ML20049H894

Supplemental Response to Util Request for Addl Info Re Contention 2.Certificate of Svc Encl

ML20049H894
Person / Time
Site:	Byron
Issue date:	02/24/1982
From:	Shawn Campbell DEKALB AREA ALLIANCE FOR RESPONSIBLE ENERGY, SINNISSIPPI ALLIANCE FOR THE ENVIRONMENT (SAFE)
To:	COMMONWEALTH EDISON CO.
References
NUDOCS 8203040446
Download: ML20049H894 (21)

Text

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Febmary 24, 1982 Rock'c-1 U :nOW UNITED STATES OF AMERICA NUCLEAR REGULATORY COSDilSS10N

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

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CO5SIONWEALTH EDISON COMPANY ) Docket Nos. 50-454

) *0-455 (Byron Station, Units 1 and 2) )

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DAARE/ SAFE SUPPLEMENTAL RESPONSE TO C03SIONWEALTH ED- .

ISON'S REQUEST FOR ADDITIONAL INFORMATION/ CONTENTION TWO. p*LCTl!fg

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In response to Edison's request for additional clarified i(on oft . iTSSax  :' g jj/

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facts underlying DAARE/ SAFE's Contentions, DAARE/ SAFE prevides t e5 follow- Gj/;

This response incorporates

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ing information relating to Contention Two.

DAARE/ SAFE's previous responses to Commonwealth Edison and =NRC Staff and specifies, to the best of DAARE/ SAFE's ability, the specific facts, docu-ments, and/or portions of documents which DAARE/ SAFE will rely upon as evidence for Contention Two. DAARE/ SAFE's clarification of it's other con-tentions will be supplied, likewise, as soon as possible.

In addition, Dr. Karl Z. Morgan, Alanta, Georgia, has offered to testify in behalf.of this Contention. DAARE/ SAFE is willing to arrange details toward his deposition and should be contacted care of: Mr. Stanley .

Campbell, (815) 962-7373.

i Upon written notification at least one week in advance, DAARE/ SAFE  :

will arrange to have available for inspection and copying requested docu-cents in this response. 63

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• PDR ADOCK 05000454 Q PDR _.

CONTENTION NDBER TWO DAARE/ SAFE is requesting the NRC Soard to compel Commonwealth Edison to re-evaluate the dose impacts of all projected routine and accident event releases of radioactive materials to determine the cumulative effects to residents in northern Illinois from the a'ddition of Byron releases to releases from the other eleven units.

DAARE/ SAFE preiently relies upon the following statements of Roger J.

Mattson, NRC Director of the Division of Siting, Health and Safeguards Standards, presented at the EPA Hearing on Proposed 40 CFR Part 190 on i March 9, 1976:

i EPA' places considerable reliance on the Commission's statement in its Statement of Considerations for Appendix 1 that several LWRs on a single site can operate with doses to individuals less than 5% of the.present 10 CFR Part 20 limit; i.e., presumably

25 mrem /yr to the whole body as 5% of the 500 mren/yr limit (Supplementary Information, Part C, p. 3]. It should be noted that the quoted statement of the NRC is not part of the regula-tion. Appendix I to 10 CFR Part 50. While the valuer so quoted

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may be appropriate for multi-LWR, sites on the average, the limiting conditions for operation in the regulation permit operation at twice the design, objective values and radiation sources other than effluents'are not included in Appendix I (e.g., N-16, storage sources, etc.). The sum of all dose contributions at a multiple reactor site can, and probably will.

exceed 5% of the current RPGs. [ Emphasis his, page 9 of attachment A}

This misunderstanding of the wt, Appendix I works in practice is simplified when one realizes the added difference between yearly average performance and short term field measurements required by EPA to demonstrate noncompliance with the proposed 40 CFR Part 190. ,

DAARE/ SAFE will also rely upon the statement received by DAARE member Dr. Bruce Von Zellen from Dr. Karl Z. Morgan, Neely Professor at the School of Nuclear Engineering, Georgia Institute of Technology, dated February 25, 1980, wherein he states:

They want to throw out 2a because the NRC has made the mistake of setting a limit for each plant but not corrected for-emissions from neighboring plants. Many of us have recognized

. .. 2 ,. ,.

this as NRC error for many years. Certainly they cannot disagree that 100 man rem fro = one plant is no worse than 10 man rem from 10 plants. 1 phink the NRC should be big enough to correct its mistakes rather than refuse to face them and institute corrections.

