ML20215M498

Forwards J Dinunno Re Ocean Dumping as Option for Disposal of Water at Tmi,For Info in Preparing to Address Subj at 870325 Meeting in Harrisburg,Pa

ML20215M498
Person / Time
Site:	Three Mile Island
Issue date:	03/09/1987
From:	Morris A NRC - ADVISORY PANEL FOR DECONTAMINATION OF TMI UNIT 2
To:	Masnik M Office of Nuclear Reactor Regulation
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Download: ML20215M498 (11)

Text

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h 'O, gi ~ '"g THE ADVISORY PANEL FOR THE DECONTAMINATION OF  ;

i l THREE MILE ISLAND UNIT 2 o /

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March 9, 1987 ,

Michael T. Masnik, Panel Liaison U. S. Nuclear Pogulatory Comnission

'Ihree Mile Island Cleanup Program Directorate P-320B Washington, D. C. 20555

Dear Mike:

Find attached a copy of a recent letter frca Joseph Dih%no regarding ocean dumping as an option for the disposal of the water at 'IMI. I am providing this with the hope that you will be prepared to address same at our necting of March 25 in Harrisburg.

Please advise should you have any questions.

Sincerely,  ;

Arthur E. bbrris, Mayor Gairnnn AEM/dk attaciment cc: All 'Itil Advisory Panel Vcnbers w/attachm2nt 8705130276 870507 PDR ADOCK 05000320 p PDR .

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h 'jk , , kin reading the transcript of the Jan. 21,1907 meeting I Qy p k' noted that the alternative of ocean disposal of the cleaned-w'ater was not completely considered.(See 5g@p@y

f. .page;up 22) The accident reason cited was an i nternational moratorium on residual ,

hM the ocean disposal of any radicactive material. It struck me odd and perhaps a source of confusion for the public that on

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@h P one, hand Federal authorities do not consider release of the

[Q. ORU.S. water to the Susquehanna a signi ficant health risk yet the is . reportedly a party to a moratorium that uould e::clude

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gTjy.3 I made a few phone calls and did a littic library research. I. learned enough to convince me that this

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, q1 alternative should be examined more thorcughly than it seems Let me share with you and the panel a brief k$ $]k33 tosummary have been. of the currehtjjor,ea,n disposal si tuation .as I ,

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The United States is a signatory to the international p "'%.. " Convention f h on the Prevention of Marine Pollution' by Dumping l =l g '-of Wastes and Other Matter". This Convention is also referred

>See ~to at times as the' London Dumping Convention. This Convention yNM was developed in 1972 and was ratified by the U.S. in 1975.

Uff.W4y Under the terms of this Convention , ocean dumping of a group KS/;),' , of materials consi dered particul arly hazardcus is prohibited.

Qd.'..- Included in this group ( Annex I) are " h i g h --l eve l r adio- ac t i ve M ).; - wastes or other high-level radio-active matter". The use of

+.N? - the ocean for disposal of l ow- l evel radio- acti ve westes is

$?,e4 not prohibited by the convention but such dumping " requires a a prior general permit".

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N+f The U.S. did permit a limited amcunt of ocean disposal of low-level radioactive waste in drums ye ars ago but this

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g practice w,s stopped,largely because af both national and i sensitiv.i.' ties about usg of the oceans for such f}[p,fr/A%hmWm 'i nWHrf f'annsm1%'t'herP Csu

P s @,p.4 *internatiofipurposes. WithOthe.aVa'ilability

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toisuch use have the been studying tVJ8.yJMfh. p .t Ec"h ni calG a n d er.vi ..v.;w ron up. -

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In 19D3, delegates to the C $ .t ,' w% ,7 1 ,sc.nd.on;.,.D.u.mpin.g Co. o d low-level dumping

