ML20091G556

Testimony of Ld Hamilton on W Eddleman Contention 8F(1)re Table S-3 Coal Particulates.Related Correspondence

ML20091G556
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Issue date:	05/31/1984
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ggED CORRE6 0

May 31, 19

'84 .,

um,,-g All:25 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

iM CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL and NORTH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )

)

(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

APPLICANTS' TESTIMONY OF LEONARD D. HAMILTON ON WELLS EDDLEMAN'S CONTENTION 8F(l)

(TABLE S-3 COAL PARTICULATES) _

, 8406040316 840531 -

POR ADOCK 05000400 "

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7 TABLE OF CONTENTS PAGE I. Introduction............................................ 1 II. Significance of Table S-3 Coal Particulates Issue...................................... 2 III. Basis for Table S-3 Particulate Figure.................. 3 IV. Particulate Concentration Levels and their Significance...................................... 5 A. Particulate Concentration Levels................... 5 B. Comparative Assessment of Impact of Particulate Concentration Levels................... 8 C. Numerical Assessment of Impact of Particulate Concentration Levels...................ll

1. Fifty-Mile Population......................... 11

2. U.S. Population............................... 15 V. Conclusions............................................ 16 t

Attachment 1 - Personal Qualifications of Leonard D. Hamilton References l

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i I. Introduction My name is Leonard D. Hamilton. I am currently, and have been since its inception, the head of the Biomedical and Envi-ronmental Assessment Division in the National Center for Analy-sis of Energy Systems at Brookhaven National Laboratory, Asso-ciated Universities, Inc., Upton, New York 11973. The Biomedical and Environmental Assessment Division at Brookhaven National Laboratory is an interdisciplinary group that assesses the health and environmental impacts of all energy sources from exploration to end use. Much of our effort over the past ten years has focused on dose-response relationships for air pollu-tion from fossil fuel combustion for electricity generation. A statement of my background and qualifications is provided in

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Attachment l. Statements contained herein are my personal opinion and are not necessarily those of Brookhaven National Laboratory. .

Eddleman Contention 8F(1) alleges that Appendix C of the Shearon Harris Final Environmental Statement (FES) under-estimates the environmental impact of the effluents in Table S-3 because "the health effects of the coal particulates,"

quantified at 1,154 MT per year, "are not analyzed nor given sufficient weight" therein. In supporting his contention, Mr. Eddleman states that emissions which "are about two-tenths

{ sic] of one percent of U.S. emissions" may cause up to 10 4

deaths per year, a number which is "[n]ot trivial."1/ This testimony will demonstrate that Mr. Eddleman is incorrect and that the health effects of particulate effluents specified in Table S-3 were adequately assessed and given sufficient weight by the NRC Staff.

In the FES, the Staff found that the emissions specified in Table S-3 " constituted an extremely small additional atmo-spheric loading in comparison with the same emissions for the stationary fuel-combustion and transportation sectors in the U.S.; that is, about 0.02% of the annual. national releases for each of these species. The staff believes that such small in-creases in releases of these pollutants are acceptable." FES, Appendix C at C-2. (Mr. Eddleman misquotes the FES in his statement of support for Contention 8F(1) in that the figure "two tenths of one percent" should actually be "two one hun-dredths of one percent" or two ten thousandths of the annual U.S. coal particulate emissions.)

II. Significance of Table S-3 Coal Particulates Issue Before beginning my analysis of the possible health ef-fects of 1,154 MT of coal.particulates associated with the estimated electrical energy needed to support the uranium fuel 1/ See Wells Eddleman's Response to Staff DEIS, June 20, 1983, at page 14.

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cycle for one year, I would like to draw attention to the lim-ited and therefore possibly misleading nature of such an as-sessment. Operation of a new nuclear power plant, such as the Shearon Harris Plant, will result in the retirement earlier than otherwise possible of old coal-fired plants with much higher rates of particulate emissions and, consequently, ,

greater health and environmental impacts than the Shearon Harris Plant and associated fuel cycle activities. The net result of such a replacement is thus a considerable reduction

.in health and environmental impacts which is not included in Table S-3 cn: in my analysis here. With this caveat in mind, j this testimony explains why the Staff succinctly and correctly

, concludes in the FES that there is a miniscule incremental en-vironmental impact from the coal particulates identified in

i. Table S-3.

