ML20062K309

Testimony of RO Mcclellan,Jw Healy & Rc Thompson on Behalf of Joint Applicants Re NRDC Contention 2e on Calculation of Guideline Value for Radiation Doses from Postulated Release. Prof Qulifications & Certificate of Svc of Encl

ML20062K309
Person / Time
Site:	Clinch River
Issue date:	08/16/1982
From:	Healy J, Mcclellan R, Thompson R JOINT APPLICANTS - CLINCH RIVER BREEDER REACTOR
To:
References
NUDOCS 8208170117
Download: ML20062K309 (20)

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[,$fTED qg UNITED STATES OF AMERICA 6 P).30 NUCLEARREGULATORYCOMMISSIONf c..,,,

In the Matter of

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UNITED STATES DEPARTMENT OF ENERGY

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PROJECT MANAGEMENT CORPORATION

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Docket No. 50-537

)

TENNESSEE VALLEY AUTHORITY

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(Clinch River Breeder Reactor Plant)

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APPLICANT'S DIRECT TESTIMONY CONCERNING NRDC CONTENTION 2e Dated:

August 16, 1982 I

8 DocKo3$o$jj7 PDR 950 i

1 R. O. McClellan J. W.

Healy R. C. Thompson Concerning Contention 2 (e) of the Natural Resources Defense Council, Inc., and the Sierra Club (10CFR100.ll Dose Guidelines)*

l INTRODUCTION NRDC Contention 2 (e) alleges that "[a]s set forth in contention ll(d), neither Applicants nor staff have adequately calculated the guideline values for radiation doses from postulated CRBRP release."

i Contention 11(d) alleges the following:

11.

The health and safety consequences to the public and plant employees which may occur if the CRBR merely complies with current NRC standards for radiation protection of the public health and safety have not been adequately analyzed by Applicants or Staff.

(d)

Guideline values for permissible organ doses used by Applicants and Staff have not been shown to have a valid basis.

(1)

The approach utilized by Applicants and Staff in establishing 10 CFR Part 100.11 organ dose equivalent limits corresponding to a whole body dose of 25 rems is inappropriate because it fails to consider important

organs, e.g.,

the liver, and because it fails to consider new knowledge, e.g., recommendations of the ICRP in Reports 26 and 30.

(2)

Neither Applicants nor Staff have given adequate consideration to the plutonium " hot particle" hypothesis advanced by Arthur R. Tamplin and Thomas B.

Cochran, or to the Karl Z. Morgan hypothesis described in " Suggested Reduction of Permissible Exposure to Plutonium and Other Transuranium Elments,"

Journal of American Industrial Hyaiene (August 1975).

In the general portion of Contention 11, NRDC claims that neither Applicants nor staff have adequately assessed the " residual risks" of CRBRP operations in accordance with existing NRC radiation protection standards.

In Contention 2(e), NRDC challenges the adequacy of the 10CFR 100.11 dose guideline values recommended by the NRC Staff in the Clinch River Breeder Reactor Plant Site Suitability Report (NUREG-0786), page III-9.

In Contention 11(d), NRDC has attempted to particularize this general allegation.

This testimony will address NRDC's Contentions 2(e) and 11(d) concerning these dose guideline values as follows:

1.

NRDC argues that the approach utilized by the NRC staff in establishing 10CFR Part 100.11 dose guideline values for CRBRP site suitability analyses is inappropriate because it

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fails to consider important organs, e.g.,

the liver, and because it fails to consider new knowledge, e.g.,

recommendations of the ICRP in Reports 26 and 30.

In Section A below, the Applicants will show that the guideline values recommended by the NRC staff in its Site Suitability Report (NUREG-0786, page 111-9), do consider important organs and new knowledge including the recommendations of ICRP Reports 26 and 30 and are appropriate for their f

intended purpose.

2.

NRDC argues in the alternative that the approach utilized by the NRC staff in establishing 10CFR Part 100.11 dose guideline values for CRBRP site suitability analyses is -_

inappropriate because it fails to consider:

(a) the " Hot Particle" hypothesis of Cochran and Tamplin; or (b) the

" Morgan Hypothesis" for permissible plutonium exposures to the bone.

