ML23158A230
| ML23158A230 | |
| Person / Time | |
|---|---|
| Issue date: | 10/26/1978 |
| From: | NRC/SECY |
| To: | |
| References | |
| Download: ML23158A230 (91) | |
Text
{{#Wiki_filter:October 26, 1978 SECY-78-560 COMMISSIONER ACTION For: The Corranissioners {..;. th Thru: From: f Executive Director for Operations Harold R. Denton, Director Office of Nuclear Reactor Regulation
Subject:
Proposed Staff Response to the Jeannine Honicker Petition for Emergency and Remedial Action
Purpose:
To provide the staff's propoed response to th July 29, 1978 subject Petition for Emergency and Remedial Action, as directed by the Commission Discussion: By letter of July 29, 1978, Ms. Jeannine Honicker of Tennessee transmitted the subject petition requesting that the Commission revoke the licenses of all nuclear fuel cycle facilities over which it has jurisdiction, decommission and dismantle such facilities, isolate hazardous radioactive materials from the biosphere, and take other appropriate measures. Her request was made under Title 10, Chapter l, Section 2 of the Code of Federal Regulations. The letter was docketed on July 31, 1978. As a result of the Federal Register notice announcing receipt cf the petition, Ms. Zella Jensen of Tennessee requested by letter of September 8, 1978 that she be made a party to the petition. Attached as Enclosure 2 is a response developed by staff which would: (1) outline the basis on which current radiation protection standards had been
Contact:
W. Kreger, NRR 49-27321
2 set; (2) describe briefly the NRC regulatory process, particularly as related to those standards; (3} place radiation exposure to the public from the nuclear fuel cycle in perspective, related to all radiation exposure; (4) show the potential harmful effect of removing nuclear power from public use; and (5) evaluate the principle "statements of fact" presented in the petition. It was decided not to respond to the petition page by page, and reference by reference, both because it would occupy an inordinate amount of staff time and because it was bel -* eved that an appropriate response could be made by discussing the "statements of fact" in detail. Individual items in the petition "statements of fact" were assigned to those staff members most knowledgable on the subject, with a number of the items being worked on by several individuals. After collecting all the input, a draft was circulated back to each offica for comment. Com ments received from seven groups of comnentors have been incorporated, as appropriate, in the attached staff petition response paper. This staff response provides a perspective on ionizing radiation based on established facts and concludes that the nuclear fuel cycle adds an inconsequential increment to the radiation exposure of the U. S. public. Nevertheless, precautions are taken in the NRC's regulatory process to assure that radiation exposure will be as low as is reasonably achievable, and do not present an undue risk to the public health and safety. Recommendation: That the Commission: (a) Authorize the staff to deny the petition, in accordance with 10 CFR 2.206, since the petition has not demonstrated that emergency and remedial action is necessary or justified. (b) Note the proposed letter of denial, attached. Coordination: The Offices of Nuclear Materials Safety and Safeguards, Standards Development, and Inspection and Enforcement,
3 t.a*,e concurred in this paper. The Office of the Executive Legal Director, which prepared section III C, has no legal objection.
//,,-,,4:/ d Harold R. Denton, Director Office of Nuclear Reactor Regulation Erclosure:
- 1. Proposed letter to Ms. Honicker.
from Mr. Denton
- 2. Proposed response to the Jeannine Honicker Petition of Emergency and Remedial Action
PROPOSED LETTER FROM. DENTON TO MS. JEANNINE HONICKER
Dear Ms. Honlcker:
Please refer to your letter of July 29, 1978 transmitting for Commission c1ctlon your petition, styled "Petition for Emergency and Remedial Action," requesting the shutdown of the nuclear fuel cycle. For the reasons set forth In the attached response to your petition, your request Is hereby denied. A copy of this determination wl I I be placed In the Commission's Publlc Document Room at 1717 H Street, N.W., Washington, D.C. 20555. A copy wl I I also be flled with the Secretary of the Commission for Its review In accordance with 10 CFR 2.206(c) of the Commission's regulations. Sincerely, Harold R. Denton, Director Office of Nuclear Reactor Regulation
Response to the Jeannine Honicker Petition for Emergency & Remedial Action: An Overview Regarding Radiation Exposure As Related to the Nuclear Fuel Cycle
TABLE OF CONTENTS Introduction A. Standards for Radiation Protection B. NRC Regulatory Process Vl. Ionizing Radiation Perspective ll A. Radiological Impact of Various Sources of Radiation Ll B. Health Effects Analysis 16 T. BEIR 1 and Ill Reports Lo
- 2. HEW Task Force on Health Effects of Ionizing 16 Radiation (F. Peter Libassi, HEW, Chairman)
- 3. Comparison of Health Effects for Nuclear, Coal U7 and Other Fuel Cycle Alternatives
- 4. Comparison of the Risk of Mortality from the 23 Nuclear Fuel Cycle with Other Societal Risks tlle Costs of Ban on Nuclear Fuel Cycle Facilities 24 A. Immediate Effects ao B. Long Term Effects 31 C. Conclusion 36 IV. Answers to Petition Principles and Evidences 34 A. Medical Principles 34 B. Physical Evidence 50 C. Statement of Law: Jurisprudential Principles 80
RESPONSE TO THE JEANNINE HONICKER PETITION FOR EMERGENCY AND REMEDIAL ACTION: AN OVERVIEW REGARDING RADIATION EXPOSURE AS RELATED 10 THE NUCLEAR FUEL CYCLE Introduction By a petition submitted to the U.S. Nuclear Regulatory Commission (NRC) on July 29, 1978, Ms. Jeannine Honicker of Nashville, Ten-nessee seeks to compe! the NRC to cease operation of al! parts of the nuclear fuel cycle except those Involving fsolation of hazards from the blosphere, to undertake al! measures necessary to prevent or lessen the Impact of emergency conditions already created and to begin emergency and remedial action within 30 days. The pet!tioner contends that the nuclear fuel cycle produces radlatton and radio-activity that results eventually In an unacceptable number of deaths and Injurles to present and succeeding generations. In response, the NRC staff wil! present arguments as follows:
- I+ has not been sclentifficaliy estab! !shed or proven that there are any health effects (risk) from the very low levels of human population radiation exposure (dose) that result from normal operation of the nuclear fuel cycle.
. Nevertheless, In carrying out {ts responsibIilftles under the Atomic Energy Act of 1954, as amended, and the National Environmental Policy Act of 1969 (NEPA), the NRC assumes that some very low dose rate health effects can be extrapolated from data on health effects at very much higher dose rates, and It takes the prudent course of using standards for radfattion protection based on this assumption.
Once the assumption [s made that human health effects may occur at the very low radlation exposure levels that do occur, one can, and the NRC staff does, calculate health effects for compartson and cost-benefit analysts purposes, and for assuring that the requirements of the regulations are met In !Icens!ng actlons. Such health effects numbers should be recognized for what they are, namely, probabliftles that the effects may occur In a very large population sample, and at sometime !n the l! fetime of the Individuals in the exposed population. In the materfal that follows, both the radlation exposure to {ndlI-viduals, In rem (a unft of radlatfon exposure), or millfrem (mrem, one thousandth, or 1075 of a rem), per year, and the collective expo-sure to populations In man=-rem per year wi!! be discussed. (The term man-rem {s the sum of the exposures to all the Individuals In the population of concern.) NRC regulations address lImits to
Individua! exposures and !Iimits to population exposures (to be discussed In the next section). Population exposure {s meantnafu! as a means of estimating risk only If the relationship between Individual exposure (dose) and risk !s a lfnear relationship. If It {sn'+, as has been suggested by some technica! authorittes, one would have to calculate rfsk to each exposed Individual, based on know!ng the Individual exposure as wel! as the relationship be*+ween exposures and risk, and +hen add al! the Individual risks to get collective rfsk. In thls response we wil! assume a !Inear dose-r!sk relationship and calculate population risk from population collective exposures (man=-rems). As will be discussed later In Section IV, there are a number of pro- ; blems relative to the nuclear fuel cycle that have yet to be completely resolved, such as waste disposal, prollferation, fuel reprocess!ng,and mine and mill tallings contalment+t. Nevertheless, the Commfssfon has determined that It fs acceptable to continue to author!ze operation of nuclear facli{!{ttes, since solution of each of these problems fs within technical grasp, or policy decision and can be achfeved with the necessary protection of public health and safety. A. Standards for Radfatton Protection Protection against fonjzing radtation began almost sImul taneously wlth the discovery of x-rays late {n the nineteenth century. By 1940 1+ was recognized that radiation damage to blological systems could be manifested {n both cancer and genetic effects and that an exposure level fnvolving no risk, l.e., a "threshold", might not exitst. The Inability to sclentifically demonstrate the ex!stence of a threshold for radiation exposure effects required that any risks expertenced as a result of radiation exposure be kept smal l and that unnecessary radiation exposure be avolded. These Ideas evolved Into the major tenents of radlation protection, as stated In the 1960 Federal Radlation Counc!!! Radfation Protection Guldes (25 FR 4402, May 18, 1960), which were approved by President Eflsenhower. These guides reflect the basic protection standards for fonizing radiation recommended In earlfer pub! {cations by the Natlonal Counc!! on Radlation Protection and Measurement (NCRP)*
- Natfonal Committee (now Councl!) on Radfation Protection and Measurements, "Permissible Dose from External Sources of lonizing Radlation," NCRP Report No. 17 (Natfona! Bureau of Standards Handbook 59, Washington, 1954).
and the International Commission on Radiation Protection (ICRP) .** Both +hese groups are constituted of Individuals who are recognized as national or International experts fn the fleld of radiation protection. The relationship between the varfous bodfes that develop radiation protection standards and guides fis shown Jn Flaure 1. The Federal Radiation Counci! Guides promulgated the following relevant recommendations: Rec. l. "There should not be any man-made radiation exposure without the expectation of benefit resulting from such exposure..." REG. 2. ".,.every effort should be made to encourage the maln-tenance of radiation doses as far below this guide as practicable." Re&. 5, See Table 1 It ts to be noted and emphastzed that the sequence of the Guides (numerfcally) has significance. For a given source of radfation, consideration must first be given as to whether the radfation exposure !s warranted at all (Rec. 1). Second, !f warranted, Is the exposure level as low as can be reasonably achleved (Rec. 2)? Third, In any case the doses should be numerically !Imfited (Rec. 3). I+ 1s of Interest that the requirements of the Natfonal Environ-mental Polfcy Act and the NRC's environmental ftmpact statement procedures thereunder are, In a historical sense, man!festatfons of Recommendations 1 and 2. In al! events, these basic principles and numerical guides are reflected In the NRC regulations of 10 CFR Part 20 and fn Append!x l of 10 CFR Part 50. The NCRP, a consultative body of sclentists as mentioned above, whlch operates under charter by the Un!Ited States Congress, has developed basic radiation protection standards. The latest summary of these standards are set forth fn NCRP Report No. 39, "Basic Radfa-
+fon Protection Criterta" (1971). Im NCRP Report No. 43, "Review of the Current State of Radlation Protection Philosophy", Jan. 15, 1975,
+he results of several !mportant recent studles and reports were summar!zed. These Included ICRP publications 8 ( The Evaluation of Risks from Radiation, 1966) and 14 (RadlosensItivity and Spatial Distribution of Dose, 1969), the United Nations Sclentifiec Committee on the Effects of Atomic Radiation (UNSCEAR) report
- Summary of Recommendations of the Commission regarding External Sources, presented In ICRP Publication No. 2, "Report of Committee 1! on Permissible Dose for Internal Radfation," Pergamon Press, (1959).
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§ SUUVONVIS NOTLISIONS ROTIVIOVE JO INSU TIAIU
ThaOLe 1 Rec. 3. Radiation Protection Guides Type of exposure Condition Dose (rem) Radiation worker: (a) Whole body, head and Accumulated dose 5 times the number trunk, active blood of years beyond forming organs, age 18. gonads, or lens of eye. 13 weeks 3. (b) Skin of whole body Year 30. and thyroid. 13 weeks 10. (c) Hands and forearms, ee 10. feet and ankles. 13 weeks G0. Cd) BONE ccc cacueec vies Body burden 0.1 microgram of radium-226 or its biological equivalent. (6) Other Organs ........ Year 1S. 13 weeks Do. Population: (A) TAGIVIGUA) Sscecccese Year 0.5 (whole body). (B) AVQGGGG .ccerecvcscss 30 year 5 (gonads).
on "Ionizing Radiation: Levels and Effects" (1972), the Advisory Committee on the Blological Effects of lon!izing Radiation of the National Academy of Sclences (NAS-BEIR) report, (The Effects on Populations of Exposure to Low Levels of lon{izing Radiation, 1972,) and the ear!fer NCRP Report No. 39, as referenced above. The result of this review was that the NCRP took the position that no change was required at that time {n the recommendations set out in Report No. 39, which are essentially equivalent to Table l above, the FRC Radiation Protection Guides. The NCRP dose limiting recommendations Include under dose limits for the pub!!ic, or occas!on-ally exposed individuals, population dose limits of 170 mrem average per year In addition to the {fndividual I!mft of 500 mrem fn any one year. In Report No. 43, the NCRP states that It "...continues to hold the view that risk estimates for radiogenic (radiation caused) cancers at low doses and low-dose rates derived on the bas!s of linear (proportional) extrapolation from the rising portions of the dose-!nctdence (radiation effects) curves at tlgh doses and high-dose rates....cannot be expected to provide real!stic estimates of the actual risks from low-level, !ow-LET (1!near energy transfer, a measure of the rate at which different kinds of radiation transfer energy to a medium) radiations, and have such a high probability of over-estimating the actual risk (emphasis added) as to be of only marginal value, !f any, for purposes of realistic (emphas!s added) r!sk-benef!t evaluation". In summary, the NCRP belfeves that low dose rate radiation {s less !!kely to cause human health effects than one would predict on the basfs of results obtafned at h!gh dose rates. The ICRP has promulgated standards for radiation protection in the international arena. These are character!zed In the terminology, permissible dose, which fs defined In ICRP Publication No. 2 as follows: "The permissible dose for an Individual !s that dose, accumulated over a long perlod of time or resulting from a single exposure, which, In the light of present knowledge, carries a neg!igible probabl lity of severe somatic or genetic Injuries; further-more, It fs such a dose that any effects that ensue more frequently are !imited to those of a minor nature that would not be considered unacceptable by the exposed Individual and by competent medical authortty." In ICRP-15 and 21*, Issued In 1970, the dose IImIits
- International Commission on Radlological Protection. Protection against fonizing radiation from external sources. A report of Committee 3. ICRP Publications 15 and 21, Pergamon Press. Oxford, 1970.
for members of the public for external rad{fat'on sources are: 0.5 rem/year to the gonads and red bone marrow; 3 rem/year to the skin, bone, and thyroid (except for 1.5 rems/year to the thyrofd of a child up to 16 years of age); 7.5 rems/year to the hands and forearms, feet and ankles; and 1.5 rems per year to other single organs. Again, !t should be noted that 500 mrem {fn a year !s considered a dose to the members of the public that meets the above stated definition of permissible dose. ICRP Publication 26*, adopted and {ssued In January 1977, which fs based on a complete review of both technical data and radiation protectton philosophy, has basically the same findings. Both EPA and NRC have regulations which Iimit the exposure received by the public by operations related to nuclear power production to values less than those allowed by 10 CFR Part 20. EPA !ssued a new regulation 40 CFR 190, Environmental Radiation Protection Standards for Nuclear Power Operations** which requires that operations covered by the regulation (al! nuclear fuel cycle operations except minting, waste disposal, transport and reuse of and non-urantum l{fcensed materfal) shall be conducted {n such a manner as to provide reasonable assurance that the annual dose equivalent does not exceed 25 mi!lirems to the whole body, 75 millfrems to the thyrotd, and 25 millirems to any other organ of any member of the public as a result of exposures to planned discharges of radioactive materfals, radon and Its daughters excepted, to the general environment from uranium fuel cycle operations and to radiation from these operations. This standard was {tssued after extensive public hearings. I+ recognizes that the requirement of Appendix l to 10 CFR Part 50 result {in much lower doses to the most exposed Individual In the vicinity of the plant than the IImits of Part 20 or Part 190. Appendix l "Numerical Guldes for Design Objectives and Limiting Conditions for Operation to Meet the Criterton 'As Low As Practicable' for Radloactive Matertal In Light-Water-Cooled Nuclear Power Reactor (LWR) Effluents" also resulted from extensive rulemaking hearings.
- International Commission on Radiological Protection. Recommenda-tions of the ICRP. ICRP Publication 26, Pergamon Press, Oxford, 1977.
- Federal Register of January 13, 1977 (42 FR 2858)
Table 2 Indicates the (most exposed Individual) des!gn objective dose values of Appendix l. They may be compared to the Part 20 dose limit of 500 mrem/year for Individuals, the NCRP recommended average dose I!nft of 170 mrem/year for populations, the 40 CFR Part 190 dose limit of 25 mrem/year, and the natural background value of m!00 mrem/year average dose to Individuals {n the U.S.A. It should be emphas!zed that the values of actual doses to the most exposed individual resulting from effluents rarely are as high as even the design objective values of table 2. Average Individual dose values for the entire U.S. pvopulation due to all nuclear fuel cycle effluents are less than 0.1 mrem/yr, as will be described later. Environmentai radtological monitoring Table 2 10 CFR Part 50, Appendix l Design Objectives? Dose to total body from all pathways 3 mrem/yr Dose to any organ from al! pathways 10 mrem/yr Noble Gas Effluents (at site boundary) Gamma dose fn alr 10 mrad/yr Beta dose In air 20 mrad/yr Dose to total body of an Individual 5 mrem/yr Dose to skin of an Individual 15 mrem/yr Radiolodines and particulates? Dose to any organ from all pathways (at a farm) 15 mrem/yr a Append!x l Design Objectives from Sects. l!.A, 11.B, I1.C of Appendix l, !0 CFR Part 50: considers doses to maximum Individual per reactor unit. From Fed. Reg!ster 40; 19442 (May 5, 1975). b Carbon-!4 and trit!um have been added to this category.
results and calculations* based on radlological effiuents Indicate that doses to the public do not exceed the design objective values. B. NRC Regulatory Process Speciflc licensing requirements for applicants for NRC licenses are contalned and described in Volume l of Title 10, Energy, Code of Federal Regulations. Parts 30-35 describe Iicense requirements for by-product (radloactive) materltal, Part 40 for source material, Part 50 for production and utIlization faciifties, and Part 70 for special nuclear materials. Part 5! Implements the requirements of the NEPA, and Part 100 prescribes additltonal requirements re-garding nuclear reactor siting, relating to public safety. The major NRC regulation related to the control of radlation exposure Is 10 CFR Part 20, Standards for Protection Against Radiation, which has been discussed above and which applies to all persons who recelve, possess,.use, or transfer NRC !!Icensed metertal and ope::ate production and ut!lization facllIties. Control of radiation exposure to the publIc comes about from the discussed limits of "art 20 and for Iight water reactors, by the design objective values of Appendix l of 10 CFR Part 50, which are also discussed above. Each application for a reactor construction permit or operating license must be accompanted by a safety analys!s report, responding to the requirements of 10 CFR Part 50 and Part 100. This report treats the design and proposed operation of the facility In great detail. The staff reviews this report, making judgments on factors which affect the safety of the proposed facility. Based on this review, the staff Issues a Safety Eval-uatlon Report summarizing the results of the technical evaluation of the proposed facllIty, and delineating the technical matters considered In evaluating the radiological safety aspects of the facility. Provided all safety Issues have been resolved, and the staff can conclude that the Issuance of a construction permit, and later on operating license, for the facility wil! not be InImical to the common defense and secur!ty or to the health and
- Population Dose Commitments Due to Radioactive Releases from Nuclear Power Plant Sites In 1975, Baker, Soldat and Watson, PNL 2439 (1977).
