ML20155H471
| ML20155H471 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/10/1988 |
| From: | Huver C SUSQUEHANNA VALLEY ALLIANCE, LANCASTER, PA, THREE MILE ISLAND ALERT |
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| ML20155H443 | List: |
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| OLA, NUDOCS 8810200228 | |
| Download: ML20155H471 (59) | |
Text
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(NI1TD SIAITS OF AMERICA NLT2 EAR REIRJIATORY CDMISSICH MJORE TYIE ATOGC SAFTIT AND LICINSDC IDARD in the Matter of:
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GIU Nuclear Corporation
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Docket No. 50-320-OIA (Three Mile Island Nuclear
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(Disposal of Acx:ident Generated Station, Unit 2)
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Water)
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AFTIIRVIT OF [R. OIARIES W. HUVER (CDUINTICH 5): FURI1ER 03EIDEPATICtG OF 111E BIOIDGICAL t.nu;m AND !!EAIH11
!! AZAR 08 OF 'IRITIlN
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Dtited: October 10, 1988 SWom arti subsexibed befom me on this/gth day of October,1988.
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t INIP000CI'ICH It is clear that based upon the biological evidence that tritium is a classic paradigm of being a widespread and serivas auntaminant of the envirtnennt whose significance has often been ignored or not fully It has unfo m taly often been downplayed as a biological and realized.
health hazard by those whose suport of mclear technology overshadows their conoarnforpublichealth(Huver,epal.,1979).
DISCUSSION l
r In Contention 5, the Joint Petitioners hold that neither detailed nor accurate information was given in the PEIS to allow decision makers and the public to detamine the offects of this prqv=ri action on public health and safety, as required by NEPA (Mmorandum and Order, ASIEP No 87-554-04-CIA).
With reference to subpart (d), I would like to expand upon the allegation that tha serious biological effects of tritium luve been underestimtad. An examination of PEIS Su@lment No. 2 ard the afficavit of Dr. Hans Behling reveals that most of the literatum on the biolrgical and health hazards of tritiu:n has been mittal and ignored with the not result that the serious genetic, developnental, carcinogenic, and imaanologic effects of tritium expanire have been seriously underestir.ated.
It is often difficult to separate genetic effects frm develetriental For exacple, the ard teratogenic effects of radiation exposure.
a 1
relatively high incidence of miw@ly cbserved by ABoc in children of survivors of Hircahima N Nagamaki who were in-utero at the time of tna explosions are prttably due to developnental effects but may have a genetic cuw.ent (i.e., danwfa to the ma of critical stam-cells in the l
cubryo). At ctrisiderably lower levels of expcnure (Tbrok, Schmahl, I
Meyer, and Kistner,1979), pregnant mice wars injected with sirgle injecticris of 0.07 mci tritium per g y weight during organageny, the resulting offsprirg displayed a significantly decrmanad weight of brain and genital tract organs. At 4.5 months postpartum the rutmhar of I
r occytes was erkedly ruW and the epithelium of the seminiferous tubulos was in a state of disintegration. Histological eA
- tion revealed retardation of the proceroerhalon ard nukod hypoplasia of the gctwis.
At still lower levels of EWre, experiments at the Harwell Radicbiology Unit (Carr and Nolan,1979) showed a ruduction in the testis mass of the crJuSO folloWiry single injections of tritiated thymidino (1.0-20 uCi tritium /g body mss) or tritiated water (10-40 oci tritiunVg body mss). 'Iho investigators reportal a prooressive loss in mass of up to 30% after 4-5 weeks followed by an irrigular ricovery which in the case of tritiated-thymidine-injected :tice was more delayed.
Calculations arnested that tritium frun tritiated th"midine "fixed" in the testis was about twice as destructive of testis tissue as the roze uniformly distrituted tritium fran tritiated water.
Mien the or.ulative genetic effects fran tritium e>posure of mle mice were studied over several generations a trerri tcward re:hrtion in the
m*Trpalation of offspriry prtpyyated frm snrents exposed to tritiated water or tritiated thymidine was nhnenred (MSWissen and Ugarte, 1979). At cach generatioit male breeders either received a single injecticn of tritiated thymidine ( 1 Ari/g of body weight) or were exposed for five weeks to tritiated drinking water (10 uCi/ml). Matirq stniles showed that, "preinplantation loss values were significantly increased in eqmrimental versus contrul sublines." Dose estimations were 3.7 rada frm tritiated water arri 3.9 rads frm trithted thpaldine.
The discussicn of rouse cocyte studies by n+anr1 and -iates in the affidavit of Dr. Hans Bohling misses the tlate most i@ortant fifriings of the studiest 1. the RBE (relative biological effectiveness) of tritium ccepued to gams radition varicd inversely with doce (at gams ray doces of 40 rad it was 1.6 shi.le at gams ray doces of a few rads the RBE of tritium rises to appruximtaly 3 (Dobscn arxi Kvan,1976);
- 2. a'c 1cvels of only 0.085 uci/ml, "a 1cvel substantially below thoco rtportcx1 previously to cauno naasurable biological etfects in mmsis, a significant decrease was still cbserved " (Wm arri Cocper,1974) arri
- 3. "no evidence of a threshold was fctni" (ibid.). Those results appear to Mye important relevarre to the prrposed release of atrospheric tritium at ihrva Mile Islani.
