting, modeled on New York City.M The probability of lp hWi such an event cannot be evaluated completely, but it can be characterized

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qualitatively as follows. As pointed out in the Sandia study, spent fuel hh4 casks are quite invulnerable to small arms fire or small explosive charges 97: 1 -;9 b y and successful dispersal by simple mechanical means is unlikely. The nf.[ study observes that "an attempt to cause a release with significant public u, - ?!7 impact will necessarily involve an attack with large explosive charges "

y kS and that some expertise and special knowledge is required fcr the ese of

,,-/ gy p;i,, large explosive charges to be effective in dispersing radioactive material. In any case, the probability of the peak consequences is smaller than that $if of the mean consequences, which are given in Table 10 for the same Esc. nf calculation as 130 carly fatalities, 660 early morbidities, and 2900 latent i3.% I'M cancer fatalities. Thus while the large consequences enumerated in the

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coment appear to be possible, a smaller number of consequences by about a factor.af ten, given the same event scenario, appear to be more realistic. Since large uncertainties exist in our understanding of the physical mechanisms involved in explosive sabotage, the NRC is pursuing a research program to improve our understanding. This research program will probably not yield results soon. Even though the staff believes that the likelihood of a sabotage attack on a spent fuel shipment is low and the difficulty of breaching a cask and dispersing radioactive material is high, the staff is considering the imposition of interim protective measures for spent Sel movemenes, pending the completion of these research activities. The next to last statement in petitioner's connent about all 50 states allowing transportation of spent fuel through dense urban areas as of January 1,1979, is questionable. Spent fuel shipments are restricted by a New York City ordinance from its boundaries. The New York City ordinance and a subsequent ruling by the U.S. Department of Transportation that it was not inconsistent with Federal regulation under the Hazardous Materials Transportation Act has spawned a rash of State legislation and municipal ordinances, most of which are patterned after the New York City ordinance. Most of these State and local regulations may not be as severe as the New York City ordinance, since they require advance notice or shipment However, the permits rather than impose effective bans on transportation. DOT ruling did not consider the effects of the Atomic Energy Act on the w m m m o d n t w w w,n n: n m m m s w"4xm Y F# e k &h 0&!:?k NDS $?U +: $.1DdQY U$!$Y;350;[~R}?$5!1l6f'ilK:5l $l& $?;$YND

New York City ordinance and it as well as these other ordinances may ultimately be pre-empted by Federal regulatory authority. At the moment. Federal regulations do not require routing control, advance notification, shipments pemits, or safeguarding of spent fuel shipments on the grounds that primary reliance for public health and safety is placed on package integrity and that the risks to public health and safety posed by transportation of radioactive materials are small. However, as mentioned above, the NRC is considering imposition of interim safeguards measures. Further, to con 5ider the matter of Federal routing control, the U.S. Department of Transportation (DOT), with assistance from the NRC, is conducting a rule making proceeding on highway movements of radioactive f materials. Finally, the statement in the cormient about total';.hipments in 1975 is ace.vrate, but it should be modiiled to show that only 12 of these 280,000 ,.j shipments involved movements of spent fuel casks.O Most of these shipments ry involved radiopharmaceuticals for medical use. 3 ,,N D 1 ;;. < Q,3 i i;I di-4/ "C - Ibid., Appendix A Table 48, p. A-61, and Chapter 4, Table 4-16, p.126 X: ,}:'y 7:;;S ,2 . h_

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.~ Question 11 ~ Please canent on the Heidelberg report mentioned at p. 2 and

p. 39 of the Coments.

j

Response

The above referenced report was prepared by the Dept. of Environmental The Protection (DEP) of the University of Heidelberg in 14ay,1978. report contains a radioecological assessment of the Wyhl fluclear ~~ Power Plant. However, the analyses described in the report contrast sharply with the radiological assessments prepared by the Reactor Y Safety Comission (RSK) and the Radiation Protection Commission (SSK) a These official organizations used dose models and = of West Gemany. The models and 4 parameters given in U.S. IIRC Regulatory Guide 1.109. parameters in the Regulatory Guide, which are based on published values of some parameters and on field measurements of others, are in 7 1 i general use for the radiological assessment of power reactors in the P. U.S. and the Eurpoean community. The models presented in the guide hw have been critically reviewed in scientific conferences and in legal [.fs There is no evidence that the Regulatory Guide models g proceedings. and parameters substantially underestimate environmental concentrations or individual doses. In fact, measurements of effluent releases and $? concomitant envirc. r. ental samples have generally confirmed the models. Qg ? The bases for the differences in the radiological assessments using y ) Regulatory Guide parameters versus DEP parameters are described in ..g Y Fy k niy. sx .=.n ~ x': w, &* ' *J.,mun +.. a n ' n; ~, wwmmmmcwwwnumann-mn_-a