DAARE/ SAFE requests the NRC to compel Commonwealth Edison to provide an adequate assessment of their releases of radioactive material from their operating power plants. The " adequate assessment," as defined below, would be the closest approach to an accurate prediction of the cumulative effect of Byron on the northern Illinois population.

Applicant (Commonwealth Edison) has only followed Westinghouse and NRC design basis criteria and has not considered the actual annual average radioactive material discharge from all their currently operating nuclear reactors under routine and non-routine conditions.

The Byron FSAR contains an overwhelming majority'of rcferences to guideline documents and redundant cross-references with little or no refer-ence to operating experiences at their other facilities.

NRC publications on non-routine releases demonstrate that preductions on such releases as are claimed cannot be made with a high degree of certainty.

The following examples taken from the LER Output cited below show documented non-predicted releases from plants of Westinghouse PWR design similar to that of Byron.

1. Prairie Island I (August 10, 1975) page 83. Release rate of long-lived halogens and particulates were twice the design standards over a 3-month period from 5/11/75 to 8/10/75.

Conclusion:

Release rates of halogens and particulates are more conservative than those calculated in accordance with Regulatory Guide'1.42, Revision 1.

2. Robert E. Ginna I (June 5, 1971), page 85. Following return to power, gaseous release rates from the auxiliary ventila' tion system leveled 3

off at a rate of 132% over the Iodine 131 limit. This release occurred as a result of.a gasket leak'around the pressure control valve on the volume control tank.

3. Robert E. Ginna 1 (April 19, 1972), page 86. During routine shutdown operations Iodine 131 was released which exceeded design specification (1.3 times license limit). It was caused by a leaky flange on the boric acid evaporator.

4 Surry I (September 4, 1974), page 92. Over a 25 day period an

" unspecified" amount of radioactive gases was released. These

" unspecified" amounts were in excess of technical specifications limits by from 4 to 22 percent. Steam generator A had a primary to secondary leak.

5. Surry I (September 29, 1975), oage 96. From 9/29/75 through 10/23/75 gaseous waste was released through the ventilation vent. These releases reached rates as high as 43.5 percent of M.P.C. for one day. " Leaking equipment caused accumulation of contaminated water in the containment (building) floor. This entered the iodine filters and saturated the charcoal. Design change being processad."

6. Zion II (January 27, 1976). page 129. Over a 3-month period (fourth quarter of 1975) 26,658 curies of noble gases were vented into the atmosphere. This more than exceeded twice the annual objectives of Zion II.

Documents:

1. NRC: " Licensee Event Report (LER) Output on PRR Events Involving Released Activity from 1969 to the Present" (through March 10, 1981).

2. Annual radioactive release reports from the NRC, e.g., NUREG/CK-1497, BNL-NUREG-51192, for the year 1978.

3. Slade, D. H., Editor, Meteorology and Atomic Energy 1968, Atomic Energy Commission.

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i We consider an adequate assesscent to include at least consideration of the average annual isotopic releases from all their operating reactors in

, routine and non-routine conditions over the last five years. The fact is that Commonwealth Edison has not done this. ]

! None of the Commonwealth Edison documents show that Commonwealth Edison f i

meets our criterion (stated above) for assessing the expected discharge rate; i

hence we rely on them for this factual statement.  ;

Although hundreds of radioisotopes have been identified to date as

. fission products, radioactive products and actinides produced in reactors,  ;

i Commonwealth Edison only specifies 27 in its Table 11.1-2. (Byron FSAR).  !

I i

Some of the isotopes not included in the Applicant's table entitled,

, " Expected Annual Average Releases of Radionuclides in Liquid Effluents" and therefore lumped in the category "all others," include isotopes detected in the liquid and gaseous waste releases of other light water reactors, and specifically, other Westinghouse pressurized water reactors.

