ML20235N189

Response of Cw Huver to Final Initial Decision of ASLB in Matter of Disposal of Accident Generated Water from TMI-2 on Behalf of Susquehanna Valley Alliance.*

ML20235N189
Person / Time
Site:	Three Mile Island
Issue date:	02/20/1989
From:	Huver C SUSQUEHANNA VALLEY ALLIANCE, LANCASTER, PA
To:
Shared Package
ML20235N141	List: ML20235N137 ML20235N143 ML20235N162 ML20235N189 ML20235N216
References
OLA, NUDOCS 8903010091
Download: ML20235N189 (5)

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RESPONSE OF DR. CHARLES W. HUVER TO FINAL INITIAL DECISION OF THE ATOMIC SAFETY AND LICENSING BOARD IN THE MATTER OF DISPOSAL OF ACCIDENT-GENERATED WATER FROM THREE MILE ISLAND NUCLEAR STATION, UNIT 2 ,

ON BEHALF OF THE SUSQUEHANNA VALLEY ALLIANCE.

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' DATED: February 20, 1989 Sworn and subscribed before me on this 26 th day of February,'1989.

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In reaching its final initial decision, it is unfortunate that the ASLB failed'to properly weigh the evidence that irreparable damage could be initiated in exposed individuals and their offspring due to nuclear remissions and transmutations resulting from the radioactive decay of tritium to be released to the environment from evaporations of approximately.2.3 million-gallons of accident-generated water (AGW). A number of 1

errors and distortions of the tritium issue and in describing my testimony are evident in the February 2, 1989 document supporting the final' initial decision in favor of the applicants plan for evaporation.

My testimony was presented as if it were advocating tritium as bioaccumulating in plants and animals when I actually stated: " Evidence for the biological concentration of tritium in the literature is rare with most studies indicating no concentration." However, the special situations of tis' sue fixed and/or organically bound tritium described in the work of Koranda and Martin (1969 I

and 1973) and Kirchman et al. (1971) were not explained away be the testimony of the applicants' witnesses, Dr.

Auxier and Dr. Fabrikant, but they did help to explain the ecological kinetics of these significant results. The importance of this matter was stressed by Koranda and 1

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concentrations in the biosphere increase, it may be advisable to develop maximum permissible concentration for tritium in an organic form.:

Furthermore, Koranda, Martin, and Anspaugh (1971) of the Lawrence Radiation Laboratory concluded, "that tritium releases to the environment, even those of short-lived nature, have some ecological and biological consequence when evaluated in terms of human food chain effects."

The Regulatory Guide 1.109 dose methodology used to assess the maximally exposed hypothetical offsite person (AGW Final Decision: p. 21) has been severcly criticized by a group of distinguished Heidelberg University scientists.

Franke, et al. (1979) have pointed out that these dose estimates underestimate the effects of the radiation release by nearly 100 times.

The view (AGW Final Decision: p.41) that the animal experiments described in my testimony based upon treatment with tritiated thymidine is of little value is incorrect for two reasons. First, part of the tritium entering the body as water will end up as DNA precursors and DNA as DNA synthesis proceeds. Second, the same types of biological damage have been described for tritiated water as has been found for tritiated thymidine but usually requiring higher amounts of the former to produce these effects (Hori and

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Nakai, 1978; Painter, et al.,.1958; Mewissen and Ugarte, 1979).

- Lastly, the issue emphasized in my. testimony of the' extraordinary biological' damage to chromosomes by small amounts of the tritium or even one tritium disintegration.

in a nucleus is virtually ignored (AGW Final Decision).

Respectfully submitted, Charles.W. Huver, Ph.D.

Dated: February 20, 1989

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, i Literature Cited Franke, B., et al. 1979.. Radiation exposure to the public from radioactive emissions of nuclear power' stations.

Critical analysis of the official regulatory guides, Institute for Energy and Environmental Research, 6900 Heidelberg, West Germany.

Hori, T. and Nakai, S. 1978. Mutation Res., 50:101.

Kirchman, et al. 1971.. Health Phys., 21:61.

Koranda, J.J., et al.'1971. Lawrence Radiation Lab ~., UCRL-73546, p.-18.

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1 Koranda, J.J. and Martin, J.R. 1973. In Tritium, ed. by l Moghissi, A.A. and Carter, M. W. USEPA, p. 430.

Painter, et al. 1958. Cited by Wimber, D.E. 1964. Adv. in Radiation Biol., 1:85.

Mewissen, D.J.cand Ugarte, A.S. 1979. Cumulative genetic effects from exposure to male mice to tritium for ten generations. In Biological Implications of Radionuclides 3

Released from Nuclear Industries, Vol. I:215-230. '

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