III. Basis for Table S-3 Particulate Figure i.

The emission of 1,154 MT of particulates a year is a hypo-l thetical attribution. It is used-in Table S-3 in order to cal-culate a reasonable estimate of the particulate emissions that might be associated with the electrical energy produced by_the

, equivalent of a hypothetical 45 MWe coal-fired power plant op-erating for'one year; this is the estimated energy needed to support the uranium fuel cycle for one year'of the Harris Plant's operation. Most of'this energy is_used in the uranium enrichment. process at gaseous diffusion plants.

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The three gaseous diffusion facilities used in the uranium

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enrichment process are located at (1) Paducah, Kentucky; (2)

Oak Ridge, Tennessee; and (3) Portsmouth, Ohio. These facili-ties are supplied with electricity primarily from power grids.

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Thus, the impact of the particulates released from coal plants supporting the uranium fuel cycle in fact are distributed in small amounts over large areas. However, for purposes of my calculations to estimate an upper limit of health risks, I have made the following assumptions. .From the TVA's grid system, I have.. assumed the Bull Run Plant 'to be the only plant serving Oak Ridge, and the Shawnee Plant to be serving Paducah, Kentucky. I have also assumed that the following facilities are dedicated to providing electric power to their respective locations: the Joppa Plant (in addition to the Shawnee Plant),

supplying Paddcah, Kentucky, and the Kyger and Clifty Plants, supplying Portsmouth, Ohio. I have also assigned the hypothe-tical 1,154 MT of particulates individually to each of these power plants on the basis of two different assumptions: first, that any one of these coal plants may be singly responsible for the electricity used to produce the entire enrichment of urani-um needed to supply the Shearon Harris Nuclear Power Plant; and second, that the source of energy to support the uranium en-richment process may be divided equally among these coal plants

-(see Section IV.C). -

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IV. Particulate Concentration Levels and their Significance A. Particulate Concentration Levels In order to provide an understanding of the upper boundary j of any possible risks _to health, there are several different ways to analyze the impact of the coal emissions assumed in ,

. Table S-3. First, I have estimated the concentration of particulates in the atmosphere produced by the hypothetical s

1,154 MT of. emitted particulates. This calculation assumes i

! that in-the region (50-mile radius) near the coal plant sup-j plying power for each enrichment facility, emissions are uni-i formly mixed in the volume of air contained in a cylinder with a radius of 50 miles and a height equal to the. average height

. of the mixing layer of air (see Table 1, below). The concen-

} tration of particulates in the 50-mile-region is a function of the quantity of emissions released by the coal plants and the

wind. speed. Thus, the total emissions mixed in this volume are i

related to the time it takes for the wind to blow the particles 50 miles from the stack to the edge of the cylinder. This calculation yields a rough estimate of the long-term average.

. coal ~ particulate exposure over the 50-mile radius area. Of

{ course, _on an individual basis, persons closer to the plant

-would' receive greater exposures than those farther away.

Simi-larly, individuals.living downwind from th'a plant would receive

, larger exposures _than_those:living upwind.

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I have calculated the exposure to particulates in the area I

of each of the coal plants supplying energy for the enrichment i facilities, assuming 1,154 MT/yr of particulate emissions and annual average daytime conditions as shown in Table 1.2/

Table 1 Annual Average Daytime Meteorological Conditions (Holzworth, 1972)

Wind Speed (m/sec) Mixing Layer (m)

E Pm a p3 Paducah, KY

, Joppa Plant 5 6.5 450 1400 Shawnee Plant 5 6.5 450 1400 Oak Ridge, TN Bull Run Plant 5 6 450 1600 i

Portsmouth, OH

, Kyger Plant . 5 6 520 1400 Clifty Plant 5 6.5 420 1400 i

2/ The_small amount of particulates equivalent to the emis-sions of a hypothetical 45 MWe coal-fired plant actually at-

- tributable to the nuclear fuel cycle is in reality much smaller than the 1,154 MT/yr set forth in Table S-3. The allowable emission-rate for three of the coal plants that supply power-to the uranium enrichment facilities (Shawnee Plant, 0.11 lb/10E6 Btu; Bull Run Plant, 0.10 lb/10E6 Btu; and Kyger Plant, 0.10

, lb/10E6 Btu)~are roughly one-eighth of the figure given.for the particulate emission-rate in Table S-3. See 401 Ky. Admin.

