ML20237B766

Comment on Relicensing of Calvert Cliffs Nuclear Power Plant

ML20237B766
Person / Time
Site:	Calvert Cliffs
Issue date:	06/24/1998
From:	Samuels S AFFILIATION NOT ASSIGNED
To:	Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM)
References
FRN-63FR31813 63FR31813-00005, 63FR31813-5, NUDOCS 9808190236
Download: ML20237B766 (7)

Text

-_ - -_ - - -

L- NM Ofru/H1 J T * ,~~m so NAl@A[Z$ @

C Gwf INSTITUTE tm MS -7 m 9: 07 FOR OCCUPATIONAL ggg a y a. pMCH AND ENVIRONMENTAL US A HEAL.TH RESEARCH P.O. BOX 1570 June-24, 1998 SOLOMONS ISLAND, MD 20688

. Shirley A. Jackson PHONE: (410) 326 2543

$EC'D BY S L ir FAX: (410) 326-6808 US Nuclear Regulatory Commmission ,, 9g 3 g g 9 g hington, DC 20555 gp61I Re: Relicensing of Calvert Cliffs Nuclear Power Plant l

Dear Dr. Jackson:

This memorandum is written'at the request of local affected citizens. It is sent to-you for inclusion in the record of any hearing on the question of the relicensing of the Calvert Cliffs Nuclear Power Plant, but also for direct consideration of the Commission because the issues examined here are broader than ,

those within the scope of a public hearing on the relicensing of a single plant.

The burden of protection must not only be on the company and the plant. It is,important to address the federal, state and local infrastructure. essential to protecting human health, the environment, and our well being in general, in the management of the unforgiving technologies associated with the peaceful use of nuclear energy.

Public support for the use of nuclear energy in power generation assumes that the federal government would ensure the highest level of technical and moral capability of thosc in-industry to whom society delegates stewardship. The Supreme Court [1] has provided guidance on how this level should be measured in terms of human risks, how to evaluate conflicting health, social and environmental priorities, and defined feasibility as the effective use of beat available technology. The licensing procedure should answer the question of whether or not BGEE specifically has demonstrated by past performance that it met and can meet the performance of the most successful achievers of that standard.

The decision cannot be made, as the compan? ,aay contend, simply i

on the basis of what will occur under projected optimally-f controlled conditions in its continually revised mechanical I process. ( b 9908190236 990624 3 f PDR ADOCK 05000317

\ H PDR k K

i

_j

Ouestions of Federal Infrastructure

- The Commission's enforcement and inspection capability, now being questinned [2], is the keystone in the federal infrastructure. If the Commission lacks the ability to fulfil its mission by reduction of its current capabilities, then consideration should be given to a moratorium on any further licensing or relicensing of nuclear power plants.

The question of whether power should be generated by use of nuclear energy is separable from the relicensing issue. Locally and nationally, the key issue is whether or not the Nuclear Regulatory Commission should set a precedent in this first relicensing proposal, by permitting the continued operation of reactors that may pose a higher level of human risk than was predicted at the time of original licensing or has actually been experienced since operations began.

Ouestions of State _pnd Local Infrastructure State agencies, prior to relicensing, should be required to demonstrate their capability in risk assessment, management and communication, with special reference to local infrastructure they control, necessary to fulfilling their obligations to monitor and control human health risks associated with Calvert Cliffs Nuclear Power Plant.[3]

A risk assessment / management study necds to be done by state and federal agencies before concluding that in fact the risk levels have been or will be increased, and what can be done to mitigate the risks as an alternative to reactor shut down.

Such a study is not a requirement for relicensing by the applicant. But as a matter of national environmental policy, such studies, both quantitative and qualitative, should be done as the first step in aiding stakeholder participate in the decisionmaking process.[4]

Ecological risk factors, such as effects cn the Bay as a food supply, or health effects across the Bay in Dorchester County where a community is growing down wind of the reactors for a * '

significant percentage of time, appear not to be assessed. ,

What follows are some of the questions that would be posed in a comprehensive risk assessment - risk management study.

Evacuation The criteria used for original licensing included an evaluation of the population density and evacuation routes in the effective risk zone of the site. The basis for l approval in this regard may no longer exist, given immense  :

population growth, increased loading and deterioration of evacuation routes. An updated, adequate plan may need to be l 1

l l

L

- I

?

1. devised. New road and bridge construction may be necessary. Total evacuation'for large segments of the population may not be

, feasible, and in the case of the two major biological laboratories, may be impossible. Alternatives need to be defined and communicated.

The existing plan (largely implemented by plant personnel) calls for evacuation only in case of a Chernobyl-like disaster. In less immediately urgent circumstances, the increased. risk of disease resulting from " sheltering" at home is deemed acceptable. Such risks, especially those imposed by deprivation of information and freedom of action, may be unnecessary and thus unethical.[5]

Plant Risk Factors: An updating of the risk assessment done by NRC and BG&E at the time of original licensing should take into account plant operating experience, deterioration and projected life of control and containment structures. Dual natural gas and nuclear fuel use at the same site, which is being discussed, might multiply those risks.