Unfortuntely, we do not Mve good chta for cxrparity the rouse occyto susceptibility to tritiuu with tMt for humn cocytes.
The increasirn RBE with decreasiry tritiu:n dose my well explain the results rtported for humn leucocytes (Hori and Nakai,1978) for
very law dose exposures to tritium. Cultures of human 1cucocytes were chronically emased for 45 hr to tritiated water and tritiated thymidine over a broad rarge of tritium h.
1he dose response was namanrad by chttnatid breaks per cell. It was found that at a highar dose rarge the yields of chrmatid breaks increased linearly with done, while those at lower dose levels were significantly higher than would be expected by a danward extrapolation frtn the linear mcdel. These results also s
appear to have relevance to the preH tritium evaporation project at Three Mile Island.
Very Icw level duvelcpwntal offocts have been hibed for embryos at the game barmele, Pollicires nolvnerus (Abott and Mix,1979).
Darmele atryos were rearui in media containiry a wide rarge of tritiatal l
water concentrations. Developwntal etfocts were observed at concentrations 4
as icw as 7 x 10
,uci/ml. This level is very close to the ICRP-2 PGC for H-3 (th0) of 5 x 10 A2C1/ml.
I the bicthysicist Li has calculated that the enertJy released by the t
i disintegration of cne tritium t'ucleus located in a chttriascre is I
sufficient to prnha a chrtroscos break, thus one wculd egoct scos gemtic effects at the lowest levels of tritium exposure. Indeed, calculations i
j (Oliver arxi Iajthe,1960) on the decay of a tritium atm within the cell l
rucleus prtdooes a dose of about 170 rad to a sphere of tissue 1 um in diamnter, scno genetic arcralies are relatively turmless ard in razu j
instarcos my to beneficial, but root are harrful arri scrn aru lethsl.
It l
is therefore expected that the prgwM release of atznospheric tritium at I
1 1
l
'Ihree Mile Island will lagd to aces harmful genetic charges in e_W humans and other anialu.
'!he carcinogenic effects of trititan have been studied to a leeser extant than its genetic ard cellular effects; however, enough laboratory ev3denon is available to regani trititan as a confinned carcinogen.
'Ihat trititan can cause increased tumore fonnation in mion has been well 1
demonstrated (lisoc, et al.,1961; haarga, et al.,1962). Upon injection of 1 mci /g of tritiated thymidine, they fourd that significantly more of these experimental animals died frun tuners than did controls.
A Federal Republic of Germny researth team ('I6t6k, et al.,
i j
l 1979) has reported that high levels of tritiated votar (0.27 mci /g) injected into fannle mouse anbryos resulted in high levels of ovarian tianors. In exposed offspring at 18 nonths, there was a five-fold increase in ovarian tmor ircidence crver controls.
l l
Iower level carcinogenic effects of tr.itiated thymidine have been Itported for mice (Mowissen,1970; Hewissen ard Rust,1973).
Tritiated thymidine was injected postnatally at a rarge of 0.3 to 1.5 uCi/g. Experimentals sNwed a statistically significant increase i
(citi-square test at the 0.05 level) in overall tumor incidence than ocaitrol animals. '1he increase in overall tumors was largely attributed to enhanced lyuphonatuxna incidence. No statist',cally significant I
dose-respcrise relationship was found for tumor incidence rates ard the
]
lowest dose was often nore effective than the highest dose in inducirg i
hanns, so there was scue evidence of a paradoxicr.1 effect. 'Ihis effect nny l
be due to inverse relationship between RBE ard doso described earlier for tritiatmi thymidine (M and Wan,1976).
stniles of the impact of tritium en on the imm2ne syste have been rulatively few in relation to the rutar of investigatione of the genetic, cellular, ard carcincgenic etfacts of trititan. Beta rays of tritium were fourd to be more effective than gama rays in causing rh==p s
to the txmo marrow of rats (ntrthner, et al.,1953). Similarly, beta rays of tritium were mre effective than gama rays in producity thymic ard splenic atrophy in the mouse (Worr.su, et al,1954).
When the effects of tritiated water on splenic and thymic atzqhy in the mouse investigated after only five days of exposure (Storer, et al.,1957), a splenic atrghy RIE of 1.32 ard a thymic atrtphy RBE of 1.52 were rtported. However, their data has been corrected (Jchnson, H.A.,1973) for the caission to mrd scre 5% of organically-bound tritium to yield a splenic atrghy RIE of 1.65 ard a thymic atrcphy RIE of 1.90 as upper limits when related to the effects of X-rays and cobalt-60 gama rays. Johnson (ibid.) concluded that the presenc quality factor of 1 for tritium be charged to 2 for estimating the biolcgical risks frta an absorbed dose. He did rot v.onsider the considerable corpus of evidence for a mch higher RIE level when the tritium has been inot.rporated in [NA or one of its precursers such as thymidjne.
