ML20196B509

Valley Alliance/Tmi Alert Response to Licensee Motion or Summary Disposition on Contentions 1-4,5d,6 & 8.* Affidavits of Kz Morgan,R Piccioni,L Kosarek & C Huver & Supporting Documentation Encl

ML20196B509
Person / Time
Site:	Three Mile Island
Issue date:	06/20/1988
From:	SUSQUEHANNA VALLEY ALLIANCE, LANCASTER, PA, THREE MILE ISLAND ALERT
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20196B518	List: ML20196B509 ML20196B527 ML20196B532
References
CON-#288-6609 OLA, NUDOCS 8806300285
Download: ML20196B509 (69)

Text

m f0b0 June 20, 19%@CKEif 0 U5HPC UNITED STATES OF AMERICA .

NUCLEAR REGULATORY COMMISSION ' 28 JN 27 P5 :35 0F'!CE u H 5 iii' BEFORE THE ATOMIC SAFETY AND LICENSING BOARDI10CKEhld A VMfI-BRANOi In the Matter of )

)

GPU NUCLEAR CORPORATION ) Docket No. 50-320-OLA

) (Disposal of Accident-(Three Mile Island-Nuclear ) Generated Water)

Station, Unit 2) )

SVA/TMI A 'S RESPONSE TO LICENSEE 'S MOTION FOR

SUMMARY

DISPOSITION ON CONTENTIONS 1, 2, 3, 4., 5d, 6 AND 8 SVA/TMIA, Joint Intervenors (JI), hereby respond to Licensee's motion for Summary Disposition on JI's Contentions 1, 2, 3, 4b, 5d, 6, and 8. None of these contentions warrants dismissal as alleged by the Licensee. JI's submitted statements L

constituting genuine issues of fact with regard to each contention, in support thereof.

This response is based upon discovery material received by l

JI, as well as Licensee and NRC documents and their references, which can be found in the public document room. Additional materials referenced in all documents listed in all JI's Responses to Interrogatories were sought and procured from local libraries, the Library of Congress and private individuals.

8806300285 880620 PDR ADOCK 05000320 G PDR 35o3

JI's also include with this response, af fidavits f rom the following experts: Dr. Karl Z. Morgan, Dr. Richard Piccioni, Louis Kosarek and Dr. Charles Huver. Information will be provided in this response which provides genuine material issues of fact requiring adjudication of the above referenced SVA/TMIA contentions.

FUIE:

Due to Dr Piccioni's busy schedule,JI has not received his affadavit,as expected. It is hoped that it will arrive in the next few days. khen received it will be prctnptly mailed to all of the parties on the Service List.

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SVA/TMIA STATEMENTS OF MATERIAL FACTS AS TO WilICll TilERE ARE GENUINE ISSUES TO BE IIEARD CONTENTION 1 Contention 1 is as follows:

Neither the Licensee nor the Nuclear Regulatory Commission has shown that the dis-posal of the accident generated water by an evaporator method complies with the A.L.A.R.A.

principle (as low as reasonably achievable).

Other methods of water disposal discussed in the Environmental Impact Statement (EIS)

(NUREG 0683 Supplement #2, June 1987) would not release all the tritium and a quantity of radionuclides into the environment as the -

evaporation method would.

A. It is required that the Licensee and the NRC show that the disposal of the accident generated water (AGW) by evaporation complies with the A.L.A.R.A. principle for the following reasons:

1. The A.L.A.R.A. principle is incorporated into a Licensee provision in the TMI-2 operating License, DPR-73, P. 3, Paragraph C.

2. The A.L.A.R.A. principle requires that the, "Licensee should make every reasonable ef' fort to maintain radiation exposures and releases of radiation as low as reasonably achievable." 10 CFR 20.1.

3. The A.L.A.R.A. principle recognizes that there is no safe dose of radiation. It is an attempt to balance the risks and benefits associated with nuclear power.

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4. Id CFR 50 inppendix I sets the mandatory limits for any releases of radioactivity to the environment and provides the design obiectiv_e.4 for any method of disposal of radioactive wastes.

5. The t1RC, ir> recognizing the regulatory responsibilities toward

- the public throughout the clean-up at TMI Unit 2, declared its intent to maintain the following regulatory objectives:

(b) Assure that environmental impacts are minimized, and that radiation exposures to workers, to the public and to the environment are within regulatory limits and are as low as reasonably achievable.

(emphasis added)

Nureg 0683, volume. 1 EIS, March 1981, P. 1-17, Section 1.6 Lines 16-18.

6. Modifications to TMI Unit-2 's license were made to' assure that the clean-up operation would provide a wide margin of public safety. In proposing new criteria for radioactive effluents from decontamination activities the NRC stated:

The TMI 2 Technical Specifications wili be supplemented to require that radioactive effluents from the cl.ean-up and decontamination operation of TM1 2 be limited so that the numerical design objectives of Appendix I to 10 CFR 50 will not be exceeded. Additionally, the Licensee will be required to maintain radioactive effluents as far below the Appendix I objectives as practicable.

(emphasis added)

Nureg 0683, Volume 1, EIS, March 1981, P. I-26, Section 1.6.3.2, Lines 16-21.

7. The t1RC recognized the difficulty in applying strict minimal guidelines to decontamination' activities. They stated that:

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, . - . . . - . - - , c,. - . . . . - - . . - . . . . . - - .

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.' lSince there is much less experience in large' scale. decontamination a'ctivities

-there is little basis on which to -

- establish numerical. design objectives.

Nureg 0683,. Volume 1, EIS, March 1981, P. 1-26, 1 .- 6 . 3 . 2 , Lines 36-37.

B.'The Licensee and the NRC did not show that the evaporation-

method-complies with-the A.L.A.R.A. principle.

. l. A.~L. A.R'.A. is defined in 10 CFR 20.1 (C) to mean:

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'a s low ~as is reasonably achievable taking into account the state of technology, the economics of' improvements in relation to benefits to the public health and safety, and other societal and socioeconomic considerations, and in relation to the utilization of atomic energy in the public interest.

Each of these aspects is looked at i n relatien ~ to the chomii tv1 of [

an alternative to dispose of AGW. -

a. State of technology - technology offers a variety.of alternatives to dispose of the water e.g. storage, solidification, and removal from the site,.(Nureg 0683, Supplement #2). .

Technology also provides a variety of evaporation alternatives (see K Z. Morgan affidavit, Exhibit A). He states that the evaporation system could be modified, "to greatly reduce the radiation hazards at a relatively low cost." (Page 6) (See also Exhibit B - K.Z. Morgan's Statement on the Draft Supplement Nureg 0693, Supplement #2).

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- bo The economics of improvements in relation to benefits to the public health and safety.

The radiation dose and the risks associated with other alternatives are less than those associated with the evapoi a t i m a nd-method do not cost unreasonable amounts of money.

A (See Nureg 0683, Supplement #2, Table 5.1, P.S.2; Table 5.2, P. 5.9 and Table 5.3 P. 5.11.)

c. Societal and socioeconouie considerations - the local population have shown resistance to the evaporation proposal.

No member of the public came forward at any of the Citizens Advisory Panel meetings to show approval of the evaporation proposal. All who spoke opposed this method. The members of the Panel voted 5-4 against the proposal.

Socioeconomic considerations of any method are difficult to assess in light of the fact that jobs at TMI Unit 2 will be lost as the cleanup is to be postponed and Unit 2 put into a phase known as Post-Defueling Monitored Storage (PDMS). The psychological effects of evaporating 2.3 million gallons of radioactive water on the popul'ation and tourists could be considerable, but have not been evaluated.

The proposal, as set torth by the Licensee and as discussed by the NRC in Nureg 0683, demonstrates that disposal of the AGW by evaporation is not in compliance with the A.L.A.R.A. principle.

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Therefore, when all- of these aspects of ALARA are considered, the evaporation proposal does not present advantages over an', of tha other alternatives.

C. The A.L.A.R.A. standard is not repealed M NEPA.

NEPA advocates a balancing of the proposed actions against not one but all of the significant environmental impacts and costs.

Meanwhile, A.L.A.R.A. is based on the principle of reducing radiological exposure to the population and other considerations are secondary.

Economic and social impacts occupy lesser tier of importance in EIS than do purely environmental or ecological concerns.

NEPA is nrt meant to supersede A.L.A.R.A. as stated below:

Where clear and unavoidable conflict in statutory exists, NEPA must give way, since it was not intended to repeal by implicatien any other statute.

Flint Ridge Development Company v. Scenic Rivers Association (1976) 426 US 776, 49L Ed 2d 205, 96 S4 2430, reh den 429 US 875 50 L E4 2d 159, 97S G 198, 97S, Glu9.

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-D. Compliance with 10 CFR 50 Appendix I is not sufficient to show that the A.L.A.R.A. principl' las been met for the followi1g l

reasons:

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1. All of those reasons stated in A.

2. The case referred to by Licensee on P.16, Licensee 's Motion for Summary Disposition, applies to a normal reactor and predates the TMI accident of 1979. TM1 Unit 2 is not an operating reactor with a concomitant benefit of alectricity production which would offset the risk derived from the disposal of AGW.

3. Porthermcro, the Licensee can not show compliance with the A.L.A.R.A. requirements of 10 CFR 50 Appendix I.

See Affidavit, Dr. K.Z. Morgan Exhibit A ar.d B.

See Affidavit, Louis Kosarek Exhibit C, F.12-13.

(This issue will be addressed later in the document).

The above discussion provides material facts which warrant adjudication of Contention 1.

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CCEEtTfION 2

, Contention 2 is as follows:

he EIS fails to ecmply with the requirements of the National Environmental Policy Act. De NRC and GPU failed to conduct conclusive risk / benefit analysis of the "No Action Alternative". The EIS has not clearly demonstrated that any adverse impact frcxn the disposal arogra:r are cutweighed by its benefits to the public. %e benefits have not been clarified except the NRC says disposal Ls a fundamental element of the clean-up. This would appear to be a benefit to the Licensee and the NRC,but not to the public.

1. The NRC is required by NEPA to provide a detailed and infonnative analysis of all alternatives. NEPA states that an EIS nust, provide a detailed thoughtful analysis from adequate data so that a reviewing body can decide on an objective basis.

Pilgrim, Supra, AIAB

2. The NPC is rqquired by NEPA in the consideration of alternatiyes to go beyond nure assertions and indicate basis for

' conclusions regarding alternatives.

3. The NRC is required by NEPA to ,

identify costs associated with appropriate actions so as not to prematurely close options which have

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less detrimental effect.

4. Table 5.2,Nureg 0683, Supplement #2, attempts to present a table of ccmparison of the various alternatives for the disposal of the water.

The table however, prevents a careful ccmparison of the alternatives in light of the following facts:

a) Whereas all the other alternatives are provided a definite figure for long term ccumitted space,the ecmnitted space for the no action-l alternative is labelled "small". This provides inadequate infonnation i

upon which to base a decision about the various alternatives, b) In the column"elapsed time for ccmpletion le time period alloted for each alternative provides a very wide range. -

e-The same com1tmn for the "no action alternative" states "0". Again it is-difficult to make acomparison in order to nake an inforned decision

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- about the alternativas. .

5. The "no action alternative" has always referred to the interim -

moaitored storage of_ the water. (Nureg 0683, Supplement 12,) The period of storage has not been specified. The NRC has assmed that at some time

- in the future the water would be disposed of in sme way. Strictly speaking then this is not the "no action alternative". However, sinc 6.the NRC believe

- this t6 be the l'no action alternative','it would have been more conclusive to analyse the dose frm radiation exposure and the risks involved at different times in .the future,taking into account the possibilities of nore advance technologies and the existence of low level waste sites closer to TMI in Pennsylvania.

6. The NRC does not provide a detailed analysis of the location of the tanH which would store the water during the storage period. ,

7. The NRC did not provide an analysis of radiation exposure to either the workers or the public. They did not provide a basis for thsir findings e

that worker and public exposure would be zero. (Table 5.2,Nureg 0683,Supp.2)

The text reads that both occupational and public exposure are not expected to be significant. This is very ambiguous ~ and provides further examples of the NRC's lack of detailed infonnation in evaluating alternatives.

(Unreg 06S3,Supp1 ment #2,P.3.33,3.5.1.2)

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8.- We NRC did not provide adequate de~ tail of the mnitoring which_ would be carried out during the storage of the AGW.

(Nureg 0683, supplement 12,Section 3.5)'

9.TheNRCdismissedthd"noactionalternative"becauseitisagainst NRC policy to leave waste on site. However,in. light of the shortage of -

space for low level waste in this country,the NRC has made arrangements for utilities to store waste on-site.

(Generic Intter 81-83, November 10,1981)

10. All alternatives for dispoal of the water have either regulatory obstacles or strong govermental and public feelings against them(evaporation and releasing the water iinto the Susquehanna). There? ore,it is not logical for the "no-action alternative" to be dismissed by the NRC.

11. W e NRC is required by NEPA to mitigate adverse impacts of a proposed project. %e "no-action alternative" mitigates the adverse impacts of the evaporation of the AGW.

(NEPA 42USCS, 4321-4347)

12. The benefits derived fran the "no-action alternative" nust be seen in the light of the costs and risks of taking action. As will be shown throughtout SVA/IMIA response to Lic?.nscee's request for Sc very Disposition, the costs and risks of taking action have been underestimated.

1 (Affadavits A,B,C,D,E) -

In light of the inadequacy of the data,the IEC's consideration of the "no action alternative" can not be considered conclusive.

13.- The NRC failed to give adequate discussion and evaluatica to Boron as

'recomtrended by EPA. Presently th'e Licensee does not have a pennit which limits the amount of boron to b6 released to the river. In light of the possible adverse affects on crops caused by use of the water fran the l< -

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Susquehanna for irrigation,and the possible adverse effects frm drinking the borated water frm the Susquehanna River,the State of Pennsylvania could conceivably restrict the release of boron to levels not achievable by the Licensee. This fact may limit the Licensee's options for disposal alternatives and heightens the need for full consideration of the"no-action

. alternative" Studies showing the adverse affects of boron include:

a) "Uptake and Distribution of Boron in Rats': Interaction with Ethanol and -

Hexobarbital in the Brain",. Magour,S. et al. Envir.Contam.& Toxicology.

11,521-525.

b) "Boron Deficiency and Toxicity Symptons for Several Crops as related to Tissue Boron levels",Gupta,U.C. Journal of Plant Nutrition,6(5) 387-395(1983) c) Boron Toxicity and Deficiency: A Review, Gupta U.C et al , Canadian Journal of Soil Science, August 1985,Vol 65,#3 For the above rearons Contention 2 should be admitted for adjudication.

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-9(a)

CONTE?TTION 3

. Conterition 3 is as follows:

. -The EIS fails to comply with the requirements of the National Enviromental Policy Act. The EIS has not demonstrated that the benefits of evaporation process will exceed the costs and risks to the public. The benefits are unclear whereas the risks include the following:

a)The release of radioactivity into the air will enter the water, food chain, human organisms and the entire ecosystem.

b)A solidification of possibly 88,000 cubic feet will be created. This waste will have to be trucked to a low level waste site.

