ML20205E502

Licensee Rebuttal Testimony of Ji Fabrikant on Health Effects of Tritium (Contention 5d).* Related Correspondence

ML20205E502
Person / Time
Site:	Three Mile Island
Issue date:	10/24/1988
From:	Fabrikant J GENERAL PUBLIC UTILITIES CORP.
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References
OLA, NUDOCS 8810270400
Download: ML20205E502 (12)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

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

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

Station, Unit 2) )

LICENSEE'S REBUTTAL TESTIMONY OF DR. JACOB I. FABRIKANT ON THE HEALTH EFFECTS OF TRITIUM (CONTENTION Sd) i SSk2$0000OS00f80 0

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Q.1. Dr. Fabrikant, whet it the purpose of this testimony?

A.12 I am straitting this testimony in rebuttal to certain statements made in Joint Intervenors' prefiled testimony entitled "Affidavit of Dr. Charles W. Huver (Contention 5): Furtber Considerations of the Biological Effects and Mealth Hazards of Tritium," dated October 10, 1988, and "Third Set of Comments Relative to Treatment and Disposal of 2,100,000 Gal. of Contaminated Water at TMI-2 by Karl Z. Morgan" dated September

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30, 1988.

Q.2. Does Dr. Huver's or Dr. Morgan's testimony change any of the statements or opinions in your direct testimony?

A.2. No.

1 Q.3. In his testimony, Dr. Huver refers to a paper by carr .

and Nolan (1979). Please comment on this article.

A.3. The article' describes a 1977 atudy, which is in complete accord with my direct testimony. The 1977 study involved the acute uptake of single injections of tritiated l thymidine (1 to 20 uCi/g body weight) and tritiated water (10 to 40 uC1/g body weight) in the male mouse, and the biological end point evaluated was testis mass loss. Evidence indicates that j the mouse is more radiosensitive than humans for the end point studied; the mouse testis is a particularly radiosensitive organ.

The 10 to 40 uCi/g dosages of tritiated water delivered doses from about il to 58 rads respectively to the mouse testis. Tr.e 1

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total dose to the testis per injected microcurie of tritium as tritiated thymidine was estimated to be about 2.4 times greater than that of tritium from tritiated water.

Carr and Nolan found that tritiated water was about 3.3 to 4 times less effective in causing an integrated fractional testis mass loss than tritiated thymidine, but in both cases there was complete recovery after exposure. Carr and Nolan also compared the effect of tritiated thymidine and tritiated water with Co-60 gamma irradiation and measured RBE values of 2.07 and 1.43, respectively. They added tb ofter correction of the RBE for Co-60 gamma radiation, a '-

ct RBE for tritium beta particles relative to x-rays is likely to be nearer to unity. . . ." Carr and Nolan concluded that on an absorbed-dose basis, tritium incorporated into DNA is only twice as effective as tritium distributed unifc'emly thrcughout tissues. They stated, "It appears . . .

that within the limits discussed . . .

the radiotoxicity of tritium is predictable from the known effects of external radiation" and "[S)uspicion that tritium incorporatad into ganetic material DNA might be extremely hazardous has been denied."

Q.4. Dr. Huver cites Dobson and Kwan (1976) for the proposition that "the RBE . .

. of tritium compared to gamma radiation varied inversely with dose (at gamma ray doses of 40 rads it was 1.0 while at gamma ray doses of a few rads the RBE of

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tritium rises to approximately 3)." Please comment on this statement.

A.4. The reference radiation used by Dobson and Kwan was Co-60 gamma radiation at very low dose rates (1 to 3.2 rads / day),

and the RBE for Co-60 gamma radiation in relation to the standard 200 kVp x-radiation decreases with dose rate. Dewey et al.

(1965) reported that the RBE of Co-60 gamma radiation at 1.5 rads / hour relative to 200 kVp x-rays ranged from 0.29 to 0.61.

dCRP 63 considered Dobson and Kwan (1976), as well as Dobson and Cooper (1974) which is also cited by Dr. Huver, and concluded that "an analysis of the dose-response curve from 3 H and from gamma rays indicated that the increase in RBE of 3 H in this -

experiment can be ascribed to a reduced effectiveness of gamma rays in the lov dose region (Bond, 1978)."

Q.5. On the fourth page of his testimony, Dr. Huver refers to a study by Abbott and Mix (1979). Please comment on this study.