+ detail in the Heidelberg document. Starting with basic physical principles, the DEP utilized Regulatory Guide expressions for cal-An culating doses.to individuals in the nuclear plant environs. extensive literature search was performed by the DEP to provide a basis for selecting the parameter values to be used in their dose calculations. The choice and use of parameters by the DEP in the dose models resulted in substantial disagreement with Regulatory Guide 1.109 dose model parameters. For example, the DEP approach predicted individual doses from 10 to 10,000 times higher than the doses calculated using Regulatory Guide parameters. The largest r disagreements were in the predicted doses from grains and vegetables produced in the plant environs due primarily to the Mrge differences in estimated radionuclide transfer factors. Other contributions to these large differences were associated with thd estimation of ~ radionuclide releases and in the atmospheric and hydrologic y 4.n M dispersion parameters. .,yc 7h It is important to note that the results calculated by the DEP can be m1 d# misleading since the parameters selected by the DEP have not been 6C g verified as a unit by environmental measurements. For example, the selection of one parameter in a dose model may influence the selection f. of another parameter in the same model. If the selection of the two h( parameters is made independently, the end result may be invalid, h Most of the models used by the NRC and the SSK have been derived at In addition, j least in part from the results of field measurements. W k 3 t a gvweppsm.peggyewgg@p$N;stgpgpaypkNbIMbb fawmig;N $$hk f kkhbNbbM bENhb5 M"'i'G T U E X E K 3 Sh(( M M 137 2 T d h M D 21 I D. _[$C7ddCAMM)gC'@:h;.5dQ

1 ) operating nuclear rsactors are required t perform routine environ-mental measurements. These measurements programs are designed to detect unanticipated concentrations in environmental media with the highest potential to expose human beings. Based on many years of surveillance activities, there is firm evidence that concentrations 1 and doses are equal to or less than the values calculated using SSK anct Regulatory Guide models. Therefore, the referenced report, to the extent the staff has been able to review ic, does not reduce the confidence in existing models. e l 3 .? : 1$ $'? sci is a k, hfh ssn;{lh. ;*f,h?hfsa,.n.g(jff fh ^%u.w;% dreA f ..' ' h ~ ~ ?'

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.;.: y _- Question 12 J Please cocraent on the Dixon data cited on page 4 of the Comments. + v.w

Response

The staff has discussed the Dixon, Jacobson, Dixon (DJD) paper with Gertrude Dixon and with Albert Bates, project director for the "Cormaents..." paper. Mr. Bates has forwarded us a copy of " Nuclear The Time Bomb in Our Bones" by Gertrude Dixon, which describes Waste: i i l briefly the methodology whereby the graph on page 4 of "Cor=ents..." was obtained. Ms. Dixon declined to provide the DJD paper, since the s' I manuscript has been submitted to Dr. Charles Huver, Associate s Professor of Ecology and Behavioral Biology, University of Minnesota t e for inclusion in a paper " Methodologies for the Study of low-level I Radiation Exposure in the Midwest". This is a joint paper between Huver and the Land Educational Associates Foundation (LAND / LEAF) research team, of which DJD are members. 3 9 i The staff has reviewed the paper " Nuclear Waste..." which, although M it does nc provide the data on which the page 4 of " Comments..." e k y graph is trased, does describe the methcdology. The paper itself is an anti-nuclear energy presentation which argues that much of the 4 Y;- radioactivity produced as a result of various aspects of the uranium 9 fuel cycle is finding its way to humans, through pathways that are 0g h ignored by the NRC because they are not critical pathways or critical t It y radionuclides, or are incorrectly calculated and assessed by URC. -a t n nA x wmw$?vws r %a$2la m w m% &:,py,Nyx>y: u w w'p%y g'g;n,e&,?%n agn Wp[f.g'Si n% J f LQQ d '; . w .' G. v. 4 5 s Ws22 t an $ P, Q o.G w. -m: % lQ s_tBz,~ %,;iWj.)] - - 8., ..n ~ a w?lf m^",1:e n W.En M X,c'..Qe? 4:l M j,Q'O.T.?'%: .V5 T.:J u f.$,.ac. .u,,:wmm uca _w w ~_ 2x w. U h D D. 6 T 6 2 P T R N1 4 M 7fzg:g W.V:7aX 7j;pg;i791g12Wy32g[Mq,m