1. NEPA states that, EIS is to provide decision maker with detailed and careful analysis of relative enviromental merits and demerits of proposed action.

Britt v USA Army Corps of Engineers 1985 CA 2 NY 769 F 2d 84.

2. NEPA places obligations on '.ne NRC to provide the pub'ic with information on envirornental impact of proposed aroject as well as encourage public participation 2 develop ent of that information.

Trout Unlimited v Morton 1974 CA 9 Idaho 509 F 2d 1276

3. In order to understand the benefits of an action the public nust be provided with:

j a) a clear statement of the merits of the action b) a clear statement of the demerits of the acticn l

These provisions .re recognised by NEPA as stated ebove.

4. The NRC has rot provided a clear statement of the costs and risks of the evaporation of the AGW. The reasons are as follows: ,

i) The efficiency of the evaporator to decontaminate the water to acceptable environTental levels and ecmpliance with the Licensee's Technical Specifications is dependent on a decontamination factor of 1000.

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(NRC Responses to Interrogatories,2-22-88, Interrogatory 22)

(Preliminary System Description 2.16.88,P18 Table 3-2)

As stated in Affadavit, Exhibit C fran Louis Kosarek,the assumption of a decontamination factor of 1000 is based on data for water with a different chemistry and is therefore not valid.- ,

ii)he NRC has not provided an independent and objective characterization of the AGW. _ 2e NRC analysed a 4 liter sample drawn fran one of the 25 locations for the storage of the AGW. Le tank from which the sample was drawn contains one fifth of the total inventory of water.

(Intter D.J. Collins to W. Travers,7-21-88).

iii)The NRC responded in Interrogatory 2,2.22.83 that the sample procedure follomd the procedures outlined in 4212-CHM-3011.05, Revision 0,5.23.84 he NRC did not indicate that sampling procedures were in accordance with ASIM Method 3370 ,which is a national standard stipulating procedures for testing nuclear materials.

iv) he radioisotope of most abundance in the water is tritium. Hcuever, in procuring and preparing their sample the NRC did not follcs procedures outlined in Procedures 4212-CHM-3013,81-P 5.0,6.1.7. These cre more recent procedures (10.27.87) for the"Determination of Tritium by Liquid Scintillation Counting" (document provided in Discovery).

The difficulties in acquiring an accurate assessment of tritium concentration are culined in the coeurent referred to in (iv) and also in "A Radiation Monitoring System for Nuclear Power Plants" Appendix F (A Study undertaken by Dr Ruth Patrick and associates and funded by the Public Health Fund and referenced )

v) Document 4212-CHM-3013,81-P5.0,6.1.7 also outlines the amint of samsle required to be analysed for an accurate count of tritium. The sample analysed by RESL for NRC was 10ml,an amount far in excess of that reconnnnded.

(RESL Sapp'.e Record Sheet, Serial #142668)

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vi) ne analysis of the PWST 2 sample by RESL for the BBC shows trajor differences with the results of analysis of the sa:m sample undertaken by the Licensee. %ese differences are heightened by the fact that the AGW amounts to 2.3 million gallons.

Licensee analysis RESL analysis -

Uci/ml Uci/ml Co 60 2.8 E-7 3.2 E-7 Cs 137 7.0 E-6 8.0 E-6 Sr 90 5.8 E-5 2.55E-5 vii) the analysis of the PWST 2 sample by RESL and the Licensee did not detect C-14 Homver,this radisotope was detected by the Westinghouse analysis.

(Harner Affadavit P.4) C-14 was found at a concentration of 3.0 E-4 Bis should be ccn: pared with Nureg 0683,Supplerent #2, Table 2.2 where the average concentration is 1.0 E-4. C-14 was also found in samples of the reactor coolant (TP0/mI-122 "Reactor Coolant System Sample Results,P.63) viii) he NRC assumes that the average concentrations of radionuclides as shown in Table 2.2,Nureg 0683, Supplement #2 can be reasonably considered a mxinum. (Response to Interrogatory 12,2.22.88) h is is an inaccurate assumption. It i.e upon this assumption that the NRC bases its dose calculations to the public.

ix) he Epicor/SDS processing systems do not provide a unifonn cuneentration of each radionuclide for each storage location. Bis is shcron clearly in"SDS Processing Batch Data"and"Epicor Processing Suranaries"provided in Discovery. Ebrthenmre the Epicor /SDS systems do not have an infinite decentamination factor.

Mr Hofstetter: Bat basically sodium borate tends to minimize the infinite DF cf that,(Epicor),that you might get if you were processing out of demineralized water.

(Transcript Citizens Advisory Panel for the Decontamination of Unit 2. 2.26.87)

x) The NRC's assumption that the average concentration of radionuclides shown

. in Tabic 2.2,Nureg 0683, Supplement #2 is inaccurate. For example.khile the average concentration of Tritium in the Table 2.2 is 1.3 E-i Uci/nn,the concentration of tritium in the storage location,PWST 2,as of 11-07-86 is 2.1 Uci/ml.

(Technical Specification for Processed Water Disposal 12.4.86. P.43(7.3) xi) Tne total inventory of radionuclides in the AGW has continued to change since submittal of the GPU Proposal. The passage of time does not mean a reduction in the source tem for the AGW. (Reactor Coolant Sample Pasults TP0/TMI-122 P.31 which shows the source tem for AGW on 3.7.86(date' sample drawn for GPU Proposal, Table 2-3) and on days. following this sample procurement Although the radionuclide concentration in Table 2-3 accurately depicts the total radioactivity in the AGW the specific source location for this inventory at a particular point in time is dependent on plant operations and does not alter the actual source term.

(Licensee Response to Interrogatories,3.30.88 #10)

Since the Epicor/SDS do not provide uniform concentrations of radionuclides in each source,this is not an accurate statement. Furthermore,as will be shom in discussion of Contentions 4 and 6,the efficency of these two processing systems is not guaranteed as the chemistry of the water changes.

xii) The changing source tem of the AGW is particularly relevant to Tritium.

The data upon which the NRC relied to calculate the source ~ term of tritium was PEIS, March 1981,RESL sample analysis of a 41. iter sample and data from the Licensee.

(NRC Interrogatory Response 13,2.22.88)

Tha source tem data upon which the Licensae relied to make calculations for tr!. tium include PEIS,1981, EGG-PBS-679843,161 and 4231 Curies respectively)

(Licensee's Response to Interrogatory 27,2.19.88)

(GPU Proposal July 1986,P.10)

They also used sample analysis (Harner Affadavit (5d)

)

Nevertheless,a document provided as a reference to Nureg.0683, Supplement 3, shons that the core inventory of tritium at the time of the accident was 8,794 curies.

(TP0/IMI-043 Rev.6 1986 "Radioactive Waste Management Sunmary Review")

Since Ititiun is both a fission product and an activation production and because the fuel rods ruptured-during the accident releasing the tritiun, and because such a large percentage of the tritiun is created in the coolant,the source term for tritiua in the AGW has not been conclusively addressed.

(Wash 1250, Wash.DC U.S.A.E.C (1968)

Xiii) The source term of the AGW is even more relevant in light of the fact that the water going into the evaporator in Batch Cycle would deviate

' even more from those concentrations listed in Table 2.2 Nureg 0683.

(System Description P.21) l (Licensee Response, Interrogatory 18,3.30.88)

All of the above der:enstrate that the NRC have based dose calculations on inadequate data. This is supported by the accorpanying affadavits.

5. EPA Irtter #51,Nureg 0683, Supplement #2 reconmended that the NRC revise Appendix.B so that a lay person might readily understand how the calculations for dose w re made. Such an understanding is essential in evaluating the merits and demerits of any action which serves to impact any individual. The NRC did not revise Appendix B (new C) in the final draft.

6. The volune of radioactive waste created by the evaporation method is unclear. If the evaporator is used to decontaminate the water,the amount of waste created by that method needs to be compared with that created by the Epicor/SDS. This amount needs to be specified.

(Licensec Response to Interrogatory (18, 3.30.88)

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. Bere is no-basis provided for Classification of the waste from

'he t evaporator. W e evaporator bottes will contain those radionuclides and other chemicals not released through the vaporizer. The NRC did not include all radioisotopes in the characterization of the water.

Examples are:

Actinium-227 Americim-242 Californim-249,250,252 Curim-243,244,245,246 Neptunim-237 Protractinm-231 Plutonium 242 Thorim- 228,230 Uranim-232

7. Deleted. ,

8. The NRC failed to calculate the cumulative risk of the evaporation proposal and other envirornantal sources of risk for the public within a 50 mile radius of the TMI site. -

(Response to Interrogatory 8,2.22.88)

This is required by NEPA. This information muld assist in an infonned decision by the public on the evaporation proposal.

9. The NRC did not undertake its own analysis of the microorganisms in the AGW. .

NRC Response to Interrobatory 7, 2.22.88.

This response indicates that. water boiling d 212 F would kill the micro-organisms. However,the evaporator will operate at a temperature of 131 F.

(System Description 2.16.88)

A quantity of the microorganisms will be contained in the water droplets to be released to the enviroment.

(NRC Response Interrogatory 7(e) 2.22.88)

Their release must be evaluated becauce of possible pathogen problems and the presence of those materials which would result frm virus organisms.

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Fbrthemore,because of their ability to plug colums,they may affect the efficiency of Epicor/SDS and the evaporator.

(NRC Re.sponse to Interrogatory 7(g) 2.22.88)

10. %e NRC assumd that the dose fran the transuranics would be delivered by the lower level of detectability of the transuranics(all of which are not included-see #6). (Nureg 0683, Supplement #2 .2.2 P.2.4)

Since the transuranics are in 25 storage locations it is incorrect to assum that the total inventory of the transuranics is at the lower level of detectability.

11. he NRC assumes that there are biological mechanisms that can repair damage caused by radiation at low doses. (Nureg 0683, Supplement #2 P.5.4:5.2) his is not an fact but rather an opinion shared by sane and not all.

he public in making their detennination of the benefits anJ risks nust be made awace of the difference of opinion surrounding this issue.

Especially when one considers the paucity of data on people who have experienced prolonged impact fran sources of low levels of radiation.

ne /,mrican Physical Society states, Among the harmful biological impacts that may occur as a result of even low level exposures are neoplastic (carcinogenic) and hereditary (nutagenic) effects.

(Review of Modern Physics Vol 57,13 Part 2 7/85)

12. We NRC mislaid the public by making the AGW seem innocuous, heir eticulations of the dose to the public by drinking the water l

had muy flaws.

(Affadavit Dr K.Z Morgan, Exhibit B)

(Nureg 0683, Supplement #2 P.2.4)

13. In calculating the dose to the public fran evaporation,the NRC ignored the more recent findings about dose and risk derived fran data on the victic..;

of Hiroshina and Nagasaki. ney used andels which tend to underestinate the risk to the public.

(Affadavit Dr K.Z. Morgan, Exhibit A) l s

14. Be safety of the evaporator for the workers has not been analysed.

(NRC Response to Interrogatory 33,2.22.88)

'Ihe dose to the population of a leakage of one of the storage tanks,which is considered to be bounding for any accidents involving the workers, appears to be inadequate in light of the fact that evaporators are prone to hose

. ruptures and puup failure.(A discussion of evaporators and their deficiences is found in Nureg 0591)

For all of the reasons discussed above Contention 3 should be admitted for adjudication.

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CORITRrION 4 .

Contention 4 is as follcus:

Sufficient evidence fus not been provided b) to ensure that the evaporator can filter out transuranics.other radionuclides as well as chemicals to protect the public health and safety.

c) the monitoring and safety systems have not been shown to provide the safeguards neaed to protect the public health and safety.

d) It has not been demonstrated that the evaporator influent can be varied from processing 3 gallons per minute to 20 gallons per minute without jeopardizing the public health and safety.

1.- % ose issues identified in "Contention 3" P 10-17 concerning the inadequacy of the data related to the characterization of the water are also relevant to this response for Contention 4 because the chemistry of the water may affect the effic!ency of the evaporator.

2. A decontamination factor of 1000 has been asstmed by the NRC and the Licensee. This factor is based on the premise that this water resembles the water for which a decontamination factor of 1000 might be expected.

However,this water has a different characterisation because of the addition of certain chemicals notably Triton X . This detergent would affect the efficiency of the evaporator to decontaminate the water.

(Licensee's Response Interrogatory S 52 2.19.88)

(Licensee's Response Interrogatory 6,3.30.88)

(Affadavit ,Iouis Kosarck, Exhibit C)

3. If the decontamination factor of 1000 is not achieved the effluent frcui the vaporizer may exceed the Maxinum Permissible Ccncentration for releases into the air. The health of the public will be jeopa: dized.

4. The evaporation has no effect on the concentration of tri*.ium in the effluent. If the water contains a concentration of 2.1 Uci/ml (Technical Specifications for Processed Water Disposal P43 (7.3)

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• ~

- the Licensee will exceed its' permissible continucus release rates which

, is 570 Uci/sec (release limit of 3 gal / min.

(GPU Proposal 1986' P.41) 5 a) The Licensee states that the allowable gaseous rate was calculated asstrning that only tritim Suild' be released as a vapor.

('.lcensee's Response Interrogatory 2/3.30.88)

Radionuclides which may also escape include I-129 (Mureg 0683, Supplement #2 P 3.9,(3.1.2)

Cs 137 and Cs 134 may also escape in the vapor as they are both soluble in water and smewhat volatile.

K-85 which was present in the water,but not listed as a characteristic of the water by either the h7C or GPU, could escape as a gas.

Carbon 14 could escape as a gas.

The Licensee claims that there is evidence at WRs that None of the Carbon 14 released was associated with CO2 '

(Licensee resp;nse Interrogatory 14,3.30.88)

This is contradicted by the follcuing observation, Carbon 14 is not measured routinely in the sampling and analysis programs of most

, nuclear powr plants in the United States,

but several independent measurement projects have made' estimates of the activities released annually. . . . . . . . . . . . . . . the conclusion of that research (Kunz 1985) is that both WRs and BWRs release in gaseous effluents approximately 10 Curies of Carbon 14 per 1000 MWe-yr of routine operation.

Appendix A,P A-47 "A Radiation Monitoring System for Nuclear Power Plants" (funded by the Public Health

! Fund and undertaken by Dr Ruth Patrick and Assoc.)

L l

l t

t a

c -

1 6. If more than one gas is released by evaporation,then the MPC for

' tritium as listed-in 10 C.F.'R 20, App B', Table ii,Colum 1 (2x10~7) 1 and used in calculations by the Licensee aust be different.

(10 C.F.R.20 App ~B , footnotes.)

7. threg/CR 2206 (11,6,81,P F-9) states that Possible explosion conditions due to .

unstable organics (e.g amines) or canbustible gases e.g hydrogen cust be covered.