In Section B below, the Applicants will show that the hot particle hypothesis has been generally discredited by the scientific community, and that NRC and EPA have specifically rejected consideration of the hot particle hypothesisinitsexistingregulationsonthegroundthap-the hypothesis lacks scientific support.

In Section C below, the Applicants will consider the Morgan hypothesis and will show that a more credible and current analysis by the International Commission on Radiological Protection is consistent with the dose guidelines recommended by the NRC Staff for site suitability analyses.

SECTION A.

DERIVATION OF GUIDELINE DOSES FOR SITE SUITABILITY ANALYSIS This section of Applicants' health effects testimony addresses the NRDC contention "that the approach utilized by Applicants and staff in establishing 10CFR 100.11 organ dose equivalent limits corresponding to a whole body dose of 25 rems is inappropriate because it fails to consider new knowledge, e.g., recommendations of the ICRP in Reports 26 and 30."

10CFR 100.ll(a) specifies dose guideline values of 25 rem to the whole body and 300 rem to the thyroid for the purpose of site suitability analysis.

These values are not intended to constitute acceptable limits for exposure of the public.

As stated in 10CFR 100.11, "The whole body do'.o of 25 rem referred to above corresponds numerically to the once ?.

n tifetime accidental or emergency dose for radiation workers whi,b, $r,e.rding to NCRP recommendations, may be disregarded in the detsrmination of their radiation exposure status (see NBS Handbook 69, dated June 5,1959).

However, neither its use nor that of the 300 rem value for thyroid exposure as set forth in these site criteria guides are intended to imply that these numbers constitute acceptable limits for emergency doses to the public under accident conditions.

Rather, this 25 rem whole body value and the 300 rem thyroid value have been set forth in these guides as reference values, which can be used in the evaluation of reactor sites with respect to potential reactor accidents of exceedingly low probability of occurrence, and low risk of public exposure to radiation."

In 1977, the NRC Staff's Site Suitability Report recommended the following dose guidelines (See page III-15,16) :

Whole body 25 rem Thyroid 300 rem Lung 75 rem Bone 150 rem The values employed in 1977 by the Staff for thyroid and whole body were those specified in 10 CFR 100.11(a).

For CRBR site suitability evaluation, additional guidelines were needed to account for organs of interest to plutonium exposure.

These additional guidelines, for lung and for bone, are equivalent doses to the 10 CPR 100.11(a) whole body guideline of 25 rem.

The guideline values of whole body, bone, and lung are all one-tenth of the value that would be obtained from 50 years exposure at the occupational concentration limits set forth in 10 CFR Part 20 and at the maximum permissible concentrations (MPCs) set forth in ICRP Publication 2.

The ICRP-2 methodology, from which the 10 CFR Part 20 concentration limits of interest were derived, was based upon a critical organ approach.

This approach specified dose limits for individual organs which were the most radiosensitive, or which received the highest doses.

Thus, all organs with a lower radiosensitivity or which received lower doses were also protected.

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1 In 1982, the NRC Staff published its revised Site Suitability Report (NUREG-0786), which recommended the following dose guidelines (see page III-9 and NRC Staf f's Supplemental Answers to NRDC 26th Set of Interrogatories to Staff, dated August 5, 1982, page 14):

Whole body 25 rem Thyroid 300 rem Lung 75 rem Bone surfaces 300 rem Bone marrow 75 rem Liver 150 rem These guidelines employ the 10 CFR 100.11(a) values for whole body and thyroid, and specify additional guidelines for organs of interest to plutonium exposure:

lung, bone (surface and marrow), and liver.

The earlier ICRP-2 method of limiting doses to critical organs considered only the dose to a single organ.

The newer ICRP-26 approach is intended to limit the risk from the irradiation of all organs involved to a value equivalent to the risk from an occupational total body exposure of 5 rems per year.

