ML20052C478
| ML20052C478 | |
| Person / Time | |
|---|---|
| Site: | Clinch River |
| Issue date: | 04/30/1982 |
| From: | Healy J JOINT APPLICANTS - CLINCH RIVER BREEDER REACTOR |
| To: | National Resources Defense Council, Sierra Club |
| References | |
| NUDOCS 8205050027 | |
| Download: ML20052C478 (15) | |
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UNITED STATES OF AMERICA '
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NUCLEAR REGULATORY COMMISSION ti' R 30\$> S ce of the Secretary
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PROJECT MANAGEMENT CORPORATION ) Docket No. 50-537 TENNESSEE VALLEY AUTHORITY )
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1 APPLICANTS' UPDATED RESPONSE TO 1 i NATURAL RESOURCES DEFENSE COUNCIL, IN .-
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AND THE SIERRA CLUB JULY 28, 1976 ; e, p , 49 REQUEST TO APPLICANTS FOR ADMISSIONS (1 -19)
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- Pursuant to 10 C.F.R. S 2.742,. end in accordance l with the Board's Prehearing Conference Order of February 11,
- 1982, the Department of Energy, Project Management Corpora-i tion, and the Tennessee Valley Authority (the Applicants),
hereby submit their Updated Responses to Intervenors, Natural Resources Defense Council, Inc. and the Sierra Club, July 28, 1976 Request to Applicants for Admissions (1-l9).1 /
Admission
- 1. The present ICRP and NCRP values of organ burden (gf 2) and body burden (q) and maximum permissible air concentration (MPC)a and (MPC), were calculated on the basis Applicants previously raponded to Admissions 1-19 on b 50E
-1/ s August 10, 1976, and supplemented certain of those i
responses (1, 8,11, 15) on January 21, 1977.-
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of uniform distribution of the radionuclides in the critical body organ (e.g. , uniform disposition in the skeleton) and irradiation only from the deposits of the radionuclide with-in the organ.
Response
- 1. The Applicants deny this statement. The NCRP calculation for the body burdens for 239Pu and 89 Sr (and, by comparison, 90Sr) were established on the basis of bio-logical comparison with radium. The calculation of (qf 2)'
(q), (MPC)a and (MPC) , for these radionuclides arose at a later time in an attempt to provide a unifying physical con-cept. Subsequent to the submission of this contention the ICRP changed its method of calculation to allow for radia-tion of an organ from radionuclides deposited in another organ, it also allows for non-uniform distribution of the radionuclide between total bone volume and bone surfaces, and calculates radiation dose separately for bone surfaces and for bone marrow. See ICRP Publication 30, Part 1,
" Limits for Intakes of Radionuclides by Workers", Pergamon Press, Oxford,1979.
Admission
- 2. Most of the alpha-emitting 239 Pu is deposited on bone surfaces of the trabecular matrices adjacent to the thin layer of endosteal tissue which happens to be the most critical tissue in this case.
1
Response
- 2. The Applicants deny this statement. The dis-tribution of plutonium in the body depends on the form of plutonium to which the body is exposed and the method of exposure to such plutonium. Plutonium which is actually deposited in bone deposits mainly on the bone surfaces them-selves, on both endosteal and periosteal surfaces.
Endosteal tissue is thought to be a sensitive tissue.
Admission
- 3. The present practice is to calculate the dose from 239 Pu to the entire skeleton, and apply an N-factor
(=5) to the absorbed dose (rad) as well as the usual Q factor (=10) for alpha-radiation in obtaining estimates of the dose equivalent (rem).
Response
- 3. The Applicants admit this statement if by "present practice" NRDC means that described in ICRP publi-cation #2.
Admission
- 4. Because of its short radioactive half life, 224 Ra, unlike 226 Ra, does not have time to be deeply imbed-ded in bone and thus may simulate to a considerable degree the deposition of 239 Pu in man.
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Response
- 4. The Applicants admit this statement.
Admission
- 5. There is a greater incidence of bone sarcoma in humans injected with 224 Ra from a given total dose of radiation when the span of 224 Ra injections is increased.