A Russian Irscarth team (Moskalev, et al.,1973) frtn the Institute of Bicphysics of the Ministry of Health have investigatal the RIE values of tritium in relation to the gams radiation of cosium-137.
Mwn declines of lygtrcytes (leukopenia) in peripheral blood ard
decreases of thynus ard spleen weights were studied the RBE of tritium mida at acute doses was between 1.45 ard 1.93.,'Ihey attributed the biolcgical damaga of tritium, "to the fact that it develops 10 to 30 tims as grunt ionization density per unit thrm volume as X-or gama radialton."
s
'Ihe declines in the lyrghold systan shown for tritium ap2ru would expected to be a contributing factor in the etiology of radiation intxand cancer for we ).now frun irmunodepressant studies in relation to organ transplantation and frun AIDG ruscarth of the powerful role of the inmune system in protecting the body against the gitwth of cancer foci.
i CDK2DSIOE AND RECOMENDATIQG 1
I l
1.
In the evaporation prcposal at TMI the radioisotope of critical l
concern is tritiu:s bocatce strontium would be canoentrated in the evaporator bottms.
t
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2.
The organs of critical concern are the ganada because of the l
extrvumaly damagirg effw:ts of tritium when localized within or near j
W in the cn11 nucleus of gem-lire cells.
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3.
Genetic nutatico ard cancer induction are two health hazards generally associated with chi alterations, en micrtmacpic ard sutnicroscopic levels, which would be expected to increase in the l
pcquiated areas surruaniirn 'IMI if the evaporation alterrative is chocen.
Gonventional radition dose and carx:er risk stimtes are likely to
undenstimata greatly the autagenic ard carcinogenic effects of tritits because of the extrumaly damaging potential of even one tritium atos disintegratirg within a cell rucleus.
4.
The present gality facxor (1) and MFC levels for trititra far underestimate the potential for biolcgical damm3e of this isotcpe when it tav=== bound to the timaan ard cells of organisms (particularly food-chain organimma) and as:;ocially when it W incorporated into the DR molecule.
5.
I th..ard prtplonged protective storage at the 7hrre Mile Islard site in new tanks in an area bemed to protect frun accidental spillage to the river. The largth of such on-cite storage should be as lorg as passible j
with consideration for tank integrity ard isolation frun the surruniirg pcpulation.
(
Respectfully sutnittal, i
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l l
i Charles W. Huver, Ih.D.
/l,%
d.
O Dated Octcber 10, 1988
IIIUW1URE CITED Akbott, D.T. ard Mix, M.C.
1979. Radiation effects of tritiated sewater on develcpeant of the goose barnacle, rollicines colvmm Health Mrynion, 36: 283.
Baserga, R., Lisco, II. and Kisialski, W.
1962.
Proc. Soc.
Expt. 11101. Mad.,
110: 687.
Osrr, T.E.F. and Nolnn, J.
1979. Tbstis mas loss ig0the m3use ituk'ari by triti'ited thymidine, tritiated water, ard Cb nama irradiaticr. Health Riyaios, 36: 135.
rWwn, R.g. aid Cocper, M.F.
1974. hitium toxicity: effect of Icw-level IDI t-re on develcpirrJ female gern cells in the mouse.
Radiatica Reaanrtti, 58: 91.
Dobson, R. L. and hvan, T.C.
1976. The RBE of tritium radiction naasured in nouse occytes:
increase at icw t-re levels. Radiaticn RoccarW, 66: 615.
fbrdner, J.E., Storer, J.B., and Ictz, V.
1953.
Ios Alamos Sci. Iab. Rtyt., IA-1544.
Hori, T. ard Nakai, S.
1978. Unusual deco-response of chrmuma aberrations irduced in human lyghocytes by very icu dose exposures to tritium. Itztaticn Researd, 50: 101 Huver, c.W., Dixon, G. A., Jarrhmri, N. and Dixon, G.L.J.
1979.
Methodolcrries for the Sttdv of trN-tevel Padiation in the Midest. Anvil Press, pp. 173.
Jchnson, ii. A.
1973. The quality factor for tritium radiation, In Tritium cd. by Moghissi, A. A., ard Carter, M.W., USEPA, p. 231.
Lisco, !!., BasertJa, R., aid Kisieleski, W.E.1961.
Nature, 192: 571.
Mcwissan, D.J.
1970, tumorigenic effects of small amunts of I
radiation.
In Medicn1 Radienuclides: Radiation [tse Effoch Proc.
of Symposium held by Oak Ridge As=~' lated Universities, Tn, USADC
)
TIO, p. 413.
Hewissen. D.J.
1973. 'Itmor incidonoe in C57 black /6 mioo treatal with tritiated thymidine.
In Tritium, ed. by Maghirai, A. A., and l
Carter, M.W., USEPA, p. 252.
Maskalev, Y.I., Shuravlev, V.F., Isotcnim, A.G., Ntrovich, I.K.
and Kazbekova, D.A.
1973. Relative biological effectiveness of tritium. In Tritium. ed. by Moghissi, A. A., and Carter, M.W.,
j USEPA, p. 240.
Oliver, R. aid Iajtha, L.G.
1960. Hazarti of tritium as a decoc(riborucleic acid latul in mn. Nature,185:91.
4
Storer, J.B., Harris, P.E., RIrthner, J.E., and largham, W.H.