Reg. $ 61:015 (Shawnee Plant); Tenn. Dept. .Public Health, Div.

of Air Pollu. Control.Regs. Ch. 1200-3-16 .02 (Bull Run Plant);

Ohio. EPA Regs., i 3745-17 (Kyger Plant). The' allowable emis-sion rate for the Joppa Plant is 0.19 lb/10E6 Btu,. which is roughly four times lower than the' figure given for particulates in Table S-3, while the rate at the Clifty' Plant of 0.236 lb/10E6 Btu is approximately three times lower. See Ill.

I Pollu. Control Bd. Rules & Regs., Ch. 2, Pt. II, Rule 203(g)(1)(c) (Joppa Plant); Ind. Control Bd. Regs., 5.325 IAC 6-2 (Clifty Plant).

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These data are used to calculate particulate concentration using

, l the equation:

Concentration = Emission Rate (ug/sec) x Radius (m)/ Wind speed (m/sec) 3 (ug/m ) t x Radius 2(,2) x Mixing Height (m) 4 (Where a 50-mile radius is 8x10 m and 1154 MT particles /yr =

7 3.6x10 ug/sec.)

Estimated daytime concentrations for the five plants are shown in Table 2.

Table 2 4

Estimated Average Daytime Concentrations in a Cylinder of Radius 80 km and Height Equal to that of the Mixing Surface Layer of Air Location Concentration (ug/m )

am pm Average Paducah, KY Joppa Plant 0.064 0.016 0.040 Shawnee Plant 0.064 0.016 0.040 Oak Ridge, TN Bull Run Plant 0.064 0.015 0.040 Portsmouth, OH Kyger Plant 0.055 0.017 0.036 Clifty Plant 0.068 0.016 0.042 l

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These simplified concentration estimates depend on both wind speed and depth of the mixing surface layer, which are closely linked.

The " aster the wind blows, the deeper is the mixing surface layer.

-Also,. faster wind results in reduced residence time, hence lower

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concentrations. (Holzworth, 1972).

B. Comparative Assessment of Impact of Particulate Concentration Levels From an uncontrolled pulverized coal-fired power plant -- the type specified in WASH-1248 (see page D-16 at Table D-6), from which the annual particulate emission rate of 1,154 MT was derived

-- the respirable particles (<10pm), called " thoracic particles" or "TP", constitute only about 40 percent of the mass of the total particulates (Fisher and Natusch, 1979).3/ Larger particles tend to be deposited in the nose or pharynx and do not reach the lung.

Thus, only 40 percent of the particles released potentially are damaging to health. Using the above equation, this means that the concentration.of TP that would penetrate the thoracic region, i.e.,

"both alveolar and tracheobronchial penetration,"4/ would be about 3/ WASH-1248 states that the 1,154 MT of particulates per year was derived from a particulate' emission rate of 22 lb/MT of coal with a heat value.of coal of 13,000 Btu /lb. This rep-resents the particulate emission rate of an uncontrolled plant, of which few remain.

4f United States Environmental Protection Agency (EPA) Office of Air Quality Planning.and Standards (OAQPS) Staff Paper in its " Review-of the National Ambient Air Quality Standards for Particulate Matter: Assessment of Scientific and Technical.

lInformation,". January 1982 EPA-450/5-82-001, at page 75.

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0.014-0.017 ug/m . This concentration range is derived using the high and low average concentration estimates specified in Table

-2.

