ML20096B950
| ML20096B950 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 05/01/1992 |
| From: | Fleming J AFFILIATION NOT ASSIGNED |
| To: | Selin, The Chairman NRC COMMISSION (OCM) |
| References | |
| NUDOCS 9205130054 | |
| Download: ML20096B950 (23) | |
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Chairman Seltn Hnston Foison
.R.-Montirg Nav 1, - 199"l Chatrman-% Iin.
it v ary nicn 6,4 nat=
H Mi al. v in our neighborhced.
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and espec2all, Boston Edi %n for this,ers iv' ta invitation to the ptblic.
inaw ma aunpart :
oclia.of openness but this is a rather neal v N 71 on N! etSt*ude for Pi l gr i m.. tde do welcomw tho
-Opportunitv to addr ess /cu pernanal1y with our c r;n ' n s.
To this ar concerns fall into two brr> s' ca teeor i es ;
i
.HE4LTH and SAFE 1Y.
Fealth concerns have been disca, sed heavily lately with Mass. Dept. Of'Public Hemith. I wtch you were present at the Public Health Meeting last m gnt to hear first hand some of the concerns we;the Public have.
I will leava with you a copy of the' testimony _ that at least I presented, perhaps you could pass.it on to your staff members who are currently preparing-the NRC's t'stimony conrer ning the State's Air Emi ssi ons St andards.
.Last night we..did receive a tentativa commitment f r orn MDPH to consider setting forth a standard that-may help reduce emissions from Pilgrim and in the long run may help
- reduce the elevated nurab er s of cancers we expertence in-th13 area.
As'you=know my-first allegiance is to safety,_ Emergency Planning in ' articular..
The Chairman and Comminuion-dio graciously extend to me the privilege of addressing the _ f u !
Commi ssi on. cn this topic 1ast fall.
I did so in the form of-a-2.206 petition, which you did accept as such.
I am happy to. report the NRC is giving a groat deal of attentian to this
. petition.
Tnere are two updates regarding that petition I would
_'llke to; personally inform you of:
4 First: : The recent commitment I have received from George Davis, Vice-president of BECo, to secure either Letters of Agreement or signatures verifying agreement from all
~ Emergency Planning. Support Groups.
.This action will bring the' Utility in compliance with NUREG 0634 A.3.
This, to my
' knowledge,-will be-the first time ever in the History of Filgri m's Emergency Planning that we will have documented
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proof of real and actual-commitments from the necessary g
-support groups.
No more will we have to rely upon the supposed secret agraements only whispered to a select few.
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Had'BECo done this-years ago they would not have faced the t'
embarrassing Natianal-Guard tssue.
T hte Second Issue are the problems that surfaced during the Dec. En er ti se -namel y the onsite - ofisite enmmunication lint.
The NRC through Jim Taylor, Tim Martin and ecpeci al l y Etm McCabe has identified a multitude of pr ob l enw. In this s
cr1tical area.
Essentiallv what I am discussing, is the
- uti li ti es abilitv to deveicp the necessary information concerning accident status and being able to disperse that information to the proper Stete agency MDPH, to they in turn can hava the ability to make a t, roper protective action guideline for the EPZ public.
This is the most essential and basic-area of planning.
W1thout a proper-PAG we have nothing.
This area was riddled with f1ans.
It is my understanding tnat the NRC and the Utility have agrced upon the corrective actionn in both olanning and training t h a t - must ' be - tal en.,
lois tw being initiated by the Utility and will be 'ollowed up on bv ti;9 NRC.
MDPH 1s not yet cooperating iully but I am-sure-now that we have a new and wi11iog BECo.. Bob, they wi11 come al ong.
o
- These two areas alone strongly indicate that there i s NO REASONABLE-ASSURANCE.
When vou and the rest of The Commission voted on the Task Force Recommandation or Jim Taylor's recommendation to be accurate, Not to set the 120 day cloci;t you had not been made fully aware of these problems.
Yet, 1 had 1dontified both thene areas to the Task
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'R 1.im only one person, without. power,- /et, I initiated g
s the actions to bring ebout correction of both these areas.
You, Chairman Selin. nave the-power to correct all the hundreds'of flaws that still e>; i st in planning.
P i rx a s e, when
- niy 2.2C6 Petition ccares before-you for consideration, set the 120 day c4ock-and give to us t h e. public the planntng that the Faderal Regulation 10-CFR 50:47 mandates we should have.
Jane 4 Fleming DRAFT
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a BOSTCN EDISON Executwo Offm 800 Doylston Street Dastan. Massachuseus 02190 Georg,e W. Davis Emut,v vice Prescent April 21,1902 Mrs. Jane Fleming 30 Oceanwoods Drive Duxbury, MA 02332
Dear Jano:
Thank you for the enjoyable lunch. The Windsor House is special and will be added to my very limited list of the area's " good places to eat". I was disappointed that time did not permit a tour of the house. Another reason to retum.
As you suggested, more formal, and binding arrangements with EP 3articipants than currently exist are desirable. I will work to that end both through Mr. Rodham and the BECo. EP organization.