I The Applicant predicts in Table 11.1-2 that 23 curies of 26 radioisotopes will be released in the liquid effluent each year from Byron Unit I, plus

! 380 curies of tritium and 0.000054 curies of "all others." The Intervenors l

1 contend there are many radioisotopes which should have been individually assessed and added to this list, and that the resulting total would be more than the estimated 0.000054 of "all others," based on many documents

available to the Applicant. ,

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(a) Some of the isotopes omitted from Table 11.1-2 include the following:

liobium-95, NB-97, Nb-99, Cerium-141 and Ce-144. All of these have half-lives of an hour or more, have high fission yields, and are listed in authoritative sources (Pigford), (Nero, Table 3.1), as radionuclides produced in a 1000-MWe Uranium-fueled light-water reac' tor. Nb-95 is a gamma-emitter, and'is listed 5

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by the IAEA (IAEA Report, " Safe Handling of Radioisotopes," Geneva, 1968)

as being of moderate toxicity. Applicant does not list any cerium among those elements to be released and yet National Council on Radiation Protection Report #60, p. iii, states that cerium is " produced in abundance in nuclear 1

fission reactions associated with nuclear industry operations." A review of an annual report of radioactive releases from 1978 indicates that all but two Westinghouse reactors in operation released cerium that year into the river  ;

or lake or other cooling water source (that is, all but San Onofre and Salem, as per NUREG/CR-1497).

Cerium was reported among the liquid effluents released from 11 of j the 16 Westinghouse nuclear power plants in 1977. (" Radioactive Materials 1

Released from Nuclear Power Plants - Annual Report 1977," NUREG-0521).

In a typical low-enrichment light-water reactor, cerium-144 is produced at the annual rate of 5.3 kilograms per 1000 megawatts of electric power . . . which is equivalent to about 17 million curies per thousand megawatt years of electric power. Other j radioactive isotopes of cerium (141, 143, 145, and 146) are a

produced from uranium fission but they have shorter radioactive half-lives and do not accumulate to as great an extent as cerium l44. [NCRP Report #60, p. 11}

j Cerium-144 has a half-life of 285 days; cerium-141, 33 days; 143, 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br />; 145, 3 minutes; and 146, 14 miautes. Cerium-139 is also listed among reactor effluents; it has a half-life of 140 days.

Cerium-144 is listed as one of the thirteen " radionuclides of probable ecological significance released from nuclear power plants," by T._R. Rice 4

and J. P. Baptist in " Ecologic Effects of Radioactive Emissions from Nuclear

, Power Plants." (in Human and Ecologic Effects of Nuclear Power Plants,

'Sagan, L. A., Ed., published by Charles C. Thomas, Springfield, Illinois, 1974). -Cerium-144 is also listed by E. E. Lewis (Nuclear Power Reactor Safety, John Wiley and' Sons, 1977) in his Table 1-2, " Characteristics of 6

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Important Long-Half-Life Fission-Product Isotopes." Cerium-144 is listed by the IAEA as being of high toxicity. (" Safe Handling of Radioisotopes,"

Geneva, 1968).

(b) Also among the radionuclides omitted by Co=mor..ealth Edison from Table 11.1-2 are:

1. Tellurium-131

2. Ruthenium-106

3. Strontium-90

4. Iodine-134 Although five isotopes of tellurium are listed in Table 11.102, Te-131 is not listed--an omission the Intervenors regard as arbitrary and capricious.

Applicant, for example, listed Te-129 which has.a half-life of 72 minutes and a fission yield of 0.32 percent. Te-129 has an activity (in kilocuries per megawatt of thermal power) of 9.5 at shutdown. Te-131, on the other hand, has a half-life of 25 minutes and an activity of 26 at shutdoen. Further, Sax lists Te-131 with a fission yield over 10 times that of Te-131m, which f.s_

listed by Com=onwealth Edison. (Sax,;i. Irving, Dangerous Properties of Industrial Materials.  !;ew York: Reinhold; 2nd Edition, 1963, Table 4, Section 8).

Ru-106 is not listed by Commonwealth Edison in Table 11.1-2, yet it is listed as one of only seven isotopes by E. E. Lewis in his Table 1-2, " Char-acteristics of Important Long-Half-Life Fission-Product Isotopes." Ru-106 is alsd listed in Pigford and by the IAEA as being of "high toxicity." Its omission from Table 11.1-2 appears to be unjustified.

The highly important radioisotope Sr-90 is not listed among liquid effluents in Table 11.1-2, although Sr-89 is listed. This is unusually l curious, since Sr-90 is both more abundant than Sr-39 as a fission product, i

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has higher t::cicity (IAEA lists Sr-90 as being of "very high toxicity,"

Sr-S9 as bei ; of high toxicity") and is listed, just as is Sr-39, in Pigford.