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thf Ct.'.ThM.t udy 2;pr oved .inecinclissive. .' In September 1985,at a h9f...Wifo.,hi,' .Msi liar J:s,essi6n,ttiej. London ocean Convention dumping of low-level passed a resolution radio-(O.f, .. . u n r.d.f.. he. con tinu. ed. ba v g igfacts v.e waste. , Th~i s '. nnin.d[of w as:Jafnon-binding resolution. The United

.gfi, States j oined wi.thi. th.e .U. K. . Canada, France, South Africa,and t f' The United p[.fp'fj,h]jd.S6,Iit;zerlarid' tq in)vot'ing iciainst the resolution..g hadStates no delegate Jna pg49 sy ,r. -:

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ig'ing. , that, would apply f or getting a general permit as prescribed by the Convention. However,it is possible such guidance may in4.g gu. J ..- .ibe s r.forth . ' coming next year.

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3 p,;;.g It may well be that the ocean disposal alternative may

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Statement of Dr. Ernest J. Sterngl. ass My name is Ernest J.Sterngless, Professor Emeritus of Radiological Physics, University of Pittsburgh, Scool of Medicine,viere I have taught courses and carried out research in tre area of radiological instrumentation and the health effects of lov-level radiation since 1967. Prior to this,I held a position as Advisory Physicist to tre Director of the Westinghouse Research Laboratories,where my functions included the development of Nuclear Medicine Instrumentation, X-ray imaging systems, nuclear radiation detectors ard the development of advanced corcepts for gas-cooled nuclear reactors. In the course of my professional activities, I have been elected to membership in various scientific ord professional organizations,includirg the American Physical Society,the Radiological Society of North- America,and the American Asssociation of Physicists in Medicine. I have published books, review articles and scientific papers dealing with both rodilogical instrumentation and the health effects of radiation.

I have examined tfe Environmental impact Statement related to tre decontamination and disposal of radioactive vastes reulting from the March 28,1979 accident at the Three Mile Island Nuclear Station, Unit 2 (NUREG-0683, December 1986) as vell as related docurrents ard letters furnished to me by the Susquehanna Yelley Alliance. As explained in detail in the testimony which I gave before the Citizen's Advisory Board at its March 2Sth,1987 meeting, the official trancript of which is made part of the present statement,it is my professional opinion that the proposed open-cycle forced evaporation of the 2.lmillion gallons of the accident-generated vater containg strontium-90 and other biologically very hazardous isotopes vould present a significant risk to the lives and the health of the public,ard that alternative methods of handling the problem exist which vould greatly reduce this risk at comparable or lover direct costs.

In particular, based on an examination of the mortality statistics for Pennsylvania, Marglard, New York and other nearby states follovirn the previous venting of the Three Mile Island containment building between June 28 and July 11 1980, togetter vith the measurements of strontium-90 released by Harvey, Piccioni and Pisello ( f ) who fourd that a comparable amount of strontium-90 was discharged into the atmoaphere as is proposed in the planned evaporation option,I estimate that between 100 ard 400 excess infant deaths ard a comparable number of deaths of adults at all ages, vill result from the proposed release.

Tre basis of my conclusions may te summarized as follovs:

l

1) According to the Environmental Impact Statement (EIS)(NUREG-0683,Suplement No. 2 Draft Report) Table 2.2. page 2.3,0.9 Curles or 0.9 trillion picocuries are present in the 2.1 1

1 Draft Report) Table 2.2. page 2.3,0.9 Curies or 0.9 trillion picocuries are present in the 2.1 million gallons of veter vaiting to be evaporated, or at a ccncentration of i 10,000 picoeuries per liter (One picocurie is ore millonth of one millionth or one trillionth of ore Curie,and ore liter is slightly more than one quart). For obtain some feeling for the magnitude of this arrount of strontium-90 stillin the remainig vaste veter,it should be noted that the bottom of Range ll of tre federal Radiation Courcil Guidelines for tte consumption of milk issued during the period of nue. lear testing in 1960-61 where concern was verranted and steps to reduce the intake should be considered was only 20 picoeuries per liter, ard the recently introduced maximum permissible level for drinking veter by the EPA is only 9 picocuries per liter. The maximum value measured during the height of nuclear testing was 31 picocuries per liter of milk according to the EIS (NUREG-0683), page 2.9. Thus, the preseht amount in the stored veter vould contaminate 100 billion liters of milk to the level of picoeuries per hter deemed of public health concern by the EPA,or 30 billion liters to the highest level recorded by the U. S.