Although I have moved my office to Boston, my wife and I continue to reside in Plymouth. We enjoy the area ar d the many frir ds we have made here. As you can appreciate, being a part of Pilgrim during the s:cet 3 y.ars we have been hora has posed some unusual challenges. I am satisf.e how,er, that the plant is t..ng operated and maintained professionally. A t a go yl pmgress is being made in realizing the goal of Pilgrim as a good neighbor. Obvit., ttly, more needs to be done in both of these imperatives - and it will be done.
Your daughter's swimming prowess is impressive reflecting a lot of cedication and persistence on her part - and sacrifice on yours. I wish her the best of luck in the weeks ahead.
Sincerely, fj$'
I G. W. Davis GWD/mg
Duxbury Huclear Advisory Committee Duxbury, Hanstchusetts April 30, 1992 Commissioner Dovid Hulligan Hass. Dept. Public Health Attn Robert Hallisey Radiation Control Program State Laboratory Institute 305 South Street Jamaica Plain, MA 02133 Re Proposed Draft Regulation For Emission Standards For Radionuclide Emissions From Commercial Nuclear Power Plants (105 CMR 123.000).
Dear Commissionert We are writing to express our concerns rogarding the draft regulation (123 CMR 123.000).
The regulation proposed by DPH has three aspects, which conceptually can be compared to an automobile speed limitt
- The Emission Standard (comparable to a 55 mph limit)
- Compliance (comparable to a pol' ice radar trap)
- Penalties (in there a fine or loss of license)
I.
THE RMISSION STANDARD It The proposed emission standard is 10 millirem per year.
is based on what DPH feels is an acceptable risk'to a selected sennent of the public -- 3 fatsl cancers per-10,000 peoplet 6 incidences of cancer for every 10,000 people.
L.
Th2 Lt.YJitl af Eink The level of risk UPH proposes for airborne radionuclides is much higher than that permitted for other carcinogens.
For airborne chemicals, DEP's acceptable standard is a lifetime cancer incidence risk of 1 in 1,000,000 for any one chemical.
(DPH Memorandum dated December 3, 1991, entitled "DEP's CHEN/,'.AL risk assessment--
See Appendix A).
Yet, according to a recent 1
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assessment by DPH of the risk from radionuclido emissions, the aqrtality risk allowou by the " standard" set in the proposed DPH regulation is 3 in 20,000, and the allowed risk of cancer incidence that 18 about 1.5 to 2 times higher.
According to the DPH assessment, radionuclide emission stande.rd would have to be reduced to 0.015 mrom per year to reduce the lifetime cancer incidents risk to the same level, 1 in
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1,000,000, as that permitted for chemicals and many other carcinogens.
L Tha Ennulation at Rink An advisory committee appointed by DPH to work on the proposed radionuclide emission regulation voted that the " safe" emission standard should protect the portion of the population that was most exposed, i.e.,
those who live nearest the Pilgrim nuclear plant.
The proposed regulation appears not to follow this vote.
Instead, it adopts a definition and method of calculation (Sec. 123.03. Definitions... Effective Dose Equivalent) that determines the risk to a hypothetical " reference man" from radionuclides dispersed and diluted over a 50 mile radius.
Quite obviously, any given level of emissions from Pilgrim will present a substantially greater risk to those living in Plymouth, Kingston and Duxbury than to the populations of Boston, Providencs and Provincetown, all of which are less than 50 miles from the plant.
C2 Eilarin's operations In April and December of 1991, Mr. Tom Sowden of Boston Edison told the DPH Advisory Committee that, since 1980, the emissions from Pilgrim I, measured at the boundary of the plant site, have been at or below 1 mrem por year 90% of the time, and at or below 0.2 mrem per year 70% of the time. (And, additionally, see a copy of the emissions summary chart from Boston Edison's testimony on this proposed regulation, dated 3/15/92-Appendix B).
2x Doscs (Rems) Versus Actual Measures Of Radinactivity (Curies 1 The proposed draft regulation defines the standard in terms of dose limits.
This poses difficulties. This is becap.se what a facility emits is not a " dose" per ss ( which is measured here in terns of millirems) bot " radioactivity" ( as measured in a tinit l
such as curies).
It is a close to impossible task to make a 2
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reliable connection between what Pilgrim emits and the dose it causes.
The "dcce" that might result to a person living in nearby towns from a given omission depends on a host of factors, includingt
- the kind of radioactive material emitted ( whether it is cesium-137 or strontium-90, and what chemical form it is in),
- the level of dilution it experiences in the environment,
- the behavior of the people near the facility-how much water they drink, where the water comes from, how much time they spered outdoors near the f acility, where they were during batch releases, etc.
In order to make actual dose estimates, therefore, assumptions have to be made about these and other factors.
Obviously, subjective judgement and uncertainty is involved in making such estimates.
Thus, even a reasonable range of assumptions could result in a wide disparity in the resulting dose calculation.
This problem makes a simple dose-based standard (such as that proposed by DPH) fuzzy and vague because there is no clear or precise onjective limit on how much radioactivity (in curies) Pilgrim would be allowed to emit, either in total or from each stack or pipe.
4 This is undesirable.
A good standard should provide a clear-cut way to tell whether it is being violated or not.
