PROCEEDINGS OF PUBLIC HEARINGS
PLUTONIUM AND THE OTHER
TRANSURANIUM ELEMENTS
\
VOLUME 1
PROCEEDINGS OF HEARINGS IN
WASHINGTON., D,C,
DECEMBER 10-11, 1974
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Radiation Programs
Criteria and Standards Division
Washington, D.C. 20460
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FOREWORD
Production and use of plutonium and the other transuranium
elements is projected to increase rapidly. Because of the long half-
lives and high radiotoxicity of many nuclides of these elements, public
and technical concern has been expressed regarding the possible environ-
mental and health impact of releases of these elements to the environ-
ment. For this reason the Environmental Protection Agency has embarked
on a program to evaluate the environmental impact of the transuranium
elements and to consider whether further guidelines or standards are
needed to assure adequate protection of the general ambient environ-
ment and of the public health from potential contamination of the
environment by radionuclides of these elements.
As a part of this program public hearings were held in
Washington, B.C., and Denver, Colorado, to gather information re-
garding the public and social implications of plutonium utilization;
the factors involved in the balancing of costs vs. benefits; dosi-
metry, health, and environmental effects; environmental levels and
pathways; applications using plutonium; and control and cleanup
technology.
This Agency believes that the information resulting from these
hearings constitutes a significant contribution to the public aware-
ness and knowledge of this problem and that wide dissemination of
these proceedings will be valuable.
W. D. Rowe, Ph.D.
Deputy Assistant Administrator
for Radiation Programs
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PREFACE
Information was presented both orally and in written form
at the hearings and, in addition, a number of letters were sub-
mitted directly to the Office of Radiation Programs of The U. S.
Environmental Protection Agency for inclusion in the hearing
record. This information is being published in three volumes:
Volume 1 contains the proceedings of the hearing in Washington, D.C;
Volume 2 the proceedings of the hearing in Denver, Colorado; and
Volume 3 the additional material submitted. Where Written submittals
are more complete, these are printed in lieu of the oral testimony.
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CONTENTS
Opening Remarks, Dr. W. D. Rowe page 3
General Electric Company
Dr. Bertram Wolfe page 21
Atomic Industrial Forum, Inc.
Mr. Ralph Deuster page 55
Or. Leonard Sagan page 59
Dr. Marvin Goldman page 67
Dr. Herbert Parker page 75
Natural Resources Defense Council, Inc.
Mr. J. G. Speth and Dr. T. B. Cochran page 163
Dr. A. Tamplin page 229
U. S. Atomic Energy Commission
(Energy Research and Development Administration)
Dr. J. L. Liverman page 275
Dr. R. E. Yoder page 291
Dr. McDonald E. Wrenn page 377
Dr. B. Bennett page 417
Dr. W. J. Bair page 463
Dr. W. Burr page 536
Dr. C. Richmond page 541
Dr. R. Thompson page 57b
Biomedical Effects Panel,
Drs. Bair, Burr and Richmond
(Continued discussion) page 711
Dr. F. Forscher, Energy Management Consultant page 724
U. S. Atomic Energy Commission
(Nuclear Regulatory Commission)
Mr. Lester Rogers page 751
Westinghouse Electric Corporation, Power Systems
Mr. F. W. Kramer page 798
Dr. J. E. Wright page 818
The Environmental Coalition on Nuclear Power
Ms. Judith H. Johnsrud page 850
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PROCEEDINGS
Dr. Mills: I would like to get this Public Hearing underway.
This is a Public Hearing on Plutonium and the other Transuranium
Elements.
This particular hearing was announced in the Federal Register
on October 24, 1974.
To open the hearing, I would like to introduce Dr. W. D. Rowe,
who is Deputy Assistant Administrator for Radiation Programs in EPA.
Dr. Rowe: Thank you, Bill
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OPENING REMARKS
BY
W,D, ROWE, PH.D,
DEPUTY ASSISTANT ADMINISTRATOR
FOR RADIATION PROGRAMS
Washington, D.C. Environmental Protection Agency
December 11-12, 1974 Washington, D.C.
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.'*
I would like to extend a most cordial welcome to both participants
and audience assembled here for the EPA public hearings on plutonium and
the other transuranic elements. The Environmental Protection Agency in
its role of providing Federal Radiation Guidance and setting standards
is soliciting information from the scientific community, State and other
Federal agencies, and the public at large requisite to developing
applicable environmental standards and guidelines for these nuclides.
The functions of the AEC related to setting of generally applicable
environmental standards were transferred to the EPA by the President's
Reorganization Plan No. 3 of 1970. The functions of the former Federal
Radiation Council were also transferred to the Administrator of the
Environmental Protection Agency at the same time. It is under these
authorities that the EPA is now attempting to place the standard-setting
picture in perspective and determine whether current standards and
guidelines are adequate or whether these should be revised or changed.
The establishment of regulatory standards and radiation guidance
involves three different types of judgment which must be clearly
recognized. It is information which will permit us to make such
judgments that we here desire.
First, we have the technical judgment. Groups of related facts may
on occasion be given a different interpretation by the experts, and
result in different conclusions. The rationale and validity of these
conclusions then needs to be examined from the viewpoint of their
influence on standard setting. In addition, there are always areas
where the results may not be definitive and uncertainties remain. While
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it may be possible to conduct scientific experiments to reduce such
uncertainties, the tijne to carry out these experiments may preclude the
necessary information being available at the time action is needed.
Therefore, experts in the technical problem area often must make
collective value judgments on the interpretation of available
information.
The second type of judgment is the one where the best technical
information as to risks, costs and benefits is considered and balanced
to achieve equitable standards for society as a whole. In making a
regulatory balance of this type, not only must costs and benefits be
balanced as a whole, but inequities where cost and risk impact on those
who do not directly receive benefits must be considered in terms of the
total and ultimate impact of this activity. In the case of plutonium
and the actinides this involves consideration of potential health
effects committed for long periods. This type of value judgment must be
made by society as a whole and not by the technical community alone.
The third type of judgment is that when standards are set they must
be capable of being implemented and enforced in a way that is visible,
traceable and reportable, and can be substantiated in an evidentiary
manner in the courts. Thus judgments of a managerial nature as to the
best means of implementing a standard certainly affect the form of a
standard.
It is not by chance that the Environmental Protection Agency's
Office of Radiation Programs has selected plutonium and other
transuranic elements as the first problem to be considered in this type
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of forum. The toxicity and long li^e of plutonium and the transuranium
elements, totally man-made elements, provide us with the need for making
value judgments now which will have long-term significance.
The objective of these hearings is to provide a forum where all
existing information on plutonium and other transuranic elements which
affects radiation protection activities can he aired and considered in a
meaningful way, where all points of view and all who wish to provide
input can have an opportunity to be heard in a studied manner. It is
our opinion at EPA that this information can be derived by the type of
hearing format we are using here - where the procedures are informal and
a panel of technical experts is used to assure that the information
presented is sufficiently clear for public recognition of all viewpoints
The information that we seek at these hearings is to provide a technical
baseline of information on radiation protection aspects of the
transuranics, but also can be addressed to any one or all o^ the value
judgments that I have described.
We are earnestly seeking out all available information. The record
of this hearing will constitute one of many sources of input of
information to that end. I want to emphasize that point -- the record
of this hearing will certainly make a significant contribution to
establishing the information input, but it is by no means intended to be
the only one. Our technical staff is already analyzing the problem, we
have let a number of contracts, and we have also requested written
submissions from the technical community and the general public by a
Notice in the Federal Register of September 23, 1974. All of this
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information will be studied and evaluated and only in this way can we
hope to include all pertinent consideration in our standard-setting
processes. It may be necessary for us to hold a second round of
hearings in another part of the country, possibly Denver, as has been
requested by local people if the demand for such a second hearing
materilizes. In any case the record will remain open for 30 days after
the final hearing date so that all may have an opportunity to comment or
rebut and additional material may be provided. All material received
will become part of the transcript of the hearings.
Now for some specifics of the problem before us. The elements
which are under consideration here include plutonium, neptunium,
americium, curium and all the others through atomic number 103. These
elements are all man-made. Forty years ago they were unknown. Today,
they are produced in large quantities in nuclear reactors. They form a
central part of our national defense, nuclear power industry and space
research program. They are beginning to appear in consumer items such
as smoke detectors and static eliminators. Research and development is
underway on such items as heart pacemakers and heart punps. The list is
expanding as larger quantities become available.
The potential hazards of exposure to plutonium were recognized very
shortly after the first milligram quantities of this element were
isolated at Oak Ridge in 1943. There is a long history of concern
related to these elements. Much work has been done on the toxicology of
plutonium -- but much has yet to be learned. Similarly, the
environmental transport mechanisms -- especially those occurring over
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extended periods of time -- are not yet well defined and much more work
needs to be done. Yet the picture is not quite so bleak. Probably more
work has been done, and more money has been spent, in trying to unravel
the mysteries of plutonium than is the case for most potentially
carcinogenic substances. The earlier studies were motivated primarily
by a concern for the safety of plutonium workers, and most of the early
guidelines were specifically for occupational exposure levels. Exposure
guidelines have been gradually decreased as new information was
developed and current maximum permissible body burden values were
adopted by the NCRP and ICRP in 1959. These are under continuing
consideration by all standard-setting organizations and cannot be
considered to be static.
A central item in our considerations involves estimates of the
total cost of plutonium utilization in terms of numbers of potential
adverse health effects. For this purpose we intend to utilize the
concept of a "dose commitment," which includes consideration of the
cumulative effects of a persistent radionuclide over the entire time it
is expected to remain in the ecosystem. This approach is especially
important for the long-lived radionuclides, where the effect of their
release to the environment is largely irreversible and preventive action
is called for. The parameters required -for such projections include an
estimate of the growth of the plutonium inventory, estimates of release
fractions, and estimates of exposed populations.
Estimates of plutonium inventories, other than those of the defense
establishment, rest largely on projections of the future of the nuclear
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power industry. Plutonium is produced in every light-water reactor. It
is the utilization of this material that is largely in doubt. There are
proposals to utilize mixed oxide fuels now pending before the AEC, which
would increase the amount of plutonium to be recycled. Somewhere in the
future there is probably the emergence of the fast breeder reactor,
which would increase the total plutonium inventory by less than an order
of magnitude but significantly increase the amounts to be reprocessed
and recycled. Thus there is a degree of uncertainty in our projections
and we are most interested in developing a better data base.
In order to develop a baseline for those judgments of a managerial
nature which are concerned with adherence to a standard, it is necessary
to know both the current contamination levels and the limits of the
measurement processes. J>Juch work has already been done in measuring
environmental levels in the past, and the work is continuing.
Analytical techniques are being refined and will become ever more
capable of measuring smaller and smaller quantities with better
accuracy.
As all of you probably know, there is already an existing worldwide
inventory of plutonium. Most of this was contributed by the early
weapons tests, with some additional contamination in the vicinity of
certain facilities which have handled these materials. I should
emphasize that, in relation to the large quantities handled, the
releases from these facilities have been miniscule. This is a testament
to the early recognition for strict control of such releases and the
need for constant vigilance. There is nothing that can now be done
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about the background levels already in existence. There is, however, a
need to examine the somewhat higher levels in the environment around
certain -facilities, and to attempt to minimize releases in the -Future.
One important element of our standard-setting process is that other
interested and involved Federal agencies be brought into our
deliberations early and that their input be given due consideration.
Only in this way can we develop standards which are truly representative
of the entire Federal establishment. We have therefore set up an
Interagency Advisory Committee to assist us in this task. Several
members of this group are here this morning as observers to these
proceedings. This group will provide both technical input and
coordination. However, the final promulgation of standards rests with
the Administrator of EPA and will follow EPA standard setting
procedures. Nevertheless, the purpose of the Interagency Advisory
Committee is to look at all aspects of the problem in a coordinated
fashion. It is expected that participating regulatory agencies will set
their own standards in conformance to EPA standards when they apply, and,
to set their own regulations in accordance with general Federal guidance
when EPA generally applicable environmental standards do not apply. The
objective is to achieve a total Federal approach to the problem, rather
than a series of fragmented efforts.
There is one problem on which I would like to touch because I
expect that it may occupy a major part of our attention during both this
hearing and the deliberations to -Follow. The radionuclides of which we
speak here are predominantly alpha emitters. The releases to the
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environment are often in participate form and may be inhaled. Because
of the low penetrating power of alpha radiation, any damage to the
tissue surrounding such an inhaled particle is restricted to the
immediate vicinity of such a particle. The question that was first
raised at the Chalk River Conference on Plutonium in 1949 and has
perhaps never been conclusively answered is whether the total radiation
dose received should properly be averaged over the receptor organ (which
in this case is the lung) or whether the exposure limits should be based
on the intense localized doses received. The Natural Resources Defense
Council petitioned both the AEC and EPA in February of this year to
lower the current guidelines for permissible air concentration values by
a factor of more than 100,000 based on precisely this argument. We
certainly intend to consider this aspect with all the attention it
deserves.
Finally, let me repeat that this is an information gathering
hearing. For purposes of conducting these hearings we have appointed a
panel of distinguished scientists. Their job is to assure that all
information is brought to light and that all sides of a question are
considered fairly and adequately.
Now let me introduce the Panel:
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MEIA'IN FIRST
Dr. Melvin First was born in Boston and received his Doctorate of
Science in Industrial Hygiene from Harvard. He has served with the
Michigan Department of Health and is now on tha faculty of the
Harvard School of Public Health. He is well kno\m for his many
contributions in air and gas purification.
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KARL Z. MORGAN
Dr. K. Z. Morgan was born in Kannapolis, North Carolina, obtaining
his Ph.D. in Physics from Duke University. He became Director of the
Health Physics Division at Oak Ridge National Laboratory in 1943. He
is a member of the NCRP as well as the ICRP and is presently the
Neeley Professor in the Nuclear Engineering Department at Georgia Tech.
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EDWARD RADFORD
Dr. Edward Radford was born in Springfield, Massachusetts. He
earned his M.D. degree at Harvard where he taught at the School of
Public Health. He is professor of Environmental Medicine at the
Johns Hopkins School of Hygiene and Public Health.
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JOHN GACIiER
Dr. John Garner was born in the United Kingdom where he was educated,
majoring in biochemistry and received his doctorate in Veterinary
Science at Liverpool. After serving in several assignments in Africa
and the U.K. he came to the U.S. in 19b5. He served as the Director
of the Collaborative Radiological Health Laboratory at Colorado State
University from 19b5 to 1972. He is now Director of the Experimental
Biology Laboratory of EPA at Research Triangle Park in North Carolina.
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WILLIAM A. MILLS
Dr. William A. Mills was born in Lynchburg, Virginia, received his
Ph.D. in Biophysics from the Medical College of Virginia. He is a
Commissioned Officer - U.S. Public Health Service, current rank
Scientist Director. Past employment; Oak Ridge National Laboratory,
The Southeastern Radiological Health Laboratory, Bureau of Radiological
Health and is currently the Director of Criteria and Standards Division,
Office of Radiation Programs, Environmental Protection Agency. Field of
sp2Cialization is the Bioeffects of Radiation.
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LAURISTON S. TAYLOR
Dr. Lauriston S. Taylor was born in Brooklyn, New York obtaining a
D.Sc. degree from the University of Pennsylvania in I960. He worked
at the National Bureau of Standards for many years starting in 1927;
becoming Chief of the Radiation Physics Division in I960. He now
serves as the President of the National Council on Radiation Protection
and Measurement.
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Dr. Mills will be the presiding officer at the hearing.
Bill, let me turn the hearing over to you.
Dr. Mills: Thank you, Bill.
Let me briefly review some of the procedures and requirements
that will be applicable to this hearing.
We need to say it was announced in the Federal Register. The
hearing will be conducted informally. Technical rules of evidence
will not apply. Discovery and cross examination of participants will
not be permitted.
The hearing panel is appointed by Dr. Rowe, and will consist of
a chairman and three or more experts in the field of radiation
protection. The panel will conduct the hearing. The chairman of the
hearing panel is empowered to conduct the meeting in a manner that in
his judgment will facilitate the orderly conduct of business, to
schedule presentations of participants, and to exclude material which
is irrelevant, extraneous or repetitious.
Persons wishing to present an oral statement are asked to give
notice no later than November 23, 1974, in order to be placed on
the agenda. The time allotment for such oral statements shall be
at the discretion of the chairman. Ordinarily, it will not exceed
20 minutes.
Persons wishing to submit written statements regarding the
agenda items may do so either in advance or during the hearing.
Such persons may also request an opportunity to present an oral
statement.
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Oral presentations may be presented by panel discussion of
technical experts chosen to present a particular viewpoint in notices
given. Time allotment for such panel discussions shall be at the
discretion of the chairman, but shall not ordinarily exceed 60
minutes.
Requests at the time of the hearing for the opportunity to make
oral statements with no previous notice shall be ruled on by the
chairman, who is empowered to apportion the time available, but not
ordinarily to exceed five minutes.
Questions may be propounded by members of the hearing panel
only. I ask that questions be submitted to Dr. Gordon Burley for
referral to the panel.
The use of cameras is permitted only before and after the
hearing, and during recesses, not during the session.
A transcript of the hearing will be made, and a copy of the
transcript, together with copies of all documents presented at the
hearing will constitute the record of the hearing.
The copy of the transcript of the hearing will be available for
public inspection and copy within 30 days after the conclusion of the
hearing at the U. S. Environmental Protection Agency.
To assist the reporter and the audience, I ask that the speakers
and panel members avail themselves of the microphones. Also, I
would ask that the speakers attempt to limit their remarks in accord
with the standard procedures, so that we can reasonably adhere to
the agenda as it is shown.
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With regard to the agenda, I am not sure I have all the changes,
but we have been asked by the General Electric Company to allow them
to be our first witness. If I could, I would like to call for the
General Electric Company, Dr. Bertram Wolfe. Is he in the audience?
Dr. Radford: Mr. Chairman, before we get to that, I would like
to ask, is it the intent that the panel of experts speaking for
individual testifiers will be given 60 minutes automatically, or will
it be held to a somewhat lower figure?
Dr. Mills: If you are talking about the discussion panel -
Dr. Radford: No. We have several groups coming in, Atomic
Industrial Forum and so on who are presenting panel testimony, under the
terms of the Federal Register statement.
There, it is stated that panels would not exceed 60 minutes. The
question is, will they be given 60 minutes automatically?
Dr. Mills: We would hope that they would stay within a 60 minute
limit. They will automatically be given 60 minutes.
Dr. Radford: They will automatically be given 60 minutes?
Dr. Mills: Yes, sir.
Is Dr. Wolfe in the audience?
Dr. Wolfe: Yes.
Dr. Mills and gentlemen, I personally and the General Electric
Company are pleased to participate in this public hearing called by the
Environmental Protection Agency.
I want to start by thanking the Atomic Industrial Forum for letting
me go first. I have an unavoidable conflict this afternoon, and a plane
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to catch.
As indicated in the Federal Register of October 24, this hearing
concerns itself with the environmental impact of plutonium and other
transuranium elements and consideration as to whether new guidelines or
standards under the authorities of EPA are needed to assure adequate
protection of the general ambient environment.
I have some written remarks on the subject which we will give to you
and would like to have in the record. I will not go through the whole
thing in the interest of saving time.
I want to indicate that my name is Bertram Wolfe and that I am
General Manager of the Fuel Recovery and Irradiation Products Department
of General Electric.
Sitting to my left is Mr. Terry Trumbull who is Counsel to the
General Electric Nuclear Energy Division.
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PUBLIC HEARING
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
DECEMBER 10, 1974
WASHINGTON, D.C.
PLUTONIUM AND OTHER TRANSURANIUM ELEMENTS
WRITTEN STATEMENT OF THE
GENERAL ELECTRIC COMPANY
NUCLEAR ENERGY DIVISION
175 CURTNER AVENUE
SAN JOSE, CALIFORNIA 95125
ORAL SUMMARY STATEMENT BY:
Bertram Wolfe
General Manager
Fuel Recovery £ Irradiation Products Dept.
Terry A. Trumbull,
Counsel
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The General Electric Company is pleased to participate in this public hearing
called by the Environmental Protection Agency (EPA). As indicated in the
Federal Register of October 24, this hearing concerns itself with the environ-
mental impact of plutonium and other transuranium elements and consideration
as to whether new guidelines or standards under the authorities of EPA are
needed to assure adequate protection of the general ambient environment.
The General Electric Company believes that it would be helpful to both the
nuclear industry and the public at large if a sound standard for ambient con-
centrations of plutonium, other transuranium elements, and other radioactive
elements of concern were developed. The emphasis on development of any
standard should be on the word sound. We believe that current practices in
the nuclear industry today, in accordance with AEC regulations, assure that
there is no risk to the public health from plants built in accordance with
these regulations. Nevertheless, a sound standard would, we believe, pro-
vide a benchmark for the public with which they could judge the adequacy
of industry measures to assure that the risk to public health is negligible.
Similarly, a sound standard would provide a benchmark for industry and
government regulatory agencies with which they could set design and surveil-
lance requirements for plants and activities involving radioactive materials.
In addition, a sound standard would allow meaningful trade-offs for public
consideration as to whether national resources should be devoted to measures
to further minimize ambient radioactive levels from human activities or
whether these resources might more beneficially be devoted to other areas of
public welfare. At present, with no quantitative standards, the public is
left with a lingering concern about the health effects of nuclear activities.
This is reinforced by the use of the philosophy of "as low as practical,"
which implies a lack of knowledge to the public r.nr! emphasizes continual back-
fitting or other improvements which are required vi 'chout regard to any analysis
of the costs and benefits to be gained. The use of th:s philosophy may result
in electricity cost increases which are not comr.icnsurate with the benefits of
relatively minor effluent control improvements.
As noted, the emphasis of our endorsement. -"•"-" tae c^vc.jj. . M': of star.clar 3::
for plutonium and transuranium elements is on the word cound. As indicated
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in the following remarks, we believe there is no risk to the public from
,]'-.r activities cuvj sicn^d i>i J.:.c ;,•_.-. ^ •-• •:.->. v - . .CC
regulations. Thus, there is time to develop a sound sLain". .rd, and the
development of such a standard will require substantial r search and study
which we believe will take a number of years. We endorse the development of
such a standard but suggest some general guidelines. First, the standard
should consider the possible health effects on individuals in light of the
unavoidable risks from radiation which occur because the atmosphere is
subject to cosmic-ray bombardment and because the materials of our planet
are, in part, naturally radioactive in any event. Further, an extensive
cost-benefit analysis needs to accompany the development of any standard.
It is imperative that the public as well as governmental decision-makers
be aware of the cost of implementing any standard and the risk which would
be avoided. For example, the public might be interested to learn what addi-
tional costs they can expect to their electric bill from a proposed standard
and how the reduction in risk compares to normal risks such as would occur
on an airplane flight or in moving from a wooden to a brick house.
Finally, we strongly suggest that if the EPA sets out to develop standards
in the area of plutonium and transuranium elements that they work closely
with the AEC to avoid the inefficiency of two governmental agencies working
independently on the same problem.
I. RECOMMENDED APPROACH TO AMBIENT STANDARDS DEVELOPMENT
The emissions of plutonium and transurcniur> elements in effluents from
nuclear facilities always nave been limited by AliC regulations and
license conditions. These emission limitations are accomplished by a
system of requirements generally as follows:
a. Confinement of radioactive material inside multiple physical barriers;
b. Control of access to plant process!::.., jrc>-is through additional
physical barriers;
c. Ventilation control such that air flcv,,-, frcm areas of lesser to
areas of greater contamination potcn' j-il;
d. Effluent treatment for air by filtration, for liquids by chemical
means, and for sol:.;- L- rl .cont.v., ' - : "..'.-:-, ,.11 remit ;.:. in
effluent rndionucliciu concantrdLio.i- I -s.^ tr.r.n regulatory values.
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In some cases, liquids are solidified;
e. Controlled burial of solid waste contaminated with radionuclides above
regulatory values; and
f. Measurement of radionuclide concentrations in effluents and on items
or materials, as well as other appropriate actions to assure that
regulatory values are not exceeded.
These requirements have been successful in limiting the emissions of such
materials from nuclear facilities to levels such that the resulting organ-
man-rem dose to the public is very low compared to the same dose from
naturally occurring alpha-emitting radionuclides.
The EPA estimates* the current annual internal radiation dose to bone
(endosteal cells) from natural alpha radioactivity in the United States
is 37.1 millirem average and to the lung is a minimum of 100 millirem.
Using the EPA figure of 205 million persons in the USA in 1970,* the total
organ-man-rem dose in 1970 to these organs is 7.6 and 21 million organ-man-
rern, respectively.
Fuel reprocessing is expected to be the dominant source of release of
transuranic elements.** The EPA's estimated annual dose accrued to the
bone and lung of the United States population from fuel reprocessing in
1970 is 0.001 millirem per person from all radionuclides. About half
of this dose results from alpha-emitting radionuclidea. The total organ-
man-rem dose in 1970 from reprocessing is calculated to be 0.0002 million
man-rem to either lung or bone. These doses are 40,000 and 100,000 times
less than the corresponding doses from natural alpha radioactivity.
Comparing similar bone and lung doses in the y^ar 2000 for 321 million
Americans shows that the natural alpha bone close ii 1? and 32. million
man-reia, respectively! In the year 2000, the org^n alpha doses from
reprocessing plants are expected to increase by about a factor of two.
*ORP/CSD 72-1, "Estimates of Ionizing Radiation L/G.-MS on the United States,
39GQ - 2000."
**Barr, N. P., "Quantitative Health estimate:, of ?:. • rr T-- r i :• Releases," paper
presented at the; Ovtcbcr 1974 meeting of ?. !<-,...i *~.a.-. .. ••' -'orjiety, Kar-hirr^r/n,
D. C.
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Therefore, the total population bone and lung <~.; : i: -lie y?-i\. 2000 ..c.'.-ld
be 0.0004 million man-rem from this source. These dOo:.s are respectively
approximately 30,000 and 80,000 times less than the :• .-rresponding doses
from natural alpha radioactivity. Current emission control procedures,
therefore, have been demonstrated effective, and the record of performance
with these regulations and license conditions does not support a need
for urgent change in the near term.
The amount of plutonium currently handled is relatively small. The AEC
estimates* population doses always will remain at very low levels—even
from the expected release of nuclides due to operation of 2,200,000 MWe of
liquid metal fast breeder reactor (LMFBR) capacity anticipated in the year
2020. At any rate, during the next five or so years, the amount of plu-
tonium handled is not likely to increase significantly and will remain
very small compared to estimates of quantities to be handled after the
end of the century. Thus, there is time to acquire needed information
such as real pathways of plutonium to man and more realistic estimates
r
of the effects of plutonium in humans upon which a practical environ-
mental standard could be developed. We understand that Mr. Parker, speak-
ing for the AIF, will describe in more detail some of the research needed.
The information required should be delineated, and a specific research
plan should be formulated to provide this information so that the develop-
ment of appropriate environmental standards for ambient concentrations of
transuranium elements can proceed on a sound basis.
Meanwhile, the American National Standaids Institute should complete
development of design criteria for mixed oxide fuel fabrication plants
and initiate development of design criteria for fuel reprocessing plants.
These design criteria should include c.,uoc: ifications for achieving effluent
emission control. Unti] the more quar.t -' r.ativc standards are developed,
the principle of limiting rndionuclide releases to levels as low as
practical may have to be ucilized. We have indicated that we believe
this to be a less than satisfactory long-term procedure, but also that
*ORP/CSD 72-1, op. cit.
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it has been effective in limiting man-made ambient transuranium levels to
below naturally occurring levels by several orders of magnitude. These
design specifications should consider the relative effect of each element
or nuclide on man, rather than assuming a single value for the entire
class of transuranium elements. The technical reasons for this recom-
mendation were set forth in the General Electric comments on the proposed
amendment of 10 CFR 20 and 150 concerning disposal of transuranic waste
by burial in soil.*
The AEC should continue its plant-by-plant control of radionuclide emissions
by regulations and license conditions. Environmental monitoring should
continue around nuclear facilities to obtain data useful in the overall
research plan.
We should like to emphasize that meaningful standards on ambient concentra-
tions of transuranium elements should be consistent with design and operat-
ing requirements for nuclear facility effluent control and waste management.
Thus, development of such standards should involve a cooperative effort of
all concerned governmental agencies to avoid both duplicative, costly
efforts by these agencies and the confusion which would result if nuclear
facilities were faced with the need to conform with inconsistent or con-
flicting requirements.
In summary, we believe that present regulatory requirements for the design
and operation of nuclear facilities are effective in assuring that the
public benefits from operation of these facilities are not negated by
effects inimical to the public health. On the other hand, we believe
that quantitative standards for ambient levels of transuranium elements,
based on sound benefit-cost analysis data, would have significant addi-
tional benefit to the nuclear industry and the public at large. We
support the development of such standards and the supporting research
efforts necessary for their development.
II. GENERAL ELECTRIC DIRECT EXPERIENCE IN HANDLING AND__USING PLUTONIUM
A. Experience with Plutonium at Vallecitos Nuclear Center
The General Electric Company has been actively engaged in the development
of plutonium-bearing fuels since 1959 CL its Vall-_-c-itos Nuclear Center (VKC) ,
*Letter to the AEC, dated 11/6/74, signed by A. N. Ttchaeche of General Electric Co.
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located in the San Francisco Bay Area. The j~: •-• -.. . ' '_G-;VJ^. ?-•*•• :>r I •.-/
was established at General Electric's Vallecito.-: ,;ucj.t .r Center in 1962,
expanded in 1967 to increase fuel fabrication capacit", and expanded again
in 1971 to include scrap recovery. For over 15 year:.., VNC has been fabricat-
ing plutonium fuels, developing process and control methods and equipment,
and studying fuel properties.
Plutonium work has not been confined to the Plutonium Laboratory. Examina-
tions of mixed oxide fuel rods and capsules are carried out in the VNC
site's alpha hot cells. Mixed oxide capsules are irradiated in General
Electric Test Reactor (GETR) and neutrographed at the Neutron Test Reactor
(NTR). Practically every facility on site has at one time or another
performed work with plutonium.
Over 1100 fuel rods have been fabricated for fast and thermal reactor
programs, using four process methods, six cladding methods, 60 kg of
plutonium, over 1.2 metric tons of mixed oxide fuel and some 171,000
pellets. The fuel pins were fabricated under stringent product quality
control conditions and were produced to meet a variety of design require-
ments. These fuel pins have been irradiated under varying conditions in
five different test reactors and four commercial power reactors.
General layout and arrangements for plutonium handling facilities are based
on multiple enclosure, separation of facilities and minimum fissile quanti-
ties. Construction materials, ventilation, glove-box design, lighting and
radiological controls have also played a key role in safety considerations.
The VNC environmental monitoring program was established to measure any
significant increase (above natural backm-ound levels) which may be
attributed to plant operations and to cnrvre th-:.4: the amounts of alpha
as well as beta-gamma activity released to che environment are controlled.
The radioactivity in the environment both, on anc! adjacent to the site is
measured.
The work performed at VNC over the last 15 yr>^rf.- has boen accomplished
in a safe and efficient rivo'_r- '.-it!'out ..•_••:' . ?}u^ .iu^
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controlled at all times to minimize release to the VNC environment to
levels substantially below regulatory requirements and generally to
several orders of magnitude below such r<'.'i'!irv:rr.c.ntj.. Tor exaniple, less
than three microcuries of alpha-emitting materials have been released
per year to the environment from the stack of the Plutonium Laboratory,
and essentially all of these releases have been naturally occurring
daughter products of uranium and thorium, not transuranium elements.
These emissions are insignificant and illustrate the effectiveness of
control at the Vallecitos site.
None of the individuals employed through the history of the plutonium
work at the site has ever experienced an internal deposition of plutonium
measurable with existing methods and procedures. It is estimated that
about 350 man-years of work have been directly connected with plutonium
at Vallecitos. There has been only one "reportable" occurrence involving
plutonium at VNC and that consisted of a plastic bag being torn from a
glove box during a maintenance operation. Contamination was confined to
the room.
Vallecitos experience shows that the plutonium economy of the future can
and should be approached with confidence. Further details on Genera.1
Electric Vallecitos experience are contained in the references listed below.
References:
1. Quarterly Report and Accumulative Annual Summary of the Vallecitos Nuclear
Center Self-monitoring Program, 1973 - 1974.
2. Annual Reactor Operating Reports, TR-1 (GETR) and R-33 (NTR).
3. VNC Stack Release—Ground Dose Rate Determinations in Support of the
Zero Release Study, November 6, 1972.
4. GE/VNC Safety Standard titled, "Regulation cf Radioactive Effluents,"
July 1974, No. 2.3.2.
5. Environmental Monitoring Manual, Vallecitcs Nuclear Center, NEDO-12449,
November 1973.
6. Statistical Evaluation of the VNC Environmental Ennui ing Program, 1965 -
1973, NEDO-12534, October 1974.
7. Enviro'iitentr.! Surveillance for Radioac-;;: v.; cy V ^ "' < ..: * - _-, Nuclear Center
(fivs operating history reports): Nl~. , I.M81 , !'.'• "-11-105, NEDO-12341,
APIO-1013-2 and APIO-1013-1.
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General Electric has had significant experience with plutonium with
the SEPOR facility. This reactor was operated for about three years
(March 1969 through January 1972) using plutonium fuel. As a part
of the extensive testing program, deliberate overpower transients
which subjected the fuel to repeated dynamic conditions in excess
of those in a commercial power reactor were induced to demonstrate
the inherent shutdown capability of the LMFBR, During the entire period
of SEFOR operation, there was no release of plutonium to the environment
or deposition of plutonium in plant operating personnel as determined
by standard detection and measurement instrumentation in environmental
and personnel monitoring programs,
SEFOR was charged with 380.4 kg of plutonium and generated 25,764
MW hours of energy during a total operating time of 3 ,895 hours .
The total operating experience includes about 117 man-years involving
plant personnel .
Details of this plutonium experience gained during the operation of
the reactor are contained in the references listed below.
References
1. Meyer, R. A., Reynolds, A. B. , Stewart, S. L. , Johnson, M. L. , Craig, E. R. ,
"Design and Analysis of SEFOR Core 1," GEAP-13598, June 1970.
2. Field, J. H., Johnson, M. L., Novak, P. E. , "An evaluation of the Effect
and Design and Operating Variables on SEPOR fuel and Fuel Cladding,"
GEAP-5309, December 1967.
3. "Southwest Experimental Fast Oxide Reactor Development Program, Thirty-First
and Final Report, November 1971 - January 1972.
4. Rider, B. F. , Ruiz, C. P., Peterson, Jr., J. P., Mclaughlin, T. V., "BURNUP:
A FORTRAN IV Code for Computing U and Pu Fuel Burring from U, Pu, Nd Mass
Spectrometric Measurements — Updated to Include Fast Roactor Fuels,"
GEAP-5355A, revised January 1970.
5. Noble, L. D. , et al, "SEFOR Core I — Test Results ro 20 MW, " GEAP-13702,
April 1971.
6. Noble, L. D, , KiiEsmaul, G., Derby, S. L., "}>:DI •r? :v-ni. .1 Program Results
in SEl-\ri< Core IT," GEAP-J3838, June 1972.
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32
7. "Standard Method of Test for Atom Percent Fission ^n !^--nium
an-I Plutonium Fuel (13d-148 ^othcd)," ;\:FTX Uc---. --. .•?.?.'-r*-,
General Test Methods, ASTM Standards, Pa: t 30, '•'
8, Cohen, K. P., Greebler, P., Horst, K. M., Wolfe, B. , .'he Southwest
Experimental Fast Oxide Reactor," VIII Nuclear Congr^.,.v., Rome, Italy,
June 17 - 20, 1963.
9. "SEFOR Preliminary Safeguards Summary Report," submitted to the Atomic
Energy Commission on October 16, 1964, and Supplements 1, 2, 3 and 4.
10. "Southwest Experimental Fast Oxide Reactor Plant Operating Report,"
First Quarterly, May 1, 1969 through July 31, 1969.
11. "Southwest Experimental Fast Oxide Reactor Plant Operating Report,"
Second Quarterly, August 1, 1969 through October 31, 1969.
12. "Southwest Experimental Fast Oxide Reactor Plant Operating Report,"
Third Quarterly, November 1, 1969 through January 31, 1970.
13. "Southwest Experimental Fast Oxide Reactor Plant Operating Report,"
Fourth Quarterly, February 1 through April 30, 1970.
14. "Southwest Experimental Fast Oxide Reactor Plant Operating Report,"
Fifth Quarterly, May 1 through July 31, 1970.
15. "Southwest Experimental Fast Oxide Reactor Plant Operating Report,"
Sixth Quarterly, August 1, 1970 through October 31, 1970.
16. "Southwest Experimental Fast Oxide Reactor Plant Operating Report,"
Seventh Quarterly, November 1, 1970 through January 31, 1971.
17. "Southwest Experimental Fast Oxide Reactor Plant Operating Report',1
Eighth Quarterly, February 1, 1971 through April 30, 1971.
18. "Southwest Experimental Fast Oxide Reactor Plant Operating Report,"
Ninth Quarterly, May 1, 1971 through July 31, 1971.
19. "Southwest Experimental Fast Oxide Reactor P.lau'c Operating Report,"
Tenth Quarterly, August 1, 1971 through October 31, 1971.
20. "Southwest Experimental Fast Oxide Reactcv K1 ant Operating Report,1'
Eleventh Quarterly, November 1, 1971 th.--ov.-jh January 31, 1972.
21. Regimbal, J. J., et al., "Fuel Failure DC-LCjtion Capability at SEFOR,
Trans. Am. Nucl. Soc. 14, p. 69, June 1, ]':"/]..
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III. NATIONAL INCENTIVES FDR USK OF PUJTONIT1:! ?•',
Any national solution to our energy supply problems over the next few
decades must include the expanding use of nuclear energy. Unless nuclear
power is fully utilized, it is questionable whether we can meet our
national energy needs without major degradation in our living standards
and painful social and economic dislocations. Without nuclear power,
there is no hope of coming close to national energy self-sufficiency.
The use of nuclear energy results in the production of plutonium which
is a valuable commodity and at the same time, a potentially hazardous
material which must be carefully managed. We have indicated previously
that several decades of experience have shown that plutonium can be
managed in accordance with AEC regulations so as to result in no effect
on the public. Indeed, the use of this plutonium as recycle fuel in
thermal reactors and ultimately in fast reactors will have significant
overall benefits to the welfare of the public.
By the end of the next decade, operation of our nuclear plants will have
produced over 500 tons of fissile plutonium. Use of this material in the
form of mixed oxide fuel in present light water reactors will save the
public over five billion dollars in cost of electricity. Perhaps more
importantly, use of this plutonium in lieu of oil would save over ten
billion barrels of oil and in excess of 100 billion dollars in foreign
exchange .
In the longer term, plutonium used in fast brt.-eJoc reactors can provide
a low-cost energy supply for this nation and) '_h<2 world for the indefinite
future. In the follov/ing discussion, the benefits of p] utonium use in
fast breeders are described in financial <-.-•-•--)<;. This rnalysis may
significantly understate the case, since- wJ ,. ~.\y.\\. th? f.>:t breeder in
the next century, the nation may be faced viti; energy needs which
cannot be satisfied in any other acceptable ::,.n^';r.
in. MATio];sAL__jr:cr;JTivF.s FOR USE OF FAST EKr:7";:i :; :.::: ; :
In addressing factors involved in cost -"• • i'1 > \~ -•*>-•'•-• .- • for the use of
}<]uto;iium, t!'> -\-Jioral rice; trie Co;ap^ , . . r;---:-* _ L'cjpdtcd _.r -<
study to evaluate the incentives for t'l'e t"p:.-t v>rccxV.r reactor, which use:-
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Plutonium as its principal fuel. General Electric believes that the n^e
of breeder would result in lower power co-Ls, j --^ - ".:•!'.-.•-..- • :.^ . •• ,
and substantial assistance toward achieving the naLio1 -1 goal of energy
self-sufficiency.
This in-depth economic' study was initiated jointly several months ago
by Commonwealth Edison and General Electric. Commonwealth Edison engaged
the services of an economist from Harvard University and an experienced
consulting engineer from the uranium mining industry.
For the study, a reference case was chosen on the basis of the best
current projections for both the capital costs of a breeder reactor
and the availability of uranium ore. An accurate means of comparing
future benefits against development costs was also developed. This
reference case indicated that there will be a 157 billion-dollar benefit
through the year 2050 from the breeder, measured in 1974 dollars (dis-
counted from an actual total benefit of 3,8 trillion dollars).
These savings come mainly from uranium utilization, since the breeder
converts the very abundant U-238 to usable plutoniuin fuel. The importance
of using this U-238 in the achievement of energy self-sufficiency must
also be considered, since projections show domestic high-grade uranium
ores being depleted about the year 2000. After this, the United States
would be forced to exploit very low-grade uranium shales, with an energy
content that is no more than coal.
The critical projections input to this study wcs also modified in a sensi-
tivity analysis in order to determine hov: sensitive these incentives for
the breeder may be to varying future conditions. For example, analyses
were run based upon assumptions that th^ currently estimated availability
of uranium ore was doubled, the capital c,xr.L c '>. breeders raised fror.i 1-1/4
to 2-1/2 times thc.t of light water ree.:- .• - .:r- the- c1 cc'trical load growth
rate was reduced from six to four perceir;, jC-r year. All cases slill
resulted in many tens of billions of dollc > L- saved as a result-of use
of the breeder.
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In addition to economic incentives, there are environmental reasons for
choosing fast breeder reactors as a future source of energy,* as with all
nuclear reactors, breeder reactors can operate with essentially no atmos-
pheric pollution. Moreover, there will be no need to mine new breeder
fuel for many decades and only minor amounts will be required after that,
Conversely, without the breeder, both the coal and uranium mining
industries will have to increase to many times their present sizes, much
of it involving highly disruptive strip mining.
* Gibson. :•. 3., "The l.iauJd Mof.nl Kc>sr ?•"-:-•., •- : •" •' c r,'' Handbook ci ilr.-•?<.;-,
Tvj'jhi.o.Loj', , McxJraw-Jij 1.1 Co. , (to \ .- TJU :I: : ,1) .
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Dr. Mills: Thank you very much, Dr. Wolfe.
An initial question: In the experience of General Electric, how do
you define "as-low-as-practical" in your use?
Dr. Wolfe: I am not sure, Dr. Mills, that there is indeed a
definition of "as-low-as-practical." I think that is one of the
difficulties the nuclear industry has in designing nuclear facilities
in general.
One looks at the technology available and designs nuclear plants and
new processing plants so that he gets as close to zero release of every-
thing as he can.
But "as-low-as-practical" of course depends upon the state of the
art at the particular time; if one develops, for example, a new instru-
ment to measure radioactivity it now becomes practical to take other
measures.
One of the problems we have in nuclear plants is that the release
in terms of ambient levels at least is so low that one cannot measure the
release around nuclear plants.
One of the other problems we have is that as new techniques are
developed, it then does become possible to get lower and lower levels
measured, which sometimes requires backfitting, which we believe in many
cases may cause an increase of cost to the consumer without any real
benefit.
Dr. Mills: I take it, what you are saying from your own experience,
limiting the "as-low-as-practical" concept to give control technology to
reduce the level of emission may not be sufficient if one looks at the
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practicality of the measurement in the environment?
Dr. Wolfe: No. I think our feeling is that "as-low-as-practical"
is to produce levels of radioactive emissions to the environmental picture
very low compared to any sensible standard relative to public health.
Our concern with "as-low-as-practical" is its a nebulous concept.
I am not able to define it very well for.you, because it is nebulous. We
think it implies to the public a lack of knowledge which the public might
interpret as meaning there is an unknown hazard which might affect them.
We think also that the "as-low-as-practical" philosophy may be
leading to increase in plant costs and, thus to cost to the consumer
which really is not transferrable to any benefits they receive from per-
haps minor deductions from effluents which may become practicable at the
time.
I might add that this is not a unanimous view. I had breakfast with
Mr. Parker who, in fact, does support the "as-low-as-practical" philo-
sophy. I think it is a generally poor philosophy for an industry to
follow.
I think no other industry follows it. I think we should understand
where the threshold, the cost-benefit level, is reasonable in terms of
providing benefit to the public relative to the risk. We should then
set quantitative standards significantly below that.
1 think the nuclear industry would agree with almost any reasonable
standard that would be set.
Dr. Mils: Dr. Taylor?
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L)r. Taylor: I have a comment. The big difficulty with this
discussion of "as-low-as-practical" centers about the fact that the gov-
ernment has tried to quantitate the concept "as-low-as-practical."
If you read all the discussions of the NCRP and ICRP, you will find
this was not supposed to be quantitated. It is good advice, generally;
the numbers that are set by these bodies and others are believed to be
numbers that are acceptably safe.
On the other hand, one should always use good judgment on improving
on his protection practices, if he can. But you should not try to tie
numbers to this.
You cannot put a numerical value on "as-low-as-practical." As soon
as you do that, you have a new set of standards.
Dr. Mills: Dr. First, do you have any questions or comments?
Dr. First: I would like to echo what Dr. Taylor has just said, and
also to point out, although, Dr. Wolfe, you have said that no other
industry adheres to this practice, I think this is incorrect in that for
many, many years, standards for occupational health have always included
the provision that one must not exceed the standard, but at the same time,
should expose the worker to no more of the mentioned substance than is
practical.
I think this is a reasonable way to handle it. It is not unique for
your industry.
I did, however, want to ask you a question on a statement on page 5
of your testimony. It says:
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"We should like to emphasize that meaningful standards on ambient
concentrations of transuranium elements should be consistent with design
and operating requirements for nuclear facility effluent control and
waste management."
Do I interpret that to mean the standard should follow with the best
practice, rather than the best practice should try to meet the standards?
Dr. Wolfe: No. I think the statement is meant to be much less
subtle than that. It really is meant to emphasize that a standard that
the EPA comes out with on ambient levels should, in fact, be consistent
with the requirements of the AEG or successor organizations that they
placed on nuclear plants, that a meaningful standard on ambient levels
should be reflected in AEC or NCRP requirements.
On the effluents from plants, the plant designer or plant operator
should not be faced with perhaps inconsistent requirements.
With respect to your other comment, I want to make it clear, I do
not think anyone in the nuclear industry suggests that one should not
take reasonable measures whenever he can that would reduce effluents,
even though he had already been well below the regulatory standards or
regulatory requirements.
I do not think that there was any argument that one should use
prudence in the same way as I take it the occupational hazard situation
you are suggesting, that one should meet the standard but at the same
time he should take all reasonable measures to further protect workers.
I do not think there is any inconsistency there with what I said.
On the other hand, I think that if you look at occupational standards
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40
rules, you do set standards and people are measured by those standards.
I do not know that they are really measured by then going in and seeing
how far below the standards they reach, which is the situation from a
regulatory standpoint in the nuclear energy business.
Dr. Mills: Dr. Radford?
Dr. Radford: Dr. Wolfe, just for the record, I would like to say
that I agree with you completely about the "as low as practicable"
concept as it applies to trying to engineer control. I also do not think
that the "stay as low as practicable" really helps the public very much
in terms of deciding whether or not there are significant risks.
I would like now to ask you a few questions.
You mentioned that General Electric has now had about 25 years of
experience in handling plutonium. Is that right?
Dr. Wolfe: We have had about 15 years in our commercial facility
in San Jose. Of course, we were the contractor for Hanford prior to that,
starting in the early 1940's.
Dr. Radford: In your current operations, you stated you had had
this experience and that you had had no problems, or words to that effect?
Dr. Wolfe: That is correct.
Dr. Radford: How did you determine whether you had problems or not?
What sort of programs do you have within the plant to determine this?
Dr. Wolfe: In the written testimony, Dr. Radford, we describe a
number of measures that we take at Vallecitos in the laboratory.
We, of course, monitor the effluents coming out of the plant. The
statement I made in the paper was the plutonium was controlled at all
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41
times to minimize release to the environment. Of course, there are
measurements that indicate that less than three microcuries of alpha
emitting materials have been released per year to the environment from a
stack of plutonium, in the material that goes out through the stack.
Essentially, all these releases have been the naturally occurring
daughter products of uranium, not transuranium elements. So these are
insignificant to illustrate the effectiveness of the site.
We take, of course, periodic and regular site surveys. I might also
add that at the site we do have some very sophisticated measuring techni-
ques that are not generally used industrially.
We use these to further examine plutonium and transuranium elements.
So that is the basis.
Dr. Radford: Then, you say you have not released more than x micro-
curies of alpha activities from the stack. Is that determined by actual
measurements?
Ur. Wolfe: Yes, measurements.
Dr. Radford: At the stack?
Dr. Wolfe: Yes.
Dr. Radford: I see.
Dr. Wolfe: We, of course, monitor our personnel, looking for
internal deposition of plutonium. Of course, the measuring techniques for
this are very difficult, because you are trying to measure low levels of
plutonium against a background.
We estimate that about 350 man-years of work has been directly
connected with plutonium at Vallecitos. We have had only one reportable
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42
occurrence involving plutonium, and that consisted of a plastic bag being
torn from a block during maintenance operation, and contamination was
confined to that room.
We essentially have had no measurable effects on any of the personnel
working at Vallecitos.
Dr. Radford: Do all the workers who are working with plutonium get
called for counting periodically?
Dr. Wolfe: Right.
Dr. Radford: The experience is that they have been close to back-
ground?
Dr. Wolfe: They have been close to background. This is a case where
it is very difficult to measure. I will tell you that we have had one
case where a new measuring technique came up and gave us a little bit of
concern.
We then took these people and sent them to Los Alamos, where they had
more sophisticated information for measuring devices. It turned out that
the original measurements had been incorrect.
It is very difficult to make these measurements, as you know.
Dr. Radford: A question on the occupational part.
How many workers overall have been exposed to plutonium, or at least
work with plutonium, during your 15 years?
Dr. Wolfe: The estimate I have here is about 350 man-years of work
has been directly connected with plutonium.
The plutonium laboratory employs about 40 people. That has been
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43
going on for nine or ten years.
Dr. Radford: This is essentially a research operation.
Dr. Wolfe: That is correct.
Dr. Radford: I see. Would you have any opinion about the ability of
other facilities that are more commercially oriented towards handling
plutonium?
Dr. Wolfe: I am not prepared to talk about existing facilities
other than to know that the government facilities have handled plutonium
in larger quantities than, of course, we have at Vallecitos.
I do feel that there is no reason why properly designed and operated
facilities could not have the same good experience as we had in our
smaller facilities at Vallecitos, or that the government has had in their
operation of facilities.
Mr. Trumbull: I might also note that other commercial facilities are
subject to the same requirements that we are at Vallecitos, such as those
that are listed on pages 2 and 3 of the written testimony. There are six
different types of requirements that all commercial facilities are
directed to meet.
Dr. Radford: That is the thrust of my question. Do you believe
that, in fact, these commercial facilities have adhered in all instances
to federal regulations or state regulations as they apply?
Dr. Wolfe: Well, I read the papers, the way everyone else does.
For example, to be very candid, I am just not prepared to discuss the
recent Kerr-McGee publicity.
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I just have no idea whether there is anything to it or not. I think
the fact is that these facilities can be designed and operated safely, in
accordance with government regulations.
Experience indicates that in fact we have. I see no reason why they
cannot be and should not be. I think that handling plutonium requires that
one exercise diligence and care.
I think the nuclear industry in general has exercised that care in
the past.
Dr. Radford: Now specifically, you are aware that the Atomic Energy
Commission required the Nuclear Fuel Service plant shut down?
Dr. Wolfe: Yes.
Dr. Radford: I am not saying over what issue, but certainly the
issue being that there were breaches of their required containment.
The General Electric Company was to embark on the fuel reprocessing
business but are not now planning to, or are they?
Dr. Wolfe: We have a plant at Morris, which we are presently looking
at in terms of trying to decide whether we should modify it and operate
it in the future as a reprocessing plant or whether, in fact, the
design deficiencies on that plant which were turned up during the pre-
operational phases before there was any radioactive material in the plant,
whether those design deficiencies are such that, in fact, it would not be
a sound commercial venture to go ahead with that plant.
I cannot answer you as to what the ultimate disposition of that plant
will be. I will, if you will allow me, make the following statement about
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45
that plant.
The technology that we used on that plant resulted in essentially
no effluent release to the environment, the exception to that being some
krypton and some tritium, a small amount that was released through the
stack.
There was essentially no plutonium that was released. There were no
fission products. They were all solidified, kept on site, stored, and
would have been shipped to AEC facilities in accordance with regula-
tions.
We had a problem at Morris which involved just an industrial process
of handling solid powders, which we encountered when we operated the
plant with natural uranium. It had nothing to do with radioactive fuel.
We believe that the technology that we used at Morris in the fuel
recovery plant would be applicable to another facility which handles the
product in a different way.
In fact, that plant would have operated as a plant based on the same
principle and will operate with essentially no effluent release and no ill
effects to the public.
Dr. Radford: That is all supposition, because the plant has never
operated?
Dr. Wolfe: That is correct.
Dr. Radford: Technology has not yet operated, so that in terms of
the record we have at the present time, we cannot really base it on that?
Dr. Wolfe: You certainly cannot use the Midwest Fuel Recovery Plant
as an example of an operating plant.
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Dr. Radford: Just a couple of other questions here, Dr. Wolfe.
You stated in the cost-benefits study which General Electric
commissioned, some aspects of the problem of, say, the current light-water
technology, one of them being, after the year 2000, the exploitation of
base technology would require perhaps high energy as well as foreign
exchange costs in obtaining adequate fuel.
Is that essentially correct?
Dr. Wolfe: It is basically correct. What we did was we used AEG
estimates of available uranium. The AEG estimates require there is about
two and a half million tons of uranium in concentrations above, say, a
hundred parts of a million.
Thereafter, one would have to go to things like the Tennessee shales
for concentrations below 80 parts. This would require huge mining efforts
and might have environmental effects that would make it highly under-
sirable.
Dr. Radford: So that basically your point, I believe, was that we
are really here talking about a breeder reactor program.
In other words, as far as future developments are concerned, it is
essentially a breeder based program, correct?
Dr. Wolfe: I think when you are talking about the end of the
century, hopefully we are talking about breeder programs.
In the interium period, I think plutonium recycle would have benefits
to the nation in terms of augmenting the uranium supply, providing time
for the breeder to come on.
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In that period, we do, as I say, have some foreign exchange problem.
Dr. Radford: One further question, with regard to the number of
millions of barrels of oil which are approximately consumed nowadays.
In terms of foreign exchange improvements, I believe it has been
stated both by federal panels and others that if we have automobiles right
today that got 20 miles to a gallon, we could, with no change in the
numbers of automobiles operating, immediately eliminate all of our foreign
exchange losses.
Do you agree with that?
Dr. Wolfe: I would like to answer that question in a more general
sense.
I think there are a lot of things that the nation could do to take
care of its future energy supply. In principle, some of them might be
more desirable forms of energy.
Nuclear energy, I think, is beneficial to the nation. It does have
potential problems connected with it. It does have a problem of the
ultimate waste.
So there are a number of alternates that one could talk about to
take care of the problem in a different way.
Let me answer your question on automobiles, because I think that is a
short range problem.
The fact of the matter is that the world is going to run out of oil
and fossil fuels, possibly by the end of the century. So the world is
going to be faced with surviving on a ever less amount of fossil fuels,
towards the end of the century. In this country, we have already — Now,
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you can look at alternates. The one I would like to mention is solar
power.
This is a wonderful source of power which, in principle, if you
listen to the advocates, has no problems. I think the problem with solar
power-you know, several years ago when people were moving to California,
Nevada put up a billboard on the boundary which said, "There is no
California."
The fact of the matter is there is no solar energy. Solar energy is
a dream. I think it should be worked on. I think we ought to go after it.
But the fact of the matter is, nobody in this room today can describe to
me a solar energy plant, what it looks like.
Furthermore, the idea that the solar energy plant will not have
hazards is, in my opinion, fallacious. Depending upon how you approach
it, you can have very hazardous conditions. If you go out to space and
you beam the power to the earth, slight malfunctions in the beam could
wipe out large areas of the country.
If you do it on land, you are talking about large areas of use which
might have, for instance, climatic effects at least in a local sense. I
do not know that it will, but at least these are things that you have to
look out for.
A thousand megawatts solar plant would require about 40 square miles
of area. If you used today's solar cells, the average household electri-
city bill would be about $50,000 a month.
If you took the 40 square miles and found out how to construct that
plant so that total cost of construction in terms of solar cells,
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49
supporting structures and all the other electrical needs such as battery
storage, if that total construction could be brought down to the cost of
an industrial building on a square foot basis, you would be talking about
an electricity bill of about $5,000 a month in today's dollars.
That is not to say we should not go after solar power, but the fact
is, it is not here today. As I said, no one can tell me what it looks
like today.
We do know how to make nuclear plants. We have got breeder reactors.
They are operating. It seems to me that we ought to follow the leads and
take advantage of what we have.
At the very least, perhaps nuclear power in the breeder will provide
time to develop more desirable energy sources if, in fact, it can be
developed. I hope they will be.
Does that answer your question, in general, about the automobile?
Dr. Radford: More than answers.
Dr. Mills: Dr. Garner?
Dr. Garner: I am going to get Dr. Radford to change places with me,
because he stole my two questions.
Let me pick up one of these points.
If I were a member of the public, I would be extremely skeptical of
some of the things which you said. After all, these people can read.
They read about leakages of plutonium from commercial plants. They
have heard about the recent Oklahoma incident. True, the plant is not a
commercial plutonium separation plant, but in the last quarter report, we
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50
read of the release per year over the last two years or so of curium, not
plutonlum.
I think we are entitled to be a little skeptical about the efficiency
of present hold up systems and so forth for plutonium in a plant. This
is not to decry the fact that G.E.C. has been very successful. I am
merely saying that given the best of technology, the opportunity is
there for plutonium and other materials to be released to the environment.
We have to recognize this. Now, having said that, I want to go to
another point, because you said you are not going to comment on this.
I was going to ask if you would comment on it. I entirely agree with
you about some of the things you said about solar energy. It is not with
us yet, and is nowhere near us yet.
I do not agree with your statement about the effects of microwaves
when solar energy comes. Perhaps the, we will have a hearing like this
to discuss it.
The fact of the matter is, and I would like to bring this out right
early in these proceedings, we have two alternative sources of energy, two
practical sources of energy: fossil fuel that we are all familiar with,
and nuclear energy which we are on the verge of.
Unfortunately, as in most cases, we are holding hearings on
basically the health risks, I think is what it comes down to, of one
particular form of energy production, that is nuclear energy production,
and one particular aspect of it.
We are considering this in total isolation from the risk from
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alternative sources. I think everybody has to understand that every
source of energy has its risks. Some of these risks are nowhere nearly
as well understood as the risks from plutonium and effluents from nuclear
power plants or fossil fuel plants.
All I am saying is that things that are going to come out of this
hearing, we have got to remember that what we hear has to be taken in the
whole picture of energy production.
Dr. Wolfe: I could not agree more with that last statement. Let me
just add one point to your comment, and Dr. Radford's, about releases from
nuclear plants.
Plainly, I think you have to expect that on some occasions, things
are not going to work out exactly as you had hoped. I think regulations
and experience have shown that you can design good plants, can operate
them, and that if you do, you can operate them well, and the risk to the
public is nil.
I think on the other hand, even if you look at potential releases and
past experience on accidents, and measure the benefits versus the risks,
you will find that even on that basis, the benefits far outweigh the risks,
I think.
That is the point to be made. For example, the fast breeder study
that looked at nuclear reactors tried to assess this also.
The gist of your comment is that it is not possible to do anything
perfectly. I guess I would have to agree with that. On the other hand,
I think the experience is that one can design and operate these plants
and the risk to the public is, in fact, negligible and less than the risk
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which they normally are willing to undertake in their normal living.
Dr. Mills: Do you have any more, John?
Dr. Garner: No.
Dr. Mills: Dr. Taylor?
Dr. Taylor: I notice in several places in your written statement,
you made reference to sound data, the need for more quantitative standards,
and more sound data, and so on.
You also made reference in several places to the fact that there is
time to develop sound data or otherwise.
I would like to ask your opinions about these two forms, but first
comment that as you may know, the National Council of Radiation Pro-
tection has under review ready for release, two reports on plutonium,
one dealing with the hot particle problem specifically and one with the
general problem.
I am not prepared to say what the final recommendations in these
reports will be except that they will say that there is no rush to do
anything at the present time, even though we may want to make some small
adjustments.
I would like to hear some more discussion about the question about
sound data, quantitative standards, if you care to.
Dr. Wolfe: Well, with respect to the time, as I just commented, I
think I have indicated in the testimony that the radioactivity from ambient
plutonium release is very low compared to what is naturally occurring,
which I think is the basis for the statement that there is time.
The concern that we have in the nuclear industry on the "sound"
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statement, to answer your question more directly, is that if we had a
quantitative standard which was "sound," the inference is that standard
would be long enduring, and would have data in back of it, to answer the
legitimate questions of concern of the public.
What we think would be perhaps worse than our present system of "as
low as practicable" would be a standard which was not sufficiently well
based, so that the standard would be periodically changed and then might
impact on very costly nuclear installations and practices, when, in fact,
it might not have to if we waited some time to allow for the accumulation
of necessary data.
I do not know if I have said what you were looking for, or not.
Dr. Taylor: I think you probably have said as much as you can on
that.
On page 3, you refer to .organ-man-rem dose. I am not quite sure what
you are talking about when you talk about organ-man-rem dose. In any case,
if you are talking about man-rem doses, to what extent do you include in
there the necessary dose rate and dose factors when you try to total up
man-rem?
Dr. Wolfe: The data presented here comes from an EPA report which is
referenced. What the engineer did who developed these numbers was to take
the EPA estimates, multiply it by the population. These were estimated
doses to the lung. We multiplied it by the population and came up then
with that organ-man-rem number.
It is just a plain multiplication, nothing sophisticated.
Dr. Mills: As you know, there is no dose rate taken into account
here.
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Dr. Taylor: That is what I wanted to bring out.
Dr. Mills: There are no more questions.
Dr. Wolfe, we thank you very much for giving your opinions today,
Dr. Wolfe: I am glad for the opportunity.
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Dr. Mills: The next on the schedule is a panel from the Atomic
Industrial Forum.
Is Mr. Deuster in the audience? Dr. Sagan, Dr. Goldman, and
Dr. Parker?
Mr. Deuster: Dr. Mills, gentlemen of the panel, ladies and
gentlemen, my name is Ralph W. Deuster. I am chairman of the Atomic
Industrial Forum's Nuclear Fuel Cycle Services Committee and president
of Nuclear Fuel Services, Inc., a subsidiary of Getty Oil.
Before I go into my prepared testimony, I would like to make one
comment to Dr. Radford's previous statement that Nuclear Fuel Service
at West Valley plant was shut down.
We voluntarily closed the plant because of no business in repro-
cessing at the time and because of our plans to make modifications which
require now the pursuit of a construction permit.
We still have our license and are paying our annual fees. That
is the official record on our facility.
The Forum is a not-for-profit-membership association incorporated
in the state of New York. It comprises some 625 corporate and institu-
tional members of the United States, as well as in some 25 countries,
all of which share a common interest in the development and application
of atomic energy for peaceful purposes.
Because of the diversity of its members which include facilities,
manufacturing companies, universities, labor unions, professional firms,
financial institutions, government organizations, and other profit and
non-profit entities, the Forum as a matter of policy does not take
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independent positions on matters pending before the Congress or pend-
ing before other public interest and quasi-judicial bodies, such as
this Board.
However, whenever possible, we do make an effort to identify
relevant technical and legal policy considerations and provide a
mechanism for determining and articulating the views of our various
members.
Accompanying me today are Dr. Leonard Sagan of the Palo Alto
Medical Clinic; Dr. Marvin Goldman of the University of California at
Davis, California; Mr. Herbert Parker, a consultant from Richmond,
Washington; Mr. Emmanuel Gordon, a nuclear fuel and financial projects
manager of the Forum; Mr. Marvin Fertell, environmental projects
manager of the Forum; and Mr. Harvey Price, Washington counsel of the
Forum.
These people are all here under Forum sponsorship in addition to
myself, you will hear from Messrs. Sagan, Goldman and Parker.
Dr. Sagan will speak on the criteria for limit setting. Dr. Goldman
will speak on the empirical approach to plutonium toxicity. Mr. Parker
will speak on plutonium limits.
Each of these persons will express his independent viewpoint.
We are pleased to have this opportunity to participate in this
hearing which was called to evaluate the impact on the environment of
plutonium and other transuranic elements.
We agree with the approach taken by the AEC that this study be
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made prior to attempting to set new guidelines or standards for these
materials.
Speaking as a fuel cycle representative whose business is concerned
with plutonium and the transuranics, I believe that the immense body of
work done by the AEG and others in prior years and currently has pro-
vided regulations and guidelines for the fuel cycle industry to protect
the public adequately.
We believe the record so shows this. We therefore recommend that
EPA give serious consideration to accepting the current limits and
guidelines as established by the AEC as adequately protecting the public.
I am sure you are all aware that plutonium is a natural product of
power reactor operations. In fact, in current water reactors, the plu-
tonium generated in the reactor produces a significant portion of the
energy output.
U. S. reactors use enriched uranium fuel, and reactor operators
have always planned to reprocess spent fuel and to recycle the uranium
and the plutonium. For economic reasons, we strongly recommend that in
your considerations, you give great weight to the importance of recy-
cling plutonium in light-water reactors.
Projected fuel cycle economics are as favorable as they are, partly
because of the anticipated use of recycled plutonium. Not using plu—
tonium will result in the need for more U. S. enrichment capacity.
There is more involved, however, than not utilizing plutonium.
It is highly likely that without the economic benefits derived
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from the recycle of plutonium, there would not be sufficient incentive
to operate reprocessing plants, and therefore, enriched uranium would
not be recovered from spent fuel.
Together with the plutonium, this would increase the need for
yellow cake, uranium raw material, by about 20% annually, and for sep-
ative work from the enrichment plants by approximately equivalent
amounts.
Put another way, failure to use plutonium then would lead to
significant fuel cost increases which must be borne by the general
public.
Also, failure to use plutonium which implies neither reprocessing
nor recycle would bring the breeder program to an end and would fore-
close on an energy course already in hand, having an energy equivalence
greater than known coal, gas and oil reserves combined.
The Nuclear Fuel Cycle Services Committee, of which I am chairman,
recently submitted two sets of comments to the Secretary of the AEC,
both of which bear on the subject of this hearing.
They have been submitted to Dr. Burley. They are comments on the
AEC's draft environmental impact statement, entitled "Management of
Commercial High Level and Transuranium Contaminated Radioactive Wastes"
known as WASH 1539, and the proposed amendments to 10 CFR and 10 CFR 50
concerning transuranium waste disposal.
These were submitted on October 25, 1974.
We also submitted comments on the draft, "Generic Environmental
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Statement on the Use of Plutonium and Mixed Oxide Fuel in Light-Water
Reactors" known as WASH 1327, and also as GESMO.
Those comments were submitted on October 28, 1974. The GESMO
deals comprehensively with plutonium and its application as a mixed
oxide fuel in light-water reactor fuel cycle. We request that you
include these two statements in this hearing record and in your sub-
sequent considerations.
We also hope that the EPA would consider, when setting standards
on plutonium and other transuranium elements that such standards be
based at levels that evolve from cost-benefit analyses.
The imposition of unnecessarily restrictive levels will have the
inevitable consequence of placing undue burdens both financially and
operationally on nuclear reactors and the supporting industry, which
burden would ultimately fall on 'the American people and the national
economy.
This concludes my statement.
For the remainder of the presentation, you will hear from Messrs.
Sagan, Goldman and Parker, with Dr. Sagan being our next speaker.
Thank you for this opportunity to express our views.
Dr. Mills: Thank you, Mr. Deuster.
I would suggest that we go through the remarks and then entertain
questions.
Dr. Sagan: My name is Leonard Sagan. I am a physician from
Calfornia. I have an interest in human radiation effects.
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I have worked in Japan among survivors of the atomic bombing. I
have an interest in government regulations on radiation exposures. I
have worked for the Atomic Energy Commission for a short period of time.
I have done some studies on health effects associated with nuclear
power plants and also some studies of health effects associated with
coal burning power plants.
In view of that experience, I would like to make some comments
about how government goes about regulating the emissions and will make
a proposal for an emission tax for plutonium.
If you will bear with me for just a few minutes, I would like to
express just a personal view about how we as a society appear to approach
societal problems, and I would like to emphasize that these are purely
my own views. They do not reflect the views of the Forum or perhaps of
anybody else.
If one reviews the past few years' experience, one sees a consistent
pattern of crises generated or at least fostered by the media. Typi-
cally, the crisis is often followed by hasty and sometimes ill-considered
government reactions.
We first had an environmental crisis, followed by an energy crisis.
Now we seem to have a food crisis, or I am told that some people think
we have a plutonium crisis.
By that I do not mean to suggest that in these examples that I
have mentioned there are not genuine problems. On the contrary, I am
certain that each of these I have mentioned does contain a problem.
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But what I would deny is that each of these is a crisis that
suddenly appears in the first year that it is brought to public
attention. Rather, each of these, in my view, is a result of longterm
historical forces. Each of these announcements of a crisis is typi-
cally followed by the hectic convening of experts who fly to Washington
meetings.
This is followed shortly by the promulgation of new regulations
or legislation, much of which is hastily conceived and in the long
run, in my opinion, counterproductive to the public welfare.
One is also likely to see a proliferation of lapel buttons and
bumper stickers urging simplistic and equally ill conceived solutions.
I bring this up and reflect on this this morning because I want
to express my hope that EPA is not going to follow such a course with
respect to plutonium. In all candor, however, I must admit that there
are aspects of this meeting that give me some misgivings and about which
I would like to comment.
For example, this is announced as a public hearing "to determine
the adequacy of current guidelines for plutonium," I am quoting from
the Federal Register," and the other transuranic elements in develop-
ing any new standards if deemed necessary."
If that were the objective, then why a hearing panel of scientists?
Since standards require totals of the social and political nature, why
should there not be economists, social scientists, union and management
representatives, as well as representatives of all segments of society?
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Questions surrounding the use of plutonium could go to the heart
of the kind of society that we want, and everyone, not only radio-
biologists, should have a voice in that decision, in my view.
On the other hand, the Federal Register announcement to this
meeting, in explaining the details of the meeting, suggests that the
agenda is to be highly technical. We are asked, for instance, to
supply the panel with information such as theoretical models developed
to predict transport to the ecosystem, highly technical material.
If the intent is to gather technical information from which
standards should be derived, then why are we having a public hearing?
Is a public hearing, I would ask, the appropriate forum in which to
gather and appraise scientific information?
I would have preferred an approach such as that chosen by the
BEIR Committee as far more appropriate for that purpose, the gather-
ing of scientific information.
I would like to add, parenthetically, since I have this opportunity,
to offer the complaint that the BEIR report was never circulated for
public comment.
In my view, we do not have a plutonium crisis. I will not go over
the reasons for that opinion in detail. Some have already been mentioned
by Dr. Rowe this morning. For the past 30 years or so, there has been
extensive experimentation with plutonium.
So far, no cancer has as yet been attributed to plutonium exposure.
I would echo a comment made earlier that we do probably have better data
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with which to understand the toxicity of plutonium than we do for the
vast majority of other carcinogenic agents.
I then have in this written testimony a good deal of material about
plutonium toxicity, but I see there are so many other people on this
program, so much more expert than I, that I am going to skip over that
and get to the material that I have a greater interest in.
Whereas, as I have just said, I do not consider there is any
particular urgency regarding the development of new plutonium standards,
I do feel that there is an urgent need for broad consideration of the
nature of the standards themselves.
Over the past several years, we have witnessed widespread
disagreement about the nature and function of standards.
There is, first all, the argument whether standards should be
based on health effects or on the basis of economic and technological
feasibilities. We have heard some allusion to that conflict in the
questionning already this morning.
There has also been dispute regarding whether or not health effects
can be demonstrated at the exposure levels permitted by standards.
All of you, I am certain, are aware of the present conflict with
respect to auto emission standards and whether they are too stringent
or should be relaxed. Frequently, the data, as in that case, simply
is not adequate to resolve these conflicts.
In my opinion, there are a number of other problems associated
with inflexible exposure standards. Number one, standards are in effect
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permissible levels of pollution.
They invite engineers, operators, to pollute to whatever level is
allowed. There are no economic incentives to reduce the emissions below
permissible levels. There may be moral incentives, as was pointed out
by Dr. First, but in our society, moral compunctions are not nearly so
effective as economic.
There is little incentive to create or purchase new pollution
control technology, nor is there the flexibility to incorporate newer
knowledge of toxicity which might modify standards in either direction.
Thirdly, standards are arbitrary. The argument to the linear dose
response curve to attack any standard as arbitrary, as insensitive to
health effects. Agencies have characteristically great difficulty in
justifying and defending standards which are not based on demonstrated
health effects.
The ability to achieve risk estimates for radiation exposure allows
a new approach, I believe, to standard setting. My own preference, as
I indicated in the very beginning, is for a tax emissions.
I would like to spend a few moments discussing how I see that
with respect to plutionium.
A tax emissions is not by any means my own creation. It is a
proposal that has been made frequently and recently by a number of
economists.
An emission tax avoids many of the problems already mentioned
above and is compatible with the currently accepted concept of a linear
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relationship in dose response. I would foresee that a tax should be
linear.
A tax would be assessed for even the smallest of emissions and so
would provide an incentive for reduction of even these smallest emissions.
A tax would not be incompatible with standards, however, as a maximum.
However, if one wished, such a tax might work in the following way:
Some estimate would be established of the relationship between a curie
of release and its ultimate health effect.
Our legal apparatus has long experience in assigning monitary
values for health effects. This experience could be exploited to
establish the monitary value associated with the health effects of
released radionuclides which would incorporate knowledge of environ-
mental transport to the human metabolism and carcinogenesis.
In this way, the emission tax would satisfy the requirement that
environmental control be related to health needs. Management in re-
sponse would make careful assessment of the cost of reducing emissions
and would optimize at the lowest level of emissions compatible with
currently available emission control equipment, thereby satisfying the
need for economic and technologic feasibility.
An emission tax is clearly experimental, both for government and
industry. The only example known to me is the example of its use in
controlling emissions into the Rhine River where it is said to have
been very effectively used.
I believe that plutonium is a particularly appropriate substance
from which to gain experience, if this need be, for an emission tax,
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since the sources for plutonium release will be very few.
Record keeping and surveillance will be rigid and releases easily
detected. My preference would be to compute an emissions tax, or call
it an emissions penalty if you like, on the resultant human exposure
rather than on the absolute quantity emitted.
For example, a tax would be considerably less in a sparsely
populated area than in a densely populated area. The effect, then,
would be to provide an economic incentive to locate such a facility
in remote areas.
I would also insist that the penalty apply to occupational as
well as to public exposure outside the facility.
There is another advantage to tax emissions that I should like to
mention briefly. As I have spoken to people about pollution and health
over the years, I have found there is a. widespread implicit assumption
that thresholds do exist, that through scientific investigation these
thresholds can be determined.
The public wants to know generally, whether it is air, food or
water, they want to know is it safe or not? The question implies a
threshold.
In my own opinion, such questions can rarely be answered with any
certainty or precision now or in the future.
An emissions tax emphasizes the absence of an easily definable
threshold level. Inflexible standards for environmental emissions
reinforce the common misconception regarding absolute levels of safety.
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In summary, then, I see no threat to the public health in current
use of plutonium that requires urgent regulatory intervention. I do
feel that the effect of widespread dissatisfaction with the use of
inflexible standards is such as to justify fundamental review of the
standard setting process as a means of controlling the environment.
In my opinion, the Environmental Protection Agency should give
serious thought to more flexible means of control, such as that offered
by an emissions tax. Such consideration should be a collaborative
effort with representatives of all sectors of society and not solely
the effort of scientists.
I believe the characteristics of plutonium production and toxicity
recommend it as an excellent starting point from which to organize this
new regulatory frontier.
Thank you.
Dr. Goldman: I am Marvin Goldman, Professor of Radiobiology at
the University of California. I have been involved in problems relating
to the biomedical effects of radionuclides in all of my scientific
career.
I would like to try and present a few comments today to put into
perspective some views that I have with respect to plutonium as a
radionuclide, and how it fits into our overall biomedical world, as
it were.
These are my own comments and do not represent necessarily the
views of anyone else here.
I feel that with the publicity and comments that keep cropping up
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with respect to plutonium, is it presumptuous for me to perhaps sit
back from it a few feet and see what we know about it and how it fits
into what we know about biomedical science and the effects of radiation,
from an empirical approach.
Is there something unique, is there some mystique or some violation
of the natural laws of physics, chemistry or biology intended to plu-
tonium that requires a special and separate consideration from that
which accompanied the evolution of our knowledge with regard to radio-
nuclides?
In summary, I do not believe this is so. As you all know, and I
suspect we will hear quite a bit of it in the next few days, there is
considerable discussion of the internal emitters. The scientists with
whom I associate usually categorize one another as lumpers or splitters.
I may try to lump today and in so doing, I may omit or condense
or perhaps compromise some of the technical information, but I think
it is important, perhaps, to get the overall pattern of information
into focus and then to evolve questions regarding the lack of specific
information and the applicability of existing information.
We live in a radioactive world. A lot comes from the soil which
has several disintegrations per minute in every gram on this planet.
Much of this is alpha activity from the decay of uranium and radium.
Therefore, there is no such thing in my view as zero.
We will start with that point. Plutonium is another alpha emitter.
It has about the same kind of energy as do these other natural radio-
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nuclides and we have found that plutonium has probably been present
in microscopic quantities in this planet since its formation.
We have more of it now, and that seems to be the crux of
consideration. It has a very long life, but so do radium and uranium,
and we know a lot about some of these other nuclides as well.
In nature, it is my opinion, that plutonium and the other trans-
uranium elements such as americium and curium appear to me, on the basis
of the information I have evaluated, and I certainly cannot say that I
have seen everything that has been printed or written about it, this is
my impression: It appears to me that it moves more slowly and less
efficiently and effectively than other elements in the surface of this
planet.
When it is very dilute and particulate, plutonium appears to age,
such that it forms a non-radioactive aggregate, particles which even
further slow down its movement and maybe enlarge the effective particle
size.
This may render an increasing fraction of surface plutonium, as
it were, that is, non respirable. Often it is the manufacture of plu-
tonium compounds that can get into the deep lung, that position problem,
that is of concern.
Thus, it would appear that with increasing time, whatever the
concentration or content of plutonium, based on some of the information
to which I had access, this appears to, in a sense, become diluted and
buries itself and becomes less and less environmentally available; as
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a quantitative observation which I think has some substantiation in
fact.
Now, the amount of plutonium that I think may be air borne
from soil deposition is characterized in many ways by a whole science
of atmospheric dynamics and solar chemistry in arriving at chemical
and physical factors, much of which I do not propose to tell you I am
an expert in, but which experts summarize a kind of ratio or factor or
resuspension ratio, which somehow relates to concentration in the air
to the concentration on the surface of that plutonium, and therefore,
gives a crude indication of the amount of the soil bound plutonium
that might be air borne.
These numbers have a variety of physical factors in them. Usually,
the ones I have seen are in terms of the microcuries of plutonium per
unit volume of air, to the microcuries on the surface of the soil below.
These ratios, in my view, are exceedingly small numbers.
It is something of the order, 1CT7 or 10~10 units of microcuries
per gram. Perhaps much of this is in the form of non-respirable aggre-
gates and that perhaps with increasing time, all other things being
equal, (and maybe we could generalize a bit) that fraction gets even
smaller and smaller.
The thing I have spent many an agonizing year and night recently
over has to do with the assessment of health consequences when the
factors in molecular event that relate to all of those things that
occur following the deposition of a packet of radiation in energy in
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the biological system, and the ultimate appearance of some deleterious
effects some time down the road.
These facts and details are necessary. They may never be available
to us. But that does not mean that we do not know something about the
toxicity of radio elements such as plutonium.
Although I understand some accidential exposures have occurred
from the literature that I have had available to me, I believe that no
health effects from plutonium exposures have been seen in man. Thus our
knowledge on plutonium health effects primarily is data based on animal
studies in laboratories.
Following the ingestion of plutonium, it is apparently not very
effectively or efficiently absorbed into the body relative to the
elements such as potassium or radium.
I estimate on the basis of the data I have reviewed that this
fraction absorbed might be of the order of 1/100,000 of that which is
ingested. Perhaps for elements in insoluble form, such as americium,
it might be 1/1,000, which is quite similar to natural radium uptake
percentages.
Following inhalation, acute exposures result in something of the
order of 1/5 of the inhaled deep lung fraction retained as what some
call an initial lung burden. I am sure you will hear from people far
more knowledgeable on that.
The toxic quality, when this amount is very large, as with any
radionuclides study in toxic effects, effects may become manifest in
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72
the case of the lung as cancerous. For plutonium, the empiric ratio
that I seem to be able to derive from experimental data that has been
published might suggest that it is about ten times worse than for
chronic exposure to x-rays, gamma rayss or beta particles emitting
radionuclides also deposited in the deep lung of experimental animals.
What I am trying to say is that the absorbed radiation dose ratios
of effects differ by about a factor of 10 over much of the body of
experimental data that we have. As the dose diminishes, it may be that
the ratio, the beta gamma type effect, also diminishes.
Now, as to the dose distribution from inhaled plutonium particulates,
all the animal studies that I know of in this country and abroad, most
of the ones abroad I think are not funded by the same agency that funds
the ones here, do seem to support a rather conservative assessment.
The more uniformly the radioactivity is distributed, whether it
be in lung or bone or liver or total body, the more effective that
given radiation dose is.
The more non-uniformly the particulates are, the less effective is
the burden in reducing the effects of concern.
In my view, plutonium is not uniquely or mysteriously toxic, but
it appears to follow fairly predictable and well studied radiobiologic
principles relative to a uniform x-ray or beta ray dose, plutonium
appears to be about ten times more effective in producing tumors in
experimental animals, with the absorbed radiation dose in rems used in
the comparison.
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73
Thus, without any specific knowledge of the sequence of events,
from alpha particle absorption to tumor appearance, one can use the
empiric observation in animal experiments to independently assess plu-
tonium toxicity, and by comparison with other radiation experience in
man can arrive at a realistic assessment of possible plutonium effects,
realizing of course, as in most biological experiments performed in
laboratories, precision and accuracy may have something to do with
factors of two or three of uncertainty, but not many orders of
magnitude.
In our laboratory, we have a sign that says, "The animal is always
right." Our job is to get the message that the experimental animal is
trying to tell us.
While all of our questions about plutonium are not yet answered,
the available information on plutonium toxicity derived over the last
30 years provides an impressive spectrum of important information.
You probably know more about the relative toxicity of plutonium
than for any other agent; in my opinion, the toxicity, following in-
corporation into the body, is in no way uniquely strange, or different.
It follows certain general radiobiologic generalizations.
The first of these is that the effects appear to depend upon
distribution of the radionuclides and its characteristic, whether it
is an alpha, beta or gamma emitter, whether the emitted radiation energy
is uniformly or non-uniformly distributed amongst the cells at risk.
Secondly, the dose rate for radionuclides is generally protracted
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rather than acute and Is continually changing rather than constant.
Thus, the dose rate relationship from internally deposited radio-
nuclides requires consideration not only of the total radiation absorbed
dose, but of the dose rate pattern by which it is acquired.
Thirdly, plutoniura as well as the other radionuclides has its
site of effects only on those cells which are irradiated and radio
induced tumors are usually found in tissues in which cellular injury
has been seen and tissue injury as well.
Fourthly, for low and intermediate radiation dose patterns, the
major end point has been tumorogenesis, which appears to account entirely
for any of the life shortening observed in these experiments with animals.
At very high levels, administered radioactivity, life shortening
may be quite marked and not solely due to tumorogenesis; while at
exceedingly low levels of radiation, in which tumorogenesis is rare or
absent, no life shortening effect is observed relative to comparable
unirradiated populations.
There appear to be no unique hazards from elements such as plutonium,
which are apparent when the dosage pattern is comparable to the exposure
to x or gamma radiation, if external.
With regard to the particular effects, it is significant to me
that dose effect occurs with beta gamma emitters; alpha emitters follow
a qualitatively parallel pattern regardless of the non-uniform distri-
bution of alpha dose.
The mean rad dose ratio for beta-gamma effects studies versus alpha
emitters for a comparable tumor incidence range only between the factor
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75
of about 5 and 20. No assumption regarding the carcinogenicity of
individual particulates are needed or implied.
A comparison with a relative, uniform beta gamma radiation in the
lung, for example, with non-uniform alpha radiation can be derived solely
from the toxicity data. I think it is important to recognize that the
appropriate models needed to describe the complete sequence of events
leading to cancer are, in my opinion, of secondary importance to a
valid determination of the relative toxicity of the two radiations.
This, in my view, is the most fundamental criteria in hazard
assessment.
In conclusion, I feel I would like to share these views with you.
On the basis of the two decades that we are worried about; these internal
emitters, I do not personally find anything unique, mysterious, strange
or in violation of the physical and biological laws that I have learned
that are associated with plutonium.
We do have a particulate exposure. There are some quantitative
differences, but in a qualitative sense, I do not believe, as
Dr. Sagan said, there is necessarily a plutonium crisis.
I hope the assessment of this will more or less be put back
into perspective.
Thank you.
Dr. Mills: Thank you, Dr. Goldman.
Dr. Parker.
Dr. Parker: My name is H. M. Parker and I have been connected
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in some form with plutonium limits since the early days of the Plu-
tonium Project.
My notes, if useful to the panel and the agency, will give
reference to some of those early limits. What I would like to do this
morning is to use material that arose at a symposium at the Los Alamos
scientific laboratory in May of this year under the topic of "Plutonium:
Health Implications for Man" in which I asked to summarize the issues
as I saw them.
I understand that this material is to be published in the journal,
Health Physics. I recommend your attention to that. I propose to use
essentially the same material here.
It will come out as a very random collection of six comments with
no intended thesis threading its way through those comments.
Number one: It is titled "Plutonium - the most toxic element
known to man?" It says here the health physicists of the Plutonium
Project had the task of rapidly developing a respect for plutonium in
some hundreds of scientists, technicians and operators.
They did it mainly by drawing parallels with the experience with
radium, and by describing plutonium as one of the most toxic elements
known to man. That statement, I think, tended to be converted to the
absolute form, the most toxic; and I think became one more tool to
encourage possible emotional reaction against the possible environmental
release of plutonium.
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As measured by actual experience to date in man, the statement I
think can be called preposterous. A recent bulletin of the National
Radiological Protection Board of Great Britain speaks somewhat to this
point.
With currently accepted permissible limits, it draws the conclusions,
skipping some finer points, that plutonium on a mass basis is 400 times
less toxic than iodine 131, 16 times more toxic than tritium as tri-
tiated water for inhalation, and some 200 times less toxic than tri-
tiated water for ingestion.
I think this is to some degree game playing, but I would perhaps
suggest if I may be so bold to the Agency that a balanced agency state-
ment on the toxicity of plutonium relative to other materials would be
helpful to all of us.
Point number two is entitled "Relative reliance on human data and
animal data." If quantitative data on the effects of exposure of man
exist, they would clearly be the data of choice.
Where they are diffuse and scanty, as in the somatic aspects of
general radiation exposure of man, the present interpretations tend
to depend more on plausible theory than on demonstrated fact.
In the very valuable NAS-BEIR Report, the emphasis on linearity
between effect and dose is more a matter of prudence than demonstration.
Some observers, including this one, believe that the relevant
animal data sometimes tend to show non-linear dependence on dose, at
least for some of the biological end points.
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For the specific case of plutonium, we must at this time use the
animal data since human data are virtually non-existent. Two clear
areas that need research seem to come from this.
Number one, for the animal data, to review periodically the esti-
mated shape of the dose-effect curves, especially for the very low doses
expected in environmental exposure and acknowledging possible differences
for different biological end points.
Number two, for the human data, to extract what information may
become available in such mechanisms as the U. S. Transuranium Registry
and the Mancuso study of atomic energy workers.
Here, I think it must be accepted that persuasive evidence on
either of these is much more likely to come by decades than by single
years. I recall that this is for the occupation case. Direct informa-
tion for the environmental case does not seem likely to be valid in a
reasonable timespan.
I would suggest that such a very arbitrary device as commitment
now to a formal national five year review plan of these data could offer
significant benefits for orderly improvements of environmental limits
from time to time.
Point number three is the "hot particle problem." Let me say if
I may that I excluded this from the Los Alamos review on the fairness
doctrine that representatives of one rather novel posture were not
present at that meeting.
So here I would like to make only a side observation that concern
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79
for various aspects of the hot particle problem, not specifically plu-
tonium hot particles, dates back in my experience to at least 1944.
I have previously documented concern that a single hot particle
in the lung may generate a tumor that would not have arisen from the
same activity in distributed form. I shall continue part of that con-
cern until I feel that we really understand the various environmental
factors that go into the initiation, promotion or proliferation of a
viable tumor in man.
For the present, however, I believe that the data presented in
such documents as WASH 1320 which I am sure will be coming later in
this hearing are more persuasive than the contrary views.
To oversimplify, hot particles can clearly be more hazardous than
depositions if there is either a threshold dose or some form of a
sigmoidal effect curve with respect to carcinogenesis.
If total linearity is accepted, as in the BEIR Report, it seems
plausible that hot particles will waste some of their activity in
killing some of the adjacent cells that need only have been damaged.
However, as a very personal opinion, I would expect that plutonium
limits should be lowered, and lowered now, by about one order of magni-
tude. I base this on hearing Dr. R. C. Thompson's review of the animal
data as defended at Los Alamos, and in the timing of this meeting, I
expected that it would already have been presented to you, Dr. Mills,
but it will, I am sure.
This, to me, with some allowance for uncertainties in both
symmetries, seems to say that absorbed doses of some few tens of rads —
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80
let me make it that indefinite, if I may — some few tens of rads do
indeed give demonstrable yields in various animals.
Conventional permissible dose in man permits the accumulation of
a somewhat light dose throughout an occupational lifetime. That does
not reflect the conservatism that we have generally felt would apply
to high radiation limits.
Some fear, again a very personal fear, that limit reduction of
this kind will be resisted because we could no longer then measure
so-called permissible lung burden by external means.
That, of course, would suggest a clear area of research to improve
that sensitivity by a factor of about a thousand which, unfortunately,
I think is impossible. It would be most helpful.
For EPA purposes, this particular inhibition fortunately will not
affect your wise decision because you are way below the possibility of
doing this during life in the human.
Let me inflict point number four on you at this time. That is
called the "indifference level." Industry will expect to have high
standards to minimize plutonium releases from their facilities and to
transfer principal radioactive wastes to carefully designed, federal
engineered storage or other ultimate disposal.
A continually growing problem remains with the disposal of
relatively large volumes of relatively low activity waste. For this,
some agreed indifference level of residual activity level is needed.
Conceivably, one might have rather a series of such levels,
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81
accounting for possible transfers to the public domain from working
materials, mostly pieces of paper that may not have remaining elements
of plutonium on them, from the clothing of workers, from the skin of
workers, and mechanisms that will be obvious, from the emissions from
the internal contamination of workers, all of which will put some amount
of plutonium into the environment.
It will be a major contribution if we could achieve a consensus
for a basis for such a level or levels, if that is the way it turns
out. Should it be set relative to natural alpha contamination, as pro-
posed by some, reflecting the existing weapons plutonium contamination
which to all intents and purposes in our background would tend to remove
that, or on some other more sophisticated basis? I offer no solution.
I hope intention to that decision will loom large in the efforts of the
agency.
Point number five: This has to do with the funny behavior of
"The isotopes of plutonium and the transplutonium elements."
The apparent matabolic behavior of two such nuclides as plutonium
238 and plutonium 239 is, in the laboratory, often markedly different
for two reasons, partly because the mass used for normal experimentation
is different. You choose an expert, and where you have a measurable
activity, separate what mass goes with that — and partly because, or
so it seems, the intense bombardment near the shorter lived source may
produce what you might call local chemistry, which certainly changes
the behavior, allegedly of insoluble particles such as plutonium oxide
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82
in the lung.
Now, environmentaml research, which you seek answers, needs to
be based on transfers of very small masses. These are best measured
if you go at it experimentally by one of the short life nuclides,
although in nature I presume plutonium 239 will remain the main real
contaminant.
Another problem in the general area of these mixed up isotopes
is that the radiobiological studies, normally conducted with one nuclide
at a time, the experimental thing to do, may or may not, more likely
not, permit reliable deduction of the effects of the expected mixtures
to be used in the developing nuclear industry.
Those mixtures eventually in low degree will invade the public
domain. So a program to study the environmental and radiobiological
behavior of one or two representative mixtures, reasonably from the
advance light-water reactor and LMFBR systems should be considered at
this time, we suggest.
My final point, Mr. Chairman, is entitled "Mixed oxides." It
maintains that the probable nuclear economy for the next one or two
decades is predominantly a mixed uranium and plutonium oxide fuel
economy.
As an extension of the previous section, knowing what plutonium
can do, we very much need to know the real environmental and radio-
biological behavior of actual mixed oxides, which does not seem to
have been worked on to any extent.
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83
One would expect some pencil and paper work, in the ordinary way,
that the hazard from this mixed oxide particle would fall well below
that of plutonium alone; as with so many of the cases here, you can
visualize some conditions that would lead to the contrary result, I
think the knowledge is most important to the ultimate welfare.
Also, I believe that variations of behavior with time, which
Dr. Goldman mentioned, plutonium may change its behavior with time.
In this case, it may change in a very different pattern and is one of
the channels through which one could conceive a growth of hazards
through time with immunition.
Above all in directly recommending studies of this nature, I
would consider it essential that it be done in two forms. Study the
behavior of mechanically mixed oxides, those turned through the years,
and begin the work now with chemically precipitated mixtures which may
be different in their behavior upon release and the ultimate industry
choice of these two forms may not yet have been determined.
Something quite unrelated to our health hazards may be the
determinant of that because you could make a proposition that the
economy which continually has only co-precipitated mixed oxides would
be very much safer from the diversionary attach point of view which I
believe is unrelated to our endeavors here.
Mr. Chairman, thank you.
Dr. Mills: Thank you very much, Dr. Parker, for some very
constructive comments.
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84
tomic Industrinl.Forum, Inc.
475 Park Avenue South
New York. New York 1001&
Telephone (212)725-8300
Cable Atomforum Newyork
r
October 25, 1974
Secretary of the Commission
U.S. Atomic Energy Commission
Washington, D.C. 20545
Subject: Comments on Draft Environmental Impact Statement
"Management of Commercial High Level and Transuranium-
Contaminated Radioactive Wastes," WASH-1539, and
Proposed Amendments to 10 CFR 20 and 10 CFR 150
Concerning Transuranic Waste Disposal
Dear Sir:
The comments herein were prepared by the Subcommittee on
Radioactive Waste of the Atomic Industrial Forum's Committee on
Nuclear Fuel Cycle Services and are submitted in response to
Federal Register notices of September 12, 1974. A list of the
subcommittee members is attached hereto.
We endorse the concept of the U.S. Atomic Energy Commission
that it take physical possession of and assume permanent responsi-
bility for both the high level radioactive waste generated from
the aqueous recovery of spent nuclear fuel and transuranium-
contaminated radioactive wastes. Further, the Commission's intent
to provide interim retrievable surface storage of radioactive high
level waste is endorsed as the logical interim step. The committee
believes that any of the three alternate interim retrievable surface
storage systems described in WASH-1539 is adequate "from the stand-
point of reliability and for the protection of public health and
safety for generations to come.
The draft states that the AEC will continue its efforts to
establish a permanent disposal system for high level radioactive
wastes based on placement in geologic formations. It is the sub-
committee's opinion that such ultimate disposal techniques should
be defined as soon as possible.
In determining the preferred location for a surface storage
waste facility (or facilities) for both types of waste, the Coinnis-
sion should give consideration to the cost of transportation from
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Secretary of the Commission "
October 25, 1974
Page 2
the generation sites to the interim facilities as well as the
cost of transportation from the interim facilities to a permanent
disposal site. We also recommend that the AEG accept title to the
wastes at the earliest possible date following their conversion to
an acceptable form and that waste form and the interim storage
concept be based on cost effectiveness considerations rather than
on the existence of an AEC operating site.
State of the art technologies for protecting the public health
and safety are now available. ?Ience, specific criteria for interim
storage packaging could be and should be written now. The adoption
of such technologies, however, should not foreclose the use of
future technological refinements which might provide further safety
margins or greater efficiency without invalidating earlier approved
technologies.
If the requirements of the draft statement are to be implerented
within the time frame indicated, the schedules for developing the
requix'ed technology and facilities must be accelerated. For example,
the development program for permanent disposition of transuranium-
contaminated hulls calls for initial operation of the storage system
in the period FY 1981 to FY 1983. At that time, significant quanti-
ties of hulls will already have been generated and should have been
sent to interim surface storage facilities.
To minimize handling and shipping, we recommend that considera-
tion be given to AEC ownership of both the interim high level waste
and the transuranic waste storage facilities at the individual
production sites. However, these facilities could be owned either
by industry or by the AEC, or operated for the AEC by industry.
Complete separation of transplutonium elements from high level
waste should be recognized as developmental at best. Endorsement
of this concept may subsequently be shown to be in conflict with
cost benefit considerations.
The problems of disposal of large, high gamma-alpha contaminate a
waste, such as failed equipment, has not been properly addressed in
the draft statement.
We also wish to point out that the draft statement has the
nature of a development program and, while the goals are clearly
delineated, the draft does not present a firm time schedule nor
does it furnish enough hard data for industry to make investment
decisions which are required in the very near term.
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86
Secretary of the Commission
October 25, 1974
Page 3
Since transuranium-contaminated wastes are treated in both
the draft impact statement and the notices on proposed changes
to 10 CFR Part 20 and Part 150, our comments on these two notices
follow.
Although we agree that wastes which contain substantial
quantities of transuranics should be placed under Federal control
and that the interim retrievable surface storage systems should
be owned by the Commission, we are concerned that none of the
management methods proposed for interim storage for commercial
transuranium waste offers the optimum in terr.is of cost effectiveness,
We record-end that a program be initiated promptly to accomplish this
goal and we would be pleased to work with the Commission on such a
program.
We also note that the proposed amendments to 10 CFR Part 20
do not contain a definition of transuranic wastes. The introductory
remarks discussing the proposed amendments make reference to general
classifications of certain types of wastes as transuranic on the
basis of their origin or upon a measurement at a 10 nanocuries per
gram level. This latter type of classification is not practical in
comrnerical nuclear facilities, considering the low concentrations
encountered with many types of waste. For example, it is stated
in WASH-1539 (p. B-3) that "at present, external radiation measure-
ments on waste packages cannot detect plutonium at this low a
concentration." The general classifications are too broad and
subject to too much interpretation. A preferred alternative, not
dependrnent upon questionable or undeveloped measurement techniques,
would be to classify wastes upon the likelihood of their direct
and substantial contact with transuranic materials, a procedure
that we believe is now followed at AEC facilities. We propose that
the following basis be adopted for classifying wastes with respect
to transuranic content.
1. Transuranic wastes:
Those wastes which have been in direct contact with
materials containing transuranium bearing elements; for example,
wastes originating in enclosures and process glove boxes containing
transuranic elements.
2. Non-transuranic wastes:
Wastes originating in uncontaminated controlled areas
outside of plutonium enclosures and process glove boxes, including
radwastes associated with or originating in current types of nuclear
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87
Secretary of the Commission
October 25, 1974
Page 4
power reactors and wastes from plants or plant areas not processing
or handling transuranium elements.
Wastes not clearly falling into the above categories
should be classified on an individual basis after a careful review
of plant operations to determine the likelihood of transuranic
contamination.
It should be noted that, as yet, there has been no definition
of the form of solid wastes that would be acceptable to the AZC,
neither has any indication been given as to the costs associated
with the AEC management and disposal of such wastes, nor has the
site to which such materials are to be delivered yet been named.
In the absence of such information, the proposed amendments are
considered premature.
It is most urgent that waste form specifications, packaging
requirements, and charges for services be stated in a complete and
consistent form at the earliest possible date and certainly prior
to the adoption of any such amendments. Such specifications,
requirements and charges should be set forth in the proposed amend-
ments and not left to future notices.
Ralph W. Deuster
Chairman
RWDrcl
Attachment
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88
ATTACHMENT
Atomic Industrial Forum
Subcommittee on Radioactive Waste
of the
Nuclear Fuel Cycle Services Committee
*******************
Ralph W. Deuster Nuclear Fuel Services, Inc., Chairman
Emanuel Gordon Atomic Industrial Forum, Secretary
S. J. Beard Exxon Nuclear Company
Gary R. Bray Allied General Nuclear Services
Irving Knudsen Westinghouse Electric Corporation
James H. Leonard Nuclear Engineering Company
E. D. North Nuclear Fuel Services, Inc.
Edmond C. Tarnuzzer Yankee Atomic Electric
Peter T. Tuite Hittman Nuclear & Development Corporation
E. E.- Voiland General Electric Company
Charles R. Woods NUMEC
10/25/74
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r
Atomic Industrial Forum, Inc. Jj y
475 Park Avenue South
Now York. New York 1001G
Telephone (212)725-8300
Cable Atomforum Newyork
October 28, 1974
U.S. Atomic Energy Commission
Washington, D. C. 20545
Attention: Deputy Director for Fuels and Materials
Directorate of Licensing-ReguI at ion
Subject: Comments on Draft, "The Generic Environmental
Statement on the Use of Recycle Plutonium in
Mixed Oxide Fuel in LWR's"(WASK-I 527)
Dear Sir:
The attached comments have been developed by an Ad Hoc Plutonium Recycle
Task Force of the Atomic Industrial Forum's Committee on Nuclear Fuel
Cycle Services. A list of the Task Force membership is also attached.
The Task Force commends the AEC for the staff effort and care reflected
in the draft GESMO and believes that the statement will contribute impor-
tant support to the ultimate recycle of pIutoniurn-bearing fuels in light
water reactors. The Task Force also commends the AEC for seeking the com-
ments of the nuclear industry and other interested parties on the drai'1
statement.
The comments are submitted with the objective of strengthening 1he draft
statement and address the following five general areas: cost-benefit
analysis, limitations of scope, safeguards, health and safety, and format.
Additional comments of a more detailed nature, derived from a page-by-page
review of the draft statement are presented separately.
The Task Force's detailed comments seek to correct certain inaccuracies,
address additional 1 epics and clarify points thai appear to hove been
based on incomplete or obsolete data. They are offered with the hope
that they will shorten review of the statement during the hearing t.V-jt is
to be held. For the most part, the exceptions taken by trie Task Force to
certain of the proposals set forth in the draft GESMO are attributable to
the Task Force's belief that there is a greater need to quanlify environ-
mental impacts insofar as possible through cost-benefit analyses. T'n; s
is especially true in those sections of the statement treating on safe--
guards.
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90
U.S. Atomic Energy Commission - 2 - October 28 1974
The Task Force appreciates this opportunity to review the draft statement
and hopes its comments will facilitate early issuance and adoption of the
final statement.
Si ncere ly,
RaIph W. Deuster, Chairman
Nuclear Fuel Cycle Services Committee
RWD/jmc
Attachments
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Atomic Industrial Forum, Inc.
475 Park A venue South
New York. New York 10016
Telephone (212)7258300
Cable. Atomforum Newyork
91
r
Attachment I of 4
General Comments on the GESMO
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92
Cost-Benefit Analysis
It is generally known throughout the industry that the capital costs enumer-
ated in Table S-14, "Capital Invested (Millions of 1974 Dollars about 1990)"
are outdated. Table S-14 cost estimates overall are low by about 20$. Sel-
elected areas, such as reprocessing and mixed oxide fabrication are perhaps
low by several hundred percent. Similarly, the operating cost assumptions
for materials and services in Table S-15, "Projected Costs for Materials
and Services in 1990 (Millions of 1974 Dollars)" are generally low by vary-
ing amounts.
Using more recent estimates of capital and operating costs, the differential
annual cost for the year 1990 to the users of LWR's generated electrical ener-
gy, if plutonium is not recycled, is approximately 0.8 mil/KV/H (compared to
0.4 mi IIs/KWH in Table S-4), or about $2 billion cost penalty compared to
the $1 billion penalty indicated in GESMO. If neither plutonium nor uranium
Is recycled, the cost penalty for the year 1990 will likely be in excess of
$2.5 billion. It should be emphasized that the economics for a single fu-
ture year case are not nearly indicative of the overall magnitude of poten-
tial cost savings attributable to plutonium recycle in LWR's. For the year
I960 through the year 2000, the users of LWR's generated electrical energy
will pay a cumulative total penalty of nearly $50 billion if plutonium is
not used in light water reactors, and nearly $60 billion if neither plutonium
nor uranium is recycled. This cumulative penalty to society through the year
2000, which is in 1974 dollars, is more than the total capital investment
that will be needed to support the LWR fuel cycle.
In the overall evaluation of plutonium recycle, the most realistic analysis
would assume some delays in the schedules as outlined in GESMO. Certainly
some slippage in almost all schedules is inevitable without solid commit-
ments to key milestones from the AEC and its licensing and regulatory agen-
cies, from the nuclear industry, from the Government in its energy policies,
and from the general public at large. It would be appropriate in GESMO to
analyze the impact of schedule slippages on the cost-benefit of plutonium
recycle. The initial delays in reprocessing should be addressed. Also, an
alternative case analysis which should be included in any further studies
on'the sensitivity of schedules is that case which considers a slippage in
the breeder (FBR's) schedule of -5-10 years. Under these circumstances, a
comparison should be made between the alternatives of LWR plutonium recycle
through the year 2000 and uranium utilization only. This approach would
provide the proper perspective on which to judge the merits of various fuel
cycles. Furthermore, this comparison should be carried out on a cumulative
basis since the true impact occurs over the number of years the program is
implemented.
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A critical issue in me consideration of the GESMO assumptions and alter-
nate case studies is the fact that without plutonium recycle in LWR's, the
growth of a breeder industry will be slowed considerably. Experience
gained with handling large amounts of plutonium through 1990 and beyond is
essential to the growth of the industry and will provide the framework for
licensing and public acceptaTvce. Under this basis, four of the six cases
evaluated by the Commission would no longer be considered viable options
for the breeder concept.
Finally, In GESMO, the impact of plutonfum recycle on the price elasticity
of yellowcake is assumed to be negligible or non-existent. This assumption
must be challenged on the basis that the demands placed on l^Og without
plutonium recycle are likely to far exceed by a considerable margin the val-
ues projected in GESMO.
Limitations of Scope
As we interpret the GESMO, there are severe scope limitations which either
restrict the applicability of the GESMO, or imply that operations outside
of the GESMO scope will not be permitted.
Manufacturing Facilities
The report would have greater credibility and usefulness if it also covered
the period of time when the MOX fuel cycle industry is evolving and growing
(1975-1990) as well as when it reaches maturity (estimated - 1990). As the
report now exists, it relates only to the wide scale use of Pu in MOX fuels
for LWR's in the year 1990. At that time (1990) an estimated 6-8 MOX fuel
fabrication plants of approximately 200-300 MT/yr. capacity would be re-
quired, the inference of the report being that these MOX fuel fabrication
plants, which do not now exist, would be new and would meet the concepts
and requirements of an upgraded safeguards program yet to be defined. No
consideration is given to the five pilot-development MOX fuel fabrication
facilities now existing and which could be viable for the interim period
between 1975 and 1985, provided they are not required to meet 1990 safe-
guards and other standards during the interim period. (See "Manufacturing"
section under "Health & Safety"). These existing plants are needed for de-
veloping both LWR and Breeder fuel.
When evaluated in relation to the upgraded safeguards concepts, it Is ob-
vious that these existing pilot facilities will be obsolete by 1990 stan-
dards. However, it is not clear that the same measures needed under the
heavy throughputs of 1990, are needed while throughputs are still very low
and adequately controlled b, existing safeguards methods. Since there will
be a need for these pilot facilities between 1975 and 1990 an environmen-
tal assessment and cost-benefit analysis should be made to determine the
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94
extent to which existing plants should be operated, partially upgraded and
perhaps even expanded without adversely affecting the environment or de-
tracting from an adequate safeguards program. Inasmuch as the AEC actively
encouraged each of the companies operating pilot MOX fuel fabrication facil-
ities to get into the plutonium business, every effort should be made to
enable the existing facilities to be gainfully used and fully depreciated
In a safe and prudent manner before such facilities are declared obsolete
under 1990 standards. As already mentioned, this analysis should consider
the small capacities of the existing MOX fuel fabrication plants, and the
fact that the facilities have already been upgraded to meet current AEC
safeguards requirements.
Limits on Recycle Amounts
Detailed discussion in GESMO relative to the model LWR indicates that the
1.15 self generated recycle (SGR) value used is an average calculated from
operating experience with existing LWR's. The report summary, however,
goes one step further and implies limiting Pu recycle to the 1.15 SGR level.
Since one might expect improved operating performance in all LWR's by 1990
it would seem more appropriate for the report to evaluate the impact on the
environment of the highest Pu recycle technically possible for LWR's and
to allow each reactor to recycle all the Pu it. generates under equilibrium
conditions.
In like manner, the report uses an upper limit of 5% Pu in uranium and men-
tions only natural uranium as the carrier. Some reactors may require slight-
ly higher Pu concentrations than 5% and could economically use depleted on
slightly enriched uranium rather than natural uranium as a carrier. These
alternatives should be considered by the GESMO report.
Statement of Purpose
It would be most useful if the stated purpose of the GESMO could be en-
larged to make it clear that environmental considerations covered by the
report need not be duplicated for inclusion in environmental statements sub-
mitted by LWR operators, reprocessing plants and mixed oxide fuel fabrica-
tion plants when Pu is ultimately recycled or new facilities are construct-
ed. If this is not allowed there seems to be little use for GESMO except
as a starting point for more discussion and perhaps the basis for repeti-
tive environmental statements.
Safeguards
We feel that GESMO should emphasize the fact that considering the existing
supply of plutonium and its current utilization, the current safeguards
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95
system, as recently promulgated by the Commission, provides reasonable as-
surance that the health and safety of the public will be protected. We,
therefore, concur with the Commission that the active safeguards system
should be continued including the ongoing assessment of changing considera-
tions. It is recognized that as safeguards are reassessed, upgrading may
be necessary in the future. Future upgrading, particularly in areas of
the government's responsibility, was addressed recently (October 9, 1974)
in a speech by the Forum's President Carl Walske. His speech is attached
for your information.
The GESMO in its present form presents no real cost-benefit analysis with
respect to upgraded safeguards programs vs. status-quo programs. The re-
port also seems to imply there are no alternatives to the concepts proposed
(although we do not believe this to be the actual intent). Since defini-
tive safeguards programs will not be issued for at least another year, some
thought should be given to separating the detailed discussions of safe-
guards proposals from the GESMO and treating these as a separate issue at
a later date.
Of those concepts which have been identified by the Commission as a means
to improve safeguards significantly, we consider co-location as having a
very long-range potential rather than being a viable near-term alternative.
On the negative side, co-location could impose commercial difficulties
which would affect the ability of fuel service suppliers to respond in a
timely manner to the needs of fuel users.
With respect to the transportation aspects of co-location, we believe that
adequate transportation safeguards can be provided within the present sy-
stem and commensurate with the type, form and amount of the nuclear mate-
rials involved. Therefore, there is no absolute requirement to eliminate
transportation in any segment of the fuel cycle. In any case, it must be
recognized that transportation could not be eliminated altogether. The
Commission has indicated as one of the advantages of an integrated fuel
cycle facility that it would make use of onsite protection measures more
efficient. But on balance, considering the small portion of the total
fuel cycle costs which would be -incurred for safeguards even with possible
improvements, the benefit of any added efficiency gained by reducing trans-
portation or by integrating facilities could not offset the added costs
associated with co-location.
We suggest that the concepts involving spiked Pu or debilitating gases be
discarded. Considering the fact that there are other reasonable means
available which can be employed to attain the Commission's objectives,
these schemes are quite unattractive. It is difficult to see how the bene-
fit could outweigh the increased hazard created.
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96
In conclusion, we believe that the present system of safeguards is generally
adequate for the current state of the industry and such improvements as are
desirable can be made in an orderly evolutionary way. We are convinced that
much of the concern being expressed today is based upon situations which may
have existed at certain facilities prior to the implementation of the pre-
sent safeguards system and upon sn inadequate understanding of the techno-
logical and other improvements that are now incorporated in the present sy-
stem.
Health and Safety
Environmental Radiation
The radiation doses in the environs from reactors using mixed oxide fuel
are calculated using as a basis WASH-1258 "Final Environmental Statement
Concerning Proposed Rule Making Action: . . .'As Low As Practicable' . . .
Nuclear Power Reactor Effluents". The GESMO evaluation, therefore, contains
the same problems of overconservative assumptions and overconservative meth-
ods of calculation of doses as that document. In fact, the GESMO evaluation
•fails to utilize several of the improvements made in caIculational techniques
and assumptions made by the AEC. Several specific examples are offered to
illustrate the nature of overconservatism in Attachment A to the comments.
"Hot Particle" Problem
Possible effects of the so called "hot particle" problem should be discussed
In more detail in the final GESMO. As long as the Commission has not devel-
oped a final position on this subject, a possibility exists that it will be
necessary to reduce the allowable airborne concentrations of plutonium by
significant factors. A discussion of the impact of such a potential reduc-
tion should be included in the final GESMO.
Manufacturing
The GESMO addresses only hardened manufacturing facilities designed, built,
and operated according to some combination of the GESMO assumptions and new
regulations which apply to plutonium in the fuel cycle. If mixed oxide
fabrication loads are less than projected in the GESMO there may be a need
to use existing facilities during the period addressed in the GESMO. The
existing facilities will, therefore, have to be modified to meet some in-
terim regulatory safety requirements. As a result, occupational safety
and environmental safety impacts of the interim facilities may not be con-
sistent with the GESMO. The final GESMO should present an analysis of this
eventuality.
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97
The final GESMO should include additional analysis of the consequences of
accidents in the manufacturing facilities. The consequences of loss of con-
finement and loss of shielding are more severe than in the UC>2 fabrication
plant where the uranium has much less radiotoxicity and external radiation
exposure is of little concern. In order to reduce the risk of accidents to
acceptable levels, design, construction and operation of recycle fuel manu-
facturing facilities will result in greater capital and operating expenses.
The factor of 1.5 greater than the cost of uranium facilities used in GESMO
appears to be low.
Format
The following comments are presented as a means of clarifying the GESMO
through some changes in format:
Although Volume I contains a good summary of the information pre-
sented in GESMO, it is often difficult to locate the detailed
discussions in the later volumes which are related to the gene-
ral statements and tables in Volume I. To clarify these state-
ments and tables, it is recommended that chapter and section
numbers of the applicable detailed discussions be referenced in
Volume I.
A rather detailed table of contents is provided for the report.
However, it would be very helpful if a subject index were also
Included. The same specific subjects are discussed in several
locations throughout the report. Therefore, it is difficult
for someone studying a particular aspect to find all of the
separate related discussions.
The report, and in particular Volume I, is quite repetitious.
The value of a brief summary at the beginning is recognized.
However, in reading through the report, one wastes time in cov-
ering the same ground several times.