Response
- 5. The Applicants admit this statement. The data of Spiess and Mays suggest that in humans injected with 224 Ra the incidence of bone cancer per 100 rads increased when the span of time over which the 224 Ra injections were given was increased.
Admission
- 6. Since 239 Pu when dispersed into the environ-ment in very low concentrations (except in some accidents) delivers a protracted rather than an acute exposure to man, the risks may be greater than those suggested by animal
- studies at high acute levels of exposure to 23?Pu.
Response >
- 6. The Applicants deny this statement. The radiation dose from plutonium in bone is always protracted, i
in man or animal, regardless of whether the plutonium is administered acutely or in a protracted manner because of
the very long physical and biological nalf-life of pluto-nium. Effects of protraction observed with the very short-lived radium-224 would, therefore, not be expected to apply to plutonium. Also, where comparable data exist for man and -
animal, as in the case of radium, the risks of bone cancer induction on an equivalent dose-to-bone basis are lower for man than for animals, regardless of the manner of exposure.
Admission
- 7. Occupational exposure values of q and qf2 fr alpha-emitting radionuclides that are bone seekers have been set by the direct comparison with the value of q=0.1 uCi of 226 Ra in the human body.
Response
- 7. The Applicants admit this statement to the extent that these values are set by comparison. However, the Applicants cannot truthfully admit or deny whether these values are set by " Direct Comparison", since the Applicants are unable to determine how this phrase is defined by NRDC.
Admission
- 8. The value of q=0.04 makes use of an N-factor of 5 for the alpha-radiation of 239 Pu and other alpha-emitting radionuclides in the skeleton.
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Response
- 8. The Applicants deny this statement. The value '
of 5 for the N-factor was derived from the experiments which 239 Pu but the led to the q value of 0.04 microcuries for 4
0.04 microcuries was obtained independently of the value of N. See Response to 1 above.
Admission
- 9. N is intended to be the relative risk from (e.g., 239 bone seeking alpha-emitting radionuclides Pu) in comparison with 226 Ra on the basis of absorbed dose (i.e.,
on a per rad basis).
Response
- 9. The Applicants admit this statement.
Admission
- 10. The appropriate value of N-for dogs is about
- 15. (Mays, Charles W., " Estimated Risk from 239 Pu to Human Bone, Liver and Lung," Preprint from IAEA Symposium, Bio- ;
logical Effects of Low Level Radiation, Chicago, Ill., 3-7 i
Nov. 1975.) i
Response
- 10. The Applicants admit this statement. ,
l Admission
- 11. Accepting the value of 15, the q value for ;
239 Pu should be corrected by a factor of 5/15 or 1/3.
Response
- 11. The Applicants deny this statement. See the Applicants' response to No. 8. The value for Plutonium-239
+ was obtained from biological comparison with Radium and the N-factor was not involved. See responses to 5 and 8 above.
Admission
- 12. The surface to volume ratio for the trabe-cular bone of the dog is about twice that for man.
Response
- 12. The Applicants deny this statement since various values have been reported. Actually, Spiess and Whitwell suggest that the surface to volume ratio for the trabecular bone is almost identical for man and the beagle.
. Admission
- 13. The same amount of 239 Pu in man would have 239 Pu near the trabecular sur-twice the concentration of faces as that in the dog.
Response
- 13. The Applicants deny this statement for the reasons stated in their response to No. 12. Even if the s tatement were true, it does not follow that the concentra-tion of 239 Pu would be twice as high near the trabecular surfaces of man as compared with the dog for the same amount of 239Pu, since man and dog have different skeletal sizes.
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Admission
- 14. Accepting the value of twice the concentra-tion of 239 Pu in man near the trabecular surfaces as that in the dog, the q value for 239Pu should be further corrected by a factor of 1/2.
Response
- 14. The Applicants deny this statement since they cannot accept these assumptions. See the Applicants' responses to Nos. 12 and 13. Even if these assumptions were accepted, the Applicants would still deny this statement since the significance of the relative surface to volume ratio of the trabecular bones of men and dogs respectively is related to dose calculations, not biological effects.