.- (in reference to evaporators)

- NRC's Response to Interrogatory 20,2.22.88 indicates that amines are present in the AGW and would vaporize into the enviroment. This issue needs to be evalua;ed.

8. NRC's response to Interrogatory 20,2.22.88 concerning chemicals in the AGW and their presence in the evaporator does not inspire confidence about the likelihood that they may vaporize. Factual basis should be provided shwing that chemicals will not be released to the enviroment in any appreciable amounts to jeopardize the public health ano safety NRC states,

.From my current knowledge of the chemicals that are likely to reach the evaporator,I do not believe that  ;

t any contaminant which woald reach the evaporator would vaporize into the enviroment with the possible exception of trace amounts of anmonia and other amines.

4 9. The decontaination factor of an evaporator is affected by the chemistry of the water which can affect the follcwing factors

a) salting, b) scaling, c) fouling b) entraiment c) splashover d) foaming e) volatilization of solute.

The NRC has fai}ed to evaluate these in light of the characterization of the AGW.

i (Affadavit louis Kosarek, Exhibit C) [

1 (tbreg 0683 Supplement #2 ,3.1.1)

10. The corrosive effects of this water upon the evaporator and the impact .

this might have upon the efficiency of the evaporator to operate has not I been undertaken by the NRC. This is recamended by threg CR 2206 (11.6.81) ,

20- -

l

10. We NRC declined to respond khen asked to identify tests perfomed

' to shcu the efficiency of maisture seperators and vapor superheaters which would be used on evaporators to ensure that liquid droplets and dissolved componer.ts are not discharged with t% vapor.

(NRC Response Interrogatory 31.(ii) 2.22.88)-  !

his infomation is needed to determine the effectiveness of evaporators.

A. non response leaves JI to wonder if no such information is available.

11. NRC and the Licensee have assumed that an. evaporator is suitable.for disposal of the AGW even though Nureg, CR 2206 P.F-2 states ,

9 Evapor~ation is most suitable for processing

. liquid waste which has a high total solids concentration and which requires a high degree of decontamination frcm its radio-nuclide content. %e volumes of such wastes are nMnully low in comparison to those of lower activity warces from nuclear pcser plants. , ,

(Nureg CR 2206 P.F-2)

12. B e NRC's experience with evaporators and a vaporaizer is limited.

(NRC Response to Interrogatory 21, 2-22-88

13. Licon Inc , installer of the evaporator has had little experierre with  !

evaporators.

(Licensee Response Interrogatory 16, 3.30.88) l

14. h e vaporizer section of the system will be monitored and controlled by a gamna radiation detector. More than 50% of the releases frcm the l vaporizer a,.e beta emitters. Cs-137 is a gamna emitter. It will be used l

l for calibrations and alarm set-point determination (Suclanan Affadavit) ,

l Lis type of monitoring aesumes a constant relationship between Cs-137 l

and Sr-90 or H-3. B is assumption may be inaccurate for the AGW.

he Licensee had been found to maintain a policy to systematically falsify critical safety data and destroy documents for months leading to ,

the 1979 accident,(27%) he Licensee has more recently been found to

misman?ge waste (10-23-87)(3-11-88). These facts put more emphasis on not 4

just the ability of _ the monitoring and safety systems to work,but also the ability of the Licensee to perform its work properly.

15. The NRC has assuned that the maximum evaporator influent will be 20 gallons / minute.

(NRC Response to Interrugatory 22,2.22.88)

However,the Licensee assunes a feed-rate of 5 gallons / minute. Variations in the feed rate will affect the Licensee's ability to cmply with its Technical Specifications related to pennissible release rates for gases and particulates. The Technical Specifications are a means to protect the public health and safety.

16. It is well docunented in Appendix A and F,"A Radiation Monitoring System for Nuclear Power Plants" that monitoring of radionuclides is an extremely difficult task and one which is fraught with errors.

, In Harner Affadavit for Contention 5d,it is stated that ,

The nuclear process involved in a reactor produces predictable fission products, activation products, and transuranics,and the rates of decay,and decay products are also known. Thus the isotopic inventory can be calculat.ad;and radionuclide constituents of any significance and their relative abundance can be determined. (p.5)

This is not entirely accurate in light of the. fact that a variety of moddls-may be used in calculations,and the calculations are only as good as the input of data. Ebrthermore,the accident at IMI created a scenario not experienced before and during which the fission products and activation products wre distributed throughout Unit 2 by way of the annosphere and the water. This is well documented in the research of the accident.

(This discussion is relevant to Contentions 3 & 5)

For the above reasons Contention 4 should be admitted for ad'.idication.

' ~

CotrrRTION 5

. Contention 5 is as follows:

the effects of tritium have been virtually ignored the effects of alpha emitters have been vitually ignored.

' 1. Those issues raised in responses for'tontention 3"are pertinent to the' issues raised in this issue,since the dose fran either Tritiun or the transuranics is dependent on the characteristics of the AGW,and vapor from the evaporating process. The efficiency of the evaporator, addressed under "Contention 4" is also pertinent to this issue.

2. It should be noted that this contention refers to the NRC's deficient discussion of the effects of tritium and the alpha emitters,and their assumptions about the lack of #fect on the population. Therefore,the Licensee's attempt to provide more infonnation on tritium and the alpha emitters does not alleviate the NRC from their responsibilities to the public.

3. In determining the exposure and dose to a member of the population, it is stated that, The chemical and physical forms of the aerosols and isotopes would detennine the biological uptake and excretion rates and so influence the effective time of exposure for var ious bodily organs (Reviews of Modern Physics,Vol.57, Number 3 Part 11, July 1985) Report to APS The NRC did not determine the physical and chemical form of the radionuclides in the AGW.with the exception of tritium.

(NRC Response Interrogatory 4, 4.4.88)

(This point should also be a part of the discussion undertaken in "Contention 3)

c

4. In its discussion of tritium in'Nureg 0683, Supplement '#2,the NRC ignored scme of-the data provided in NCRP # 62. Some examples are as follows:

a) The NRC discussion of tritim assumes that the effects of tritium are well known and understood (Behling Affadavit expresses same). The '

NCRP report however states, There have been many studies of the metabolism of i ' tium in animals and humans with somewhat less attention given to radiation effects.

5. NCRP report also~ states thanfollowing uptake of tritium Within minutes it can be found in varying ,

concentrations in the various organs fluids and tissues of the body.

6. The rate of elimination frm the body is dependent on where the tritium is incorporated. If it is incorporated into organically bound pools it will be retained in the body longer. The NRC recognised this but failed throughout the Nureg 0683'to relate it.to the'reldase of t'ritium upon the population stound IMI which would occur as a result of the evaporation of the AGW.

7. As recognised by NCRP #62, the amount of tritium incorporated into the DNA is most important. NCRP quotes two studies which show the

labelling of DNA by tritium. In one study all DNA were labelled with tritiun in various amounts. In another study by Mewissen and Rust,it was found that incorporation into RNA was five-fold greater than in DNA.

The NRC' neglected this vital information in its determination of the effects of tritium. (Affadavit ,Dr C.W.Huver, Exhibit D)

8. There is evidence of the concentratici, of tritium in vegetation. ,

I (Affadavit Dr C.W.Huver, Exhibit D) t e *

9. Assessnent of the Relative Biological Effectiveness of trititm is difficult. Dose calculations vary greatly with the use of different values. In view of NCRP's statement which documents the difficulties in assessing the RBE it is prudent to err on the side of caution in detennining dose to the population exposed to tritium.

(Affadavit Dr K.Z. Morgan, Exhibit A) tERP / 62 states that the difficuties are confounded by the following:

a) the metabolic and physiologic processes controlling the distribution and therefore the dose due to tritium are poorly knwn (this is especially important in extended exposure situations) (emphasis added) b) tritium incorporation into organic nelecules and structures as well as the differential distribution of tritiated water result in inhomogeneous dose distributions, c) dose estimates are based on secondary measurements d) distmption of tissue structures by the initial dose fraction of a total dose delivered over an extended period of time will result in a non-hmogeneous dose distribution.

e) the reproductivity of low dose experiments relative to high dose experiments is low.

In its evaluation of dose from tritium the NRC does not evaluate this infonmtion and as a result virtually ignores the effects of trititm.

10. tIRP #62 states that available data supports the general conclusion that slw uptake is logically associated with long retention. ihis infonration is particularly relevant to assessing the dose frm trititrn incurred over a twc year period by evaporation. The NRC did not utilize this infonmtion in its discussion ur calculations in Nureg 0683.

11. It has been found that. tritium releases to the enviroment have some ecological and biological consequences when evaluated in tems of food chain effects.

(Affadavit,Dr C.W Huver, Exhibit D.)

13. 'Ihe hPC did not take into account the already existing impact frm the dose delivered to that part of the population which also receives a dose frm the tritium in their drinking water,such as those who live in the city of Lancaster.

(NRC Response to Interrogatory 8,2.22.88) 14 In considering the offects of transuranics on the dose delivered to the population,the hPC assumed that these transuranics were present at the lower levels of detectability. (See page 16 #10 of this response.)

Having made this assumption,the NRC continued to ignore the effects of any amount of transuranics by not providing infonration on the chemical and radiological characteristics of these alpha emitters. In light of their extreme toxicity,more consideration was warranted. (Nureg 0683,Section 2.2) 15 By virtually ignoring the effects of tritium and the transuranics, the EIS dces not provide adequate data to the public for traking an informed decision about the disposal of the AGW.

For all of the above reasons Contention 5d should be admitted for adjudication.

6 e

e

CONTEUFION 6 Contention 6 is as follows:

he effects of chemicals on the Epicor/SDS and the evaporator have not been evaluated.

1. h e Licensee states that the use of chemicals at MI-2 is strictly controlled by the F1-2 "Chemical Controls Procedure" (Harner Affadavit)

Nevertheless, vendor product 1192 was added to the system in 12.8.86 (Licensee Response Interrogatory 5,3.30.88)

Vendor Product 1192 was shom in tests to reduce ion removal efficiency of the resins. heir effect on the evaporator has not been demonstrated.

(NRC Response Interrogatory 13(b),2.22.88)

2. 350 gallons of Triton-X w re added to the AGW. Bis is a detergent and as such changes the characterization of the water. It affects the effiency of the evaporator. B is has received no evaluation by NRC.

(Affadavit Louis Kosarek, Exhibit C.

3. Le NRC states that additional chenical will be added. Evaluation is needed.

After defueling saae additional decontamination of the reactor coolant system would probably be required before the carpletion of clean-up.

Decontamination of the reactor coolant system is expected to involve additional mechanical decontamination technology,such as vacuuming fuel debris and water flushing of the system and nuy involve saae chemical decontamination techniques as w il.

(Nureg 0683, Supplement #3 Draft Supple: Tent Dealing with Post Defueling Monitored Storage Subsequent Clean-up. P 2.16, (2.1.3

4. Licensee states that he effects of the substances have been evaluated and for the most part have no significant effact.

en tee ion exchangers (emphasis added)

Licensee's Request for Su:mury Disposition of Contentions 4b in parti and 6. P.5

. Licensee further states,

' Very limited amounts of a few substances '.

that eculd adversely affect ion exchange media have been introduced into batches of-accident generated water,but they were subsequently removed by processing.

Id 10-19 ,

However, Licensee contradicts this by stating, This 3rocessing removes not only radio'nuclides but c wmical constituents as well with the result that levels of chemicals other than boron and sodium in processed water are low.

Id 6 Obviously then all the chanicals are not removed from the AGW ,and their effect on the processing systems have relevancy to these ' proceedings.

5. See #8,P.20 of this response.

6i'In Buchanan affadavit P.8 itstates that foaming agents may be added to the AGW. This is additional chemical ;iollutants which need to be evaluated.

6. In Buchanan Affadavit P.13, recognition is made that there may be a chemical contaminant which might affect the efficiency of the evaporator.

The dicussion goes on the say how it will be detected.However,the discussion does not provide solutions to the problem.

For the reasons stated above, Contention 6 should be admitted for adjudication.

COtTITRFION 8 Contention 8 is as follows: -

'Ihe PEIS fails to give reasonable cbnsideration to two disposal methods,viz., closed cycle evaporation with solidification and shipment to a low level waste site of the bottoms and condensate,and storage of the water in tanks within the contaiment building.

1. 'Ihe requirements to consider these alternatives,which are both reasonable,are set out in Contention 2,P 7 of this response.

2. All those material facts raised in "Contention 2" cencerning the NRC's treatment of the no-action alternative" will apply to this .

Contention since the NRC treats these two alternatives in one section in hbreg 0683 3.,5. P.3.32. and in Table 5.1. P.5.2.

1 3. 'Ihe NRC neglected to consider monitoring of water table wells,and stream and water sampling for the longer period of storage.

4. Tankage replacenent was not evaluated by the NRC for the long term storage. (Nureg 0683 Section 3.5.1.1 P3.33

5. Regulatory obstacles were not evaluated for the long term storage of the AGW. Nureg 0683 3.5.1 P3.32.

6. 'Ihe cxtission of the above information demonstrates the NRC's lack of objectivity.

For the above reasons that part of the contention which deals with long term storage should be admitted for adjudication.

Additional caments on statenents made by the Licensee in their reauest for Sumrarv Disposidon on Alternatives (Contentions 1,2,3,8.

P.10 Line 11 It is hoped that camon sense also will tell us that when an action is proposed which will affect our health and enviromunt,that we would always closely scrutinize it and replace it by an alternative which would have less effect.

P 11. Line 8 The "obviously superior"standard raises the question as to who should decide what is "better" or "obviously superior".

In the case of the AGW,the people were not involved in its creation.

It was created by errors and technical malfunctioning,both of which the Licensee was expected to have control. The people are now being asked to burden the responsibility for dealing with this water. They are being asked to solve a national problem of Icw level waste disposal by having the radioactivity let loose into their enviroment for no apparent benefit.

P.14.Line 5 Licensee claims that JI took an inherently contradictory position. khile it is true that in scne cases actions with the 1crmst radiological consequences may not be those with the lumst non-radiological consequences, in this case ,the disposal method with the least of both consequences is available.

P.18. If the NRC decided that no alternative is clearly preferable and the public around TMI are those who will be impacted upon,then the decision should rest with the public.

P.22. Throughout this response to Licensee's Motion there is clear evidence that the evaporation method is not "enviromentally acceptable, technologically sound,and cost efficient."

P.23 Line 10 Licensee is incorrect to say that background radiation in this areais 300 mrem per year. Tne NRC state that it is 178 mrem per year.

- so _ '

5

- P 24.Line 7- he Licensee is incorrect in stating that'the disposal of the water by evaporation will be a carplete resolution of the issue.

For many years to cane,the : adionuclides will affect our air and water. ,

he waste created by the method will be in a site decaying. The Licensee no doubt sees evaporation to resolve the problem for thanselves. It-most certainly does not resolve the problem for the public.