10 safety of the public, a recommendation !s made for !ssuance. The recommendation and all matertal !n support thereof {ts reviewed by the Advisory Committee on Reactor Safeguards, which !ssues a letter of recommendation to the Commissioners related to the proposed facility. If the recommendation ts favorable, an Atomic Safety and Licensing Board {ts convened to conduct public radio-logical safety hearings on the proposed action. At the end of these hearings, If favorable,a recommendation is again made to the Commissfoners to {ssue the requested permit or license. An example of a Safety Evaluation Report !s NUREG-0422, avallable In the NRC public document room. An environmental report, responding to NEPA requ!rements set out In 10 CFR Part 51, accompanies each app! !cation for a construction permit or an operating I!cense. A notice !s published In the FEDERAL REGISTER regarding the avallabll!ity of the report. All comments by Interested persons on the report are considered by the staff. In conducting the required NEPA review, the staff meets with the I!fcense applicant to discuss !tems of information in the environmental report, to seek new Information from the applicant that might be needed for an adequate assessment, and generally to ensure that the staff has a thorough understanding of the proposed project. In addition, the staff seeks Information from other sources that will assist In the evaluation and visits and {nspects the project site and surrounding vicinity. Members of the staff may meet with State and local officlals who are charged with protecting State and local !nterests. On the basis of all the foregoing and such other activities or Inquirltes as are deemed useful and appropriate, the staff makes an I{nde-pendent assessment of the considerations specified {in NEPA and (in 10 CFR Part Sl, This evaluation leads to the publication by the NRC of a draft environmental statement, which Is then circulated to Federal, State and local governmental agencles for comment. A summary notice {s publ!shed {n the Federal Register of the availabli!ty of the applicant's environmental report and the draft environ-mental statement. Interested persons are Invited to comment on the proposed action and the draft statement. After recelpt and considerations of comments on the draft statement, the staff prepares a final environmental statement, which Includes a discusslon of questions and objectives ralsed by the comments and the disposition thereof; a final benefit-cost analysis, whIch considers and balances the environmental effects with the environ-mental, economic, technical, and other benef!ts of the facility;
11 and a conclusion as to whether--after the environmental costs and after avallable alternatives have been cons!idered--the action called for, with respect to environmental issues, !s the !ssuance or dental of the proposed permit or license or Its appropriate conditioning to protect environmental values. This final environmental statement and the safety evaluation report prepared by the staff are submitted to the Atomic Safety and Licensing Board for !ts consideration In reaching a decision on the application. Any person whose Interest may be affected by a !Icensing action may file a petition for leave to Intervene In the proceeding. if timely petitions or requests are received, a notice of hearing or other appropriate order wil! be Issued. In the event a hearing {s held and a person !s permitted to Intervene, that person becomes a full party to the proceeding and has a right to participate fully In the conduct of the hearing. The staff's review of the activities associated with the proposed operation of the facility for which a license fs requested, and the potential Impact, with both beneficial and adverse affects, wil! not result In a construction permit or operating I!cense, unless among the other factors mentioned above: the risk assoclated with accldental radiation exposure {!s very low, and; no slanificant environmental {mpacts are anticipated from normal operational releases of radioactive materftals. Quantitative assessments of the rad{fological impact wlll be treated In a later section of thls paper. An example of an NRC !ssued Final Environmental Statement {s NUREG-0365, avall-ble In the NRC public document room. In addition to the above processes, which take place sequentially before any construction fs allowed on the proposed nuclear power plant site, and later, before fuel {!s loaded Into the reactor and operation {s begun, there {s a cont!inulng program of Inspection during the operating I!fe of the plant, and through the Inspection process, cont!nultng enforcement of all applicable regulations. jontzing Radiation Perspective A. Radlological Impact of Various Sources of Radiation Radftation exposures to the public occur from seven major sources of radtation which can be categorized as follows:
- 1. Natural radfation and radfoactivity, Including technologically enhanced radiation (mainly assoclated with mining Industries other than urantum (urantfum mining to be Included In 4 below),
and consvruction materltals).
12 Ayo Healing arts (medical and dental radfation use) Nuclear weapon-related (fal lout) BW Other energy (fossil! fuels) UI Nuclear energy (uranium fuel cycle) OV Consumer producys 1 Other (accelerators, research reactors, etc.) These subgroups are displayed in descending order of total man-rems of exposure to the entire U.S. population. The toral population dese of lonizing radiatton exposure In the U.S. from al! sources of radiation ts estimated to be approximately 40 mijifon man-rems annually, es fs shown fn Table 3. Table 3 shows the distributton of the general population expesures, by Natural background radiation {!s the largest source of
+
source. population exposure and will fncrease as the population Increases. The heallng arts contribute nearly as much as natural background. There has been raptd growth recently In radlography and radio-pharmaceutical use, which suggests a strong future Increase In
+h!s source. These two major sources of radiation, natural beckground and medical/dental contribute about O7% of 611 U.S.
population sxposure. The contribution of 0.02 x 10° man-rems of U.S. population exposure resulting from nuclear energy generation Is obtained, as described below, ustng results presented In staff testimony developed and presented before the Atomic Safety and Licensing Board*., Enclosure 5 to that testimony ts reproduced In part as Table 4. Since *he values In Tadle 4 are 100 year dose commitments (that fs, the dose contrtbut{lo1 to Individuals from long IIved radfonuctides Is con-sidered for 100 years Into the future) and the values for the other radlatlon sources In Table 3 are essentially per year dose comm! t-ments It Is necessary to convert the 640-710 man-rems total to a per year basis. Approximately half of the dose due to the nuclear fuel cycle occurs In the first year of release. Tnis would result In
~350 man-rems per 800 MWE year. SInce.the values of Table 4 are also based on a U.S. population of 300 x 10° peopJe, the value also has
+o be reduced to the equivalent for 210 x 10° people, the 1978 popu-lation estimates used for Table 3. In 1978, 70 reactors have operating
- Supplemental Affidavit of Dr. R.L. Gotchy, Staff Exhibit S-12, In
+he Matter of Portland General Electric Company, Pebble Springs Nuclear Plant, Units 1 and 2, Docket Nos. 50-514, 50-515, May 24, 1978.
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14 Table 4 Estimated U.S. Populetion 100 Year Scse Commi-ments per 800 MWE-year Off-Site Toral Sody Dose Fuel Cvcie Component Commitmen* (man-rems)
- Mining 110 Milling 3S Uf. Conversion 6.9 EnP i chmen+ 0.022 UO, Fuel Fabrication 0.48 Ligh* Water Reactor Effiuents 100-130 irradiated Fuel Storaae 0.0055 Reprocessing (not administration approved) 570-410 Transporation Lal Waste Management 8.9 Industry Toval 640-710 man-rems
- not Including accidents jicenses, with a total energy generation capacity of 51,000 MWE.
Making these conversions, there would be a tozal 1978 U.S. population impact of the nuclear fuel cycle of .012 x 10 man-rems per year. For the purposes of Table 3, the number .02 x 10° man-rems hes been used as a conservative value. The average annua! dose to a member of the U.S. public from al! facilities In the nuclear fuel cycle *there-fore, Is 10.1 mrem/yr, a figure far be!ow the limits discussed In IA above. The results of Table 3 can be put In further perspective by con-sidertng the dose-health effects converston factors developed by the BEIR committee In thelr first report, referenced In IA above. In approximate value, there are 0.87 to 4.5 (the Satter Is relative risk model) probable eventual cancers resulting from 10,000 man-rem of population exposure. Using these values, potential health effects can be calculated, as shown In Table 5. Table 5, Source of Radfation Eventual Cancers/year (U.S. pop. - !978)
- 1. Natural 2,000-9,000
- 2. Medical/Dental 2,000-8,000
- 3. Weapons related 100-500
- 4. Other energy 4-200 or 20-900
- 5. Nuclear energy 2-9
- 6. Consumer products i) iy OTner <l
le) These flgures can be compared with U.S. cancer statistics*. For 1978, the estimated number of new cases of cancer {n humans !s 700,000. The number of cancer deaths estimated for the same popu-lation ts 390,000. B. Health Effects Analysis
- 1. BEIR l and I11 Reports In the summer of 1970, the Federal Radfatl!on Counc!! (whose activities have since been transferred to the Office of Radtation Programs, EPA) asked the Natfonal Academy of Sciences for Infor-mation relevant to an evaluation of present radlation protection guides, which have been discussed above. The BEIR l report (referenced on page 6) was !n response to that request. It presented a summary and analysis by members of the Advisory Committee on the Biological Effects of lonizing Radlation and Its subcommittees, of then current knowledge relating to r!sks from exposure to fonizing radiation. The report dealt with the sclentific basis for the establishment ot radlation protection standards and encompassed a review and reevaluation of the sclentific knowledge existing at that time concerning radiation exposure of human populations.
The committee came to a number of {!mportant conclusions as a result of their studies. Regarding genetic rlsk for example, It was calculated that the effect of 170 mrem/year, the popula-tion average dose IImit gulde, (or 5 rem per 30 year reproduction generation) would cause In the first generation between 100 and 1800 cases of serfous, dominant or x-I!nked d!seases and defects per year, assuming 3.6 million births annually In the U.S. This Is an Incidence of 0.05%. However, average population dose related to the nuclear fuel cycle has been shown above to be approximately 0.1 mrem/year for 70 reactors In operation, which would make the human genetic risk assoclated with the nuclear fuel cycle undetect-able (a factor of '1000 less than the !70 mrem/year related ffgure). The BEIR study also concluded that 5 rem per generation would eventually lead to an Increase of 5% tn the {I!1 health of the popu-lation. At the factor ofwl000 less In average population dose per
- 1978 Cancer Facts & Figures, American Cancer Soclety, 1977.
16 generation (0.1 mrem/yr x 30 years per generation*3 mrem), the increase In potential fi] health due to radiation related to the nuclear fuel cycle would be undetectable. Regarding somatic effects, the BEIR committee suggests a most !{fkely estimate of cancer deaths due to 5 rem in 30 years to the whole U.S. popula-tion to be approxtmately 6000 cancer deaths annually. Again, actual average U.S. population exposure of 0.1 mrem/year due to 70 nuclear power plants operating (fn 1978) would result potentially fn 4 eventual cancer deaths annually, according to the BEIR analysts. The anticipated report of the reconvened BEIR Committee, due to be published fn January 1979, will reexamine these factors.
- 2. HEW Task Force on Health Effects of lonizing Radlation (F, Peter L!bass!, HEW, Chafrman)
On May 9, 1978, the White House (by a memorandum from Stewart Eflsenstat and Zbigniew Brzezinsk!) requested the Secretary of Defense, Secretary of HEW, Secretary of Energy, and Admint-strator of Veterans Affairs to coordinate the formulation of a program {including the following:
- a. A study or sertes of studies to determine the effects of radiation exposure on participants {!n nuclear weapons tests, workers at nuclear faci!!ties and projects, and other persons as Indicated.
- b. A public Information program,
- c. A plan for care of persons affected by radiation exposure.
- d. Recommendation of steps which can be taken to reduce the Incidence of radiation exposure In the future.
This memorandum resulted In the formulation of seven separate tasks, under the overall! dlrection of F. Peter LIbass!, General Counsel, Department of Health, Education and Welfare, with particlpation by all agencles having responsIbI!l!tfes regarding radiation expo-sure for the controlled sources among those !!sted and discussed In l1.A above. The s!x tasks groups that have been develop!Ing Input since the May memorandum plan to present a report to the White House In mid-October. I+ has been recognized that the two major sources of population exposure, natural and medical/dental
sources, ere fargely uncontrolled and unrecu!ated, and that significant collective exposure reductions are sosstble and may be desirable for some of t+hese sources.
- 3. Compartson of Heal Cycie Alternatives In September 1977, the NRC published for public commen* ea draft document ,NUREG=0332, entitied, "Health Effects Attributable to Coal and Nuclear Fuel Cycie Alternatives", as a result of the January 1977 Atomic Safety and Licensing Appeal Scard deciston* ;
suggesting +he need to proviae more catalled connartsons of *he environmenral impacts of the coal and nuciear fue! cvcles. The results of several subsequant statt resval fons and changes in source terms and other factors have been !ncorporated Into comparfsons of mortality related to the coa! and cruclear fuel cycles that are summarized In Table 6. The risks from reactor ac-cldents has been the subject of much debate and any estimate of the absolute excess mortality due to thts par+ of the ructear cycite fs subject to considerable uncertainty. A major a**emp ra + to quant!fy the probability and consequences of reactor accidents wea 1975, the Reactor Sefety Study, WASH=-1400. An {ndepandent review of WASH=1400 by @ group including persons not employed by +he NRC and who were critical of the study hes recently been !ssued, NUREG/CR-0400, Seprember, 1978. This group found that they were unable to determine whether the absolute probabliftles of accident sequences fn WASK-1400 were high or fow, but belleved that t+he error bounds on those estl-mates were, fn general, greatly understated. The group also noted that the WASH=1400 result on core melt probablli!ty Is less than *wo orders of magnitude below the current experlence record, and precursors of major accidents unldent!ffed {fn WASH-1400 might perhaps be expected to begin to show up. Some of the group concluded that unfdentiffed event sequences significant to risk might contribute at most something between a smal! Increment and an Increment expressed as a small multiplicative factor above the WASH-1400 result, as opposed to an order of magnitude or more. One of the group ques7loned whether the methodology can be Implemented to alve such a high level of confidence that the summed probabIilIlty of many known and unknown accident sequences Jeading to an end polnt such as a core melt fs well below the Ifmfit set by experience. The staff has
- In re-Tennessee Valley Authority (Hartsvi!le Nuclsar Plant Units 1A, 2A, aB, and 2B) ALAB=367, SNRC92 (1977).
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ered The comments a w croup In cing @ rangs of v Ss 7 ane ality véelues (genera! public) of WAS oc. assun7s G Ot (0G. DlGhor and a factor of 10 lower, to reasonably represen? the spectrum of scholarly optnton on the subject. This would give 0.05 e nas general public general public acciden* mortality for an all suctsar fuel cycle and 0.10 3p 0} for the camtined fue! cycle. The toral values of excess mortality sacome C.54-6.66 (1.9)% and 1.16-17.01 (4 ,4)* toe #he fwo huclear cprions (*!6 ceore ric meen), Using the geometric mean for voth fueiear and cosl, the Farle of coal +o nucier total mortalities Is 22 (al! nuclear) and 9.5 (with coal power backup). This Indicates the relative Insensivivity to uncertainties in the vaiues used, since The numbers cornerable to 22 ana g 0 in Table 6 are 42 and 14, without considering [ns expanded range. In additlon to compartsons of potential health effects, the +a t win -h wn has ettempted to estimate the Impact of premature mortallty amon wor
- 0 the U.S. population for the coal and nuclear fuel cycles In term of llfe-shortening. The detalled methodology fs described In R.L. Gotchy's supplemental affidavit of May 24, 1978, referenced earller. Table 7, taken from that testimony, Is shcwn below. As Indicated, the average risk to any member of the public IIving within the next 1,000 years ts estimated +o be In the renge of 0.25 to 0.35 seconds of Iffe-shortening per plant year of opere*ton--
a small toss of l1ife expectancy. In the case of coal, Ifttle Is known about the l!ong-*erm Impacts This lack of knowledge was highlighted by the Department of He l Education and Welfare In thelr January, 1978 report to the Pres! on "Health and Envtronment Effects of Increased Coal UtIIfzation".
- Federal Register, Vol. 43, No. 10, pp. 2229-2240, January 16, 1978.
(continuation of footnotes, Table 6, page 18) (¢) Primarfly members of the general public killed at ral! crossings by coal traltns. (g) Primarily respiratory faflure among the sick and elderly from comous-tion products from power plants, but tncludes deaths from waste coal bank fires. (h) 100% of all electricity consumed by the nuclear fuel cycle produced by coal power; amounts to 45 MWe per 0.8 GWy(e).
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2) Indeed, It {fs poss{ble that tne long-term Impacts from sources such as metals leached from coal-ash and flue-gas desulfurlzation sludge {nto surface and ground waters may have a much greater potential health impact than the relatively large near-term effects. However, ignoring such uncertalntfes and considering only potent!al short-term health effects on the public (primarfly from coal combustion), {t Is concluded that a lower-bound estimate of average Il!fe-shortening from the coal fuel cycle can be made using recent estimates by Argonne Nattonal Laboratory*. ANL estimates that the average risk of Iife-shortening for the 50 miles population around a typical eastern or mid-western coal-fired power plant !s about 0.027 weeks (16,000 seconds). If this risk Is averaged over the U.S. population, 1 the average loss of Iife expectancy Is about 200 seconds per plant year. Thus, {n terms of average I!fe-shortening, nuclear power Is on the order of several hundred times less damaging than foss!l power. The conclusion demonstrates that the average health risks for both fuel cycles are extremely smal! even !f the Impact of elther cycle were many times greater than the current estimates {ndicate. Other studies have recently been published wh!ch support the current NRC staff position regarding the coal and nuclear fuel cycles, and provide further perspective by making compar!sons with other fuel cycle altenatives. These Include efforts by Brookhaven Nattonal Laboratory** and the Atom!c Energy Control Board of Canada.*** In
- A. J. Dvorak, et al., "The Environmental Effects of Using Coal for Generating Electricity", Argonne Natlonal Laboratory, NUREG-0252 (June, 1977).
- L. D. Hamilton and A. S. Manne, "Health and Economic Costs of Alternative Energy Sources, {n International Conference on Nuclear Power and !ts Fuel Cycle, !AEA-CN-36/448, International Atomic Energy Agency, Vienna (1977).
- Herbert Inhaber, "Risk of Energy Production", Report AECB-I119, Atomic Energy Control Board of Canada, Ottawa, Ontarfo (March, 1978).
- L. D. Hamilton and A. S. Manne, "Health and Economic Costs of Alternative Energy Sources, {n International Conference on Nuclear Power and !ts Fuel Cycle, !AEA-CN-36/448, International Atomic Energy Agency, Vienna (1977).
general, such studles show that the only alternative fuel cycle which has lower health risks than the nuclear fuel cycle {s natural gas. Coal, oll, solar, wind and ocean thermal fuel cycles all have about the same or higher health risks. Other authors have looked at the rfsks associated with producing energy by all feas!ble means. In the Canadian study by Herbert Inhaber, referenced above, there !s an analysis of publJc deaths related to all aspects of each of seven different energy production means. Table 9 of this section provides the results of the Canadian study for seven different energy alternatives app!l!cable to the U.S. The conclusions regarding so-called "soft technologies" I{ke solar or wind power can be attributed to the fact that decentralized energy systems are more resource and labor Intensive ({!.e.; many more workers and home owners are killed or Injured per un!it of energy produced), and such systems require backup energy (!.e.; a dual energy system) or storage systems to provide reliable power when the sun or wind fall to generate the needed electricity. The Canadian study assumed hard technologles I!ke coal power would provide the backup power for the "soft technologies". Table 9 Public Risk of Mortal!ty for Varfous Energy Cycle Alternatives* Energy Source Deaths/1,000 MWe-yr Relative to Nuclear Nuclear 0.034-0.19 1.0 Coal 1 6-120 50-600 Otl 1.4-140 40-700 Solar Thermal! 1.1859 40-200 Solar Photovoltaic 0.7-39 20-200 Solar Space Heat!ng 0.42 2-10 Wind 2.2-40 70-200 Source: Herbert Inhaber, The Risk of Energy Productlon, Report AECB-1119, Atomic Energy Control Board of Canada, Ottawa (March 1978).
- 4. Comparison of the Rfsk of Mortality from +he Nuclear Fuel Cycle with Other Soclteta!l Risks The NRC staff has compared the risks assoclated with electricity generation to other societal risks such as alr travel, automoblle driving, cigarette smoking, or using electricity tn everyday Iffe, to name just a few. Most of these activities have assoctated with them risks of both fatal and non-fatal (Iliness and Injury) occur=
. rences. Since fatal occurrences are generally judged more serfous than Illness Injury, the compartsons which follow are restricted to risks of mortality.