If the data were expanded and all technical inaccuracies cor-
rected, the Volume 3 technical data would be useful with regard
to the out-of-reactor portion of the licensing process. The
Volume would be extremely useful to industry with regard to the
reactor portion of the licensing process if it contained a table
for indicating the impact of Pu recycle as was provided by the
Commission with respect to the impact of the uranium fuel cycle.
This may have besn the Commission's intent judging from the ti-
tles of the Tables IV A-7 and IV A-8 listed in the Table of
Contents, however, these tables of GESMO are missing.
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The paragraph designations used in GESMO are confusing, consider
the use of a straight number system. With the number system, the
reader could easily determine what main section and subsections
a specific paragraph is contained in. For example, paragraph
l.b.d).(a) of Chapter IV, Section E cou l.d be straightforwardly
designated as I.2.I.I of Chapter IV, Section E or Paragraph
4.5.1.2.1.1.
Numerous general statements are made in GESMO which should be
further clarified by placing them in context. For example, it
Is stated that the immediate recycling of pIutoniurn would re-
duce the requirements for uranium mining by about 9% around 1990.
It would be beneficial to add what fraction of the total benefit
(In dollars) this reduction represents. This type of clarifica-
tion would make GESMO much easier to understand and it would
strengthen many of the arguments presented.
The purpose of the GESMO seems to get lost in the words (page
S-13). It should be possible to state the objectives more clear-
ly and then to equate the conclusions to them.
-------
Atomic In'Jur.triol Forum, inc.
47b Park Avenue South
New York, r..':.vv York 10016
Telephone (212)7213-8300
Cable Atomforum Newyork
99
r
Attachment 2 of 4
Detailed Corr"ncnts on the GESf-'O
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100
DETAILED COMMENTS
Paragraph k. This paragraph states that "accidents in the
mixed-oxide fuel fabrication plant, a facility that does not
occur in the UCL fuel cycle, are similar in consequence
to accidents at UCL fuel cycle facilities. . .". This is only
so if plutonium fabrication plants are designed and built like
reprocessing plants. If this is the implication, it should be
more clearly stated or the paragraph revised.
S-3 Table S-1. It would help if there was a footnote indicating the
size of the 1990 LWR industry and what fraction of the fissile
material is plutonium. It is also not clear if the Kr-85 is
released or removed from the effluent streams.
S-k Paragraph j_. The definition of self-generated quantities of
recycle is somewhat ambiguous. Does this refer to total amount
of plutonium available or equilibrium amounts? Although the
choice of 1.15 times self-generated recycle for the reference
case is reasonable some statement should be made about the relative
effect of larger quantities of plutonium in recycle fuel (up to 200%).
In view of the delays in start-ups of spent fuel reprocessing
plants it may be necessary or desirable for the industry to recycle
larger than self-generated quantities of plutonium in order to
work off the backlog of reprocessed plutonium which will develop
after a number of reprocessing plants have begun operation. Thus,
the report should also consider the relative effects of
significantly larger than 115% self-generated plutonium recycle.
S-A Last Paragraph. The GESMO seems to place unnecessarily heavy reliance
on a situation "already dominated" by other strategic SMM materials.
There is considerable uncertainty in the timing of the LMFBR and
the HTGR programs. Furthermore, it is suggested the amounts of
special nuclear material projected"for the HTGR and LMFBR programs
be more spec! f ica 1-ly identified. It is not obvious whether Pu
for military uses is included in the "other" category.
This paragraph also seems inconsistent with later statements
since it indicates that plutonium recycle will not significantly
affect required safeguards since other SUM dominates the shipping
picture. Later, however, on pages S-6 and S-7, the statement is
made that the current safeguards provisions are inadequate and
further work is being undertaken to study methods of upgrading
them.
S-5 Table S-2. Is the bottom 1ine SNM wi thout the plutonium recycle
program or SNM less recycle plutonium? Is the top line add!tional
SflM due to plutonium recycle? Also, it is not clear if the quantities
are total plutonium or fissile plutonium.
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Page
S~7 Paragraph 1. Some reference to the timing for the co-location
concept is believed to be important. The concept, if viable,
becomes more important as the number of fuel fabrication and
reprocessing plants increases. It is not a very important
or effective method of improving safeguards while the number
of plants are very few. Furthermore, the opportunities of
co-locating with any of the partially constructed reprocessing
plants are difficult to access so that it is not clear that
co-location can be a practical solution for use in time for
the first additions of fabrication capacity.
S-7 Concept 6. Somr'inention of the fact that "spiking" is likely
to be the most e«pfi«*;ive of all the alternatives should be made.
S-7 Paragraph 7. Although this paragraph implies that the above
are only concepts which are under study, it is recommended that
the Commission make this more positive. It should be clear that
the six listed concepts are merely examples and that the
Commission is not now locked into any of these, and that many
alternatives will be investigated before firm determinations
are made.
S-7 Paragraph 8. Upgrading of safeguards about one year after issuance
of the final GESMO is likely to delay decisions on the construction
of any manufacturing facilities for mixed oxide fuel. Since the use
of additional safeguards seems to be a rather firm conclusion,
it would seem more advisable to recognize that evaluation of the
alternative safeguards methods will proceed in parallel with the
GESMO. The timing on release of upgraded safeguards regulations
should not be tied to the timing of the final GESMO but rather
proceed as expeditiously as possible.
S-8 Paragraph 9. The conclusion that "alternative ^. ranks best"
cannot be made directly from the data presented in Table S-3
(page S-9) . Based on that table, alternative 3- is the best.
S-9 Table S-3. Depending on the manner of safeguard upgrading, the
whole body radiation exposure for alternative 3- and ^. may not
be identical ("spiking" may greatly increase the exposure).
The value under whole body radiation exposun; "plus 21%" should
be "minus 2U".
The ability to calculate the cost differential between Cases III
and IV is highly questionable considering the vast differences
.between the costs of the six subcases considered in I tern ^4.
What is the time basis for this table? (Annual?)
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Page
S-10 Paragraph 3. "1955" should be "1995".
S-10 Paragraph k. Clarification is required. This paragraph first
implies that some LWR plutonium will feed LMFBR's and then
states "the only potential use of Pu" is LWR recycle.
S-10 Paragraph 5. Alternative 5- which involves permanent storage
of plutonium is claimed to present a reduced safeguards threat
compared to the base case. It is not immediately apparent that
having a large stockpile of plutonium involves less of a hazard
than smaller amounts in recycle.
S-ll Table S-4 (and preceding text). There is no indication whether
the costs presented are based on current dollars or costs
escalated to the 1990 comparison date. Also, Table S-4 indicates
that costs include upgraded safeguards but does not state which
safeguards are included (although it seems apparent that the costs
of the various safeguards proposals will vary widely).
S-12 Paragraph 6. In the conclusion to approve plutonium recycle, (and
in a number of other places in the report), the implication is
that the approval of more than 1.15 SGR would not be given. It
would be unfortunate if this blanket limit was adopted without
compelling reason and it would be much better to rely on a
case-by-case analysis. Some reactors will very likely have
greater recycle capabilities and needs than others.
S-12 Conclusion 2.B. Remarks relative to timing of the decisions for
upgrading safeguard measures should be omitted as discussed in
the comment on Page S~7> Paragraph 8.
S-12 Conclusion 2.C. Some expansion of the statement to identify those
safeguard measures-which will be promptly implemented would be
helpful.
S-13 Paragraph 1. This should be reworded to indicate that plutonium
recycle constitutes a federal action which potentially affects
the quality of the environment.
S-]k Paragraph 2. The manner in which this paragraph is worded opens
up the question as tojust what purpose the GESMO does serve. It
is recommended that the paragraph be written in a more positive
vein, indicating the purposes the GESMO serves, and its limitations,
S-]k Paragraph 3. The uranium prices are too low and need to be updated.
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Page
27ft
S-15 Paragraph 3. Should J Pu be
S-15 Paragraph k. The stated concern for Am conflicts in basic
approach to the consideration using "spiked" plutonium to improve
safeguards.
It does not appear that the costs and effects of plutonium
repurificat!on to remove Am have been included in the evaluation
of alternatives. in particular, there should be a cost savings
for alternatives 3- and b. (immediate Pu recycle) as opposed
to alternative 1 (base case). Undoubtedly the costs are relatively
small but they should not be ignored.
S-15 Footnote. Does "other isotopes, e.g.. 2^°Pu" include ' Pu?
If so, the statement is incorrect. 23opu js not. an imoortant
fissile material but is extremely important to evaluating overall
environmental impact, including cost benefit analysis.
S-16 Paragraph 5- This should specify that MOX spent fuel contains
larger quantities of Pu and transplutoniurn isotopes.
S-18 Paragraph 2. In contrast to the judgment made in the GESMO,
dissolution of mixed oxide fuels may well present significant
difficulties to the reprocessor. Complete dissolution of
plutonium will probably require the addition of fluoride in
quantities sufficient to cause corrosion in the stainless steels
used throughout most head-end processes. Major modifications
to flow sheet and equipment will, therefore, be necessary in ell
existing reprocessing plants.
S-20 Paragraph 2. "TWR" should be "LWR".
S-21 Paragraph k. Relating plutonium inventory to FBR fuel requirements
seems meaningless since FBR requirements increase approximately
five times between 1990 and 1995 and approximately twenty times
between 1S90 and 2000.
S-22,23 Figures S-1, S-2, S~3. Are the amounts in the figures annual
or cumulative?
S-27,28 Are the amounts in the tables annual or cumulative?
$-28 Table S-6. The use of fossil fuel should be clarified.
What percentage of the energy requirements for the cycle
are assumed to be supplied by fossil fuel?
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S-31 Table S-7- Assuming -that Table S-7 represents the worldwide
effects of the U.S. LWR industry, the title of the table
should read, ". . .FROM THE U.S. LWR INDUSTRY."
S-35 Paragraph k. Quantity of 2 x 10 Btu needs a time dimension
(per year?).
S-35 Paragraph 6. Is the "residual heat" the total heat value of the
waste from 10 years decay to infinity? The term should be
defined or clarified.
The size and capacity of the waste canister (I1 0 x 10' L, 3-2 MT
fuel at 2 ft3 waste/MT) or a reference to Page IV H-12 should be
shown in paragraph 6.
S-35 Last sentence, bottom of page. This sentence should be changed
to read, "Since the quantity of waste is small and since the
waste is stored and not released to the environment, there would
be minimal environmental impact."
S-36 Paragraph 3. Change the first sentence to read, ". . .0.27 and
0.18 cases per year respectively".
S-^0 Table S-9. An attempt to quantify the radiological effects
of transportation accidents should be made. The term "small"
is indefinite.
Footnote. The last two sentences in the footnote should be omitted.
A reference to Page S-36 might be desirable.
S-^3 Table S-10. The estimates of Puf utilization in commercial LWR
recycle fuel shown in Table S-10 should be updated to reflect
the availability of reprocessing facilities. In particular, it
appears that there will be no recycle plutonium in 1976 and
something less than 2^00 kgs Pu in 1977-
S-kk Paragraph 5- A reference should be maae to the recommendations
of Will rich and Taylor as stated on page V-37-
In the third sentence of Paragraph 5-, "ompliment" should be
"implement".
S-J»5 Paragraphs 1 . S 2. The element of cost has been omitted from
the discussion of safeguards in the first two paragraphs.
Any increase or tightening of safeguards measures should consider
the cost and cost benefit to be derived from such changes.
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S-J»5 Concept 1. It should.be noted that with Integrated Fuel Cycle
Facilities (minimization of Pu shipping) the utility might be
forced into using the specific fabrication facility which is on
the reprocessing plant site (or vice versa).
S-^5 Concept 6. It should be noted that the use of "spiked" plutonium
might prove to be impractical or uneconomical due to the cost
of processing such material in the PuO,j conversion and fuel
fabrication operations. One of ttse purposes of reprocessing is
to minimize fission product content so that semi-remote handling
is possible.
S-W Paragraph 2. This paragraph expresses a time relationship between
the issuance of the final GESMO statement and the decisions on
safeguards upgrading. This relationship appears to be contrary
to the ultimate purpose of GESMO. Several of the concepts under
study could have a significant impact upon the environment and the
cost benefit of plutonium recycle. For this reason, decisions
on upgrading of safeguards requirements need to be made as soon as
possible regardless of the date of the final GESMO statement.
In addition, Pu conversion, storage, and MOX fabrication facilities
are being designed and/or constructed today. Postponement of
safeguards decisions will only lead to inefficient backfitting
and costly construction and operational delays. A statement
should be made in paragraph 2. acknowledging the existence of
present-day MOX fuel fab plants.
S-A6 F. Paragraph 3. The statement: "Spent 1.15 SGR fuels would
contain about 16% more tritrium and 11% less °5«r than spent
U0_ fuels" should be referenced.
S-^7 Paragraph 3. This paragraph should mention the proposed
disposition of the transuranics after separation.
S-^7 Paragraph 5. The various safeguards concepts being considered have been
detailed earlier and it appears too restrictiva to single out
one of the concepts in Paragraph 5- It is, therefore, suggested
that the second sentence be omitted and the third sentence
be restructured.
S-51 Fi gure $-?• Alternative 1 in this figure should show a Pu Storage
"box" (wi thout asterisk) similar to the box in Alternative 5-
S-52 Table S-11. Under Alternative 2. the Whole Body Radiation Exposure
should be negative (-21%).
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Page
S-53 Table S-12. Under Alternati ve 6_. the number of Transportation
Shipments should be "-2500".
The 77,900 MT SWU base case enrichment quantity should be
footnoted to the effect that it includes kk% (or 30,000 MT
SWU) of foreign enrichment requirements. This note will
make Table S-12 consistent with the separative work units
discussed on page S-61.
$~5b Last paragraph. TsuJe number should be S-13-
S-55 Table S-J3. Under Alternative 6. the kgs. of Pu, accumulated in
storage through 1990 should be "-309,200".
S-57 Paragraph 5. Sentence 4 should read, "Those operations where
additional safeguards measures should be considered over
Alternative 1. . .". A need or requirement has not been
established; reference the wording and intent of the second
paragraph on page S-^2.
S-58 Paragraph 2. The last sentence speaks of ". . .the AEC's
need to upgrade the safeguards program." Again, this need
has not been established, and the sentence should probably read,
". . .the AEC's decisions on an upgraded safeguards program."
The paragraph entitled Capital Investments should state that
costs are calculated in 197^ dollars and that Table S-l^ represents
total accumulated capital investment to 1990 (if that, in fact,
is the case).
The paragraph entitled Materials and Services Costs should state
that costs are calculated in197^ dollars and that Table S-15
represents annual 'expenditures in 1990 (if that, in fact, is
the case).
S-59 Table S-14. Under Alternative 6 and in the supporting data
LTLVolume 4, the reason for a $70 million capital cost differential
above the base case for "Spent Fuel Transportation" is not clear.
Increased mileage accounts for the operating cost differential
in Table S-15 (pg. S-60) but the reason for the capital cost
differential is not apparent.
S-60 Table S-15. The differential changes in "Mining-Milling" costs
between the alternatives in Table S-15 do not appear to be consistent.
Table S-12 on page S~53 shows that the increase in mining-milling
quantities for Alternatives 2 and 6 is approximately equal to the
quantity decrea= in Alternatives 3 and ^ (e.g., milling is
+ 11,900 tons U ;' in Alternatives 2 and 6 versus -10,000 tons
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107
S-60 (Cont'd) U.On in Alternatives. 3 and 4). The operating cost figures in
Table S-15, however, show a significant dollar change
(+$670 million for Alternatives 2 and 6 versus - $300
million for Alternatives 3 and 4). If these figures are
correct, some explanation should be given either in this
summary section or in Volume 4. It appears that footnote "d"
should also apply to the "Waste Management" item since the
previous table (S-14) indicated that waste management capital
costs were absorbed by the federal government.
S-61 Paragraph 2. The enrichment cost of $48.90/kg SWU for
Alternatives 3 and 4 shown in the last line of paragraph 2
appears to be incorrect. Table XI-12 on page XI-35
indicates a figure of $55.06/kg SWU. This latter figure is
also consistent with the -$400 million enrichment cost
differential for Alternatives 3 and 4 shown in Table S-15-
Use of the $48.90/kg SWU cost would yield a differential of
about -$600 million.
1-2 Section A. It would be beneficial if the purpose of GESMO
should be more simply stated.
1-3 Paragraph 2. Next to las.t sentence beginning with, "for
comparison, . . .". This seems out of place. Makes the whole
paragraph sound defensive.
1-3 Section B, 1st sentence. Need to define central station.
1-7 The out-of-reactor fuel cycle operations are presented.
Subsequently plutonium and radioactive wastes are discussed.
There is a need to establish what is done with "tails".
1-8 Fig ure 1-3 • Need to define acronymsand use consistent units.
Show depleted "tails" stream from enrichment. The whole
balance is difficult to follow.
1-9 Does projected cost of yellowcake include escalation?
1-10 Figure 1-4. Consistent units should be used - define acronyms.
1-12 Figure 1-6. Is plutonium storage/inventory cumulative to 1990?
The depleted U - "tails" - stream should be shown as part of
balance. Whole balance is hard to follow.
1-14 Paragraph 1, second sentence. Beginning with "thus, it would be
. . ." is ver« difficult to follow.
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Page
1-14 Paragraphs 2 and 3. This seems to establish a firm limit on
quantity of plutonium charged in MOX. Is this the intent?
MOX should be defined.
1-17 What is the time basis of values in Table 1-3.2? Are these
annual or cumulative?
11-2 Paragraph 1. "Estimates of nuclear power generation capacity. . ."
Where is this shown? A reference should be provided.
ll~3 2nd Line from top. . . ."ingested significant amounts of plutonium
. . .". What is significant? This should be related to MPC .
3
11-3 Paragraph 2, 2nd sentence. . . ."under the defense in depth design
. . .". is not clear.
11-4 Page 11-4 and Table I 1-3 seem to imply an optimistic schedule
for spent fuel recovery operations in U.S. (and, therefore,
earlier than expected plutonium availability). Start-up, date
for the plants on Page 11-25 is not achievable. This fact
is Implied in the definition of Case I (Base Case) for the
cost/benefit calculations, but may make alternatives 3, 4 and 5
unrealistic. Perhaps more information could be presented on
effects of delays in implementation of recycle and on effects of
various cost parameters (storage costs, capital investment costs)
on the results.
11-5 Paragraph 4, last sentence. Delete "The chart below,".
11-5 Paragraph 5, last sentence. This sentence should reference
Table 11-2.
11-12 Figure I I - 4_. The cost/unit on right side of chart is confusing.
11-14 Table 11-3. This schedule is probably not realistic as noted
above(Page 11-4 comment).
11-20 Table 11-7. Half life of Pu-24l given as 13.2 years. IV C-58
lists the value as 14 years. The currently accepted value is
^15 years (consistent with Volume 1 S-15).
11-24 Paragraph 2, 1st sentence. correct spelling of "about".
11-24 Paragraph 2. With regard to the coefficients of reactivity
"larger" should be "more negative".
The discussion on caIculational uncertainties is inconsistent
with a subsequent passage (Volume 3» IV. C-59) on the same subject.
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Page
11-25 1st sentence. Need a period after parenthesis.
11-25 Paragraph 1. Since cores containing mixed oxide assemblies
are more stable GESMO indicates that "part length fuel rods"
may be eliminated. The reference should be to part length
control rods.
11-25 Last paragraph. The start-up dates for existing or planned
reprocessing plants should be updated.
11-26 Paragraph 3, 1st sentence. Delete "very".
11-27 Paragraph 5- No mention is made of the hazards of plutonium
ni trate.
11-27 Paragraph 5. Neutrons due to subcritical multiplication can also
be very significant.
11-28 Section b. The beta contribution from Pu-2^1 is not discussed.
11-29 Section c and d. It is not clear whether this section is still
restricted to plutonium oxide. Also, there is a statement that
plutonium absorbed through the skin deposits in the bone which
seem to contradict section a. on page 11-28.
Appendix In the Appendix to Chapter II, dealing with criticality accidents
in chemical processing, it is recommended that the material recently
published by Olsen, Hooper, Uotinen and Brown on "Empirical Estimation
of Number of F i ss i ons from Acci den ta 1 Cr i t ica 1 i ty in Uran i urn or
Plutonium Systems" (ANS Transactions, winter meeting, 197*0 be
included. This work is not merely a compilation of data on
miscellaneous accidents, but presents an empirical means of
estimating the energy release from various criticality accidents.
11-32 Paragraph 3. 3 x 10^ should be 3 x lo"1^.
11-35 Paragraph 3- "• • •» the fuel fabricators designed the i r LWR f ue 1
facilities to produce. . .".
11-38 Paragraph 2. There are redundant phrases concerning burn-up and
linear heat ratings. Clarification is required.
11-^0 Paragraph 1. Statement on cladding material of construction needs
clari fication.
H-^0 It is not clearly stated what type of reactor Saxton was. (PWR)
M-J»8 Tab1e 11-12. No value given for hole size; footnote implies
values given for % dishing are hole sizes.
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Page
11-52 Table I 1-15. "Pu concentration, % +_ .10 "is not clear
(is this on the ratio or a percentage?).
11-62 Paragraph k. Mixed oxide reprocessing may require additional
capaci ty in the plutonium purification facilities, not add!tions.
I \-6k Paragraph 1. "In all transuranium elements certain small losses. . .".
Statement needs clarification.
30% heat geni_. -. •', •,' ,rease lasts over what time period?
\\-6k Paragraph 3- ^-5 microcuries per pound.
11-65 Paragraph 1. "Present plans are to hold. . .". Statement needs
clar i ficat ion.
I 11-^1-7 Figures I I 1-1,2,3. Shouldn't ordinate scale be labeled "ICr Megawatts"
instead of megawatts x 1()3?
111-8,9 Fi gures 11 I-4A & B are unnecessary. The same information is
provided in Table III-].
I I 1-1 The number of fuel reprocessing plants and mine-mill complexes
may not be attainable in the period specified.
IV A-2 Paragraph 1. Reference in the first paragraph to "1/3 of the total
power" is confusing, since power is an instantaneous measure.
Is the word "energy" meant instead of "power"? This same confusion
exists on other pages (e.g. IV B-2).
IV A~5 Figure IV A-2. No stream is shown in this figure for spent
recycled plutonium" or uranium, which have negligible value.
It appears that continuous mixing with newly produced recycled
material would not be economical. Also, no tails stream
is shown from the enrichment plant on this figure or figure
IV A-1 and similar figures in Section 3.
IV A-6 Table IV A-1. What is the basis of values in this table, annual?
IV A-7 Table IV A-2. Units in Table IV A-2 need clarification.
3H & 8bKr in millions Ci per year?
IV A-8 Table IV A-4. Same comment.
IV B-7 Paragraph 1. R'jarding the last sentence of the first paragraph
under 2.a., did C consider the added costs at reactors recycling
Pu? This sta - ,.. -.' implies they did not; in cost/benefit analysis
it should be L , :dered.
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Page
IV C-2 Paragraph 1. Is "equivalent p1utoniurn" total Pu or fissile Pu?
IV C~3 Under ' 'Ace i den ts " jhe if i r s t sen ten ce_ seems to be more appropriate
to "Normal Operation". This should be clarified.
IV C-3 Is the GESMO serving any purpose if each request for licensing
mixed-oxide assemblies must be evaluated on a case-by-case basis?
Also line 3 "normaly" should be "normal". At the end of this
paragraph, the phrase "just as each new type. . ." could be
placed at the end of the second to last sentence, if this is the
actual intent. Third line from bottom change "basically11 to
"initially".
IV C-^ Last paragraph. The last paragraph refers to both 63 rods and 6^
rods in a BWR assembly. Actually there are 63 fuel bearing rods
plus one non-fuel bearing rod (water-hole rod).
IV C-8 Some figures (such as Figure IV C-A) are out of date and do not
match text discussion (e.g., Figure IV C-ll).
IV C-13 Paragraph 5. 100 tons - standard or metric? PWR core was expressed
in pounds. Also, this description applies to the design of only
one of three vendors.
IV C-20 Paragraph 2, line 8. Add "IV" before "C-15".
IV C-2*» Second sentence. The intent of the second sentence on this page is
unclear. Was 197^ used only to compute the values of isotopic
abundance shown in Table IV C-l? If so is this conservative or not?
IV C-28 Paragraph 2, 3-a. Suggest the following wording changes:
in line 2 change "changes are" to "differences is" and add
"which" after "isotope."
in 1 ine 3 change "and the" to "causes a".
At ,the gn, d pf 3• a• do "thermal-hydraulic consideration"
include fuel temperature, fission gas release, etc? If so the
statement is not accurate as discussed later in GESMO.
IV C-29 Paragraph 3. Should specify that Saxton and San Onofre were PWR's.
IV C~32 Paragraph 2. Is there an error in the f i rst sentence in the
second paragraph under Control Rod Worth, regarding the thermal flux
level being "only half"? It is certainly reduced but not by a
factor of two. The argument following this statement still stands,
however.
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Pacje
IV C-33 Paragraph 5. The fifth paragraph is weak since it implies a
difference between UCL and MOX. Could it be changed as follows:
"The worst-stuck-rod control requirement may be unchanged
and is affected by fuel loading patterns."?
Paragraph 7. The meaning of the last sentence in this paragraph
is unclear.
Paragraph 8, 1ine 2. Between "in" and "mixed" add "core containing",
IV C-3*» Line 5. In line 5 replace "necessity of" with "need for" since it
is difficult to imagine reducing a necessity.
Paragraph 3, 1ine 1. Change "effect" to "affect".
At the bottom of page are words "above in Chapter V" correct?
If Chapter V is the correct reference, "above" should be "below".
IV C-35 Why are Gd, Xe and Sm cross sections shown?
IV C-38 After first paragraph, there should be two conclusions. From
reading the text that follows it is not clear what they are.
Paragraph 2, line 3- Change "since" to "and as a result".
IV C-39 At the bottom ofr paae, change "is generally true" to "may be".
IV C-^3 Fi rst 1ine. Change "would" to "could". No evidence is provided
supporting this conclusion. Last sentence in second paragraph
is a preferred approach in this area also.
IV C-55 The statement that "these increases are largely offset by
the reduction in control. . .of mixed oxides" is not clear as
to meaning. What may be meant is that "these increases are
largely offset by the lower initial reactivity of mixed oxide
fuels."
What is meant by "the required volume of coolant becomes excessive"?
What is referred to at the end of the first paragraph; i.e.,
"beneficial effect" on what? ~ """""
IV C-58 Line 2. Change "results in" to "produces".
h., 1ine 2. add "is" after "natural uranium" and in 1ine 1
change "and" to "an".
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Page
IV C-59 Should another "bullet" be added stating to the effect that
"less experimental data is available for normalization"?
IV C-61 The next to last paragraph should be more fully explained.
IV C-6*» Label is missing on ordinate of graph (%M.O.).
IV C-71 Reference 1: ". . .The Big Rock Point. . .".
IV C-72 Item (6). Change "^reaction" to "Creation".
IV C-100 Paragraph 1. The syntax of the fi rst sentence is incorrect.
IV C-100 Paragraph 2. The syntax of the second sentence is incorrect.
IV C-10A Table IV C-22. The dose from direct and scattered radiation should
be "Total Body" rather than "GI Tract".
IV C-112 Table IV C-33- Heading should read Man-Rem/Year.
IV C-113 Paragraph 2. It is stated that "The most significant difference
in man-rem does occur as a result of water ingestion for river-
sited boiling water reactors." While water ingestion shows
the largest percentage change, differences in dose from other
exposure pathways are more significant, even though the percentage
change may be smaller.
IV C-113 Paragraph 5. First sentence should read "The transportation of
fresh fuel. . .".
IV C-11A Paragraph 2. A more typical effluent cleanup system should be
employed so that infant thyroid doses are typical of that normally
expected.
IV C-115 Paragraph 3. The statement that "At worst, some SGR fuels exhibit
as much as a 1k% increase in the iodine thyroid dose source. . .
more typically. . .a 10% increase" is not consistent with
Table IV C-3&, which shows a maximum increase of 8% and typically
no increase in iodine dose source.
IV C-116 Paragraph 1. The last sentence should refer to Table C~37.
IV C-117 Table IV C~37. This table is confusing because of the comparison
of different plutonium types at differing exposures. Are the
Pu-2 - 3 and Pu-1 - 2 cases selected for the calculation of the
element dose ratios the most limiting cases?
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Page
IV C-120 Table IV C-40 and IV C-^l. In view of the difference in inventory
ratios(Table IV C-37), why are the radiological consequences
of postulated accidents identical both with and without plutonium
recycle.
IV D Chapter IV-D assumes that glove-box type operations will continue
to be the design basis for MOX fabrication facilities. The
accuracy of this is questioned in that higher radiation and neutron
fields are anticipated in the future with the use of plutonium
containing higher percentages of the heavier isotopes.
IV D~3 GESMO assumes that eight fabrication plants are operated in 1990
while only five would be required. While there is likely to be
some overbuilding, the greater than 50% excess capacity seems large.
IV D~3 Paragraph 4. The 1990 release should be specified as the annua1
release. Do annual dose commitments include Beta dose from Pu-24l?
IV D-l» Are Beta doses included?
IV D-6 Paragraph 1. The enrichment of PuO- fuel may be greater than 5%,
and the diluent may be depleted or slightly enriched uranium
rather than natural DO..
IV D~9 Paragraph 6. The production of M0_ fuel rods by a combination of
chemical and mechanical operations would seem to be independent
of the installation of equipment at reprocessing plants to convert
plutonium nitrate to a solid.
IV D-13 Paragraph 3- Depleted or slightly enriched uranium may also be used
in place of natural U0?.
IV D-17 Paragraph k. Enrichment of PuO» may be greater than 5%- The first
sentence should read ". . .enough fuel for about 25 reactors
operating at the VI5% SGR loading.
IV D-20 Paragraph 5. Slightly enriched uranium may also be employed.
IV D-21 Paragraph 2. Error in syntax.
IV D-26 Paragraph 2. Proven technology may exist for solidifying Purex
wastes, but AEC burial and transportation requirements have not
been formulated.
IV D-26 Paragraph 7. 9 x lo"6 yC_i_ H/sec
IV D-31 Paragraph 2. Isn't 1 rem/yr used in the AEC for interpreting
"as-low-as practicable" limits for personnel exposure?
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Page
IV 0-32 Paragraph 6. What is the basis for estimating airborne releases
of plutonium? Why are releases expressed in alpha curies
only; 30-50% of dose- from LWR plutonium comes from beta of Pu-2^1.
IV D-33 Table IV D-8 also indicates alpha curies only. Do estimated
doses include beta effects of Pu-2^1?
IV D-37 Fabrication of MOX fuel may require some operations in remotely-
operated eel 1s.
IV D-38 Is the beta dose included in Table IV D-11?
_Q
IV D-39 Paragraph 2. The value stated for filter efficiency (10 ) is in
error; This is the transmission factor. The basis or reference
for this value should be indicated.
IV D-39 Paragraph 1. Basis for filtration efficiency and air loading
should be given.
IV E-2 Paragraph 1. Specify "Annual requirements in the year. . .".
IV E-5 The paragraphs on reprocessing facilities are outdated and should
be revised.
IV £-7 Paragraph 3. Mixer-settlers are used extensively; centri fuga1
mixer-settlers aren't.
IV E-l'j, It appears that iodine removal should be discussed. Iodine
15.16 removal is indicated in Figure IV E-6.
IV E-16 Paragraph 2. Last statement unclear; throughput instead of
throughout?
IV E-25 Table IV E-12. The annual dose commitments appear to be high
compared to similar numbers in earlier environmental statement
submittals and the EPA Environmental Analysis Report, EPA-520/
9-73-003D.
IV E-26 Paragraph *t. What is the basis for the statement "the isotopic
composition of uranium isotopes is somewhat less biologically
hazardous with Pu recycle than without. . ."?
IV E~30 Paragraph 1. Why is the critical!ty excursion 10 times worse
in fuel reprocessing than in the fabrication process (10 vs.
10^° fissions)? No justification is given for the difference.
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Page
IV E-31 Paragraph 2. Syntax error in second sentence.
IV F-2 Paragraph 2. What is the basis for the statement "These values
(9 and 11 % reduction in uranium mining and enrichment demand)
are significantly less than the theoretical 15% reduction
in uranium consumption. . ."?
IV F-6 U,0g Costs in Table IV F-3 should be $/lb. Although the
footnote of Table IV f~3 notes that these costs are the costs
at which uranium could be produced, rather than the sales price,
greater emphasis should be given to this distinction since the
sales price may be 50-100% higher.
IV F-15 Paragraph 1. The decrease in facilities (175 underground mines
and 13 open pit nines) is not consistent with Table IV F-k
(total decrease of 180 facilities).
IV F-29 Paragraph fr. ". . .studied including: (1) Phase. . . .".
IV F~32 Table IV F-6. Are the total electrical power needs for added
capacity supplied by gas centrifuge plants in addition to or
in place of the requirements for gaseous diffusion plants.
Why aren't the "Aneeds" for diffusion and centrifuge
plants in the ratio of ten assumed in the basis given in the
footnote?
IV F-33 Paragraph 7. The reference to Table IV F~5 is incorrect; the
reference should beto TableIV V-6 or 7-The minimum range of
electrical energy required (75 million megawatt hours) seems
low and cannot be obtained from either Table IV F-6 or 7- The
quoted values of coal consumption (^4.8 and 39-9 million metric
tons without and with recycle respectively) are not consistent
with Table IV F-?.-
IV F-3A Paragraph *t. The next to last sentence should read "Small
radiological releases from the diffusion complexes, consisting
only of uranium and uranium daughter products, . . .".
IV F-36 Paragraph 1. The quoted reduction of particulates and oxides
of nitrogen by about 65,000 metric tonnes each is not consistent
with Table IV F-? which shows a 50,000 MT reduction. The 1.6%
reduction in chemical effluents is not consistent with the 1.5%
redaction in coal combustion quoted on page IV F-35-
IV F(A)-1 The total for no Pu recycle of the water discharged to ground
should read 108,000.
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Page
IV G~9 Paragraph 6. Depleted or slightly enriched uranium may also
be employed.
IV G-10 Table IV G~3 shows a 30% increase in dose to transport
workers and a k~l% increase in dose to the general public
for transportation of PuO- to storage with Pu recycle;
in view of the order of magnitude reduction of the quantity
of plutonium going into storage, this increase seems
unl i kely.
IV G-12 paragraph k. Depleted or slightSy enriched uranium may also
be employed.
IV G-13 Paragraph 3- Since the reduction of transportation steps prior
to uranium fuel fabrication could have easily been factored into
the analysis, why was this conservative simplification made.
IV G-23 Paragraphs *t and 5. Depleted or slightly enriched uranium
may also be employed.
IV G-24 Alpha waste associated with obsolete equipment or decommiss ioni ng-
related rubble (masonry, structurals, etc.) which will not fit
into drums will have to be specially crated and sealed to prevent
dispersal of radioactivity. This type of container may be unsuitable
for ultimate disposal, but will be required for many years of interim
operations.
IV G-30 Une fr, Paragraph 2 should include sorption, followed by shipment to a
central facility for incineration, and chemical destruction of
organic bulk followed by recovery of Pu from residues or burial.
IV G-39 A more comprehensive analysis of risk may show that PuO? shipments
in certain areas can be safeguarded more effectively by point-to-
point aircraft shipment, using either rotary or fixed-wing
equipment rather than by road shipment. This statement is made
with full recognition of recent federal legislation to ban all
aircraft shipments of Pu.
IV G-42 Fi rst sentence. Modify to show dose if half of fuel shipments
are made by truck.
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Page
IV G-^ Performance of PuO- (and Pu nitrate) shipping containers during
transportation accidents should reference more recent papers by
U.S. (BNWL) and French (CEA) authors, in Sessions 12A and 11 of
the Fourth International Symposium on Packaging and Transportation
of Radioactive Materials (Sept. 22-27) 197^- AEC-sponsored
work at BNWL showed that the Pu transportation risks are three orders
magnitude less than for meteorite hits, if current-day fireproof
packaging is used. Prior evaluations should be re-ranked and these
new findings be incorporated in Table IV-G-9 to give proper
perspective to the low risk of shipping Pu nitrate (if correctly
packaged). Overseas processors are expected to continue shipping
Pu nitrate because of equivalency of risk compared to PuO_. See
author's final manuscripts as presented at September 22-2/ meeting
in addition to CONF-7^0991.
IV G-^8 Actual data on package closure from an AEC-sponsored survey should
be referenced and used. See reference above.
IV G~5^ In paragraph 3-, use of qualitative phrases such as "very small",
"highly unlikely", etc. should be supplanted by probability ranges
like 10^ to 10.7 per year where assessments have already been published.
IV G-51* I tern (e), Paragraph 1, last sentence should say "oxide or other
form shown to be of equal or lower safeguards and transportation
risk". AEC criteria for oxide vs. nitrate shipment need to be
re-examined in the light of recent findings coupled with safeguards
i mpa c t.
IV G-55 Accident risk statements, such as last sentence of item f.
are not sufficient unless the phrase "in the vicinity of"
are made clear by example. Isotope dispersal by waterways from
a "major impact" site could be geographi ca.l ly far-reaching.
Also amplify results of local confinement and cleanup opportunities
if a "major impact" accident occurs.
IV G-56 Last paragraph under "Routing". The railroad associations have
passed recent regulations and recommendations which affect the
routing of rail cask trains. These details should be explained
in the GESMO if AEC and industry perceive them to be long-lasting
and relevant to the routing issue.
IV G-59 Line k suggests rewording as follows:. . ."assemblies, and limit the
shipment of separated plutonium to only that quantity which is
needed to balance the manufacturing loads (peak and valley effects)
within the network of fabrication and reprocessing facilities."
Delete statement referring to "elimination of need to ship
separated Pu" because this idealistic condition could not be
maintained at all times. Even if idealized IFCF siting could
be achieved in 20 years, the transition period would require
interplant shipment of plutonium.
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Page
IV H-2 Paragraph I — insertion in line k "to increase the total
transuranium alpha activity sent to burial by a factor of five.
Emphasis in subsequent statements should be on safe long-term
alpha management, not just on heat generation and handling.
IV H-2 Paragraph k and IV H-10, Paragraph 5- In order to keep the volume
down to estimated levels in GESMO report, current proposed AEC
rulemaking must be changed to redefine exempt low-level alpha
wastes by a new operationally-acceptable criterion (a) because
10 nanocurie per gram level is not practical to measure and
administer and (b) because AEC recommendation to include all
waste generated in "controlled areas" would inflate the burial
volume and cost out of proportion to the benefit, especially
considering $100 per cu. ft., projection for transportation
and long-term management.
IV H-3 60 megacurie difference in hull burial is explained on Page IV H-20,
but long-lived alpha buried with hulls changes in opposite
dirrection from activation products, therefore, actinide curie
comparison should be given in separate line.
IV H-4 No explanation is given for the maximum credible accident and
why it involves only one waste canister. This section is too brief.
The accident safety issues are not adequately covered.
IV H-15 Table IV H-3 should show separate subtotals for long-lived alpha
and beta activity.
IV H-21 Footnote-''" should be reworded to state the end result required,
i.e., quantitative Teachability and devitrification stability
of "glass" and then discuss generic aspects of one or more
preferred solidification process routes, rather than deferring
the analysis.
IV H-41 See note on IV H-21, also. The conversion to glass would require
opening and emptying of the RSSF canisters or total fusion of
canister plus contents. Discarded canisters disposal is not
menti oned,
In last paragraphand on Page IV H-^2, line 6, statements on
shielding at RSSF do not seem consistent with high neutron and gamma
streaming in storage cask configuration shown on Page IV H~36.
A different air duct configuration would be needed to reduce
surface dose to 2 mr/hr.
IV H-^3 Paragraph 5 "milligrams" and "mi 11icuries" require specific
definitions. If this level of alpha release is meant, then it
is high relative to MOX fabrication plant normal stack release.
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IV H-^6 What is the environmental effect of meltdown in a canister? Can
& J»7 the discharges be controlled. Which concept for RSSF is the
safest. Which is most tamper-proof and fail-safe? Such
sondierations when left to the imagination of the public reader,
are likely to lead to confusion.
Statements made in WASH-1539 "Environmental Statement - Management
of Commercial High Level and Transuranium-Contaminated Radioactive
Waste" page 2.5"2 indicate that RSSF design includes protection
against man-made intervention, assumed to mean with malicious
intent. What is actually provided to prevent dispersal by sabotage?
IV H-57 The concept of storing all plutonium waste at remote RSSF's with
central incinerators should consider at least one eastern site-
to serve the fuel fabrication and reprocessing operations in this
region of the U.S.
IV H~59 Last paragraph. Volume reduction should be changed to 3 to k
because field experience survey shows secondary scrap generation
(filters, refractory, etc.) affects net volume reduction, especially
with incineration.
IV H-61 Paragraph 1. Rationale for considering only remote desert region
is not clear for Pu waste RSSF.
IV \-k Suggest deleting paragraph 3 in its entirety since soft gamma
contribution from Am-2^1i s a minor factor, considering that the
new generation of fabrication plants have no choice except to
be well-shielded and the Am-24l problem will be taken in stride.
IV 1-5 Line 1. After critical!ty prevention add "high accuracy inventory
measurements for safeguards compliance".
MIC Change the word "when" to "if" in line 1 of the last paragraph.
IV 1-6 The storage inventory without recycle should be changed
to show buildup starting in 1978 net 1976 since there will
be no reprocessing carryout until about 1978.
IV J-6 Improvements in control of occupational exposure during
uranium mining and milling have not been listed as to effect
on fifty year dose commitment. This information should be
added for balance. Likewise, the impact of several inadvertent
releases from reprocessing plants or mixed oxide fabrication
plants have not been assessed and .listed in the fifty year dose
commi tment.
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Page
IV J-7 Item C, Line 7. Plutonium fallout of 320 kilocuries ratioed
to the area of the United States should be given in addition
to the worldwide fallout.
Paragraph *t. After reference 2 the text should indicate
an analysis by C. R. Richmond which was published in 197^
following the Second Annual Life Sciences Symposium at
Los Alamos during May.
IV J-16 Transportation accidents should be included in this table.
IV j(a)-4 Most resuspenslon data have been based on experiments in arid
terrain. There is a lack of useful data in heavily vegetated
areas such as the Middle Atlantic Region. Resuspension data
with uranium shown on Page IV J(a)-6 may indeed be conservative
but considering that the bulk of the population is located
in the eastern half of the country, more realistic data
should be made available.
IV J(c)-7 \tern 2. 197^ publication by C. R. Richmond, LASL, should
be listed as a primary reference since it deals with the
hot particle problem.
IV J(c)~9~ The text is silent as to the toxicity of plutonium when combined
17 with uranium in a mixed oxide compound. To date there have been
no studies on the radiotoxicity of various mixtures of plutonium
with uranium. Although only a small percentage perhaps 5-15% of
the total tonnage of mixed oxide being processed in the year
1990 represent solid solution mixed oxide in the finely divided
processing stages, if this combined form followed a pathway which
resulted in adverse effects in regard to either bone or other
critical organs, it should be identified at an earlier enough
date to appropriately adjust the models. To our knowledge
there are no animal experiments currently funded in the United
States which will evaluate the effect of the mixed oxide particle
itself. Uranium and plutonium would be expected to
disproportionate in the body fluids and the results may be
more complex to interpret and apply than for PuO-7 or other
100% plutonium compounds.
V-6 Second paragraph. Improved statistical treatments should probably
be included as one of the means of improving safeguards systems.
V-6 Last paragraph. While it is stated that "a early evaluation
of tne concept is necessary" GESMO should recognize that the
decision is already late. One manufacturer is currently faced
with siting a mixed oxide fuel plant requiring "large capital
investments" for which considerable engineering has been done.
Perhaps there should be an acknowledgment that earlier plants
may not be co-located, but that as the industry matures co-location
v-ould improve the overall safeguards. This would put the concept
i.'ito proper perspective; it should, not be a "go--no go" situation.
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V-7 Section 6. This does not appear to acknowledge the considerably
increased difficulty of making fuel with "spiked" plutonium.
V-28 Bottom of page. Here and in other sections of the GESMO the
entire approach seems to be based on hardened manufacturing
facilities. It would be highly beneficial (and probably
a necessity) to address the problem of existing facilities.
V~39 Last paragraph. A similar listing of the disadvantages would
seem to put things in better balance.
V-J*0 Paragraph 3. The weight of shipping containers for LWR plutonium
oxide will probably range from 2500 to 5000 pounds due to
shielding and confinement requirements.
V-^l Last paragraph. Some estimate of the probable costs of these
systems would be appropriate.
V-AA Paragraph 6. This approach (incomplete separation) is not
consistent with previous statements which imply conversion would
have to be done at the reprocessor due to the ban on plutonium
solution shipment.
V-kk Paragraph J. The implication is that only additional shielding
is required for fabrication of spiked fuel. In fact, entire
new processes would have to be designed and QA activities would
be greatly complicated. It is entirely conceivable that there
may be..no practical way to fabricate fuel under these conditions.
V-l»5 Paragraph 1. It seems much more likely that the fuel fabricator
would be more concerned with health effects than a bomb builder.
The population exposure as related to manufacturing personnel
should be taken into consideration.
V-^5 Paragraph 2. An increase in fabrication cost of $500/kilogram
(wh i ch isprobably not at all unrealistic) would likely render
plutonium recycle uneconomic. Also, the effects decreasing fuel
reliability (consequently enhancing population exposure due to
fuel failures) because of decreases in the effectiveness of the
quality assurance programs is not addressed.
VII-2 Paragraph 1. The lead sentence indicates that not all differentia'
effects are adverse. However, the discussion is limited to only
those effects which are adverse to plutonium recycle. Although
such an approach is undoubtedly conservative, it serves to
weaken the overall impact statement in that it fails to identify
both favorable and adverse effects. It is believed this chapter
should be expanded to identify both the favorable and adverse
unavoidable environmental effects assignable to plutonium recycle
as they differ from uranium fuel.
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Page
VI1-12 Paragraph 4. This indicates "additional measure to further limit
any adverse effects may be possible. . .". However, the specific
need for implementation of each approach is not justified
in the report. Such quantification is believed essential for the
final impact statement. Specifically, citing criteria for
recycle plutonium facilities, guidelines on "as low as practical"
releases for the facilities, improved safeguards, additional spent
fuel shipment cask safety design criteria, long term waste
management criteria, and possibly other items must be prudently
developed and established prior to the accurate assignment of cost benefits
to the various alternatives considered.
VI1-14 Paragraph 6. The meaning of "action levels" is unclear.
VI1-15 Last paragraph. "Fuel melt down" probably refers to clad melting.
VI I 1-8 Paragraph k. Spent fuel transportation plus reprocessing cost
of approximately $35/kilogram are undoubtedly too low.
VII 1-13 Paragraph 3- Under the alternative of reprocessing spent fuel
immediately and storing for later use, the build-up of Am in the
recovered plutonium during storage and its associated impact
seems to be ignored. Americium builds up in the recovered products
through the decay of ^Ipu and in turn decays with a very strong
alpha emission. The concentration of americium in the stored
plutonium is dependent on the elapsed time since reprocessing and
the isotppic concentration of 2^1pu in the plutonium. Typical
plutonium recovered from reprocessing LWR fuel which is stored
much in .excess of one year prior to fabrication no longer can
meet the current industry's specifications on americium concentration
for recovered plutonium. The presence of americium in the plutonium
and its associated strong alpha emission, imposes a significant
radiological handling problem to the mixed oxide fabricator.
Consequently, the heed for chemical separation of the americium
from the plutonium is required prior to mixed oxide fabrication.
The major disadvantages of this additional separation step are:
(1) the production of additional plutonium bearing
wa s te.
(2) the potential of introducing additional chemical
impurities in the plutonium effluent.
(3) the need to reconstitute the plutonium back to
its original oxide form for either shipping or
uranium blending requirements.
(k) the major economic impact of the additional
separation step.
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VI11-13 When assessing this alternative in the final impact statement,
(Cont'd) both the cost benefit analysis and the environmental consequences
of this additional requirement should be considered.
VI 11-16 Paragraph 3- The use of depleted uranium as a carrier for
the plutonium should be addressed. Utilization of tails
assay materials, currently an unused waste from the uranium
enriching process, should result in the significant benefits
to this alternative.
•VI I I-16 Paragraph ^. This alternative would also have the same potential
benefits of using depleted uranium as a carrier.
VI I 1-1? Paragraph 2. Alternative 6 seems to be discussed in paragraph i.
not j.
VI I 1-21 Paragraph 1. A mixed oxide cost of twice uranium fuel fabrication
is probably too low even considering current regulations, and
is likely to increase rather than decrease as additional regulations
are implemented. A cost of three times uranium fuel, over the
entire time period (a surcharge of two times) should be subject
to less argument. (The recent public bid openings at TVA
and LADWP provide more concrete information on current pricing.)
VI 11-21
CtllU UMLJWr (JIUVIUC IIIUI C UUIIUI C LC I II I Ul Hid L I UH Ull <~UI I dl I. pill.
Paragraph 2. The $35/kilogram number for reprocessing and
spent fuel transportation needs to be updated.
VI I 1-33 Paragraph A. The long term plutonium storage costs appear
to be exceedingly low. The reason for this is not immediately
clear and is recommended that the bases for the estimates
be further explained.
VI Il~37 There is some question as to the reasonableness of the estimated
value of plutonium. Perhaps AEC could indicate the basis on
which these estimates were made. Also, it would be desirable
to include a statement on the sensitivity to a plus or minus
change of $l/gram.
VIII-A8 Paragraph 2. See comments under VI 11-21, Paragraph 1.
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VI I 1-65 Paragraph 1. The unit costs of separative work, U,0o, and other
factors used in the calculation of plutonium value need to be
reviewed and revised to correspond with recent changes in the
industry. Refer to other comments related to unit costs, escalation,
and sensitivity to a plus or minus range when estimates are used.
VII1-65 Paragraph 2. The fabrication cost differentia] discussed in this
paragraph does not relate to earlier parts of the GESMO that
mention up to $500/Kg increase for safeguards concepts, such as
spiking the plutonium. It would be desirable to track all
cost-related items through the entire report to assure
cons is tency.
VI I 1-69 Section C. This paragraph is confusing. It is suggested that it
be rewritten to relate more closely with the other paragraphs
discussing integrated fuel cycle facilities.
VI I 1-73 Sect!on D. The cost to protect against theft of fresh fuel and
the cost of additional hardening of barriers against theft of
plutonium, each estimated at $1,000,000 for each reprocessing
plant and for each mixed oxide fuel fabrication plant, is suspect.
It is suggested that the discussion be expanded to indicate how
these figures were derived.
VI I 1-75 Section N. The first sentence of this paragraph is not consistent
with earlier parts of the GESMO, which indicated that costs would
more than double when using "spiked" plutonium. It is suggested
that the report be reviewed for consistency in matters of this sort.
XI - The capital cost of facilities generally looks low. Since the
General major contributor to the benefits of Alternatives 3 and ^ are the
savings in investment in Enrichment and Mining-Milling facilities,
this modification will not affect the results.
One item open to question is the capital investment needed at
a nuclear power plant to receive, store, and use Pu recycle fuel.
It is not clear where this has been included. If one assumes
it could add $5 million to the cost of each reactor recycling
plutonium, the added costs to reactors is $600 million. If this
figure is appropriate, the impact is small but is indicative of
hidden costs which may need to be further investigated as
licensing regulations evolve. Credibility of the report will
be enhanced if all such cost items are identified.
XI-22 The cone 1 usion paragraph, should be expanded to discuss
the apparent inability of the nuclear industry to get
reprocessing and manufacturing facilities constructed.
The problem areas should be outlined.
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Page
Xl-2lf Table XI-10. The 1990 $12.83 figure for the U Og price in the
terms of unescalated 197^ dollars is low and will distort the
economic comparisons. This is indicative of the low cost
numbers used in the report. It is recognized that there has
been a dramatic increase in costs related to various components
in the fuel cycle during this last year. For this reasons,
all cost numbers and related economics should be updated.
XI-29 Table X I- 1 1 . The previous comment also applies to this table.
the report need to be update
ty of the economic conclusions.
.
All U,OQ cost projections used in the report need to be updated
in oraer to enhance the credibili
Paragraph 3. Please expand the discussion to point out why the
plutonium storage facilities would be similar to high-level
waste disposal facilities.
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ATTACHMENT A
Examples of Overconservatism in Dose Calculations^
1. The use of the semi-infinite cloud model for gamma dose may
approach being correct at some great distance from the point of
release, but it is not correct at distance of usual interest.
The resulting degree of conservatism depends on whether the
release is from a stack, a roof vent, or a lower elevation. The
correct model to use is the finite cloud gamma model.
(p. IV J-(A)-2)
2. The X/Q values used are based on ground level release assumptions.
Recent tests have shown that roof vent diffusion is much better
than previously assumed by the AEC. (p. IV C-95)
3. The submersion total body dose from noble gases calculation
was applied to Gl tract, thyroid and bone. The revised
Appendix I (2/20/7*0 does not apply submersion dose to
Individual organs. (p. IV C-103)
k. Details of iodine inhalation dose calculations are not evident and
need to be reviewed. They apparently include assumption of out-door
exposure at fence post all year. (p. IV C-103)
5. The iodine milk doses include all the overestimates which were
shown to be objectionable at the ALAP hearings, namely
(p. IV C-103):
a. Iodine chemical form-overestimate by a factor of 2
b. Roof vent diffusion-overestimate by factor of 10
c. High Iodine deposition factor-overestimate by factor of 2
d. High transfer; grass to milk, overestimate by factor of 2
e. Assumption of fence post cow and baby factor of 2 to 100
depending on actual cow location and milk usage. (The
AEC abandoned fence post cow concept on 2/20/74.)
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Atomic Industrial Forum, Inc. Attachment 3 Of 4
Public Affairs and
Information Program
128
SAFEGUARDS-THE INDUSTRY'S ROLE AND VIEWS
Carl Walske
President
Atomic Industrial Forum, Inc.
The U.S. nuclear industry, or nuclear energy community—whatever we may call it—consists of hundreds of compa-
nies and other organizations interested in commercial applications of nuclear energy. Most, if not all, of them are
members of the Atomic Industrial Forum—some 625 as of today. Their opinions naturally vary on any issue which
affects the development of nuclear energy, though oftentimes there is a general consensus view. So it is with the
matter of safeguarding nuclear material of weapons grade—or special nuclear material.
While the Forum has not polled its membership on safeguards questions we on the staff have had a number of discus-
sions with a good sample of responsible people from our member organizations. These include people from fuel
reprocessors and fabricators, utilities, reactor manufacturers and transportation companies. On the basis of these dis-
cussions I have some feeling for what "the industry" is thinking about safeguards. As I talk I shall also mix in my
own views, identifying them where they may be special to my own experience.
First of all, the industry is proud of the record to date. There have been no diversions. There has been no sabotage.
There have been a few cranks, or other malicious persons, who have made threats. Most of these, unfortunately,
probably were inspired by the publicity which has been given the subiect. In the view of many of us, the publicity
was unfortunate, but that's water over the dam now and we have to deal with the situation as it is.
I said that the record to date is perfect and that's true. Of course, the quantities of plutomum and highly enriched
uranium handled in the industry have been mimscule by comparison with what lies ahead as we move toward the
eighties. The industry knows this and fully appreciates that strengthened controls are necessary to deal with the large
amounts of special nuclear materials which we anticipate.
Now, is it possible to protect special nuclear material sufficiently so that reasonable people will agree that any risk
from diversion or sabotage is negligible' I believe that it it and at a cost which, although high, need not be so high as
to cripple the economics of nuclear power.
The current safeguards system, as spelled out in new AEC regulations, is a clearly strengthened one as compared to
what we had just a year ago. I believe it goes a long way towards what we need. At the same time there are certain
aspects of this safeguards system which can be further improved. Some are appropriate to the industry's area of
responsibility, some to the government's area. The balance of this paper discusses these possible improvements. They
are, I believe, supported generally by the nuclear industry
I shall be talking about the security personnel with the special nuclear material, physical protection, accounting and
monitoring of special nuclear material m plants, communications, the command function, reinforcements and intelli-
gence information All these are necessary and complementary in building a first-class protective system for any-
thing—whether it's gold bullion or special nuclear materials. They are necessary for special nuclear material at a fixed
installation or in transit.
Guard forces and physical protection with special nuclear material can provide a first line of defense. It is not neces-
sary that this line be impregnable, provided it is backed up with a reliable communications system which can be used
to call up adequate reinforcements from a friendly command. Accounting for and monitoring of special nuclear
material, ideally on a current basis, can signal departures from normal conditions, that is, sound a warning that some-
thing has gone wrong. Intelligence information, when available, is even better; it can signal in advance that something
is about to go wrong.
Let's talk now about guard forces. First of all, most people in the industry would prefer to manage their own, other
things being equal, but there is a problem. AEC regulations call for the use of armed force, if necessary, to prevent
diversion or sabotage of special nuclear materials. In my own view this is appropriate, but in the civilian nuclear
industry it is essentially unprecedented. It brings with it a responsibility beyond the experience of most commercial
organizations and one which threatens with a morass of legal liabilities. However, there is a compromise on the ques-
tion of who should provide and manage guard forces. The compromise approach is to divide functions between those
requiring the use of armed forces and all others. The former should be performed by governmental forces; the latter
by security personnel directed by the company responsible for the special nuclear material.
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For example, at fixed installations, monitoring and searching, if necessary, of plant personnel; materials accounting
and monitoring; and maintenance and testing of physical security systems can all be done perfectly well by personnel
under the plant management. In fact, they can be done with less upset to plant operations and to plant personnel-
insiders dealing with insiders.
However, should the situation call for the use, or threatened use, of firearms to deal with a security problem-
attempted diversion or sabotage—properly authorized public law enforcement forces should be brought into play.
Such forces may be stationed at or near the fixed installation, or they may be on call from their normal station near-
by. Obviously, they must be in a position where they can provide a timely reaction. For most fixed installations
local police units may prove to be the most satisfactory.
Guards accompanying special nuclear material in transit must be able to meet force with force. Local police forces,
in general, will not be able to respond rapidly enough to deal with attempted diversion and sabotage. Largely for
this reason many in the industry feel that such guards must be under governmental control and must be authorized
to act in emergencies under governmental orders. This might be done by using a special, governmentally organized
force, or by civilian guards under contract to the government.
In all cases—material at fixed installations or in transit—guard forces should be well trained and required to exceed
minimum physical and mental qualifications. They should be requalified by government inspectors on a periodic
basis. Most importantly, guards should be given clearly defined authorities to govern their actions in the various
emergency situations that could arise.
Physical protection of special nuclear material may include fences, lighting, vaults, and detection and alarm systems
at fixed installations; and for material in transit it may include heavy containers or armored vehicles. These comple-
ment the assigned guard personnel. In general, the industry has accepted and agreed with AEC requirements for
physical protection. There should, however, be a continuing review of these requirements, on the one hand, to see
that no "Achilles' heels" are left in the protection systems and, on the other hand, to eliminate costly features which
make only marginal additions to security.
AEC regulations currently permit shipment of special nuclear material—as defined in 10 CFR Part 73—either m a
conventional truck with an armed escort vehicle manned by two armed guards, or in a specially designed truck or
trailer without an armed escort. The design of such a special truck or trailer must include a capability for immobili-
zation of the vehicle and must provide armor and other deterents to physical penetration. In a properly designed
overall protective system the deterence to physical penetration will allow sufficient time for reinforcements to
arrive at the scene of a diversion attempt.
In general, the industry is sympathetic with the armored vehicle approach when it is applied to special nuclear mate-
rials in a sensitive form suited to easy movement and direct usage in nuclear explosives, that is, separated highly
enriched uranium or plutonium in the metallic or oxide form. However, when either of these fuels is contained in a
fabricated fuel element, they are awkward to transport and they must be separated chemically or physically in order
to be used as ingredients in a nuclear explosive. Thus, the industry's feeling is that for truck shipments of separated
or concentrated special nuclear material, we should phase over, as practical, to the use of the armored vehicles. Until
this is achieved and while conventional trucks are still in use, I believe that more than one armed escort vehicle
should accompany shipments and each escort vehicle should have at least two armed guards.
Shipments by air, where possible, can generally be made the most secure. I noticed recently that the JCAE's Conway
Committee has recommended against plutonium shipments by air, except in cases involving national security. This
appears to me to be unfortunate. The risk of extensive aerial dispersion in a plane crash is certainly minimal. Careful
choice of flight paths and special packaging could reduce even this small risk. It seems to me wrong to give up our
most secure means of transporting plutonium.
Shipments abroad of special nuclear material must provide for adequate protection until a shipment is safely in the
hands of its intended recipient. It goes without saying that precautions must be taken against hijacking and also that
recipients must be capable of protecting material in their custody.
Reliable personnel are an absolute must if we are to have good security. Although security-type clearances are for-
eign to the civilian industry, nevertheless a clearance program appears appropriate. It would apply to all personnel
having access to significant quantities of special nuclear materials. The AEC has now obtained legislation necessary
for such a program. I believe the industry, in general, understands the need for this and supports it.
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Such personnel clearances should certainly reduce the concern of those—such as the author of the Rosenbaum
report—who postulate that "insiders", including senior management and operating personnel working within a facil-
ity or transportation company, could be involved in sabotage or diversion.
Furthermore, such cleared employees of licensees need be searched only exceptionally on entering or leaving protec-
ted areas containing special nuclear materials. Monitoring with instruments should suffice, with spot check searches
only infrequently. As I said earlier, any such physical monitoring or searching should be the responsibility of person-
nel employed by the plant management.
At the same time I must say that security-type clearances are not to be taken lightly. It is most important that our
society carefully preserve the rights of its members. Security clearances can obviously be abused. It will be up to all
of us to guard vigilantly against any such abuse.
Much effort and much expense have gone into accounting and monitoring systems for special nuclear materials "in
process" in a plant. Presently available techniques suffer from two great faults: First, their accuracy is such as to
leave sizeable quantities of special nuclear material in a doubtful status; and, second, they report on losses only after
they have happened, not as they are happening. All the same, the industry generally supports the rational application
of the present techniques. There is, however, a strong feeling that it is illogical to incur greatly increased costs by
shutting down plants frequently for overall inventories and by reducing allowed inaccuracies beyond what is straight-
forward. Unfortunately, the answers from the present system will be inaccurate, whatever the effort expended.
Therefore it is sensible to use the present system only for what it is capable of doing—that is, detecting gross losses
or diversions.
Beyond the present system, we may hope to have real time and accurate accounting someday. I don't know how
achievable this may be, but it is certainly the right objective. Even now we can use special precautions whenever
there are inter-area transfers at a plant. These could include independent weighings, checks of seal integrity, and
other routine accounting actions and measuring actions to aid in the prompt detection of diversion.
Let us turn now to the question of communication systems. As I said earlier such systems serve the purpose of per-
mitting local guard forces at a fixed installation or with a shipment to call for assistance, that is, to call for reinforce-
ments. Obviously, such a purpose will only be met if the communications are highly reliable and if reinforcement
forces are available for timely reaction from authorities having such forces at their disposal.
The AEC presently requires a licensee to maintain communications between his so-called control point and the guard
forces at his installation or with shipments containing special nuclear materials. Carriers must make advance arrange-
ments to assure support from law enforcement agencies. For shipments the present system relies on (1) the use of
radio-telephones which are not effective in large areas of the United States, although they are working well in pres-
ent operating areas; (2) local or state law enforcement agencies for reinforcements; and (3) support arrangements as
can be made between such law enforcement agencies and the licensee.
There are several important improvements that should be made to the present system. First, the communications
should be based on a federally operated, high frequency network. Such a network has proven highly reliable in main-
taining radio contact with virtually all areas of the U.S. Second, a federal command center, perhaps supported by
regional centers, should be established. It would receive and act promptly on reports of attempted diversion or sabo-
tage involving special nuclear materials. Such a communications system and command center would be for both
fixed installations and shipments.
The federal agency responsible for operating the federal command center should be responsible for consummating
agreements with local and state police, the national guard and federal armed forces for provision of reinforcements.
As mentioned previously, effective local law enforcement agencies are particularly well suited for responding rapidly
to incidents at fixed facilities. Generally, state and federal forces will be more effective for incidents affecting mate-
rial in transit. The agreements will certainly involve state governors for state police and the national guard; they will
involve the President for federal armed forces. New legislation may be necessary to implement these arrangements. It
is my impression that this area of federal communications, a federal command center and authority and implement-
ing agreements, is the single most important task facing us as we move to improve the protective system. You will
note that this, as I have presented it, is a task requiring the initiative and leadership of the federal government.
A special type of reinforcement capability would be needed if a diversion attempt were to prove successful, that is, if
a diverter were to escape the first line of defense. In this event retrieval of the special nuclear material would be our
objective. A retrieval operation would logically use nationwide intelligence information and therefore would best be
handled by using a federal force under federal direction. This might be basically an FBI operation under the Attor-
ney General.
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Intelligence information available to the FBI. Treasury Department, CIA, Department of Defense, AEC, and state
and local law enforcement agencies will never be sufficient to forecast all threats that may be developing. However,
the totality of information available to these agencies can be very helpful in reducing risks. It is not clear to me that
a good mechanism now exists for the prompt reporting of such information to a central, responsible command
authority of the type previously mentioned and, also, the prompt dessemination of such information to law enforce-
ment agencies. If it is not being done well, as I suspect, it should be corrected.
I have discussed a number of improvements that would strengthen our present safeguards system. The major new
tasks are in the area of governmental responsibility, although I have mentioned some additional tasks for the indus-
try. These would not, in my view, involve an appreciable increase in present safeguards costs. In fact, the AEC's new
regulations—in effect since December 6, 1973, and now being implemented—went a long way to provide the neces-
sary measures required of the industry
As we look on ahead to the future, the nuclear industry will continue to work with the AEC to employ more strin-
gent methods and procedures. Safeguards cannot be static as the nature of the problem changes. Both industry and
government must move forward together to meet their vital responsibilities in this area.
My main points in this paper, aimed at strengthening our safeguards system are, I believe, generally acceptable to the
nuclear industry. These points are:
1. Local guard forces and physical security measures should be sufficient to detect, report and delay attempted sabo-
tage or diversion until reinforcements arrive.
2. Guard and security forces at fixed installations should be under the supervision of the plant management, except for
those guards charged with the use of armed force. These last should be governmental forces, or at least governmen-
tally organized and supervised guards.
3. Guards accompanying special nuclear material in transit should be under governmental control and should be author-
ized to act under governmental orders in emergencies. They may, thus, be government employees or contract guards
under government orders.
4. Moreover the federal government should be directly and fully responsible for security of special nuclear materials in
transit, coordinating and making use of local, state and federal resources.
5. For shipments of concentrated special nuclear material phasing over of conventional truck transportation should be
undertaken, as practical, to the use of armored vehicles with immobilizing features. The design of the transport
vehicle should include a strong barrier against penetration, which will allow sufficient time for reinforcements to
arrive.
6. Physical protective features for special nuclear materials should complement guard forces in such a way that no
"Achilles' heels" are left, but also so that costly features providing marginal additions to security are eliminated.
7. Agreements should be consummated, as necessary, between the responsible federal agency and local, state and feder-
al officials for the prompt use of their forces when necessary. These agreements should include arrangements for op-
erations by a federal retrieval force and for exchanging threat information with law enforcement and other agencies.
8. A federal communication system and command center should be created to support and coordinate the response of
local, state and federal security forces in the event of attempted sabotage or diversion attempts at fixed installations
or during transport.
9. Improved real time accounting procedures should be developed and implemented, at which time the dependence on
MUF and LEMUF for detection of diversion should be greatly reduced.
10. An employee clearance program should be established for licensee personnel who have accesss to significant quanti-
ties of special nuclear material.
I regret that adequate safeguards require so much government involvement, particularly by the federal government.
It would certainly be preferable if the industry could handle this problem entirely "in-house". Unfortunately, that
does not seem to be a practical way to reach our objective of providing proper protection to special nuclear materi-
als. We must, it appears, proceed with an industry-government partnership with each carrying out its role where it
can do the best job.
In conclusion, I want to re-emphasize that the nuclear industry recognizes the importance of protecting nuclear facil-
ities and special nuclear materials at fixed sites and in transit We are confident that potential risks will be held at
such a low level that they will be acceptable in the judgment of reasonable people.
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Attachment 4 of 4
Ad Hoc Plutonium Recycle Task Force
of tha
Nuclear Fuel Cycle Services Committee
D, R. da Ha I as (Chairman)
Emanuel Gordon (Secretary)
Richard L. Booth
Colin S. Caldweli
Bernard H. Cherry
Joseph Cupo
George Darmohray
Christopher Fowler
Rudolph Grubo
William Macnabb
Harvey Price
Raymond Robinson
Norton Shapiro
Thomas Snead
Wailaco Sumner
Robert TalIman
William Utnage
Albert Watson
The Babcock 4 Wllcox Corcpany
Atomic Industrial Forum
Nuclear Fuel Services, Inc.
Nuclear Materials 4 Equipment Co.
General Public Utilities Service Corp.
Westlnghouse Electric Corp.
General Electric Co.
Al Hod-General Muclear Services
Yankee Atomic Electric Company
NUS Corporation
Atomic Industrial Forum
Exxon Nuclear Company
Combustion Engineering, Inc.
Duko Power Company
Allied-General Nuclear Services
Bonnevllle Power Administration
Kerr-McGee Nuclear Corporation
Carolina Power 4 Light Company
10/28/74
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I wonder if the members of the Atomic Industrial Forum would care
to come up to the front, and perhaps we could ask the questions from
up here. It would be much easier.
I have a few questions I would like to ask.
Dr. Sagan, I am impressed with your emissions tax proposal. One
of the questions I had as I understood it, you said in a sparsely popu-
lated area, a tax would be different from what it would be in a densely
populated area.
Would this in some way imply an inequity in the risk to the
population? Would there be more material going out?
Dr. Sagan: I think there should be some balance between the
risk to the individuals and total risk to the population.
The way I would visualize that, and I must admit I have not given
great thought to how this would be implemented, I would suppose that
one would begin by estimating a dollar cost per man-rem. This is done
many times for radiation as a whole.
I would guess that that dollar cost per man-rem for plutonium
exposure would be less than for total body exposure. That is to say,
the estimates for total body exposure range from $10.00 up to $500.00.
I would think the man-rem cost for plutonium would be lower than
that, simply because fewer organs are exposed. Then, what I am
suggesting in my talk is that that cost, whatever might be arrived at,
might then be adjusted upwards or downwards depending on how many
people were exposed to such a plutonium release.
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For example, if that release were in the middle of New York City,
I would think there should be greater penalties attached to it than if
it were released in the center of the Nevada Desert.
Dr. Mills: Thank you. I have a question for Dr. Goldman.
Many times it is proposed that we put our radiation standard into
perspective. We often use the perspective of natural background.
Would you care to comment on how you visualize this perspective
being put to use; that is, are we really talking about natural back-
ground rather than a threshold level for an effect, or are we talking
about proposing releases in addition to natural background, that these
releases are so small that they are within the noise level and therefore
the effects are simply indistinguishable from the normal occurrence?
I am just trying to seek your comments as to how you visualize
this.
Dr. Goldman: If I understand your question correctly, I introduced
the topic of natural background just to remind us that it is composed
of a variety of radiations, including alpha emitting particles with
varying propensity to become diffused.
We do not start out with zero. I do not believe that on the basis
of laboratory information I have seen that there are radiation effects
derived from background. That is really beyond biomedical science,
that minor differences in radiation background could produce effects.
The reason for this is in the bulk of the radionuclide studies
that I have been familiar with, it is only when one gets to factors of
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a thousand times above background, something like three to ten thousand
times the background radiation rate, with animal experimentation that
I have seen, be it a linear or sigmoidal or threshold type of response,
that I have seen increases in the effects under study.
I do not know whether we will ever be able to quantify, whether
what I have said is 3,000 or 10,000. I am merely saying that on
the basis of my assessment, that is the kind of thing I see.
In the case of things like radium, or perhaps even plutonium,
the dose rate to the critical organ gets up into the range of hundreds
of millirem per day, to find whatever quality factor you want, to get
from rads to rems, but it is at that point that the biomedical effects
data start to arise.
What is rather fascinating is one need only go another order of
magnitude higher when you get complete 100% type effects. When one
gets beyond that, we get into wasted radiation and inefficient utili-
zation, computing risks and all that.
My concern has been to concentrate on that region. These effects
wander between the 80 percent and 5 percent level of effect. I think
we can learn much about the nature of response for radionuclides where
the dose rate is rather low, although the cumulative total may appear
large.
It would appear that something akin to what Mr. Parker said with
regard to a signoidal type response exists.
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I think what I am trying to say is that I do not believe there is
a risk associated with the levels of radiation that we call natural
background.
Dr. Mills: But you would agree that any assessment, any models we
use to assess the effects of plutonium, that those same models there
is no uniqueness to plutonium toxicity, should be used in the assess-
ment of what natural background might contribute?
Dr. Goldman: You are then asking me to say that some fraction of
the background health effects might be attributed to the contribution
from background radiation.
If there were a magnet that could eliminate background at the
spontaneous rate of condition A, B or C, that might be reduced. Is
that the sense of your question?
Dr. Mills: No. I am not really asking you that. What I am saying
is, in terms of putting radiation in perspective, we have viewed that
quite often, would you agree that models that one uses to make the
assessment, those radionuclides which are added to the environment,
that those same models, where they are compatible — would those same
models be used for the naturally occurring radionuclides?
Dr. Goldman: I think that is one approach, yes.
Dr. Garner: Would you agree, this procedure would be fine for
comparative purposes. Maybe you would not agree if you were talking
about absolute risk. Would that be a distinction in this use of models
for natural background?
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Dr. Goldman: I feel a bit more comfortable in considering things
on a relative scale rather than on an absolute scale.
Dr. Garner: I have a question. I do not know quite to whom to
address it. It is the question of plutonium recycling.
I would like to try to find out, if some one of you can answer
it, to what extent this recycling would reduce the amount of the pre-
sent risk. One of the major concerns of the general public is, of
course, the hazard from long term storage of waste which we are told
will be dangerous for millions of years.
If in some way we could reduce the amounts of this hazardous
material present in waste, I should think we should try.
Is plutonium recycling, or the efficiency of recycling of a
transuranic, is it going to be effective in reducing the amount
present in the waste to be diposed of?
Mr. Deuster: If one reprocesses, which is what you are presuming,
the normal reprocessing plant will remove about 99 percent of the plu-
tonium from, the fuel. There is something like a half of one percent
to one percent of plutonium that was originally in the spent fuel
that does go with the high level waste when they are separated.
All of the plutonium, then, that is separated will be recycled
back into the reactor. Thus, that will be taken out of the waste
stream.
In other words, if you did not reprocess spent fuel and you
elected to store or dispose of spent fuel, then all the plutonium
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would remain in that spent fuel assembly.
Dr. Garner: Yes. The question I am asking is, you said it would
be economical to recycle plutonium. Is this economy such that there
are better separations techniques in trying to extract plutonium in
recyclable materials; disposing of them with a fission problem, because
we know there is much more of a problem with storing of fission pro-
ducts than with transuranics.
Mr. Deuster: We have no plans to improve on the extraction process.
I believe the extraction efficiency of plutonium from the spent fuel in
our facility is essentially the same as that for the other facility
that is expecting to go into commercial operation, the Allied General
Nuclear Services Facility.
I do not know whether Dr. Wolfe is still here, but I believe
the efficiency of the plan for Morris operation was similar to that
of West Valley.
Dr. Garner: So it makes very little difference?
Mr. Deuster: I am not a chemical engineer. But the discussions
I have had on this particular subject are such that, yes, it is possible
to improve on that abstraction efficiency by some small amount, perhaps
a half percent, by redesign of a plan to add another separation stage,
perhaps take it down to a .2 percent, but this is still a rather small
change and, on an economic basis, unjustified.
Dr. Garner: I have another question to address to Dr. Goldman.
I would agree with you until a few moments ago that the main health
hazard from plutonium was the question of suspended material. I think
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this is what you concentrated on.
Dr. Goldman: I did not say it was the main question. It is what
has gotten the greatest publicity.
Dr. Garner: In fact, aging material may become more biologically
available so that a very small percentage could be absorbed in the body
and might be increased by aging material. Would you like to comment on
that?
Dr. Goldman: As I said, I think there is going to be a profusion
of technical comments made on some of this by the people who actually
generated this type of data you are referring to.
I am a firm believer, though, in the fact that whether it be by
ingestion or inhalation, it is the absorbed radiation dose that is of
primary concern to me, and that the nature of the response in the
critical organ is not too disparately different.
If one wants to postulate on a linear scale what the environmental
consequences are on this, that, or the other, I in my own assessment
found it necessary to include a fraction that might be ingested rather
than inhaled. The fact that the intestinal tract is so efficient in
barring against the uptake of this has a conservatism built into it
that may not exist with respect to inhalation. So there are going to
be additional considerations there.
Dr. Garner: Following up this question, relating to Dr. Parker's
statement, when we talk about the transuranics we talk quite frequently
about plutonium, meaning plutonium 239 as being perhaps in some of our
minds the most toxic of these materials.
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To some, I believe that americium 241 is considered to be perhaps
the most toxic componant transuranic.
Would you like to comment on that?
Dr. Parker: Of the two, one would expect that the evaluation
of americium could well be. In selected isotopes of plutonium such as
239, we would make the point that what is our real definition of toxicity.
I found out the other day, as a health physicist, I do not really
know. I hope the agency knows.
Expressing things in terms of mass per gram of the contaminating
substance, as mentioned in the British reference that I quoted, the
transuranium elements are not even in the first 50 elements that you
could come up with as being toxic, on that very arbitrary basis.
What was the real toxicity, I do not know. 239 obviously is waste-
ful because if you had some cooperation in the body, you are going to
be dead with most of that staying in; so therefore, a clear waste of
radiation, looking at it from the enemy point of view.
So you want something that does its darndest while entirely within
the body. What that is in terms of the raw substances, I would hestitate
to say, only that it be looked at very carefully.
Dr. Garner: I entirely agree with the statement that you made
that we should review it from time to time. We fall into somewhat of
a trap, continually using the linear non-threshold model, perhaps in
a context it should not be used in.
Have you any solutions to offer if we abandon that model and start
looking at animal data and decide there is a threshold, sigmoid, or
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something of this kind?
What solutions shall I offer to my colleagues in the radiation
programs, for example, who are faced with predicting the long-term
consequences of exposure to these materials?
Dr. Parker: I would hope that the next stage, rather than having
to assume a linear relationship, as a prudent method, we would, say in
one decade from now, begin to have some data that would show a dose
relationship to effect as A times dose plus B times dose squared some-
thing of that nature, in which you never have a precise value, but a
reasonable estimate on what the values of A and B are.
Jumping the gun in terms of thinking that we know some of those,
for example, from some of the data in Dr. Chuck Mays, you would pro-
bably come to the conclusion that at the environmental level, which I
am assuming is very low, in activity scale you could safely say that
the nose count of alleged cancer death is lower by, say, a factor of
100 than is derived on the linear model.
I believe, sir, if we had that data in hand and I am sure we
do not have it today, this will be a real advance in comfort of what
you might ask others to accept at the very low levels involved in the
environment.
Is that responsive to your question?
Dr. Garner: Yes. It is responsive up to a point. You know as
well as I do that abandoning this popular model is opening an enormous
can of worms because we need to know the distribution, for example, of
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the population or what have you.
It is all very well to talk about a dose square model, but then
we have to know then exactly what these — but then, we would not go
into that.
Dr. Parker: I was not restricting this to plutonium. I have this
hope in mind for the broader analysis of dose.
Dr. Garner: I would like to end with one very short comment that
we should not talk ourselves into a state of complacency because, in
fact, we have seen nothing in human exposure to plutonium.
There are about half a million curies of plutonium around the
world. From tests, one could argue that we see nothing from this and
why bother. But we know quite well that —
Dr. Radford: I would like to follow up on this dose response. I
think Dr. Goldman made some statement to the effect that all the data
he had seen showed no effect until, you conceded, about 3,000 to
10,000 times the background rate. Is that a fair statement of what
you said?
Dr. Goldman: Yes, in terms of chronic radiation exposure. Dose
rate from internal emitters is difficult to handle in terms of a unit
dose, but rather one must keep in mind that it is a total dose derived
over a longer period of time than in most of the human experience that
has gone into the BEIR report.
In the case of animals, it has been over a decade, for example, a
dose rate to the organs under exposure for that particular nuclide.
You get up into the order of a hundred or more millirem per day,
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that is when I see an increase in the incidence of tumors in that
particular organ.
Dr. Radford: Let us deal with the dose of radium aspect first.
I want to make it plain I am only talking about alpha emitters from
here on out, only alpha emitters because these are essentially all
the transuranic elements that are of importance here.
I will get to the question of which one in a minute. With respect
to the effects of dose for rates of high radiation, what is your
thinking about whether this rate has any effects on the risk factor
for, say, cancer production?
Dr. Goldman: I feel that if the dose rate is sufficiently low
particulates, that biologically it seems reasonable to me that the
risk may not necessarily be unit proportional to that risk which might
be more easily derived from a higher dose rate of the same kind of
alpha particles, by virtue of the fact that — maybe it sounds a bit
simplistic — but biologic systems are very dynamic.
If a sufficient amount of time intervenes, and if the alpha
particles are sufficiently separated with respect to time as well as
space, it is entirely conceivable to me that the effectiveness of those
alpha particles is going to be far diminished over the kinds of data
which is more easily derived.
You are going to have very high doses. Sometimes you call them
incandescent experiments, in which very high levels do not permit what-
ever recovery or molecular repair events to occur. I can not really
quantify or define it on a molecular basis.
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Dr. Radford: Everything you seem to have said so far is just
kind of a cerebration of the process based on some sort of model.
Dr. Goldman: It is not based on any model. It is based on an
assessment of the response to radium, from alpha emitters, as well as
emitting gammas and betas, over the lifespan of a variety of animal
species, and when one corrects for the incident rate, the cause specific
incident rates, and the amount of radiation dose, the response curves
are not linear.
Dr. Radford: Which radium isotope are you talking about?
Dr. Goldman: 226, a long lived isotope which I think is more
germane to the question you are raising.
Dr. Radford: Would you agree that radium 226 exposure in man has
produced cancer when the radiation dose has been given over long periods
of time?
Dr. Goldman: I did not say it did not. I am saying the nature
of the response incurred is not linear, but even in the limited amount,
in the lives of humans, we see excess doses of radium over a century.
The current consensus is —
Dr. Radford: Are you quoting from the BEIR Report on that?
Dr. Goldman: I am quoting from the BEIR Report and some recent
reports from the Argonne National Laboratories and Center for
Radiobiology.
Dr. Radford: If I recall correctly, the BEIR Report said that
while the data appeared to show non-linear relationships, a linear
fit could not be ruled out. Is that a correct statement?
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Dr. Goldman: That is a correct statement, and I have added to
it the fact that when one adds animal experience to it, it is probably
one of the few radionuclides for which we have that bridge.
People keep telling about how one extrapolates from animal infor-
mation to human, that the nature of the response here does not vary
qualitatively. There are differences, of course, in the way one scales
time. The dose rate story that I told you about with respect to
animals is not inconsistent with the pattern one sees in the data
published in the BEIR Report, when one really connects data points
rather than putting a line to it.
Dr. Radford: Now about radium 224?
Dr. Goldman: Radium 224 is very short lived and may indeed have
a different dose distribution pattern, so one can not have low dose rate
radium 224 studies with a nuclide that only lasts for a portion of a
week.
Here one is dealing with what I consider acute radiation.
Dr. Radford: But it was shown by Mays and Speth that when the dose
was protracted, the same total radiation exposure was given over a pro-
jected period of time, there appeared to be a higher cancer rate than
when dose was given in relatively few injections.
Dr. Goldman: Then one has to make decisions about what kind of
model to follow; in view of the absence of specific knowledge as to
what happened, it would appear that the dose in terms of rads for the
radium 224, might have had a lot of what Mr. Parker or someone mentioned
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as wasted radiation in its effectiveness.
The difference between the 224 and the 226, if I recollect rightly,
is within a factor of about two or three.
Dr. Radford: In terms of mean rad dose, it is much more than that.
Dr. Goldman: The same level of effect. The radiation doses, I do
not think would have been different.
Dr. Radford: Do you recall what the lower dose received by any
individual who developed cancer from the radium 224 injection is?
Dr. Goldman: I think that is subject to quite a bit of a problem
in that the radiation estimate was retrofitted after the material had
decayed. If I recollect, as Mr. Parker said, some tens of rads.
Dr. Radford: What about the lung cancer production, say in a
mining population? How would you characterize the radiation exposure
under those circumstances? Again, I am talking now in terms of dose rate.
Dr. Goldman: In terms of dose rate, the products that have been
postulated to be responsbile for some of the excess lung cancer in these
miners, I guess, would consider to be a chronic or fractionating
exposure.
There may be some residual radionuclides in the lungs as well as
the alpha emissions from the gaseous products, but that is continuous.
I had some very serious problems with regard to quantifying that
epidemiological information.
In fact, this is probably a problem in much of epidemiology when
the dose is estimated. It is just that, just an estimation. It is not
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a measurement. I do not know whether the people who have been reported
to have this lung cancer had ever been mining, the conditions in which
they worked.
One could get an accurate estimate of their exposure level;
futhermore, it is my understanding that a goodly number of these people
were heavy cigarette smokers.
We do not know enough about the epidemiology of lung cancer to be
able to separate the role of their cigarette smoking history from the
number of tumors that have been ascribed soley to radiation.
So there is dilemma there, especially in view of the fact that few
non smokers have had comparable exposure. We do not know if such
cases occurred. We may be dealing with a chemical synergism, but then
again it is speculation as to model.
I have a problem in quantifying that.
Dr. Radford: To get that issue out of the way, the fact is that
a number of cancers are now appearing in non smokers. It is historical,
What about the miners in Newfoundland? Would you characterize
their dose estimate as inaccurate?
Dr. Goldman: I did not say inaccurate. I am just saying that one
has precision problems in real life that are sometimes eliminated when
one is in the laboratory, where there is specific control over all of
that.
It is the precision, when one gets down to these levels and the
small numbers of people involved, and the inaccuracies perhaps in the
dose, still leave these open to question.
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Dr. Radford: In essence, what you are saying is you do not believe
the estimates had been made by the investigators. Therefore, you cannot
really judge anything on the basis of this data. Is that essentially
what you are saying?
Dr. Goldman: No. That is not what I am saying.
I am saying the dosage data exists. I have no reason not to
accept it. It is the extrapolation beyond where the real data lies,
that I have difficulty with because of the problems.
I think they have done an admirable job in estimating dose, but
I know we have some problems, and especially in converting it down to
three orders of magnitude lower dose.
Dr. Radford: Apropos of the three orders of magnitude lower
dose, it seems to me one of the fundamental issues we are here to
discuss, whether in fact it is three orders of magnitude lower dose.
I would ask anyone on the panel to answer.
Would you agree with Dr. Bair and his colleagues that a single
*
alpha particle can be considered to have 500 rem exposure, one alpha
track, when ingraded over only that, that it passes through about 500
rems?
Dr. Goldman: That is a physically measurable quantity.
Dr. Radford: So the hot particle issue, isn't it, gentlemen,
that you have a single source of alpha radiation which when integrated
over the volume to which it is distributed may lead to hundreds of
thousands of rems, is that not over perhaps x period of time?
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Isn't that what we are here talking about? High dose effects
from a single particle?
Dr. Goldman: That is one part of the problem. I attempted to say
very superficially in my few remarks that on the basis of empirical
observation, using those types of particle that the animal experi-
mentation does not raise the order to a uniquely different risk. That
might be estimated on the basis of just adding up the number in that
microscopic volume.
When describing the alpha particle on the basis of just toxological
information, it is very unpractical to push this approach very far.
Dr. Radford: I would like to raise a couple of other questions.
I believe it was Mr. Parker who mentioned the U. S. Transuranium
Registry. Could you explain what that Registry is?
Dr. Parker: Yes, I would be glad to, Dr. Radford.
It is an operation that functions out of my headquarters in
Richland. It is currently operated by the Hanford Environmental Health
Foundation.
It briefly consists in an attempt to sign up those workers who
are presumably exposed to plutonium to permit access to autopsy
samples, prefereably as was done with many uranium cases, on whole
willed bodies in the hope that eventually from this source, by being
aware of the health conditions of these men and making presumably
eventually reliable determination of their residual plutonium, we will
get some real relationship between available plutonium in the body and
deleterious effects, whether they be cancer or otherwise.
-------
I would like, if I may, to go back parenthetically to Loren's
closing remark which I suppose Dr. Goldman and I both thought the other
was going to answer.
I am afraid the record will show that Dr. Garner brought up the
issue of saying I hope we are not complacent and it drew a total silence
from us.
I hope we are not complacent, too. None of our statements to you
this morning, gentlemen, reflect that. I think my personal emphasis
on the value of the Registry reflects that this is virtually the sole
logical source of human data.
I will perhaps say I am not a little suprised that we have not seen
deleterious effects among the some hundreds of workers who have measur-
able depositions of plutonium, which Dr. Garner says is always the
issue of latency.
But eventually, that has to disappear because some of the more
seriously exposed people were those in the early days of the project
when conditions were not as favorable as they are now.
Some 30 years have gone by and in another decade, we will know a
lot more. I do not want to project how the curve goes, but it is vital
to the nation, as I see it, Dr. Radford, to do the best we can to acquire
all the possible human data.
Dr. Radford: Apropos of just that point, you state that the
Registry is an attempt to sign up workers who have been exposed to
plutonium with particular emphasis, because you mentioned it in your
next sentence, on willing their bodies for whole body analysis.
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How many workers have you signed up so far?
Dr. Parker: I do not have that answer. I could ascertain it and
submit it for the record from the head of the Registry, or possibly from
some member of the Commission who may have it here.
I do not know the answer, sir.
Dr. Radford: Well, is it five?
Dr. Parker: No. It is more than that.
It is a number which varies very much between the principal sources
of which plutonium has been used. My basic familiarity has been with
the Hanford experience. I have no personal knowledge from memory of
numbers.
As I say, I can obtain these numbers very easily.
Dr. Radford: You said you were in charge of the Transuranium
Registry?
Dr. Parker: No, sir. I am a member, one undistinguished member
of a large advisory committee. If I were that, I would hope I would be
better informed, sir.
Dr. Radford: I want to come back to this time factor in terms
of exposure. I really think this is a general question that I hope
we can focus on and get out of the way once and for all.
It is somewhat germane to some of the points Dr. Garner made
earlier; that is, what elements are we talking about here?
Is there anyone in this group, for example, who knows what mix
of isotopes we are talking about? You mentioned, for example, mixed
isotopes. What isotopes?
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Dr. Parker: This is an engineering determination of the exposure.
We have to determine what fuels are going to be used in the next 20
years and determine what exposures are most advantageous. I think it
is rather elementary to work out those compositions.
I am suggesting my notes, which were made very brief, that you
could possibly pick two representative conditions. I had a report some
time ago with a similar theme which picks three. It depends on how
many dollars you want to put into different compositions.
A required number of compositions would lie somewhere between
two and infinity, if you had no limit of dollars to put into it.
Dr. Radford: Let us not get into the experimental design. I
just would like to know does anyone on this panel know which isotopes
we are talking about?
Mr. Deuster: The plutonium that is produced in the water reactors
varies on the reactor type. The PWR will produce a slightly different
composition than a BWR because of the spectrum in the reactor.
Typically, if we are reprocessing normally radiated fuel in the
range of 25,000 to 30,000 megawatt-days per ton, the plutonium 239
content would be perhaps around a 70 percentile.
Then, plutonium 240 and 241, and some 242; perhaps, 240 at 15
percent or 18 percent; 241 at nominal 10 percent; a percent or two of
242. Then when we mix that material with some uranium, it may be
natural uranium; it may be, some people propose using the tail uranium —
Dr. Radford: I was mainly concerned with the — But that is through
a fuel processing plant?
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Mr. Deuster: Typically, but it will vary.
Dr. Radford: Those are mass percentages, right.
Mr. Deuster: Yes. But they are not that accurate, in any case.
Dr. Parker: I can read three accurate compositions into the
record, if it will be helpful, or give it to you later.
Dr. Radford: No. I have the numbers. I am just trying to find
out whether we are talking about the same thing.
I am referring specifically to the ORNL report 4451 on Fuel
Reprocessing that gives as a topic, compositions as a function of
time after removal from the reactor for a 30 day holdup time for radio-
active decay and so on.
The significant point to me is that plutonium 238 is much higher in
concentration by activity. This is in the waste stream assuming 25
percent, so it comes up on an activity basis.
We are talking about, say, 300, I think, curies per ton throughput,
curies per metric ton; and plutonium 239, only 17.7 curies.
Now, are we talking about plutonium 238 or are we talking about
plutonium 239?
Mr. Deuster: The plutonium just comes out, and it is all mixed.
We have little control over what its isotopic content is.
Dr. Radford: But the dose rates from a single micron particle
of plutonium 238 is extremely irregular, from that of 239, is that
correct?
So in terms of dose rate influences, you need to know whether you
are talking about one or the other, or a mixture.
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Dr. Goldman: I think we were talking in terms of rads. That
does not require specifying any specific activity, sorting out particles.
I forget what the number is; I think it is something like 250 difference
in mass; the same activity between the 239 and 238 isotope.
But a microcurie is a microcurie. The energies of 238 and 239 are
essentially the same.
Dr. Radford: But when we were talking about radium 224, you
emphasized the rate distribution would be different from the radium 226.
I am suggesting simply the rate distribution would be different.
Dr. Goldman: There are very different magnitudes here. The
physical decay rate for 238 is eighty-eight years; for 239; it is some
24,000 years. The decay rate for radium 226 is intermediate 1600 years,
but that for the 224 relative to the life of a cell or tissue in man is
only measured in hours, 3.5 days, I believe.
There is a gross difference as far as the human body is concerned.
I might suggest that with regard to decay rates, the 238 and 239 are
essentially the same. Both of these are quite long relative to a
lifetime.
Dr. Radford: One final question on this, or two quick ones.
If you have a particle escaping from the fuel reprocessing program,
is it likely to be a mixture of plutonium isotopes as well perhaps of
americium, curium, maybe some Californium or would they be separated
in the reprocessing essentially?
Mr. Deuster: The transplutonics are separated from the plutonium
and they would go into the high level waste stream initially, so that
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if particulates evolved from the plant, they would naturally be from
plutonium or the mixed uranium plutonium parts.
Dr. Parker: May I elaborate on that? Some of them, however, will
grow in again whether you like it or not, so there will be americium
derived from each plutonium 241, nothing to be done about that once
you have left go of your actual separation process.
Dr. Radford: Of the transuranics that we are talking about here,
at least one of them anyway, and maybe more that you know about, have
spontaneous fission rates which are, while not high, still definite.
Is there any possibility that one could sequester a portion of the
fuel reprocessing, enough spontaneous fissions to give a neutron flux
that would be significant as far as inducing fission?
Mr. Deuster: Yes. That is one of the design factors taken into
account in a mixed oxide fuel fabrication facility.
It is also one of the factors taken into account in the design of
shipping costs, the neutron dose does evolve from spontaneous fission.
Dr. Mills: Let me ask for a comment from the NRDC? What is the
latest that you can get on? I know that you want to get on this morn-
ing, and we will try to do everything that we can.
So, will you bear with us? I apologize for having put you off.
Mr. Speth: I think we can postpone it until this afternoon, since
people are getting hungry.
Dr. Mills: In deference to you, Mr. Speth. perhaps we can put you
on now or within five minutes or wait until after lunch. I will leave
it to you.
I apologize for the delay. What is your preference?
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Mr. Speth: My preference is to go now.
Dr. Mills: Let me just get a couple of brief questions from
Dr. Taylor and Dr. First.
Dr. Taylor: What I have really is more of a comment than a
question.
As Dr. Parker mentioned, the desirability of a five year review
plan, the fact is standards for internal emitters have been under study
and review for the last 15 years.
They have come up with a new number every few years. Over this
length of time, the number has not fluctuated by more than a small
amount, less than one order of magnitude, 1 would say, as far as
I am aware.
Dr. Parker: I think that is only a partial answer, though,
Dr. Taylor. After all, the standards are characteristically found
wearing white hats. There are some legitimate responders in this who
are entered as wearing the black hats.
I believe very firmly their voice should be heard in these five
year reviews, is what I am saying. Until such time that we can
convince them that we were right, which of course we knew all the
time, but that is not the way this thing should be done.
Dr. Taylor: I do not disagree with that. My real point, though,
is as far as I am aware with whatever studies we have made on this,
we are not expecting to see anything more than an order of magnitude
off of where it has been for some time.
You suggested it might be a rational number in any case.
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Dr. Parker: Yes. I agree, but we have to reserve the right to
be wrong, since we do not know all the facts.
Dr. Taylor: I could not agree or disagree with you more.
Dr. First: I would like to clarify a couple of items in the
disucssion which we have had so far. We have heard a good deal of
talk about background values and also about plutonium and transuranic
exposure.
I have the impression, which may be quite wrong, and I would like
a comment, that we are comparing the dose of these particular materials
with general background radiation from all sources, and that we are
not saying specifically that the background that we are comparing
the exposures from processing, background respirable particles, is
this correct or incorrect?
Dr. Parker: Strangely enough, both.
Dr. First: Could you please straighten it out?
Dr. Parker: I think people do make comparisons with both. I
would say it is profitable to do so, in the intellectual sense;
possibly, that which pertains to alpha particle bearing substances
in the atmosphere being inevitably taken into the lung, is possibly
the more relevant for some of the species of arguments in which we
are involved here.
Let me relate that, in fact, to what you did not ask me, but asked
everybody else, about the lowest practicable level.
Let me say that if we are trying to reduce plutonium to the
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lowest practical level in the environment, this will increasingly
spiral the dollars from the millions to the billions.
At some stage, we could in theory improve the health of the
citizen of the United States more effectively by removing the natural
radiation.
People sit back and say we cannot do anything about that. It is
nonsense. All it happens to take is more money than we have, but there
is some stage at which it would be far more useful to attempt that than
take away the last plutonium atom, as I see it, sir.
Does that answer properly the question you had in mind?
Dr. First: I think it alerts me to ask this question. When we
start getting comparisons as the hearing goes on, to define it, but
your last comment brought me to another question which I had.
This relates, I believe, to Dr. Goldman's comments about the
weathering of plutonium particles in the environment. There was no
quantitative aspects in your comments. If these particles do weather,
what time scale are we talking about, and ultimately, can one derive
from such numbers a safe level of emission to the environment that we
can hope that natural processes will continue to keep up with the
depositions so that we will maintain a constant level?
Dr. Goldman: I think I am going to defer the specific quantifi-
cation on that to some people that I believe studied this more inten-
sively than I. I was speaking as a biologist. I leave the mysterious
ways of geology and atmospheric sciences.
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I was observing the increase of time. I am talking about decades
rather than days or weeks.
Dr. First: That is not going to be any help to me personally.
Dr. Goldman: It will be a help to somebody, that the material
appeared to migrate downward more deeply and aggregate in such a way
that the fraction per unit volume is biologically less potent.
Dr. First: I was thinking about geological time in the point I
was trying to get at.
Dr. Goldman: I think 1 am talking in terms of decades.
Dr. First: Perhaps another question I had, and I will try to
make this brief, is more up your line. Dr. Wolfe mentioned the fact
and I can quote him quite specifically, that he was interested in more
information on real pathways of plutonium.
We had a lot of comment from you and others concerning the fact
that animal data and man data should be quite comparable, and I thought
you said that we could depend, Dr. Parker, that we could depend quite
reliably on animal data.
Is this a difference of opinion here? Just how reliable are the
animal data to our human exposures?
Dr. Goldman: The real pathways can be described in fraction rate
quality of material from whatever the source is, say from the nostril
or intestinal tract, as it were.
That is my view of what the pathway situation is. What is real
or unreal about it may be the fact that we can not quantify over the
long time span, the exact contribution of the air borne suspension,
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water borne, dietary borne, the grow in of other nuclides.
We can model the consequences, though, of a given unit absorbed,
regardless of the pathway that it took to get there, whether it is a
skeletal dose; it could be the soluble fraction of that in the lung;
it could be something injected intravenously; or a fraction absorbed
through the intestinal tract.
The assessment is how much activity is there? How was it
distributed? And what kind of dose?
It is kind of an independent factor perhaps, in that sense, as
to what environmental impact it may have, part of the overall path.
Dr. First: I am not sure whether I understand whether you are
in agreement or disagreement with Dr. Wolfe on this point.
I am not trying to generate an argument between the two of you,
but I am confused by what appears to me to be a difference.
I get the impression that Dr. Wolfe is saying we do not know
enough about the real human pathways to be able to judge the situation
adequately.
Dr. Goldman: I do not disagree with what he said. I said that I
feel a lot more comfortable about the assessment. I guess as you pointed
out I feel qualitatively somewhat comfortable about the real pathways,
but I suspect from his point of view he would like greater quantification.
But I do not think we are in disagreement.
Dr. First: The question is do we have enough information to make
judgments? One never has enough information, obviously, to do all we
would like.
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Dr. Parker: I think an ultimate solution of the total ecological
web is really out of the question. It depends on our intelligence in
identifying the main signalling paths which in the case of plutonium all
seem to be rather small, compared with the experience we have had. Right
now, we certainly do not have enough data, 1 think, defined.
The volume by Dr. Stannard and colleagues has a chapter on the
environmental knowledge assessed at about two years, that defines
what it is.
From memory, I think he leaves off the chapter by saying we do
not know enough.
In the research field, you always have to say that or you would
not get money to work the next year, so that has to be put in its
proper place.
What we have today is the knowledge of something approximating
the knowledge of body burden that the United States population has
from weapons plutonium.
This has been analyzed by various groups, and the results are
in concord enough to give us that degree of transfer from which you
might want to speculate. You have a first order of approximation to
what may come from the nuclear industry as it increases its possible
burden decade by decade.
Dr. First: You think then that we know enough about the subject
at the present time to make standards relating to environmental
exposures, or do we have to wait for' a considerable body of new infor-
mation, which is what I gathered from Dr. Wolfe's comment?
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Dr. Parker: I have to give you what is a hedged, ambiguous
answer. I think we know as much about this as we do in many other
things in which we daily come forward with an alleged answer, and
we would be foolish if we did not continue our vigilance in trying
to prove that answer.
Dr. Mills: Let me suggest, if there are other questions for this
panel, could we write to you and elicity answers to those?
Thank you very much.
We will reconvene at 1:30.
Again, let me thank NRDC for their patience.
(Whereupon, at 12:40 p.m., the hearing in the above matter was
recessed, to reconvene at 1:30 the same day.)
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AFTERNOON SESSION
Dr. Mills: Perhaps we can reconvene.
To start off this afternoon, we have the Natural Resources Defense
Council, Dr. Cochran, Mr. Speth, and Dr. Tamplin.
Again, gentlemen, let me thank you for the patience you showed
this morning, for this extended period of time.
With that, I turn it over to you.
Mr. Speth: My name is Gus Speth. This is Tom Cochran, who will
speak after I do.
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1 C F
Natural Resources Defense Council, Inc.
mo N STREET, N.W.
WASHINGTON, D.C. 20036
202 783-5710
Palo Alia Offia New York Office
664 HAMILTON AVENUE 15 WEST 44th STREET
PALO ALTO, CALIF. 94301 NEW YORK. N.Y. 10036
415 327-1080 212 869-0150
NRDC Statement
at the
Environmental Protection Agency
Public Hearings
on
Plutonium and the Transuranium Elements
J. G. Speth
Arthur R. Tamplin
Thomas B. Cochran
December 10, 1974
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We appreciate the opportunity to participate in these hearings.
The nuclear industry's proposal to make plutonium into the principal
nuclear reactor fuel in the years ahead has implications for our
society that deserve the widest possible public airing. We hope
these hearings will contribute to that goal.
Our presentation will be in tv/o parts. Today we will discuss
briefly the basic issue of the acceptability of plutonium as a
commercial fuel. The key question here is whether the promised
benefits of proceeding into what the Atomic Energy Commission (AEC)
has called the "plutonium economy" are worth the tremendous risks
to the health and safety of the public associated with such a course.
We conclude, emphatically, that they are not.
Our presentation tomorrow will include a more detailed treat-
ment of the "hot particle issue" — the question whether minute,
insoluble particles of plutonium have uniquely high cancer-producing
potential. We raised this issue before the EPA and the AEC ten
months ago when we petitioned that the radiatio'n protection standards
applicable to plutonium and other hot particles be tightened by a
factor of about 100,000. Since our views on the hot particle issue
have been published and available for some time, we hope that at the
session tomorrow we can concentrate on responding to questions from
the panel and to issues raised in the testimony of other speakers.
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I. Introduction and Summary
First with the initiation of plutonium recycle and then with
the introduction of the fast breeder reactor, the AEC and the nuclear
industry hope to transform plutonium from its current status as a
troublesome by-product of the fission process into the principal fuel
for future nuclear power plants. If these plans are consummated, the
commercial plutonium industry at the turn of the century could involve
hundreds of reactors fueled with plutonium, a score of fuel reprocessing
and fabricating plants, and perhaps thousands of interstate and inter-
national shipments containing hundreds of tons of plutonium.
To appreciate the implications of having one of our most im-
portant industries based upon plutonium, certain characteristics
of the element must be understood. First, plutonium is one of the
most toxic respiratory carcinogens known. Lung burdens on the
order of one-millionth of a gram (the weight of a grain of pollen)
have been shown capable of producing lung cancer in animals with
virtual certainty. And one of the purposes of these hearings is
to shed light on whether plutonium is several orders of magnitude
more toxic than the AEC believed when it set current radiation ex-
posure standards. Concern is amplified by the fact that plutonium-
239, the principal isotope of the element, has a half-life of
24,000 years. Its radioactivity is undiminished within human time
scales.
Such considerations led the International Commission on Radio-
logical Protection to conclude that:
"in terms of amounts available, projected usage,
extent of anticipated accidental human exposure,
arid radiotoxicity, plutonium is the most formidable
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radionuclide in the periodic table."1
This ICRP statement addresses the toxicity of plutonium. But
Plutonium's toxicity is only part of the problem; the least of its
two evils many would suggest. An amount of plutonium the size of a
Softball is enough for a nuclear explosive capable of the destruction
we witnessed in Nagasaki. Scientists now widely recognize that the
design and manufacture of a crude nuclear explosive is no longer a
difficult task technically, the only real obstacle being the availa-
bility of the plutonium itself. The successful theft of this material
by organized crime or terrorists, as Willrich and Taylor note, "could
enable a small group to threaten the lives of many people, the social
order within a nation, and the security of the international community
of nations."
Given the facts about plutonium, the widespread reliance upon it
contemplated by the industry and the AEC would give rise to three
problems, each of the utmost gravity:
A major public health problem. As we move into
the plutonium economy, exposure of industry em-
ployees and members of the public to plutonium
will become increasingly widespread. Experiences
at existing plutonium facilities provide fright-
ening examples of what the future holds.
An unprecedented public safety problem. If
plutonium is permitted to become a major commercial
I/ ICRP Publication 19, The Metabolism of Compounds of Plutonium and
Other Actinides, Pergamon Press, New York,(1972), p.IT
2/ Willrich, Mason and Theodore B. Taylor, Nuclear Theft: Risks and
Safeguards, a Report to the Energy Policy Project of The Ford Founda-
tion, (Ballinger Publishing Co., Cambridge, Mass., (1974), p. 1.
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fuel, current realities are such that plutonium
will most likely be stolen, a plutonium black market
will most likely appear, illicit nuclear bombs will
most likely be made and used both here and abroad.
An intractable civil liberties problem. The drastic
nature of the nuclear terrorists' threat will be
used to justify a drastic police response. Exten-
sive intelligence gathering, security surveillance
measures will most likely become commonplace since
they are among the cheapest and easiest safeguards.
In sum, our judgment is that the proposed use of plutonium
as a commercial fuel would give rise to unprecedented social risks
and costs. We do not believe that a fully informed public would be
willing to accept these risks, certainly not in light of the uncon-
vincing benefits. Plutonium recycle, for example, would reduce
light water reactor fuel costs by about 10-15%. But fuel costs
represent less than 20% of the costs of nuclear power, and by 1985
nuclear power is expected to account for only about 15% of total
domestic energy. In other words, plutonium recycle involves an
economic savings of less than one-half of one percent.
In the longer term, the economic incentive to use plutonium may
become substantial but only if one assumes a high and sustained
reliance upon nuclear fission, a prospect which is increasingly
uncertain. Developments in solar, geothermal and fusion energy, in
more efficient and clean means of consuming fossil fuels and in
energy conservation generally suggest that alternatives to- prolonged
reliance upon increasingly controversial fission-based power do
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exist. A major part of the problem of assuring the timely availa-
bility of these alternatives to plutonium is the fact that the AEC's
fast breeder reactor development program continues to drain off a
major share of federal energy R&D funding. This is a classic case
of misplaced priorities.
It is imperative that our society develop the ability to say
no to technologies that are too risky and too demanding. We can
no longer assume that each new innovation accompanied by major finan-
cial backing should be permitted to proceed, even with regulation.
Some should simply be halted for the reason that their advantages
bear no reasonable relationship to the possibility of tremendous
social harm they present. The use of plutonium fuel falls into this
category. There is something fundamentally insane about the wide-
spread commercial use of a material which is both fiendishly toxic
and capable of being easily fashioned into atomic weapons.
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II. Dimensions of the Plutonium Economy
Plutonium is almost unknown in nature: the entire present-day
inventory is man-made, produced in nuclear reactors.^ Most of this
inventory has been used to construct nuclear weapons for national
defense purposes. Much lesser amounts have been used for civilian
reactor research and development.
The fuel currently used in present-day commercial reactors is
uranium. Unlike plutonium, this uranium fuel is not extremely toxic,
and it is not sufficiently rich in the fissionable isotope uranium-235
to be fashioned into nuclear weapons.^ While present-day reactors
are operating, however, they are also producing as a by-product
substantial amounts of plutonium, principally plutonium-239. A
typical large reactor produces about 200 to 250 kilograms (400 to
500 pounds) of plutonium each year. Since this plutonium is easily
fissioned, it can be used as reactor fuel.
Sometime in the coming year the new Nuclear Regulatory
Commission (NRC) will decide whether to authorize "plutonium recycle"
the use of this plutonium as a fuel in nuclear power plants around
the country. The AEC Regulatory staff (which will constitute the
.NRC staff when it is formed) has recently prepared a draft environ-
mental statement on plutonium recycle.^ Its view is that "plutonium
3_/ Plutonium occurs in nature but in such small amounts that it does
not constitute a practical source of the element. The ratio of the con-
centrations of plutonium-239 to uranium in ores varies from 4xlO~13 to
1.5xlO~H. Katz, J.J., Chapter IV, The Chemistry of Actinide Elements,
Methuen and Co., Ltd., London, (1957), pp. 239-330.
£/ Only with extremely sophisticated technology not available to the
public, notably gaseous diffusion or gas centrifuge plants, can uranium
be enriched to weapons grade.
5/ DRAFT GESMO: U.S. Atomic Energy Commission, "Draft Generic Environ-
mental Statement Mixed Oxide Fuel (Recycle Plutonium in Light Water-
Cooled Reactors)," WASH-1327 (August, 1974).
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171
recycle would result in a small reduction in the already negligible
radiological exposure to the general population from the present
LWR [light-water reactor] industry," that "plutonium can be adequately
safeguarded [from theft] in a plutonium recycle economy,"^ and there-
fore that plutonium recycle should be authorized. NRDC has taken
strong exception to the Regulatory staff's position in the appended
report, "The Plutonium Decision: A Report on the Risks of Plutonium
Recycle,"7 and in NRDC's additional comments on DRAFT GESMO.8
The next escalation in the availability of plutonium is projected
to come with the introduction of the fast breeder reactor. According
to the AEC's schedule the breeder reactor will replace today's
reactors after about 1990. The breeder reactor is designed to con-
vert uranium to plutonium faster than the plutonium is consumed as
fuel. In other words, the breeder reactor breeds more fuel than it
burns.
A nominal size (1000-megawatts) breeder will contain two to
four tons of plutonium at any given time. Annually, approximately
one-half this amount, one to two tons, will be removed for reprocessing
and will be circulated through the fuel cycle. The AEC has proposed
that we build between 1987 and 2020 some 2,200,000 megawatts of breeder
reactor capacity. Over the lifetimes of these plants, we can project
6/ AEC Regulatory Staff Response to Questions on Pu Recycle,
addressed to Senator Walter F. Mondale, signed by L. Manning Muntzing,
Director of Regulation, U.S. Atomic Energy Commission (7 October
1974), p. 1.
7/ Speth, J.G., A.R. Tamplin and T.B. Cochran, "The Plutonium
Decision: A Report on the Risks of Plutonium Recycle," Natural
Resources Defense Council, Washington, D. C. (September 1974),
printed in The Bulletin of the Atomic Scientists, Vol. XXX, No. 9,
(November 1974), pp. 15-22.
8/ These comments were submitted to the AEC on October 30, 1974.
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a cumulative flow of some 100,000 tons of plutonium through the nuclear
fuel cycle. This would correspond to about lO17 (100 billion billion)
lung cancer doses if the lower risk estimates are correct. One
hundred thousand tons of plutonium also corresponds to about 10
million atomic bombs of the size dropped on Nagasaki. We present
these numbers not as a procedure for calculating risk, but only
to show that the plutonium economy offers a potential for social
harm that is truly awesome.
In order to appreciate the significance of the plutonium economy
from a somewhat different perspective, we suggest that you consider
what the public response would be if our government leaders proposed
that we base our energy system on botulin toxin. There can be little
doubt that the public would be properly skeptical of an energy strategy
centered around using a biological warfare agent as a fuel in thou-
sands of plants, each containing several tons of this material and
each generating more of this material than it consumes. Certainly
one would hope that we would consider the "botulin breeder" only as
a last resort. However, an examination of our present energy
strategy demonstrates that with our fast breeder reactor program, we
are actively pursuing a course which in relevant respects closely
parallels the botulin breeder.
9/ For reference purposes the AEC has estimated that of the plu-
tonium activity released routinely, one can expect that one part
in 1Q5 to be inhaled into someone's lungs of which 15 to 25 percent
would be deposited in the deep respiratory tissue.
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III. The Present State of Affairs
Lest it be thought that our concerns are only for the future,
we turn now to the present state of affairs with respect to plutonium
safeguards and accidental exposures to plutonium.
A. Plutonium Safeguards
In the language of the nuclear industry, the various programs
and techniques to prevent nuclear theft and recover stolen nuclear
material are called "safeguards." There have been a series of
major studies on the adequacy of the present safeguards program
within the last year, including the study by Willrich and Taylor
for the Ford Foundation Energy Policy Project,^ the AEC's "Special
Safeguards Study" (the Rosenbaum Report),-'--'- and a series of reports
by the General Accounting Office.12 All of these have concluded
that our present safeguards program is totally inadequate. In fact,
the most disturbing routine releases from the nuclear power industry
are the continuous flows of documents pointing out the inadequacies
of our present safeguards program. The AEC's own Rosenbaum Report
states:
"Even though safeguard regulations have just been revised,
two factors have appeared in recent months which make
necessary a new and fundamental look at the problem.