P.29 Line 1-3 2 ese estimates of dose to the workers are still within the limits projected for the clean-up of Unit 2. %ey seem enormously high in light of the NRC's evalution of the plant at the beginning of

PDMS.(dureg0683Spplement#3) p.30 Footnote 31 The Licensee appears to believe that the NRC's regulations are based on the belief that there is a safe dose of radiation. This is not the NRC's position. See Nureg 0683 Supplement #2,7.24(7.5.3)

The NRC's regulations permitting releases are supposed to reflect a careful balance between the risk and benefit of generating electricity from nuclear power. It is of course difficult to calculate the amount of risk that the public is willing to take for a conmodity. No agency should set itself the task without constant input from the public.

l P.31 It should be noted that Licensee assigned the period of 30 years since the JI did not specify an actual number.

t p.33 Line 18 Our children unfortunately are left with the legacy of all waste from IMI and other pollutants.

l l

P.33 The disposal of the AGW is hardly a major step in the completion of i the clean-up in light of GPU's PDMS proposal which postpones clean-up for i

an unspecified period of time.

P34 It should be noted that all NRC licensees did not suffer a major accident and its resultant clean-up problem. Furthemore the doses frun ovaporation are in addition to those already received.

P35 Line 19- Absent a careful evalu'ation of the risks and benefits of this action,' it is perfectly logical to await making a decistun.

l I- _

EXHIBIT A AFFADAVIT OF DR K.Z. MORGAN IN SUPPORT OF CONT.hTIONS 1,3,4and 5

\. ,

c

! Second Set of Comments Relative to Treatment and Disposal of 2,100,000 gal. of Contaminated Water at TMI-2 by Karl Z. Morgan March 2, 1988 Fo11ov Up Comments ,

First of all I wish to state that I stand by my comments in my earlier report on this subject dated March 19, 1987 and wish now to respond to a criti-cism of that report and bring this discussion up to date. At the outset also I would like to make it clear that I offer these cc nents, not as a paid consul-tant, but as a citizen interested in the long term genetic and somatic health of persons living in this community, i.e. I am accepting no payment for the time and effort I am spending on this case.

The only criticism I have seen of my report of March 19, 1987 is that my calculations of dose are based on values of body uptake, distribution, retention and energy distribution given in ICRP-2 (1959) rather than data given in ICRP-30 (1981). It is true that this use of earlier data has in general led to higher estimates of dose for some of the radionuclides such as Sr-90 but has had little effect for such radionuclides as H-3. However, I deliberately made use, for the most part, of the data in this earlier report because I believe they are more represent.itive of man for two reasons, 1) The data in ICRP-2 are more representative of the average person in the community and 2) The data in ICRP-30 are a selected set of data by current members of ICRP who have a conflict of interest because of their association in the nuclear industry.

- It is well established.th.* for most of the radionuclides the dose from a given environmental exposure is greater for children and for females. The early 1

~ _ _ .

4

• data made use of information from a variety of sources--old, young, male, female, human, animal, etc. The more recent ICRP-30 data apply more s.trongly to the cdult working male.

There is no question but that a conflict of interest has led to a selection of biological and physical parameters that guarantee a lowering of the est,imated dose to body organs from incorporation of the radionuclides in case of the more important exposures. I pointed to some of this defect in present membership of ICRP in a recent publication (Radiation and Health by R.R. Jones and R. South-vood, chapter 11, "ICRP Risk Estimates--An Alternative View," by K.Z. Morgan, J. Wiley & Sons, 1987). The following table is copied from this publication.

Here we have the startling observation that all values for greatest concern in our case (H-3, C-14, Cs-137, Sr-90, Ru-106, Ce-144, Co-60, Pu-239 and I-129) are larger in ICRP-30 than in ICRP-2. 'These increases are not by accident but by design. As one of the three emeritus members of ICRP I objected to the direc-tion ICRP was tsking but all to no avail. I could not condone a policy of ICRP to increase the allowable values of maximum permissible concentration, MPC, in cir, water and food at a time when all of us recognized new data were showing that the risk of radiation induced cancer is much greater than we thought it to be when ICRP-2 was published. This trend, however, began in the last five years before I was voted out as an active member of ICRP. There had been strong op-I position by some members of ICRP to the so-called ten day rule to limit diagnos-l tic X-ray exposure in the pelvic and abdeminal region of young women except i during the ten day interval following menstruation and we had a long squabble i

over the fact that ICRP-2 had set the quality factor for low energy beta radia-

! tion (such as that from H-3) at 1.8. Dr. H. J. Muller (the world famous geneti-cist) and I won out in a battle for the 10 day rule but I lost out on a higher i

2

value of Q for low energy beta radiation. Some of us had gathered biological data indicating the value of Q'probably should be no lovar than five and I had physical data indicating the stopping power dE/dx of low. energy betas was simi-lar to that of alpha radiation. Today ICRP sets Q=20 for alpha and neutron

. radiation but the year I left active ICRP membership (1971) the Q for low energy beta was dropped to 110. One member of ICRP even used the argument that we should not raise the value of Q for low energy beta radiation because it would hamper production of nuclear weapons.

I believe all the above is rather pertir.ent to our case here for were we to set the Q=20 for the H-3 beta (the value for alpha) the dose estimates we arrive at for H-3 would be increascd by a factor of 20.

There are other reasons also for concern for the dose from H-3. Hydrogen is a basic constituent in the nucleus of the living cell. Triciated thymidine (Cf014 H N02 5) in the DNA undergoes two dramatic events when the H-3 gives off a beta. First, recoil energy might break or rearrange chromosomes in the nucleus of a cell and second, when the hydrogen atom gives off a beta particle, it is transmuted to a helium atom ( H - gS+ He). These events could be especially serious in the human ovum or sperm cell prior to or shortly after meiosis of the chromosome. It takes many generations in a human population to measure the full extent of such genetic changes but perhaps (and unfortunately) the large increase of H-3 in the human environment may visit serious consequences on chil-dren yet to be born. Fortunately the half life of H-3 is only 12.26 years.

However, C-14 has a half life of 5,730 years and much of what is said above re-garding H-3 applies to C-14 and its low energy beta. In this case we are con-cerned with the transmutation of a carbon atom in one of the chromosomes to a nitrogen atom, i.e. C ,gS+ N.

3

Another reason for uneasiness and concern about the release of steam and ,

vator droplets containing H-3 into the environment via the open cycle evapora-3 tion method is that H O2 is considered to be 100 times more hazardous than H 2 cnd studies of H O have shown man absorbs the same amount through the skin as 2

via inhalation.

Ever since ICRP-30 and ICRP-26 (1977) came into print I have fought against increasing the MPC values but it has been a losing battle--recently NCRP, NRC and EPA succumbed to pressure from the nuclear industry. I attach a copy of my comments on the proposal of the NRC to adopt ICRP-26 and ICRP-30 in Part II Title 10 Part 20 submitted March 27, 1986.

For the past 10 years I have been publishing papers showing why the cancer risk estimate of one radiation induced cancer death per 10,000 person rem (10 ed/pr) is too low and should not be less than one per 1,000 person rem (10' cd/pr). The ICRP, NCRP, UNSCEAR, NRC, DOE, EPA, etc. , however, have been adamant end have persisted in using 10 cd/pr. Last year all these agencies took a terrific blow and are now in the process of sating crow. This low figure of 10 ed/pr is based on early data from survivors of the atomic bombings of Hiro-shima and Nagasaki and a publication from the Japanese research group (D. L.

Preston and D. A. Pierce, RERF TR-9-87) struck like a thunderbolt to their smug-ness. At its Como, Italy meeting last fall the ICRP stated that this publica-tion required an increase by a factor of 2.8 in the cancer risk estimate and went on to 'say "Substantially larger changes in the Commission's present risk ostimates for cancer induction would, however, result from two further factors."

These two factors are, 1) change from the use of an absolute risk to a relative risk model and 2) change in the shape of the dose response curve. In spite of these humbling admissions, the ICRP concluded "Since the risk data are yet far; 4

from conclusive, the Commission will await the result of-the comprehensive evaluations of its sources of epidemiological information that are currently being made, before judging the consequences for the revision of its system of dose limitation." Amazing' Let's wait and count more bodies before doing some-thing that might jolt the nuclear industry. I am still for the proper develop-ment of the nuclear industry but not at an unacceptable cost in suffering and human life. If I could have made the choice in the early period, I would.have opted for renewable sources of energy but now it is too late and I would like to make the best of what we have by trying to shut down the power reactors with a poor operating record and increasing the safety of those remaining on line.

Fortunately in the UK they are not waiting to count more bodies and have an-nounced the intention of an immediate reduction in levels of exposure to ioniz-ing radiation by a factor of three and perhaps additional reductions at a later date. ,

Finally and in conclusion, I believe the doses would now be found to be larger for the open cycle evaporation method than I calculated in my March 19, 1987 report were I to take account of all the factors discussed above. In that report I suggested three methoos of closed cycle evaporation that would greatly reduce the radiation hazards at a relatively low cost and I believe these methods should be carefully studied before embarking on an open cycle method that does not conform with ALARA and does not meet provisions of the NRC numerical guide in 10 CFR 50 of 3 mrem per reactor year to the total body from all pathways for liquid effluents or 5 mrem per reactor year to the total body of an individual for gaseous effluents.

6 ,

' ~

Ttble 3 Comparison of ICRP-30 with ICRP-2 values Table 3 Confinamt Radio- IIalf-life ICRP-30 ICRP-2 ICRP-30' ICRP-2 Radio- Ilatf-life ICR P-30 ICRP-2 ICRP-30' ICRP-2 nuclide DAC-(Bq/m') MPC. ALI (Jg) MPC. auclide DAC.(Bq/m') MPC. ALI (Bq) MPC.

MPC. 4Ci/cc). M PC,, MPC.

GCi/ccb -

MPC. GCi/cc). GCi/ccb 4Ci/cc).' GCi/ccb ~ 4Ci/cc). 4Ci/ccb 11 3(11: 0 ) 12.26y 8 x 10' 3 x 10' I-132 2.26h I x 10' 10' (2.2 x 10-8) (5 x 10-') (0.3) (0.I) .

(2.7 x 10-*) (2 x 10-') (0.0I) (2 x 10-8)

C.I4(coa) 5730y 3 x 10' 9 x 10' g.133 20.3h 4 x 10' 5 x 10' (8.1 x 10-') (4 x 10-') (9 x 10-') (0.02) (1.1 x 10-') (3 x 10-') (5 x 10**) (2 x 10-*)

N2-24 I4.%h 8xIO* 10' I.I35 6.68h 2 x 10* 3 x 10' (2.2 x 10-*) (10-') (0.01) (8 x 10-') (5.4 x 10-') (10-') (3 x 10-8) U x 10-')

P.32 I4.28d 6 x 10' 2 x 10' Xc.13I 5.27d 4 x 10' -

(1.6 x 10-') p x 10-') (2 x 10-8) (5 x 10-*) (l.I x 10-*) (10-') - -

S-35 87.9h 3 x IC' 4 x 10',2 x 10' Cs.134 2.046y 2 x 10' 3 x 10' (8.I x 10-') (3 x 10-') (0.04, 0.02) (2 x 10-') (5.4 x 10-') (10-') (3 x 10-*) (3 x 10-*)

Cl.36 3.1 x 10'y 4 x 10' 6 x 10' -

Cs.I3 30.0y 2 x 10' 4xT (1.1 x 10-') (2 x 10-' (6 x 10-') (2 x 10") (5.4 x 10-') (10-s) (4 x 10-') (4 x 10-*)

Ca.45 165d I x 10' 6 x 10' Da Ido 12.8d 2 x 10* 2 x 10' (2.7 x 10-') (3 x 10-') (6 x 10-8) (3 x 10-') (5.4 x 10-') (4 x 10-8) (2 x 10-') (7 x 10'*)-

Cr.51 27.8d 3 x 10' 10' Cc.144 284d 200 8 x 10' (8.I x 10-*) (2 x 10**) 0.1 (0.05) (5.4 x5 10-') (6 x 10-') (8 x 10-') (3 x 10-')

M2-54 303d I x 10' 7 x 10' f r-192 74.2d 3 x 10 4 x 10' (2.7 x 10-') (4 x 10-') O x 10-') (3 x 10-') (8 I x 10-') (3 x 10-') (4 x 10-8) (10-8)

I c.55 2.6y 6 x 10' 3 x 10' Po-210 138.4d 10 10' (I.6 x 10-') (9 x 10-') (0.03) (0.02) (2.7 x 10-") (2 x 10-") 10-' (2 x 10-')

I'e-59 45.6d 8 x 10' 3 x 10' Ra-226 1602y 10 7 x 10' (2.2 x 10-') (5 x 10) (3 x 10-8) (2 x 10-') (2.7 x 10-") (3 x 10-") U x 10-*) (4 x 10-')

Co-58 71.3d I x 10' 6 x 10',5 x 10' Th-232 I.4I x 10"y 4 x IO-' 3 x 10' (2.7 x 10-') (5 x 10-') (6 x 10-s,5 x 10-8) (3 x 10-') (I.I x 10-") (2 x 10-) (3 x 10-') (5 x 10-')

Co.60 5.26y 500 2 x 10',7 x 10* U.234 2.47 x 10'y 6 x 10-8 5 4 x 10 ,7 x 10' (1.4 x 10-') (9 x 10-') (2 x 10-8,7 x 10-') (10-8) (1.6 x 10-") (10-") (4 x 10-8,7 x 10-*) (9 x 10-')

Ni-59 8 x 10*y 3 x 10' 9 x 10' U-235 7.1 x 10'y 6 x 10-8 5 x 10',7 x 10' (8.1 x 10-') ($ x 10-') (C.09) ~ (6 x 10-') (I.6 x 10-") (10-") (5 x 10-8,7 x 10-*) (8 x 10-*)

Co-64 12.8h 3 x 10' 4 x 10' U-238 4.51 x 10'y 7 x 10-' 5 x 10', 8 x 10' (8,.I x 10-*) (10- *) (0.04) (6 x 10-8) (I.9 x 10-") G x 10-") (5 x 10-8,8 x 10-*) (10-8)

Za-65 245d 4 x 10' 10' Np-237 2.14 x 10*y 9 x 10-2 3 x 10' (I.1 x 10-') (6 x 10-') (10-') (3 x 10-') (2.4 x 10-") (4 x 10-") (3 x 10-') (9 x 10-')

Sr.89 52.7d 2 x 10' 2 x 10' Pu-238 86.4y 3 x 10-' 3 x 10, 3 x 10' 5

(5.4 x 10-') (3 x 10-') (2 x 10-8) (3 x 10-') (8.1 x 10-") (2 x 10-") (3 x 10-5,3 x 10-*) (10-')

S1 90 27.7y 60 [10-')* 10', 2 x 10' (10-'l* Pu.239 24390y 2 x 10-' 2 x 10', 2 x 10' (I.6 x 10-') (3 x 10-") (10-*, 2 x 10-') (4 x 10-*) (5.4 x 10-") (2 x IG-") (2 x 10-5,2 x 10-') (10-')

M399 66.7h 2 x 10' 6 x 10', 4 x 10' Pu.240 6580y 2 x 10-8 2 x 10', 2 x 10' <

(5.4 x 10-') (2 x 10-') (6 x 10-8,4 x 10-8) (10'8) (5.4 x 10-") (2 x 10-") (2 x 10-8,2 x 10-*) (ID-')

Rs.106 368d 200 7 x 10* Am-241 458y 8 x 10-8 5 x 10' (5.4 x 10-') (6 x 10-') f7 x 10-*) - (3 x 10-*) (2.2 x 10-") (6 x 10-") (5 x h0-* (ID-*)

Te-127m 109d 4 x 10' 2 x 10',10' A m.243 7.95 x 10'y 8 x 10-'

• 5 x 10' (1.1 x 10-') (4 x 10-8) '(2 x 10-8,10-') (2 x 10-') (2.2 x 10-") (6 x 10-") (5 x 10-*) (ID-')

1 126 2.6h 500 8 x 10' Cm.244 17.6y 2 x 10-' 9 x 10' (I.4 x 10-') (8 x 10-') , (8 x 10-') (5 x 10-') (5.4 x IO-") (9 x 10-") (9 x 10-*) (2 x 10-*) .