First, the public risk of mortality from the generation of electrical power by any fue! cycle alternative !s compared with the risk of usfng the electicity once !+ has been generated. The present-day average Individual risk of accidental electrocution ts about 6 In one mil!fon per year, or one chance tn 1,500 per l!fetime. Other risks assoclated with the use of electrictty result from electrical fires, burns from hot substances, and more obscure (but real) risks of death from pollutant em!ssfons such as sulfur oxides, nitrogen oxides, ozone, and toxic trace elements and compounds emitted In Industrial operations ranging from smelting, coking, steel making and manufacture of electrical wire, plastics and applfances. Added to this would be other related risks such as from Instailation and maintenance of radio and television antennas. Using results from the staff reevaluation of the radlologic Impact of the entire uranium fuel cycle, discussed In ll B 3 above, the max{mum average annua! Individual risk of radfogenic cancer death fs about 4 In one trillion per plant-year of normal operation* amongst a stable population of 300 mil!fion people during a perlod of 1,000 years, For 1,000 reactors operating for 30 years each (3 x 104 plant-years), the average annual risk of death would be about one In 10 million, or an average I!fetime risk §75 years per person) of approximately one chance In 100,000 (10~ per person). Clearly, the risk of cancer death from a mature nuclear Industry represents a very small Increase In the risk of us!ng electric!Ity regardless of how It fs generated, (nuclear, coal, ofl, solar, wind, or other). To provide additional perspective, It Is posstble to compare a risk of death of 10°?/per person with other competing risks to which people may be subjected In order to be functional members of soclety.
- {ncludes anticipated operational occurrences, but not accidents (class 3-9).
24 Using principally UK data* Table 10 was assembled: Table 10 Estimat ed Lifetime Risks of Mortality to an Average Individual Comparable to the Risk ( 10°- per person) from a Mature Nuclear Industry Risk Equivalent to Source of RIsk 107° per Person (one fn 100,000) Smoking Claarettes 15 claarettes Air Travel 2,500 miles Or{iving a Car 500 miles Rock Climbing 15 minutes Drinking Wine 5 bottles Living withtIn 50 miles of 1 week a coal-fired plant**
- E. E. Pochin, "The Acceptance of Risk", Br. Med. Bull, Vol. 31, No. 3, pp. 184- 120 (1970) <<
H* Nuclear Power: Issues and Chofces, Ford Foundation/MITRE Corp., Ballinger Publ! shing Co. Cambridge, MA (1977). Estimates up to 25 deaths/plant year; essentially all within 50 miles. Assumes 3.5 mil ifon persons at risk, 30 year plant I!fe, 75 year !!fe expectancy. Costs of a Ban on Nuclear Fuel Cycle Factiitites The !mpacts of displacing the U.S. electical output contr{- buted by nuclear power plants would be far reaching because of electricity's Importance In almost every aspect of thls country's social and economic well belng. A highly complex
)
Interactive model would be required to accurately estimate the full Impact of such a decision. Thts approach !s not employed here be-cause of time constraints and because even lower bound estimates that are subject to simple calculation can demonstrate the general magnitude of the effects. Essentially, thls section captures only the most obvious cost penalties accompanying such a dectston and does so In a conservative fashion. The first part of the section will discuss the general effects of an !mmedtate shutdown of al! nuclear power plants. Second, a dis-cussion will be presented of the long term effects of a permanen+ shutdown {Including an extension to plants now In the planning and construction phase. An approximate ten year perlod fs used for the second discussion. It Is recognized, of course, that al though Immmedfate shutdown of nuclear fuel cycle facllitles would el tminate some radioactivity release problems identiffed In the petition, !+ would have no effect on others, such as waste storage, releases from mine and miJ! tal! ings and others. A. Immediate Effects Nuclear plants are a significant contributor to the electrical power and energy capablitty of the United States. As of July 31, 1978, 69 nuclear unfts capable of produc!ng approximately 50,000 megawatts (net) of electrical power (MWe) were I!censed for commercfal operation. This !s approximately 9% of the total electrical generation capacity for the contiguous Unfted States (ustng the criterion of net dependable capability). In 1978, these nuclear units wil! generate a net of nearly 25 billion kftowatt hours (kwh) per month or 13% of the total U.S. electricity productton,*
- 1. Replacement Energy Costs The nuclear power plants presently on-!!ne provide an economic source of baseload energy for the rematnder of 1978 and fol low!ng years. The constructton costs and environmental and social costs associated with construction have already been Incurred and are not affected by whether the plant operates. The relevant economic decisfon varfables are production costs, consIsting of fuel and other operation and mafntenance costs. If replacement energy costs more than the nuclear fue! and O&M costs, an economic
- 8th Annual Review of Overall! Relfabi!l!ty and Adequacy of the North Amertcan Bulk Power Systems, National RellabI!Il!ty Counc!!, August 1978.
penalty will be !ncurred by the consumers of electricity. Nuclear unlts are among the lowest electric production cost units. It fs therefore, an economic benefit to the nation to have these untts operating as scheduled. Clearly, ff the nuclear un!ts are shutdown, the electric power fndustry must seek out alternative power sources, or else fall to supply the electricity demanded by customers. All replacement power sources avallable to the ut!lities will be more costly. The cost differential between producing the energy with nuclear capacity and the alternative constitutes the most immediate and unavoidable penalty associated with shutting down the nuclear facilities. The selection of a replacement power source !s not something one can readily predict. Logically, the utfllty will utflfze the least expensive alternative available. However, what !s avall-able will depend on the demands existing on the utfil!ty systems during the shutdown perfod and the amount of energy to be replaced. As an Immediate response, replacement power may hypothetically be suppl!ed by some combination of base, intermediate, and peaking un!ts on the systems, or through outside purchases.*
- 2. Replacement of Nuclear Energy by Coal Energy Most coal capacity on electrical systems {ts base load and already fully utfil!zed and thus !s not avallable as replacement for nuclear units. However, for the sole purpose of JI lustration we conserv-atively assume that the utfIl!tles are capable of replacing the energy with units already existing on their systems as a lower bound cost estimate.** Even If these generators could makeup the energy lost from nuclear plants, {t fs doubtful that coal supplies
- Base Load un!ts are designed to operate on a more or less cont!nu-ous bas!s to meet demand. Intermediate un!ts are used to meet that portion of the demand that fluctuates rather gradually, for example, on a seasonal basis. Peak!ing units supply sudden surges !n demand, such as that resulting from extreme temperatures or other very short term demand changes.
He Some util itles have hydroelectric plants, but since these are lower cost to operate than nuclear plants they are IIkely already operat-Ing at maximum output and are not avallable as replacement un!ts.
would be adequate as an {immediate adjustment. To provide the cur-rent electrical output of nuclear power plants with coal fired plants would require about 10 millfon tons of coal per month.* Thts !s about a 20% !ncrease over total U.S. coal consumption and about a 25% tncrease {n consumption of coal by U.S. electric utilittes.** Coal transportation factlitles could ship this Increased tonnage only with extreme difficulty.*** Using coal plants to makeup thls energy would also require about 600,000 barrels of of! per month, primartly as transportation fuel. The 1978 nuclear fuel and O&M costs are at most 8 mills/kWh whereas, , comparable costs for coal fired generators are approximately 15 milis/kWh.**** The coal estimate, which Is based on 1977 actual dellvered prices, probably understates the 1978 cost of coal glven the recent coal miner wage settlement. Furthermore, a 20% Increase fn demand whitch would result from a nuclear plant shutdown would provide further upward pressures on price. In any event, the I5 mill/ kWh value was selected with the recognition that {+t may const!tute an additional conservatism on our ultimate estimate. Given the assumptions spec!ffled above, the average production cost differential between coal and nuclear !s 7 mills/kWh. This cost differential {s then multip!fed by the number of kWh's of nuclear generated electricity foregone due to the shutdown. Thus, If all of the 25 billfon kWh's are madeup with coai units, the economic penalty tn {ncreased production costs alone would approximate $175 million per month. These costs would be borne by each ut!lity and Its customers {n the same proportion as {s thelr ownership In nuclear capacity. If the shutdown {s extended In time, the monthly economic penalty would In all probability be even greater because even equivalent escalation rates {mpact more heavily on coal production costs which are over 80% more at the present t!me than nuclear production costs. Electric Power Supply and Demand, 1978-87 For the Contiguous Un!ted States, DOE/ERA-0018, July 1978. HK Annual Report to Congress, Energy Information AdmIin!stration, U.S. Department of Energy DOE/EIA-0036/2, 1978. HEE Transporting the Nation's Coal: A Preliminary Assessment, U.S. Department of Transportation, January 1978.
- K[lowatt hour costs are commonly measured In mills. Ten mills are one cent.
Optimistically, electrical outpu+ from coal-fired untts can be expanded by about 52.* Thts would produce nearly 5 billlon kWh's or 20% of the total deficit. Ustng coal for this portion of the deficit would cost about $35 millfon per month. A+ least the remaining 80 percent would have to come from other fuels, if the electricity Is to be suppl ted.
- 3. Ol! As Replacement Energy As a second approximation I+ !s assumed that the makeup power wll]
come from units utiltztng of! as fuel. This fs more !tkely than the coal scenarlo but ts also subject to Impractical!ty. There fs a, mixture of generating units using petroleum products. Base load unfts generally use fuel of! while combustion turbines and combIned cycle, which are for peaking, use more expensive fuel, (distillate, diesel fuel, etc.). Many of the of] unfts which as destgned for base load are old and are not presently used fn that capacity. Peak!Ing un!ts would require major overhauls !f required to run flat out for a perfod of a few months. Also, the Increased olf! requirements would be considerable and would have a significant effect on of] prices and tend to further depress the value of the dollar. It would require more than 35 mfllfon barrels of of] per month. This would result fn a 6% I!ncrease !n a demand for of}. If It were suppl fed by Imports, which would be Ifkely glven current domestic supplies, !t would require about a 13% tncrease In ofl imports. On an Immediate bas!s, I+ Its questionable whether the U.S. could Increase of! production and transportation to meet th!s demand. International trade In of! couid be disrupted. The 1978 of! fuel and O&M costs are estimated at approximately 30 mi!ls/ kWh. This results In an average production cost differential between nuclear and of! of 22 mills/kWh. Applying fdentical assumptions as were used In the coal example and assuming all the deficit Is made up Fowler, Goble, and Hohenemser, "Power Plant Performance" tn Environment, Vol. 20, No. 3, April 1978. We belfeve a 5% Increase !s quite optimistic. Although most coa! untts are base load, I+ has been argued that coa! unlts are used for load following. If they were not used for load following about 5% addittonal output could be possible, agaln assuming there fs sufficlent capability to ship the additiona! coal.
29 from of! results In Increased production costs of approximately $550 mil!flon per month. These costs are probably also under-stated because of the expected Increase fn ol! prices due to this surge In demand. If ts ft assumed that the 80% of the deficit which cannot be suppl ted by coal fs supp!fed by ofJ-fired plants, the additional cost of this electricity fs $440 million per month. Adding thls to the cost of supplying 20% of the deficit by coal sums to $475 miliion per month. Before going further, a note should be made concerning the expression of the Impacts tn dollar costs. Dollars have no value In and of themselves. They are only an expression of the amount of goods and . services which can be purchased. There fs a direct and immediate Impact on the public welfare of Increastng the payments for electricity. This means that other goods and services must be sacrificed by the public, among the myrltad fs health care. If one were certain what the public would sacrifice to pay the additional cost for electrical energy, the Impacts could be expressed In these goods and services rather than dollars. Dollars are merely a convenlent way of expressing the real Impact.
- 4. Cco-~s:quences of Electrical Energy Shortages The substantial risk that some of all of the ceficit from closing down nuclear power plants cannot be replaced by other un!fts ~cessIi tates a treatment of the potential ftmpacts of electricity shortages. There would undoubtedly be a preferential treatment to customers depend!ng on the serfousness of a supply shutoff. Residential and municipal!
(e.g., street lIghting) IIkely would be given preference. The Immediate past winter shuws an example of this. When natural gas supplies to sectlons of the eastern U.S. did not meet demand, selected Industries were required to shutdown. A similar requlrement would Ifkely result In the case of an electrical shortage. The 25 blII!lfon kWh supplied by nuclear power per month {fs 20% of the total electrical power used by the commerctal and Indusirtal sector. If these two sectors shared In absorbing the total shortfali of electricity, up to 20 precent of these Industries might be required to close down or reduce production by 20%. Considering the disruptions which occur when one Industry closes down, for example, dur!ng labor-management dispute, closing down 20 percent of commerce and Industry would have a very significant Impact.
30 Of course, there are a Sarge number of possible allocation schemes. If, for example, the two Industries using the greatest amount of electricity were shutdown, that Is chemicals and allted products and orfmary metal fndustries, this would accommodate the shortfali resulting from closing down nuclear power plants. Besides the direct loss of production and wages of 17 bilifon dollars per month (based on 1976 data) closing two such Industries would have an unquantiflable but significant effect on the U.S. economy. Residential and municipal customers could share the burden of shortages with the commerctal and Industrial sectors. Among other things, due to the number of customers Involved, this would create an enforcement problem of much greater magnitude than when only Industrfal and commercial customers are Involved. More Importantly, shifting of shortage to these customer classes Impacts much more heavily on basfc needs for survival. The cost of not meeting demand Is a subject that has been given considerable attention In recent years. As recently as July, 1978 the Department of Energy (DOE) released a study entitied, "Impact Assess-ment of 1977 New York City Black Out".* This study concluded that the cost of unserved energy during a 1977 black out totalled $4.11 per kWh. The study also cites other estimates for unserved energy that range from 33 cents to $91 per kWh. Apply!ng the low end of thls range for conservatism (33 cents per kWh) to the 25 bil !lon/kWh per month of displaced energy results In a monthly cost penalty of about $8.3 billflon. Even {ff only a part of the electrical needs went unserved, the cost could wel! be In the billions.
- 5. Impact on Rellabllfity of Electrical Supply The generating capacity avallable to an electrical power supply system must exceed the demand at all times, If rellable service !s to be provided. Most uti! Itles, therefore, need planned reserve margins falling within the range of 15% to 25% of system peak demand. This reserve !s not to be confused wlth surplus capacity. The reserve Is needed to malntaln relfable service In the face of a number of contingencles. Some of these contingencies are: forced outages, scheduled malntenance, higher load than expected, delays In scheduled additions, unforeseen shortage of fuel, and unforeseen env!lronmental and safety lImitations.
- Impact Assessment of 1977 New York City Black Out, U.S. Department of Energy, DOE HCP/T5103-O!, July 1978.
3 Nuclear un!ts are base load un!ts and are added to a system where there {s a need to meet large energy demands. However, because these same nuclear un!ts are an Integral part of a system capability they also contribute to that system's reserve margin. Thus, a decision to deny thelr use would not only reduce a system's ab! lity to meet energy load but also would reduce reserve margins and rellablil ity. Presently, the U.S. Is organized Into nine Regional Electrical Relfablifty Councils. Among other purposes these are designed to exchange power between utll!tles to accommodate unexpected capab!!I+y shortages of Individual ut!l!tles. Based on the 1978 fllfngs by *+he' Regfonal Electric Rellabil!ty Courclls, we have estimated the effect on reserve margins at the RellfabI!!ty Councl! level of fore closing the use of nuclear capacity. The effect on Individual ut!tittes would be greater. In the winter of 1978-79, the Southeast RellabIl!ty Counct! (SERC) and the New England Power Poo! (NEPP, a subset of the Northeast Power Coordinating Councf!) are projected to experlence thetr annua! peak. The removal of al! nuclear units from these two systems would result In unacceptably low reserve margins of 11.5% (NEPP) and 10.6% (SERC). However, because al! other relfabIl {ity councl!s are projected to peak during the summer, thelr winter reserve margins wil! probably be adequate to provide the necessary support for maintaining rel labIil!ty In the two defic!l+ areas. However, If the nuclear ban extends Into the summer of 1979 when most systems experfence thelr annual peak, the Intertte support will be significantly weakened. For the nation as a whole, reserve margins will approximate 15.6%. However, because nuclear capacity !s spread unevenly among the rellabll{fty councl!s, actual rellablifty will vary dramatically from a negative reserve for the Mid-Continent Area Relfabllfty Council! (MARCA) to a reserve margin of over 30% for the Electric Relfablil ity Councl! of Texas (ERCOT). In all, 5 of the 9 relfablifty councils wil! have reserves below l5%.* Hypothetically, power can be Interchanged between rel lab! Ity councils to achleve the above kinds of shortages. However, on the scale that would be required, there fs !{!ttle assurance
- U.S. DOE - Electric Power Supply and Demand 1978-87 for the Cont!guous U.S., July 1978 DOE/ERA-0018.
32 that thts could be done. During the I!!-day coal strike (f.e., nearly four months) I5 billion kWh's were transmitted Into fuel short areas across RellabIlity Counctis.* This Is an average of 4 bIl!lon kWh's per month. The transfer capabilities were able to supply rellable service during this time. Whether a major portion of the 25 billion kWh's deficit could be trans-ferred 1s highly uncertain. Such requirements have never been placed on the nation's bulk power supply system,
- 6. Al! Nuclear Fuel Cycle Faci!Ittes ;
The treatment so far has only dealt with the power generation Industry. There would be direct and secondary Impacts throughout the range of nuclear fuel cycle activittes If these were closed down, In 1976, there were over 130,000 workers employed In al! phases of the nuclear fuel cycle.** These would be face unemp! oyment+ under an emergency shutdown., The Income derived from all phases of the nuclear fuel cycle was nearly $9 bIl!fon In 1976, measured In terms of value added. This severe economic disruption could cause a situation equivalent to a major strike. B. Long Term Effects A permanent ban on the operation of nuclear power plants would have severe economic consequences for the nation. Electric utflittes, without such a ban, will add substantial nuclear capacity to that already on Ine. The following discusstfon wll! discuss Impacts over the next !0 years as an example of the long term. Over the next 10 years an additional 109 nuclear unIts total ling about 119,000 MWe are scheduled to be added. These nuclear additions constitute approximately 50% of the total projected net Increase In U.S. electric capablifty and by the end of 1987 fs expected to bring nuclear's share of total U.S. electrical capability to
- 8th Annual Review of Overall! Rellabilfty and Adequacy of the North Amerftcan Bulk Power Systems, Natlonal Electric Relfabfltty Counct!, 1978.
- An Economic Definition of the Nuclear Industry, prepared for Office of Planning and Analysis, U.S. Nuclear Regulatory Commission, Aprfl 1978.
approximately 20% and electrical output to 27%.* Furthermore, most of these scheduled nuclear add!tions are already In some stage of the I{icensing process and as of March 31, 1978, 69 of these proposed nuclear additions were already under construction.
- l. Replacement Energy and Cap!tal Costs The cost of replacement energy will be higher In the future, both because nuclear plants are planned to have a bigger share In electricity production and the fuel cost differential !s expected to widen. In 1987 the deficit to he made-up by replacement power or by reduced electricity use !s forecasted to grow to 980 bIIlfon kWh !
(as average of 82 bi!l!fon kWh per month). The uncertainty as to the renlacement energy {n the near term Is great, forecasting for decade !s much more uncertain. There fs sufficlent time to bulld coal plants, the next cheapest source, to replace most of the nuclear capacity. Other types of plants can be bullt In less than 10 years. However, the massive construction program which would be required makes th!s accomplishment quite uncertain. Assuming coal plants do replace nuclear, the fuel and O&M cost differential {!s forecasted to be 10 mills per kWh. Nuciear O&M costs are forecasted to be 15 mills and coal 25 mills. This would cause a total cost {ncrease of $820 million per month or $9.8 billfon per year. Mak!ng up part or all! of the cost with of! would lead to even higher costs of alleviating the deficit. A permanent shutdown would mean not only the production cost penalty, but the need to replace the plants. The 50,000 MWe of capac!ty now ex{sting plus the Investment already made In the 69 plants now under construction would have to be replaced by the construction of non-nuclear units. Very conservatively 10% of the Investment In the plants or about 7000 MWe under construction would be !rretrfevable under a nuclear ban. This !s added to the cost of replacing the undepreclated value of the 50,000 MWe of current capacity. A con-servatively low cost of thls replacement capacity over the next 10 years $s at least $1200 per kWh. Thus, a total of some
- $600 bil lfon would be required to replace this capacity. This Is In addition to the expenditures already planned to make the needed additions to the nation's electrical generating capacity.
- 8th Annual Review of Overall! Rellabll!ty and Adequacy of the North American Bulk Power Systems, Natlonal Electric Rellabll!ty Councll, August 1978.
34
- 2. Impact on Electrical Rellabllf!ty and Energy Shortages The potential for adjustments are great over a long term period.