From the perspective of enforceability, a clearer standard would be one which places a specific, concrete limit on allowable emissions of radioactivity, rather than simply on dose.
Practically no other industry emitting any other pollutant is allowed this dose-based approach followod in the nuclear area and in this draft regulation, instead, industries must comply with environmental-health standards that set specific numerical i
limits. (See Appendix C).
l Comment The Committee's view is that DPH's decision to allow i
i radionuclide emissions at a level that creates a risk 450-600 times greater than that permitted from any single airborne chemical is nnt reasonable.
In this respect, it is important to l
note the following:
1 l
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a.
There is a growing body of scientific literature, including L2H's own recent report on the incidence of leukemia in the areas adjacent Pilgrim I, indicating (1) that low-level radiation presents a much greater risk of cancer,(ii) that even less may cause autoimmune disease. chromosomal damage and reproductive disorders, and (iii) that there is no known " safe" loval of endix g).
radiation. (see, App % n q c
b.
According to thekformer Chairman of the Nuclear Regulatory Commission, Kenneth Carr, and as was discussed in detail at the 21st DOE /NRC Nuclear Air Cleaning Conference, held in San Diego, California on August 13-16, 1990, thn technology needed to reduce airborne emissions essentially to zero is readily available.
The technology is discussed in the published three volute Proceedings of that conference. (See, Appendix D).
c.
The effects of radiation are cumulative.
The proposed standard deals only with future airborne radionuclide emissions.
It does not take future liquid radionuclide emissions into Plymouth-Duxbury Bay into account; neither does it consider either the past or future effects of previous releases of radionuclides (many of which have extremely long half-lives) into the water or the air.
7.
In determining what risk is " acceptable", one of the critical questions is " risk to whom?"
In its proposed regulation, DPH ignored the advisory committee's vote that the
" safe" emission standard should protect the portion of the population that was most exposed.
This decision, the effect of which is to allow Pilgrim to release far more radiation than would otherwise been permitted, is particularly open to question since Boston Edison's statements to DPH about Pilgrim's actual emission levels (at or below 1 mrom per year 90% of the time, and at or below 0.2 mrem per year 70% of the time) referred to emissions as measured at the site boundary, not 50 miles away.
3.
Particularly in view of available technology, the position of the Duxbury Nuclear Advisory Commit'cee regarding the r
emission standard is clear:
a.
The emission standard should be set at 0.015 millirem per year.
There is no justification for allowing a greater risk of cancer incidcngs, not only death, than in the case of other carcinogens.
4 J
s b.
The definition of " Effective Dose Equivalent" must be changed to reflect the Advisory Committoo's vote that the
" maximally exposed person" is protected, rather than permitting emissions based on the dose experienced by the diluted / dispersed 50 mile " reference man."
4.
The Duxbury Nuclear Advisory Committee feels, fron the perspective of enforceabilty, the standard should include in addition to the current dose-based one, a standard limiting (and requiring reporting of) radioactivity of specific isotopes measured in curies.
II. DETERMINING COMPLIANCE Once the emissions standard is set, the next question is how the state is to determine if a nuclear power plant has complied.
All the proposed regulation provides is that:
1.
The utility may " estimate radionuclide emissions" rather than making any actual measuraments (Sec. 123.09(1));
2.
If the utility chooses to measure emission rates, periodic rather than continuous measurements are allowed if the flow rate is "relatively constant" (Sec.123.09(2)(a)(3));
3.
Any release point that does not have a " potential to dischargo radionuclides into the air in quantitles which could cause an effectivo does equivalent in excess of it of the standard" may be ignored. (Sec.123.09(1)(d)); and, 4.
The utility must submit annual reports " covering the emissions of a calendar year by March 31 of the following year" (Sec.123.06).
Comment In the opinion of the Duxbury Nuclear Advisory Committee, the proposed regulation falls far short of the most fundamental essential requirements.
To insure that airborne radionuclide emissions from a nuclear power plant comply with an air emission
^
standard there must be:
i 1.
Continuous, real-time monitoring of all potential radionuclide release points; 5
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2.
Continuous reporting, by a direct, real-time computer link with DPH, of the output of all the release point monitors.
3.
Continuous reporting, in curies, of each isotope released, as well as reporting in m/ rems.
Laws or regulations providing for this type of real-time monitoring and reporting are already in effect in a number of states, including Maine, New York, Pennsylvania and Illinois.
Since 1987, Massachusetts Commissioners of Public Health have Supported legislation that Would require it in Massachusetts.
The testimony of Boston Edison Company has submitted on this
... administering very Draft P.egulation, on page one, states, these regulations would creato additional paperwork, expand bureaucracy, and increase the cost of doing business...".
This is ridiculous.
The regulation only requires the utility to fill out the very same NRC forms it is already required to fill out for the NRC.
Indeed, a duplicate copy would seem to suffice.
To the extent that Boston Edison's complaint has any currency at all, a direct data line from its existing real-time monitors would obviate the need for any paperwork, and would place the onus of any extra work, not on the utility, but on DPH.
s III.
RFFECT OF NON-COMPilANCE The proposed regulation provides only one penalty if a nuclear power facility fails to meet the required emission level "If the facility is not in compliance... the facility must report to the Director on a monthly basis" (Sec. 123.06(3)),
rather than only once a year (Sec. 123.06(1)).