The radioisotopes of I-131 through I-135 are listed with the striking omission of -134, which is listed by Pigford as con'2ibuting more than any iodine isotope to the reactor inventory. Similarly, Lewis lists I-134 in his Table 1.1 (Characteristics of Important Short-Half-Life Fission-Product Isotopes) as having a higher activity at shutdown than any of its sibling isotopes.

(c) The Pk'R-CALE Code as the computerized mathematical model used by NRC licensees for calculating the release of radioactive material does not individually identify radionuclides that contribute less than 0.00001 curies per year. E: ever, the presence of an aggregate of radionuclides, even if individually in a=ounts below the model's reporting level, may nevertheless constitute a cenace to public health and welfare.

Some of the long-lived isotopes which may be released each year in amounts which f all below the PWR-GALE Code include:

1. Iodine-129 which has a half-life of seventeen million years.

Although few picocuries may be released in comparison with shorter-lived isotopes, such as iodine-131 (half-life of 8 days), iodine-129 is one of only a few isotopes specifically regulated by the EPA thrcash its Environmental Standards for the Uranium Fuel Cycle, 40 CTR 190.10(b)--along with krypton-85, plutonium-239, and other alpha-emitting transuranic radionuclides with half-lives greater than one year. (The release per year of iodine-129 from the production, use and reprocessing of the uranium fuel for a 100C.-regawatt reactor must be kept below five. rillicuries per year).

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2. Tc-99 which has a half-life of 210,000 year. According to the Federal Register, Vol. 46, Mo. 42, March 4, 1981, p. 15155:

Technetium-99 releases are not given in Table S-3. The Fuel Cycle Rule Hearing Board concluded that the conservative assumption of complete release of iodine-129 tended to co=pensate for the omission of technetium fr'om the table.

However, the Com=1ssion decided that the emissions of technetium, together with an appraisal of the impacts associated with them, could be considered in individual reactor licensing proceedings.

The Intervenors believe Tc-99 should be considered in the Byron  ;

proceedings because of the admitted presence of its progenitors, Mo-99 and Tc-99m. Furthermore, according to the " Assessment of 99Tc Releases to'the Atmosphere - A Plea for Applied Research,"

by J. E. Till, et al., ORNC/TM-6260, June 1978, p. 2

The yield from thermal neutron fission of 235U for 99Tc is high, 6.2% fission, or about 0.84 kg per metric ton of uranium in typical spent pressurized water reactor fuel (compared to 1.3 kg per metric ton of 137Cs and 0.55 kg per 1 metric ton of 90Sr).

(d) Among the radioisotopes not listed with the corrosion and activation products in Table 11.1-2 are isotopes of Ni, Zr, Sb, Ru and others which are i

f mentioned in Pigford, as well as in NUREG-0686 (Dresden Chemical Decontamina-tion EIS, October 1980) and in WASH-1258 (AEC - Vol. 2 Analytical Models and Calculations). Mn-56 is not listed in Table 11.1-2, although it is listed J

in IAEA as of toxicity equal to that of Mn-54 (which is listed by Applicant) and is listed by the AEC (WASH-1258 above) in Table B-6 as having a calculated concentration higher than that of isotopes listed by Applicant. Zr-95, not listed by Commonwealth Edison, is prominently mentioned in NUREG-0686 (Table 2-1) and in. IAEA (moderate toxicity). The critical dependence of relative percentage concentration of corrosion and activation product radioisotopes in reactors on years of operation is strikingly described in NUREG-0586:

- 9 .~- .

_ - . - . .=- - - . - -. __

A PWR that has been operated only a short time will contain 60Co '

as the largest contributor to radiation dese. In this case, the integrity of the entombing structure need only be maintained for  ;

a few hundred years, as the disappearance of radioactivity is controlled by the 5.27-year half-life of 60Co. If, on the other hand, the reactor has been operated for 30 or 40 years, substan-tial amounts of 59N1 and 94Nb (80,000-year and 20,000-year half-lives) will have been accumulated as activation products in the reactor vessel internals. The dose rate from the 94Nb present in the reactor vessel internals has been estimated to be approximately 2 rem / hour.(about 17,000 rem / year) while the dose from the 59Ni in the internals is 0.1 rem / hour (about 880 rem /

year). These dose levels are s'ubstantially above acceptable residual radioactivity levels and, because of the long half-lives of 94Nb and 59Ni, would net decrease by an appreciable amount, due to radioactive decay, for thousands of years. (from Draft Generic EIS on Decoemissioning of Nuclear Facilities, January 1981, pp. 4-6]