To accomplish this, in (W ),

Publication 26 the ICRP specified weighting factors T

" representing the proportion of the stochastic risk (i.e., cancer and genetic effects) resulting from tissue (T) to the total risk when the whole body is irradiated uniformly."

These factors, reproduced below, add to a value of one for the total body.

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ICRP TISSUE WEIGHTING FACTORS Tissue Ny Gonads 0.25 Breast 0.15 Red bone marrow 0.12 Lung 0.12 Thyroid 0.03 Bone suClaces 0.03 Remainder 0.301 The values above are based on cancer mortality data and incidence of serious genetic effects, as evaluated by the ICRP, and are essentially a measure of the relative radiosensitivity of the various organs.

The whole body has a value of 1.0.

The lung, for example, is 0.12 times as radiosensitive as the whole body, or if irradiated singly, can take 8.3 (1 divided by 0.12) times as much radiation as the whole body for the equivalent mortality effect.

These weighting factors of ICRP-26 were employed by the NRC Staff to derive their 1982 site suitability guideline values for organs of interest to plutonium exposure.

These weighting factors could have been used in two ways:

(1)

Use the whole body dose guideline of 25 rems as a basis and scale from this number.

this gives:

Dose Guideline frem)

Lung 210 l

Liver 420 Bone surfaces 830 Red bone marrow 210 I WT = 0.06 for each of the five organs or tissues of the remainder receiving the highest dose equivalents.

(2)

Use the thyroid dose guideline of 300 rems as a basis and scale from this number.

This gives:

Dose Guideline frem)

Lung 75 Liver 150 Bone surfaces 300 Red bone marrow 75 The NRC staf f has selected the lower of these values--scaling by the relative risk factors from the thyroid guideline dose of 300 rems.

Thus, contrary to NRDC's contention, NRC has considered all important organs and has followed the most recent ICRP recommendations.

NRDC has raised three additional points in the course of discovery:

(1)

They argue for use, in place of ICRP weighting factors, of the factors given in the EPA proposed guidance for occupational exposure.

The EPA weighting factors eliminated the weighting factor for gonads (genetic effects being considered a different type of risk to be handled i

separately) and added a weighting factor for skin.

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(2)

They argue for use of non-stochastic 2 limit of 50 rems / year given in ICRP-26 or 30 rem / year given by the EPA.

(3)

They argue that the EPA proposed guidance in EPI-520/5-77-016, September 1977, should be used.

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i 2 on-stochastic effects are those which have a threshold dose and N

which can be prevented by holding exposure below this threshold (e.g.,

cataract).

In contrast, stochastic effects are those which are thought to have no threshold dose, and can, therefore, only be minimized (e.g.,

cancer and genetic effects). -

None of these arguments have merit.

In the method used by the NRC Staff, the absolute values of the weighting factors are not employed; they are used only as ratios.

Thus, while the individual weighting factors will be changed if the weighting factor for gonads is eliminated, the ratios of these weighting factors to one another will not change, and the dose guidelines derived by the NRC Staff by application of these ratios will not change.

It is not clear how NRDC would specifically apply the non-stochastic limit.

This is an annual limit. 'It seems clear, however, that an annual non-stochastic limit is not applicable to the dose guidelines recommended by the NRC Staff.

As indicated above, the dose guidelines correspond numerically to a once-in-a-lifetime accidental dose, and are reference values for the specific purpose of reactor site suitability evaluation.

As also indicated above, the NRC Staff's derivation of the dose guidelines used the 300 rem thyroid value'as given in 10 CPR 100,11(a) and scaled from that value using ratios from ICRP-26.

Direct application of the annual non-stochastic limit as a dose guideline would fix all dose guideline values at 50 rem, including the thyroid value. This would be incompatible with NRC's existing regulations which specify in 10 CFR 100.ll(a) a thyroid dose guideline of 300 rem.

The September 1977 EPA proposed guidance in EPA-520/5-77-016 was intended to establish a set of guidelines for areas contaminated with plutonium already in the environment:

1 mrad / year to lung and 3 mrad / year to bone.