1957.
'Ihn relative biolcgical effectiveness of various ionizirq radiations in
- lian systmas. Partidir=1 Ramsartit, 6: 188.
'Dxtk, P., Sctanahl, W., Meyer, I. ard Kistner, G.
1979. Effects of a single injection of tritiated water during organcgeny on the prenatal ard pestnatal develcpnent of mios. IAEA-SM-237/24.
Worinan, F.C.V., 'nzrney, D P. ard Intz, P.
1%4.
Ims Al - Sci.
Imb. Rgt., IA-1641.
t I
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1 i
Third Set of Comments Relative to Trent. ment and Disposal of 2,100,00 Gal of Contaminated Water at TMI-2 by Karl Z. t1 organ September 30,1988 A. Historical-Factors Leading to Conclusion That the Licensee is Not Ccpable of Evaporating the Tt11-2' Contaminated Water in a Safe (1anner
- 1. The Amount of Contantinated Water is Unknown and is Likely to 6
Exceed 2.1x10 gal.
6
- a. Reports have given the amount of this water as 2.1 x 10,
6 6
2.2 x 10 and 2.3 x 10 gal.
- b. From my own expertence in cleanup operations in Oak Ridge, Tenn. I have found the contarr,Inated water almost always exceeds the estimates in spite of efforts to keep it to a minimum
- 2. Ttc Quantity of H-3, the Principal Radionuclide in Terms of Activity (n Cis) to Be Released to the Envlornment, is Unknown and Given Errcalously,
- a. The following values are given.07,0.13,0.19 and 2.14 C1/ mil. This is a range of 30 in the amount of H-3 and in 4
the associated dose to members of the public.
I recognize that it is difficult to make an accurate theoretical estimate of the H-3 present from the(1W-hrs.,
the B in the reactor as a function of time and from information on other stable elements in the primary and secondary water systems but proper sampling techniques certainly should reduce the uncertainty to less than a few
2 percent and not 3,000SI I recognize that although H-3 in the PWR is produced 23S (fission)3 + other f p's,10 +N+
principally by the U
H B
8ge.3 +0.2MeV, I I +N+9Be+3 '+9.6 MeV,10 +N+2J.t 3 H
B H
B H
10 +N -+7L1+N+3H, there are many other reactions and B
2 contributing to H-3 pioduction such as H+N+3H, I 4 +N+
N I 2 + 3, I + N4 H(2 +N+3 ), 6 C
H H
2 H
H 1
Li+Nd+3 +4.69MeV. It is H
for this reason I alw'ays give more credulence to properly conducted sampling rather than to theoretical estimates.
Why such poor sampling?
4 h
- 3. The Quantity of Other Radlonuclides in the Processed Water (Just Before Evaporation) Has Not Been Det,rmined with Suffictent Accuracy.
For Example Sb-125 is given as 6,2x10-7 and(1,1x10-7 l
pC1/mi, Cs-137 as 800x10-0 and 7.6x10'O 4 C1/ml, Co-60 as 32x10-0 and 8.4x10-0 p Cl/ml, Pu239/240 as(3,7x10-0 and i
<1.2xiO'O p Cl/ml, C-14 as 3000x10-7 and 2.3x10-7 p C1/ml, Tc-99 as 25.0x 10-8 and 1.6x10'O p Cl/ml. I consider these uncertaintles as serious. Cs-137 and Co-60 are among the ?) ore Important gamma emitters (external dose) in the evatorator bottoms and the residuals of the 3DS and EPICOR-Il processing before the evaporation so a difference of the Cs-137 dose by a factor of > 100 and of the Co-60 dose by a facMr of 4 is of great consequence in terms of occupatton31 exposure and exposure i
during transportation operations. The Pu risks will be around for hundreds of thousands of years and so a difference by a factor of 3 is very significant. The C-14 is constdered by some experts as a principal environment hazard of nuclear power operations yet
3 the estimates of C-14 dif fer by a factor of 13001 As one of the, scientists who has tried to make nuclear energy and its product nuclear power acceptably safe during the past 45 years, I feel a bit insulted by any organization that suggests uncertainties of the occupational and environmental radiation hazards of the above magnitude should be acceptable.
- 4. Both the Licensee and the NRC Have Lef t a Record That Cast Doubt on Their Sincerity when They State They Give High Priority to Safety and Conformance to ALARA.
The public record of the licensee is well established and need not be elaborated here.
The atitude of the NRC and its senior staff toward radiation safety is exempitfled in a letter I wrote to the chairman of NRC (see Appendix A) which, by the way, was never answered. To me it is incredible that an organization such as the NRC claims its policy is to conform with ALARA while at the same time it blindly accepts recommendations of ICRP to increase levels of maximum permissible air concentration (MPC)a of radionuclides such as H-3 by a factor of 44,20 for C-14,1.5 for Co-60,1.4 for 7
1.7x10 y 1-129,2.1 for I-1315.4 for Cs-137,2.7 for Pu-239, etc and increases values in water (MPC)w such as H-3 by a f actor of 3,2.0 for Co-60,2.0 for I-129,1.7 for l-131,2.0 for Pu-239, etc.