For perspective, this concentration of TP (0.014-0.017 ug/m ) should be compared with the EPA's estimate of potential-ly injurious concentrations of TP. In a critical review of the available scientific and technical information most relevant to the review of primary (health) National Ambient Air Quality Standards (NAAQS) for particulate matter, EPA states:

Based on a staff assessment of the short-term epidemiological data, the range of 24-hour TP levels of interest are 150 to 350 (micrograms per cubic meter). Under the con-ditions prevailing during the Lo.ndon studies, the upper end of the range represents levels at which effects are lakely in the sensitive populations studied. Given the uncertainties in translating these results to U.S. condi-tions and the seriousness of the potential health effects, the upper end of the above range contains no identifiable margin of safety and should not be considered as an ap-propriate standards alternative. The uncer-tainties and the nature of the potential ef-fects are important margin-of-safety considerations. Neither the studies used to derive the range nor more qualitative studies of' effects in other sensitive population groups (e.g., asthmatics, children), or ef-fects in controlled human or animal studies provide scientific support for health risks of consequence below 150 [ micrograms per cubic meter). . . Based on a staff

! assessment of the long-term epidemiological data, the range of annual TP levels of interest are 55 to 110 [ micrograms per cubic meter). The upper end of this range overlaps the somewhat uncertain " effects levels" de-

, rived from these studies. Due to these un--

l certainties, the upper end of the range (110

[ micrograms per cubic meter]) may not include l any margin of safety, and should not be con-

_sidered as an appropriate standard I~

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- alternative. The lower end (55 [ micrograms i per cubic meterl) represents a level where some risk of symptomatic effects micht remain but no detectable differences in pulmonary '

function or marked increases in respiratory diseases are expected. Increases in symp-tomatic effects at the lower levels are un- ,

certain and small in comparison to baseline rates (emphasis added).5/

In other words, EPA has concluded that from both short-and long-term exposures to particulates, the " bottom line" or lowest level of TP at which there may be some risk of health effects is approximately 55 ug/m . As stated above, the concentration of such particulates in the atmosphere, assuming a reasonable distribution of the entire 1154 MT in a 50-mile i radius around a single coal plant, would be 0.014-0.017 3

ug/m . This means that even if the 1,154 MT was all dis-tributed by a single coal plant in one place, which obviously ,

is not the case since three different gaseous diffusion plants are used in-the-enrichment process, the concentration would be i

approximately 3,000 times smaller than the minimum concentra-tion having some risk of symptomatic effects. While the 0.014-0.017 ug/m 3 of TP is an incremental concentration to a pre-existing background concentration of TP, its proportional responsibility for any biological effect is equally miniscule.

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. ;1/ EPA op. cit. pages

112-113.

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C. Numerical Assessment of Impact of Particulate Concentration Levels .

1. Fifty-Mile Population In addition to the comparative analysis above, I have cal-culated some conservative estimates of possible health effects of coal emissions attributable to the Harris Plant's uranium fuel cycle needs. In this calculation, I have used a damage function for respirable particulates in a linear non-threshold way, thereby corservatively assuming that even the smallest in-cremental particulate dose has an incremental health effect.

Moreover, to provide an understanding of the upper boundary of risk from coal particulates emitted in support of the uranium fuel cycle, I also have conservatively assumed that the entire hypothetical 1,154 MT of particulates are emitted and expose the 50-mile population around each of the fossil plants serving the three gaseous diffusion facilities.Q/

The calculated health risk relies upon a damage function for fine particles developed recently by the Harvard University Energy and Environmental Policy Center.7/ This study recom-mends, for quantitative risk assessment, use of only a fine g/ This assumption ignores the fact that the 1,154 MT is

-roughly 3 to 8 times more than the actual particulates those plants emit per 45 MWe equivalent. See note 2, supra.

'7 s/' See " Analysis of Health Effects Resulting from Population Exposures to' Ambient Particulate Matter" October 1983 (" Harvard Report"), prepared for idun Health and Environmental Risk Analy-sis Program of the U.S. Department of Energy.