10/ Willrich and Taylor, op. cit.
ll/ Rosenbaum, Dr. David M., et al., Special Safeguards Study, safe-
guards study made for the Atomic Energy Commission (1974), referred
to herein as the "Rosenbaum Report."
12/ U.S. General Accounting Office, Improvements Needed in the
Program for the Protection of Special Nuclear Material"! Report to
the Congress, B-164105 (November 7, 1973); Protecting~Special
Nuclear Material in Transit: Improvements Made in Existing Pro-
blems ,Report of the Joint Committee on Atomic Energy, B-164105
(April 12, 1974); and Letter Report on Security Systems at Com-
mercial Nuclear Power Plants, addressed to Dixy Lee Ray, Chairman,
USAEC and signed by Henry Eschwege, Director, Resources and Economic
Development Division, USGAO, B-164105 (October 16, 1974).
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The first of these is the widespread and increasing
dissemination of precise and accurate instructions on how
to make a nuclear weapon in your basement. While such
information may have always been available in the un-
classified literature it was masked by a great deal of
irrelevant and incorrect information, also readily avail-
able. There is a slow but continuing movement of
personnel into and out of the areas of weapons design
and manufacturing. These moves are sometimes forced
and can create very strong resentments in the people
involved. As a result, larger and larger numbers of
people with experience in processing special nuclear
materials and with varying psychological attitudes are
dispersed in the overall industrial community. In
addition, the psychological effect on terrorist groups
of widespread dissemination of such information should
not be overlooked.
"The second new factor is the recent start of political
kidnappings within the United States. It is our opinion
that the kidnapping of Patricia Hearst "does not represent
"an isolated and passing incident, but is rather the pre-
"cursor of a wave of such incidents. If not firmly and
competently met, these kidnappings may lead to a risk of
"urban terrorist groups in this country of a sort without
precedent in our history.These groups are likely to
have available to them the sort of technical knowledge
needed to use the now widely disseminated instructions
for processing fissile materials and for building a
nuclear weapon. They are also liable to be able to
carry out reasonably sophisticated attacks on installa-
tions and transportation. We believe these new factors
necessitate an immediate and far reaching change in the
way we conduct our safeguards programs."13
In "The Plutonium Decision" (appended hereto), we reviewed the
steps the AEC suggests might be taken to correct present safe-
guards inadequacies. We discussed why an "adequate" system of
safeguards may be impossible to achieve and why such a system
would probably be unacceptable. One of the recommendations of
the AEC's Rosenbaum Report gives us a flavor of the type of correc-
tive measures required of an adequate system:
13/ Rosenbaum, Dr. David M., et al., op. cit., pp. 2-3.
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"The Need for Better Intelligence"
"The first and one of the most important lines of
defense, against groups which might attempt to
illegally acquire special nuclear materials to make
a weapon, is timely and in-depth intelligence.
Such intelligence may involve electronic and other
means of surveillance, but its most important as-
pect is infiltration of the groups themselves. It
is not the AEC's business to conduct this sort of intel-
ligence, but it is the AEC's business to see that those
agencies of the United States Government which have
intelligence gathering responsibilities including the
FBI, CIA, and NSA, focus their attention upon this
particular threat to our national defense and security."
This is not the Houston Plan, rather it is part of the
"Blueprint for Plutonium Recycle."
In reply to a recent letter from Senators Mondale and
Hart questioning the wisdom of a commitment to plutonium recycle at
this time, the AEC's Director of Regulations wrote:15
"The AEC safeguards program has as its objective
achieving a level of protection against such acts
[as unauthorized possession and sabotage of nuclear
facilities] to insure against significant increases
in the overall risk of death, injury, or property
damage to the public from other causes beyond the
control of the individual." [emphasis added]
and elsewhere:
"... studies are required to determine the additional
specific safeguards measures or combinations thereof
that will be required to meet the Commission's safeguard
objective. Until these are completed the Commission
will not be in a position to judge the exact nature of the
measures that should be established to protect plutonium
and other special nuclear materials."
In other words, not only are the present safeguards inadequate,
the AEC staff has not even developed an adequate program on paper.
Moreover, the nuclear industry is not even complying with the
currently inadequate safeguards regulations. On October.31, 1974,
IV Ibid.
15/ Letter of Regulatory Staff Response to Questions on Pu Recycle,
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the AEC announced it was fining the General Electric Company
(plants at Vallecitos, California) and Nuclear Fuel Services (West
Valley facility) $12,500 and $4,000, respectively, for safeguards
violations involving failure to have required intrusion monitoring
and alarm systems and physical barriers to protect against industrial
sabotage. ^
B. Plutonium Exposure
Occupational as well as public exposure to plutonium' has already
become commonplace. Robert Gillette, in the first of a three part
series in Science, describes the present state of the industry:
"Increasingly, and with a frequency that seems
disproportionately high, incidents of plutonium
inhalation are being recorded from a small group
of privately owned and operated facilities en-
gaged not in weapons work but in reclaiming plu-
tonium from reactor fuel and recycling it in new
reactor fuel. . . .
"The record reveals a dismal repetition of leaks
in glove boxes; of inoperative radiation monitors;
of employees who failed to follow instructions; of
managers accused by the AEC of ineptness and failing
to provide safety supervision or training to employ-
ees; of numerous violations of federal regulations
and license requirements; of plutonium spills
tracked through corridors, and, in half a dozen
cases, beyond plant boundaries to automobiles,
homes, at least one restaurant, and in one in-
stance to a country sheriff's office in New Y
In recent months in two separate incidences production workers
have come to Washington to complain to AEC officials about the
health and safety practices at the fuel fabircation facilities
where they worked. These workers were accompanied by officials of
their union, the Oil, Chemical and Atomic Workers (OCAW) . The first
case involved a meeting on August 13, 1974, with workers from
16/ AEC News Releases, November 6, 1974, p. 2.
17/ Gillette, Robert, Science 185 (20 September 1974), pp. 1030-1031
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the Nuclear Fuel Services' (NFS) Erwin, Tennessee facility;18 the
second meeting on September 27, 1974, involved employees of Kerr-
McGee's Cimarron Facility near Crescent, Oklahoma.
The employees from the NFS-Erwin facility had five areas of
specific concern, the following three of which were verified by
1 q
subsequent AEC inspections.
0 The company has failed to reduce exposures to meet
the "as low as practicable" (ALAP) requirement expressed
in the AEC regulations.
0 The company has failed to provide adequate radiation
surveys.
0 The company has failed to perform adequate biological
monitoring, i.e., determination of uptake of radio-
active materials by workers.
18/ This facility i.s presently fabricating enriched uranium
fuel rods and has not fabricated any plutonium fuel in the
past 18 months. However, the allegations and subsequent
violations cited by the AEC involved practices occurring
both during and prior to the last 18 months.
19/ Internal memorandum to N.C. Moseley, Director, Region II from
John G. Davis, Deputy Director for Field Operations, "Allegations
Against NFS, Erwin — Meeting with OCAW Representatives," with
attached Note to Files, "Nuclear Fuel Services, Erwin, Tennessee,
License No. 70-143 -- Meeting with Representatives of the Oil,
Chemical, and Atomic Workers International Union," dated August 29,
1974.
Letter to Mr. William Manser, Jr., Plant Manager, Erwin,
Tennessee from N.C. Moseley, Director, Directorate of Regulatory
Operations, U.S. AEC [RO:II:FJL 70-143/74-01] dated October 11, 1974,
Letter to Mr. William Manser from N.C. Moseley, U.S. AEC
[RO:II:FJL 70-143/74-01] dated October 18, 1974.
Two allegations of willfulness were not verified but are still
indispute. These include: a) The company has failed to permit
OCAW representatives to accompany AEC inspectors as required by
10 CFR 19; and b) The company has failed to notify workers of
overexposures as required by AEC regulations.
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The following is a sample of the information presented in support
of the employee concerns cited above:
Failure of the company to meet ALAP.
0 Lunchrooms. The company provides two lunchrooms.
Workers are permitted to enter the lunchroom after
washing hands and donning shoe covers over shoes
worn in the production area. The clothing worn in
the production area is worn in the lunchroom. A
monitor is provided for use by the workers. The
sink provided for washing hands also is used to
wash parts from vending machines. Workers state
that these parts have shown contamination. One of
the lunchrooms is immediately adjacent to a production
area. A taped closed door serves as a wall. The
workers contend that radiation, i.e., radioactive
material, enters the lunchroom as evidenced by con-
tamination on food dispensing machines. The
workers state that up to 40,000 dpm have been
measured on a beverage vending machine. In excess
of 20,000 dpm were measured inside the machine.
Several vending machines were removed from service
and replaced because of contamination. The current
location of the machines was not known.
Failure to provide adequate radiation surveys.
0 With regard to surveys for removable contamination,
there are no instructions on how this is to be'done
and no established frequency for surveys.
-------
0 Previously, there had been routine surveys of
workers by health physics technicians. Those
no longer are performed.
A complete summary of the NFS-Erwin allegations is contained in an
AEC "Note to Files," dated August 29, 1974,20 which is appended
to our testimony. After investigating these allegations, the AEC
cited NFS for two licensing violations which required immediate
action and subsequently cited NFS for five licensing violations. ^~
The letters reflecting these citations are also appended here.
The employees from the Kerr-McGee Cimarron facility alleged
among other things that:
0 Employees were not educated as to the hazards of
plutonium. One employee, Karen Silkwood, related
that she had worked at the facility one and one-half
years before learning that pltuonium exposure could
cause cancer. She also said that she never received
a respirator that fit her face which was narrow,
although the company had promised to order her
respirator that fit over a year earlier.
0 Employees coming on board were often sent directly
to production work before receiving classroom health
20/ Internal memorandum to N.C. Moseley, Director, Region II from
Zlohn G. Davis, Deputy Director for Field Operations, "Allegations
Against NFS, Erwin — Meeting with OCAW Representatives," with
attached Note to Files, "Nuclear Fuel Services, Erwin, Tennessee,
License No. 70-143 —"Meeting with Representatives of the Oil,
Chemical, and Atomic Workers International Union," dated August 29,
1974.
21/ Letter to Mr. William Manser, Jr., Plant Manager, Erwin, Tennessee,
fTom N.C. Moseley, Director, Directorate of Regulatory Operations, U.
S. AEC [RO:II:FJL 70-143/74-01] dated October 11, 1974. Letter to
Mr. William Manser, Jr., Plant Manager, Erwin, Tennessee from
N.C. Moseley, Director, Directorate of Regulatory Operations,
U.S. AEC [RO:II:FJL 70-143/74-01] dated October 18, 1974, Enclosure 1.
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180
and safety training. One worker, unaware of the
hazards of plutonium exposure, was purportedly
badly contaminated, and quit work the next day
before he received any health and safety training.
o Production workers have been required to wear
respirators for an entire week due to high activity
air concentration levels (above MFC) in the pro-
duction area, the emphasis being on meeting produc-
tion schedules as opposed to locating the source
of contamination.
o Plutonium was stored in unapproved areas (e.g., desk
drawers).
o There was no routine procedure for changing filters
on respirators.
These are but some of the allegations still being investigated by
the AEC, and as of this date the AEG has not issued a report or
cited the company for licensing violations pertaining to these
allegations.
On November 7, 1974, some five weeks after meeting with the
AEC officials, Karen Silkwood, upon reporting to work at the Kerr-
McGee facility, was found to be externally contaminated with plu-
tonium. Plutonium alpha contamination levels up to several thou-
sand disintegrations per minute were found on her clothing and
body. Subsequently, her roommate, also a Kerr-McGee employee,
and their apartment were found to be contaminated. Isolated areas
22/ Directorate of Regulatory Operations Notification of an Incident
or Occurrence, at Facility: Kerr-McGee Nuclear Corporation -
Crescent, Oklahoma Cimarron Plutonium Facility, License No. SNM-1174
Docket No. 70-1193, dated 11/11/74, No. 134.
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181
of contamination ranging up to a few hundred thousand disintegra-
tions per minute were found in the kitchen, bathroom and bedroom
areas. 3 Less than two weeks later Ms. Silkwood was killed in an
automobile accident on the way to a meeting with a union official
and a New York Times reporter to provide background information in
support of an allegation that the facility was manufacturing
faulty plutonium fuel rods and falsifying q\iality assurance in-
spection reports. There have been several as yet unsubstantiated
allegations pertaining to this incident, including that her death
was the result of foul play, ^ and that she smuggled plutonium
0 ^
from the plant and deliberately contaminated herself. The entire
bizarre incident related to her exposure and death is still under
investigation. It is known from fecal and urine samples taken
when she was alive, and an autopsy after her deathf that Ms. Silkwood
ingested a very large amount of plutonium.
There have been several recent cases where members of the
public have inadvertently been exposed to plutonium. Moreover,
it is well known that the area east of the Rocky Flats plant in
Colorado is contaminated with plutonium. Recently the Environmental
Protection Agency indicated that cattle grazing in this area show
2V Ibid.
24/ The New York Times, November 19, 1974 and November 20, 1974.
2_5/ The Washington Post, December 8, 1974, p. A3. This same report
stated : "Kerr-McGee sources say their internal investigation has
determined that a fuel rod inspection report was falsified at least
20 times over the summer months by William Scott Dotter, a former
employee. That prompted a search by Kerr-McGee and Westinghouse
Corp., the contractor, for the affected rods, either in Oklahoma
or at Richland.
"Dotter says he did nothing deliberately, although he may have
included erroneous information in reports because he does not feel
he was adequately trained for the job."
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182
a high degree of plutonium in their lung.26 The implication of
this for humans in the area is obvious. These recent events follow
a history of serious public exposure and offsite contamination, in-
cluding but not limited to the exposure of Edward Gleason, a
?7
stevedore in a trucking terminal, the fire and explosion at Gulf-
United 's plutonium facility in Pawling, New York,28 the burnup of a
SNAP reactor over the Indian Ocean, plutonium found at the bottom
of the Erie Canal next to Mound Laboratory, and surface contamin-
ation near Palomares, Spain and Thule, Greenland resulting from
the non-nuclear detonation of strategic weapons.
Aside from highlighting the deplorable state of affairs presently
existing in the fledgling plutonium industry, these most recent
plutonium exposures are evidence of the need to take urgent action
to insure that the present radiation standards applicable to plu-
tonium exposure are adequate. This brings us to the final chapter
of our presentation — the adequacy of the present plutonium expo-
sure standards.
2t/ The Washington Post, December 6, 1974, p. 3.
27/ Tamplin, A.R. and T.B. Cochran, "Radiation Standards for Hot
Particles," op. cit., Appendix B.
28/ Gulf United Nuclear Fuels Corporation, "Report of Incident at
Gulf United1s Plutonium Facility at Pawling, New York," Elmsford,
New York (January 19, 1973).
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183
Hot Particle Petition
Beginning in 1969, the existing radiation exposure standards
came under strong public criticism. As a consequence, an Advisory
Committee on the Biological Effects of Ionizing Radiation (the
BEIR Committee) of the National Academy of Sciences was convened to
review the biological data on the effects of radiation as they relate
to the exposure standards. In November, 1972, three years after the
debate began, the committee issued its report and stated the existing
standards were unnecessarily high.^9 it is now two years later and
the EPA has not reduced these standards. While they may have serious-
ly considered this matter, and perhaps even performed some additional
studies, nevertheless the same discredited exposure standards are
in the Code of Federal Regulations.
It was ten months ago that NRDC petitioned the EPA and AEC
relative to the plutonium standards. Just recently EPA asked the
BEIR Committee of the NAS to study the question. If history repeats
itself, five years from now EPA will have done nothing about the
plutonium standards.
In the meanwhile, nuclear industry employees and members of the
public are being exposed to plutonium, many at or above the standards
we have urged. We would hope that one of the strong recommendations
of this panel is to tell EPA that it is time to take the steps that
are required. EPA has a strong ethical and legal obligation to take
action without delay on the hot particle issue. Given the immediacy
NAS-NRC, "The Effects on Populations of Exposure to Low Levels
of Ionizing Radiation," (BEIR Report), NAS-NRC, Washington, D.C.,
November, 1972.
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184
of the problem, the lapse of 10 months between the filing of our
petition and the initiation of these hearings and the National
Academy of Sciences review is simply deplorable.
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bulletin
OF THE ATOMIC SCIENTISTS
185
(Reprinted by permission of the Bulletin of the Atomic Scientists
and the authors. Copyright (c) by the Educational Foundation for
Nuclear Science.)'
Plutonium Recycle:
The Fateful Step
Impending move to reprocess fuel would escalate the risks of nuclear power
/ fear that when the history of this century is
written, that the greatest debacle of our nation
will be seen not to be our tragic Involvement in
Southeast Asia but our creation of vast armadas
of plutonium, whose safe containment will rep-
resent a major precondition for human survival,
not for a few decades or hundreds of years, but
for thousands of years more than human civili-
zation has so far existed.
James D. Watson
Nobel Laureate, Medicine
J. GUSTAVE SPETH, ARTHUR R. TAMPLIN
and THOMAS B. COCHRAN
The Atomic Energy Commission, if unchecked, is
about to sow the seeds of a national crisis. The Com-
mission now proposes to authorize the nuclear power
industry to proceed to use plutonium as fuel in com-
mercial nuclear reactors around the country. The re-
sult of a decision approving this commercial use of
plutonium will be the creation of a large civilian plu-
tonium industry and a dramatic escalation in the
risks posed by nuclear power.
This decision to launch what the AEC calls the
plutonium economy is the conclusion of the AEC's
recently released draft environmental impact state-
ment for plutonium recycle: the recycling of plutoni-
um as fuel in the present generation of light water
reactors [1,2]. The final version of the impact state-
ment, which is expected to confirm the decision to
authorize plutonium recycle, is due in a few months.
Plutonium is virtually unknown in nature; the en-
tire present-day inventory is man-made, produced in
nuclear reactors. Plutonium-239, the principal iso-
tope of this element, has a half-life of 24,000 years,
J. Gustaue Speth (attorney), Arthur R. Tamplin
(biophysicist) and Thomas B. Cochran (nuclear
physicist) are on the staff of the Natural Resources
Defense Council in Washington, D. C. Dr. Tamplin
is on leave of absence from the Lawrence Livermore
Laboratory of the University of California.
hence its radioactivity is undiminished within human
time scales. It is perhaps the most toxic substance
known. One millionth of a gram has been shown ca-
pable of producing cancer in animals [3]. Plutonium
is also the material from which nuclear weapons are
made. An amount the size of a Softball is enough
for a nuclear explosive capable of mass destruction.
Scientists now widely recognize that the design and
manufacture of a crude nuclear explosive is no longer
a difficult task technically, the only real obstacle
being the availability of the plutonium itself [4].
We believe that the commercialization of plutoni-
um will place an intolerable strain on our society
and its institutions. Our unrelenting nuclear tech-
nology has presented us with a possible new fuel
which we are asked to accept because of its potential
commercial value. But our technology has again out-
stripped our institutions, which are not prepared or
suited to deal with plutonium. Those who have asked
what changes in our institutions will be necessary to
accommodate plutonium have come away from that
enquiry profoundly concerned. And the AEC's en-
vironmental impact statement does not allay these
concerns. It reinforces them.
The AEC concedes that the problems of plutonium
toxicity and nuclear theft are far from solved and in-
dicates that they may not be for some years. Yet it
concludes, inexplicably, that we should proceed.
Whether stemming from blind faith in the technol-
ogy it has fostered or from callous promotion of the
bureaucratic and industrial interests of the nuclear
power complex, the AEC's proposal cannot be justi-
fied in light of what we know and, just as important,
what we do not know.
The fuel now used in present-day reactors, the
light water reactors, is uranium which has been en-
riched; the uranium-235 content is increased from
0.7 percent present in natural uranium to. about 3
or 4 percent. Uranium-235 is a fissionable isotope of
uranium, the remainder being non-fissile uranium-
238. Unlike plutonium, uranium fuel is not extreme-
ly toxic, and it is not sufficiently rich in uranium-235
to be fashioned into nuclear weapons. The uranium
NOVEMBER 1974 VOLUME XXX
NUMBER 9
16
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186
The current AEC radiation protection standards governing the amount of plutonium to
which members of the public can be exposed are roughly 100,000 times too lax.
can be enriched to weapons grade material only with
extremely sophisticated technology which is not
available to the public, notably gaseous diffusion
plants.
While present-day reactors are operating, how-
ever, they are also producing as a by-product mod-
erate amounts of plutonium, principally plutonium-
239. A typical large reactor produces about 200 to
250 kilograms of plutonium each year. Since this
plutonium is easily fissioned, it can be used as reac-
tor fuel. Plutonium recycle is the nuclear industry-
AEC proposal to recover the plutonium produced in
light water reactors, process it and recycle it as fuel
back into these reactors.
Several critical steps are involved in recycling this
plutonium. First, the used or spent fuel from the re-
actor must be shipped to a fuel reprocessing plant
where the plutonium is recovered from the spent fuel,
converted to oxide form and shipped to the next fuel
cycle stages—the fuel fabricating and assembly
plants. At a fuel fabricating plant the plutonium ox-
ide will be mixed with uranium oxide into mixed
oxide fuel. This mixed oxide fuel will be fabricated
into fuel pellets, the pellets will be placed in fuel rods,
and these rods will be collected into fuel assemblies.
These assemblies will then be sent to the reactors for
use, thus completing the fuel cycle.
At this point plutonium recycle has not yet begun,
and there is no major industrial commitment of re-
sources to it [5]. No major commercial plutonium
fuel fabricating plants are operating or under con-
struction.* No commercial reprocessing plants are
operating now.** Reprocessing plants, in addition to
recovering plutonium and other fission products from
the spent fuel, are supposed to solidify high-level
wastes and ship them to a permanent AEC reposi-
tory for perpetual management. As yet, however, the
AEC has no such repository. Nor does the AEC know
whether the technology and social institutions for
isolating these high-level wastes for geologic periods
can be made available.
If the plans of the AEC and the nuclear industry
are permitted, however, a major plutonium industry
will develop quickly. Some 140 tons of plutonium
could be recovered from commercial reactors by 1985
"There are, however, several small commercial facilities
that process plutonium for research and development pur-
poses
**The first commercial reprocessing plant built in the
United States, Nuclear Fuel Services in West Valley, New
York, was shut down in 1972 for repairs and enlargement.
The Midwest Fuel Recovery Plant under construction near
Morris, Illinois, has been declared an almost total loss due to
faulty design and construction [6]. The Barnwell Nuclear
Fuel Plant in South Carolina is 70 percent complete. Thus,
since mid-1972, all spent fuel from light water reactors has
been simply stored and not reprocessed.
16
and some 1,700 tons by the year 2000 [7]. A pluto-
nium industry by the turn of the century could in-
volve hundreds of light water reactors fueled with
plutonium, perhaps a score of fuel reprocessing and
fabricating plants, and thousands of interstate and
international shipments containing hundreds of tons
of plutonium.
Plutonium Toxicity
The most pernicious product of the nuclear indus-
try is plutonium. Microgram quantities in skin
wounds cause cancer, and in the body plutonium is
a bone seeker where, once deposited, it can cause
bone cancer. But plutonium is most dangerous when
inhaled. Donald Geesaman explains this hazard:
Under a number of probable conditions plutonium
forms aerosols of micron-sized particulates. When lost
into uncontrolled air these particulates can remain sus-
pended for a significant time, and if inhaled they are
preferentially deposited in the deep lung tissue, where
their long residence time and high alpha activity can
result in a locally intense tissue exposure. The lung
cancer risk associated with these radiologically unique
aerosols is unknown to orders of magnitude. Present
plutonium standards are certainly irrelevant and prob-
ably not conservative. Even so, the fact that under
present standards, the permissible air concentrations
are about one part per million billion is a commentary
on plutonium's potential as a pollutant [3].
To determine whether the AEC's radiation pro-
tection standards for plutonium are inadequate, as
Geesaman suggests, two of the authors of this article
undertook a review of the biological evidence for the
Natural Resources Defense Council (NRDC). Their
report, Radiation Standards /or Hoi Particles [9],
concludes that plutonium particulates or hot par-
ticles are uniquely virulent carcinogens and that the
current AEC radiation protection standards govern-
ing the amount of plutonium to which members of
the public can be exposed are roughly 100,000 times
too lax.
The lung cancer risk associated with hot particles
of plutonium, as estimated by Tamplin and Cochran,
is comparable to the lethal dose of botulin toxin, a
biological warfare agent. Certainly one would hope
that this nation would give careful consideration and
pursue all alternatives before implementing an ener-
gy policy based on such toxic materials.
As a result of this study, NRDC formally petitioned
the AEC and the Environmental Protection Agency
to reduce the present maximum permissible exposure
levels by 100,000. Neither the AEC nor the EPA have
responded finally to NRDC'S petition, but the petition
is now being considered by National Council on
Radiation Protection and Measurements, National
Academy of Sciences, Biophysical Society and sev-
eral AEC national laboratories. Moreover, EPA will
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187
shortly commence a series of hearings and other in-
itiatives on plutonium-related issues, including the
hot particle controversy.
Although the adequacy of the AEC's plutonium
standards is thus a matter of considerable doubt and
great controversy, the AEC's draft environmental im-
pact statement for plutonium recycle simply assumes
that the present standards are adequate. The entire
risk analysis of the statement, as well as the ultimate
decision to proceed with plutonium recycle, are based
upon a premature and unexplained rejection of the
hot particle hypothesis. Yet, the AEC is forced to
concede that this hypothesis "is being given careful
consideration in a separate proceeding" [2, chap. 4,
pp. 5-7].
We submit that the AEC has no basis whatever to
conclude that plutonium recycle will not cause undue
risk to the public health and safety until it has either
satisfactorily resolved the hot particle issue or calcu-
lated the impacts of plutonium recycle using the as-
sumption that hot particles are uniquely carcino-
genic. The AEC's draft environmental impact state-
ment for plutonium recycle does neither. However,
the more basic issue is whether we want our energy
system based on a material of unprecedented
toxicity.
Some plutonium contamination of the environ-
ment has already occurred, due principally to the
atomic weapons program. The leakage of plutonium
from contaminated oil at the AEC's plutonium wea-
pons plant at Rocky Flats, 10 miles west of Denver,
Colorado, led to an uncontrolled source of plutonium
which was much larger than the integrated effluent
loss during the 17 years of plant operation. Tens to
hundreds of grams of plutonium went off-site, 10
miles upwind from Denver [3, p. 59].
The Nuclear Materials and Equipment Corpora-
tion (NUMEC) of Apollo, Pennsylvania, was recently
fined $13,720 for a 16 count violation of AEC regu-
lations ranging from failure to follow radiation moni-
toring procedures to failure to comply with certain
safeguards requirements [9]. Production workers
at Nuclear Fuel Services, Inc. in Erwin, Tenn., a fuel
processing and fabricating facility, met with AEC
inspectors on August 13, 1974 to complain about
the absence of even the rudiments of accepted health
physics practices at that plant. Occurrences such as
these can reasonably be expected to multiply greatly
if plutonium is made a major article of commerce.
Nuclear Theft
On May 18 of this year the world was made dra-
matically aware of the relationship between nuclear
power and nuclear weapons when India exploded a
nuclear device made from plutonium taken from a
peaceful reactor built with Canadian assistance. The
magnitude of the threat posed by the availability of
plutonium from power reactors is set out by Willrich
and Taylor in their book Nuclear Theft: Risks and
Safeguards:
As fuel for power reactors, nuclear weapon material
will range in commercial value from $3,000 to $15,000
per kilogram—roughly comparable to the value of black
market heroin. The same material might be hundreds
of times more valuable to some group wanting a power-
ful means of destruction. Furthermore, the costs to so-
ciety per kilogram of nuclear material used for destruc-
tive purposes would be immense. The dispersal of very
small amounts of finely divided plutonium could neces-
sitate evacuation and decontamination operations cov-
ering several square kilometers for long periods of time
and costing tens or hundreds of millions of dollars. The
damage could run to many millions of dollars per gram
of plutonium used. A nuclear explosion with a yield of
one kiloton could destroy a major industrial installation
or several large office buildings costing hundreds of mil-
lions to billions of dollars The hundreds or thousands of
people whose health might be severely damaged by dis-
persal of plutonium, or the tens of thousands of people
who might be killed by a low-yield nuclear explosion in
a densely populated area represent incalculable but im-
mense costs to society [4, pp. 107-108].
In our troubled world, terrorist activity and other
forms of anti-social violence are an almost daily oc-
currence. A recent AEC study identified more than
400 incidents of international terrorism carried out
by small groups during the past six years [10]. In an
age of bombs and bomb threats, of aircraft hijacking,
of the ransom of diplomats and the murder of Olym-
pic athletes, the risks of nuclear theft, blackmail and
terrorism are not minimized even by some of the
most ardent supporters of nuclear energy. Thus
former Atomic Energy Commissioner Clarence Lar-
son has described the evolution of a'plutonium black
market:
Once special nuclear material is successfully stolen in
small and possibly economically acceptable quantities,
a supply-stimulated market for such illicit material is
bound to develop. And such a market can surely be ex-
pected to grow once the source of supply has been iden-
tified As the market grows, the number and size of
thefts can be expected to grow with it, and I fear such
growth would be extremely rapid once it begins. .. .Such
theft would quickly lead to serious economic burdens to
the industry, and a threat to the national security [11].
The critical point here is that these tremendous
risks will become real with the advent of plutonium
recycle. Unless plutonium is reprocessed and recy-
cled, the possibility that it will be stolen is small. If
the plutonium has not been detoxified by separating
it from the high-level wastes in the spent fuel at a re-
processing plant, it is very effectively protected from
theft, at least for hundreds of years. Willrich and
Taylor explain these relationships:
In the light water reactor (LWR) fuel cycle without
plutonium recycle, plutonium which is produced in a
power reactor, if reprocessed, might be stolen at the
Is the American public willing to accept the risks of plutonium in exchange for the
promised benefits?
November 1974 Bulletin of the Atomic Scientists 17
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188
output end of a reprocessing plant, during transit from
the reprocessing plant to any separate storage facility
ised, and from a long-term plutonium storage facility.
Until irradiated fuel is reprocessed, the theft possibil-
ities in the LWR fuel cycle are minimal. (Emphasis
added.)
In the LWR fuel cycle with plutonium recycle, in
addition to possibilities without recycle, plutonium
might be stolen during transit from any separate long-
term storage facility, and from a fuel fabrication plant.
Complete LWR fuel assemblies, each containing a sig-
nificant quantity of plutonium might also be stolen
during transit from a fuel fabrication plant to a power
reactor, and at a power plant prior to loading into the
reactor, although the weight of each assembly makes
this difficult [4, p 168],
In sum, plutonium recycle will bring with it all the
risks associated with nuclear theft that numerous
authors have described [12]. Reasonable prudence
dictates, therefore, that we have adequate answers
to the problem of nuclear theft well in hand before
we begin plutonium recycle.
Safeguards and the AEC
In the language of the nuclear industry, the vari-
ous programs and techniques to prevent nuclear theft
and recover stolen nuclear material are called 'safe-
guards.' There is now widespread agreement—at
least among those outside the nuclear industry—that
present safeguards against nuclear theft are woefully
inadequate [13]. The AEC's Rosenbaum Report
concluded:
In recent years the factors which make safeguards a
real, imminent and vital issue have changed rapidly for
the worse. Terrorists groups have increased their pro-
fessional skills, intelligence networks, finances and level
of armaments throughout the world. . . .Not only do
illicit nuclear weapons present a greater potential pub-
lic hazard than the radiological dangers associated with
power plant accidents, but. . .the relevant regulations
are much less stringent [13].
The problem is not simply that the AEC has not im-
plemented the necessary safeguards programs; rather
the agency has not even developed an adequate pro-
gram on paper.
On the subject of safeguards, the AEC's draft im-
pact statement on plutonium recycle is a marvel of
clouded reasoning and breezy optimism. The state-
ment concedes that the objective of keeping the risk
of nuclear theft small "will not be fully met for the
recycle of plutonium by current safeguards meas-
ures" [2, pp. 5-6]. Steps which might be taken to
correct current inadequacies are then summarized
in the statement as follows:
1 Minimization or elimination of the transportation
of plutonium from reprocessing plants to mixed oxide
fuel fabrication facilities which is the operation most
vulnerable to an attempted act of theft or sabotage. To
the extent that such shipments are minimized or elim-
inated, the safeguarding of plutonium would be en-
hanced. This objective can be accomplished by locating
mixed oxide fuel fabrication plants in close proximity
to or adjacent to reprocessing plants in Integrated Fuel
Cycle Facilities. .. .
2. Further protection of transportation functions by
use of massive shipping containers, special escort or
convoying measures, vehicle hardening against attack,
18
improved communications and response capabilities.
3. Additional hardening of facilities through new bar-
rier requirements, new surveillance instrumentation,
new delaying capabilities (e.g., incapacitating gases).
4. Upgrading of operating and guard functions
through the use of personnel security clearance pro-
cedures, a federally operated nuclear security system,
more advanced systems for monitoring and searching
of personnel, and closer liaison with law enforcement
authorities.
5. Improving the timeliness and sensitivity of the sys-
tem of internal control and accountability of plutonium.
6. Use of 'spiked' plutonium which would be less sus-
ceptible to theft and would be more difficult to manu-
facture into a nuclear explosive because of the required
elaborate handling procedures [2, pp. 5-7].
Despite the facts that: (1) these proposals are pre-
liminary and their content not well defined, (2) they
are still being studied, some apparently for the first
time, (3) some would require Congressional action,
(4) some would necessitate substantial changes in
the structure of the U.S. utility industry, and (5) a
sophisticated safeguards program would pose a major
threat to civil liberties and personal privacy—despite
all these facts the draft impact statement neverthe-
less recommends that we proceed now with plutoni-
um recycle because "the Commission has a high de-
gree of confidence that through implementation of
some combination of the above concepts the safe-
guards general objective set forth earlier can be met
for plutonium recycle" [2, pp. 5-7]. The Commis-
sion's faith, unfortunately, is hardly reassuring.
The AEC's lead safeguards suggestion—the Inte-
grated Fuel Cycle Facility concept—merits special
comment. It actually represents a major watering
down of a far more significant concept, that of nu-
clear power parks where reactors as well as fuel re-
processing and fabricating plants are all located at
one site [14]. In our judgment, a safeguards system
which does not require nuclear parks is not address-
ing the problem of theft during transportation in a
serious and responsible way. Moreover, the nuclear
industry's current plans, already well advanced, do
not call for the implementation of even the Integrat-
ed Fuel Cycle Facilities concept.
Adequate Safeguards?
While it may be possible to devise an adequate
safeguard system in theory, there is little reason to
believe that such a system would be acceptable in
practice [15]. This is true for several reasons.
First, the problem is immense. The illegal diver-
sion of weapons material is only one type of anti-
• social behavior a safeguards program must protect
against. Terrorist acts against the reactors, ship-
ments of radioactive wastes, fuel reprocessing facili-
ties and waste repositories can result in catastrophic
releases of radioactivity. Such threats against nu-
clear facilities have already occurred [16]. More-
over, a safeguards system would have to exist on a
vast, worldwide basis. Some 1,000 nuclear reactors
are projected for the United States in the year 2000,
with hundreds of shipments of radioactive materials
daily. Hundreds of tons of plutonium will be in the
commercial sector of our economy by that date.
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189
To accommodate plutonium we shall have to move toward a more intimidated society
with greatly reduced freedoms.
Abroad, American firms are constructing nuclear re-
actors in countries that have little political stability
and in countries, such as Japan, who have not sighed
the Non-Proliferation Treaty. Safeguarding nuclear
bomb material would ultimately require a restruc-
turing of the socio-political institutions on a world-
wide scale. The United Nations unfortunately gives
us little reason to believe that this is a practical re-
ality.
Second, safeguards measures are strongly opposed
by the nuclear industry. The degree to which the in-
dustry is sensitive to the diversion hazards and is
likely to be an effective partner in the enforcement
and implementation of safeguards programs was ap-
parent in the vociferous industry opposition to the
modest strengthening of the AEC safeguards rules
which were first published in the February 1, 1973,
Federal Register [17].
Third, experience with present safeguards is hard-
ly reassuring. Nuclear Materials and Equipment
Corporation, over several years of operation, was un-
able to account for six percent (100 kilograms) of
the weapons grade material that it handled. As noted
previously, it was also fined by the AEC, in part,
because of safeguards violations. At a safeguards
symposium the director of the AEC's Office of Safe-
guards and Materials Management observed that
"we have a long way to go to get into that happy land
where one can measure scrap effluents, products, in-
puts and discards to a one percent accuracy" [3, p.
59]. This statement takes on particular significance
when it is realized that only one-half of one percent
of the plutonium utilized by the commercial sector in
the year 2000 is enough to make hundreds of atomic
bombs. The editors of the Bulletin have noted that
the frequent 'misroutings' of shipments of weapons
grade materials highlights a key safeguards problem
—hijacking [18].
A spot-check by General Accounting Office inves-
tigators at three AEC-licensed contractors showed
that in some cases access to easily portable quanti-
ties of special nuclear material could be gained in less
than a minute using the simplest of tools. At two of
the three plants checked, GAO found weak physical
barriers, ineffective guard patrols, ineffective alarm
systems, lack of automatic-detection devices, and the
absence of an action plan should material be stolen
or diverted. AEC's inspectors, however, were giving
the same facilities good marks on virtually every se-
curity category [GAO, 13].
Fourth, and perhaps most basically, there is little
reason to believe that safeguards will work when little
else does. For example, the AEC supports the crea-
tion of a federal police force to provide an immediate
federal presence whenever the use of force may be
needed to protect these incredibly dangerous mate-
rials from falling into the hands of would-be sabo-
teurs and blackmailers. But is there anyone who be-
lieves that police are effective at a level commen-
surate with the potential nuclear hazard? The New
York City police department was proven incapable
of maintaining security over confiscated heroin. Are
similar losses of plutonium acceptable?
The general point here is that our safeguards sys-
tem must be essentially infallible. It must maintain
what Alvin Weinberg, former director of the Oak
Ridge National Laboratory, has called "unaccus-
tomed vigilance" and "a continuing tradition of
meticulous attention to detail" [19]. Yet our human
institutions are far from infallible. Our experience
indicates that rather than sustaining a high degree
of esprit, vigilance and meticulous attention to de-
tail, our governmental bureaucracies instead become
careless, rigid, defensive and, less frequently, cor-
rupt. A basic question, then, is whether we want to
entrust so demanding and unrelenting a technology
as plutonium recycle to institutions which are negli-
gent of their own responsibilities and insensitive to
the rights of others and to technical fixes which are
untried and unproven.
Threat to Civil Liberties
One principal reason for our believing that an ade-
quate safeguards system would not be acceptable in
practice is the tremendous social cost of such a sys-
tem in terms of human freedom and privacy. Safe-
guards necessarily involve a large expansion of police
powers. Some one million persons have been trained
in the handling, moving and operation of nuclear
weapons. The projected growth of the nuclear indus-
try will give rise to a parallel and, ultimately, a much
larger group of persons, in this case civilians, who will
be subjected to security clearance and other security
procedures now commonplace in the military wea-
pons program. Indeed, the AEC makes the following
disturbing statement in its draft environmental im-
pact assessment of plutonium recycle:
Security problems are much simplified when it can be
established with high probability that the persons who
are responsible for the handling of plutonium or imple-
menting of related safeguards programs are trust-
worthy. Various court rulings in recent years have been
favorable to the protection of individual privacy and of
individual right-to-work. These rulings have made it
difficult to make a personnel background check of an
individual in commercial activities to assure with high
probability that he is trustworthy and, hence, poten-
tially acceptable as a steward for the protection of plu-
tonium. The AEC has requested legislation which would
allow background checks of individuals with access to
plutonium and related material accountability records
[2, chap. 5, p. 42].
November 1974 Bulletin of the Atomic Scientists 19
-------
190
The keeping of police dossiers will not be limited
to nuclear industry personnel. The New York Times
reported August 11 that Texas state police maintain
files on nuclear power plant opponents. How much
more government investigation into the private lives
of individuals can be tolerated by a free society? Se-
curity and surveillance procedures at best infringe
upon the privacy of families and their friends. At
worst, they are the instruments of repression and
reprisal.
A second AEC safeguards proposal is the creation
of a federal police force for the protection of plutoni-
um plants and shipments. The draft impact state-
ment for plutonium recycle justifies such a federal
force in the following terms:
A federal security system would he less apt to have the
variations in staff and capability that would be en-
countered in use of private security guards. In addition,
it should be noted that the consequences of a successful
theft or diversion of plutonium would undoubtedly
have nationwide impacts and could best be handled by
Federal authorities, certainly, with Federal participa-
tion, there is the potential for a larger force, more ef-
fective weapons, and better communications [2, chap 5,
p. 42].
How large would such a force be? What standards
should govern and restrain its operations? The Wash-
ington Post reported in October 1973 that the AEC
issued shoot-to-kill orders to personnel directing the
production, shipment and storage of atomic weapons
at the height of the Yom Kippur War.
Once a significant theft of plutonium or other wea-
pons material has occurred, how will it be recovered?
To prevent traffic in heroin, police have asked for no-
knock search laws. This infringes upon one of our
most cherished freedoms. To live with plutonium we
may have to abandon this freedom along with others.
In the presence of nuclear blackmail threats, the in-
stitution of martial law seems inevitable. It has been
said that the widespread availability of weapons ma-
terial and terrorists targets in the nuclear fuel cycle
will radically alter the power balance between large
and small social units (De Nike [16]). It should be
added that the threatened society will undoubtedly
attempt to redress that balance through sophisticat-
ed and drastic police action.
In sum, to accommodate plutonium we shall have
to move toward a more intimidated society with
greatly reduced freedoms. In this respect the follow-
ing passage from the report of the distinguished in-
ternational group of scientists attending the 23rd
Pugwash Conference on Science and World Affairs
is instructive:
The problem of theft of nuclear material by internal
groups of individuals intent on sabotage, terrorism or
blackmail was agreed to be a very serious one, although
there was some sentiment expressed that the possibility
of such activity was much smaller in socialist states.
We believe that sentiment to be true. It is also ap-
parent that that is the direction in which we must
move to accommodate the nuclear industry. After
having spent billions of dollars for our nuclear de-
terrent, our civilian nuclear industry might well ac-
20
complish that which our defense system is trying to
prevent.
Alvin Weinberg is one of the few persons closely
associated with the nuclear power complex who has
looked carefully at the political and regulatory insti-
tutions that will be necessary to support a plutonium-
based nuclear power economy, and his views on this
subject merit close attention [19]. Weinberg's basic
premise is that nuclear power will place unprecedent-
ed strains on our society. In an unpublished paper
circulated prior to a conference in June 1973 at the
Woodrow Wilson International Center for Scholars
in Washington, D.C., Weinberg set out his views on
the type of new institutions required to cope with
the plutonium economy:
One suggestion (proposed by Sidney Siegel) that is
relevant to the situation in the United States would be
to establish a national corporation patterned after
COMSAT to take charge of the generation of nuclear
electricity. Such an organization would have technical
resources that must exceed those available to even a
large utility: and a high order of technical expertise in
operating reactors and their sub-systems is essential to
ensuring the continued integrity of these devices. [Here
Dr. Weinberg suggests nationalization of the industry.]
Each country now has its own AEC that sets stand-
ards or, in some cases, actually monitors or operates re-
actors. Perhaps this will be sufficient forever. Yet no
government has lasted continuously for 1,000 years:
only the Catholic Church has survived more or less con-
tinuously for 2,000 years or so. Our commitment to nu-
clear energy is assumed to last in perpetuity—can we
think of a national entity that possesses the resiliency
to remain alive for even a single half-life of plutonium-
239? A permanent cadre of experts that will retain its
continuity over immensely long times hardly seems
feasible if the cadre is a national body.
It may be that an International Authority, operating
as an agent of the United Nations, could become the
focus for this cadre of expertise. The experts themselves
would remain under national auspices, but they would
be part of a worldwide community of experts who are
held together, are monitored, and are given long-term
stability by the International Authority. The Catholic
Church is the best example of what I have in mind:
a central authority that proclaims and to a degree en-
forces doctrine, maintains its own long-term social sta-
bility, and has connections to every country's own Cath-
olic Church. (Emphasis added.)
These are far-reaching concepts presented by
Weinberg. The basic question they pose is: Will the
plutonium economy raise socio-political problems of
such magnitude that their resolution will be unac-
ceptable to society? In attempting to do the impos-
sible—live with plutonium—we may create the in-
tolerable.
Super-Human Requirements
The commercialization of plutonium will bring
with it a major escalation of the risks and problems
already associated with nuclear power. Plutonium
will further strain the already weakened regulatory
fabric of the nuclear industry.
Hannes Alfven, Nobel laureate in physics, has de-
scribed the regulatory imperatives applicable to the
nuclear industry:
Fission energy is safe only if a number of critical de-
vices work as they should, if a number of people in key
-------
positions follow all their instructions, if there is no
sabotage, no hijacking of the transports, if no reactor
fuel processing plant or reprocessing plant or reposi-
tory anywhere in the world is situated in a region of
riots or guerrilla activity, and no revolution or war—
even a "conventional one"—takes place in these re-
gions. The enormous quantities of extremely dangerous
material must not get into the hands of ignorant people
or desperados. No acts of God can be permitted [20].
Weinberg similarly stresses the need ". . . of creat-
ing a continuing tradition of meticulous attention to
detail" and suggests that "what is required is a cadre
that, from now on, can be counted upon to under-
stand nuclear technology, to control it, to prevent
accidents, to prevent diversion" [19].
The public and its decisionmakers must seriously
question whether it will be possible to attract, train
and motivate the personnel required for these func-
tions. These must be highly qualified persons who
will maintain a tradition of "meticulous attention to
detail" even when the glamorous aspects of a new
technology become the commonplace operations of
an established industry. We suggest that it is beyond
human capabilities to develop a cadre of sufficient
size and expertise that can be counted upon to under-
stand nuclear technology, to control it, and to pre-
vent accidents and diversion over many generations.
There is considerable evidence at the present time
to suggest that the fledgling nuclear industry is al-
ready unmanageable. Consider, for example, that a
previously secret AEC study released by Ralph
Nader concluded that:
The large number of reactor incidents [850 abnormal
occurrences], coupled with the fact that many of them
had real safety significance, were generic in nature,
and were not identified during the normal design, fab-
rication, erection, and preopefational testing phases,
raises a serious question regarding the current review
and inspection practices both on the part of the nuclear
industry and the AEC [21].
In addition, consider the tritium that recently ap-
peared in the drinking water of Broomfield, Colorado.
Consider the 115,000 gallons of high-level radioac-
tive wastes that leaked from the tank at Hanford,
Washington, over a period of 51 days while no one
monitored the tank. Consider that the radioactive
releases from the famed Shippingport reactor in
Pennsylvania were higher than recorded. Consider
that the executives of Consumers Power Corporation
in Michigan failed to notify the AEC that their
radioactive gas holdup system was not functioning.
Consider that two reactors in Virginia were half com-
pleted before the AEC was informed that they were
being constructed over an earthquake fault. Con-
sider that the GAO found security at plutonium
storage areas totally inadequate after the AEC in-
spectors had certified the facilities.
Considering all this, there is good reason to sug-
gest, because of the meticulous attention to detail
that will be required at every stage of plutonium re-
cycle, that a decision to proceed with plutonium
recycle will precipitate an already unmanageable sit-
uation into a national crisis.
Given that the risks of plutonium recycle are un-
acceptably high, particularly in light of the present
191
Plutonium in cake form. This batch was produced
at the AEC's Savannah River Plant near Aiken,
S.C.
uncertainties, a key question is what are our options?
What are the alternatives to the AEC's proposal to
proceed now with plutonium recycle? We believe that
there are essentially three options, each of which is
preferable to the AEC's announced plan.
Alternatives to Plutonium Recycle
• We could phase out nuclear power reactors.
There is mounting apprehension among knowledge-
able persons concerning the human and societal haz-
ards of fission reactors which would only be com-
pounded by plutonium recycle. The 23rd Pugwash
Conference on Science and World Affairs in Septem-
ber, 1963, concluded:
1. Owing to potentially grave and as yet unresolved
problems related to waste management, diversion of
fissionable material, and major radioactivity releases
arising from accidents, natural disasters, sabotage, or
acts of war, the wisdom of a commitment to nuclear
fission as a principal energy source for mankind must
be seriously questioned at the present time.
2. Accordingly, research and development on alter-
native energy sources—particularly solar, geothermal
and fusion energy, and cleaner technologies for fossil
fuels—should be greatly accelerated
3 Broadly based studies aimed at the assessment of
the relation between genuine and sustainable energy
needs, as opposed to projected demands, are required.
This third recommendation implies the implementa-
tion of energy conservation measures. It is important
to recognize that energy conservation can be our ma-
jor energy source between now and the year 2000.
Conservation means using our present energy more
efficiently; it need not mean a change in life styles.
Coupled with the use of solar and geothermal energy,
energy conservation could eliminate the need for new
nuclear power stations.
• We could continue with the present generation
of light water reactors but strictly prohibit plutonium
recycle for the foreseeable future. Such a decision
would be premised upon a judgment that plutonium
November 1974 Bulletin of the Atomic Scientists 21
-------
192
is too dangerous because of its toxicity and explosive
potential to be allowed to become an article of com-
merce. Of course, we would still have plutonium to
cope with because it is produced in present-day reac-
tors. But without plutonium recycle there should be
little incentive to reprocess the plutonium out of the
spent fuel, so the plutonium could remain in the
spent fuel where it is effectively protected from theft
and, hopefully, confined and contained.
The benefits of plutonium recycle are small. Pluto-
nium recycle would reduce the annual uranium re-
quirements by about 10 to 15 percent and reduce the
light water reactor fuel cycle cost by about the same
amount. But the nuclear fuel cycle cost represents
less than 20 percent of the total cost of power from
nuclear plants, and nuclear plants by 1985 will rep-
resent less than 40 percent of the electric, or about
15 percent of the total, domestic energy supplied. In
other words, plutonium recycle involves an economic
savings of less than one-half of one percent.
Plutonium differs from the high-level wastes in the
spent fuel in one critical respect: whereas the radio-
activity of high-level wastes will continue for thou-
sands of years, that of plutonium will continue for
hundreds of thousands. Thus, while the problem of
effectively storing both these materials and prevent-
ing their entering the environment are unprecedent-
ed in human history, plutonium must be contained
for eons longer. For this reason, an argument can be
made that, ultimately, the safest thing that can be
done with plutonium is to burn or fission it in reac-
tors, thus making it into high-level wastes rather
than plutonium. But that is an activity that is best
left for decades or even centuries hence—for a society
more capable and less violent than today's.
• We could defer for several years the decision re-
garding plutonium recycle until present uncertainties
regarding safeguards and plutoniunv toxicity are sat-
isfactorily resolved and a basis has been laid for a
more intelligent judgment regarding the risks and
benefits of the commercialization of plutonium. We
believe that this option must command general sup-
port. Too many questions, both technical and social,
are unanswered today. And until these questions are
answered it would be a grave error, we believe, to rush
into the AEC's plutonium economy.
Is the American public willing to accept the risks
of plutonium in exchange for the promised benefits?
The national debate which must occur on this basic
question has hardly begun.
NOTES
1. Glenn T. Seaborg, "The Plutonium Economy of the
Future," Release No. S-33-70 (Washington, D.C.: Atomic
Energy Commission, October 5, 1970).
2. Atomic Energy Commission, "Draft Generic Environ-
mental Statement on the Use of Mixed Oxide Fuel," WASH-
1327 (Washington, D.C.: The Commission, July 1974).
3. Donald P. Geesaman, "Plutonium and the Energy De-
cision," in The Energy Crisis, ed. R.S. Lewis and B.I. Spinrad
(Chicago, 111.: Bulletin of the Atomic Scientists, 1972), pp.
58-59.
4. Mason Willrich and Theodore B. Taylor, Nuclear
Theft: Risks and Safeguards (Cambridge, Mass.: Bellinger,
1974).
5. The AEC's attempt to recycle plutonium into the Big
Rock Point (Mich.) reactor was stopped by a lawsuit. West
Michigan Environmental Action Council v. AEC (W. D.
Mich. Dkt. No. G-58-73).
6. Weekly Energy Report, "GE Fuel Recovery Plant 'In-
operable,'" II (July 15, 1974), 1.
7. Atomic Energy Commission, "Nuclear Power Growth:
1974-2000," WASH-1139 (Washington, D.C.: The Commis-
sion, 1974), p. 34 (Case D projection). The year 2000 figure
includes plutonium produced in liquid metal fast breeder
reactors.
8. Arthur Tamplin and Thomas Cochran, Radiation Stand-
ards of Hot Particles (Washington, D.C.: Natural Re-
sources Defense Council, Feb. 14, 1974). Copies of this report
are available from NRDC (1710 N St., N.W., Washington,
D.C. 20036) for $3 per copy.
9. Atomic Energy Commission, press release, August 14,
1974
10. W. C. Bartels and S. C. T. McDowell, quoted in Nu-
clear News. 17 (Aug. 1974), 46.
11. Clarence E. Larson, "Nuclear Materials Safeguards:
A Joint Industry-Government Mission," in Proceedings of
AEC Symposium on Safeguards Research and Development,
Oct. 27-29, 1969, WASH 1147 (Washington, D.C.: The
Commission, 1969); and Deborah Shapley, "Plutonium: Re-
actor Proliferation Threatens a Nuclear Black Market,"
Science, 172:3979 (April 9, 1971), 143.
12. See, for example, Bernard T. Feld, "The Menace of
a Fission Power Economy," Bulletin, 30 (April 1974), 32-34;
22
Lawrence Scheinman, "Safeguarding Nuclear Materials,"
Bulletin, 30 (April 1974), 34-36; David T. Rose, "Nuclear
Electric Power," Science, 184:4134 (April 19, 1974), 351-359.
See also Robert L. Heilbroner, An Inquiry into the Human
Prospect (New York: W. W. Norton, 1974), pp. 40-43.
13. See, for example, Atomic Energy Commission, "The
Threat of Nuclear Theft and Sabotage" (Rosenbaum Re-
port), Congressional Record, April 30, 1974, p. S 6621; Gen-
eral Accounting Office, "Protecting Special Nuclear Mate-
rial in Transit: Improvements Made and Existing Problems,"
B-164105 (Washington, D.C.: U. S. Government Printing
Office, 1973).
14. Dean E. Abrahamson, "Energy: Nuclear Theft and
Nuclear Parks," Environment (July/August, 1974), 5.
15. Taylor and Willrich believe that "a system of safe-
guards can be developed that will keep the risks of theft of
nuclear weapon materials from the nuclear power industry at
very low levels" [4, p. 171]. Yet they also emphasize that
"regardless of its effectiveness, a nuclear safeguards system
applicable to the nuclear power industry in this country can-
not provide complete assurance that unannounced fission ex-
plosions will not occur in the United States in the future."
They point out that "no future safeguards system that will be
practical can offer 100 percent assurance against theft" [4,
p. 123]. They never say what level of nuclear theft, or what
size plutonium black market or how many unauthorized nu-
clear explosions nre in fact acceptable to them.
16. L. Douglas DeNike, "Radioactive Malevolence," Bul-
letin, 30 (February 1974), 16. See also the story on the bomb
threats that have occurred at the Zion nuclear power plant in
northern Illinois reported in Environment, "Spectrum" (Oc-
tober 1974).
17. Nuclear Industry, "Industry Inundated by Proposed
New Safeguards Rules" (February 1973), pp. 45-47.
18. R. S. Lewis and B. I. Spinrad, eds., The Energy Crisis,
(Chicago, 111.: Bulletin of the Atomic Scientists, 1972), p. 59.
19. Alvin Weinberg, "Social Institutions and Nuclear
Energy," Science, 177:4043 (July 7, 1972), 32-34.
20. Hannes Alfven, "Energy and Environment," Bulletin,
29 (May 1972), 5.
21. AEC Task Force Report, dated October, 1973, page 16,
released in testimony presented to the Joint Committee on
Atomic Energy by Ralph Nader and the Union of Concerned
Scientists, January 29, 1974.
-------
UNITf.'D srAi'CC, 193
ATOMIC LNEHGY COMMISSION
VVA'-.HJNGTO'J, D C. Ji/j'.i
August 29, 1974
N. C. Iloselcy, Director, Region IT,
ALLEGATIONS AGAINST KI'S, ERWIN - MEETING WITH. OGAW REPKF,GK;!TATIVES
Please note the attached infornntion, concerning items of concern
expressed by OCAU representatives at a meeting in Headquarters on
August 13. We believe these inatters to be of priority concern.
PJease note that the allegations include two allegations of willful-
ness. Note also, that OCAW has specifically requested that an order
be issued directing the licensee to perform whole body counting of
workers ,
In your investigation of tfis matter, please determine, specifically,
the correctness of each allegation. In developing the specifics of
the allegations you should contact the alleger - QCAW represer. :atives
in Erwin.
OCAU has requested to be allowed to be present at the management
interview following this investigation. We will inform you of the
position to be taken by you.
The brief history of NFS compiled by the OCAW attorney and the
"existing conditions at the plant (if as allcged)raise rational
questions about the effectiveness of our enforcement actions
against NFS, Erwin. Please comment on this.
I will appreciate from you, your estimated date for submittal of
your report.
If you desire to discuss this, please contact; me.
<. __ ^_
^/Jonn G. Davis, Deputy Director
for Field Operations
Enclosure:
Mote to Files dtd 8/29/7A
-------
194
UNITED SfATCS
ATOMIC ENERGY COMMISSION
WAS-.HINC.TO;,!, o.C. 20145
August 29, 1974
Koto to Files
NUCLEAR FUEL SERVICES, ERWIN, TENNESSEE, LICENSE NO. 70-143 -
MKETING WITH REPRESENTATIVES 0? THE OIL, CHEMICAL, AND ATOMIC
WORKERS INTERNATIONAL UNION
In response to a telephone call from Steven T-Jodka, Legislative
Assistant, Citizenship - Legislative Department, OCAWj a nesting
was held on August 13, 1974, with representatives of the OCA* 7 to
discuss working conditions relative to radiation exposure at the
NFS, Erwin facility. Attendees at this meeting are shown on
Enclosure 1.
Wodka generally was the spokesman for the OCAW, although, there
was active - and, at tines, emotional - participation by many
of the OCAW contingent.
Wodlca opened his presentation by remarking:
1. The OCA*7 was highly concerned with worker exposure at fuel
cycle plants - both those unionized and those not unionized -
and will devote effort to see that the .exposure.*: are reduced.
2. He had reviewed the file on NFS, Erwin, in the Public Document
Room and had noted tiany instance's of worker overaxposuro.s
reported over the years.
3. His review of the file was incomplete since he had been
unable to locate the basic license in the PDE. and, conse-
quently, could not accurately determine the requirements
placed on the licensee.
4. The OCAU had, over the years, made several complaints on .
activities at NFS, Erwin to the AEC and, although the AEC
looked into the complaints, OCAW was not satisfied that
working conditions at NFS, Erwin had improved. Because of
this, the OCA1-I concern was being elevated to OCAU International
Headquarters level.
-------
195
Kotc to Filac A"CUUt 29> 197/'
With regard to the specific situation at NFS, Erwin, Wodha stated
the OCA1,: had five areas of specific concern:
1. Ttie company has failed to reduce exposures to meet the "an low
ac; practicable" requirement expressed in the AEC regulations.
2. The con.pa.ny has failed to pemit OCAW representatives to accompany
AEC inspectors as required by 10 CFR 12.
5. The company has failed to notify workers of overexposures as
required by AEC regulations.
4. Trie company has failed to provide adequate monitoring.
5. The company has failed to perform adequate biological monitoring,
i.e., determination of uptake of radioactive materials by workers.
The approximately two and'a half hour neeting cor-risted of providing
details supporting the five areas of concern. In the discussion,
OCAW representatives specifically alleged that the licensee willfully
failed to comply with requirements in two of these areas of concern:
1. Failure to permit worker representatives to accompany AEC inspectors.
2. Failure to notify individuals of exposures.
In addition, the OCAW specifically requested, due to continuing significant
differences in bioassay and whole body counting results, that the AEC
immediately order NFS, Erw:'u, to whole body count all workers for plutoniuzi,
thorium, ur'anius 235 and uraniun 233.
The following is an account of the substance of the information and remarks
presented by OCAW in support of the five areas of concern:
'1. Failure cf the coapany to meet ALAP.
/ a. Lunchrooms. The company provides two lunchrooms. Workers are
.- f. I? _y_ permitted to enter the lunchroom after washing hands and donning
'J- y ijL''''''' shoe covers over sheas worn in the production area. The cloth.ing
//' worn in the production area is worn in the lunchroom. A monitor
' , is provided for use by the workers. (^ The sink provided for washing
,lf,i '. hands also is used to wash parts from the %'emljpg machines/) Varknrr
Btatc that these parts have shown contamination.
V/0,v>. -
-------
196
Note to Files August 29, 1974
One of the lunchrooms is immediately adjacent to a production
area. A taped closed door server as a wall. The workers
contend that radiation, i.e., radioactive Tp-iterial, enters
the lunchroom as evidenced 1>y contamination on food dispensing
machines. The workers state that up to 40,000 dpn have heen
mear.ured on a beverage vending machine. In excess of 20,000
dpra were measured inside the machine.~ Several vending machines
were removed from service and replaced because of contamination.
The current location of the machines was not known.
The V7orkers state that the snaarable contamination limit is
500 dpm on eating table services. The only action required
by the licensee is to decontaminate to below 500 dpra alpha.
The opinion was expressed forcefully by Cochran, the health
physics consultant, that he could not relate a 500 dpm limit,
at a plant authorized to possess plutonium, with ALAP.
The OCAW representatives strongly expressed the opinion that
the location of the lunchroom in proximity to the work area
contributed in exposures to individuals that violated ALAP.
This is evideaceJ by contanin.ition. detected in the lunchroom.
Exposures of people. Wodka stated that his review of the docket
in the PDR showed, since 1969, there had been reported over-
exposures of 53 individuals. In addition, whole body counting
currently shows six individuals where the measurements indicate
the uptakes are increasing although the licensee is supposed to
have removed those workers frou radiation work. Wodka stated,
also, that the information on exposures in the PDR is very
difficult to relate to specific exposures to individuals. These
repeated instances of exposures show, according to OCAW, failure
to meat ALAP.
Contamination. The company, according to OCAW, has shifted from
a practice of some years ago of removing contamination to'a
practice of fixing - by paint - contamination. Fixed contamina-
tion on floor surfaces reading up to 500,000 dpm exist. In
addition, shipments are made within containers showing 100,000
dpm fixed contamination.
Respiratory protection. Rather than provide confinement,
respirators are routinely worn on some jobs to prevent over-
exposure. OCAW alleged no program of control of the reapi-
ratorr,. There in no program fnr changes of filtering elements
or monitoring of the respirators. Trr.ining in the xir.e of
respirators in not formalized. The washing i:\nchine ur.ed for
wasliing the rer.p Lratora shows ?.0,COO dp:.i on the inside.
-------
Note to Filer, • August 29, 1974
e. Confinement. OCAW alleges that there Is general work area
contamination in excess of that which would result from good
practice. In general, the scrap recovery building has areas
capable of confinf.ment - and it would be practicable to do
so — which are not now confined. In the plutoniuin line, bags
leak.
f. Air effluents. Previously, the company monitored for particles
on the roof. This no longer is done. Process areas operate
with open building doors and with fans drawing air from the
process work areas (not process lines) directly outside without
filtering.
Stack sampling on the 302 and 303 buildings previously was
performed daily, it new is performed weekly. A recently
installed stack for process line air discharge is not sampled.
It is filtered.
2. Failure to permit OCAW representative to accompany on AEG inspections.
After 10 CFR 19 became effective, OCAW alleges that in 1973 and 1974,
two AEG inspections vere conducted and Union representatives ware
denied, by the company, the right to accompany ARC inspectors. OCAW
alleges that the coir.pany was fully aware of the 10 CFR. 19 require-
ments - although the local OCAW representatives were not - and
willfully denied OCAW representatives accompaniment rights. The
OCAW is particularly disturbed regarding this since a local wildcat
strike occurred which, included this issue. OCAW states that it is
the workers representative; has been so designated and recognized;
and the company clearly understand." the long standing desire on
the part of the workers to be represented on AEG inspections; and
that the local president is this workers representative.
OCAW requested that their representative be allowed to attend the
management interview following the inspection as well as accompany
during the performance of the inspection.
3. Failure to notify workers of exposures.
OCAW alleged that NFS, Erwin does not notify workers of exposures
as required. For example, Franklin Tifton was exposed on August 23,
1973, and was only told the x^eek of August 4, 1974, of the exposure.
The notification wan verbal. The company states that in the cc.ne
of Gerald Webb, his exposure records have, been lost. There are
cases where there have been no notification. Where notificnticn
does occur, it nay lir: as long as ihr:>e to five Koathr; after Lhu
exposure. OCAW eontumlr; t:h:tt this failure to notify crmloyeor; o£
exporjprc;- a:; a wfllfu.l act on the part of t:h:- 1 tronren. OtlAW
alleges that: th.i.'. failure to i-nLify appKc" to both notification
of fxporuire:; in c-xceun of lii.iLt,:; nuJ routine cxposurrn.
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198
Note to Filer, August 23, 1974
A. Failure to provide adequate monitoring.
a. At on a t:It.K'., the company used trained health physics technician:
to prov'do adc-nuc'to monitoring of work areas. .lore recently,
the company liar, moved into the practice of 'V.elf-monitoring".
OCAW contends that this practice does not provide adequately
trained personnel to evaluate exposures."
b. OCAW contends that monitoring equipment is not adequately
maintained.
c. Work station air samplers are not located as to accurately
measure ,the exposure of workers. Also, results of roon air
samples are averaged. Because of locations, this averaging
produces results lower than the concentration level to which
workers actually are exposed.
d. The volumes used for calculations of air concentrations are
not correct. Sample buildup severely changes the air flow
through the filtering medium. Consequently, the reduced
yoluna makes the concentration calculations; erroneous ,in a
non-conservative riannar.
e. Air samples, in seme cases, are not changed for a period up
to 48 hours. 17i In permits excessive buildup on the. sampling
medium and renders inaccurate the results. Al_5;o, samplers
are permitted to run th.i entire weekend without changing of
samples. The long cycle of sampj.es would permit small time
periods of high concentrations without detection.
f. With regard to surveys for removable contamination, there are
no instructions on how this is to be done and no established
frequency for surveys.
g. Previously, there had been routine surveys of workers by
health physics technicians. Those no longer are performed.
b,. When a criticality alarm sounds and evacuation occurs, there
is no monitoring within tha work areas prior to reentry to
assure that actual criticality did not occur. On at least
one occasion, workers have been ordered to reenter the plant
with the alarm sounding. Difficulty had been experienced in
resetting the alarm. Under this circumstance, if criticality
had occurred, there would have, been no alarm associated with
the criticality event.
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199
No., to Files Au^St 29> 197A
5. Failure to provide adequate biological monitoring.
a. OCAW expressed concern 0:1 the present method of urine sample
collecilon - collected at employee's home and flr.st collection
on second day alter expo-: are. 'iho OCAW was concerned on lack
of discipline in the method and about 10% of those who have
IS/I/.'T/.'/J been selected for sampling do not actually submit the samples.
b. CCAW was concerned that cases exist where urinalysis does not
show uptakes while a whole body count of the :.U:me Individual
'does shew an uptake. OCAW believes that the reliability of
the NFS, Erwin urinalysis is doubtful. This lack of confidence
is reinforced by the company practice of denying OCAW members
asslgrt"tRant to perform, or assist in performing, analyses. OCAW
contends that worker representatives should assist in the analysis
or the samples should go to a disinterested outside supplier.
c. OCAW is concerned, due to the differences in results, in the small
number of employees whole body ccriuted. Also, due to those.
differences in results, OCAW requests the AEC to order whoLc
body counting for plutonlum, thorium, uraniuu 235 and uranium 233
for all workers.
d. Nasal smears, which formerly were taken r©w-n-H*e*ky, no longer are
taken.
Other specific matters, outside the five areas of concern, discussed by
OCAW representatives are:
1. NFS, Erwin apparently is aware of each AEC inspection and devotes
considerable effort to preparing for each inspection. The AEC does
not have the opportunity to inspect typical activities due to those
preparation efforts. P; c ri ? * >f
2. Previously, during criticality alarm test evacuations, the employees
evacuated through gates to areas distant from the plant. Now, they
arc not permitted to exit through those emergency gates. NFS, Erwir.
attributes this change to new AEG security regulations,
3. Employees use "Oven—off", an oven cleaner, as a means of removing
contai.iiuaL Lou from their hands. Tiie company supplit-s the "Oven-off"
and has not objected to its use.
4. OCAW believes there is a beryllium ha.:ard associated with, a portion
of work at NFS, ErwJn. OCAW is unsure of the in!_orface between AEC
and OS1LA on this matter.
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200
Note to Files August 29, 1974
The OCAW representatives do not desire to have their identifies
protected. They have no objection to these comments and allega-
tions being specifically identified to NFS, Erwin as to source.
On August 27, this summary information was discussed by telephone
with Mr. Wodka. He confirmed the substance expressed the OCAW
concerns.
John G. Davis
Enclosure:
As Stated
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201
Enclosure 1
Meet-Ing vJth CHI, Chemical and Atomic Markers
Internal:tonal Union
Attendees, August 33, 1274
Ato:nic Energy Comnu^sion
Directorate of Regulatory Operations
J. G. Davis, Deputy Director for
Field Operations
G. C. Cower, Regional Coordinator
G. H-. Snita, Regional Coordinator
P. R. Guinrt, Radiation Specialist,
Region II
G. P. Coryell, Fuel Facilities
Inspector, Region II
Oil, Chemical and Atomic Workers
International Union
S. Uodka, OCAW - Legal Department
T. Mazzocchl, OCAV7 (Rep., Int'l Pres.)
E. D. SvTisher, Int'l V.P., OCAW-AFL-CIO
H. A. Adkinson, OCAU, Int'l. Rep.
T. Harris, OCAU, V.P. Local 3677, Erwin
J. Villiams, OCAU Representative
E. Gesrcer, OCAW
R. Lewis, NFS - Health Physics Technician
D. K'isters, NFS - Operator
L. Tolley, NFS, Operator
T. B. Cochran, OCAV7 - Health Physics
Consultant
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202 UNITED STATES Q
ATOMIC ENERGY COMMISSION
DIRECTORATE OF H2GULATORY OPERATIONS
REGION II - SUITE 8'B
230 PEACMTREE STREET. NORTHWEST TuimOMl: 14041 »J«-4 3OJ
ATUANT A. GEORGIA 3O303
In Reply Refer To: QCT 1 1 1974
RO:II:FJL i
70-143/74-01'
Nuclear Fuel Services, Inc.
ATTN: Mr. William Manser, Jr.
Plant Manager
Erwin, Tennessee 37650
Gentlemen:
This letter refers to the investigation conducted at your facility
regarding alleged excessive contanination and unsafe working con-
ditions. Two of the items substantiated by our inspectors are of
more immediate concern to us.
The two items which are in violation of conditions of your license
and which involve failure to meet the "As Low As Practical" criteria
are:
1. Lunchroom Contamination:
Lunchrooms continue to be contaminated in excess of limits
established in Section 3.3.5 of the "Contamination Survey
Program" procedures.
2. High Enriched Scrap Recovery Building
The high enriched scrap recovery building continues to be
contaminated in excess of the limits established in Section
3.3.5 of the "Contamination. Survey Program" procedures.
Based on a telephone conversation between Mr. Long and Mr. Coryell
of this office, and Mr. Manser on October 9, 1974, it is our under-
Standing that immediate action is being taken to assure that
contamination levels in the two areas of immediate concern are
reduced and maintained at levels compatible with AEG requirements.
Specifically, we understand that in addition to corrective actions
already taken you will:
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203
Nuclear Fuel Services, Inc. OCT 1
1. Institute rigorous enforcement of the self-monitoring procedure
for personnel entering the lunchroom.
2. Require that all personnel working in known or suspected con-
tamination 'areas wear smocks over work clothes when in the
lunchroom.
3. Increase the frequency of surveys in the high enriched scrap
recovery building to. assure prompt detection of contamination.
4. Perform immediate cleanup of contaminated areas.
5. Take high volume air samples during cleanup or when airborne
contamination is suspected.
6. Require use of masks as a precautionary measure during periods
of known or suspected airborne contamination.
7. Shutdown building operations if contamination levels remain
above limits for prolonged periods.
8. Revise operating procedures to require use of protective
covering around contaminated equipment or product containers
prior to uduua.j.ng in open areas.
9. Expedite procurement of material and installation of planned
engineering changes to improve containment and building
ventilation.
If the above stated understandings are contrary to your actions
regarding the two items, we should be informed promptly in writing.
You may expect to hear further from us regarding the enforcement
aspects of this matter. In addition, other matters identified to
you previously regarding the investigation findings will be
communicated to you by separate correspondence.
Very truly yours,
N. C. Moseley
Director
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x\^i".Q>>N 204 UNITED STATES
/f/V v, r(i\ ATOMIC ENERGY COMMISSION
KC£Drj
\^-v/^
REGION II - SmTt 8I«
rniRet STBEtT.No«rH
AT UANT A. GLOROIA 30303
In Reply Refer To:
RO:II:FJL OCT 1 8 t0
70-143/74-01
Nuclear Fuel Services, Inc.
ATTN: Mr. William Manser, Jr.
Plant Manager
Erwin, Tennessee 37650
Gentlemen:
This refers to the investigation conducted by Messrs. G. P. Coryell,
J. H. Kahle, and P. R. Guinn of this office on September 17-20 and
September 24-26, 1974, of activities authorized by AEC License No.
SNM-124, for the NFS, Erwin facility, and to the discussion of our
findings held by Messrs. Long, Coryell, Kahle and Guinn with
Messrs. Manser, Idecker and Michel subsequent to the investigation on
October 7, 1974.
Areas examined daring tha investigation included allcg-ticns of
excessive radioactive contamination and unsafe working conditions.
Within these areas, the investigation consisted of selective
examination of procedures and representative records, interviews
with personnel, and observations by the inspectors.
During the investigation, it was found that certain activities under
your license appear to be in violation of AEC requirements. The
violations and references to pertinent requirements are listed in
Enclosure 1 of this letter.
This notice is sent to you pursuant to the provisions of Section 2.201
of the AEC's "Rules of Practice", Part 2, Title 10, Code of Federal
^Regulations. Section 2.201 requires you to submit to this office,
within 20 days of your receipt of this notice, a written statement
or explanation in reply including: (1) corrective steps which have
been taken by you and the results achieved; (2) corrective steps
%which will be taken to avoid further violations; and (3) the date
when full compliance will be achieved.
One item which remained unresolved at the conclusion of the investigation
has been referred to Regulatory Operations Headquarters for further
evaluation. The iten is discussed in Enclosure 2 to this letter. We
will inform you of the results of this evaluation when available.
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Nuclear Fuel Services, Inc. OCT 1 8
If you have any question concerning this letter, we will be glad to
discuss them with you.
Very truly yours,
//'
N« C. Moseley
Director
Enclosures:
as stated
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206
Enclosure (1)
RO Investigation Report No. 70-143/74-01 QCT 1 8 1974
NOTICE OF VIOLATIONS
Certain activities under your license appear to be in noncompliance
with AEC and license requirements as indicated below,
The following violations are considered to be of Severity Category II:
1. 10 CFR 20.201(b) requires licensees to conduct such surveys as
•necessary to comply with the Regulations. NTS has chosen to
employ urinalysis as a means of compliance with this requirement.
Contrary to the above, the evaluation of urinalysis results was
not adequate to determine compliance with 10 CFR 20.103.
2. License Condition No. 8 incorporating the license application
dated June 3, 1963, Section 3.3.5 of procedures entitled
"Contamination Survey Program," states in part, "....that smear-
able contamination' less than 500 d/m is considered acceptable in
certain areas."
Contrary to the above, lunch room contamination surveys during the
period July through September 1974, including surveys made in the
presence of the AEC inspector, revealed contamination levels which
exceeded the specified limit. Levels up to 4000 d/m were detected.
3. License condition No. 8 incorporating the license application
dated June 3, 1963, Section 3.3.5 of procedures entitled
"Contamination Survey Program" states in part, that "....in
plant processing areas, smearable contamination to 5000 d/m is
considered acceptable."
Contrary to the above, contamination in the Building 233 pro-
cessing area has exceeded the specified limit on a continuing
basis during the period July through September 1974. Levels
up to 30,000 d/m were detected.
4 License Condition No. 8 incorporating license application dated
June 3, 1963, Section 3.3.2, "Respiratory Protection," requires
in part, that "....employees wash their respirators at the end
of each shift and that filters on the respirators be changed
once each week or more frequently as determined by the Health
and Safety Department."
Contrary to the above, there was no evidence that respirators
were cleaned daily and that respirator filters were changed
once each week, prior to initiation of a revised mask and
respirator protection program*in August 1974.
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Nuclear Fuel Services, Inc.
Enclosure (1)
207
5. License Condition No. 8 incorporating license application dated
June 3, 1963, Section 3.0, "Health and Safety," paragraph 3.5,
"Basic Health and Safety Rules and Regulations," item 15, states
"Bioassay samples must be submitted by all laboratory, operating
and maintenance personnel on designated dates."
Contrary to the above, bioassay samples were not submitted by 68
persons including laboratory, operating and maintenance personnel,
Delinquent periods ranged from three months to two years.
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208
Enclosure (2)
RO Investigation Report No. 70-143/74-01
ITEMS REFERRED TO REGULATORY OPERATIONS HEADQUARTERS
FOR FURTHER EVALUATION
Air Sampling
Investigation findings confirm the allegation that air samples run
the entire weekend without changing of samples, versus the normal
workweek practice of changes each 24 hours. This weekend schedule
has been in effect since initial plant startup. Investigation
findings relating to the corollary allegation that the long (72 hour)
cycle of samples would permit small time periods of high concentrations
without detection is being referred to Regulatory Operations for further
evaluation.
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209
Dr. Mills: Thank you, Dr. Cochran, Mr. Speth.
The point that Mr. Speth made has to do with revising plutonium
standards. Is it your concern that the safeguards program or a failure
in non-compliance exists as they are today, that any release of the
plutonium because of non-compliance or breakdown of the safeguards pro-
gram should be such that there should be no public health — risks to
public health, I guess, is the word I speak of.
Is that the focus of the discussion on the non-compliance, the
failure of compliance?
I am trying to tie in, in terms of establishing standards, the
safeguards program and the incidents that you talked about of failure
to comply that the AEC found out.
Is what you are proposing to address in terms of the standard
itself such that those releases would not be of public health risk?
Mr. Speth: We are not sure we understand the question. But one
thing you may be asking is why we did discuss the safeguards problem
in this particular format.
I think the answer is that we do not feel you can make an
artificial separation between those issues. When we consider plutonium,
we have got to consider the whole fuel cycle and its implication.
Obviously, there are certain jurisdictional things that EPA cannot
do, but it is also true, you have got to make a basic societal judg-
ment about the desirability of moving into what the AEC has called
the plutonium economy, large scale reliance on plutonium as a fuel.
When we make that judgment, we would better know all the facts
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210
and be aware of both sides, all of the problems that are associated,
not just the plutonium toxicity problem.
Dr. Mills: My point was, in the establishment of an environmental
ban, the standard, I do not see how it could insure against failures
of non-compliance.
Dr. Cochran: One standard you might consider is to not use this
material.
Returning to the question of safeguards, there has been some
discussion earlier and one of the points in the Federal Register is
with respect to the costs versus benefits of use of this material. You
cannot just weigh the benefits against part of the cost and eliminate
the safeguards aspect. There was even some suggestion here earlier
this morning that we should weigh the cost against the cost, that is,
the effects of releases of plutonium weighed against the effects of
natural background radiation.
The point we would make with respect to the safeguards is that
it is one of the principal, if not the principal, cost items in this
weighing. These two issues, the safeguards and the toxicity are of
principal concern to us. When we look at these and the benefits we
do not see why there would be any commercial plutonium recycled at this
time. On the benefit side, we made the statement here earlier in
Mr. Speth's presentation that plutonium recycle reduces light water
costs by 10 or 15 percent. That is really the AEC statement, not
ours. I would submit that the cost of reprocessing and fabricating
mixed oxide fuels has gone up so drastically in recent years, there is
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211
a very good chance that there is no economic incentive, forgetting
about safeguards for plutonium recycling at this time.
Some of your evidence for this is in the materials presented in
our comments on GESMO, the material presented by the intervenors in
the licensing proceedings going on at NFS, West Valley, and also in a
recent G.E. report on nuclear energy parks.
Dr. Mills: Do you agree, then, that in establishing a standard
we have to look at the benefit of the activity as well as the health
impact? Can I interpret that correctly?
Dr. Tamplin: Yes. I think that is true. Also, that we addressed
our comments here to most of the items that were listed in the Federal
Register that these hearings were about, which was not strictly standards.
The first one was general, to include consideration of general con-
cern, including the public and social implications of plutonium utili-
zation and the factors involved, balancing benefits and costs.
The recommendation of this panel, the social implications of
plutonium are such that it should not be an item of commerce.
I think that is a possible conclusion you could come to.
The fourth item here was applications using plutonium to include
consideration of current and projected uses of plutonium and other
transuranic elements.
The estimated quantities in each application and the magnitude of
the possible releases to the environment: From the industry, you are
going to hear a very rosy picture of the releases in the environment.
1 think these non-compliance situations should cause you to regard
this rosy picture with some skepticism.
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Dr. Mills: Fine. Thank you.
Dr. Taylor?
Dr. Taylor: Well, his last statement has made me change the
remark I was going to make. I thought it was pointed out this morning
that our discussions on radiation protection standards really involved
two parts, you might say: the technical part on the one hand, and the
social, political and economic on the other.
We are sitting here; most of us at this table, if not all of us,
are all technical people. We are certainly not politicians in the
ordinary sense. I do not think any of us at this table are qualified
to comment on any of the social or political implications that have
been presented in this very interesting discussion.
Dr. Tamplin: You are certainly as qualified as any other human
being.
Dr. Taylor: That is not the purpose of this particular conference
in my judgment. I am quite willing to talk about these things, but not
here.
Dr. Cochran: As we read the Federal Register this is the purpose.
You may have been deceived when you were invited.
Dr. Mills: Dr. First?
Dr. First: I am not sure I understand your position here,
gentlemen. On the one hand, you are talking about a lower standard
than presently exists, a liability of magnitude.
On the other hand, you are saying let us do away with plutonium
completely as well as all other radionuclides, if I understand your
position.
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213
Is this not incompatible?
Dr. Cochran: I do not think it is incompatible. You say our
position is let us do away with plutonium. Our position at this time
is you should not be recycling this material. You should not be
removing it from the fuel rods.
The reason I do not think it is incompatible, ~L think given the
present evidence as we see it, the occupational exposure standards and
the levels at which people are currently being exposed are levels which
we believe carry with them a high probability that these people would
get lung cancer; so regardless of whether you want to do away with plu-
tonium recycle, you should not have a standard that unnecessarily exposes
the workers. A judgment on plutonium recycle involves weighing of costs
and benefits. The standards issue involves consideration of the fact
that when you weight cost and benefit, there is no equity arrange-
ment, whereby the people that pay the costs are the same people that
get the benefits. The workers are receiving the costs, and people who
use the electricity are the receivers on the benefits side.
Dr. Tamplin: I might add one other thing. That is there is an
existing plutonium industry today. There are, say, people in the
military program exposed to it. So standards are something that have
to be resolved whether or not plutonium is recycled.
But you have to recognize there is another industry besides the
nuclear industry that would be involved in standards. One of them is
the industry that makes such things as pacemakers, using plutonium 238.
The other industry is fire detector equipment, where they use americium.
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214
So the plutonium standard itself can be considered separtely from
the whole question of the nuclear power industry.
Dr. First: I think that clarifies it. The point you made just
now was perfectly all right, while I am sorry that you did not want to
reprocess spent fuel rods.
Dose that signify that you are satisfied with the present nuclear
operations if you do not reprocess spent fuel rods, or is there still
another issue in your minds?
Mr. Speth: We obviously have a problem that is a major controversy
in the country today, for the general safety of the nuclear power
industry we have now.
Dr. First: Even I am aware of that.
Mr. Speth: I think what we are saying here, at a minimum, is let
us not escalate that problem by going ahead with plutonium recycle.
Let us not escalate by going ahead with the breeder reactor. We
feel that the introduction of those new technologies will represent a
substantial escalation in the problem we already have, the problem that
the new field is already out of control and serious.
So basically, that is what we are saying here in connection with
plutonium. Let us not go ahead with the plutonium economy. It is
just going to be too risky and too dangerous. It does not really
address the question of whether what we already have is already too
risky and too dangerous.
If you want me to address that, I can tell you what I think, but
it is really not germane.
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215
Dr. First: Well, if it is not, then I certainly would be happy
to pass it over.
I think I have gotten a pretty good idea of what you are not for.
In the context of the present hearing, could you tell us what you are
for? What do you advocate as a positive approach, other than just
doing away with things?
Mr. Speth: I am not quite sure what you are saying. It is our
feeling that assuming the light-water reactors will operate, that we
should explore what is the safest thing to do with this fuel.
Given that we do not favor recycling it or making the plutoniuro
industry, or giving birth to a plutonium industry, what is the safest
thing to do?
That may be what we suggested that some people should consider
simply leaving it in the fuel'rods.
Dr. First: Indefinitely?
Mr. Speth: Yes. At some point, a generation hence, you may want
to fission that plutonium, but certainly not under current circumstances,
in the world that we have today, with the problems that we have.
I am not sure that is positive enough.
Dr. First: I think that gets at what I was after.
I wanted to know what you stood for, as well as against.
One other point I would like to ask before I give up on this.
That is, the information that we got this morning from a number of
vistors regarding toxicity of the plutonium seems to be somewhat at
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216
odds with the information that you presented here, in fact quite
considerably.
In these presentations there was a good deal of reference to the
publications and studies. I was wondering if you have documented the
biological basis for your recommendation of a plutonium standard.
Did you say 100,000 times, or 1/100,000 of. what the present
total is, or is this something which you are planning to do tomorrow?
If it is tomorrow, I will pass the question.
Dr. Tamplin: We have a report that we have issued, and also, we
have made responses to some AEG reports, a draft on the LMFBR, and draft
on plutonium recycle. We have also commented on one of the more recent
reports that came out of AEG on WASH 1320.
If this material is not already available to you, we would
certainly make that available tomorrow.
Dr. First: Is this in the handout which I have just gotten?
Dr. Tamplin: Some of it is, but anyway, that will be available
tomorrow.
Dr. First: I will pass that question, then.
Dr. Tamplin: The Environmental Protection Agency did not supply
us with this material, since it was supplied along with our petition tc
the Agency. I guess that is the major reason why we did not bring
copies of our report.
Dr. First: I just want to be sure that it will come up at some
point in these hearings, but if it is planned, I will pass it.
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217
Dr. Cochran: I might add, we assumed that the panel members would
have been familiar with most of that material already.
We submitted that material, our first report, to the EPA on
February 14. They have had 10 months to call us and invite us in,
if they wanted information on it. We are a little bit puzzled that
they wait 10 months and want us to sit down with them in this short
time and go over that material.
What we intended to do was to be prepared to answer questions
on that material. If you want a presentation on that, 1 think we
could do that tomorrow.
Dr. First: I think I have made my point clear.
Dr. Mills: Dr. Radford?
Dr. Radford: First, I have had the material that has just been
referred to, so at least one member of the panel has seen it, including
WASH 1320, so I am prepared to ask questions as to specific sections of
that.
With regard to the presentation we have just heard, I would like
a little further clarification. I am not quite clear myself.
Is it my understanding that your position is that breeder techno-
logy which is pretty dependent on plutonium isolation as I understand
it, thereby, in your opinion, should not be embarked upon?
Is that one conclusion of your statement?
Dr. Cochran: I think our position with respect to the breeder
program is that it cannot be justified at this time from an economic
cost-benefit standpoint, that it certainly exacerbates the hazards in
plutonium toxicity.
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218
Our position would be we would advocate that you would cancel
the commercial introduction of this facility. We would not propose
at any time that you should just have wholesale elimination of the
program.
Ultimately, if you continue to rely on fission as the energy
option, eventually you would need a breeder of some sort. So we have
not suggested that you cancel the R & D aspect of the program.
I think our position as we present it in our 450-some odd pages
to the AEG, commenting on the impact statement of the breeder, it is a
misallocation of R & D financing, that you should cut that program back
and put that money where it would do more good, in other energy techno-
logies.
Dr. Radford: Before getting to that issue, we heard testimony
this morning from General Electric, and I do not believe it differs
greatly from what we heard from the AEG later, that the availability of
low cost uranium fuel is such that by the year 2000, maybe 2010 or 2020,
depending on your estimates, we will be in a similar position to where
we are with oil and the inadequate domestic resources.
The estimates for a viable breeder based fuel breeder program
providing adequate electricity to supplement the light-water reactors
must get underway now if we are to have it adequately tested by the
time it must go on line, somewhere around 2000, or 2010 or 2020.
Now, you are in effect saying to defer a further development of
the breeder program and would seem to me to say, we should also defer
any further development of the light-water reactors.
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Dr. Cochran: The arguments are different. You can make a case
against the LMFBR, assuming you have a viable light-water reactor. I
would separate those arguments from the arguments against having any
sort of fission economy.
With respect to the first, the argument of why there is no economic
incentive with respect to the breeder, I documented my case in a book.
Subsequently NRDC, primarily the three of us here, have updated that
work in NRDC's comments on the draft LMFBR Environmental Impact
Statement. These comments contain analysis that takes issue with the
AEC's and General ElectricTs position with regard to uranium availability
and a number of other assumptions.
The uranium availability is only one of several keys, Dr. Wolfe
was referring to earlier. It is an unpublished study that has been
bounced around in OMB and NFS and elsewhere. It, too, has what I
believe are some erroneous or unjustifiable assumptions about the input
data. There is enough flexibility so that by shifting your assumptions
with respect to the price of the reactor plants, the uranium availability,
and energy demand, you can generate senarios where it appears that a
breeder will be needed. We take strong exception to many of these
assumptions.
Dr. Tamplin: EPA, in their comments on the fast breeder, also
were quite critical of the economic analysis. When I say also, one of
the questions relative to when plutonium should be used, one of the
arguments for the fast breeder was it had to be a crash priority pro-
gram. They wanted it by 1985.
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This is one of the aspects of the economic analysis that causes
it to fall apart, that the breeder would not be economical in 1985.
They say the year 2000 or something, so one of the things that we are
proposing is let us not move into this plutonium economy with all kinds
of unresolved problems.
Let us stretch the breeder program out. Let us take the R & D
funding and put it elsewhere. Then we can resolve some of these un-
resolved issues relative to plutonium in the interim period.
Dr. Radford: Would not you say that one of the unresolved issues
about the plutonium technology or the breeder technology is whether the
large breeders will work?
Is not that a fairly important issue to get settled at as early
a date as we can?
Dr. Cochran: It depends on how you define "work." There are some
areas of research and development that we would suggest could be
continued and should be continued, because they are rather benign.
When you are talking about putting a 350 megawatt commercial
facility in one of the areas of the country that has the worst meteoro-
logical conditions, when you do not know the upper bound on the explosive
potential of that reactor, when the plutonium standards are in question,
and when you do not have adequate safeguards programs in hand, that is
not a good course of action.
So that is why I say let us cut out the commercial component of
the breeder program. Then we can talk about what sort of R & D we should
continue to prove out some of these unresolved issues.
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Dr. Radford: I was not aware that this was really in the commer-
cial stage, even though I recognize that some of the utilties are
contributing to it. I do not think it was designed for commercial pro-
duction of power.
Let us get off that subject, if I may, and get to the question
which you raised on the issue of economics.
In relation to the competitive value of different fields, do you
think that pure economic concerns should dominate whether we go this
way, that way, or the other way?
We heard, for example, today some projections by Dr. Wolfe about
how much it is going to cost to generate electric power by solar energy.
Do you think that type of economic analysis, correct or not, ought to
be the basis of whether we develop solar power?
Dr. Cochran: I am not an economist, but I would prefer that you
be a little more specific on what you mean by economic assessment,
because there are many economists who would include all the social costs
and so forth in their economic assessment in the weighing of the costs
and benefits.
I certainly think that economic analyses of the type you are
referring to should be one input in the decision making process, but it
should not necessarily be the primary one. Clearly, it should not in
the case of breeder reactors or plutonium recycling.
The health and safety issues, in my view, are the primary issues
because the risk in these areas is so great.
Dr. Radford: So questions of cost of the safeguards levels that
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you might consider acceptable, you would not consider that necessarily
binding?
Dr. Cochran: I do not understand your point.
Dr. Radford: Let us assume you could build a facility handling
Plutonium where you could absolutely contain it completely at sufficient
cost.
Let us make the assumption, anyway, that the containment is
partially a function of cost. The issue of how much that costs would
not be an important issue as far as whether to go with plutonium recycle
or not?
Dr. Tamplin: I think you are getting sort of at the issue there.
One of the reasons why we brought up the social and political impli-
cations of the safeguards program is that safeguards programs have to
exist here in the United States before being applied. The social con-
sequences of a breakdown in the safeguards program are such that
certainly, if you were going to have plutonium, whatever it costs in
terms of dollars to make a safeguards system safer would certainly be
justified because the social implications of a breakdown, in plutonium
diversion and nuclear blackmail, are such that the dollar cost would
bear no relationship to the social costs.
Dr. Radford: I am sure that some R & D could be developed, for
example, to poison the plutonium fuel so that it could not be readily
handled by somebody — I just toss that out for a comment.
That is an area of R & D that could be developed.
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You mentioned fines at the General Electric and Nuclear Fuel
Services, West Valley plant. Were those fines for the breach of
plutonium containment?
Dr. Cochran: No. They were safeguards violations.
Dr. Radford: Safeguards regarding unauthorized entrance?
Dr. Cochran: According to the report the safeguards violations
involved "failure to have required intrusion monitoring, alarm systems
and physical barriers to protect against industrial sabotage."
That is a quote from the AEG news release.
Dr. Radford: So that really had nothing to do with whether
fission products, plutonium or other transuranics were distributed
within a plant?
Dr. Cochran: That is correct.
Dr. Radford: Finally, with regard to the standards, most of the
concern that you have expressed with regard to the number of these
episodes deal with occupational exposure. Is that correct?
Dr. Cochran: That is correct.
Dr. Radford: Unfortunately, it is my understanding that the EPA
has no jurisdiction over occupational exposure, so I ask the question,
do you believe that plutonium, having the nature in itself, being what
it is, is quite likely to be carried outside the plant if there are
significant occupational exposures?
Are there ways to deal with this?
Dr. Cochran: I believe there is already evidence of its being
carried outside the plant. Rocky Flats is the most alarming example
in that regard.
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I think the EPA ought to be privy to how the industry reacts to
regulations. Their regulations will, in fact, affect the indstry and
their effluent releases. We have presented examples of what is going
on in the industry. The present situation indicates they are not
following the regulations.
Some of the things that I have seen and heard from workers would
suggest to me that some of these facilities are lacking in the rudi-
ments of accepted health physics practices.
I think it would be fair for EPA to infer that if they impose
stricter environmental releases standards, they should not expect any
better performance by the industry than we are getting presently with
respect to the worker standards.
Dr. Mills: One point of clarification on this. EPA has no
regulatory authority as far as occupational is concerned.
Dr. Radford: A final question about the standards: If your
standards are adopted, how would you propose that it be enforced?
Dr. Tamplin: Rigorously.
Dr. Radford: Would you have instruments available that could
detect the concentrations that might occur?
Dr. Tamplin: You mean, is it possible today to go out and measure
one particle per meter square of a surface? I think that is very
difficult at this point, at this particular time.
The fact may be that by the time you are able to detect plutonium
in the environment, you are already at too hazardous a situation.
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That is a question which, in a way, this panel is addressing
relative to the standard. If you can detect plutonium, are you already
beyond the point in the environment where it is acceptable?
Dr. Mills: Dr. Garner?
Dr. Garner: Let us start with the trivial.
There is one statement in Dr. Cochran's presentation which I found
extremely irritating. It is the sort of statement I always find
irritating.
After referring to something from Rocky Flats, you talk about
plutonium being found among cattle. Then you go on to say the impli-
cation of this for humans in the area is obvious.
It is not obvious to me at all. Cattle poke around in the grass
and inhale a lot of material. People do not poke around in the grass
and inhale this material. So to me, this is not as obvious as it is
to you.
Could you expand on that?
Dr. Cochran: I do not know that it really requires a great deal
of expansion. We do not know precisely how plutonium particles got
into the lungs of the cows.
Certainly, it indicates that the plutonium in the area is
available. How the lungs of humans in the area compares with the lungs
of cows in the area is another thing, but we do know that Dr. Ed Martel
has measured plutonium in the environment of Rocky Flats and he has
found plutonium particles in the air in the area. So the implications
are obvious, I think, but quantitatively they may not be so obvious.
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Certainly, it indicates there is environmental contamination of plutonium
in the area. The implications are that this may be at levels that are
not adequate from the standpoint of public health.
Mr. Speth: One other comment on that.
I do not know about yours, but my kids poke around in the grass
a lot. I am not sure you were serious. Were you?
Dr. Garner: It is the kind of statement that leaves things hang-
ing in the air. I hate to see a statement where the implication is not
obvious.
Mr. Speth: The report, as I understand it, is just a one page
abstract of it, but it is circulating around.
Dr. Garner: As I told you, it was a trivial matter. I did not
want to make a great deal of it.
Since a lot of questions have been asked, I will confine myself to
just one thing, the violations.
You painted a terrible picture of violations in an embryo plutonium
industry, but I think we ought to get our feet back on the ground again.
This is not unique to the plutonium industry. I think if you
would like to go and look at a great many other industries, you will
find equally horrifying violations.
Dr. Cochran: NRDC works in those areas also.
Dr. Garner: With plutonium, we are talking about something which
may produce health effects. In other industries, such effects are
certain.
Mr. Speth: We have been trying for some time to get EPA to do
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something about carcinogens in the environment, with absolutely no
success, so you are in a better position to try to do something about
that than we are.
Dr. Garner: I am just a simple research person.
I think you have confirmed what I think you are saying, that is,
that industry as a whole should look into safety precautions.
Industry as a whole, not just the plutonium industry, but industry as
a whole.
I would just like to end by saying one can interpret things in
different ways. The files that Dr. Cochran has referred to, you could
argue always, if you want to.
You could argue that if we accept G.E.'s statement, that it has
operated safely, that is has not exposed people beyond a reasonable
amount to plutonium, has not contributed significantly to the environ-
ment and has done this despite the fact of safety violations — If
one imposed safety regulations which are supposed to be enforced,
then one could argue that things could be better still. We would be
better off.
This, I know, is not a good argument, but I am simply trying to
say that you can turn things anyway you like.
Dr. Tamplin: Of course, General Electric is still the safest fuel
reprocessing plant in the country: it does not operate.
Dr. Mills: I would like to add for the record, there is a comment
from Mr. Deuster which has to do with what Dr. Cochran was talking
about, from the standpoint of NFS, Erwin.
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That is, he says the alleged violation about the NFS Erwin facility
does not involve plutonium. They are all uranium related.
Dr. Cochran: I thought I made the relevance of the violations to
these hearings clear in my statement.
Dr. Mills: Thank you very much.
(Note: The following testimony by Dr. Tamplin was given on the
afternoon of the llth but is included here in the proceedings to aid
in continuity.)
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Dr. Mills: I would like to get started, please.
I would like to first bring your attention to what the main part
of the schedule is like. We have run into some problems with plane
schedules and what have you.
The next participants are from the Natural Resources Defense
Council. Dr. Tamplin will speak.
Subsequent to that will be Ms. Judith Johnsrud from the Environmental
Coalition on Nuclear Power.
After that, we would hope that the members of the biomedical group
from the AEC could be around to answer additional questions the panel
might have. The additional questions, we would hope to limit to, at
the most, 45 minutes.
So, Dr. Tamplin.
Dr. Tamplin: I would like to start off by making just a few
general remarks.
One of the things that I think should essentially be cleared up
for the record, we have heard a number of people mentioning various
standard setting bodies. As I read the laws of this country, there
are two standard setting bodies that are standard setting bodies so
far as radiation is concerned. They are the Environmental Protection
Agency and the Atomic Energy Commission.
Now, there are other groups like the International Commission on
Radiological Protection and the National Council on Radiological
Protection and the BEIR Commission of the National Academy of Science.
None of these bodies have any responsibility whatsoever for setting
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standards. They make recommendations, but when it comes to the pro-
cesses of setting standards, I think it is becoming quite ludicrous
the way the AEG and the Environmental Protection Agency always refer to
these advisory bodies as standard setting bodies and try to pass the
buck there.
1 might even say that if one looks at the legislative history of
the National Environmental Policy Act, 1 think you will conclude that
legislative history of that Act indicated that the NCRP and BEIR Committee
were not recognized by Congress as standard setting bodies, because when
that bill passed the House, it had an amendment on it which was going
to emasculate the EPA's position in this situation by saying that they
had to seek the advice of the National Commission on Radiological
Protection and the BEIR Committee.
There was a lobby in the Congress on that and that particular
item was removed in the Senate. The one passed in the Senate did not
contain that and the event was dropped when the conference between
the two houses took place.
I think the legislative history that established the Environmental
Protection Agency indicates that the NCRP and these other committees
are not standards setting bodies and are not so recognized by the
Congress in that respect.
So when it comes down to setting standards, the buck stops with
EPA and the Atomic Energy Commission.
Now, certainly, there is a great deal of philosophy or a great
deal of principle that has to be involved in the setting of standards.
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I think one of the unfortunate things that exists at this particular
point, both in the AEC and in the Environmental Protection Agency,
there seems to be no clear statement of what that principle is.
The various agencies such as NCRP have talked about something
that is as low as practicable. That is, basically, I think we have
seen in some of the discussions here, that is basically some kind of a
way that an industry can survive even though the regulations which
regulate it are not necessarily in the best interest of the public
health and safety.
The EPA or AEC should clearly enuciate a principle that is involved
in terms of setting radiation protection standards. I think we have
actually sort of a legislative principle that came out of the Congress
which said there should be no degradation in the air quality.
Well, this is kind of a principle. We do not see any of this in
the area of radiation protection, and if you look at the ICRP recommen-
dations, the limit for genetic exposure, they indicated that they felt
the level was such that it allowed latitude for the development of the
industry, and that they hoped it was a proper balance between benefits
and risks that were associated.
They only hoped that; but they did know that it allowed sufficient
latitude for the development of the industry. So that is kind of as low
as is practicable.
But that does not seem to me to be a sound principle of public
health on which to establish standards. We have also heard in these
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discussions here a number of people saying, well there is not enough
information at this particular point to determine what the standard
should be.
Certainly we have heard that with respect to plutonium, that there
is kind of a growing consensus that the standard is too high. It could
be reduced, we heard here today, by a factor of ten to a hundred.
Then we hear the comments, I do not think we should do anything
with the standards until we get some more information.
This, again, does not seem to be a solid principle or practice for
public health. It seems to me that our Environmental Protection Agency
or agencies that are set to protect the public health should clearly
enunciate the principles upon which regulations will be based.
When information is lacking, they should determine the kind of
approach that would be used to establish the standard. Now, when they
say that in the case of plutonium, that we do not know enough to set
adequate standards today, so depending upon your point of view — Mine
would be, well then, let us not fool around with plutonium until we do
know what the standards should be because we do know that the plutonium
standard is not adequate.
The other approach is to establish a standard on the basis of the
conservative and supportable hypothesis and then let the industry develop
the technology to meet the standard. But the idea of determining what
industry can do before you set a standard, or wondering whether industry
can survive with a particular standard, should not really be part of the
practice for public health.
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We have heard also here a great deal of discussion about fallout
of plutonium. It is fairly easy to recognize that both the chemical
and physical nature of the fallout plutonium is most likely different
from that which will be expelled as part of a nuclear reactor program
in the plutonium industry.
Not only is the plutonium in particles that are of much smaller
particle size than one could anticipate this industry developing, the
specific activity of the plutonium particles is also significantly lower.
From the nuclear power industry, you can expect particles of plutonium
oxide but the plutonium in the particles from fallout is mixed with
the debris that constituted the remainder of the device, and also
indicates that some of the surface and water is mixed in with melted
and reconstituted soil.
1 think there is also some question in terms of the pathways to man.
Whether studies of plutonium fallout can be transposed immediately to
the releases from nuclear facilities.
Of course, the other thing about the nuclear facility is their
releases will for the most part be ground level releases, and they are
going to cause a much more circumscribed environmental consequence than
some of the very high altitude tests of nuclear weapons.
Now, I would like to then get into, briefly, a discussion of the
hot particle issue and our petition to the Environmental Protection
Agency and the AEG asking them to modify their radiation protection
standards so far as they apply to alpha emitting radionuclides in soluble
form, deposited in the lung.
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Just briefly, I would like to describe the nature of the hypothesis
on which this is based. I might say I have not been concerned about
plutonium since the Chalk River Conference in 1944. My concern about
plutonium only began in 1967.
At that particular time, when we first looked at plutonium in the
laboratory, we recognized that one of the major ways in which plutonium
from the nuclear industry would be dispersed into the environment would
be in the form of highly radioactive particles of plutonium oxide which
are insoluble in deep respiratory regions of the lung and which have
long residence in the lung.
So we were presented with more or less a unique situation where you
have a very small body of tissue that is irradiated to a very high dos-
age of radiation. When we looked at the available data that related
to irradiating small bodies of tissue at very high levels, we discovered
that that data indicated that cancer was an almost inevitable result from
those experiments.
Now, most of those particular experiments, of course, dealt with
various experimental animals and exposure of small areas of the skin.
At that particular time, this represented the kind of major information
you had. Plutonium particles in the lung, very high doses, and when
you look at experiments that did that, you found out that cancer was
a very frequent result of these terms.
So at that particular time, we suspected that these hot particles
deposited in the deep respiratory tissue in the lung may represent a
unique carcinogenic event. It was then last year that Tom Cochran and
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I reexamined the information that was available which had been prepared
and developed by Don Geesaman.
We examined that information and what new information was available
and then supplied some quantitative numbers to this hot particle hypo-
thesis which eventually led to our petition.
Now, some of the new information which is available to suggest
that hot particles deposited in the deep respiratory zone of the lung
may indeed represent unique carcinogenic events comes from — I think
we heard a discussion of it by Dr. Richmond, which was the lesion
which was excised from the palm of a mechanic.
This lesion was caused by plutonium. I think it was .8 microgram
of plutonium embedded in his skin. I would just like to read if I may
the description which is found in the paper discussing that particular
lesion, which he excised.
They said the autoradiograph showed precise confinement of the alpha
tracks to the area of maximum damage, and their penetration into the
basal areas of the epidermis, where epithelial changes typical of
ionizing radiation exposure were present. The cause and effect relation-
ship of these findings, therefore, seemed obvious.
Although the lesion was minute, the changes in it were severe. The
similarity to known precancerous epidermal cytological changes, of course,
raised the question of the ultimate state of such a lesion, should it
be allowed to exist without surgical intervention.
Now, as I read that, I gain the impression that here was a lesion
caused by a small particle of plutonium embedded in a palm of a hand
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that had changes in it which made the pathologist think that if that
lesion was not excised, that there was a reasonable probability that it
would progress into a cancer.
Now, there have been some experiments — These were also performed
by Dr. Richmond, who injected a few small microspheres of plutonium
into the femoral vein which subsequentely became lodged in the capillary
beds of the lungs.
Now, commenting on these experiments which involved rats,
Dr. Richmond indicated that he found lesions around these microspheres
in the lungs of the rats. His description is the pertinent thing here.
Such a lesion with coagulates degenerate and subsequent liquefaction due
to the large local dose of radiation at high dose rate has been reported
by Lushbaugh, whose description of a plutonium lesion found in the
dermis is very similar to that observed for plutonium in the lung.
Now, Dr. Richmond et al subsequently went on and injected these
microspheres into the lungs of hamsters. In the hamster lungs, they
also observed cytological changes around the microspheres.
In the progress report for January through December 1973,' concern-
ing these lesions, they said: A consistent observation of this lesion
after drastically different induction times could lead to speculation
that the amount of tissue irradiated is an important element in the
timing of the tumorigenic response.
There has been no increase in the tumor observed within the past
year. However, the epithelial changes described above should be con-
sidered as precursors of peripheral abnormalities.
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So, in other words, as we look at experiments for small bodies
of tissues exposed to high doses of radiation, we find that cancer is
a very frequent result. When we look at small particles of plutonium
embedded in the skin, we see that they develop a lesion which suggests
that it should be removed because it may develop into tumors.
When these hot particles are then put into the vast capillary
bed of the lung, lesions develop around those which have similar cyto-
logical changes and which suggest some kind of an incipient carcino-
genic response.
Well, now, to proceed further with standards one has to first accept
the hypothesis that these hot particles of plutonium embedded in the
lung tissue may be capable of producing cancer, having a unique car-
cinogenic risk associated with them.
If one, looking at the available data, does not accept that, then
of course, the need to go ahead and talk about standards for hot partic-
les just does not exist.
My own feeling is that the evidence suggests that we should be very
cautious in considering these hot particles in the lung because experi-
mental data and biological data, biological observations, suggest that
they do pose a unique carcinogenic hazard.
So, once one has accepted that, then in order to have standards
you have to, then, go ahead and develop some kind of a risk estimate for
the particles. You need some approach towards a quantification of this
observed, especially significant carcinogenic risk.
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Well, to arrive at a quantitative approach, we use the experiments
conducted on the skin of rats on which was observed a high carcinogenic
response when some 24 square centimeters of rat skin was irradiated.
This radiation dose got up above 2,000 rads, getting up to five tumors
per rat. There were a variety of experiments with x-rays and so forth
but when he put these all together, he found that the number of tumors
which he observed were strongly correlated with the number of atrophied
hair follicles that were produced in this irradiated mass.
It was between one tumor per 2,000 to one tumor per 4,000 atrophied
hair follicles. This, then, represented a correlation between disturbed
architectural unit of tissue and the subsequent development of cancer.
In developing quantitative values for hot particles we adopted
this risk measurement as the risk for hot particles that when you created
a disturbed tissue mass or disturbed tissue architecture that chances
of that going on to developing cancer would be 1 in 2,000 as is observed
for the disruption of hair follicles.
The next thing which one has to turn to is what really constitutes
a hot particle. There again we use the experimental observations of
Albert's skin data which indicated there was a precipitous change in
respond to dosage when it went above 1000 grams. So that then we
use to define that limiting activity per hot particle so that the hypo-
thesis proposed then with the quantitative values for establishing
radiation protection standards was if a particle deposited in the deep
respiratory tissue is of such an activity as to expose the surrounding
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lung tissue to 3 dose of at least 1000 rems, in one year this particle
represents a unique carcinogenic risk.
The biological data suggests that such a particle may have cancer
risk equal to 1 in 2000. So this then is how we arrived at the
quantitative numbers related to exposure.
Now plutonium 239, a particle which delivers 1000 rems per unit,
an oxide particle which delivers 1000 rems per year would be a particle
6/10th of a micron in diameter and containing .07 microcuries. Than
then was the basis for establishing the hot particle standard which we
proposed to the EPA and the Atomic Energy Commission.
1 might say that personally I feel that the observed biological
changes associated with hot particles in the palm tissue and in the
rat and hamster lungs surrounding these hot particles, these histo-
logical changes are sufficient for me to strongly believe that these
particles represent a unique carcinogenic risk, and that the uncer-
tainties related to our hypothesis or related to our standards the
quantitative values which we selected in order to determine the
standards. So the uncertainty is the risk of cancer for disruptive
tissue mass comparable to that for disruptive hair follicles.
We selected the 1 to 2000 as the chance of one of these lesions
going on and becoming cancer. The other uncertainty is a particle
capable of irradiating the surrounding tissue mass at a rate of 1000
rem per year sufficient to produce such a lesion.
We picked the 1000 rem per year because that correlated with the
beginning incidents of tumors and atrophied hair follicles in the
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Albert experiments.
The second part is the activity that we have selected as the
minimum activity to represent a hot particle. The observations of
Richmond et al that the microspheres in the lungs of hamsters, these
cytological changes which they have observed in the hamsters occurred
with particles that were about 60 times or had 60 times more activity
in them than the critical particle activity which we selected.
In order to get 60 times more activity in the particle, you have
to increase its diameter by a factor of 4, so that then gets us from
a 6/10th micron particle of plutonium 239 to 2.4 micron particle
which is still in the range where the particle can be inhaled and
deposited in the deep respiratory zone.
With high burn-up fuel which would be used in the nuclear power
industry, that critical particle size would be smaller, because of the
plutonium 238 which contaminates plutonium 239.
So the evidence then would suggest that we really do have a hot
particle problem and the question where there would be uncertainties
involved, just how critical is that hot particle problem? We see the
histological changes in the lung particle sizes which can enter the
deep respiratory zone and which can be expected to be produced within
the nuclear power industry.
Is the risk of such a particle comparable to the risk of the
disruptive hair follicle, something like one in 2,000. We tried to
arrive, by using some biological data, at another value for the risk
associated with the particle. We were unable to come up with it.
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Maybe someone else can. So far they have not. I might say that
in terms of the rest of the testimony that has been presented here in
these two days, the only testimony, factual information that was pre-
sented which was proposed to relate to hot particles dealt with the
exposures in the Manhattan workers.
A particle size distribution for the Manhattan workers was
presented. No one really knows what the particle size distribution
was in those Manhattan workers.
The other thing is, even if they knew the particle size at this
point, they do not know what the specific activity per particle was.
The particle size distribution which was presented here was one that
was comparable to the particle size or was the particle size distri-
bution determined for the fire at Rocky Flats.
So it represented the plutonium oxide particles that were
generated as a result of burning plutonium. The studies of Hempelmann
describing contaminating events at Los Alamos indicates that the way
in which the plutonium was dispersed in the environment was a result —
one of the major sources was adding peroxide to plutonium nitrate
solution and aspiration of droplets from there.
When one looks at the concentrations of plutonium in those
solutions, you have to have particle sizes for the most concentrated
solutions which they used; the concentration varies from one to 40
grams per liter.
The most concentrated one, the 40 grams per liter, the particle
size had to be some 5 microns in order to have this limiting particle
activity which we have suggested here.
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The data which you saw here were for particle sizes above .6
micron, something like a factor of ten below.
Certainly, the Manhattan workers, since they represent some 30
years down the line, we did have some better information about what
the nature of the particles that might have been involved in their
exposures were. We might be able to shed a little bit more light on
this.
But at this particular point, there is really no way of using the
Manhattan workers. The information and the nature of the examination
would suggest that hot particles as we have defined them were involved,
and if a critical particle activity for a hot particle is something
like 60 times what we have suggested, well, then, the chances are
extremely remote that they were involved in that.
I might say, though, with respect to what the critical activity
to make something qualify as a hot particle, that the experiments on
the hamsters were involved with animals that had relatively short life
spans, and there is no reason to rule out that if particles of lower
activity existed in animals with a longer life span, that the kinds
of histological changes that were seen in the hamsters would appear at
lower and lower particle activity.