Corsment There is one fundamental reason for an airborne radionuclide emission standard - protection of the public health.
If a utility fails to comply with the standard, " monthly reporting" does not provide the necessary protection.
We feel the proposed regulation must be changed.
At the very least, it should require:
(
l.
The facility to be closed until the reason for too-high eminsions has been determinet l
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Corrective action to eliminate the cause of the too-high emissions prior to re-start.
3.
Limits on emissions during continued operation to whatever level is required to insure that the tota) enissions during the calendar year in question do not exceed the annual level permitted 4.
An appropriate fine in an amount sufficient to (a) deter future violations and (b) cove. any costs incurred by the state or local towns as a result of the impermissibly high emissions.
IV.
ADDITIONAL COMMENTS Finally, DPH should initiate a "Heroorandum of Understanding" with all border statea with the goal of developing uniform standards. There are no lead shields at the borders to protect our Massachusetts follow citizens.
Furthur, the regulation should apply to Yankee Rowe.
Although not operational, Yankee Rowe will remain able to emit radionuclides into the air during the upcoming and lengthy decommissioning process.
We thank you, commissioner Mulligan, for initiating this process. -We hope you will give serious consideration to our comments, so the final regulation will be both protective of our health and act as a model for the nation.
Sincerely, b"'
huiLA kg %ne G he ei,equ The Duxbury Nuclear Advisory Committee h pa. -
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1 mImAL rsummm rmswes for farmxxs AIR Iurnnum,pernus) am NADZaartTrEK SIPnNaIR 1989 thited States Dwitw.maiuti Protect.icri Agemy offios et Radiation Prtgrams (ANR-459)
Risk 1-M Mathcd) logy EPA /520/1-89-305 12winnaantal Imact statanent NESEPS far Radicruclides Darkgreal Informaticm W==1t - Volume 1 Risk Ar - tv.ata EPA /520/1-89-006-1 Dwironmental Igact Statarent NESRPS for Rxliornclldes Backgrcund Inforation Document - Volume 2 frontraic Asseranent EPA /520/1-89-007 nwironmental Imact Statenent lESMPs for Palicruclides luckground Inforntion Docunent - Volume 3 FT W ASSFR MENT BonRC WMYR REACIUCdE!B1 Patrarnoes 3
Highest-Incidental Lifetime t.
Fatal Cancer Risk 5 x 10 <
Vol. 3 p. 1-3 Dose Dates for Model BWR 0.2 unen/yr.
Vol. 2 p. 4-56 At.Wic Radioac.tive Dnissicns Asstaned for Model Ble 1415 ci/yr.
Vol. 2 p. 4-53 Distance at Prtdcninant Wird Direction 750 meters Vol. 2 p. 4-55 Total Cancer Incidenoa Resulting nun mole Body Dpcaure 1.5-2.0 Huma Vol. 1 p. 3-9 the arrtality risk Lifetime cancer Risk Lifetime Baxsuru o
(anan/yr.)
Fatal 5 x 10-6 0.2-Fatal 1 x 104-0.03 Incidence 1 x 10-6 0.015 ratal 3 x 10-5
.1 Tatal 3 x 10-4 10 Fatal 3 X 10'3 100 L
Fatal 1.5 x 10-2 500 Elizabeth Anne Bcurque, Ih.D. - Atgust 16, 1991 i
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1 to:
BobIIallisey 1T04:
Liz Dourgoo RE:
DEP's QID4/AAL risk asnessment DATE
[
- m h r 3, 1991 The following are responses to the questions cn Depadzent of Environmerital Protection's (DD's) Chemical licalth Effects Assessment liothodology and the Methcd to Derive Allowable Ambient Icyals (OfDi/AAL) of air mntaninants raised at the 11/21/91 uneting of the Advisory 0:mittea on Radionuclide Air thissions Stardania.
- 1. Ibr each air contaminant DEP calculates a.'Wgg33ELJE2Cm ETK0ulC UMPf (TEL) value developed for rg;ggssp! rn;ien!r eff mts that in a quantifiable level, threshold leve;,, which produces the adverse effect, e.g. skin irritation et al.
In determining the TEL DEP uses a 24-hour average Invul.
- b. urem mmemPt(?.TA) value developed for riBW.hreshoLd effects sudi assig;Einogenicity>
In determining the AAL DEP uses an arnalsomragaprvgl.
Accortling to DD the TEL and AE values for each chemical nust be used together to be protective of public he9th for both threshold aryi nonthreshold effects.
It is obvious tho.t DEP does not use an instantaneous rehase 1cvel as a c:riteria for air contaminant levels.
- 2. DEP's risk level coal for a mixture of chmicals Jj :
lifetime cancer ircirkvice risk of 1 x 10 J
h.rt even in mixtures they try to limit the risk as such as possible.