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particles (FP) risk coefficient, or particles smaller than 2.5 l

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-micrometers.8/ FP represent a small portion of the thoracic 1

particles (TP) previously described. (Fine particles are about 10 percent of the total particulate emissions from an

. uncontrolled pulverized coal-burning power plant (Fisher and Natusch, 1979).) The FP damage function, which is 1.3 + 0.6 3

deaths / year /10 persons per ug/m FP, is derived from available cross-sectional mortality analyses.9/

4 Using this damage function,'and the 10 percent FP func-tion,~ I have calculated the expected excess deaths per year

- from population exposure to 1,154 MT/yr total particulate emis-sions around-each of these plants (Table 3). These estimated excess deaths should be compared with the expected deaths from all causes in the population around each of these plants; this is also shown in Table 3. The estimated excess deaths from 4

particulate exposure are indistinguishable from zero against the background of expected deaths from all causes. The upper

limit of estimated expected' deaths from particulate exposure

! - corresponds to.about one-one-thousand of one percent of the

- mortality rate.

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8f See Harvard Report;ht page 8 and Table.1,.page 5.

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45-50.

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Table 3 l Estimated excess deaths per year from population exposure to 1,154 MT/yr total particulate emissions and total deaths from all causes.

Location Excess Mortality (deaths /yr)

Expected from

, particulate 95% Expected from exposure

• range all causes Paducah, KY Joppa Plant 0.014 0.001-0.027 2,400 l Shawnee Plant 0.017 0.0015-0.032 2,800 i Oak Ridge, TN Bull Run Plant 0.044 0.004-0.080 7,400 Portsmouth, OH I Kyger Plant 0.014 0.001-0.027 2,600 2

Clifty Plant 0.068 0.006-0.13 11,000

• In my original affidavit I conservatively assumed that respirable particles ( < 10pm) or "TP" constituted about one half the mass of the total particulates, while in fact they constitute only about 40% of the mass of the total particulates. I also overly conservatively assumed that the fine particles (< 254m) or "FP", as used in the Harvard damage function, were the same as the TP, while in fact FP constitute only 10% of the mass of the total particulate emissions from an uncontrolled pulverized coal-burning power plant (Fisher and Natusch, 1979).

l The above estimates are based on the assumption that any one of-these plants may be singly responsible for the electri-city which supplies the entire enrichment of uranium needed to i- .supplyfthe Shearon Harris plant. Using this assumption, the greatest health risk posed by the coal used to supply uranium

._ enrichment facilities is 0.068 deaths annually for-the 50-mile population around the Clifty Plant.

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An equally plausible assumption is that uranium enrichment services are being supplied equally by all three facilities to produce fuel for the Shearon Harris plant. Using this assump-tion, the amount of coal generated for each facility would be divides by three and health risks associated with each site would be similarly reduced.10/ This would result in a worst case health risk of 0.023 deaths annually.

These calculations are conservative estimates. The actual numbers could be zero. As the Harvard Report states:

[T]he FP coefficient is most representative for an'" average" urban aerosol composition and will, to some extent, be subject to the biases noted for sulfates when applied to aerosols having a makeup very different from from the mean composition . . .

Although the use of a fine particle mortal-ity coefficient should provide an improve-ment over previously used cross-sectional indices of particle air pollution, we must emphasize the large uncertainties sur-rounding any such damage coefficient. In-deed, despite the fact that the coefficient is statistically greater than Zero, uncertainties not considered by such analyses (e.g., errers in the measurement '

of the exposure variable) make it possible

-that the mortality risk might in fact be zero.

Harvard Report at pages 8, 50 (emphasis added).

10/ _This calculation does not account for different quantities of energy being supplied by more than one coal plant in the vi-cinity of the uranium enrichment plant.

2. U.S. Population Jul alternative way to calculate the health (mortality) ef-facts of coal particulate emissions attributable to the uranium

, fuel cycle is to consider the health risk for the entire United States due to the long-range transport of these particulates.

Based on the Brookhaven National Laboratory's Biomedical and Environmental Assessment Division's matrix results (Rowe,

_1981), it is estimated that the average total U.S. exposure to i fine particles from all coal _ power plants is 90 person-ug/m3 per MT emissions. Using the FP damage function cited above,11/ the calculated additional deaths in the entire U.S.

t population from coal particulates associated with the uranium fuel _ cycle would be 0.13, with a 95 percent statistical range 0.013-0.26. In.the entire U.S., roughly 2 million die annually

. from all causes.