(see Appendix B, Table 3)
Also, I consider it incongruous that the NRC like the ICRP, has not lowered the level of maixumum permissible exposure to external sources of lonizing radiation, MPE by at least a f actor of
- 3. The present MPE and values recommended in BEIR-Ill are based on the risk of radiation Induced cancer as determined by studies
4 of survivors of the atomic bombings of Hiroshima and Nagasaki.
Those doing these studies have recently published papers showing this risk is greater at least by a factor of 3 than previously published values. The British have low'ered their MPE by a f actor of 3 (see Appendix C) with indications additional reductions may f
follow. Why is the NRC stalling?
t The table below gives values of radiation induced cancer.
Comparative Values of Cancer Risk Source Cancers / Person mn by:
Absolute Model Rel?tive Model l
BEIR-1972 1.15x 10-4 5.68x 10-4 UNSCEAR-1977 (0.75-1.75)x 10~4 ICRP-1977
( 1.0- 1.25)x 10~4 i
NRC-1981 1.35x10-4 5.4x 10-4 Recent Japan (4-8)x 10-4 (1.6-3.2)x10-3 Studies-1988 1
- 5. The Licensee Does Not Propose the Use of the Most Recently Developed and Recommended Instrumentation and Environmental Monitoring Procedures in Order to Comply with ALARA.
A number of Improvements in instrumentation, techmques and operating procedures are recommended in the Environmental Monitoring Report prepared by Dr. Ruth Patrick'of the Philadelphia l
Academy of Natural Sciences, Prof. John Palms, Vice Pres. of j
Emory University, et al for the TMI Public Health Fund. Especially l
pertinent are some of sections in Appendix F cf this TMI-PHF report (See Appendix 0). It is unthinkable that the NRC has not 1
considered monitoring of wells and springs. The reader is referred also to a paper by Prof. Jorin M. Palms.I
S
- 6. The GPU Staff and the NRC Do Not Make it Clear Which Waste Water Will Be Treated or If Any Pretreatment is Now Planned.
There are many sources of contaminited water evolving from the TMI-2 cleanup. Because of uncertainties and risk of mistakes, I believe these water sources (other than the sanitary sewer) should not be separated and treated dif ferently - they should all be treated by the SDS and BPICOR-Il system; each of course with the necessary preparltory treatment.
In some responses it is stated the water will be treated by both the SDS and EPICOR-Il systems (e.g. NRC Staf f Response dated Feb.
22,1988, page 4) In other responses, however just the contrary is stated (e.g. GPU ID 0068P, Feb. 3,1987, page I). What are we to believe? I believe the preblem of uncertainty In concentration of the various radionuclides is not with the analysees in most cases but with the extremely poor and definately unacceptalbe method employed by the licensee in providing representative water samples.
r 1
- 7. The NRC Staff Demonstrates a Warped oi Serbusly Distorted Understanding of the Risk from the Transuranic Radionuclides.
l Page 7 of the NRC Staff Response to Interrogatories from TMl/SVA of Feb. 22,1988 states,"However from the i
results of the analysis of PWST-2 (see response 2 above) transuranics make up less than 18 of the total curle I
content of AGW as they do in Table 2.2 of Supplement No. 2 as well."
6 NRC Staff would console us about their lack of sertous consideration of the transuranics in the AGW because on a curie or activity basis they comprise less than 15. To me this is absurd. Essentially all the curies in Table 2.2 (i.e.1020/1021.2 or 99.885) consist of H-3. However the relative cancer risk of Pu-239 to that of H-3 as given by the ratto of the inverses of I
(MPC)a for the two radionuclides is Sx10-6/2x10-12 2,500,000.
[
In other words one would vtant the content (curies) of the trans'iranics to be 0.00004N rather than 15 for the risks to be comparable. Furthermore, there are many publications showing the (MPC)a for Pu-239 is f ar to large.
- 8. The Licensee and NRC Appear Not to Be Giving Serious Consideration to the Modifications l Have Suggested to the Vaporation Method.
See Recommendations dated March 19,1987 and March 2, 1988.
I
- 10. There Has Not Been Provided Convincing Evidence That the Evaporator Method as Proposed Will Provide an Overall Decontamination Factor of 1000.
Problems associated with liquid transfer, spillage, accidents, shut-down, equipment f ailure, sabotage, explosion, reduced ef ficiency, etc. have not been given thorough consideration,
7
- 11. The Need for a Biological Ef fe:tiveness Factor Greater Than l
I for Low Energy Beta Radiation Has Not Been Recognized.
Toward the end of their tracks electrons or beta particles have a very high spectfic tonization or' stopping power, dE/dx, and thus approach alpha and f ast neutron particle values of RBE. The ICRP now sets the RBE of alpha and fast neutrons at 20. Many studies indicate the RBE for low energy beta radiation suchbs that from H-3 and C-14 is greater than I and may be as high as S. In other words, this factor alone would indicate an underestimate of the population dose and the concomitant risks of radiation l
Induced malignancies and genetic defects by a facotr as
[
much as S.
j
- 12. It Is Unrealistic to Assume That C-14, I-129 and Cs-137 Will Be Removed Completely by the Proposed Evaporation System.
i l
This must be proven by experiments which have never been done and one must not rely on theory.