Public Health Service during the height of nuclear bomb testing.

2) Using the dose factor for infants ingesting food or veter containing strontium-90 as given by the Nuclear Regulatory Commision in its pubilcation NUREG- 1.109, namely 0.0185 millirads per picoeurie, this represents a dose commitment of 16.65 billion millireds to tre bone ofinfants. This means doses of 16.65 millirads to a billion infants,16,650 millirads to a million infants,or 165,500 millirads to ore hundred thousand infants if the strontium-90 in 4 the vater vere to reach their milk, food and drinking veter, regardless of whether the releases are spread out over days, months or years.

3) The EIS assumes that only 1 % of the strontium-90 vill actually escape into the air with tre evaporated water,or 9 billion picocuries. This must be compared with the 50,800 picocuries reported by the NRC in NUREG-0218 as having hen released to the atmosphere during normal operation of Tiil Unit I in 1975, some 177,000 times less. But even assuming that only 1 %

vill escape, the above doses vould still be very large. Thus, enough vould escape to give a dose of 1,650 millirads to one hundred thousand infants if the amount escaping vould enter their diet or the air they breathe. Even assuming still further that only 1 % of the amount escaping actually enters the body (1), this vould still represent 16.5 millirads for 100,000 infants. But extensive studies by Stewart (2) and others ( 3) (4) involving diagnostic X-rays during pregnancy have shown that the developing infant is some 100 to 1000 tirres more sensitive to the development of leukemia ard other childhood cancers than the adult depending on the stage of 2

development. More recently,a large scale study by Kneale and Stewart on the effect of me.9. red background radiation in England involving 22,351 carly cancer deaths (0- 15 yrs) tes shown that only 160 millirads per year,or 40 millireds during the most sensitive first three months of intrauterine development, double the risk of leukemia and cancer (5). Thus, one vould expect that 16.5 millirads vould result in a 40% inrease in chilhood leukemias and cancers alone in a group of 100,000 infants born in tre years after the release.Since about 1 in 1000 infants rormally develop leukemia or cancer, among 100,000 infants,100 cases vould termally be expected. Thus a 40% ircrease represents 40 excess cancer and leukemia deaths as a result of tre proposed metted of evaporating the vaste water,or 2.5% per millired. lf one vere to assume that only the portion deposited on farmland enters the food chain, as did Harvey et al

( 1), the estimate vould be cut to 16 deaths. However, since other long lived isotopes also contained in the vaste water have not been considered at all in the above rough estimate, and since the maximum bone dose estimate arrived at in the ESI of 3 millirads is of the same order of magnitude as the 6.6 millireds estimated above assuming only tre material deposited on farmland reaches the infant,it is clear that at least of the order of 10 to 40 cancer and leukemia 4 deaths may te expected as a result of the proposed release.This is some 10,000 times more than tre 0.003 cancer deaths estimated in the ESI (Section 5.2) based on data for adults exposed to shori external radiation doses such as occurred at Hiroshima or in the course of medical diagnosis. But, as explained in detail in my oral testimony of february 25,1987, these adult populations exposed to short external exposures are not appropriate bases for comparison with infants or fetuses whose DNA repair processes are not yet developed. f urthermore,long chronic exposures by bets rays to crucial organs of the developing immune system such as the bone-merrow, for which the damage is mainly produced by the much more efficient production of free-radical oxygen ( 6)( 7)(8 ), are some 1000 times more damaging to cell-membranes than short, high-dose and high dose- rate exposures.The much greater mutagenic effect of lov dose irradiation than expected on the basis of earlier high dose studies has recently teen demonstrated in laboratory studies on single human chromosomes incorporated in hybrid cells (9).