A.5. Abbott and Mix studied the effect of tritiated sea water on the molting of barnacle embryos (an index of normal  :

barnacle development). The invertebrate biological system and endpoint examined are so far removed from human response and potential health effects that the results obtained must be considered irrelevant to the human situation. In particular, Abbott and Mix noted that because of the "mosaic" pattern of

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development of the barnacle (coupled with the long exposure),

"(t]he loss of early cells often cannot be compensated for as it is in vertebrates; hence cellular damage in the population of embryos is more likely to be detectable." There were also some significant experimen.tal problems encountered by Abbott and Mix.

Some unknown factor caused molting failure in almost 50% of the barnacle embryos, including the controls not exposed to tritiated water. The group exposed to tritiated sea water in the lowest concentration in fact exhibited less molting failure than the controin. The authors concluded, "It is probable that some aspect of the culturing technique induced stress on the larvae, thereby increasing their radiosensitivity." They were unable to t reach any meaningful conclusions regarding mechanisms of l

radiation damage. '

Q.6. Dr. Huver refers on thr; sixth page of his testimony to a study by Moskalev el al. (1973). please comment on this study.

A.6. This was a study of rats injected with tritiated water in quantities of 0.15 to 3.0 mci /g body veight, resulting in l total body doses of hundreds to thousands of rads -- very acute I

i doses in the lethal range. The dose causing a 50% decrease in leukocyte count, for example, was 224 rads. Splenic and thymic veights were exanined after doses as high as about 1100 to 1700 rads. These massive radiation doses were compared with Cs-137 gamma radiation to establish RBE values with lethality and other

i acute effects as endpoints. Cs-137 gamma radiation is relatively less effective than the standard reference radiation of 200 kVp x-rays. The range of RBE values for tritium reported at very high doses in this experiment were 1.34 - 1.35 for lethality; and 1.45 - 1.93 for response in peripheral blood and thymic and

splenic weights. Even if one ignores the fact that the doses and i

biological endpoints examined do not apply to the evaporation of AGW, the experimental values reported are immaterial in view of J

the Q value of 1.7 used in GPUN's dose modeling.

Q.7. Dr. Morgan, at page 4 of his testimony, provides a

table entitled "Comparative values of Risk." This table purports 9 to show risk factors ascribed to "Recent Japanese Stadtes" that are higher than previous estimates. Is this table correct?

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A.7. The risk estimates ascribed to recent studies of the Japanese atomic bomb survivors are presumably based on Preston and Pierce (1987, 1988), though Preston and Pierce did not present risk estimates in the manner depicted in Dr. Morgan's

{ table. Preston and Pierce (1987, 1988) was a preliminary j presentation of the effects of the DS86 dosimetry on cancer risk I

estimates in the Japanese atomic bomb survivors, and the discussion of risk estimates in this paper was based on a number i

of broad assumptions to permit the authors to discuss some of the a

possible implications of the emerging new data. They were not based on the actual individual radiation dose revisions in 1

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4 Hiroshima and Nagasaki, nor on the new data of cancer mortality now available. Accordingly, Preston and Pierce's paper does not contain precisely quantified risk estimates upon which radiation protection guidance may be appropriately based. That task is currently being undertaken by the UNSCEAR Committee and the 1988 BEIR V Committee, based on the subsequent, more precisely quantified data presented in the Radiation Effects Research Foundation's (RERF) Technical Report 12-87 and other current epidemiologicaldataavailable. The data in RERF TR 12-87 supports an increase in the excess relative risk of cancer at various sites ranging from 1.35 to 1.51, and an increase in absolute risk of 1.38 to 1.61 fold under the DS86 system (as compared with the T65D system).

UNSCEAR 1988 is just completing its re-evaluation of radiation-associated cancer risk estimates, taking into account the new DSB6 dosimetry. For high dose, high dose-rate radiation, UNSCEAR has arrived at total or lifetime cancer risk estimates of 4.5 x 10~4 per rem using the absolute model and 7 x 10~4 per rem using the relative model. This estimate compares with the Committee's 1977 assessment of 2.5 x 10-4 per rem using the absolute model for high dose, high dose-rate exposures. Cancer risks at low doses and low dose-rates would be less due to the dose-rate reduction factor of between 2 and 10, as reported in NCRP Report 64. In 1977, UNSCEAR used 2 as its dose reduction factor to arrive at a risk estimate for low dose, low dose-rate I

I radiation. Assuming UNSCEAR again applies a DREF of 2 to its '

current high dose-rate estimates, risk estimates of 2.25 x 10-4 per rem (absolute method) and 3.5 x 10-4 per rem (relative method) would be derived for low dose, low dose-rate exposures.