4 In assessing the 50-mile and U.S. population risk esti-

- mates described above, it is important to keep in mind that linear dose-response functions are not able to-distinguish be-tween large doses to a few persons and small doses to many per-sons. The estimates for health effects of long-range transport

, are based on exceedingly small exposures to millions of per-

- sons.: Since the human body.has many defenses against low-level exposure:to: particles, these small doses are prcbably less harmful per unit exposure than higher' doses. The long-range 3

11/ The calculation is'(90 person-ug/m per.MT) (1154 MT) 3 (0.1 FP/ total emissions)'(1.3E-05 deathe-m / person /ug).

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-transport health effects estimates therefore probably are bi-ased on the high side.

It also must be recognized that the health-damage function 1

! described above links annual average fine particle exposure to i

increased annual mortality rate. It does not represent the acute effects of exposure but, rather, the long-term impact on

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the population of a continuing (chronic) environmental expo-sure. The mortality rates calculated above are based on the assumption that, although the sequence of events leading to its impact on the population is unknown, long-term exposure to fine particles, particularly in childhood, presumably increases the

susceptibility to respiratory infection. A history of repeated respiratory infection, possibly coupled with continued fine particle exposure, increases the prevalence of chronic respira-tory' disease. This leads to"more deaths from a broad range of

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cardiopulmonary diseases. Implicit in this hypothesis, there-fore, is the assumption that the exposure to fine particles

! that eventually is reflected in mortality rate is continuous

and long-standing.

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i. V. Conclusions i

i In summary, the 1,154 MT of annual particulates referenced l in Table S-3.is a hypothetical figure for the sole purpose of-calculation of estimates of the level of particulate emissions

-that might be emitted from a 45 MWe coal-fired plant. - This figure essentially is based on.the annual quantity of energy p - g 7- y ._

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from coal plants needed to support the uranium enrichment fa-cilities that are part of the uranium fuel cycle. Conservative calculations of the upper limit of health risk which may be as-sociated with the 1,154 MT figure indicate that atmospheric concentrations of the amount of particulates attributable to 1 45 MWe coal-fired plant reasonably distributed over a 50-mile radius would be 3,000 times smaller than the minimum concentra-tion determined by the EPA to present some health risk. More-over, conservative calculations of the upper limits of risk of those particulates distributed among the populations around the five fossil plants supplying the uranium enrichment facilities indicate that, at most, a tiny fraction of a death, each year those plants are in operation, could be attributed to the particulate emissions. This quantity is extremely small, par-ticularly when compared to the deaths one would expect in those same populations from all causes. This upper limit of risk is confirmed by an alternative calculation of the impact of the Table S-3 particulates over the population of the entire United States. Moreover, these calculations assume that exposure from particulates is long standing; otherwise, the calculated impact is inapplicable.

. Attachmsnt 1

. DR. L. D. HAMILTON -

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l PERSONAL QUALIFICATIONS My name is Isonard D. Hamilton. My address is: 6 Childs Iane ,

Setauket, New York, 11733. I am, among other responsibilities, Head of L

the Biomedical and Environmental Assessment Division in the National Center for Analysis of Energy Systems at Brookhaven National Laboratory, Associated Universities, Inc . , Upton, New York, 11973. The Biomedical and Environmental Assessment Division is jointly sponsored by'the Department of Energy and Environment and Medical Department- at i

Brookhaven. The Biomedical and, Environmental Assessment Division (BEAD) aims at developing a realistic assessment of biomedical and environmental l sffects of energy production and use. All forms of energy, including electric power generation using fossil fuels, hydro, nuclear, and new technologies, are assessed. The. Biomedical Environmental Assessment

! Division is. the lead group in the Health and Environmental Risk Analysis i

l Program, Human Health and Assessment Division, Office of Health and i

j Environmental Research, Office of Energy Research, U. S. Department of Energy, ' assessing the health and environmental effects of energy production and use and among other responsibilities is charged with producing ' a comparative health and environmental effects assessment of l

the different energy systems. The- Biomedical and Environmental Assessment Division also has substantial support from the U.S.