4) Hovever, cancer and leukemia are not the only serious health consequences of the ingestion of strontium-90 and other internal beta-r89 emitting isotopes. In the case of bone-seeking isotopes such as strontium-90,it is the cells of the immune system developing in the bone-morrov that are the most critical targets. Studies not considered by tre NRC staff or the BEIR Committee on whom the staff relies (Section 5.2) indicate that at doses in the range of 3

millirads projected for the proposed t elease, clearly detectable damage to the cells of the bone-marrov has in fact been detected by Stokke et al( 10 ) as discussed in my oral testimony.

Still more recently, laboratory studies by Haller and Wigzell (11) have shown that strontium-90 preferentially deactivates the so-called Natural Killer (NK) cells, one of the j most crucial components of the natural immune defense system of the human body against viruses, bacteria and career cells. As a result, strontium-90 not only increases the risk of developing leukemia ord cancer, but also increses the risk of dying of infections, thereby affecting total mortality due to all causes and not just cancer mortality as assumed in tre NRC staff's estimates of deaths, helping to explain the gross underestimation ofite health risk arrived at in the ESI.

a

5) Aside from strontium-90, there are a series of other important radioactive chemicals which are contained in the vaste veter to be evaporated into the air around Three ttle Island such as cesium-137, tritium, carbon-14andiodire-129. Among the most serious of theseis iodine- 12911sted in e letter ( Document ID 0068P dated February 18,1987 ) submitted by GPU to the NRC but not even mentiored in tre ESI (NUREG-0683).Just like iodire- 131,this 1!

element seeks out the thyroid gland of the developing infant,where it corcentrates as much as 100 times as strongly as in the muchlerger thyroid of the adult (12), except that per picocurie it is much more damaging in its long-term effect because it has a half-life of some 16 million years, as compared to only 8 days for iodine- 131, stayirn in the body much longer and beirq recycled in the environment generation after generation.

Whereas the NRC staff only considers the relatively small risk of thyroid cancer resulting i

10-20 years after exposure, the most critical health effect actually is the reduction in output of thyroid hormone controlling tre physical and mental development of the fetus and the infant during the first two years after birth. Even a small reduction in the rate of development of the lung can lead to inability to breathe immediately offer birth, cousing infants to die of respiratory distress within a fev days after birth in much greater numbers than due to all cancers and leukemias combined.

As discused in my March 25th testimony and the orticle on the Chernobyl accident attached to the present statement (13 ),it is the underdeve.'opment of the newborn which rose sharply in the U.S. during the period of fallout from nuclear weapons testirn (14 ) ard which appears to be tre sirgle rnost important factor leadirq to the sloving down in the normal & cline of infant mortality. This decline resumed only after the end of large-scale atmospheric weapons testirn, 4

but it reached the lov rates projected by the pre-ver trend only in areas hke Wyoming and 4

New Hampshire vtere there vere no large nuclear plants or other sources of fresh fission products in or near their borders, as predicted by the hypothesis that radioactive iodine and strontium radioisotopes vere the pricipal new causal factors in the environment.Since there are about 10 times as many infant deaths due to all causes combined as due to leukemia and cancer,one must therefore expect that some 100 to 400 infants vill die as a result of the proposed release.These deaths do not ircludecomparable number of deaths due to veakened immune systems among older adults and those in future generations due to tre long-lived strontium-90, carbon-14 and iodine- 129 in the diet for centuries to come, nore of which was er,nsidered in ihe ESI.

