ML20062E265
| ML20062E265 | |
| Person / Time | |
|---|---|
| Issue date: | 07/21/1982 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Armstrong W SENATE |
| Shared Package | |
| ML20062E267 | List: |
| References | |
| NUDOCS 8208090033 | |
| Download: ML20062E265 (9) | |
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CEf4 TRAL Reading Files BSnyder JUL 21 1982 ED0 Reading File DEisenhut f1RR Reading File LUnderwood RAB Reading File RCunningham f1RC PDR-w/ incoming RMattson LPDR-w/ incoming RWHouston PPAS FJCongel HRDenton WPasciak EGCase LFairobent RMinogue DMeyer The Honorable William L. Armstrong SHanauer CPaul United States Senate RVollmer SCavanaugh ED0 Washington, D. C.
20510 HThompson CA
- 12000 HThompson SECY -
Dear Senator Arnstrong:
PCheck 82-0618(4)
This is in response to your note dated June 14, 1982, requesting our assistance in responding to concerns of its. Mysocki. Tbc !!RC staff has reviewed the con-cerns of t:s. Mysocki regarding the infomation contained in the !!atural Rights Center's letter. Enclosed is a copy of tbc flRC staff's response to her concerns.
If you have any questions concerning this natter, we will be pleased to discuss then with you.
Sincerely, (signed) T. A, Rehn d(filiam J. Dircks J Executive Director for Operations
Enclosures:
1.
Inconinq letter fron Ms. Wysocki 2.
Letter of Natural Rights Center 3.
I:RC staff responses 4.
D.C. Cir. Iln. 81-2006 4
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Central Files ED0 Readin'g File NRR Reading File RAB Reading File NRC PDR-w/ incoming LPDR -w/ incoming PPAS LUnderwood HRDenton RCunningham EGCase RMattson RMinogue RWHouston
!!onorable Willian L. Armstronq
,SHanauer FCongel The United States Senate f RVollmer WPasciak Washington, D.C.
20510
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Dear Senator Arnstrong:
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BSnyder CPaul
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DEisenhut SCavanaugh ED0 This is in response to your note dated Jurie 14, 1982, requesting our assistance
- 12000 in responding to concerns of its. Wysocki. The I:RC staff has reviewed the con-SECY-cerns of 11s. tlysocki regarding the information contained in the l'atural P,ights 82-0618(3)
Center's letter.
Enclosed is a copy of the t'RC staff's response to her concerns.
If you have any questions concerning this matter, we will be available to discuss then with you.
Si ncerely, William J. Dircks Executive Director for Operations
Enclosures:
1.
Inconing letter from t1s. Mysocki 2.
Letter of flatural Rights Center 3.
Mf!C staff responses 4.
D.C. Cir. !!o. 81-2006
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CENTRAL FILES NRR R/F RAB R/F Minogue, RES Denton, NRR Mattson Vollmer Houston Thompson Congel Check Cunningham Snyder Underwood Case H01:0RABLE WILLIAll L. ADtSTR0hG Denton THE U!!ITED STATES SEl: ATE
'PPAS Washington, D.C.
20510 Eisenhut Hanauer
Dear Senator Amstrong:
This is in response to your note dated June 14, 1982, recuesting our assistance in responding to concerns of its. Mysocki.
The llRC staff has reviewed the con-cerns of lis. Wycoski regarding the infomation contained in the Natural Rights Center's letter.
Attached is a copy of the NRC staff's response of her concerns.
If you have any questions concerning this ratter, we will be available to discuss then wi th you.
Si ncerely, Villiam J. Dircks Executive Director for Operations Attachments:
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Incominq letter fron fis. Mysocki B.
Letter of !!atural Rights Center C.
MRC staf f responses D.
D.C. Cir. No. 81-2006 i
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i NRC STAFF RESPONSES TO LETTER O' MAUREEN WYSOCKI TO SENATOR WILLIAM ARMSTRONG DATED APRIL 19, 1982 The letter from the Natural Rights Center attached to Maureen Wysocki's letter dated April 19, 1982, reflects concerns raised by Jeannine Honicker in a petition filed by her requesting the NRC to revoke the licenses of all nuclear power plants and all other fuel cycle facilities except those involving isolation of hazardous radioactive material. The Nuclear Regulatory Commission denied Ms. Honicker's petition effective August 4,1981. The statement of denial appeared in the Federal Register Vol. 46, No.149 (46 FR 39573).