The 1988 BEIR V reassessment is due to be published at the end of this year, but it too is concluding that the new Japanese dosimetry increases the site-specific risk estimates only slightly -- in the range of about 1.4 to 1.7 and much less than a factor 2.

Q.8. Will the ICRP examine the radiation-associated cancer risk estimates now that reassessment of the Japanese dosimetry is available?

A.B. Yes, the ICRP is examining radiation-associated cancer

. risk estimates and other factors such as genetic and teratogenic risks.

The ICRP intends to issue recommendations after the UNSCEAR Committee and others complete comprehensive evaluations of the current epidemiological information. The ICRP issued a statement at the end of its 1987 annual meeting, however, observing that "under the new 'DS86' dosimetry this increase in risk is reported as being by a factor of about 1.4 compared with the risks that would have been estimated by the former 'T65D' dosimetry." At the time of this meeting, the ICRP considered this information to be too sparse and preliminary to warrant any consideration for an immediate change in the dose limits for

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occupational exposure until thorough scientific evaluations have been concluded on which to base guidance for recommendations.

Q.9. Has the United Kingdom reduced its permissible occupational dose limits as Dr. Morgan states?

A.9. No. The National Radiological Protection Board (NRPB),

1 which is an advisory body, has recommended an interim reduction pending the evaluations of radiation associated risk estimates by the current ICRP and UNSCEAR Committees. However, only the Health and Safety Executive of the United Kingdom has the authority to effect such a change, and to date the NRPB's interim recommendation has not been adopted. The NRPB has stated that it vill give "formal" advice when UNSCEAR has published its conclusions and ICRP has issued its recommendations.

Q.10. Are the third and fourth pages of Appendix C to Dr.

Morgan's testimony the recommendations and conclusions of the NRPB7 A.10. No, they are not a part of NRPB-GS9. I believe these pages are from a British Friends of the Earth petition which was submitted to the ICRP and which I recall reviewing at the ICRP's 1987 annual meeting. The body of the text of the NRPB recommendation (NRPB-GS9), some 7 pages of scientific explanation, are missing from Dr. Morgan's Appendix C.

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References Abbott, D., and Mix, M., "Radiation Effects of Tritiated Seava-ter in Development of the Goose Barnacle, Pollicipes Pozymerus," 36 Health Phys. 283 (1979).

Bond, V.P., Meinhold, C., and Rossi, H., "Lov dose RBE and Q for X-ray Compared to Gamma-Ray Radiations," 34 Hea:th Phys. 433 (1978).

Carr, T., and Nolan, J., "Testis Mass Loss in the House Induced by Tritiated Thymidine, Tritiated Water, and Co-60 Gamma I' radiation," 36 Health Phys. 135 (1979).

Dobson, R., and Cooper, M., "Tritium Toxicity: Effect of Low-Level of TOH Exposure on Developing Female Germ Cells in the House," 58 Radiat. Res. 91 (1974).

Dobson, R., and Kvan, T., "The RBE of Tritium Radiation Measured in House Occytes: Increase at Low Exposure Levels," 66 Radiat. Res. 615 (1976).

Moskalev, Y., Zhuravelov, V., Istomina, A., Petrovich, I., and Kazbekova, D., "Relative Biological Effectiveness of Tritium," in "Tritium," A. Moghiss, and M. Cr**cr, eds. .

(1973).

Preston, D., and Pie'rce, A., "The Effects of Changes in Dosimetry on Cancer Mortality Risk Estimates in the Atomic Bomb Survi-vors," Radiation Effects Research Foundation Technical Report 9-87 (1987).

Preston, D., and Pierce, A., "The Effects of Changes in Dosimetry on Cancer Mortality Risk Estimates in the Atomic Bomb Survi-vors," 114 Radiat. Res. 437 (1988).

Shimizu, Y., Kato, H., Schull, W., Preston, D., Fujita, S., and Pierce, D., "Life Span Study Report 11, Part 1, Comparison of Risk Coefficients for Site-Specific Cancer Mortality Based on the DS86 and T65DR Shielded Kerma and Organ Dosas,"

Radiation Effects Research Foundation Technical Report 12-87 (1987).

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1 WILLIAM W. WEAVER , 7, ,7 . g u p. - c

'83 CCT 25 P5 :33 We. a

. i)0N % .. (i; eeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeeegesseeeeeeeee RELEVANT WORK EXPERIENCE Self-Emoloyed Consultant 1987 to present On-Site Consultant et Three Mlle leland. Safety Review Group quellfled. Member of Emergency Response team. Alternate Special Nuclear Material Coordinate. Work ecope includes developing a PRA for Unit 2 and Chapter 15 accidente for BAR submittel. Performed multi-ettribute declelon theory analysis on block well disposition dociolon.