However, the massiveness of the effort required to make plans for switching the 169,000 MWe of nuclear capacity (1987) to other fuels are also great. An optimistic assumption Is that the adjustments could be made so that electrical relfab!lity and adequate supply of electrical energy would be restored. I+ must be emphasIzed, however, that this fs optimistic. Electric fndustry analysts are already concerned that capacity may be Insuffictent beginning In the early 1980's.* A nuclear ban would only add to these concerns. Severe pressures already are on the coal mining industry to expand production to replace ol! con-sumption. A nuclear ban would worsen these pressures. Relying on of! means not only high costs, but the uncertalnty of foreign supplies. Implementation of the 1977 Clean Alr Act Amendments, which require extensive additions to pollution contro! for coal plants, could delay the construction of 77,000 MWe of coal plants planned durtng the next 10 years. Those coa! plants now under construction are expected to be delayed at least a year. I+ Its, therefore, questionable that coal plant construction could be speeded up to replace the nuclear deficit without retracting the nation's commitment to clean alr. Therefore, there Is a possibIi!ty of electrical shortages and the accompany!ng economic and socfal dislocations over the long run, as well as belng an Immediate possibil!ty. As Indicated In the discus!on of Immediate effects, energy shortages of the magnitude at rfsk under a nuclear ban could be serlous. C. Conclusion The adjustments made to a shutdown of al! nuclear fuel cycle factiIttes would be elther to replace the electrical energy with generators using other fuel types or a decrease of up to 13% 8th Annual Review of Overall! Relfabli!ty and Adequacy of the North American Bulk Power Systems, National Electric Relfabllfty Councll, August 1978,
currently and 27% within a decade !n the use of electricity. Efther would cause severe economic, socla! and perhaps International disruptions. The staff has great difficulty !ientifying a most IIkely result from each. A reasonable expectation fs the case derived above where!n there would be a monthly cost of $475 million In replacement power costs. Thts would Increase each year as bigger and bigger shares mus+ be made up to replace the capacity otherwise planned to be supp! ted by nuclear. By 1987, there would be an annual cost of $9.8 blilion In replacement power. Beginning In the summer of 1979 and continufng at least through the mfid-1980's there are I!kely to be generallzed relfabflfty problems resuiting In substantial Increases In the number and length of blackouts. There may well be energy shortages beginning fmmedtate-ly and continuing as difficulttes in adding to capacity and securing fuel supp!fes continue. This wil! severely Impact Industry and commence measured In tens to hundreds of billions of dollars per year depending how successful generating plants burning other fuels are at replacing the nuclear deficit. Responses to Petition Principles and Evidences The petition summarizes the materfals presented thereln by emphas!{z-Ing certain medical and jur!sprudential principles, and physical evidences. It Is the purpose of thls section of the NRC response to discuss specifically al! of the principles and evidences on the basis of the staff's analysis of the Issues and of avaliable technical and legal Information. The sectfons that follow wil] first repeat the petition evidences and princtples and then present the staff's response. A. Medical Principles Petition Principle 1. The effects of radtation on the human blo-logical organism Include direct and fndirect cellular destruction and mutation, resulting In a broad spectrum of health effects Including carcinogenesis, mutagenesis, teratogenesIs, and al] effects of reduced Immunity.
Response 1. The effects of Individual {!nteractions between x-rays, neutrons and fonizing particles (beta and alpha particles and protons) and blological systems at the cellular level are well known. It Is also widely accepted, on the basis of experimental evidence obta!ned primarfly at high levels of radiation compared to normal isuman expe-rience (such as natural background radiation), that exposure of the whole body or specific parts to fonizing radiation may be carclino-genic, teratogenic and mutagenic. It {fs further known that other blological effects are possible, Including the formation of cataracts, non-specific I!fe shortening, and lethality (at very high doses and dose rates relative to normal human experfence). These effects can be considered wel! known, thru animal and human . data, again primarfly at high radiation levels, particularly In compar{son to the deleterfous effects o* many other known or sus-pected harmful chemfcal and physical agents to which humans are exposed. Because of the knowledge of harmful effects of radiation, there has been a major effort In the technical community for years to try to determine the exact relationship between a dose received by a blo-logical system and a specific health effect such as cancer. The NAS-BEIR report, referenced {in section l! A above, used avallable radfological, blolocical, and epfdemlological data and Information to provide numerical values of the relationship between human radiation exposure dose and effects, both somatic and genetic. The report also supports the extrapolation of the results obtained at high doses and dose rates, down to zero effect for zero dose, ona l!near basts. The NRC has used these results {n the health effects determined for the nuclear fuel cycle, as discussed In l and ll above. It has used conservative practices In standard settings based on the dose-effect relationship also discussed earlier. Nevertheless, {+t should be re-emphas!zed that at the extremely low levels of radlation exposure to the public from the nuclear fuel cycle (f!.e., an average exposure of less than 0.1 mrem per year), there are no known or sclentifically proven effects of radiation exposure to humans. The NRC suff continues to follow closely al! major research or study proazams on effects of radiation exposure on humans, and wi! adjust the regulatory radlation protection standards whenever sclentific evidence supports such adjustment. In addition, the NRC will continue to regulate the faciIitles of the nuclear fuel cycle {n a manner such that radiat!on exposures wlll be as low as {s reasonably achievable.
Petition Principle 2. The combination of rad!ation with other environmental toxins may produce a synergy more Jethal than any single component acting alone. Response 2. The NRC staff agrees that radlation exposure comb!ned with other environmental agents may produce a synergistic effect. However, it should be noted that all of the data used by the BEIR Committee In 1972 were data from real human. populations exposed to many other environmental agents and stresses Including cigarette smoking, urdan alr pollution, and Industrial occupational environ-ments, as well as exposures to medical and dental x-rays, varlous drugs, food additives and other agents. In that sense, all such l potential synergles were part of the human data collected and considered by the BEIR Committee. Until completion of the new BEIR report and the HEW Task Force study on the effects of low-level radiation, both discussed earller, the staff belleves that the 1972 BEIR report {ts appropriate for standard setting, and that the dose to risk conversion factors used by the NRC staff from that report are proper. Princtple 3. While background radiation may be necessary for an orderly pattern of aging and death, faclIl{tating evolution, It represents a bloligcal hazard to a given Individual. Natural background radlation may be responsible for 50% of all disease, 75% of all non-accidental deaths. Response 3. The staff does not agree that natural background radiation may be responsible for 50% of all disease and 75% of al! non-accidental deaths. There are no proven or demonstrated health effects associated with exposure to background radtation. Attempts to correlate cancer and other forms of II! health with the variations In natural background radiation have elther falled or have been Inconclusive. (See Adisr and Welnberg, for examp!e.*) In thelr 1972 report, referenced above, the BEIR Committee considered all of the pertinent data relating to poss!ible health effects from natural background radiation and concluded that the total number of excess deaths due to background radiation (100 mrem/yr) might Ile between
- H.I. Adler and A. M. Welnberg, "An Approach to Setting Radiation Standards, Health Physics 34 719, (1978).
1,210 to 8,340 In a stable population of 198 millfon (1967 U.S. population). Vital statistics* show that In 1967, 157.2 deaths due to cancer occurred per 100,000 population. Thus, there were 31!,000 cancer deaths {n the U.S. during that perfod. Using BEIR estimates natural background radiation therefore might have accounted for between l or 2% of the observed U.S. cancer deaths. Since the 1972 BEIR Report, there have been additional reports of studies of human populations exposed to higher than average natural background radiation. The most recent of these reports {s that by A. Frelre-Mala and H. Krfieger** which concluded that "the results showed no detectable effect (emphasis added) of natural radtation on the sex ratio at birth, on the occurrence of congenItal anomalles, and on the numbers of pregnancy term{na-tions, stillbirths, I{vebirths, and post-Infant mortality Jn children, as well as fecundity and fertil!ty of the couples". The staff agrees with the authors' admonition that "nonsignifi-cant results cannot be considered as disproving harmful effects of natural radiation on mortal!ty and morbidity" and that "other causes of mortal!lty and morbidity are so Important, under the conditions of the study, the contribution of low-level, chronic natural radiation !s made negligible". However, If natural back-ground exposures on the order of 100-200 mrem/year were causing 50% or more of observed deaths and !IIness, there would be very demon-strable effects correlations In high exposure groups. The fact that such effects are not observed** supports the 1972 BEIR estI-mates in that whatever health effects may be caused by natural background radiation, !f they exist, they must represent a smal part of the total health effects being observed In the real world. Serfes B 149-166, 7 YUU, Historical thiotuwi eG Statistic Ss tics of the U.S. (Part 1) Colonlal Times to 1970, Bicentennial Ed!tionfon, U S. Dept. of Commerce, Bureau of the Census, Wash!Ington, D s G - (Sept. 1975) A. Frelre-Mala and H. Krieger, "Human Genetic Studies In Areas of High Natural Radlation-IX. Effects on Mortal!ty, Morbidity, and Sex Ratio", Health Physics, 34, 61, (1978).
This concluston {ts supported by earller studies* of U.S. population cancer statistics In areas showing significant variations Jn natural background due to latitude, altitude and In studies of populations {n high natural background areas !n Kerala Province, IlIndia.** Petition Principle 4. Blological effects of some forms of radlation are superlinear In dose response, rising very rapidly at low expo-sures. This assumption Invalldates previous recommendations of the NAS-BEIR, NCRP, ICRP and other sources, upon which the federal regulations regarding permissible dose rates are based. ' Response 4. The petitioner presents 3 graphs (Figure 2 on page 9, Figure 6 on page 18 and Figure 20 on page 33) to support her allegation that there !s a superl{!near dose response at low exposures. The type of rad{fation used !n the exposure recorded In all of these graphs {s alpha particle radiation. Figures 2 and 20 give doses In rads (the unit of adsorbed dose). Because alpha particles have high LET (ltnear energy transfer), these dose values should be multIplied by at least a factor of 10 to obtaln the dose equivalent !n rems (the unit of absorbed dose multipl!ed by the quality, or effective-ness factor). Thus, the lowest dose group In Figure 2 Is equivalent to about 90 rads (or 90,000 mrads) and the lowest dose group In Figure 20 {s about 100,000 mrads. These doses are exceedingly high compared to the population exposures that are discussed earlfer for the uranium fuel cycle.
- N.A. Figerto, et al, "The Argonne Radlological Impact Program (ARIP)
Part l, Carcinogenic Hazard from Low-Level, Low-Rate Radlation, ANL/ES-26, Part l (Sept. '73). N.A. Figerto and R.S. Stone, "Carcinogenic and Genetic Hazard from Background Radlation" {n Blological and Environmental Effects of Low-Level Radiation, pp. 385-393, IAEA, Vienna, (1976). A.P. Jacobson, et al, "The Role of Natural Radfations {n Human Leukemogenes!s", AJPH, Vol. 66, No. 1, pp. 31-37, (Jan. '76). 4% K.P. George, et al, "Investigations on Human Populations Residing In High Background-Rad!ations Areas of Kerala and Adjolning Regions", In Blological and Environmental Effects of Low-Level Radiation, Vol. Il, pp. 325-329, IAEA, Vienna (Jan. '76).
The petittoner has m!sinterpreted the slgniftcance of both Figures 2 and 6. The signiffcance of Figure 2 Is discussed more completely In the response below to petition (medical) principle (5) on page 33 of the petition. With respect to Figure 6, If the dotted !fne tn thls figure were the actual dose response, then {+ would provide evidence of a threshold dose below which there were no health effects, slace It Intersects the horizontal axfs (zero excess cases) at a positive value of mean bone dose. Petitioner's Figure 6 Is an Incomplete reproduction of Figure c-! on page 130 of the 1972 BEIR Report. The complete figure c-1 {fs reproduced below. If the dotted curve were the most appropriate dose-response curve, then the curvi l Snear portion falling above the I{!near curve (with slope 0.11/10° per year per rem) !!es In a dose range of approxt-mately 8,000 (8,000,000 mrem) to 80,000 rem. This !s far,far above the permissible human exposure standards which !!Im!+ the annual bone dose rate to 30 rem In the last year follow!ng 50 years of cont!nuous occupational exposure. If thls dotted curve were correct, and {ft were further assumed that the curve fntersected the 0-0 of the axes (no threshold dose) the !!near extrapolation mode! would overestimate the dose response a+ doses below approximately 8,000 rem, because the !Inear curve would Ife above the continuation of the dotted curve. The BEIR committee considered the possible forms of the dose-response relationship and, for somatic effects, concluded that a quadratic dose-response would be more representative. However, because of prudence, I+ was decided to use a lInear cose-response relationshIp. There have been no human exper!ments or observations fn human populations which would Indicate conclusively that the BEIR risk values based on a !{!near dose-response significantly underestimate the health risk from exposure to lontzing radlattion. Petition Principle 5. Present evidence suggests that for all cancer the Increased risk may be from 1% per mrem to 0.5% for each rem whole body exposure when exposures are brief, and 10 to 100 times greater for prolonged low doses. For leukemla the doubl!ng dose may be ! to 5 rads In adults, and I5 times tn developing embryos. An annual dose of 25 mrem from environmental exposure may glve at least 1.0 to 10% tncreased cancer risk.
12,000 [~ RISK OF BONE CANCER VY RADIUM 226 EXPOSED GROUP DIAL PAINTERS FOLLOWUP THROUGH 1971 10,000 - 7 oe cc -° z 2 8,000-ac 4 a. Zz i 3 6,000 /-
=wn uw wn
© 4,000 f-17) uJ oO x
=
2,000 l-O ! ! ! ! J J 20,000 40,000 . 60,000 80,000 100,000 120,000 MEAN BONE DOSE (REM) i
+ series of subjects exposed to radium-226 in Figure c-1. Dose-response data for bone cancer in Argonne National Laboratory given radium therapeutically.
period from 1915 to 1935 (8, 9). This group includes dial painters and some patients Ordinate: Excess bone cancer cases per million person years , Abscissa: Mean bone dose in rem (RBE=10). weighted mean slope taken from Table c-1. Error The dashed line is drawn by eye through the points; the solid line is the bars based on Poisson statistics and include 90% range (see Appendix IV).
*The Effect on Populations of Exposure to Low Levels of Ionizing Radiations, NAS-BEIR, (1972)
42 Response 5. The staff !s not aware of any biological data which indicate that the doubling dose (the amount of radfation needed to double the natural fnctdence of a genetic or somatic anomaly) for cancer from brief (acute) exposure to low level fon!izing radiation "may be as little as 100 mrem (1% per mrem). A doubling dose of 200 rem (0.5% per rem) {ts probably a reasonable upperbound estimate for al! cancers. This {!s obtained as follows. The BEIR Report* (referenced earlfer) estimated that the "most I{fkely" risk of cancer from background radiation to the U.S. population {fs on the order of "3,000 *o 4,000 cancer deaths per year (or a 1% Increase In the spontaneous rate)." This value represents a risk over the I!fetime of Individuals from constant (chronic) radiation at the rate of 100 mrem/year. This Impl!es a doubling dose of up to five hundred rem for total body Irradlation. e.g.: 100 mrem/yr x 50 yrs at risk/IIfetime <<. 500 rem/IIfetime 1% {ncrease 100% {!ncrease The staff !s also not aware of any blological data which Indicate that the doubling dose for all cancer from chronic exposure to low level fontzing radiation may be as Il{ttle as l mrem. In fact, most of the petitioners own references which Indicate the possibility of a 100 mrem doubling dose (Petkau; Stokke-Ofedal and Pappas; Scott, Stewart, Porter and Serafinejad) are polnted at determination of one of the mechan!sms by which radiation damage
!s produced. Changes In membrane permlabil!ity by the Indirect action of fonizing radlation !s not surprising. It Is, however, not the only mechanism for radtation damage. In any event, the Impact of the change !n permiabIIIty of bone marrow cells and erythrocytes extended to the doubl!ng dose for appearance of clinical cancer {!s not clear.
The interpretation of the work of Sanders et al, made by the petitioner on pages 8 and 9, !s In conflict with Dr. Sanders! Interpretation of his own experimental results. (Ref. C. L. Sanders, Rad Res 56, 540, 1973 and Personal Communication, Parsont (NRC staff)- Sanders, September 15, 1978]. Sanders Indicated that his results e.g.: pp. 168
showed no statistically staniffcant Increase {in cancer above contro! levels below !l or 2 rads (10 to 40 rem, depending whetner a quality factor of 10 or 20 {s used for alpha particles). Two of the curves attr{buted to Sanders on page 9 of the petitlon were not contained In the referenced article but apparently were drawn from data contained In the abstract of Sanders' article. The I{ne (c) In the petition Figure 2, page 9, which purports to represent the expected risk from the I{inear hypothes!s, was not part of Sanders' work. In addition, {t ts Incorrectly drawn !f, In fact, It !s based on Sanders! data. The labeling of the abc!issa fs Incorrect--It should {ndicate "Lung Dose In Rads". Because of thls, curve (a), which !s Identified as Incidence of all tumors, makes no sense because there !s no direct. ! relationship between lung dose, the measured quantity, and other cancers to which humans are subject. In addition, the petitioner did not account for the difference In effect of high versus low LET radiation, the fact that the dose levels given were at 2 years past exposure and that Figure 7 of the article shows that, for all non-mammary tumors, the slopes of percent cancer Incidence versus life span curves for the 3 exposed groups are approximately the same. The staff concedes that, for certain radiation effects, there have been experiments which Indicate that the slope of effect (Induction of certain specific tumors, for example) versus dose relationship may be steeper at-low doses than at higher doses. However, the extension of these results to all cancers !s Improper. In addition, the BEIR Report, UNSCEAR (1977), NCRP (Report No. 43) as have been referenced earller, and Dr. Radford In hls testimony of February 8, 1978* {tndicate that the I{near dose response hypothes!s does not significantly underestimate the health risks from exposure to low level radiation. Petition Princtple 6. Preconception and In-utero exposures result In stochastic effects which pred!spose Individuals to diseases Involving decreased Immunity for thelr entire Ifves. Response 6. The princ!pal work relating preconception and {n utero _radfation exposures to decreased !mmun!ity was conducted by
- E.P. Radford, Testimony of Hear!ngs On Low-Level lonizing Radfation Subcom!ttee on Health & Environment, U.S. House of Representatives Committee on Interstate and Forelgn Commerce, (Feb., 1978).
44 Dr. Irwin Bross ut!lizing the Tri-State leukemia data. Bross's hypothes!s was that both leukemla, and certain other diseases, !.e., asthma, urticara, eczema, pneumonia, dysentery, and rheumatic fever, resulted from genetic damage to germ cells prior to conception, or to genetic components of cells involved {In blood forming systems during {n utero exposure. More specifically, Bross postulated that radiation-tnduced misinformation in a cell's genome impairs feedback machinery that controls the white cell population. It Is this fallure of feedback control that leads to {Irregularities Jn the whIite cell population, and the consequent diseases. In a secondary sense, since leukemla Is a disease of part of the Immune system, pre-leukemic Impairment of the immune system may render Individuals more susceptible to Infectlous diseases. This possibility was polnted out In 1973 by revlewers* of Bross anu Natarajan's work and supported by Dr. Alice Stewart at a recent Informa! seminar sponsored by HEW.** Dr. Stewart commented that In her clinical experfence persons with Inciplent leukemia were especially prone to pulmonary Infectious diseases, e.g., pneumonia. Th!s concept of a pre-leukemic state of Immuno-suppression !s apparently supported by the Diamond, et al, data referenced by the petitioner. However, {t should be noted that radlation-induced !mmune suppression which {fs a mantfestation of Incipflent leukemla, must be viewed as a second-ary rather than a primary effect of radiation, and !t can be argued that this decrease {n Immunity Is !nconsequential since leukemla ts generally fatal. With respect to preconception (JSn-utero) {rradlation, reduced Immunity must be viewed In the context of other radiation-!nduced genetic effects. According to the Bross model the relative risk of Infectious disease In the first generation Is 5, but for only l% of the population, which !s only 10% of the leukemia risk found In the same study. Reviews of Dr. Bross's work have been obtalned from NRC consultants or carrfed out by the staff and are
- P.G. Smith, e+ al, "Multiple Factors In Leukemogenes!s", Br. Med. J.,
- p. 482, (26 Me., 1973).