I.129 I.7 x 10'y 100 2 x 10'. ,

(2.7 x 10-') (2 x 10-') (2 sx 10-') (10-') + clan W only I.1314 ' ' ' 8.05d . 700 (I.9 x 10-8 J o .r . ..a .

(9 x 10-') (10-*)

,-

• value given in ICRP-6 (1962). D

. (6 x 10-')

- --om _,,_, NRPB-GS9

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Interim Guidance on the implications of Recent Revisions of Risk Estimates and the ICRP 1987 Como Statement National Rudiological Protection

. Bourd

(/)

g cia Chilton, Didcot, Oxon OX11 ORQ

$ November 1987 2

d

+

4

• l NRFs-Cs9 DCTRIM CL'IDANCE CN THE IMPt.!CATICES OF RECDrf REVIS!CNS CF RISK ESTIMATES Atc THE 107 1987 CDrc STA*.EMDrf A&575ACT The revision of the dosimetry of the survivors of the Japanese atmic bmbings, together with the now increased follow-up time for epidemiological s tudies , are being taken into account by the taited Nations scientific Cossaittee on the tifects of Atomic bdiation (LNSCIAR) in producing risk estimates for ionising radiation exposure. Their report is expeted at the end of 1988 and it will be used by the International Ccrutis sion on hdiological Protection (20#1 in reviewing its reconnendations on the system of dose limitaticen. In the meantise ICPP has issued a statement and the board considers it necessary to give interia guidance on the control of exposure to ionising radiation. The Board will g;ve forral advice in its A3P series een IOS issues its revised recosumendatiore.

The IC?e statesent indicates that a preliminary re-assessment of the Hitcshima the ex;csedand pc Na saki svrvivors has raised the fatal cancer risk estimate for stion by a total factor of the order of 2. This information, in the view of ICRP, is not considered r,vificient to warrant a change in dose lia.its for occupational exposure.

The Board recoanises that estimates af the level of risk associated eth radiation expcsure are rising, ano advises those with regulatory responsibilities to consider the possible isplications for dose limits. As long as the legal dese limits remain at their present levels, the scard esghasises that it is even more important to keep exposures as Icw as reasonably achievatie, since continued expcsure near to the dose limit represents a level of risk which verges on the unacceptable.

In particular, it is reconeended that individual workers doses should be controlled so as not to exceed an average of 15 a5v effective dose equivalent p r year. For individual aerbers of the public, it is reccamended tAat the ef fective dose equivalent should not exceed 0.5 asy per year frcan effluent discharges f rom a single site. The scard expects that because all exposures n11 be as lw as reascnably achievable, most resuJ ting doses will te wil below these figures Approved for issue by the Director Author A B Clarke Naticrial Radiological Protection Scard Chilton Didcot Oxon CK11 QRQ Ac9twed for publicatices October 1981 Publication dates tevenber 1987 tt".so, f 3.00

!&SN O 859$1 293 2 De

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SUMMARY

OF MAIN CONCLUSIONS AND RECOMMENDATIONS 1 Data from recent studies of occupations 11y-exposed workers and the atomic bomb survivors have been -

reviewed, and indicate that the current ICRP risk estimates for f atal cancer underestimate the true risk from exposure to ionising radiation by between two and ten times. Overall, the data strongly favours a fivefeld increase in cancer risk estimates.

2 The current systemic of radiological protection, recommended by ICRP pays insufficient attention to the risk of inducing non-f atal cancers. Tha total cancer risk is probably ten times greater than the current ICRP fatal cancer risk.

3 The currently recommended ICRP dose limits

• for radiation workers are too high. An immediate five fold reduction.is imperative.~with a

[arget or a_ tenfsid reduction within a reasonable ~

. period of_ time. " " ' ~ ~ ' *

• 4 The introduction ' organ weighting factors' in ICRP 26 allowed substantial increases in individual organ exposure. Organ-specific dose limits should be introduced which reflect the fivefold teduction in the whole body dose Irmits, and which pay proper attention to the risk of non-fatal cancer.

5 The risk of inducing cancer of the gonads should be included in the effective dose equivalent concept, but genetic risks should be considered separately.

Data within UNSCEAR and BEIR III reports suggest that the genetic risk for all generations may be ,

five to tee ~ times greater than the risk estimate given in ICRP 26.

6 There are particular reasons to be concerned by the

~~

T"Tak ,*to tTse f oetus f rom exposure to ionisine radiation.

In particular, it is known that Qx osure during ,

pregnancy, particularly from weeks ejghi[Yb'ftfteen, t is associated in mental retardation in the offspring.

aEd that this ef fect may be without threshold. In

__..; -- ad3itT6n. some studies of exposure to diagnostic radiation during pregnancy indicate that the dQubling }Tgj dose for childhood cancer may be itse than(10 mSf3 (T R7ET.~ ~ Although the epidemiological data 7h3w '

inconsistencies, it is clear that recemmendations should err on the side of caution. 'itRP recommendations r'Ulating'to women workers whc may be of childbearing age, ur whom have diagnosed pregnancies, are seriously defh lent.

e

\, ,

7 The uncertainty about foetal sensitivity to ionising radiation justifies an immediate reduction in the recommended public dose limit to 200 pSv/ year (20 mrem).

8 Excess _qAs.es of childhood leukaemia have been dpmentad,a(65n'd a number of nuclear f acil,*. ties in the pK u stric'ularly the reprocessing ft.!cilities II:54314fleld and Dounreay. Both facilities discharge >

significant quantiVriF"bf longlived alpha emitters.'

such as Plutonium and Americium. It is quite possible that the current risk models under estimate the biological effect of these actinides on leuksemogenesis, particularly during foetal life, as the target tissues for leukaemia induction in the foetus is not known with certainty. Consequently, particular attention should be paid to protecting the public from such actinides. Radioactive discharges and, hence, public doses should-be limited by the principle of ALATA (as low as technically achievable) rather than by ALARA (as low as reasonably acheivable).

9 ALARA has not been effective in reducing the exposures of so=e more highly exposured radiation workers.

ALARA should be replaced by a system of more stringent

' dose limits, which will be ef fective in protecting t' hose cost at risk .

10 The ICRP have frequently'c iticised as being unrepresentative of the public and ' workers that it claims to be protecting. [1,v. slued judgements are to be made by the ICRP then, at the very least, there

~

"should be worker and public representative'on the Commission. .

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,, Ccorcia Institute of Technology BIOGRAPHICAL SKETCit -

(II986,).

. . MORGAN, MARL Z. - Neely Professor

• Educatten ,

A;n.,' University of North Carolina

• H. A., Physics, University of North Carolina 1929 1930 /

Ph.D.,, Phy. sics, Duke University * '

1934 Imolovment History '

Lenoii Rhyne College, Chairman, Physics Department ,

1934-1943 University of Chicago, Meta'11urgical Laboratory 1943 Cak Ridge National Laboratory Director, Health Physics Division .

1943-1972 Ceorgia Institute of Technology, Neely Professor 1972.Ig83 ,,

Appalhchian State University Health Physics Consultant 1983-1986 '

19,83-pres e,nt Experience Sur. mary: During the period as Chalinan of the Physics De'part=ent at

. 1.cnoir Rhyne CollegeNesearch in cooperation with Duke University in the field

. pf cosmic ray'ahowers, mason lifeti=e, etc. , vas

carried out. While at the University of Chicago, tiot gan was one of a group of six persons she developed

~

and established the new science and profession of health physics. At Oak Ridge Ustional Laboratory he was Director, Hesith Physics Division, from its ince.p-

• tien. !!c dirceted over 200 persons engaged in resepreh, engineering, and 100 in applied activitics. As a .profcesor at Ccorgia Tech Dr. Morgan t, aught courses in he.sich physics and directed the research of eleven Ph.D. students. '

Exnerience Sur: nary as a Teacher: Continuously throughout his professional life Dr. 1: organ has been a teacher. 1.hile esmpleting his graduate studies and conducting cosmic riy research at Duke University (1931-34) he taught courses in physics, and from 1934 to 1943 he was a professor and chairman of the physics department of Lenoir Rhyne College. During the early var years, prior to 1943, he taught night courses in theory of flight, navigation, and instrunent'ation to Navy s,:udents . In 1943, when the Chicago health physics group moved to Oak Ridge, Tennessee, he was in charge of the duPont hestth physics trainee group, many of whom (e.g., L. J. Cherubin, L. L. Cerman, J. U. Healy, C. M. Patterson,

• U. McAdams, etc.) became leaders in healt;h physics. While . director of the Health Physics Divisian at Oak Ridge National Laboratory, he conducted the first

- formal training of health physics. There were close to 100 students in those early classes (1946-49) and among these were many who later becane leaders in this. profession; for exampic Albert H. Holland, Van C. Tipton, Ralph H. Pen-

.nington, H.- W. Speicher , P. E. Klevin, T. E. Shca , O. R. Placak, C. B.,Penell, C.

, , P. S traub, F. U. Cha:.bers, et c. -

t 9

>~ ,

2- BIOGRAPHICAL SKETCH MORGAN, KARL z, Experience Sum ary as a Teacher (continued) .

In 1949, he organized the Health Physics Fc11oyship programs at Vanderbilt University and the University of Rochester. Later, these programs vere cxtended to li.other universities and these programs led to the education and training of a larCe fraction of the leaders presently inRidge the health physics to Vanderbilt profession.

University and Trom 1950 to 1972 !! organ commuted from Oak 8 University. of Tennessee ship students.

Dr. Morgan has had many other special t.eaching activities, such as Short Courses 11, at Georgia Tcch, a teaching assignment at the University of Sao Paulo, Bra:

program director of four. International Su=er School on Radiation Protection in Yugoslavia, etc.

It was an act of f ate that brough't Dr. )! organ to the University of Chicago early in 19,43 to join H. H. Parker, E. O. Wollan, C. C. Camers telder, R. R. Coveyu, On O.

C. Landsverk, and L. A. Pardue as the eriginal group of health physicists.

one of his cosmic ray expeditions to A. H. Compton's laboratory on }!ount Evans, f near Denver, Colorado, he Icarned to know Professor J. C. Stearns, chair =an o the University of Den u r. Dr. ?! organ vanced to =ove the physics Department at so they planned to change teaching posi-vest and Stearns wished These to co=e plans east, were interrupted by the war, but his association tions in 1943.

with Stearns and compton and 12 years experience in cos=icUniversity ray research resu in his being asked by Stearne to join the Metallurgical Projet at thein 1943 to b of Chicago, under the direction of Compton, education and *d:ini-aver 135 years of active work in health Physics researche stration.

Experience Su-nary as a Research=r_

This From 1931 to 1943 Dr. Morgan conducted research on cosmic radiation. i in included studies of cosmic shouers and meson measurements on

!! orth Carolina and Fromtit. 1943 to 1972 he performed research on instrument develop-North Carolina. From 1972 to 1980 he has conducted ment and internal dose of radienuclides.

research on dosimetry ofetching alphaofand neutron (fast, polycarbonate and CR-39 thermal foils, and epit irradiation, electrochemical (human and anical) and cataractogenesis of X, plutonium distribution in bone garna and neutron radiation.

Current Fields of Interest _ internal dose Health Physics, radiation protection, diagnosticradiation x-ray exposure, protection standards, from radionuclides, environmental exposure, nonionizing radiation, safe operation of the diation. nuclcar energy industry ef fects of human exposure to' low levels of ionizing ra Professional Ac tivitics , Memberships _

Member: in 1956 20 years llcalth Physics Society, First President International Cocnission on Radiological Protection,burden Chairman of for-of cc::sittee publishing values of caximum permissible body

1. '. MO,: : AN , }'ARL Z . DIOGRAPHICAL SKETCH .

], 'PIrofessional Activities , }!embe.rships (continued)

, radionuclides and maximum permissible concentration MPC in air, water and food. These serve as basis of radiation standards in all countries.

National Council on Radiation Prote: tion, Chaircan for 20 years of co=ittee publishing values which are essentially the same HPC li=its now used by NRC. -

American Association for the Advancernant of Scienc'e American Nuclear Society Radiation Research Society American Physical Society International Radiation Protection Association, First President, 1968 Fachverband fur Strahlenschutz Sigma Pi Sigma Honors:

Associate Fellow: American College of Radiology Fellou: A=erican Physical Society and A=erican Nuclear Society First President Health Physics Society in 1956 and International Radiation Protection Association, 1968 Awarded the.first gold medals for meritorious work in the field of radiatien protection by the Royal Academy of Science of Sweden in 1962 jointly with Walter Binks (England)

Distinguished Alu=ni Award and Honorary Doctor of Science Degree from Lenoir Rhyne College, 1964 and 1967, respectively Honorary =embership in Sig=a Pi Sigma, the physics honor society, frc: Berea college, 1957 First Distinguiched Service Award of the Western Chanter of the Health Physics Society, 1968 .

Distinguished Achievement Award, Health Physics Society, 1973 Honorary member of Fachverband fur Strahlenschutz,1973 -

Editer-in-Chief, Journal UCALTH PHYSICS, 1958-1977 Reports and Publicatiens ,

over 350 papers and publications have been vritten since 1930. The early enes dealt with cosmic radiation, and the later ones with health physics. Listed below arc 100 of the 200 vritten in the period 1968-1981:

1. "Comen Sources of' Hunan Exposure to Ionizing Radiation in the United States," American Engineer, July 1968.

2. "Ionizing Radiation: Denefits Versus Risks," Annual Meeting of the

' Health Physics Society, June 16-20, 1968, Denver, Colorado; and published in Health Physics, Vol. 17, No. 4.