Babcock G Wilcox ,

1983 to 1988 On-Site PRA/ Reliability Cenaultant at Three Mlle leland. Member of emergency response team. Alternese Special Nuclear Meteriale Coordinator. Work scope included analyalne leeues (W a probabillotic perspective) on a case-by-case basis such as exemptioa>-from solemic requiremente, boron dilution concerne.

and Fire Hazards Analysis. Performed reliability analyses on routine hardwore such ae plant erenee and unique hardwore such as the Robot Vehicles.

1982 to 1983 Fellowship to Derden Buelness School. University of Virginie.

Work concentration *In Optimiretion. Scheduling. Deciolon Making under Uncertelnty. and Strategy Formulation and Strategy implementation.

1980 to 1982 Supervisor of PRA Group. Responsibilittee included technical supervisor of group and individual projects. Individual work scope included principal reviewer for Crystal River IREP. input to Oconee/NSAC ef fort. and peer reviewer on NUREG/CR-2300.

1975 to 1980 Rollebility Engineer in technical staff group. Performed analyses i (Foult Tree. R50. FMEA. Markov) on mechanical and electrical systems including AFW. MFW. HPl. LPl. ESFAS. RPS. and ICS.

Cost / Benefit and Aging Analyses. Project leader with budgetary 1 responalbility for RAM RGO octivities. }

f I

PART ACTIVITIES

• Reviewer for NRC/ industry Prebebilistic Risk Assessment Guldebook.

• IEEE Subcommittee 5.44 Working Group t

• Atomic Industrial Forum Subcommittee on PRA

' Interdivisloaal BGW Reliability Committee i

f .

t PARTIAL PueLICATION LIST

• 'The Impeeg of Aging Mechanisme on Reactor Safety Performance.' (co-author with E. Celkere (BEMD. Nuoleer Erlence and Engineerine. Volume 89. No. 3. December 1970

• ' Aging Techniques id Quellflod Life for Safety System Components.' Nuclear Befety. l Volume 21. No.1. Jers - Feb 1900

• 'Determinletic Criterie Versus Probabilletic Analysos: Examining the Single Fellure end l Separation Criterls." Nucleer Technology. Volume 47. No. 2. February 1990

' 'Auxillery Feedwater Rollebility Analyses for Plants with BGW Oseigned NN's." (co-author '

with R.S. Ensinne and R.W. Dormen (SGWI). ANS 26th Annual Meeting. June 8-12. 1980.

LeeVegas

• 'Probabilletle Analysis and IREP Studies.* (co-author with E.R. Kane (SGW) and P.M.

Abraham (Duke Powerll. presented at the 7th Annual Nuclear Operating Experience Conference. Attente. March 1981 ,

' 'Pitf alle in Current Design Requirements.' Nuoleer Befety Volume 22. No. 3. May-June

• 1981

• ' Methodology and Application of Coet-Benefit Analysis: MFW System.' (co-author with S. Ahmed (BGWI) presented at ANS 1981 Annual Meeting. Miel. FL ,,

• 'A Decialen Methodology for Quantl&gtive Safety Goal Allocatione for Nuclear Power Plants."

(co outhor w!th S. Ahmed (BGWl). Proceedings of the AP4/EPS Topical Meeting on Probabilletic Riek Assessment. Sept. 20-24. 1981 Port Chester (Invited) i *

• Estimating Fellure to Close Probabilities for Prosaurizer Velves.' presented at the j

international Meeting on Thermal Nuclear Safety. Chicago IL. August 29 - September 1.

1982

' ' insights from the TMI-2 LOOP Analysis." (co-author with F.W. Deininger (Fen-Pac)). ANS.

l Reno. June 1986 1

• 'A Method to Integrate PR A Results with Plant Upgradee.' ANS. Weehington. CC. Novem-bar 1985 (invited)

EDUCATION t

• United States Merchant Marine Academy - BS Marine Engineering

! ' Meesechusette Institute of Technology - MS Nuclear Engineering

• George Weehington University - MBA

• University of Virginia - All course work completed for Doctorate in Buelnese Adminletration l end Operatione Research PROFEMIONAL CERTIFICATIOPS

• Certified Quality Engineer - ASQC

' Certified Reliability Engineer - ASQC

• 3rd Engineer Stasm and Olesel. Any Horsepower - USCG ct__m