Instrumentation directly and continuously monitoring changes in critical measurements telemetered outside the plant and observed by appre3riately trained state or county personnel should be investigated. A critical element in the Three Mile Island incident was the inability of company control room personnel to read, interpret and take appropriate, timely action. In a recent incident at the plant in question, excessive worker exposure occurred for similar reasons. .I Workforce Projections.Of all workers exposed to ionizing radiation, those in nuclear energy (6) are exposed on average to a dose of 8.4 mSv/ year This is at least eight times the dose experienced'by most other workers in other jub categories, and about four times the exposure of naval reactor personnel ( 2. 2 '

mSv/yr.) Averaging does not take into account special circumstances. Thus, at plants that have experienced in-plant incidents, such as those often cited by NRC at Calvert Cliffs, it is prudent to reconstruct the dose or exposure to ionizing and non-ionizing toxic agents. The sickness and death experience needs to be analyzed and monitored prospectively by a neutral agency. Most of the workers at risk are only now entering that time in the latency period for cancer when the disease might be expected to beccme clinically manifest.

A computerized record system may need to be kept at a designated clinica 11 center for use in an emergency. Local primary providers need training on'the special time-dependent care workers may require [such as whole body scanning and chelation, a detection and removal technique for plutonium-iapacted workers.) A neutral source for risk information to exposed workers and their families needs to be identified.

i

Storage of Spent Fuel: The state and Native Ameri in tribal  ;

governments in Nevada appear to have rejected use of S acca 1

= Mountain as a waste repository. Thus, it may be prudet.t to assume l that the accumulated spent fuel will be stored onsite. The risks and costs of projected management of permanent on-site storage should be explored, e.g., classification.

i Emergency Response Infrastructure: Local first responders {

[ police, fire, EMT] appear not to be adequately aware, trained or equipped to assist the population at risk, or to protect themselves from exposure both to ionizing and non-ionizing toxic agents at the plant that would be widely dispersed in a nuclear incident. No specialized federal or state resources can be assumed to be immediately available to assist the local police, fire, emergency medical and hospital structure. Access by responders to the critical ten mile zone around the plant on both sides of the bay [which includes two long-term care medical facilities, housing for senior citizens, several day care centers and at least four schools] may be hindered given the in-place blocks to evacuation router., which would be enhanced during an incident.

However, more likely than a major nuclear disaster, smaller radiation and non-radiation incidents have and can be expected to continue to occur. All responders need not only special training for both kinds of events, but also immediate identification of the ionizing and non-ionizing toxic agents being used in the plant, and access to precautionary procedures for self protection.

Many of these procedures have been developed and are already widely available to fire fighters and EMTs in hazardous waste and induetrial plant situations. In addition, the state of Pennsylvania has developed first-responder procedures for measuring radiation exposure among themselves and the people they protect.[7]

The local hospital and its staff need to be trained and equipped to evaluate, treat, and transport radiation victims.

Public Health and Communications: A survey of emergency resources for assessment, management and communication by public agencies needs to be done and reported to the public. Currently, both agencies and the public are reliant on information communicated by the plant, on measures that must be taken either to evacuate or, as is likely for many, take coping measures in their homes and schools [such as protected sources of drinking water during a power failure.]

Current educational materials promote misconceptions through the use of misleading language, such as the term " safe". Since the term " safe" means freedom from harm to many if not most people,  ;

i 1

S it is without a scientifically demonstrable basis for use'in discussing environmental carcinogens. [8]

No entirely " safe" or risk-free levels of exposure have been found in human populations for ionizing radiation. Current releases of radiation to the ambient environment, even if they pose a low order of risk, are not known to be risk-free. More, in the case of nuclear workers, individual risks increase with the rise of cumulative exposures.[6]

Another misconception is perpetuated in what some in the industry call "the standard of small significance", a term that has been used to describe the effects of both relatively small unplanned and routine emissions at the plant. What is meant by this

" standard" is the averaging of low levels of risk over very large, heterogeneous populations. While arguably these levels might not be expressed in greater than normally expected deaths or disease in such a population, the averaging process obscures risk in especially susceptible subsets of the community and workforce populations.[9]

Susceptibility may be generated by past personal exposures to radiation, synergistic or additive effects with medicines and other toxic agents, differences in age (with greater susceptibility among children and the elderly] and genetic differences. These susceptible can be expected to experience death and disease at rates greater than normally expected and not at all of "small significance." Thus, these subsets may be consciously and unnecessarily sacrificed as the price of continued relicensing.

Clearly, the educational task might properly be assumed by credible, specially-trained public health staff.

KI Distributions Compliance with the recent NRC advice to states for prophylactic distribution of potassium iodide tablets, while not mandatory, is nevertheless a consideration in relicensing.