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- 13. The Evaporation System of 1/5 gal / min would Take 319 4
Days of Continuous Operation with No Shut Down and j
Perfect Operation.
This is too long to hold a tiger by the f aill Actually the operation probably would take over 2 years under the most i
favorable circumstances. With the modifications I have 1
suggested, it would take much longer.
- 14. Neither the Licensee Nor the NRC Seem to Know What the
4 8
Natural i3ackground Radiation is in the Local Area.
The Licensee gives the background as 300 mrem / year and l
the NRC gives it as 178 mrem / year This is the starting point in determining tne added radiation risk and accurate values must be provided area-wide for this.
This information is essential for those writing the last chapter and the conclusion of Who Done Itl 4
i
- 15. The Licensee and the NRC Have Consistantly Underestimated Both the Occupational and Public Radiation Dose and Risk of Radiatton Induced Malignancies and of Genetic Defects.
See my comments dated March 19,1987 and March 1988 and Appendices B and C.
It should be appreciated that since both H-3 and C-14 2
deposit in the gonar and in DNA and RNA, they are a genetic risk to children yet to be born a thousand years 3
3 from now. Because of the reactions H+/b He and I4+p+I4N, one of the 46 chromosomes in a germ cell of a homo C
sapien can end up suddenly with a hydrogen atom replaced by a helium atom of gas or a carbon atom may be replaced 4
i l
by a nitrogen atom.
B. Present Opinion Regarding Disposal of Contaminated Water at i
)
TMI-2 Because of the above and other facts I have concluded that all plans for i
the evaporation procedure should be abandoned. I believe, as Indicated above, that all the contaminated water should be treated by the SDS and j
EPICOR-il Systems following appropriate pretreatment. The solid or l
slurry residue from these treatments should be sized, mixed with j
l
9 cement in 55 gal, drums and sent to a licensed burial ground, e.g.
Hanford. The contami,nated water should be placed temporarily in large holding tanks. Other pretreatmonts, Ion exchange chemical steps and better systems that are ef fective in removin'g stable boron and more of l
the radionuclides should be investigated and applied where feasible.
The holding tanks should be so installed and located that any leakage is known with absolute certainty to drain into a sampling sump tank.
Great care must be taken to prevent any explosive materials entering the tanks via sabotage or otherwise. Under no conditi0ns should cement, solidifying or coagulating materials be placed in these tanks. It is likely plans will be undertaken to remove this contaminated water at a later date and we do not wish to be confronted then with protslems such as those that stalled and daunted operations at West Valley.
l C. Recommended Future Course of Action 6
i Ultimately, it will be desirable to drain the tanks of the 2.tx10 plus gallons of contaminated water. Most of the activity (curles)in the l
tanks will be that of H-3. Various estimates of the H-3 activity are i
provided us but if the Initial level is 1000 Cl, the drop of f in time of H,
3 Cs-137, Sr-90 and Pu-239 will be as follows, l
TimeM H-3 C1 Cs-137Cf Sr-90C1 Pu-239u Cl 0
1000 0.03 0.08 300 1
945 0.029 0.078.
300 10 568 0.028 0.062 300 30 184 0.015 0.038 300 i
50 59 0.009 0.023 300 100 3.5 0.003 0.007 299 200 0.012 0.0003 0.0005 298 (0.000298 Ci) I j
300 0.00004 0.00005 0.00004 297 (0.000297 Cl) r i
20,000
~0
-0
-0 169 i
100,000
~0
-0
~0 18 i
- -_--._. ~.-,.-_ - -._ _. - - _,_
10 4
Since most of the initial activity is that of H-3 (HL-12.262 y),
the above column 2 represents the total activity in the tanks as
]
well as that of H-3 until about 300 years when the CS-137, Sr-90 l
and H-3 activities are all about equal. Af ter 200 years the Pu-239 activity is about equal to that of Cs-137 and Sr-90. The t
Pu-239 activity predominates and is significant af ter 20,000 l
years when it consists of 127,000 maxiumu permissible body burdens for a member of the public (i.e. 0.0013 p Cl).
j Many f actors and circumstances will determine how long the contaminated water should :
- main in the tanks. It would seem to me, however,30 years might be reasonable. With proper adjustment of ph the tanks should not leak in this time while the l
activity of H-3 will have dropped to 18AM and that of Cs-137 and 1
j Sr-90 to about SOR. If over this time a S000 gal. tank gave Indication of leakage its contents could be mixed with concrete as it is emptied into about 100 SS gal. drums and then shipped to a state operated medium level repository.
l
]
D. Concluding Comment I appreciate very much the vable of having an Atomic Safety l
and Licensing Board, ASLB, and for several years I served on a NRC committee to recommend memberships on these ASLB's. For the most part i believe members of these Boards strive to be impartial but l
)
in many cases they have a confilet of interest and I believe the i
i selection process should be modified to minimize this confilet. It i
j would seem that membership on these Boards should reflect as equally i
as possible the views and goals of the public living near the nuclear power plant as well as views of the nuclear utility. I am not convinced l
that this is always the case.