Admission
- 15. The rate of turnover (burial) by apposition of new bone of the deposits of alpha-emitting radionuclides on trabecular surfaces is probably about 10 times that in the dog of that in man.
Response
- 15. The Applicants can truthfully neither admit or deny this statement because of the many undefined varia-bles which influence this factor, including the age of man and dog, and the region of the skeleton that is of concern.
An average value for turnover rate of trabecular bone in
T 9-adult dogs is most likely to be about 5 times that of trabe-cular bone in the adult human. See W. B. Black, 1981, "The Effects of 1,25 Dihydroxycholecalciferol, Perithyroid Hormone, and Thyroxine on Trabecular Bone Remodeling in Adult Dogs",
Am. J. Pathol. 105, 279-287; D. B. Kimmel and W. S. S. Jee, l "A Quantitative Histologic Study of Bone Turnover in Young Adult Beagles:, Anat. Rec. (in press); and A. M. Parfitt, "The Physiologic Clinical Significance of Bone Histomorpho-metric Data", in Bone Histomorphometry: Techniques and i
Interpretations. R. R. Recker (ed.) , CRC Press , Inc. , Boca Raton, FL (in press).
Admission
- 16. Accepting this higher rate of turnover in the dog, the q value of 239Pu should be further corrected by a factor of 1/10.
Response
. 16. The Applicants deny this statement. There is no simple proportionate relationship between the rate of turnover of bone and the relative toxicity of bone-deposited plutonium and radium. Other factors that must be considered are a) that apposition of new bone will reduce the surface dose from radium as well as that from plutonium, b) the f
! life-span over which turnover will occur, c) the turnover rate itself, and d) the fact that the turnover rates will l vary with time for both species.
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1 Admission
- 17. Studies of Metivier, et. al., on the survival time of baboons relative to the dog for various concentra-tions of 239 Pu in the lungs suggest that the baboon is about 4 times as radiosensitive as the dog.
Response
- 17. The Applicants deny this statement. Although comparisons suggested baboons were slightly more sensitive than dogs to early mortality, none of these comparisons showed consistently significant differences. Since only early mortality was considered, the results have no applicability to possible late effects. Moreover, since bone cancer was not observed in either the dog or baboon studies, any inferences with respect to bone cancer are entirely unwarranted. See W. J. Bair, H. Metivier, and J. F. Park, 1980, " Comparison of Early Mortality in Baboons and Dogs Af ter Inhalation of 239 Puo2
, Radiat. Res. 82, 588-610.
Admission
- 18. Assuming this same ratio (4 to 1) would apply f for bone burden of 239 Pu and that the radiosensitivities of the baboon and man are the same, the q value of 239 Pu should be further corrected by a factor of 1/4.
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Response
- 18. The Applicants deny this statement. See the Applicants' response to No.17, supra. Not only is there no valid scientific support for the first assumption, there is also no reason to accept as true the second assumption, i.e., that man and baboon are equally radiosensitive and equally susceptible to radiation-induced bone cancer. Thus, there is no basis for applying the correction factor sug-239 Pu.
gested by NRDC to the q value for Admission
- 19. The four correction factors above show (a) an overall reduction in q for 239 Pu of 1/240, and (b) that a body burden of 0.04 uCi of 239 Pu is 240 times more carcino-genic than 0.1 uCi of 226 Ra.
Response
- 19. The Applicants deny this statement for the reasons stated in their responses to Nos. 11-18, supra.
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UNITED STATES OF AM2JtlCA M*)CLEAft PEGUL7@RY Cotm1SSION In Osa matter of U.S. ;?NCNY RESTM:CH AND DEVCLOPMENT ATMINIGTRAT10N PitCJCCT PANACEMENT CORPORATIOtf and TCM.'t3SEE VALLE*/ AUTHCRITY Art: DAVIT O{ JCHN W. IEALY
.rchn W. Hea13, being duty sworn, depouca and says as follows:
- 2. That he is enployed as a staff membce, Walti 01viaton, '
Los A*.emn h'ational Laborate::'y, an3 that.hrt is. duly eJtriorized t.o answer l 7/29/7G adnissions, centention 7, nuters 0-33: co7.cTtion 3A, nu,ibors 1-20; a.v3 content. ion 00, nt:rbers 1-14
'. The above e.entioned fr.d attached en:wcrs are true and correct. t.o t.he ber.E of his knewledge and heliv.f.