Additional activation products found in significant quantities in the i

4 primary coolant at the Yankee-Rcwe and Haddam Neck Westinghouse plants, but i i

not listed at Byron, include sodium-24 (half-life of 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />) and silver-s 110m (half-life of 253 days). (

References:

Radiological Surveillance Studies, EPA, RD 71-1, p. 16, and EPA-520/3-74-007, pp. 18 and 56).

1 (e) Table 3-1 of Nero (see p. 35), adapted from Pigford, lists the f

4 4

following actinides: Th, Pa, U, Np, Pu, Am, Cm. These, according to this table, contribute over 20 percent to the total reactor inventory (3,614 x 106 Ci out of 15,600 x 10 6C1). The actinides, furthermore, are well-known to be of very high toxicity (IAEA).

Therefore, an " adequate assessment" of atmospheric radioactive pollutants 1

would incorporate:

1. The worst case engineering prediction of routine releases of each isotope;

2. Operating experience with unplanned isotopic releases over the past five to ten years; 3.- Any analysis of the release of radioisotopes that have been heretofore overlooked by the nuclear industry.

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. i DAARE/ SAFE agrees with Dr. Irwin D. J. Bross, Director of Biostatistics at Roswell Park Memorial Institute, shen he states "I didn't think that anybody believed in the threshold theory any more, but I suppose there are 1 always some people who are re-fighting the Civil War."

In re-fighting this battle with Commonwealth Edison, we rely upon the i

.following facts and evidence:

(a) " Delayed Effects of A-Bomb Radiation: A Review of Recent Mortality Rates and Risk Estimates for 5 Year Survivors," by Alice M. Stewart, a manuscript submitted to the British Journal of Epidemiology and Community Health on May 1, 1981.

! (b) Stewart, A. M., " Childhood Cancers and the Im=une System," Cancer lesunology (1980), Vo.l. 9, pp. 11-14.

(c) , G. W. Kneale, and T. F. Mancuso, "Hanford II B; The Hanford Data--A Reply to Recent Criticisms," Ambio (1980), Vol. 9, pp. 66-73.

(

(d) Kneale, G. W., T. F. Mancuso, and A. M. Stewart, "A Cohort Study of the Cancer Risks from Radiation to Workers at Hanford (1944 to 1977 4

Deaths) by the Method of Regression Models in Life-Tables," British Journal of Industrial Medicine, in press, 1981.

l (e) , and A. M. Stewart, " Pre-Cancers and Liability to Other 4

Diseases," British Journal of Cancer (1978), Vol. 37, pp. 448-457.

1 I (f) Ugeno, Y., " Carcinogenic Hazard from Natural Background Radiation in Japan," Journal of Radiation Research (1978), Vol. 19, pp. 205-212.

(g) " Revised Dose Estimates at Hiroshima and Nagasaki," (abstract) by W. E. Loewe - 29th annual meeting of the Radiation Research Society, Minteapolis, Minnesota, June 1981.

(h) Baverstock, K. F., et al., " Risks of Radiation at Low Dose Rates,"

Lancet, February 21, 1981, pp. 430-433.

(i) Gofman, J. W., Radiation and Human Health. In Press. San Francisco, California: Sierra Club Books. Scheduled for publication October, 1981.

(j) Hearings before the House Commerce Subcommittee on Health and the Environment, Ninety-Fifth Congress, on the Effect of Radiation on Human Health,~Vol. I, testimony of Ethel S. Gilbert, Pacific Northwest Laboratories, February 8, 1978.

(k) Loewe, W. E., and E. Mendelsohn, " Revised Estimates of Dose at

' Hiroshima and Nagasaki, and Possible Consequences for Radiation-Induced Leukemia," D-30-14, Lawrence Livermore National Laboratory (1980).