J
I1 On another point, I believe the method of financing the /,SLB hearings should be improved. Members of ASLB and their consultants and the NRC staff are paid by the NRC and there should be some arrang? ment by which members of the public and their organizations that contest plans of the utility that affect them can be paid a fee and have coverage of their expenses. Some years ago (just a few days before I had to rush home to testify before Senator Kennedy in a Congressional hearing regarding consequences of the TMI-2 accident) I testified in the Gorlieben Hearings against a proposed method of the i
West Germans to dispose of radioactive waste in dome salt. It was my i
impression that both sides of this controversay were financed by the W.
]
German government. Why can't we in the U.S. be as democratic as the W.
Germans? Because I know we have no such system in the U.S. and some members and organizations of the local community are striving so nobly i
for their Constitutional rights I have not asked to be paid and will not request payment for many days I have spent in preparation for these I
hearings; this in spite of the fact my sole business and livelihood is that of consulting in health physics and defending in our courts plaintif fs who have evidence of injury from excessive exposure to l
lonizing radiation.
This is not a criticism of the present ASLB but a plea that the NRC will try to make this process more democratic and f air to the heroic members of the public that try to make this democratic process a useful and successful operation even though most of l
those in this community and in other communities where I have Intervened relative to nuclear utility proposals believe there is i
much room for improvement of this process.
I l
j
Reference:
John M. Palms, B.G. Wahlig, D.M. Walker, PtR. Ghave, i
12 "Problems Associated with Routine In-Plant Radioactive Effluent Monitoring Systems at U,.S. Light-Water Reactors." Accepted for publication in# Nuclear Safety."
Respectfully Sut>mitted
/W. W Karl Z Morgan
7,:
APPENDIX A e
1984 Castleway Drive Attenta, GA 30345 May 4, 1983 Mr. Lando W. Zech, Jr., Chairman U.S. Nuclear Regulatory Commission 1 White Fitnt North 11155 Rockvilla Pike Rockville, MD 20802
Dear Mr. Zech:
During the period of April 10-19, 1988 I attended meetings in Sydney, Australia or three organizations, the International Radiation Protection Associ.
ation (IRPA), the International Connireion on Radiological Protection (ICRP) and the If,ternational Atomic Energy Agency (IAEA). At these nestings Mr. R. E.
Alexander of your organization gave a paper with which I strongly disagree. The pctncipal focus of his paper was that he and his staff were reconnending to you that the NRC not follow the lead of the V4 by re,ducing the maximum permissible i
exposure (MPE) for occupational workers by 1/3, i.e. from 3 rem /y to 1.5 rem /y.
He proposed that the NRC mimic the ICRP and count more bodies before reducing the HPE.
i i
I was one of the 13 members of ICRP for over 20 years and now am one of its 4 emeritus members but have been strongly in opposition to two of its recent moves:
- 1) to increase levels of maximum permissible concentration (HPC) of radionuclides in air, wate; and food at a cima when the changes should have been in the opposite direction because the risk of radiation induced carcinoma is now known to be much grotter than we thought it to be when ICRP-2 was published in
- 959 and 2) at its 1987 meeting in Como, Italy ICRP acknowledged that its esti.
mate of risk of radiation induced fatal cancer, o = 1.25 por 10,000 person. rem, was too low in light of recent publications of the RERP Japanese research group 1
doing studies on survivors of the atomic boubings of Hiroshima and Nagasaki but failed to act..
As you know, the recommanded values of HPE as given by ICRP and applied by the NRC are based on values of a as determined by the Japanese studies.
Prior to the Como meeting of ICRP a petition signed by over 800 scientists (including myself) from 16 countries requested the ICRP to reduce the HPE level.
)
In response the ICRP acknowledged that "Under the new DS.86 dosimetry this in rease in risk is reported as being by a factor' of about 1.4" and that longer 4
l follow-up "and %ther factors cited in the paper (D.L. Preston and D. A. Pierce of RERF) raise the risk estimate for the exposed population by a further factor of the order of 2."
The product of these two factors is about 3.
To me it was incredible and amazing that in spite of this recognition of fact the ICRP con.
cluded, 'This information alone is not sufficient to warrant an immediate change j
in the dose limits."
Fortunately for the workers in the'UK tha National Radiological Protection
~
Board took appropriate action to proteet its radiation workers in November 1987 (NRPB.GS9) and ruled "Conssquently, the Board recommends that the occupational 4
4 i
.,,,.---w.,,
7
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/.
Mr. Lando W. Zech, Jr., Chairman Iby 4, 1983 Page 2 workers exposure should be so controlled as not to exceed an average effective dose equivalent of 15 mSv per year (1.5 rem /y). " This reduction by a factor of 3 has been taken as.an initial step with the understanding that additional' re-doe *4ans nrnkskly vill be requi- ' hcn the reevoluation of the Japaneses data is completed. The need for an additional reduction seems eminent because Preston and Pierce using a linear dese-effect codel arrive at e radiation cancer risk of e = 16 fatal cancers per 10,000 person. rem or (1.25/16) x 5 rem /y = 0.39 rem /y or a reduction by a factor of 12.8 instead of a factor of 3.