DEP's risk leual abhene themicultist lifetTas canoar irmi% risk of i x lod
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annual whole body dose to the maximally exposed individual of less than 5. millirem / year.,Thir Design Objective is based on the concept
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of ALARA (As Low As Reasonably Achievable) and is the de facto s t a r11a rd f o r en i.s s i on s ir em ' c me r_p_i.31_rmc l e a r nom._pla nt s.
t In addition, existing EPA regulation 40CFR190 limits the total annual dose from the e nt irn_.u._r_a nium Ge_L cvc l e including milling, conversion, enrichment, fuel facrication, and generation of l
electricity to only 25 milliren/ year.
This limit corresponds to the ICCFR50 design objective of 5 millirem / year to a person living near a commercial nuclear power station.
PNPS operates well within both existing NRC and EPA standards and the proposed NESHAP.
As you can see from figure 3, over the last 10 years, calculated annual doses from Pilgrim Station to the most exposed member of the general public (usually the person livir] at or near the Pilgrim Station property boundary) have been much less than the NRC Design Objective of 5 milliren/ year and very much less than the proposed state limit of 10 millirem / year.
Actual doses are too small to reliably measure in the presence of natural background radiation.
Figure 3 a
Calcu'ated Annt, al Cf f aite
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In order to comply with the reporting requirements of the proposed regulation, additional manpower will be necessary to provide the reports on the frequency and in the format required.
The information in these reports is redundant to that already required by 4
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Sionificant. Findinos on Child Henith Risks of Low-Level Radiation.
Gardner et al.
Results of case-contro1' study of leukaemia and lymphoma among young people near Sellafield nuclear plant in West Cumbria.
BMJ Vol. 300, 17 February 1990. ""'
In February of 1990 Hartin Gardner and his research team discovered strong associations between paternal occupational exposures and subsequent childhood cancers in the village of Seaccale, England, close,to the, site of the British. nuclear reprocessing plant, known as sellafield.
Gardner's finding suggests that father receiving as.little as 1 rem exposure to radiation, (less than six' months before conception).may be passing on a mutation to their offspring that increases the offsprings' subsequent risk of,cnneer..: The' village, Seascale, had 12 times as many' childhood cancers as, expected.,-*A dose-response relationship'was', observed,'the; association being strongest in the highest.. paternal, dose group.".*f Gardner,
demonstrated in a case / control.etudy that'a high,' proportion of these cancers were linked to father's occupation at the Sellafield plant.'
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- i ? * "' " I ' ' ' i' P'i "
(Exposures; 1 rem or'mor5)'
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Hatch et al.
Background. Gamma. Radiation and Childhood Cancers Within Ten Miles of a US Nuclear Plant.
International Journal of Epidemiology, Vol. 19lINo! 3,~1990.
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A stu'dy by Hatch and Susser of Columbia School of Public Health in New York published intho' International Journal of Epidemiology found a'p6sitive'correlati6n'b'e't' ween background
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gamma radiation and childhood cancers in census' tracts within ten miles of the Three Mile Island Nuclear Facility.
For childhood cancers, as a whole, incidence rates relate significantly to background radiationi'th5 aasociatios is; strongest in' children
^
ages 10-14 years.~' ;Their.. data indicate"u"50%' increase in risk of cancer for children under.15 with over'0.1"edy"' increase in estimated ann.ual,r.,ackgrou wnd gammara,y dose' rate.".
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....n Stevens,'et'ai) 5euNemia'3nUtah[anhRadioactive"Fal15utfrom 5, August 1,'1990. Q ',y \\,[...*': [.tudy." JAMi,i'{t] ;
the Nevada Test Site.' A Case-Control'S Vol. 264, No.
. ;. s,.
A study published in,v. -JAEA in August 1990.showed an excess s....,
risk of acute lymphatic leukemia.for those. individuals who were younger than 20 years.of age when exposed to fallout from nuclear testing at the Nevada Test Site between 1951p55.... Estimated doses to the population ranged between 2.9 mGy._to,30,mGy.
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Forman, et al.
Cancer Hear Nuclear Installations.
Nature, Vol.
329, 8 Octobtr 1987 (Commentary).
Pubifshed in Nature in 1987 was a study of cancer near nuclear installations in the United KingN m, conducted by Forman et al.
Tris deteiled study analyzed childhood and adult cancers in local authority areas that had one-third of its population living with a 6-10 mile proximity to a nucioar installation.
The age group of 0-24 years had excess cases of lyrphoid leukemia and brain tumors.
Particularly high excesses were noted around Sellafield and two nuclear installations in Scotland (Dunreary and Hunterston).
Knox, Stewart, Gilman and Kneale.
Background Radiation and Childhood Cancers.
J.
Radiol. Prot. 1988, Vol.
8, No. 1 9-18.
In early 1988, Knox et al. published a study on background radiation and childhood cancers in the Journal of Radiological Protection.
These investigators matched outdoor levels of terrestrial gamma radiation with local childhood cancer rates for every 10 KM square in Groat Britain.
A statistically significant positive correlation was found between exposures to background radiation levels and rates of childhood cancer mortality.
The finding suggests that radiation might be a primary cause in the majority of all childhood cancers.
Increases in overall fetal radiation exposures, from whatever cause, would then be expected to result in a near proportional increase in the subsequent cancer rata.
Average absorbed fetal dose is
.?' mCy (220 millirems).
Sever and Gilbert.
The Prevalence at Birth of Congenital Malformations in Communities near the Hanford Site.