- HEW Work Group (L!bdass! Task Group) Meeting, July 6, 1978, Humphrey Bldg., Washington, D.C.
contained fn Enclosure O of the Commission paper SECY 78-415 (1978).* If tt fs correct that the fnher!ted m!siInformation (genetic miscodtng) was expressed as defects fn the first generation following Irradlation, thts would suggest a dominant or seml-dom!nant+ component to the genetic effect. The 1972 BEIR report considered that the rate of Induction of domfnant visible mutations was at least an order of magnitude lower than that for recessive specific locus mutations. The !977 UNSCEAR report (referenced ear!tter) also fndicates that radiation Induced recessive mutations are prohably more frequent than dominant or semfi-dominant mutations. These statements are made to add some perspective to the poss!Ib!e risks Involved. Although ' the concept of low level radlatfion-{induced fmmuno-suppression Is supported by recent work, and Is suggested from the above discussion, this form of radiation damage requires much additional study before any dose-response for Immuno suppression can be rellably quantified In the larger context of total radlation-!nduced somatic and genetic risk trom low-level fontzing radiation. Petition Principle 7. Of all the known and suspected carcinogens, mutragens, and teratogens, radlation appears to be the single most certain and potent. Particle for particle, radionuclides may be 100 mil lfon times more toxic to developing embryos than thal ldomide. Response 7. The petitfoner relfes upon the studies of Dr. L.J. leVann.** The NRC staff has reviewed this paper and found no support for the petitioner's statement that radtonuci!des may be 100 millfon +!mes more tox!c to developing embryos than thal!ldomide. Furthermore,
Enclosure 0 = Summary of the Staff Evaiuation of Finai Report #13 by Thomas F. Mancuso; and Reports by a Consultant to the Staff on the two papers, Genetic Damage from Diagnostic Radiation, and Leukemfa from Low Level Radlatiton--Identification of Susceptible Children, by !.D.J. Bross, Jr. and H. Natarajan. Attachment 1, Review of Final Report
#13 Submitted by Thomas P. Mancuso, M.D., by David Rubinstetn (NRC);
Attachment 2, Review of 2 Bross, Natarajan papers by Dr. Rothman of Harvard Schoo! of Public Health.
- L, J. TeVann, "Congenital Abnormal !ttes tn Children Born In Alberta During 1961: A Survey and a Hypothes!s" Canadian Medical Assoclation Journal, 89: 120-126 (July 20, 1963).
Dr. leVann examined congen!tal abnormalities as a function of rainfall !n particular areas of Canada. The paper contalns no measurements or data to relate rainfall and radiation exposure. The relationship to radtoactive fallout ts stated by Dr. leVann to be an hypothes!s to explain the possible association of rainfall and congenital malformations. The NRC staff notes that even th!s assocfation was not determined to be statistically valid as no statistical tests were appl led to determine whether the apparent relationship of congenital disorders and rainfall was purely due to chance. Lastly, even If such a relationship were found to be statIstically significant, the possibility of other tox!c agents such as ' sulfur aicxide being present In ratn was not examined. Such : agents are known or suspected to be carcinogenic, mutagenic or teratogenic, and may wel! be more certain and more potent. The lack of nearly as much sclentific data or many other toxic agents relative to that on radioactive materltal makes It difficult to put them In proper perspective. The NRC staff concludes that petitioner has not presented any sclentifically valid evidence to support this contention. Petition Principle 8. Radiation ts itmperceptible. Radloactive [sotopes are forms of common, blologically useful, readily assimllable elements and have no difficulty traveling withIn the blosphere, the food chain, or the human body. Highly active radiotoxins, such as strontium and plutontum, can even cross the placental barrier to reach the developing fetus. Response 8. The NRC staff agrees that radiation at the very low levels of concern here Is !mperceptible by human senses, and also accepts the general claim that some (but not ail) radto-Isotopes "are forms of common, blologically useful, readily assim{lable elements and have no difficu!ty traveling within the blosphere, the food chaln, or the human body". However, this ts not true for most man-made radionucl{!des such as strontium-90 and plutonium !sotopes. Many of the radlolsotopes are merely chemical congeners (analogues) of some common, bloogically useful elements such as hydrogen, calclum, tron, lodine, and potass!um. Non-essential chemical congeners of
47 essential elements are generally selected agalnst In uptake by I!lving organisms. For example, In man, lICRP-2* Indicates that while 54% of the calcium ingested reaches the bone, only about 9% of the strontium-90 !ngested reaches the bone. The staff accepts the claim that many radionuclides such as strontium and plutonftum, can cross the placental barrier to reach the developing fetus, although there !s also evidence of blological discrim!nation against such nuclides In mammals. For example, Twardock, et al** as early as 1969 showed blological discrimination against strontium and cesium In favor of thelr blologically essential congeners, calcium and potasstum. Petition Principle 9. Not all Individuals In the population are equally susceptible to the effects of lonizing radiation. Susceptible tndividuals may be greatly affected by even extremely minute exposures In addition to natural background radiation. The class of these {ndividuals !s not equally protected by federal regulations designed to protect the general populatson as a whole. Response 9. It Is true that not all Individuals In a population are equally susceptible to the effects of fonizing radfation, or any other biological Insult. The sensitivity of an organism to a given Insult !s a function of Its genetic const!itution and particular mode and circumstances of exposure. In humans, a myrtad of other epidemlological factors have been seen to determine relative sensitivities to a given Insult, Including age, sex, ethnic and soclo-economic status. Because our present state of knowledge precludes al! possible meaningful quantifications of the relative radiosensitivity of a given Individual, !t fs true that persons are not necessarily equal ly "protected" by current federal regulations des!gned to protect the general population as a whole. However, the NRC staff calculations
- Report of ICRP Committee l! on Permissible Dose for Internal Radlation (1959), Health Physics J., (June 1960).
- A. R. Twardock, et al, Comparative Transfer of Calcium and Strontium and of Potass!um and Cestum In the Guinea Pig Placenta, !n Radlo-blology of the Fatal and Juven!le Mammal, 17th AEC Sympos!um Serles, U.S. Atomic Energy Commission, p. 97 (December, 1969).
of the dose to Individuals due to radioactive effluents from nuclear fuel cycle factiftiles do distingu!sh between doses to infants, children, teenagers, and adults.* There has been a ploneertng effort !n susceptible subgroup !fdentI-fication by Bross and co-workers, but critics have cautfoned that the results must be viewed as tentative and preliminary, and require extensive review and confirmation. It should be noted that the Bross work was considered In the BEIR report referenced earlier (see pp. 165-166 for example). On Apri! 7, 1978, the Nuclear Regulatory Comm!ssfon sponsored a : public meeting at which Dr. Bross presented some of hfs relevant findings.** The NRC had previously contracted with Dr. Kenneth J. Rothman, an-Assocfate Professor of Ep!demfology at the Harvard School of Public Health, to critically revilew Dr. Bross work. Dr. Rothman's review was also presented at the meeting. Or. Rothman pointed out that the major public health s!gnificance of !{dentfy!ng susceptible groups derives from the possib{Ilities for prevention specifically for the "hfgh risk" population, but that there were no preventative possib!i!i{ties arising from Dr. Bross' study of susceptibility factors In radlation-{nduced leukem!a, because the susceptible subgroupshe tentatively described are not Identifi-able unt!l after the radfation exposure (the exposures were fn utero). Although Rothman was critical of Dr. Bross! methodology, and did not agree that Bross findings warranted any revision In radiation protection standards, he stressed that the Bross analysis of the Tri-state data was valuable from the standpoint of emphasizing the possibility of a preconception hazard, and descr!b!ing possible risk factors which act blologically with radiation. lf and when future ep!demlological Investigations bring to frultion relfable methods of Identification of "susceptible" subgroups, these
- Calculation of Annual Doses to Man from Rout!ne Releases of Reactor Effluents for the Purpose of Evaluating Comp! {ance with 10 CFR Part 50, Appendix l, NRC Regulatory Guide !.109, (3/76).
- Hazards to Persons Exposed to lonizing Radlfation (and to Their Children) from Dosages Currently Permitted by the NRC l.D.J. Bross, Jr. Trans-cript avallable from ACE Federal Reporters, Washington, D. C.
these can, and will, be incorporated Into a viable nuclear regula-tory program of pre-occupational notification and/or screening, and we would encourage such efforts. Petition PrincIples 10 & 11. 10) Since even the natural background radiation ts Known to result In serfous health effects, any add!tional man-made radiation which Is allowed to be released to the environment can only multiply the Incidence and serfousness of these effects.
- 11) Observed effects on human populations, with studfed groups num-ber{ng in the millions, confirm the serlous underestimation of the health effect predictions embodied In the present regulations. A consequence of the present error has been deaths to {Innocents {fn the U.S. population on the order of tens to hundreds of thousands.
Response 10 & 11. As noted In the staff response to Statement 3, the staff accepts the estimate of the BEIR Committee that background rad{- ation may account for a few percent of the observed diseases and deaths In the U.S. However, that !s not to say that background radiation "Is known to result In serfous health effects". It Is a relatively simple matter to demonstrate that lung cancer, which {!s a major type of cancer potentially associated with the nuclear fuel cycle, cannot be largely the result of background radlation exposure. For example, although exposures to naturally occurring radon-227 , cosmic, and terrestrial radlation has been essential ly constant over the last 200 years*, the lung cancer rate** has been stead!ly rising since the early 1930's. In fact the lung cancer rate for American males has In-creased by over a thousand percent since 1930, while the rate for females seems to be undergoing a similar Increase although lagging behind that for males by about 30 years. While It Is probably true and that these Increases are largely a result of cigarette smoking urban alr pollution, It 1s pertinent to examine the 1930 lung cancer statistics further to establish an upper bound I!mit to the potential contribution of background radfation on lung cancer Incidence.
- Natural Background Radlation In the United States, Report No. 45, Washington, Natlonal Counc!! on Radiation Protection and Measurements, D.C. (November 1975).
Cancer Facts and Figures, American Cancer Soclety, 777 Third
- 1978 Avenue, New York, N.Y. 10017 (1977).
In 1930, the lung cancer Incidence (from al! environmental causes) was abou* 2 per 100,000 persons; nearly the same for both men and women, According to the National Counc!l on Rad!ation Protection (NCRP)* there {s about 100 million to 240 million curfes of radon-.2/. released annually from the surface of the United States. This very larae release results, according to the NCRP, !n a dose rate of abouy 450 mrem/yr to the bronch!lal epfthelfum of the jung (not to be con-fused with the 100 mrem/yr total body exposure from natural background that has been discussed above). I+ fs Important to recognize that the 1930 population, !ncorporating 100's of milllons of persons of al! ages, and al! genetic charac-ter{stics, constitutes a very large group that had been chronically-exposed to low level (natural background, Including radon) Irradiation of the bronchial ep!thelfum and all other environmental agents from birth through death. Cons!dering th!s, and !f one assumes that all of the jung cancers observed [n this population were due to background radiation, +hen the number of cancers must upper bound the potential Jung cancer risk from such sources. As shown above, the annual dose-rate to the bronchlal epfthe!!um would have been about 550 mrem/yr (450 from radon and 100 total body) from al] sources. However, recent measurements Indicate the actual population lung doses may be even higher since most radon-222 exposures occur {ndoors where the daughter concentrations are generally higher than outdoors. The higher concentrations are due primarlly to the emanation of radon from structural materfals (rock, cement, brick, etc), natural gas and domestic water and the fact that slower alr turnover allows the short-I!ved radon daughters to reach much h!gher concentrations then would normally occur fn outside alr. Such concentrations have been found to be 500 to 1,000 pC!/m-(I.e., 3 to 7 times greater than typ!ica! outside alr)**, If the exposures were only 3 times greater than NCRP-45 estimated the typical dose to the bronchlal ep!thelf!um would be about 1,500 mrem(1.5 rem)/year. Natural Background Radfation In the United States , Report No. 45, National Counc!! on Radfation Protection and Measurements, Wash!ngton, D.C. (November 1975).
- Sources and Effects of lontzing Radlation, United Nations Sclentific Committee on the Effects of Atomic Radlation (1977).
lf this were true for the I!fetime expcsure of people who died I[n 1930, then the maximum upperbound risk of lung cancer from Irrad!ation would be: 2 luna cancer deaths per 100,000 people vear = 13 lung cancer deaths 1.5 rem/year 100 man-lung rem For an air concentration of 7 times outside alr, the result of this calculation would be 31 per 106. These numbers compare with the range of NRC risk estimators of 22 to 150 lung cancer deaths per million man-!ung-rem currently belng used. This calculation using real data from millions of people chronically exposed to low-level natural background radiation !ndicates that NRC estimates of the major potential health Impact assoclated with the entire uranium fuel cycle cannot be serfously underestimated as clalmed by the petitioner. B. Physical Evidence Petition Evidence. 1) All stages of the fuel cycle emit radloac-tive poisons to the blosphere which can and do affect the health of citizens. 4) Hundreds to thousands of additional cancers are occurring among citizens now living In the vicinity of the fuel cycle facilities due to the designed routine releases and common accidental releases of radfotoxins. Response 1 and 4. All stagos of the nuclear fuel cycle release some quantity of radioactive material to the blosphere, as {!s documented In the environmental statements Issued prior to I!censing any NRC-licensed facility. These releases are controlled, reported, and monttored both at the release polnt and In the environment, as well as belng evaluated before !!censes are !ssued. As noted In the staff responses to petitioners principles 3, 10, and 11 regarding "Medical Principles", as well as In sections preceeding these, there are no proven health effects assoclated with exposure to natural background radlation, nor to the much lower values associated with ne nuclear fuel cycle. Sifnce fuel cycle releases for a mature nuclear power Indusrry would not result In significant Increases {n background radliation, {t cannot be stated with any degree of certainty that the anticipated releases from the nuclear fuel cycle "can and do" cause health effects. Nevertheless, the NRC staff
prudently assumes health effects may result for purposes of evalu-ating potential future health effects Impacts, and these health effects have been documented In earlier sections of this response. A recent evaluation* of public health trends near nuclear facilities concluded that the norma! operation of nuclear facilities will not have i .fignificant Impact on public health. Physical Evidence 2. There Is no practical method presently fdent!- flable that wll! prevent the release of radiation once uranfum Is mined. Response 2. The NRC staff agrees that It Is not practicle to prevent the release of some radioactivity to the bflosphere once the uran!um has been mined. However, varfous technological options are avaliable to keep such releases as low as !s reasonably achlevable for each step of the uranium fuel cycle and these are belng employed In the industry. The NRC Is respons!ble for ensuring that the radionuclide releases at each step of the uranium fuel cycle are as low as Is reasonably achfevable and do not result In significant !mpacts on the population. NRC responsibIi!i!tfes In thts regard have been briefly described earlfer In this response. Physical Evidence 3. Recently disclosed evidence from NRC [Internal memorandums Indicates that on the order of 100 deaths wil! occur at the milling stage of the nuclear fuel cycle to future peoples for each day that fue! Is produced. Response 3. It ts very difficult to determine the meaning of this "evidence" and the bases that lead to the petitioner's conclusions, since the number 100 deaths at the milling stage does not appear as such In the petition. However, NRC staff's best guess Is that the statement derives principally from the discussfon on page 42 of the petition where Dr. Jordan of the ASLBP, NRC, Is credited with estl-mating that 400 deaths per annual reactor fuel requirement would result presumably from radon released by mil! tallings plles over several half I!ves of thorfum-230 extend!ng over several hundred C.H. Patrick, "Trends In Public Health In the Population Near Nuclear FaciiItifes: A Critical Assessment", Nuclear Safety, Vol. 8, No. 5, (September-October, 1977).
thousand years. [Th!s calculation orlginated with Dr. Pohl tn Search* and has been referenced by Dr. Jordan. ] The pet!ittoner further estimates Pe 42) that the loss of lite among future citi-zens from each year's commitment to the fuel cycle ts 28,000 from mill tallings alone. Thus the projected dally rate given In the physical evidence 3 statement fs obtalined by dividing 28,000 by 365 to obvain 80 which ts "on the order of 100," A thorough review and compartson of the calculations of long term radon releases and thelr effects by Dr. Pohl, by Dr. Jordan of ASLBP, and Dr. Gotchy of the NRC staff** requires careful consideration of the many varfables and assumptions that+ are used In these three different anaiyses. In several respects the calculation methodology and some assumptions and estimates are very simitar. Two assumpttons that are major and about which judgments may differ are noted below: (1) The long term radon release rate from stabil!zed tallings plies. (2) The appropriate time intervals for mezilngful projections and calcu!asrtons. The NRC staff belfeves that (1) tallings plies can be malntalned to lim!+ radon releases to near prior natural background conditfons as required by current NRC IIcens!Ing procedures for extended periods, rather than suffer the early loss of substantial earth cover, a cond!- tton Imp! fictt In Or. Pohli's calculation. I+ should be noted that If deterforation of stabi! fzation cover for tallings plies Its observed, remedial action can be readily taken. As discussed In numerous NRC papers, the below grade disposal of tallings plles and other recommended measures help to malntain long term stabilfzation. (2) calculations of projected health effects from radon releases of +t=ilngs piles beyond 1000 years are without meaning, primartly because nelther population figures nor condition of the earth's surface can be pre-dicted that far ahead. The NRC staff has calculated the Impact from long term radon releases under the assumptions ( judgments) noted above and the results differ significantly from those of the petitioner. For example, If tallings
- R.0. Pohl, Health Effects of Radon-222 from Uranium Mining, Search 7 (5), 345 (Aug 1976).
- For complete reference to the Gotchy work, see page 12, Section Il A.
pile stabilfzation {s mafntatned without sertous degradation for about 1000 years, staff caicualtlons show +hat +he projected number of deaths over that perfod would be about 0.02 per reactor annual fuel requirement. For the present Industry of 70 reactors, the risk from radon emissions of taflings plies for one year Is therefore 0.02 x 70 or about 1.4 deaths which would translate to about 0.004 deaths for each day of operation. This number ts to be compared witn the "order of 100" deaths per day quoted by the petitioner. It ts unlikely that stabflfzation would be maltntatned withou+ some deterforation, so to attempt to bound the problem and provide some ' Indication of the !mpact under severly degraded condIt+ions, cal-culations were made for the follow!ng scenarto: near natural background radioactivity release rates (current stabl!fzatton objective) for the first 100 years; release rates ten times back-ground (assocfated with partial removal of earth cover) for the next 400 years; release rates 100 times background (corresponding to the removal of all earth cover) fer the next 500 years. Under these conditions the projected deaths from cancer over 1000 years would total 1.1 per annual fuel requiremen+ for one reactor. For the Industry of 70 reactors, the Impact per annua! fuel reug!rement would be approximately 77 deaths which translates to about 0.2 deaths for each day of operation. I+ should be noted that Dr. Jordan was a member of the ASLB that conducted the Hearing on the Perkins Nuclear Power Station which concluded on July 14, 1978, that all the releases of radon-222 assoctated with the uranium fuel cycle and health effects that can reasonably be assoclated therew!+th are Insignificant In striking the cost-benef!l+ balance for this power station. Thus the NRC staff belleves that the petitioner's estimate of "on the order of 100 deaths" {fs too high by a factor of 500 to 25,000, compared to results obta!lned using the above described assumptions about key Input parameters, namely pers!stence of stab!I!zation controls and the length of time over which the Impact !s cons!dered (perlod of Integration). Petition Evidence 5. Physical and ep!demlological studies Indicate cancer deaths may result from enrichment process releases to populattons residirg near the facli!ties. Radon gas escaping from enrichment tallings may cause mlllfons of deaths fn future generations. Response 5. Some studies could be Interpreted as Indicating that eventual cancer deaths may result from enrichment process releases. However, It !s Important to note that the recent Oak Ridge study,
referenced by the pet!itioner* (petition p. 49) as a bas!s for +he claim that enrichmen+ plants may now be caus!ng cancer deaths, clearly estab!l!shes the fol low!ng: (1) Oak Ridge Natlonal Laboratory contains numerous nuclear factiitles which may release radioactivity In addition to the gaseous diffuston plant so that any study cannot distingutsh cause! reiationships, and (2) "The overal! results of the study tndficate cancer mortal!ty rates that are not significantly higher than would be expected In the general population." The claim that radon gas escaping from enrichment tallings may cause mll!lfon of future deaths ts rejected by the staff (see, In addition, response 3 above). The facts are as follows: (1) the urantum-238 currently contalned In steel cylinders fs befng held as a potentially valuable national resource, and Is not a waste; (2) In the event of a future dectsfion to Implement the breeder re-actor, the recycle of this depleted uranium wi!! substantially reduce the m!ning and milling requirements of the nuclear power Industry. This would substantially reduce the radon releases from those mining activities and subsequent potential public health effects that may result, primarily from mine talling releases; (3) pending that decision, there wll! be no releases of radon from the steel cyclifnders now encapsulating the uranium; (4) even accidental rupture of the cylinders would not result In stgnifl-cant radon releases for centurles, since I+ will take thousands of years before the thorfum-230 and rad!tum-226 will bulldup Into even a minute fraction of thelr equil!brium concentrations; (5) In t+he event that these materlals are not used for generating electricity during the next century, they would be disposed of {!n a manner whIch would not result In significant releases of radon-222, such as wil] also be the case for high level radloactive waste. Petition Evidence 6. Fuel fabrication faci!i!ties are causing long term health effects by direct release of polsons to the blosphere, by serfous Irradfation of workers and thereby the human gene pool, and by removing from the reach of humanity forever rare alloys which are essential to the medical sclence. Response 6. StInce this contention !s general, It will first be answered generally and then the specific contentions In the supporting materfal of the petition will be answered. Although fuel fabrication facilities do release extremely small fractions of throughput of radloactive materlals to the environment,
- C.H. Patrick, "Trends In Publ !c Health In the Population Near Nuclear FactIiIttes: A Critical Assessment," Nuclear Safety, Vol. 18, No. 5 (September-October, 1977).