6) These estimates are supported by tre actual increases in infant mortality in Pennsylvania, idaryland,and Upstate New York outside of New York City as published in the U.S. monthly vital statistics following the earlier venting of June-July 1980 at T hree (1ile Island in which a comparable amount of strontium-90 was discharged. Thus, comparing the six months of July through December after the venting with the first six month of the same year,one finds the t

following increases in infant deaths:

For Pennsylvania: a rise of I 15 from 1032 to t 147, en increase of i 1.1 %.

For fiarytand:a rise of 99 from 288 to 385,anincrease of 34.4%.

For Upstate N.Y.: a rise of 29 from735 to764, an increase of 3.9%.

For the three areas combined, this is an excess of 241 infant deaths,or of tre order expected from the 2.5% increase per millired for the early intent in the first trimester found by Kneale and Stewart for childhood leukemia and cancer in relation to background radiation in England, Scotland and Wales. In contrast to the above increases, the U.S. infant mortality as a whole kept declining at an average rate of 0.4% per month during this period.

The causal connection of this rise in infant deaths with the radioactivity released in the tie venting is further supported by the fact that for the month of July 1980, the number of births in Pennsylvania suddenly rose by 41.4% from i 1,358 to a record high for 1980 -82 of 16,065, followed by a sharp decline tol 2,499 in August, indicating that some 4,700 births took place prematurely immediately after the release.Such early delivery leads to a sherp ircrease in urderdeloped and underveight babies,which ts known to be the biggest single cause of infant death in tie United States today, a rise thet began in the early 1950's (l 4) when 5

nuclear weapons testing began. A second wave of premature births occurred in Octo5er, folloved by the largest number of infant deaths in 1980, namely 218 in November, for a record rate of 17.1 deaths per 100011ve births, compared with only 12.5 for the U. S. as a whole tret month.

7) The connection with the relese of radioactivity from the venting is further indicated by the fa:t that when the radioactivity in the environment began to declire following tre end of the July 1980 venting, infant mortality for Pennsylvania suddenly dropped at tte highest rate ever seen in the entire history of Pennsylvania vital statistics,namely a decitre of 36.3% in the two years folloving July 1980.The number of infant deaths in each six month period and the successive declines as reported in the monthly bulletins of the U.S.Yital Statistics is as follovs:

July-Dec.1980 1147 0 0%

Jan.-June 1981 990 -157 - 13.7%

July-Dec.1981 846 -144 - 14.5%

Jan.-July 1982 781 - 65 - 7.7 %

July-Dec.1982 731 -50 - 6.4%

This sudden declire in infant deaths vien all radioactive releases from Three Mile Island Units 1 and 2 ceased is perhaps tre most significant supporting evidence that tre large radioactive releases from these facilities vere responsible for the previous rise.The situation is exactly paralell to the case of the cholera epidemic in I.ondon in the early 1800's, when the epidemic ended after a public veter pump suspected of being contaminated was closed down.

This conclusion is especially difficult to avoid when one examines the decline in infant trertality after 1980 in various states at different distances from Three Mile Island , as shown belov by a comparison of the changes between 1980 and 1981 in Pennsylvania, Margland, New York, ard Yermont:

State 1980 1981 Change in No. Charge in %

2179 1835 -343 - 15.7%

Pennsylvania 675 594 -81 - 12.0%

thryland New York 3210 3052 -148 - 5.6%

63 59 -4 - 6.0 %

Yermont Although these declines ininfant mortality in Pennsylvania efter1980 probably reflect ret only the end of the venting but also the continuing decline of environmental radioactivity produced by the origital accident in 1979, the rise in the secord half of 1980 relative to ite first half cannot be explained as an effect of the Maren 1979 accident.