Also, there is a suggestion that since none of these hamsters
developed a cancer that that tends to rule out the hot particle hypo-
thesis. But there is no a priori reason for believing that the induc-
tion time by this mechanism is compatible with the life span of a
hamster.
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So, that then, is sort of a condensation of the nature of the
hot particle hypothesis, following the approach which we used to
insert quantitative values into the hypothesis in order to derive
exposure standards associated with a unique carcinogenic risk.
With that, I guess I will meet with your questions.
Dr. Mills: Thank you, Dr. Tamplin.
For the record, I would like to point out what you probably already
recognize. Under the legislative authority of EPA, with the transfer
of the Federal Radiation Council, there is a legislative history
associated with that which calls for the administrator of EPA to consult
with NCRP, the president of the National Academy of Sciences, as well as
other groups. So it is consultation, then.
I am somewhat intrigued by this critical architectural unit petition.
A great deal of the hypothesis has been proposed, related, and I assume,
you are making a relationship between a hair follicle such as units in
the lung.
Would you care to broaden this particular unit in terms of a
particle that might localize in other tissues, as what this unit
might be?
Dr. Tamplin: I think the observation of Lushbaugh on the single
particle embedded in the palm of the mechanic suggests that the
critical architectural unit is more diffused in that particular tissue.
I think the same thing applies relative to the observations of
Richmond around the microspheres, that the critical architectural unit
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in terms of the skin experiments happen to be a hair follicle that was
more sensitive to this kind of disruption than was the rest of the skin
tissue.
But there is no reason to suspect that other portions of the skin
would not also, a particle would not have accrued a disruptive tissue
mass of a sufficient size to represent a unique carcinogenic event.
Dr. Morgan mentioned earlier the experience of Finkel in which
he injected a microgram quantity under the skin of rats and produced
a high incidence of cancer.
There is also the experiments at Argonne which put things such as
small pieces of mylar film under the skin of rats and produced cancer.
What you are talking about here is a disrupted tissue architecture.
The experiments of Bruse would suggest that you could do this, that with
a hot particle you are creating an altered tissue mass which in itself
creates or may be creating a new surface which represents a unique car-
cinogenic move towards the surrounding tissue.
So I would say that on both the lesion and size by Lushbaugh and
observations on the rat and hamster lungs suggests we probably should
never have used the critical architectural unit kind of thing.
We suggest that this is rather diffuse in some cases.
Dr. Mills: You would expect this to be diffused in the lymph
nodes? The particle might be located in the lymph nodes?
Dr. Tamplin: I would not rule out the possibility that there
would be such areas within the lymph nodes. At this particular point,
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I am only talking about the lung and the observations that epithelial
metaplasia and so forth is occurring around the particles deposited
in the lungs.
I think the evidence concerning these cytological changes exists.
Dr. Mills: As I understand it, you propose a thousand rems per
year constitutes essentially a threshold dose for the induction of lung
cancer? I am asking this from the standpoint of a broader issue than
the hot particle. Obviously the threshold concept from the standpoint
of setting standards has not been adopted.
Would you care to comment on that from the standpoint of the use
of a threshold in setting standards?
1 am not sure I really understand a thousand rems p^r year. Is
that the lowest dose that will induce the lung cancer?
Dr. Tamplin: We stated' in our report that we selected this because
this was where there was a precipitous change that occurred in the
Albert data, and in my presentation here, I indicated that when you use
that, you arrive at a certain particle activity.
The observations of Richmond at this particular time, he has
observed that these cytological changes around particles are about 60
times the minimum activity which we selected.
That is one of the uncertainties in there. We also say in this
nothing about particles of lower activity. That does not mean some-
thing that delivers 990 rems is innocuous. As a matter of fact, I
think someone like Ed Martel would pick up on that end of the spec-
trum and propose a new hypothesis associated with particles of lower
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activity than the ones we are suggesting.
We in this particular case were trying to define the biological
consequences of the effects of particles of a particular size. Any
inference about lower particles or so forth, I do not think can be made
from the information.
Dr. Mills: I think it would be interesting, have you received
any comments, either you or Dr. Cochran, from Dr. Albert or Dr. Lushbaugh
as to the interpretation that has been applied to these?
Dr. Tamplin: Ever since we submitted this report to the EPA and
AEG, we have been treated like lepers. There have been many opportun-
ities.
When we submitted it, we had hoped that what this would do would be
to begin a constructive dialogue that might lead to resolution, and
that is why we welcomed the chance to come here.
We can begin with the sequence of events. This is in the material
you have. In our critique of the Bair, Richmond, Wachholz report,
WASH-1320, we go through the background of this.
I might read it since you asked the question. On February 14,
1974, the Natural Resources Defense Council petitioned the Atomic
Energy Commission and the Environmental Protection Agency to amend their
radiation protection standards applicable to hot particles, plutonium
and other actinides where hot particles were defined more fully in the
accompanying reports.
I will skip over that. That is what happened on February 14.
On March 15, 1974, the AEC released its draft of the Liquid Metal
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Fast Breeder Reactor Environmental Impact Statement. This statement
contained a 15 page discussion of the hot particle problem. This
*•
discussion, based on an earlier report by John Healy of the Los Alamos
Scientific Laboratory, was used as justification for ignoring the
approach taken in the Tamplin-Cochran report for estimating lung cancer
incidents associated with the inhalation of plutonium particulates and
using instead the assumption of uniform lung exposure, even where hot
particles are concerned.
On March 28, 1974, the AEC gave notice in the Federal Register of
NRDC's filing its petition and requested public comment.
On April 16, when NRDC submitted to the AEC a critique of the
hot particle in the draft LMFBR environmental impact statement, since
the hot particle discussion in the draft statement drew heavily from
the Healy report — As a matter of fact, much of it was produced ver-
batim — the NRDC comments were a critique of the Healy report itself.
On August 5, the AEC said it was releasing a draft impact state-
ment on mixed oxide fuel, which they called effectively draft GESMO,
and NRDC in a letter of February 21, 1974, requested the AEC to give this
generic environmental statement full and candid discussion of the recom-
mendations supporting evidence presented in the NRDC division and
accompanying report.
In the draft GESMO, just as in the draft LMFBR, the uniform
exposure assumption was used to calculate the lung cancer risk for
hot particles.
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48
The first paragraph from the final quote from the draft GESMO
gives justification for this assumption, and the remaining two para-
*
graphs describe the AEC's treatment of the NRUC petition and the
Tamplin-Cochran report.
I will not read this whole thing, but I just wanted to say that
what occurred there was, in the draft GESMO — This is now put out
some six months after we responded to the draft, the LMFBR statement,
they put the Healy report in the draft GESMO and totally ignored our
comments on the Healy report.
Finally this comes out, WASH 1320, this is coming out now, about
eight months after we have submitted out comments on the Healy report.
It covers much the same material that was covered in the Healy report
and which we commented on.
In this they did not acknowledge any of our comments. They have
absolutely refused, and I say this applies to EPA, they have absolutely
refused to engage in a dialogue with us.
So here we are here today for the fifth time, repeating the same
argument, and hearing the same ones.
Dr. Mills: I am afraid you interpreted my question much too
broadly.
What I specifically asked you was, had you in fact had any comments
from Dr. Albert or Dr. Lushbaugh?
Dr. Tamplin: As I say, we have been treated like lepers. We
have received no comments from anybody, EPA or anyone.
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As a matter of fact, they had a meeting on plutonium at Los Alamos,
and it was by invitation only. Of course, we were not invited.
We have been around. People could have written to us, and we
could have responded.
Dr. Mills: OK. I have no further comments.
Dr. First?
Dr. First: I have none.
Dr. Mills: Dr. Radford?
Dr. Radford: Arthur, some years ago, you and John Gofman
submitted a number of critiques of the then existing radiation stan-
dards for population distribution in general.
One of the critical issues that you raised at that time was the
concept of the doubling dose for radiogenic cancer. Is that correct?
Dr. Tamplin: Yes, we indicated that our impression was that the
available data would support the idea that all forms of cancer, the
natural incidence of all forms of cancer, would be doubled by the
same level of radiation.
Dr. Radford: Without taking anything away from the value of the
analysis you did, do you still believe that that statement you just
made is correct?
Dr. Tamplin: I have not seen any solid information at this point
which would cause me to change that. I might say that I do not feel,
in terms of the issues that we were raising and in terms of setting
radiation protection standards, that that was an hypothesis upon which
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the effects of radiation had to live or die.
I would say that certainly the hypothesis has not been proven,
but at this point, I have not seen any sufficiently cogent arguments
causing me to reject it, based upon the available data.
Dr. Radford: As you know the BEIR committee went through an
exercise very similar to what you and John Gofman had gone through and
they reached a conclusion that the doubling dose was not constant for
different types of cancers.
Different organs or different tissues within organs would respond
differently to the same radiation exposure.
Have you read that section?
Dr. Tamplin: I read that section and, quite frankly, I think they
have milked the data for a little bit more than it was worth.
I was somewhat concerned about the dosimetry approach that they used
with respect to spondylops. At the same time, the answer that they came
to in terms of the practical problem of radiation protection was not all
that different.
So, so far as the biological effects of radiation are concerned,
I feel that their committee report is a perfectly adequate document for
reasonable people to make reasonable judgments on.
I think the disagreements I have with it are more academic than
practical.
Dr. Radford: One rather important academic or practical conclusion
germane to today's discussion is the reading of sensitivities of differ-
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ent tissues. That is the point I am trying to get at.
Do you believe that different tissues in the body, in man now,
the available human data, differ in their likelihood of developing cancer
when the radiation exposure is, as far as we can evaluate it, approxi-
mately equivalent?
Of course, one of the biggest groups where we can do this clearly
is the Japanese survivors, where they all got the same kind of exposure,
even if it might differ in quantity. There, the evidence is clearly
that certain types of cancers are not increased whereas other cancers
are very significantly increased.
Dr. Tamplin: The evidence which I have looked at and which was
most compelling to me at that time, you might say I have not checked
back in on the atomic bomb casualty commission data, I figure I would
wait another few years because, among other things, I would like to see
the people who were very young at the time of the exposure.
I would like to see their subsequent experience in terms of cancer,
but anyway, I recall back when I was first learning radiobiology that
I
they were talking about radioresistent tissues and radiosensitive
tissues.
At that particular time, the leukemia in bone marrow was considered
the most radiosensitive because you found a lot of leukemias. A radio-
resistent organ was called a thyroid gland.
It was not very long after that that they began to find these
thyroid cancers in children who were irradiated in the sinus during
infancy. Anyway, when they finally put the radioresistent organ and
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this radiosensitive organ together, they calculated the number of
cancers per rad, it turned out to be the same for both of them.
So, I became a little bit skeptical of that at that time.
Dr. Radford: We can all have our opinions about what statements
have been uttered by people in the past. That is not really what I
am trying to get at here.
Dr. Tamplin: I do not understand exactly what it is you are
trying to get at. I have not, at this point, and I am willing to be
convinced by the evidence, but I have not set aside the idea that there
is a doubling dose related to carcinogenesis.
I understand this is modified by things like synergism and so
forth, and 1 do not think that the data in the BEIR report and the
analysis in the BEIR report sets that aside at all.
But I agree that the consensus of the BEIR committee was that the
doubling dose concept was not applicable.
I might also say that once I saw that, I was working on other
things, I have not gone back through the data in any great detail.
Dr. Radford: But the implication of your written material and,
to some extent, your oral material today, was that there were critical,
self-divided groups in the skin which would be more at risk, and that
specifically was the hair follicle.
Now, would you say that the hair follicle is more at risk than
other tissues in the skin or not?
Dr. Tamplin: I see what you are getting at there.
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Yes. I would say the hair follicle was such that the mechanism
involved there, in those terms, the hair follicle was the one that
developed the tumors, as they increased the radiation dose and killed
over the tissue there irradiated, forms of cancer began to appear from
the underlying tissue.
So I would say certainly the observations in terms of the experi-
ments conducted by Albert indicated that the hair follicle developed
cancer sooner than the other tissues did. Yes.
Dr. Radford: Sooner, in general, would mean that it is more
sensitive?
Dr. Tamplin: OK. If you want to define it, it is the same way
leukemia occurred much earlier and thyroid cancers and so forth.
Dr. Radford: With regard to the problem of setting air or other
standards for plutonium in soluble particles, what specific tissues —
where do you expect the problems lie?
Is it because you are concerned with particles getting embedded
in the skin? Or how are you going to regulate that?
I would like to know where you think the problem is. I have read
it in your material. I would like to get it from you personally.
Dr. Tamplin: Our petition was specifically related to inhalation
and particles in the lung. Certainly I think the particle that was
excised by Lusbaugh suggests you would not want to have 200 or 300 of
those particles embedded in the palm tissue, but our petition was
directed towards the lung.
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Dr. Radford: Now, in the lung of man, do all tissues show the
propensity to produce cancer?
Dr. Tamplin: You are bringing it down from organ tissue. As
you indicated yesterday, the major ones are pulmogenic carcinomas and
the uranium miners; there would be different kinds.
Dr. Radford: And the gas workers, and the metal workers, and
various other workers. But let us leave the histology out for a moment.
We have enough problems as it is.
The point is they arise from the bronchial cells, correct?
Dr. Tamplin: Yes.
Dr. Radford: So that the question at issue is what is the specific
dose from a particle going to do to bronchial epithelia tissues. Is not
that correct?
Dr. Tamplin: I am not sure that we are talking about what a
specific dose does. The whole effect, in this particular case, may be
mediated by radiation injury or killing of cells in the development of
a lesion, rather than, say, a carcinogenic mechanism caused by the
radiation effect.
Dr. Radford: But the cell damage might occur by a subpleural
particle, and might not be likely to have any effect on the bronchial
epithelial, say.
Dr. Tamplin: I do not know what the dimensions are involved.
Dr. Radford: I am trying to get at the point, where does the
damage occur?
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Dr. Tamplin: The particle is deposited in the alveolar tissues
below the ciliated bronchi where it is deposited in there.
Dr. Radford: But cancers in man do not arise from alveolar tissue,
except extremely rarely?
Dr. Tamplin: Yes. And the particle is lodged in there and it
creates a disturbed tissue mass.
L)r. Radford: We have a great many disease processes that lead to
disturbed tissue as architecture in the lung, yet they are not associated
with cancer in that site.
For example, in an asbestos worker, they do not develop cancers in
the alveolar cells even though they have asbestosis. They develop it
in the bronchi, right?
Now, I am trying to get at the question, if you inhale insoluble
plutonium particles, how do you postulate that they are going to produce
the disturbed architecture and the radiogenic changes in a tissue which
would be sensitive to carcinogenic change?
You have indicated that they are deposited in the alveoli, as I
have tried to point out —
Dr. Tamplin: You are proceeding mechanistically.
Dr. Radford: You cannot say just because you handle a particle,
you are going to get cancer at some remote point. That would have to
be a scope or effect, the likes of which I do not know.
Dr. Tamplin: We would expect that this particular particle
radiates a tissue mass and causes much the same as we saw on the palmer
tissue or as the particles in the Richmond experiment which were
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deposited in the capillary bed produced this epithelia metaplasia.
Dr. Radford: But the changes in the Richmond studies were in
tissues that do not have epithelial hyperplasia or growth. There may
be modifications in the cells, but it is not a point at which cancers
normally arise in man.
There are differences between animals and man. I do not want to
get into that in detail here. I would prefer to get with Dr. Bair on
this, but the point I am trying to get at here is, to my knowledge, in
general, environmental effects on lung tissue have not produced cancer
except in the bronchial tissues or in the mesothelium cells, not in
the lung itself. Would you say that is a fair statement?
Dr. Tamplin: I would have to confess that my knowledge of that,
I cannot answer that question at this time.
Dr. Radford: Let us assume that it is the bronchial epithelial
tissue at risk here. Then the question is, how would you postulate
that an inhaled plutonium particle would affect the likelihood of
bronchial epithelial undergoing a malignent change?
Dr. Tamplin: It depends upon if you want me to affect that
directly, one would have to look at where the particles were ultimately
deposited.
As I recall some of the observations that were made, for example,
one of the things they suggested was the particles were kind of moved
around and eventually, they are engulfed in macrophages or in the
epithelial cells. One would then have to —
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My problem at this particular point is I do not have the dimensions
of this thing perfectly well in mind. I can see a particle deposited
in the alveolar space near the terminal bronchi, which is killing cells
in a broad area.
Dr. Radford: Forty microns?
Dr. Tamplin: No. It would be bigger than that because of the
spongy nature. I do not think that at this particular point I will be
able to answer your question.
I am going to have to think about it some more.
Dr. Radford: In other words, the model which you presented on
deep lung deposition really referred to alveolar deposition and
retention?
Dr. Tamplin: Yes. Because the indications are it's only in the
deep respiratory zone below the ciliated bronchi that this resting time
exists.
My knowledge at this particular point of the dimensions of what
we are talking about —
Dr. Radford: In other words, if I may summarize briefly what you
have just said, your model postulates a certain deposition in the
alveolar tissue, with a radiation of that type of tissue predominantly,
leading to cancer?
Dr. Tamplin: I do not say it predominantly. I simply, at this
point, would not want to agree that that is what we are saying at this
point.
Dr. Radford: Can you make any other statement as to what might
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occur in terms of the risk to individuals inhaling insoluble particles?
l)r. Tamplin: No. As I say, you can see what that is based upon.
I would like to go back and look into this aspect of this question
which you raise here.
Dr. Radford: We may, if we have time, get some comments from
other panelists, the AEG representatives, which may help you out a
little on this.
You are familiar with the fact that Dr. Albert did some earlier
epidemiologic evaluation of children irradiated for ringworm in the
scalp and found some skin cancers?
Do you recall what the dose was which those children received?
Dr. Tamplin: No. I did not review that particular work. I
also understand that subsequently they developed some pyschological
problems.
Dr. Radford: Psychological problems, too, yes. That is direct
evidence in man of the carcinogenicity of radiation on the skin.
The reason I bring that up, is there any reason to believe that
the skin has a somewhat different dose response curve than other
tissues? More of the threshold type, or likely to have?
Dr. Tamplin: I cannot postulate any reason for suggesting that
the skin —
Dr. Radford: Basing it upon experimental evidence, such as it is,
in man?
Dr. Tamplin: Not to my knowledge.
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Dr. Radford: As you know, skin cancer was one of the first
radiogenic cancers that have been described?
Dr. Tamplin: Yes.
Dr. Radford: So far as we can see, it does appear that the skin
is somewhat more resistent to an overdose, at least, this is a tenable
hypothesis compared with other tissues in the body where significant
effects have been observed at low doses.
And, indeed, the animal experiments of Dr. Burr showed earlier
seem to show that with relatively low doses, carcinogenic cancers can
occur.
I would like to come back to this question of the significance of
your thousand rem per year. Is there any reason why you put a per
year on that? In other words, why is there a critical dose rate?
Dr. Tamplin: The basis for that was it may seem to suggest that
that was a reasonable terminal turnover rate for the epithelial.
Dr. Radford: Except in a number of tissues that are not greatly
turning over more rapidly than that or the same as in the case of the
bone cells. We have heard about the radium-224 data that protracting
the dose does not seem to have very much effect.
It may have in some cases an enhancing effect, and in other cases
a slightly less enhancing effect. But traditionally, and in keeping
with the ICRP view of these things, protracting the dose for high L.E.T.
radiation does not really change the cancer. It is the total accumu-
lated dose.
Would you agree with that?
-------
Dr. Tamplin: Yes. The reason for selecting, putting the one
year on there, again, as I say, we were postulating as a mechanism
here. It was more of an injury media mechanism, rather than a biological
transformation of cells into carcinogenic cells as a result of the
radiation.
Therefore, the idea was in that respect that this would tend,
then, to kill essentially a large fraction of the cells within the
irradiated body, so that is why we were concerned with what was repre-
senting turnover time.
I say that is one of the uncertainties that are involved here:
What constitutes a hot particle?
Dr. Radford: In other words, if I can put it in another parlance —
I will let you agree or nor agree — At high enough doses, ionizing
radiation acts as its own co-carcinogen. Would you go along with that
as a statement?
Dr. Tamplin: I have heard that, yes, that you both damage tissue —
Dr. Radford: You transform some cells and you destroy the
architecture. Is that, in essence, what you are saying?
Dr. Tamplin: I think it is plausible. I do not think it is
necessary in all cases that both things happen. It is possible in the
case of these particles that that does occur, but I do not think it is
necessary that both events occur.
Dr. Radford: But you implied that there had to be a disturbance
in the normal architecture as a necessary condition, which is almost
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the same thing.
Dr. Tamplin: OK. In other words, it was simply that changed
architecture as a potential carcinogenic mechanism, such as the mylar
film —
Dr. Radford: What 1 am really trying to get to is the question,
what about the smaller doses or dose rates, or what about the other
isotopes like plutonium 238 which would have a higher dose per unit
volume?
Would you expect that plutonium 238 would have a higher rate or a
lower rate than plutonium 239?
Dr. Tamplin: On a per particle basis?
Dr. Radford: Let us put it on a per curie basis, although that
is a little difficult because, obviously, the particles are —
Dr. Tamplin: A particle of plutonium 238 which was not sufficient
activity would be no more or no less than plutonium 239.
Dr. Radford: Yet a particle of plutonium 238 would be substantially
smaller, I think. I have calculated quickly.
Dr. Tamplin: Yes. It would be.
Dr. Radford: About one 300's of a volume,' so it would be around —
I cannot do it quickly. So, in other words, a particle of plutonium 238
would have a much smaller volume, would deliver your thousand rems a
year from a much smaller particle?
Dr. Tamplin: But if you took a particle of plutonium 238 that
was one micron in diameter, a particle of 239 which was one micron in
diameter, we would suggest that the effects would be the same.
Dr. Radford: But the activity is much greater?
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Dr. Tamplin: The activity would be much greater, but it is the
particle that is involved rather than the activity.
Dr. Radford: Then, in other words, the dose distribution around
the particle is really not critical here?
Dr. Cochran: Let me say I believe you are trying to read more
into the model than we thought the biological data suggested.
You could say the biological data is poor. Everybody admits
that. We tried to build a model and assign some risk numbers on the
basis of available data.
I think you are carrying this beyond what we thought at the time
we could build into the model from the available data. We assigned
a risk per particle and made that the same risk per particle regardless
of the activity level of the particle, as long as it was above some
minimum activity level sufficient to disrupt the architectural
structure which in turn carries some probability of developing into a
cancer.
Your questions are useful questions, but is sounds like you
believed we had more depth into the model than we really did.
Dr. Radford: I am beginning to get that impression. Yes. But
I still think in contrast there is a good body of information. The
sophistication of dosimetry that has been applied experimentally,
even in man, to radiogenic cancer is a very high level indeed.
In effect, what you are saying is that dose is not germane to
this issue, which I find difficult to believe.
Dr. Tamplin: In this particular case, I do not know that we are
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proposing a novel mechanism for carcinogenesis. Other people have
suggested injury media mechanism before. We feel that the particles
are involved in a different mechanism of carcinogenesis than uniform
radiation or more uniform radiation tissue, with the same number of
curies.
I am proposing that the mechanism involved here is identical with
this other mechanism for carcinogenesis.
Dr. Radford: What you are saying seems to imply to me that if
you have particles below a certain critical diameter, then everything
is all right.
Ur. Cochran: No. We just meant we offer no opinion. We offered
an opinion where we believe the available biological data supports the
hypothesis and a petition to EPA and AEG to amend the standards. We
offer no opinion on some of these other areas.
Dr. Radford: All right. If I may summarize now, then I will pass
on the microphone here.
If I may summarize, you are saying on the basis of a skin radiation
effect, predominantly by Albert, you come out with the impression that
a hair follicle constitutes a significant target for radiation, and that
from his data, you infer that about one in every two thousand, when
radiated above a thousand rems, and he really did not work very much
below that, incidentally — so you cannot say on lower doses what
might have been expected.
On that basis, then, you translate that to a risk factor for
particles deposited in the alveoli of man. Am I correct in that bridge
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there?
Dr. Tamplin: As I indicated, if you want to develop radiation
protection standards, in order to do that, you have to assign some
risk value.
Now, the risk value which we used was related to this disrupted
tissue architecture that derived from the alveoli. That said that if
you have a disrupted tissue mass that the chance of it developing into
cancer was like one in two-thousand.
It is one of the uncertainties in this thing, as to whether or not
that happens to be a number which is available which relates to disturbed
tissue architecture, to cancer.
The other uncertainty in it involves the size of the activity of
a particle that is required to produce this disturbed tissue archi-
tecture.
There are other mechanisms of the biological effects of radiation
that one can postulate, but this is the nature of our hypothesis and
the nature of the data that we used to quantitate it in order to arrive
at numbers that would be available for setting radiation protection
standards.
It is uncertain, and this question about particles below .the
critical particle size, we come to no conclusion on, in that respect.
Dr. Radford: What was the nature of this disturbed architecture
in Albert's experiments?
Dr. Tamplin: He said the tumors that developed were similar to
those, and he plotted it, atrophied hair follicles versus tumors.
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Dr. Radford: But the disturbed architecture, then, was atrophy?
Dr. Tamplin: That is how he described it, yes.
Dr. Radford: But atrophy simply means the cell division has
stopped, which in those doses it almost certainly would have. Is
that disturbed architecture?
Dr. Tamplin: Well, certainly. In other words — I am afraid I
do not —
Dr. Radford: The implication from your hypothesis, as I understand
it, is you get liquefaction of tissue, you get actual radiolysis of
tissue. That is very different from atrophy of a hair follicle, from
simply stopping cell division, is not it?
Am I wrong in assuming that one of the disturbed architectural
features that you are describing is the very intense radiation exposure
right around a particle where it is killing cells?
Dr. Tamplin: And creating a lesion.
Dr. Radford: That is very different from atrophy of a hair follicle.
Would you agree?
l)r. Tamplin: Not necessarily. No. I would not necessarily agree
with that. I would be willing to look at some other approach towards
determining what the risk, say, associated with these cytological
changes that are observed around these particles are.
That happened to be a number which was available that represented
disrupted tissue and subsequent cancer. It may be there may be better
choices.
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Dr. Mills: Dr. Garner?
Dr. Garner: Dr. Tamplin, let me tell you that when I first read
your petition, there were several things that troubled me. I guess it
started off with this tremendous leap from effects, let us say, of
about 1,000 reins of electron radiation delivered in a few hours to
skin, to the effects of a 1,000 rem delivery over a year to a lung.
But the thing that bothered me most, I think, was that you simply
had not reviewed all the literature. You made the statement that you
and Dr. Cochran had noted all the information available, but you had
not read all the information available, to my mind.
You mentioned — Many of them, I agree, but there are several
which suggest strongly to me that non-uniform radiation is less
effective than uniform radiation.
Above all, the thing that seemed most significant to me was that
you built the entire hypothesis practically on Albert's experiment
with electronic radiation of skin. Yet you have omitted to refer to
one paper which was specifically addressed to this tissue, one which
appeared in Radiation Research, Volume 30, 1967.
This was work on tumor formation from electronic radiation in a
rat. It addressed itself specifically to this problem.
Its introduction starts off: "The cancer hazard arising from
occupational exposure to ionizing radiation is almost never associated
with a uniform distribution of dose in exposed tissues. Non-uniform
radiation patterns may take extreme forms. In the case of radioactive
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particles in the lung, the dose to very small volumes of tissue close
to the particles may be thousands of times as high as the average for
the organ as a whole."
It goes on to say, "The extent of the cancer risk from such highly
non-uniform dose distributions is called the "hot particle" problem in
the field of radiological health protection."
It came up with the results, and I quote from them. It states the
observations suggest that "at very high non-uniform pattern radiation
doses the skin responds as if it were uniformly irradiated, but at
lower doses the observed tumor yield following non-uniform radiation
can be considerably below the predicted level."
Dr. Tamplin: If I am not mistaken, we did discuss the sieve
pattern which Roy Alberts performed. They indicated when they used
the sieve pattern, carcinogenic response was suppressed.
Subsequently, there were some additional experiments which were
done. One of the problems with the carcinogenic response seemed to be
dosimetry because of the high scattering of electrons.
In the proton experiments, the carcinogenic response was not
suppressed in the sieve pattern. The presumption there was that the
dosimetry was better understood.
What was the volume on that?
Dr. Garner: Volume 30, page 525.
Dr. Cochran: That is our reference 35 in "Radiation Standards
for Hot Particles."
Dr. Garner: What I was really getting at, it seemed to me to be
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rather a one-sided review of the information available.
You have not made use of all of the information available. That
is how your petition struck me.
Dr. Tamplin: We did not reference all the information. Some of
it, we thought, was not relevant. It does not mean that we have not
looked at it.
Dr. Garner: But you did not give the other side of the picture.
Dr. Tamplin: In proposing this, we did not say we had proven
anything. We said this is a hypothesis that seems to be supported
by observations, and presented information which we felt was supportable.
Dr. Cochran: I might add, there seems to be some confusion between
a hot particle hypothesis, as we have proposed it, and this concept of
uniform versus non-uniform dose on a per microcurie basis. We tried
to discuss and clarify this issue in our critique of WASH 1320. There
are numerous experiments on uniform versus non-uniform dose, which
suggest that when you analyze it on a per microcurie basis, the more
spread out the dose, for example, spreading the activity on more
particles, the higher the tumor incidence. But these data can be
exactly consistent with the hot particle hypothesis. The point is
you are examining tumors per microcurie, whereas the hot particle
hypothesis is based on tumors per particle. So it is not particularly •
relevant to say such and such an experiment sees a higher tumor risk
with more uniform exposure. That could be consistent with a hot
particle hypothesis. If you take the same activity and put in on
more particles assuming there are hot particles you get a higher tumor
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risk according to the hot particle hypothesis. You really have
demonstrated nothing, that is to say, you have not tested the hypothesis.
Dr. Garner: So that is one point of view.
Dr. Mills: Dr. Morgan?
Dr. Morgan: Most of the questions I might have asked have been
addressed.
In interest of the lateness of time, I will refer to your statement,
Dr. Tamplin, that we should have a quantitative approach to the risk in
hot particles.
I think we all agree to this very much. It is a question —
certainly Herb Parker and I and a few others have lived with it for
over 30 years, and worried and wondered about.
There have been many other questions of similar importance that
we have had to face in setting our radiation protection standards.
You indicated that you and Dr. Cochran and perhaps others, because
of the position that you are taking, that you were looked upon as lepers.
Certainly not in my eyes — not through my eyes do I look on you that
way.
You tell me when the time comes that all people that are willing
to stand up and take a position are ruled out — When this is no longer
possible, then I will tell you the time when there is no longer democ-
racy, because I think it is very essential that we have people like you
around to believe in something and take a position, and enable us to
thrash these things out.
Some years ago, six or seven years ago, you and Gofman suggested
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that the environmental exposure level of 500 millirems per year should
be reduced by a factor of ten.
Well, independently, the Atomic Energy Commission reduced the
exposure factor by 100. They went one better than you.
I rather doubt now, from any information that I have seen, that
they will reduce the figure that you have suggested, reduction factor
of a ten to the fifth, and suggest a factor of ten to the seventh.
We have similar questions, of course, to the hot particle question
that we have had to address and to live with for many years. Even in
external exposure, there is a question at times of whether to take a
surface dose, the average dose, the mid-line dose, the gram-rem dose,
or the gram-rem dose average.
We really do not know which best repesents the risk, to man or
to animals. So basic questions like this still remain to be resolved,
but this is not unique to ionizing radiation.
You have even more when it comes to the environmental pollutants
that we have to deal with. When it comes to internal dose, the
internal dose committees of ICRP and NCKP have made a number of simpli-
fied assumptions, hopefully that they were justified on the basis of
limited biological data.
For example, the average dose over an entire organ, we knew this
basically is not what we would like to do. The kidney is not really
one organ, but we average the dose to the kidney over the entire kidney.
If we had more biological data, if more hundreds of millions of
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271
dollars could be spent on research, and perhaps some time it will,
then we would treat these as separate organs and average over the
different components.
When it comes to bone, we are doing a little better through the
years. Thanks to the biolgoical data that has been accumulated at
Hanford and at Salt Lake and at a number of other laboratories, we
•
now believe that we might be justified in averaging the dose to the
tissue, and the Commission suggested averaging it out to a distance
of ten microns in this tissue.
This seems a rather arbitrary approach, but maybe we are getting
a little closer to the target that we are shooting at.
Then, when it came to the question of lung dose, as has been pointed
out by several of the very fine papers here today, when insoluble
material like plutonium dioxide goes into the respiratory system, a
large fraction of it ends up in the pulmonary lymph node.
Even in some human cases, considerable amount of plutonium in
soluble form is localized there. But the International Commission,
again, has wrestled with this problem through the years, for over a
decade, and suggested many different solutions. But we never found
a satisfactory one other than it appears at the present time, from the
data that we have at hand, that the lymphatic tissue is not a likely
target for these malignancies.
They do not seem to show up in animals. They do not seem to
originate in these particular cells, even though they received very
large doses. To me, this was ,the most satisfactory argument for not
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using the pulmonary lymph node as critical tissue although the doses
would be in the order of thousands of rads compared to some 15 rads
per year to the average lung.
So, from step to step, in setting standards, we had to make what
appeared to be rather arbitrary decisions, but we tried to base them
on what the observations are in animals and in man.
So, for example, with an alpha particle, we would not dare suggest
that you take a dose along the track of alpha particle, even a dose of
a cell through which the alpha particle passes, because it receives
roughly 100 rads.
So we have to make a decision then. What body of tissue are we
going to take? Some decisions are poor; we hope that most of them
are decisions that we and our grandchildren are about to live with.
I do not believe at this present time that we have enough infor-
mation to accept a radiation protection standard based on the localized
dose, as we defined it, hot particle implanted in tissue.
I do believe, though, that there is good evidence that plutonium
in bone in very small quantities leads to very high incidence of tumors.
Why you do not get similar results when plutonium is contained in hot
particles in the lungs, to me, remains an unanswered question.
I think that there are really other unanswered questions besides
the hot particle problem, but I certainly do not believe that there is
sufficient evidence to reduce the permissible exposure levels for plu-
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273
tonium in the lung or the body burden on the basis of the evidence that
we have today.
At this time, maybe you would like to comment?
Dr. Tamplin: I understand what you are saying.
I have a philosophical problem with that, though, and that is by
not setting the standard, you in effect set one. In other words, by
saying that there is not enough information available at this time to
set a standard for hot particles, you are in effect setting a standard.
I guess what you are really saying is that you do not feel that
any changes you have made because of hot particles would be significant.
Therefore, you do not feel compelled at this time to set a standard for
them because in your gut you feel that such a standard would not be
very different from the one that exists today because, in effect, by
not setting one, you are setting it, it seems to me.
Dr. Morgan: Of course, I do not speak for the International
Committee, but I think their response might have been for some unknown
reason, the risk when plutonium in past specific activities localized
in the skin of animals, and at least one case in man, the risk seems to
be rather large in skin. But this does not seem to be the case in the
lung because, as Dr. Radford pointed out, the tissues behave
differently. There seems to be some difference there which at least
I do not understand.
On this account, then, they feel it is satisfactory to continue
the present practice of averaging the dose, not only of the hot
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particle, but also that delivered from the plutonium contained in
the lymph nodes over the entire lung.
Dr. Tamplin: It does not seem like there is any comment I can
make on that.
We made our proposal and submitted our petition. As I say, there
are certain philosophical aspects of this which, personally, my gut
feeling says that these hot particles may represent an undue hazard.
Hopefully, what will happen now is more information will be
brought to bear on the subject, so that another 30 years from now we
would not be talking about the Chalk River conference which was 30
years ago.
It seems to me that as we look at what is potentially going to
happen, the rapidly expanding plutonium industry, that we have to come
to grips with the problem today because if you do have the industry, it
has to be designed around certain exposure standards so that the idea
that you can wait another ten years, I do not think that is true.
Some decisions relative to this have to be made right now. The
decision may be that Dr. Cochran and I are greatly overestimating the
risk and the existing standards are apt.
Dr. Morgan: Or it might be that 30 years from now, when we
reconvene here, that we will have discovered that the real problem
with plutonium in the lungs is that it localizes in large measure in
the lymph nodes which serve as reservoirs.
Then you have leakage to the skeleton and the liver and here is
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27o
cr
the problem of chronic environmental exposure.
Dr. Mills: Let me thank you very much, Dr. Tamplin and Dr. Cochran,
for this time.
Next on the agenda, we have speakers from the Atomic Energy
Commission.
Heading this group will be Dr. Jim Liverman. If any of you
have written statements, it will help the reporter.
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276
Introductory Testimony
by James L. Liverman
Assistant General Manager for Biomedical and
Environmental Research and Safety Programs
U. S. Atomic Energy Commission
Washington, D. C. 20545
par't of the AEG presentation at the
EPA Plutonium Standards Hearings
Washington, D. C,, December 10-11, 1974
My name is James L. Liverman. I am Assistant General Manager of the
Atomic Energy Commission with responsibilities for biomedical and
environmental research, waste management, and safety programs. I will
provide introductory testimony and will be followed by members of AEC
and contractor staff who will provide more specific and detailed testimony.
Mr. Lester Rogers, who will represent the regulatory and licensing activities
of the Atomic Energy Commission, is scheduled to testify tomorrow.
It is our understanding that these hearings are being held to gather
information relevant to EPA's intention to evaluate whether new guidelines
and standards are needed to assure adequate protection of the environment
and public health from potential contamination of the environment by radio-
nuclides of the transuranium elements. Judgments by EPA regarding new
guidelines and standards for transuranic elements will influence development
of nuclear energy to help meet nationwide energy needs, national security
programs, and other matters of substantial importance to our society.
Public concern regarding the manufacture and use of transuranium
elements is, I think, based on several facts.
1. Increasing quantities of the transuranics are being produced, and the
rate of production will increase substantially in the foreseeable future
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as nuclear fuels provide a growing fraction of our national energy
requirements.
2. Several radioisotopes of plutonium and other transuranic elements have
exceedingly long half-lives and, once released, will persist and accumulate
in the environment for time periods extending over many human generations.
This is, of course, also true for some naturally occurring alpha-
emitting radioisotopes such as those of radium and uranium.
3. These naturally occurring alpha-emitting radioisotopes are known to
produce cancer of the lung, bone, and liver in humans exposed to large
concentrations.
4. Comparable concentrations of alpha-emitting transuranic elements are
known to produce cancer of the lung, bone and other organs in experi-
mental animals.
These facts make it clear that, in operations involving the production
and use of transuranic elements, bioenvironmental health and safety considera-
tions are necessarily of primary concern. This point was recognized at the
very outset of the nuclear age -- when some of the first plutonium made
was turned over to biomedical investigators. Since that time (in 1944)
bioenvironmental and control technology programs have proceeded in parallel
with and have guided engineering development of the nuclear technology.
More than thirty years of research and development have produced a sub-
stantial fund of knowledge and understanding regarding the health and
safety aspects of operations involving the production and use of trans-
uranics. Through application of this knowledge, experience, and under-
standing, it has been possible to establish health and safety (radiation
protection) procedures which have permitted many thousands of kilograms of
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278 '3-
plutonium to be produced and processed, and we have yet to identify
successfully a major health consequence attributable to its radiotoxicity.
This record contrasts sharply with that for the commercial use of radium
earlier in the century where manufacture and use of a few grams resulted
in extensive occupational exposures and many cases of cancer.
I would like to make five points regarding the setting of standards,
criteria, and guidelines for the transuranium elements and comment briefly
on each.
1. Meaningful judgments on the adequacy of current standards and guidelines
must be based in part on the knowledge and understanding acquired in
the course of nuclear development including the research in the
life sciences. This knowledge is extensive; it cannot be presented,
evaluated, or even adequately summarized in a few days. It is, however,
available to all, and specific measures have been taken to assure
accessibility and to expedite wide dissemination of this information.
For example, Nuclear Science Abstracts (NSA) contains well
over 10,000 references on all aspects of the physical, chemical,
environmental, and biological properties of plutonium and other trans-
uranic elements. RECON - a computerized bibliographic searching
system -- permits rapid access to NSA and other bibliographic data bases
from terminals dispersed widely through AEG, its contractors, other
Federal agencies, and some universities.
There are in addition to this broad bibliographic base a number
of specialized information centers relevant to the collection, dissemina-
tion, and evaluation of information on the transuranic elements. These
include the data base on comparative metabolism of plutonium maintained
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4 " 279
at the Comparative Animal Research Laboratory of the University of
Tennessee and the environmental plutonium data base, the Information
Center for Internal Exposure, and the Nuclear Safety Information Center,
all located at Oak Ridge National Laboratory (ORNL). ORNL also maintains
direct access to the "Tox-line" and "Med-line" systems and computer
information systems of the National Library of Medicine.
To have another example, scientific meetings provide an important
opportunity for information exchange. In 1974 alone, five meetings
devoted to (i) the biological effects of internally deposited alpha-
emitters, including the transuranium elements, (ii) plutonium in the
environment, and (iii) radionuclide carcinogenesis have been held this
year (at Los Alamos, Richland, Seattle, Alta, Utah, and Las Vegas).
Proceedings of these meetings are published in the AEC Symposium series
or by the sponsoring laboratory. Meetings of professional societies
also provide opportunities for exchange of scientific information.
Numerous international meetings on the environmental and biomedical
effects of the transuranics have been sponsored by the International
Atomic Energy Agency.
Finally, there are monographs on this subject, an instance of
which is the recently published volume of the Handbook of Experimental
Pharmacology entitled, "Uranium, Plutonium, Transplutonic Elements."
2. The next point I wish to make regarding the setting of standards
relates to those organizations independent of government which have
played ari essential role in the analysis of much of the relevant
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280
biomedical and environmental information and in the development of
the standards, guidelines, and general procedures which are currently
used for the nuclear industry. It is essential that the objectivity
which these organizations represent continues to be involved in this
process.
These organizations include the United Nations Scientific Committee
on the Effects of Atomic Radiations, the IAEA, the International Commission
on Radiological Protection (ICRP), the National Council on Radiation
Protection and Measurements (NCRP), and the National Academy of Sciences
(NAS) through its various committees. All of these address themselves
to the analysis and evaluation of pertinent data. More so than the
others, the ICRP and NCRP are involved in the development of radiation
protection criteria and standards. From time to time these organizations
consider special issues such as the "hot particle" issue now under
consideration by a committee of the NAS.
3. Judgments regarding the adequacy of current guidelines and standards
need to be based on evaluation of the results of their application to
specific development and operational activities and in regulation.
Particularly in the case of plutonium already in the environment the
establishment of additional "generally applicable" standards may not be
as effective an approach to cost-effective control of radiation hazards
as can a case-by-case analysis based on current standards and guidance.
Our experience suggests that in such situations specific circumstances
such as physical and chemical form of the material, climate, and
current and projected land use are highly variable and site specific.
Each of these circumstances may exert an important influence on the
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practicability, including cost-effectiveness, of alternative
remedial actions. Since the number of contaminated sites is
likely to remain small, it might be more effective to deal with
these situations on a case-by-case basis using current standards
than to attempt to develop additional standards and guidance generally
applicable to all of them.
If additional guidance is developed for this purpose, it would
be essential that it include the flexibility required to assure
effective application in widely varying circumstances.
4. Despite the citation in Point 1 of thousands of references, information
on the biomedical and environmental behavior of plutonium and other
transuranics is not complete. It is not likely to ever be complete.
We need to know that it is adequate to assure safety in current and
future activities and we need to identify specific areas where increased
understanding is likely to have the greatest impact on specific develop-
mental, operational, and regulatory decisions so as to focus our
research there.
We do wish to point out, however, that there are much greater
deficiencies and uncertainties in data that would permit assessment of
the environmental and health impacts of alternative energy sources
leading one to the conclusion that major efforts are still required
in all energy forms.
5. The AEC has a major research program on the biomedical and environmental
aspects of the transuranics. This program focuses on those areas where
additional information is most likely to critically influence develop-
ment programs, operations, and regulations.
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282 -7-
We continue to support research on various species of
experimental animals exposed to transuranic elements in various
forms. A major portion of efforts in this area focus on determining
the consequences of inhaling small quantities of aerosolized transuranics
and quantitating the effects of aggregation of alpha activities into
"hot particles."
We continue observations on humans exppsed to plutonium more
than twenty-five years ago and we are expanding the Transuranium
Registry of potentially exposed occupational workers.
In the environmental area we continue observations on the
behavior of transuranic elements dispersed globally by weapons testing
and studies of the behavior of plutonium in the quite diversified
environments near weapons test areas in the U.S. and the Pacific and
around operating facilities in the U.S.
The aim of this research is to reduce the need for conservative
and possibly very costly assumptions by providing the information needed
to make more realistic estimates of potential health and environmental
hazards of transuranium elements. The results of this research are
published regularly and are accessible through the various routes I
mentioned earlier.
Increasingly, in anticipation of ERDA, we are integrating research
activities in this area with research on the environmental behavior
and potential health consequences of pollutants from alternative energy
sources so that we will be better equipped to assess bioenvironmental
aspects of alternative energy technologies so as to help orchestrate
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their development and to provide a sound basis for operating and
regulating these technologies as they are installed.
Mr. Chairman: I realize these comments have been all too
brief but they will be expanded in major ways to cover in detail
much of what I have alluded to during the course of the afternoon
and tomorrow morning. If I could simply introduce those who will
participate with me at this point and in the order in which they
will appear, I could remain quiet as we proceed;
Dr. Yoder, AEC's Div. of Operational Safety will discuss
Source Terms and Control
Dr. Ed Wrenn, followed by Dr. B. Bennett, will discuss
Environmental Levels of the Transuranics
Dr. W. J. Bair, Battelle Northwest Lab, will discuss
Transuranics in Experimental Animals
Dr. W. W. Burr, Deputy Director, DBER AEC, will talk
concerning Human Exposures
Dr. Chet Richmond formerly of Los Alamos Lab but now
with Oak Ridge National Lab will discuss Biomedical
Effects in Humans
Dr. Roy Thompson, Battelle Northwest Lab, will finally
discuss Implications with Regard to Protection Criteria
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Dr. Mills: Thank you. Did you want to respond to questions now?
Dr. Liverman: I will be happy to take any questions the panel
may have, or you might like to wait until after the other speakers;
I will leave it to you.
Dr. Mills: I think Dr. Taylor has a question.
Dr. Taylor: This morning, Dr. Sagan mentioned, and you mentioned
again in your testimony, the desirability of including flexibility in
the standards.
The very thought of flexibility appeals to me, but any time we
have in the past tried to make anything flexible, we get our ears
beaten back by the regulatory people, or the cities, or the states.
I wonder if you have some bright ideas as to how we can make
some flexible standards?
Dr. Liverman: I am not sure that I do. I was rather intrigued
with something Dr. Sagan was proposing regarding the issue, but I
have no special way that one can approach this matter.
It just seems from a sort of layman's standpoint that if you
are in a wide open country and there is nobody around, the issue is
not quite as critical as it is if you were in the middle of the city.
How one achieves that becomes almost a specific, localized
activity subject to change as time goes on. As we heard from the
General Electric man, and I happen to agree with him, it is very
difficult to engineer a changing regulation into a system.
I really have none.
Dr. Taylor: This low as practicable concept was centered about
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flexibility, but it is being made as rigid as a dead man.
Dr. Liverman: I have no particular solution.
Dr. Radford: I have a comment, Mr. Chairman.
I would like to know, is it the intent of the AEC panel to
complete their testimony within an hour?
Dr. Liverman: No, sir. We had never intended or felt that
could be done. We had, in fact, I believe, requested of the EPA
at the time we submitted our testimony that it would take perhaps
as much as four hours.
We are not acting as a panel. They are independent and separate
papers. There are five different groups of paper. They could have
been listed as individuals.
Dr. Radford: I specifically raised this question this morning
because I was a little concerned looking at that list and knowing
some of the technical expertise that is represented.
Do you want to make a ruling on that? The question is are we
going to have any time for questions this afternoon?
Dr. Mills: The schedule that we established was based upon
the fact that the response that we got to the Federal Register in
the case of the Atomic Industrial Forum, they specifically stated
that they would have a panel discussion and that would be 60
minutes.
In the case of the Atomic Energy Commission, they did not
propose this whole listing as a single panel. I would suggest that
we would allow the Atomic Energy Commission their requested time,
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which was four hours for this particular aspect.
We also recognize that we will not get through this afternoon.
Therefore, we will at some point in time, when it seems to be that
we have covered a particular topic, we will adjourn until tomorrow
morning.
Dr. Radford: It is the intent, then, to question each one of
the speakers after his presentation?
Dr. Liverman: Dr. Radford, in discussing it with Dr. Mills, it
is perfectly permissible to question Dr. Yoder after his presentation.
The next two speakers, you should hear them both through before
the questions.
Dr. Bair is operating essentially alone; then, Dr. Burr and
Dr. Richmond are a pair; and Dr: Thompson is a single.
I would suggest that you question them in that order, but the
Chairman is the man who decides this issue.
The topics in the order I have given them to you are closely
interrelated.
Dr. Radford: If I may make a suggestion: In the interest of
not turning us off before we are through here, would it be possible
that the speakers would depart from their written testimony and
emphasize the highlights and shorten their presentations?
I am not trying to throttle them, but I think that many of the
issues will come out in the discussion. I think, perhaps, one of
the things that may be apparent to the audience is that it is in
the questioning that we begin to get at the nub of some of these
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issues.
The formal presentations can be shortened down to give the
highlights. The only other alternative I see, frankly, is to go
on into an evening session.
Dr. Liverman: Of course, since I am through, I can say yes.
But I think the thing for us to try to do is to summarize our
comments.
Dr. Mills: The agenda for tomorrow afternoon is lighter. We
may be able to make up for some of the time we lose today, so I
would not propose that we go into the evening hours in trying to
address this.
However, I would say that some attempts could be made to
summarize the comments, as Dr. Liverman has suggested. Then we
would ask questions in terms of specific topics as shown under
the AEG portion of the agenda.
Dr. Radford: I am concerned, frankly, that we not be running
so late that Dr. Tamplin's presentation will be thereby curtailed,
if not by pressure of the time, by pressure of the fact that people
start to leave.
So I think it is very important that we have plenty of time
available for questioning Dr. Tamplin at length just as we hope
we will have time to question the AEG representatives.
Dr. First: Would it be possible to start tomorrow earlier
and cut tomorrow's lunch to an hour?
Dr. Mills: Dr. Tamplin is scheduled for tomorrow afternoon,
-------
290
so I think we have sufficient time to get him on tomorrow after-
noon without shortening his presentation.
In spite of the time frame, for the benefit of the reporter
who has to keep all of this going into her machine, let me call
for a ten minute recess until she has time to catch her breath.
(Brief recess.)
Dr. Mills: We will resume the hearing.
Our next speaker is Dr. Yoder.
-------
-i3 - 291
Potential Source Terms and Control Measures
by Robert E. Yoder, Jr., Ph.D.
Assistant Director for Facilities Safety
Division of Operational Safety
U. S. Atomic Energy Commission
Washington, D. C. 20545
part of the AEC presentation at
EPA Plutonium Standards Hearings
Washington, D. C., December 10-11, 1974
Introduction
The information presented in this discussion will include the current
sources of transuranium materials within the Atomic Energy Commission (AEC)
operations, an indication of projected inventories, and an overview of
control measures taken to reduce effluents. This is not intended to be
an exhaustive review of the subject matter, but to highlight the AEC
actions in managing its transuranic materials operations. Specific
information regarding the location and quantity of material which has
been released to the environment will be presented later.
There have been releases of plutonium and these have been well pub-
licized. The quantities of materials involved in these instances have
ranged from much less than one to a few kilograms of material, and steps
have been taken to reduce the accident potential in AEC operations. A
comparison of the quantities released to the quantities in use shows that
a very small amount has been released in accidents. Routine emissions
are now very low and still decreasing. Because the AEC is concerned
about environmental discharges and any attendant buildup in the environment,
it is fully implementing the "as low as practicable" concept. For
example, if our routine emissions continue at the present levels by the
-------
292
year 2000 less than 3 additional curies of plutonium will be discharged
to the environment, compared to the kilocurie quantities already present
from atmospheric weapons testing. The intensive environmental sampling
program which quantifies the amount of plutonium in the environment and
its specific location in identified pathways provide confirmation that our
control programs are effective. Information developed in this program will
be available and analyzed well before a potential problem exists and will
allow ample time to take effective action.
In those instances in which environmental cleanup actions have been
required, specific measures tailored to the specific site have been used.
Because the number of the cases is very small, they are best handled on a
case-by-case basis so that a comprehensive evaluation can be made to
effectively limit the availability of these materials.
Cost-Benefit
The AEC uses plutonium or handles plutonium in three broad program
categories: national defense, energy research and development, and
service to other agencies and private industry. The benefit-risk analyses
with regard to each of these areas is developed along separate lines of
reasoning: (1) The executive and legislative branches of the government
have established the benefit-risk associated with a viable national
defense program which requires plutonium for its development and main-
tenance. The AEC produces and manufactures plutonium components for use
by the Department of Defense. Also, as required by the Test Ban Treaty,
the AEC maintains a viable nuclear development and test program. (2) The
current energy situation has brought into focus a number of elements per-
tinent to the risk-benefit of plutonium reactors as sources of electric
-------
-15' 293
power. The AEC conducts the research and development necessary to support
the industry options to use these reactors for electric power production.
(3) Service functions are associated with the development of nuclear
radioisotopic thermoelectric generators which are manufactured by the AEC
for agencies who themselves have developed the risk-benefit analyses supporting
their use. In this case, the AEC merely supplies the material in a form
suitable for the specific program use. As an additional service function,
the AEC provides the burial facilities or interim storage facilities for
transuranic materials.
In June 1973 the AEC began the preparation of an environmental impact
statement for the overall Liquid Metal Fast Breeder Reactor (LMFBR) pro-
gram (WASH-1535) as required by the National Environmental Policy Act (NEPA).
The environmental impact statement, now in the final stages of review
prior to release, differs from the conventional statement because it
addresses the important environmental and societal impacts from the assumed
eventual commercialization of LMFBRs which are expected if the research
and development goals are attained rather than the impact of the research
and development activities. It was necessary, therefore, to look ahead
some 40 to 50 years to foresee an LMFBR industry that would provide about
40 percent of the total installed electric generating capacity in the
United States by the year 2020.
The direct costs include LMFBR development program costs and those
costs normally imbedded in the price of electrical energy. Over 70
separate postulated cases were considered in estimating United States
electrical power production costs over the period 1974-2020. One of the
major quantifiable conclusions of the direct economic analysis was that
-------
294
the introduction of a fast breeder into the United States electric power
utility system will produce significant financial benefits. These benefits
result largely from a reduction in uranium ore and enrichment requirements.
Additionally, the fast breeder results in a nuclear power industry that
will have total power costs, in constant dollars, that decrease with time.
Capital requirements accumulated to the year 2020 are estimated to be
about 10 percent less with a fast breeder industry due to the reduced
requirement for mining, milling, and enrichment facilities.
Indirect benefits, though no less significant, come partly from the
improved resource utilization. The use of plutouium as a reactor fuel for
electric power production would free the finite resources of fossil fuels
for their optimum use, thus assuring the domestic availability of fuel
for electric power production for the long term. A mature LMFBR industry
together with the nonbreeders can generate sufficient fissile material for
the nuclear industry to be able to use stockpiled depleted uranium for
hundreds of years as the sole source of fertile fuel material.
Other indirect benefits of note are in the cumulative health and
safety effects for both occupational and public groups.
Inventories
The AEC has produced several tens of tons of plutonium-239 in its
reactors, including several tons of nonweapon grade plutonium, since the
mid-1940's. In addition, 200 kg of Pu-238, 4 kg of Cm-244, and 2 grams
of Cf-252 have been produced in the Savannah River reactors. Additional
quantities of transplutonium elements have been produced in Savannah
River reactors, separated, and refabricated into targets for further
-------
295
irradiation as part of the Cf-252 program.
Plutonium-238 is used principally as power sources for space research,
satellites, and heart pacemakers. These applications have required about
40 kg of plutonium-238 since 1961. The requirements for specific applications
through FY 1986 project a need of about 540 kg of plutonium-238. Since
1961 the United States has launched radioisotope thermoelectric generators
containing 34.7 kg of plutonium-238. Of this quantity, 13 kg are on the
lunar surface, 6.8 kg are in long-lived earth orbit, and 9.4 kg have been
ejected out of the solar system. One kg was released to the earth's atmos-
phere in a reentry burnup (as designed), 2 kg of encapsulated material
were recovered from the Santa Barbara Channel following a missile abort,
and 2.5 kg impacted intact (as designed) in the South Pacific Ocean following
an aborted lunar mission. No plutonium-238 was released from the latter
two incidents.
Small quantities of plutonium-238 will be required for heart pacemakers.
A potential equilibrium number of 170,000 of these devices will be needed
in the United States by the year 2000. The total quantity of plutonium-238
required ranges from 25-75 kg. Several companies at present are licensed
to implant these devices and an equilibrium implant rate of 10,000 per year
is expected to be reached in the early 1980's.
The major increase in plutonium inventory is anticipated to be that
associated with commercial nuclear power reactor activities which are
projected to have "on-hand" a potential commercial plutonium inventory
of 117,000 kg in the year 2000. Reactor research and development program
annual plutonium requirements are projected to vary in the range of 500-
2,500 kg over the next 10-year period.
-------
296 ~18"
The types of operations in the AEG involving plutonium include its
production in reactors at Savannah River and Richland, chemical processing
to separate plutonium from uranium and fission products, reduction to the
metal, casting, machining, and other metallographic operations. In addition,
scrap material is processed for recovery of plutonium by incineration,
digestion, precipitation, and solvent extraction. Plutonium also is
removed from liquid effluent streams by filtration and precipitation to
reduce the volume of material which must be sent to waste handling and
storage facilities, and to reduce the quantity present in waste streams.
The AEG also manufactures experimental fuel elements containing plutonium
and operates reactors containing plutonium fuel elements, such as the
EBR II. Waste material from all AEG operations is placed in retrievable
storage if the plutonium or transuranic material concentration in the
waste is in excess of 10 nCi/g. A proposed rule-making would cause all
commercially generated transuranic waste in excess of this limit to be
sent to AEC storage sites pending the development of a final repository
(Federal Register, Volume 39, September 12, 1974). In the execution of
these programs the AEC engages in the transportation of radioactive
materials in interstate commerce. However, this material is safeguarded
as appropriate to the type and quantity of material, and the associated
potential hazards.
The quantity of transuranic materials now stored or buried at AEC
sites totals about 950 kg contained in approximately 1 million cubic
meters of material. This material is located in burial grounds at the
Idaho National Engineering Laboratory, Idaho; Richland, Washington;
-------
- 19 - 297
Savannah River, South Carolina; and Oak Ridge, Tennessee. The characteristics
of transuranium-contaminated waste will change as the breeder reactor pro-
gram develops and will require the storage not only of transuranic
materials, which are primarily alpha emitting materials, but also trans-
uranic materials contaminated with gamma activity in fuel hulls which
contain induced radionuclides and fission products. The assessment of
projected quantities of transuranic wastes expected by the year 2000 is
presented in Table 1.
Emissions
A concerted effort to accelerate the reduction of all emissions of
all radioactive materials from AEG operations was initiated in 1970, in-
cluding a program to quantify all past releases from AEC facilities.
Figure 1 summarizes the total plutonium release data from all AEC sites having
significant releases for the years 1967-1973. Figures 2 and 3 provide a
breakdown of these data to show the quantities released via air and water.
The important point to note is that the releases from all sites have been
approximately 1.5 Ci over the 6-year period. From our operational experience
and the improved control measures at all facilities, we anticipate that
AEC releases will not exceed, through normal discharge systems, 0.1 Ci/yr
from all operations from all sources.
In 1973, 0.053 Ci of plutonium and approximately 0.002 Ci of other
transuranics were released offsite. In the same year approximately 100 Ci
of plutonium and approximately 0.1 Ci of other transuranics were released
onsite to treatment and disposal systems such as seepage basins. The
-------
298 - 20 -
composition of the 1973 onsite releases is shown in Table 2. The largest
component of this discharge occurred at Richland, however, this operation
has been sufficiently modified so that no plutonium has been discharged
to date during CY 1974. We anticipate that in CY 1974 less than 1 Ci will
be discharged onsite from all sources of plutonium at all AEG sites.
These reductions should be viewed with the fact in mind that much larger
quantities have been discharged onsite in the past. The impact of the
releases and a full assessment of their significance in the environments
surrounding AEG facilities is available in WASH-1259.
Control Measures
An intensive reevaluation of the AEG handling of plutonium was initiated
following the 1969 Rocky Flats Plant fire. All plutonium operations and
storage facilities were surveyed and new safety criteria developed for
these operations. Because the new criteria addressed in detail areas not
previously highlighted, there are certain modifications which cannot be
undertaken in present facilities, particularly regarding natural phenomena
(tornado, earthquake) protection. However, in these cases additional safe-
guards and alternate protection has been provided. Plutonium operations
are being conducted in glovebox and/or canyon facilities, which provide at
least three barriers (e.g., glovebox, operating compartment, and outer
facility walls) between the operation and the outside environment. Where
possible, inert atmospheres are used to reduce the potential of fire.
Fire protection is provided through the use of sprinkler systems and,
in some cases, inert gas protection. Firebreaks and operation compart-
mentalization are used to limit the extent of any incident. At least
-------
~21~ 299
three high efficiency air cleaning devices are required between plutonium
operations and the outside environment. This criteria is being met
through the use of three or more stages of high efficiency filters or two
stages of high efficiency filters in addition to a sand filter. To
provide assurance for the control of plutonium in the event of a postulated
accident, emergency power and protected, isolated emergency control rooms
are available. A formal safety analysis report requiring AEC approval
must be written for all new plutonium operations. These safety analysis
reports critically review every operation, every control measure, and every
interaction between operations and controls to avoid a possible loss of
control. To date over $210 million for construction has been committed
to upgrade or replace existing facilities. A significant sum has been spent
also in accomplishing a myriad of small projects.
The AEC has always operated under the "as low as practicable" philosophy
with regard to the release of any radioactive material to the environment.
However, values associated with "as low as" have continually decreased
with increased operating experience and improved control technology. Every
transuranium operation has been reviewed recently and additional safeguards
installed to reduce effluents to the lowest level that is economically
possible. At the Rocky Flats Plant, for example, a water treatment plant
to clean and permit the reuse of process water is scheduled for FY 1977
in order to minimize the quantity of potentially contaminated waste water
which is discharged from that site.
-------
300 - 22 -
The plutonium-238 encapsulation operation at the Mound Laboratory is
being transferred to an upgraded plutonium facility at the Savannah River
Plant. By 1980 primarily only encapsulated plutonium-238 material will
be handled at Mound Laboratory. This program will restrict the availability
of unencapsulated material and reduce significantly the release potential
of plutonium-238 oxide as well as minimize the quantity of waste material,
and the number of shipments required.
Accidents
The release of plutonium and other transuranic materials in decreasing
order of quantity are associated with:
1. atmospheric weapons testing;
2. weapons tests at the Nevada Test Site;
3. accidents—both from military operations and AEG plant operations; and
4. effluents from normal discharge waste streams.
The major plutonium releases associated with AEC plant operations
have occurred at Oak Ridge, Rocky Flats, Richland, and Mound. The total
quantity involved amounted to a few tens of curies, which represents a
small fraction of that in process. In each of these areas intensive
environmental survey programs are underway.
An analysis of three accidents associated with military operations is
provided in the supporting documentation. The important element in the
cleanup actions for these accidents is the careful analysis of the signi-
ficance of any material not removed. The experience we have gained from
these accidents has led to an enhancement of our capability to survey and
-------
- 23 -
cleanup accident sites. Portable monitoring instrumentation useful for
2
onsite surveys provides a sensitivity of .1 p,Ci/m of plutonium on the soil
surface. An aerial monitoring program using sensitive radiation monitoring
instruments and helicopters, allows the survey of large areas with a
2
sensitivity of 0.3 ^Ci/m . This survey technique allows operation at 100
feet altitude above the ground surface and at an air speed of 60 knots.
Analytical analyses for plutonium in environmental samples provide assess-
-5 2
ments such that we can determine plutonium at levels below 10 u£i/m .
Now a number of AEG laboratories have a proven capability to process,
specifically for plutonium, soil or vegetation samples with this sensitivity.
The limit of sensitivity in these cases is limited by the quantity of
material which one can manipulate in the chemical processes and the capability
to analyze a large number of samples, such as may be required in an
accident situation. The accidents which have occurred were in quite different
environments and required very different techniques for cleanup. As a
matter of course one removes all radioactive material which is practical to
remove and which poses a potential significant source of exposure. The
techniques which can be used include excavation, plowing, and fixation.
New techniques to fix plutonium to reduce its movement prior to cleanup
are under development. The guidelines which can be used for the cleanup
levels must be specifically set at each site because the pathways for
human exposure and ability to cleanup will vary from site to site. The
situations which occurred at Palomares, Spain; Thule, Greenland; Rocky
Flats, Colorado; the Nevada Test Site; and Enewetak Atoll are all unique.
No two have the same problems nor do they appear at this time to be
amenable to the same cleanup techniques. The quantity of plutonium involved
301
-------
302
- 24 -
in any accident represents a very small fraction of the quantity of that
material in the inventory, and the quantity left after cleanup is even
smaller.
Summary
There have been releases of plutonium and these have been well
publicized. The quantities of materials involved in these instances have
ranged from much less than one to a few kilograms of material, and steps
have been taken to reduce the accident potential in AEG operations. A
comparison of the quantities released to the quantities in use shows that
a very small amount has been released in accidents. All routine emissions
are now very low and still decreasing. Because the AEG is concerned about
environmental discharges and any attendant buildup in the environment, it
is fully implementing the "as low as practicable" concept. For example, if
our routine emissions continue at the present levels by the year 2000 less
than 3 additional curies of plutonium will be discharged to the environment
compared to the kilocurie quantities already present from atmospheric
weapons testing. The intensive environmental sampling program which quantifies
the amount of plutonium in the environment and its specific location in
identified pathways provide confirmation that our control programs are
effective. Information developed in this program will be available and
analyzed well before a potential problem exists and will allow ample time
to take effective action.
In those instances in which environmental cleanup actions have been
required, specific measures tailored to the siatuion have been used. Because
the number of the cases is very small, they are best handled on a case-by-case
basis so that a comprehensive evaluation can be made to effectively limit
the availability of these materials.
-------
1000
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- 25 -
RELEASES OF PLUTONIUM OFFSITE
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1967 1973 1967 1973 1967 1973 1967 1973 1967 1973
TOTAL SR MOUND LASL ROCKY FLATS
303
Figure 1
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- 26 -
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LIQUID RELEASES OF PLUTONIUM OFFSITE
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TABLE 2
AEC TRANSURANIC RELEASES
CY 1973
Onsite Discharges (rounded)
Plutonium 100 Ci
Curium 0.10 Ci
Other transuranics .001 Ci
Effluent Discharges
Plutonium 0.053 Ci
Americium 0.001 Ci
Curium .000^ Ci
Neptunium .0005 Ci
-------
- 30 -
308
TABLE 3
CONVERSION FACTORS
Plutonium-238 17 kCi
kgm
Plutonium-239 .063 kCi
kgm
8l.8 kCi
kgm
Californium-252 539 Ci
gm
-------
- 31 -
309
SUPPLEMENTAL INFORMATION
-------
310 -33-
DIVISION OF BIOMEDICAL AND ENVIRONMENTAL RESEARCH
Potential Plutonium Source Term for Medical Uses
Radioisotope-Powered Cardiac Pacemaker
1. The purpose of the AEG program is the demonstration that technology
exists which will permit the production of nuclear-powered cardiac
pacemakers which will, with great confidence, substantially improve
upon the reliability and lifetime capabilities of presently avail-
able chemical battery-powered pacemakers.
The 197^ pacemaker population is approximately 126,000 world-wide.
The potential U.S. nuclear pacemaker market is estimated to be 10,000
per year with an equilibrium number of 170,000 in the U.S. population
in the year 2000.
The primary environmental implications are from radiation during normal
use and from potential exposure to fuel following a breach of the capsule
and a release of the fuel to the environment-.
The benefits of a long-lived nuclear pacemaker are direct functions of
minimizing the number of reimplantations during the patients remaining
lifetime.
2. Approximately 350 nuclear pacemakers are currently in use in the U.S.
Three companies are presently licensed to implant 20 units per month
each. An equilibrium implantation rate of 10,000 per year is expected
to be reached in the early 1980's.
The inventory of plutonium-238 in the nuclear pacemakers ranges from
140 to 420 milligrams per unit. Thus, the total plutonium-238 inventory
for a population of 170,000 in the year 2000 ranges from 24 to 71
kilograms.
3- The fuel capsule has demonstrated its capability to survive all the
safety tests defined by the AEC's "Interim Safety Guide for the Design
and Testing of Nuclear Power Cardiac Pacemakers" with additional sub-
stantial safety margins.
4. Fuel processing losses which are unuseable wastes amount to about
1 percent of the starting inventory. For 10,000 units per year the
plutonium wastes would be in the range of 1S to 40 grams per year.
-------
- 34 - 311
THE WASTE MANAGEMENT OF TRANSURANIC SOLID WASTE
Solid wastes of widely diverse nature and contaminated to varying degrees
with heterogeneous amounts and forms of plutoniw are generated in several
AEG facilities. The radioactivity in such wastes has been confined within
controlled areas of AEC sites by burial in shallow trenches or pits and
since 1970 in easily retrievable containers. The principal burial sites
include the Richland site, the Idaho Falls site, Los Alamos Scientific
Laboratory, Oak Ridge National Laboratory, and the Savannah River Plant.
The waste matrices in which the transuranic isotopes are contained vary
greatly in their composition. Normally, they can be segregated into
those which are noncombustible and those which are combustible. Depending
on the facility, the noncombustible fraction may comprise up to one-half
of the total volume of waste generated, while the combustible portion
includes such things as paper, rags, plastics, rubber, and discarded
clothing. Table 1 shows the results of a waste composition survey taken
by the Los Alamos Scientific Laboratory. This table gives an idea of the
tremendous variation in composition of wastes generated by different
laboratories.
Table 2 shows the projected increase in production of transuranic waste.
If current process techniques continue, by the year 2000 approximately
2^4,000 cubic meters of alpha waste will be generated; and an additional
86,000 cubic meters of waste will be generated which has a high gamma
background. Although these wastes will require much improved treatment
and handling systems, our past experience indicates that release of TRU
nuclides to the environment will be well within AEC guidelines based on
recommendations of the International Commission on Radiological Protection.
Current management programs offer little chance for environmental con-
tamination by transuranics. Effluent treatment processes which produce
some solid waste materials may lead to limited offsite radioactivity
releases but these are extremely low and must always be within AEC guide-
lines .
Several years ago the AEC reexamined its policy regarding the management
of its own transuranium-contaminated radioactive waste. Until that time,
it was felt that the remoteness of the burial sites combined with favor-
able geological and hydrological conditions would assure the safety of
the environment from TRU wastes. However, there exists the possibility
that the status of sites may change as a result of new national prior-
ities. Also, the quantities of transuranic waste generated are expected
to increase substantially as a result of the generation of nuclear power.
It was decided to limit the outright burial of transuranium-contaminated
waste, and in March 1970, the AEC issued a directive^ requiring its con-
tractors to segregate transuranium-contaminated waste from ncntransuranium-
contaminated waste and to store the transuranics in a manner which would
^'Policy Statement Regarding Solid Waste Burial," USAEC, IAD No. 0511-21,
March 20, 1970.
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permit them to be readily retrieved in a contamination-free condition
for a period of at least 20 years. This would permit time to develop a
national policy «mich would "be acceptable to the public for disposal of
transuranium-contaminated waste.
The transuranic waste storage site at the Idaho National Engineering
Laboratory (INEL) at Idaho Falls is a good example of current practices
resulting from this directive. Here the waste is stored on an asphalt
pad which has a four inch gravel base. The surface is sloped to permit
moisture drainage. The waste is packaged in 55"gallon steel drums or in
plywood boxes which are coated with fiberglass. The 55-gallon drums are
currently lined with a 90-mil. polyethylene liner to prevent contact of
the waste with the wall of the drum. These packages are stacked on the
pad in sections of approximately 150 feet by 80 feet. Once a section is
full, the stacked waste is covered with plywood and a plastic sheet and
then mounded over with earth. Normally a 3-foot space is left between
each section of the pad. This 3-foot section is filled with earth and
provides a fire-retarding wall.
The volume of transuranium-contaminated waste in the U.S. and the contained
transuranium nuclides is expected to increase greatly in the coming years
as a result of the use of plutonium in the production of nuclear power.
Due to this*projected increase, the Directorate of Regulation* of the AEC
has proposed a change in the Federal Regulations regarding licensee manage-
ment of transuranic waste. In September 197^-, a notice2 was published in
the Federal Register regarding a proposed rulemaking which would result in
Federal management of these wastes.
According to current plans, the operating arm of the AEC** would manage
commercially generated transuranic waste in the same manner as they manage
AEC-generated transuranic waste. The waste would be placed into 20-year
retrievable storage just as it is at INEL. The generator would pay a one-
time fee which would cover the cost of all future management. An environ-
mental impact statements is being prepared by the AEC which discusses
alternatives for waste management in detail and is available in draft
(WASH-1539).
* To become NRC about January 1, 1975'
**To become part of ERDA about January 1, 1975-
n
"Transuranic Waste Disposal," Federal Register, Vol. 39, No. 178, Thursday,
September 12, 197^, pp. 32921-32923-
•a
"Management of Commercial High Level and Transuranium-Contaminated Radio-
active Waste," WASH-1539, USAEC, September 1971*- (draft).
-------
- 38 -
315
In Table 3 "the total volume of radioactive waste at the major AEC sites is
shown in the first column in cubic meters. The total quantity of trans-
uranium nuclides oc.rtained in all of this nolle1 vaste is about 950
kilograms. Of this quantity, roughly 175 kilograms is stored in a
readily retrievable fashion and the remaining 775 kg has been buried.
The volume of waste retrievably stored is roughly 29*000 cubic meters,
and it contains roughly one-fifth of the total quantity of transuranic
nuclides generated to date.
The buried transuranium nuclides at AEC sites and the 80 kg of plutonium
at licensed facilities will require continued long-term surveillance. The
waste package is not considered to have any integrity after it is buried.
Monitoring and surveillance programs at AEC sites have shown that migration
of the buried transuranics has been negligible.^ However, the wastes will
remain hazardous for an extremely long period of time and one cannot predict
with certainty what, if any, environmental changes will take place during
this time.
In consideration of the long periods of time for which these wastes must
be confined, the AEC is developing hazards analysis procedures to determine
the risk to man and his environment which may result from these wastes in
the future. Based on these analyses, the AEC will be able to decide
whether it *rill be necessary to remove these wastes from the burial areas.
"Environmental Monitoring at Major USAEC Contractor Sites," WASH-1259,
USAEC, August 1973.
-------
316
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317
SNS PLUTONIUM OPERATIONS
General Program Aspects
For the past 15 years, the AEG has been developing Radioisotope
Thermoelectric Generators (RTG) to provide electrical power for
both space and terrestrial applications. These devices convert
thermal energy derived from the decay of radioactive isotopes
to electrical energy utilizing the thermoelectric properties of
bimetallic couples. Several isotopes have been considered as
thermal sources; however, the most desirable one from an overall
system point of view has proved to be Plutonium-238. The follow-
ing discusses Space Nuclear Systems (SNS) operations utilizing
Plutonium-238 as a fuel form.
A. Purpose
The purpose of the Plutonium RTG program is to develop long
lived, unattended, reliable and light weight power system
for space applications.
It is the intent of SNS to develop these systems so as not
to present undue hazards to operating personnel, to the
general public or to the worldwide population.
B. Advantages of Nuclear Systems
The following are advantages of using nuclear systems for
space missions:
1. With the proper isotope, the system can be designed for
long life, it can be compact, and it can provide a high
power to weight ratio.
2. In space, it need not be dependent on sunlight or sun
orientation. All outer planet exploration missions must
use nuclear power because of the lack of solar energy.
3. A nuclear system is naturally radiation hardened for
military applications and will withstand radiation
emitted by planets.
4. It can provide both electrical and thermal power any-
where in space.
-------
318 -4i-
C. Specific Advantages of Plutonium
Plutonium-238 provides a specific power which enables the
RTG design to meet the advantages indicated above. Because
it provides its thermal power from alpha decay, little
shielding is required. Also, because of its reasonably long
half-life, no power flattening is required for missions as
long as 10 years. The oxide of plutonium provides a reason-
ably high melting point which permits the design of space
systems to preclude Plutonium-238 releases in thermal environ-
ments to which the system may be exposed if flight aborts
should occur.
D. Safety Criteria
The general safety design objectives of a radioisotope heat
source and/or its associated power system components are to
contain the radioactive materials (the isotope fuel form and
its radioactive products) and to limit the interactions of
the radioactive materials wich humans and the environment.
For normal operations, containment and interaction requirements
are absolute; for potential accident situations, containment
requirements are based on probabilistics and are determined by
a given source term (amount of radioactive material released)
and/or the direct external dose to one or more random human
receptors.
Containment and the limiting of interactions between the
radioactive source, humans, and the environment are absolutely
maintained in normal factory-to-flight and post missions
operations. The exposure limits for radiation workers,
individuals and the general public applicable to normal mission
operations are those set forth in the Code of Federal Regu-
lations (CFR), Atomic Energy Commission Manual Chapters (AEC-MC)
and the International Commission on Radiological Protection (ICRP),
In the event of random earth impact situations, the safety
objectives are to locate and recover the nuclear heat source(s).
For accident situations, the following recent probabilistic
criterion is required of the system: the total probability
of releasing one millicurie of fuel and/or its daughter
products or exposing one or more people to a direct external
radiation dose exceeding the limits set forth in the above
documents should be less than 10"5 per flight, given the
occurrence of any accident. For source terms other than one
-------
-42- 319
millicurie, scaling the fuel release probability inversely-
proportional to the source term should be considered. The
above probabilistic criteria should be demonstrated at a
reasonable confidence level ( > 50%) by analysis and/or test.
E. Safety Assessment
Before any nuclear system is used, it must be reviewed and
evaluated on the bases of risk to the general public and the
environment by an Interagency Nuclear Safety Review Panel
(INSKP) who must submit a Safety Evaluation Report (SER) to
National Security Council (NSC) for presidential approval
action. This INSRP is comprised of experts in the field of
nuclear system design, launch vehicle design, accident
evaluations, aerodynamics, thermodynamic, meteorology,
terradynamics, oceanography, astrophysics, health and safety,
biology, medicine and others from EPA, NASA, DOD, AEC, NOAA,
and their government agencies and their contractors.
The review covers all aspects of possible accidents from
factory-to-flight including ground transportation, launch,
suborbital, orbital reentry, impact and post impact situations.
The panel reviews the results of safety verification tests
which are generally conducted by the systems contractor to
evaluate the response of the heat source in overpressure,
launch-pad fires, reentry, impact and post-impact environments.
A Safety Evaluation Report prepared by the panel provides an
analysis of the risk to man and the environment based on the
results of the INSRP review.
Since the AEC is not the user agency of the nuclear systems,
it is not responsible for benefit analyses and environmental
impact statements. These requirements and the request for
launch approval are the responsibility of the user agency.
II. Plutonium Applications
A. Current Applications
The following programs are currently using plutonium or
contemplate using plutonium in the very near future:
1. Pioneer 10 and 11 - NASA mission of two spacecraft
to Jupiter which use four RTG's per spacecraft
(1200 grams each RTG). Launches in March, 1972 and
April, 1973.
-------
320
- 43 -
2. Viking - NASA mission of two Mars landing spacecraft
which will carry two RTG's per spacecraft (1200 grams
each RTG). Launches are in August and September, 1975.
3. LES 8/9 - DOD mission of two satellites to synchronous
altitude will use two RTG's per satellite (4.2 kg per
RTG). Simultaneous launch of both satellites on the
same spacecraft in November, 1975.
4. Mariner/Jupiter Saturn (MJS) - NASA mission of two
spacecraft to sJupiter and Saturn with three
RTG's per spacecraft (4.2 kg each RTG). Launches in
August and September, 1977.
B. SNS Operational Sites
The following sites are presently being utilized by SNS for
their RTG activities:
1. Monsanto Research Corp. (MRC), Mound Laboratory,
Miamisburg, Ohio, provide encapsulated, sealed plutonium
heat sources for use in all of the programs.
2. Launches are from either Kennedy Space Center or Cape
Canaveral Air Force Station, Florida.
3. The AEC's Savannah River Plant at Aiken, South Carolina,
will begin providing Plutonium-238 fuel forms for the
space program in the 1977 time period.
C. Current Plutonium Inventories in Space
Since 1961, the AEC has launched 34.7 kilograms of Pu-238.
Of this amount, one kilogram was released to the earth's
atmosphere by burn-up during reentry, two kilograms were
recovered from the Santa Barbara channel after a missile
abort, two and a half kilograms deposited and contained in
the South Pacific Ocean near the Tonga Trench, after an
aborted Apollo mission, 13 kilograms are on the lunar
surface, 6.8 kilograms are in long lived earth orbit, and
9.4 kilograms have been ejected out of our solar system into
deep space.
-------
-44- 321
D. Forecast Inventories at Fabrication Sites
Plutonium inventories planned at fabrication sites for
future SNS activities include the following:
1. Mound Laboratory - Unencapsulated fuel at Mound will be
decreasing from about 40 kg at present to zero by FY 1980>
in accordance with SNS plans to transfer fuel form
fabrication to Savannah River. Mound Laboratory
will continue assembly of heat sources in the future,
using encapsulated fuel forms supplied by Savannah
River. Time-average inventories of this encapsulated
fuel at Mound Laboratory are expected to approximate
30 kg/yr by FY 1978.
2. Savannah River - Beginning in FY 1977, inventories will
increase from zero to a time-averaged level approximating
40 kg/yr, including associated process salvage.
3. Inventories in R&D at Savannah River and Mound Laboratory
will approximate 3 and 7 kg/yr, respectively. Time-
average inventories in recovery operations at Savannah
River may approximate 10 kg/yr.
E. Future Applications
Additional Viking missions to Mars are planned by NASA in the
1981 time period. Post 1980 missions planned by NASA include
a Mariner Jupiter Uranus flyby, a Mariner Jupiter Orbiter,
a Pioneer Jupiter Orbiter, a Pioneer Jupiter Probe and a
Mars Sample return mission. The DOD has several planned
missions in the post 1977 time period. All of these missions
will utilize plutonium fuels for electrical power. The
following plutonium inventories are contemplated to meet the
above requirements:
1. FY 75 - 30.9 kg
2. FY 76 - 19.4 kg
3. FY 77 - 14.4 kg
4. FY 78 - 35.3 kg
5. FY 79 - 59.0 kg
6. FY 80 - 69.7 kg
7. FY 81 - FY 86 - 331.8 kg
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322
III. Control Technology
A. Past Effluent Releases
Early isotopic space systems were designed to burn up on
reentry yet provide absolute containment for all ground
handling and accident situations. In 1964, SNAP 9A burned
up on reentry as designed after an abort on ascent to orbit.
One kg of Plutonium-238 was burned up in the stratosphere
(particle size - 0.4 ji) .
Systems after the SNAP 9A were designed for intact reentry.
Two aborts after 1964 released no radioactive material.
The first, a Nimbus spacecraft was aborted in 1968 after
launch at the AF Western Test Range. It was intentionally
destructed at 100,000 feet after the launch vehicle went
off-course. The radioisotope capsules were retrieved intact
from the Pacific Ocean (contained 2 kgs). The second, an
Apollo 13 aborted in 1970 and the LEM returned to earth with
the radioisotope capsule. The capsule sustained reentry
and impacted in the deep ocean south of the Fiji Islands
in at least 20,000 feet of water with the Plutonium-238
contained in multi-containment capsules.
B. Projected Effluent Control Plans
No releases are projected in the future. Systems are designed
to remain intact under all normal and all credible accident
conditions. Also in the design of future systems, con-
sideration is given to possible search and recovery of
aborted systems. Plans and techniques for worldwide search
and recovery exist now and are continually being updated.
Salt water actuated pingers are standard items on all flights
to assist in locating and recovering the Pu-238 in the event
of an advertent water impact, should early launch vehicle
accidents occur.
Effluent control at the Savannah River is under the Production
Programs and at Mound Laboratory is under Weapons Programs,
except that the SNS operations at Savannah will be a "dry
process" producing no effluents.
C. Containment Test Programs
1. To verify containment design, extensive safety test
programs are conducted under all simulated accident
conditions: fire, over-pressure, reentry, impact,
and post-impact environments.
-------
-46- 323
IV. Projected Waste Quantities
No waste quantities are projected as the result of space operational
activities.
Manufacturing site wastes are projected as follows:
1. Savannah River - less than 120 grams/yr, accumulating
annually beginning in FY 1978.
2. Mound Laboratory - less than 600 grams in FY 1975 decreasing
to less than 50 grams in FY 1980 and thereafter.
3. Transuranium wastes are sent to appropriate AEC burial sites.
-------
324 -47-
DIVISION OF PRODUCTION AND MATERIALS MANAGEMENT
Overview on Plutonium and Transuranic Elements -
Source Terms and Operations
1. Production and Materials Management Program Summary
The nuclear reactors at AEC's Richland and Savannah River plants were built
to produce nuclear materials for the Nation's defense program. Continued
operations under /.EC policies will enable the plants to continue pro-
viding protection of the" population and the environment from adverse
effects of radioactivity while fulfilling the function of producing
Plutonium and tritium for National defense. The principal product at
Richland is plutonium and at Savannah River both plutonium and tritium are
produced. Small quantities of other transuranic isotopes such as Np-237>
Pu-238, Am-2Ul, Am-2^3, Cm-2^ and Cf-252 are produced at the AEC production
sites. The Idaho Chemical Processing Plant, which recovers enriched uranium
from test reactor and Navy irradiated fuels, is also a part of the production
program.
The Richland plant was initially built during the second world war and has
been in operation about 30 years.. The original plant consisted of a
uranium fuel fabrication facility, three graphite moderated water-cooled
reactors, two chemical separations plants for plutonium recovery and
decontamination and a facility for the final isolation and purification
of plutonium nitrate solution. Production capacity at Richland was expanded
on numerous occasions between 19^-8 and 1962. Six additional reactors
were built including N reactor which is a dual purpose reactor producing
steam for electric power production in addition to plutonium. Only N
reactor is presently operated. The original batch-type plants for the
separation of plutonium were shutdown by 1956 and replaced by two continuous
solvent extraction plants. Neither of these plants are being operated
today but one plant is being held in standby for future operation.
Facilities were £.Xso provided for conversion ui plutonium nitrate to oxide
and metal and for the fabrication of weapons components. The fabrication
plant has been shutdown for several years and is currently being dis-
mantled. The Richland plant includes facilities for the treatment and
storage of liquid radioactive wastes.
-------
- 48 -
325
The Savannah River Plant was built in the early 1950's and included
facilities for fuel and target element fabrication, five heavy water moderated
and cooled production reactors, two chemical reprocessing plants for
both plutonium and enriched uranium recovery, tritium separations
facilities, and a heavy water production plant. Currently, only three
reactors are operating. Facilities have been added for the fabrication
of targets to be irradiated to produce other transuranics such as Np-237,
Pu-238, Am-243, Cm-244, and Cf-252 and for the separation of these products.
New facilities are currently being provided to fabricate Pu-238 oxide
fuel forms for thermoelectric power sources. Facilities are also provided
for the treatment and storage of liquid radioactive wastes.
The Idaho Chemical Processing Plant includes facilities for the separation
and purification of irradiated enriched uranium from test reactor and Naval
reactor fuels. Facilities are also provided for the temporary storage of
liquid radioactive waste which contain transuranic elements. The liquid
waste is converted to a calcined granular solid in a fluid bed and sub-
sequently stored in stainless steel bins.
2. Applications of Transuranics
The principal mission of the AEC production reactors is the production of
plutonium and tritium for weapon application. However, significant
quantities of non-weapon plutonium has been produced in support of the
civilian nuclear reactor development program and smaller quantities for
foreign sales. Pu-238 is produced for use as a heat source in thermo-
electric power for space application and for R&D for possible medical
application (pacemakers, artificial heart, etc.). Cm-244 has been used
in R&D programs and may be used as a replacement or supplement for Pu-238
in space applications. Cf-252 is used as a neutron source for neutron
radiography, cancer therapy, etc.
The AEC has produced several tens of tons of plutonium in its reactors
including several tons of non-weapon grade plutonium since the beginning
of the production program in the mid 1940's. In addition, 200 kg of Pu-238,
-------
326
- 49 -
4 kg Cm-244, and 2 grams of Cf-252 have been produced in Savannah River
reactors. Additional quantities of transplutonium elements have been
produced in Savannah River reactors, separated and refabricated into
targets for further irradiation as part of the Cf-252 program.
3. Control Technology
The AEC plutonium production plants control releases of transuranic
elements by the following procedures:
1. All process air passes through at least two high efficiency
particulate filters (HEPA) before release. All effluents
are monitored for releases.
2. Any liquid waste streams containing significant quantities
of transuranic elements are stored in waste tanks. Liquids
containing extremely low levels of transuranics such as evaporator
overheads are released to seepage basins or other controlled
facilities.
The total current releases of transuranics to controlled facilities
at Richland and Savannah River are about one curie per year while stack
releases from Richland and Savannah River average about 0.0013 and
0.02 curies, respectively. Releases to date from our plants are shown
in the table below.
Releases of Transuranics in Curies to July 1, 1974
3/
Richland— Savannah River— Processing 'i'lanu
Stack Releases - Ci 1-36 3.64 *
Seepage Basins, Ponds,
Cribs, Ditches, etc. - Ci 18^750** 20.13 0
* In the separation of enriched uranium at Idaho, fission products
and plutonium are separated from enriched uranium. The high level
liquid waste which contains the fission products and plutonium is
subsequently calcined to a granular solid. In this operation a small
-------
- 50 -
327
amount of radioactivity is released from the plant stack. The plutonium
releases from this operation which are essentially below the level of
detection are reported as less than 1 curie per year.
** The true level may be only about 66% of the reported level due to the
overstatement of quantities in the Z-9 crib.
In an effort to further reduce releases, the liquid process waste from
the plutonium finishing and scrap recovery operation, which was being
discharged at Richland to cribs or covered ditches, is being sent to
waste storage tanks. At Savannah River, a new sand filter is being built
in each of the two separations areas and all air from the plutonium and
transplutonium processing operations will be routed through a final
sand filter in addition -to at least two HEPA filters. At Idaho, a
filter is being installed which will substantially reduce stack releases
of radioactivity which is principally fission products but contains traces
of transuranics.
The AEG has established new criteria for facilities which process or store
plutonium including resistance to fires, earthquakes and tornados.
Facilities meeting the new criteria are available at Richland for the
storage of plutonium as metal, oxide, nitrate solution or scrap. Vaults
meeting the new criteria are available at Savannah River for plutonium
storage. At Savannah River a new facility is being built within an
existing building for converting Pu-238 oxide powder to specific fuel forms.
This building is being upgraded to meet the new plutonium criteria. The
process air from this building, which will be filtered by from two to
four HEPA filters, will be routed through the new F Area sand filter as
further backup against potential releases.
4. Future Projections
In the future, if production levels continue at about the same level, the
releases of transuranic elements can be expected to be held at about the
present level or slightly reduced due to the use of new facilities which
are under construction. Increases in the production of transuranic
dements with -ihort half-lives such as Pu-238, Cm-244, Cf-252 could
-------
328 -si-
require additional control facilities to control' releases at the current
level. Such facilities would be provided in accordance with accepted
AEG policies; however, at the present time there are no plans for
increased production of these elements.
I/ Data taken from [ARH-2806 4Q REV], "Radioactive Liquid Wastes
Discharged To Ground In The 200 Areas During 1973", and
[ARH-2807 4Q], "Radioactivity In Gaseous Waste Discharged From
The Separations Facilities During 1973", and updated with reports
for first six months of 1974.
21 Data taken from draft WASH-1537 Environmental Statement - Waste
Management Operations, Savannah River Plant and updated from SR
monthly reports.
3J Data taken from draft Environmental Statement, Waste Management
Operations, National Reactor Testing Station.
-------
-52-
Overview Reactor Research and Development Program Area
Source Terms and Operations
Prepared for
EPA Public Hearings - 12/10/74
1. Reactor Research and Development Program
For over 20 years the AEC has been engaged in the development of nuclear
power reactors to help meet the Nation's need for energy. To date, several
reactor systems have been successfully developed and some have come into
commercial use. These commercial reactors are now producing about 5 70 of
the Nation's electricity from the energy released from the fission of
uranium, with plutonium as a by-product.
Because of limitations inherent in today's nuclear power plants, only 1
to 27, of the energy potentially available in uranium can be used. The
fast breeder reactor, which is in an advanced stage of development can
extract 60% or more of the energy in uranium, including depleted uranium,
and also utilize the by-product plutonium for the initial fissile fuel.
This use of plutonium, through the development of the fast breeder reactor
to the point of large scale commercial application would mean the
availability of low cost uranium sufficient to provide a large fraction of
the Nation's electric energy requirement for hundreds of years, if needed.
Several promising breeder concepts have been investigated and the focus
of the AEC reactor development program is now on the sodium cooled Liquid
Metal Fast Breeder Reactor (LMFBR). At the same time, other breeder
options are being held open by carrying forward technology efforts for
breeder reactor concepts such as the Light Water Breeder Reactor (LWBR), the
Molten Salt Breeder Reactor (MSBR) , and the Gas-Cooled Fast Breeder Reactor
(GCFR).
-------
330 - 53 -
The LMFBR program has as its objective the timely development of
technology for a breeder reactor that will offer a commercially
competitive and environmentally acceptable option for helping to
assure the Nation's long-term electric energy supply. The program
recognizes that domestic economic uranium (and thorium) resources
are finite and that of the 220 or more nuclear power plants, now in
operation, under construction, or on order in the U.S., the pre-
ponderance are light water reactors which operate on the uranium-
plutonium fuel cycle. The overall LMFBR program for the development
of the required broad technological and engineering base, is being
carried out by AEC laboratories and by industrial firms at a number
of locations throughout the country. This includes many facilities
which are variously used to permit testing of physics, fuel, components
and instrumentation. Some of these facilities have plutonium
inventories.
The total of the plutonium inventories at RRD facilities is in the
range of 4000 kgs Pu. Table 1 lists the inventories of plutonium
reported by each of the major field offices for RRD programs as of
June 30, 1974. Table 2 shows the estimated annual Pu requirements for
major RRD programs thru 1986.
-------
- 54 -
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- 56 - 333
In June 1973 the AEC began preparation of an environmental impact statement
on the overall IMFBR Program (WASH-1535) as required by NEPA. The environmental
impact statement which was developed, and is now in the final stages of review
prior to release, diifers from the conventional statement in that the important
environmental and societal impacts [which are assessed] would not arise from the
proposed research and development activities, but rather from the eventual
commercialization of IKFBRs which would be expected if the research and
development goals were attained. It was necessary therefore to look ahead some
40 to 50 years to foresee an LMFBR industry that would constitute about 407=
of the total installed electric generating capacity in the U.S. by the year
2020.
Many estimates and forecasts were made for this study which could prove useful
in assessing the quantities and impacts of the plutonium that would be in use.
Pertinent tables from the report will be used in the following discussion.
In addition, an intensive cost-benefit assessment was undertaken, considering
both the direct and tha indirect costs and benefits of the development of the
IMFBR.
The direct costs were confined to IMFBR development program costs and to those
costs normally imbedded in the price of electrical energy. Calculations for
over 70 separate postulated cases were performed to estimate U.S. electrical
power production costs over the period 1974 - 2020. One of the major quantifiable
conclusions of the direct economic analysis was that the introduction of a fast
-------
334 -57-
breeder into the U.S. electric power utility system will produce
significant financial benefits. These benefits result largely from
a reduction in uranium ore and enrichment requirements. Additionally,
the fast breeder results in a nuclear power industry that will have
total power costs, in constant dollars, that decrease with time.
Capital requirements accumulated to the year 2020 are estimated to
be about 1070 less with a fast breeder industry due to the reduced
requirement for mining, milling and enrichment facilities.
With the breeder, the nuclear industry can eventually free itself
of the need to mine uranium. The advanced oxide fueled breeder,
with an astimated 10 year compound doubling time, can meet the
fissile fuel demand of a growing nuclear power industry with self-
generated plutonium shortly after the turn of the century.
Specifically, without the LMFBR, the cumulative U»08 requirement
to the year 2020 is 6.3 million tons, while the cumulative U_00
j o
requirement with the LMFBR is 2.6 million tons. Without the LMFBR,
U,0Q will be mined at an ever increasing rate, while with the LMFBR,
J O
the annual ore requirement becomes insignificant after about the
year 2015, with similar trends for separative work capacity requirements.
Indirect benefits, though no less significant, come partly from the
improved resource utilization. The use of plutonium as a reactor
fuel for electric power production would free the finite resources
of fossil fuels for their optimum use, thus assuring the domestic
-------
335
availability of fuel for electric power production for the long
term. A mature LMFBR industry together with the non-breeders can
generate sufficient fissile material for the nuclear industry to
be able to use stockpiled depleted uranium for hundreds of years
as the sole source of fertile fuel material. A premium market
would be established for the plutonium produced by LWRs . There
would also be the potential for substituting electricity for
fossil fuels in energy- intensive applications.
Other indirect benefits of note are in the cumulative health and
safety effects for both occupational and public groups. Major
improvements in occupational health and safety arise from the
fact that the LMFBR system does not have associated with it the
mining of uranium and replaces fossil plants burning coal. Timely
introduction of the breeder could reduce occupational accident fatalities
by 3000 persons through year 2020 (and an additional 2000 persons after
2020 due to plants then in operation). In contrast the use of coal
instead of nuclear fuel would lead to an additional 51,000 occupational
fatalities and 27,000 more public fatalities due to associated fuel
transportation accidents.
These are but a few of the conclusions from the extensive study
soon to be published, which will be available to the EPA.
-------
336 -59-
2. Applications Using Plutonium
As has already been stated, plutonium is a by-product of the reactors
built, under construction and planned by the electric utility industry,
both LWRs and High Temperature Gas-Cooled Reactors (HTGRs). Plutonium
now is being considered as a potential fuel for recycling in the LWR
reactors and as a fuel for the breeder. The AEC Directorate of Licensing
has prepared a draft generic environmental statement for the use of
recycle plutonium in light water-cooled reactors (GESMO - WASH-1327,
August 1974). Starting on page VIII-65 of "GESMO" there is a discussion
of the dollar value of plutonium as a reactor fuel for recycling. Using
the assumptions stated, plutonium has a near-term value of about $11.00
per gram fissile. Since this value is tied in to the cost of enriched
*
uranium, the value continues to rise to about $16.50/gram fissile plutonium
in 1995. As a breeder reactor fuel the value is expected to be considerably
higher. These are the prospective values shown in GESMO:
Projected Plutonium Value*
($/gm fissile plutonium)
Year Pu Value
1975 9.90
1980 11.75
1985 14.89
1990 15.81
1995 16.50
*if recycled promptly in LWR's.
To make the assumed value more meaningful one may look at the quantity of
plutonium that will be produced by the commercial reactors and that can be
-------
- 60 -
reused as reactor fuel. AEC's publication, "Nuclear Power Growth 1974-
2000" (WASH-1139 (74), February 1974) projects 4 cases. Case D, one of
the more conservative cases, assumes a general reduction in the growth of
electricity use and some improvement over recent experiences in nuclear
plant construction and regulation. Under these assumptions, Case D fore-
casts the following nuclear generating capacity in thousands of MW:
Year MW x IQ3 Year MW x 1Q3
1975 - 47.3 1990 - 475
1980 - 102.1 1995 - 760
1985 - 250.0 2000 - 1090
Table 3 taken from WASH-1139 (74), shows the fissile plutonium recovery and
utilization in the U.S. using Case D assumptions.
As shown^in Table3, the total plutonium recovered by the year 1995 would
aggregate to about .86 million Kg. Assuming a value of $l6.50/g in
1995 (according to GESMO) this inventory would be worth about $14.2
billion if'it were to be used in recycling, and potentially more as a
breeder fuel. Considering the plutonium inventories and their prospective
values, it would appear that we are already in a plutonium economy
3. Control Technology - Identification of Source Terms
In the LWR and HTGR fuel cycle, plutonium is present in the irradiated or
spent fuel. It is stored for a cooling period and then shipped in shielded
containers to a reprocessor for the recovery of plutonium and uraniunrr
I/ Environmental Statements have been prepared by Directorates of Licensing
•nd Regulatory Standards, USAEC.
337
-------
338
- 61 -
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In the IMFBR fuel cycle, plutonium and uranium bearing materials would be
combined at the fuel fabrication plant for use in the reactor. After
cooling, the irradiated fuel would be shipped in specially built containers
to the reprocessing plant. The separated fission products would be
2/
solidified and eventually shipped to a waste storage facility-?- and the
plutonium would be recycled as D4FBR fuel. A summary of materials and
quantities shipped for a 1000 MW IMFBR is shown in Table 4.
WASH-1539, Draft Environmental Statement" Management of Commercial High
Level and Transuranium Contaminated Radioactive Waste" September, 1974.
-------
340
- 63 -
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- 64 -
The estimated releases of alpha-emitting transuranic elements from normal
operations of the LMFBR fuel cycle are summarized in Table 5, The principal
airborne release is from the fuel reprocessing plant, totaling 0,36 tnCi per
1000 MWe-year. Other airborne releases are small by comparison. Liquid
transuranic effluents are assumed to occur only for the fuel fabrication
plant and are estimated at 0.05 mCi per 1000 MW-year.
The estimated population dose from alpha-emitters expected from operation of
the LMFBR fuel cycle is shown in Table 6. The estimated man-rem exposure
from LMFBR transuranic releases is shown in Table 7.
In addition to normal operational experience various accident situations were
postulated in developing the environmental impact statement for the LMFBR
program. Estimated releases of transuranic elements for major accident categories
are summarized in Table 8 which shows only those quantities of material esti-^ted
to pass all containment barriers which have been designed into the system.
The total plutonium released annually due to postulated transportation accidents
would average less than 10~ Ci per year associated with the operation of a
1000 Mw LMFBR.
-------
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- 67 -
Table 6
ALPHA-EMITTING RADIOISOTQPES IM THE POPULATION
OF THE UNITED STATES
Population Dose frcn
Amount of Alpha Alpha Emitters in U.S.
Emitters in Population (r-sn-re-'.s/
U.S. Population 70 year lifosnii)
Source (curies) BoneLung
Natural Radioactivity > lO^a > 7 x 108a > 7 x 108a
1000-MVJe-year LKFBR < 10'^ < 30 b < 4 b
8Source: Ionizing Radiation; Level and Effects, Vol. 1, "Levels," United
.Nations, t!ew YorK, i9/T]
DSee Table 4.7-2
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348
The development of reactor technology that would be reliable and safe and
reduce radioactive effluents including the transuranics, to levels that are
as low as practicable has been one of the concerns of the Division of Reactor
Research and Development from the beginning. One example is a current research
and development program to further reduce the effluents expected in the
reprocessing of IWFBR fuels to meet as low as practicable guides. This
concern for public safety from man-made sources of radiation has been a
feature of the fuels program, the engineering and components development
program and is a major concern of the reactor safety activity of the division,
as well as the statutory requirement of the AEC.
-------
349
.SDU11C1I. 'm&.l-
Tlie principal environmental contaminant will be weapons plutonium.
Initially, the major alpha source following a \vc;rj)ons plutonium release
incident would be 239-Plutoni urn. After a decay-growth period, then
would be added 241-Americium at. a substantial level relative to the
239- Fu level.
The amounts of plutonium involved in the U. S. weapons program are
necessarily classified. As an unclassified approximation it can be
stated that yearly plutoniun processing is on the order of 100,000
Curies .
The only reason for U. S. weapon plutonium to enter the environment
would be from accidental circumstances. Historically, the AI-C's acci-
dental releases have taken place during production. Most, pluloniuni
fires are fully contained within the production facility; however, plu-
toniu-n contamination has escaped in fractional curie amounts during one
or possibly two fires. Contciiinr.at ion in amounts from 10 to 100 Curies
escaped in a waste spill from rusted waste storage drums. Improved
metho'Js and facilities make the possibility of these types of release
highly improbable. Based on accident history, releases of trrmsurarn r
contamination from tli-c AFC ' s weapon program total less than 100 Ciu i r i. .
Future accident release potentials from the weapons program arc con-
servatively estimated at 1 Curie per year for five years lowered to a
small fraction of a Curie per year after 1980 due to better facilities
and in-proved performance. Future releases from routine operations of
the weapons program are estimated at 0.01 Curies per year.
While the U. S. no longer conducts atmospheric testing of nuclear weapons,
foreign atmospheric testing and other foreign nuclear weapons operations
might continue to contribute 500 to 5,000 Curies per year until there is
a complete stop to atmospheric testing.
-------
350 - 73 -
COSTS OF PLUTONIUM FACILITY IMPROVMENTS
Expenditures for fire safety and operating conditions improvement in
Plutonium facilities following the fire at Rocky Flats have been
greater than $24-0 million. Major items are tabulated below:
1. Rocky Flats Plant - $155 million
a. New Plutonium Recovery and Waste Treatment Facility
b. Filter Plenum Improvements, Various Manufacturing
Buildings (four buildings - two tunnels)
c. Liquid Plutonium Waste Treatment Facility Improvements
(Building 77^)
d. Inerting Hazardous Gloveboxes, Various Manufacturing
Buildings
2. Los Alamos Scientific Laboratory - $75 million
New plutonium processing facilities and improved fire pro-
tection.
3. Pantex Plant - $1.7 million
Mainly fire protection for production facilities.
4. Mound Laboratory - $1.6 million
Fire protection and fire detection in gloveboxes.
-------
-74- 351
RADIOACTIVE MATERIAL SPREAD BY WEAPONS FIRE
An accident occurred at McGuire Air Force Base in 1960 in which
a missile containing a nuclear weapon burned. Certain aspects of the
physical situation at McGuire would probably be pertinent to many weapon
fire circumstances: (1) a weapon containing plutonium and explosives
was involved, (2) the weapon was housed in an enclosed structure, (3)
water was used to fight the fire, and the fire occurred in the presence
of quantities of jet fuel. No HE detonation took place.
The explosive burned along with the jet fuel with an intense heat for
nearly an hour. The plutonium became melted and much of it puddled
under the burned out missile. No criticality problems occurred. The
detectable plutonium spread was mostly limited to the area covered by
smoke and water from fire fighting efforts. Environmental monitoring
conducted on the day after the accident showed almost no contamination
scatter. Zero ground contamination was found beyond 100 feet from the
accident location. Some close-in contamination was found; evidently
this was associated with fire-fighting water. No air contamination
was detected.
While the cost due to decontamination and loss of the weapon was high,
the overall magnitude of the accident was less than that which might have
resulted from a one-point detonation and caused no serious off-site
effects. Under these or similar circumstances, the off-site effects of
this type of accident at a weapons maintenance facility would probably
be much less severe than those for a one-point detonation.
-------
352
- 75 -
WEAPON RADIOACTIVITY SPREAD BY DETONATION IMPACT
On January 17, 1966, a B-52 aircraft carrying four nuclear bombs collided
with a KC-135 tanker over Palomares, Spain, during refueling operations.
Four bombs broke free in the crash as the disabled aircraft plummeted hear
the village. One fell in a steep bank of soft earth and did not detonate.
One fell into the sea and was later recovered. However, the HE components
of two weapons did detonate upon impact; one in low mountains and the other
on land used for agriculture. The wind velocity at the impact site was
approximately 30 knots at the time of the impact and the area contaminated
by plutonium from the detonated weapons was long and narrow. The area con-
taminated from 3.2 to 32 |j,Ci/m was slightly over one-half mile long and
one-sixteenth of a mile wide, with plutonium detectable to a distance of
approximately two miles.
As mentioned above, the high explosives in two of the weapons detonated
on impact. The quantity of plutonium involved in these weapons remains
classified. Evidentially, much of the plutonium involved in these detona-
tions was converted into a fine, oxide and was dispersed by the 30 knots
wind which prevailed at the time of the accident. The Air Force survey
showed that the 32 pCi/m2 level covered something over five acres with an
additional 41 acres contaminated to more than about 3.2 microcuries per
square meter. An additional 500 acres were found to be contaminated to
greater than 0.32 )j,Ci/m2.
The Air Force did careful appraisals to learn the whereabouts of all radio-
active material and radioactive contamination following the accident.
Most of the aircraft wreckage was found to be uncontaminated or to have
negligible contamination. All of the wreckage with slight contamination
was gathered and disposed of by dumping in deep, remote Atlantic waters.
More contaminated wreckage was picked up, packaged, and transported to
the United States for disposal.
No plutonium or tritium contamination was found in the sea water at any
time following the accident nor was any tritium found at the impact sites
or anywhere in the Palomares area higher than background.
Shortly after the accident, United States experts met with officials from
the Spanish Government to advise and assist Spain in handling this con-
taminating accident, and to decide upon criteria for disposal of contami- „
nated soil. It was agreed that soils contaminated with more than 32 u-Ci/m
would have the top 10 centimeters (four inches) removed for disposal in the
United States. Areas with less contamination (3.2 to 32 u-Ci/m2) would be
plowed to a depth of about 30 centimeters.
-------
-76- 353
Based on the agreement reached with Spain on the decontamination process
the top four inches of soil for the area which had been contaminated at
greater than 32 |j,Ci/m were removed from approximately 5.4 acres and
placed in drums for shipment to a United States storage site; approximately
550 additional acres which had been contaminated to less than 32 ^Ci/m^
were plowed to a depth of about 30 centimeters.
While it had been agreed to plow areas having contamination levels greater
than 32 (j,Ci/m2, in the actual field operation areas plowed included all
down to about 3.2 y,Ci/m2 where feasible. Crops grown on soil on the area
which had been contaminated to more than 32 \j,Ci/ra?- were also shipped to
the United States for burial, while those grown on the deep-plowed soil
in the area which had been contaminated to less than that figure were
burned at the sea shore on days when the wind was blowing toward the sea.
After the decontamination was finished, lung counts for radioactivity
were taken on the 100 villagers most likely affected and no positive
counts were found in the group. Urine samples for plutonium were negative
for 70 persons and showed only insigificant amounts for the others (0.1
to 0.2 dpm in a 24 hour sample).
In 1971, six years after the accident, there appeared to be little change
in the community from the time before the accident. Farming habits have
changed, but mostly due to other factors such as drought, flash flooding,
and economics. Followup studies show little change in exposed persons
and none is expected.
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354
- 77 -
RADIOACTIVE MATERIAL SPREAD BY AIRCRAFT CRASH
An aircraft carrying four unarmed nuclear weapons crashed on ice in the
Arctic while attempting an emergency landing necessitated by an on-board
fire. The angle of impact of the main body of the plane was about 15°.
The left wing was about 60° low, and the velocity of impact was estimated
at 500 knots or greater. At impact, it appears that the high-explosive
components of all four weapons detonated, dispersing the plutonium in
the devices into the conflagration resulting from ignition of the jet
fuel, all of which was released with high forward velocity at the instant
of impact and detonation of the weapons' high-explosive components.
The gross weight of the plane was about 1.9 x 10 kg, of which 1.0 x 10
kg (35,000 gallons) was JP-4 fuel. The perpendicular momentum vector
would be attenuated very fast by the inertia of the ice and water and
the binding and crush strength of the ice ( 30 to 40 inches thick), while
the parallel vector would undergo relatively slow attenuation, resulting
in a great forward splash of fuel and debris. This deduction was clearly
indicated by an aerial photograph of the crash site, showing a long
patch of black discolored ice extending away from the aircraft's impact
point (See figure).
At impact, there was a large explosion and intense fire. The fire
continued to burn for at least 20 minutes. Actual measurements of the
cloud showed a height of approximately 2400 feet and a length of about
-------
- 78 -
355
380mg/m*
112
SURFACE WIND DIRECTION
PHASE 1,24 JAN68 AND PHASE D, 28JAN6
SURFACE WIND DIRECTION
ON2IJAN68
Plutonium contamination levels observed.
O O O 000 O
Ic* cor* sample locations.
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356
- 79 -
2200 feet. At the earliest possible time, the crash site was monitored
for occurrence of nuclear criticality. Absolutely no evidence was
obtained of any nuclear yield, limiting the problem to one of contamina-
tion of the broken ice in the impact area and the surface of the packed
snow by plutonium, tritium, uranium, plane debris, and jet fuel.
The plutonium in the accident was converted largely to oxides by the
explosion and fire. The plutonium oxide was dispersed as fine insoluble
particles (from fractions of a micron to several microns in diameter).
Plutonium oxide is notoriously insoluble; its solubility in sea water at
20°C is only 20 micrograms Qug) per liter. Particles of plutonium oxide
were impinged into all bomb and plane surfaces struck by the high-explosive
shock wave, entrained and carried forward in the splashing fuel, blown
into the crushed ice at the impact point, and carried aloft in the smoke
plume along with the combustion products of the burning fuel.
At the time of the crash, there was a 6-knot wind blowing from slightly
east of north to slightly west of south. There was a stable inversion at
approximately 2400 feet altitude and no turbulence. This stable condition
persisted for several hours after the crash. Three days after the crash,
a surface wind of about 25 knots (with gusts up to 45 knots) persisted
for approximately 12 hours. Four days later, a similar storm occurred
which persisted for about 24 hours. These winds blew from southeast to
northwest, spreading some surface contamination in the downwind direction.
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~80~ 357
TECHNICAL INFORMATION
Following the accident, certain technical information was obtained,
including: amount, distribution, particle size, ir.d mode of fixa-
tion of plutonium in the crushed and refrozen ice in the impact area;
the amount and distribution of plutonium contamination remaining on
the surface; particle size, depth, and degree or mode of fixation of
plutonium in the surface crust; tenacity of fixation of plutonium to
the metal debris of the aircraft in the event large, highly-contaminated
pieces went through the ice; monitoring of the bottom end of ice core
samples taken around the impact area in the event large pools of con-
taminated jet fuel had been trapped beneath the unbroken ice; and
sampling and analyzing snow surfaces along nearby shorelines.
Surface Distribution of Plutonium
It appears certain that a large fraction of the fine debris from the
disintegrating aircraft and the plutonium oxide from the weapons were
entrained in the large amount of JP-4 fuel released and projected forward
by the impact and detonation of the weapons' high-explosive components.
When the ignited fuel dropped back to the surface of the snow, it con-
tinued to burn until oxygen and temperature dropped below combustion
levels. Extinction of the fire left a large quantity of unburned fuel,
particularly in the blackened crust, some of which percolated down into
the white snow pack beneath. The fuel that went below the
blackened zone, however, carried little or no plutonium with it. From
1 to 40 percent of j et fuel on-board may remain unburned at the crash
site, depending on the porosity and other characteristics of the surface
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358 -si-
over which the fuel is spread. Packed snow would appear to constitute
a porous surface. In this incident, estimation of the jet fuel in
random samples of the blackened crust suggests that about 18 percent
4
(1.9 x 10 kg, 6500 gals.) of the fuel remained unburned.