Regarding the first move of ICRP to which I have objected (mentioned above),
I enclose a copy of a table which T rave in a lecture in London.last year and which was puulished in the book Radiation and Health by Jones and Southwood, John Wiley 6 Sons.
This table emphasizes the appalling fact that when ICRP pub-11shed ICRP-26 (1977) and ICRP-30 (1979) it increased rather than decreased the HPC values for a number of the radionuclides of major concern to the NRC such as Sr-90, C-14, Co 60,1-131 and Pu-239.
I was chairman of the original Internal Dose Committees of both ICRP and NCRP for over 20 years and this was during the time when ICRP-2 was published. This ICRP-2 is the basis of NRC limits set in its formar Title 10 Part 20 regulations which were in use by the NRC for over two decades.
I testified before the ACRS in opposition to the NRC moving in the wrong direction and using the ICRP as a template in revising its values of HPC and was under the impression that Mr. Alexander sided with me on this issue, but apparently I was mistaken--politics and appeasement of those in the nuclear in-dustry rather than a lower cancer risk are more important.
Incidentally, as one of the five first health physicists (there are 20,000 in the verld today), as the director of the Health Physics Division of ORNL for 29 years and as the first president of both the Health Physics Society and the IRPA, I still am in favor of the proper use and development of nuclear energy but not at any cost.
I ap-plauded the NRC when it set the value of I rem at $1,000 or the value of a hume.n life at $10,000.000 (i.e. $1,000 + 1 f atal cancers per 10.000 person rem =
$10,000,000 per fatal cancer).
Now, however, with e = 10-3, $1,000 per person rem corresponds to only $1,000.000 per human life.
Is this an appropriate eval-uation? I believe we could have this industry without coverups and half truths; I believe that some of the nuclear power plants have an excellent operating record and should be commended and encouraged to further improvements while others have a miserable record of safety and acceptable operational history and should have been shut down and decomnissioned permanently.
I hope in the years to come a major portion'of'the interest and effort of NRC will be in the development of inherently safe. nuclear power plants--only then will vc have no more Chernobyls and can we exp'ect more orders in the US for new nuclear power plants. Many persons balk at the nuclest vaste proolem and believe it is insoluble but as the director of the ORNL HP division that conducted the studies on disposal of high level nuclear vaste in the ransas bedded salt formations, I believe this problem can be solved but only by a hard nose policy and programs and not by depreciating the risk of radiation induced cancer and failure to acknowledge facts.
Since I lef t ORNL in 1972, the radiation waste disposal program has languished and is trying to reinvent the wheel.'
7 There are many reasons why the cancer risk is, greater than that given in BEIR-III & IV.
I enclose also a few additional pages from the above references.
O Mr. Lando W. Zech, Jr., Chairman May 4, 1988 Pago 3 In this I give some of these reasons. Also, we must recognize as concluded by an export committee of the CAO (Report to the Congress of the United States, Prob 1 cms in Assessing the Cancer Risks of Low Level Ionizing Radiation Exposure Vol. 2, EMD-81-1, Jan, 2,1982) that at low doses the supra linear relationship fits the data better than the linear function and for this reason alone we should be cautious in avoiding all unnecessary exposure and follow the ALARA principic. The weak arguments given by Mr. Alexander for not reducing the MPE
-- -.. 41 %1a **.. u so I do not cnumerate them heto.
They wane into insignifi.
cance in relation to these other f acts, some of thich I have provided you.
I havo testified in the House and the Senate many times and when the issue came up of uranium minerssvorking at Rn-222 levels equal to and higher than those in the cobalt mines of Schueeberg and Saxer., and Joachimschal of Bohemia in 1500, I did what I could to reduce these exp.. ore icvels but it was like holler.
ing in the wind. I was frustrated when the USPHS and the FR0 sided with the AEC and they offered congressional testimony to try to negate that which I offered.
I had been naive in believing the USPH Service was operated to protect the health of people in the U.S.
I was not surprised that the AEC sided with ',ndus.
try. However, I rejoiced in that an ho.est man finally turned up in Washington.
Mr. Wirtz, Secretary of Labor, came to che rescue of the dying uranium miners.
Following my testimony before the Department of Labor he unilaterally reduced the level I had recommended to 4 WLM/y (~ 3 x 10-8 pCi/cc of Rn 222). I often wonder how Democracy survives in a society where money and social and political stature are all important but now I know.
It takes only one honest uan under the right circumstances to make Democracy work.
I bope and pray in this instance 1
I am not disappotried In conclusion ; will be most grateful if you provide the other Commission members with a copy of this letter.
Thoro will be no need to have Mr. Alexander respond to this lettet becaust I have already heard him expound his vie 0s on this subject. Also, I wish in no wise to deride or berate him; everyone should have a right to express his views and establish his position on an issue of public concern.
In this case, of course, you are the one to evaluate these opinions and make the decision.
I trust it will be in f avor of the radiation workers.
Respectfully spbmitted.
1 l
Si
- erely, Y
t K(1
. Morgan 7
KZM:1sg Enclosures
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