Ms. Honicker appealed this decision to the U.S. Court of Appeal s.
On May 11,1982, the Court of Appeals decided in NRC's favor and upheld the NRC's denial of Ms. Honicker's petition.
Four " facts" are cited in the Natural Rights Center letter.
Specifically,
" fact" 1 appears to combine a statement by Ms. Honicker and one by the Commission.
Ms. Honicker stated:
" hundreds to thousands of additional cancers are now occurring as a result of routine releases...." (46 FR 39573).
One of the statements made by the Commission in dealing with this petition was:
l "Nonetheless, costs in human lives stand apart from other costs... some deaths from activities with the scope and value of nuclear power are " acceptable", at least in the sense that Congress, the Executive and the Judiciary know about them and accept them..." (46 FR 39580).
Not only did the combining of these two separate statements change the meaning of the Commission's conclusion regarding potential health effects, nowhere in its review of the petition did the
?
- Commission find evidence to support the estimates of the number of additional cancers quoted by Ms. Honicker. The Commission believes the number of health effects to be much lower.
According to the Natural Rights Center letter, " fact 2" was extracted from a brief filed by the NRC with the U.S. Court of Appeals (D.C. Cir. No. 81-2006). We have reviewed the brief and conclude that this " fact" was not taken directly f rom i t.
A footnote on page 11 of the brief refers to hypothetical 250,000-year impact, but does not refer to 1,740,000 cancer and birth defects noted in the
" f ac t". The number of cancer and birth defects noted in this " fact" misrepresents actual effects likely to occur. The footnote goes on to say that "The Commission's Debial (of the petition) took explicit note that radon releases health effects could be reduced to zero if necessary, by measures short of nuclear shutdown."
It should also be pointed out that the NRC staff believes estimates lof impacts for periods as long as 250,000-years to be inappropriate for regulatory decision purposes.
Predictions over time periods greater than even 100 years are subject l
to great uncertainties. These uncertainties result from, but are not limited to, political and social considerations, population size and health character-istics, and, for time periods on the order of thousands of years geologic and climatologic effects.
Consequently, the NRC staff limits its time periods i
of consideration to 1000 years or less for decision-making and impact-(
calculational purposes.
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. " Fact" 3 states that 80 percent of the health effects calculated will be to chil dren. There is some evidence in the scientific literature which suggests that for certain types of health effects associated with radiation exposure, the risk to children is twice that to the average person.
However, since children make-up less than 30 percent of the U.S. population, even with a risk factor twice the average, the fraction of health effects borne by children would be less than 50%. We find no basis for the 80% value.
It is not clear in " fact" 4 what specific numbers are considered to be "true numbers" by the Natural Rights Center.
However, based upon the contents of the letter, the NRC staff assumed that the referenced "true numbers' referred to' the estimated health effects cited in Ms. Honicker?s petition. The Commission believes that the best available evidence contradicts the petition's quantitative estimates of nuclear power health effects and continues to support-the NRC Staff's estimates (46 FR 39676).
Regarding the " secret memo" referenced in the Natural Rights Center letter, an analysis was made by the NRC staff some years ago of fuel cycle impacts that dealt only with radioactive releases from mining and milling operations.
It was pointed out by Walter Jordan in an NRC memorandum that the analysis neglected to consider extended releases from other parts of the fuel cycle. This memorandum was made part of the public record for Pebble Springs Nuclear Station on October 14, 1977.
Subsequently, a complete analysis has been made by the NRC staff that also l
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includes releases from active tailings, stabilized tailings, and reclaimed and unreclaimed open pit mines over extended periods of time. These new estimates were considered by the Commission in the denial of the Honicker petition.
In summary, the " facts" presented in the Natural Rights Center letter mis-interpret conclusions of the Commission's basis for denial of Ms. Honicker's petition.
Enclosed for your use is a copy of the above referenced brief and the reason for-denial contained in the Federal Register.
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DESCRIPTION
.{JLETTER O MEMO O nEP9RT O OJHER SPECf AL INSTRUCTIONS OH HEMARKS fac1 itr fn Murcen dysocki rqardf.Y, S
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