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Other hta .ri the health effects of lo w-level radiation vere recently cited by the Work Group on Science of the Interagency Task Force on the Health Effects of Ionizing Radiation la its report of June 1979:

(1)^ Studies are cited on page 18 of the report concerning 35,000 workers employed since 1944 at the nuclear facilities in Hanford, Washington. Several of these reports by if ancuso, 4

Stewart and Kneale indicate increased mortality from multiple myeloma and pancreatic cancer possibly associated with occupational radiation exposure. Similar patterns of e.xcess cancer mortality in Hanford workers were described in an earlier analysis of death certificates by T1ilham. "Some, but not all, of these inalyses have also sugge.sted statistically significant excess mortality for lung cancer and for all cancers as a poup."

(2) The Science Work Group also cites evidence on Page 17 of the mortality statistics for radiologists in the U.S. and Britain which have been compared with statistics for other physicians and for the general population in several studies over the

, past 35 years, increased risk of leukemia and other cancers has heen regularly documented, particularly for older phys;etes exposed in the oarly days of radiologic practice when radiation ha/.ctrds were not fully appreciated (11atanoski, Seltzer and Rartwell). Fiole I, huge 8) indicates t'ia t radiologists show trang aci i".ms with "meers ' inked to radiation.-

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(3) Several epidemiologie studies cited on pages 15 and 16 examined the risk of childhood cancer following in utero O

exposure via pelvic x-rays during pregnancy. The largest of these studies is an ongoing investigation in Great Britain, begun in 1954, in which histories of in utero exposure have been compared for children who died of cancer and for living children without cancer (Bithell, Stewart). A 50 percent overall increase in cancer risk was estimated for children irradiated in utero, risk increasing in rough proportion to the nun $bers of x-ray films taken. Similar estimates of total risk have been obtained in 2 other major studies. MacMahon assessed frequency of in utero radiation exposure among 7,242 cases of childhood cancer in New England. The other (part of the so-called Tri-State Leukemia Study) compared a variety l

of past exposures and illneses in 313 childhood leukemia cases and 854 age-matched controls, identified in parts of New York, Maryland, and Minnesota (Grahm, Levin, Lilienfeld, et al.).

(m) Recent findings by R.P. Larsen and R.D. Oldha m, of the Radiological and Environmental Research Division of the Argonne (Illinois) National Laboratory reveal that platonium poses risks for the digestive system in addition to the long-recognized risks to the respiratory system:

Working under the auspices of the U.S. Department of Energy, Larsen and Oldham conducted experiments'using samples of actual Chicago drinking water and of a synthetic Chicago drinking water.

They analyzed the waters at the time of chlorination, and again 13

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> later, to determine the amount of plutonior in each oxidation state. After 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the proportion of Pu(VI) to Pu(IV) was markedly greater than at the time of cholorination, as is shown in the table provided in their report in Science, Vol. 201, September 15, 1978. (" Plutonium in Drinking Water: Effects of Chlorination on Its Maximum Permissible Concentration," R.P.

Larsen and R.D. Oldham Science, Vol. 201, September 15, 1978, pages 1008-1009.

According to Larsen and Oldham, "We have established that Pu(IV) is oxidized to Pu(VI) by chlorine in water treatment plants and distribution systems." (Id.) In the abstract prefacing their report, the authors add that, "Under certain conditions, Pu(VI) is readily absorbed from the gastrointestinal tract. It appears that due consideration has not been given to the effect t' at the presence of plutonium in this oxidation state may have en the maximum permissible concentration of plutonium in d-inking water." d (Id.)

Larsen and Oldham call into question conclusions reached by Committee 2 of the International Commission on Radiological Protection (ICRP)in 1965. The ICRP's Committee 2 had established a task force to investigate the metabolism of plutonium and related elem ents. One of the task group's conclusions, in an article published by the -ICRP in 1972 (A. Lindenbaum et al., "The Metabolism of Plutonium and Other Actinides" (ICRP Publication 19, Pergamon, New York,1972), was that "the current value for the gastrointestinal absorption factor, 3 ' x .10-5, appears to be reasonable for soluble plutonium compounds. In drawing this conclusion, the task group either did not consider the possibility

that Pu(VI) would be formed during water treatment or, if they did, they concluded either that the data obtained by Weeks et al.

(M.H. Weeks et al., Radiation Research 4, 339 (1956)) on the absorption of Pu(VI) were invalid or that Pu(VI) would be rapidly reduced to Pu(III) or Pu(IV), or both, in the gastrointestinal tract."