American Journal of Epidemiology, Vol. 127, No. 2, 1988, Sever and Gilbert.
A Case-Control Study of Congenital Malformations and Occupational Exposure to Low-Level Ionizing Radiation.
American Journal of Epidemiology, Vol. 127, No.
2, 1988.
On the subject of birth defects resulting from increased exposure to radiation, investigatorn at Battelle, Sever and Gilbert, published studies in 1988 which did find a statistically significant association between parental cumulative radiation exposure and neural tube defects.
Congenital dislocation of the hip and tracheoesophageal fistula showed a significant associa-tion with employment of the father-before conception.
These positive findings were downplayed at the time as false positive findings or artifacts because previous studies had-shown no similar effect-at such low doces.
However, due to the recent Sellafield findings by Gardner, these birth defect findings must be explored more thoroughly.
The investigators themselves recommended birth defects curveillance in the central Washington state area.
Exposures to these workers at Hanford were between 1
- 10 remo over their work experience.
4 Modon, Baruch, E. Ron, A. Wornor.
Thyroid Concor Following Senip Irradiation.
Rcdiology 123:741-744, 1971.
In the Israeli Scalp' Irradiation Study, Hodan and co-workers (Hodan77) reported on the excess of thyroid-cancers observed among over 10,000 children in Israel who received x-irradiation for ringworm of the scalp.
The estinated thyroid dose per child was 7.5 rads, total.
Thyroid-cancor was observed at five times the expected rato during a limited follow-up period.
SPECIAL NOTE:
)
In December 1989, the BEIR V (Biological Effects of Ionizing Radiation) Committoo, of the United Nations, adopted revisions to the Japanese follow-up of A-bomb survivors.
The Committee stated that radiation risks were understimated by three - four times.
For an independent review of A-Bomb Survivor Study, see Coffman, John - Rndiation-Induend Cancer from Low Done Ernosure, Committee for Nucioar Responsibility; 1990, San Francisco.
Stewart, A. - Healthy Worker and Healthy Survivor Effects in Relation to the Cancor Risks of Radiation Workers.
Am. J.
of Industrial Hod. 1990 11, 151-54.
4 4
E l
l
j I
HEALTH EFFECTS FROH !TUCLEAR WEAPONS TESTING FALLOUT -
RONGELAP (MARSHALL ISLANDS).
Thomas E. Hamilton, MD, PhD.
The Henith Effects of Radioactive Fallout on Marshall Islanders:
Health Policy Issues of Nuclear Wcapons Production.
PSRQ; 1991; 1:15-23.
1
~~
The most prevalent long-t'ernihealth'ef'fic'tin the Marshallese population has been the development of benign and malignant thyroid neopinsms.
Approximately 304 of adults on Rongelap (and over 60% of children exponed when younger than 10 years of age) developed thyroid nodules, a small proportion of which were thyroid carcinoma.
4.-
7 Long-term health effects other than thyroid neoplasia have included hypothyroidism, grewth retardation in several individuals, and most probably two deaths, one"each from acute myelogenous leukemia and gastric'ca~rcinoma,'.among the 86,
Rongelapese persons who were highly exposed. (In addition, chromosomal aberrations in this group were increased relative to comparison groups 10 years after exposure to fallout radiation.
See also:
' ~
'~
', [ ~ ~
Thomas E. Hamilton, MD, PhD; Gora'id 'va'n B'elle7 'PhD; Jimis P.
LoGerfo, MD, MPH.
Thyroid Neoplasia in Marshall Islanders Exposed to Nuclear Fallout.
JAMA Aug. 7, 1987 - Vol. 258, No. 5.
~ ~" '"
I'"
w c[ '..
British Atomic' Veterans
~
- .'. 9
. ~..
EG Knox, T Sorahan, A Stewart.
Cancer Following Nuclear Weapons Teets.
Letter to the Editor, The Lancet, April,9, 1983.
ca..+.
,s.t The South Pacific tests - whose local base,..was Chris'tmas Island - overlapped in time with other weapons t'es.ts.
- Thus, there were twelve tests in Western and South Australia between 1952 and 1957, and nine South Pacific t'est'i'Between May,'1957, and November, 1958.
The follow-up of the'Sduth Pacific population is far from comple.te but already there is evidence of an abnormally high incidence of le.uha'emiaand'other reticulo-
'" 3#*
endothelial system (RES) _ neoplasms.'m"
~
- L.u wMo n.m _6 For the aen with RE3 neop1as"m'd 'th[e"d'o8ddin't'.ar'y"e' vide'nce i'n suppo-t of the diagnosis and weapons test involvement is such fxcluded.
This leaves that a major artifact can be confident 1r' enc'cfo~f thdse' r~adiation-as possible explanation of the high incid related esneers either; (a) far more men at ri'sk than the 8000 we have allowed; (b) much higher radiation doses than has hitherto
'been supposed; (c) much higher cancer risks from small doses of radiation than has hitherto been supposed; (d) exposure of the men to o her causes of RBS neoplasms; or (e) a combination of some or all of these factors.
CANCER EXCESSES PROM KEDICAL IRRADIATION.