From these doses, EPA derived soil contamination values which would provide a screening level.

If soil contamination were below these values, no action would be required.

If not, additional analyses or cleanup might be required.

These proposals were intended to provide guidance to federal agencies for possible l,

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action after plutonium contamination has occurred.

They were not intended to have any application to the derivation of ref erence values for the specific purpose of reactor site suitability evaluation, which correspond numerically to a once-in-a lifetime accidental dose to radiation workers.

Therefore, NRC's recommended 10 CFR 100.ll(a) dose guidelines for organs of interest to plutonium exposure are appropriate for the intended purpose.

SECTION B.

CONSIDERATION OF THE " HOT PARTICLE HYPOTHESIS" Tamplin and Cochran, in the mid-1970's, advanced the view that the carcinogenic risk of inhaled alpha-emitting particles, due to a

" hot particle" effect, was greater than the risk posed by more uniform irradiation of the lung.

They contended that as a result of the " hot particle" effect, NRC standards were not adequate for inhaled plutonium and other actinides.

On this basis, NRDC Contentions 2(e) and ll(d)(2) claim that the NRC Staff's site suitability dose guideline value for the lung is not valid.

As discussed in Section A above, the NRC's 1977 dose guideline value for the lung of 75 rem is based on the concentration limits set forth in NRC's existing 10 CFR Part 20 radiation protection standards.

Although the NRC Staff's 1982 value for the lung was derived by a different methodology, it is the same as the 1977 value.

Consequently, the dose guideline value is still consistent with existing NRC regulations.

The alleged effect of " hot particles" has been rejected by scientists engaged in studies of the biological effects of inhaled radionuclides.

These views are summarized in reports published by the i

National Academy of Sciences, Ad Hoc Committee on " Hot Particles" of the Advisory Committee on the Biological Effects of Inhaled l

Radionuclides" (1980).

The responsible regulatory authorities have also rejected the hypothesis.

In 1976, the NRC rejected a petition for rulemaking filed by NRDC which sought, based on the " hot particle" hypothesis, a reduction in the NRC regulations for inhaled plutonium and other actinides.

This petition was rejected on the grounds that the hot particle hypothesis was lacking in scientific support (41 Fed. Reg. 15371 (April 12, 1976)).

In 1977, EPA also rejected the NRDC petition (42 Fed. Reg. 1288 (January 1977)).

Since the NRC Staff's recommended site suitability dose guideline value for lung is consistent with existing regulations, and since NRC and EPA have not considered the " hot particle" hypothesis to warrant any revisions to the existing regulatiens, the hypothesis does not provide a basis for a lower guideline value.

SECTION C.

CONSIDERATION OF THE MORGAN HYPOTHESIS As indicated in section A above, the NRC Staff's 1982 recommended dose guideline values for organs of interest to plutonium exposures were derived by scaling f rom the 10 CPR 100,11(a) 300 rem thyroid value using the ratios of relative organ radiosensitivity from ICRP-26.

This yielded dose guidelines of 300 rem for bone surface and 75 rem for bone red marrow.

The Staff's 1977 recommended value of 150 rem for average dose to bone was derived on the basis of the 10 CFR Part 20 concentration limits and the corresponding ICRP-2 MPCs.

The ICRP-26 system is a dose-based system which establishes a recommended annual dose limit for uniform irradiation of the whole body and weighting factors to be used in censidering irradiation of individual organs.

In contrast, with reference to bone, the previous ICRP system (ICRP-2) established limits for 239Pu using human 226Ra body burden versus health effects data and laboratory animal data comparing the toxicity of 239Pu and 226Ra.

The limits were expressed in units of radioactivity allowed as a maximum permissible body burden and maximum permissible concentrations in air and water.. -

i The Morgan hypothesis ref erred to ' n contention 11(d) (2) claims I

i that the ICRP-2 maximum permissible body burden (q) of 0.04 microcurie

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for 239Pu shou _i be reduced by a factor of 240.