(Plutonium in Drinking Water: Effects of Chlorination on its Maximum Permissible Concentration," R.P. Larsen and R.D. Oldham Science, Vol. 201, September 15,1978, pages 1008-1009).

In the experiments conducted by Weeks et al., referenced above, plutonium in the oxidized state was administered to food-deprived rats to measure the rate of absorption and degree of retention in the gastrointestinal tract. The results showed that, at 80 days, retention of Pu(VI) was much higher than that of Pu(III) or Pu(IV). Larsen and Oldham describe the findings of Weeks et al. as "quite definitive." They point out that, while the ICRP task force was aware of the experiments by Weeks et al., they doubted the validity of the data and characterized the evidence as " meager."

Because the oxidizing effects of chlorine on plutonium were not given adequate consideration in the past, Larsen and Oldham point out, "present values for the maximum permissible concentration (MPC) of plutonium in drinking water (SpCi/ml for the general public) (Standards for Radiation Protection (Energy Research and Development Administration Manual, Washingten, D.C., April,1975, chapter 0524.) appear to be too 'high by several orders of magnitude. . . It is our view that. . . due consideration was not- given to evidence in the literature that the absorption of Pu(VI) is higher by three orders of magnitude than that for Pu(IV) 15 p .-

or to the possibility the Pu(VI) could formed during water treatm ent." (Idj. .

(n) A " Plea for Applied Research" on technetium-99 was issued by the Oak Ridge National Laboratory in 1978, and was published in 1979 in Health Physics (Vol. 36, pp. 21-30):

p. 21: "Little information is available to provide insight into possible long-term retention of Tc-99 in organs of interest (notably the thyroid); such data are needed to accurately assess the dose due to chronic exposure to routine releases from a nuclear facility.

There is an urgent need for information describing the uptake and retention of Tc-99 in children. since they could comprise the critical segment of the ocaulation at risk." (emphasis added. by J.E. Till, et al.).

Health Physics, Vol. 36, pp. 21-30, Pergamon Press Ltd.1979 (Research sponsored by the Department of Energy under contract with Union Carbide Corp. J.E. Till, F.O. Hoffman and D.E. Dunning, J r., Health and Safety Research Division, Oak Ridge National Laboratory.):

"Because of the inadequacy off the data currently available, we feel that it is not possible to derive a 'best estimate' of the soil-to-plant concentration factor for 99Tc. However our analysis of reported concentration factors for 99Tc in soil and plants suggests that the value presently being used, 0.25 significantly underestimates the uptake of 99Te through the roots. On the other hand, it is entirely possible that the concentration factors obtained under laboratory conditions could be overestimates. Nevertheless, one cannot be

- justified at this time in disregarding the data shown in Tables 1 and 2 and continuing to assume a concentration factor of 0.25." (p. 24)

" Finally, we should emphasize that this analysis does not include the contribuiton to dose via liquid-effluent pathways. Therefore, the total dose from g i

99Tc may be higher than that calculated here when all pathways of exposure are considered."

(p. 27)

"This assessment indicates that 99Tc is a potentially critical radionuclide in the nuclear fuel cycle. However, the confirmation of this assessment can only be determined after improving the state of knowledge about the environmental behavior and dosimetric properties of this isotope."

(p. 28)

(o) CRC Handbook of Chemistry and Physics, 61st Edition, 1980-81, page B-41: " Technetium-99 has a specific activity of 6.2x10 8 dis.ntegrations per second/g. Activity of this level must not be allowed to spread. Tegg is a contamination hazard and should be handled in a glove box."

(p) A BEIR Report (Biological Effects of Ionizing Radiations) by a committee of National Academy of Sciences members, was prepared in 1972 ("The Effects on Populations of Exposure to Low Levels of Ionizing Radiation," Report of the Advisory Committee on the Biological Effects of Ionizing Radiations, Div. of Medical Sciences, National Academy of Sciences, National Research Council, Wash.,

D.C. 1972) for the Federal Radiation Council (which has since become a part of the Environmental Protection Agency). In 1976, EPA requested another study which was submitted by the 20-member committee in May 1979 with conclusions similar to the 1972 report. ("The Effects on Populations of Exposure to Low Levels of Ionizing Radiations," Report of_ the Committee on the Biological Effects of Ionizing Radiationc, Division of Medical Science Assembly of Life Sciences, National Research Council, National Academy of Sciences,1979; hereafter "1979 BEIR"). This 1979 report was recalled, however, at the request of six of the 20 17

i members, and the six revised the chapter on somatie effects over the period of a year, publishing the final report in June .1980.