E. G. Knox, A. M. Stewart, G. W. Kneale, E. A. Gilman.
Prenatal Irradiation and Childhood cancer.
Journal of The Society for Radiological Protection, Volume 7, No. 4 (1987).
Estimates of the relative risk of chi 1dhood cancer, follow-ing irradiation during fetal life, are reported.
They are based upon extended case-control investigations.of childhood cancer donths in England, Unles and Scotland between'1953 and 1979 comprising 14,759 geographically-matched and birth-date-matched case / control pairs.
47 j'.' ';3 ;",l.'4 7
The estimates Yere calculated using CoEditio'nal' Logistic Regression (Mietttinen-Breolow) techniques.
This method of risk-estimation limits the distortions caused by confounding factors or by bicsed selection of controls..Through anelysing a range of reported exposures other than radiation, levels of general, reporting and recording biases between casesand controls were also assessed.
There was no evidence','among 'cas'od,or controls of any systematic reduction in the freqhehey of_ pregnancy.x-rays
~
between 1950 and 1979.
During this period'of; time,'about 7 percent of all childhood cancers,, and 8 percent'of those with onset between the ages of 4 and 7 years, wers caused by x-ray
+
examinations.
The dose-response relationship was 'one death per 990 obste,tric x-ray exam.inati.ons; or.2,00,0 d.ea.ths por. 104 man-Gy.
s.u r
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E A Gilman, G W Kneale, E G Knox and A N Stewart..g Pregnancy X-Rays and Childhood cancers:
Effects"of Exposure Age ~and Radiation'. Dose..i..,.R.adiol.. Prot.
J.
19 8,s.'.,J..ol.
8.,.. No., 3r., 1, 3-8.
8 V
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Alice Stewa'rt, Josefine Webb, David Hewitt.' A Survey of m,
,s, Childhood Malignancies..
Q,.BritionM.edicalJournal, June 28,. ;.Q, ; {
- f Q 'y"
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- 1958, Vv1. i, pp 1495,-1508..
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.....4 MacMahon, Brian.~ Pronstal X-Ray Exposure and Childhood Cancer..
JournaloftheNat,ionalC,ancorInstitute,jl,28:1173-1191,1962.
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The higher frequency.of prenatal,,,x-ray in _the,,,canc.,.,..,
er cases than in the sample was'atatistically"sibntfi' cant.',.Aftor Torree-tion for birth order and other" complicating' variables, it'was estimated that cancer mortality.(including leukemia mortality) was about 40% higher in the x-rayed than~ in' the u'nt '-rayed x
members of the study population..This relationship held for each of the three major diagnostic categories
.. leukemia, neoplasms of the central nervous system, and other ) neoplasms.,.' ~
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1
e III. QTHER LOW DOSE FINDINGS CANCER RISKS NEAR THE PILGRIM NUCLBAR POWER PLANT.
Morris H, Knorr R.
TheSoutheasternMasshchusettsHenithStudy 1978-1966 - Report of the Massachusetts Departmont of Public Houlth, October 1990.
(Not yet published in peer review journals.
This case-control study found an associatidn between radintion released from the plant and leukemia incidenco among cases diagnosed before 1984.
A dose-response relationship was observed in that the relative risk of leukemia increased (four-fold) as potential for exposure to plant emissions also increased.
c
?-
. in
... v Clapp K, Cobb 8, Chan C, Walker, B.
"Loukemia Near Hassachusotts Nuclear Power P? ant".
Letter, Lancet, Dec. 5, 1987.
.. u; n n ra-Investigators obeorved an increased incidence of leukemia, particularly myelogenous leukomia, in a five-town area in Massachusetts during 1982-1984. 'In one of these towns, a commercisi nuclear power plant is located and released signifi-cant radio-isotopes in 1974-75.
The most striking excoss was for myelogenous leukemia in males.
'.: r
- p - W C.
,,, m CANCER RISKS FROM URANIUM MINING.*
"n r o s -* r
- 2-Archer, Victor E. and Wagoner, Joseph K.
Lung Cancor Among Uranium Miners in the United States.
Healthy 1 Physics, Pergamon Press 1973.
Vol. 25 (Oct.), pp. 351-371. Mede 1:
~
Excess respiratory cancor has boon demonstrated among all groups of uranium miners who havo had more than 120 Worki.12 Level Months of radon daughter exposure.
Lung cancer incidence rose with increasing exposure.
Factors which might distort the exposuro-response relationship w3ro reviewed.
Exposure to other agents such as cigarettes probably contributed to the excoss, but these factors should not be considered in setting permissible levels.
Rospiratory cancers are continuing to appear at a high rate among the Study Group even though radon daughter levels have been markedly reduced and most of the Study Group have stopped mining.
i See also:
Wagoner, Joseph K; Archer, Victor E; Carroll, Benjamin E; Holaday, Duncan A; Lawrence, Pope A.
Cancer Mortality Patte ns l
Among U.S. Uranium Miners and Miller, 1950 through 1962.
Journs1 of the National Cancer Institute, Vol. 32, No. 4, April 1964.