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John"el. II6aly EA, M}
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SUB ctinEn and sWou to before me this .10th, day of A;;ril,1982.
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flotary Public My comiselon expi.tes: /du ,f /# /f[d
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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In the Matter of )
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UNITED STATES DEPARTMENT OF ENERGY )
)
PROJECT MANAGEMENT CORPORATION ) Docket No. 50-537
)
TENNESSEE VALLEY AUTHORITY )
)
(Clinch River Breeder Reactor Plant) )
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CERTIFICATE OF SERVICE Service has been effected on this date by personal delivery or first-class mail to the following:
- Marshall E. Miller, Esquire Chairman Atomic Safety & Licensing Board U. S. Nuclear Regulatory Commission i Washington, D. C. 20545 t Dr. Cadet H. Hand, Jr.
Director Bodega Marine Laboratory ,
University of California P. O. Box 247 ,
Bodega Bay, California 94923
- Mr. Gustave A. Linenberger Atomic Safety & Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C. 20545
- Daniel Swanson, Esquire
- Stuart Treby, Esquire Office of Executive Legal Director U. S. Nuclear Regulatory Commission Washington, D. C. 20545 (2 copies)
-2_ ,
- Atomic Safety & Licensing Appeal Board U. S. Nuclear Regulatory Ccamission Washington, D. C. 20545 i
- Atomic Safety & Licensing Board Panel U. S. Nuclear Regulatory Commission -
Washington, D. C. 20545
- Docketing & Service Section
- Office of the Secretary ,
U. S. Nuclear Regulatory Co= mission Washington, D. C. 20545 (3 copies)
William M. Leech, Jr., Attorney General l William B. Hubbard, Chief Deputy Attorney General r Lee Breckenridge, Assistant Attorney General State of Tennessee Office of the Attorney General 450 James Robertson Parkway Nashville, Tennessee 37219 Oak Ridge Public Library Civic Center Oak Ridge, Tennessee 37820 Herbert S. Sanger, Jr., Esquire Lewis E. Wallace, Esquire i W. Walter LaRoche, Esquire James F. Burger, Esquire Edward J. Vigluicci, Esquire Office of the General Counsel Tennessee Valley Authority 400 Commerce Avenue Knoxville, Tennessee 37902 (2 copies)
- Dr. Thomas Cochran
- Barbara A. Finamore, Esquire ;
l Natural Resources Defense Council !
1725 Eye Street, N. W., Suite 600 Washington, D. C. 20006 (2 copies)
Mr. Joe H. Walker 401 Roane Street
! Harriman, Tennessee 37748 Ellyn R. Weiss Harmon & Weiss 1725 Eye Street, N. W., Suite 506 Washington, D. C. 20006
~
l i
Lawson McGhee Public Library 500 West Church Street
. Knoxville, Tennessee 37902 William E. Lantrip, Esq.
Attorney for the City of Oak Ridge Municipal Building r P. O. Box 1 i Oak Ridge, Tennessee 37830 Leon Silverstrom, Esq. 1 Warren E. Bergholz, Jr., Esq. '
U. S. Department of Energy 1000 Independence Ave., S. W. ,
Room 6-B-256, Forrestal Building '
Washington, D. C. 20585 (2 copies)
- Eldon V. C. Greenberg Tuttle & Taylor >
1901 L Street, N. W., Suite 805 r Washington, D. C. 20036 Commissioner James Cotham Tennessee Department of Economic and Community Development Andrew Jackson Building, Suite 1007 Nashville, Tennessee 37219 A
GeorgVL. Edgv -
Attorney for Proj ect Management Corporation DATED: April 30, 1982
- / Denotes hand delivery to 1717 "H" Street, N.W., Washington, D. C.
- / Denotes hand delivery to indicated address.
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