Microscopic and autoradiographic examination of solids filtered from
melted samples of blackened crust showed plutonium oxide particles
frequently associated with small fragments of debris of all kinds (metal,
glass, and nylon fibers, plastic, rubber, flecks of paint, etc.).
The significance of these observations, of course, has to do with the
ultimate distribution of the plutonium in the event large amounts of the
blackened crust were allowed to break up with the ice and melt. The
fact that, large amounts of jet fuel are involved, in which the plutonium
associated with low specific gravity debris may float, could result in
contamination of the shore line during the summer season.
Plutonium Surface Deposition from Monitoring Results
Large-area monitoring was accomplished by running two radial grids, and
the immediate vicinity of the crash site was monitored according to a
rectangular grid (50-foot intervals). On another occasion the crash
site was monitored at 50-foot intervals along the long axis of the
blackened pattern and along three diagonals (readings at 25-foot intervals),
one on each end and one near the middle. The counts per minute readings
along each grid line and radial were plotted and fitted with smooth lines,
from which interpolations were taken for contour plotting using the com-
bined data. The contour readings were converted to milligrams (ing) of
239 2
Pu per m by an instrument calibration factor (determined both in the
-------
-82- 359
laboratory and the field) adjusted by x-ray absorption factors determined
through correlations between field readings and laboratory analysis of
crust samples representative of the principal contour areas. Integral
areas within the contours were determined by planimetry. Total amounts
of plutonium were then estimated by integrating the surface concentration
of plutonium as a function of area. The plutonium values obtained are
probably good to - 20 percent out to the edge of the blackened crust
2
area, which corresponds roughly with the 0.9-mg/m contamination contour.
This information indicates 3150 - 630 g of plutonium on the surface, of
which about 99 percent was in the blackened area and would be removed by
removing the full thickness of the blackened crust. Assuming removal of
crust and packed snow to an average depth of 4 inches, the volume of
3 6
material removed would be 6,000 m (1.6 x 10 gallons). Assuming further
that the volume ratio of packed snow to water is approximately 5.0, this
would constitute 3.1 x 10 gallons of water, which would contain between
2,500 and 3,700 g of plutonium.
Plutonium Particle Size in Crusted Area
The diameters of plutonium oxide particles and the inert particles to
which the plutonium oxide particles were frequently attached were measured
in two blackened crust samples using a photomicrographic-autoradiographic
technique.
The average plutonium oxide particle count median diameter (CMD) was about
2 microns with a standard deviation (a ) of approximately 1.7. The
O
average calculated mass median diameter (HMD) was about 4 microns. The
HMD of the inert particles with which the plutonium was frequently
associated appeared to be 4 to 5 times larger than the plutonium particles
themselves.
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- 83 -
Lavation of Plutonium from Metal Debris
In order to learn how contaminated metal debris might behave after it
reached sea water, pieces of metal varying in weight from 10 to 120 g,
which had been recovered from the crash site, were subjected to the
washing action of sea water, and the removed activity was determined.
Total removal after 41 hours of washing varied from 23 to 89 percent.
The rates of removal were different for each sample. All lavation
curves, however, tended to level off with time. One might expect the
rates of lavation and total amounts of plutonium removed to vary from
sample to sample, depending on the velocity at which the plutonium
oxide was impinged and on the hardness and nature of the surface against
which it was blown.
Amount, Distmbution, and Nature of Plutonium Contamination in and
Under the Ice in Impact Area
To investigate the distribution of plutonium in and below the ice, a
total of 182 core samples (7.5 cm in diameter) were taken. The plu-
tonium activity in the cores was usually segregated into one or two
bands associated with blackened material. Some cores showed a single
band of activity, ranging from about 5 to 30 cm in thickness. This
band was usually near the top, but in a few cases (about 18 percent of
the samples in the crushed ice area) it was near the bottom, indicating
that an occasional ice cake had been contaminated and inverted. Some
cores showed both top and bottom bands of blackened activity. The
bands were usually horizontal but were occasionally tipped at a significant
angle with respect to the core axis.
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- 84 -
361
Nature or Form of Fixation of the Plutonium
Differential analysis of the plutonium within the cores indicated that
about 85 percent (range 75 to 95 percent) was associated with large
fragments of material which settled out almost immediately when the
cores were melted. Microscopic examination showed the plutonium assoc-
iated with fragments of fiberglass, rubber, plastic, metal, paint, etc.
There was no JP-4 fuel floating on the surface but only a thin film of
fine carbonized material. The remainder of the plutonium was retained
on the surface associated with this carbonized film. Only about 1 per-
cent was suspended through the water phase as very fine particles.
This rapid settling of most of the plutonium decreases greatly the
possibility of shoreline contamination from floating debris when the
ice melLs.
Amount and Spatial Distribution of the Plutonium
As would be expected from the mode of dispersal, no plutonium was found
in or on the bottom 01 the ice except in the immediate vicinity of the
primary impact point where the ice was drastically broken, displaced,
and refrozen.
The only significant plutonium contamination in the impact area was con-
fined to the vicinity of the point of primary impact where the ice had
been severely crushed and broken.
The observed plutonium distribution pattern in this area was highly
erratic and suggested a highly segregated pattern probably related to
reorientation of blocks of ice displaced at the moment of impact and
detonation of the weapons' high-explosive components.
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362
- 85 -
Plutonium Contamination of Land Areas
The amount of plutonium accounted for on the surface within the contours
and in the broken ice at the primary point of impact is lass that the
total inventory of the four nuclear weapons. The remainder of the plu-
tonium was removed with the salvaged aircraft debris and carried up in
smoke plume, which had a visible height of about 2400 feet and a length
of about 2200 feet. The plutonium carried up in the cloud with fine
particles of debris and combustion products of the fuel. The meteor-
ological conditions persisting at crash time and for several hours
thereafter caused wide dispersion in a southerly direction. Undoubtedly,
the substance of the cloud and the accompanying plutonium traveled
hundreds of miles and settled out over a vast area, producing extremely
low surface plutonium levels. The amount of plutonium involved in this
4
long-range distribution pattern and associated with salvaged aircraft
debris will never be known and can never be estimated perhaps to better
than an order of magnitude. However, the low-level surface contamination
was measured on land masses in the near vicinity of the crash site.
Plutonium analyses of these samples showed contamination levels that were
insignificant with respect to producing any risk either to the inhabitants
or to their ecology.
Summary
Complete plutonium accountability estimates are only approximate and
some of that information must necessarily remain classified. However,
it can be estimated that only a small percent of the total plutonium
involved in the accident escaped as an airborne aerosol for distribution
away from the local area of the accident. The plutonium was distributed
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- 86 -
over a relatively small patch of ice about 100 meters wide by 700 meters
long where it attached to the surface ice and snow. The balance of the
plutonium was attached to aircraft and bomb fragments scattered about
the crash location.
After the accident, independent scientists concluded that the amount
and distribution of plutonium in the area after the accident was such
that it could not be of significance to the health of inhabitants*(as
close as about 10 kilometers).
363
*Even so, all the contamination that was reasonably accessible on the
ice was removed so that the amount of remaining contamination was sub-
stantially reduced.
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364
Dr. Mills: Thank you, Dr. Yoder.
I have a few comments initially.
When you speak of routine emissions continuing at the present
rate, are you talking about a constant amount of material or are
you taking into account the growth of the industry?
Dr. Yoder: We are looking at the growth and what we are
projecting with the data I presented and the trend that we antici-
pate with regard to improvements in our facilities and techniques,
I think we can conservatively project that those quantities may be
what would be added to the environment.
Dr. Mills: Does that include some indication of what new
technology you expect to be in existence by the year 2000?
Does it include some anticipation of new technology that
might come into existence?
Dr. Yoder: No. Just current technology.
Dr. Mills: But it does include the projected growth?
Dr. Yoder: Yes. Of AEC operations. My comments are
directed to AEC, government owned contractor operated facilities
and operations.
Dr. Mills: I see. You are not talking about commercial
nuclear power plants?
Dr. Yoder: No.
Dr. Mills: Could you indicate from the standpoint of the loss
in the inventory of plutonium; that is, the amount that is produced
and the amount of handling, would you even like to guess as to what
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365
a ballpark figure might be as to that released fraction?
Dr. Yoder: The difference between what is produced and what
is released?
Dr. Mills: One would expect to find in the environment.
Dr. Yoder: I do not believe I would like to take a guess on
that one. I do not know anyone who has the answer to that, at least
as I understand the question.
Dr. Mills: How do you utilize, then, the information from
the accidental releases? That is, one makes a determination of
what the developments are. How do you consider these releases in
the future assessment of plutonium in the environment?
Dr. Yoder: We are trying to prevent all accidental releases
and making substantial progress in containing in facility (building)
releases within the facility itself.
I have limited my discussions to routine releases.
Dr, Wrenn will be discussing radioactivity around sites. I would
hesitate to answer all questions with regard to accidental environ-
mental situations. But I think he is going to summarize this data
for you.
Dr. Mills: On page 4, there is a matter of clarification. In the
middle of the page, it reads: "Other indirect benefits of note are in
the cumulative health and safety effects for both occupational and
public groups."
Would you expand on that?
Dr. Yoder: Yes. As I pointed out, this is a distillation of a
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366
number of pieces of information. Perhaps my distillation went a
little too far.
The environmental statement discussed the activity associated
with mining of coal, transportation of coal, and other associated
options. When one compares the projected impact of the plutonium
LMFBR versus these, I think that there was a clear benefit for the
working population as well as the general public.
Dr. Mills: Dr. Garner?
Dr. Garner: I do not really have any serious questions. I was
concerned to see that you stated there were 13 kilograms of plutonium.
Are they free or encapsulated?
Dr. Yoder: They are encapsulated.
Dr. Garner: That is all.
Dr. Mills: Dr. Radford?
Dr. Radford: I have a few questions, Bob.
When you talk about plutonium, which plutonium isotopes are you
talking about?
Dr. Yoder: I include the isotopes 239, 240, 241, when I refer to
plutonium. I speak of plutonium 238 separately through the paper; 1
have tried to specifically identify that.
Dr. Radford: How is plutonium 238 separated from plutonium 239?
Dr. Yoder: How is it separated?
Dr. Radford: In these commercial applications which are using
specifically plutonium 238 and, I assume', no plutonium 239, how do
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367
they get the plutonium 238 away from it? Or do they manufacture it
separately?
Dr. Yoder: I would like to ask Ray Moore who is a specialist in
this area, to answer.
Mr. Moore: In producing the plutonium-238, we irradiate
neptunium. Then we make a separation of the neptunium from
plutonium-238. There is no separation of isotopes. Therefore, the
plutonium-238 will contain some of the heavier isotopes of plutonium.
Dr. Radford: In other words, all your discussion pertaining to
238 inventories in commercial operations is because it is made
specifically for that, and really does not have to do with isotope
separation, while it is uses up a little bit of neptunium-Ok, well,
now you have heard a little discussion earlier about which isotopes
we are talking about here.
Correct me if I am wrong. Is it not correct that it is
predominantly plutonium 238 that we are talking about, if you look
at either the production rate of a breeder reactor fuel or the canyon
stock fuel that you get, in curies not in grams now, but in curies
amounts, you get more plutonium 238 than you get plutonium 239?
Dr. Yoder: I would like to ask Dr. Ed Sinclair to answer that,
since he is a breeder reactor expert.
Dr. Sinclair: Dr. Radford, the material that Dr. Yoder has been
talking about is material produced in the AEG complex. It is what we
call production plutonium. It contains very small quantities of
plutonium-238. It is largely plutonium 239.
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368
We have calculated the plutonium 238 content of equilibrium
plutonium from Liquid Metal Fast Breeder cycle. It will be about
50 percent of the alpha activity on an activity basis, or on the
order of one percent of the isotopes on a mass basis.
Dr. Radford: The Liquid Metal Fast Breeder reactor. How about
the garden variety light water currently operating?
Dr. Sinclair: That has higher plutonium 238 content, about two
percent.
Dr. Radford: So that would be about 3/4 of the activity?
Dr. Sinclair: In initial fueling, yes, sir. But after equilib-
rium, it will be reduced.
Dr. Radford: Then the implication in terms of curie activity
anyway would be quite different from a civilian nuclear power program,
in the AEC facility. Is that correct?
Dr. Sinclair: Very much so.
Dr. Radford: That is what I wanted to get at on that one. So
that would also account for the fact, Dr. Yoder, I believe, that the
importance of, say, curium or americium of some of the other isotopes
is much less in the AEC program than it would be for your power program.
How, I am a little confused as to what you estimate the AEC releases
will be, either .1 curie per year or -
Dr. Yoder: If you look at the graph of AEC release, you will find
that releases are below .1 curie per year with a few exceptions in the
past.
We are trying to project those, and, since we are below that already,
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369
we will be a little comfortable and project .1 curie per year.
Dr. Radford: If a substantial part of that were airborne in the
form of small particles, that would be a lot of particles, right?
Dr. Yoder: Yes.
Dr. Radford: Because each particle may contain -
Dr. Yoder: It depends on how you want to specify particles size.
You can calculate very easily the number of particles.
Dr. Radford: You mentioned that AEC began its off site montior-
ing program in 1970. Is that correct?
Dr. Yoder: No. The program in 1970 was to improve our monitoring
program to where we had a very good inventory, a much better inventory
of the plutonium and other radioactive materials in the environment
around our plants.
This program has been going on for a number of years, but in 1970
we made a concerted effort to continue to reduce the emissions through
several mechanisms, one of which was an enhanced environmental sampling
program and documentation on all releases at AEC plants-more specific
documentation.
Dr. Radford: With regard to the Rocky Flats fire, did the AEC
undertake environmental surveys after that fire?
Dr. Yoder: Yes, the Health and Safety Laboratory, U.S. AEC, has
done environmental sampling around Rocky Flats.
Dr. Radford: How far away?
Dr. Yoder: Ed Hardy?
Mr. Hardy: Dr. Radford, the extent of our environmental program
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370
around Rocky Flats consisted of taking soil samples as to a measure of
the integrated deposition of intially airborne materials that blew off
the site.
We took these samples out to about 30 miles east of the plant, and
in some directions, north and south as well, we were able to isopleth
these concentrations and inventory the total amount that had been
dispersed from the plant site.
Dr. Radford: When was the work done?
Mr. Hardy: This work was done in February, 1970.
Dr. Radford: Are your data consistent with those of Poet and
Martel?
Mr. Hardy: Dr. Poet and Dr. Martel did not inventory the entire
amount of plutonium that had dispersed from the plant. What they did
was to announce that there had been plutonium offsite.
Dr. Radford: They did present isopleths to them, didn't they?
Mr, Hardy: Not that I am aware.
Dr. Radford: You do not know whether your results agree with
theirs or not?
Mr. Hardy: Where we had been able to compare sites that were
closeby, there seems to be no difference in our data.
Dr. Radford: Were your results published in the open literature?
Mr. Hardy: Yes, sir. They were.
Dr. Radford: Where?
Mr. Hardy: In the Health Physics journal and also in the Health
and Safety Laboratory reports.
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371
Dr. Radford: When did that publication appear?
Mr. Hardy: The Health and Safety Laboratory report appeared in
August of 1970; the Health Physics article appeared, I think, last
December. (Added note: the article appeared in the January, 1974
issue of Health Physics.)
Dr. Radford: Turning to the Mound Laboratory releases, did the
AEC sample the sediments in the canal or in the lake or pond or
whatever it was?
Mr. Hardy: Mound Laboratory undertook the major environmental
sampling offsite. The Atomic Energy Commission through our laboratory
did do some sediment sampling, but only as a cross check on the Mound
data.
Dr. Radford: The reason I am bringing this up is, Dr. Yoder in his
summary statement said there have been releases of plutonium and these
have been well publicized.
If one believes the press, apparently they were not well publicized
until some non AEC people reported them. Is this correct? Is this a
fair appraisal of the way in which the information was gotten out to
the public?
Mr. Hardy: I am really not qualified to answer that question
because we responded to the Rocky Flats situation at the request of the
Atomic Energy Commission headquarters, our parent organization, the
Division of Biomedical and Environmental Research.
Up to that time, we were not particularly aware that there was
a problem offsite.
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372
Dr, Radford: Is it your conclusion that there is not now a
problem offsite and was never one?
Mr. Hardy: I do not know what you mean by problem, Dr. Radford.
There is plutonium offsite from the Rocky Flats plant.
Dr. Radford: You would feel that it meets current standards,
however those are defined?
Mr. Hardy: I am not qualified to respond to that question.
(Added note: this question was discussed thoroughly at the EPA
January 10, 1975, public hearings on plutonium in Denver, Colorado.)
Dr. Mills: Dr. First?
Dr. First: Dr. Yoder, you have already stated that your estimates
of material releases apply only to AEG and AEG contractors?
Dr. Yoder: That is correct.
Dr. First: Have you also, in your calculations, made any
estimate as to what this represents as a total projected release
from AEG and non-AEC operations?
Dr. Yoder: No, I have not. I have only done it for AEC
activities.
Dr. First: We cannot put this in a proper context, then, for
total release?
Dr. Yoder: I cannot at this moment.
Dr. Liverman: Mr. Rogers will be talking in the morning about
the regulatory or non-AEC operations.
Dr. First: He will be able to answer this question?
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373
Dr. Liverman: I hope so.
Dr. First: Can you estimate what percent of cleanup is obtainable
on the basis of the experience which you related for prior accidents?
You indicated that only a very small amount of material remained.
Based on this experience and so on, can you predict what percentage
might remain if you were to have another episode of that general nature?
Dr. Yoder: Each incident has been somewhat different. If you
give me an incident, I might be able to hazard a guess on what percent-
age was cleaned up.
Dr. First: I am just trying to get some order of magnitude.
Dr. Yoder: It varies.
Dr. First: Between what and what?
Dr. Yoder: Sixty to ninety percent, perhaps, would be cleaned
up.
Dr. First: This would represent future capability, not necessarily
past?
Dr. Yoder: That is past experience.
Dr. First: Can we do better than that?
Dr. Yoder: I think so.
Dr. First: How much better, do you think?
Dr. Yoder: It is so site dependent I would hate to hazard a number
and then find out we could not do it.
Dr. First: If we had to go back to Spain again, just to pick
a name out of the hat, how much better would you be able to do the
second time around, having had the experience of the first one which
obviously was tackled?
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374
Dr. Yoder: I would prefer to give you a written answer to that
question.
Dr. First: I do not mean to push you. I just wonder so we would
have some basis.
Dr. Yoder: I would just be picking a number out of the air.
I would rather give you a well thought out evaluation than a guess.
(Added note: an answer to this question is contained in supplemental
information submitted by the AEG. See Vol. 3).
Dr. First: One last question, if I may: You have indicated there
are three areas where plutonium is being used at the present time.
One of these would be in the civilian power area, eventually if
it becomes commercial?
Dr. Yoder: Yes.
Dr. First: Would you give us any estimates of what percentage
of plutonium usage would be in the civilian power program at some
date such as 1980, 2000 or 2020?
In other words, if we did not have a civilian power program using
plutonium, would there still be a large plutonium industry?
What I am trying to do, again, is to get some idea of what the
implications of civilian power is in using plutonium, what it might
be on a total?
Dr. Yoder: I do not have an answer. I could try to give one,
perhaps, if you wish. Perhaps Mr. Rogers tomorrow will be able to shed
some light on that particular question.
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375
Dr. First: Thank you.
Dr. Mills: Dr. Taylor?
Dr. Taylor: No questions.
Dr. Mills: Dr. Yoder, there are two questions here which came
from the floor which I would like to give to you and let you respond.
In regard to the stated benefits of the breeder program, does
the EIS you referred to include the cost of the safeguards program?
If so, what dollar value is assigned to the impact on civil liberties?
Do they include this in the safeguard program? If so, what
dollar value is assigned to the impact on civil liberties?
Dr. Yoder: Dr. Sinclair.
Dr. Sinclair: I do not believe any value has been assigned
to it because no one knows how to.
Dr. Mills: A ten percent financial benefit was stated for the
breeder program. Is this benefit at the usual discount rate when
applied to the capital cost, or must a special discount rate, as in
the draft EIS, be needed to show the benefit?
Dr. Sinclair: I do not recall a 10 percent financial benefit.
That term is meaningless to me. Ten percent discount perhaps was
used as one of several cases analyzed.
That is the discount rate at which the extrapolated dollar
benefits are brought back to present worth. The answer is, yes, with
the 10 percent discount rate, the benefits are still substantial.
That is, the ratio of the cost of the program to the accrued benefits,
even after a 10 percent discount rate is applied remain substantial.
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376
Dr. Mills: I think it had reference, as Dr. Radford has pointed
out, on page 4, the top of the page, the second sentence.
Dr. Sinclair: That has to do with the capital requirements. The
capital requirements of the electric utility industry have been
estimated with and without the breeder.
The breeder is expected to be somewhat more capital intensive
than non-breeding competitors such as light-water reactors; obviously
more capital intensive than fossil fuel plants.
Nevertheless, it does offset the need for developing uranium mines,
uranium milling, and it does offset the need for additional gaseous
diffusion capacity.
These savings in capital otherwise would be lost if the breeder
were not present and they would be greater than the additional capital
cost estimated for the breeder.
Dr. Mills: Thank you very much, Dr. Yoder.
The next topic is "Environmental Levels" and Dr. Ed Wrenn and
Dr. Bennett.
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- 89 -
377
ENVIRONMENTAL LEVELS OF PLUTONIUM AND THE TRANSPLUTONIUM ELEMENTS
by McDonald E. Wrenn, Ph.D.
U. S. Atomic Energy Commission
Division of Biomedical and Environmental Research
part of the AEC presentation at the
EPA Plutonium Standards Hearings
Washington, D. C., December 10-11, 1974
Introduction
My name is McDonald E. Wrenn. I am a member of the biomedical programs
staff of the Division of Biomedical and Environmental Research of the United
States Atomic Energy Commission. This testimony was assembled with the
assistance of the staff of the AEC Health and Safety Laboratory and the
Division of Operational Safety. Supplementary written testimony from
Edward P. Hardy, Jr. of the AEC Health and Safety Laboratory will also be
submitted for inclusion in this presentation.
Objective
This section briefly summarizes information about the locations, amounts,
origins and distributions of plutonium and transplutonium elements present
in the environment, available for environmental transport, and not readily
amenable for retrieval.
The summary and analysis presented here is drawn largely from AEC-
generated information in the public domain and selected references are
given where appropriate.
Units of measure
The total amounts of plutonium and transplutonium elements will be
expressed in curies (Ci) or kilocuries (kCl), the amounts found deposited
upon the earth's surface will be expressed in activity per unit area --
2
in millicuries per square kilometer («Ci/km ), or activity in soil in
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378
- 90 -
-12
picocuries (10 curie) per gram (pCi/g), or in the case of air in
-IS 3
femtocuries (10 curie) per cubic meter (fCi/m ). It will become
apparent that the range of activities to which we need to refer exceed
Environmental plutonium can be described in two general categories
namely that which is widely or globally distributed and that which is of
limited distribution and attributable to a local source.
Globally distributed levels of plutonium and the transplutonic elements.
Estimates of the amount of globally distributed plutonium are shown in
Table 1. There are two sources, nuclear weapons testing and space nuclear
applications. Our best estimate of the global inventory is 460,000 curies,
primarily of plutonium-239 and 240, which are both alpha emitters with half
lives of 24,000 years and 6,600 years, respectively. Most of the activity
(about 607o) is Pu-239, but the analytical techniques commonly used to measure
environmental plutonium cannot distinguish between the 239 and 240, and
accordingly the reported measurements which are sometimes expressed for
brevity as Pu-239 activity are generally the sum of the two alpha activities.
A source of Pu-238, about 17,000 curies was released when an isotopic
generator used in the space nuclear program burned up in the atmosphere in
1964.
The estimates of plutonium associated with weapons testing are essentially
those made by Harley in 1971^ updated through 1973. The estimate of globally
distributed Pu was based on the results of a soil sampling program conducted
in 1970-71 by the Health and Safety Laboratory of the AEC specifically
designed to evaluate Pu. Cores of soils were collected around the world
at Locations selected to best represent the cumulative deposition. From the
amount of Pu-239, 240 measured in each sample, the amount per unit area was
-------
- 91 -
calculated. The global inventory in Table 1 was constructed by summing the
products of the areas in given latitude bands by the areal density of
Pu-239,240 present there.
The total inventory from weapons testing was deduced from multiplying
estimates of all fission yields in testing to date by the known yield of
C 2)
Sr-90, and the measured ratio of Pu-239/Sr-90. ' This ratio has not varied
greatly over the years of weapons testing. Estimated in this manner the
total Pu-238,239,240 injected into the atmosphere in weapons testing is
approximately 440,000 curies. Other transplutonium elements are produced in
nuclear weapons testing although relative to Pu only americium (Am-241) is
significant in activity, comprising about 25% (110,000 curies) of the present
Pu alpha activity. This estimate of the quantity of Am-241 is based on the
relative activities measured in soils. A roughly equal amount of Am-241 will
build in from already extant Pu-241. An estimate of the amount of curium
(Cm-245,246) produced in all weapons tests of 90 curies has also been made
(3)
using the approach of Thomas and Perkins. This estimate, which is roughly
a thousand fold lower than the estimates for Pu and Am,was made by applying
nuclide yields determined in a single test to all tests, and is accordingly
only approximate.
The great bulk of nuclear weapons testing occurred prior to 1963 and
the accumulated deposition from this early testing on the earth's surface
is almost complete.
Figure 1 shows the yearly deposition of Pu-239 measured in New York
since 1954; 1963 was the year of peak deposition. Figure 2 shows the
cumulative deposition which is now increasing slowly. 90% of the current
cumulative deposition had occurred by the end of 1965.
379
-------
380 -92-
The present stratospheric inventory is about 17» of the amount which
has been deposited on the earth's surface and the concentration of Pu-239
in surface air sampled at Richland, Washington, since 1962, which is shown
in Figure 3 shows that the concentration of Pu-239,240 in ground level air
(expressed in disintegrations per minute per thousand standard cubic meters
of air) has decreased considerably since the early 1960's.' ' The sustained
concentrations of Pu-239,240 in ground level air during the last several years
result from nuclear weapons testing in the atmosphere by China and France.
The increased ratio of Pu-238/Pu-239 in 1966 reflects the arrival in ground
level air of Pu-238 from the SNAP-9A burnup in 1964.
Accordingly the bulk of the plutonium and transplutonium elements
produced in weapons testing have already deposited on the earth's surface.
At any given terrestrial location, the cumulative accumulation may differ
from cumulative deposition depending on the site if erosional processes are
at work which may accentuate accumulation or deplete it. In addition
the cumulative deposition also may vary with location at a given latitude
due to variation in depositional processes such as rainfall. Accordingly,
the distribution of plutonium is not uniform on the earth's surface.
Figure 4 shows how Pu-239 was distributed between the northern and
southern hemispheres, as of 1970-71. About 250 kilocuries were dispersed
in the northern hemisphere and 70 kilocuries in the southern hemisphere
making the total global inventory 320 kilocuries. For comparison, about
16 kCi had deposited on the conterminous United States and about 3 kCi
on the Australian continent which is of comparable area. The distribution
of Pu-239 with latitude should be essentially the same as for Sr-90, shown
in Figure 5. The highest deposition of Pu-239 is in the mid-latitudes of
the northern hemisphere and it falls off toward the north pole. There is
a low in the equatorial region and then a small rise in the mid-latitudes
-------
- 93 -
381
of the southern hemisphere, again dropping toward the south pole.
The total deposit of Pu-238 is about 7 percent of the Pu-239 and the
SNAP-9A debris is a major contributor, particularly in the southern hemis-
phere. The Pu-238 from the SNAP device almost tripled the global deposit
of this plutonium isotope and we know from stratospheric measurements that
it has essentially all been deposited.
2
Figure 6 shows the Pu-239 accumulation in mCi per km at various
locations in the United States. Generally the drier areas are lower than
the wet areas indicating that precipitation scavenging is an important mechanism
for bringing nuclear debris to the surface. Fallout in some western areas
is higher per unit of precipitation than in sites along the Pacific coast
or east of the Mississippi. Evidence seems to indicate that these are regions
where stratospheric debris preferentially enters the troposphere and is
deposited. Most of the values for this limited sampling program across the
U.S. vary by only a factor of 3 or 4, and within a particular constant
rainfall region the variability in deposition appears to be much smaller.
Much information about the distribution and variability of Pu-239,240
in soils can be obtained by comparison with Sr-90 and Cs-137 which have
been studied much more extensively.
For example, the vertical distribution of plutonium in soils has been
determined at a few sites; whereas the vertical distribution of Sr-90 and
Cs-137 have been studied at many. Globally deposited Pu-239,240 is
deposited initially as small particles which do not remain indefinitely on
the surface. Figure 7 shows the vertical distribution of Pu-239, Sr-90,
and Cs-137 in a sandy loam soil sample from New England. Most of the
deposited plutonium is in the top 5cm (2 inches) and its distribution is
-------
382 -94-
similar to that of Cs-137. Both nuclides can be found in measurable
concentrations down to 20 cm (8 inches) but the amount below 5 cm is only
about 20 percent of the total. Strontium-90, by comparison, is less retained
in the top soil and can be found to 30 cm (12 inches) so one can conclude
that it is migrating at a faster rate than Pu-239 or Cs-137.
Accordingly, the concentration of plutonium inferred from measurements
in surface soils will depend on the depth of the sample and the variation
of Pu-239,240 concentration with depth. The vertical distribution will
most likely change with time at varying rates in different types of soils
and different environments. The factors which influence the rate of vertical
migration are not well understood and are the subject of active investigation.
In Table 2 the widespread plutonium alpha activity is compared with
the total alpha activity from naturally occurring actinides in soil, using
the continental United States as a model and assuming that soils contain
about 1 pCi/g of both uranium and thorium. Approximately 4.4 million curies
of natural alpha emitters are present in the top 2 centimeters of soil of
which approximately 1.6 million curies are alpha emitting actinides
(Uranium and Thorium). Compared in this manner the concentration and amount
of alpha activity from Pu-238,239,240 in surface soils (the top two centi-
meters) is about 17o of the natural background actinide activity.
Representative concentrations of Pu-239 in air, soil, ocean water, and
human tissue ' ' ' are shown in Table 3, all expressed in pCi/g of
medium, with selected measurements chosen around 1971 and 1972.
The lowest concentration is found in surface air. This reflects the
transient nature of the atmospheric content. Ocean water, soil, and human
-------
- 95 -
tissue all show higher concentrations partly as a result of accumulation
of material over many years. Surface ocean water was typically an order
of magnitude higher than air but much lower than soil due to efficient
dilution to great depths. In addition there has been some removal to the
marine sediments. The concentration in human lung tissue reflects continued
accumulation from air by breathing and the relatively slow removal of material
(5)
from lung or lymph tissue (see Bennett's testimony). The highest concen-
trations are observed in surface soils. These relatively higher concentrations
result from the cumulative nature of the deposit on the surface and the very
slow downward rate of migration into the soil.
There are to my knowledge no good estimates of the total amount of
globally distributed plutonium in biota. However, this has been studied in
local ecosystems
Local Accumulations
Local accumulations of plutonium may occur in association with specific
facilities or activities. Table 4 lists the estimated local cumulative
releases and inventories in excess of 0.1 curie which are environmentally
available for a selected number of AEG and AEC contractor sites. These
estimates are drawn from cumulative measurements of liquid and gaseous
releases, evaluations of non-routine releases such as accidents, annual
routine environmental surveillance reports, and environmental measurement
programs designed to provide information on environmental inventories.
Because soil measurement programs, useful for estimating the amount in the
environment from soil measurements alone, are still in progress at
383
-------
384 -96-
most facilities, estimates of environmentally available amounts may
change as more complete information becomes available. In Table 5
the maximum off-site surface soil concentrations which have been
observed are listed. These values are drawn from the reported environ-
mental surveillance program results for individual operational facilities
and sites. ' The results of the environmental surveillance program for
all sites are reported annually in the EPA publication of Radiological
Health Data. In addition, a compendium of the results of all sites
/Q \
and facilities programs is assembled annually as an AEC report.
The sources fall in five general categories, which are nuclear
weapons testing, nuclear weapons accidents, major AEC production and
test sites, AEC contractor industrial type facilities, and purposeful
release of wastes under controlled conditions to the environment.
Nuclear weapons testing can be a source of local contamination both
surface and sub-surface. The U.S. test areas include the Nevada test
site and the pacific testing sites, Bikini and Enewetak. An extensive
9
radiological survey and evaluation has been completed for Enewetak
where concentrations in soil range from 30 to 3000 pCi/g. This
evaluation concludes that the Pu present will not seriously limit
the reinhabitation of the atoll. In fact the most limiting nuclide
in terms of dose is Sr-90.
The behavior of environmental Pu has been under study at the Nevada
Test site for many years. Early intensive studies were conducted during
and following tests, and presently intensive studies are underway to
evaluate the environmental behavior of Pu which has been in situ from
one to close to two decades. Under investigation are such aspects as
the vertical and horizontal migration of Pu and Am in soils, the factors
(10)
which affect resuspension, and the particle size of resuspended Pu. An
-------
-"- 385
inventory of material available from such testing at the Nevada Test
Site is underway but not complete. Most of the material on the surface
of the site is inside government site boundaries. Some of it is available
for transport by wind but much of it has been either weathered or treated
to minimize redistribution.
Nuclear weapons accidents near Palomares, Spain (1966), and Thule,
Greenland (1968), resulted in local environmental contamination. Extensive
decontamination was effected at each site. From the Thule accident '
it may be estimated that about 25 Ci are in marine sediments and surface
soils. The residual plutonium in Spain is being followed by the Junta de
Energia Nuclear. ' These accidents are discussed briefly in the
supplementary material provided.
There has been little offsite environmental contamination at major
AEC development, production and testing facilities, including Hanford,
Idaho, Savannah River and Oak Ridge. The amounts of materials stored in
wastes at these facilities were discussed in section B as well as releases
onsite to treatment and disposal systems such as seepage basins. Only
small portions of these have become environmentally available. This
question is treated in environmental statements being prepared for the
(9)
major AEC production and testing sites. The environmentally available
amounts (i.e., available on the surface for transport by wind) are not well
known. However, it is probable that these numbers do not exceed a few tens
of curies. For example, at Savannah River about 5 Ci has been released
to the atmosphere and surface soils, of which approximately 2 Ci is estimated
to be outside the site boundaries. However, the cumulative amounts measured
-------
386
- 98 -
2
in soil at the site boundary (1.9 mCi/km for 10 cores taken at 4 locations)
are not distinguishable from the background levels from global fallout
(1.8 mCi/km at 160 km radius, 10 cores from 3 locations).
Another category consists of industrial type facilities such as
Mound Laboratories and Rocky Flats. Pu contamination of the environment
around Rocky Flats has been reasonably well documented and is described
in a series of HASL reports published in recent years. ' ' Our best
estimate is that several curies are distributed off-site and on the order
of ten curies in surface soils on-site.
The following are examples of purposeful release of wastes to the
environment. The U.K. for many years has made it a policy to dispose
at sea of some of their intermediate level wastes which contain plutonium
and americium. Upwards of 3000 curies of & activities have been disposed
of in this manner from a pipe at Windscale into the Irish Sea; this
activity is probably half Pu and half Am. Between 1951 and 1963 the
U.S. disposed at sea of about 6400 Ci of drummed wastes described as
plutonium contaminated. In 1971-72, the European Nuclear Energy Associa-
tion disposed of a large number of 55 gallon drums of solid wastes contain-
ing an estimated 1300 curies of alpha-emitting wastes. Local releases in
foreign countries other than the examples just cited have not been
summarized here, although they may influence local radionuclide concentrations.
In summary, it may be concluded that the major transuranic activity
in the environment is composed of plutonium and americium from weapons
testing and that this material is detectable in surface soils around the
world, although their presence raises the alpha background in surface soils
-------
-99- 387
generally less than 1%. The Pu and Am activity per gram near the surface
will decrease slowly with time. Finally, local sources of plutonium
although much smaller in quantity than that from globally distributed
weapons testing fallout can result in concentrations of Pu in soil exceeding
the concentrations of the global level from weapons testing.
-------
388
- 100 -
Selected References
1. J. H. Harley, "Worldwide Plutonium Fallout from Weapons Tests," p. 13-19,
Proceedings of Environmental Plutonium Symposium IA-4756, Los Alamos,
New Mexico, 1971.
2. Testimony of Edward P. Hardy, Jr., "Worldwide Distribution of Plutonium"
3. C. W. Thomas and R. W. Perkins, "Transuranium Elements in the Atmos-
phere," BNWL-1881 UC-48, Battelle Pacific Northwest Laboratories,
presented at the ANS Meeting, Washington, D.C. 1974.
4. Testimony of Herbert L. Volchok, "Transuranic Elements in the Marine
Environment"
5. Testimony of Burton G. Bennett, "Plutonium Fallout Pathways to Man"
6. F. W. Whicker, C. A. Little, and T. F. Winsor, "Plutonium Behavior in
the Terrestrial Environs of the Rocky Flats Installation," IAEA Sym-
posium on Environmental Surveillance Around Nuclear Installations,
IAEA/SM-180/45, Warsaw, Poland, 1973.
7. Annual Reports of Environmental Surveillance at AEG Facilities and
Contractors Facilities.
8. Environmental Monitoring at Major USAEC Contractor Sites, CY 1973,
WASH-1259, 1973
9. NVO-140, "Eniwetok Radiological Survey," USAEC, Nevada Operations Office,
Las Vegas, Nevada, October, 1973.
10. NVO-142, "The Dynamics of Plutonium in Desert Environments," Nevada
Applied Ecology Group Progress Report, July 1974.
11. H. A. McClearen, "Plutonium in Soil at the Savannah River Plant,"
DPSPU 74-30-14, Second AEC Environmental Protection Conference,
Albuquerque, New Mexico, 1974.
12. P. W. Krey and E. P. Hardy, "Plutonium in Soil around the Rocky Flats
Plant," USAEC Report HASL-235, 1970.
13. P. W. Krey and B. T. Krajewski, "Plutonium Isotopic Ratios at Rocky
Flats," USAEC Report HASL-249, 1972.
14. H. L. Volchok, R. Knuth, and M. Kleinman, "Plutonium in the Neighborhood
of Rocky Flats, Colorado: Airborne Respirable Particles," USAEC
Report HASL-246.
-------
- 101 -
389
15. "USAF Nuclear Safety," AFRP 122-1, Jan/Feb/March 1970, No, 1,
Vol. 65 (Part 2) Special Edition.
16. A. Aarkog, "Proceedings of the International Symposium on
Radioecology Applied to the Protection of Man and His
Environment," pp. 1213-1218, Rome, Italy, September 1971,
(CONF 710973, EUR-4800, Vol. 1, 2).
17. "First Results from the Programme of Action Following the
Palomares Accident," E. Iranzo, Junta de Energia Nuclear -
Madrid, Spain, Symposium on Radiation Protection of the
Public in a Mass Disaster, International Radiation
Protection Association (IRPA), Interlaken 1968.
18. "Experience of an Accidental Contamination by Radioactive
Materials, Palomares, Spain (1966)," E. Ramos and E. Iranzo,
Junta de Energia Nuclear, Madrid, Spain, Second International
Civil Defense Symposium on Nuclear Radiation Hazards, Monoco,
1966.
-------
390
- 102 -
CO
-------
- 103 -
391
Figure 3. 238Pu AND 239Pu IN SURFACE AIR, 45°N
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Table 3
Representative Concentrations of Pu-239
in Various Media (Circa 1971)
Media pCi/g
Air (Richland, Washington 1971) 1 x 10~7
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Human tissue (lung - U.S. 1971) 3 x 10"4
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- 115 -
401
WORLDWIDE DISTRIBUTION OF PLUTONIUM
by Edward P. Hardy, Jr.
Health and Safety Laboratory
U. S. Atomic Energy Commission
New York, N. Y. 10014
part of the AEC presentation at the
EPA Plutonium Standards Hearings
Washington, D. C., Dec. 10-11, 1974
Introduction
It is certainly clear that plutonium contamination of the environment
on a global basis is primarily the result of atmospheric nuclear weapons
testing. There are localized areas where plutonium contamination has
occurred through accidents or inadvertent releases from nuclear facilities.
The total amounts released are on the order of curies as compared with
hundreds of thousands of curies from nuclear tests. Contamination levels
in these areas are documented and studies are being carried out to follow
the movement of plutonium through the eco-system pathways to man. For the
future, however, it is important to know how plutonium from nuclear tests
is distributed because this so-called "background" will be the baseline
against which perturbations of the environment by the escalating nuclear
industry must be assessed.
Nuclear Tests
Most of the plutonium now dispersed around the world was produced by
nuclear tests conducted through 1962. The above-ground tests carried
out by the People's Republic of China in the Northern Hemisphere and France
in the South Pacific since 1963 have contributed an additional ten percent
-------
402
(2)
to the global inventory. The principal isotopes of plutonium that have
been measured are Pu-239,240 and Pu-238. These are the isotopes that
have been produced in greatest abundance. With time, a daughter isotope -
Am-241, will become an important contributor.
SNAP-9A
Although its contribution to the plutonium radioactivity now dispersed
over the earth is relatively small it is worthwhile noting that Pu-238 was
released in the high stratosphere in April 1964 when a nuclear powered
satellite failed to achieve orbit and disintegrated. This Pu-238 has now
settled out on the earth's surface and constitutes a substantial increment
(3)
to the Pu-238 fallout from nuclear tests.
Sampling Programs
The Atomic Energy Commission has traced the dispersal of plutonium from
atmospheric tests and the SNAP-9A satellite through its sampling programs
in the stratosphere, and at ground level. I intend to review the measured
levels and show how this radioactivity has changed with time. To give some
perspective to the amount of plutonium produced, the Pu-239,240 radioactivity
is about 2 to 3 percent of the long-lived fission product Sr-90 radioactivity.
The Pu-238 radioactivity from nuclear tests is only 2 to 3 percent of the
Pu-239,240 radioactivity. From now on when I refer to Pu-239 it can be
inferred that I mean Pu-239 + Pu-240 because these two isotopes cannot be
distinguished by conventional alpha spectrometry.
Stratosphere
Figure 1 shows the amount of Pu-239 in the stratosphere as a function
of time. The unit is kilocuries and separate curves are given for the
northern and southern hemispheres. After the intensive period of testing
-------
- 117 -
403
in 1961 and 1962, the levels of Pu-239 declined with a half residence time
of 10 to 11 months. Since 1967, sporadic testing by France and the People's
Republic of China has maintained relative constant or only slightly
diminishing amounts of Pu-239 in the stratosphere up to the present time.
Figure 2 represents the amount of Pu-238 in the stratosphere from
the satellite called SNAP-9A. This was a one-time input and it is now
impossible to distinguish the level from this source against the Pu-238
(4)
from nuclear tests. The SNAP device released 17 kilocuries while the
total amount of Pu-238 that reached the stratosphere from weapons tests
was about 9 kilocuries.
Surface Air
Throughout this period of weapons testing, it is generally agreed that
human exposure to plutonium is primarily through inhalation. The surface
air concentrations of Pu-239 in New York City as illustrated in Figure 3
show that at peak level in 1963 the concentration was 1.7 femtocuries per
m or about 9 percent of the most conservative concentration guide for
populations. Recent surface air concentrations attributable primarily
to Chinese tests in the northern hemisphere are about 4 percent of this
peak level. To assess the inhalation hazard, the fraction of the total
concentration which may deposit in the nonciliated portion of the lung,
must be known. Measurements of this so-called respirable fraction indicate
that 80 - 85 percent of the Pu-239 aerosol is associated with particle
sizes that are respirable. These data refer only to plutonium from
weapons tests.
-------
404
- 118 -
Deposition
Measurements of deposited plutonium have made it possible to estimate
the total amount on the earth's surface and to determine how it is distri-
buted. A properly selected soil sample can represent the accumulated
deposit, and, based on a worldwide soil program carried out in 1970-71,
Figure 4 shows how Pu-239.is distributed between the northern and southern
hemispheres. About 250 kilocuries is dispersed in the northern hemisphere
and 70 kilocuries in the southern hemisphere making the total global inventory
320 kilocuries. For comparison, about 16 kCi has deposited on the conterminous
United States and about 3 kCi on the Australian continent which is of
comparable area. The highest deposition of Pu-239 is in the mid-latitudes
of the northern hemisphere and it falls off toward the north pole. There
is a low in the equatorial region and then a small rise in the mid-latitudes
of the southern hemisphere, again dropping toward the south pole.
The total deposit of Pu-238 is about 7 percent of the Pu-239 but the
SNAP-9A debris is a major contributor, particularly in the southern hemis-
phere (see Figure 5). The Pu-238 from the SNAP device almost tripled the
global deposit of this plutonium isotope but we know from stratospheric
measurements that it essentially all deposited.
2
Figure 6 shows how much Pu-239 in mCi per km has deposited at various
places in the United States. Generally the drier areas are lower than the
wet areas indicating that precipitation scavenging is an important mechanism
for bringing nuclear debris to the surface. Fallout in some western areas
is higher per unit of precipitation than in sites along the Pacific coast
or east of the Mississippi. Evidence seems to indicate that these are
regions where stratospheric debris preferentially enters the troposphere and
-------
- 119 -
405
is deposited. ' The extremes in Pu deposition for the stratospheric
source vary by only a factor of 3 or 4 and within a particular constant
/ o \
rainfall region, the variability in deposition is less than 15 percent.
The total deposit of plutonium in the region of Salt Lake City is about
two times higher than expected from global fallout. The excess plutonium
probably came from the high explosive detonations involving unfissioned
(9)
plutonium that were carried out at the Nevada test site in the late 1950's.
The deposition rate of Pu-239 with time can be illustrated for New
York City (see Figure 7). The pattern is similar to that for surface air,
as expected. By integrating these rate data, the total deposit is in good
agreement with the more direct measurement in soil.
Some information on the depth distribution of plutonium in soil is
available which shows that most of the deposited plutonium is in the top 5
cm (2 inches) and that its distribution is similar to that of Cs-137, the
most abundant long-lived fission product generated in nuclear tests. Both
nuclides can be found in measurable concentrations down to 20 cm (8 inches)
but the amount below 5 cm is only about 20 percent of the total. Strontium-90,
by comparison, is less retained in the top soil and can be found to 30 cm
(12 inches) so one can conclude that it is migrating at a faster rate than
plutonium or cesium.
241
Americium
It was mentioned earlier that Am-241 is a daughter of the isotope
Pu-241 which builds up with time. Knowledge of its behavior in the environ-
ment is important because its chemical properties are different from
plutonium. The few measurements that have been made of this nuclide in
fallout show that its activity level is about 25 percent of that from
-------
406
- 120 -
Pu-239. Despite elemental differences, Am-241 from global fallout shows
a depth distribution in soil similar to Pu-239 but further measurements
are needed.
Summary
Nuclear tests conducted in the atmosphere are the major sources of
plutonium contamination on a worldwide basis. About 320 kilocuries of
Pu-239 have deposited and about 4 kilocuries remaining in the stratosphere
will reach the earth's surface. Measurements are being made of air concen-
trations at ground level and the deposition rate. Inhalation is the major
route of human exposure and later testimony will be presented to show the
resulting body burden. Contamination levels in foods have also been
measured and the comparatively smaller body burden from ingestion will also
be discussed.
-------
- 121 -
407
References
1. Harley, J. H.
Worldwide Plutonium Fallout from Weapons Tests
USAEC Report, LA-4756, Los Alamos, pp. 13-17, Dec. 1971
2. Estimated from information provided by the news
media and other unclassified sources
3. Hardy, E., P. Krey and H. Volchok
Global Inventory and Distribution of Fallout Plutonium
Nature, 241, No. 5390, pp. 444-445, Feb. 16, 1973
4. Krey, P.
Atmospheric Burn-up of a Plutonium-238 Generator
Science, 158. No. 3802, pp. 769-771, Nov. 10, 1967
5. International Commission on Radiological Protection
Report of Committee II on Permissible Dose for Internal Radiation
ICRP Publication 2 (1959)
Assuming soluble plutonium with bone as the critical organ
and based on 1/30 of the occupational level for a 168 hour week
6. Volchok, H., R. Knuth and M. Kleinman
The Respirable Fraction of Sr-90, Pu-239 and Pb in Surface Air
USAEC Report HASL-278, pp. 1-36 to 1-40, January (1974)
7. Volchok, H. L.
High Fallout in the Western United States - An explanation
USAEC Report HASL-257, pp. 1-18 to 1-32, July (1972)
8. Hardy, E.
Regional Uniformity of Cumulative Radionuclide Fallout
USAEC Report HASL-288, pp. 1-2 to 1-9, January (1975)
9. Hardy, E., P. Krey and H. Volchok
Plutonium Fallout in Utah
USAEC Report HASL-257, pp. 1-95 to 1-118, July (1972)
10. Hardy, E.
Depth Distributions of Global Fallout Sr-90, Cs-137, and
Pu-239,240 in Sandy Loam Soil
USAEC Report HASL-286, pp. 1-2 to 1-10, October (1974)
-------
408
- 122 -
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-------
.05
- 123 -
FIGURE 2
STRATOSPHERIC INVENTORY OF SNAP-9A Pu-238
409
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-------
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- 124 -
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-------
415
Dr. Radford: Dr. Wrenn, what is the ordinate on Figure 3? Can
you put numbers there on the concentration?
Dr. Wrenn: The reference by Perkins does not have the numbers on
them, but the units he uses are disintegrations per minute per thousand
standard cubic meters. (Note added: the numerical values have been
added to Figure 3 which displays the information requested by
Dr. Radford.)
Dr. Radford: But he did not put numbers on his?
Dr. Wrenn: He did not have the numbers on his.
Dr. Radford: That is rather strange, to publish in a scientific
journal, a graph with no numbers on it.
Dr. Wrenn: I think his point was to point out the relative change
with time and the increase in the isotopic ratio at this particular
point.
Also, to point out the continued input from atmospheric testing,
rather than to point out the absolute values of these numbers.
Table 3 shows the average concentration of Pu-239 in air at
Richland for 1971.
Dr. First: Does Table 4 list accumulated material per site, is
that it?
Dr. Wrenn: Table 4 is a rough estimate of the amount available
per site, yes.
Dr. First: The units you have there are quantity per what, per
site?
Dr. Wrenn: Total curies per site. Roughly up to the end — Well,
-------
416
the dates on each of those are not the same, but, say, 1972 is maybe a .
good mean.
Dr. First: All right.
Dr. Wrenn: The Rocky Flats number, for example, is a little more
up to date than that.
Dr. Mills: We will hold further questions on this until we hear
from Dr. Bennett.
Dr. Parker: Dr. Wrenn, you stated you borrowed from Dr. Perkins,
a former colleague of mine at Richland.
Comments were made by the panel on the competence of Dr. Perkins
as a scientist. I happen to consider him one of the finest in the
country.
May I ask, Mr. Chairman, that you address yourself by letter to
Dr. Perkins to have him clear up the question of the graph that was
shown.
Dr. Mills: Yes, sir. Surely.
Dr. Wrenn: I would like to say that I consider Dr. Perkins highly
competent. I was talking with him last night rather late about this.
In my remarks, I certainly meant nothing to reflect improperly
on Dr. Perkins. In fact, his is one of the finest collections on long
term environmental data available.
Dr. Mills: Dr. Bennett?
Dr. Bennett: My name is Burton Bennett. I am a research scientist
at the AEC Health and Safety Laboratory in New York.
I would like to present for your consideration a brief discussion
of the "Environmental Pathways of Transuranic Elements."
-------
417
ENVIRONMENTAL PATHWAYS OF TRANSURANIC ELEMENTS
Burton G. Bennett
Health and Safety Laboratory
U. S. Atomic Energy Commission
New York, N.Y. 10014
I. GENERAL CONSIDERATIONS
Exposure of man to transuranic element contamination may occur by the
inhalation or ingestion pathways. A large number of laboratory and ecological
studies have been performed or are in progress to elucidate specific aspects
of these pathways, such as resuspension of deposited activity, plant uptake,
and physical and biological transfers in terrestrial and aquatic environ-
ments. In addition, the measurements of fallout plutonium, tracing the
course of this material in air and diet to man, provide some of the most
directly appropriate data regarding the environmental pathways.
It is generally recognized that for an initially airborne release, the
inhalation pathway is the dominant contributor to the body burden in man.
The low solubility of the transuranic elements Inhibits plant uptake and
absorption from the gastrointestinal tract and minimizes the importance
of the ingestion pathway. The physical mechanisms of transfer of activity
are thereby emphasized instead of biological accumulation mechanisms.
Dispersion of airborne radioactivity is governed by the local and
regional meteorology. For contamination which originates on the ground
surface, such as leakages or spills, resuspension could be an important
consideration. Radioactivity in air or in soil may reach plants by
deposition on plant surfaces or by root uptake. Plant uptake is governed
-------
418
- 132 -
by the isotope and soil chemistry and by the plant physiology. Disposition
of inhaled or ingested material and the biological behavior have been
studied in numerous animal study programs.
There have been a few good summaries, reviews and bibliographies of
pathway considerations, as well as applications of such data in environmental
(1-9)
statements. I could not possibly elaborate here on all of the
accumulated data. I can, at best, remind you of some of the considerations
and then present the fallout experience.
Resuspension
Resuspension is a much discussed phenomenon. Although its importance
is recognized in ground contamination situations, for initially airborne
releases, such as fallout radioactivity, resuspension has not markedly
(9)
influenced the measured concentrations in air. A very large range of
possible resuspension factors is often quoted - a range of 9 or 10 orders of
magnitude. It is Important, however, to carefully distinguish between those
values which have been suggested for hazard analyses and those values that
might reflect more realistic situations.
Measurements of resuspension have been conducted at contaminated areas
of the Nevada Test Site. Soon after contaminating events, resuspension
factors (ratios of radioactivity per unit volume of air to radioactivity
ve been
(10-12)
-4 -6 -1
per unit surface area of soil) on the -order 10 to 10 m have been
obtained, decreasing subsequently with 35 to 70 day half-times.
We are often reminded of those results, 10 to 10 . Less often, however,
are we reminded of the conditions under which they were obtained. Langham
and his co-workers set out in 1956 to measure resuspension at the Nevada
-------
-133- 419
Test Site. Having little initial success, they found it necessary to assist
the micrometeorology. They arranged to have heavy trucks roar back and forth
(IS 1
in front of the air sampler. The first value reported by Langham
7 x 10"5 m"1 is described as obtained during "extensive vehicular traffic,"
A second value, 7 x 10" m" , was derived for "dusty rural air." Langham L '
had a feeling that 10" might be more appropriate for general usage, and
Stewart also suggested that value for "quiescent conditions." In later
years, subsequent to weathering and downward movement of plutonium in soil,
values of 10" to 10" m" have been reported. ' The results for the
desert environment are admittedly not easily generalized to more usually
inhabited areas.
An important constraint in estimating a realistically applicable general
resuspension factor is the fallout experience. Values should not be so large
that when applied to the fallout deposition amounts, the measured air concen-
trations are exceeded. For fallout plutonium and as applied to natural
uranium in soil as a tracer, most reasonably assumed is a resuspension factor
to 1
(9)
-9 -1
of 10 m to be applied to accessible activity in soil (activity in top 1
cm or less).
It is recognized that a number of parameters are involved in describing
the resuspension process, including soil conditions, moisture, wind, and
vegetative cover. There may also be perturbations due to mechanical
disturbances, such as digging or traffic. Activity may also be transferred
to the body or clothing which may also lead to additional intake. Healy^6*
has discussed many of these considerations. Research efforts under way
should provide increased understanding of the resuspension phenomenon and
allow better prediction of short-term effects.
-------
420
- 134 -
Plant Uptake
A number of tracer studies have been conducted in which specific
influences of plant uptake of transuranic elements have been identified.
These factors include chemical form, solubility, oxidation state of the
radioactive element, composition and pH of the soil, and plant species.
(3)
Reviews of the various studies have recently been prepared by Price
and Francis , and Durbin has given detailed treatment primarily of the
chemical considerations involved. In Table 1, I have made a further attempt
at synthesis. Additional effort will be required to achieve completeness
and uniformity of reporting.
The laboratory "pot experiments" are limited by the sometimes unusual
growing conditions or spiking methods and often involve seedling plants in
quite short duration studies. One may worry about the extension of these
results to the edible portions of mature plants grown under field conditions.
On the other hand, the controlled experiments are better able to isolate the
factors which apply, and the data on relative uptake of several isotopes
are quite useful. The lowest values of uptake in Table 1 may reflect the
short duration of exposure. The highest values, field data from
/ ofi^
Palomares, may involve some direct contamination as well as root uptake.
The result for peeled potatoes from soil contaminated by global fallout
(22)
fits in well with the laboratory study results.
Longer term experiments have not demonstrated significant uptake changes.
(21)
Neubold ' indicated a slight increase in uptake for ryegrass in a 2 year
experiment, but the data are inconclusive., since the concentrations barely
(32)
exceeded minimum detection levels. Romney reported a 7-fold increase
-------
- 135 - 421
(23)
in 5 years, due possibly to increased root development. Buchholz
found equal or greater variations in uptake measurements over a 4 year
period, but there was no time trend.
There appear to be no isotope differences in plant uptake, either for
plutonium or curium isotopes, though the data are not extensive.
If one were to generalize on the basis of the data on hand, one might
assign plant uptake of plutonium to be 10 (pCi/g fresh wt. per pCi/g
dry soil), plus or minus an order of magnitude, with uptake of americium
and curium about 30 times greater.
Uptake from foliar deposition is being studied. Very little trans-
location of plutonium following deposition has been found in initial labora-
xper:
(22)
tory experiments, in agreement with fallout plutonium measurements of
wheat.
Ecological Studies
Ecological studies are in progress to assess the distribution of
transuranic contamination in plant and animal communities. Changes
with time and any reconcentration processes will be investigated. An im-
portant contributor of plutonium contamination of plants has been shown
to result from wind-borne activity deposited on plant surfaces. The
amounts of activity present in small mammals have not been unusual,
( (\
'
considering the exposure pathways which exist.
Aquatic Studies
The only evidence for concentrations of transuranics above surrounding
background comes from studies of aquatic environments. There, it is as
much the low retention of suspended activity in water as it is accumulations
in plant or animal organisms. Plutonium is readily removed to sediments.
-------
422 " 136 "
The highest activity levels in biota are found in marine plants, with
concentration factors as great as 1000 (pCi/kg wet wt. per pCi/1 water).
The concentration factors decrease with increasing trophic level. The
(19}
general behavior of plutonium in fresh water systems is comparable.
I have appended a summary of transuranics in the marine environment by
Herbert L. Volchok of the Health and Safety Laboratory which includes a
large literature compilation.
Biological Behavior
An excellent discussion of the entry of plutonium and other actinides
into animals and man and the biological behavior is presented in ICRP
Publication 19. Absorption from the gastrointestinal tract and entry
through intact skin and wounds are considered. The ICRP Task Group Lung
Model has been formulated to be used in determining the disposition of inhaled
material. Fractional deposition in the three lung regions is determined by
particle size. Three classes of transfer parameters, dependent primarily
on chemical form of the inhaled material, are provided to determine subsequent
movement from the lung to other organs in the body or to excretion. The
Lung Model provides a sound basis for considering inhalation intake.
Other Aspects
There are many other aspects of environmental pathways which can and
should be considered, such as mobility in soil, chelation effects on plant
uptake, wash-off from plant surfaces, and animal intake pathways with
transfer to meat and milk. Much'data on these topics is available and
more is being accumulated. Let me go on, however, to the fallout experience.
-------
References
- 137 -
423
1. Langham, W.H., "The Biological Implications of th• Transuranium Elements
for Man," Health Phys. 22, 943 (1972)
2. Bair, W..T., R.C. Thompson, "Plutonium: Biomedical Research," Science,
183. 715 (1974)
3. Price, K.R., "A Review of Transuranic Elements in Soils, Plants, a-i-f
Animals," J. of Environ. Quality 2, 62 (1973)
4. Francis, C.W., "Plutonium Mobility in Soil and Uptake in Plants: A
Review," J. of Environ. Quality 2, 67 (1973)
5. Durbin, P.W., "Transfer of Plutonium from Soil to Plants: A Review
of the Problem," Univ. of Calif. Report UCID-3689 (1974)
6. Healy, J.W., "A Proposed Interim Standard for Plutonium in Soils,"
Los Alamos Scientific Laboratory Report LA-5483-MS (1974)
7. Thompson, R.C., "Biology of the Transuranium Elements - A Bibliography,"
Battelle Pacific Northwest Lab. Report BNWL-1782 (1973)
8. Environmental Plutonium Data Base Group, "Environmental Aspects of
Plutonium and Other Elements - A Selected, Annotated Bibliography,
Oak Ridge National Lab. Report ORNL-ETS-73-21 and 74-21 (1974)
9. Environmental Statement, "Environmental Impact of the LMFBR," USAEC
Report WASH-1535, Sec. 4G.2 (1974)
10. Stewart, K., "The Resuspension of Particulate Material from Surfaces,"
in Surface Contamination (B.R.Fish, ed.) Pergamon, New York pp. 63-74
(1964)
11. Langham, W.H,, "Plutonium Distribution as a Problem in Environmental
Science," Proceedings of Environmental Plutonium Symposium, Los Alamos
Scientific Lab. Report LA-4756 (1971)
12. Anspaugh, L.R., Phelps, P.L., Kennedy, N.C., Booth, H.G., "Wind-Driven
Redistribution of Surface - Deposited Radioactivity," Proceedings of
Environmental Behavior of Radionuclides Released in the Nuclear
Industry, IAEA, Vienna (in press)
13. Anspaugh, L.R., et al., "Resuspension of Plutonium: A Progress Report,"
Lawrence Livermore Laboratory Report UCRL-75484 (1974)
14. Volchok, H.L., "Resuspension of Plutonium-239 in the Vicinity of
Rocky Flats," Proceedings of Environmental Plutonium Symposium,
Los Alamos Scientific Lab. Report LA-4756 (1971)
-------
424
- 138 -
15. Klepper, B.L., D.K. Craig, "Plutonium Aerosol-Foliar Interaction
Program, Summary," Battelle Pacific Northwest Lab., unpublished (1974)
16. Nevada Applied Ecology Group Progress Report, "The Dynamics of
Plutonium in Desert Environments',1 USAEC Report NVO-142 (1974)
17. Whicker, F.W., C.A. Little, T.F. Winsor, "Plutonium Behavior in the
Terrestrial Environs of the Rocky Flats Installation," Proceedings
of Symposium on Environmental Surveillance Around Nuclear Installations,
IAEA (1974)
18. Hakonson, T.E., L.J. Johnson, "Distribution of Environmental Plutonium
in the Trinity Site Ecosystem After 27 Years," Los Alamos Scientific
Lab. Report LA-UR-73-1291 (1973)
19. Radiological and Environmental Research Division Annual Report, Argonne
Nat. Lab. Report ANL-8060, Part III (1973)
20. International Commission on Radiological Protection, "The Metabolism
of Compounds of Plutonium and Other Actinides," ICRP Publication 19 (1972)
21. Neubold, P., "Absorption of Plutonium-239 by Plants," U.K. Agricultural
Research Council Report ARCRL-10 (1963)
Literature Cited - Table 1
239 240
22. Bennett, B.C.,"Fallout ' Pu in Diet," in Fallout Program Quarterly
Summary Report, USAEC Report HASL-286, October (1974)
23. Buchholz, J.R., W.H. Adams, C.W. Christenson, E.B. Fowler, "Summary
of a Study of the Uptake of 239Pu by Alfalfa from Soils," Los Alamos
Scientific Lab. Report LADC-12897 (1971)
941 239
24. Cline, J.F., "Uptake of Am and Pu by Plants," Battell^ Pacific
Northwest Lab. Report BNWL-714 (1968)
25. Cummings, S.L., L. Bankert, "The Uptake of Cerium-144, Promethium-147,
and Plutonium-238 by Oak Plants from Soils," Rad. Health Data and
Reports 12, 83 (1971)
26. Fowler, E.B., et al., "Soils and Plants as Indicators of the Effectiveness
of a Gross Decontamination Procedure," Los Alamos Scientific Lab.
Report LA-DC-9544 (1968)
27. Hale, V.Q., A. Wallace, "Effect of Chelates on Uptake of Some Heavy
Metal Radionuclides from Soil by Bush Beans," Soil Science 109,
262 (1970)
-------
- 139 -
28. Jacobson, L., Overstreet, R., "The Uptake by Plants of Plutonium
and Some Products of Nuclear Fission Absorbed on Soil Colloids,"
Soil Science 65, 129 (1948)
29. Nishita. H., E.M. Romney, K.H. Larson, "Uptake of Radioactive Fission
Products by Plants," in Radioactive Fallout, Soils, Plants, Food,
Man. E.B. Fowler (ed.), Elsevier, New York (1965)
2^7 239 241 244
30. Price, K.R., "Uptake of Np, Pu, Am, and Cm from Soil by
Tumbleweed and Cheatgrass," Battelle Pacific Northwest Lab. Report
BNWL-1688 (1972)
31. Rediske, J.H., J.F. Cline, A.A. Selders, "The Absorption of Fission
Products by Plants," Hanford Research Report HW-36734 (1955)
32. Romney, E.M., Mark, H.M., Larson, K.H., "Persistence of Plutonium
in Soil, Plants and Small Mammals," Health Physics, JL9, 487 (1970)
33. Thomas, W.A., D.G. Jacobs, "Curium Behavior in Plants and Soil,"
Soil Science 108. 305 (1969)
241
34. Wallace, A., "Increased Uptake of Am by Plants Caused by the
Chelating Agent DTPA," Health Physics, 22, 559 (1972)
35. Wilding, R.E., T.R. Garland, "Influence of Soil Plutonium Concentration
on Plutonium Uptake and Distribution in Shoots and Roots of Barley,"
J. Agr. Food Chem. 22, 836 (1974)
36. Wilson, D.O., J.F. Cline, "Removal of Plutonium-239, Tungsten-185 and
Lead-210 from Soils," Nature 209. 941 (1966)
425
-------
426
- 140 -
Table 1
PLANT UPTAKE OP TRANSURANIC ELEMENTS
Coneentrntion Factor (pCi/g frosh weight per pCl/g dry soil) - when ncccssnry, data
adjusted on basis of ash
wt. 17. and dry wt. 207.
of fresh wt.
239Pu
-4
Cone. Factor (xlO ) Reference Plant Species and Method
.02 - .1 Jacobson, Overstreet barley seedlings in clay suspension
for 24 hr.
.04 - 1 Price cheatgrass, tumbleweed - 2 mo - rad,lo-
actlve layer in soil.
.001 - .3 Buchholz, Adams, alfalfa, barley, beans, tomatoes, lettuce
Christenson, Fowler 4 yr. - nitrate, oxide and weapons
contaminated soil
»8pu
2*lto
2*4Cn
2*2C«
!!!&
233,,
.1 - .4
.1 - 1
.04 - .3
.4 - 4
3
1-300
.02 - 2
1 - 3
3
4-6
20
300
1-4
0-4
25 - 220
.5 - .7
Summary:
239Pu 10"5 to lO*3
*aa 93Q
238Pu same as "*Pu
2A1Am 10-4 w lO"2
Cllne
Wilson, Cllne
Wildung, Garland
barley - 18d. - beans In solution
barley shoots - 30d - factor of 2 higher
in roots
Romney, Mark, Larson clover - 5 yr. - NTS soil
Nlshlta, Romney, Larson
Redlske, Cline,
Selders
Bennett
Fowler, et al.
Cummings, Banker t
Price
Buchholz, et al.
Cllne
Hale, Wallace
Wallace
Price
Thomas, Jacobs
Price
Buchholz, et al.
244CD aa»e .. 2'
beans, tomatoes, barley, thistles -
leaves - nutrient media for 20d
potatoes, peeled - fallout background soil
tomatoes, maize, beans, alfalfa -
Palomeres soil - veg. samples washed
but may still Include external con-
tamination.
oat shoots - 3 wks. In 9 soils - radio-
active layer in soil
(see 239Pu)
*!
"
bush beans - leaves
soy beans - leaves and stems - higher in
roots - chelates increase uptake
(see 239Pu)
beans - 7. uptake agrees with Price -
forage grass - no detectable uptake
(see 239Pu)
(see 239Pu)
^Am 233U 10-4
242- 244«
iH*Cm same as Cm
237Np io-2
Relative Uptake - experiments with identical plant
239Pu 233u
1 6
1
1
241Am 244Cm
30
20-30
30 40
species and soils for each Isotope
237flp Experiment
Buchholz (see 239Pu above)
Cllne
2000 Price "
-------
- L41 - 427
II. FALLOUT PLUTONIUM PATHWAYS TO JjAN
Fallout plutonium reaches man by the inhalation and ingestion patnways.
Direct inhalation of the initially airborne weapons-produced natet...i Las
been the dominant contributor to the plutonium body burden. Plutonium \n
air is deposited on vegetation or on soil, contaminating food by direct
deposition or by root uptake. The low plutonium concentrations occurring
in food and the very low transfer across the gastrointestinal tract make the
importance of the ingestion pathway very minimal. Both pathways, however
have been considered in detail.
Ingestion Pathway
A complete diet sampling, consisting of representative foods from 19
separate categories, was conducted in 1972 in New York by the Health and
Safety Laboratory. The plutonium concentrations in the various foods
were determined and the annual intake estimated.
Because of the low plutonium concentrations in the foods, relatively
large samples were required (100 g ash). The total sampling comprised
237 kg of fresh food. Table 1 lists the analytical results. Tha highest
concentration was found in shellfish, followed by grain products and fresh
fruits and vegetables. Lower concentrations were found in meats, eggs,
peeled potatoes, and canned or processed foods. No activity above the
minimum detection level (.01 dpm/sample) was found in milk.
The listing indicates that external contamination is a factor in
the occurrence of plutonium in foods. The difference between fresh and
canned foods indicates that some of the activity is lost through washing
and processing. The plutonium concentration on potato peels exceeded the
concentration fn the peeled potatoes by a factor of 60. The activity on
-------
428
- 142 -
the peels could be accounted for by the soil activity.
Separate analysis of clams and shrimp, which made up the shellfish
sample, showed 8 times higher plutonium concentration in the clams. Much
of the activity in clams, which are filter feeders, is no doubt as ;,o; later*.
with the gastrointestinal portion. The meat portion of tha fresh fish
sample had a concentration 10 times less than the shellfish sample.
The absence of detectable activity in milk had been observed earlier
(2)
for milk sample in 1965. A tracer study has indicated very low transfer
_ /• / o \
of plutonium to milk (10 of ingested dose per liter).
90
Analysis of the identical food samples for Sr indicated that plu-
tonium is deficient in all food items, relative to the deposition amount?;,,
No unusual concentrating processes have been observed. The few plutonium
analyses of food sampled some years earlier indicate that the concentrations
are decreasing as the deposition rate decreases.
239 240
The concentration factor for ' Pu in potatoes was determined from
analysis of Long Island (New York) potatoes and representative Long Island
(1) -4
soil. The result was 3 x 10 (ratio of concentration in fresh peeled
potatoes to that in dry soil). Tracer studies have indicated similar results
for other plant species. This determination indicates that there should be
no unexpected behavior for the uptake to the edible portion of plants at
low environmental levels of plutonium.
Analysis of plutonium in New York tap water (.3 fCi/J. in 1973) indicates
that plutonium, as does cesium, becomes largely removed to sediments.
Ingestion intake of fallout plutonium has been determined from the
concentration results and food consumption estimates. These results are
listed in Table 2. The annual intake during 1972 was 1.6 pCi, due 35% to
-------
429
grain products, 20% each to vegetables, fruits, and meats, and less than
4% to dairy products. The annual intake in 1965 was estimated to be
2.6PCi.(2>
Uptake of plutonium from the gastrointestinal tract is estimated to
range from 3 x 10 to 10 On this basis, the 1.6 pCi ingestion intake
during 1972 would have contributed, at most, 5 x 10 pCi to the body burden.
While inhalation intake during 1972 (.2 pCi) was less than the ingestion
intake, the contribution to body burden was greater than the ingestion
contribution by a factor of 1000.
Inhalation Pathway
Inhalation intake of fallout plutonium can be determined directly from
the measured air concentrations. Estimates of retention in lung, transfer
to blood, and organ distributions are obtained using the ICRP Task Group
Lung Model. Details of the model and results of the computations for fallout
plutonium were reported recently.
Based on the measured and inferred plutonium concentrations in air in
3
New York and a constant inhalation rate (20 m /d), the inhalation intake is
determined. The intake, listed in Table 3, reflects weapons testing
activity - a decrease in 1960 during the test moratorium, a maximum in 1963
(12.2 pCi) following the 1961-62 tests, and declining intake after the 1963
Test Ban Treaty. The cumulative inhalation intake through 1973 has been
42.2 pCi.
The lung model is shown in Figure 1. The transfer rates and fractions
(4)
are the amended values accepted by ICRP Committee 2 in 1971. The Class
Y parameters have been assumed, the form of the fallout plutonium being
most likely Pu02. Deposition in the nasopharynx (N-P) and tracheo-bronchial (T-B)
-------
430 -
regions is cleared rapidly and almost entirely to the G.I. tract.
Elimination from the pulmonary (P) region is primarily with a 500 day
half-time with 807. going to the G.I. tract (40% with a 1 day half-tiro ,
57o to blood, and 157« to the lymph system. Some permanent retention in the
lymph nodes is assumed -* 107o of the amount passing through the lymph system.
Equal partition (457» each) of the amount transferred from blood to bone and
liver is assumed. An additional 17» transfer from blood to kidney can be
assumed, the remainder going to other soft tissue and excretion. The removal
half-time from bone is taken to be 100 years and from liver and kidney 40
years. Transfer of plutonium from the gastrointestinal tract to blood is
quite low (10 )» making negligible contribution to organ burdens from
activity passing from lung to the G.I. tract.
Regional deposition in the lung depends on the particle size. From
measurements of size characteristics of airborne fallout, ' it has been
assumed that fallout plutonium radioactivity is attached to representative
0.4 urn aerosol particles. This size results in 327. deposition in the pulmonary
region. Since 607o of the deposition receives longer term retention, about
207» of the inhalation intake contributes to the initial lung burden. The
lung model transfer parameters indicate that about 67» of the intake reaches
blood, and with the 45-45-1 subsequent distribution to bone, liver and
kidney, 2.757» of the inhalation intake can be expected to be found in bone
and liver and 0.06% in kidney.
239 240
The cumulative inhalation intake of 42 pCi of ' Pu could thus
have resulted in about an 8 pCi body burden (42 pCi x 2070), but since the
intake occurred over several years, a maximum body burden of 4 pCi was
reached in 1964 (Table 3). Little activity having been removed from bone
-------
- 145 -
and liver, the burdens estimated from cumulative intake (42 pCi x 2.75%"^
1 pCi) agree closely with the more detailed computations of the current
burdens. Table 4 lists the computed organ amounts for 1973. The total
body burden is 2.5 pCi.
Comparison of the results of the lung model calculations of organ
burdens of fallout plutonium are available with the human tissue autopsy
analysis results of the Los Alamos Scientific Lab. The comparisons have
shown good general agreement. The averages observed for 50 to 75 samples
/o\
obtained during 1972-73 were recently reported. The observed-computed
comparisons are .3 - .2 pCi in lung, .2 - .5 pCi in lymph nodes, 1.6 - 1.0
pCi in bone, 1.1 - .9 pCi in liver, and .2 - .02 pCi in kidney.
Figure 2 shows the measured inhalation intake of fallout plutonium and
the computed organ burdens, including extrapolated values which assume no
further intake beyond 1974. The continuing air concentration and tissue
sampling programs will provide further checks of our prediction capability
following inhalation intake.
The doses due to the computed burdens have been determined, based on
uniform distributions within the organs. The cumulative doses through
1973 to an individual exposed throughout the entire fallout period since 1954
have been 15 mrem to lung, 8 mrem to bone and 4 mrem to liver. Longer term
retention in liver and bone eventually causes the doses to these organs to
exceed the dose to lung. The cumulative doses through the year 2000 to
the same exposed individual are estimated to be 34 mrem to bone, 17 mrem to
liver, and 16 mrem to lung. These dose commitments are less than 10% of the
total dose commitments due to all other fallout radionuclides.
431
-------
432
- 146 -
References
1. Bennett, B.G.
Fallout 239,240Pu in Diet
USAEC Report HASL-286, October (1974)
2. Magno, P.J., P.E. Kauffman, B. Shleien
Plutonium in Environmental and Biological Media
Health Physics 13, 1325'(1967)
3. Sansom, B.F.
The Transfer
British Veterinary Journal 120. 158 (1964)
The Transfer of 239Pu from the Diet of a Cow to its Milk
4. International Commission on Radiological Protection
The Metabolism of Compounds of Plutonium and other Actinides
ICRP Publication 19 (1972)
5. Bennett, B. G.
Fallout 239pu Dose to Man
USAEC Report HASL-278, January (1974)
6. Schleien, B., N.A. Gaeta, A.G. Friend
Determination of Particle Size Characteristics of old and Fresh
Airborne Fallout by Graded Filtration
Health Physics 12, 633 (1966)
7. Lockhart, L.B., R.L. Patterson, A.W. Saunders
The Size Distribution of Radioactive Atmospheric Aerosols
Journal of Geophysical Research, 70, 6033 (1965)
8. Annual Report of the Biomedical and Environmental Research Program
of the LASL Health Division, January - December 1973
Los Alamos Scientific Lab Report LA-5633-PR, May (1974)
-------
- 147 -
433
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Computed Burdens
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Inhalation Intake and Burden in Man of Fallout 239/240Pu
Figure 2
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- 149 -
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-155-
TRANSURANIC ELEMENTS IN THE MARINE ENVIRONMENT
Herbert L. Volchok
Health and Safety Laboratory
U. S. Atomic Energy Commission
New York, N. Y. 10014
Following is a brief summary of current information concerning trans-
uranics in the marine environment. Most of this material was developed
during a workshop convened by the Ocean Affairs Board of the National
Research Council in late 1973. The workshop subject was "Assessing Potential
Ocean Pollutants"; one chapter (Volchok et al., 1974) is devoted specifi-
cally to transuranics. The report of this workshop will be published in
the very near future. The entire bibliography of the workshop chapter has
been included here, along with the actual references cited.
In marine environments, transuranic elements have been introduced, in
dispersed form, in four ways:
1. Close-in fallout from nuclear explosives testing.
2. World-wide fallout from nuclear explosives testing.
3. Atmospheric burn-up of plutonium power supplies.
4. Fluid wastes from chemical reprocessing and reactor operations.
The environmental redistributions of plutonium have been followed,
to some extent, after its introduction by each of these avenues, and a
small amount of information exists about americium. Unfortunately the data
now at hand do not permit us to distinguish among the distributions of
plutonium following its introduction in different ways. It has been assumed
by Bowen and his co-workers (Wong e_t al.. 1970a, 1970b; Bowen e£ al., 1971;
-------
440
- 156 -
Noshkin and Bowen, 1973) that both plutonium and americium from world-
wide fallout do pass through soluble phases in the oceans, but this has
not yet been confirmed.
Pillai at al. (1964) found that plutonium concentrations in surface
water, collected while fallout rates were high, were explainable by con-
sidering the precipitation exposure of the water masses sampled. More
recently, samples collected while fallout rates were low showed concentrations
that were explained by sedimentation of plutonium, in contrast to the con-
90 137
servative behavior of Sr and Cs in the same samples (Miyake and
Sugimura, 1968; Miyake et al., 1970; Bowen e£ al., 1971; Noshkin, 1972;
Noshkin and Bowen, 1973).
Profiles of Pu concentration as a function of depth in ocean water
columns have been measured, primarily by Bowen and his co-workers at Woods
Hole Oceanographic Institution (WHOI) in AEC-DBER and GEOSECS programs.
239
Noshkin and Bowen (1973) studied the relationship between the Pu in
the sediment (expressed as a fraction of the estimated delivery to the
latitude sampled) and the depth of the overlying water; several shallow
water cores contained 100 percent of the predicted delivery, whereas their
239
deepest core (over 5300 m) contained, in 1971, no measurable Pu . The
major marine removal pathway for this transuranic is apparently biogenous
sedimenting particles.
Data are insufficient to show that this behavior can be generalized
OO Q
for other transuranic elements, or even for Pu that was introduced by
241
SNAP-9A. Schell and Young (1973) suggest that Am is being removed from
the water column in Bikini atoll; Sugihara and Bowen (1962) and Bowen and
Sugihara (1965) argued that lanthanide sedimentation was usually on inorganic
-------
- 157 -
particulates, and americium is predicted to be much more Ianthanide-like
than is plutonium. Unpublished data (Bowen et al., unpublished manuscript)
show, in one N. Atlantic water column, a steady increase with depth, of
O/ 1 O *^ Q
the Am /Pu ratio, from 0.16 at 200 m, to 0.38 at 3200 m; this appears
241
to be too great an increase to be explained by generation of Am by
241
decay of Pu , and in that case, would argue strongly for control of plu-
tonium and americium distributions by their solution chemistry in sea water.
239 241
Aarkrog's (1971) study of the accidental release of Pu and Am
near Thule, Greenland, showed that of the Pu measured, upwards of 95 percent
went to the sediments; 1 percent found in the water column was fine particles
(as was expected of recently formed PuO« particles). The biological data
239
are not yet sufficient to show the extent of remobilization of the Pu ,
241
and no examination has yet been made of the Am . The reprocessing waste
discharge into the Irish Sea from Windscale also results (Preston and Mitchell,
239 241
1973; Mitchell, 1971a, 1971b) in association of most of the Pu and Am
with the sediments close to the discharge area.
239 241
Pu and Am from fallout have been found in marine organisms from
a variety of places in both hemispheres (Noshkin, 1973; Cherry and Shannon,
242
1974). Cm has been found (Livingston, personal communication, 1973) in
237
Fucus from the Irish Sea, and Np (at very low levels) in a variety of
samples from Eniwetok (Noshkin, personal communication, 1973).
Sources in Polykarpov (1966) indicate concentration factors of about
239
1000 for Pu in marine plants; Noshkin (1973) has tabulated much recent
data shown in Table 1, indicating that this level is often exceeded by
marine benthos and zooplankton, and usually very greatly exceeded by the
Atlantic Ocean species of pelagic Sargassum.
441
-------
442
Data reported by Bojanowski et al. (1974), and by Mitchell (1971a,
241
1971b) show that Am , from fallout or from waste, is strongly concentrated
241 239
by Sargassum or rooted algae leading to in-plant ratios of Am /Pu
several times higher than those in the medium. Their data indicate that
241
Am is more concentrated in Porphyra from the Irish Sea than Fucus
241 239
(Am /Pu as high as 1*4 in Porphyra, versus 0.18 in Fucus).
Study by Wong e_t al. (1972) showed that in the great Pacific kelp
239
the maximum Pu concentrations (about 2 pCi/kg) were confined to the
thin outer layers of the plant, the inner parts showing concentrations only
1/200 of that near the outside surface.
In general it appears (Noshkin, 1972) that marine invertebrates exhibit
239
higher concentrations of fallout Pu than do fish, this is also the trend
939
of the data on close-in fallout Pu about the Pacific test sites. The
239
fish Pu shows bone or liver-seeking behavior, as it does in mammals;
239
liver-seeking may also be characteristic of Pu in molluscs and Crustacea,
but there are few data. The tendency shown by molluscs and lobster, for
239
high concentrations of Pu associated with shells, can be explained by
the well-known tendency for shell-periphyton to accumulate trace constituents
from the medium, rather than by the invertebrate equivalent of bone-
seeking.
The data show little evidence for any trophic level enhancement of
239
Pu accumulation, although in the one case specifically studied (Wong
239
e_t al., 1970) starfish showed consistently higher Pu (fallout) than did
the mussels on which they were feeding.
-------
- 159 -
239 241
By analogy one would expect Pu or Am , once incorporated in
tissues of marine organisms, to show long residence half-times; in the
one case studied, Hodge e_t a^L. (1973) suggested a half-time of 3.5 years
239
for Pu in albacore liver.
239
It has been noted a number of times that even Pu accumulations from
fallout represent higher radiobiological doses (in rems) to some marine
organisms analyzed than do either their Sr or Cs contents. This is
because of the relatively greater biological effectiveness of alpha particles
versus the beta or gamma radiation of Sr or Cs
443
-------
444
*** - 160 -
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**
Avargues, M. and H.P. Jammet. 1966. Etude du site marin de La Hague
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Bojanowski, R., H.D. Livingston, D.L. Schneider, and D.R. Mann. A pro-
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Hakonson, I.E. and L.J. Johnson. 1973. Distribution of environmental
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ICRP - See International Commission on Radiological Protection-
International Commission on Radiological Protection (ICRP). 1972.
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- 168 -
TABLE 1.
PLUTONIUM IN MARINE ORGANISMS
Organism^
Plants
Algae (attached)
Sargassum(attached)
Sargassum(pelagic)
Animals
Plankton(mixed)
Sponge
Annelid Worm
Starfish
Gastropods
n
Bivalves
Sal pa
Crustacea
F1sh
Collection
Date
1964
1970-71
1971
1971
1965-70
1950
1961
1964
1970
1970
1970
1970
1970
1964
1968
1970
II
1958
1968
1964
1969
II
II
1970
II
M
II
1970
II
II
1971
Location
California Coast
Cape Cod, Mass.
California Coast
California Coast
Atlantic Ocean
California Coast
Atlantic Ocean
California Coast
Cape Cod
n n
n ji
M II
II II
California Coast
Danish Coast
Cape Cod
n
Atlantic Ocean
. Janish Coast
California r-oast
Cape Cod
n
n
Cape Cod
n
n
M
Cape Hatteras
n
ii
Cape .Hatter,as
Tissue and
lumber Samples
Whole (4)
11 (6)
" (19)
" (2)
11 (6)
" (1)
" (1)
" (1)
" (1)
" (1)
" (1)
Body (2)
Shell (2)
Body (2)
? (1)
Body (5)
Shell (2)
Whole (3)
" (5)
" (1)
Muscle(l)
Liver (1)
Bone (1)
Muscle (3)
Liver (3)
Gut (3)
Bone (3)
Muscle (3)
Liver (3)
Bone (3)
Muscle(2)
Bone (2)
Mean
Pu 239
pCi/kq v/et
0.47
0.53
0.64
0.28
20.7
0.023
2.03
1.08
1.80
3.50
0.87
0.35
0.42
0.22
7
0.31
0.47
1.40
1.5
0.001
0.005
0.03
0.6
0.003
0.05
0.68
0.11
0.003
0.15
0.02
0.006
0.03
Pu238
Pu239
^_
—
—
~
—
—
—
—
0.07
0.06
0.09
0.05
0.09
—
—
0.07
0.08
—
—
—
—
~
~
—
~
—
—
~
--
~
—
Range of
Cone.
Factors
660-1570
100-1600
260-3500
325-450
3000-100, OC
—
2300
2600
2100
4100
1020
140-660
300-690
230-290
8200
300-520
490-600
900-2400
1060-4500
3
1-5
—
—
1-2
14-60
40-1100
50-600
4
175
21
10-15
30-50
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453
Dr. Mills: Thank you, Doctor. You and Dr. Wrenn have given us a
great deal of technical information which will take quite a lot of time
to digest.
I have two quick questions, one to you and one to Dr. Wrenn.
In regard to the question of plutonium uptake to include the food
chain for humans, has there been any information that came from the
Palomares episode which would lead us in a determination of what plu-
tonium might do by way of transport to humans?
Dr. Bennett: Yes. There have been some studies of plant uptake
for edible foods at Palomares, and also laboratory tests and experiments
using Palomares soil. Some of these data, reported by the Los Alamos
Scientific Laboratory, are included in the comprehensive summary table
of plant uptake included in my written testimony.
Dr. Mills: Other than the inhalation problem, does the depth of
the soil — did there seem to be a critical depth of plutonium in the
soil uptake, or the food chain? That is, the growth and transport of
materials, is it all within the first centimeter?
Dr. Bennett: For cultivated fields, that of course would not be
the case. It would be more uniformly distributed. That should be
considered.
Even for uncultivated areas, there is some downward mobility, as
Dr. Wrenn pointed out. It does not remain on the surface forever.
Dr. Mills: I have one question for Dr. Wrenn.
In your Table 3, where you show representative concentrations of
plutonium 239 in various means, you have 4xlO~8 picocuries per gram, I
recognize the sample size is an important consideration but would you
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454
comment on the ability to make measurements at these levels?
That is, keeping in mind that one can only work with a reasonable
size sample. Are these pretty close to the detectability, do you feel?
Just a comment is all that I am looking for.
Dr. Wrenn: Yes.I would say they are. They represent generally
research type measurements in which one takes a great deal of trouble
to collect a very large sample and to process that sample and analyze
it.
For example, in seawater samples, there was .1 picocuries per 100
liters, so you have to collect 100 liters to get a tenth of a piocurie
of plutonium.
To answer your question, yes. You have to stretch to do that. On
a research basis, you can.
Dr. Mills: Do you have any questions, Dr. Taylor?
Dr. Taylor: I want to ask one question of Dr. Bennett, if I may.
You pointed out that the uptake of plutonium in foodstuffs seems
to be very low relative to the amounts deposited in comparison with
other radio elements.
What is the explanation for that?
Dr. Bennett: I notice that in wheat, very little translocating
to the inner part of the kernal takes place. That might be one explana-
tion, since there is little translocation, there is more opportunity for
washoff.
The explanation for low levels in other foods in terms of plant
uptake is explained by the chemistry.
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455
Dr. Mills: Dr. First?
Dr. First: You have gone through a great deal of data in your two
presentations in a short time. It is obvious you have concentrated them
quite a bit.
I am going to ask you to concentrate still more, if you can. Could
you tell us, either/or both of you, what is the significance of the data
which you have presented to us this afternoon in terms of the objective
of this conference?
What should they mean to us?
Dr. Bennett: The fallout measurements, I think, are directly
appropriate to your consideration in that they are actual measurements
of plutonium in the environment.
To that extent, it is not speculation; and to that extent, I think
it will be important in your consideration of standards.
Dr. First: I do not think I have made my question clear. What
should I think about it now that you have presented it? What am I
supposed to deduce from this information?
Dr. Bennett: Whatever a scientist would care to deduce from it.
It is your prerogative.
Dr. First: I realize this, but I would like to know what the
significance is in your mind. Why did you present the particular things
you did? Why did you highlight the particular items? They must have
had some significance in the context of this particular meeting.
What I am asking you for, really, -is to help me decide what this
all means by not having to go through all the references.
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456
Dr. Bennett: I am not sure I understand you.
I presented what I believe is objective scientific data. I think
it does give you some indication of the behavior of plutonium in the
environment.
I cannot really say anything further.
Dr. Mills: Perhaps I can read one of the specific items in the
Federal Register. Information was asked for on the environmental
levels. It was to include consideration of available data of the pro-
cedure, and accurateness and completeness of available data, a theoreti-
cal model developed on transport through the ecosystem, and experi-
mental verification of such a model.
I would assume that some of this information some where down the
road could be interpreted in this context.
Dr. Bennett: Yes. I would certainly hope so.
Dr. Mills: That was a very big job.
Dr. Wrenn: I guess I can have a crack at it quickly. It seems
to me that one needs to discuss the existing amounts of given types of
material in the environment when considering environmental type
standards.
Secondly, they teach us an awful lot about the way the material
will behave in the future.
One of my reasons for pointing out the americium 241 amounts is
that we are going to learn from environmental studies in the next few
years a lot of things about the translocation of this particular element
that we do not know yet.
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457
Dr. First: I hope nobody is interpreting this as being critical
of the papers or of the information presented.
I am very much interested in it. I think it is a very fine job.
I would like to know what it means.
Dr. Liverman: It seems to me that with the information on hand
you can conclude the following sorts of things.
Here is fallout. You can measure what is on the top of the soil
and at different levels. You can grow plants on it and find out how
much they take up, how much is in the food chain, how much gets to
bones, lungs.
It begins to tell you, then, something about what should be
permissible to be allowed on the surface or at different levels in the
soil in different regions of the country, so that you have a better
feeling for saying OK, you cannot get that dirty there; you are in
real trouble. It then begins to tell you something about the levels
at which one should set permissible standards in different environmental
conditions.
At least to me, that is what this would say.
Dr. First: Yes. I agree.
What are the levels?
Dr. Liverman: What should the levels be?
I thought that was the purpose of all of these explorations, to
help us try to arrive at what these should be.
Dr. First: Yes. I agree. I thought each one might have some
estimate.
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458
Dr. Liverman: I have not. Perhaps others do.
Dr. Taylor: This will help us set flexible standards, will it?
Dr. Liverman: It should tell you how much flexibility is needed.
Dr. First: This is a do it yourself project, I take it.
Dr. Radford: I have a few questions for both the speakers.
You heard, first, about the AEC facilities and Dr. Yoder indicated
those are not necessarily typical of distribution of radionuclides that
occur from civilian power development.
Now we have heard about weapons testing fallout which also probably
is not typical. I guess you can say flatly it is not typical.
In particular, for example, would either of the speakers comment on
the importance of curium versus americium or plutonium in waste now
rather than just total? I realize plutonium is the big item, but when
we get into the waste system, we are dealing with curium, too. Right?
Dr. Wrenn: I pointed out in my slide number three that curium is a
trivial input in weapons testing.
Dr. Radford: It may not be trivial when we get into wastes for
nuclear power plants?
Dr. Wrenn: It may not be. The relative abundance will be quite
different.
Dr. Radford: So the contribution that curium isotopes might have
to this problem are not inferrable from this information. I would like
just to ask Dr. Bennett first with regard specifically to this lung
model, I take it that as far as the fallout material is concerned the
principal conclusion that I would draw from your data is that inha-
-------
459
lation exposure to lung tissues is essentially the principal problem.
There may be some uptake into other tissues, but it is predomi-
nantly in the lung tissues. Is that right?
Dr. Bennett: Yes. Initially it is, and subsequently some transport
to G.I. tract and to blood; subsequently, to other organs. Yes.
Dr. Radford: But the dose calculated in the method you used came
out pretty small for those other organs. Is that right?
Dr. Bennett: Yes, initially.
Dr. Radford: Initially, and integrated over the whole?
Dr. Bennett: Long term retention is assumed for bone and liver,
so those doses do exceed the lung dose eventually.
Dr. Radford: Now, the principal concern as I understand it of the
panel and this discussion is the possibility of cancer production in
man. Is that your understanding, too? Or genetic effects?
Dr. Bennett: Health effects, yes.
Dr. Radford: Health effects. And those are predominantly cancer
effects by alpha emitters. Is that what we are talking about predomi-
nantly?
Dr. Bennett: I am not talking about it. My studies end with the
estimated burdens in man. I have not directed any of my comments on
health effects-
Dr. Liverman: I think we will go into that area in great depth
in the morning, Dr. Radford.
Dr. Radford: All right. I just wanted to make a point pertient
to Dr. Bennett's presentation, since you did present the lung model and
-------
460
the derivations therefrom.
The radiogenic cancers that occur in man occur in what tissues
specifically within the lung? Are you familiar with that?
Dr. Liverman: I do not think he can be expected to answer that.
Dr. Bennett: I am an environmental scientist. I am not a
biologist.
Dr. Radford: Oh, I see. Well, never mind, then. For the sake of
an interest in time, I will take that it is predominantly in the bron-
chial epithelium or the substructures to that, and the ICRP lung model
does not include this as a compartment, nor are there very good data on
the transfer rates in and out of that compartment.
So that the application of modelling by the ICRP model is not
particularly germane to this issue today.
Dr. Wrenn, would you care to speculate on the lung concentrations
that have been observed, that you reported in your Table 3, and which I
guess were similar to those Dr. Bennett presented in relation to the air
concentrations?
Dr. Wrenn: Dr. Bennett went over this in detail for New York. I
just took essentially the highest concentration and — it will be talked
about later in Dr. Richmond's paper — I stuck that in as a representa-
tive example.
The function of this Table is merely to allow you to rank the amount
of activity.
Dr. Radford: What is the form of the alpha emitting elements in
fallout? Are they in submicron particles, dust particles, or how? Is
this known?
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461
Dr. Bennett: Yes. They are submicron particles attached to the
aerosol particles. Yes. You can understand that from the production
method in the weapons test, dispersion in the stratosphere.
Dr. Radford: Would expect a particle size distribution to be the
same in a weapons test fallout as it would be, say, in material coming
out of a fuel reprocessing plant?
Dr. Bennett: It could well be different, but it could also be quite
similar.
Dr. Mills: Dr. Garner?
Dr. Garner: Dr. Bennett, we have in our written testimony a state-
ment from William B. Lipton, who describes himself as a doctoral candi-
date who has been working on uptake of plutonium by plants.
He states, "If you use plutonium chelating agents...the uptake
factor is -increased by about 50."
Also, recently, there was a paper in the Journal of Agricultural and
Food Chemistry, Pacific Northwest Lab, describing an increase in uptake
of plutonium from soil.
Do you think this will modify the conclusions you will have to make
when we start talking about plutonium with other things coming out of it,
from nuclear plants as opposed to fallout?
Dr. Bennett: Yes, I am aware of these studies. I mentioned some of
the effects in that table of chelation treatment. It will increase plant
uptake; it is not often sustained, however. It is possible to increase
plant uptake using certain chelating agents.
I am aware of that. Whether these will be of widespread use in
-------
462
agriculture would be hard to say.
Dr. Garner: What about the Pacific Northwest results that showed a
gradual increase in uptake by kilogram?
Perhaps someone will comment on that tomorrow?
Dr. Bennett: I think it was a gradually increasing uptake by plants
with decreasing concentration in soil. However, there was only a factor
of about two difference, really not significant; if you extrapolate to
background levels to fallout levels, you do not find a corresponding
extrapolated increase in uptake at these levels.
Uptake is not radically different from the levels that Wildung
obtained.
Dr. Garner: So you think there is no reason to suspect in the
future that major exposure of man will change from inhalation to
ingestion?
Dr. Bennett: Yes. 1 have stated that there should be no surprising
plant uptake at the low levels such as we have experienced with fallout
plutonium.
Dr. Garner: Thank you.
Dr. Mills: Are there any more questions or comments?
Thank you, gentlemen.
I would suggest we adjourn until the morning.
We will reconvene at nine o'clock tomorrow morning.
(Whereupon, the hearing in the above entitled matter recessed at
5:30 p.m., to reconvene the following day, on Wednesday, December 11,
1974, at 9:00 a.m. o'clock.)
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463
Dr. Mills: We will start off this morning with the area of
Biomedical Effects, testimony given by the Atomic Energy Commission.
The first speaker this morning is Dr. Bill Bair.
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- 171 -
464
The Biological Effects of Transuranium
Elements in Experimental Animals
by W. J. Bair, Ph.D.
Director, Life Sciences Program
Battelle - Pacific Northwest Laboratories
Richland, Washington 99352
part of the AEG presentation at the
EPA Plutonium Standards Hearings
Washington, D. C., December 10-11, 1974
INTRODUCTION
The toxicity of plutonium has been of concern since milligram
quantities were first produced in the Oak Ridge reactor starting in late
1943. In 1944 milligram quantities were allocated for biomedical studies.
In 1947 and 1948 the first biological experiments were completed with
americium and curium. Since then, biological research has been in
progress at several laboratories in the United States and abroad. Most
of the research effort has been directed towards the compounds of the
239
most common isotope of plutonium, Pu. Within the past 10 years as
the concept of plutonium recycle and the fast breeder program developed,
recognition of the potentially increasing abundance of the transplutonium
elements has led to expanded biomedical research on neptunium, plutonium,
americium, curium, californium, berkelium, and einstinium.
The purpose of these animal experiments is to enable us to predict
the health consequences of transuranium elements in man. These studies
have considered two different kinds of contamination events. One of
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465
these, occupational exposures to transuranics released into the work
environment, involves relatively small numbers of people. Such exposures
can be simulated reasonably well in the laboratory with the expectation
of observing unmistakable effects in statistically significant numbers
of animals. The second kind of contaminating event of concern is the
exposure of large populations to very low levels of the transuranium
elements. Such low level exposures cannot be directly simulated in the
laboratory because exceedingly large numbers of experimental animals are
required to yield meaningful results. Therefore, an understanding of
the mechanisms of the biological action of low levels of transuranics is
required to predict what cannot be measured in the laboratory.
An overriding concern of all the animal experimentation is the
confidence with which the results can be extrapolated to man. While
sophisticated experiments can be performed with rodents, dogs, cats,
swine, and primates, questions regarding the applicability of the
results to man will be settled only as data from human exposure cases
become available.
The major health effects of the transuranic elements are due to
their emission of alpha radiation and the nature of the effects depends
upon which tissues are irradiated. This is determined by the disposition
of these radioactive elements in the body which in turn is determined by
their chemical and physical properties and their route of entry into the
body. Thus, in this presentation, I will review in a general way the
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466 - 173 -
absorption of the transuranic elements into, and the distribution within
the body following ingestion, deposition on skin, and inhalation. Then
I will summarize the biological effects which have been observed in
experimental animals, in particular the late effects resulting from
relatively low level radiation exposures. The emphasis will be on
plutonium because it is the transuranic element we know most about.
Much of the information included in this presentation has appeared
in several recent reviews (Hodge, Stannard, Hursh, 1973; Bair and Thompson,
1974; Bair, 1974; Thompson, 1974; Bair, Richmond, and Wachholz, 1974;
Dolphin et al., 1974; Buldakov et al., 1969; Sanders et al., 1970;
Healy, 1974; Thompson, 1974; Park, 1974; Stover, 1974).
DISPOSITION OF TRANSURANICS IN THE BODY
Transuranium elements released to the environment may reach man
through three pathways. Transuranics which become incorporated into
foodstuffs may be ingested and absorbed from the gastrointestinal
tract, while those dispersed in air may be either deposited on the
skin and absorbed, or inhaled and deposited in the respiratory tract.
Occupational exposures may include entry through a wound.
ABSORPTION FROM THE GASTROINTESTINAL TRACT
Experiments confirm that most transuranic element compounds are not
readily absorbed from the gastrointestinal tract. Table 1 gives values
for the gastrointestinal tract absorption of uranium and several transuranic
elements in newborn rats and adults. In rats, neptunium nitrate was most
readily absorbed, nearly 1 percent. The least absorbed was Pitf^, 0.0001
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- 174 -
percent. Gastrointestinal tract absorption was one or two orders of
magnitude greater in the newborn rat than in the adult. Americium,
curium, berkelium, and einstinium show at least a 10-fold greater
absorption than plutonium.
ABSORPTION THROUGH INTACT SKIN
Although percutaneous absorption of all available transuranic
elements has not been thoroughly studied, results from experiments with
plutonium indicate that absorption through intact skin is a relatively
minor route of entry into the body, Table 2. The highest value, 2 percent,
was obtained in rat skin exposed to Pu(NO~)/ in 10 N HNO^ for 5 days.
All other experiments gave values of less than 1 percent. About 0.05
percent of einstinium, the only other transuranium for which data are
available, was absorbed over a period of 7 days through rat skin.
Results from animal experiments and human contamination incidents indicate
the intact skin to be an effective barrier to the entry of plutonium and
einstinium, and probably the other transuranium elements.
RETENTION AND TRANSLOCATION FROM LUNG
Airborne transuranic particles are similar to most other particles
when they are inhaled in that deposition in the respiratory tract is
primarily dependent upon the physical properties of the particles and
the respiratory characteristics of the individual inhaling the particles.
Clearance From Lung
Animal experiments and limited human data provide a range of values
for the retention half-times of several plutonium compounds. These are
467
-------
468
o QQ 239
summarized in Figure 1 for Pu and Pu. The retention half-times
for organic complexes of plutonium, plutonium nitrate and fluoride range
from less than 100 days to about 300 days in rats and dogs. The retention
half-times for PuOo are substantially longer, ranging from 200 to 500
days in rats, 300 to 1000 days in dogs, and 250 to 300 days in human
beings. The wide range of values for dogs is largely due to extensive
experimentation with a variety of plutonium oxides with different particle
size characteristics. The relatively low retention values for human
beings, compared with dogs, suggests either that man clears plutonium
particles from his lungs more rapidly than do dogs or that the materials
inhaled in the human accident cases were more soluble than plutonium
TOO
dioxide. Studies with PuO^ in dogs indicate a much shorter lung
239
retention time than is observed for PuC^- This appears to be due to
238
instability of PuC>2 particles, possibly caused by radiolysis in
tissue fluids.
Figure 2 illustrates the effect of the physical properties of the
inhaled particles on retention of plutonium in lung. Retention half-
times are given in days for several plutonium oxides. Each bar represents
data from one dog. Plutonium oxide prepared by calcining the oxalate at
1000°C was retained with a half-time of 650 to 950 days compared with
300 to 400 days for an oxalate calcined at 350°. Oxides prepared from
metal powder at temperatures of 123 to 450 were retained in lung
longer than the low fired oxalate. Particle size is also important.
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469
The small particle size high-fired oxide was retained with a half-time
of 400-500 days, compared with half-times up to 900 days for the larger
particle size high-fired oxide. Retention of the small particle size
238 239
PuOo was less than for the comparable PuC^.
Pulmonary retentions of inhaled transuranic compounds have been
compared in rats and dogs. In rats, both Am and Cm nitrates were
238 239
cleared much more rapidly than Pu and Pu nitrates, Figure 3.
241 242
Autoradiograms from this study indicated Am and Cm to be dispersed
238 239
much more throughout the lung than Pu and Pu. In another experiment
the rate of clearance of intratracheally instilled einstinium chloride
o / o
was found to be much like that reported for Cm nitrate.
The retention rates of several inhaled transuranics in beagle dogs,
Figure 4, compare favorably with the results from rat experiments.
Plutonium oxide, nitrate and fluoride were retained in the lung much
longer than curium and americium oxides.
Spatial Distribution of Transuranics Within Lung
From the moment transuranic elements are deposited in the respiratory
tract, biological and physical forces are at work to cause their removal.
Thus, it is difficult to visualize plutonium and the other transuranics
remaining static throughout their residence time in lung. It is not
possible to document the course of individual particles and aggregates
of particles in lung. However, the temporal and spatial characteristics
of radioactive particles within tissues can be inferred from autoradiographs
of tissue sections prepared from animals exposed to radioactive aerosols.
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470
- 177 -
The first observation is that radionuclides are nonuniformly deposited
throughout lung. Further, the radionuclides may deposit unequally among
the lung lobes or among portions of lung lobes. Studies of inhaled
plutonium nitrate in both rats and dogs show that immediately following
the inhalation exposure, plutonium is present in both particulate and
nonparticulate forms, as evidenced by the presence of alpha stars and
single tracks in autoradiographs, Figure 5. Einstinium nitrate, Figure
6, and einstinium hydroxide also show particulate and nonparticulate
forms a few days after deposition in the lung. Autoradiographs prepared
239
from dogs exposed to inhaled PuC^ show an initial relatively diffuse
distribution of particulate plutonium throughout the entire lung.
A fraction of the amount of transuranics deposited in the lung may
be dissolved and absorbed into the blood. The remaining transuranic
particles and aggregates may be engulfed by macrophages. This has been
demonstrated in studies with plutonium. Phagocytized plutonium dioxide
particles are rapidly localized in the cells, Figure 7.
The alveolar macrophage appears to be capable of transporting
transuranic particles and aggregates from the alveoli to the ciliated
epithelium lining the bronchioles. These phagocytic cells containing
particles and aggregates can then be removed from the lung in the mucous
blanket which is propelled up the respiratory passage by ciliary action.
Transuranium elements removed from the lung by this route are swallowed
and excreted in the feces.
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471
Both soluble and insoluble transuranics not immediately cleared
from the lung tend to become further aggregated. This mobility and
aggregation of transuranics may have large effects on the temporal and
spatial distribution of the alpha radiation dose. A few days after
inhalation of plutonium nitrate and other relatively soluble compounds
single tracks in autoradiographs decrease and after several weeks nearly
all of the radioactive material appears to be aggregated. Figure 8
238
shows aggregation of Pu in rat lung 100 days after inhalation of
o)/. Curium tends to aggregate less than plutonium (LaFuma et al.,
in press) .
Particles of transuranium elements are transported via lymphatic
vessels in the lung and collected in the thoracic lymph nodes. Autoradio-
graphs of lung tissues taken from dogs several weeks and months after
inhalation of PuOo show alpha stars concentrated in subpleural areas,
apparently in lymphatic vessels, Figure 9. Autoradiographs also suggest
that radioactive particles become immobilized in scar tissue in subpleural
O O Q
areas. Figure 10 is an example of a PuO? particle located in scar
tissue of a dog 5 years after exposure. Areas around the scar tissue
appeared to be normal .
Radioactive particles transported to lymph nodes eventually appear
sequestered in "hot spots" of scar tissue and do not appear to be mobile.
The residence time for plutonium in lymph nodes appears to be very long.
There is ample evidence that transuranic particles deposited in
lung are subjected to biological and physical forces. This argues
against either particles or aggregates of transuranium elements remaining
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- 179 -
static indefinitely, except for that which becomes immobilized in scar
tissue. To the contrary, while the rates may be low, movement of
transuranic particles within lung tissue by several mechanisms certainly
occurs as the lung attempts to expel the radioactive particles and other
foreign material which may have been inhaled. The migration of deposited
radioactive particles in lung partially compensates for the nonuniformity
of the radiation exposure from the particles.
Translocation From Lung to Other Tissues
The relative distribution among body tissues of the transuranics
translocated from lung by the circulating blood is essentially the same
for all transuranic compounds, but may differ quantitatively depending
upon the chemical and physical state of the inhaled material.
In beagle dogs within several months after inhalation of relatively
soluble plutonium nitrate, the fraction remaining in lung decreased to
40 percent or less of the amount deposited in the lower respiratory
tract, Figure 11. Translocation of plutonium from lung resulted in bone
accumulating about 30 percent, and liver about 10 percent. A small
percentage was found in spleen, lymph nodes, and other soft tissues and
the remainder was excreted in urine and feces.
When plutonium dioxide is inhaled, the lymphatic system accounts
for a large fraction of plutonium cleared from lung, Figure 12. Data
from a 11-year study with beagle dogs shows that after 5 years lung
and thoracic lymph nodes each contained 30 percent of the plutonium
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473
initially deposited in the lower respiratory tract. After 11 years the
amount in the lung had decreased to about 10 percent and the thoracic
lymph nodes had accumulated 40 percent. Translocation of plutonium from
lung resulted in levels in liver of about 10 percent, in bone of about 5
percent, and in the abdominal lymph nodes of about 1 percent.
The average radiation doses to these tissues bear the same relationship
as the plutonium concentration in the tissues, Table 3. The average
concentration of plutonium was highest in the thoracic lymph nodes and
next highest in the abdominal lymph nodes. Average concentrations in
lung and liver were over 1000 times less than those in the thoracic
lymph nodes. The concentrations in spleen and bone were about one-fifth
to one-tenth those in lung. Thus, the lymph nodes received a much
higher average radiation exposure than other tissues in the body.
238
Data were presented showing that Pu02 may be cleared from lung
239
more rapidly than Pu02- It has also been found that translocation of
r\ o Q
JOPu from lung to other tissues in the body may be greater than for
•"Pu, Figure 13. Distributions of plutonium in tissues of beagle dogs
238 239
5 years after inhalation of PuC>2 and PuC>2 are compared. After 5
238
years only 10 percent of the body burden of the Pu was in lung compared
239
with 46 percent for Pu. Accumulation in thoracic lymph nodes was
239 238
three times greater for Pu than for Pu; however, the bone burden
of 238Pu was 12 times that of 239Pu. This illustrates that the behavior
OOQ
of -* PuQ2 in the body may differ significantly from that of
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- 181 -
All of the transuranics tend to translocate from lung to bone and
liver and, to a lesser extent, to spleen and kidney. However, the rate
at which translocation from lung to these other tissues occurs differs
considerably among the transuranics, depending mostly on the in vivo
solubility of the compound inhaled. For example, CmClo, CmO, 7~,
O / 1
and AmO? are readily translocated to the bone, similar to plutonium
nitrates, Figure 14. Translocation of plutonium occurs very slowly
after inhalation of plutonium fluoride and plutonium dioxide.
In dogs exposed to aerosols of oxides of transuranium elements,
Cm was almost equally distributed among lung, liver, bone, and muscle
f\ i -i
after one month, Table 4. The translocation of Am was predominately
238
to the liver while translocation of a relatively soluble form of Pu,
O OQ
the hydrated oxide, was mainly to bone. More stable Pu oxides and
showed little translocation from lung to other tissues, but
showed greater accumulation in the thoracic lymph nodes than occurred
7/.-1 244
after inhalation of H-LAm02 and CmOx.
The tissue distribution of transuranium elements absorbed through
the skin, from wounds or from the gastrointestinal tract is similar to
that observed after translocation from the respiratory tract. The rate
of translocation may vary, however, because deposition in a wound or in
the lung provides a reservoir for continuous absorption into the blood
stream. Absorption from skin or the gastrointestinal tract will be of
short duration, until the skin has been decontaminated or the GI tract
cleared, except in cases of continuous exposure.
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475
The quantitative differences in translocation of different transuranic
elements and compounds from the lung and other deposition sites can lead
to significant differences in biological effects which may occur.
DEPOSITION IN GONADS
Because of the concern for possible genetic effects of radionuclides
deposited in the body, measurements have been made of the amounts of
radionuclide which accumulate in the gonads of experimental animals.
This is summarized for plutonium in Table 5. About 0.05 percent of the
plutonium in the circulating blood may deposit in testes and only about
0.01 percent in ovaries. In the testes about half of the plutonium
appears to be associated with germinal tissue. Few data are available
on the deposition of the other transuranics in gonadal tissue but
preliminary results suggest that the fractional uptake will be about
the same as that for plutonium.
CROSS PLACENTAL TRANSFER
The transfer of transuranics and other radionuclides across the
placenta have been studied in rats, Table 6. Neptunium, plutonium, and
einstinium show significantly less transfer to the fetus as well as to
the placenta and the placental membranes than uranium, cesium, and
241 244
cerium. Preliminary results from studies of Am and Cm suggest
less transfer than has been observed for plutonium. These results show
that the placenta is an effective barrier to transuranium elements, and
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476
- 183 -
that extremely high levels of contamination would have to occur in the
pregnant female before appreciable quantities of transuranium elements
would occur in the fetus.
BIOLOGICAL EFFECTS
It has been shown that the distribution of the transuranium elements
among the tissues in the body varies depending upon the route of entry,
the chemical compound and the radioisotope. The biological effects which
may occur will depend upon the radiation exposure and the relative
radiation sensitivity of each tissue into which the radionuclide is
deposited. These are primarily blood, bone, liver, lung, and the lymphatic
system. The biological effects of greatest interest are those that
might occur at low doses. Animal experiments have identified neoplasia
as the most sensitive response to the long-term effects of transuranic
elements deposited in the body.
BLOOD
Transuranic elements are cleared from the circulating blood within
a few days after absorption from the site of deposition such as the
gastrointestinal tract and lung. Therefore, the major effects seen in
blood cells will be due to irradiation of the hematopoietic tissue in
which the radionuclides are deposited or to irradiation of blood circulating
through tissues containing deposits of the radionuclide.