("The Effects on Populations of Exposure to Low Levels of lonizing Radiation," Committee on the Biological Effects of lonizing Radiations, Division of Medical Science, Assembly of Life Science, National Research Council, National Academy of Science 1960; hereaf ter "1980 BEIR"). The final report was never acted upon by the 20-member committee.

The six dissenters used a new formula for estimating cancer deaths from gamma rays which softened the 1979 projections, and chose to ignore the subject of cancer incidence which was detailed in the 1972 and 1979 reports. The following comparisions reflect not only the curious degree to which six are able to catweigh the consensus of 20, but also the irreconcilable differences in assessments of hazards among our leading scientists:

Estimated increase in mortality from a single 10-rad exposure 1979 BEIR pp. 329, 330: female, .5% - 2.7% male, .4% - 2.0%

1980 BEIR p.191: no assignment by sex .5% - 1.4%

Estimated increase in mortality from continous lifetime exposure of I rad / year 1979 BEIR p. 330: female, 8% - 17% male .4%-10%

1980 BEIR p.194: no assignment by sex 3% - 8%

Estimated increase in cancer incidence from continuous lifetime exposure of 1 rad / year 1979 BEIR p. 330: female, 8.1% - 32.6% male, 5.2% - 17.9%

i

[

1980 BEIR no estimates

. ,, ^

18 -

These estimates were extrapolated from estimated doses from the nuclear explosions at Hiroshima and Nagasaki as calculated in T65D which stands for Tentative Dose Estimates compiled in 1965, and were assembled by John Auxier of Oak Ridge National Laboratory. (In 1972 these original data were shredded by mistake.

SCIENCE, Vol. 212, May 22,1981, p. 902). T65D claimed radiation at Hiroshima was largely from neutrons (high LET - Linear Energy Transfer) with a small amount of gamma rays (low LET); Nagasaki showed negligible neutron evidence as gamma radiation was predominant. Mortality and incidence were higher in Hiroshima, so neutron radiation was deemed responsible.

Now comes " Revised Dose Estimates at Hiroshima and Nagasaki," by W.E. Loewe and E. Mendelsohn (U.C.R.L. 85446 preprint,1 Oct.1980, Lawrence Livermore National Laboratory, Livermore, Calif.), presented in May 1981, which shows that neutron radiation was 1/9 that given in T65D, and gamma radiation was three times that given in T65D. Edward Radford ws the chairman of the 1979 and 1980 20-member BEIR committee and has stated that the new evaluation indicates that risk estimates in all BEIR reports (1972,1979,1980) are too low. (SCIENCE, Vol. 213, July 3, 1981, p. 6). Other scientists disagree, but all insist furtherr work must be done, and the " data base containing information on the individual Japanese survivors must be revised to reflect" the new estimates. (1).

There is no conventional wisdom on ill effects and threshhold tolerances of low-level radiation; new data have served only to

increase the questions which must be answered, and no utility can claim that g amount of low-level radiation is harmless.

i b

No

i e

AFFIRMATION OF PREPARATION

- a c';

1, Stanley Campbell, being duly sworn, state that I was'. responsible'for preparing the feregoing response for Centention Two, to Cc=enwealth Edison's Interrogatories. Tha t response is true and correct to the best of my know-ledge.

Sworn to and signed before me c ( %Y  %?

stanley y mpoeil v this 7th day + Febr ry, 1982.

.L uo .i hena Notary Public My commission expires: 10-6-84 ,

I, Diane Chavez, being duly sworn, stace that I was responsible for preparing the foregoing response for Contention Two, to Commonwealth Edison's Interrogatories. That response is true and correct to the best of my know-ledge.

Sworn to and signed bef re me l(m h. ln%

this - h day of Febru y, 1982.

Diane Chave: 0

/

%' - l A-1A1 , Q Notary Public My co=ission expires :10-6-84 ,

i l

The undersigned, a member of DAARE/ SAFE, certifies that en this date she served a copy of this " Response" on each member of the service list by United States mail, Special Delivery, or by other means as appropriate. ,

l

_Jf sw_

Diane Chavez btrah

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