Industry opposition to this standard precaution is evidence of the industry's inability to manage nuclear energy. In Frcace, where 77% of the power is nuclear, within a 10 km radius of French nuclear facilities, the govetnment distributes potassium iodide [KI] pills for use by children in case of a nuclear emergency. The inexpensive pills block and replace radioactive forms of iodine that the children may ingest and which might raise their risk of thyroid cancer. WHO recommends that all school children in Europe have immediate access to KI tablets in the event of an incident. Poland used such tablets after the Chernobyl incident.[10] Pennsylvania has already taken steps to provide KI tablets to all populations at risk.[7]

. l Economic Risks

• Economic arguments - actual threats of the loss of jobs, tax increases and a shortage of electricity - are being cited in pressing state and local legislators, officials, business, and taxpayers to support relicensing. Most of Calvert County's treasury surplus is attributed to tax revenues from the plant and its workforce.

Unfortunately the picture painted of the county's profit and economic well-being may be an illusion. The failure of the state and local governments to alert stakeholder to their financial responsibility and to provide for an adequate, responsive public health and emergency response infrastructure has resulted in higher than necessary risks to life, and to property now, and response costs and other economic sequellae that would be compounded in the event of a nuclear incident.

In any comprehensive cost / benefit analysis, the large costs of these measures [which by-and-large are not be.ing taken) significantly reduce the actual net income from plant taxes.

Another hidden set of costs lie in decremental shifts of real estate value and incremental shifts of insured and uninsured personal and property liability, from the company to the community. j i

Thus, much - if not all - of the county " surplus" derived from plant-generated taxes may not really exist. Much - if not all - )

is already obligated, i.e., it should be spent on infrastructure.

Since the power generated supplies other counties, these costs currently are unfairly distributed, i.e., concentrated in the county that derives the least economic benefit, and diluted in counties that derive the greatest benefit: power costs subsidized by tax payers in risk-impacted Calvert County. Pressing for a redistribution of these costs should become a legislative priority of the state.

Public discussiou of the impact of a plant closing on the company and the County'a tax and employment base does not take into account the *:alue of the property as a " brownfield" or the market value of dismantled reactor components. The increasing unavailability of power plant sites in the Middle Atlantic, plus the site's established power grid connections and trained workforce makes the conversion of the site attractive for other power producers in the forthcoming deregulation of the power industry.

For example, the next generation of electric power technology, in which BG&E has no demonstrated or entrance capability, might well include on-site use and/or manufac~c ure of hydrogen fuel cells for l

commercial and residential facilities by competing enterprises. ]

While still at a developmental stage, albeit an advanced stage, j l

-s- j I

l c

4 e

these may be available by the time the current licensing ~ period has ended. It is an alternative that should be explored in the

, risk management plan.

Respectfully submitted,-

7 hi Sheldon W. Samuels Vice President, Policy Studies References

[1] Industrial Union Department, AFL-CIO v. American Petroleum Inst. 448 0.5 607 USSC 1980 and prior decisions op. cit.

[2] Wald, ML At a Hearing, Nuclear Regulators Are Criticized on 2 Fronts. New York Times, 7-18-98, p. A9

[3] Tinker, T, Pavlova, M, Arkin, B and Gotsch, A. Risk Communication In A Changing World. Proceedings ATSDR-DOE-EOHSI Conference on Risk Communication. Piscataway, Dec. 6, 1996.

Ramazzini Institute /OEM Press Beverly Farms, MA April 1998.

[4] Samuels, SW. Nuclear and Non-Nuclear Energy Systems:

Risk Assessment and Governmental Decision-Making. Proceedings, MITRE SYMPOSIUM, Washington, February 5-7, 1979

[5] Samuels, SW. Ethical and Metaethical Criteria for An Emerging Technology: Risk Assessment. (J. Brit. Soc. Occ. Med.)

OccMed 47,4: 241-246. June 1997.

[6] Upton, AC. Ionizing Radiation ID Environmental and Occupational Medicine. Rom, W, editor. 1992 2nd. ed., pp. 1071-1084 Boston: Little, Brown.

[7] PA Emergency Management Agency. Nuclear Power Plant ,

Accident Emergency Worker Dosimetry and Potassium Iodide [KI) {

ruidance and Information Circular 095-10 December 1995 i

[8] Samuels, SW and Adamson, RH. Quantitative Risk Assessment: A Report of the Committee on Risk Assessment, National Cancer Advisory Board. JNCI 74: 945-951, 1985

[9] Samuels, SW The Arrcsance of Intellectual Power in Phenotypic Variation in Populations. Brookhaven Symposium. A.D.

Woodhead et al, eds. pp. 113-120 Plenum New York 1988.

[10] News and Comment France Distributes Iodine Near Reactors. Science. 275:5308 March 28, 1997.

I

--__----__------__---a-- _ - - _ - - _ - - -