1 1
l
Important-Features Among Studios - Public Hoaith Implications These studios demonstrate that patterns of increased cancor risks with findings that range from suggestive to significant, have been apparent oince 1977. Many of those studies show that with longer follow-up (particularly to 26 years) and when long exposure lags (15+ years) are eniculated, more correlations between radiation exposure and cancor are detected.
Cancers most frequently observed are lymphopoietic neoplasms (all leukemia, non-Hodgkins, myeloma, reticulum cell sarcoma), prostate and female cancers.
r a r~>-
- ~ 7
...-j.t.
Other significant features for cancer dotection ' included controlling both for the general healthy worker effect and for a selection bias within the worker population.
Several studios indicrto that workers in the more dangerous jobs are more selected (higher education, income, more physically fit).
When internal comparisons woro mado controlling for this bias, there was increased risk detection..
.<."..i c a
3,,.
Soveral major studies conclude that linear extrapolation from higher to lower doses may seriously underestimate radiation risks. Those studios
-present a major public health concern, as elevated.and significant cancer risks are found among workers exposed to very' low levels of external radiation. In the Wing study, 140 millirems was the average exposure, others range from 2-3 rems.'At those very low lovels, we see elovated risks among a very healthy population. The general population, in the vicinity of those plants, receiving a fraction of those dosos, could be at comparable risk for increased cancers.
W
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(See appendix for specific study citations, their findings and an c)clanation of terms.
Section III is an excerpt from the CCRI Newsletter -
October 1991).
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,, 9 DMt,0xfordshire.
cella that survive an ussult by low.
A form of sediation i ry, one Separatelyand tn related work.Dt. level alpha radiation can pass on that causeslongterm genet damage John D. Little and collaegues et the some unknown charises through I
to living cells, luts been discovend Harvard University Schoolof Public rnany generations. This could have independently by two poups of re-Health in Boston said they had implications for the eventual rise of searchers. The effnt, if confirmed.
fonas a ilmilar "dahyed mutation leukemias and other cancers long may eventually lead to 7nore strin*
effers" when using X. rays to irradi. after exposure to radiation, he said, gent standards for pro tectfnC nuclear ata hamster cells.
Estimates ofleuktmis risk are now powe7 worbera and ofhers frorn redh Little said in a telephoneinterview based on a pergn's possible exposure atton.
that it appears both research groups to high ene, penttrating radla.
One research rroup, b n report toand the same or similar phenorne. tion, such as eta. gamma and X.roy behis published In today's haue.af na while approachtnr the problem radiation. and allow for little contri.
the journal Nature, sald that when from different directions and with bution from the weakl penetrating they pond mouse cells to the type different types of tr4ation. We did alpha rays, the Britti rescsrchers
, of ra ation known as alpha partl* our experiments win. X.rsys and we,noted - -
cles, abnormalities of the chromo-saw evidence of a delayed genetic archers trom both.
a somes appeared in some descendant phenomenon that is different fro that if the work is cone.rm esti.
celh several enerations of cell divi
- normal radiation. Induced snuta mates of the health rista of radiation slon later. A a particles are emit-tion," Little said.
rney hav epward:-
ted by radioactive plutonium and by Usually, radiation altars the genet.
A rays can be.very damaging redon gss.
le makeup of a cell, causing its 'to enlls they reach because they This long. delay'ed e'ffect is novet immediate.descendanta to take on unload all their energy in a small andt different from the immediata new characteristica. !n the new find. ' area. ~he delayed effects seen la the genette damage caused by experi* ings, some of the cella that survwe ' mouse celk used in the erperimenta mental X.roys and gamma rays, said radioactive anault appear normal Indicates the radiation damage can Dr.: Eric G. Wright, leader of the through several divisions, Little said. be star than it appears initta:ly, team from the Brithh Medical Re-
"We think the whole thing la set Wr ht said.
off by an induced inetabolle process The Brithh researchers used stern that continues to produce damage, cella from mouse bone marrow for unnoticed as the cell reproduces, the experhnent. This type of cell not
- Da.ly Games untti lt suddenly becomes appar=nt onir produces blood ceik. but ano i
for some reason," he notad.
next nerations of stem cells Wednesday Mass.
Wright said in a telephone intar. throus which an undetected abnor.
D' lly Humber:5943 view that.the work his group, matity caused radiation could a
Pa'yo!!s on $1 bet:
including Munira A.Ka him,a post-pass. Stem cells m Inbred mice prone to dmiopin eukernia wue
,, more susceptible to {ter alpha radia.
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to reach $12 million ity. wri ht aat*d-
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$120 no Jackpot winners in last night's Wri ht said. "This could mean that-t.ast 3: h355552 Megabucks drawing, state lottery Indi ual humans who also have a.
Megabu
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$12 mi!! ion, they said, radiation than others.*
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CONF-900813 Vol. 2 w
Proceecings 0:? ::ae 21s : DOE /NRC Nuc~ ear Air C: Leaning Con:?erence Sessions 9-16 Held in San Diego, California August 13-16,1990 Edited by M. W. First Sponsored by U.S. Department of Energy U.S. Nuclear Regulatory Commission International Society of Nuclear Air Treatment Technologies, Inc.
The liarvard Air Cleaning Laboratory Proceedings prepared by The Harvard Air Cleaning Laboratory
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