Most of the hematologic effects observed after deposition of the
transuranics in the body occur at relatively high doses, doses above
those which have resulted in cancer, Table 7. A variety of hematologic
-------
477
effects have been reported in all animal species studied. Summarized in
this table are only data from dog and pig experiments. The erythrocyte
levels are only reduced at the highest doses. Elements of white blood
cells show transient reductions following intravenous injections of all
of the transuranics studied similar to those seen after exposure to
external radiation. Although the transuranics deposit in bone and lymph
nodes, leukemia has not been a common finding in animal experiments. It
has been reported in less than a dozen rats after intravenous injection
of plutonium and americium, in a few rats after intratracheal injection
of einstinium, and in one dog (which also had osteosarcoma) after inhalation
, 238,,
of Pu.
The most consistent hematologic response seen after injection and
inhalation of the transuranics is lymphopenia. This is well documented
238 239 241
after inhalation of Pu, Pu, and Am. In current experiments
with dogs this is the most sensitive indication of a biological effect,
239
occurring at dose levels of inhaled Pu02 which have not yet shown
cancer, Figure 15. The possible health consequences of a plutonium-
reduced level of circulating lymphocytes are not yet known. One cannot
rule out the possibility of a relationship between the reduction of
circulating lymphocytes, lymph node pathology, decreased immunological
competence, and the pathogenesis of transuranic-induced cancer.
BONE
Osteogenic sarcomas appear to be the most sensitive effect following
the skeletal deposition of plutonium, americium, curium, and einstinium
in mice, rats, and dogs. In most of these experiments the solutions of
-------
478 -
the transuranics were injected intravenously. However, osteogenic
sarcomas have occurred after pulmonary deposition of Cm and ^Es in
900 244 253
rats and JOPu in rats and dogs. In these experiments the Cm, Es,
OQQ
and Pu were largely translocated to the skeleton.
The most informative experiment on the effects of transuranics in
bone is a beagle dog study with plutonium at the University of Utah.
This experiment began in 1952 to compare the long-term effects of intra-
venously injected plutonium and radium. The objective was to determine the
toxicity ratio between plutonium'and radium in dogs, so that the radium
toxicity data available from human exposures can be used to infer the
toxic response to plutonium in man. The results from the plutonium
animals in this experiment are shown in Table 8. There were 9 to 13
animals per exposure group, injected at levels differing by about a
factor of three, and ranging from 2.9 |JiCi/kg to 0.016 |j-Ci/kg. There was
a substantial incidence of osteosarcoma, 31 percent at the lowest level.
When it became evident that effects were occurring in the lowest exposure
groups, additional groups were added to the experiment at levels down to
0.0006 nCi/kg, which is equivalent to the occupationally permissible
body burden for man.
A number of long-term studies in rodents have also pointed to
osteosarcoma as the most sensitive indicator of plutonium in the skeleton,
Figure 16. The incidence of osteosarcoma is plotted against cumulative
radiation dose to bone. For each datum point 95 percent binomial confidence
limits are shown. Each point represents a group of animals at a given
dose level; each type of symbol represents a given experiment. The
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- 186 -
open circles represent the Utah dogs and are quite clearly a separate
population from the rodents. From these kinds of data, Mays and Lloyd,
assuming a time-independent linear dose-response relationship, have
calculated an increased incidence per rad of 0.38 percent for beagles,
0.10 percent for mice, and 0.06 percent for rats. Although few data are
available, it appears that doses greater than those which caused bone
cancer in dogs do not cause bone cancer in miniature swine.
Of more interest than absolute incidence figures and their uncertain
extrapolation to man, is the finding in the Utah studies that plutonium-239
is 5 to 10 times more toxic than radium-226, on the basis of the same
total energy delivered to bone. This difference is attributed to the
more hazardous localization of plutonium on bone surfaces, whereas
radium is distributed more uniformly throughout bone. The cells from
which bone tumors originate are located near bone surfaces.
OOQ
The inhalation of Pu02 nas n°t led to the development of osteogenic
sarcomas in experimental animals. However, osteogenic sarcomas have
238
occurred in dogs after inhalation of PuOo» Table 9. These occurred
238
as a result of the translocation of Pu from the lung to bone, which
received a higher radiation dose than the lungs. Lung cancer was a
secondary finding in one of these dogs. Another dog had leukemia and
fibrosarcoma as well as osteosarcoma.
LIVER
Liver is comparable to bone and lung in terms of transuranic content
and radiation exposure. However, the liver appears to be less sensitive
than bone and lung to the carcinogenic action of alpha radiation.
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480
- 187 -
Malignant liver tumors were the primary cause of death in two of 96
plutonium dogs at risk in the Utah experiment. Small, benign bile duct
tumors were incidental findings at autopsy in eight other dogs, but
these were also seen in controls at a somewhat lower incidence. The
liver tumors had a longer latent period than bone tumors which might
explain the lower incidence. Because of this, the possibility remains
that liver tumors might predominate at lower doses.
LUNG
Inhalation of relatively soluble plutonium compounds such as organic
O OQ
complexes, plutonium nitrate, and Pu02 has resulted in primary lung
cancer in rodents, rabbits, and dogs in addition to the bone cancer
253
already mentioned. Lung cancer has also occurred in rats given EsCl_
244
by intratracheal instillation and in rats after inhalation of CmOx,
24^Cm(N03)3, 38Pu(N03)4, Am(N03)3, or Am02. Lung cancer has also
been observed in beagle dogs, baboons, and rodents after inhalation of
The experimental data on plutonium-induced lung cancer are shown
in Figure 17, with tumor incidence in percent plotted against the lung
dose in rads. These are rat, mouse, and rabbit data except for the
results from one dog study represented by the square symbols. The dogs
seem to be more susceptible than the rodents; however, there are no dog
data below about 1000 rads. Some of the low incidence data are of
uncertain significance because there was a low incidence of lung tumors
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- 188 -
in the controls of some of the experiments. For both lung and bone
tumors, the lowest dose at which a clearly significant affect has been
observed is about 30 rads.
253
In rats given EsClo by intratracheal instillation, the malignant
lung tumor incidence was 4 percent for a lung dose of 38 rads and 12.5
percent for a lung dose of 1900 rads. The incidence of osteogenic
sarcomas in these animals was 42 percent at 230 rads and zero at 5 rads.
239
In comparison with soluble forms of the 24,000 year half -life Pu, the
253
20.5 day half-life Es was less efficient in producing lung cancer and
more efficient in causing bone cancer, providing some basis for speculating
on the dose rate effects of alpha radiation (Ballou et al., in press).
Other experiments are in progress in the United States and abroad
to determine the carcinogenic response of inhaled curium and americium
239
relative to Pu and Pu. Squamous cell carcinomas and bronchiolo-
alveolar carcinomas are being observed in these experiments.
Preliminary results from several laboratories indicate that the
transuranics readily induce lung cancer in rats. However, these same
laboratories find that Syrian hamsters tend to be much less sensitive to
the carcinogenic action of the alpha-emitting transuranium elements than
rats. This is in contrast to results being obtained in other laboratories
210
with Po introduced by intratracheal injection which show a high incidence
of lung cancer.
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482
The available data on plutonium-induced lung cancer has been analyzed
to describe mathematically the relationship between cancer incidence and
radiation dose. Although other models may have equal merit, a logarithmic
probit curve was selected based on its long usage in toxicology. In
Figure 18, arithmetic representations of the fitted function are shown
by heavy lines for probit curves and linear regressions. Dotted lines
show a limited extrapolation of the fitted functions.
This analysis indicates the current status of information on plutonium-
induced lung cancer. Studies now in progress are adding substantially
to our understanding of the dose-effect response.
LYMPH NODES
It was shown that plutonium accumulates in lymph nodes following
deposition of plutonium in the respiratory tract. Months or years after
the contaminating event, lymph nodes may attain concentrations of plutonium
many times the average concentrations remaining at the site of deposition
and consequently the accumulated radiation dose to some lymph nodes may
be greater than to any other tissue. The fact that the biomedical
significance of plutonium concentrations in lymph nodes is unknown is a
major concern in establishing permissible limits for plutonium.
239
Although dogs have been studied for 11 years after inhaling PuC>2
and rodents have been studied in life span experiments after inhalation
of a variety of plutonium and other transuranic compounds, primary
cancer of lymphatic tissue has not occurred. In dogs which had primary
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- 190 -
483
cancer, metastasis to mediastinal lymph nodes and lymphatics occurred,
but only one dog had a possible malignant lymphoma and this was confined
to the mesenteric and mandibular lymph nodes. Therefore, it can be
concluded that the lymph nodes are not especially susceptible to the
carcinogenic action of alpha radiation from plutonium.
RELATIVE SENSITIVITY OF DIFFERENT SEGMENTS OF THE POPULATION
An important question relevant to the establishment of exposure
standards for radiation or other potentially hazardous agents is whether
all segments of the population are equally sensitive. Research on this
question relative to the transuranics has not been extensive; however,
some information has been gained from experiments with rats.
Effect of Age on Osteogenic Sarcoma Response to Plutonium
Studies of rats given plutonium intravenously indicate that the
newborn and weanling may be slightly more sensitive than the adult to
plutonium-induced osteosarcoma, Figure 19. The decreased incidences at
the higher doses for the weanlings and newborns are probably due to
shortened life spans for these groups which did not allow the full
cancer potential to be expressed. However, the high dose adult group
also showed a significantly shortened life span and still had a high
incidence of bone cancer (50 percent).
253
A similar study with Es did not indicate a difference in the
incidence of osteogenic sarcoma between the adult and weanling groups at
bone doses of 100, 500, and > 2000 rads (D. D. Mahlum, personal communication).
-------
484
The Effect of Iron Deficiency
Iron deficiency is common in the human being particularly in pregnant
women, pre-menopausal women, and in young children. Because of the
metabolic relationship between iron and the transuranics in the blood,
iron deficiency could have a bearing on the distribution and subsequent
biological effects of the transuranics. In an experiment with mice
rendered iron deficient it was found that deposition of intravenously
injected plutonium in bone of the iron deficient mice was much greater
than in the controls. This suggests that persons deficient in iron
could have an increased susceptibility to plutonium-induced osteosarcoma.
Iron deficiency did not affect the deposition of plutonium in gonads
(H. A. Ragan, personal communication).
THE "HOT PARTICLE" ISSUE
It was recognized in the early 1940's that plutonium particles
deposited in the lung would irradiate cells in the immediate vicinity of
the particle rather than the entire lung. This gave rise to the concern
that plutonium particles might be exceptionally efficient in causing
lung cancer. Research during the past nearly 30 years has provided no
evidence for an enhanced effect of the localized radiation dose from
plutonium. Although not conclusive, experimental results to date suggest
that plutonium particles might be less hazardous than the same amount of
plutonium distributed throughout the lung because many fewer cells would
be exposed to alpha radiation. However, experiments to resolve this
question are technically difficult because inhaled plutonium does not
-------
- 192 - 485
distribute throughout the lung but tends to aggregate. Also, such
experiments require life time studies with large numbers of animals. A
few experiments which bear on the issue have been completed with several
transuranic compounds, others are still in progress.
OOQ
Rats exposed to relatively non-particulate soluble Pu which was
highly dispersed during its relatively short residence time in the lung
developed a higher incidence of lung cancer than has been observed for
OOQ 239
more particulate Pu and Pu sources (Sanders, 1973). The implication
o no
is that the dispersed Pu exposed more cells to the carcinogenic
action of the alpha radiation than particulate plutonium.
In France the influence of non-uniform distribution of alpha radiation
238
in lung is being studied in about 700 rats exposed to Pu(NO~)>,
239Pu(N03)4, 239Pu02, 241Am(N03)3, 241Am02, or 244Cm(N03)3. Of these
244
transuranics, Cm was the most uniformly distributed throughout the
lung and was most effective in reducing survival time followed in descending
order by 238Pu, 241Am, 239Pu(N03)4> and 239Pu02 which was the most
heterogenously distributed (LaFuma et al., in press).
e\ i i
The relatively uniform distribution of Cm in lung is illustrated
by the autoradiogram in Figure 20. This can be compared with the more
239
aggregated Pu(NO ) in Figure 21. Although the experiment is not yet
3 4
completed, nearly 200 squamous cell carcinomas and bronchiole-alveolar
carcinomas have been observed. The authors report that the results to
244
date indicate that for lung cancer induction, Cm, the most widely
-------
486
- 193 -
dispersed alpha emitter, is more effective than the more particulate
transuranics. Again, the implication is that more cells are exposed to
244
the alpha radiation from the dispersed Cm than from the other less-
dispersed transuranics.
Another experiment was designed specifically to address the "hot
particle" issue at the Los Alamos Scientific Laboratory (Richmond and
Voelz, 1972, Anderson et al., 1974). It is impossible to distribute
alpha emitting sources uniformly throughout the lung by inhalation
exposure due to the tendency for such material to be mobilized and
aggregated by clearance processes. Therefore, 10 am zirconium oxide
microspheres containing PuO~ at specific activities corresponding to
respirable particles were given intravenously to hamsters. The micro-
spheres were observed to be firmly fixed in the lung vasculature and were
highly dispersed throughout the lung. By varying the quantity of Pu in
the microspheres the microdistributiori of the radiation dose could be
controlled. A total of over 2000 hamsters have been given 2000 to
1,600,000 microspheres ranging in activity from 0.07 to 59 pCi per
microsphere. Total lung burdens range from 0.14 nCi to 354 nCi. This
study is still in progress. However, nearly 1200 animals have lived
their full life span or have been sacrificed. These animals were given
a total of about 5.7 x 10 microspheres, each containing in excess of
0.07 pCi. Three malignant tumors were observed. This suggests a tumor
risk of about 10 per particle. The preliminary results from this
study do not suggest that particulate sources are more hazardous than
equivalent less-particulate sources.
-------
- 194 -
In this experiment and in other experiments with plutonium particles,
the lack of significant histopathology in areas adjacent to the particles
is a common finding. An example is shown in Figure 22 which is an
239
autoradiograph of a section from a lung of a rat given PuC>2 by intra-
peritoneal injection (Sanders, in press). From 0.2 percent to 2 percent
of the plutonium was phagocytized and transported to the lung where the
particles lodged in 'the vasculature similar to the microsphere experiment
with hamsters. The lungs of these rats surprisingly showed little
evidence of pulmonary pathology that could be attributed to the plutonium.
The radiation doses to the lungs of the several groups of a total of 151
rats were 10, 20, 40, 170, and 600 rads. Only one lung tumor occurred;
this was observed after 823 days in one rat of 36 which had a lung dose
of 10 rads.
Another example of Pu particles residing in lung which shows no
evidence of histopathology is illustrated in Figure 23. This is an
autoradiograph of a histologic section from a lung of a dog about 2
239
years after inhalation of Pu02 showing several particles in areas of
normal lung. Other sections of the lung from this dog showed evidence
of plutonium-induced changes. However, normal appearing areas such as
this containing plutonium particles, are not uncommon in animal experiments.
The pathogenesis of plutonium induced neoplasia is not fully understood.
However, observations made during the past 10 years, suggest that phagocytosis
of the plutonium particle is one of the steps leading to necrosis and a
connective tissue response such as fibrosis and/or an epithelial response
such as hyperplasia, metaplasia, and eventually neoplasia.
487
-------
488
In agreement with the observations from studies of plutonium and
other transuranics deposited in lung are the results from a recent study
of the incidence of chromosome aberrations in the liver as a function of
239
the size of the PuC>2 particle administered. For the same total
quantity of plutonium administered, the more uniform dose was more
effective in producing chromosome aberrations than the more localized
doses (Brooks et al., 1974).
The "hot particle" issue continues to be the subject of controversy
and will not be settled to everyone's satisfaction until more of these
difficult and expensive experiments are completed. However, the results
of relevant experiments at laboratories in the United States, France,
and the United Kingdom have led the scientists conducting the experiments
to believe that particulate alpha emitting transuranics in the lung do
not represent a higher risk of lung cancer than the equivalent quantity
of relatively non-particulate transuranium elements distributed
throughout the lung (LaFuma et al., in press; Dolphin et al., 1974).
COUNTERMEASURES FOR INHALED PLUTONIUM
An important consideration in evaluating the potential health
effects of plutonium is the availability of effective countermeasures
for plutonium exposures. Since no acceptable therapy exists for radiation
exposures, the only really effective countermeasure for inhaled transuranics
is their removal from the body. Inhaled insoluble plutonium is not
effectively mobilized by a wide variety of agents which have been tested.
-------
489
The most effective method for removing plutonium from the lung is lavage
with isotonic saline. In rats, dogs, and baboons about 50 percent of
the lung burden can be removed by lavage.
A chelating agent, Diethylenetriaminepentaacetic acid (DTPA), has
had wide application for treating persons occupationally exposed to
plutonium. It reduces the liver burden and, to a lesser extent, the
bone burden causing an increased urinary excretion of plutonium. DTPA
has also been found to be effective in reducing the systemic burden of
Am, Cm, and Es. However, it is not effective in removing insoluble
transuranics from lung or lymph nodes.
Therefore, it must be recognized that truly effective counter-
measures for transuranic contamination have not yet been found, and that
for all practical purposes transuranics deposited in the body will
remain there until removed by natural processes, most of which are very
slow. The development of therapeutic procedures for removing transuranics
from the body are high priority research projects in several laboratories.
SUMMARY AND CONCLUSIONS
STATUS OF CURRENT RESEARCH
Research relevant to the problem of low level exposures to transuranium
elements has increased significantly during the past 10 years. Life
span animal studies of the biological effects of the transuranium elements
have greatly expanded. The current status of our knowledge of plutonium
is shown in Figure 23. The dose levels at which major biological effects
have been observed in experimental animals are shown relative to the
-------
490
- 197 -
maximum permissible lung burden of 0.016 p,Ci for occupational exposures.
Lung cancer has been observed at dose levels equivalent to about 100
times the maximum permissible lung burden. Current experiments are
directed towards determining whether health effects will occur at lower
levels. However, because of the cost in terms of time and money of such
experiments, the most productive research may be that which is directed
towards understanding the mechanisms by which alpha emitters induce
cancer. Some of these studies are in progress and more are anticipated.
RESEARCH IN PROGRESS
Research is in progress in several laboratories in the United States
and abroad to examine the late effects of low levels of transuranic
elements. Three dog studies are in progress in the United States. At
the University of Utah the late effects of transuranics are being studied
after intravenous administration, Table 10. This study is primarily
directed at effects in bone and liver. At the Lovelace Foundation dogs
238 239
are being exposed to monodisperse aerosols of Pu and Pu, Table 11.
A total of 360 dogs are being given single exposures to plutonium aerosols
with particle sizes ranging from 0.75 to 3 p-m aerodynamic diameter.
Initial lung burdens range from 0.1 to 5.6 \id.
At Battelle-Northwest 221 dogs have been exposed to polydispersed
238 239
aerosols of Pu02 and Pu02, Table 12. Initial lung burdens ranged
from 0.002 |iCi to 5 p-Ci.
In addition to these major dog experiments, all of the available
transuranics are being studied in thousands of rats and hamsters following
inhalation, ingestion and intravenous injection. These long term animal
-------
491
experiments are being supplemented by increasing levels of research to
develop a better understanding of how alpha radiation from the transuranium
elements causes cancer and other possible health effects.
No significant surprises are expected from this intensified research
effort. However, the results will help us sharpen our predictions of the
health consequences of the expected increased utilization and availability
of the transuranium elements.
-------
492 -
References
Anderson, E. C., Holland, L. M., Prine, J. R., and Richmond, C. R.,
"Lung Irradiation with Static Plutonium Microspheres," In: Experimental
Lung Cancer, Carcinogenesis and Bioassays, Springer-Verlag, Heidelberg,
in press, CONF-740648-1, 1974.
Bair, W. J., and Thompson, R. C., "Plutonium: Biomedical Research,"
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Bair, W. J. , "Toxicology of Plutonium," In: Advances in Radiation
Biology, Vol. 4 (J. T. Lett, H. Adler, and M. Zelle, Eds.), Academic
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Bair, W. J., Richmond, C. R., and Wachholz, B. W., "A Radiobiological
Assessment of the Spatial Distribution of Radiation Dose from Inhaled
Plutonium," USAEC, WASH-1320, Sept., 1974.
Bair, W. J., "Consideration of Reactor Accident Exposure Guides for
Plutonium," In: Conference on Fast Reactor Safety (CONF-740401).
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Bair, W. J., "The Effects on Populations of Exposure to Low Levels
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Ballou, J. E., Dagle, G. E., and Morrow, W. G., "The Long-Term Effects
of Intratracheally Instilled 253gsci j_n Rats," Radiation Res. (in press)
Buldakov, L. A., Lyubchansky, E. R., Moskelev, Y. I., and Nifatov, A. P.,
(1969), In "Problemy Toksikologii Plutoniya," Atom Publications,
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Brooks, A. L., Retherford, J. C., and McClellan, R. O., "Effect of
239puc-2 Particle Number and Size on the Frequency and Distribution
of Chromosome Aberrations in the Liver of the Chinese Hamster,"
Radiation Res. 5_9, No. 3, Sept., 1974.
Dolphin, G. W., Smith, H., Popplewell, D. S., Stather, J. W., Adams,
N., Spoor, N. L., Brightwell, J., and Bulman, R. A., "Radiological
Problems in the Protection of Persons Exposed to Plutonium," Document
NRPB-R29, National Radiological Protection Board, Harwell, England,
1974.
Healy, J. W., (1974), "Contamination Limits for Real and Personal
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-------
- 200 -
493
Hodges, H. C., Stannard, J. N., and Hursh, J. B. - Editors, Uranium,
Plutonium, Transplutonic Elements Handbook of Experimental Pharmacology
XXXVI, Springer-Verlag, New York, 1973.
Hungate, F. P., Ballou, J. E., Mahlum, D. D., Kashima, M., Smith, V. H.,
Sanders, C. L., Baxter, D. W., Sikov, M. R., and Thompson, R. C., "Pre-
liminary Data on 253Es and 249sk Metabolism in Rats," pp. 653-656. In:
Biological Implications of the Transuranium Elements, R. C. Thompson and
W. J. Bair (eds.), Health Physics, Vol. 22, June 1972.
LaFuma, J., Nenot, J. C., Norin, D., Masse, R., Detivier, H., Nobile, D.,
and Skupinski, W., "Respiratory Carcinogenesis in Rats after Inhalation
of Radioactive Aerosols of Actinides and Lanthanides in Various Physico-
chemical Forms," Symposium on Experimental Respiratory Carcinogenesis and
Bioassays, Seattle, WA, 1974 (in press).
Mahlum, D. D., Sikov, M. R., "Influence of Age on the Late Effects of
Plutonium-239 in Rats," Radiat. Res. 59, 171, (abstract), 1974.
Mahlum, D. D., and Sikov, M. R., "Distribution and Toxicity of Monomeric
and Polymeric 239Pu in Immature and Adult Rats," Radiat. Res. 60, 75-88,
1974.
McClanahan, B. J., Ragan, H. A., and Mahlum, D. D., "Plutonium Metabolism
in Newborn and Weanling Pigs," Radiat. Res. 59. 171, (abstract), 1974.
McClellan, R. 0., Boyd, H. A., Gallegos, A. F., and Thomas, R. G.. "Retention
and Distribution of ^Cm Following Inhalation of 2/wCmCl3 and 2^CmOi.73
by Beagle Dogs," Health Physics. Vol. 22, pp. 877-885, 1972.
McClellan, R. 0., "Progress in Studies with Transuranic Elements'1 at
the Lovelace Foundation, Health Physics, Vol. 22. pp. 815-822, 1972.
Park, J. F., Catt, D. L., Craig, D. K., Olson, R. J., and Smith, V. H.,
Solubility Changes of 238pu Oxide in Water Suspension and Effect on
Biological Behavior after Inhalation by Beagle Dogs, pp. 719-724, In:
Third International Congress of the International Radiation Protection
Association. Vol. 1, W. S. Snyder (ed.), (CONF-730907). NTIS, Springfield,
VA, 1974.
Park, J. F., Lund, J. E., Ragan, H. A., Hackett, P. L., and Frazier,
M. E., "Inhaled 238puO -Induced Bone Tumors in Dogs," presented at Bone
Tumor Conference, Dusseldorf Germany, 1974.
Park, J. F., "Late Effects of Inhaled Plutonium in Dogs," Fifth International
Congress of Radiation Research, Seattle, WA, July 14-20, 1974 (in press).
-------
494 - 201 -
Richmond, C. R., Langhan, J., and Stone, R. S., "Biological Response to
Small Discrete Highly Radioactive Sources," Health Physics Vol. 18,
pp. 401-408, 1970.
Richmond, C. R. and Voelz, G. L., eds., Annual Report of the Biological
and Medical Research Group (H-4) of the LASL Health Division, January
through December 1971, Los Alamos Scientific Laboratory report LA-4923-PR,
pp. 18-34, April, 1972.
Richmond, C. R., and Voelz, G. L., eds., Annual Report of the Biological
and Medical Research Group (H-4) of the LASL Health Division, January
through December 1972, Los Alamos Scientific Laboratory report LA-5227-PR,
pp. 1-11, March, 1973.
Richmond, C. R., and Sullivan, E. M., eds., Annual Report of the
Biomedical and Environmental Research Program of the LASL Health
Division, January through December 1973, Los Alamos Scientific
Laboratory report LA-5633-PR, pp. 1-9, May, 1974.
Richmond, C. R., and Thomas, R. L., "Plutonium and other Actinide
Elements in Gonadal Tissue of Man and Animals." Accepted for publication
in Health Physics (in press).
Sanders, C. L., and Adee, R. R., "The infrastructure of Mononuclear
Phagocytes following Intraperitoneal Administration of 239puQ2
Particles," J. of the Reticuloendothelial Soc. Vol. 6, No. 1, Feb., 1969.
Sanders, C. L., "Carcinogenicity of Inhaled Plutonium-238 in the Rat,"
Radiat. Res. 56, 540-553, 1973.
Sanders, C. L., Thompson, R. C., and Bair, W. J. (1970), "Lung Cancer:
Dose Response Studies with Radionuclides," In: Inhalation Carcinogenesis,
(M. G. Hanna, Jr., P. Nettesheim, and J. R. Gilbert, eds.), CONF-691001:
285, AEG Symposium Series No. 18, U.S. Atomic Energy Commission, Office
of Information Services, Springfield, VA.
Sanders, C. L., "Effects of PuC>2 Particles Deposited in the Lung Following
Intraperitoneal Injections" Health Physics (in press).
Sanders, C. L., and Dagle, G. E., "Studies of Pulmonary Carcinogenesis in
Rodents Following Inhalation of Transuranic Compounds," Symposium on
Experimental Respiratory Carcinogenesis and Bioassays, Seattle, WA, 1974,
(in press).
-------
- 202 -
495
239
Sikov, M. R., and Mahlum, D. D., "Influence of Age on Pu Distribution,
Dosimetry, and Effects." Trans. Amer. Nuclear Soc. 18, 389, (abstract)
1974.
Smith, V. H., "The Biological Dispostion of £3(^3)3 in Rats after
Intravenous, Intramuscular and Subcutaneous Administration," pp. 725-
730, In: Third International Congress of the International Radiation
Protection Association, Vol. 1, W. S. Snyder (ed.), (GONF-730907).
NTIS, Springfield, VA, 1974.
Stover, B. J., "Dose-Response Relationships for Beagles Injected with
239Pu(IV) or ^lAm(III)" Fifth International Congress of Radiation
Research, Seattle, WA, July 14-20, 1974 (in press).
Thomas, R. G., McClellan, R. 0., Thomas, Randi L., Chiffelle, T. L.,
Hobbs, C. H., Jones, R. K., Mauderly, J. L., and Pickrell, J. A.,
Health Physics Vol. 22. pp. 863-871, 1972.
Thompson, R. C., "Effects of Plutonium in Animals," Presentation before
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Exposure Limits, Fifth International Congress of Radiation Research,
Seattle, WA, July 14-20, 1974 (in press).
-------
496
- 203 -
Acknowledgement: The author is indebted to the staff
of the Biology Department, Battelle, Pacific Northwest
Laboratories; to Dr. E. C. Anderson, Health Division,
Los Alamos Scientific Laboratory; and to Dr. C. H. Hobbs,
Inhalation Toxicology Research Institute, Lovelace
Foundation for results from current research and for
future research plans at their respective laboratories.
-------
- 204 -
497
RETENTION OF PLUTONIUM IN PULMONARY REGION
OF LUNG
ANIMAL
ISOTOPE COMPOUND SPECIES
238pu
0 200 400 600 800 1000
LUNG RETENTION HALFTIME (DAYS)
Figure 1
-------
498
The attached tables were inadvertently omitted
from the original printing of the AEC testimony. They
are included here in the record however.
-------
499
TABLE 1
Gastrointestinal Tract Absorption of
Transuranics in Rats
(percent of Administered Dose)
Transuranic
233U
237NP
238Pu
239Pu
241Am
244Cm
249Bk
252Cf
253ES
Compound
Nitrate
Nitrate
Nitrate
Nitrate
Chloride
Oxide
Nitrate
Chloride
Oxide
Nitrate
Chloride
Oxide (aged in H^O)
Oxide (fresh)
Chloride
Nitrate
Nitrate
Chloride
Newborn
7
1
2
0.3
-
-
9
-
0.5
6
-
2
0.3
-
4
4
-
Adult
0.2
0.9
0.03
0.003
0.007
0.0001
0.07
0.03
0.01
0.2
0.05
0.1
0.03
0.01
0.1
0.03
0.06
Information in this Table was developed from published reports and
from results of current research at PNL by M. F. Sullivan.
-------
500
TABLE 2
Absorption of Pu and Es through Intact Skin
Pu or Es Compound
Pu(N03)4 in 10 N HN03
Pu-tributyl phosphate in
CC14
Pu(N03)4 in C.I N HN03
Pu(N03)4 in 10 N HN03
Pu(N03)4
Pu citrate
Pu in 9% HC1 + EDTA
Pu(N03)4 in 0.4 N HN03
Es(N03)3 in 0.01 N HN03
Animal
Species
rat
rat
rat
rat
rabbit
swine
man
man
rat
Duration of
Exposure
1 hour
15 min
5 days
5 days
14 days
10 days
-
1 hour
7 days
Percent
Absorbed
0.05
0.04
0.1-0.3
1-2
0.15
0.25
0.01
0.002
0.05
-------
501
TABLE 3
Relative Concentrations of Plutonium in Tissues of
Dogs 7-9 Years After Inhalation of 239pu02
Relative Concentration
Tissue of Plutonium
Lung 1
Thoracic Lymph Nodes 1400
Abdominal Lymph Nodes 100
Liver 0,5
Spleen JO. 2
Bone 0.06
-------
502
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-------
503
TABLE 5
Deposition of Plutonium in Gonads
Percent of
Pu in Blood
Testes 0.05
Ovaries 0.01
From C. R. Richmond and R. L. Thomas - in press
-------
504
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-------
TABLE 7
Hematologic Effects of Transuranic Elements
505
Isotope
I.V.
226Ra
239Pu
228Th
228Ra
241Am
249Cf
253£s
253Es
242Cm
Inhaled
239Pu
238Pu
241Am
Species
dog
dog
dog
dog
dog
dog
dog
pig
dog
dog
dog
dog
Dose
(yCi/kg) RBC
.06-10.4 +
.02-2.9 +
.02-2.8 +
.05-8.5 +
.02-2.8 +
2.8
2.9 4 t
3.0
2.6 4 t
.08-5.8*
.14-5.4*
^25
Neutro Lymph
4 t 4
4- t 4
4- 4-
4- 4-
1 4-
4 t 4
4- t 4 t
4 t
4 t 4
4
+ 4-
4 4-
Mono
4 t
4- +
4- t
4- t
4- t
4- t
4 t
4- t
4- t
-
4
EOS
4 t
4- t
4-
4
4
4 t
4 t
4- t
4-
-
\
*Initial Lung Burden
^Depression at highest doses only
4-Sustained depression
4'tDepression with evidence of recovery
-No effect
(Summary of published and unpublished data provided by H. A. Ragan, PNL)
-------
506
TABLE 8
Plutonium-Induced Bone Cancers
in Utah Dog Study
Injected Dose Cancer Dose to
(yCi/kg) Incidence Bone of Cancer Dogs
(RAD)
2.9 7/9 = 78% 4900
0.9 12/12 = 100% 1300
0.3 12/12 = 100% 600
0.1 10/12 = 83% 310
0.05 9/13 = 69% 190
0.016 4/13 = 31% 78
Controls 0
-------
TABLE 9
ono
Osteosarcoma in Dog: after Inhalation of PuO
507
Plutonium Distribution
(% of Body Burden)
238PuO?
Calcined at 350°C
Crushed microspheres
Survival
Time
(Months)
23-70
22-76
Terminal
Body Burden
(yCi) Lungs
2.6-3.0 17
0.2-3 20
Thoracic
Lymph
Nodes Liver
9 23
12 16
Osteo-
Bone sarcoma
47 5/8*
24 4/8**
* 1 lung tumor
** 1 myelogenous leukemia and 1 fibrosarcoma
(Park et al., in press)
-------
508
o
-C
to
•*->
to
0>
•o
OJ
o
OJ
CO
3
O
C
Ol
CO
CO
OJ
oo
C
Q.
OJ C
i«- (O
(O
S-
to
CO
CD
O
Q
10
+J
<0
o
>-
vo co
VO
CM VO IO
CO
V£> VO
3
TD
(O
D1
C
O
14-
(_>
CT>
CM
,=
CO CO
* > _lny
3 3
•o -a
ro (^}
CJ> CD
C C
0 0
14- CO
O UJ
CM CO
CM CM
CO
CD
O
T3
VO
ID
CO
1
g
•U
CO
3
CD
3
*
-------
509
TABLE 11
Life Span Study of Inhaled Plutonium
In Oogs at Lovelace
Particle Size* Initial Lung Burden
(urn) (uCi) Number of Dogs
1 72
72
72
72
72
238Pu02
238PU0.
2
239PuO,
i.
239Pu02
239PuO-
2
1.5 5.6, 3, 1.4, 0.7, 0.3,
3.0
0.75
1.5
3!0
360 + 60 controls
*Aerodynamic diameter of monodisperse aerosols
-------
510
TABLE 12
Life Span Study of Inhaled Plutonium in
Dogs at Battelle-Northwest
23V6o2
Initial Lung Burden
(nCi)
.002
.02
.08
.35
1.3
5.2
No. of Dogs*
20
20
20
20
20
13
113
239Pu02
Initial Lung Burden
(yCi)
.004
.02
.08
.3
1.1
5.8
No. of Dogs*
20
20
20
20
20
8
108
*Half male and half female + 40 controls
-------
- 205 -
511
PULMONARY RETENTION OF INHALED PuO2 IN DOGS
1000
- 800
o
W5
600
400
200
1000° 350° 450° 123° 900'
-238puQ2-
750°
2.8 2.8 4.8 1.3 .12
PARTICLE SIZE, MMD (//m)
.1
Figure 2
Pulmonary Retention of Inhaled PuCL in Dogs
-------
512
- 206 -
100
Ctf —
CD o
O t-
50
10
RETENTION OF TRANSURANICS IN RAT LUNGS
238 239 241 242
"°Pu, Pu, Am, and Cm INHALED AS
NITRATES
'EsCI3 - INTRATRACHEALLY INSTILLED
i i i i i
239
Pu
50
TIME AFTER EXPOSURE. DAYS
100
Figure 3
Retention of transuranium elements in rat lungs (238pU)
239pUj 241/\m ancj 242cm - Nenot et al., 1972; 253EsCl3 -
Ballou et al., submitted for publication)
-------
- 207 -
513
LUNG RETENTION OF INHALED
TRANSURANIC ELEMENTS IN BEAGLE DOGS
100
10
CO O
O t=
£ 1.0
0.1
244
CmCI
23%02-3500C
J I
400 800
TIME AFTER EXPOSURE, DAYS
1200
Figure 4
(Redrawn from R. 0. McClellan, 1972)
-------
514
- 208 -
'ViC*
V,v-
*y'* ra*®>A>?
tfv v* / v^ <
^>*x*'-
t*fc
Figure 5
Autoradiograph showing particulate and non-
particulate plutonitun in lung of a rat immediately
after inhalation of 239pu(N03)4
(Provided b.y J. E. Ballou, PNL)
-------
- 209 -
&, *.'/ '
**^lg. ft V
\.J8B *
515
Figure 6
Autoradiograph of a histologic section from a
rat lung 7 days after inhalation of "3Es(N03)3
(Provided by J. E. Ballou, PNU PNL747349-7
-------
516
- 210 -
/.*
ȣ
1-
Figure 7
Electromicrograph of plutonium dioxide particles (inset)
from an aerosol inhaled by rats and of a cell from the lung
of an exposed rat. The dense appearing material in the cell
is plutonium dioxide which had been engulfed by the cell.
(Provided by C. L. Sanders and R. P. Adee, PNL) PNL0673470-5
-------
- 211 -
517
r
n»m
.**»•• p
V' , ' '.S
J* / v
-
Figure 8
238
Autoradiograph showing aggregation of Pu in a lung
of a rat 100 days after inhalation of 238Pu(N03)4.
(Provided by J. E. Ballou, PNL) PNL747349-3
-------
518
- 212 -
Figure 9
239
Autoradiograph showing Pu02 particles in a subpleural
area of lung from a dog. (provided by G. E. Dagle, PNL)
PNL747349-2
-------
** . ;
- 213 -
519
4«^
\f
% 1
4*1
V1*
Figure 10
238
Autoradiograph showing Pu particles in
lung of a dog 5 years after inhalation of
(Provided by J. E. Lund) PNL747349-6
jr tissue in a
-------
520
- 214 -
DISTRIBUTION OF PLUTONIUM IN DOGS AFTER
INHALATION OF 239Pu(NO3)4
-3 TOO
o
z
r? 80
UJ H
D W 60
52 Q-
*
\
\
I- \
OfiC
40
*2 20
o
LL
LUNG
• BONE
_JL.
LIVER
100 200 300
TIME AFTER EXPOSURE (DAYS)
Figure 11
-------
- 215 -
521
DISTRIBUTION OF PLUTONIUM IN DOGS AFTER
INHALATION OF 239puQ2
THORACIC LYMPH NODES
ABDOMINAL LYMPH NODES
10
TIME AFTER EXPOSURE, YEARS
Figure 12
-------
522
- 216 -
DISTRIBUTION OF PLUTONIUM IN TISSUES OF DOGS
5 YEARS AFTER INHALING *«>PuO2 OR
- 100
LLI
O
CC
0)
a
o
m
0.
LLI
H
o
u
LLI
D
M
W
80
60
40
20
238Pu
LUNG
BONE
THORACIC
LYMPHNODES
ALL OTHER
TISSUES
Figure 13
-------
- 217 -
523
SKELETAL RETENTION OF INHALED TRANSURANIC
ELEMENTS IN BEAGLE DOGS
100 c
1
I 10
CO
o
§i
°° u.
O
LO -
0.1
244.
1.73
D c
Pu F
*puo-qooc
239pu 0, - 350°C
2
< 1% UNTIL AFTER 800 DAYS
400 800
TIME AFTER EXPOSURE, DAYS
1200
Figure 14
(Redrawn from R. 0. McClellan, 1972)
-------
524
- 218 -
EFFECT OF INHALED 239puQ2 ON BLOOD
LYMPHOCYTE LEVELS
GROUP
MEAN INITIAL
ALVEOLAR
DEPOSITION (fj Ci)
TIME (MONTHS AFTER EXPOSURE)
Figure 15
-------
- 219 -
525
PLUTONIUM-INDUCED OSTEOSARCOMA IN EXPERIMENTAL ANIMALS
100
* 80
o
fe 40
o
I
o
•z.
- 20
I.I II...1
10 100 1000
CALCULATED CUMULATIVE MEAN DOSE TO BONE (RADS)
10,000
Figure 1 6
Plutonium-induced Osteosarcoma in Experimental Animals.
Mean incidence and radiation dose values are those reported
in the literature. Binomial confidence limits were
calculated from data included in the referenced literature.
o 239Pu Citrate, Monomeric - IV - Dogs (from Jee, 1972)
A 239Pu Citrate - Inhaled - Rats (from Buldakov and Lyubchansky, 1970)
V 239Pu Plutonylpentacarbonate - Inhaled - Rats (from Buldakov and
Lyubchansky, 1970)
0 239Pu Nitrate - Sub- and Intracutaneous - Rats (from Buldakov, et al.,
1971)
239Pu Citrate - Oral (Daily) - Rats (from Buldakov et al., 1969)
239Pu Plutonyltriacetate - I.T. - Rats (from Erokhin et al., 1971)
239Pu Citrate - IV - Mice (from Finkel and Biskis, 1962)
D 239Pu Citrate, Monomeric - IV - Mice (from Rosenthal and Lindenbaum,
1967)
-------
526
- 220 -
H 239Pu Citrate, Polymeric - IV - Mice (from Rosenthal and
Lindenbaum, 1967)
X 238Pu02 - Inhaled - Rats (from C. L. Sanders, 1973)
* 239Pu Nitrate - I.T. - Rats (from Erokhin et al., 1971)
+ 239Pu Nitrate - I.T. - Rabbits )from Koshnurnikova et al.,
1971)
* 239Pu (Pentacarbonate) - Inhaled - Rabbits (from
Koshnurnikova et al., 1971)
^ 239Pu Citrate - Inhaled - Rats (from Koshnurnikova et al., 1971)
*" 239Pu Pentacarbonate - Inhaled - Rats (from Koshnurnikova
et al., 1971)
(See Bair, 1974 for complete references)
-------
- 221 -
527
PLUTONIUM-INDUCED LUNG CANCER IN EXPERIMENTAL ANIMALS
100
e>
60
o
UJ
§40
O
O
z
20
'li
10 100 1000
CALCULATED CUMULATIVE MEAN DOSE TO LUNG (RADS)
10,000
Figure 17
Plutonium-induced Lung Cancer in Experimental Animals
Mean incidence and radiation dose values are those
reported in the literature. Binomial confidence limits
were calculated from data included in the referenced
1iterature.
I 239Pu02 - Dogs (from Park and Bair, 1972)
V 239Pu02 - Mice (from Temple et al., 1959)
A 239Pu02 - Mice (from Temple et al., 1959)
* 239Pu02 - Mice (from Wager et al., 1956)
o 239Pu Citrate - Rats (from Buldakov and Lyubchansky, 1970)
• 239Pu - Plutonylpentacarbonate - Rats (from Buldakov and
Lyubchansky, 1970)
x 238Pn - Rats (from C. L. Sanders, 1973)
-------
528
< 239Pu - Rats - Pu(NOsK (from Erokhin et al., 1971)
+ 239Pu - Rabbits - Pu(N03K (from Koshnurnikova et al., 1971)
* 239Pu - Rabbits - NHf Pu Pentacarbonate (from Koshnurnikova
et al., 1971)
(See Bair, 1974 for complete references)
-------
- 223 -
529
PLUTONIUM INDUCED LUNG CANCER
WEIGHTED LINEAR REGRESSION
COMPARED WITH PROBIT ANALYSIS
100
90
80
70
s£
ttf
LLJ
^ 60
-------
530
- 224 -
OSTEOSARCOMA INCIDENCE IN FEMALE RATS
(815)
°\
(780)
(555)
A ADULT
W WEANLING
NB NEWBORN
0 MEAN SURVIVAL TIME
I
I
I
400 800 1200
SKELETAL RADIATION DOSE, RADS
1600
Figure 19
(D. D. Mahlum and M. R. Sikov, PNL, to be published
in Pacific Northwest Laboratory Annual Report for
1974) PNL747510-13
-------
- 225 -
531
Figure 20
Autoradiograph of a histologic section from a lung of a rat
after inhalation of 244Cm(N03)s. (Provided by J. LaFuma,
Commissariat a I1 Energie Atonrique, Association Euratom.
C.E.A. CEN. FAR. France.) PNL747596-4
-------
532
- 226 -
Figure 21
Autoradiograph of a histologic section from a lung of a
rat after inhalation of 239pu(N03)
-------
- 227 -
533
Figure 22
Autoradiograph of a histologic section from a lung
of a rat 356 days after intraperitoneal, injection
of 239pu02 particles. (Provided by C. L. Sanders,
PNL) PNL747358-1
-------
534
- 228 -
V* »> t
>'"'.
*
Figure 23
Autoradiogram of a histologic section from a lung of a
dog 2 years after inhalation of 239pu02. (Provided by
G. E. Dagle, PNL) PNL66199-1
-------
- 229 -
535
OBSERVED BIOLOGICAL EFFECTS OF INHALED
PLUTONIUM
MAXIMUM PERMISSIBLE
HUMAN LUNG ;". . .'."• LUNG HEMORRAGE & EDEMA
BURDEN
—0.016 n Ci - ~— RESPIRATORY INSUFFICIENCY
LUNG FIBROSIS
LYMPHOPENIA
LUNG CANCER
BONE CANCER
i ' 1
A-ACUTE DEATH
(DAYS TO WEEKS)
B-SUBACUTE DEATH
(WEEKS TO MONTHS)
C-CANCER (YEARS)
I 0.0001 \ 0.01 0.1 1.0 10
0.00001 0.001
INHALED DOSE (//Ci/GRAM LUNG)
Figure 24
-------
536
Thank you.
Dr. Mills: The next speaker is Dr. Burr.
-------
- 231 -
537
Biomedical Effects of Plutonium on Humans
by William W. Burr, Jr., M.D.
Deputy Director, Division of Biomedical
and Environmental Research
U. S. Atomic Energy Commission
Washington, D. C. 20545
part of the AEC presentation at
EPA Plutonium Standards Hearings
Washington, D.C., December 10-11, 1974
Although considerable data exists concerning the biological effects
of plutonium on experimental animals, comparatively little information is
available regarding the effects of plutonium and other actinide elements
on man. However, despite its limited availability, we regard the human
data as highly relevant.
The human data serves at least two purposes. First, it provides a
check on the metabolic behavior of the actinide elements in man as compared
to experimental animals. Secondly, the human observations will, in the
course of time, provide an improved basis for the guidelines and standards
under which the industry operates. The available data make us confident
that present exposure standards are not grossly inadequate and that the
experimental animal work can be accepted as relevant to the human situation.
However, the human data are far too limited at this time to permit more
specific conclusions to be drawn from them with respect to exposure limits.
Those individuals who have been exposed to and/or retained plutonium
for the longest periods of time are of particular interest. There are
three such groups. The first of these consists of those persons who have
-------
538 - 232 -
been occupationally exposed to plutonium at some time during their working
life. While some of these exposures occurred 30 years ago, others have
occurred more recently; it will be some time before these more recent
exposures will contribute to our store of knowledge in a meaningful way.
Industrial accidents during the Manhattan Project resulted in inhalation
exposures of a number of individuals to plutonium. Some of these persons
have maintained multiples of the maximum permissible body burden for nearly
three decades.
In addition to the depositions that date from the mid-forties, we know
of over 200 industrial exposures between 1953 and 1970 that resulted in
burdens of plutonium exceeding 2570 of the maximum permissible body burden.
Other exposures have occurred before and since the period covered by these
statistics. Although the exact levels of internal contamination are uncertain
in most such cases, it is evident that these exposures constitute a valuable
resource for current and future study. Some information has been obtained
already from particular groups of industrially exposed persons; other
studies are now being formulated and expanded to collect data from additional
members of that population.
A second source of valuable information is a group of 18 people, thought
to be hopelessly ill, who were injected with plutonium during and immediately
after the days of the Manhattan Project to study excretion and distribution
patterns in man. Data from these persons provided the basis for the
excretion equations developed by Dr. Wright Langham that have been used
in modified form to estimate plutonium body burdens in workers ever since then.
-------
" 233 " 539
A third population of interest is that of the world at large. The
general population has accumulated minute quantities of plutonium from
the fallout debris that resulted from nuclear testing in the atmosphere
and from the atmospheric burn-up of a thermoelectric generator. Study
of this population will give insight into the extent to which man takes up
plutonium from the biosphere.
Programs for the analysis of human tissues obtained at autopsy from
exposed workers and from non-occupationally exposed persons will in time
furnish much information regarding the efficiency with which man incorporates
plutonium into his body and will provide data regarding the distribution
of plutonium among the various body tissues. In the case of occupational
exposures these studies permit us to compare estimates of body burdens
based on analysis of urine specimens or external lung counting with
estimates based on actual analysis of tissues obtained from the same
individuals. These programs have been expanded in recent years.
In view of the fact that thousands of persons have been exposed or
potentially exposed to plutonium during the course of their work, it is
inevitable that some of those people who may have some lung or body burden
of plutonium will die of cancer, including lung cancer. When this occurs
it must be recognized that the appearance of common forms of cancer in
persons with plutonium burdens does not constitute proof that the deposition
is causally related to the disease. In order to establish whether or not
the number of such deaths exceeds our expectation for a comparable unexposed
population, our scientific resources will be taxed to the utmost. We are
now entering a period when the working population that was young during
the 1940's may be expected to develop a meaningful incidence of disease of
all kinds. Follow-up studies attempting to establish whether any detectable
-------
540
increase in relevant disease may be seen in the exposed populations will
become increasingly important.
Although the clinical follow-up of persons with burdens has been
reassuring, any conclusions with respect to late effects of plutonium
in man must remain tentative for some time. We can, however, state with
confidence that available data does not support the viewpoint that the
current radiation protection standards and guidelines which have been
followed for many years underestimate by many orders of magnitude the risk
due to plutonium deposition in man.
Dr. Richmond, Associate Director for Biomedical and Environmental
Sciences at the Oak Ridge National Laboratory, will summarize the data
obtained from the various populations that I have mentioned.
-------
- 235 -
541
Biomedical Effects of Plutonium on Humans
by C. R. Richmond
Oak Ridge National Laboratory
Oak Ridge, TN 37830
part of the AEC presentation at
EPA Plutonium Standards Hearings
Washington, D.C., December 10-11, 1974
INTRODUCTION
My name is Chester R. Richmond. I am the Associate Director for
Biomedical and Environmental Sciences at the Oak Ridge National Laboratory.
However, the views I express here are my own.
Plutonium was recognized as a potentially hazardous material soon
after its discovery in early 1941. The urgency to conduct biological studies
with plutonium was appreciated by several people, notably Dr. Seaborg, with
the hope that the unfortunate problems experienced with radium earlier in
the century would not be repeated. Within three years of the discovery
of plutonium ( Pu) in February, 1941, 0.5 g Pu had been separated from
the material produced by the Clinton pile and on 8 February 1944, Dr. J. G.
Hamilton and coworkers at Berkeley received about 10 mg to begin experimental
studies in rodents.
During late 1943 and early 1944, plutonium operations at Los Alamos
consisted of research activities involving milligram quantities of material.
During late 1944, gram quantities were processed in research activities
directed mainly toward the production of pure plutonium metal and investiga-
tion of its physical and chemical properties. By mid-1945, kilogram
quantities were processed as part of the effort to produce the nuclear com-
ponents for the Alamagordo and Nagasaki weapons. Some of our most
-------
542
- 236 -
relevant data as regards exposure of humans to plutonium comes from the
medical follow-up of the military personnel who worked with plutonium
at Los Alamos in 1944 and 1945.
Although we have accumulated a considerable amount of information on
the biological effects of plutonium on experimental animals, there is little
to be said of the data on effects in humans. Obviously, we should be
encouraged because of the lack of data on biological effects of plutonium
in man.
DEVELOPMENT OF MAXIMUM PERMISSIBLE BODY BURDEN (MPBB) FOR Pu
Throughout 1943 and the first nine months of 1944, a maximum permissible
body burden of 4-5 p,g was assumed to be an acceptable guide even though no
reliable method of estimating personnel exposure to plutonium had been
developed. The value was derived by using bone as the critical organ and
o 9 /:
making a direct comparison with the energy deposited from 0.1 p,g of Ra
fixed in the body (assuming 50% radon exhalation). Later, because of
apparent differences in bone deposition patterns between Pu and Ra in
rodents, a safety factor of about 5 was introduced, and the maximum permissible
body burden became 1 p,g. This value was used until the Tripartite Permissible
Dose Conference at Chalk River, Canada, in late September 1949, at which time
Dr. A. Brues presented experimental chronic toxicity data from rodents that
239 226
suggested Pu was 15 times more damaging than Ra when both were injected
in equivalent microcurie quantities. The conference recommended that the
MPBB be reduced to 0.1 |j,g.
Subsequent reexaminations of the experimental data led to a recommendation
239
of 0.6 p,g as the MPBB for Pu. This decision was based upon the following
239
observations related to the assumption that 0.1 |j,Ci of fixed Pu was
-------
-237- 543
equivalent to 0.1 p,Ci of fixed """Ra.
(1) The Pu:Ra toxicity ratio of 15:1 was based on the injection of
known amounts into rodents. Since~75% of the injected Pu was retained in
rodents while only -^25% of the Ra was retained, the ratio on the basis of
retained dose could be lowered by a factor of about 3.
(2) Because radon was about 50% retained in man and only about 15-20%
retained in rodents, the toxicity ratio could be lowered by another factor
of at least 2 on the basis of relative energy deposited.
Thus, strictly on the basis of biological data, the MPBB for man was
calculated to be:
(MPBB)pu = 0.1 x x ^ x | x Y = 0.6 |ig (0.04
As a result of this information, the AEC authorized 0.5 ug (0.033
OOQ
J Pu as the MPBB. In 1951, the International Commission on Radiological
Protection (ICRP) at a meeting in London recommended a value of 0.04 M-Ci
which was later endorsed at the Tripartite Conference on Permissible Dose
at Harriman, New York in March 1953. In the fall of 1953, both the National
Committee on Radiation Protection and Measurements (now the National Council)
739
and the ICRP recommended a MPBB of 0.04 p,Ci for Pu in their official
publications; the value has remained unchanged to date although the MPBB
has been discussed in more recent publications of both organizations.
MANHATTAN PROJECT EXPOSURES
Since the discovery of plutonium over three decades ago, personnel
exposures have been studied and reported on in varying degree, both during
(2-9)
life and after death. One of the most interesting groups, because of
-------
544
- 238 -
both the length of the period since exposure and the levels of exposure, is
that of the Manhattan Project plutonium workers.
Twenty-five male subjects, who worked with plutonium during World War II
under very crude working conditions by today's standards, have been followed
medically during the intervening periodo Within the past several years, 21
of these men have been examined at the Los Alamos Scientific Laboratory.
In addition to physical examinations and laboratory studies (complete blood
count, blood chemistry profiles and urinalysis), roentgenograms were taken
of the chest, pelvis, knees and teeth. Chromosomes of lymphocytes cultured
from peripheral blood and pulmonary cytology were also studied. Urine
specimens assayed for plutonium yielded calculated body burdens which
ranged from 0.005 to 0.42 ^Ci. These estimates of body burden are generally
higher than earlier estimates based on radioassay of urine samples collected
in the past, perhaps reflecting uncertainties in the models used to estimate
body burden from excretion data. Table 1 indicates the kinds of information
obtained from the Manhattan Project plutonium workers. Most, but not all,
of these examinations have been conducted every four to five years since
the group has been studied.
This group of men in their early to mid-fifties had only the usual
diseases encountered in this age zone. One man had a coronary occlusion
but had recovered and was well compensated. Another of the original
group died in 1959 of a coronary occlusion at age 38. Another had a
hamartoma of the lung surgically removed without complication in 1971. A
third had a melanoma of the chest wall (regional lymph nodes were negative).
-------
- 239 -
545
A fourth had a partial gastrectomy for bleeding ulcer. Several had
mild hypertension and moderate obesity, and one had gout. All were
working actively. More detailed information on this particular group of
workers has been published.
Blood samples were obtained from the group during the most recent
medical checkups for chromosome studies using standardized established
techniques. No abnormalities were found in these subjects. Except for one
(13)
special case reported by Schofield and Dolphin chromosome aberration
studies carried out on plutonium workers in the United Kingdom showed no
(14)
significant increase in aberration yield.
Because lung cancer has been observed experimentally in animals exposed
to plutonium aerosols, cytological examinations of bronchial cells in sputum
samples have been added to these studies. In a few subjects, moderate to
severe dysplastic changes have been observed. The significance of these
changes is not clear except in one man who was a heavy cigarette smoker
(3 packages per day).
It is important to realize that these men worked under very crude
working conditions as judged by today's standards. At times, the activity
to which some of these personnel were exposed was orders of magnitude
over the presently accepted maximum permissible air concentrations. Most
of the exposures were believed to have occurred via inhalation as evidenced
by a strong correlation with frequent contamination of the nasal vestibule
and highly contaminating operations. The nasal swabs on one occasion yielded
over 1 p,g Pu from each nostril. Figure 1 shows the building in which
these men worked in the early years.
-------
546 - 24° -
Attempts have been made to estimate the number of particles inhaled
by the Manhattan Project plutonium workers. By making certain assumptions
with respect to the mass median diameter, geometric standard deviation of
the distribution and the particle density, one can calculate the mass
fraction for plutonium dioxide particles larger than any stated size. For
example, the mass fraction for plutonium particles larger than 0.6 micron
diameter is approximately 157o. Further calculations indicate that approxi-
mately 10 particles larger than 0.6 micron diameter could have been retained
by the 25 subjects during their exposures in 1944 and 1945. The observed
lung cancer incidence is zero almost 30 years since exposure.
Table II shows the current status of several LASL plutonium study
groups. Group 1 was discussed in the preceding paragraphs. Group 2,
which is now in the early stages of study, will expand the size of the
original cohort by perhaps 40 people. Twenty-eight of the 40 men who
have been identified have been located and have responded to question-
naires. Once again, these are extremely important subjects to study
intensively as approximately three decades have elapsed since their
exposures. Group 3 will comprise a broader spectrum of exposures, including
OO Q
more recent accidents and some exposures to Pu. All are estimated to have
systemic plutonium burdens of 4 or more nanocuries. Table III shows the
-------
-241-
estimates of plutoniura systemic body burdens on certain workers in Group 1,
all of whom had estimated burdens greater than 120 nCi (3 maximum permissible
body burdens) in 1972. The table also contains the 1953 and 1962 estimates
for these individuals. The increase in the values for each individual with
time is at least partly attributed to modifications in the method of esti-
mation that have generally resulted in higher estimates in more recent years.
The model for estimation of body burdens from urine assay values involves
uncertainties that limit the accuracy of estimation. It is also true
that some of the body burden estimates are based on relatively few data
points. Again, the original exposures were in the early 1940's so that
Case 3, who now has approximately 10 times the allowable occupational bone
burden, has carried this estimated 410 nCi of plutonium for approcimately
three decades. The selected cases shown in Table III represent systemic
plutonium burdens ranging from 0.13 to 0.42 |j,Ci, which correspond to annual
bone doses of approximately 2 to 6 rad.
Table IV contains information which is detailed in an earlier pub-
(10) 239 240
lication. The data are for the ' Pu content for some tissues that
were removed from Case 2 of Group 1, who developed a non-malignant growth
(hamartoma) in the lung. Surgical removal of the hamartoma, which was
found during a medical follow-up study, afforded an opportunity to obtain
tissue from the hamartoma, lymph nodes, rib and normal lung for radiochemical
239 240
analysis. The concentration of ' Pu was approximately the same in both
.the tumor and normal lung tissue. The lowest plutonium concentration was
found in a rib sample and the highest in the lymph node. This distribution
is consistent with experimental findings in dogs exposed to plutonium dioxide
by inhalation. If one assumes a total lung weight of 1000 grams, tracheo-
-------
548 -242 -
bronchial lymph node weight of 20 grams and a homogeneous distribution of
plutonium throughout these tissues, the total plutonium burden is estimated
to be 8 nCi, roughly equally divided between the lung and lymph nodes. This
estimate of the burden of plutonium in the thorax based on extrapolation
from the analysis of lung and lymph node tissue is in reasonable agreement
(within a factor of 2) with the estimate based on chest counting procedures.
Figure 2 is a photomicrograph of an autoradiograph of a plutonium
particle in a lymph node section removed from Case 2. Additional observations
on histologic sections of lymph node tissue suggested a non-uniform radiation
dose distribution from the plutonium particles.
PLUTONIUM ADMINISTRATION STUDIES IN HUMAN SUBJECTS
In an attempt to determine relationships between urinary excretion,
total excretion and body content of plutonium, 18 persons received plutonium
parenterally during 1945-1947 as shown in Table V. Fifteen of the
239
18 were older than age 45, and all but two of the 18 were given Pu only
238 239 238
(one received both Pu and Pu and another received only Pu). The
amounts of plutonium administered ranged from about 0.1 to about 6 u.Ci.
For comparison, the current occupational maximum permissible body burden
939
for Pu is 0.04 g,Ci.
Although these subjects were thought to be hopelessly ill, four of
the group were alive in November 1973, almost three decades after receiving
the plutonium. Excretion data for some of the survivors have been reported
(19)
recently. These data provide a unique opportunity to verify the
excretion equations that are used currently by radiation protection personnel
to estimate body burdens. It is of considerable interest that much of the
data used to establish the excretion equations was obtained from this group
-------
-243- 549
of 18 subjects during the relatively short period (several months in most
cases) during which they were studied. In addition to the data obtained
from those individuals, Langham used data obtained from several Los Alamos
occupational exposure cases for about 300 days and one for about 1700 days
in formulating his excretion curves. These equations have been very useful
although they have proven to be somewhat conservative when estimated body
burdens based on urine assay are checked against estimates based on post-
mortem analyses.
One of the original 18 plutonium recipients is of particular interest.
He was a white 58 year old male who was believed to have a gastric carcinoma
238 239
with hemorrhage when he received 5.19 (j,Ci of Pu and 0.12 |j,Ci of Pu as
PuO~(NO,.)- by intravenous injection. Gastrectomy disclosed a gastric ulcer
from which the patient recovered. He did not die until some 21 years later;
the cause of death was cardiovascular disease. We can obtain a very rough
estimate of the bone dose by assuming 40% deposition in the skeletal tissues
with no subsequent loss. Under these circumstances, the skeletal dose over
the 21-year period would be approximately 900 rad. The annual dose rate
to the skeletal tissues would be approximately 40 rad, a factor of
approximately 70 higher than the annual skeletal dose rate of 0.6 rad
239
delivered by the maximum occupational bone burden of 40 nCi of Pu.
Some information can be obtained on the amount of plutonium in the
gonads of some of these subjects. The fraction of administered plutonium
-5 -4
found in the gonads at autopsy was 9 x 10 for one female and about 3 x 10
for three male subjects. These numbers agree quite well with data obtained
from several species of experimental animals.
-------
550 - 244 -
U.S. TRANSURANIUM REGISTRY
During the summer of 1968, the United States Atomic Energy Commission
authorized the establishment of the National Plutonium Registry which was
later renamed the United States Transuranium Registry (USTR). The registry
is operated by the Hanford Environmental Health Foundation in Richland,
Washington, and collects information from AEC contractors and licensees
(21-23)
regarding employees potentially exposed to transuranium elements.
Cooperation with the USTR is completely voluntary on an individual basis
and includes release of medical and health physics data. Permission is
also obtained on a voluntary basis for postmortem analyses of tissues of
interest. Major AEC contractors and certain licensees handling plutonium
and other transuranium elements have agreed to endorse the program and
have recommended to their employees that they participate in this program.
The principal criterion used by the USTR to determine inclusion of an
individual in the Registry is that the employer provide a routine surveillance
program because of a reasonable likelihood that an exposure could occur. This
rather broad criterion allows for the different methods used to estimate the
extent of contamination, e.g., urine analysis, chest counting, or air
concentration data, and for uncertainties in estimating burdens under
certain conditions, e.g., chronic inhalation of insoluble plutonium. It
also avoids the exclusive consideration of cases involving heavy exposures.
At autopsy, comparisons can be made between estimates of the body burden
based upon tissue analyses and estimates made previously on the basis of
health physics and operational data. In addition to a medical history,
information may be obtained on an employee's work history, smoking habits,
exposure to toxic materials, and other pertinent data.
-------
551
Preliminary findings for the first fourteen autopsy cases reported
by the USTR appeared in the proceedings of the 12th Hanford Biology
(24)
Symposium held in 1972.v To date, information obtained by the USTR
indicates that estimates of the plutonium systemic burden based on urine
analysis have been on the conservative side, that is, they are higher than
(24)
estimates based on analysis of tissues obtained at autopsy. Workers in
the United Kingdom have also found this to be true.
Table VI indicates the status of the USTR as of June 1974. To date,
most of the USTR activities have been confined to Hanford, Los Alamos, and
Rocky Flats. The interested reader is directed to a recent USTR report for
details of the level of cooperation between the USTR and the other AEG
(25)
contractors shown in Table VI.
ACCIDENT CASES
A considerable amount of information has been obtained from accidental
occupational exposures to plutonium. However, the total number of accident
cases has been relatively small. Information obtained from the AEC's Division
of Operational Safety as shown in Table VII indicates that during the period
1957 to 1970 about 200 contractor personnel had depositions greater than
25% of the occupational maximum permissible body burden (MPBB) or lung
burden for plutonium. These data also indicate that inhalation is the major
portal of entry and that more than half the exposure cases represent plutonium
burdens less than 50% of the maximum permissible burden. Eighteen percent
of the total exposures resulted in plutonium burdens greater than one MPBB.
Table VII also shows that about 18% of the cases were treated by chelation
therapy. Fifty-four percent resulted from production activities.
-------
552
- 246 -
Operational experience at Windscale in the United Kingdom shows that
15 men have exceeded the maximum permissible body burden of 40 nCi during
a time covering about 7000 man-years of plutonium production and handling.
It is also possible that about half these men have considerably less plutonium
in their bodies than the calculations based upon urine radiochemistry currently
(13)
indicate. Because of the importance of human data it is important that
studies of personnel involved in accidents be continued and perhaps expanded.
A case of contamination resulting from a puncture wound is extremely
interesting as it has been interpreted by some as an example of cancer in
man resulting from plutonium deposition. The lesion was first described in
/ f\ r \
the literature more than ten years ago and was included along with other
(4)
information on plutonium wounds at a later time. The 5 nCi particle of
plutonium was surgically excised from the individual's palm approximately
four years after the accident. The radiation dose around the plutonium
implanted in the palmar skin was estimated to be about 75 million rads.
However, this kind of dose estimate is probably meaningless as we do not
know which cells were exposed or for what time periods. The entire lesion
-5 3
was very small (estimated to be about 3 x 10 cm ). Figure 3 shows a
histologic section of the lesion. The pathologist involved in the study
described the cellular pattern in the lesion as having "a similarity to
( 9 f\ \
known precancerous epidermal cytologic changes." This particular lesion
appears to be the most severe demonstrable effect having a direct relationship
to plutonium deposition in man.
TISSUE ANALYSIS PROGRAMS
(27)
For many years the Los Alamos Scientific Laboratory and other AEG
/ n c> o 1 \
contractor laboratories have conducted tissue analysis programs to
-------
- 247 - 553
determine plutonium levels in tissues obtained at autopsy from both exposed
occupational personnel and members of the general population who are not
engaged in work with plutonium. These programs were started in the 1940's
in the Hanford plant and at the Los Alamos Scientific Laboratory. A report
/ OR1)
from one program contains information on approximately 350 autopsies.
f Q 0 *5 / \
Additional reports from this and the other groups are available.
Table VIII shows plutonium concentrations as determined for lung, liver,
lymph nodes, kidney, and bone for the period 1959-1971 for non-occupationally
exposed persons from several parts of the United States and for occupationally
exposed persons. Data for plutonium concentrations in gonadal tissue,
which appeared in the original publication, are not included in Table VIII
because errors associated with a change in analytical procedures were detected
by the authors subsequent to the original publication. Similar data shown
in Table IX have been obtained for non-occupationally exposed persons and
(35)
represent analyses made during the period 1972-1973. The average con-
centration in the lungs for the data shown in Table IX is about 0.3 pCi for
a 1000 gram lung, and the lymph node concentration is about 11 pCi/g. No
unusually high concentrations of plutonium in gonadal tissue have been
observed in this particular study. Recent analysis of the gonadal data
suggest that the concentrations of plutonium are about 0.18 pCi/kg for
non-occupationally exposed persons.
The higher plutonium concentrations in lymph node tissue of non-
occupationally exposed individuals in Table IX as compared with those in
Table VIII are not thought to represent real increases but rather to reflect
an improvement in the technique for dissecting the lymph nodes from the lungs.
-------
554 -
The AEC's Health and Safety Laboratory (HASL) recently has used
information obtained from the International Commission on Radiological
Protection to model the intake and body burden resulting from plutonium
/ n /; \
in fallout and to estimate the radiation dose to man from this source.
The cumulative lung and bone doses for the period 1954-2000 are estimated
to be 16 and 34 mrem respectively. The HASL group has also compared body
burdens based on their model with values obtained from the tissue sampling
programs. The agreement is quite good between the Colorado-New Mexico tissue
data and the model predictions as shown in Table X for 1970-1971. The
comparison based on the New York tissue sampling data is not as good and may
reflect the small sample of 25 autopsies that were included in the analysis.
Results of the tissue sampling programs for occupationally exposed
plutonium workers has also given us the opportunity to compare the body burden
at autopsy with that estimated during life on the basis of bioassay data.
(25 29 35) (13)
Almost without exception, workers in the USA ' ' and United Kingdom
have found less plutonium by significant factors at autopsy as compared with
the amount predicted during life. For example, the United Kingdom workers
found that for 9 plutonium workers studied at autopsy, the body burden
estimates based upon tissue analysis were lower by factors of 1.2 to 8.3 than
those estimates made during life on the basis of urinary excretion analyses.
Thus it would appear that estimates of the body burden made during life are
conservative in that they predict more plutonium than is actually present in
the body. Because a considerable amount of relevant data is now available,
it may be appropriate for scientists in the field of radiation protection to
explore this observation in more detail as regards current radiation protection
practices and the guidelines followed in the nuclear energy industry.
-------
- 249 -
Recently several investigators have examined the United Kingdom medical
experience for workers handling plutonium. They have concluded that the
information to date cannot conclusively validate or repudiate the presently
accepted working levels for plutonium, but the information does allow for
a certain amount of cautious optimism. They also state, "it is true to say
that after 30 years' experience in the USA and 22 years' in this country,
no disease attributable to plutonium toxicity has been diagnosed in any
worker concerned in the production or manipulation of plutonium."
PLUTONIUM IN MAN FROM FALLOUT
Plutonium is present in extremely small quantities in various organs of
man today. Although most of the plutonium in fallout resulted from atmospheric
testing of nuclear weapons by several countries prior to the 1963 limited test
treaty ban, some material from contemporary atmospheric weapons testing by
France and the People's Republic of China adds to the total human burden.
The current lung burden as estimated for persons in the United States is
239 240
about 0.3 pCi of ' Pu, and a very rough estimate of the total amount
in the body is perhaps 3.5 pCi as shown in Table XI. Estimates of the total
amount of plutonium produced in the course of nuclear weapons testing vary,
but a value of about 0.4 megacurie is a reasonable estimate. Of this amount,
-8
if 0.3 megacurie has returned to the biosphere, very little (about 10 ) has
g
found its way into the earth's population (3 x 10 people). Another approach
-12
to this matter is to divide the estimated average human burden (3.5 x 10
curies) by the estimated amount in the biosphere (0.3 x 10 curie); the
average accumulation is about 10 per person.
555
-------
556 _ 250 .
CONCLUSION
239
Control of industrial hazards of Pu processing is based upon the
premise that personnel exposure should be as low as practicable not because
the maximum permissible body burden is a level which would do harm but
because it is sound industrial medical and health protection practice.
The lack of demonstrable biological effects of plutonium in man is
reassuring and represents presumptive evidence that the standards are not
grossly inadequate. My personal opinion is that those standards are adequate
and that there is no compelling reason at this time to initiate changes, either
upward or downward.
I would like to now quote a portion of the Rulison decision as given
by Judge Arraj as I believe it is appropriate.
"The field of radiation protection is constantly changing with the
appearance of new scientific knowledge on the biological effects of
ionizing radiation. Careful decisions must be made in the context of
contemporaneous knowledge. Such decisions cannot be indefinitely post-
poned if the potentials of atomic energy are to be fully realized. All
that is required to establish reasonableness of the decision setting
a standard under the statutory directive to protect the public health
and safety is that it be made carefully in light of the best available
scientific knowledge. Absolute certainty is neither required nor possible."
-------
557
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-------
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-------
- 253 -
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-------
562
- 256 -
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- 258 -
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576
Thank you.
Dr. Mills: Our next speaker is Dr. Thompson.
-------
577
Implications with Respect to Protection Criteria
by R. C. Thompson
Battelle, Pacific Northwest Laboratory
Richland, WA 99352
part of the AEG presentation at
EPA Plutonium Standards Hearings
Washington, D.C., December 10-11, 1974
My name is Roy Thompson. I am a staff scientist in the Biology Department
of Battelle Pacific Northwest Laboratory.
Introductory Description of Problem
Those preceding me in this presentation have tried to summarize the
facts that define the problem--present and projected--of plutonium and
other transuranic elements in our environment. It is my task to suggest
to you how these facts might be utilized in arriving at appropriate
standards for control of these transuranic elements, for the protection
of the general populace. This is a presumptuous undertaking, considering
the collective wisdom represented on the Hearing Board. I do not expect
to tell these gentlemen something they do not already know about the
philosophy or practice of radiation protection.
I've therefore chosen the opposite approach. If I cannot propose
a new concept to solve our problem, I will try, instead, to review the
problem, in its most basic aspects and hope that from this "return to
fundamentals" we may achieve some clarification of what it is we need
to do. If you feel at times that your intelligence is insulted by my
-------
578 - 272 -
simplistic approach, I can only ask that you bear with me--I won't
take very long.
In the first figure, I present what seems to me the most basic
formulation of our problem. An exposure to some noxious substance results
in an undesirable effect. We wish to prevent or minimize this effect.
So, from our knowledge of this exposure-effect relationship, we establish
a standard, which in some manner acts to control the exposure at a level
that does not produce an unacceptable effect.
For the case of plutonium, we can elaborate this a bit, as shown in
Figure 2. Exposure is often translated into terms of a radiation dose
that is thought of as producing the effect. We know that exposure must
occur via some kind of environmental pathway, and that the plutonium
in the environment has its origin in some "source term." It also seems
obvious that the best place for the standard to be applied for control
of exposure is at the level of the source term.
Note that "dose" is enclosed in brackets, to indicate that it is
really not an essential step in the process. Dose, as employed in radiation
protection, is a concept in the mind of the scientist, which may or may
not be useful in relating exposure to effect. Exposures, on the other
hand, are real occurrences that happen to people. Effects happen to
people. If a relationship between exposure and effect is known, a
standard may be set to control that exposure and eliminate that effect--
in total ignorance of the dose or any other knowledge of the mechanism
-------
- 273 -
579
by which the effect is thought to be produced. I stress this point
because, as will be noted later, much of the confusion in this field is
due, in my opinion, to a misplaced emphasis on, and confidence in, dose.
I might add that this problem does not trouble most other areas of
industrial toxicology where we are too ignorant of mechanisms to be
concerned with such sophistication.
Exposure
I would like to consider the individual elements of our basic problem--
first exposure. I think it will help us to think in terms of three kinds,
or levels, of exposure. First, there are the levels that we know can
produce effects in animals. Roughly speaking, these are exposures that
result in lifetime doses to bone or lung in excess of about 30 rad (1).
Now, I'm speaking of dose, because it's a convenient way to lump a lot
of exposure data; but, you know from Dr. Bair's presentation, that I'm
lumping rats and mice and dogs and baboons--so you won't place too much
confidence in my numbers. I must also specify that I am talking about
average organ dose. And I must remind you that in terms of dose
equivalent, as currently defined, we are talking about 300 rems to lung
or 1500 rems to bone (2). These exposures, we know, have resulted in a
low, but significant incidence of malignant tumors in animals.
Second, there are the exposure levels that have occurred in man.
Some occupational exposures approach, or perhaps even exceed, the minimum
levels that have produced effects in animals (3,4). But most occupational
exposures are much lower, and the exposures from fallout plutonium, very
much lower (5).
-------
- 274 -
580
Finally, there are the exposure levels about which we should be
concerned if we are to protect the general populace from plutonium
effects. We don't know exactly what these levels are--or we wouldn't
be here. But, I think everyone would agree that these levels must
certainly be much lower than those we have considered acceptable for
occupational exposure.
Effect
Now, let's try to relate these exposure categories to the effects
side of our relationship. For the exposure levels studied in animals,
this is relatively easy--easy because of 30 years, and many millions of
dollars worth of research. We know more about the effects of plutonium
in animals, I would guess, than about any other industrial pollutant.
For the human exposures, one is tempted to say that we know nothing
about effects, but this is not strictly true. Effects clearly attributable
to plutonium have been observed at the cellular level--histological
changes (6), perhaps chromosome abberations (7). Of course we knew
before we looked that each alpha disintegration would probably kill
cells. But we cannot, even qualitatively, relate these kinds of effects
to health consequences. So, effectively, we know nothing about effects
in humans.
But this absence of information is itself informative. It sets some
upper limit to our problem. We don't quite know how to evaluate this
limit, because we don't know as much about our population of plutonium-
-------
581
exposed humans as we should, and because we may yet see effects, although
it may be difficult to identify these effects as due to plutonium.
However, we can at least qualitatively contrast the problem with that of
exposures to radium, or exposures in uranium mines, where, within much
less than 25 years after these exposures commenced, lethal effects were
all too obviously evident. This kind of experience we have thankfully
not had with plutonium.
If we have no useful human data on plutonium effects, can we perhaps
utilize other radiation effects data that are available for humans? We
can certainly make such an attempt — the UNSCEAR (8) and BEIR (9) committees,
among others, have done so--but we must be aware of the uncertainties
involved in such an approach. In fact, we must be aware that whatever
route we take to the estimation of the health consequences of plutonium
in humans, we are necessarily involved in some uncertain extrapolations.
We must either extrapolate from observed plutonium effects in animals to
predicted effects in humans, or we must extrapolate from observed non-
plutonium radiation effects in humans to predicted plutonium effects in
humans. Whichever of these routes we take, we must further extrapolate
from exposure levels where we have data, to the much lower exposure
levels that are of primary concern in the protection of large populations.
Extrapolations
Let us look at some of the problems involved in these extrapolations.
The human radiation effects data, as recently summarized in the BEIR
Report, derive largely from whole-body, external exposure to penetrating
-------
582
radiation, at high dose rates and high dose levels (9). We must
extrapolate to a condition of very non-uniform, internal exposure of
a few organs to alpha radiation, at very much lower average dose rates,
but perhaps very much higher local dose rates. Such extrapolation can
only be made through the medium of simplifying assumptions regarding dose
and dose equivalent. These assumptions are familiar to you--I will mention
only a few of the more critical ones. One must assume a relative
biological effectiveness for alpha particles—a number derived from
non-human studies (2). One must correct for non-uniformity of distribution--
a correction presently based on animal data in the case of bone, and assumed
to be insignificant in the case of lung (2) [though this latter assumption is
challenged by some as grossly in error, on dosimetric grounds (10)] .
For my money the extrapolation of the animal data is subject to
fewer uncertainties. The whole quagmire of dose can be sidestepped.
Animals can be exposed to the actual materials of concern, whether they
be "hot particles" or solutions, ingested, injected, or inhaled, chronically
or in a single exposure. And, effects are directly observed. They are, of
course, effects in a rat or a dog--not in man. But bone and lungs of
different animals are not that different, as can be demonstrated by
comparative toxicity studies in several animal species. Such differences
as are observed can often be explained in terms of anatomical or physiological
factors and corrections can be applied for the predicted influence of these
factors in man.
-------
- 277 -
583
But one needn't choose between these two approaches. Both animal
and human data should be utilized as best one can, and the encouraging fact
is that the two approaches lead to similar predictions. Figure 3 shows
some of these predictions as prepared for inclusion in the LMFBR Environmental
Impact Statement. These cancer risk predictions are stated in terms of
cancers produced per million person-rems. The range of numbers estimated
from the BEIR Report data are not maximum and minimum estimates, but the
range of "best" estimates derived by different procedures--all involving
an assumed linear response to dose (9). The numbers derived from animal
data also assume linearity of response, and are of varying quality (1).
Much better animal data should be available within a few years.
The point of this comparison is not to establish a particular number,
but to indicate the kind of agreement that is seen. As an indication of
the agreement seen in a related area, Figure 4 shows similar numbers
for radium, where we have direct data for humans to compare with
experimental animal data (11). The animal data show a generally higher
incidence, but there is certainly "ballpark" agreement. Recalling the
numbers on Figure 3, let me say that I would have considerable confidence
in that "ballpark" of plutonium numbers, if applied to individual "person"
exposures in the range of a few hundred to a few thousand rem. Whether
any of these numbers have any significance when applied to exposures
in the range of a rem or less is far less certain, and is the major
extrapolation uncertainty that we face.
-------
584
Figure 5 attempts to graphically portray this problem. We are
plotting average organ dose equivalent, to bone or lung, in rem, against
effect in unspecified units. The heavy line at doses in excess of 100 rem
represents the hard data from animal studies. The vertical lines are
meant to indicate the considerable statistical uncertainty in that data.
Actually, the hard data-now stops at about 300 rem for lung and 1500 rem
for bone, but I think that experiments currently in progress may well
extend the range of observed significant effects to something approaching
this level of 100 rem. Below 100 rem we have no data on plutonium toxicity
nor can we expect to obtain any. We can, with confidence, assume zero
effect at zero dose; and the simplest interpolation over the unknown
interval is a straight line between the last data and the zero-zero
point. I won't try to review the theoretical arguments that have been
presented to justify such a linear interpolation, nor will I present the
theoretical arguments for some kind of enhanced effectiveness at lower
dose levels, or the arguments for a threshold dose below which there will
be no effect. Because they are based on unsupported theory, none of these
arguments are totally convincing, though some I must admit are more
convincing than others.
What I do find convincing is this zero point. And, I feel quite
confident that the approach to this zero point is much more likely to be
asymtotic to the dose axis than to the effect axis. I said a moment ago
that we can expect to obtain no experimental data in this region below
a lifetime dose of about 100 rem, but we do have data of a sort in this
-------
- 279 -
region that I have cross-hatched, below about 10 rem. An experiment
in this dose region has been in progress for quite a few millions of
years, during which time the human race has received lifetime doses
averaging about 3 or 4 alpha rem per person to bone and lung, and
approaching 10 rem total lifetime radiation dose (18, 20). The numbers
on the viewgraph represent 70-year cumulative background doses. Though
we know something about the dose, we can't evaluate the effect side of
this experiment, except to say that we are the effect. What we might
have become if not subjected to this radiation is a fascinating, but
academic question. It is quite apparent, however, that we have not
evolved in a manner to spare us from this radiation. We have not
developed external shielding nor have we rejected potassium as a
metabolically critical element, because of its TC content. These
facts argue strongly, I think, that any precipitous change in the dose-
effect relationship does not occur within the range of natural background.
If there is an enhanced effect of radiation at low dose levels as
represented by the upper range of curves on the viewgraph, this effect
certainly cannot continue to zero dose, and 1 think cannot reasonably
be thought to persist within the region of background dose.
Conclusions
Now, may I express just a few general conclusions. Most importantly,
I would say that "As Low As Practicable" is still a very good idea--
particularly for plutonium, in view of the uncertainties we've discussed;
585
-------
586
- 280 -
and particularly for population exposure standards where it may be often
difficult to identify an individual benefit to balance an appreciable
risk.
Exposure of total populations should be controlled at some fraction
of natural background levels, because it is only in this range of exposure
that I feel we have assurance of insignificant effect—an assurance
based upon the survival, over past eons, of the human race.
Because the dispersal of plutonium amongst the general populace will,
for many centuries at least, be quite non-uniform, I think we cannot
accept limitations on person-reins as a totally adequate basis of control.
While it may be expedient, and even conservative, to assume dose-effect
linearity for the evaluation of risk to populations, we cannot use such
an assumption as an argument for permitting individual overexposure. If
1000 person-rems are distributed evenly among 1000 persons, the probability
of an eventual effect may be less than, equal to, or greater than the
probability associated with the same 1000 person rems delivered to a single
individual--we cannot be sure. And in no way should that uncertainty be
used to justify the high individual exposure. We don't need to choose
between these alternatives. We should protect the "critical individual"
as well as the total population, although not necessarily to the same
per-capita limits.
It seems inevitable that control must be based on environmental
monitoring, since the appropriate "people-limits" will be certainly un-
measurable. This places a burden of great significance on our knowledge of
food chain and inhalation pathways, which is required for translating
-------
587
a people-limit to an environment-limit. Of critical importance is the
assumption to be made with regard to an ultimate environmental sink for
plutonium. Certainly, the longer-lived plutonium isotopes need not be
assumed to remain optimally available to man for the hundreds of thousands
of years before they undergo complete radioactive decay.
It may be expedient to express exposure limits for the individual in
the population as some appropriate fraction of an occupational exposure
limit, because the derived occupational limits will incorporate considera-
tions of exposure pathways and the summation of dose commitments to
critical organs. This "appropriate" fraction, however, cannot be an
arbitrary number applicable to all radionuclides under all circumstances.
It should be set primarily in relation to considerations of natural back-
ground and "practicability." Thus, the absolute value of occupational
exposure limits is of little relevance to population exposure--a different
set of criteria are involved on the benefit side of the risk-benefit
equation.
Finally, I would just like to address, very briefly, a few specific,
critical questions that have been raised with regard to the adequacy of
plutonium toxicity information. Enough has probably already been said about
the "hot particle" problem. This is a theoretical argument, centering around
totally inadequate knowledge of the microdose-macroeffect relationship (10).
Fortunately, there ace experimental animal data and human experience, not
dependent upon theoretical interpretation of dose, that denies the
existence of any major enhanced effectiveness of such particulate exposure
(13).
-------
588 - 282 -
Concern has been expressed that the potential for genetic effects from
plutonium deposited in gonads may not be adequately evaluated. Although
animal experiments to prove this point have not been done, and would be
very difficult, there is evidence from both animal and human data that
plutonium is not concentrated in gonads, and that the dose from gonadal
plutonium is therefore small—much smaller, and therefore of less concern,
than the dose to lung, bone, or liver (14). Some early analyses, which
seemed to indicate high levels of fallout plutonium in human gonads, have
been shown to be in error (14, 15).
Lymph nodes draining the lung will probably receive the highest
radiation dose from inhaled plutonium but this dose has not been considered
in setting occupational exposure standards. This seems justified in light
of the overwhelmingly greater incidence of cancer in bone and lung
of animals that have inhaled plutonium (1).
One must be particularly concerned for the exposure of the very young
members of a population, since they are usually considered to exhibit an
enhanced radiosensitivity. The fact that the radiation exposure from
each increment of internally deposited plutonium is spread over the whole
subsequent lifetime of the exposed person, provides an automatic safety
factor for the young child. Assuming uniform continuous exposure, dose rate
will increase throughout the life span, and will be at its lowest value in
the newborn. While gastrointestinal absorption of plutonium may be markedly
increased in the infant, this condition is probably limited to a very short
period following birth, a period during which the infant is relatively
protected against most forms of exposure (16).
-------
-283- 589
REFERENCES
1- W. J. Bair, "Toxicology of Plutonium," in Advances in Radiation
Biology, Vol. 4, Academic Press, New York, pp. 255-315, 1974.
2. International Commission on Radiological Protection, "Report
of Committee II on Permissible Dose for Internal Radiation,"
ICRP Publication 2, Pergamon Press, 1959.
3. D. M. Ross, "A Statistical Summary of United States Atomic Energy
Commission Contractors' Internal Exposure Experience," in
Diagnosis and Treatment of Deposited Radionuclides, Excerpta
Medica Foundation, Amsterdam, pp. 427-434, 1968.
4. L. H. Hemplemann, W. H. Langham, C. R. Richmond, and G. L. Voelz,
"A Twenty-seven Year Study of Selected Los Alamos Plutonium Workers,"
Health Physics 24, pp, 461-479, 1973.
5. B. G. Bennett, "Fallout 239Pu Dose to Man," Fallout Program
Quarterly Summary Report, HASL-278, 1974.
6. C. C. Lushbaugh and J. Langham, "A Dermal Lesion from Implanted
Plutonium" Arch. Dermatol. 8j>, pp. 461-464, 1962.
7. W. F. Brandom, R. W. Bistline, A. D. Bloom, and P. G. Archer,
OOQ
"Somatic Cell Chromosome Changes in Humans Exposed to Plutonium,"
Radiation Research 59, p. 206, 1974.
8. U. N. Scientific Committee on the Effects of Atomic Radiation,
Ionizing Radiation; Levels and Effects, Vol. I and II, United
Nations, NY, 1972.
9. U. S. National Academy of Sciences - National Research Council, The
Effects on Populations of Exposure to Low Levels of Ionizing Radiation,"
Report of the Advisory Committee on the Biological Effects of Ionizing
Radiations, Washington, DC, 1972.
-------
590 - 284 -
10. A. R. Tamplin and T. B. Cochran, "Radiation Standards for Hot
Particles," Natural Resources Defense Council, Washington, DC,
1974.
11. C. W. Mays and R. D. Lloyd, "Bone Sarcoma Incidence vs. Alpha
Particle Dose," in Radiobiology of Plutonium (B. J. Stover and
W. S. S. Jee, eds.) J. W. Press, Salt Lake City, pp. 409-430, 1972.
12. W. M. Lowder, J. H. Harley, and J. E. McLaughlin, "Data Needs for
the Assessment of Population Dose from Background Radiation,"
Population Exposures (J. C. Hart, R. H. Ritchie, and B. S. Varnadore,
eds.) USAEC Doc. CONF-741018, pp. 23-28 (1974).
13. W. J. Bair, C. R. Richmond, and B. W. Wachholz, "A Radiobiological
Assessment of the Spatial Distribution and Radiation Dose from
Inhaled Plutonium;1 WASH-1320, 1974.
14. C. R. Richmond and R. L. Thomas, "Plutonium and Other Actinide
Elements in Gonadal Tissue of Man and Animals," Health Physics.
Manuscript Submitted, 1974.
15. E. E. Campbell, M. G. Milligan, W. D. Moss, H. F. Schulte, and
J. F. Mclnroy, "Plutonium in Autopsy Tissue," Los Alamos Scientific
Lab. Doc. LA-4875, 1973.
16. M. R. Sikov and D. D. Mahlum, "Plutonium in the Developing Animals,"
Health Physics 22, 707-712, 1972.
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- 285 -
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-------
596
Standards for the Transuranic Elements
by J. Newell Stannard
University of Rochester School of
Medicine and Dentistry
Rochester, N. Y. 14642
part of the AEC presentation at
EPA Plutonium Standards Hearings
Washington, D.C., December 10-11, 1974
The following remarks are in lieu of personal appearance for testimony
which I regret previous commitments precludes. It is not heavily documented
or intended to be in any way a complete summary of the many important con-
siderations which have had or will have a significant bearing on both these
important standards and their implementation. Reference will be made, however,
to especially pertinent documents and summaries where needed.
While I take responsibility for this statement entirely as an individual
scientist, it cannot help but be influenced by my current interests and
activities for the National Council on Radiation Protection and Measurements
whose Scientific Committee-34 I happen to Chair, and by interaction among
its members and others in the field. Committee-34 has as its charge the
recommendation to the Council of radionuclide concentration standards for
both occupational and population exposure in the United States. It is
actively engaged in consideration of aspects of this urgent subject but has
not yet reached any conclusions on matters as detailed as standards for
the transuranics.
My personal view is that some of the current recommendations regarding
exposure to transuranics, now many years old, will be changed by the responsible
-------
- 292 -
597
national and international bodies such as ICKP and NCKP and will, quickly,
or even before, be modified somewhat in the Federal and probably the State
codes. It is also my view that the modification will be in the direction of
a reduction in derived limits, perhaps also in the primary dose standards,
although the change in the latter might be relatively smaller. Decisions
regarding the magnitude of any future reductions and to which nuclides they
might be applied is now the prime source of debate and delay. Fortunately
the extant philosophy of operating on the "as low as practicable" basis makes
such delays in decision-making of less importance than they might otherwise
be. However, none of the above remarks should be interpreted as implying
that we have reliable scientific evidence showing significant biological
damage in either workers or populations who have never been exposed above
the current standards. But the future increases in numbers of potential
exposees and in the quantities of transuranium nuclides potentially available
makes the current emphasis on reexamination of standards a very legitimate
enterprise even though the organizations concerned have and continue to
maintain constant vigilance over the validity of the basic recommendations.
Basis for Present Standards
The biological basis for ICRP, NCRP and various governmental standards
has been reviewed and scrutinized in depth by many, probably also at these
hearings. In addition to basic documents, I especially commend the excellent
historical review of maximum permissible body burdens and concentrations
I of
(2)
of plutonium by Langham and Healy , and of concentration and body burdens
of the transplutonic elements by Dolphin.
Yet a few points need reiteration even here. Firstly is the fact that
the body burden standard for plutonium is based on a large volume of excellent
-------
598
- 293 -
biological work first in rodents and then in the dog, and to a lesser
extent primates. In addition there is a respectable amount of information
on the behavior of plutonium in man which suggests no major differences in
its metabolism in the human as compared to the animal species used.
It was the empirical ratio of the toxicity of plutonium relative to
radium found in animal experiments which led to a reversal of proposed early
standards based on energy considerations alone and to our present standards
with bone as critical organ. But we have no storehouse of information on
effects of plutonium in man as we do for radium (both -226 and -224) . Indeed
fortunately we have nothing but one or two isolated instances of effects
which may be attributable to plutonium exposure. But it is frequently
forgotten that we do have a storehouse of metabolic information both in man
and animals and of effects in animals upon which to base a standard for
plutonium.
Because of its similarities to radium the standard for plutonium in bone
was therefore based on the biological information alluded to above, including
the experience with radium in man. By contrast both body burden and derived
standards for plutonium when organs other than bone are critical were derived
quite differently viz: by calculation of that amount in the organ which
will yield no more than the maximum allowable dose or dose rate to that
organ. This maximum allowable dose or dose rate was derived not from
experience with radium but largely from experience with external radiation
sources. For most soft tissues in which the transuranics deposit (lung,
liver, kidney, GI tract, et cetera) this rate is 15 rem per year for occupational
exposure. Since the calculated dose to bone using the radium experience is
-------
599
at least double this quantity, a factor of at least two enters into the
prime standards between bone and other likely critical organs. A difference
of this magnitude is well within the limits of our present knowledge.
More recently the ICRP has essentially abandoned the system of direct
comparison to radium and substituted calculation of the dose to endosteal
cells as the basic procedure for bone. Since this would allow a dose rate
of only 15 rem per year for occupational exposure situations, the prime
standard might be expected to be reduced by a factor of at least two by
this change. But, as of the present writing, the complexities of calculating
dose to endosteal cells from alpha emitters have made the ICRP decide to keep
the old approach for alpha-emitting bone seekers.
The transplutonic elements such as Am, Cm, Cf , Es, Fm, et cetera, seemed
by and large to behave enough like plutonium to be handled in much the same
way, i.e., bone as critical organ and the comparison to radium retained. Or
so it would seem from the official ICRP and NCRP publications on internal
emitters. But Dolphin makes no mention of direct comparison to radium in
(2)
deriving body burden figures for the trans-plutonics in his recent survey.
Instead he cites the basic dose standards of 5, 15, and 30 rem/year, the
latter presumably applying to bone and calculates therefrom. The NCRP in
(3)
its most recent report on basic radiation standards does not make specific
mention of any dose rate for bone, although it might be presumed to be
included in "other organs...." at 15 rems per year. In fact, the NCRP
Report specifically defers judgment (paragraph 202, page 77, reference 3)
on bone doses to await recommendations from its committees on internal
emitters; which committees have yet to issue judgements beyond the one con-
tained in the referenced paragraph above.
-------
600 - 295 -
Thus the official primary standards for the transuranium elements
remain, despite much ferment, pretty much as they were in 1959 except for
certain additions and modifications of derived figures. But let it not be
forgotten that changes would have been made quickly and certainly if the
growing storehouse of biological information had begun to indicate any
serious flaws in the basic information used originally. The situation would
not have remained static very long.
The Current Reexamination
A. Changes in Models and Metabolic Parameters
Over the years since 1959 much new biological information has
been gathered and formulated. In addition to different values for
some of the metabolic parameters, we have a new and more versatile
lung model, a new GI tract model, much more about standard man,
et cetera. Only a small fraction of this has found its way into
official use, although it has been generally drawn upon for almost
(4)
every other purpose. In my paper at Los Alamos I presented "old"
and potential "new" figures for Maximum Permissible Annual Intake
by ingestion or inhalation of plutonium-238 and 239 and the derived
values for air concentrations. For the "new" figures I selected
likely - but totally unofficial - metabolic values and models.
The changes in derived values were almost all within a factor of
ten, some increasing and some decreasing. While it must be admitted
that other choices - especially of aerosol characteristics might
have made larger differences, the prediction that the newer models
and metabolic data would lead to drastic reduction in standards,
has not been realized for plutonium.
-------
- 296 -
601
The accumulated information on toxicity ratios between trans-
uranics and radium in the monumental dog experiment at the University
of Utah indicates rather remarkable similarities to the ratios
derived from shorter-lived rodents. However, the current ratio of
five (expressed as the "N" factor in ICRP and NCRP formulations)
is certainly none too high. Some of the dog experiments indicate
factors more like eight or ten. This combined with Marshall's
indication that slower movement of the nuclides in bone structure
of man might lead to a higher toxicity in man indicates a potential
for some reduction in basic derived standards on this basis when
the responsible bodies complete their sifting of the newer (and
still accumulating) data. Newer work with the transplutonics has
been ably summarized by Durbin. Her survey plus currently
appearing papers suggest larger accumulations of some of these
nuclides in soft-tissues and correspondingly less in bone than in
earlier work. If the critical organ dose calculation mode is used,
these changes would seem unlikely to lower standards. If the risk
estimate approach is employed the situation might be different.
Results so far suggest that the transplutonics may be about equally
effective with plutonium (on activity basis) in inducing bone tumors.
Although the experiments are far from complete, especially those
249 252
with Cf and Cf, if this is indeed true then these nuclides by
their greater mobility compared to plutonium may present greater
risks to soft tissue. The net result might well be a reduction of
derived standards. But current data do not suggest a large reduction
on this basis if it does occur.
-------
602 - 297 -
B. Cancer Incidence Relationship
In an important paper at the Fifth International Congress of
Radiation Research, Dr. Roy C. Thompson presented two summary graphs
which put together in one place most of the animal data on bone
and lung cancer incidence from long-term exposure to plutonium.
These present the incidence rates as a function of calculated radia-
tion dose and are fraught with all of the pitfalls and difficulties
of determining the true radiation dose which caused the cancer. These
are especially serious difficulties for an internal emitter like
plutonium. Also, the combining of data from many experiments em-
ploying many species into a single summary graph is a very gross way
to express relationships. Yet, the broad outlines of cancer incidence
rates are discernable since the data are reasonably coherent.
As Dr. Thompson will no doubt point out in his own testimony
at these hearings, the composite figures for lung cancer show a
small but apparently significant increase at a cumulative mean dose
as low as 30 rads. The composite portrayed for plutonium-induced
osteosarcoma shows several points above the abscissa (i.e., above
zero increase in incidence) below 10 rads, although the mean
figures are not above zero until a cumulative rad dose of slightly
over 20 rads. If one considers that at 15 rem per year and 50
years of exposure, the total allowable cumulative occupational dose
to the lung could be 750 rem while 30 rad is only 300 rem, one
wonders if the safety factor in this standard is as large as desirable.
-------
- 298 -
603
Fortunately the occupational limits for air concentration have been
arranged so that the limiting dosage rate of 15 rem per year is
reached only in the 50th year of exposure. Thus 750 rem would never
be reached under this regimen. But if this annual rate were to be
applied to single or a series of short exposures, the total doses
might come uncomfortably close to those associated with detectable
increase in cancer incidence.
A similar argument might be made for bone, although the practice
of tying its limits directly to radium exposures in humans and the
even greater difficulties of calculating radiation dose to bone for
alpha emitters make it more likely to be specious.
Application of the dose commitment concept for single or short
bursts of exposure has probably helped to prevent unacceptably
large accumulations in man. But it seems reasonable to expect that
the presence of finite cancer incidence at calculated doses as low
as 10 rads or 100 rems will exert pressure toward lowering of the
present official ICKP, NCRP, and other permissible exposures and
intakes.
C. Non-uniform Distribution
It is amply clear that the transuranic nuclides show a marked
tendency to form aggregates in vitro and in vivo, especially in the
chemical and physical states of most likely exposure. Thus, the
maximal radiation doses in some areas may far exceed the average
dose to the organ conventionally calculated. A special case of this
well-known non-uniform distribution phenomenon is the "hot particle"
-------
604
problem emphasized in extenso by Tamplin and Cochran and the
Natural Resources Defense Council, Inc.
While the bulk of current biological information does not
support the notion of any special carcinogenic effectiveness of "hot
particles" in the lung, there are many critical pieces of information
which are not available. Nor can they be expected to appear until
more is known of the mechanisms of carcinogenesis itself. While I
disagree with the 115,000 factor by which Tamplin and Cochran suggest
the standards should be lowered, I do believe the "hot particle"
discussion will tend, along with other factors noted in the testi-
mony, to drive standards down, even if the scientific basis is not
clearly evident from experimental work.
There is one aspect of the "hot particle" problem, however,
which I feel needs special emphasis. As discussed earlier, we are
dealing with actual incidence data for plutonium, and to a lesser
extent for the transplutonics. The animal exposures undoubtedly
involved non-uniform distributions, even "hot particles." The
tissue responses measured have thus largely resulted from non-
uniform sources. If maximal doses are utilized for the incidence
curves which take into account the non-uniformity of distribution,
instead of the average dose to the whole tissue, then the apparent
radiosensitivity, i.e., the dose to produce the effect, would be
correspondingly lowered. The "effective dose" would be much higher
by this convention. Then standards should be keyed to those doses
-------
- 300 - 605
rather than to the calculated average dose. Thus, in a sense the
dosage calculations have led us astray. We should be sure we do not
forget that direct biological information should always take priority.
The great strength of the data for radium in man and of the deri-
vations of many of the standards for internal emitters therefrom,
lies in the fact that activity and effect can be correlated without
obligatorily going through the step of calculating a radiation dose.
This is also true in our extensive animal data with transuranics.
Thus, I personally will await a clear demonstration of a special
effectiveness of hot particles in the lung before accepting a drastic
reduction based on dosage calculations alone.
D. Population Exposures
The enormous impetus of the "fall-out controversy" and the sub-
sequent UNSCEAR and BEAR committee deliberations led first the
Federal Radiation Council^ then the ICRP^8' and NCRP^3-* to set
down specific limits for radiation exposure of the general population
both on the average and to an individual. These were applied to
radioisotope releases in the Federal Code of Regulations essentially
by scaling down the occupational figure by factors of 1/10 or 1/30
(the iodines and particulates have received separate and much more
stringent treatment). Such a scaling down process introduces
many dilemmas for the transuranics as described in a paper I gave
(4)
at the Los Alamos Plutonium Symposium so long as one continues
to use the calculation of dose and critical organ convention.
An alternative, taken up at length in the report of the BEIR
-------
606
- 301 -
Committee ' and in the 1972 UNSCEAR report^ ' is to attempt to
assay total or specific health effects. Estimates of risk and
decisions regarding acceptable risk take the place of comparing
a given exposure with a maximum allowable dose or dose rate. This
approach has its attractions, but it must lean heavily on estimates
of risk derived from a few special human populations.
While there are an increasing number of papers appearing in
which the direct estimation of total or some specific health effect
is employed in connection with aspects of the nuclear fuel cycle
(e.g., Barr^ '), neither ICRP or NCRP has yet officially embraced
this alternative. What effect if any such a change if it does occur
will have on basic and derived standards is difficult to predict,
particularly since opinions are still widely divergent on details
of risk assessment. Nonetheless, it seems unlikely that the
figures for total health effects or even the most likely specific
effects from the presently accepted dose rates or total doses will
be accepted if the technology will permit lower risks without undue
loss of benefits. In any event, the use of a population exposure
figure for the transuranic group of nuclides based on a simple
scaling factor from occupational levels is probably untenable.
Thus change in these, not necessarily drastic, but definite seems
very likely, and it will probably be downward.
E. The Lymph Node Problem
A final example of how dosage calculations, unmodified by bio-
medical information, can lead to dilemmas and claims of overexposure
is seen in the deposition of inhaled nuclides in pulmonary, parti-
cularly bronchiopulmonary, lymph nodes. This was discussed at some
-------
- 302 -
607
(4)
length in my paper at Los Alamos in May 1974. Every toxicologist
knows that insoluble materials leaving the lung deposit, sometimes
in very high concentrations, in the lymph nodes along the channels
of lymphatic drainage of the lung. This is fully true for the
transuranic elements and very high radiation doses can be calculated
as resulting from the amounts deposited. But there has yet to be
found a primary cancer associated with or resulting from these
deposits. The nodes may be completely fibrosed and essentially
non-functional, but no cancer. Lung and bone cancers appear in
the same animals and at much lower calculated doses.
Because of the strong concentration of nuclide in lymph nodes,
dosage rate alone would make them critical organ after inhalation
exposure in nearly all cases of inhalation of insoluble compounds
and derived standards would be automatically reduced. But this
has not been done because of the apparent radioresistance of this
tissue in terms of local cancer induction. Perhaps this should be
recognized and the dilemma of not allowing an "overdose" solved for
the health physicist by providing a more realistic maximum permissible
annual dose rate for this tissue. But I would not personally wish
to see such a move allow doses which would produce significant
fibrosis or other definite damage, and these would probably not be
so far above current dose levels that the dilemma would cease to
exist. On this basis, I feel that a proper accounting should be
made of the lymph node activities and biological changes associated
therewith rather than simply pass the problem by as too difficult to
-------
608
- 303 -
handle. I can envision such a move as resulting in some lowering of
current standards under certain conditions.
Conclusions
This statement is much more speculative in some respects than I
usually allow myself to engage in. But since my subject concerns the
probable future trends of standards for the transuranic elements, I feel
it necessary to indulge in many personal prognostications. These in
summary predict downward alterations of present primary and derived standards
but of magnitudes which would probably not strain current technology unduly.
But on the other hand, it must be stressed that we still need some very
important biomedical information which only time, patience, and careful
scientific work can supply and standards will probably continue for some
time to involve many assumptions which must rest on incomplete information.
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609
REFERENCES
(1) Langham, W. H. and J. Healy, Chapter 12 in Vol. 36 of the Handbook of
Experimental Pharmacology series, entitled "Uranium, Plutonium, and
the Transplutonic Elements." H. C. Hodge, J. N. Stannard and J. B.
Hursh, Ed., Springer-Verlag, New York, Heidelberg, Berlin, 1973.
(2) Dolphin, G. W., Ibid. Chapter 19.
(3) National Council on Radiation Protection and Measurements, Report No. 39,
"Basic Radiation Protection Criteria." NCRP Publications, Washington,
D.C., 1971.
(4) Stannard, J.N., "The Concepts of Critical Organ and Radiation Dose as
Applied to Plutonium," presented at Los Alamos Biology Symposium,
May 1974. To be published in Health Physics.
(5) Durbin, P.W., Chapter 18 in Vol. 36 of the Handbook of Experiment
Pharmacology series, entitled "Uranium, Plutonium, and the Trans-
plutonic Elements." H. C. Hodge, J. N. Stannard and J. B. Hursh, Ed.,
Springer-Verlag, New York, Heidelberg, Berlin, 1973.
(6) Tamplin, A. R. and Cochran, T. B., "Radiation Standards for Hot
Particles, A Report on the Inadequacy of Existing Radiation Pro-
tection Standards Related to Internal Exposure of Man to Insoluble
Particles of Plutonium and Other Alpha-Emitting Hot Particles,"
Natural Resources Defense Council, Washington, D.C., February 14, 1974.
(7) Federal Radiation Council (FRC), Report No. 1, 1960, (U.S. Department
of Commerce).
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610
(8) International Commission on Radiological Protection (ICKP), 1966,
Publication No. 9 (Pergaraon Press, Oxford).
(9) National Academy of Sciences-National Research Council (NAS-NRC),
Division of Medical Sciences, 1972, Report on "The Effects on
Populations of Exposure to Low Levels of Ionizing Radiation,"
(NAS-NRC, Washington, D.C.).
(10) United Nations Scientific Committee on "The Effects of Atomic Radiation
(UNSCEAR), 1972, Vol. II: Effects, (United Nations, N.Y.).
(11) Barr, N. F., "Quantitative Health Estimates of Transuranic Releases,"
Division of Biomedical and Environmental Research, paper presented
at American Nuclear Society meeting, Washington, D.C., October 1974.
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Dr. Mills: Before we turn to the comments and questions, could we
take about a five minute break.
(Brief recess.)
Dr. Mills: I would like at this time to introduce Dr. Karl Z.
Morgan of the Institute of Technology, a member of the panel.
We are happy that Dr. Morgan has recovered partially and is able to
sit with us today.
We will have some scheduling problem. What 1 have suggested is that
we limit our comments and questions of this particular group to about 15
or 20 minutes or so, but ask if they would, if they would stick around for
this afternoon, so if we have any additional questions -
I do not know how much difficulty that will give you people. Those
who can. If they are not around, we may submit some written questions.
Dr. Radford: Will they be able to stay around?
Dr. Liverman: They each have individual travel plans.
Dr. Burr: Some have problems after four.
Dr. Mills: Hopefully we will get through before that.
Dr. Liverman: What about the group from yesterday? Those, too, or
just this group?
Dr. Mills: Does anyone have any questions of the group from yester-
day?
I think it is primarily this group.
Yesterday, I started off with the questions. Today, I would like to
turn it around a little bit: I would like to start with Dr. Taylor.
Dr. Taylor: I would like to make a comment first.
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This group of papers this morning was really one of the nicest
collection of information on the status of this situation that I have
listened to in many a day.
I was going to ask a question, but the question was very nicely
answered for me in the last statement of Dr. Richmond.
I wanted to draw from these people some feeling on their part,
at least their personal feeling, as to whether we were moderately within
base, as it were, with our present plutonium standards for occupational
exposure as well as for population exposure.
I think both of these questions have been adequately answered. Two
things have really come out of discussion: One, that we do not seem to be,
in their opinion, really off base much; and secondly, there is no great
likelihood of there being any vast reservoir of new information develop-
ing as a result of our experience which is likely to change the situation
with regard to our present day standards.
I would just like to ask one general question.
Is that conclusion that I am drawing the same as the conclusion
you people were trying to present? Does anybody want to argue about it?
Dr. Thompson: I think I am on record-if I was not already,
Herb Parker put me on record yesterday-as feeling that the present occupa-
tional standard for plutonium is less conservative than the radium standard
by something like a factor of ten.
I feel that a factor of ten in such a standard is sort of a marginal
change, that you cannot be certain about such things by less than a factor
of ten.
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So I do not consider this to be a serious problem or a major change.
Compared to the standard for radium I think the standard for plutonium is
not quite as safe.
Dr. Taylor: I regard a factor of ten as having one foot on the base
still.
Dr. Thompson: Right.
Dr. Richmond: I would like to add that the usual practice and
procedures followed operationally within the industry is to remove people
when they show a fraction of the maximum permissible occupational burden.
I think it is very interesting that the autopsy data that is now being
accrued from various laboratories and from the United Kingdom suggests
quite strongly that there is a conservative factor built into the bioassey
procedures that are used to estimate the body burden.
So I point out that almost without exception, the amount in the body
at autopsy is less than that predicted.
The reason I make a point of this is that when people are removed
from the particular job, they are put into another. Very often, people
make the assumption that there is no risk with any other operation in the
industry.
We all know this is not true, so I think it is a very important
consideration, the fact that there is apparently this conservation built
in.
Dr. Mills: Dr. First?
Dr. First: I have just one general question. This relates to the
details of the human exposure data; the data base, as many of you have
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mentioned is quite small. This did not come up in your discussions. I
wonder if there has been a consideration of what the confidence limit would
be in drawing conclusions from this small number of cases that you reviewed?
Dr. Richmond: Yes. We have addressed that question in the references
that accompany my information and that was submitted for the record.
There is a reference to a publication which is now available, part of
the Third International Congress on International Radiation Protection,
which was held here in Washington in September, 1973.
It is a very good question you bring up. I think that is primarily
the reason that some of the information I showed this morning reflects the
concern in terms of building up that data base.
Group II is an attempt to increase those individuals that were
exposed back in 1940's. Since we have a three decade period of potential
change.
In the paper I mentioned specifically, we did look at vital statistics
data. You would expect more, perhaps five or six, I believe, as the number
of cancer deaths in a group of say 25 people, let us say, normal individuals
from a population. However, there are only certain kinds of effects one
would expect to see on the basis of the animal data: cancer, notably
cancer of the lung, bone and perhaps liver. So one can make estimates of
the numbers of those kinds of effects one would see, even with a popu-
lation that small.
The number happens to be about one for lung cancer, and a very small
fraction, for example, for bone cancer. So I think it would be disastrous
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not to study a small group on the basis of statistics alone.
It is reassuring because if we saw three or five bone cancers in this
group where we would expect a smaller fraction, perhaps .04, as I remember,
this is very telling.
So, I guess my point is there are only certain kinds of effects that
screens down the statistical problem, in a sense.
Dr. First: This is referenced in your paper? I could find its
reference?
Dr. Richmond: Yes. I could make it available to the Chairman, if
you would like the entire publication.
Dr. First: No. That will be all right. Thank you.
Dr. Mills: Dr. Radford?
Dr. Radford: I have a great many questions, and I may be asking some
of you to come back. I do not want to usurp all of the time this morning
from my colleagues.
It seems to me we are really getting to grips with the issue that
is before this panel predominantly.
Anyway, may I add to what Dr. Taylor had said and congratulate
especially Dr. Bair, but also Dr. Richmond in their presentations, and to
congratulate Dr. Bair especially for the work that has been done at the
Hanford Laboratory on these problems over many years, which obviously goes
back a long time before 1970.
It is regrettable that the operational division of the Agency had not
seen fit to be, perhaps, as vigilant in looking at this problem from the
environmental point of view.
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Now, I would like to address a number of questions and I will try to
keep them down so that 1 wiil give my colleagues on the left a chance.
First, with regard to the current plutonium standard or other trans-
uranic standards, they have been based on bone effects. The .04 occupational
body burden is based on bone end point. Is that correct?
I believe in reading through that section that Dr. Richmond skipped
over, that is the thrust of the statement. Is that correct?
It is a comparison between the radium 226 results and the plutonium
results?
Dr. Richmond: Yes.
Dr. Radford: So that if there were problems in connection with
certain of the transuranic mix that did not have bone as the primary site
of ash, then that approach would not be applicable?
Dr. Richmond: Correct. There are other considerations. For example,
I think you are alluding probably to effects that might occur in a lung.
In that case, there is another primary radiation standard which, I am
sure you know, is 15 rem per year for occupational workers. This standard
is based on other data.
So that it depends on the specific organ which one is concerned with
as to what standard one uses and how it is developed.
Dr. Radford: The version of the body burden standard that I am
familiar with, and I may not have the latest one, does not give a lung
burden as the standard for plutonium 239. Correct?
Dr. Richmond: That is correct in a sense. I think that should be
explained. You will not normally find calculated values in tables for any
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regulation applied to the lung.