6

Althoughinfant mortalityis rot the only healthimpact of the venting since especiall,y tre immure systems of older adults are also weakered by tte chronic radiation of the bone-morrov produced by strontium-90 and otter radiolsotones,it produces tre most immediate effects and can therefore be used as an early indicator of serious public health impact of radiation releases into tre environment.

f urthermore, present NRC dose calculations must nov be regarded as grossly underestimating the population dose. They assume that airborne releases do not enter distant drinking-veter supplies even though run-off from agricultural land into rivers is recognized as an important source of drinking vater contamination by terbicides and pesticides. Also, they only consider the population within an erbitrary 50 mile zore to be effected. However, as both tre above data and the recent experience following the Chernobyl accident Indicates, the radioactive gases can contaminate the air, the drinkirq vater and the food supplies far beyond this Es mile limit. f urthermore, food and milk affected by airborne contamination within a 50 mile radius is often shipped to rearby large metropolitan areas, as is the case for tre Philadelphia, Baltimore and Washigton Metropolitan areas within 75 miles of Three Mile Island, so that the existing computer models greatly underestimate the true population size effected by airborne releases.

In conclusion, there is by nov sufficient laboratory and human epidemiological evidence of d

urexpectedly large health effects of chronic exposures to lov levels of rt iation especially for the developing infant as compared with all theoretical expectations based on the earlier findings for adults exposed at w: y high dose-rates, that the option of eleasing large quantities of strontium-90 eM other internal emitters into the air or drinking vater can no longer be regarded as eccetable.

April 13,1987 Ernest J. ernglass Professor Emeritus of Radiological Physics University of Pittsburgh 7

_ References

1) J. Harvey, R.G. Piccioni ard D. Pisello, Strontium-90 Released in TMi Ventirk;, Safety in Chemistry ard Environment, March 1982.

2) A.Stevert and G.W. Kneale, Radiation Dose Effects in Relation to 0bstetric X-rays and Childhood Cancers. Larcet j_: 1185 ( 1970).

3) 8. MacMahon, Prenatal X- ray txposure and Childhood Cancers. J. National Cancer Inst. 23, i173 (l962).

4) A. M. Lilienfeld, Epidemiological Studies of the Leukemogenic Effects of Radiation, Yale Journal of Biology ard Medicine 39,143(1966).

5) G.W. Kneale and A. M.Stevert, Chilhood Cancers in the U. K. and their Relation to Background Radiation, Proc. Int'1. Conf.on Biol. Eff.of lonizing Radiation, Hammersmith Hospital, London, November 24-2S,1986.

6) A. Petkau, Effect of Na-22 on a Phospholipid Membrane, Health Physics,22,239 (1972).

7) E.J.Sterngless, The Role of Irdirect Radiation Effects on Cell Membranes in the immune Response, Proc.of the 1974 Hanford Radiobiology Symposium, Div. Tech. Inf., ERDA,0ak Ridge, Tenn. (1976) (CONF-740930).

8) A. Petkau, Radiation Carcinogenesis from a Membrare Perspective, Acta Physiol.Scand.

Suppl. 492,81 (1980).

9) C.Waldren, L.Correll, M. A. Sognier and T. T. Puck, Measurement of Lov Levels of X-rey Mutagenesis in Relation to Human Disease, Proc. National Acad.of Science USA R3,4839 (1986).

10) T.Stokke, P.0ftedal and A. Pappas, Effects of Small Doses of Radioactive Strontium on the Rat Bone Marrov, Acts Radiologica Therapy Physics Biology 1,321 (1968).

11) O. Haller and H. Wig 2 ell, Suppression of Natural Killer Cell Activity with Radioactiv?

Strontiurn: Effector Cells are Marrov Dependent.J.of immunology .UJ, 1503(1977)

12) W. H. Beiervaltes et al, Radioactive lodine Concentrationn in the fetal Human Thyroid Gland from Fallout.J. Am. Med. Assoc. 173,1895(1960).

13) E.J.Sterngless, Implications of the Chernobyl Accident for Human Health, Int'l.J. Biosocial Res. a,7 (1986).

t 4) K.-S. Lee, N. Paneth, L. M. Garther et al, Neonatal Mortality: An Analysis of Recent improvement in the United States, Am. J. Public Health,2Q,1 S ( 1980).