'- - 3. "Redirecting Health Physics Studies to Areas of Greatest Interest,"

First European Congress of the International Radiaton Protection Association, Menton, France, October 9-11, 1968; Published in Proceedings, 1968.

4. "Development of Health Physics as a Profession," Proceedings of First Intctnational Congress of Radiaton Protection, Rome, Italy, Vol. 1, 3, Pergamon Press, 1968.

~.NOhGAN, KARL Z. -.

-4 DICCM?H8 CAL SKr.*:CH Major Reports and Publientions (continued) l , 5. "The Need for Standardization Procedures in the Application of Ionizing '

Radiation to Medical and Dental Patients," Seminar sponsored by the  :

National Center for Radiological }!ealth, Rockville, Maryland, November 15, 1968, Seminar Paper 003.

6. "The Proper Working Level of Radon and Its Daughter Products in the Uranium Hines of the United. States,"Illearing on Radiation Standards for Mines, Washington, D.C.i'No'vesber'20, 1968; Congressional Record,

, 1963.

7. "Supplemental Statement on the Proper Working Level of Radon and Its 1

Daughter Products in thu Uranium Mines of the USA," Supplement to 3

Testimony presented en November 20, 1968, Washington, D.C.;

Congressional Record, 1968. -

8. "Assumptions Made by the Internal Dose Committee of the International  :

Commission on Radiological Protection," Sixth Annual Meeting of the

' Cese11schaft fur Nuclearnedizin, Wiesbaden, Germany, September 26-28, 1968; published in Proceedings, 1969.

D. "Present status of Recocrnandation of the International Co==ission on I Radiological Protection, National Council on Radiation Protection I and Federal Radiation Council,"~eontained in book entitled Proeress in Nuclear Energy, Series XII, Vol. 2, Pergamon Press, 1969.

10. "Risks from Diagnostic X-Rays," Yale Scientific, Vol. XLII, No. 5 February 1969; Reprinted from _ Yale Scientifie in the Jodrnal of the

~

American Radiography Technologists, Vol. XIV, No. 4, Winter 1969. t

11. "Future Opportunities in Health Physics," Health Physics Society .

Midyear Topical Symposium, Los Angeles, California, January 29-31, e 1969. -

12. "Education, Training and Certification Requirenents of the X-Ray Technologist," A=er. Soc. of Radiological Te'chnologists, July 2, 1969.

13. "Radiation Standards for Reactor Siting," Testimony presented beforc  ;

the Joint Committee on Atomic Energy at its Hearings on Envirer ental  !

Effects of Producing Electrical Pouer, Phase 2, January 1970;

.! Congressional Record.

+

14. "Energy Pollution of the Environment," Hidyear Symposium of the Hecith ,

Physics Society, Louisville, Kentucky, January 28, 1970; Proceedings published in USPHS-BRH Series, BRH/DEP-70-26, Oct., 1970. j

15. "A Time of Challenge to the Health Physicist," Presidential Address presented before the Second International Congress on Radiaton Protection, May 8, 1970, Brighton, England; Health Physics, Vol. 20,

! May; 1971, pp. 491-498. .

16. "My opinion-You Can Drastically Cut X-Ray Exposure Below Today's Levels," Consultant, March / April, 1970.

] 17. "History of the Health Physics Society," published as part of the RSNA 3

Synposium en the Crtical History of /serican Radiology (Nov. 1970)

I 18. "Standard Man-Standard Patient," Medical Radioisotopes: Radiation Dose j and Effects, AEC Series 20, p. 87, June 1970.

l 19. "History of the International Radiation Protection Association," ,

l published in Proceedings of the RSNA Symposium on the Critical History American Radiology, November 1970.

• i i

p I

i

20. ' "Adequacy of Present Stendards of Radiation' Exposure," Environmental Affairs, 1., No. 1, April, 1971

21. "Criteria for the Control of Radioactive Effluents," IlEA Syr.posium '

on Environmental. Aspects of Nucicar Pouer Stations, UN Building,

• New York, August 1970, Proceedings published, this paper is IAIA-SM-146/10; synopsis published also in Environmental Studies, 1971.

22. -

xi=u'm Permissible I,evels of Exposurh to. Ionizing Radiation,"

'nte'rnational Summer School on Radiation Protectier..Boris Kidric In'stitute of Huelear Sciences, Cavent', Yugoslavia, September 20-30, 1970; Proceedings published in 1971 under title of "Radiation Dosimetry." .,

23. "President's, Report on the' General Assembly of IRPA," 3righton, England, May 1970, Hemith Physics, Vol. 20, No. 5, 1971. '

, 24. . ',' History of, Radiation Protection," Symposium Comemorating the 75th

, . . Anniversary of the Dis lcovery of X-Rays, Milwaukee, November 13-14, 1970; Materials Evaluation, Vol. XXIX, No. 3, March 1971.

25. "Why'the 1968 Act for Radiation Control for Health and Bafety Is

. R,equired," Radio' logy, Vol. 99, No. 3, pp. 569-5J8,. June 1971.

26. "Excessive Medical Diagnostic Exposure," Third Annual National Conf.

on Radiation Control, Scottsdale, Arizona, May 3, 1971; published in i Proceedings. '

27. "Health Physics and the Environment," International Sy=posium on Rapid Methods for Measurement of Radioactivity in the Environment,

, Neuherberg, Federal Republic of Germany, IAEA-STI/ PUB /289, Vienna, 1971. 3

28. "Adequacy of Prcsont Radiation Standards," pre: anted at the Environmental i and Ecological Forum, Silver Spring, Maryland, January 20, 1971; Proceedings of Forum published in 1972, USAEC-TIC-25857.  !

29. ."Never Do Harm," Enviernment, y , No. 1, January / February, 1971.

30. "Proper Use of Information on Organ and Body Durdens of Radioactive Material," presented at the IAEA/UHO Symposium on the Assessment of Radioactive Organ and Body Durdens, Stockholm,. Sweden, Novamber 22 .

26, 1971, IAIA/SM/150-50; Proceedings of Symposium published by IAEA.

31. "Health Physics Measures to Implement New USAIC Regulatic' tis Relating to Radiation Exposure of the'Ceneral Public," Budapest, May 1971; Proceedings published by Akademiai Kiado, Budapest, Hur. gary.

. 32. "The Need to Reduce Medical Exposure in the United States," outilne of testimony presented before the Health and Welfare Subce==.ittee of the, Senate Co.=tittee on I. abor and Public Welf are on Senate Bill S.3327, May 15, 1972, Washington, D.C.; published in Congressional Record, 1972.

33. "Comparison of Radiation Exposure of the Population from Medical Diagnosis and the Nuclear Energy Industry," Transactions AMS, 1_5_: 1, 64 (June 1972).  ;

34. "Environmental Impact of Natural and llan-Made Ionizing and Non-lenizing Radictions," Second International Sumner Schoci, on Radiation Protection, Herceg Novi, Yugoslavia, Aug. 1973; Proceedings, 1973.

35. "The Need for Radiation Protection," Radiologie Technology, 4_4_, 6,

p. 385 (1973).

36. "Exposure in the United States," and "Mogliche Folgen einer i Ubermassigen Medizinischen Strahlenbelastung in der Vereinigten Staaten von Amerikn," Rontgen-Bistter, 2_7,, 127 (March 1974). -

i O

e J

.,-e- .n,n n-. . s -.

i MORGAti, KARL Z. B10CRAPHICAL SKETCil Major Reports and Publications (continued)

37. "Reducing Medical Exposure to Ionizing Radiation," American Industrial Hygiene Journal, M , No. 5, 358 (May 1975).

38. Tuo chapter.s in text, Environmental Problems in !!edicine titled "Exposure'to Non-Ionizing Radiation" and "Ionizing Radiation Exposure," ti. D. McKee, Editor; Chas C. Thomas Publisher, 1974.

' 39. "Types of Environmental Health Physics; Data That Should be Collected and Evaluated in a !!uclear Power Program," p. 276-298, Chapter 16 in Environmental Impset Statements for Nuclear Power Plants, Eds.,

R. A. Karam and,K. Z. Morgan, 1975, Pergamon Press .

40. "The Bases for Standards and Regulations," p. 313-336, Chapter 17 in Environmental Impact Statements for Nucient Power Plants, Eds.,

R. A. Karam and K. Z. Morgan, 1975, Pergaaen Press,

41. "Release of Radioactive Materials from Ret.ctors ," p. 101-155, Chapter 5, and "Ways of Reducing Radiation Exposure in a Futuro Nuclear Power Economy," p. 155-169, Chapter 6, Nuclear Pouer Safety, Ed., J. H. Rust, and L. E. Weavor, 1976, Pergamon Press

42. "Transportation of Radioactive Material by Passenger Aircraft," Report to Joint Cor.aittee of Congrsss on Atomic Energy, Report No.1 -

Sept. 17, 1974, U.S. Covernment Printing Office.

43. "Itcalth Physics - Past, Present, and Future," presented at First Asian Regional Congress of the Inte'rnational Radiation Protection Assn. in Dombay, India, Dec. 1974; published in Proceediegs.

44. "Suggested Reduction of Pernissible Exposure to' Plutonium and Other Transuranibs Elements," J. Am. Ind. Hygiene 3_6,, 6 (8), 567 (Aug. 1975).

45. "Effects of Radiation on l!an - Now and in the Future," p. 251-262, Cost-Benefit Analysis _;

Chapter 13, in Encrcy and the Environment --

Pergemon Press, Eds., R. A. Karam and K. Z. Morgan, 1976

46. "Prograr.s Needed for Education and Training of 11ealth Physicists,"

P ro c . Arn . P hy s . Soc. Meeting, December 1974.

47. "Recent Developments in Fast Neutron Personnel Dosimetry Using Track Etch Methods," presented at Cnngress of the International Radiation Protection Assn., Holland, May 1975; published in Proceedings.

48. "Medical Radiation Protection," presented at Health Physics Meeting, Duffalo, Neu ' fork, July 15, 1975. presented

49. "Ways of Reducing Exposure in a Future Nuclear Power Econo =y,"

at tr.erican Public Health Association Annual Meeting, Chicago, Illinois , Noveciber 18, 1975.

50. "Keeping Doso Commitments ALAP," Pree. ANS !!stional Topical Meeting, 71,'rueson, Arizona, October 6-8, 1975.

51. "The Particle Probicm," Third Internat Lonal Sue =er School on Radiation Protection, Herceg Novi, Yugoslavia, published in Boris Kidric Institute Series, August-September 1976.

52. "The Linear vs. The Threshold Hypothesis," Third International Su=mer School on Radiation Protection, iterces Novi, Yugoslavia, published in Boris Kidric Institute Series, August-September, 1976.

- 53. "Current Problems and concepts of the Health Physicist," Third International Summer School on Radiation Protection, Herceg Novi, Yugoslavia, published in Boris Kidri'c Institute Series, August-September 1976.

O

~

1. ' .

!!ajor Reports and Publications (continued)

54. "Use of Recycle Plutonium in Mixed Oxidc Puel in Light Water Cooled Reactors," testimony,prosented at public hearings on MOX fuel, Washington, D.C., Nov. 1976.

55.

"A Course on Non-Ionizing Radiation Protection for State and Local

• Health Officers," Proceedings of Health Physics Society, Denver, Colorado, February, 1976.

56. "Coments on operation of the Xerr-HeCee Cinarron Facility and the Karen Silkwood Case," before the Congressional Small Business Co::n. ,

~

April 26, 1976.

57. "Data Interpretation," Proceedings of Workshop on the Utilization and Interpretation of Environmental Radiation Data, Orlando, Fla.,

March 1-3, 1976.

58. "Rolf M. Sievert: The Pioneer in the Field of Radiation Protection,"

11ecith Phys. 3 , 263-264 Sept. 1976.

59. "Health Hazards from Diagnostic and Therepeutic X-Ray," Proceedings of Conference on Diagnostic Imaging, Chicago, Ill., Sept. 27, 1976.

60. "Yes is the Answer to question of R. H. Thomas and D. D. Busick, 'Is It Really Necessary to Reduce Patient Exposure?'" J. Am. Ind.

Hygiene 37, 665-667, Nov. 1976.

61. "The Linear (typothesis of Radiatien Damage Appears to Be Non-Conservative in llany Cases," Proceedings of Fourth International Congress of the International Radiation Protection Association, Paris, France, April 25-29, 19,7.

- 62. "The Diler=x of Present Nuclear Pouer Progracs," Proc. of Hearines Before the Energy Resources Conservation and Develorment Comm.,

Sacramento; Cal., February 1, 1977.

63. "Radiation-Induced Health Effects," Science 195, 157, 344 (January 28, 1977).

64. "The Necd to Reduce Medical Diagnostic Exposure," J. Am. Ind. Hvciene

-38, 6, June 1977.

65. "Whit is the Misunderstanding All About?" Bulletin of Ato=ie Scientists 57, 56-58 (February 1979).

66. "listron Dosimetry in Iligh Energy X-Ray Beams of Medica 1' Accelerator,"

Phys . lied. Biol . 24, No. 4,756 (1979),11. Schrabi and K. Z. Morgan.

67. "Alpha Particle Track Production in Polycarbonate Foils 6plified by E1cetrochemical Etching," Mucl. Tracks 3, 185 (1980), C. B. Stillwtgen

~

, and K. Z. Morgan. '

68. "Energy Dependence of Fast Mcutron Dosimetry Using Electroche=ical Etching,"Trans. Am. Nucl. Soc. Student Conference, Cainesville, Fla.,

1978, S. J. Su and K. Z. Morgan.

69. "Should Permissible Limits for Occupational Exposure be Reduced?" Proc.

of Annual llecting of the llecith Physics Soc., Minneapolis, Minn.,

June 19, 1978. Published in Proceedings of Fourth International Suener School on Radiation Protection, Doris Kendric Institute, Belgrade, Yug., Sept. 1979.

70. "A New Polycarbonate Fast Neutron Personnel Desimeter," _Ac:er. Ind. Hygiene Assn. J. 39, 438-447 (June 197S) K. 2. Morgan and !!. Sohrabi.

71. "Purpose 2 Radiation Protection Monitoring," IAEA Symposium on Advances in Radiation Protection l!onitoring, Stockholm, Sweden, IAEA SM-206/139, 3-20, June 26-30, 1978.

!!ajor Repor2s and Publications (continued)

72. "Should Radiation Exposure. from Operation of fluelcar Power Plants be Reduced?" Dossey, Switzerland, Pub. _ Bulletin of the t!orld Council of Churches, May 2-7, 1978.

73. "Cancer and Lou Level Ionizing Radiation," The Bulletin of Atomic Scient ists , 30,-41, (September 1978).

74. "The Effect of Field Strength and Frequqncy in the E1cetrochenical Etching of Recoil Particle Tracks in Polycarbonate," Health Physics y, 894 (Dec. 1978), H. Schrabi and K. 2. Horgan.