also discusses the author's opinion that NRC assurances of low doses to the public are based only on design release goals and imprecise. environmental monitoring that "is not used as the basis for determining the potential doses to individuals" (Roger Mattson at the EPA 40 CFR 190 hearings). Because of the belief that these statements and characterizations were correct, the LAND / LEAF research team decided that a realistic fission dose calculation could be made by starting with actual monitoring records and by developing a method to " include as much of the whole L fission dose as possible". They used milk radioactivity as monitored t S in Wisconsin by the state Radiation Protection Section. "Only three of the major fission radionuclides were measured even in milk" (LAND / LEAF). Using EPA data on portions of dairy products to the total dict, they estimated the total diet content of these three contaminants. .lt The basic calculations, derived from local monitoring, were called j M " the R Clet Dose (3-Radionuclide Diet Dose). Additional portions for 3 external dose were available in UN and EPA studies. They state "since p NRC guides are available for deriving the millirem dose for each of fr 189 radionuclides for specific age groups, it was possible to calculate j. m the lifetime accumulated dose for a Wisconsin teenager born at the start X of the monitoring period (1963). A calculat. ion was also made for the dose during those 14 years to an adult". They then describe why the p + conclusions that they reach regarding dose, are understatements of the b g ~D b: ..e/ N ME"'1%$$VjMEUl?'/pw UA S2 N W YME7N 7 M 3@@~D/@l3MMl'$rsQn $yN3 N;'$w$$$0sN$@ mom. 3[$[S an

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dose, "because of the following necessary omissions": (n:t to be 1 I itemized here). From the statements made in the Dixon paper that the staff has in hand. l it is not possible to detemine just exactly how dose is calculated, s i and how that dose would compare with the dose calculated by the staff The staff has therefore arranged to obtain for the same circumstances. the Wisconsin State Radiation Protection Section milk monitoring data. In discussions with 1.arry Mcdonald of that Section, it was determined that the main fluctuations in the state data over the years appears to be related to weapons tests, and it also appears that the Dixon I ) work did not acconnodate for the fact that the measurement sensitivity I threshold gave an effective background level of almost 10 pico Ci/l l that was really due to measurement system noise. l 1 1 b b m = S:.. in !,rM r p= Wi .s J b il, Is r DW ~ t h g RJ $f Y! Q= m f.n,.,. k,i.., h,.+. yv Y [ w$~$l $ m y$$Y! &.. *a*.,l % INTQ M,f ( i:fM ij7" JG C9g~;; 3[

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,,v o. g , < = s ..l Qu:stion 13 g,- What are the error bands on staff calculations of health'effe'ts? .d fI$ ~ ' c Are the most pessimistic pathway estimates chosen to calculate < /zC l dose? If not, what is the percent change in dose and risk if. the, 3 SMrip CW most pessimistic pathway figures are assumed? t

Response

It is impossible to precisely estfsate the error bands on staff estimates of health effects. The staff has repeatedly cautioned hearing boards that such health effects are accurate to within an order-of-magnitude. Many of the quantities used cannot be given error bands. Although the BEIR III report "has yet to be released, it is doubtful if the upper bound risk estimators (health effects 6 l per 10 person,em) will be more than a factor of 5 higher than the staff's values, and probably no more than a factor of 2 higher for the BEIR Comittee's "best estimate". This conclusion is based on i l l evaluation of the comprehenr.ive 1977 UNSCEAR report " Sources and Effects of Ionizing Radiation", and informal discussions the staff has had with the Chairman of the BEIR Comittee and other BEIR Committee members. On the other hand, most health experts feel all such estimates are likely to be exaggerations of the probable risks associated with low dose and low dose-rate exposures, perhaps by one or more orders-of-magnitude. That is because the linear-dose response hypothesis, while prudent for decisions involving the nation's health, does not allow for well known cellular repair mechanisms (both genetic and e somatic). a l 8 J t'N T N W S Hl u ? M @ M M @d $ 1 3 8 Q W$NN&Ni MW% w m w w a m m m = w = w e xvw m ca w w asa

t I-However, when unc;rtainties in icng-term populations, technological advances (e.g; ra' waste treatment systems, cure and treatment of d ~ ) cancer and. genetic defects, etc) stability of mill tallings and pathway analysis of released r?.dioactivity are considered, it is possible the uncertainty bounds (above or below) could be greater than two orders-of4 magnitude over periods on the order of 200 to 1,000 years, and several orders-of-magnitude over many millenia. For most of the radionuclit.es evaluated by the staff, the cathway estimates tend to be quite conservative, but not necessarily the most However, for the nuclides which account for over 99% pessimistic. of the radiologic impact of the uranium fuel cycle (C-14, H-3, Kr-85 and Rn-222), the pathways are believed to be realistically conserva-tive for periods on the order of a few hundred years. At the present time there is no way to estimate the percent changes in dose or risk if the most pessimistic pathway figures are assumed. In fact, it is doubtful if most pessimistic pathways can Le defined. i:

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erva-g The staff believes that the values they have presented are tive, and that since the resultant health effects are small, on both an absolute and relative (to other societal risks) basis, it does not appear to be realistic io try to evaluate error bands on the calculations. ME$?$$MiM$Ms5$$M @ E dWNE$ % $igdid E r' r

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