56 the concentrations of these materlals In alr and In water are ex-tremely low and mee+ NRC regulations. Radfoactive matertals releases that meet 10 CFR Part 20 requirements for maximum permis-sfble concentration for unrestricted areas as do *+hoese of l {fcensed nuclear fuel cycle facliifties, result In exposures that are less than the Part 20 Ifmfits for unrestricted areas. The basis for the Imits have been d!scussed In l above. Occupational exposure also meets 10 CFR Part 20 requirements and, simflarly, the exposure I fmit for restricted areas are considered to be acceptable compared to routine socletal rfsks. The staff does not agree that rare alloys (allegedly zlircontum used as encapsulating materfal for fuel rods) which are essential to the i medical sclences are being removed forever from +he reach of humanIty. The petition states the U0, fuel pellets from defective fuel rods are recycled by dftssolving them fn nitric acid, purtflication by solvent extraction, calcination and reduction to UO5 and then returned to the fuel fabrication process. The petition then goes on to say that "UO recycle ts a simflar process to spent fuel reprocessing and plutonium recovery." The staff belleves that th!s statement Its misleading and offers the following comments:
- 1. The bulk of the scrap In this process Is termed clean scrap and Is made up of U0z pellets that are mechanically damaged. They are reduced to powder mechanically or thermally and repel iettized.
These U02 pellets are not chemically contam!nated and therefore, are not d!ssolved In nitric acid and purlffed by solvent extraction.
- 2. A much smaller fraction of the UO, scrap (about 10% of Item 1 above)
Is termed "dirty scrap" and fs made up of U05 powder that ts chem-Ically contaminated. This dirty scrap fs su6 lected to the chemical scrap recovery process that !s somewhat similar to fuel reprocessing only because dissolution In nitric acid and solvent extraction processes are used. Thus, although a smal! fraction of UO. scrap recovery !s chemically sImilar to fuel reprocessing, !+ Is not at all similar from a radlological or toxic hazards standpo!nt be-cause thls U0, does not contain the highly radloactive and toxic fission products of Irradiated fuel. Furthermore, !+ contalns no plutontum. Resource Comm! +ment The petition Implies that the nuclear power !ndustry through Its
use of zirconfum In fuel rods Is denying use of thls material for sanitary engineering or for medical uses. The staff emphasizes that there fs no known shortage of this matertal; In fact, a number of producers have gone out+ of the business due to a lack of demand. Zircontum ts Itsted as the 9th most abundant meta!, (Encyclopedia of Engineering Materlals and Processes, 1962), the 19th mos* abun-dant element In the earth's crust (Handbook of Chemistry, N.A. Lange, 1946, p. 86) and compr!ses 0.022% of the !gneous rocks of the earth (Inorganic Chemistry, Therald Muller, 1952, p. 866). Seven to elght militon pounds of zirconium metal are produced annually and this {s only 2-3% of the annual production of zirconfum or zirconium compounds. The balance {fs zirconium refractories. In medica) uses, titanfum Is preferred for body parts because !t Is !fghter and cheaper to fabricate. In fact, the use of zirconium metal {fn reactors created an Industry, which clearly benefitted medical use. Prior to the advent of nuclear power, zirconium metal was a rarity because economical processes for producing the metal from ore had not been developed. Possible disposal of smal! amounts of zirconfum wil! not result In a shortage of thls metal for medical applications. Impact The petition makes no direct allegations about the environmental Impact of UO, fuel fabrication factIifttfes; however, {t+ Imp! fes that uncontrolled releases of urantum occur routinely and that these are very harmful to the environment. Source terms from ue fuel fabri-cation plants are wel! documented by NRC 1m NUREG-0002* and by EPA In EPA 520/9-73-003B** and In EPA 520/1-77-009.*** "The very smal l quantities now released In the effluent gases and !!quids result In concentrations of radloactive materlals !n these media that are about 0.04% and 10%, respectively, of 10 CFR 20 I!Imits at the slIte boundary" (NUREG-0002). The petition states that radionuclides are released Into drinking water. Liquid waste streams from fuel fabrication plants are
- Final Generic Environmental Statement on the Use of Recycled Pluton!um In Mixed Ox!de Fueled Light Water Cooled Reactors (GESMO), NUREG-0002, (Aug 1976).
- Environmental Analyses of the Uranium Fuel Cycle, USEPA, (1973).
- Radlological Quality of the Environment In the United States, USEPA (1977).
discharged Into storage tanks or ponds and released to the environ-ment only after monitoring shows the concentration of radloactive {sotopes to be within federal limits. (e.g., 10 GFR Part 20.) The petition states that avallable data Indicate that the release of uranium from scrap recovery operations fs at least 1% of all matertal processed, possibly several tons per year. NRC sponsored studies (ORNL-TM-4902, Fig. 45, pg. 137) estimated that 2% of U0. throughput goes through the scrap recovery process and that no more than .03% of the U0. sent to scrap recovery !s released to the environment tn liquid wastes. Thus, the petition overstates these estimated releases by about 100 to 1000 times, depending on how the statement In the petition fs Interpreted. The petition states that the estimated total Industry discharge of "this contaminated radioactive water" to watercourses !s estimated by the NRC to be about 9 mil!fon gallons a day. It should be pointed out that the 9 million gallon/day figure Is taken from NUREG-0002 (page IVF-59) and that estimate Is for the year 2000 for a production capacity of 13,500 MTU. The estimated fuel fabrication requirement for 1978 was about 2000 MT; on a proportional bas!s, the present dally Industry-wide quantity of water discharged to watercourses would be about 1.3 mil!lon gallons of water per day. Furthermore, the concentra tion of radioactiv e materlals In this water meets federal requireme nts for discharge to unrestric ted areas. Occupational Exposures The petition quotes estimated annua! dose commitments to workers of 9.95 rem to the lung (NUREG-0002, page IVF-60). This figure In the NRC document was In error and has been revised by the staff to 1.2 rem annually, which !s about 8% uf the estimated annua! dose commitwent that a worker wou!d receive If he breathed alr containing the max!mum permissible concentration of urantum In restricted areas. As has been explained earlier, the maximum permiss!ble concentration and exposure values In the NRC regulations are established from Federal Radiation Guides and are such that any possible health effects resulting would be considered acceptable. The petition states (page 54) that river sediments collected 5 miles downstream from the NFS Fuels Fabrication Plant at Erwin, Tennes-~ see, conte! neg 0.14 plcocurfes of plutontum-238 per gram (a pice curte ts 107'4 curte or 107° microcurie). This Is 1.4 x 107
microcur les per gram and Is ebout+ 0.5% of the 10 CFR 20 IImI+ of 5 x 10 microcurtes of Insoluble plutontium-238/ml In water re-leased to unrestricted areas or about 3% of the limit of 5 x 19076 microcurfes ut soluble plutontum-238/m!l of water released to unrestricted areas. Thus the values are for below establ!shed IImits. The petitton also states that five drinking water samples taken fn Jonesboro {tn May 1978 showed positive readings of radloactive metals ranging as ign as 3.2-1.6 picocurles/liter.* This translates to 3,271.6 x 10°? picocurtes/ml or 3.2=1.6 x 10° microcurtes/ml which fs about 1 x 10° of the 10 CFR 20 Jim!+ for release of urantum to water tn unrestricted areas, agaln a value far below established IImlts for protection of health and safety of the public. The petition goes on to state that In 1977, 250 to 500 pouncs of enriched urantum was reported to be released Into the Nol fchucky River by routine plant operation, Based on known occurrences, It appears that what was meant was that In 1977 1+ was reported that a total of 250-500 pounds of enriched uranium had been released Into the Noifchucky River over many years of routine plant operation. Even If the entire quantity were released In one year, the concentration of enriched uranium In the Nolfchucky River could be within Federal l}imits because of the high diluttons present. Thus, the release over an extended perfod of time appears wel! within accepted I!mits. Physical Evidence 7. Reactors can and do release enormous amounts of polsons to the environment--many thousand curles of radioactive liquids, many hundred-mil!fon curltes of radioactive gases, and many biillons of curles of stored solids--at the present annual! level. Release of just 24 curfes of a single Isotope, Carbon-14, !s sald by the Environmental Protection Agency to have caused 1,000 health effects already. The Immediate effect of these releases !s now observable In populations If!ving and working near reactors. Tne limit of error Is plus or minus 50% of the reported value, which may Indicate a low conficence In the results reported In the analysts.
Response 7. Reactors can and do release radloactivity to the environment, subject to the requlrements of the Federal! Regulations that have been discussed above. The followtng fs a d!scusston of the experfence of the cufrent generations of operating reactors and the staff estimate of the performance of reactors presently belng des!gned and constructed. Data* from operating light water reactors Indicate the fol low!ng quantities of radionuclides releases to the Ifquid environment: TABLE. 11 : Releases of radloactive materftals In Itquid effluents from operating LWRs (Cur tes/year/reactor) Mixed Fisston and Activation Products Trittum PWRs : La 400 BWRs 1.4 20 The above summary Is based on 103 reactor years of operation for PWR's and 45 reactor years of operation for BWR's. I+ Is Important to note that the data do not Include releases during +hose years when the reactors had begun operation but the I!quid radwaste systems were not yet Installed. Many of the early reactors were bullt with minimum treatment provided for IIquid wastes. At the time these designs were approved, the only !!mitation on releases were the JO CFR Part 20 radtonuc!!de concentration IIm!ts (Appendix B-Table I1-Col. 2). Releases from untreated I!quid rad!oactive waste streams reached 200 curfes per year of mixed fissfon and activation products for 2 BWR years Data on effluent releases are provided annually +o the NRC by l Icensees as annual reports. See also reference to PNL 2439, page 9 of this petition response paper.
operations and 8! curles per year of m!xed fissi!on and activation products for } PWR year of operation. Al! other exper!tences were substantially under these values. In response to the NRC requ!rements that releases be "as low as Is reasonably achlevable" as out!!ned In !0 CFR Part 50, Append!x l, the early reactors upgraded thefr !fquid racwaste systems with additional treatment equipment. These modifications to tne systems have resulted fn large reductions fn the level of releases compared to the untreated system as can be seen from the magnitude of the average releases In Table !1. PWRs and BWRs currently under design and construction generally have more advanced radioactive waste treatment systems than were provided {in the upgraded piants and therefore provide more treatment and a further reduction of releases. Therefore, the Staff estimates that the releases of m!xed fission and activation products from those BWrRs and PWRs under design and construction wil! be less than !.0 curles per year per reactor. Stnce the reactors currently tn operation, and the reactors currently under des!gn and construction, will! operate with the use of their upgraded treatment system for the rest of thelr operational I!fe, the data from reactors having Installed systems was used In comp!!!ng Table 11. . The tritium release average !s also based on data from operating reactors. It {fs important to note that operating experfence from Haddam Neck and San Onofre, Unit No. !, was not Included In the PWR average because these reactors use stainless steel as the fuel cladding rather than zircaloy as !s used by al! other PWR's now operating or being designed or constructed. Zircaloy fuel cladding plants have a tritium release average of 400 C!/yr as shown In Table 11 while the stainless steel fuel cladding plants have a tritfum release average of 4300 Curles/year. The higher release !s a result of greater tritium diffusion capablI!ty through the stainless steel. Since those two reactors are atypical of all other reactors being operated or constructed, they have not been used In the average In Table 11. It Is misleading to lump tritium releases with mixed ffisstfon and activation products since the dose per curle of tritlum !s generally less than the dose per curle for other radionuc!!des. In addition, the blological accumulation factor (a factor that Indicates the amount of bulldup and retention of the element In the body), for trit!um is unity (or slightly less) whereas the blo!ogical accumulation factor for other principal radionuc!!de dose contributors !s about 100 or more.
Data from operating light water reactors {indicates the fol low!ng quantities of radfonuclides released to the atmosphere: TABLE 12 Releases of radioact!ve noble gases [fn gaseous effluents from operating LWRs j (Curltes/year/reactor) PWRs 7000 BWRs 32000 The data are compiled from !07 reactor-years of operaton for PWR's and 4! reactor years of operation for BWR's. It Its Important to note, especially for BWR's, that the quantities listed In Table 12 do not Include releases during those years when the reactor had begun operation but the gaseous radwaste systems were not yet Installed. Many of the early BWR's were bullt without any treatment of the steam jet alr ejector (SJAE) off gas except for a 30 minute delay lI!ne with release to a tall chimney. At the time these designs were approved, the limitation on radioactive effluent releases were the !0 CFR Part 20 concentration limits (Appendix B-Table Il!-Col. 1). The examples cited In the petition on pages 60 and 7] concerning the Browns Ferry Unit l and Millstone Uni+ l noble gas releases of 2.5 x 10° curles per year and 2.9 X 10 curies per year, respectively, are for untreated SJAE off gas systems. in response to the NRC requirements that releases be "as low as Is reasonably achlevable" as out! {ned fn 10 CFR Part 50, Append!x l, those early BWR's upgraded the SJAE off-gas systems with augmented off-gas (AOG) systems. These AOG systems have resulted In substantial reductions In the releases as compared to the untreated system. BWR's currently under design and construction wil! have gaseous radio-active waste releases of less than 10,000 curltes/year/reactor.
The statement that many billfons of curltes of stored solfds are released to the environment at the present annua! level Its very misleading. Low-level solld wastes from the reactor, consisting largely of spent resin beads, evaporator concentrates, filter sludges, and other wastes are solidified and packaged In containers In the nuclear station. These wastes are then shlpped to commercial burfal grounds. The solid wastes processed and stored In this manner are not exposed to, or released to, the environment In an uncon-trolled manner. Releases, If any, are carefully monitored and must meet the requirements of the regulations, 10 CFR Part 20. With regard to the quantities of solfd waste wh!ch are solidified, ' packaged, and shipped, the following Is an estimate of these quantities generated by a 3400 MwWt PWR or BWR, based on reactor operating experlence: TABLE 1 Quantity of Radloactive Materlal in Solfd Waste for 3400 MWt reactor based on operating expertence VOLUME - ACTIVITY (cuble feet/year/reactor) (curles/year/reactor) BWRs 30,000 4,100 PWRs 15,000 2,000 The statement that "24 curles...of carbon-14 Is sald by the Environmental Protection Agency to have caused l,000 health effects already", cannot be ver!fled. On page 62 of the petition, a similar statement {s made but correctly states that the NRC estimates a release of 24 curles of C-14 per reference reactor year. By the completion of the year 1977, about 300 reference reactor years had been experfenced and thus about 7,000 curfes of C-14 have been released to date. Based on th!s experlence and the estimated growth of the nuclear Industry, EPA has calculated the potentia! health effects to the world population from the released C-!4 as a function of time to the year 2000. On page 96 of the petition (Fig. 59), a plot of potential health effects from C-!4 versus calendar year, generated by EPA, {!s reproduced. This plot represents cumulative nuclear Industry releases of C-!4 and estimates about 200 health effects have occurred to date In the world population. This value closely represents the generally accepted results of health effects estimation by other government agencles and respons!ble sclentific groups.
The tast statement regarding the observablil{ty of these health effects In populations Iliving and working near reactors !s unsubstan-tiated. See responses to physical evidences (11) through (17), as wel! as the health effects summary In Section II. Petitlon Evidence 8. Reprocess!ng plants release as much polson to the blosphere in a single day as reactors release annua! ly. Response 8. The staff contends that thls statement Is misleading and ' [ls not relevant to the Pet!tion's claim. There are three factors that should be taken Into consideration when the urgency or the merit of this petition {fs belng welghed:
- 1. The concentrations of radioactive materlals {n gaseous and I!lauld effluents from fuel reprocessing plants (FRP) wil! be controlled by NRC regulations (10 CFR 20, Appendix 8B) and the socleta! risks of radioactive materfals {n those concentrations are addressed earlier In thls response.
- 2. No reprocesising plants are operating In the U.S. at the present time and none are currently l{icensed to operate. Reprocessing of spent fuel has been suspended Indefinitely pending she outcome of the International Nuclear Fuel Cycle Evaluation which has as Its objective he Identification of nuclear fuel cycles that reduce the rfsk ot prol!feration of nuclear weapons grade material.
- 3. Since a 2000 MT/year spent fuel reprocessing p!ant would service about 75 MWe LWR's per year, the compar!son of radioact!ve source terms from a reprocessing plant with those of a reactor should be made on the basis of the spent fuel reprocessed per 1000 MWe. On that basis, and adjusted for krypton-85 <<nd carbon-14 recovery systems that would be added to a reprocessing plant to comply with EPA regulation 40 CFR Part 190, also discussed earller, a reprocessing plant (If reprocessing Is resumed {n the U.S.) would release about 3 times the radloactive material that a 1000 MWe nuclear reactor would release, as shown In Table 14.