By inference, this i

argument would claim that a corresponding reduction in the ICRP-2 MPCs, the 10 CFR Part 20 standards, and the 1977 NRC Staff recommended i

bone dose guideline is warranted.

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The Morgan hypothesis is misplaced in the context of the NRC Staff's 1982 recommended dose guidelines since, as indicated above, these were not derived from the ICRP-2 methodology but from the 10 CFR 100.11(a) thyroid dose guideline, and scaling factors from ICRP-26.

The ICRP-26 system, which involves weighting factors and two l

components of bone (surface and red marrow), takes into account the risks f rom diff erent patterns of radionuclide deposition in bone.

i This approach eliminates the need for direct use of comparative toxicity data for the individual radionuclides, which is the basis underlying Morgan's hypothesis.

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In addition, ICRP-30 applied this ICRP-26 methodology to derive Annual Limits on Intake (ALI's) for particular isotopes, including j

239 u.

The ICRP-30 analysis considered matters such as those embodied P

in the Morgan hypothesis and arrived at an ALI that would result in an attained body burden, after 50 years exposure to the ALI, that is a factor of two lower than the permissible body burden corresponding to the 10 CFR 20 limits.

This difference is a result of many counterbalancing changes, but the total net numerical effect can be ascribed to an increase in the quality factor from 10 to 20, which applies to all alpha-emitters and is based on no considerations of radionuclide distribution within bone.

t t.

In re.lation to the 10 CFR Part 20 standards, the ICRP-30 analysis would not support the factor of 240 reduction in the maximum permissible body burden urged by Morgan.

In the context of the NRC Staff's 1982 dose guidelines, however, the maximum permissible body burden or 10 CFR Part 20 concentration limits for bone are not of importance because the 1982 dose guidelines were derived using the ICRP-26 weighting factors, and not the 10 CFR Part 20 concentration limits.

Even if those limits should change in the future, the dose guidelines for bone would be unaffected.

Theref ore, contrary to NRDC's contention 11(d)(2), the NRC i

Staff's recommended dose guideline values for bone remain appropriate for purposes of 10 CFR 100.11(a) site suitability evaluation.

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STATEMENT OF QUALIFICATIONS Roger O. McClellan President and Director Inhalation Toxicology Research Institute Lovelace Biomedical and Environmental Research Institute Albuquerque, NM 87185 I received a Doctor of Veterinary Medicine degree with highest honors from Washington State University in 1960 and a Master of Management Science degree from the University of New Mexico in 1980.

In 1967, I was certified (by examination) as a Diplomate of the American Board of Veterinary Toxicology and in 1980, certified in General Toxicology by the American Board of Toxicology.

Following graduation from Washington State University, I was employed in the Biology Laboratory, Hanford Atomic Product Operations, General Electric Company, Richland, Washington, Progressing from a Position as Biological Scientist to Senior Scientist.

My responsibilities included the design, conduct and interpretation of studies on the metabolism, dosimetry and toxicity of internally deposited radionuclides.

This included studies with 90Sr, 137 s, 1311 C

and transuranic radionuclides.

A major portion of my effort was directed to conducting a multi-generation study of the effects of l

daily ingestion of 90 r in miniature pigs, S

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From 1965 to 1966 I served as scientific staff member in the Medical Research Branch, Division of Biology and Medicine, U.

S.

Atomic Energy Commission.

In this position, I had responsibility for monitoring a major portion of the Commission's research'on internally deposited radionuclides and providing advice and counsel to senior management on such matters.

In September 1966 I joined the staf f of the Lovelace Foundation for Medical Education and Research in Albuquerque, New Mexico, with responsibility for directing the Foundation's extensive program on the toxicity of inhaled radionuclides.

This program was initially concerned with fission product radionuclides and in the late 1960's was broadened to include research on plutonium and other transuranic radionuclides.

More recently the program has been expanded to include research on airborne materials associated with utilization of coal and use of diesel-powered vehicles.