75. "Risk of Cancer from Low Exposure to Ionizing Radiation," Symp. of the AAAS , tJashington , D'. C., Pcbruary 17, 1878.

76. "Arc the Current Standards and Guidelines for Low-Level Rcdiation Adequate to Protect Public Health?" "tJhat are the Current Standards?", Co==ents made by KZH acting as moderator.in Senate Conference, Washington, D.C. ,

Senate Office Bldg., February 10, 1978. Published in Congressional Record and Reprinted by the Environmental Policy Institute.

77. "Significance of 11uman Exposure to Low-Level Radiation," Presented be fore Congressional Hearing, Washington, D. C., January 24, 1978, published in Congressional Record.

78. "Walter S. Snyder," Fealth Physic E , 1-2 (January 1978).

79. "A Chirper Checker - Adjunct to the Use of Personal Radiation Monitors,"

llealth Physien M , 693-697 (!!ovember 1978), P. S. Stansbury and K. Z. Morgrn.

80. "Evoluating the bulk Etching Rate for Polycarbonate Foils During E1cetro-chtmical Etching," Health Physics 34, 735 (1978), C. B. Stilluagon, K. Z. Morgan, and S. J. Su.

81. "llow Dangerous is Lou Level Radiation," !!eu Scientist, April 5, 1979.

82. "Radiation-Induced Concer in Han," Congressional hearing hefetc Senator John Glenn, March 6,1979. .

03. "Decom:uissioning of the Corleben Facility," Proceedings of hearings in llannover, Germemy, April 5,1979

84. "!cutron Dosimetry Using Electrochemical Etching," Shian-Jong Su, G. 3. Stilluagon and K. 2. Morgan, Annual meetiN of Henith Physics Society, July 3, 1977.

85. "So=e New Characteristics of a Polycarbonate Fast Neutron Personnel Dosimeter," M. Schrabi and K. Z. Morgan, Am. Ind. Hygiene Society, May 16, 1976.

86. "A Rejoiner to a nejoiner on Radiation Risks," Neu Scientist, 1979.

87. "Cancer and Low-1.cvel Ionizing Radiction," IV International Su=ct School on Radia: ion Protection Proceedings, August-Septc=ber, 1979.

88. "Hazards of Lou-l.avel Radiation," 1980 edition of the Encyclopaedia Britannica. ...

89. "Education and Training of llealth Physicists, Proceedings of\Jtecith Physics Syeposium, Honolulu,llauali, December 10-13, 1979.

90. "The Recomendations of the Duracu of Radiological Hetith on How to Deal with Fallout Conta nination are not Suf ficiently Conservative,"

11calth Physice 3_S,, 432, March ,1980.

91. "Mensurement of i:cutron and Charged Particle Contamination in High Energy

!!cdical Therapy X-Ray Deams Using Recoil Track Registration in Poly-carbonate Foila," IIcalth Physics Society, Scottle, Wochington, July 23, 1980.

MORGAN, KARL Z. 510CP/.PilICAL SKETCH

92. Radiation Risks from Ducicar Power--Final Round," Neu England Journal, 303, No. 11, 645, June 9, 1980.

. .93. "Tuo Groups of Track Sizes in Polycarbonate Poils following Alpha Perticle Radiation," 11ealth Physics )_6, 741,1979.

94. "Radiation Dosimetry," Science 213, 602, August 2, 1981.

95. "Risks of Nuclear Power Plant Accidents and Consequences on Population and Biosphere," Proceedings of Colloguium on Energy and Society, Paris, Frante, September 16-18,1981, Croup 8e Bellerive, Geneve, Switzerland.

96. "Risk 4ssessment of Exposure to Ionizing Radiation--Another View," Pro-ceeJings American Nuclear Society, Miami, Florida, June 8,1931

97. "Derection of Alpha Particles Utilizing Polycarbonate Poils Processed by

.he E1cetrochemical Etching Technique," Health Physics 3_9, 751, November, 1981.

98. "Appreciation of Risks of Low-Level Radiation vs Nuclear Energy;" Co::=ents on Molecular and Cellular Biophysics 1, No. 1, 1980.

ed. "Microdosimetry of an Internally Deposited Alpha Emitter," in publication,

~

. Health Physics, 1982.

100. "Nucicar Power Plant Accidents," Annual Heeting Amer. Assoc. Advancement of Science, Washington, D.C., January 3, 1982.

lo uc .

,i # -

e A so A

[ 44 b e

4 e . ~

PROVISIONS OF 10 CFR' 50 DEFININC NUMERICAL

~

CUIDES FOR "A5 LOW AS 15 REASCMBLY ACHIEVABLE" LEVELS OF RA-DIOACTIVE MATERIALS IN LICHT WATER COOLED NUCLEAR POWER RL-ACTOR EFFLUENTS Fmposure Mode Desion Objective Liquid Effluents Dose to the total tiocy 3 ellliree/rea:ter year from all path-ays' Dose to any organ free 10 elllire p reactor year all pathways Caseous Efftvents ,

10 miittrad/ reactor year Cama Dose in air Beta Dose in air 20 millirad / reactor year Dese to the total body of ,

5 rillirem/ reactor year an indivMual Dese to the skin of an 15 ellitree/ reactor year individual ,

Radiolodines and Particulate Matter Released to the Atmosphere Dose to any organ from all pathw.tys IS zillirem/ reactor year 9

4

_I_

e Comments on Part II Title 10 Part 20 Dated January 9,1986.

Standards,for Protection Against Radiation; Proposed

Rule; Extension of Comment Period and Public& tion.

By Karl 2. Morgan March 27, 1986 I have taken a hurried look at the Federal Register, Part II NRC 10 CFR 19 et al.of Tuesday, January 9,1986 and considered this a terrible retreat of the NRC from its obligation to. protect the public from the harmful' effects of nuclear power. The NRC and EPA have finally weakened to political p,ressure a6 given second place to the health of radiation workers a , he public by adopting the Handbook 26 recommendations of the Intecnational Commission on Radiological Protection .(ICRP) .

• I was a member of ICRP for a quarter of a century but now am an' emeritus macher. During the years I was active with,ICRP I was chairman of the Internal Dose Committee that prepared ICRP-2.

1. ales I and II of presont Title 10,Part 20 are, for the most part, a cotaplete adoption of the tables of (MPC) a and (HPC)w

[maximumper*missibleconcentratfonsinairandwater) from IC RP- 2. During th,e quarter of a century I was an active member of ICRP we recognized an inconsistency in the rules by which we had set values for (HPC)a and (HPC)w, namely we set the dose rate

. . limit at 5 rem /y for both the total body and the gonads. It

~

o .

, l

~.:.., , -

see'med obvious th'at if the whole body, including the. gonads, got 5 rem /y the dose allowed to the gonads alone would be greater. I suggested the solution was very simple,viz. reduce the limit to whole body to 2.5 rem /y. Ur/ettunately, after I retired from active membership in ICRP, ? M :/ Aoved in the other direction and kept the 5 rem /y for' whol:bcdy and raised the dose limits to all ,

other organs. In this reckless move, ICRP jumped.from the frying pa'n into the fire' because with other modificatic ~ ~ the dose rates to the thyroid and bone became 167 rem /y instead - ;tue p.avious 30 rem /y and ICRP realized that this could cause radiation sickness in employees.. Thus, to save face, ICEP picked the number 50 rem /y out of thin air as the limiting dose rate for these two organs. I took a look at some of the radionuclides of major interert in the nuclear industry (28 altogether) and found that in about half the cases the proposed values of (HPC)a and (KPC)w were increased in the January 9,1986 NRC Title 10 Part 20 tables for occupational exposure using ICRP-2 6 recommendations. All the values are not increased becauso of other changes brought on by ICRP-26, e.g. here the doso to a i . . ,

critical organ is determined I not only by ~ the amount of .

radionuclide in this organ but also by the additional dose from i

the radionuclide deposited in adjacent body organs.

During the past few years I have met with members of l'EC

o>-

l

• twice trying to convince them that this was not an appropriate l t

i

.m , . - - , - _ , , _ , -,-.--.r-.-,.-,.,-,y- - , - ,,p- -

_,y- , - . - . - , . - - _ ,. --

?,o .),

>=.. * --

. e * -

e- ,

time to increase values of- MPC because the prosent ICRP-2 was publ,ished in 1,959 and today we know that the risk of ,

radiation-induced cancer'is more than ten times what we believed it to be in 1959. I, along with R.E. Alexander of the NRCj urged we adopt the ICRP-26 values when they were lower than the ICRP-2 or Title 10 Part 20' values but otherwise we keep the present values.

The newly proposed values of January 9, 1986 are not only higher than present values in at least 50% of the cases but the values are not given directly; in s te 4*S they are given in an obsure and surreptitious manner. Vn iar:% of Annual Limit on

Intake (ALI) and Derived Air Concentration (DAC) are given instead of (MPC)w and (HPC)a. I can't help but believe 'this choice was made only as a coverup or ,to make it more dif ficult for the radiation worker and menbers of the public to reali

e that at a time when the Maximum Permicsible Concentrations of .

radionuclides in air, water and food should be reduced by at least a factor of 10 they are being increased. In practice the health physicis't br radiation worker will never use ALI or DAC but must convert them to (HPC)w and (MPC)a respectively.

.~ o In'the attached table we have for radiation workers',

e--

(MPC) w=3. 04 x / E-6 (ALI) oral microcuries/cc and

- ~

_4 (MPC) a= 4.17 x 10 E-10 (ALI)inhal microcuries/cc.

1

~ -

~~ The values of (MPC)a and (KPC)w for members of the public should be 1/30 of the above occupational values except when the whole body is the critical organ. In this case the values for 1

l public are 1/100 the occupational values in order to reduce the genetic risk. l There are many'other ways in which the January 9, 1986 proposed changes of Titla 10 Part 20 are a serious regression and a political concession to the nuclear industry at the expense of l

l the workers and public in terms of a greater' somatic, teratogenic and genetic risk.

It is unfortunate that the Government Agencies we have set up to protect the public so consistently come to believe their mission is to protect big business. We have numerous examples of this. For example, the Veterans Administration is not offering help and compensation to'the servicemen who, in the line of duty, have suffered,ra,diation damage. Even in the early period we have i

a good example. When, in about 1960, i t was shown that uranium miners in the Color' ado Plateau were dying of lung cancer from radon levels higher than those. in Bohemia and Schneebcorg, Saxony

, 500 years earlier, the AEC, PHS and FRC, fought against redu'cing L_ . _ - , -.

- _ - - _ _ . - A

y- - 3

. '. /,

, . I. ./

. 4

.. 5 e

the Radon-222 level in uranium min ~es to the value given in

^

ICRP-2. Finally, an. honest man show%'d e up in, Washington, Secretary of Labor (1962-69), Mr. W.W. Wirtz,,and he unilateraly adopted the ICRP-2 value of 0.3 WL (working level) or 4 WLM/y.

, 1 e

I hope it is not .too late f,or NRC .and EPA to recant its '

crayfish posture and consider 'the need to, reduce the .value's of' MPC rat!her than increase them. -

. (

W 6

e .

0 5 #

9 ' ,

• 9 6

4 g

's e /

C- ,e-g -- -.

-, -,,----y. , , , - - - . , , ,-- , . - , - - - - - - , - - -

MX1 HUN PERMISSIBLE COMCENTRATIONS OF RADIONUCLIOES '

In Microcuries Per Cubic Centimeter (pCi/cc) q --- _-

____-_.-w -

1 OCCUPATIONAL EXPOSURES  ; ;. ,

I AIR I WATER EXPOSURES TO CENERAL PUCLIC  !

sotope !! ICRP_-2 1 10CFR20 l ICRP-2 AIR I WA TER I

>241 ll 6E-12 l 2E-12

; 1 10CFR20. ,I,.;l ._IC_RP-2 q.-

1 10CFR20 l ICRP-2 1 10CFR20 ll 1E-4 ,

u-198 ll 3E-7 l (2E-6 X' l

2E-3 3.6E-6 ll 7E-14 2E-14 1 1E-6 ,

3E-8 ll 11 I"(7E-7 X 3. 6E-3'4! ! 3E-9<" ;. (3E-9 I 2E-5 a-140 1 1E-7  ! 6 E-7 >< .

! H .

Il I"(2E-9 '

J --

?!

e-7 1 6E-6 8E-4 '

1.8E-3M  ! 1E-9 2E-9 X

! II b-58 I BE-6 X i' SE-2 1.5E-1XI 2E-8 l IE-5 7E-6 i

.BE-7 1 (4E-7 4E-3 l 3E-8 '4 7E-4 6E-4 I"(3E-7 1 3.6E-3 3E-9  ! (2E-9 l 3E-5 1

o-60 1 2E-5 -

1 i 3E-7 I (BE-8 IE-3 i 7.3E-4

~(IE-9: 1

!"(1E-8

,1 1E-9 (2E-10 1 1E-5 3E-6 i s-134 L 4E-8 l' 4E-8  ;

l l"(SE-11 1 5-137 3E-4 2.5E-4 1E-10 I b-59

I 6E-8 I 6E-8 I 4E-4 3.6E-4 il 2E-10 1 ,

1E-10 1 9E-7 9E-7  !

2E-10 11 1E-7 ' 1 (IE-7 1 2E-3 1 l 2E-6 1E-6 1.

l L

2.9E-3XQl 7E-10 l (SE-9 % 1 2E-5  !1E-5 3 ~(2E-7 X l  !!

l' SE-6 3E-5 X i ,1 E ~(7E-10 1 2.9E-1X  !

129 l'2E-9 2E-8 7E-8 X 3E-4 L>131 i SE-9 l 4E-9%- 1E-5  ! 1. 8E-5 X 2E-11 1 1E-3 X l 4E-11 >

2E-88 6E-5 1.1 E-4 X 1E-7 3E-7 X  !

' 85

i. 1E-5 1E-10 l 2E-10 X 7E-7 1E-6 X

!! 1E-7 l

)-237 I: 4E-12 1 2E-12 .

>-210 11'. 1E-10 ! 1E-10 1E-4 lX ? ' IIE-5 1 2.5E-7 .! 3E-14 1 l 7E-7 X l 2E-14 1E-6 I --

>-110 -11 5E-10 1 3E-10 4E-6 I 2.2E-6 ll IE-12 1 4E-13 I 1 2E-9 ll 2E-5 1 1E-8 1E-8  !!

t-238 l' 2E-12 1: 1.1E-5 11 7E-12 I 9E-13 l 2E-7...?

(3E-12x 1E-4 2.5E-5 l 4E-8 l f(7E-12 X 2E-14 I (2E-14 2E-6 1-239' 11 l, i 2E-7  !!