Specifically for plutonium 239, let us consider the lung; the derived
standard is a quantity (0.016 microcuries) of plutonium which will deliver
the annual dose rate equivalent which was 15 rem per year.
This is the procedural mechanism that is involved for calculating the
derived standard from the primary standard, which is the dose rate for
various radionuclides.
Dr. Radford: Dr. Richmond, since you are answering, you mentioned in
answer to Dr. First's question, I think, that the data comparing the models
of exposure, say, of lung tissue or other tissue to excretion data or other
criteria by which you calculate body burden, contain an element of con-
servatism because in Britain and the United States finding that perhaps
the model was a little over-estimating the body burdens.
Yet, you state there was good agreement between the calculated and
the observed data by organ tissue in the human samples that you showed in
one of your charts.
To my eyes, that agreement is not really terribly spectacular when you
looked at the particular ones; the big deviation seemed to be the lymph
nodes calculated to be substantially higher than they were since the lymph
nodes, apparently have a fairly large fraction of the total body burden.
That would give the appearance that the body burdens were conservative.
What I just said, is that in accord with your understanding of the facts.
Dr. Richmond: I am not sure I understand, but let me try to answer,
I think there are two issues. Basically, you are right in both.
One comparison I made was with the amount found at autopsy in the body
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as compared with the amount predicted from bioassey data.
There was another comparison made; that is, the amount found in non-
occupational ly exposed personnel or people with the amount predicted from
models that Burt Bennett talked about yesterday which incorporated the
ICRP parameters that determine lung deposition and translocation to
different organs and tissues.
So there are really two comparisons that I made.
Dr. Radford: Which ones do you think are the most important and
relevant?
Dr. Richmond: I have already addressed my responses about how I
view the importance of the finding. Apparently there is a conservatism
built into the bioassey models that are used to estimate the amount
of plutonium in a worker during life.
I think the other comparison is important in that it tells us that
we are not way off base in using the metabolic parameters that have been
developed by ICRP in getting the material from the air through the lung,
for example, to a given organ.
Dr. Radford: I am referring to Table X in your paper, "Plutonium 239
in Man." You have Colorado-New Mexico and New York. That is the table
I am referring to.
Those are occupational exposures?
Dr. Richmond: These are non-occupational exposures.
Dr. Radford: Do you consider the agreement good there?
Dr. Richmond: Yes, I see your question now. You are concerned about
the fact that the lymph burden as measured is .03; whereas computed, it
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is .6.
Dr. Radford: Right.
Dr. Richmond: That is the one tissue that does not agree well. I
think my interpretation is that the particle size -
Dr. Radford: All the other organs show higher values when you
calculated, so to that extent, if you are talking about other tissues
than lymph nodes, the exposure would be underestimated.
Dr. Richmond: I think there are a lot of uncertainties in these
values. When you are talking about measuring small quantities. You have
.3 piocuries for an entire lung. There is a notable difference in the
lymph tissue.
My own feelings there are, this case represents plutonium from fall-
out. It is relatively small particles, and the quantity is small so you
do not have a physical entrapment, for example, in a lymph node, because
of radiation dose considerations.
You have transit through the lymph tissue. These are reflections on
the kind and size of plutonium during fallout.
Dr. Radford: I think it was brought out yesterday that the fallout
distribution of both isotopes and particle size may be quite different from
the kind of thing you have observed occupationally or in the environment
around a nuclear facility.
That is correct, isn't it?
Dr. Richmond: Yes. I think basically one would expect these to be
different, but I think you have to actually have a set of data to compare
one to the other.
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Dr. Radford: I would like to ask the question, when you do these lung
measurements, how do you actually measure the plutonium in the lung that
you report on these tables, lung tissue. How is it actually done?
Dr. Richmond: You are referring to the analytical procedure?
Dr. Radford: I do not care about the radionanalytical part. I mean
you have a cadaver lying there. What happens? How do you sample?
Dr. Richmond: The samples are taken by pathologists who are involved
in these studies in a cooperative basis. They are sent to the laboratory
involved.
Dr. Radford: OK. What does the pathologist give you?
Dr. Richmond: The samples that are asked for.
Dr. Radford: What you ask for?
Dr. Richmond: Lung, lymph nodes, bone. The ones that were indicated.
There are established procedures in terms of quantities requested; if
possible, entire half lung, or one lung.
Dr. Radford: Do you get whole lungs?
Dr. Richmond: In some cases, yes.
Dr. Radford: When you get a whole lung, you put it in a blender and
measure the whole lung?
Dr. Richmond: The samples are processed by both wet and dry procedures,
put in ovens and reduced. Ultimately, one does a chemical separation and
then does spectroscopy, identifying the alpha emitters, following electro-
deposition, by measurement of the actual energy of the alphas involved,
238, 239 or whatever.
Dr. Radford: Would it be fair to say most of the lung samples you
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mentioned up to now have been pices of lung obtained by the pathologists
rather than whole lungs?
Dr. Richmond: It is very difficult. I think what one would have to
do is sit down and look at the data base.
For example, many of the individual autopsies that date back into the
1940's, say, in Hanford and Los Alamos, were done in small communities with
local people. It was not uncommon to be able to obtain entire lungs.
I think more recent in history, it is progessively difficult to get
entire organs.
Dr. Radford: Those measurements, to summarize then, are basically
lung paretum measurements?
Dr. Richmond: I think again — I hate to make broad statements. I
think one would have to go back and look at the actual information. There
are very detailed studies looking at, for example, the periphery of the
lung just under the outer covering, looking at different portions of the
lung.
So it depends. In addition to looking at the entire amount within an
organ, there have been other attempts to see if the concentrations vary.
I think in most cases, the primary piece of information one gets is
the total amount of plutonium in the tissue sample that is submitted.
Dr. Radford: I have a lot of other questions, both for you and for
Dr. Bair, but I would like to ask just one final question so we can move
on to the next questioner.
Did I read your statement correctly, that in the one case of hematoma
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that occurred in an early exposed group, that the total burden as measured
was largely the lymph nodes and it was eight nanocuries?
Is that a correct statement?
Dr. Richmond: I believe that is correct. It is estimated to be eight
nanocuries, roughly, evenly distributed between the lung and lymph tissue.
Dr. Radford: So in that one istance, a rather rare tumor, which may
be of low malignancy, but nevertheless would be life threatening if it were
not operated on, was obtained with the body burden well below the current
value of 40 in lung tissue?
Dr. Richmond: Would you repeat the question, please?
Dr. Radford: The question is, there is one tumor of the thorax which
has been observed in this group of 21 that have been followed. That tumor
arose, a rare tumor, unusal; you would not expect to find it in 21 people
or even maybe 21,000.
Yet, that occurred in a person with eight nanocuries body burden,
most of which is in lung tissue.
Dr. Richmond: I think what I would like for you to do is to refer to
Appendix I in the Health Physics paper which we wrote on this, which is
Volume 25, 1973.
There is an appendix referring to the medical follow up on patient
#2. I do not presume to be a physician. I think it would be unfair for
me to try to answer that kind of question.
Dr. Radford: OK. I would like to indicate that I would like to ask
many more questions, since these are very important presentations.
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Dr. Mills: Dr. Garner?
Dr. Garner: I would like just to refer back to the dialogue between
Dr. Radford and Dr. Richmond.
There are two models: One is an excretion model used for predicting
body burdens from urinary excretions data. The other model he was
referring to was a model based on the ICRP model, two entirely different
things.
I would like to come back to Dr. Thompson, who seems to extrapolate
from animal data. Once you choose to extrapolate from animal data, you
open up an enormous can of worms.
I would like to ask a couple of questions bearing on this.
One is, all the data so far, at least the data you referred to, was
obtained on a homogeneous group of healthy animals, I would presume. I
would like to ask if any data exists on modification and response; for
example, intercurrent bacterial infection?
Dr. Bair: To my knowledge, no plutonium experiments are in progress
with animals that have been subjected to bacterial infection.
There is an experiment in progress where animals are being exposed
to plutonium plus benzo(a)pyrene. Also, an experiment with asbestos plus
plutonium has been done.
Dr. Garner: Isn't there some work of the Lovelace Foundation on this
problem?
Dr. Bair: I believe it is a pulmonary clearance.
Dr. Garner: I thought it had something to do with mataplastic and
neoplastic tissue.
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Dr. Bair: It may be, but I am not aware of it.
Dr. Liverman: We do have a man here from Lovelace.
Dr. Hobbs: I am Chuck Hobbs of the Lovelace Foundation. We do have
some work which has not been published on the combined effects of plutonium
inhalation and influenza infection, both in mice and in hamsters.
It is in the earlier stages.
Dr. Garner: So something is going on anyway. That is what I wanted
to establish.
The second thing is, I would like to ask Bill Bair if, in fact, the
spectrum of tumors that was seen in animals produced by plutonium and other
transuranium elements can be expected in humans?
Isn't there a difference in the type of tumors? Isn't this a big
problem, the extrapolation from animals to man?
Dr. Bair: The question of extrapolating from animal experiments
to man is important. In animals which have inhaled plutonium the site of
origin of the tumors appears to be primarily in the lung periphery. I
would expect the same thing in man.
In the event of a human exposure, I would expect the plutonium to be
deposited and accumulated in essentially the same areas of the lung that
accumulate plutonium in experimental animals.
Consequently, if a tumor develops, I would expect it to originate in
the lung periphery.
In experiments being performed in laboratories in the United States
and France, the types of tumors observed are similar to the types of tumors
that occur in man.
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In France, they are seeing an equal number of squamous cell carcinomas
and bronchiola alveolar carcinomas in rats after inhalation of plutonium
and other transuranics.
One difficulty in extrapolating to man from experimental animals is
man himself. As you have already brought out, man is exposed to many
toxic agents. Smoking, certainly contributes to the pathology of the
human lung and we do not know how this might influence the response to
inhaled plutonium. The fact that pathologists often disagree in classi-
fying tumors and identifying the origin of tumors in human lung creates
a further problem.
In summary, I believe the origin of tumors and the types of tumors
which occur after inhalation of plutonium are reasonably well identified
in experimental animals. I would expect a similar response in human
beings, unless complications were brought about by the exposure of human
beings to other agents.
Dr. Garner: Just one final comment, for Dr. Thompson. I appreciated
his presentation very much, but I thought he started off on the wrong foot
because he skipped the real big problem.
He mentioned unacceptable risk because the problem is what is an
acceptable risk.
Dr. Mills: Dr. Morgan?
Dr. Morgan: I would like to ask Bill Bair how he would interpret
today the early experiments of Finkle et al where small amounts of plu-
tonium, as small as one microgram of plutonium 239, were injected in the
animals and got about a 40 percent to 50 percent incidence of tumors.
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Yet, the tissue involved, the tissue at risk is essentially the same
type of tissue that is involved in parts of the lung.
Have you any interpretation of the reason that we have these
differences?
Dr. Bair: No. I am not prepared to answer that question. I would
have to look at the experimental data.
Dr. Morgan: There are several other data that suggests that wounds
are particularly vulnerable at the site, and yet as I say, it is some of
the same type of tissue that behaves differently, apparently, in the lung.
First of all, I should commend each of you for the very fine and
scholarly presentations that you have made.
Dr. Burr, you mentioned the fact that common forms of cancer that
will undoubtedly occur in former employees in the National Laboratory's
production facilities and so on, that these should not be taken as evidence
that they resulted from the exposures to plutonium.
Perhaps you did not intend to underline the words "common forms of
cancer," but my question is, what types of cancer are you thinking about
that we should focus on?
Certainly, you would be concerned about increased instances of these
common forms, but did you mean to imply that there are other types we
should be looking for?
Dr. Burr: Your interpretation is right: I should not have put the
emphasis on "common." In other words, what I was trying to point out is
the fact that if one sees cancer; that does not show a causal relationship
because in a population like this, one anticipates that there will be
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cancers and cancer deaths.
What I was trying to emphasize is that we are going to be taxed to
considerable extent with the sizes of population to try to decide if there
is indeed an increase in the number of incidents.
You are quite right. That is what we are looking for, an increase in
incidents of any tumors as an indication of the effect.
There was one other point I wanted to make that Dr. Richmond made
earlier - but it slipped my mind now - in one of his earlier answers,
which I thought in part answered that.
Dr. Morgan: Dr. Richmond, you recall some of the earlier exposure
data on humans where presumably we have good information on the quantities
that were administered to these humans and yet give data on the total body
content.
Is their information on the distribution of the body organs — It
seems to me that to know the distribution in the human body from a known
intake, and of course, we would like a known intake primarily from
insoluble plutonium oxide forms, what would the distribution be in the
lung, the liver, the bone and osteotissue of the bone, as a function of
time and age of the individual, having taken in the known burden of
plutonium oxide by inhalation?
It seems to me maybe this is the $64 question, because you may have
some evidence that turns the heat off the hot particle problem, at least
in my eyes it does, or at least may shelve that problem until we get more
information.
But I do not think we have any cause to relax our concern for the
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Certainly, it is evidence, I believe, that it is not the lymph nodes
that presumably receive the largest dose, so the tissue of highest dose
is not the accurate or necessarily sufficient criterion of the critical
organ.
Dr. Richmond: Let me say I agree very wholeheartedly with your last
comment. The particular case that Dr. Radford was referring to earlier is
pointed out in the appendix to our 1973 paper in Health Physics. It is of
interest and is consistent with much information obtained from other
experimental data.
We sometimes see changes, high concentrations or relatively high
concentrations and yet, essentially, no biological effects relative to
effects you see in the lung, for example.
Dr. Morgan: Dr. Thompson, you referred to the BEIR Report and the
extrapolation from external exposure primarily. The, going to the use of
the alpha emitters, the use of the RBE and the end factor of the non-uniform
distribution.
But it seems to me that there are a number of other factors that he
might have focussed on. One that was brought out in the meeting at Alta,
Utah this past summer and was emphasized is the fact that with human ex-
posure to radium 224, which like plutonium 239 deposits on the surface
tissue of the tibecular bone, because it does not have time, having a
short half-life, to be buried as does radium 226, so this radium 224 de-
posits, then, on the surface and behaves very much than like plutonium 239.
This is human data. It was emphasized at this meeting that pro-
traction of the dose enhances the hazard rather than diminishes the
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hazard, as is the case with external exposure.
Of course, this might be something that would be great concern or
great interest, let us say, for chronic long time exposure to humans
because that certainly is protracted exposure.
Would you care to comment on this?
Dr. Thompson: I think that is a very significant observation and
one which certainly is applicable to this problem,
One can speculate that this observation might be explained in terms
of a more uniform distribution of the dose. Just as is seen in other
experiments on a spatial basis, here we have a more uniform distribution
on a time basis and we are exposing more cells by fractionating the dose
in time.
I did not mention the radium 224 data specifically, although it was
included on the one viewgraph. But this is an important source of infor-
mation on human effects which, though it is not plutonium data as
Dr. Morgan has explained, its distribition in bone is perhaps very
similar to plutonium because of its short half-life.
Dr. Morgan: Also, you had a graph that gave, I believe, the effects
axis of the dose — you indicated it was more likely to be asymptotic to
the dose axis than to the effects axis.
This would seem to be contrary to the paper given by Dr. Bonn at
the annual meeting of the Health Physics Society in Houston this year in
which he plotted his data on bi-rythmic curve, and it's the best fit of the
data for alpha emitters in humans.
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For the function, say, of effect E equal to some constant times
dose to the nth power, the best fit was to take n equal to one half
rather than one, or something greater.
This would mean it would likely become asymptotic to the effects
axis rather than the dose axis.
Do you have any comment on this, or any criticism you would like to
make of Dr. Bonn's report?
Dr. Thompson: I did not hear the report and I have not got a clear
picture of it. From this brief discussion, I would say, in the first
place, my figure was not semi-logarithmic. It was meant to be linear.
I do not know how that would affect your question.
It does seem to me, though, on almost intuitive grounds, that
when you get down into the range of background exposure, you can not have
a steeply rising curve relating effect to dose.
Otherwise, there would be such a tremendous advantage to living
in a low background area that our higher elevation areas would be
unpopulated.
Dr. Morgan: We could discuss this later.
One final question, to the panel. I do not address it to anyone
in particular, but following up on Dr. Taylor's question, it may be as
I said before, we cannot resolve to our liking the question of the hot
particle problem.
It has been with us, or at least with me, for over 30 years. It is
recognized for that long. But the question of the incidents of tumor in
bone, if we look at that and take the excellent data at Utah it would
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seem to me that the end factor could be increased somewhere between,
somewhere in the neighborhood of 10 to 15.
So we might have justification of increasing the end factor of the
present guideline. We now use for Q the body burden based on bone by
a factor of three.
Dr. Thompson and Dr. Bair pointed out, I believe it was in the
paper in Science in February of the past year or this year, that the
surface to volume ratio where you have the deposition on the skeleton
of the actinide elements is roughly twice that in a dog to that in a
human.
So that would have a factor two. Then, Bill, both you and Roy
pointed out that the burial effectiveness of the actinides, presumably
ten times greater in a dog than it is for man.
The rate of burial, so there we have a factor of ten.
Then there is the French paper which shows that in the case of
primates such as the baboon, that they are four times more radiosen-
sitive in terms of survival following exposure to plutonium oxide than
is man.
That would be a factor of four.
So it would seem to me, if you would multiply all of these
together, you end up with something of a hundred or more rather than
your factor of ten.
It seems to me, then, setting the exposure value based on bone's
critical tissue, that maybe our present value should be lower by a
factor of 100.
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I believe you said maybe by a factor of ten.
Dr. Bair: I might comment about the appropriateness of multiply-
ing factors and identify at least one that perhaps should not be
multiplied by the factors for bone that you mention.
That is, the factor you mentioned with regard to the baboon
studies in France. I believe the life shortening in these baboons
was due to plutonium dioxide in lungs and not to radiation exposure
of bone.
I am not sure you would want to multiply a factor obtained for
lung by other factors that pertain to bone, without at least some
modification to reflect the distribution of plutonium between these
two tissues.
Dr. Thompson: I think Dr. Morgan and I agree that there is some
reason to perhaps lower the standard. Whether it is by a factor of
ten or a hundred, I do not think this is probably the place to try to
settle that issue.
I do think that there is a question about the multiplicability of
all these various factors.
Dr. Richmond: I would like to add to that, if I may. I think it
is important to realize that these are studies that are underway.
We are now trying to find out more about the relative deposition,
bone surface to volume ratio in dog, man and other animals, and make
refinements.
I guess my personal feelings are I think we had better get more
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of this information and try to understand it a little better before
we do calculations and get too carried away with them.
To me, that is a very important thing. We are recognizing some
of these factors, but they have not been quantitated yet. Personnally,
I think a lot needs to be learned yet.
Dr. Mills: Dr. Radford has one more question.
Dr. Radford: I would like to ask this of the whole panel because
it is germane to some of the discussion we have been having on the
effects of dose.
I think you gentlemen are all familiar with the ICRP publication
on the relative biological effectiveness concept and the conclusions
that the ICRP committee drew on that.
It is presented in the form of a graph which shows, for example,
that if you plot the effect as a function of dose for low radiation,
the power may be greater than one which is consistent with an exponent
of less than one, meaning that the curve effect is a curve linear down-
ward to the axis.
The point I want to ask, do you not infer from this, as indeed
the ICRP committee inferred from this, that the relative effectiveness
of high L.E.T. radiation is greater at lower doses than at higher
doses?
Dr. Thompson: I will tackle at least one aspect of that question.
The question in my mind is when does this curve — if there is an
enhanced effect of dose — when does that curve come down? It curves
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634
down some time before it gets to zero. It's got to reach zero at zero
dose.
I do not think there is any evidence I am aware of to indicate
where in this area that curve comes down.
My feeling is it comes down before you get to the background
region — it does not just come down asymptotic to the effect axis.
But we do not have experimental data in this area. I revert to my
basic conviction that the important point here is not dose, but the
effects, as seen in experimental animals.
Dr. Radford: As you know, in the uranium miners, there have been
considerable discussions on just this point. I heard some data pre-
sented at the Seattle meeting this year, showing that more recent
uranium mine data does support the concept of the relative effective-
ness per rad dose does go up at the lower dose.
This has been the orthodoxy.
Dr. Thompson: But these lower doses are still far higher than
natural background.
Dr. Radford: Sure, I am not talking anything about natural
background.
Dr. Thompson: This (natural background) is the area of concern
as far as general populations are concerned.
Dr. Radford: But the point is that a group of people from the
ICRP who are very knowledgeable about the whole theoretical and experi-
mental basis did conclude that one would expect the R. B. E. would
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635
increase at lower doses; that is, low L.E.T. radiation becomes less
effective in low doses where high L.E.T. radiation would stay about
the same.
I am not saying it is getting more so.
Dr. Mills: I hate to cut this discussion off, but I would like
to add to the panel opinion here, that the material you have submitted
is well documented.
Thank you very much.
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636
SUPPLEMENTAL ADDITIONS TO THE AEC TESTIMONY
-------
- 307 -
U' : .ID STATES,
ATOMIC EIVRGY COMMISSION
WASHiriGTON, D.C. 20545
637
AUG 1 6 1374
Clarence C. Lushbaugh, M.D.
109 Darwin Lane
Oak Ridge, Tennessee 37830
Dear Dr. Lushbaugh:
The Atomic Energy Commission has received from the Natural Resources
Defense Council a petition to establish special standards for alpha-
emitting radionuclides in insoluble, particulate form. A copy of this
petition, and a supporting statement submitted with the petition, are
enclosed. On pages 26 through 29 of the supporting statement a
quotation from an article by C. C. Lushbaugh and J. Langham, published
in the Archives of Dermatology in 1962, is used as the basis for the
following conclusions:
(1) A single Pu-239 particle is capable of inducing cancer;
(2) The risk of cancer may be greater than 1/1000 per particle.
The Commission's standards for exposure to insoluble, airborne
plutonium and other alpha-emitters are based on a permissible lung
burden of 16 nCi, which could consist of many thousands of particles
deposited in the lung, the actual number depending upon the size of
the particle. For example, 16 nCi is equivalent to 2 x 10^ particles
of 0.3-micron diameter. The risk associated with such a large number
of particles would obviously be unacceptable if the risk pe,r particle
is as great as concluded in the supporting statement.
The Commission is currently conducting an evaluation of its standards
for airborne, alpha-emitting radionuclides in insoluble form, and
great importance is attached to the risk which may be associated with
relatively small numbers of alpha-emitting particles in the lung. In
this connection we would appreciate receiving from you a statement as
to whether your findings in the case reported in the Archives of
Dermatology do in fact support the two conclusions drawn in the
supporting statement, as listed above.
Sincerely yours,
:er Rogers
Director of Regulatory Standards
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638
September 10, 1974
Mr. Lester Rogers
Director of Regulatory
Standards
U.S. Atomic Energy Commission
Washington, D.C. 20545
Dear Mr. Rogers:
In reference to your letter of August 16, 1974, I should
point out that earlier this year I worked with Dr. Bruce Wachholz
of Bio-medical Prograras, DBER, Germantown Headquarters, on the
initial stages of a document recently numbered VIASH-1320;
.entitled, A Bad-iobio'log-Lca.l Assessment of the Snatial Distinbiiti-on
of Radiation Dose from Inhaled Plutonium Particles; and authored
by W. Bair, C. Richmond, and B. Wachholz.Although I have not
seen this paper in its final form as it is at this moment still
•being printed, I am certain that it contains an attempt to
answer the question of whether or not Mrs. Langham's and my
article in Archives of Dermatology (1962) supports the contention
of Dr. Tampion and Mr. Cochran that a single particle of Pu-239
is capable of inducing cancer and that the risk of cancer fron
such a particle is 1 per 1000. We believe that these conclusions
cannot be derived from the histopathologic observations we reported
In this case report nor in the other cases we subsequently puiiished
along with it in the Annals of the New York Academy of Science.
In the petition from the Natural Resources Defense Council to
which you refer, one can see that the authors apparently do not
know the difference between a precancerous cellular change and a
cancer. While it is true that the term "precancerous change" contains
the' implication that a cancer follows it, this is not always the case
because precancerous changes are reversible and reparable. In fact
when a lesion showing precancerous changes is renoved surgically,
the surgeon knows from this diagnostic ir^ression given him by
the pathologist tv»at the lesion he reooved is :.ot a cancer and that
he
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-309' 639
Mr. Lester Rogers -2- September 10, 1974
the term "precancerous" to describe the cytologic appearance of
sons of the epithelial cell nuclei around the plutonium particles
in the skin of the case in Arch. Dermatol. was to point•out that
in spite of tha amazingly huge dose of alpha radiation over
a period longer than 4 years a cancer had not developed and
that one could at most only call the changes pre-cancerous.
In reviewing this case in the Annals of the New York Academy
article/ we attempted to show that the strictly localized injury
caused by the plutonium particles was developing in such a
fashion (like a pimple) that the particles would have been shed
in time along with a small amount of pus-like material as the
pimple "ripened" and drained spontaneously. Dr. Tamplin-in
his arguments assumes that fibrosarcomas in rat skin are equate-
able with the minimal changes we described in the skin of this man.
Of course, they are- not. The statement that it is "clear" on the
basis of this one human case that plutonium can cause skin
cancer in man is false. If this case and others like it show
something of radiobiologic importance, they show only that the
development of cancer from plutonium exposures of human tissues
must be much more difficult to obtain than cancers in rodent
tissues, since no human cancers have ever been seen or reported
following plutonium exposure of human beings. Logically, if
there is rro observed plutonium-induced human cancer case, the one
per thousand per particle level of cancer risk for plutonium
exposkre has no basis in fact and amounts to only a conjecture
on-lthe part of the authors of the NKDC petition.
C. C. Lushbaugh, M.D ,-Ph.D
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640
- 311 -
A Critique of the Tamplin-Cochran Proposal
for Revision of the Current Plutonium Exposure Standards
Roy E. Albert, M.D.
Professor and Vice Chairman
Institute of Environmental Medicine
New York University Medical Center
March 25, 1974
Summary
Largely on the basis of rat skin tumor experiments, Tamplin
and Cochran propose that a single radioactive particle in the
lung which delivers a local dose of more than 1000 rem per year
will produce focal tissue damage and that this focal damage per
se confers a risk of lung cancer of one in two thousand.
A review of current knowledge about the relationship of
tissue damage to the induction of cancer does not support the
contention that tissue damage is a proximate cause of cancer;
rather that tissue damage represents a parallel toxic action of
carcinogens which, to some extent, may enhance the development
of tumors produced by carcinogens. Since the Tamplin-Cochran
proposal is based almost wholly on radiation tumor studies of the
rat skin hair follicles, the decisive argument against this
proposal is the evidence that focal alpha irradiation of localized
regions on the hair follicle, in a pattern similar to that from
a plutonium particle, is non-tumorigenic.
The Tamplin-Cochran Proposal (1)
The authors point out that the current ICRP occupational
exposure standard for insoluble plutonium in the air is
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641
4 x 10~H uCi/ml. This is the calculated level of atmospheric
contamination that would lead to a maximum permissible lung
burden (MPLB) of 0.016 uCi and would be associated with a maximum
permissible lung dose of 15 rem/yr when the radiation dose is
averaged over the entire lung.
They point out that the dose is not delivered uniformly to
the entire lung:
"It would take 53,000 particles...(1 u in diameter,
0.28 pCi)—to reach the MPLB of 0.016 uCi which results in
15 rem/yr to the entire (1000 g) lung. However...these particles
would irradiate only 3.4 g of this 1000 g to the lung, but at a
dose rate of 4000 rem/yr...these particles result in an intense
but highly localized irradiation. A fundamental question is,
then: is this intense but localized irradiation more or less
carcinogenic than uniform irradition?" (ref. 1, pg. 17).
The Tamplin-Cochran approach to the risk assessment from
hot particles is based on the Geesaman Hypothesis (2, 3) which
in turn is based almost wholly on the radiation skin experiments
of Albert and co-workers. The interpretation placed on these
experiments by Tamplin and Cochran and the rationale for their
proposed standard is described by the following excerpts from
their report (1).
"A high incidence of cancer was observed after intense
local doses of radiation, and the carcinogenesis was proportional
to the damage or disordering of a critical architectural unit
of the tissue, the hair follicles." (ref. 1, pg. 23).
"Certainly a reasonable interpretation of these experimental
results is: when a critical architectural unit of a tissue
(e.g., a hair follicle) is irradiated at a sufficiently high
dosage, the chance of it becoming cancerous is approximately
-------
642
- 313 -
10~3 to 10~4. This has become known as the Geesaman hypothesis."
(ref. 1, pg. 26) .
"Geesaman indicates that the tissue repair time in the lung
is of the order of one year. It therefore seems appropriate,
but not necessarily conservative, to accept as guidance that
this enhanced cancer risk occurs when particles irradiate the
surrounding lung tissue at a dose rate of 1000 rem/yr or more."
(ref. 1, pg. 33).
"As seen from Table IV, using Geesaman1s lung model, a
particle with an alpha activity between 0.02 pCi and 0.14 pCi
is required to give a dose of 1000 rem/yr to irradiated lung
tissue. For purposes of establishing a maximum permissible lung
particle burden we will use 0.07 pCi from long half-lived
(greater than one year) isotopes as the limiting alpha activity
to qualify as a hot particle." (ref. 1, pg. 34).
"The existing standards for uniform radiation exposure of
the whole body or lung can be used as the basis for establishing
particle exposure standards by equating the risk of cancer
induction between the two types of exposure (uniform vs. grossly
non-uniform). The most recent assessment of the risk associated
with uniform irradiation of man was performed by the NAS-NRC
Advisory Committee on the Biological Effects of Radiation.
Their report, published in 1972, is referred to as the BEIR
Report.
The existing occupational exposure standard for uniform
whole body irradiation is 5 rem/yr and for the lung, 15 rem/yr.
The BEIR Report estimates that exposure of the whole body of an
individual to 5 rem/yr would le\d to a cancer risk between
4.5 x 10~4 and 2.3 x 10~3/yr. Their best estimate is 10~3/yr."
(ref. 1, pgs. 41-42).
"It is recommended here that the best estimate of the
effects of uniform exposure by the BEIR Committee be used
together with a risk of cancer induction of 1/2000 per hot
particle in determining the MPLPB for insoluble alpha-emitting
radionuclides in hot particles. This is a somewhat arbitrary
compromise and is not the most conservative value that could
be recommended. Thus, the recommended MPLPB for occupational
exposure from hot particles of alpha-emitting radionuclides in
the deep respiratory zone is 2 particles. This corresponds to
a MPLB of 0.14 pCi and represents a reduction of 115,000 in the
existing MPLB." (ref. 1, pgs. 43-44).
-------
- 314 -
643
Differences Between the Tamplin-Cochran Proposal and the Geesaman
Hypothesis
Whether intentional or not there is a subtle but important
difference between Geesaman's hypothesis and the Tamplin-Cochran
proposal. The pertinent portion of Geesaman's conclusion is the
following:
"Tissue injury and disturbance are a primary consequence
of intense radiation insult, and are observed in association with
carcinogenesis. Albert has exhibited a simple proportionality
between skin carcinomas and atrophied hair follicles. No general
description of precarcinogenic injury exists, but in a crude
sense the available observations are compatible with the idea
of an injury-mediated carcinogenesis. Cancer is a frequent
instability of tissue. Since tissue is more than an aggregate
of cells, and has a structural and functional unity of its own,
it would not be surprising if some disrupted local integrity,
a disturbed ordering, comprises a primary pathway of carcinogenesis.
The induction of sarcomas with inert discs of Mylar, cellophane,
Teflon and Millipore (Brues et al.) is indicative that such a
mechanism exists." (ref. 3, pgs. 6-7).
Geesaman is saying that ''...some disrupted local integrity,
a disturbed ordering, comprises a primary pathway of carcinogenesis."
This ireans that it is not the radiation but rather the tissue
damage which is the proximate cause of cancer.
Tamplin and Cochran blur the issue by saying: "Certainly
a reasonable interpretation of these experimental results is:
when a critical architectural unit of a tissue (e.g., a hair
follicle) is irradiated at a sufficiently high dosage, the chance
of it becoming cancerous is approximately 10~3 to 10~4 . This
has become known as the Geesaman hypothesis." Taken literally,
Tamplin and Cochran do not require that tissue damage be produced,
only that the "...critical architectural unit is irradiated at
a sufficiently high dosage..."
The Tamplin-Cochran proposal is evaluated here from two
standpoints: (1) the Geesaman hypothesis, i.e., does tissue
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644
damage, per se cause cancer? (2) The Tamplin-Cochran interpretation
of the Geesaman hypothesis, i.e., would intense irradiation of
a "critical architectural unit" cause tumors, regardless of
whether damage was produced?
The Theory that Tissue Damage Causes Cancer
The Geesaman hypothesis, on which the Tamplin-Cochran
proposal is based, revives one of the oldest theories of cancer,
namely that the cause of cancer is chronic tissue damage. This
is the chronic irritation theory propounded by Virchow in 1863.
As reviewed by Oberling (4) , the theory was in vogue for about
50 years. It stemmed from the early clinical observations that
cancer rarely appears in healthy tissue and is almost always
preceded by chronic inflammatory conditions such as scars,
ulcerations or fistulas. Post-mortem observations in this era
suggested that the same association applies to internal organs.
Virchow pointed out that every injury of tissues is followed
by a state of irritation in which the cells are stimulated to
multiply in order that the damage may be repaired. If the
noxious influence persists, the irritation persists with it and
the proliferation grows more and more excessive and irregular.
Virchow argued that if such a condition persists year after
year, cancer will occur.
The Virchow theory claimed that chronic irritation was the
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645
sole and non-specific cause of cancer, i.e., cancer was the
secondary outcome of a whole series of conditions widely
differing from one another and possessing no features in common
except chronic damage.
As pointed out in a review by Berenblum (5), Virchow's
theory was demolished by experiments beginning in 1918 which
showed that cancer can be produced by very potent substances
that vary widely in their capacity to cause damage whereas many
agents which cause damage do not cause cancer. Furthermore,
there are many conditions in humans in which tissue disorganization
and damage is a characteristic feature where no association
with cancer has been demonstrated, e.g., tuberculosis and
silicosis of the lung and traumatic injuries associated with
war wounds that have occurred by the millions during this
century. The focus of cancer research long ago shifted away
from tissue damage as a cause of cancer. Nevertheless, the
frequent association between tissue damage and cancer remains
valid for many types of human and experimental cancer but there
are other types of cancer where no association exists.
The most probable reason for the association is that
virtually all carcinogens are highly toxic agents. The only
outstanding exceptions are the oncogenic RNA viruses. There
are many examples to show that an appreciable yield of tumors
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646
can be produced only at carcinogen doses which cause a large
amount of cell death in the target tissue. This can be seen
for example in relating the doses of radiation required to
produce tumors in mouse skin (6) to those which cause cell
death (7). The action of chemical carcinogens and ionizing
radiation in producing the parallel effects of cell death and
neoplastic cell transformation is also evident in tissue culture
studies (8, 9).
There are various forms of damage produced by carcinogens
which depends mainly on the target tissue. For example,
application of a chemical carcinogen or ionizing radiation to the
surface epidermis of the skin or the bronchial mucosa results in
cell loss followed by a hyperplastic response in which the number
of epithelial cells is much increased for long period of time.
In the bronchial epithelium the hyperplasia is also accompanied
by squamous metaplasia of mucosal cells. Another form of tissue
damage can be produced by inhaled radioactive particles which
deposit in the alveoli; such particles can produce fibrotic
damage. Atrophy is still another form of tissue damage as
illustrated by the damage to the hair follicles in the
irradiated rat skin.
Although tissue damage cannot be assigned a primary causal
role in cancer induction, there are various ways in which tissue
-------
- 318 -
647
damage could contribute to tumor formation. One possibility is
that the killing of a portion of cells in the target tissue has
the consequence of stimulating the survivors to proliferate in
order to restore the cell population. There is evidence that
neoplastic transformation does not become fixed unless cell
division occurs within a relatively short period after carcinogen
exposure. This is true for ionizing radiation (10) and viruses
(11). The likelihood of producing transformed cells could thus
be increased by provoking cell division particularly in a tissue
which normally has a low rate of proliferation.
There is evidence that neoplastically transformed cells in
physical contact with normal non-transformed cells are inhibited
from proliferating (12). Tissue injury could free transformed
cells from this type of growth restraint.
It is possible that an area of tissue, heavily damaged by
a carcinogen, particularly with scar formation, would coistitute
an immunologically privileged site and thus interfere with
important defense mechanism against neoplastically transformed
cells (13) .
There are several other speculative ways in which damage
could contribute to tumor formation which can be mentioned: cell
damage might interfere with repair of carcinogen-induced DNA damage;
dedifferentiation of surviving cells in a heavily damaged organ
-------
648 - 319 -
could make them more susceptible to infection by oncogenic
viruses, as with the irradiated thymus (14); in the case of
chronic carcinogen exposure the increased cell proliferation
induced by tissue damage could make cells more susceptible to
the transforming action of a carcinogen.
Although all of the above mechanisms for the enhancement
of carcinogen effects by various forms of tissue damage have
some basis in scientific evidence, the degree of importance as
contributing factors has not been established.
The Effect of a "Hot Particle" Type of Irradiation Tumor Induction
in the Rat Skin
The Tamplin-Cochran proposal uses mainly the results
obtained by the Albert-Burns radiation skin experiments to
infer alpha-particle risks in the lung. Hence, the critical
test of their hypothesis is the question of whether a hot
particle pattern of alpha irradiation of the skin could produce
tumors.
Two approaches were used in skin experiments. The first
approach determined whether isolated areas of irradiated skin
gave the same yield of tumors per unit area as large-area skin
irradiations. The focal irradiation pattern was produced by
use of sieve plates. Low LET radiation, such as electrons (15)
and soft X-rays (16) showed pronounced suppression of tumor
-------
-320- 649
formation with sieve irradiation. A higher LET radiation
(protons) did not show a protective effect of sieve radiation
(17).
The second approach involved the use of irradiations at
different depths in skin. The results of electron irradiations
with different penetrations on the induction of tumors and atrophic
follicles suggests the existence of target cells at a depth of
about 0.3 urn in the skin corresponding to the lower end of the
resting hair follicle (18). This critical depth remains constant
even when the skin is irradiated with the hair in the growing
phase, i.e., when the follicles extend to a depth of 0.8 mm
(19). There is a quantitative association between the incidence
of tumors and atrophic follicle for various types of ionizing
radiation, various spatial distributions of dose within the skin
and for different phases of hair growth (20). In our view, a
plausible explanation for the experimental results is thet each
follicle has a population of stem cells at a depth of 0.3 mm
that are concerned with the production of sebaceous cells and
hair. These stem cells constitute the most sensitive tumorigenic
cell population to ionizing radiation in the rat skin. The
tumors are mainly of hair follicle origin (21). Neoplastic
transformation of a significant number of these target cells
requires large radiation doses which in turn kills most of the
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650
- 321 -
target cells and thus causes follicle atrophy.
Since the radiation from alphas has a range of only about
45 microns from a plutonium particle, the effect of focal
irradiation at different levels of the hair follicle is a
crucial test of the Tamplin-Cochran proposal. Alpha and proton
irradiations that extend from the skin surface to a depth of about
0.15 mm do not produce tumors (22). This result, however, is
consistent with the existence of a target cell population at a
depth of about 0.3 mm. However, selective irradiation of the
lower end of the hair follicle at a depth of 0.3 mm by use of
the Bragg peak from an alpha beam did not produce tumors or
atrophic follicles unless there was substantial irradiation of
the entire follicle (22). This observation suggests that even
though the critical cell population is located at 0.3 mm,
that there are recovery mechanisms that block tumorigenesis
when only part of the "critical architectural unit of tissue"
is irradiated. What these recovery processes might be is not
understood. Nevertheless, this result does not support the
contention that a single plutonium particle positioned next to a
"critical architectural unit" such as the hair follicle, will
produce a tumorigenic risk of the magnitude assumed by Tamplin
and Cochran.
It might be argued that since particles can move about in
-------
" 322 " 651
the lung, it is appropriate to consider the effects of a single
Plutonium particle in the skin which moves up and down and
irradiates the entire follicle. However, under these circumstances
it should be necessary to consider the important factor of
temporal recovery from the tumorigenic action of ionizing
radiation which has been shown by split dose experiments to be
very large for low LET radiation (23); preliminary data from an
ongoing split dose experiment suggests that recovery from proton
radiation is also very substantial (24). Data applicable to
estimation of the recovery rates from exposure to a moving
radioactive particle are not available. Geesaman's estimate
of a one year recovery time for radiation effects on the lung
is mere speculation.
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652
- 323 -
References
1. Tamplin, A. R. and T. B. Cochran. Radiation Standards for
Hot Particles. A Report on the Inadequacy of Existing
Radiation Protection Standards Related to Internal Exposure
of Man to Insoluble Particles of Plutonium and Other
Alpha-Emitting Hot Particles. Natural Resources Defense
Council, Washington, D.C., 1974.
2. Geesaman, D. P. An Analysis of the Carcinogenic Risk
from an Insoluble Alpha-Emitting Aerosol Deposited in Deep
Respiratory Tissue. Lawrence Radiation Laboratory, University
of California, Livermore, TID-4500, UC-48, Feb. 1968.
3. Geesaman, D. P. An Analysis of Carcinogenic Risk from an
Insoluble Alpha-Emitting Aerosol Deposited in Deep
Respiratory Tissue: Addendum. Lawrence Radiation Laboratory,
University of California, Livermore, TID-4500, UC-i8,
Oct. 1968.
4. Oberling, C. Riddle of Cancer, Yale University Press,
New Haven, 1952.
5. Berenblum, I. Irritation and Carcinogenesis. Arch.
Path. 38:233-244, (1944).
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653
6. Albert, R. E., F. J. Burns and P. Bennett. Radiation-
Induced Hair-Follicle Damage and Tumor Formation in Mouse
and Rat Skin. J. Natl. Cancer Inst. 4_9_: 1131-1137, (1972).
7. Withers, H. R. The Dose-survival Relationship for
Irradiation of Epithelial Cells of Mouse Skin. Brit. J.
Radiol. _4£:187-194, (1967).
8. DiPaolo, J. A., K. Takano and N. C. Popescu. Quantitation
of Chemically Induced Neoplastic Transformation of
BALB/3T3 Cloned Cell Lines. Cancer Res. 32:2686-2695,
(1972).
9. Borek, C. In Vitro Cell Transformation by X-Rays. Radiat.
Res., (1973). (Abst.)
10. Sachs, L. An Analysis of the Mechanism of Carcinogenesis
by Polyoma Virus, Hydrocarbons, and X-Irradiation. In:
Moleculare Biologie des Maligner Wachstums, Springer Verlag,
New York, 1965.
11. Todaro, G. J. and H. Green. Cell Growth and the Initiation
of Transformation by SV40. Proc. Natl. Acad. Sci., U.S.
55:302-308, (1966).
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654 -325-
12. Sivak, A. and B. L. Van Duuren. A Cell Culture System for
the Assessment of Tumor-Promoting Activity. J. Natl.
Cancer Inst. £4:1091-1097, (1970).
13. Bates, R. R. and R. T. Prehn. Role of the Fibrous Capsule
in Carcinogenesis by Plastic Film. Nature 205;303-304,
(1965).
14. Kaplan, H. S. On the Etiology and Pathogene'sis of the
Leukemias: A Review. Cancer Res. 14_: 535-548, (1954).
15. Albert, R. E., F. J. Burns and R. D. Heimbach. Skin Damage
and Tumor Formation from Grid and Sieve Patterns of Electron
and Beta Radiation in the Rat. Radiat. Res. 30;525-540,
(1967).
16. Unpublished data.
17. Burns, F. J., R. E. Albert, P. Bennett and I. P. Sinclair.
Tumor Incidence in Rat Skin After Proton Irradiation in a
Sieve Pattern. Radiat. Res. 5_0:181-190, (1972) .
18. Albert, R. E., F. J. Burns and R. D. Heimbach. The Effect
of Penetration Depth of Electron Radiation on Skin Tumor
formation in the Rat. Radiat. Res. 30:515-524, (1967).
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- 326 - 655
19. Unpublished data.
20. Albert, R. E., F. J. Burns and R. D. Heimbach. The
Association between Chronic Radiation Damage of the Hair
Follicles and Tumor Formation in the Rat. Radiat. Res.
.30:590-599, (1967).
21. Albert, R. E., M. E. Phillips, P. Bennett, F. Burns and
R. Heimbach. The Morpholbgy and Growth Characteristics of
Radiation-Induced Epithelial Skin Tumors in the Rat.
Cancer Res. ,29_: 658-668, (1969).
22. Heimbach, R. D., F. J. Burns and R. E. Albert. An Evaluation
by Alpha-Particle Bragg Peak Radiation of the Critical
Depth in the Rat Skin for Tumor Induction. Radiat. Res.
3£:332-344, (1969).
23. Burns, F. J., R. E. Albert, I. P. Sinclair and P. Bennett.
The Effect of Fractionation on Tumor Induction and Hair
Follicle Damage in Rat Skin. Radiat. Res. 53:235-240,
(1973) .
*
24. Unpublished data.
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- 327"-
656
WASH-1320
WASH-1320, "A Radiobiological Assessment of the Spatial Distribution
of Radiation Dose from Inhaled Plutonium," by W. J. Bair, C. R. Richmond
and B. W. Wachholz, September 1974, was entered into the Record as an
integral part of the AEC Testimony. A copy accompanies this document.
-------
WASH-1320
657
A Radiobiological Assessment
of the Spatial Distribution
of Radiation Dose
from Inhaled Plutonium
by W. J. Bair, C. R. Richmond,
and B. W. Wachholz
United States Atomic Energy Commission
SEPTEMBER 1974
For sale by the Superintendent of Documents, U.S. Government Printing Office
Washington, D.C., 20402 - Price $1.10
-------
-------
659
PREFACE
This report was prepared at the request of the Division of Biomed-
ical and Environmental Research, U.S. Atomic Energy Commission. The
authors have attempted to assemble and review the data currently avail-
able which bears upon the problem of uniform versus nonuniform dose
distribution in the lung. This problem has been termed the "hot particle"
question. Because the quantity of material available from laboratories
and individuals in the United States and foreign countries far exceeds
the space limitations of this document, the more peripheral work, as
judged by the authors, was omitted. While a compendium of all informa-
tion relative to the subject would be useful, the authors elected to pre-
pare a report of less voluminous dimensions, directed specifically to a
radiobiological assessment of the spacial distribution of plutonium in the
lung.
The authors requested and received assistance from numerous indi-
viduals and/or laboratories throughout the country in an effort to include
additional general and specific expertise in various disciplines, as well as
to consider as broad a sampling of expert opinions as possible.
Grateful acknowledgment is extended to:
Roy Albert, M.D., New York University
Battelle Memorial Institute, Pacific Northwest Laboratory
George W. Casarett, Ph.D., University of Rochester
Marvin Goldman, Ph.D., University of California at Davis
Los Alamos Scientific Laboratory
Clarence C. Lushbaugh, M.D., Oak Ridge Associated Universities
Roger O. McClellan, D.V.M., and the staff of the Inhalation
Toxicology Research Institute, The Lovelace Foundation
Harald Rossi, Ph.D., Columbia University
Their assistance in reviewing drafts of this report, as well as their
initial contributions, is most appreciated; however, the authors accept
sole responsibility for the content of the report and for the opinions and
the conclusions expressed herein.
It is hoped that the report will serve as an informative scientific
document which will provide the reader with an overview of the applicable
human, experimental and theoretical evidence to date. For additional
information the reader is referred to the specific references provided.
111
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661
TABLE OF CONTENTS
Page
Summary and Conclusions 1
I. Statement of the Problem 3
•
II. Background 5
III. Animal Studies 9
IV. Human Experience 25
V. Theoretical Considerations 31
VI. Bibliography 43
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-------
SUMMARY AND CONCLUSIONS
663
1. Recognition of the importance of spatial
distribution of dose to radiation protection
practices by national and international stand-
ards setting organizations and the scientific
community predates the discovery of pluto-
nium. Continued examination of the radiobiolog-
ical aspects of the spatial distribution of dose,
especially as regards alpha-emitting particles,
has not led to major changes in radiation pro-
tection standards. However, the problem is and
should be continually reassessed.
2. Experimental animal studies clearly indi-
cate that inhaled radioactive particles move
from the lung to other organs and may be ex-
creted from the body by several mechanisms.
The experimental data also show that truly
uniform distributions of inhaled radionuclides
in lung seldom, if ever, occur. However, be-
cause of the mobility of plutonium within lung,
there is some biological justification for aver-
aging the radiation dose to the total tissue.
3. Although particles deposited in lung are
dynamic and mobile unless trapped, i.e., in scar
tissue, experiments have simulated the static
plutonium particle to study the biological ef-
fects of truly "hot spots" of radioactivity in
lung. These and other comparative experi-
ments of uniform and nonuniform distribu-
tions of absorbed energy from radioactive par-
ticles suggest a biological sparing effect for
both acute and late responses to the nonuni-
form distribution. Available experimental data
indicate that averaging the absorbed alpha ra-
diation dose from plutonium particles in lung
is radiobiologically sound.
4. Dosimetric models used to predict lung
tumor probability in animals and in human
beings are biologically deficient, primarily be-
cause of the lack of the required biological in-
formation. Also, most models are based on
studies of tumor induction in irradiated rat
skin and on the assumed validity of extrapolat-
ing to lung tissue. This practice is questionable
for several reasons including the fact that the
results of studies with rats, i.e., tumor type,
vary with rat strains and that the results of
comparable studies of irradiated mouse skin
have not given results identical to the rat ex-
periments. Thus, use of these models can lead
to erroneous predictions of tumor probabilities.
5. Consideration of mechanisms of radiation
carcinogenesis suggests that there has been no
change in direction or strength of data which
would compel departure from the concept that
average lung dose for alpha particles provides
a reasonable and conservative base for protec-
tion.
6. After thirty years experience with plu-
tonium in laboratory and production facilities,
there is no evidence that the mean dose lung
model on which occupational radiation protec-
tion standards for plutonium are based is
grossly in error or leads to hazardous prac-
tices. Currently available data from occupa-
tionally exposed persons indicate that the non-
homogeneous dose distribution from inhaled
plutonium does not result in demonstrably
greater risk than that assumed for a uniform
dose distribution. Thus, empirical considera-
tions lead to the conclusion that the nonuni-
form dose distribution of plutonium particles
in the lung is not more hazardous and may be
less hazardous than if the plutonium were uni-
formly distributed and that the mean dose lung
model is a radiobiologically sound basis for es-
tablishment of plutonium standards.
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-------
I. STATEMENT OF THE PROBLEM
665
The nonuniform distribution of radionu-
clides and the attendant biological response of
tissues at risk relative to the spatial distribu-
tion of the absorbed energy have been of inter-
est for many decades to the scientific commu-
nity, particularly those individuals and groups
charged with the responsibility for derivation
of exposure standards. Permissible limits for
the respiratory intake of radioactive materials
are commonly calculated on the assumption of
complete absorption of the radiation energy by
the critical organ. Further, it is implicitly as-
sumed that there is a uniform distribution of
the energy per gram of tissue throughout the
critical organ. This particular situation raises
the interesting question as to the probability of
a unique hazard to the respiratory tissues for
a given amount of inhaled radioactive material
distributed in the form of small, discrete, radio-
active particles or aggregates as compared
with a more homogeneous distribution. Stated
in another way: for the same amount of radio-
active material, is the biological harm to the
lung greater or less when the energy is concen-
trated into very small tissue volumes than
when the energy is absorbed by the entire
organ? For alpha and some other radiations,
the distribution of energy will be nonuniform
and consequently concentrated about the parti-
cles, thereby producing intense radiation doses
to the nearby cells. For the case of nonuniform
distribution of alpha-emitting materials in the
lung, the initial biological interaction is that of
an extremely large energy deposition in a very
small tissue volume. For such situations, the
use of the organ-mean dose concept for radia-
tion protection has been seriously questioned.
At present the recommended dose limit (oc-
cupational exposure) for lung is 15 rem/year;
the quantity of 239Pu required to deliver this
dose equivalent rate, if one uses the currently
accepted method of assuming homogeneous ab-
sorption of energy throughout the entire lung,
is 0.016 iJ.Ci. However, as shown in Table I, the
number of cells which absprb the energy is a
function of the size of the particles comprising
the 0.016 />Ci. As the particle size increases
there are fewer particles and, therefore, fewer
cells are irradiated but at progressively in-
creasing dose rates.
The theoretical aspects of dosimetry and on-
cogenesis, results of animal experiments, and
30 years experience with humar beings occu-
pationally exposed to plutonium will be exam-
ined to assess the relative hazards of nonuni-
form and uniform distribution of alpha
radiation in lung and other tissue. This assess-
ment will be applied to an evaluation of the
currently accepted practice of averaging the
radiation dose throughout the lung, or other
organs as appropriate, for purposes of quanti-
tating the biological effects of inhaled pluto-
ninum and for establishing radiation protection
standards.
Table I
RELATIONSHIP OF PARTICLE SIZE TO NUMBER
OF CELLS AT RISK FOR A STATIC LUNG
BURDEN OF 0.016 /»Ci ™PuO2*
Particle Number of
diameter particles
Activity per
particle
Cells at
risk
Fraction of
lung
(Mm)
0.1
0.3
0.7
1.0
5.4x10'
2.0x10'
1.8X105
5.4X10*
(pCi)
3 XlO'4
0.01
0.08
0.3
3 XlO"
1.3X10'°
1.2X10'
3.6X10"
(%)
30
1
0.1
0.03
' Assuming static particles in a structureless human lung of uni-
form density 0 2 g cm~3 with an average cell volume of 10J /im'.
Cells at rihk are taken to be those in a sphere of radius equal to
the alpha range (200 /zm at the assumed density)
-------
-------
II. BACKGROUND
667
The nonuniform distribution of radiation
dose within the body and within tissues of the
body has been of long standing interest to
those concerned with the potential exposure of
persons to radiation, especially from radionu-
clides. Almost every kind of radiation expo-
sure, whether it be for diagnostic or therapeu-
tic purposes, from accidental occupational
exposures, from fallout radionuclides, or from
natural background radiations, results in non-
uniform absorption of energy within the body.
In 1969, an International Commission on Ra-
diological Protection Task Group (ICRP,
1969) identified three classes of nonuniform-
ity of dose:
"(i) Partial irradiation of an organ or tissue,
where the part irradiated is representative of the
whole organ or tissue, as in external irradiation
of skin or bone marrow."
"(ii) Partial irradiation, where the part irradi-
ated is not representative of the whole. This often
occurs with internal emitters, such as bone-seeking
radioactive materials in bone, where certain loca-
tions and cell types are preferentially irradiated.
A special case of this class is irradiation by short-
range emitters metabolically localized in structures
which are biologically very important, for instance,
tritiated thymidine in DNA."
"(iii) Irradiation from radioactive materials in
particulate form."
This report will deal with the third class,
which is the common situation following the
deposition of radioactive materials in the res-
piratory tract.
The decision to use the average dose to the
lung* (and other organs) has been consistently
maintained over three decades by numerous or-
ganizations and individuals. The bodies respon-
sible for such recommendations have not ig-
nored the subject during these decades, but,
* The average radiation dose is calculated by assum-
ing the complete and homogenous absorption of energy
throughout the entire organ. An exception to this ap-
proach is the calculation of dose resulting from the in-
halation of radon daughters.
rather, have periodically reviewed the relevant
human and experimental data and have main-
tained their position that nonhomogeneous
dose distribution does not result in a demons-
trably greater risk than does uniform dose dis-
tribution. Thus, there has been recognition, if
not complete resolution, of this problem since
the 1940's. In the early days of the Manhattan
Project, the concern for the problem of nonuni-
form dose distribution led to studies of ra-
dionuclides inhaled or deposited on skin. In
fact, interest in nonuniform dose distribution
in animals and man predates the discovery of
plutonium in 1941 because of the occupational
and medical exposures to 22<;Ra.
At the Chalk River Tri-Partite Conference
attended by scientists from the United States,
the United Kingdom, and Canada (McMurtrie,
1950), Dr. Hamilton pointed out, in relation to
the possible pathological effects of radioactive
particulates in the lungs, that cells in the im-
mediate neighborhood of a dust particle con-
taining 1 or 2 percent of plutonium would be
subjected to a dose of about 400 r/day. The
general opinion which emerged from the dis-
cussion was that the carcinogenic effect per
unit volume is probably considerably less for
the irradiation of small masses of tissue than
for large.
The National Academy of Sciences-National
Research Council considered the question of
nonuniform dose distribution in Publication
848, Effects of Inhaled Radioactive Particles
(NAS-NRC, 1961a). This publication pointed
out that lung exposures are often expressed as
mean dose to the lung by calculating the dose
assuming uniform distribution of radioactive
material throughout the lung, although uni-
form distribution of inhaled particles is not ob-
served in practice. The report also stated that
because local concentration of particles results
in nonuniform distribution of energy, the dose
-------
668
delivered to small volumes of lung tissue could
vary by several orders of magnitude above and
below the mean value and, therefore, the calcu-
lated mean dose to the lung should be used
with caution in estimating biological effects.
Report 848 also contains specific discussions
of point sources and tumor production and the
then current status of the radioactive particle
hazard evaluation. It also recognized as unre-
solved the effect of the spatial distribution of
the radiation on pulmonary tumorigenesis. It
was not known whether differences in tumor
production were due to the particular tissue in
which the deposition occurs or to the localiza-
tion and resulting strong irradiation of the tis-
sue. The skin experiments, cited in Report 848,
using radioactive point sources as compared
with flat plates indicated that, in the range
where extremely large doses are given, with
consequent killing of cells, tumor production
was considerably lessened for localized sources.
The report, however, states that these experi-
ments shed no light on the localization of
smaller quantities of materials where the dose
rate is not adequate to definitely kill the cells
within a given range of the radioactive mate-
rial.
The subject of energy distribution also was
considered in the National Academy of Sci-
ences-National Research Council Report of the
Subcommittee on Internal Emitters of the
Committee on Pathological Effects of Atomic
Radiation (NAS-NRC, 1961b). In chapter IV,
entitled Special Problems, the report states
that there are good reasons to believe that,
when radiation is uniformly delivered to tis-
sues, the biological effects may differ from
those observed when the radiation arises from
focal aggregations of radioactive material
(point sources) (Marshall and Finkel, 1959,
1960). In the latter case, dose rates close to the
point source would be different from those
near the end of the range of the particles with
an extremely high dose rate found near the or-
igin. The report notes that spatial differences
in dose may have considerable importance if
the relationship between biological injury and
energy absorbed is not linear.
The NAS-NRC report (1961b) pointed out
that spatial distribution of dose is of signifi-
cance when particular tissue elements are
selectively irradiated, and insofar as the rela-
tion between dose and the degree or probabil-
ity of any type of injury is not linear. The re-
port states that the available information is
not adequate to define differences in hazard be-
tween focal and diffuse radiation.
The question of nonuniform dose distribu-
tion was addressed also in the BEIR Report
(NAS-NRC, 1972). A statement is made that
an important issue is whether local or "hot
spot" radiation doses are more effective in pro-
ducing cancer of the respiratory tract as com-
pared with uniform radiation exposure to the
entire respiratory epithelium. The report cites
the work of Grossman et al. (1971), in which
210Po chloride was given intratracheally either
alone or with hematite particles, as being per-
tinent to the issue. Because polonium solution
alone was as effective as polonium given with
hematite, the authors of the BEIR Report
thought that it may be inferred that a higher
localized dose from alpha particles was not
more carcinogenic than the same mean tissue
dose delivered more uniformly to critical cells.
The 1971 report of the National Council on
Radiation Protection and Measurements, enti-
tled Basic Radiation Protection Criteria
(NCRP, 1971), contains a concept of "signifi-
cant volume" over which radiation dose should
be averaged. The report states:
"Simplifications in practice hinge largely on re-
porting a single representative protection dose for
a limiting organ system even when the actual irra-
diation is grossly non-uniform. The representative
dose is taken as the highest that can be obtained by
averaging over a prescribed significant volume. The
implication of this concept, or at least the conven-
tion that is followed, is that any redistribution of
a given dose within such a volume does not ma-
terially alter the radiation response. It is usually
assumed that the 'significant volume' should be of
the order of one cubic centimeter. This will be
grossly conservative under most circumstances, and
in special situations use of a larger volume is
justified."
As indicated in the NCRP report, there are
some cases in which choice of significant vol-
umes or areas are virtually meaningless. For
example, the averaging of dose over the entire
lung or over one cubic centimeter may have lit-
tle meaning if a single radioactive particle in
the lung or lymph node can be carcinogenic.
The ICRP periodically has addressed this
subject of nonuniform dose distribution,
usually by special groups commissioned by the
ICRP to study the question. In its Publication
9 (ICRP, 1966), the ICRP pointed out that for
the case of nonhomogeneous distribution of
absorbed dose in the lung, an estimate of the
-------
669
Dose Equivalent to the whole lung as deter-
mined merely by the product of QF and the
mean absorbed dose might be greatly in error
but full understanding of this problem must
await further experimental evidence. The re-
port indicated that there was no clear evidence
to show whether, for a given mean absorbed
dose, the biological risk associated with a non-
homogeneous distribution is greater or less
than the risk resulting from a more diffuse
distribution of that dose in the lung.
The authors of the ICRP report point out
that the problems of high local concentration
of dose are most severe for radioactive parti-
cles, especially alpha-emitters, in tissue where
the local dose can reach very high levels even
though the mean tissue dose may be very low.
They state that one cannot assume that linear-
ity of radiation dose and effect will hold at
these high doses and dose rates yet there may
be a great deal of cell death, particularly for
the short well-defined range of alpha particle
irradiation, and the number of affected but
viable cells may be small as compared with the
number of killed cells.
The report (ICRP, 1966) states:
"On the basis of general considerations and of
some experimental data and clinical experience the
Task Group were of the opinion that, for late
effects, the same radiation energy absorption might
well be less effective when distributed as a series of
'hot spots' than when uniformly distributed. Thus,
with particulate radioactive sources within a tissue,
a mean tissue dose would probably introduce a fac-
tor of safety. However, a severe practical problem
has now been recognized in connection with the
inhalation of plutonium participates, and is now
being considered in detail by a Task Group of
Committee 1 of ICRP." '
Current radiation protection standards for
limiting radiation dose to the lung from inter-
nally deposited radioactive materials continue
to be based upon our collecting knowledge of
the effects of radiation on the lung. Calcula-
tions of the average dose to lung tissue as a
correlative step between biological effects and
a quantity of radionuclides have been based on
the assumption that the absorption of energy
is uniform throughout the mass of tissue. It is
well known that this situation does not exist
for "insoluble" radionuclides which can pro-
duce focal spots of high levels of radiation
close to the particle, with the level decreasing
with distance in a pattern depending upon the
quality and energy of the radiation. Also well
known is the fact that postulated cases of uni-
form distribution of energy for "soluble" radio-
active materials seldom, if ever, occur.
Since the opinions of the standard setting
bodies were expressed, additional data have ac-
cumulated which bear on the problem and will
be discussed in the sections to follow. While
the question of nonuniformity of dose cannot
be answered unequivocally, these new data
tend to support the conclusion expressed by the
ICRP Task Group (ICRP, 1969) that for radio-
active particles "a mean tissue dose would
probably introduce a factor of safety."
Thus, it is clear that nonuniform distribu-
tion of radiation dose has been examined con-
tinually by national and international standard
setting bodies. The fact that these organiza-
tions have not changed or recommended
changes in the procedures used for calculating
dose to the lung as the result of their delibera-
tions is an indication of implicit guidance on
this particular problem.
-------
-------
III. ANIMAL STUDIES
671
The disposition and biological effects of in-
haled plutonium and other radionuclides have
been reviewed recently (Buldakov et al., 1969;
Sanders et al., 1970; Bair et al., 1973; Bair,
1974; Healy, 1974). Therefore, attention will be
given only to those experimental data relevant
to spatial distribution of radiation dose from
inhaled radionuclides.
A. Retention of Plutonium in Lung
Airborne radioactive particles are similar to
most other particles when they are inhaled in
that deposition in the respiratory tract is pri-
marily dependent upon the physical properties
of the particles and the respiratory character-
istics of the individual inhaling the particles.
The ICRP Task Group on Lung Dynamics
(Morrow et al., 1966) dealt with the deposition
of particles in the respiratory tract in consid-
erable detail.
Within the first week after exposure, a frac-
tion of the deposited plutonium is cleared from
the respiratory tract and excreted. The amount
of plutonium cleared depends upon the fraction
of readily solubilized material present and the
distribution of the plutonium within the respi-
ratory tract. Plutonium deposited upon the cil-
iated epithelium of the upper respiratory tract
may be trapped in mucus and transported to
the esophagus and swallowed. Plutonium de-
posited in the lower regions of the lung is not
readily available for clearance and may be in-
corporated into the cellular structures of the
lung and retained for a long time.
The kinetics of the clearance of plutonium
from lung are complicated and difficult to
quantitate. Because the clearance of plutonium
from the lower lung appears to be exponential
with time over a reasonably long period after
exposure, retention half-times are estimated.
Animal experiments and limited human data
provide a range of values for the retention
half-times of several plutonium compounds,
Figure III-l. The retention half-times for or-
ganic complexes of plutonium, plutonium ni-
trate and plutonium fluoride range from less
than 100 days to about 300 days in rats and
dogs. The retention half-times for PuO!2 are
substantially longer, ranging from 200 to 500
days in rats, 300 to 1000 days in dogs and 250
to 300 days in human beings. The wide range
of values for dogs is largely due to extensive
experimentation with a variety of plutonium
oxides with different physical characteristics.
For example, Pu02 calcined at high tempera-
tures is cleared more slowly than air oxidized
plutonium; Pu02 comprised of large particles
(~ 3 i+m AMAD) tend to be cleared more
slowly than aerosols of small particles (—/ 0.1
/<.m AMAD); and 238Pu02 has a much shorter
lung retention time than 239Pu02. The relative-
ly low value for human beings, compared with
dogs, suggests either that man clears pluto-
nium particles from his lung faster than dogs
do or that the materials inhaled in the human
RETENTION OF PLUTONIUM IN PULMONARY REGION OF LUNG
ANIMAL
ISOTOPE COMPOUND SPECIES
200 400 (00 BOO
LUNG RETENTION HALFTIME (DAYS!
Figure III-l.—Retention of Plutonium in Pulmonary
Region of Lung. Ranges of published values for re-
tention half-times are indicated for each animal spe-
cies and plutonium compound (Bair, in press).
-------
672
accident cases, from which these data were ob-
tained, were more soluble than plutonium diox-
ide.
Plutonium appears to be retained in the
lower respiratory tract longer than most other
materials that have been studied. Thorium
dioxide and ruthenium dioxide show retention
half-times comparable to those observed for
plutonium. Uranium-oxide, cerium oxide and
other metal oxides are retained at half-times of
less than 200 days, some less than 100 days.
The reason for the relatively long retention
time of plutonium is not known, but may be
due to its low solubility in tissue fluids, chemi-
cal binding with proteins and other constitu-
ents of lung, and the cytotoxic action of the
emitted alpha radiation.
B. Spatial Distribution of Plutonium Within
Lung
From the moment plutonium is deposited in
the respiratory tract, biological and physical
forces are at work to cause the removal of the
plutonium. That these forces are not as effec-
tive for plutonium as for other inhaled mate-
rial is indicated by the relatively long reten-
tion half-times observed for plutonium.
Particles deposited in alveolar spaces may be
cleared via the lymphatic system, mucociliary
pathway of the tracheobronchial tree, or by
dissolution and absorption into blood. With all
of these processes at work removing plutonium
from lung, although at low rates, it is difficult
to visualize plutonium remaining static
throughout its residence time in the lung.
Techniques have not been developed to docu-
ment the course of individual particles and ag-
gregates of plutonium in lung. However, the
temporal and spatial characteristics of pluto-
nium within tissues can be inferred from auto-
radiographs of tissue sections prepared from
animals exposed to plutonium aerosols.
The first observation is that plutonium and
especially insoluble plutonium compounds are
nonuniformly deposited throughout lung. Fur-
ther, plutonium may deposit unequally among
the lung lobes or among portions of lung lobes.
Deposition of plutonium following inhalation,
however, is more uniform than after intratra-
cheal injection—an experimental technique
often used when exposure of animals to pluto-
nium aerosols is not feasible. Studies of inhaled
plutonium nitrate in both rats and dogs show
that immediately following the inhalation ex-
posure, plutonium is present in both particu-
late and nonparticulate forms (Koshurnikova
et al., 1971; Sanders et al., 1971; Ballou and
Park, 1972; Lafuma, 1974), as evidenced by
the presence of alpha stars and single tracks in
auto radiographs, Figure III-2. Autoradio-
graphs from dogs exposed to inhaled 239Pu02
show an initial relatively diffuse distribution
of plutonium throughout the entire lung
(Clarke et cd., 1966).
Plutonium not rapidly removed from the
respiratory tract by the mucociliary pathway
or by absorption into the blood, may be en-
gulfed by macrophages. Phagocytosis of parti-
cles deposited on the non-ciliated epithelium
distal to the terminal bronchioles and in the al-
veoli usually occurs /very rapidly (Sanders,
1969). The alveoli of the lung contain reticu-
loendothelial cells derived in part from circu-
lating monocytes. These reticuloendothelial
cells consist of mononuclear cells and histio-
cytes within the septal walls and alveolar mac-
rophages in the air spaces, all of which are ca-
pable of phagocytizing plutonium.
Phagocytized plutonium particles are rapidly
localized in the phagolysosomes of
reticuloendothelial cells (Sanders and Adee,
1970). While the mechanism is not known
(Casarett and Milley, 1964), the alveolar mac-
rophage appears to be capable of transporting
plutonium from the alveoli to the ciliated epi-
thelium of the bronchioles. These phagocytic
cells containing plutonium particles and aggre-
gates can then be removed from the lung in
the mucous blanket which is propelled up the
respiratory passage by ciliary action. This
mechanism of clearing plutonium from the
lung is important early after an inhalation ex-
posure and apparently continues to function
long afterward, as evidenced by the appear-
ance of macrophages containing plutonium in
lung lavage fluid at long times after exposure
(Sanders and Adee, 1968), and by the contin-
ued appearance of plutonium in feces, although
the latter is only circumstantial evidence.
Both soluble and insoluble plutonium not im-
mediately cleared from the lung tend to be-
come further aggregated. This mobility and
aggregation of plutonium may have large ef-
fects on the temporal and spatial distribution
of the alpha radiation dose. A few days after
inhalation of plutonium nitrate, single tracks
in autoradiographs decrease, Figure III-3,
10
-------
Figure III-2.—Autoradiograph of lung section from dog
1 day after inhalation of 239Pu(NO3)4. 320X. (Pro-
vided by J. E. Ballou, Battelle-Northwest).
673
Figure III-4.—Autoradiograph of lung section from dog
several weeks after inhaling 2-"9Pu(NO3)4. 120X. (Pro-
vided by J. E. Ballou, Battelle-Northwest).
Figure IH-3.—Autoradiograph of lung from dog 14
days after inhalation of 239Pu(NO.04. 320X. (Provided
by J. E. Ballou, Battelle-Northwest).
and after several weeks nearly all of the plu-
tonium appears to be aggregated, Figure
III-4. It is not known whether this represents
continued aggregation, perhaps by chemical
binding, of the plutonium in the lung or
whether aggregation only appears to be in-
creased as the non-aggregated plutonium is ab-
sorbed into the blood and thus disappears from
the lung leaving only the aggregates.
Plutonium particles, and to a lesser extent
aggregates of soluble plutonium, are trans-
ported to thoracic lymph nodes. Clearance of
particles to lymph nodes occurs via lymphatic
vessels in the thorax that drain interstitial
spaces. Particles either penetrate the intersti-
tium directly or gain access by transport in
phagocytic cells (Morrow and Casarett, 1961;
Casarett and Milley, 1964). Autoradiographs
Figure III-5.—Autoradiograph of lung section from dog
several months after inhalation of 23<
-------
674
Erratum Sheet For
"A Radiobiological Assessment of the Spatial
Distribution of Radiation Dose from Inhaled Plutonium"
(WASH-1320)
Please note that there is an error in the second sentence in column
2 on page 12.
The sentence now reads:
In experimental however, it is not known whether the plutonium can be
found in the circulating blood; however, it is not know whether the
plutonium has been absorbed from the lung directly or reabsorbed from
liver or bone to which the plutonium had Been translocated previously
from the lung.
The sentence should read as follows:
In experimental animals at long times after exposure, plutonium can be
found in the circulating blood; however, it is not known whether the
plutonium has been absorbed from the lung directly or reabsorbed from
liver or bone to which the plutonium had been translocated previously
from the lung.
-------
675
of lung tissues taken from dogs several weeks
and months after inhalation of Pu02 show
alpha stars concentrated in subpleural areas,
apparently in lymphatic vessels, Figure 111-5.
Autoradiographs also suggest that some plu-
tonium particles become immobilized in scar
tissue in subpleural areas. Plutonium particles
transported to lymph nodes are deposited in
lymphatic sinuses of subcapsular and medul-
lary areas. The particles eventually appear
sequestered in "hot spots" of scar tissue and
do not appear to be mobile. The residence time
for plutonium in lymph nodes appears to be
very long; there is no direct evidence for clear-
ance of inhaled plutonium particles from tho-
racic lymph nodes although clearance of plu-
tonium from cervical lymph nodes of dogs
after subcutaneous injection (Lebel et al.,
1972) and from mesenteric lymph nodes of
rats after intraperitoneal injection (Sanders,
1974) has been reported.
Plutonium particles not phagocytized by al-
veolar macrophages and removed by the muco-
ciliary pathway or transported to the lymphat-
ics can be found in Type I alveolar epithelial
cells and in peribronchiolar vascular areas,
Figure III-6. There is autoradiographic evi-
dence of particles being immobilized in scar
tissue in the alveolar and peribronchiolar
areas. Although Type I alveolar epithelial cells
phagocytize plutonium particles rapidly—
within a few hours after deposition (Sanders
and Adee, 1970), the fate of particles phagocy-
tized by these cells is not known. The Type I
cells do appear to be relatively radioresistant
to alpha irradiation (Sanders et al., 1971). It
is possible that plutonium particles, other than
those in lymphatics or trapped in scar tissue,
retained in the lung for long periods, are cy-
cled through generations of Type I or other
cells.
Type II alveolar epithelial cells, or the so-
called "granular pneumonocytes," do not phag-
ocytize plutonium particles (Sanders et al.,
1971) and, thus, do not appear to be directly
involved in clearance of plutonium from lung.
The intracellular localization of plutonium
particles within pulmonary macrophages has
been demonstrated by autoradiography of
smears from pulmonary lavage fluid and of
lung sections (Sanders, 1969). Lesions in mac-
rophages have been observed as early as one
hour after phagocytosis of large amounts of
plutonium.
There is much experimental evidence for
the absorption of plutonium into the blood al-
most immediately after deposition of soluble
and even "insoluble" plutonium compounds in
the respiratory tract (Bair and McClanahan,
1961; Bair and Willard, 1961). In experimental
however, it is not known whether the pluto-
nium can be found in the circulating blood;
however, it is not know whether the pluto-
nium has been absorbed from the lung directly
or reabsorbed from liver or bone to which the
plutonium had been translocated previously
from the lung. Plutonium is also continuously
excreted in urine after an inhalation exposure.
Again it is not known whether the origin is
the lung directly or the secondary liver and
bone pools. Mercer (1967) suggested that dis-
solution of plutonium particles deposited in the
deep alveolar lung region was the major path-
way for clearence and that dissolution rates
were directly proportional to the surface area
of the particles and their chemical composition.
It seems certain that dissolution of plutonium
particles and aggregates does occur in the
lung, although at low rates, and accounts for
at least some of the mobility of plutonium in
the lung as well as clearance from the lung.
Although the kinetics are unknown and even
a qualitative description is still rather primi-
tive, there is ample evidence that plutonium
deposited in lung is subjected to biological and
physical forces. This argues against either par-
ticles or aggregates of plutonium remaining
static indefinitely, except for the plutonium
that becomes immobilized in scar tissue. To the
contrary, while the rates may be low, move-
ment of plutonium within lung tissues, by sev-
eral mechanisms, certainly occurs, as the lung
attempts to expel the plutonium and other for-
eign material. The migration of deposited
plutonium particles in lung is recognized in the
USSR as at least partially compensating for
the nonuniformity of the radiation exposure
from plutonium particles and justifying accep-
tance of the concept of averaging the radiation
dose over the entire lung mass (Zalmanzon and
Chutkin, 1971).
C. Pulmonary Neoplasia
High doses of inhaled plutonium in experi-
mental animals have been shown to cause se-
vere radiation pneumonitis and fibrosis
resulting in early death due to respiratory in-
12
-------
676
sufficiency (Bair et al., 1973). Lymphopenia is
the earliest response seen in animals after in-
halation of Pu02 and has been observed in dogs
with total lung deposition of 0.08 /uCi (Park et
al., 1974). Cancer is a potential long-term re-
sponse to plutonium in the body and has been
observed in experimental animals to occur in
lung, bone and liver, all of which are major
repositories of plutonium deposited in the res-
piratory tract (Bair, 1974). However, lung
cancer is the biological response of most rele-
vance to this discussion of the spatial distribu-
tion of radiation dose from inhaled plutonium.
Experimental data on plutonium-induced
lung cancer are summarized in Table III-A. In
rats exposed to ammonium plutonium penta-
carbonate or plutonium citrate, the incidence
of pulmonary neoplasia was about 10% at
doses of the order of 0.01 /iCi/g of lung, and
above 30% at 0.015 to 0.026 /iCi/g lung. The
lung tumors were squamous cell carcinomas,
adenocarcinomas, and hemangiosarcomas.
Sixty to 100% of the animals in the range of
doses studied (40 to 7320 rads) developed pul-
monary sclerosis. The maximum incidence of
malignant neoplasms in the lungs (30-47%)
was observed at an absorbed dose of 500-1000
rads. Studies with soluble plutonium in dogs
have been concerned with acute effects and no
tumors have been reported. Plutonium-239
oxide caused pulmonary neoplasia in mice
given doses by intratracheal injection ranging
from 0.02 to 1.0 ^Ci/gram lung (Wager et al.,
1956; Temple et al., 1959, 1960). One tumor
was seen in a mouse that inhaled about 0.25^Ci
2V>PuOj per gram lung (Bair, 1960). In a larger
study with nearly 800 mice that inhaled about
0.1 to 2 nCi per gram (Bair et al., 1962), there
was no shortening of life-span and no evidence
of pulmonary neoplasia in the animals avail-
able for histopathological examination. Rats
showed a 50% tumor incidence at inhaled
(through a glass tube inserted into the tra-
chea) -''"PuO, doses of about 0.2 jnCi/gram lung
(Lisco, 1959). These tumors were epidermoid
carcinomas, adenocarcinomas, and hemangioen-
dotheliomas. No primary tumors of thoracic
lymph nodes were seen in any of the rodent ex-
periments.
In beagle dogs given a 10-30 minute expo-
sure to -'-!''Pu02, deposition of more than 0.1
fiCi/g lung caused death within about a year
due to respiratory insufficiency (Park et al.,
1972). Thirty dogs died between 55 and 412
days postexposure due to plutonium-induced
pulmonary edema, fibrosis, and bronchiolar and
alveolar epithelial hyperplasia and metaplasia.
The subsequent severe respiratory insufficiency
was characterized by progressive hypercapnia
and hypoxia. In another experiment with 40
dogs, 32 died or were sacrificed when death
was imminent. Five were sacrificed for study
of plutonium distribution in tissues. Of the 32
deaths, 30 were due to plutonium-induced pul-
monary fibrosis and/or neoplasia. The three re-
maining dogs have died and all grossly showed
lung tumors; however, the histopathology and
radiochemistry results are incomplete (Park
and Bair, 1974). Twenty-four dogs had pulmo-
nary neoplasia in addition to fibrotic and meta-
plastic lesions, Figure III-7. The survival
times of these dogs are plotted as a function of
the estimated amount of plutonium initially de-
posited in the alveolar regions of the lungs of
the dogs, expressed as nCi/g of blood-free lung.
The curve was fitted to all the data by least
squares analyses to describe the relationship
between quantity of plutonium deposited and
the time of death due to pulmonary neoplasia
and/or pulmonary fibrosis-induced respiratory
insufficiency. Another curve was fitted to just
the pulmonary neoplasia data points by least
squares analyses. In these dogs the develop-
ment and growth of the pulmonary neoplasms
were followed radiographically. In all cases
tumors appeared to originate in the periphery
of the lung, the location of most of the pluto-
nium. This observation is consistent with the
histopathology which showed that the predomi-
nant tumor type was bronchiolar-alveolar car-
cinoma. Epidermoid tumors similar to those
generally attributed to cigarette smoking
and/or exposure to radon daughters as in ura-
nium miners, were incidental findings in a few
dogs which also had bronchiolar-alveolar carci-
noma (Howard, 1970). The estimated initial
alveolar deposition in the dogs with pluto-
nium-induced pulmonary neoplasia was 0.2 to
3.3 i^Ci or 3 to 45 ^Ci/gram of bloodless lung.
Metastasis occurred to thoracic lymph nodes
and to many systemic organs.
In addition to bronchiolar-alveolar carcino-
mas, other types of tumors were incidental
findings in several dogs. Two dogs developed
benign-appearing tumors of endothelial origin
which were classified as hemangiomas. Tho-
racic lymph nodes, as well as a few hepatic
13
-------
677
Table III-A
PLUTONIUM-INDUCED LUNG CANCER IN EXPERIMENTAL ANIMALS
Deposited
Compound
=J9Pu
Citiate
2]»pu
Ammonium
Plutonium
Penta-
carbonate
-•i»Pu
Pu(NOs).
Animal
species
Rat
Rat
Rat
Rat
Rat
Rat
Rat
Rat
Rat
Rat
Rat
Rat
Rat
Rat
Rat
Rat
Rat
Rat
Rat
Rat
Rat
Rat
Rat
Rat
Rat
Rat
Rat
Rat
Rat
Rat
No. of
animals
268
167
124
203
31
105
113
39
90
12
20
48
101
91
126
83
126
22
65
23
11
42
80
17
22
88
69
62
108
86
Exposure •
method*
Control
Inhal.
Inhal.
Inhal
Inhal.
Inhal.
Inhal.
Inhal
Inhal.
Inhal.
Inhal
Inhal.
Inhal.
Inhal
Inhal
Inhal
Inhal.
Inhal
Inhal.
Inhal
Inhal
in lungs
(ftCi)
0 008
0.02
0 04
0.08
0.16
0 25
0.36
0.51
0.80
1 03
0 004
0.007
0.017
0 045
0.16
0 26
0.35
0.46
0 77
1.46
1/iCi/g)
0.0026
0 0067
0.013
0.026
0.060
0 08
0.12
0 17
0.26
0.34
0.0013
0.0023
0.0057
0.016
0 05
0.08
0.12
0 15
0 26
0.48
Dose to
(rads)
—
47
117
234
467
852
1390
1740
2370
3090
3820
41
80
186
497
1065
1616
2140
2780
3900
7320
I T.(HNOjl - —
I.T.
I.T.
I.T.
I T
I.T.
I T
I T.
I T.
0 00042
0 0042
0.01
0.03 1
0 048
(I 1
0 42
1 0
0 00014
0.0014
0.003
0.01
0 016
0 03
0.14
0.3
2.7
28
62.5
205
318
622
2760
6960
Mean
time (days)
670
635
586
545
546
464
416
221
124
69
64
571
571
584
582
484
361
247
139
78
77
686
541
755
793
592
704
589
426
330
± 8
± 3
± 12
-t- 11
± 22
± 12
± 12
± 13
± 9
-f- ~,
± 2
± 21
± 16
+ 12
± 11
± 14
+ 11
± 21
+ 10
± 7
± 6
± 20
Lung tumor
incidence
No.
1
11
3
17
11
27
27
3
2
0
0
2
7
12
48
38
31
2
3
0
0
2
1
2
4
7
12
33
19
%
0.39
7.1
2 5
8 4
35 5
25 7
24
7 7
2.2
0
0
4 2
7
13 2
38
45.9
24.6
9.0
4 6
0
0
2.5
5.9
9.9
8.16
17.5
18.9
33
24 2
Tumor type
Squamous cell
cancer, adeno-
carcmoma, and
hemangiosarcoma
Squamous cell
cancer, adeno-
carcinoma, and
hemangiosarcoma
Squamous cell
cancer, adeno-
carcinoma, and
hemangiosarcoma
(Incidence calcu-
lated on animals
at risk)
Reference
Koshurnikova,
Lemberg, and
Lyubchansky,
1971
Kobhui nikova,
Lemberg. and
Lyubchansky,
1971
Erokhin,
Koshurnikova,
Lemberg,
Nifatov, and
Puzyrev. 1971
48
I T
19 39.6
Plutonyl
Triacetate
SQuamous cell
cancer, adeno-
carcmoma, and
hemangiosarcoma
Erokhin,
Koshurnikova,
Lemberg,
Nifatov, and
Puzyrev, 1971
J3»pu
Ammonium
Plutonium-
Penta-
cai bonate
=J"Pu
Pu(N03U
Rabbit
Rabbit
Rabbit
Rabbit
Rabbit
Rabbit
8
13+
18+
20+
12
13
Inhal
Inhal
Inhal.
Inhal.
I T.
I.T
0
0.02
0.17
0.50
0.65
2.38
0
120
1010
2960
3840
13960
1431.5 ±
926.4 +
673 9 ±
631.5 ±
665 7 ±
428 2 ±
201
96 8
74 8
61.5
53 6
31 2
- - — Malignant
--
' 18 7
1 6.0
7 68.3 Malignant
3 23.0
Koshui nikova,
Ijemberg, and
Lyubchansky,
1971
Koshurnikova,
Lemberg, and
Lyubchansky,
1971
'»PuOj Mouse
Mouse
Mouse
Mouse
'"PuOj Rat
'"PuOj Dog
Dog
Dosr
Dog
"PuO; Rat
Rat
Rat
Rat
• Inhal. - Inhaled: I.T
21
17
41
73
—
8
13
6
5
92
30
30
32
—
I.T.
I T.
I T.
Inhal.
I T.
Inhal
Inhal
Inhal
Inhal
Inhal
lnh.il
Inhal
Inhal
intratracheal
0.003
0.06
0 16
0 1
0 2-1
0 6
1.3
2
3 1
0
0.005
0 018
0 2
injection
0 008
0 15
0 4
0 25
—
0071 ± 0026
.0147 + 0029
.0229 + 0021
.0392 ± .0032
0
0 002
0.0072
0.092
115
2300
4000
—
1230
2086
2498
4094
0
9
32
375
600
400
100
600 +
>250
2922 + 732
1992 ±_ 437
1.139 ± 388
1094 ± 236
825
(.50
675
550
1
2
1
1
-.
7
11
4
2
1
2
7
8
5
12
2.6
1 4
50-100
87 5
84
67
40
1 1
6.6
23 3
25 0
Fibrosarcoma
Squamous cell
carcinoma
Bronchiolar
carcinoma
Bronchiolar
carcinoma
Epidermoid
adenocarcmoma
Bronchiolar-
alveolar
cat cinoma
Dose calculated
to 700 days after
exposure
Temple et {U.,
1959
Wager et al..
1956
Temple etal..
1969
Bair. 1960
Lisco, 1959
Park and Bair,
1972
Sanders, 1973
14
-------
678
nodes, showed sclerotic lesions associated with
accumulated plutonium. Three dogs had tho-
racic lymph node lesions of endothelial origin
classified as hemangiosarcoma, lymphangio-
sarcoma and endothelioma. Another dog had
a possible malignant lymphoma involving the
mesenteric and mandibular lymph nodes. Auto-
radiographs of these nodes showed no radio-
activity. This isolated case is not considered to
be associated with the plutonium exposure.
In contrast to the results with 23"Pu02, pre-
liminary data from a study of inhaled 238Pu02
in dogs show a high incidence of osteosarcoma,
although pulmonary neoplasia also occurred
(Park et al., 1974). This is consistent with the
observed translocation of 238Pu to bone follow-
ing inhalation of 238Pu02 in both dogs and rats.
Sanders (1973) has recently reported on the
carcinogenicity of inhaled 238Pu in rats. Three
groups of 35 animals each inhaled an aerosol
of 238Pu in saline which gave initial lung bur-
dens of 0.005 ,uCi, 0.018 p.Ci, and 0.2 p.Ci with
associated cumulative radiation doses to lung of
9 rads, 32 rads and 375 rads, respectively, at 700
days postexposure. However, because of the rap-
id clearance of 23SPu from lung, nearly all of the
radiation dose was delivered to lung within 30
days after the inhalation exposure. The lung
tumor incidence within the 0.005 ju.Ci group
was not significantly different from the control
group. Groups receiving the two higher levels
showed a statistically significant increased in-
cidence of tumors but no increased mortality
rate.
Osteosarcomas were observed in 238Pu02
treated animals at the highest dose level only
(i.e., greater than 50 rads accumulated dose to
skeleton) which correlated with the transloca-
tion of plutonium to bone. The aerosol
(crushed 23SPu02 microspheres) was 72% ul-
trafilterable and was considered "soluble." Of
the 19 pulmonary tumors found, there were 14
bronchiolar-alveolar tumors, two mixed carci-
nomas, one epidermoid carcinoma, one undif-
ferentiated carcinoma and one malignant lym-
phoma.
There are limited data available on
plutonium inhalation by nonhuman primates.
Metivier et al. (1972) reported studies in
which 19 baboons (Papio papio) were ex-
posed at 2-3 years of age to an aerosol of
239Pu02 with a count median diameter of 0.5
mm. The total lung burden at the time of death
ranged from 0.01 to 0.1 ^Ci per gram of fresh
RELATIONSHIP BETWEEN THE QUANTITY OF
239
PuO,
DEPOSITED AND SURVIVAL TIME OF DOGS
1000
S 100
- 10
oPULMONARY FIBROSIS
•PULMONARY NEOPLASIA
Y = 34,600 f1-028
10 100 1000 10,000
SURVIVAL TIME, t (DAYS AFTER EXPOSURE)
Figure III-7. — Relationship between quantity of ^'»
deposited and survival time of dogs, Park et al., 1972.
lung. Translocation was largely to tracheo-
bronchial lymph nodes. All of the baboons had
radiation pneumonitis. In addition, two epider-
moid carcinomas of about 1.0 cm diameter
were found after 80 days and two mucous-se-
creting adenocarcinomas of the same size were
found after 180 days. Animals living past 80
days postexposure showed extensive areas of
squamous metaplasia or nests of small "tumor-
lets." The authors concluded that baboons may
be more sensitive than dogs to acute internal
alpha irradiation.
Figure III-8 shows the incidence of lung
cancer in the animal experiments described
above as a function of the calculated total
mean radiation dose to the lung. These data
show an increased incidence of rat lung cancer
occurring with doses as low as 10 rads. In rats
and mice, the peak incidence probably occurs
at doses between 200 and 1000 rads. The re-
sults from the only dog experiment show
higher incidences than have been observed in
rats.
The marked histopathologic changes in
tracheobronchial and mediastinal lymph nodes
of dogs that have inhaled plutonium (Clarke
and Bair, 1964), and those occurring is super-
ficial cervical and axillary lymph nodes of dogs
given plutonium implants in the subcutaneous
fascia over the dorsal metacarpus (Lebel et al.,
1972) were not observed to have been detri-
15
-------
679
mental to the dogs. The only possible exception
is one dog given a 5.8 /xCi implant of air-oxi-
dized plutonium in the dorsal metacarpus. This
dog showed a generalized lymphadenopathy
after four months and died of lymphosarcoma.
However, because of the early development of
this lesion the authors were hesitant to attrib-
ute it to the plutonium (Lebel et al., 1970;
Watters and Lebel, 1972). The calculated ra-
diation dose to the superficial cervical lymph
nodes was about 7000 rads. No other neo-
plasms were observed in these dogs, but they
had been at risk for less than three years. In
the plutonium inhalation studies at Battelle-
Northwest, over 50 dogs have been at risk five
to 11 years (Park et al, 1972). Metastases of
primary pulmonary tumors to tracheobronchial
and mediastinal lymph nodes and lymphatics
were common. However, as previously men-
tioned, only one dog had a possible malignant
lymphoma, which was confined to the mesenteric
and mandibular lymph nodes. It can be con-
cluded from the relatively numerous rodent and
dog experiments with -MSPu and ->!''Pu in which
many lymph nodes have been exposed to a wide
range of doses and dose rates from background
PLUTONIUM INDUCED LUNG CANCER IN EXPERIMENTAL ANIMALS
CALCULATED CUMULATIVE MEAN DOSE TO UHC IRADS)
Figure III—8.—Plutonium-induced Lung Cancer in Ex-
perimental Animals. Mean incidence and radiation
dose values are those reported in the literature. Bi-
nomial confidence limits were calculated from data
included in the referenced literature.
D 23°PuO2—Dogs (from Park and Bail, 1972)
V ="PuOa--Mice (from Temple el al., 1959, 1960)
A -'3'PuOit—Mice (from Temple et al., 1959, 1960)
0 22!'Pu02—Mice (from Wager et af.,1956)
O -!"Pu Citrate—Rats (from Koshurnikova «>i al.,
1971)
0 z3opu Ammonium plutonium pentacarbonate—Kats
(from Koshurnikova et al., 1971)
X ^sPu—Rats (from C. L. Sanders, 1973)
-------
680
should be less hazardous than equivalent radia-
tion energy distributed over a large tissue vol-
ume. In fact, such a concept would lead imme-
diately to the conclusion that the larger the
particle (in terms of activity) the less effective
the radiation emitted would be in producing
cancer because of the increased fraction of ra-
diation energy wasted on dead cells. An experi-
ment showing this effect was done by Passon-
neau et al., (1952) using glass beads
containing <)0Sr on rat skin. The same amount
of activity was used for the same area of skin
but the activity was distributed either in a uni-
form flat plate, in 50 beads, in 20 beads or in
10 beads. The results given in Table III-B in-
dicate clearly a decrease in the tumor produc-
tion efficiency as the radioactivity was concen-
trated in fewer sources irradiating a smaller
total area of tissue. However, the beads with
the most radioactivity produced the largest
number of tumors per bead and the smallest
number of tumors per microcurie. The relevant
parameter is tumors per microcurie because
the basic question is how the risk from hot
particles compares with the risk from uni-
formly distributed radiation doses.
Dean and Langham (1969), using data de-
rived by Albert (1967a) on the production of
tumors in rat skin, predicted on an absolute
basis the probability of tumor production from
various sizes of plutonium particles. The re-
sults of this calculation predict a very high
probability of tumor production from most
particle sizes relative to a 0.016 pd lung bur-
den. The experiment of Albert on rat skin is
not really applicable to radioactive particles
deposited in lung because it did not deal with
particles, while Passonneau's is applicable to
the extent that it deals with particulate radio-
active sources, yet it still requires extrapola-
tion from skin to lung.
The recent Natural Resources Defense Coun-
cil (NRDC) petition (Tamplin and Cochran,
1974) uses mainly the results obtained in ra-
diation skin experiments (Albert et al., 1967a,
1967b, 1967c) to infer alpha-particle risks in
the lung. Hence, a critical test of their hypoth-
esis is whether a hot particle pattern of alpha
irradiation of the skin can produce tumors.
Two approaches have been used in skin ex-
periments. The first was to determine whether
isolated small areas of irradiated skin gave the
same yield of tumors per unit as large-area
skin irradiations. The focal irradiation pattern
with low LET radiation, electrons (Albert et
al., 1967b), was less efficient than the large
area exposure in producing tumors. However,
with high LET radiation (protons) there was
no difference (Burns et al., 1972). If these re-
sults can be extrapolated to alpha radiation,
they suggest that the risk from particulate
sources is no greater than from uniformly dis-
tributed sources.
The second approach involved the irradia-
tion of different depths in skin. In studies of
electron radiation with varying energies and
penetrating power, the occurrence of tumors
and atrophic follicles suggested the existence
of target cells at a depth of about 0.3 mm in
the skin corresponding to the lower end of the
resting hair follicle (Albert et al., 1967a). This
critical depth remained constant even when the
skin was irradiated with the hair in the grow-
ing phase, i.e., when the follicles extend to a
depth of 08 mm (Burns et al., 1973a). There
was a quantitative association between the in-
cidence of tumors and atrophic follicles for
various types of ionizing radiation, various
spatial distributions of dose within the skin
and for different phases of hair growth (Al-
bert et al., 1967c). A plausible explanation for
the experimental results is that each follicle
has a population of stem cells at a depth of 0.3
mm that are concerned with the production of
sebaceous cells and hair. These stem cells ap-
parently constitute the most sensitive potential
oncogenic cell population to ionizing radiation
in the rat skin since all the tumors were
mainly of hair follicle origin (Albert et al.,
1969). Neoplastic transformation of a signifi-
cant number of these target cells required
Table III-B
TUMOR PRODUCTION IN RAT SKIN FOLLOWING
EXPOSURE TO FLAT PLATE AND POINT
SOURCES OF ™Sr/°"Y*
Number of tumors
Source
Number Per Relative
Activity of rats Total bead Per jiCi efficiency
Flat Plate
(1000 /iCit
Flat Plate
(1500 M'O
.~>0 Bends
20 Beads
10 Bends
28.6 iiC\/cm-
42.9 /id/cm2
30 /iCi/bead
75 ^Ci/bead
150 /jCi/bead
-I
\
73!
58
77
74
89
27 0 009
24 0 016
1C 0.022
0.00049
0.00031
0.00021
0.00014
1.59
1.00
0.671
0.464
Modified from Passonneau et al. (1952) by information given in
NAS-NRC Publication 848 (NAS-NRC. l'J61a) .
17
-------
681
large radiation doses which in turn killed most
of the target cells and thus caused follicle atro-
phy.
Similar studies were reported (Albert et al.,
1972) in which the dorsal skin of mice was ir-
radiated with electrons in single exposures at
varying dose levels. Comparison of these data
with the rat skin experiments showed that the
radiation sensitivity of the mouse skin for hair
follicle destruction was at least twice that of
the rat, that the incidence of atrophic follicle
formation in the mouse was considerably less
than in the rat, and that as a consequence the
incidence of epithelial skin tumors (adnexal tu-
mors) is "markedly lower in mice than in
rats." Thus the hair follicles in the mouse skin
exhibit a lesser ability to form atrophic hair
follicles and a greater sensitivity to the lethal
action of the radiation. Furthermore, there are
striking differences between strains of rats in
the incidence of adnexal tumors resulting from
similar doses of electron skin irradiation (Al-
bert etal,1961).
Because alpha radiation from a plutonium
particle has a range in unit density tissue of
only about 40 microns, the effect of focal irra-
diation at different levels of the hair follicle is
a crucial test of the recent NRDC proposal
(Tamplin and Cochran, 197-4). Alpha irradia-
tion of the skin from the surface to a depth
of about 0.15 mm did not produce tumors
(Heimbach et al, 1969). This result, however,
is consistent with the existence of a target cell
population at a depth of about 0.3 mm. How-
ever, selective irradiation of the lower end of
the hair follicle at a depth of 0.3 mm by use of
the Bragg peak from an alpha beam did not
produce tumors or atrophic follicles unless
there was substantial irradiation of the entire
follicle. This observation suggests that even
though the critical cell population is located at
0.3 mm, there are recovery mechanisms that
block oncogenesis when only part of the "criti-
cal architectural unit of tissue" is irradiated.
What these recovery processes might be is not
understood. Nevertheless, this result does not
support the contention that a single plutonium
particle irradiating a "critical architectural
unit" such as the hair follicle, will produce a
tumorigenic risk of the magnitude assumed by
Tamplin and Cochran (1974).
Richmond et al. (1970) investigated the ef-
fects of 2J8Pu dioxide particles lodged in the ro-
dent lung vasculature following intravenous
injections. These particles averaged about
180 ju.ni in diameter and gave average dose rates
to the entire lung of about 3.5 rems per hour
with the alpha particle dose rate at the surface
of the particle on the order of 10s rads per
hour. The longest exposure until sacrifice was
a group of 6 rats which lived to 600 days. Ex-
amination of the lung following these expo-
sures indicated the presence of a microlesion
with complete degeneration of the cells close to
the particle. However, the evidence indicated
that this was not simply a stable type of scar
tissue but rather that the lesion was in a dy-
namic state in which the collagen was renewed
constantly with subsequent liquincation.
Within this time period there were no tumors
produced nor were there any indications of ef-
fects that would be deleterious to the animal's
overall well being. It is noteworthy that the
energy delivered to the lung, if averaged over
the entire lung, would be on the order of
2,000,000 rads in 600 days. This dose, if uni-
formly distributed, is much greater than that
shown to cause deaths in relatively short times
and is considerably above doses shown to pro-
duce lung cancers.
In the experiment of Richmond et al.
(1970), the particles appeared to be firmly
fixed in the blood vessels, and therefore were
not representative of particles actually depos-
ited in the alveoli. Although movement of such
particles is known to occur, compared with in-
haled plutonium they are relatively static. Cells
located at the periphery of the zone of cellular
destruction caused by the radiation may re-
ceive radiation doses ranging from just suble-
thal to essentially zero.
Experiments in which 238PuO^ microspheres,
similar to those used in the rodent studies, and
-J''PuOj microspheres were surgically implanted
into the lung of beagle dogs yielded results
that were qualitatively similar to those ob-
served in rodents. The implanted plutonium
particles produced small discrete microlesions
but no lung malignancies were observed (Rich-
mond et al, 1974). It should be recognized that
relatively few animals were used and that the
times of exposure were not long. However, one
dog was sacrificed at 4 years and 2 are still
alive 7 years past implant. That lung malig-
nancies have not been observed even though
the local radiation doses were extremely in-
tense is of considerable radiobiological interest.
18
-------
682
Any repopulation of the volumes of de-
stroyed tissue could result in rapid prolifera-
tion of damaged cells which have received
sublethal doses of radiation. This situation
would appear to have a high potential for pro-
ducing cancer but is difficult to investigate ex-
perimentally without an understanding of the
basic mechanism of cancer production and of
the response of such damaged cells to an other-
wise normal environment. Information on this
possibility is limited but some indication that
it is not a predominant problem can be ob-
tained from the experiments of Passonneau
(1952) and Richmond et al. (1970, 1974)
which did involve just such conditions in sev-
eral types of tissue.
Current work uses a similar experimental
design but with 10 ju,m diameter zirconium
oxide microspheres containing Pu02 at specific
activities corresponding to respirable particles
of Pu02. These experiments are directly
applicable to the hot particle problem (Rich-
mond and Voelz, 1972, 1973; Richmond and
Sullivan, 1974). In these experiments every
animal received 2000 plutonium-containing
particles. Eight exposure levels and two con-
trol groups were used with particle specific ac-
tivities ranging from 0.07 to about 60 pico-
curies. Of the 713 hamsters used in this
experiment only two control animals and one
injected animal are alive at present. Table
III-C shows the radiation doses calculated by
three dosimetric models and the number of ex-
pected tumors per group as calculated from a
lung model (Coleman and Perez, 1969) based
on Albert's skin data. This model is basically
similar to those developed by Geesaman (1968)
and Dean and Langham (1969) as the dose re-
sponse function assumed in the calculation is
based upon the Albert rat skin data. About 1 %
of the lung mass of the animals shown in
Table III-C was irradiated, and the median
dose rate to those cells within alpha range of a
microsphere was estimated to be 20-1800
rad/day.
No aberrant clinical signs have been ob-
served in any of the animals that have died or
have been sacrificed to date. Blood samples
have revealed no abnormalities even after long
exposures and there have been no regional
lymph node effects. Occasionally, small accu-
mulations of macrophages are seen around
spheres but the fibrous encapsulation pre-
viously described for the larger more radioac-
tive (about 180 micron diameter) spheres
(Richmond et al., 1970, 1974) are not seen.
Two rarely occurring tumors were observed
among animals included in Table III-C. One
hamster developed an angiosarcoma of the
lung after 9.5 months exposure to 2000 micro-
spheres each containing 0.42 picocurie alpha ac-
tivity (level 2A). Another animal developed a
lung sarcoma at the same exposure level after
12 months. Table III-C shows a predicted
tumor incidence of 40 tumors for this group
(level 2A). No other lung tumors have been
observed in this experiment. Every animal in
the experiment should have developed two lung
tumors if the tumor probability is 10'3 per par-
ticle as speculated by Geesaman (1968).
Table III-C
EXPOSURE CONDITIONS FOR PRELIMINARY EXPERIMENT (2000 SPHERES/ANIMAL,
ABOUT 70 ANIMALS/GROUP)
(Richmond and Voelz, 1972)
Isotope
"'Pu
"Pu
Level
Number
1
2
2A
3
3A
4
5
6
nCi/Animal
0.14
0.44
0.84
1.82
3.2
8.6
26.6
119.0
Specific
Activity
pCi/sphere
0.07
0.22
042
0.91
1.6
4.3
13.3
59.4
Equivalent -
Diameter
Pure !JSPu02
e Rate at
Surface
of Sphere
(rads/hr)
4.2 X 101
1.2 X 10-'
2.5 X 10:
5.5 X 102
1.0 x 103
2.5 x 103
8.4 x 103
3.6 x 104
40 fim from
center
(rads/hr)
6.8 X lO'1
2.2 X 10"
4.1 X 10°
1.0 X 101
1.7 X 10'
4.2 x 101
1.3 X 102
5.8 x 102
Expected Tumoi
Incidence"
(tumors/group)
2
10
- 40
60
40
10
0
0
• Using NUS structure lung, with a lung density of 0.19 g/cma (Coleman and Perez, 1969.)
b Assuming 1 g of lung irradiated.
19
-------
An additional 485 animals were injected
with larger numbers of spheres,
6000-1,000,000 per animal, to irradiate over
98% of the lung. Lower specific activity
spheres were used, and median dose rates
ranged from 6-25 rad/day. One of these ani-
mals developed a primary lung tumor. Other
animals have been injected writh 50,000-
900,000 spheres to extend the range of
sphere specific activity down to 0.015
pCi/sphere. Lung burdens were 0.86-177 nCi,
and median dose rates were 1.3-320 rad/day.
There are about 2000 animals in this study.
Approximately 1150 animals have lived their
full life spans or have been sacrificed to date
as part of this experiment. About 5.7 X 106
spheres with specific activities in excess of 0.07
pCi each were injected into these animals. The
observation of three primary lung tumors sug-
gests a tumor risk of roughly 10'7 per particle
as a preliminary estimate. These results are
particularly significant in view of the demon-
stration by Little et al. (1970a, 1970b, 1973)
that the Syrian hamster develops pulmonary
neoplasms with high efficiency and short induc-
tion time following exposure to soluble 210Po.
The distribution of all exposure conditions is
summarized in Figure III-9 in which the ordi-
nate is the number of spheres per animal
(scale on left) or fraction of lung irradiated
(scale on right), and the abscissa is sphere
specific activity. The diagonal lines are loci of
constant plutonium dose and are labeled with
the lung burden in nCi. The special interest in
burdens between 10 and 100 nCi is occasioned
10'' 10"' 10 10'
Specific Activity (pCi/sphere)
Figure III-9.—Distribution of exposure groups with
respect to number of spheres per animal (ordinate)
and specific activity of spheres (abscissa). The lines
are loci of constant lung burden and are labeled with
nCi of plutonium per animal. Symbols indicate year
of injection: (•) 1971; (•) 1972; and (A) 1973
(Richmond and Sullivan, 1974).
683
by the report of Little et al. (1970a) that a
high tumor incidence develops rapidly in ham-
sters exposed to these levels of soluble 210Po.
In a study of 21"Pu02 particles administered
by intraperitoneal injection in rats, about 2%
of the plutonium was found in the vasculature
of the lung 300-500 days post-injection (Sand-
ers, in press). The mean lung doses from these
plutonium particles of > 0.3 ,um diameter
ranged from 10 to 600 rads for three treat-
ment levels: 0.072, 0.360 and 2.900 ^Ci. Of 106
rats that survived longer than 200 days (life
shortening occurred in the highest dose groups
and was due to irradiation of the peritoneal
cavity), one rat in the lowest dose group died
with a bronchiolar-alveolar adenocarcinoma
after 823 days. There was no other primary
pulmonary neoplasia and little evidence of
cellular reaction to the plutonium particles in
the lung, even among those cells adjacent to the
particles. Inflammation, fibrosis, and epithelial
hyperplasia and metaplasia were not observed.
In general these findings agree with the results
from the current plutonium microsphere stud-
ies at Los Alamos (Richmond and Voelz, 1972,
1973; Richmond and Sullivan, 1974).
The liver has been used to determine the
effectiveness of -3aPuO:, particles in producing
chromosome damage relative to the amount
produced by 239Pu citrate in the ionic or mon-
omeric form (Schubert et al., 1961). Brooks et
al. (1974) injected monodisperse 230PuO.> parti-
cles (0.17, 0.30, 0.44 and 0.84 /im) intrave-
nously into Chinese hamsters. About 90% were
deposited and retained with a long effective
half life in the liver. Using these four particle
sizes and 239Pu citrate, two cytogenetic studies
were conducted. In the first, a constant total
activity, 1 x 1Q-3 ^Ci/gm body weight, was in-
jected using the three sizes of Pu02 particles.
Constant activity and variable particle size
produced a constant average radiation dose to
the liver with a varied local radiation dose and
percent of the liver irradiated. In the second
study, a constant particle size, 0.30 fan, was in-
jected with activity ranging from 6 X 10'3 to
6 X 10~5 fid/g body weight. The local radiation
dose rate around each particle was constant in
this case and the average radiation dose and
number of particles were variable. Unexposed
animals and animals administered 2J9Pu citrate
at a concentration of 6 X 10"" /xCi/g body
weight were used for comparison purposes.
20
-------
684
When the average dose was related to the
aberration frequency for the 239Pu citrate
(Figure 111-10), there was a linear increase
according to the equation Y = 0.02 +4.8 x!Q-3D
where Y is aberrations per cell and D is dose
in rads. This relationship implies that approxi-
mately 200 rads of irradiation from uniformly
distributed 239Pu were required to produce an
average of 1 aberration per cell. Because cells
with radiation-induced chromosome aberra-
tions have poor reproductive potential, these
cells can be considered as reproductively dead
(Carrano and Heddle, 1974). Abnormalities
observed following injection of the particles in-
creased in an approximately linear manner over
an average dose range up to about 200 rads,
then plateaued at higher doses. The slope of
the ascending portion of the dose-response
curve for the particles was less than that ob-
served following injection of 239Pu citrate. The
relationship between aberration frequency and
average dose to a sphere of tissue within the
range of alpha radiation from plutonium parti-
cles indicates that the efficiency of producing
aberrations decreased as the particle size in-
creased. At the smallest particle size, 0.1 fan,
the response was close to that seen in animals
exposed to 230Pu citrate suggesting that the
dose distributions in the liver were similar.
In addition to determining the aberration
frequency per cell, the distribution of damage
throughout the cell population was also deter-
mined. The distribution of damage among liver
cells exposed to plutonium particles was non-
Poisson, indicating that the damage was lim-
ited to relatively few cells, some of which were
severely injured. The damage in cells exposed
to 239Pu citrate (Brooks et al., 1974) was de-
scribed by a Poisson distribution, indicating a
Figure 111-10.—Chromosome aberration frequency in
the liver of the Chinese hamster following intrave-
nous injections of 23!lPuO2 particles or 239Pu citrate
relative to average tissue dose in rads.
large number of less severely damaged cells;
similar results were observed in experiments
with 241Am (McKay et at., 1972)^and 252Cf
(Brooks et al., 1972). This implies that a
larger fraction of the irradiated cells were re-
productively dead after nonuniform irradiation
than after uniform irradiation, and perhaps
also indicates a smaller risk for tumor induc-
tion.
Little and co-workers (Little et al., 1970a,
1970b; Grossman et al., 1971; Little et al.,
1973) studied the effects of 21"Po chloride ad-
sorbed onto hematite (ferric oxide) particles in
Syrian golden hamsters following intratracheal
instillation. Animals were given 15 weekly
injections of 3 mg of hematite containing ei-
ther 0, 0.01 or 0.2 /nCi of 210Po; the mean radia-
tion doses calculated for the entire lung were
225 and 4500 rads, respectively, at the end of
one year (Little et al., 1970a). The earliest and
highest incidence of pulmonary neoplasia oc-
curred in those hamsters receiving the larger
dose of 210Po; the first lung cancer appeared in
an animal sacrificed 15 weeks after adminis-
tration. This experiment showed that lung can-
cer could be produced in hamsters by alpha ra-
diation, but it did not consider the relative
effectiveness of uniform versus nonuniform
dose distribution.
In an experiment designed to consider uni-
form and nonuniform dose distributions
(Grossman et al., 1971), four groups of 50
hamsters each were given separate intratra-
cheal instillations twice per week for seven
weeks of either 3 nig hematite followed by 0.2
/iCi =10Po in saline, saline followed by 0.2 /tCi
J'"Po, saline followed by 0.2 /xCi 210Po adsorbed
onto 3 mg hematite, or saline followed by 0.2
ju.Ci 2l"Po adsorbed onto 0.3 mg hematite. In an
additional experiment (Little et al., 1973)
hamsters were given seven weekly injections
of 0.2 /iCi 210Po alone in saline. The cumulative
radiation dose to the lung was about 800 rads
as compared with about 2000 rads when the
same amount of activity was given adsorbed
on either 3 or 0.3 mg hematite particles. The
mean tumor induction time was considerably
shorter for the group given 210Po in saline, and
the tumor incidence was lowest for the group
with the most nonuniform distribution of
210Po.
The major differences among the groups in
these experiments was in the microscopic dis-
tribution of the 210Po as shown by autoradiog-
21
-------
raphy. Distribution throughout the lung was
distinctly nonuniform for the J'°Po contained
on hematite. Reduction of the mass of hematite
particles from 3 to 0.3 mg should have had the
effect of further increasing the nonuniformity
of the 210Po in the lung as there were 1/10 as
many particles administered and each one con-
tained 10 times as much activity. Preliminary
results suggested that an equal amount of 2iaPo
adsorbed on 0.3 mg hematite was even less
effective for lung tumor induction than when
adsorbed on a larger number of carrier parti-
cles of lower specific activity (Table III-D and
Fig. III-ll).
Little et al. (1973) tentatively concluded
that ". . . in the dose range studied, alpha ra-
diation is more carcinogenic when a lower but
relatively uniform dose is delivered to a large
volume of lung tissue than when a similar
amount of radioactivity is distributed nonuni-
formly such that the primary effect is to de-
liver much higher radiation doses to relatively
small tissue volumes."
Studies of a beta-gamma emitter failed to
confirm the existence of a unique carcinogenic
hazard due to intense irradiation of tissue sur-
rounding radiation particles in lung (Cember
and Watson, 1958a, 1958b; Cember et al., 1959;
Cember, 1963; Cember, 1964a, 1964b; Cember
and Stemmer, 1964). In a series of experi-
ments with intratracheally administered
144CeF3 and 144CeCl3 in rats, the incidences of
pulmonary neoplasia were similar to those ob-
served at comparable radiation doses in experi-
ments where 90Sr containing glass beads were
implanted in rat lungs.