Environmental Protection Agency and is the lead group for assessing the health effects of complex technologies. The Division is designated a World Health Organization and United Nations Environment Program (WHO &

UNEP] Collaborating Centre for the Assessment of Health and Environmental.

Effects of Energy Systems.

I

. 1 I have been involved in assessing the risks of radiation for man for 37 years, specifically the health effects of nuclear energy for electric power generation for 22 years, and the assessment of the comparative health effectc from various energy sources, for the past 10 years. The Biomedical and Environmental Assessment activity formally began in July, 1973; for the past and present year our level of effort is 204 man-months annually.

I received my Bachelor of Arts in 1943 and qualified in medicine from Oxford University in 1945. I am a registered medical practitioner in the United Kingdom and licensed physician in New York State. After several positions in University hospitals, which included a position as Resident Medical Officer at the Radiotherapeutic Centre, Addenbrooke's Hospital, Cambridge, during which time I was concerned with the management of cancer patients undergoing treatment with radiation, I proceeded to research at Cambridge University on histological studies of the mechanism of the action of therapeutic doses of ionizing radiation for which I received my Ph.D. in experimental pathology in 1952. In the meanwhile, in 1951, I had received my Doctor of Medicine degree from Oxford; this is a senior medical qualification in the United Kingdom, roughly equivalent to Diplomate in Internal Medicine in the United States. I am also a Diplomate of the American Board of Pathology (Hematology) .

From 1950-1964 I spent 14 years on the research staff of the Sloan-Kettering Institute for Cancer Research and on the clinical staff of Memorial Hospital in New York being Associate Member and Head, Isotope Studies Section at the Institute and Assistant Attending Physician, 1

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Department of Medicine .at Memorial. During this time I was also a member f .

of the faculty of Cornell University Medical College and a Visiting Physician, Cornell Division, Bellevue Hospital. Since then I have i

maintained a continuing association with the Sloan-Kettering Institute as Associate Scientist. _

At the lastitute my laboratory research was on the molecular structure of the genetic material (DNA) and the cells in man concerned with the immune mechanism. I provided the DNA on which the proof of the ,

double-helical structure of DNA is based, and was one of the first to establish the long life of the immune cells in man. My clinical work in Memorial Hospital involved research on the treatme.nt of patients afflicted with cancer and leukemia with new chemical agents and also with new applications of radiation therapy.

In 1964 I joined. the- scientific staff of Brookhaven National Laboratory as Senior Scientist and Head , Division of Microbiology, and l Attending Physician, Hospital of the Medical Research Center. Since 1973 1

I have been Head of the Biomedical and Environmental Assessment Group i which in 1976 became a Division of the National Center of Analysis of Energy Systems.

i At- Brookhaven I continued my laboratory research begun at i

Sloan-Kettering. In addition since my Visiting Fellowship at St.

l Catherine's College, Oxford 1972-73, I have been concerned with placing i

all risks - in life in perspective; and since becoming. Head of the

! Biomedical and Environmental Assessment activity in 1973, particularly with the assessment of the hasards associated with different energy sources' and their use. Our group has the lead responsiblity to DOE for t-

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-_ - ~ _ . _ _ ____ _., , -- - .- - - _. _. _ _ _-

i the assessment of health and environmental effecto from various energy systems, and of coordinating such assessments in n'ationaL laboratories, universities and research institutes in the United States.

.My interest in the risks of radiation for man began with my Ph.D.

j work in Cambridge in 1946 and, since DNA and the immune system are prime targets of radiation damage has continued throughout my laboratory

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research. I was associated informally with the United Nations Scient1fic Committee on Effects of Atomic Radiation (UNSCEAR) almost since its ,

inception in 1957, served as Consultant, Office of the Under-Secretaries for Special Political Affairs (UNSCEAR), 1960-62, and was responsibl[for the first draf t of the somatic effects of radiation in the 1962 report.

This t.ection covers the effects of radiation in inducing leukemia and i

{ cancer in man. I have reviewed most of the working papers of UNSCEAR

) since then. I was a member of the National Research Council-National Academy of Sciences (NAS-NAS) Committee on Biological Effects of Atomic Radiation, Subcommittee on -Hematologic Effects, 1960-64, the NRC-NAS i

Solar Energy Research In9titute Workshop, 1975, the NRC-NAS Committee on

} Environmental Decision Making, Steering Committee on Environmental i

l Monitoring, Panel on Effects Monitoring 1975-76, the NRC-NAS Health Effects Resource Group, Risk Impact Panel of the Committee on Nuclear and .