4 Since 1976 I have served as President of the Lovelace Biomedical and Environmental Research Institute (a subsidiary of the Lovelace i

Medical Foundation) and as Director of the Inhalation Toxicology Research Institute, which is operated by the Lovelace organization for i

the U.S.

Department of Energy.

My responsibilities include management of the Institute and participation in the design and interpretation of studies on the toxicity of radioactive and non-radioactive airborne materials.

I am especially interested in the late-occuring ef fects of i

exposure to pollutants and the use of data from laboratory animals to estimate health consequences for people, I have served oa numerous advisory groups concerned with i

l assessing the health ef fects of occupational and environmental i

exposure to a wide range of mate' rials.

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STATEMENT OF QUALIFICATIONS John W.

HEALY Staff Member Los Alamos National Laboratory Los Alamos, NM 87545 Mr. John W.

Healy is a staff member in the Health Division of the Los Alamos National Laboratory which is operated for the Department of Energy by the University of California.

In his current position, he is advisor to the Division Leader, Health Division.

He is extensively involved in DOE activities related to plutonium in the environment.

Mr. Healy received training at Oak Ridge in radiation protection in 1944.

Following nine months of training, he moved to Hanford where he spent the next 16 years.

During this period of time, he established the environmental monitoring, low-level analytical radiochemistry, and bioassay programs for the laboratory.

During this period he also was involved in the internal dosimetry, dose assessment, reactor safety and meteorology programs.

In 1960 he transferred to New York where he was concerned with reactor safety and product safety for the General Electric Company.

In 1968 he moved to the Los Alamos National Laboratory where his activities have included the bases for and development of radiation standards and regulations, radiation dose assements, and the application of risk estimates to such dose assessments.

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I Mr. Healy received a Bachelor of Science degree from Pennsylvania State College in 1942.

He was born in Corry, Pennsylvania, on May 9, 1920, and presently resides in Los Alamos.

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STATEMENT OF QUALIFICATIONS Roy C. Thompson Senior Staff Scientist Pacific Northwest Laboratory Richland, WA 99352 Dr. Roy C. Thompson is a Senior Staff Scientist in the Biology Department of Pacific Northwest Laboratory, which is operated for the Department of Energy by Battelle Memorial Institute.

His current position title in the Biology Department is Coordinator of Nuclear Programs.

He is extensively involved in DOE activities related to the toxicity of plutonium and other actinides.

Dr. Thompson has worked at the DOE /ERDA/AEC laboratories in Richland, Washington since 1950.

Prior to that time he held positions as Assistant Professor of Chemistry at the University of Texas, and as Research Assistant at the University of California in Berkeley and at the University of Chicago Metallurgical Labortory (Manhattan Project).

Dr. Thompson received Bachelor of Arts, Master of Arts, and Doctor of Philosophy (Bio-Organic Chemistry) degrees from the University of Texas.

He was born in Kansas City, Missouri on June 19, 1920 and presently resides in Pasco, Washington.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

)

In the Matter of

)

)

UNITED STATES DEPARTMENT OF ENERGY

)

)

PROJECT MANAGEMENT CORPORATION

)

Docket No. 50-537

)

TENNESSEE VALLEY AUTHORITY

)

)

(CLINCH RIVER BREEDER REACTOR PLANT)

)

)

CERTIFICATE OF SERVICE Service has been effected on this date by personal delivery or first-class mail to the following:

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20545

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U. S. Nuclear Regulatory Commission Washington, D.C. 20545

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U. S. Nuclear Regulatory Commission Washington, D.

C.

20545 (2 copies)

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• Atomic Safety & Licensing Appeal Board U. S. Nuclear Regulatory Commission Washington, D. C.

20545

• Atomic Safety & Licensing Board Panel

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U. S. Nuclear Regulatory Commission 1

Washington, D. C. 20545 t'

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William M. Leech, Jr., Attorney General j

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20036 Commissioner James Cotham Tennessee Department of Economic and Community Development Andrew Jackson Building, Suite 1007 Nashville, Tennessee 37219 gr eorgejf/ Edgar Attorney for Project Management Corporation DATED:

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