Table 14 L WR FRP Major effiuents, Cl/yr/1000 MWe Noble gases 15,000* 30,000 Trittum 400 13,000 Carbon-14 8 2 Exposures, Person-rem/yr/1000 MWe Occupational 560 20 Population (entire U.S.) 100 170 ; Although the staff feels that +he foregoing presents !I+s postition on Petition Evidence No. 8, there are erroneous or misleading statements about reprocessing In the text of the petition that should be corrected for the record. Staff comment on *+hose statements follows. The petition states that spent fue! shipping contaluers occasionally are lfeaking upon arrival at the fuel reprocessing plants (although the staff Is not aware of any spent fuel contalners that were !eaking upon arrival at an FRP) and that during unloacing, cask wash water Is used to cool the containers and wash off the transport and unloading vehicles and equipment. The petition states that this cask wash water should be discharged to stared waste systems but+ that generally I+ !s released to +he blosphere In a direc* or delayed pathway. The staff points out that upon arrival, spen+ fuel shipping conta'ners are surveyed for poss!ble contamination If no contamination !s found, the wash water {fs discharged to a surface disposal! system. The staff position Is that this procedure !s adequste. The petition states that over 99% of the krypton-85, % of the tritfum and a large fraction of the halogens are :eleaced Into the off-gas system durfng nitric acid leaching of ~he spen> fuel from the sheared cladding. The staff's commen; Is that If a reprocessing plant Is operated In the future, I+ would Ifiely releuse less than 10% of the krypton-85 and 0.1% of the halogens, <<* a resilt of radwaste treatment. Normal !zed to 2/3 PWR, 1/3 BWR - data based cn Table 12 above
Tne petition states that the Barnwell! FRP wll! sh!p urany! nitrate In tank trucks to conversion facilities and that plutontum wil! be stored and shipped fn the nitrate form. The staff wishes to pofnt out that If Barnwell! operates, [t wil! convert urany! nitrate to UF at {ts on-site UFe Conversion Fac!ll{ity and that NRC requ! ations (10 CFR Part 71.42) require that plutonium {n excess of twenty curies per package be shipped as a solfd. The petition !mplfes that the waste storage tanks at the Barnwell FRP will contain radioactive !!quid wastes only temporarily and therefore are a hazard. In support of this !mplication, the petition polnts out that the radicactive acid !!qu!id corrodes staliniess steel rap!dly and . that HLW tanks at SRL have already cracked and d!scharged to the Savannah River Watershed. The staff points out that HLW tanks at SRL are made of carbon steel, not stainless steel. A more representative compar!son would be the HLW tanks at the Idaho Reprocessing Facility, which are made of stalnless steel, and where no !eaks have been experfenced. Furthermore, the plan at Barnwell! !s to coo! the HLW and thus store It as a non-bolling nitric acid sc!ution prior to converting it to a solid form for transfer to a Federal repository !n accordance w!th 10 CFR Part 50, Append!x F. The storage of non-bo!lling nitric acid solutions !s based upon sound engineer!ng princip!es and practice and, contrary to what the Pet!tion Implles, are expected to last for the operating I!fe of the plant. The petition alleges that the most advanced technology systems for treatment of radioactive effluents include only one IlImIitedly effec-tive system for centro! of radlolodine, and no contro! methods for either tritium or ca: bon-14,. It shoulda be 1:.sted that EPA has determined (40 CFR 190) that technology exists to contro! the release of krypton-85. If a cryogenic system !s used to remove 85kr, It will probably be used +> also remove '4C. The removal of tritium from gaseous and I!aqulid effluents Is rather difficult aud costly; EPA has not determined that removal of tritf!um Is cost effective. The pet!tion states that a dec!s!on on whether It Is preferable to discharge radioactive waste to the atmosphere only or to both gaseous and I!quid pathways has been postponed unt!! operating experlence with both methods Is obtained. That !s Incorrect; the dec!s!on whether to d!scharge radioactive effluents to the atmosphere only or to both atmosphere and I!qu!id path-ways !s based on the system that wou:d result !n the least radiclogical Impact to man at that site.
The petition states that In addition to the anticipated normal dis-charges, miscellaneous alrborne releases can occur because of the complexity of the varfous processes and the unproven reliability of contro! mechanisms and that such releases may not be detected by stack monitoring, remote mon{itor!ng or In-plant alr mon!ftoring techniques. The staff comments that the process systems and control mecnan!sms In any licensable plant would be des!gned in accordance witn estab! !shed eng!neer!ng practices and should be very relfable. Radioactive releases would be monitored by In-!{!ne and stack mon{toring techniques. In addition, a comprehensive environmental radioactivity monitoring program would be employed to ensure that any radiological impacts on the environment were detected. The petition states that NFS terminated [ts contract and left New York State with the contaminated s!te and the waste {n storage. The staff notes that although NFS notified the NRC that !t was withdraw!ng from reprocessing, It has not abandoned the facil!ty; NFS has cont!nued to meet Its !icensing responsibIi!itles. Moreover, NFS has not termInated
!ts contract with New York State. New York State !s a party to the license pertaining to the NFS plant, and as such owns the s!te and the waste storage tanks; thus, from the beginning the state accepted responsibility for the site and waste storage.
The petition says that "NFS In the flve years It operated exposed Individuals I!ving In the vicinity to 77 mrem average and 90 mrem maximum bone dose from Sr-90 according to a "Public Health Study In 1968" and that data on external radiation exposure Indicate a mean gamma dose around NFS of 4 mrem per month above background." This statement Is misleading because It fs taken out of context and mis-represents the Intent of the referenced document, which goes on to say (p.9, paragraph 2, BRH/NERHL 70-1, "An Est!imate of Radlation Doses Rece!ved by Individuals Living In the Vicinity of a Reprocessing Plant") that "Considering analytical and statistical! varfations In data, the dose commitment from diet to the typical Individual around NFS does not differ significantly from that of the average adult population of the rest of New York State and can be attributed largely to radilo-active fallout (related to nuclear weapons tests)." The petition then goes on to calculate that during the five years that It operated, the NFS Plant caused 20 additional cancers among the 170,000 population living within a 25 mile radius of the plant. The staff contends that this estimate !s Inval!d because the referenced document does not support the clalmed population exposures and because the document "avoids del!neation of the s!ze of the population at risk" (p. 12, paragraph 1, BRH/NERHL 70-1).
The petition discusses occupational expesure a+ the Wes*+ Valley Pian+, Incilud!ng *he use of temporary workers In radiation areas. The staff notes *hat although the NRC does no+ condone the practice of using temporary workers, especlally large numbers of temporary workers, to perform maintenance or decontamInation operations In radtation areas, thts practice is permissible under present NRC regulations. In general, employees are Informed about any radiation dangers assoclated with porential exposure to radfation, and +hey also recelve tratning In radtologica! protection. The Ifcensee {fs required to meet all the requirements for radiation protection of 10 CFR Par+ 20. Employment In a nuclear factlifty, !!ke employment In other Industries, !s not necessarfly the cause of employee {I1s nor the basts for birth defects ' nor other family I! inesses. The peti*fon states that toxic waste was abandoned when the West Valley Plant was closed, that the waste mus*+ be constantly cooled to prevent bofl!ng, that I+ fs burted In one of two adjacent +anks and that In the event of a leak there are no pumps or p!Ipes to transfer the waste to the spare tank. The staff position !s that thts contention Its not+ true. As reaulred by Its ltcense, NFS matntatns the wastes a+ Wes* Valley In a safe condi+tlon--the high-level wastes have not been aban-doned. NFS matfntains pumps and ptp!ng at the West Valley s!te that could be rapidly Installed, !f necessary, to transfer the HLW Inventory to the spare tank. The petition points out that the estimated cost to d!spose of conta-minated factlitfes and waste at the site of the West Valley Plant exceeds the $2.5 million "perpetual care fund established by NFS. The staff acknowledges that the perpetual care fund set up between NFS and New York State to cover the costs to dispose of wastes at the West Valley site ts Inadequate. The Department of Energy Is making a detalled review of the situation a+ West Valley and expects to !ssue a report by the end of 1978 for publ !c comment. This ~snort will de-fine the federal and state responsIbIiIItles related to the West Valley reprocessing s!te, and propose a recommendation to Congress with respect to the disposal of the contaminated facll!itles and wastes. The petition quotes reprocessing stage dose comm!tments and krypton releases from GESMO as annual releases but the staff notes that GESMO states (Table IVE-19, p. IVE-47) that these releases are cumulative for the 26 year perlod from 1975-2000. Thus, the petl-tion greatly exaggerates the estimated enviromental Impacts of reprocessing.
Stmilarly, the petition states (p. 93, paragraph 1) that 59 miilion curles of tritium are reieased annually from reprocessing plants end attributes this estimate to GESMO. The staff po!nts out that This also Is not correctly quoted. The petition states that the GESMO report estimates an annua! source term of 59 millfon curfes for reprocessing. The staff polnts out that this quote fs wrong. GESMO (Table IVE-19, p. IVE-47) estimated that the reprocessing Industry would release a cumulative total! of about 42 million curfes of trittum, !f the spent fue! was reprocessed, over the 26-vear perlod from years 1975 through 2000. The petition says that 110 curies of fodine-129 and 2700 curles of 1-131 would be released from reprocessing annually. The staff polnts out that the GESMO report estimates that the reprocessing !ndustry would release a cumulative total of about 110 curfes of 1-129, If the spent fuel was reprocessed, over the 26-year period from years 1975 through 2000. Pecause of Its 8-day half-life, only about 8 cur'es of ftodine-131 would remain [tn the environment {fn year 2000. The petition discusses the estimated health effects resulting from uncontrolled releases of krypton-85 from a 2100 MTHM/yr reprocess!ng plant for 20 years. The staff notes that EPA requlations, 40 CFR Part 90, require the installation of krypton recovery systems In reprocessing plants. This would resu!t In about a 90 percent re-ductton In the amount of 85kr released from a reprocess!ng plant, and about 90 percent reduction In the estimated health effects shown on this page. Petition Evidence 9. Transportation and handling of nuclear fuel cycle materlals and wastes result In direct exposure to populations and releases of polsons to the blosphere. Congress recently learned of 118 highway Incidents between 1971 and 1976, Involving some radioactive sp!llage. A large accidental release of nuclear matertal has the potential for enormous destruction. The I!kel!hood of such an accident occurr!ng Increases each year the fue! cycle cont!nues, as new records continue to be set Involving accidental releases of persistent polsons for wh!ch no repalr mechan!sm exists. Response 9. Transportation and hand!!ng of nuclear fuel cycle materlals and wastes does result In very IImlted direct exposure to populations but It should also be polnted out that IImits to such exposure have been estab!!shed and are observed. These l!mits take the following forms:
- 1. 10 CFR Part 20, as discussed earller, retative to both workers and the genera! public.
- 2. Regulations promulgated by the Department of Transportation (DOT) and the Nuclear Requaltory Commission (NRC) which limit rad!fation dose rates external to shipping packages both under cond!tions for norma! transportation and transportation acc!dents.
- 3. Practice by [ndustry In which rad!lation dose rates external to packages are observed to be smalier than the regulatory limits at least by a factor of two.
The petition evidence statement that transportation and hand! Ing of nuclear fuel cycle materfals and wastes result In releases of polsons to the blosphere Is mislead!ng s!nce packages are des!gned to requ!a-tions requiring that no rad!foactive materlals be released dur!ng norma! transportation and that only very !Im!lted quantities of radloactive materlals be released from a package as a result of an accident. For sma!! packages (Type A), the contents are !!milted to smal! quantities of radioactivity, to obviate a requirement for acc!ident res!stant packaging. For large packages (Type 8B), the packages are designed to regulations requiring that no radioactive materltals be released In specifled accident tests. Accidents more severe than these tests are concelvable but very unlikely. The statement that Congress recently learned of 118 highway Inc!idents between 1971 and 1970 Involving some radioactive spillage differs from our Ipformation. From petition p. 104 one obtains the Informa-tlon that the DOT reports (no specific reference) that In the years 1971-1975, 144 (of more than 32,000) hazardous materfals Incident reports i:ivoalved radioactive materltals and 36 of these 144 reports Inclcated release of contents o- excess radiation levels. The DOT report actually goes on to say that "In most cases, the release Involved minor contamination from low specific activity, exempt or Type A packages (a!! of wh!ich are regarded as smal! packages or packages of low hazard material). In many Incidents Type A packages had been subjected to crushing, Impact, or sim!flar accidental conditions with no release of contents. No deaths or significant Injury to persons jue to radlation or radioactivity from the sh!pments was experlenced ...." re number 118 could be a wrongly taken difference (with an arlfthmetical error) between 144 Incidents Involv-Ing radioactive materfal anc 36 Incidents Indicating releases, but we dc not know the source of the number. It should be noted that the requirement tor hazardous materlals Incldent reports promulgated by DOT by 49 CFR 171.15 pertains not only to eas!ly recogn!zable accidents (death, Injury, property damage, fire, breakage, sp!!!age) but also to events of suspected contamination.
The statement that a large accidental release of nuclear materlal has the potential for enormous destruction does not character!ze accidents that might occur In transportation or handling of nuc!ear fuel cycle materlals and wastes. If a transportation acctdent occurs, !+ most Ifkely wil! not Involve retease of any radioactive materfal In case of a Type B package and not more than a lImited amount of radioactive material !n case of a Type A, exempt or low specific activity (LSA) materfal package. For the spent fue! pack-ages containing the largest quantities of radioactivity, most of the radioactivity (up to 99.5 percent) restdes In the solld matter of the spent fuel, the smal! remalnder being In the form of a gas. If released, the health effect of the gas !s limited princ!pally to superficial radfation exposure (e.g., skin and lung) since the gas emits beta rays, which are stopped by the skin. If the spent fuel gets hot enough durlng the course of the accident (through loss of coolant), up to 15 percent of the radfoctivity In the cask may be subject to volatilization from the solid matertal, but actually the cladding perforates {fn localf!zed regions and a correspond!naly smaller quant!ty may be released. Under highly oxidiz!ng conditions, such as might happen If the spent fue! were pulver!tzed Into fine particles and subsequently subjected to a fire (no credible condition Is known which would cause this) an additional 26 percent of the radioactivity In the cask may be subject to volati!l{zation; but with the IImitation of locallzed perforation, a smaller quantity may be released. The rest of the materfal remains sol!d and In place In an accident. The estimate of the NRC staff for maximum accidental release of cesium, which Is the principal volatile radioactive component of spent fuel, [s a release of no more than a small frac-tion of 150 curles.* Compared to the radioactivity contalned In the cask, even 150 curfes represents a fraction of the order of 10°", Thus the prospect of a large release of radioactive material {fn an accident !s considered extremely unllkely. The radiological consequences of a conjectured release of radloactive matertal depend both on the quantity of material released and on the number of people nearby who are exposed to the released material, as well as the physical conditions of the local environment. Recent
- "Potential Releases of Ceslum from Irrad!ated Fuel !n a Transportation Accident", WASH-1238, Supplement l1, U.S. Nuclear Regulatory Commission (July 1976)
studies*>>** {Indicate no health effects consequences or only a smal! number of consequences may occur for extremely severe acc!dents In high population densities, and the associated probabil!+fes for such events are also extremely small. The NRC fssued environmental Impact statement on transportation of radioactive materfals* concluded that under the present reaulatory system, shipments could continue by all modes and that no regulatory changes were required at this time. This position directly opposes the petitioner's {mplied allegation that transportation of radlo-active materfals endangers public health and safety and must be halted. The staff has also made the followtng specific comments to petition ; statements on pages 99-106. The petition states, "The level of radioactivity In a fuel or weapons grade shipment ts very high-over one million curles [In some cases. Consequently, a transportation accident could lead to enormous damage." This concluston does not follow because the protective packag!ing of the radioactive materfal has not been taken Into account. The petition states, "Under fair weather conditions, a person one half mile downwind from an accident releasing a radtoactive gaseous cloud could recelve a dose of approximately 160 rems." I+ ts most !mportant to describe the conditions that would yleld such a result. The staff has calculated an average value of 130 rem for Individual dose at a distance of one half mile for a spectrum of weather conditions (obtained from a year's worth of observed data) when a large spent fuel cask Is Intentionally attacked with explos!ves.
"Final Environmental Statement on the Transportation of Radloactive Materfal by Alr and Other Modes," NUGEG-0170, U.S. Nuclear Regulatory Commission (December 1977).
He "Transportation of Radionuclides In Urban Environs," U.S. Nuclear Regu-latory Commission, Federal Reg!ster 42, 12271 (March 3, 1977) and 43, 29864 (July 11, 1978). At the meeting announced In the latter notice, a document which will form the bas!s for the NRC environmental state-ment was discussed: "Transport of Radlonuc!ides In Urban Environs: working Draft Assessment," Sand!a Laboratorfes, SAND 77-1927 (May 1978).
It was further assumed that a maximum relsese in finely divided, resplrable form '!s optimally achteved of a!! tne geses anc volatiite solfd radionuclides and one percent of the rest of the radioactive Inventory of the cask. This result ts not appropriate for most transportation accidents and for fair weather conditions, hcwever.
/
The petition states, "This $s greater than the amount recelved by many of the 300,000 Hiroshima fatalities." As just discussed, the effects of a sabotage event are smaller than the petition quoted result, and an accident does not match a sabotage event with respect to efficftency In dispers!ng materla!l. To compare ' the consequences of a transportation acc!dent with those of tne explo slon of a nuclear device for mllftary purposes Is not realistic. The petition states, "There !s a growing backlog of nuclear materials to be shipped, !ncluding spent fuel, transuranic wastes (TRU) and h'igh-level wastes (HLW)." Although some HLW Is presently stored, no commercita! reprocessing !s belng conducted, and no additional HLW Is being accumu! ated. The petition states, "At this time, protection of the public Is de-pendent upon package design and Integrity, rather than special routing, escort, and speed IImitations." This statement Its basically true, but the pos!tion of the regu!atory agencies, NRC and DOT, Is not as rigid as stated. Primary rel!ance for safety Is placed on package Integrity, but If necessary, operational controls can also be applied. At present, no routing restrictions are deemed necessary, but some communit!es may require escorts and for certain shipments, government requires speed !!Imltations for protection of the product. The petition states, "The agencies do not set standards which wil! protect the public from harm; they set standards which are reasonably achlevable by shippers." The transportation safety record belles such an Inference. The purpose of the reguiations !s to (1) establish adequate protection for the public and (2) further restrict the radiological exposure of the public to levels as !ow as reasonably achievable. The petition states, "Once the shipment Is loaded, most author!ty passes from the NRC to DOT."
Both agencles retain requ!atory authority over sh!pments of ractcactive materfta!l at al! times. However, s!nce both agencies have authority and wish to avold duplication of regulatory effort, each agency discharaes Its respons!bIilitles according to a Memorandum of Understanding signed by both agencies. The DOT reguiat!fons per-ta!n to packaging, labelling and marking, placarding, sh!pping papers and routing. The NRC requ!ations pertain to packaging of certain radioactive materials and physica! security. The pet!tion states, "Drivers recelve no special training and may not recelve any special instructions concerning accidents or route." The DOT regulations require a2 person who offers hazardous materlals for transportation to !nstruct each of his officers, agents, and employees having any respons!ibIllity for preparing hazardous materlals for shipment as to applicable regulations (49 CFR Part 173.1). The DOT regulations also require that shipping papers describing the matertal and packaging In the shipment accompany each shipment (49 CFR Parts 172.200-172.204). Im many cases, notably sh!lpments of uran!um ore concentrate and uran!tum hexaflourtde, shippers voluntarlly provide detalied handling Instructions In event of an accident. In a recent appraisal of emergency response requirements, a jofnt NRC-DOT study group proposes that a requirement for a pertinent telephone number, such as that of the shipper or centralized Information organization (CHEMTREC), be added to the shipping paper requirements. The sentence !s disturbing because It might be based solely on a newspaper account described on petition p. 104 and yet !s made as a general statement. In that particular Incident, the mistake of not placarding the truck was evidently corrected before the truck reached Its destination. The whole affair did not jeopardize public health and safety, but was Investigated by the Bureau of Motor Carrier Safety of the DOT. The petition states, "Expected methods of transport (of HLW) wil! be tn 0.5 MT casks and AMTX ral!cars." The AMTX rallcar Is presently used by contractors for the Department of Energy for transportation of low-level or transuranic waste related to defense programs. For transportation of commercial waste, NRC approval {fs required and th!s approval has not been granted for the AMTX rallcar. Transportation of HLW wil! most Ilkely occur In casks sim{lar to present generation spent fuel casks, but to date no package designs for HLW have been submitted for NRC approval.