! Alternative Energy Systems (CONAES) 1975-80,. the ' NRC-NAS Panel on the F

l Trace Element Geochemistry of Coal Resource Development Related to Health 1976-80, and the' NAS-NRC Committee on ' Research Needs on the Health Effects of Fossil Fuel Combustion Products, 1976-80.

I was 'a member of the Mayor's Technical Advisory Committee on Radiation, - New York City, since 1963 until its end, December, 1977 and I

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have been a member of the Technical Advisory Committee on Radiation to

< the Commissioner of Health of the City of Neu York since August, 1978.

F Since 1972, I was a' Consultant to the Environment Directo rate ,

. Organization for Economic Co-operation and Development; since 1976 served as DOE (formerly ERDA) Representative in the U. S. Delegation to the i Environment Comittee and U. S. delegate to the Joint Environment-Energy

, Steering Group. I was a member of the United Nations Environment Program e (UNEP) International Panels of Experts on the Environmental Impacts of Production, Transportation, and Use of Fossil Fuel 1978, on the Environmental Impacts of Nuclear Energy 1978-79, on Renewable Sources of Energy and the Environment 1980, and on the Comparative Assessment of Environmental Impacts of Different Sources of Energy, 1980. I was a member of the Beijer Institute, UNEP, and USSR Commission for UNEP International Workshop on Environmental Implications and Strategies for Expanded Coal Utilization,1930.

I am currently a member of the U. S. Department of Health and Human Services, Public Health Service Centers for Disease Control, National Institute for Occupational Safety & Health group of consultants advising on the epidemiological study of the employees at the Portsmouth Naval Shipyard where an alleged increase in leukemia was reported by Najarian and Colton in 1978, and a Consultant to the Division of Environmental Health, World Health Organization and the United Naticas Environment Programme on the comparative health effects of different enargy sources.

I 'have been Professor of Medicine, Department of Medicine,- Health Sciences - Center, State University of New York at Stony Brock, New York since 1968 and I am currently a member - of the American Association for

Cancer Research, American Society for Clinical Investigation (emeritus), l

- American Association of Pathologists, Inc., the Harvey Society, and the British Medical Association.

I have published more than 150 scientific papers , including many 4 reports assessing the hazards of various energy sources. ,

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References

1. Fisher, G.L., and Natusch, D.F.S. Size and Dependence of the Physical and Chemical Properties of Fly Ash. In Karr, C., Jr. (ed.) Analytical Methods for Coal and Coal Prod-ucts, Vol. III, Academic Press, pp. 489-541, 1979.

2. Holzworth, G.C. Mixing Heights, Wind Speeds, and Potential for Urban Air Pollution throughout the Contiguous United

, States. U.S. Environmental Protection Agency, Office of Air Programs, Research Triangle Park, North Carolina, January 1972.

3. Ozkaynak, H., Thuraton, G.D., Tosteson, T.D., Smith, C.M.,

Kinney, P.L., Beck, B., Skornik, W., Colome, S.D., and Schatz, A. Analysis of Health Effects Resulting from Pop-ulation Exposuren to Ambient Particulate Matter - Health and Environmental Effects Document 1983, Harvard Universi-

ty, Energy and Environmental Policy Center, Cambridge, MA,

October 1983.

4. Rowe, M.D. Human Exposure to Particulate Emissions from Power Plants. BNL 51305, Brcokhaven National Laboratory, Upton, NY, May 1981.

5. U.S. Atomic Energy Commission, Environmental Survey of the Uranium Fuel Cycle, WASH 1248, April 1974.

6. U.S. Environmental Protection Agency, Office of Air Quali-ty Planning and Standards Staff Paper. Review of the Na-tional Ambient Air Quality Standards for Particulate Mat-ter: Assessment of Scientific and Technical Information, EPA-450/5-82-001, January 1982.

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