2E-12 i (2E-12 l 1E-4 1 2.2E-5 11 2E-14 i

il

!! l'(6E-12x! '1  ! (2E-14 1 2E-6 l 1E-7 il i-240 l 2E-12 (2E-12 s 11 -

1 1 1E-4 l 2.2E-5 !! 2t-14 l,(2E-14 l 2E-6 I

11 11 ~(6E-12x !  !  !!  ! IE-7 1-226 3E-11  ! ((

t-106 1.1 3E-10)( ! 4E.7 1 7.3E-6xt ' 2E-13 9E-13X i

si "l 8E-8 '

(4E-8 '

4E-4 2E-9 7E-8MLj.

L-(5g-9 1 7. 3E-4 XI ,

1E-9 (IE-10  ; 3E-6 3E-6 l l  ;

- 89 11 3E.8 D (4E-7 g j 3E-4 " L~{2E-11 0 11 '

1.8E-3xl" 3E-10  ! (IE-9 X 3E-S l i

.-90 ~ ( 6 E -8)( l i I~(2E-10 6E-6X iill 11 1E-9 (BE-9 X i 1E-5 i

1.1E-4sl 7E-12 i (3E-11% 7E-8  : 4E-7,K ll

~(2E-9 X i

-99 e i 2E-6 (2E-6 1E 2 ~{SE-12 -

i 1.5E-2 1 2E-8 (SE-9 X IE-4 l -(3E-7 6E-5

.-232 1, 2E-12 (SE-13 I

SE-5

. .ll l'(9E-10 '

? II I

I 1

2.5E-6 ll 2E-14 l (4E-15 7E-7 3E-8

~(1E-12 1 835 1 SE-10 (6E-10x! I

$E.-4 3.6E-5 l 6E-12 (3E-12 ei 238 11  !"(2E-11 "

11  !"(6E-14 1E-5 1 3E-7 il 11 lg 7E-11 1 (6E-10X ! 1E-3 3.6E-5 !! 1E-12 .I (3E-12 xi L l il

-95 l'( 2 E-11 i li 1"(6E-14 1E-5 l 3E-7 il 11 1E-7 I (SE-8 . l. 2F-3 l l  !!

g I 3. 6E-3 xi l 4E-10 l (4E-10 l- 2E-5 "t1E-7 I r 2E-5 i l, 1

I

. I FR 20: (MPC)w = 3.64E-6(ALI)w (MPC)a = 4.17E-10(ALI)a

-2: (MPC)a' and val ue s occu Ka se.pa tional orkersw(MPC)w exceot wh 1/30 of values for

. reduction factor is 1/100.en for Neber radionuclide s of is the . gonad

& public a're exposure problem, in wh ce: X.2i' Morgan, February 13, 1986. 7% x Waca.teun increase

?

EXHIBIT B AFFADAVIT OF DR K.Z. MORGAN IN SUPPORT OF CONIENTIONS 1,3,4,5 u

J l- This document which contains Dr Morgan's original caments on the l EIS, Supplement #2,is supplied as the original was handwritten and when

~ published was not easily readible.  ;

l.  ;

[

s J

6 Y-Comments Relative to Treatment and Disposal of 2,100,000 gal, of Contaminated Water at TMI-2 by Karl Z. Norgan March 19, 1987 Qualifications to Express an Opinion 1 - So far as I can determine I am the first person to publish a paper showing how to calculate dose from internal exposure to ionizing radiation and set standards of MPC (' Tolerance Concentration of Radioactive Substances," by K.Z.

Morgan, J. Phys. & Colloid Chem. 51, 984, 1947).

2 - I was chairman of the Internal Dose Committees of both ICRP and NCRP for about two decades.  ;

3 - I have worked with and researched ionizing radiation and health physics problems for over 50 years.

Materials Reviewed in Preparing These Comments 1 - NUREG-0683 Sup. No. 2 (draft report) 2 - GPU Nuclear Corp. 'ttachment 4410 ; L-0023 3 - GPU Nuclear Corp. Attachments 4410-86-L-0178 4 - NCRP Commentary No. 4, "Guidelines for the Release of Waste Water from Nuclear Facilities with Special Reference to the Public Health Significance of the Proposed Release of Treated Waste Waters at TMI," 1987 Comments My comments are very brief because I have been able to spend only two days on this review.

l .

l l

1

i Comments on NCRP-Comm. No. 4 Report I beli, eve that although the task group that prepared this report contained some experts in the area of radioactive waste disposal (e.g. F. L. Parker, J. W.

Healy and D. G. Jacobs), the final conclusions should not be accepted in the de-cision to dispose of the radioactive water by the methods proposed by GPU without some modifications. I agree with their conclusion that after evaporation the vapor should not be released up the 50 meter stack but pumped to the 11,000 gal.

condensate test tanks. Discharging the condensate via mixing with the 22,000 gal per minute blow down water from the draft cooling tower is far better than direct discharge to the river but I am opposed to this method of disposal. I 0

urge that, rather, investigation be made of disposal of the 2.1 x 10 gal. of water by one of the following methods listed in decreasing order of preference.

1 - Load the v.;ter (condensed vapor) into tank cars and ship and transload on a boat for disposal at sea. This would provide a far more rapid means of dilution. This method of sea disposal should receive no serious challenge by those concerned with our International Agreements Regarding Sea Disposal because of the relatively low level of radio-activity and predominance of H-3. Using this method of disposal the insult to the marine envirorment and to man would be orders of mag-nitude less than those posed by the English operations near Seascale where they discharge radioactive waste into the Idah Sea. The shipment of the 420 carloads using 5,000 gal. tank cars should present no seri-ous risks.

2 - Load the water (condensed vapor) in 5,000 gal, tank cars and send to a site prepared to dispose of the water by deep-well injection. Con-0ne of these is that of the London Dumping Convention, IMO-198.

i i

2 b _ .

~

Y sidering there will be very little solid material in this condensate, deep-well disposal is made to order.

3 - Dispose of the water (condensed vapor) by shipping in 5,000 gal, ta,nk cars to a site prepared to dispose of it by the hydrofracture method.

Comments on the NUREG-0683 Sup. No. 2 Report and the Two GPU Attachments These reports as well as the NCRP report underestimate throughout the dis-cussions the dose to the individual (rems) and the population dose (person rems).

The NCRP report is doubly at fault in that it uses values of e (the cancer coef-

~

ficient = cancers (either-incidence or mortality) = 10 cancers /personrem) which I and many others in this field believe is low at least by an order of

~3 magnitude, i.e. the value should be no less than 10 cancer deaths per person rem. (See the chapter, p. 216-229, in the Encyclopaedia Britanica, "Hazards of low-Level Radiation," by K.Z. Norgan. Copy attached.)

This NUREG report gives a table No. 2.5 of the NRC concentrations in air and water (above background) that are acceptable in restricted areas. Below I re-produce the first and third columns from this table but add the EPA values I calculate that are based on the EPA limit of 4 mrems/y to the total body for drinking water. Values are not given by EPA for bone so in this table I increased l

the value for bone from 4 mrem per year (for total body) to (30/5) y 4 = 24 mrem /y because the ICRP-2 limit for occupational exposure of bone is 30 rem /y and the l

limitfortotalbodyis5 rem /y.

Isotope Water Activity Water Activity Limit of NRC (uCi/ce) Limit of EPA (uCi/cc)

H-3 S -T B 3 x 10-5

-5 2.4 x 10

I 3 x 10 ,,

Sub -- .-

3

_ _ _ ._ . . _ _ __ - ~ . . . _ _ _ . .

7 Isotope Water Activity Water Limit Activity of NRC (uCi /cc) Limit of EPA (uCi/ce)

Cs-137 S-TB 2 x 10

-5 1.6 x 10-7 I- 4 x 10 ,,

Sr-90 S-B

-7 3 x 10 -5 3.2 x 10 -9 I 4 x 10 ,,

S = Soluble, I = Insoluble, TB = Total Body, B = Bone Here it is noted there is essential agreement for H-3 but the NRC value is 125 times the EPA value for Cs-137 and 12,500 times the equivalent value for Sr-90.

When two Government Agencies differ to such extremes in evaluating an en-vironmental risk, I believe the peoples' court, DA, in the interest of safety, should insist the more conservative agency and the one in this case established to protect man and his environment, takes precedence.

Next, I took a quick look at Tables 2.2 and 2.3 in NUREG-0683 Sup. No. 2 and the tables in the two GPU Attachments. The data in these tables were some-what surprising. Below in columns 2 and 3 (1st two items) I give data from these tables. Where the values in these reports differed, I entered in column 2 the value that was published last. I derived equations (see Appendix) and made a number of calculations (having available only a hand calculator) and entered some of the results in the above table. All the values are for the adult (standard or reference man). The doses in most cases would have been considerably larger for the child but I have not had time to make these calculations. The dose values marked (a) given in NUREG should check with my calculated values of dose marked (b) but it will be noted two of my values,14 mrem for H-3 and 3,680 mrem for Sr-90, are larger than the NUREG values that are 7.8 mrem for H-3 and 960 mrem for Sr-90. My value of 1.6 mrem for Cs-137 is lower than the NUREG value of 2.6 mram. These differences should be investigated.

4

[

Radionuclide, (f ,and Base Case Achievable Values (Effective Half g)fe)

Li H-3-(fy=1) (10 days in total body)

Activity, (pci/cc) 0.13 0.13 Dose Estimates (mrem)

NUREG-0683-2 7.8 TB 7.8 mrem TB One year dose from continuous exposure 10,600 TB 70 year dose from continuous exposure 7.7 y 10 5 TB Do,se from 1 day's intake of 103 cc water 14(b) TB Dose from 1 day's intake of 2,200 cc water / day 30 TB 1

Cs-137 (f y=1) (70 days in total body)

-5 Activity (pCi/cc) 3.7 X 10 4.0 x 10-

' Dose Estimates (mrem)

NUREG-0683-2 2.6 TB, 3.0 B 0.29 TB, 0.32 B One year dose from continuous exposure 947 TB -

sa 70 year dose from continuous exposure TB Dose from 1 day's intake of 1,000 cc wa,ter 90, 1.6 g TB Dose from 1 day's intake of 2,200 cc water 3.6 TB

] Sr-90 (fy=0.09) (17.53 years in bone)

Activity ( Ci/cc) 1.1 X 10- 1.0 x 10 '

Dose Estimates (mrem)

NUREG-0683-2 960 B, 19 TB 87 B, 1.8 TB J One year dose from continuous exposure 57,600 B j 70 year dose from continuous exposure 137,000 000 B

Dose from 1 day's intake of 1,000 cc water 3,680(bj B Doso from 1 day's intake of 2,200 cc water 8,090 B i i i

1 i

( ..

Radionuclide, (f ), and Base Case Achievable Values (Effective Half gLife)

Ru-106 (fg=0.03) (7.2 days in kidney) ,

Activity ( Ci/cc) < 3.1 X 10~

Dose Estimates (mrem)

NUREG-0683-2 -- --

One year dose from continuous exposure < 12 K 70 year dose from continuous exposure < 830 K

, Dose from 1 day's intake of 1,000 cc water < 0.015 K Dose from *. d- intake of 2,200 cc of water < 0.032 K Dose er suol) I'om 1 year's continuous exposure < 47 GIT ca-144 (fg =3 x 10 ) (268 days in bone)

Activity (WCi/cc) < 1.8 X 10-Dose Estimates (mrem)

NUREG-0683-2 -- --

One year dose from continuous exposure < 2.7 B os 70 year dose from continuous exposure < 532 B Dose from 1 day's intake of 1,000 cc of water < 0.010 B

, Dose from 1 day's intake of 2,200 cc of water < 0.021 B j Dose to GIT (LLI) from 1 year's continuous exposure < 27 GIT j Co-60 (f g=0.3) (9.5 days in total body)

~7 Activity (pCi/cc) GPU 4.8 x 10 Dose Estimates (mrem)

NUREG-0683-2 -- --

One year dose from continuous exposure 1.67 TB 70 year dose from continuous exposure 122 TB

Dose from 1 day's intake of 1,000 cc of water 0.002 TB Dose from 1 day's intake of 2,200 cc of water 0.005 TB

. Dose to GIT (LLI) from 1 year's continuous exposure 1.44 GIT t

P

e .

Radionuclide, (f , and Base Case Achievable Values (Effective Half Y)ife) .

Pu-239'(fg=3 x 10-5) (72,000 days in bone)

Activity (pCi/cc) GPU < 1.4 x 10~ B Dose Estimates (mrem)

NUREG-0683-2 -- --

One year dose from continuous exposure < 0.24 B 70 year dose from continuous exposure < 1,098 B-Dose from 1 day's intake of 1,000 cc of water < 0.17 B Dose from 1 day's intake of 2,200 cc of water < 0.38 B Dose to G1T (LLI) from 1 year's continuous exposure < 0.07 G1T ,

TB = total body B = bone K = kidney GIT (LLI) = gastro-intestinal tract (lower largs intestine) e

9 These values are for an intake of 1,000 cc of the processed water. I don't know why the NRC staff used only one intake of 1,000 cc. The standard man-con-sumes 2,200 cc per day, so I made these calculations obtaining 30 mrua for H 3 and 3.6 mrem to total body from Cs-137. Note that these values of one day's intake should'be compared with the EPA limit of 4 mrem for drinking water. The cquivalent EPA values for bone and kidney are (30/5) x 4 = 24 mrem and (15/5) x 4

= 12 mram where 30 rem /y, 5 rem /y and 15 rem /y are the limiting dose rates for bone, total body and k'idney, respectively, for the occupational worker.

I looked at three radionuclides, Sr-90, Cc-144 and Pu-239 for which bone is often the critical body organ. Here it is noted that the values for Sr-90 (3,680 mrem from 1 day's intake of 1,000 cc or 8,090 mrem for 1 day's intake of 2,200 cc far exceed the EPA equivalent limit of 24 mrem per year and most of this dose is in the first year after intake. The GPU provides no data for ac-tivities of Ru-106, Ce-144 or Pu-239 but their limit of detection is adequate for a single intake of 1,000 cc or 2,200 cc (i.e. 0.015 mrem and 0.032 mrem are

< 12 mram and 0.01 mrem, 0.021 mrem, 0.17 mrem and 0.38 mrem are leas than the 24 mrem / year bone dose limit) .

It seems to me that an evaluation of the dose from one day's intake of 1,000 cc or 2,200 cc of processed water does not strike at the more meaningful svaluation of continuous intake of the processed water. For continuous intake l

for one year the doses are 10,600 mrem for H-3, 947 mrem for Cs-137, 57,600 mrem I

l for Sr-90, < 12 mrem for Ru-106, < 2.7 mrem for Ce-144, < 1.67 mrem for Co-60 and < 0.24 mrem for Pu-239. Were a standard man to consume this water for 70

( years at the projected level of contamination at discharge, the doses would be 770,000 mrem for H-3, 90,300 mrem for Cs-137, 137,000,000 mrem for Sr-90, < 830 mrem for Ru-106, < 532 mrem for Ce-144, 122 mrem for Co-60 and < 1,098 mrem for Pu-239. Thus it is seen that levels below the limit of GPU detection would be far in excess of a safe dose for consumption of the water for 70 years.

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