The petition states, "Another way of making this calculation fs to assume l extra cancer fatal!ity occurs for ever 100 man-rems." faterta!l presented earlter [In this response indicate that the r!sk Is more on the order of 1 potent!al health effect per 10,000 man-rems. The concluston that a halt of all transportation of radioactive mate-rlals !s the only alternative presently avaliable to adequately protect the public hea! th !s not supported. The NRC environmental statement, referenced earller, Indicates just the oppos!te conclusion: that under the present requiatory system, the risk to pub!!c healtn and ; safety !s so smal! that transportation of radioactive materlals can be allowed to continue In al! transportation moges. Petition Evidence 10. NRC admits that the nuclear fue! cycle emits large quantities of radiation to the blosphere--on the order of 1976 person-rem to be eventually absorbed by c!t!zens of the Un!ted States and foreign countries--and that additional contro! measures are elther unavallable or uneconomical! for practica! app! ication to the present Industry. Response 10.The NRC staff is not certain of the bas!s for this state-ment, but assumes It was based on the GESMO (NUREG-0002) analysis, which Indicates "on the order of 106 person-rem for the entire nuclear Industry for the years 1975-2000" The GESMO estimate represented an upper-bound [In that source terms and Industry size were larger than current estimates would [ndicate. For example, the growth scenarlo used assumed that 507 reactors and al! the necessary supporting facI!!- ties would be operating by the year 2000; current estimates Indicate about half of that number wll! be operating. Nevertheless, the GESMO study represented a tota! Industry which would provide about 4,000 GWy of electrical power, Imply!ng about 250 person-rem per GWy(e) or 200 person-rem per reference reactor year of operation. Therefore, the staff accepts the petitioners statement "on the order of 10° person-rem" to be reasonably correct for the high Industry growth scenarlo assumed In GESMO. However, the most recent NRC staff est!mates would Indicate that when dose commitments are calculated over perlods of l,000 years, the radiologic Impact would be about an order-of-magn!tude greater than calculated In GESMO. With regard to the statement that "additional controls are elther unaval!lable or uneconomica! for
practical application to the present Industry ", the staff wishes to qualify such claims as follows: (1!) The major radionuc!ide of concern Identified by current staff evaluations !s radon-222 from mining and milling operations. Careful below-grade burfal!l of mill taflings, a current method of tallines disposal reduces the !mpact of this radionuclide by approximately an order-of-magnitude w!th an almost imperceptible increase fn the cost of nuclear power to consumers. (2) The next most fmportant nuclides of concern are carbon-1!4 and tritium from reactor operations and fuel reprocessing. The staff agrees that at the present time there does not+ appear to be any cost-effective control technology for reducing these releases. However, fuel reprocessing of commercial irradiated fuel fs presently not being permitted In the U.S., and that would be the major source of both carbon-1!4 and tritfum re-leases [n the U.S. To that extent, the NRC staff !s currently overestimating the {Impact of those radionuc!!des. The effect of the releases of radioactivity to the environment has been placed In perspective In Section l! of this report, where poten-t+lal health effects that may be related to the nuclear fuel cycle are calculated. The staff relterates that health effects related to the nuclear fuel cycle are very smal! and that appropriate attention and concern !s belng devoted to the health and safety of the public. Petition Evidence 11thru 17. 11. NRC admits that any release of radiation to the public results In health effects, {!ncluding cancer and genetic defects. NRC has est!mated these health effects for the entire Industry to be on the order of 102 deaths from cancer and 10 genetic defects over the next twenty-two years. NRC bases this estl-mate on the 1972 NAS-BEIR report. 12. Edward Radford, Chairman of the BEIR Committee, testified to Congress on February 8, 1978 that the 1972 BEIR report had underest!mated the damage caused by fonizing radiation at low levels. Recent discoveries In the rad!at!on sclences and among the human population Indicate new estimates of the effect of radiation on man are required. 13. The range of revised estimates for cancer and leukemla from routine fuel cycle releases !s now from 100 to 1,000,000 annually. 14. The 80 dally death commitments from mining and milling, and the other deaths from other stages from ac-cildents, and from variant releases, represent deaths to both private citizens and occupational workers, neither of whom have knowingly
ee consented. 15. Because a number of factors have not yet been fig-ured {nto these calculatfons, such as non-cancer deaths, !ong term genetic damage, the super!{near curve of dose response, and !mproved data and ana!ysis which may make the actual damage thousands of +!mes greater, these early estimated health effects ment+foned by the petitfoner may be orders of magnitude too low. 16. I+ is uncontested that each and every stage of the fuel cycle emits polsons to the biosphere. in earlier times I+ had been thought that the volume of these pofsons would be so insignificant as to not Injure public health, The best avaflable current evidence now [Indicates that re-lease to the blosphere of these polsons at any level attalfnable by present destan of the fuel cycle constitutes a serfous public health burden and a loss of life to milltons of people over Jong perlods of time. 17. This loss {fs avoldable. Responses 11 thru 17. Estimated health effects, such as those In GESMO (NUREG-0002) and other NRC reports are all based on the assumption that the linear extrapolation of health effects observed at high doses and high dc. rates may cause a proportfonate number of health effects at low .es and low dose-rates. There Is abso-lutely no way of demonstrating health effects from doses that are a very small! fractionof the ambfent background radiation levels. This has been discussed In detall in Sections l & ll! above. While the petitioner pofnts to the ex!stence of new data and studies (e.g.; Mancuso, et al, referenced In the petition) which clalm to establish that radiation risks have been serfously underest!imated In the past, other reviews and data which suggests the opposite effect are Ignored. For example, a UK study* of Windscale workers shows that for cancers of the haematopofetic and lymphatic systems, there has been no observable Increase (95% confidence level) above the expected numbers. The most recent evaluation of the Hanford worker data** [Indicates that regardless of the questionable findings of Mancuso, et al:
- G. W. Dolphin, "A Comparison of the Observed and Expected Cancers of the Haematopoletic and Lymphatic Systems Among Worker at WInd-scale, a First Report", NRPP-R54, Natl. Radfological Protection Board, Harwell, England (December, 1976).
- B.S. Sanders, "Low-Level Radiation and Cancer Deaths", Health Physics Journal, Vol. 34, pp. 521-538 (June, 1978).
Exposed Hanford workers !{fve longer than nonexposed workers, their siblings, or matched controls; Nonexposed workers have shorter I!ves than their sfblings and matched controls; All observations avaliable so far give no firm Indication of any lasting adverse health effects attributable *o occupational exposure to radiation within permissible Ifmivs. While the staff does not conclude that there are no adverse health effects from occupational expcesures, !t !s clear that the pet!tloner's ' challenge to the !972 BEIR Committee risk estimates rests on very questionable grounds. It !s perplexing io note that the petitifoner correct! . iS UO olnts tne ny cu ait Cur the existence of radiation repair processes (e.q.; + petition+ p. 6) and then totally Ignores the very rea! poss!b!!Ity that such mechantsms may also correctly repairs much or most of the ce! lular (and motecular) radiation damage which occurs at very low doses and dose-rates (e.g.; from background radiation). Such repair mechanisms may be overwhelmed by multiple fonizations resulting from high exposures g!ven at high rates such as has presumably occurred among the Hirosh!ma and Nagasaki survivors, the uran!um miners, and the ankylosing spondyi!tics treated with x-rays. As noted by the BEIR Committee, "The dose rate character!stic for background radiation (approximately 0.! rem/year) Is one-hundred-mili:on to one-billfon times lower than the dose rate at which effects have been observed In most Irrad!ated study populations... Tie enormous difference may have important Imp! Iicaticns with respect to the production of radiation damage and !ts repair at the molecular level". Since the 1972 BEIR estimates of risk are based almost entirely on such human data, [t Is possible that NRC has overest!- mated potential risks of the nuclear fuel cycle. Indeed, the staff agrees with the BEIR Committee* that "the poss!bIilIity of zero (effects) cannot be excluded by the data".
- BEIR Report, Natfonal Academy of Sclences, Wash!ngton, D. C.,
- p. 88 (1972).
The petitioner's claim that the NRC staff has estimated tnousancs of cancer deaths and genetic effects over the next 22 years !s fattacilous, since those are the effects which might occur over centurles beyond the year 2000 (e.9.; as calculated In GESMO). For example, the major potential releases of radioactivity for a rap 7 Vv growing nuclear industry as assumed In GESMO) would occur near t n e enc of the !975=2000 t!me per!od. The dese commitments from which the potential health effects were calculated are extenced (!n GESMO) over a total of 90 years after the year of release, with subsequent latent cancer death occurring even later. In addition, the cenetic effects estimates represent the potent!ia! !mpact on populations for 5 generations Into the future. In doth cases, somatic and cenetic effects were assumed to occur, and no allowance was made for the that even If low !eve! radiation can Induce very real poss!ibility cancer and genetic effects, future discoveries In prevention and cure of cancer, and genetically related diseases and genetic eng!neering may negate many of these effects. Or. Edward Radford, Chairman of the BEIR Committee, testified to Congress on February 8, 1978 that the !972 BEIR report had (somewhat) underestimated the damage caused by lon!zing radiation at iow levels, and that recent d!scoverfies In the radiation sc!ences ana recent epidemiological! studies Indicate new estimates of the effect of radiation are required. Or. Radford also testified that the l !near dose response mode! st!!! represents a reasonable estimate of the radiation risk, although It appears to underestimate the risk of total cancer by a factor of only about 2, and of certal!n specific cancers by as much as a factor of 4. Or. Radford did not cal! for the discont!nuation of nuclear power, but recommended a loweri!ng of the occupational exposure lIimits based on an apportionment of cancer risk between radiation and other potential environmenta! causes of cancer. In addition, he recommended that the 25 mrem/yr EPA I!mit to Individuals In the population (40 CFR Part !90) be appiled, as It fs to be for NRC Ifcensees. In addition, !t should be noted that the risk estimates provided In the !977 UNSCEAR* report are not appreciably different from those estimates In the 1972 BEIR report. Sources and Effects of lonizing Radtation, United Natftons Sclentific Committee on the Effects of Atomic Radiation, 1977 Report to the General Assembly, Un!ted Nations, NY (1977).
Oi qo Finally, although recent studies by Mancuso, Sress, and others have sugcested that tne 8EIR report estimates have grossly under-estimated the actua! sancer and cenetic risks, these stud!es have met with consigerable critic!sm In the scient!fle community, and appear to be at odds with the recent report by a highly regarded sclentific body with substantia! expertise and experience, !.e., the UNSCEAR Committee. (report referencec ear!ter) Thus, !f !s not a matter of fact that observed effects confirm sertous uncerestimations of the health effects predictions embod!ed In the present requiations. The low !eve!l radiation dose-response question Is being vigorously debated by the scientific commun!ty, and th!s climate Indicates the need for more and better - a pa a a Bs ae ' t om am i 8 me Aw +n! t ee ee ee as tt..w 1 epidemiciosc ca: tiiiwe arion. ~ Aarormé ve voconcs cv3iise:s, it will be promptly Incorporated Into the Nuclear Requ!atory Commission's radiologica! impac? assessment methodology, and when substantiated, Into the radiation protection standards. The staff also rejects the petitioner's claim that "rev!sed estimates for cancer and !eukemla from routine fuel cycle releases !s now from 100 to !,000,000 annua!!y". While the lower range !s nearly comparable to current staff estimates of potent!al cancer deaths among 3 bililon Americans assumed I!v!ing during the next 1,000 years from each year's operation of existing power reactors, such deaths are not belleved to be occurring annually at the present time from routine releases at !icensed fuel cycle facilities. The upper end of the range (1,000,000) !s 3 times greater than the total cancer deaths actually occurring annually In the U.S. now, and !s therefore Inconsistent with fact. The staff projection of health effects related to mining and mil!i!ng have been discussed earller, a part of the !mpact of the nuclear fuel cycle, and disagree by orders of magn!tude with the petition claim of "80 dally death commitments from mining and milling." We concur with the BEIR Committee, Dr. Radford, NCRP and UNSCEAR (all as referenced ear!!fer) that the !!near dose response extra-polation does not significantly underestimate tne risk of low level radiation effects. Thus, If In fact there !s an underestI-mate of health effects, !t would not be by orders of magn!/tude. The contribution of radiation to non-cancer deaths !s also recognized as a possIibIl{ity. However, In this case the dose response form {s even more obscure than for cancer. We do not deny that there {s a possibility of low-level radlatfon contributing to other pathologic conditions, however, It seems that, at present, cancer !s the most prevalent and serfous potential radfogenic health effect.
With regard to the pet!tioner's ci l'fe are avoidable, the staff also d!sacrees. how the future electical pewer needs of mankind a technology 's without risk. As pointed out ear!! of coa!, of! or solar pcower for nuc!ear power can be predicted to result in even greater number of much !ess hypothetica! deaths. The staff disagrees with the pet!tioner's statement that "much-!f not most-of commercially generated LLW from al! parts of the fue! cycle does not go to licensed land bura! sites." Most commerical iow jeve!l wastes are disposed of at the commerically operated NRC l'censed or state licensed burlal grounds. Less than 100 l! Iicensees d!spese of smal! quantities of materia! uncer the limit!ng cond! tions specified In 10 CFR 20.304. Although the risk associated with burfais under section 20.304 !s smali, the NRC, as par waste management program, !s evaluating whetner a trols such d!sposa!l should be cont!nued. The staff disagrees with petitioner's contention that large volumes of radioactive wastes are presently being released to the blosphere, e!ther by direct d!ispersal In the air or water, or by delayed d!spersal through !and burla! operations. The NRC and Agreement States license and contro! the commercia! LLW bur!a! s!tes. Although releases of low concentrations of radionuc!!des have occurred at some of these sites, the releases have been small, have presented no hazard to the public health and safety, and corrective actions have and are being taken at these site. C. Statement of Law: Jurtsprudential Princ!ples Petitioner sees governmental authorization of "the nuclear fuel cycle" as approval of an experimental! process which "depr!ve(s) human be!ngs of thelr !!ves !n order to obtain energy for other human belngs." Petition Abstract, at 1. Viewed from this perspective, cont!nued operationof the fuel cycle !s regarded by petitioner as a "willful causing of disease, death and deformity within a large number of peop!e over a long perfod of time." Id. The "exper!ment" and {ts Review of the Current State of Radiation Protection Philosophy, NCRP Report No. 43, Natlonal Counc!li on Radiation Protection and Measurements, Washington, D. C. (January, 1975).
aA ve purpor*ed effects are thus ~ecarded by petitioner as "crimes aca!nst humanity of the most he!nous cegree and inimical to American and International concepts of justice under the !aws." Id. And while "Colapttai punishment !s not asked for," Petition at 131, the Comm's-sion ts asked to "revoke the licenses of all nuclear fuel cycle l facillttles over which ft holds jurisdiction." Petition at 151 .1/ No d!iscussion of the Comm'ssion's legal authority to revoke licenses ts contained in tne petition. Instead, the petition !s devoted to discussions of the Nuremberg trials, Internationa! iaw and general constitutional principles, none of which are related by petitioner to the requiatory authority of the NRC. Commission's author!ty to revoke Iicenses !s governed by section (nD 7 no of the Atomic Energy Act. 42 U.S.C. 2256. That section autnor-wm Oo s revocation only under certain specified circumstances. These cumstances may be summarl!zed as follows:
¢ 71
-for a material faise statement;
-because of cond!t!lons revealed by a license app! ication;
-because of conditions revealed by a statement of fact required to be submitted pursuant to section 182 of the Act;
-because of conditions revealed by any report, record, or Inspec-t+lon or other means which would warrant the Commission to refuse to grant a license on the original application; and
-because of violation of the terms of a license, a requiation or the Act.
Petitioner has falled to provide any reasonable bas!s which would justify l!ficense revocation under sectlon 186 or under any other provision of law. The petition does not "reveal" anything about the varfous fuel cycle !fcenses which was not generally known at the
+{me the orfginal I!cense applications were granted. The pet!t+fon provides no new Information. More Importantly, however, the pet!+foner misapprehends the bas!{c statutory standard for authorizing activities In the nuclear fuel cycle.
1/ Although the petitioner asks that the Commission take several other actions {In connection with the shutdown of the nuclear fuel cycle (e.g., Isolate hazardous matertals), revocation of all fuel cycle I!censes fs the critical actfon sought.
According to the petition:
"it was clearly the Intent of the Congress to piace this onus Cpresumably "th!s onus" refers to the onus of assur!ng public health and safety] upon *he nuciear reguiators Including the NRC, to evoke their good falth and careful judgment to protect the public from harm, at the first sign that there might be any."
Petition, 133 (emphas!s In original). The emphas!s here on any"' harm to the public Indicates that pet!-
+loner belleves no !mpact at all on public health and safety 's tolerable; that nuclear act!ivities must be eiim'inaeted If there Is any adverse public effect, however smail that effect may be.
The licensing standard estab!i!shed by the Congress for app! lication to nuclear fuel cycle I!censees Is, of course, quite diffe oot from the standard the petitioner considers to be applicable. As a precondition to issuance of a !!cense for operation of a nuciear facility, the Atomic Energy Act of 1954, as amended, requires a finding that there Is "adequate protection of the hea!th and safety of the public." 42 U.S.C. 2232(a). No Ilficense may be !ssued If Its !ssuance "would be Inimical ... to the heaith and safety of the publfe." 42 U.S.C. 2133(d). Contrary to the petitioner's conten-tion, the Act does not require an absolute guarantee of safety before nuclear activities may be lawfully !!censed. In +he words of one court, "La]bsolute or perfect assurances are not required by AEA (Atomic Energy Act), and neither present technology nor public policy admit of such a standard." Citizens for Safe Power, inc. v. NRC, 524 F.2d 1291 (D.C. Cir. 1975). Accord, Natural Resources Defense Council, inc. v. NRC, No. 77-4157, Slip Op. at 3836 n.3 (2d CiIr., July 5, 1978); North Anna Environmental Coal!tion
- v. NRC, 533 F.2d 655, 665 (D.C. Cir. 1976); Nader v. Ray, 363 F.
Supp. 946, 954 (D.D.C. 1973). The Commission {tself has rejected an Interpretation of the Act that would require absolute assurances of safety, stating:
"Neither the statute nor the Commission regulations..., however, require an unattafnable guarantee of risk-free operation.... We do not !!ve In a riskless society, nor could modern technological societies exist on that basis. We are, of course, aware of the potential risks In nuclear matters {f safety !s not given the very close attention It deserves." In re Petition for Shutdown of Certain Reactors, CL1-73-31, 6 AEC 1069, 1070 (1973), aff'd sub nom. Nader v. NRC, 513 F.2d 1045 (D.C. Cir. 1975).
See also In re Maine Yankee Atomic Power Co., ALAB-161, 6 AEC 1003, 1007 (1973), aff'd sub nom. Cit!zens for Safe Power, inc. v. NRC, 524 F.2d 1291 (D.C. Cir. 1975); In re Duke Power Co. (Wililam B. McGuire Nuclear Station, Units 1 & 2), ALAB=-128, 6 AEC 399, 405 (1973) aff'd sub nom. Carolina Environmental! Study Group v. United States, 510 Fiza 796 (D.C. Cif. 1975). Under the Atomic Energy Act of 1954, Congress ended the government monoply over atomic pcwer and began the present I!censing system that allows private partic!pation !n power development. Congress recognized then "that greater private participation In power develop-ment need not bring with !* attendant hazards to the health and safety of the American people. S. Rep. No. 1699, 83d. Cong., 2d Sess., . : reortnted in 2 U.$. Code Conc. & Ad. News 3458 (1954). Again, the responslblifty for prc:ecting public health and safety In the licensing process lay with the Comm!ssion, Id. at 3475, 42 U.S.C. 2133(b), but Congress did not require absolute assurances of safety before nuclear activities could be I Icensed. From the very outset the NRC and !*+s predecessor the AEC have Interpreted the Congressional mandate to require reasonable ansurgnce that the healt; and safety of the public will not be endangered, and the courts have sustained this standard as satisfying the require-ments of the Atomic Energy Act of 1954, as amendea. Fower Reactor Development Co. v. International Union ov Electrical, Radlo and Machine Workers, 367 U.S. 396, 414 (1961); Nader v. NRC, 513 F.2d 1045, 1052 (D.C. Cir. 1975). In determining what constitutes 2/ E.g., 10 CFR 50.40, which was embodied In the first set of regulations, promulgated to Implement the reactor !!censing provisions of the 1954 amendments to the Atomic Energy Act, provides as follows:
"Standards for Licenses And Construction Permits.
"50.40. Common Standards. In determing that a !!cense will be Issued to an applicant, the Commission wil! be guided by the following considerations:
"(a) The processes to be performed, the operat!ng procedures, the facllIty and equipment, the use of the facIll!ty, and other technical specifications, or the proposals, !n regard to any of the foregoing collectively provide reasonable assurance...
that the health and safety of the public will not be endangered." 21 Fed. Reg. 355, published Jan. 19, 1956, effective Feb. 18, 1956.
reesonable assurance of adequate protection of sublic health and safety, the Comm!ssion has the responsibility to assess the imrect of new technology, the risk of accicents, the record of past performance, the need for further !mprovement In safety techn! ques, and other reievant factors. Nader v. Ray, 363 F. Supp. 946, 954-55 (D.0.C. 1973). That It has fulfilled this responsibility 's a matter of record and really not at Issue in this petition. Rather, petitioner, at bese, appears to be quarreling with tne s*ancard estab!i!shed by Congress. Be that as !* may, for the reasons set Out above, no supportable bas!is has been shown for the requested Il !}cense revocations.}}