Table III-D
INFLUENCE OF DOSE DISTRIBUTION ON
21°Po CARCINOGENESIS
Treatment Schedule*
Mon
Wed
Number
of Num-
Animals Ntim- ber
Autopsied ber with Tumor
Radiation 58th Still LunK Inci-
Dose** Week Alive Tumors denre
3 mg 210Po alone 800 rads 37 0 22 60%
heme
Saline 2>°Po-3 mg 2000 rads 31 6 18 58%
heme
Saline 21°Po-0.3 mg — 25 12 9 36r/
heme
* Animals received two instillations each week fot i v-eeks
Polonmm-210 (0.2 fiCi) Riven either alone in saline 01 liourid to
hematite particles in amounts indicated.
** Cumulative radiation dose averaged ovei \\hole lun^s for pel lod
up to 1 week after last instillation. These doses tentatively as-
signed, based on preliminary radiochemical data.
685
When Cember gave 0, 4.5, 45 or 4500 micro-
curies of Ba35S04 as a single intratracheal
injection to rats, no lung cancer or any other
lesion suggesting that cancer might develop
was observed in any of the experimental ani-
mals during a nine-month observation period
(Cember et al., 1955). When the Ba"SO, was
given as 10 weekly doses of 375 microcuries
each, 2 of the 16 rats which survived the injec-
tion regime died at 312 and 319 days later
with extensive squamous cell carcinomas of the
lung (Cember and Watson, 1958b). Calculated
radiation doses were on the order of 12,000
rads.
Cember and Watson (1958a) implanted 90Sr
containing glass beads in the lungs of rats.
The beads contained from 1.09 to 59.3 ,j.Ci 90Sr
and were 320 ± 110 p,m diameter. Seven of the
23 rats (30%) developed primary pulmonary
neoplasms: 4 had squamous cell carcinomas
and 3 had lymphoid neoplasms. The earliest
death in a tumor bearing animal occurred at
169 days following implant. The total radiation
dose in these animals, calculated for a sphere
of tissue with a radius equal to the range of
the beta radiation, ranged from 47,000 to
260,000 rads. Murine pneumonia was a prob-
lem with the experimental animals. No acute
deaths were due to radiation effects and no
life-shortening was observed.
,25
z
<
020
O
a: 10
1
A
_..+
*- "f
10 20 30 40 50
TIME AFTER FIRST INSTILLATION, weeks
Figure III-ll.—Influence of dose distribution on the
induction time of lung tumors. Hamsters were given
seven weekly intratracheal injections of 0.2 /iCi of
•10Po and hematite particles by different treatment
plans: •---•, -'iop0 in saline and 3 mg of hematite
given on different days each week, x- - -x, -10Po ad-
sorbed onto 3 mg of hematite particles. +--- + , -10Po
adsorbed onto 0.3 mg of hematite particles (see Table
III-D).
22
-------
686
The experiments of Cember are of consider-
able relevance to the problem of nonuniform
dose distribution. Cember (1964a) stated that
the question of the unique carcinogenic hazard
associated with the high absorbed dose gra-
dient around a single radioactive particle de-
posited in the lung seemed to be answered by
the results of the acute Bair>SO, exposures to-
gether with the 14!Ce experiments. He also
pointed out that the negative results of the
long term retention of several Bajr'SO, parti-
cles, under conditions suitable for testing the
hypothesis that such focal radiation presents a
unique carcinogenic hazard to the lung, imply
the absence of such a hazard associated with
one or a very small number of loci. His review
also emphasized that, for a given total amount
of absorbed energy, low-level, continuous expo-
sure of the total lung may be more carcino-
genic than the same amount of energy deliv-
ered acutely to a restricted volume of tissue.
Furthermore, Cember (1964a) realized that
the quantitative relationship among total ab-
sorbed dose, the temporal and spatial distribu-
tion of the dose, and probability of developing
radiogenic lung cancer had not been estab-
lished at that time. However, the similarity of
the lung tumor dose response curves for solu-
ble 14'CeCl, and insoluble '"CeF., suggested the
absence of a hot particle effect. He states
"should this be true, then it follows that radia-
tion dose to the lung from inhaled radioactive
dusts may be calculated, for purposes of esti-
mating radiological risk, by assuming uniform
absorption of energy throughout the lung."
However, the 144Ce experiments should be in-
terpreted with caution since Cember (1964b)
noted that the "4CeCl3, which is soluble in solu-
tion, produced discrete focal areas of radioac-
tivity in the lung following injection.
In the summary of his review Cember
(1964a) states, "Experiments with rats have
shown that radioactive substances deposited in
the lung can lead to pulmonary neoplasia. Ra-
diations from 35S, 90Sr-90Y, and 144Ce elicited
bronchogenic carcinoma and alveolar cell carci-
noma in addition to several other tumor types.
These experiments did not confirm the exist-
ence of a unique carcinogenic hazard due to
the intense concentration of absorbed energy
in the lung tissue immediately surrounding an
inhaled radioactive particle."
Studies reviewed by Moskalev (1972) with
inhaled 239Pu citrate or ammonium
-'"plutonium pentacarbonate have shown a sig-
nificant increase in the incidence of lung tu-
mors in rats at cumulative absorbed radiation
doses to the lung of about 50 rads. Studies in
rats reported by Sanders (1973) indicated in-
creased lung tumor formation at 9 and 32 rads
following inhalation of = 1RPu although the num-
ber of tumors in the 9 rad dose group were not
statistically significant as compared with unir-
radiated controls. According to Koshurnikova
et al. (1968) the microdistribution of 239Pu in
the lungs and regional lymph nodes at long
times after exposure is characterized by non-
uniformity. This has also been observed in
dogs, Figure III-3. Therefore, it is likely the
radiation dose from the J'lsPu in Sanders' study
was more distributed in lung tissue than the
-|r'Pu in the studies reviewed by Moskalev, thus
irradiating a relatively larger number of sensi-
tive cells. This could account for Sanders find-
ing lung cancer occurring at lower radiation
doses from -'"Pu than has been associated
with 2!''Pu. However, dose rate cannot be ex-
cluded as a contributing factor because the
-''•Pu in Sanders' experiment was cleared very
rapidly from the lungs; nearly all of the radia-
tion exposure occurred within 100 days after
inhalation of the ~JXPu aerosol.
Preliminary results from studies by Lafuma
(1974) and his colleagues with compounds of
-"Pu, -:''Pu, -"Am and -44Cm in rats indicate
that the toxicity increases with the dispersion
of the inhaled radionuclide in lung. Curium-
244 nitrate was the most highly dispersed and
the most toxic at equivalent radiation doses.
Curium-244 was also cleared from lung more
rapidly than the other radionuclides with a
pulmonary retention half-time of only eight
days.
The conclusion which results from a careful
consideration of these experimental animal
studies is clear. None of the results unequivo-
cally prove that plutonium distributed in lung
tissue as particles is more hazardous than the
same amount of plutonium distributed uni-
formly. To the contrary, experimental results
lead to the conclusion that the hazard of plu-
tonium increases with the dispersion of pluto-
nium within the lung. Although inhaled pluto-
nium is seldom if ever uniformly distributed in
lung but is aggregated, a model based on uni-
form distribution is probably the conservative
approach for radiation protection purposes.
23
-------
IV. HUMAN EXPERIENCE
687
There has been no recorded incidence of can-
cer in man resulting from the internal deposi-
tion of any plutonium isotope in the more than
three decades that plutonium has been used.
This excellent record has resulted from ex-
tremely effective control methods. The absence
of tumors is also significant evidence concern-
ing the tumorigenic potential of plutonium in
the lung because a number of wartime acciden-
tal exposures occurred three decades ago—a
time comparable with probable tumor induc-
tion times. Data from occupationally exposed
Pu workers, limited as it is, constitutes human
experience of the most relevant kind for estab-
lishing value judgments where experimental
data are not always conclusive for formulating
risk evaluations.
During late 1944 and 1945, at what is now
the Los Alamos Scientific Laboratory, 29 men
associated with the Manhattan Project as plu-
tonium workers were identified on the basis of
nose swipes or urine radioassay as having re-
ceived plutonium exposures (Hempelmann et
al., 1973b). Of these, 3 were later dropped
from the series as the result of improved assay
techniques which indicated lower plutonium
burdens than estimated earlier, and 1 died of
coronary heart disease. These individuals were
all young men involved in four basic opera-
tions related to the development of the first nu-
clear weapons: plutonium purification (wet
chemistry); fluorination (dry chemistry); re-
duction to metal; and recovery.
Clinical and laboratory data from this group
of men have been collected periodically since
1953. These data consisted of medical histories,
physical examinations, blood counts and chem-
istry, urine radiochemistry, routine urinalysis,
and roentgenograms (Hempelmann et al.,
1973b). Studies of sputum cytology, lympho-
cyte karyology, and chest counting for ura-
nium L x-rays were begun in 1970. Table IV-A
shows information on estimated date of expo-
sure and estimates of the body burden as
determined by urine radiochemistry measure-
ments made in 1953 and 1972 (Hempelmann et
al., 1973a). In all cases, the values represent
estimates of the body burden based on a urine
excretion model obtained from human data
(Langham, 1957). In all cases but two, the
1972 estimates are higher than those for 1953,
usually by a factor of 2-3 and occasionally by
a factor of 5-6. The 1972 estimates are consid-
ered to be more relevant as they are based
Table IV-A
PLUTONIUM BODY BURDEN ESTIMATES FOR
MANHATTAN PROJECT PLUTONIUM WORKERS
ESTIMATED SYSTEMIC
Numberf
1
2
3
4
5
6
7
8
9
10
11
12
13
16
17
18
19
20
21
'22
23
24
25
26
27
A D t
of Exposure
Late 1944
Late 1944
May 1945
June 1945
June 1945
June 1945
June 1945
June 1945
July 1945
July 1945
July 1945
July 1945
July 1945
July 1945
August 1945
August 1945
August 1945
August 1945
August 1945
August 1945
September 1945
September 1945
September 1945
October 1945 .
October 1945
BODY BURDEN*
1953
0.03-0.06
0.006-0.032
0.08
0.08
0.08
0.06
0.06
0.04
0.06
0.05
0.03
0.03
0.02
0.006
0.04
0.04
0.03
0.02
0.02
0.02
0.02
0.006
0.006
0.02
0.02
1972
0.206
0.03
0.42
0.26
0.18
0.14
0.15
0.11
0.11
0.10
0.05
0.12
0.005
0.03
0.13
0.10
0.02
0.05
0.04
0.05
0.04
0.03
0.01
0.006
0.05
Microcurie + approximately 50% at the year indicated.
f Subjects #14 and #15 were dropped because of the death of one
subject from coronary heart disease and the low body burden of
the other as determined by modern assay techniques. Two others,
not shown, were dropped from the original 29.
25
-------
688
upon more excretion data and improved ana-
lytical techniques. High plutonium levels of
nose swabs at the time of exposure suggested
that most of the subjects received their expo-
sure via inhalation.
Based on data shown in the last column of
Table IV-A, the 25 men shared a total systemic
plutonium burden of approximately 2.5 ju.Ci in
1972. If one assumes, as a rough approxima-
tion, that 25% of the initial lung burden was
translocated from the lung to the systemic cir-
culation and then to organs such as the liver
and bone, it follows that the total initial lung
burden for thig group of men was approxi-
mately 10 juCi.
During the most recent examinations per-
formed at Los Alamos (Hempelmann et al.,
1973a) estimates were made of the amount of
plutonium in the chest (lung and respiratory
lymph nodes) of each man using in vivo chest
counting techniques. At 27 years following
contamination, 14 of the 21 men measured had
calculated chest burdens ranging from 0.003 to
about 0.010 /iCi. This observation indicates
that some of the plutonium was inhaled or re-
tained in a relatively insoluble form, which is
consistent with the fact that some of the indi-
viduals were known to have been exposed to
239PuOo because of the work they performed.
Studies of these and other men are continuing.
Except for the ailments one would expect in
a group of men mostly in their early fifties, all
of the Manhattan Project workers are in re-
markably good health. This is additional infor-
mation that tends to support the general argu-
ment that the radiation protection guides for
plutonium have not been grossly in error. Al-
though the study group is relatively small (25
men), the magnitude of the plutonium bur-
dens, the long time since exposure, and the co-
operativeness of the men make it unique and
extremely valuable. However, because some-
thing like 16 to 20% of all deaths annually in
the United States are from cancer, one might
be concerned about the size of the group, as 4
or 5 might be expected to die from "naturally
occurring" cancer had they never been exposed
to plutonium. However, evidence obtained from
experimental animal studies indicates that plu-
tonium induces specific kinds of cancer, pri-
marily lung carcinomas, bone sarcomas, and to
a lesser extent bile duct tumors, depending on
the route of exposure.
Although the particle size distribution of the
inhaled material is unknown, an estimate can
be made on the basis of aerosols produced by
somewhat similar incidents. The value of 0.32
ju.m for the mass median diameter was meas-
ured for an incident involving a fire at the
Rocky Flats facility in 1965 (Mann and Kirch-
ner, 1967) and is similar to values found in
a glovebox at a fuel fabrication plant by Raabe
(in preparation) and by Moss et al. (1961) for
plutonium aerosols in plant and laboratory op-
erations. Ettinger et al. (1973) report various
particle sizes for several operations. For a re-
covery operation, a submicron aerosol had a
typical activity median aerodynamic diameter
of 0.3 /xm.
If one assumes a log-normal particle size dis-
tribution with a mass median diameter of 0.32
/urn, standard geometric deviation (o-g) of 1.83,
and a density of about 10 g/cm3, the number of
particles above a given size can be calculated.
In this case, about 15% of the mass can be
shown to be associated with particles larger
than 0.6 ^m real diameter (about 2 /urn aero-
dynamic equivalent diameter). One can then
calculate that each person in the group of 25
men might have retained about 4 X 10r> parti-
cles above 0.6 ^m diameter (0.07 pCi or more
per particle) from the orginal 10 /*Ci. If the
cancer risk for such "hot particles" were 5 X
10~4 per particle, as postulated by the Natural
Resources Defense Council report (Tamplin
and Cochran, 1974), the 4 X 105 particles
should yield about 200 cancers per man or
about 5000 for the group. Even the residual
plutonium (average of 6 nCi per man) measured
in 14 of the original Manhattan Project pluto-
nium workers should yield 3 cancers per person.
One could also argue that the number of cancers
predicted from such a risk estimate might be
ten times larger as the product of 10s particles
(10 /iCi -s- 0.07 pCi), each 0.6 p.m real diame-
ter, and the risk estimate of 5 X 10 4 per parti-
cle yields 5 X 104 tumors for the group. The
observed lung cancer incidence after almost 30
years since exposure is zero.
Because of observations of chronic lympho-
penia in dogs exposed to plutonium oxide aero-
sols, one might expect to observe chromosome
damage in lymphocytes of exposed plutonium
workers. This observation led Dolphin (1971)
to investigate the possibility of chromosomal
aberrations in lymphocyte cultures obtained
from workers in England known to have been
26
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689
exposed to plutonium. He compared the find-
ings in eight plutonium workers who had been
exposed to plutonium plus 14 rad of external
irradiation over a 7-year period with workers
who had received external irradiation only and
found that the dicentric yield of lymphocytes
of the plutonium workers could be accounted
for by the external radiation dose received by
the workers. Dolphin (1971) also cites another
case in which a plutonium worker was found,
by chest-counting, to have 10 to 20 times the
permissible level of plutonium in the lung
about three years after an inhalation accident.
Chromosome analysis indicated minimal radia-
tion exposure to the lymphocyte series even at
a high level of exposure of the subject.
Brandon et al. (1973) reported an increased
incidence of chromosomal aberrations in plu-
tonium production workers at the Dow Rocky
Flats plant. These investigators contrasted
chromosomal aberrations observed in lympho-
cyte cultures from six unexposed controls,
seven workers exposed to penetrating radia-
tion, and 27 men thought to have internal dep-
osition of plutonium. Although the workers
with lung burdens of plutonium had levels of
chromosome aberrations greater than those ob-
served for controls, the highest incidences of
chromosomal aberrations were observed in plu-
tonium workers who were thought to haye pri-
marily liver and bone burdens rather than sig-
nificant lung burdens. Because some of these
individuals worked around hot cells, the contri-
bution to the total radiation dose (plutonium
plus penetrating radiations) from the pene-
trating radiation is uncertain and complicates
the analyses.
The most recent physical examinations were
performed on 24 of the 25 Manhattan Project
workers during the past several years (Hem-
pelmann et al., 1973a). In addition to the usual
hematological procedures, blood samples were
obtained from these men for chromosomal
studies. Utilizing established cytogenetic tech-
niques for cultured lymphocytes, no chromoso-
mal abnormalities were found in any of the
subjects. However, it is planned that recently
developed chromosomal banding techniques
will be utilized in the future in evaluating the
presence or absence of lymphocyte chromoso-
mal aberrations.
Despite their relative rarity, much useful in-
formation has been obtained from accident
cases. Information obtained from the AEC's
Division of Operational Safety indicates that,
during the period 1957-1970, there have been
on the order of 200 contractor personnel ex-
posed to 25 r/r or more of the maximum permis-
sible body burden (MPBB) for plutonium.
These data also indicate that inhalation is the
major portal of entry and that more than half
of the cases are below 50% of the MPBB (0.04
/•Ci).
it may be instructive to look at a specific in-
stance of an industrial accident which was re-
ported by Mann and Kirchner (1967). On 15
October 1965, a fire in a plutonium fabrication
plant resulted in a large-scale spread of pluto-
nium oxide. The Rocky Flats body counter was
used to measure the plutonium in the lungs of
all employees working in the area and, of ap-
proximately the 400 employees counted, 25
were found to have enough plutonium in their
lungs to deliver a dose of 15 rem per year or
greater (i.e., at least 0.016 (u,Ci). Data from
each employee were obtained with a pair of
scintillation detectors in contact with the sub-
ject's chest; the 60 keV photon peak of 211Am
was used in the measurements. The J"Am con-
tent of the plutonium released in the fire was
determined, and the plutonium quantity was
then estimated from calibrations using a chest
phantom with similar -"Am/^Pu ratios. The
plutonium consisted of "high-fired" Pu02; par-
ticle size measurements of air samples collected
after the fire indicated a 0.32 /on mass median
diameter (MMD) with a geometric deviation
(ov) of 1.83. Lung counting data to date show
a slow clearance of plutonium, confirming the
high degree of insolubility of the inhaled mate-
rial. On the average, 30% of material initially
deposited in the lung was cleared in 2 to 3
months, with the remaining material clearing
slowly with little or no measurable absorption
into the bloodstream.
Of the 25 people who were involved in the
Rocky Flats incident, two had burdens as high
as 0.16 /xCi, a factor of 10 above the current
maximum permissible lung burden. Of those
available for follow-up, most are measured for
retained activity several times each year. In-
formation from these cases should ultimately
be included in the U.S. Transuranium Registry
(USTR).
By using the same assumptions employed
above for the Manhattan Project workers, one
can estimate the number of "hot particles"
[e.g., more than 0.07 pCi per particle as de-
27
-------
690
fined by Tamplin and Cochran (1974)] re-
tained in the deep lung of each of the involved
Rocky Flats personnel to be about 10" to 105.
Again, if the cancer risk were 5 X 10"1 per
particle, as postulated by the Natural Re-
sources Defense Council report (Tamplin and
Cochran, 1974), these particles should yield
5-50 lung cancers per person. To date, none of
these workers has shown detrimental effects
associated with his inhalation exposure of "in-
soluble" plutonium oxide in 1965. In this re-
gard, an increased incidence of lung cancer has
been reported as early as 5 to 9 years after
uranium miners were exposed to radon decay
products and other biological stressing agents
such as tobacco smoke and diesel fumes (Lun-
din et ai, 1971).
The local dose to tissue from each of the ap-
proximately 10' to 10" "hot particles" retained
in the lungs of the Rocky Flats workers, as-
suming a sphere of lung tissue at risk (180 ^m
radius) around each particle, is about 1200
rad/yr. Assuming an effective half-life for lung
clearance of 500 days, the cumulative local
dose to some cells over the 8.5 years for each
particle might be 2400 rad. This calculation as-
sumes a static particle irradiating a fixed
group of cells. Calculations based upon other
models (e.g., moving particles) would result in
smaller doses. Based on this information, one
might expect detectable biological effects in the
lung to have occurred in some of these exposed
workers, yet none has been reported to date.
One case of plutonium contamination result-
ing from a puncture wound is extremely inter-
esting, as it has been interpreted by some as
resulting in a "precancerous lesion" (Tamplin
and Cochran, 1974). In this reference, the fol-
lowing statement is made: "This precancerous
lesion indicates that a single plutonium-239
particle irradiates a significant (critical) vol-
ume of tissue and is capable of inducing can-
cer." Information on this case was originally
published in 1962 (Lushbaugh and Langham,
1962) and appeared again with additional in-
formation in 1967 (Lushbaugh et al, 1967).
The radiation dose around the plutonium im-
planted in the palmar skin was estimated to be
75,000,000 rad for the 4.25 year period be-
tween contamination and excision. However,
this kind of estimate may be meaningless, as
we do not know which cells were exposed or
for what time periods. The entire lesion was
small, being of the order of 2.8 x 10~5 cm3.
The authors (Lushbaugh and Langham,
1962) stated:
"Although the lesion was minute, the changes in
it were severe. Their similarity to known pre-
cancerous epidermal cytological changes, of course,
raised the question of the ultimate fate of such a
lesion should it be allowed to exist without surgical
intervention. Although no malignancies of the skin
of man have ever been shown autoradiographically
to be associated with such alpha-emitting foreign
bodies, the changes here would seem to indicate
that the development of such a lesion is possible."
This particular case has been referred to as
representing a "precancerous" condition result-
ing from plutonium (Tamplin and Cochran,
1974) and might have been the basis of a re-
cent statement (Gillette, 1974) which reads as
follows: "Only one human cancer case is
clearly linked to plutonium exposure." Ac-
tually, no human cancer case has ever been
'clearly linked" to plutonium exposure. The
U.S. Transuranium Registry (Norcross and
Newton, 1972) continues to attempt to corre-
late postmortem findings with body plutonium
measurements.
Cytologic changes have been described in
cells in the vicinity of embedded plutonium
particles in man. However, the malignant cel-
lular transformation required for the diagnosis
of actual cancer has never been found next to
"hot particles" in human tissue (Lushbaugh
and Langham, 1962; Lushbaugh et al., 1967).
Similar results have been reported for several
animal experiments designed to study the bio-
logical effects of hot particles (Richmond et al.,
1970, 1974). On the other hand, under certain
exposure conditions, plutonium is an efficient
cancer-producing agent in experimental ani-
mals.
For many years, several AEC contractor
laboratories have conducted tissue analysis
programs to determine plutonium levels in var-
ious tissues of both occupationally exposed per-
sonnel and members of the general population
(Lagerquist et al., 1972; Nelson et al., 1972;
Campbell et al., 1973). For example, as shown
in Table IV-B, plutonium concentrations have
been determined for lung, liver, lymph nodes,
kidney, and bone for the period 1959-1971 for
nonoccupationally exposed persons from sev-
eral regions of the United States and for occu-
pationally exposed persons. Similar data have
been obtained from nonoccupationally exposed
persons for the period 1972-1973, as shown in
28
-------
691
Table IV-C (Richmond and Sullivan, 1974).
The average lung concentration for the latter
period is about 0.3 pCi for the 1000 g lung, and
the lymph node concentration (per kilogram) is
about 11 pCi. The increase in lymph node con-
centration is due to greater care in lymph node
excision; the mass of relevant tissue excised
was reduced 5-7 fold, with consequent appar-
ent increase in Pu concentration.
Plutonium is present in extremely small
quantities in various organs of contemporary
adult humans. Although most of the plutonium
was produced from atmospheric testing of nu-
clear weapons prior to the 1963 limited test
ban, some material from contemporary atmos-
pheric weapons testing by China and France
adds to the total human burden. The current
lung burden estimate for persons in the United
States is about 0.3 pCi 2<">.«°pu, an(j an esti.
mate of the total amount in the body is about
3.2 pCi (Bennett, 1974).
The AEC's Health and Safety Laboratory
(HASL) recently has used information ob-
tained from the International Commission on
Radiological Protection to model the intake
and body burden from fallout plutonium and to
estimate the radiation dose to man from this
source (Bennett, 1974). The cumulative lung
and bone dose estimated from the period
1954-2000 is 16 and 34 mrem, respectively.
Bennett (1974) also compared the body burden
based on their model with that actually ob-
tained from the tissue sampling programs. The
agreement between the Colorado-New Mexico
tissue data and the model predictions for 1970
and 1971 was good.
Table IV-B
50th Percentile Distribution of Plutonium in Human Tissue (1959-1971)
Plutonium Disintegrations per Minute per Kilogram
Lung:
Liver
Lymph Node
Kidney
* Number of samples (in parentheses).
t Samples not requested.
} Data cannot be compared as a group because of differences m type and duration of exposure.
Table IV-C
50th Percentile Distribution of Plutonium in Human Tissue (1972-1973)
Plutonium Disintegrations per Minute per Kilogram
Lung
Lymph Node
Kidney
* Number of samples (in parentheses).
** 7 samples from Savannah River
9 samples from New Mexico and U.S.
14 samples from Colorado
Bone
Nonoccupationally Exposed:
Los Alamos
New Mexico and U.S.
Colorado
New York
All Populations
Occupationally Exposed :f
Potential
High Potential
1.3 (57)*
1.0 (76)
0.5 (66)
0.4 (26)
0.8 (217)
4.0 (44)
100.0 (15)
1.1 (58)
0.9 (73)
1.7 (60)
1.7 (26)
1.4 (217)
1.0 (41)
100.0 (15)
5.0 (52)
4.0 (66)
2.0 (46)
f
3.0 (164)
15.0 (42)
700.0 (14)
0.1 (54)
0.2 (66)
1 4 (45)
f
0.6 (163)
0.1 (42)
10.0 (13)
0.4 (35)
0.5 (41)
0 9 (65)
2.0 (25)
0.6 (166)
0.3 (25)
50.0 (11)
Gonad*
Nonoccupationally Exposed:
Los Alamos
New Mexico and U.S.
Colorado
Savannah River
All Populations
0.8 (8)*
0.4 (17)
0.7 (29)
0.4 (20)
0.6 (74)
1.6 (5)
0.7 (10)
1.8 (25)
1.2 (14)
1.5 (54)
35 (4)
20 (15)
15 (22)
40 (6)
25 (47)
0.2 (5)
1.2 (10)
3.0 (25)
2.2 (11)
1.5 (51)
1.6 (5)
0.4 (16)
1.1 (25)
0.7 (12)
0.7 (58)
0.4 (30)
29
-------
-------
693
V. THEORETICAL CONSIDERATIONS
A. Dosimetry
The distributions and interactions of the ab-
sorbed energy from alpha-emitting plutonium
particles among the cellular elements in lung
tissue are difficult to examine experimentally
and, therefore, have to be considered on a theo-
retical basis. This requires integrating our
knowledge of the properties of alpha radiation
with our understanding of the dynamic charac-
teristics of lung, the cell types which populate
lung tissue and the interactions which occur
between cellular constituents and plutonium
particles.
1. Alpha Particle Irradiation of Cells and Tis-
sues
The two plutonium isotopes of primary con-
cern are 238Pu and 239Pu which emit alpha par-
ticles of average energy 5.5 MeV and 5.15
MeV, respectively. In passing through a me-
dium such as tissue or air, alpha particles lose
energy by collisions with electrons of atoms,
producing charged atoms and free electrons or
delta rays. The delta rays cause further ioniza-
tion events. Alpha particles from plutonium
have a range of about 40 ^m in soft tissue of
unit density. The energy of the alpha particle
drops to zero at the end of its range. The aver-
age loss of energy per unit of path (Linear
Energy Transfer, LET) is about 140 keV/Vm.
However, the loss of energy per unit of path
length and the number of ionizing events it
produces actually increase along the path of
the alpha particle as the energy of the particle
approaches zero (the Bragg effect). Ninety
percent of the ionization events occur within a
cylindrical volume of about 0.01 /j.m radius
around the alpha particle track; most of the
remaining 10% occur out to about 0.2 /j.m.
This pattern of energy dissipation differs
greatly from that of electrons (beta radiation
or secondary to x and gamma radiation) which
are characterized by values of LET that are
two or three orders of magnitude smaller. Con-
sequently equal absorbed doses of alpha and
electron radiation, although by definition are
depositions of equal energy per unit mass of ir-
radiated material, produce drastically different
energy distributions at the microscopic level
which can be numerically expressed in terms
of the quantities of microdosimetry.
The specific energy, z, is the energy im-
parted to the matter in a specified volume di-
vided by its mass. The average or expectation
value of specific energy, z, is equal to the ab-
sorbed dose but z may fluctuate greatly around
this value (ICRU Report 19, 1971). If a region
in tissue is traversed by a particle, the result-
ing increment of z depends on the LET of the
particle and on the length of track within the
sphere but a mean always can be specified for
a given set of conditions. Thus, for the alpha
particles under consideration, and 2.5 /on diame-
ter nuclei (within essentially spherical "cells"),
the mean z deposited in such a nucleus is about
500 rads and this value is independent of the
absorbed dose, z. At absorbed doses that are
much less than 500 rads most nuclei experience
no traversals; the number of nuclei that are
traversed is proportional to the absorbed dose
and the mean value of z in these nuclei is inde-
pendent of dose. When absorbed doses are com-
parable to 500 rads, the probability for multiple
traversals becomes appreciable and higher aver-
age values of z in traversed cells result (Rossi,
1967).
The same considerations apply to electrons
but the numerical values are quite different.
Thus, an electron having an LET of 0.3
keV/^m will in traversing the 2.5^m diameter
volume impart an average increment of z that
is about 1 rad. Hence, at an absorbed dose, z,
of 50 rads where one in 10 nuclei is traversed
by an alpha particle delivering an average z
(dose to the nucleus) of 500 rads, electrons will
traverse almost all nuclei and z will differ little
from 50 rads.
31
-------
694
2. Biological Factors in Alpha Radiation Do-
simetry
In Part III of this report it was pointed out
that all inhaled particles, including plutonium
and aggregates of plutonium, are subjected to
numerous physical and biological forces which
tend to remove the particle from the respira-
tory tract. Therefore, plutonium does not re-
main static in lung tissue unless the plutonium
becomes immobilized in scar tissue, bound to
biochemical moieties, or otherwise trapped.
However, as evidenced by the relatively long re-
tention time of plutonium in lung, much of the
plutonium deposited is made inaccessible for
ready clearance by some mechanism such as
immobilization or recycling through genera-
tions of the several types of cells capable of
phagocytizing particles. All of this contributes
to the complexity of the spatial and temporal
distribution of the absorbed radiation dose
from plutonium in lung.
Lung tissue surrounding particles will be ir-
radiated at relatively constant rates, assuming
the particles are fixed intracellularly. extracel-
lularly or trapped in alveoli blocked by cellular
products or debris. The amount of radionuclide
and solubility of the particles will influence the
biological damage to the cells. However, rela-
tively soluble plutonium may be chemically
bound in cellular material and be retained in
lung for a long time, e.g., studies with inhaled
Pu(NO.,)4 (Ballou and Park, 1972).
The degree of isolation of particles by cellu-
lar debris, fibrosis, and similar changes conse-
quent to biological damage caused by irradiation
or physical and chemical irritation of the sur-
rounding tissue is an important consideration.
Because alpha emissions from 238Pu and 239Pu
have a range of approximately 40 ju.ni in unit
density tissue, the degree of this walling-off ef-
fect will be a major factor in dosimetric con-
siderations. Complete "walling-off" of the par-
ticle might reduce the risk from the alpha
emissions to lung epithelial cells greater than
40 ,um from the particle boundary, but the risk
from the delta rays, X, and gamma radiation
accompanying the 238Pu and 23
-------
A minor factor in dosimetric considerations
of radioactive particles in the lung is move-
ment during the respiratory cycle of tissue rel-
ative to a deposited radioactive particle. For
the most part, tissue movement would be such
as to increase or decrease the radius of the ex-
posure field concentric with the particle. While
the volume would change somewhat during
these movements, the mean volume would
apply for dosimetry calculations as they re-
late to possible biologic effects. During a respi-
ratory excursion, particles will tend to move
with the tissue in which they are contained.
The same cells will be at risk, regardless of the
variability of the volume of the tissue sphere.
These biological considerations emphasize
the importance of the dynamic characteristics
of lung tissue and of particles deposited in
this tissue. Although the kinetics of the inter-
actions of plutonium particles and their alpha
emissions with cells in lung are not known,
they are certainly more complicated than a
fixed source of plutonium particles irradiating
a static population of cells within a 40-50 /*m
range.
3. Models for Dosimetry and Tumor Probabil-
ity
There have been a number of attempts to
understand the spatial distribution of energy
from alpha emitters deposited in lung by devel-
opment of models using computer technology
applied to various representations of lung ar-
chitecture. From the preceding discussion it
will be obvious that all of these models are de-
ficient in respect to biological considerations.
Scientists at Los Alamos (Richmond and
Voelz, 1973) developed a model to determine the
number of cells which receive given radiation
doses as a function of distance from plutonium
microspheres. A first objective of this model
was the identification of the effect of lung struc-
ture on radial distribution ("radial interaction"
function) of encounters between alpha tracks
and cells for calculation of dose. Photomicro-
graphs of thin sections of hamster lungs were
scanned by a high resolution densitometer, and
the digitized images were stored on magnetic
tape. Numerical evaluation of the radial inter-
action function was accomplished by a Monte
Carlo technique operating on the digitized im-
ages. Mean intercept lengths of alpha tracks in
air and tissue were varied by digital manipula-
695
tion of the images to determine the effects of such
parameters as lung density, alveolar size, and
wall thickness. These investigators found that
lung density could be eliminated as a parame-
ter by appropriate normalization (e.g., ex-
pressing "distance" as mass per unit area) but
that the scale factor of lung structure (ratio of
characteristic dimensions to the range of al-
phas in tissue) had a profound effect on the
radial distribution of energy deposition.
Dean and Langham (1969) developed a theo-
retical approach to estimating tumorigenic risk
from exposure of skin and lung to high specific-
activity particles of 235U, 238Pu, and 239Pu.
The radiation dose from discrete sources was
treated in such a manner that an estimate of
the individual cellular response can be made.
Dose averaging was not used in the model.
Particle movement within the lung was taken
into consideration (500-day half-time) and
lung density of 0.26 g/cm3 was assumed. The
tumor probability versus dose-response curves,
which are the basic ingredients of the model,
were taken from the rat skin tumor data (Al-
bert et nl., 1967a, 1967b, 1967c). Dean and
Langham (1969) point out that the rat is sen-
sitive to skin tumor development and that sen-
sitivity may be different for the human lung.
In their model, calculations of the lung tumor
probability per particle as a function of parti-
cle size show peak responses at about 10~l for a
1 /j.m diameter 238Pu particle and about 10"1 for
a 5 ,um diameter 239Pu particle.
At the 1 fi.m diameter size, the tumor proba-
bility for 239Pu is three orders of magnitude
lower (10~4) as compared with 238Pu (1Q-1).
Dean and Langham (1969) compared the lung
dose from 0.016 MCi of 239Pu for 720 days fol-
lowing an acute exposure using the dose aver-
aging technique (3.2 rad) and their model
(1.6 X 10s rad absorbed by 3 X 105 cells). This
model, like others, makes no allowance for cell
repair, turnover and replacement; it does pro-
vide for "wasted radiation" and assumes that
the Albert data for rat skin (Albert et al.,
1961; Albert, 1962; Albert et al., 1967a, 1967b,
1967c) can be applied to lung.
Geesaman (1968) proposed a cubical lattice
model to represent clusters of alveoli with elas-
tic walls of uniform thickness. The geometrical
representation was a honeycomb-like structure
comprised of truncated spheres (the alveoli)
wrapped around a duct (the bronchioles). The
volume of "tissue" irradiated by a 1 ^m 238Pu02
33
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696
particle embedded in the lattice was calculated
by considering the angular dependence of the
geometrical range of alpha emission in the cu-
bical lattice. Alpha radiation emitted along the
lattice axes, in the lattice, and in a sphere
about the particle would penetrate about 100
alveoli, according to this model, and irradiate
about 10"' endothelial and epithelial cells. Using
published values for turnover times of lung
cells and observation of the response of lung
cells to a high dose of x-rays, of cultured kid-
ney cells to alpha particle radiation, and of cell
cytoplasm to protons, Geesaman estimated
that, unless the 238Pu02 particle is less than
about 0.25 ^m diameter, the yearly alpha flux
will be lethal for all epithelial cells in the ex-
posed volume of tissue. The equivalent "criti-
cal" size for a 230Pu02 particle was 1.75 /j.m.
The calculations are for a static source. A
moving source will expose a larger volume of
tissue, but, according to Geesaman (1968), if
the distance traversed is only to an adjacent
ciliated bronchiole, the irradiated volume
would probably not increase by an order of
magnitude. However, one can calculate the dis-
tance from an alveolus to the ciliated epithe-
lium to be about 8000 Fm (Weibel, 1963) or
about 45 times larger than the 180 (u.m range
of a 5.1 MeV alpha particle in lung tissue of
density 0.22 g/cm3. Therefore, the irradiated
volume would increase by several orders of
magnitude, but the duration of exposure would
be drastically shortened as the particle would
be removed from the lung after reaching the
ciliated epithelium. On the basis of his model,
Geesaman concluded that the carcinogenic risk
does not scale with the total energy from a
plutonium particle.
Using Davies' (1961) model of the alveolar
region of the lung, Coleman and Perez (1969)
developed a cylindrical model of the nonciliated
region of the lung comprised of the respiratory
bronchi, alveolar ducts, atria, alveolar sac, and
the alveoli. The structure of the lung was as-
sumed to consist of parallel, cylindrical air
ducts arranged in such a way that the mini-
mum distances between any adjacent ducts are
equal and with maximum ratio of air volume
to total volume. The space between air ducts is
the tissue volume. This model was deemed ade-
quate for calculation of "smeared" doses but
was refined for "local" dose considerations to
include "cellular" structures lining the alveoli
and a coordinate system. Dose rates in rads
per second were calculated for tissue surround-
ing a static particle from point sources of 238Pu
and from volume sources.
Plutonium particles do not reside for long
periods of time in the tracheobronchial region
of the lung. However, the possibility for expo-
sure of these tissues occurs during inhalation
of plutonium and during transport of particles
cleared from the lung on the ciliated epithe-
lium. Animal experiments have shown the bron-
chiolar-alveolar region of the lung rather than
the bronchial epithelium to be the primary site
of particle retention and the major site of
damage induced by inhaled plutonium. How-
ever, in addition to tumors of bronchiolar-al-
veolar origin, a few epidermoid carcinomas
were incidental findings at necropsy in beagle
dogs at long times after the inhalation expo-
sures (Howard, 1970). To compare the relative
radiation doses to the bronchiolar, bronchial
and tracheal epithelium from inhaled pluto-
nium, Harley and Pasternack (in press) derived
dose curves for 0.06 ^m and 2 ju.m 239Pu02 parti-
cles from which the dose in rads per minute at
any depth in the epithelium of the trachea and
terminal bronchioles could be computed. The
difference in the dose rates for the largest air-
way (trachea) and the smallest airway (termi-
nal bronchioles) was small and, therefore, dose
rates for intermediate airways were inferred
to be about the same. For continuous exposure
to the ICRP maximum permissible concentra-
tion of 10-11 /iCi/cm3 air, the maximum annual
dose from 0.06 /i.m diameter 239Pu02 particles
is 0.014 rad at a depth of 22 /on in the epithe-
lium of terminal and subsegmental bronchioles.
The maximum annual dose from 2 /im particles
was similarly calculated to be 1.2 X 106 rad,
delivered to the segmental bronchioles.
Recently Mayneord and Clarke (1974) com-
pleted a mathematical study of the carcino-
genic risks associated with radioactive parti-
cles using a nonlinear peaked cellular
dose-response function, a power law response.
Assuming that all cells of a tissue are equally
at risk, it was concluded that beta radiation
from a point source of MlRb or :)r>S is more
hazardous at low source strengths than the
same activity uniformly distributed; however,
the opposite is true at high source strengths.
The mean dose at which the transition occurs
increases with the beta energy emitted by the
particles and with increasing organ mass and
34
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697
power law cellular response. However, if the
tumorigenic response is a linear function of
dose, the uniform tissue irradiation rather
than the point source gives the greatest expec-
tation. Under the most pessimistic conditions
of numbers of hot particles of both high and
low beta energy, the authors conclude that the
carcinogenic risk is not more than about a fac-
tor of 10 greater than predicted by a linear hy-
pothesis. With alpha radiation the expectation
of events which might lead to cancer from a
point source is greater than that from uniform
irradiation of the same amount of energy for
point source strengths up to that at which cell
killing predominates. However, because of the
small number of particles emitted the authors
question the application of this macroscopic
method and suggest that the stochastic meth-
ods of microdosimetry might be a better ap-
proach. The authors conclude, that in the light
of present knowledge of cellular response, spa-
tial distribution of cells at risk and localization
of particles within tissue, the use of mean
organ doses and the assumption of a linear re-
lationship between dose and effect is a reasona-
ble guide to estimating the carcinogenic risks
from radioactive particles.
These dosimetric models can be useful in un-
derstanding how a given biological effect such
as cancer occurs following deposition of plu-
tonium in lung and might even lead to identifi-
cation of possible mechanisms for cancer in-
duction. However, because these models are
deficient with respect to the biological aspects
of plutonium in Jung (in most cases for the
simple reason that the biology is not ade-
quately known), the models are not dependable
for predicting the health consequences of plu-
tonium. In fact these models can be used to
yield almost any answer desired.
B. Radiation Carcinogenesis Relative to Spa-
tial Distribution of Dose
The calculated radiation doses around hot
particles are an unreliable base for the calcula-
tion of biological effects because of the lack of
adequate biological models for carcinogenesis.
Experimental data, meager as it is in some in-
stances, is more valuable than models based
upon calculated radiation doses, which in
themselves may be very uncertain, and upon
inferences from other organ systems that may
have no relevance to the organ system in ques-
tion. This latter point is particularly true for
the use of dose-effect models derived from rat
skin data as the basic input for models of
human lung carcinogenesis arising from radia-
tion.
The importance of understanding wasted ra-
diation before trying to solve the "hot parti-
cle" problem cannot be overemphasized.
Because of the pattern of alpha energy depo-
sition in a tissue volume around a given plu-
tonium particle, the nearest cells are virtually
all killed while those more distant are either
exposed to very low radiation doses or are not
irradiated. Because of the short range of the
alpha particle, most of the deposited energy is
absorbed within extremely small tissue vol-
umes. Depending on the number of particles
and their dispersion and mobility, much of the
lung may be unaffected.
These observations lead one to a hypothesis
to explain the relative sparing effects on tissue
of alpha particle radiation associated with plu-
tonium particles as compared with a more uni-
form distribution of energy. The following dis-
cussion considers primarily those cells that are
affected in some manner but not killed by the
alpha irradiation (Richmond et ai., 1970). A
large variety of cellular changes can result from
alpha irradiation, yet only a small percentage of
these changes can lead to carcinogenesis. Be-
cause of the many possible alterations, the
chance of the specific change or combination of
changes required to produce an oncogenic re-
sponse is extremely unlikely to occur in any sin-
gle cell. There is a large probability that death
of a cell would precede the occurrence of the
critical random events that would result in an
oncogenic response; however, if one adminis-
ters sublethal radiation doses to a sufficiently
large number of cells, it becomes more proba-
ble that oncogenic changes would occur, de-
pending upon the cell number and the radia-
tion dose. This idea has been mentioned by
numerous authors, including Archer and Lun-
din (1967).
A common hypothesis is that a direct linear
relationship exists between radiation-induced
neoplasms and ionizing events per cell multi-
plied by the number of cells irradiated. How-
ever, for nonuniformly distributed alpha radia-
tion the "wasted radiation" must be
considered. Although the quantification may
not be clear, it is obvious that the amount of
35
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698
tissue irradiated is an important factor in the
production of cancer. Cember (1964a) stated:
". . . , the likelihood of inducing lung cancer seems
to increase as the volume of irradiated lung tissue
increases—that is, as the number of radiation foci
increase and overlap. Furthermore, the experi-
mental results imply that the carcinogenicity of a
given amount of absorbed radiation energy in-
creases, up to a point, as the absorption of energy
is spread out both time- and space-wise. From a
practical point of view this means that, for a given
amount of absorbed energy, low-level, continuous
exposure of the total lung may be more carcino-
genic than the same amount of energy delivered
acutely to a restricted volume of tissue."
Others have postulated models for cancer in-
duction in which a "threshold" volume or mini-
mal mass of tissue must be damaged before the
carcinogenic process of unlimited cellular pro-
liferation overrides the inhibitory mechanisms
regulating growth processes (Rashevsky,
1948). There is evidence that transformed cells
in physical contact with normal unaffected
cells are prevented from dividing (Sivak and
Van Duuren, 1970). Widespread tissue dam-
age, such as could occur with a more uniform
distribution of the same amount of energy,
could release transformed cells from this
growth restraint. As Mayneord (1968) points
out, "Radiation must be much more effective in
killing cells or in interfering with their abil-
ity to multiply than in causing- the alleged spe-
cific malignant transformation of individual
cells or of small foci of cells."
Mechanisms for preventing or mitigating er-
rors in replication which can produce somatic
mutations must exist, because there are proba-
bly on the order of 1012 to 1013 mitoses every
day in the human body (Burnet, 1964). There-
fore, even for those cells damaged by radiation
in such a way as to be transformed there are
processes that prevent the development of a
malignant growth. Each change does not pro-
duce a malignant growth. Thus, a carcinogenic
agent may induce an event in a single cell or a
group of cells which is followed by the develop-
ment of clones of cells which gradually but
rarely free themselves from growth controls
exerted by the entire organism (Mayneord,
1968). In some tissues these controls may re-
sult from the autoimmune response or from
cellular contact inhibition of division (Burrows
and Horning, 1953). It is suggested that nor-
mal cells can act as mitotic inhibitors; thus,
one cell bearing a malignant potential might be
prevented from dividing by the influence of
surrounding normal cells. Uncontrolled mitosis
would be prevented unless the inhibition were
removed in some way.
The free movement of transformed cells in
culture stops when they are in contact with
normal cells, suggesting that the transformed
cells are responsive to inhibitory signals from
normal cells (Stoker, 1964, 1967). Although
transformed cells may be inhibited by contact
with normal cells, they can continue to grow
and move when in contact with other trans-
formed cells. The requirement of cell-to-cell
contact for transfer of materials between cells
is known, and the presence of growth inhibi-
tors in normal cells has been postulated, but
this mechanism is apparently deficient in
transformed cells (Burk, 1966).
Thus, both acute and late effects of the
same quantities of plutonium in the lung might
reasonably be predicted to be less hazardous
when the plutonium is nonuniformly distrib-
uted as compared with a more uniform distri-
bution for the following reasons. For nonuni-
formly distributed plutonium, the volume of
irradiated tissue is much less, much of the ra-
diation dose is wasted, in most cases cells are
either killed or not irradiated, many fewer
cells are irradiated but not killed, and the ratio
of damaged (transformed) cells to normal cells
is much smaller than for uniformly distributed
plutonium. All the above factors are important,
yet the last may prove to be the most impor-
tant, especially for extremely nonuniform dose
distribution patterns.
One can also consider the mechanisms of
carcinogenesis from the standpoint of patho-
logical changes in tissue irradiated both by
uniform and by nonuniform distributions of
energy. The following is a discussion of carci-
nogenic mechanisms that may be applicable to
irradiation of skin and lung (Casarett, 1965,
1973a, 1973b). The mechanisms of most, if not
all, types of cancer appear to be multi-event,
multi-stage processes including cellular initiat-
ing events which confer cancer potential upon
cells and promotional events or conditions
which stimulate or permit proliferation of the
tissue in which the cancer originates (includ-
ing the cancer-potentiated cells) and/or permit
proliferative advantage or autonomy of the
cancer-potentiated cells.
In the development of some cancers, for ex-
ample those of lung or skin, the promotional as
36
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699
well as the cellular initiating events appear to
be closely associated at the sites of origin of
the cancers and to be largely independent of
extraordinary influence of remote factors gen-
erated in other organs. In such cancers, the
promoting events or conditions appear to con-
sist of tissue damage and disorganization (cell
degeneration and necrosis, vascular degenera-
tion, fibrosis, compensatory cellular prolifera-
tion, and metaplasia) the so-called "precancer-
ous lesion."
Radiation in sufficient doses to a large
enough volume can cause both the cellular ini-
tiating events and the promotional events. The
most likely candidates for cellular initiating
events are certain types of mutations or chro-
mosomal aberrations. High frequencies of such
changes can be caused by relatively modest
doses of radiation, and also by other mutagenic
agents. However, increasing the radiation dose
increases the incidence of reproductive sterility
among cells, even in cell types that are rela-
tively resistant to destruction. Such perma-
nently sterilized cells cannot be the source of
cancer. Thus, a maximum in the dose response
curve is to be expected.
On the other hand, the so-called precancer-
ous lesions, if they are to be caused largely by
the radiation and not by other pathologic con-
ditions or aging, require large doses of radia-
tion ; that is, doses capable of inducing the pro-
gressive vascular changes and connective
tissue reactions sufficient to reach a degree and
extent of tissue disorganization that is cancer-
promoting prior to the time when such lesions
might have developed if radiation had not been
involved. Such large doses sterilize many cells
and eventually lead indirectly to non-selective
cell necrosis secondary to the vasculocon-
nective-tissue-circulatory degeneration, with
persistent and abortive attempts by some of
the nearby and less affected cells, even in nor-
mally low-turnover tissues, to proliferate in
compensatory fashion, often atypically. The
probability that damage will overwhelm restora-
tive mechanisms and produce gross local tissue
breakdown increases with the size of the area
exposed, in particular, when the linear scale
exceeds the size of the sensitive structure or
target. This critical size might be determined
by the ability of the local restorative mecha-
nisms to compensate for such injury.
The character of the precancerous lesions in
this type of mechanism is such that they pro-
gress to a particular degree of severity faster
after higher doses than after lower doses, there-
by accounting at least in part for the shorter la-
tent period after the higher doses. If, however,
the promotional condition is supplied by means
other than the radiation dose in question, the
size of the radiation dose required to assure
the development of a particular cancer within
the remaining life expectancy, if that expect-
ancy is long enough to accommodate at least
the minimal latent period, is the size of the
dose required to cause or to complete the cellu-
lar initiating events in sufficient incidence.
For this type of mechanism, if the promo-
tional condition is to be supplied largely by the
radiation exposure, the optimum carcinogenic
dose is likely to be that which provides a net
optimum balance between effective promotional
tissue damage and incidence of reproductively
capable cancer-potentiated or transformed
cells. Larger doses sterilize and/or kill exces-
sive numbers of cells and reduce or even abol-
ish induction effectiveness. The volume of irra-
diated tissue, with respect to numbers of
reproductively capable cancer-potentiated cells
and amount or critical volumes of tissue in-
volved in the promotional precancerous le-
sions, is likely to be an important factor influ-
encing the probability of development of
cancer.
For cancer induced by local exposure of the
tissue of origin there is, in general, an increase
in incidence and reduced latent period with in-
creasing radiation dose within a certain dose
range. With further increase in dose, there
tends to be a decline in the rate of increase in
incidence per unit dose. This decline at high
dose levels is represented first by a plateau in
the dose-incidence curve at peak incidence
level, and then by a fall in the curve at still
higher dose levels. The fall in the incidence
curve at the highest dose levels has been at-
tributed to degrees of tissue destruction, in-
cluding cell reproductive sterilization, that re-
duce or eliminate cancer induction.
Although the germinal cells of the hair
follicles in the dermis are rapidly renewing
cells relatively sensitive to the direct necrotiz-
ing actions of ionizing radiation, the epithelial
cells of the lung are slowly renewing cells rela-
tively resistant to the direct necrotizing ac-
tions of ionizing radiation. Both of these epi-
thelial cell types can be reproductively
37
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700
sterilized by irradiation and both can be de-
pleted indirectly by interference with their mi-
crocirculatory support as a consequence of sub-
stantial progressive vasculoconnective tissue
changes. Such changes increase the histo-
hematic connective tissue diffusion barrier and
reduce effective blood circulation in the proc-
esses of widespread fibrosis.
Radiation-induced lung cancer or skin cancer
apparently is preceded by a considerable de-
gree and extent of local tissue damage, disor-
ganization, and fibrosis, that is, the so-called
precancerous lesion. The experimental induc-
tion of cancer in either of these organs by ir-
radiation of the normal organ apparently re-
quires large radiation doses. That is, there
seems to be a large minimal or "threshold"
dose, but the required doses are reduced if the
promotional local tissue damage and disorgani-
zation is caused by means other than the radia-
tion. As discussed earlier, the dosimetric mod-
els used to predict lung tumor response to
alpha particle radiation (see section V.B) are
based upon dose response data obtained from
experiments using rat skin.
In the experiments by Albert et al. (1961,
1967a, 1967b, 1967c, 1969) and Burns et al.
(1968, 1973a, 1973b) involving induction of
cancer in rat skin by intense electron irradia-
tion, most of the cancers were said to be simi-
lar to hair follicle epithelium, and the promot-
ing condition was apparently the tissue
damage and disorganization in the dermis, in-
cluding the tissue of hair follicles. The field of
irradiation was large, relative to the follicle
size, and in one experiment was 24 cm2. The
fact that there was a relationship between the
incidence of cancer and the number of atro-
phied hair follicles in the large field of dermis
irradiated and damaged at or about the level
of hair follicles, and elsewhere to some extent,
may be related only incidentally, in part or
wholly, to the achievement of the required de-
gree and volume of disorganized dermis. The
required volume may be considerably larger
and qualitatively broader than the volume of a
single hair follicle and the structures contained
within the hair follicle. The geometrical effect
of exposure with sieve patterns observed in Al-
bert's experiments, notably the suppression of
cancer induction at 1700 R but not at 2300 R,
may be a suggestive indication of the impor-
tance of distinguishing between effects on hair
follicles as individual structural units and the
more general effects on volumes of dermis and
its vasculature as promoting conditions.
At present there is no compelling reason to
believe that the critical structure or volume re-
quired for radiation-induced promotion of can-
cer arising from cancer-potentiated cells of
hair follicles is limited to the hair follicle.
There is also no cogent evidence that the lung
has analagous discrete susceptible architectural
units with critical tissue volume as small as
the sphere of alpha particle range from an iso-
lated "hot particle."
Increase in the risk of lung cancer with in-
crease in the number of inhaled particles (for
example, insoluble PuCK particles) retained in
deep lung tissue may not be simply a function
of increasing numbers of retained particles
that are widely separated from one another in
location and tissue effect, but possibly a func-
tion of the frequency with which certain mini-
mal numbers of particles become lodged within
sufficient proximity of one another to cause
relatively confluent tissue disorganization
throughout a promotionally effective tissue
volume that is larger than the sphere of effect
of a single particle (or sub-minimal number of
closely associated particles), and at the same
time, to increase substantially the number of
cancer-potentiated, reproductively capable cells
near and within the volume of disorganized
tissue.
With protracted, nonuniform exposure of
tissue to alpha particles, there is uncertainty
not only as to the tissue component dose rele-
vant to carcinogenesis, but also as to the por-
tion of the total accumulated dose that effec-
tively contributes to the induction of the
cancer. In cases of intense irradiation, some of
the total accumulated close is "wasted" and ir-
relevant, as regards the induction of a cancer.
Some of the dose in excess of the minimal in-
duction dose conceivably may shorten the la-
tent period to some extent by substituting for
other contributing factors that would have oc-
curred eventually but later.
Considering the amount of human data
available for carcinogenic risk estimates, and
the variability and uncertainty concerning
dosimetric factors (e.g., relevant doses, differ-
ences in spatial and temporal dose distribution,
etc.), it has thus far been regarded as neces-
sary to select single values of quantities that
38
-------
characterize the exposure of an organ or that
organ in a group of individuals. Mean accumu-
lated tissue dose is the only criterion that can
be used practically at present until adequate
knowledge of more relevant criteria becomes
available. Furthermore, when the energy is de-
posited nonuniformly and its influence in the
exposed organ or a group of individuals is not
known, the nonuniformity cannot be dealt
with until more adequate data are available.
The linear (proportional) hypothesis is the
only one that normally permits the use of
mean dose as the significant dose factor for
conditions of nonuniform exposure and expo-
sure rate in an organ or among individuals,
for purposes of estimating risk or setting dose
limits in the absence of adequate data on dis-
tribution of dose and dose rates.
It is highly questionable that the ratio of in-
duced cancers to atrophied hair follicles in Al-
bert's experiments with large volume external
irradiation ofi rat skin can be taken as the
basis for the risk of cancer induction from a
radioactive particle in or near a hair follicle in
skin or isolated in deep respiratory tissue. It is
also highly questionable that the existing
standards for uniform radiation exposure of
the whole body or lung can be used as the
basis for establishing particle exposure stand-
ards by simply equating the risk of cancer in-
duction between the two types of exposures,
that is, uniform vs. grossly nonuniform. The
risk for uniform irradiation of man as repre-
sented in the NAS-NRC BEIR report (1972)
is based on the linear hypothesis as applied to
data from uniform low LET irradiation of all
cells in the lung over a dose range associated
with a rising dose-incidence relationship. This
dose range did not involve doses so large as to
greatly reduce the carcinogenic effectiveness by
excessive cell sterilization and killing, but was
capable of contributing to tissue disorganiza-
tion anywhere in the irradiated lung. As indi-
cated earlier, there are many more cells at risk
in the case of uniform distribution of dose
than with nonuniform distribution, for the
same amount of radiation dose. Also, the bulk
of the available evidence suggests that in the
radioactive particle situation the great major-
ity of cells surrounding a single isolated parti-
cle within its sphere of irradiation are likely to
be reproductively sterilized if not destroyed.
701
C. Assessment of Experimental Animal Data
The question of whether the practice of ex-
pressing the radiation exposure to lungs from
inhaled plutonium as an average dose is rea-
sonable can be considered empirically by exam-
ining the results from experimental animal
studies in which the late effects, such as lung
cancer, were observed in several animal spe-
cies.
In reports of the carcinogenic response of
experimental animals to inhaled radionuclides
the authors generally calculated mean radia-
tion doses to the total lung. To avoid hand
drawing the "best" line through the data, a
logarithmic probit curve was selected from
among possible transforms and was fitted to
data from a number of experiments in which
there were several dose groups showing a pro-
gressive increase of cancer incidence or a sin-
gle dose group if the lifespan was not sub-
stantially reduced compared with the controls
(Thomas and Bair, submitted for publication).
Binomial confidence limits were also calculated.
Results from studies of beta-gamma emitting
radionuclides are plotted in Figure V-l. The
heavy line is the curve fitted to the composite
data. The thin lines were fitted to individual
multidose experiments and provide a kind of
experimental error band. No statistical validity
is ascribed to this procedure; however, it is a
useful expedient by which to summarize the
nature and magnitude of the dose effect ca. ve.
A similar treatment of data from experiments
with plutonium is shown in Figure V-2.
The composite curves for the experiments
with beta-gamma emitters and for alpha emit-
ters are redrawn in Figure V—3. At all doses
the incidence of lung cancer was greater for
alpha emitters (plutonium) than for the beta-
gamma emitters; however, the differences be-
tween the two curves were greater with in-
creasing dose. At a mid-point tumor incidence
of 20 percent, the corresponding doses are 300
rads for alpha emitters and 3500 rads for
beta-gamma emitters. Thus, based on calcu-
lated mean lung doses, alpha emitters were
about 10 times more efficient for lung tumor
induction than were beta-gamma emitters. At
10 and 30 percent incidences, the alpha emit-
ters were about 5 and 20 times more efficient,
respectively, than beta-gamma emitters. Since
the RBE for alpha particles ranges from 1 to
20, depending upon the biological system and
39
-------
702
response studied (NCRP, 1971), and is often
given as 10, this greater efficiency of alpha ra-
diation in producing lung cancer in experimen-
tal animals appears reasonable.
Consider now the dose to the lungs of the
animals that inhaled the alpha emitter, pluto-
nium, calculated on the basis of a "critical vol-
ume" of lung tissue, that fraction of lung tissue
actually irradiated by static dispersed or ag-
gregated particles in the lung. It was pointed
out in the discussion of experimental animal
studies that nearly all plutonium compounds
deposited in lung tend to form aggregates and
are never uniformly distributed. Table I gives
the calculated fractions of lung irradiated by
a lung burden of 0.016 /-.Ci 239Pu02 of different
particle diameters. For purposes of this discus-
sion it will be assumed that 0.1 percent of the
lung is irradiated. On this basis the calculated
alpha doses for the experimental animal data
would be increased by a factor of 1000 and the
lung cancer incidence curve is transposed to
the right of the beta-gamma dose effect curve,
Figure V-3. Now it would appear that alpha
radiation from particulate sources in lung is
about 100 times less efficient than beta-gamma
radiation in causing lung cancer in experimen-
tal animals. This factor of 100 would become
10 if one assumed an irradiated lung volume of
1 percent. The curve would still be to the right
of the beta-gamma curve, which is radiobiolog-
ically unrealistic, i.e., it implies an RBE for
alpha particles of less than 1.
One can conclude from these considerations
that the mean dose to lung from plutonium
5 10 '00 1000 10000
CALCULATED CUMULATIVE MEAN BETA GAMMA DOSE TO LUNG RADS
Figure V-l.—Relationship between incidence of lung
cancer and radiation dose to lung from inhaled beta-
gamma emitting radionuclides in experimental ani-
mals.
Pu PENTA -CARBONATE -RATS IBuldakov & .yuflchans
3Vl CITRATE -RATS IBuldakov & Lyubchansky 19701
^PuO?-DOCS (Park 8, Bair 197?)
PuCyMIU (T
38Pu-RAlS (Sa
al 19591
CALCULATED CUMULATIVE MEAN ALPHA DOSE TO LUNG RADS
Figure V—2.—Relationship between incidence of lung
cancer and alpha radiation dose to lung from inhaled
plutonium in experimental animals.
particles is a biologically reasonable basis for
expressing the quantitative relationship be-
tween tumor incidence and alpha radiation
dose. Also, one can conclude that the mean
dose concept represents a conservative ap-
proach to the establishment of permissible lim-
its for plutonium provided the radiation pro-
tection criteria for lung exposure is based on a
limiting rad dose.
It is significant that the dose-effect curves
for beta-gamma emitters and alpha emitters
ALPHA EMITTERS
(BASED ON UNIFORM
ABSORPTION OF
ENERGY)
ALPHA EMITTERS /
(ENERGY ABSORBED IN /
CRITICAL VOLUMES, /
0.1% OF LUNG) /
100 1000 10,000 100.000
CALCULATED CUMULATIVE RADIATION DOSE TO LUNG, RADS
1,000.000
Figure V-3.—Comparative relationships between the in-
cidences of lung cancer and radiation doses from in-
haled beta-gamma and alpha emitters in experimental
animals. The dose to the lung from alpha emitters
was calculated in two ways: assumed absorption of
energy in the total lung mass and assumed absorp-
tion of total energy in only 0.1% of the lung mass.
The radiation energy from beta-gamma emitters was
assumed to be absorbed throughout the total lung
mass.
40
-------
703
are "parallel." Regardless of the nonuniform
distribution of the alpha dose the mean rad
dose ratios between beta-gamma and alpha
emitters for comparable tumor incidences range
between only about 5 and 20, and no assump-
tions regarding the carcinogenicity of individ-
ual particles are needed or implied. Thus, a
comparison of relatively uniform beta-gamma
irradiation with nonuniform alpha irradiation
can be derived solely from toxicity data. The
appropriate models needed to describe the com-
plete sequence of events leading to cancer are
of secondary importance to a valid determina-
tion of the relative toxicity of the two radia-
tions—the most fundamental criteria in any
hazard assessment.
According to Geesaman (1968), tissue dam-
age rather than radiation is the proximate
cause of cancer. Tamplin and Cochran (1974)
suggest that irradiation of a critical architec-
tural unit of a tissue (e.g., a hair follicle) at a
sufficiently high dose rate is a requirement for
cancer induction. The results of experimental
animal studies which bear upon these two
views are from studies of low LET radiation
in which the entire lung and, therefore, all
the "critical architectural units," regardless of
the number, are irradiated, and from studies in
which a specific target tissue is irradiated.
Figure V-4 shows that lung tumor incidence
increases with dose for rats given bronchial
implants containing 32P or 10GRu. Tumor inci-
dence is virtually zero at 103 rad and about 60%
at 10° rad. The radiation dose was calculated
for a specific target tissue, that is, the basal
layer of the bronchial epithelium. Because of
the size of the implanted pellet it is likely that
many of these target cells were irradiated.
Data in Figure V-4 for five species of ani-
mals given 60Co wire implanted in their lungs
show lung tumor incidences ranging from
about 8 to 40%, in all but one instance, for
total doses of 105-10« rad to either the entire
lung or to the esophagus. It is of interest that
the entire lung is irradiated, including any and
all possible "critical architectural units," at
high dose rates, yet the tumor incidence is not
unity. Also of interest is the similar response
shown for the several species used with the
possible exception of the rat lung, the highest
cancer incidence point. The observation of
tumor incidences well below unity is true also
for the whole-body exposures to X-irradiation
in which the entire lungs and body of rats re-
ceived doses near 103 rad. Although these were
acute exposures, the entire lung was irra-
diated.
The high doses from the implanted sources
and the process of implanting the sources as
well caused severe localized reactions. How-
ever, such lesions do not appear to be a re-
quirement for cancer induction, because the
whole-body exposures from external sources do
not involve severe necrosis although pneumoni-
tis and fibrosis can result at high exposure lev-
els.
These data from experimental animal stud-
ies involving low LET radiations lead one to
conclude that there probably is not a critical
structure in the lung analagous to the hair fol-
licle in the skin of a specific strain of rat
which, if irradiated at a dose of 103 rad, will
produce lung tumors in high yields.
10' 10s \06 10'
CALCULATED DOSE TO LUNG (RADS)
Figure V-4.—Fractional Incidence of Lung Cancer in
Animals Exposed to Low LET (/8,X,y) Radiation
O '"Co implant. Rats, mice, hamsters, rabbits, guinea
pigs (Warren and Gates, 1968).
A ""'Ru implant. Rats (Laskin et at., 1963).
n JP implant. Rats (Laskin et al., 1964).
9 X-ray. Rats (Koletsky and Gustafson, 1955).
T X-ray. Rats (Castanera et al., 1968).
41
-------
-------
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Sanders, C. L. and Adee, R. R., (1968), "Phagocyto-
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47
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711
(Note: Following is further questioning of the AEG conducted at
the end of the hearing.) Dr. Mills: We appreciate the members of the
biomedical group sticking around. We will try not to hold you much
longer.
Probably the best thing to do will be to have Dr. Richmond and
Dr. Bair, if they would, to come up; and Dr. Burr, if he is still
around.
I would suggest that we try to confine this within the next
half hour.
Before we start, I assume, Dr. Bair, you have cancelled your
plane?
Dr. Bair: It just left.
Dr. Mills: We appreciate that. Ed, you seem to have most of the
questions that you would like to address, so why don't you begin?
Dr. Radford: Are there other questions that you had in mind?
Dr. Garner: I have just one.
A very short question that I did not get to last time: Do your
results shed any light at all on the einsteinium problem going into
the bone?
Dr. Bair: We have some preliminary results showing chat ein-
steinium which has a 20.5 day half-life is less effective in causing
lung cancer in rats and more effective in causing bone cancer than
PU-239.
This is an interesting preliminary finding in an attempt to study
possible dose rate effects of alpha irradiation. I believe these parti-
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712
cular bone tumor data are contrary to what would be expected on the
basis of current concepts of protracted radiation exposures.
Dr. Radford: I apologize, gentlemen, and I do appreciate your
willingness to stay with us. I regret that we did not have time to
complete the discussion.
It seems to me that the principal value of this questioning at
this stage, from my standpoint, is to determine, is there a hot
particle problem or isn't there, because, to be honest, I was not very
convinced by the presentation comparing skin and alveolar cell radiation
that was already presented.
I would like to address a few questions — I think maybe we can
shorten this down in view of the circumstances.
Bill, would you want to comment on your feeling as to whether the
particles that you show in your photomicrograph as being deposited in
the lung are likely to produce cancer, and if so, what kinds of
cancer?
Dr. Bair: The photomicrographs that I have shown did not include
areas of cancerous tissue. Therefore particles present in these
sections, as indicated by the autoradiograph, cannot be directly re-
lated to cancer induction. Similar particles certainly have been
associated with cancer in some of our experimental animals.
Dr. Radford: When the cancers are produced by these transuranics,
where do they arise?
Dr. Bair: In our plutonium experiments, and also in the
-------
713
experiments being conducted at Fontenay aux Roses, France, with plu-
tonium and other transuranics nearly all of the cancers originate in
the lung periphery.
Dr. Radford: What is the cell type, do you know?
Dr. Bair: The tumors are practically all bronchiola-alveolar and
squamous cell carcinomas.
Dr. Radford: But they arise from a cell type associated with
terminal bronchioles?
Dr. Bair: I am not sure what cell types they originate from but
they certainly originate in the alveolar and bronchiolar areas.
Dr. Radford: Which is it, alvelolar or bronchiolar?
Dr. Bair: I do not know, except that the tumors appear to
originate in the alveolar and bronchiolar areas of the lung.
Dr. Radford: I see. I know this has been a continuing battle
for the experimental lung cancer. Would you agree, either you or any
other member of the panel, that in man, the bulk of the cancers do not
arise from whatever environmental causes may be related to them — They
do not appear to arise very often in this terminal bronchiolar or
alveolar region?
Dr. Bair: That is my understanding.
Dr. Marks is here from the Atomic Energy Commission. He is a
pathologist quite more qualified to comment on this than I am.
Dr. Marks: I am a former pathologist, but I have been with the
AEC for a few years now. I was part of the team that worked on the
early experimental pulmonary exposures at Hanford.
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714
At that time, the doses that were involved were quite large. There
was metaplasia and also bronchiolar proliferation that went into the
alveoli in the animals.
Even though we were dealing with bronchiolar origins for the
carcinomas, they were sometimes associated with these very heavy tissue
changes that took place in the alveolar part of the lung.
Dr. Radford: The question is about human cancers.
Dr. Marks: In human cancers, the bulk of the tumors are actually
epidermoid carcinomas, with the exception of the uranium miners who
have shown a number of anaplastic carcinomas.
Dr. Radford: The point of origin, was it more proximal
bronchial?
Dr. Marks: Yes. Very definitely. The customary site of origin
of the carcinomas in the human is in the proximal bronchi.
Dr. Radford: Again, for whoever wants to answer this: The
relevant information that one would need, if you were going to estimate
the risk from an inhaled particle for man, would probably therefore
be the dose delivered to those bronchial cells?
Dr. Marks: I would agree with that.
Dr. Radford: Would you agree, Bill?
Dr. Bair: I am not sure. What you are actually saying, I think,
is that we should not expect plutonium to produce cancer in man of the
same type seen in experimental animals. I assume that plutonium would
be deposited in the lung of man in the same way as in the experimental
animals — that is the plutonium would accumulate in the peripheral
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715
areas of the lung. That is where the radiation dose would be
delivered and, as in experimental animals, that is where I would
expect tumors to originate.
I think you are telling me that because cancer seldom originates
in the lung periphery of man plutonium may not cause cancer in man. I
would not expect plutonium to induce cancer readily in the relatively
unirradiated areas of the lung such as the bronchi where plutonium has
not accumulated.
Dr. Radford: I am not telling you anything. I am asking you, do
you think the relevant dose that has to be applied, if you are talking
about dosimetry around the hot particle, the dose that is pertinent to
cancer production will be the dose delivered to those bronchial tissues,
not to peripheral tissues where it might have to be.
Dr. Bair: I do not think I can answer the question. I believe
radiation generally induces cancer in areas of the irradiated
tissue.
Dr. Radford: Let me put it in a slightly different tactic. You
showed a number of slides today, but I noticed you did not slide
Figure 36, from page 11 on the WASH 1320 report.
I do not know if you have it in front of you. It's this one,
showing the plutonic particles on the radiographic lung section from
dogs after several months of inhalation of plutonium 239 oxide, show-
ing a pair of bronchial accumulation of plutonium particles.
Now right above that, Figure 35, which shows it out in the
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716
periphery — I think you did show that slide. The point I am making
is, if I look at this, some of these particles are parabronchial, but
some look like they are in the bronchi.
Dr. Bair: The autoradiograph shows peribronchiolar accumulation
of plutonium particles, not peribronchial. These are accumulations of
particles near the alveolar regions.
Dr. Radford: That is a pretty big bronchus, if it's 50 times.
Dr. Bair: I accept the word of our pathologists.
Dr. Radford: The point is, one of the questions has been whether
particles can migrate from the mucusiliar screen into the bronchus,
ephithelium; or conversely, whether they can migrate from the sub-
bronchioli arid lymphatics into the bronchial epithelium.
There has been some recent evidence that has shown that the first
mechanism does not occur, at least for hematype particles. A rather
significant amount can become embedded, especially, say, in regions of
the bronchi, where they would not necessarily meet with cleansing
mechanisms.
Are you familiar with this concept?
Dr. Bair: Vaguely, yes.
Dr. Radford: The question, then, that would come up, if one is
talking about cancer, is from any inhaled material, what is the dose
to the sensitive tissue? That is what we say in the case of bone, in
the case of thyroid, in the case of lung.
So we are basically concerned here with a dose to the bronchial
epithelial, right?
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717
Dr. Bair: If there is only one sensitive tissue, I am not sure
that is necessarily the case. Certainly, in the animal experiments,
the sensitive tissue is not — Let me put it this way, the tumors arise
in the areas where the dose is delivered.
We do not see bronchiogenic carcinomas very often in experimental
animals. This really does not tell us anything about relative sensitiv-
ity of the two tissues.
I would be surprised if plutonium caused a lung tumor in man
which was not the same kind of tumor originating in the same area of
the lung as in these animals.
Dr. Radford: Except in the case of radium, anaplastic types of
tumors arising in animals are not the same type of tumors produced by
radionuclides in man, to the extent that we have any human experience
in this. You do not get the peripheral types of tumors with radon
daughters.
Dr. Bair: The dose is delivered in a different tissue in the case
of radon daughters. In the case of inhaled radon, they are delivered
to the bronchial epithelial.
Dr. Radford: Let me try a different tack.
The French data that you cited has shown squamous carcinoma and
alveolar-bronchiolar carcinoma. Do you recall the proportions?
Dr. Bair: About 50 percent each, but they nearly all originate
in the bronchiolar-alveolar regions.
Dr. Radford: I do not think there is any argument that animal
exposures generally are in the periphery of the lung, where the
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718
tumors occur. This also is true in the case of plutonium exposure to
a large extent.
On the other hand, it has been possible to produce radiogenic
cancers in the large bronchi by putting the material there directly.
So it is a matter then, perhaps, of the physiology of the bronchial
tree being different in the two situations.
Would you agree that is a possibility?
Dr. Bair: That is a possibility.
Dr. Radford: Another possibility, of course, is that the human
being, exposed as he is to viruses and a lot of other things, has a
different bronchial clearance mechanism than the experimental animal
kept under relatively managed conditions.
Would you agree that is a possibility, too?
Dr. Bair: I would agree that is a possibility.
Dr. Radford: That is not getting us very far.
The basic question is really getting to the point you raised: If
plutonium particles do not reach the bronchial epithelial of man, then
they will not be carcinogenic. This is the point I am trying to get
at, precisely this point.
Dr. Bair: That may very well be the case. I am not aware of lung
cancer being attributed to plutonium in any human exposure case so far.
Dr. Radford: This brings me to the next point, which now impinges
on Dr. Richmond's comments. What we need to know is the dose that is
relevant to the tissue that is likely to produce cancer, that is, to
the bronchial epithelium.
-------
719
That was the basis of my statements earlier today, or questions
about how the sampling is done on these autopsy specimens.
I was really trying to make a plea that in the subsequent work,
where these rather valuable opportunities to measure the local tissue
dose, that it not be lost, that indeed a special effort be made to
dissect out the bronchial tree and to measure the local concentration
in the bronchial tree as distinct from the paren.
If we find they are not present there, then this is a further
reduction in the probability of cancer, in my opinion.
Would you agree with that, Ur. Richmond? Or Dr. Marks?
Dr. Richmond: I am not sure I understand what your real question
is, frankly. But let me set the record straight for something I said
earlier today.
You asked a question about whether or not the entire lung was
sampled in the tissue analysis programs. My comment, as I remember,
was that probably larger samples were obtained farther back in time. I
have been told by Herb Parker, who is here and has written an excellent
article on this question recently, that this is not true.
In fact, if you look at five year increments, the amount of
tissues obtained is increasing as time has progressed by five year
increments.
I hope I did not give you the impression that only the lung
periphery is used in the analyses.
Dr. Radford: But no effort is made to specifically dissect out
the bronchi in any of those?
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720
Dr. Marks: That is correct, as far as I know.
In one case, they have tried to separate out the pleura from the
bronchi, but no effort has been made to separate out the bronchi. The
bronchi are included within the lung tissue in the analysis of whole
lungs, which is done quite frequently now; but this, again, is not
what you are seeking.
Dr. Radford: If, for some reason, the concentration in the
bronchi were lower than we expected or if for some reason the con-
centration in the bronchi were higher, you would not be able to detect
it because you have averaged it over the whole lung.
Dr. Marks: We will make this recommendation to the people who
are doing this work. They may have done so in special cases, but, if
so, we are not aware of it.
Dr. Radford: I think you can see the purpose of my comments on
this. If we are going to talk about radiation exposure to sensitive
tissue just as in the case of the hair follicle, we ought to be talking
about sensitive tissue in man.
It seems to be the most sensitive, the bronchial epithelial,
influenced by a lot of other things.
Dr. Bair: I should mention that Dr. Park has done some dissections
on lungs provided by the Transuranium Registry, but I cannot give you
the results.
Dr. Radford: But they are separting out separate tissue?
Dr. Bair: Yes.
-------
721
Dr. Radford: I think that makes the main point.
Dr. Richmond: I think I would be remiss if I did not say some-
thing as a scientist. I do not wish to engage in polemics right now,
but a lot of comments were made previously about work that I had done.
I feel quite disappointed, actually, that Ur. Tamplin did not make
the point that of the two pieces of research that he referred to, one
was specifically done to check the theoretical speculations or model,
whatever you prefer, for the hot particle case. I was rather distressed
that he did not point out that in each case, when the animals were given
2,000 particles, each of which qualified for hot particle, tumors did
not develop, except in several cases, when the theory predicted that
every animal should have produced a tumor. The other evidence related
co cytological changes with earlier experiments which I. did. It is true,
there were cytological changes produced, but the thrust of the paper
was that tumors were not produced.
I find this rather distressing. I think I would be remiss if 1
did not point this out.
I would also like to point out, for the benefit of the committee,
that the people in the United Kingdom have examined the petition and
have commented on it in the radiological protection bulletin of the
National Radiological Protection Board.
I urge you strongly to read it, as another view on this subject.
There is also the report (LA-5810-MS)(Note: This report is located
in Vol. 3 of in these proceedings) which has been sent recently to the
chairman of the panel and to other people, including Mr. Speth, from
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722
NRDC, which was prepared by Healy and others at Los Alamos. It is a
review of the NRDC petition.
The WASH 1320 was not meant to be a specific review of the NRDC
petition, but the Los Alamos document which is now available is meant
to be a review of the NRDC petition.
Dr. Bair: I have one further comment regarding the hot particle
problem. I am beginning to feel that the hot particle issue is becoming
something of a red herring because we are spending so much effort argu-
ing about the uniform and non-uniform distribution of dose that we are
beginning to ignore the real problem, and that is the public health con-
sequence of a given deposition of plutonium. I hope we can get away
from the hot particle issue, and deal directly with the toxicity or
carcinogenic properties of inhaled plutonium.
The sudden attention recently given the hot particle issue is
really misleading, because it was recognized more than 10 years ago
that plutonium is nearly always present in lung as particles or aggre-
gates, even if it is inhaled as a soluble compund.
So we are, in fact, dealing with a hot spot problem, but the
important issue is the relationship between and the amount of plutonium
deposited in the lung rather than whether the plutonium in the lung
qualifies as "hot particles."
Dr. Radford: I would like to add just a couple of notes.
First, with regard to the experiments that Dr. Richmond and his
colleagues carried out, I think it is unfortunate that the test was
made, although it did speak to the issue that has been raised today by
-------
723
Dr. Tamplin, but still I do not think it answers the issue.
I do not know if Dr. Richmond would agree, but the fact that
tumors were not contained when the material was injected intravenously
would not necessarily rule out the possibility, if they happened to be
close to the tissue which might be more radiosensitive, that, by way of
introducing the point again, that if we are concerned about inhaled par-
ticles, we should be concerned about exposure to the sensitive tissues.
At least, in man, it appears to be largely the proximal bronchio
epithelial rapidly dividing cell system, not too dissimilar to skin,
but probably having very different characteristics.
The question, basically, as I see the hot particle problem is if
you have a radiation source which at its circumference is leading to a
few hundred rads per day or even a few hundred rads per year, and then
decreasing off to a lower dose — and I would hope that someone would
present a dose distribution for a variety of particles — I think this
would be a useful exercise, mixed oxide and so on with different alpha
energies — The question is, do you have an extremely high probability
of finding just the right dose applied to cells that are sensitive.
That, to me, is the hot particle issue.
Can a few cells irradiated with just a critical dose lead to a
cancer? Unfortunately, I do not think we have addressed that issue
very thoroughly in this hearing.
Dr. Richmond: Just to comment very briefly, I understand your
concern because of your personal research interest, obviously, but I
may point out you might be interested, if you get a chance some time,
to visit Los Alamos and talk to the pathologist and look at some of
-------
724
their slides because that particular technique does offer you the
opportunity to have exposed a wide distribution of various tissues types
within the lung since the particles are filtered out by capillaries,
and the capillaries occur in all different portions of the lung.
You can see from the radiographs, for example, or the microscopy,
that these particles do indeed lodge near many target tissues in the
lung.
Dr. Burr: I just want to mention, this came up earlier in the
afternoon, whether or not comments were available from Dr. Lushbaugh.
We have a letter written to Mr. Rogers from Dr. Lushbaugh.
I know Dr. Lushbaugh would be pleased to have it introduced into
the record. (Note: see preceding material submitted by the AEG.)
Dr. Mills: There will be a small change in the program.
Mr. Frederick Forscher from the Energy Management will have some time.
-------
FREDERICK FCTRSCHCR
£nf-iau <^{anaqt: incut Consultant 7 9 ^
JJ J 1 Vrf «J
65HU BEACON STREET PITTSBURGH, PA. 1521V
412/S21-O615
Testimony of
Dr. Frederick Forscher
Chairman of Standards Committees
N 46.4 Design Criteria for Fuel Fabrication Facilities
N 46.8 Fireprotection for Fuel Cycle Facilities.
at a public hearing of the
U.S. EPA - Office of Radiation programs
on
Plutonium and the Other Transuranic Elements : Information
Required for Standards Development.
At the EPA Offices , Washington, D.C.
December 10 and 11. 1974.
MEMBER: ASME A1ME ANS ASM AIF iNMM AAAS ANS! ASTM
-------
726
My name is Frederick Forscher, I am a Consulting Engineer, specializing in the
area of energy management, a new profession involving economics, engineering and
ecology. I am testifying today in my capacity as chairman of ANSI's subcommittee
N 46.4 whose subject matter covers criteria and standards for nuclear fuel
fabrication facilities.
Since early in 1972 a working group of this subcommittee has worked on the
development of an A+ priority standard: N287 "Criteria for the Siting, Design
and Operation of Plants for the Manufacture of Mixed Oxide (U-Pu) Fuels,"
The standard has gone through five drafts and a formal balloting. The
committee is now in the process of resolving any and all comments received
from the balloting action and plans to submit the final version of the
standard to the BSR (Board of Standards Review) early next year.
I believe that some of the background, considerations, and conclusions of
the deliberations of our subcommittee should be of interest to this hearing.
In presenting this testimony I'd like to emphasize that this standard has not
yet been approved by the AEC, EPA, nor the BSR of ANSI, and that the manadatory
"shall" provisions in N 287, as in any voluntary consensus type technical
standard, are not to be construed as regulatory conditions. They merely re-
present the considered judgment of well informed and interested members of
the working group made up of representatives of a multitude of societal interests.
The purpose of the standard is defined in Section 1.0 as "These criteria
establish the necessary siting, design, fabrication, testing, and performance
requirements for structures, systems and components important to safety, to
the physical security and accountability of special nuclear materials, and to
the protection of the environment; thus to provide reasonable assurance that a
facility, meeting these criteria, can operate without undue risk to the health
and safety of employee and the public, to the national security, and to the
natural environment."
BACKGROUND
Early in 1972 I became chairman of N 46.4 and established, with the help of
the nuclear insurance pools (NEPIA-Maerp, and NELIA-Maelu), the subcommittee
whose work I am about to report on. At the annual meeting of the ASME in
November 1972 I presented a talk "Toward Criteria and Design Standards for
Large (U-Pu)-Oxide Fuel Fabrication Plants." The introduction to this paper
is quoted here to serve as a still appropriate background to this standard
development effort.
The continued progress of the nuclear industry depends on its performance,
safety record, and public acceptance. We will achieve public acceptance if we
show reliable performance and demonstrate safety in all phases of the industry.
Public concern and regulatory emphasis over the past years has concentrated on
power reactors. Too little attention has been devoted to the remainder of the
fuel cycle, particularly all aspects of plutonium utilization. It is clear
that in the near future public concern and regulatory surveillance is going
to shift toward the other facilities in the fuel cycle, such as reprocessing
plants and fuel fabrication plants, as well as the associated waste disposal.
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727
"It should be noted that reprocessing plants are covered under 10CFR50 and by
practically all other regulations that apply to reactors as well, including
Price-Anderson coverage. On the other hand, fuel fabrication facilities are
not so covered, and their performance, experience, and safety evaluation are
not generally available. The most important of these facilities, from the
public Health and Safety point of view, as well as because of its national
security aspects, is the next generation of plutonium fuel manufacturing
plants (PFMP's). By PFMP is meant a facility with production capability for
power reactor fuel elements at the rate of, at least, 50 metric tons of mixed
oxide per year.
"No such facility exists in this country today, but several are needed by the
late 1970's. True, their number and cost will not approach those of power
reactors. Yet, the absence of PFMP's effectively prevents the utilization of
plutonium for recycle in LWR's, as well as its use in breeder reactors. Without
such fuel fabrication plants, the era of breeders remains sterile.
"Why has so little been done in such an important area? The answer lies in
lack of leadership. The nuclear industry just did not provide the necessary
technical and social/economic leadership that is called for. It is generally
conceded that plutonium hazards are the most serious hazards to the public in
the long run. Plutonium will be the battle-cry of the anti-nuclear forces for
many years.
"Segments of the nuclear industry that are, or should be, concerned with the
PFMP design include the fuel manufacturers, the cognizant regulatory agencies,
also A/E's, Insurance pools, environmental protection agencies and consultants,
and some people in the area of breeder technology. This diversity of interest
has been pre-occupied with more serious problems, causing expensive delays in
the power reactor area. There is also much uncertainty how NEPA will apply to
the PFMP's and what the Environmental Impact Statement should contain. Futher-
more, there is the confusion associated with the license requirements for
material protection, safeguards, and national security, and also with the imple-
mentation of the Non-Proliferation Treaty that opens our domestic PFMP's to
teams of interantional inspectors from the IAEA.
"Perhaps the most significant aspect of the work connected with standards develop-
ment is the need to come to grips with a variety of judgmental factors in
numerical, or at least quantitative, form. Only quantitative and measurable
requirements can avoid interminable procedural disputes, which are the results
of vague language, such as "as low as practicable," or "as reasonably safe,"
or "as technically available and feasible," etc. Standards ought to be clear
enough (and so should be laws and regulations) to allow a competent designer
to use it as his design objective. Not stating these factors explicitly in the
first place, but then challenging the chosen limits in public hearings or in
the courts, just does not make any sense.
DESIGN BASIS ACCIDENTS AND EVENTS
"Every engineering design involves judgmental factors. The lack of public
acceptibility of these factors, and the lack of industry's credibility with the
-------
728
public have been a source of agony. Much could have been avoided had there been
a body of voluntary consensus standards that could replace some or most of these
judgmental factors in design.
"The best known of these factors are in the economic domain, because engineers
are trained to produce a "safe design at lowest cost." But, how safe is safe
enough? What is the numerical value of the safety factor and how is it arrived
at? In addition, the designer must now also consider emission limits and
exposure levels over the total life time of the facility, counter-sabotage
protection, physical security, etc. They must be properly balanced and developed
quantitatively by consensus of experts.
It nay seem to some novice in standards' work that this multitude of requirements
can never be met by general design criteria or standards without referencing a
specific plant design. However, this dilemma arouse before in reactor design,
and it was resolved by the introduction of the concept of a Design Basis Accident.
For the LWRs the design basis accident was considered to be a postulated
Loss of Coolant Accident (LOCA). In the case of the PFMPs the matter is even
more complex. The following definition was adopted:
THE DESIGN BASIS ACCIDENT is a postulated event or sequence of events leading
to a condition for which the confinement system must meet its functional goals.
The confinement system is ~. series oC physical barriers, which together with an
operating ventilation system minimizes the release of radioactive materials
to the environment under normal and abnormal conditions.
The confinement system is further defined. The primary confinement is the barrier
which is or can be directly exposed to plutonium, e.g. sealed process
equipment (pipes, tanks, hoppers, etc.) gloveboxes, caissons, and cells, and
their ventilation systems. Fuel rod cladding, and other sealed containers can
be considered as primary confinement. The secondary confinement is a barrier
enclosing a room or compartment in which the primary confinement is located.
Ventilation zone I is the space within the primary confinement and its associated
ventilation system. Any space, that during the course of normal operations,
may contain plutonium. Ventilation zone II is the space within the secondary
confinement and its associated ventilation system, serving as operating areas
and potentially contaminted areas adjacent to ventilation zone I.
Perhaps the most difficult part of the committee's work was the development
of the seven specific design basis accidents and events, the latest version
of which is attached to this testimony. The postulated accidents and events
consist of the DBA-Fire, the DBA-Explosicn, the DBA-Criticality, the DBA-Power
Failure, the DB-Water, the DB-Natural Phenomana, and the DB-Diversion.
Remember that the number and sequence of these events is not specified, but
that the confinement system (i.e. last barrier) must prevent the escape of
plutonium into the environment under any conceivable combination of these
quantitative postulated design bases.
The DBA's have to be specific enough to allow the designer to proceed, while
at the same time not to restrict his ingenuity and application of uew tech-
-------
729
nology. Two examples are cited to illustrate this point.
The DBA-Fire is that fire which results from the burning of all flammable and
combustible materials within an area enclosed by a fire resistant barrier of
at least a two-hour rating (ASTM E119-71). The rates of combustion for the
flammable and combustible materials shall be as specified by the Fire Protection
Handbook, 13th Edition, NFPA.
The DB-Diversion is a postulated scenario, by which at least two "effective
kilograms of special nuclear materials" (defined in 10CFR70) are removed from
the facility, either at once or within less than a year's time. This scenario(s)
includes also any act of "industrial sabotage" (defined in 10CFR73). The
scenario(s) shall only be disclosed on a "need to know" basis.
ACCIDENT CONDITIONS
The facility has to be designed and operated in such a manner that the probability
of the Design Basis Accident (as defined above) is less than (10) to the -6 percent,
The Appendix to the standard defines four accident conditions of which the
DBA is the most severe.
In the consideration of the risk associated with postulated accidents, the
probability and severity of their occurences and their consequences must be
taken into account. The risk is equal to the product of frequency and consequence.
Design considerations should provide mitigating engineered safety features
and/or redundant plant services to achieve reliability in the intended safety
function. Since it is not practicable to consider all possibilities, the
spectrum of accidents, ranging in severity from the trivial to the very serious,
is divided into four Accident Conditions. Each condition can be characterized
by an occurance rate and a set of consequences.
Condition 1 - Normal Operational Occurances
Accidents of this type do not result in the release of plutonium to areas outside
of the primary confinement. The probability of such events occurring is relatively
higher than other accident conditions considered, and are considered part of
"normal operations." The consequences of accidents of this nature are relatively
minor.
Condition 2 - Small Release of Plutonium from Primary Confinement
Accidents under condition 2 result in the release of small quantities of plutonium
to the secondary confinement, without release to the environment. They are less
frequent and have lower probabilities of occurence then condition 1 accidents.
The consequences of a condition 2 accident would require operational downtime
to make repairs, to replace damaged equipment, and to effect decontamination
within the plant structure.
Condition 3 - Release of Plutonium from Secondary Confinement
Condition 3 accidents result in the release of small amounts of plutonium outside
-------
730
of the secondary confinement. These accidents are less probable than either of
the previous accident conditions and should have a probability of occurrence of
less than (10) to the -2 per year. The consequences shall be limited to dose
commitments no greater than the values shown in Table 1, Appendix B as medium
type accidents. The consequences of condition 3 accidents require considerable
operational downtime of the total processing line, possibly the entire facility.
Condition 3 accidents could result in minor environmental effects beyond the
building.
Condition 4 - Small Release of Plutonium from Confinement System
Condition 4 accidents are equivalent to design basis accidents. Condition 4
accidents may result in releases of plutonium beyond the site boundary, but not
in excess of the maximum accident release limits. A person spending two hours
(or the total time of the accident) at the site boundary shall not incur a
dose commitment of more than 25 rem total body, 150 rem to the bone, or
75 rem to the lung. (Table 1, Appendix B, severe accidents) Condition 4
accidents are much less probable than the foregoing accident conditions and have
a probability of less than (10) to the -6 per year. The consequences of a
condition 4 accident may be an extended shutdown of the whole facility and an
extensive cleanup operation.
More severe accidents, while possible, have a probability of less then
(10) to the -6 per year. They are equivalent to probabilities of accidents
beyond LOCA in LWRs. The consequences would be orders of magnitude smaller
than for a past-LOCA accident.
The values in Table 1 and Table 2 (attached to this testimony) we're
selected to meet the following specific objectives: They must provide
guidance for site selection, design and operation of the facility; project
employees, the public and the environment; are comprehensive, covering the
full range of possible conditions; are generally consistent with other
regulatory criteria (such as 10CFR20, 50 and 100); and are attainable with
present technology.
The dose commitment and end-point criteria are summarized in Table 1. Typical
release limits are shown in Table 2. Considerable judgment has to be exercised
to develop an independent method to connect release limits with end-point
criteria. The meteorological models and atmoshperic dispersion estimates
for a specific site could lead to slightly different release limits. The
release limits shown in Table 2 are based on the consensus judgment of the
committee and are reported for guidance to the designer. Without such release
limits and other quantitative criteria provided by N 287, the designer would
be at a loss for any or all of the limiting conditions on his design.
CONCLUSION
In my opinion, the nuclear industry is grossly underrating the public impact
that the plutonium economy can have on the progress of nuclear power. It
includes such subheadings as: the diversion of special nuclear materials, the
-------
731
advent of the breeder, choice of commercial isotope separation, physical
security in plants and during transport, and the processing, fabrication
and storing of plutonium fuels. The significance of this issue resides in the
fact that plutonium is not an element found in our natural environment and
that the biological effects of microquantities of plutonium are known to be
serious. Consequently we must exclude this material permanently from our
biosphere. The quantity that may seep into the biosphere from the various
plutonium operations must approach zero.
This standard N287, goes beyond the mere concern for the health and safety
of the public; it includes in its objective - as any plutonium standard should -
the long range quality of our environment and the difficult aspects of safe-
guarding plutonium for reason of national security. The fact that three or
more different regulatory and security agencies of the Federal government
are cognizant of the various aspects of plutonium utilization tends to push
industrial reaction into similar compartmentalized thinking. But the
social effects of plutonium are not easily divisible. This standard is a first,
and perhaps too brave, holistic approach.
In the final analysis it will be the public that determines the trade-offs
between what may be called a "healthful" environment, and what may be called
a "reasonable" cost for electric power. This determination is made in an
ongoing adversary, political process. The chances against plutonium dispersion
and diversion must be better than a million-to-one to overcome a public attitude
that would rather freeze in the dark than take a chance on plutonium. To achieve
this goal of an acceptable plutonium economy, promptly and reliably, will take
the best technical, economic and organizational skills this country has to offer.
-------
-6-
732
5.0 PI-SIGN HAS IS
5.1 DesignBasis, Accidents and Events
5.1.1 The PISA-Fire is that fire which results from the burning of all
flammob'le materials v/ithin an area enclosed by a fire resistant barrier of
at least a two-hour rating (ASTM E119-71). The rates of combustion for
the flammable materials shall be as specified by the Fire Protection Handbook
13th Edition, NFI'A.
5.1.2 The PISA-Explosion is the rupture of a primary confinement barrier with
an energy release equivalent to an internal pressure of 105 psig. (This
will result not only in a pressure wave, but may also generate missiles
within the process area.)-
5.1.3 The DBA-Critica1ity is an accidental excursion of heterogeneous
liquid-powder mixture witn a neutron spike yield of 10-exp-18 fissions,
releasing about 30,000 Rtu in less than one second, or an accidental pulsating
excursion with a total fission yield of 10-exp-20 fissions. (This energy
release may disperse unencapsulated plutonium from a typical glove box and may
pressurize the room.)
5.1.4 The DBA-Power Failure is the loss of "total" electric power for 60
seconds, and the loss of "normal" electric power for 48 hours. Total electric
power means all sources of electric energy, delivered, as well as auxilliary
and standby. Normal electric power means the services usually supplied by
a utility company.
5.1.5 The DBA-Water i.3 the result of an Uncontrolled Water Hazard: that is,
water which is intentionally supplied to the plant from a controlled external
source and which, through a mishap within the plant, is released for 30 minutes
in a manner which results in loss of a system, subsystem, structure or
component important to the integrity of the confinement system. This concept
includes both the effect of accidental flooding within the plant and the loss
of fecdwater to any equi]wient which, without adequate water supply, would
prevent the function of the confinement system.
•5.1.6 The PR-Natural Phenomena is the effect of site related conditions,
such as, postulated earthquake, tornados, floods, etc.
5.1.7 The DB-Divcrsion is a postulated scenario, by which at least two
"effective kilogram s of special nuclear materials" (defined in 10CFR 70)
are removed from the facility, either at once or within less than a year's
time. Tliis scenario(s) includes also any act of "industrial sabotage"
(defined in 10CFR 73). The sccnario(s) shall only be disclosed on a "need
to know" lias is.
-------
-2-
733
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-------
734
Table 2
RELEASE LIMITS
Condition
Stack ileiRht, m
Normal Operations
Annual Release 2
Medium Release-Medium
Probability Accidents 3
Maximum Release-Low
Probability Accidents 4
Release Limit, mCi ft i-239 Eguiva 1 cnt\
0.1 km Exclusion
0
0.02
0.2
7.
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2
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700.
Footnotes to Table 2
1 Equivalence based on radio toxi city; for example, SO Ci
-------
735
72-WA/NE-12
$3.00 PER COPY
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Discussion is printed only if the paper is published in an ASME
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Released for general publication upon presentation
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Toward Criteria and Design Standards for
Large (U-Pu)-Oxide Fuel Fabrication Plants
FREDERICK FORSCHER
Consulting Engineer,
Pittsburgh, Pa.
Mem.ASME
By the mid-seventies plutonium will become available in ton quantities from the
reprocessed fuel of our domestic light water reactors (LWRs). The key to the effec-
tive utilization of this fuel is to get sufficient fuel fabrication capacity on stream.
All of the present facilities are only of pilot plant scale. Criteria and design stand-
ards have to be set promptly and safely to avoid the licensing delays and public
reactions that have become a way of life in the reactor business.
Contributed by the Nuclear EiiRiiiccrins DiiWon of The American Society of Mechnni-
cal Engineers for presentation ut the Winter Annual Mcclinp, \ew York, \. Y., No*em-
b«r 26-30, 1972. Manuscript rccc'ncd at ASME Headquarters August 1, 1972.
Copies Hill be available until September 1, 1973.
THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS, UNITED ENGINEERING CENTER, 345 EAST 47ttl STREET, NEW YORK, N.Y. 10017
-------
736
Toward Criteria and Design Standards for
Large (U-Pu)-Oxide Fuel Fabrication Plants
FREDERICK FORSCHER
INTRODUCTION
The continued progress of the nuclear indus-
try depends on its performance, safety record, and
public acceptance. We will achieve public accept-
ance if we show reliable performance and demon-
strate safety in all phases of the industry.
Public attention and regulatory concern over
the past years has concentrated on power reactors.
As more reactors come on line, and their design,
construction, licensing, and operation becomes a
matter of increased standardization, it is clear
that the emphasis of public concern and regulatory
surveillance is going to shift toward the other
facilities in the fuel cycli, such as reprocessing
plants and fuel fabrication plants, as well as the
associated waste disposal.
It should be noted that reprocessing plants
are covered under 10CFR50 and by practically all
other regulations that apply to reactors as well,
Including Price-Anderson coverage. On the other
hand, fuel fabrication facilities are not so cov-
ered, and their performance, experience, and safe-
ty evaluations are not generally available. The
most Important of these facilities, from the public
Health and Safety point of view, as well as be-
cause of its national security aspects, is the
next generation of Plutonium fuel manufacturing
plants (PFMP's). By this is meant a facility with
a production capability for power reactor fuel
elements at the rate of, at least, 50 metric tons
of mixed oxide per year. No such facility exists
In this country today, but several are needed by
the late 1970's. True, their number and cost will
not approach those of power reactors. Yet, the
absence of PFMP's effectively prevents the utili-
zation of plutonium for recycle in IWR's, as well
as its use in breeder reactors. Without such fuel
fabrication plants, the era of breeders remains
sterile.
Why has so little been done in such an im-
portant area? The answer lies in lack of leader-
ship. The nuclear industry Just did not provide
the necessary technical and social/economic lea-
dership that is called for. It is generally con-
ceded that plutonium hazards are the most serious
hazards to the public In the long run. Plutonium
will be the battle-cry of the anti-nuclear forces
for many years.
Segments of the nuclear industry that are,
or should be, concerned with the PFMP design in-
clude the fuel manufacturers, the cognizant di-
rectorates, divisions and offices of the AEC, also
Architect-Engineers, Insurance Pools, environmen-
tal protection agencies and consultants, and some
people in the area of breeder technology. This
diversity of interest has'been pre-occupled with
more serious problems, causing expensive delays in
the power reactor area. There is also much un-
certainty how NEPA will apply to the PFMP's and
what the Environmental Impact Statements would
contain. Furthermore, there is the confusion as-
sociated with the license requirements for materi-
al protection, safeguards, and national security,
and also with the implementation of the Non-Prolif-
eration Treaty chat opens our domestic PFMP's to
teams of international inspectors from the IAEA.
Because of all this diversity of interests
that exist in the industry, it is not surprising
that so little was done toward development of de-
sign standards and criteria. Early in 1972, a
fresh start was made under the "neutral" auspices
of the American National Standards Institute's Nu-
clear Technical Advisory Board. A group of con-
cerned professionals, representing all special in-
terests In this issue, volunteered to focus on the
hard (numerical) and judgmental questions with a
knowledgeable and impartial attitude for the bene-
fit of the industry as a whole, rather than a pa-
rochial self-interest of its component parts.
OBJECTIVES
Perhaps the most significant aspect of the
work connected with standards development is the
need to come to grips with a variety of Judgmental
factors in numerical, or at least quantitative,
foiT.. Only quantitative and measurable standards
can avoid interminable procedural disputes, which
are the results of vague language, such as "as low
1
-------
as practicable," or "as reasonably safe," or "as
technically available and feasible," etc. Stan-
dards ouiht to be clear enough (and so should laws
and regulations) to allow a competent designer to
use It as his design objective. Not stating these
factors explicitly in the first place, but then
challenging the chosen limits in public hearings
or in the courts, Just does not make any sense.
The purpose of this paper is to present some
of the Judgmental and numerical factors to the nu-
clear industry, to the technical community, and to
the public at large. These factors are not yet
final nor are they complete. It is expected that,
if and when they are finalized, they could be
adopted as regulation by the regulatory agency.
They must satisfy che current spirit of participa-
tory technology, and they must meet the statutory
requirements of the Act of 195^ in regard to pub-
lic health and safety, and in regard to national
security. The scope is defined as follows:
There are three primary considerations for
the criteria for the siting, design, consvructlon,
and operation of plants for the manufacture of
mixed oxide (U-Pu) fuels:
1 Protection of the general public and envir-
onment
2 Protection of site personnel
3 Control of nuclear materials
It is planned to folio", as much as possi-
ble, the criteria of 10CPR50 (and Appendices), and
any applicable design standards, safety guides,
specifications or codes, etc. There is no intent
to duplicate any existing standards or any work in
progress. Accordingly, we have drafted the three
Introductory paragraphs (Table 1), following
closely the language of Appendix A, and which para-
graphs further define the scope of our effort.
The first two paragraphs address themselves
to the statutory requirements of the Act of 195^,
while the last paragraph applies to the National
Environmental Protection Act of 1969 (NEPA). It
Is worthwhile to point out, that only the first
paragraph, in connection with the Health and Safe-
ty of the Public, is a citation from Appendix A.
The second paragraph is a paraphrase of the same
Idea, but in connection with the equally important
aspect of National Security. The second require-
ment assumes about equal importance in operating
any PFMP, but appears of lesser significanae in
the case of a power reactor.
These introductory paragraphs seem to be
suitable for ?>ny fuel fabrication facility. In
the case of Pu-fuel, it could equally well apply
to Pu-alloy, mixed carbide, or mixed oxide fuel.
However, in order to be most responsive to present
needs, to take advantage of the widest technical
Table 1 Design Criteria Objectives
These criteria establish the necessary de-
sign, fabrication, construction, testing, and per-
formance requirements for structures, systems, and
components important to safety; i.e., they provide
reasonable assurance that the facility can operate
without undue risk to the health and safety of the
public.
In addition, some criteria establish the
necessary design, fabrication, construction, test-
ing, and performance requirements for structures,
systems, and components important to the physical
security and accountability of special nuclear ma-
terials ; i.e., they provide reasonable assurance
that the facility can operate without undue risk
to the national security.
In addition, some criteria establish the
necessary design, fabrication, construction, test-
Ing, and performance requirements for structures,
systems, and components Important to the protec-
tion of the environment; i.e., they provide rea-
sonable assurance that the facility can operate
without undue risk to the quality of the envir-
onment .
base, and to aim for a reasonably short completion
date of the criteria to be developed, our committee
decided to forego, at present, all considerations
of the hazards associated with metallic or carbide
fuel, and concentrate only on mixed oxide fuel.
This type of fuel represents clearly the largest
volume of Pu-fuel for plutonium-recycle in LWRs,
as well as for the first generation of LFMBRs.
DESIGN BASIS ACCIDEI.T
Every engineering design involves Judgmental
factors. The lack of public acceptability of these
factors, F.nd the lack of industry's credibility
with the public have been a source of agony. Much
could have been avoided had there been a body of
voluntary consensus standards that could replace
some or most of these judgmental factors in de-
sign. The best known of these factors are In the
economic domain, because engineers are trained, to
produce a "safe design at lowest cost." But, how
safe is safe enough? What Is the numerical value
of the safety factor and how is it arrived at?
In addition, the designer must now also consider
emission limits and exposure levels over the total
life time of the facility, counter-sabotage pro-
tection, physical security, etc. They must be
properly balanced and developed quantitatively by
consensus of experts.
-------
738
It may seem to some novice in standards'
work that this multitude of requirements can never
be met by general criteria and design standards
without referencing a specific plant design. How-
ever, this dilemma arose before in reactor design,
and it was resolved by the Introduction of the
concept of D?slgn Basis Accident (DBA). For
LWRs, the Loss of Coolant Accident (LOCA), as de-
fined in Part 50, is the accepted DBA. For trans-
portation of nuclear materials in approved con-
tainers, the DBA consists of a 30-ft drop test,
followed by a specified fire, and finally ended
by water immersion of the test container. In line
with such precedents, and in accordance with the
language to be modeled after 10CPR50, it was clear
that designers need a clearly defined DBA for the
mixed oxide plants. It is equally clear that an
accident so defined will be strictly a design
basis, and most likely will never happen in a real
plant situation. (Table 2: Definitions).
There is general agreement that the protec-
tion of the integrity of the final containment —
the one separating the Inside of the containment
system from the environment at large — must be
the subject of utmost concern. For this reason,
the facility must include structures, systems, and
components which have specific safety functions.
The containment system is defined as that
series of physical barriers which prevents the re-
lease of radioactive materials to the environment
under normal and abnormal conditions. The con-
tainment system must be so designed as to maintain
Its Intended safety function under abnormal condi-
tions, both internal and external to the facility.
This design objective can be reached if the ab-
normal conditions are clearly stated in quantita-
tive terms.
External abnormal conditions may result from
natural phenomena that are site dependent, such as
tornadoes, earthquake, differential settlement,
floods, loss of power, loss of other utilities,
loss of access and communications, etc. External
abnormal conditions could also be man made, such
as riots and insurrection, impact by a falling
airplane, fire or explosion in an auxiliary facil-
ity or nearby building, collision by derailed cars
and engines, leaking chemicals, sewage explosion,
and others.
However, we are primarily concerned here
with the internal abnormal conditions which are
more analogous to the LOCA, and consist of acci-
dental criticallty, fire, explosion, power fail-
ure, and uncontrolled water. The importance of
defining these occurrences numerically and quan-
titatively cannot be overestimated. The numbers
must be defendable, simple, and useful in design.
The DBA Criticallty is a burst of lO1^ fis-
Table 2 Definitions
1 Standard — The stated result of a par-
ticular standardization effort approved by a recog-
nized organisation, and which has been achieved by
general consent, or common use: A standard usual-
ly establishes a definite level, degree, material,
quality and the like, as that which is proper and
adequate for a given purpose.
2 Criterion — A statement of principles,
rules, or regulations which serves as basis for
Judgment, or decisions.
3 Design basis accident — A postulated
event, or sequence of events, leading to an acci-
dent (e.g.: breach of containment system) which
the design aims to prevent.
4 Containment system — A series of physi-
cal barriers which prevent the release of radio-
active materials to the environment under normal
and abnormal conditions.
sions with an energy release of 200 Mev/fis. The
type and quantity of fission products is process
dependent.
The DBA Fire for each process area shall be
that which generates as a minimum 1000 Btu/sq ft/
min., plus that amount i>f heat potential in the
primary containment and all contents therein, for
a period of 30 min., except for processing areas
using significant quantities of flasunable hydro-
carbons (solvent extraction area), where the DBA
Fire generates 10,000 Btu/sq ft/min. for 30 min.
The primary containment is that physical
barrier that is closest to the plutonlum contain-
ing substance. The Process Area Is the space be-
tween the primary containment and the next fire
resistant physical barrier.
The DBA Explosion is a rupture of a primary
containment at an Internal pressure of 105 psi.
Please note that this will result not only in a
pressure wave, but also in missiles within the
process area.
The DBA Power Failure is the loss of total
electric power for more than 60 sec and the loss
of normal electric power for more than 4-8 hr.
Total electric power means all sources of electric
energy, delivered, as well as auxiliary and stand-
by. Normal electric power means the services usu-
ally supplied by a utility company.
The DBA Uncontrolled Water is a break inside
the plant of the main pressurised water supply for
30 min. Please note that uncontrolled may imply
"too much," or "too little" for safe operations.
The Design Basis Accident for the PFMP is
defined as a breach of the containment system.
-------
whether resulting from natural phenomena or the
occurrence of a single event. Including crltlcali-
ty, explosion, fire, power failure, and uncon-
trolled water; or a conssquential combination
thereof. Initiated by a single event internal or
external to the facility.
With the DBA firmly established, one can now
proceed to use the designer's prerogative and in-
genuity in the actual design of the PFMP. Natural-
ly, many other established standards must be fac-
tored into the design. Here I have in mind criti-
cality limits, personnel exposure limits, MFC's
for air and water effluents, shielding data, and
many others.
In this connection, it Is well to point out
that the designers must, of course, consider other
accident conditions besides the DBA defined in the
foregoing. It is suggested to follow the Annex to
Appendix D of 10CFRJO titled, Discussion of Acci-
dents in Applicants Environmental Reports. Several
classes of accidents are defined, each class being
characterized by an occurrence rate, and a seb of
consequences. It is not too difficult to come up
with a similar series of classes of accidents for
the PFMP, ranging from the trivial to the cata-
strophic .
ESTIMATED ECONOMIC EFFECTS
The rational for the proposed DBA was pri-
marily to provide "reasonable assurance that the
facility can operate without undue risk to the
health and safety of the public." However, there
are two other Design Criteria Objectives (Table 1)
which will also "harden" the facility and thus in-
crease the cost. Provisions must be made to satis-
fy the "reasonable assurance" clause, that the
facility can operate without undue risk to: (a)
the national security, and (b) the quality of the
environment.
For the latter category, for example, it is
quite reasonable to expect that no contaminated
liquid waste is allowed to leave the plant through
an effluent. This requirement would call for
evaporators, solidifiers, storage, etc. Leachable
waste could be decontaminated with liquids, and
burnable waste may involve incineration and liquid
processing of the residues. In any event, satis-
fying the environmental quality requirement will
add to the capital cost and operating cost of the
facility.
Regarding the "reasonable assurance" clause
for national security, we should, for example, ex-
pect requirements that include counter-sabotage
provisions and material security devices of quite
sophisticated design, such as the new line of non-
destructive Instruments which can detect, by ac-
tive or passive Interrogation, the quantity, loca-
tion, species and movement of special nuclear
materials. Diversion of Plutonium Is a threat
that cust be taken serious. The scenarios by
which this material might be stolen are only lim-
ited by the imagination of the science fiction
writers. One obvious scenario, however, would be
a false evacuation alarm, i.e., a plant evacuation
initiated by the dlverters. All persons present
inside the plant would scramble for the nearest
exits; some would carry with them significant
quantities of plutonium. An external and con-
trolled access perimeter must be provided for such
or sir.ilar eventualities.
Sabotage can be described In scenarios cov-
ering a whole range of threats. It Is useful to
classify these threats within a spectrum of sever-
ity, ranging from the trivial case of pilfering
(say, plastic containers) to a full blown organized
and mechanized attack of a para-military nature.
Like the range of "classes of accidents" discussed
in the foregoing (Annex to Appendix D of 10CFR50),
we must define the central portion of the spectrum
of threats, against which the design will offer
the "reasonable assurance" against undue risk.
All these examples point In the direction of
"hardened" — which means more costly — facili-
ties.
Let us assume that because of all these con-
siderations, the necessary capital investment
would actually double. What would be its effect
on the fuel cycle cost? One simple way to fet a
ball-park answer to this question is to look at
the various components that make up the total gen-
erating cost. Without reference to a specific
plant, type, size, or year of completion, I pro-
pose to use the following rough figures:
Plant cost --------5.50
Fuel cost -------- 1.60
Operation, maintenance - - 0.40
Total 7.50 mills/kwhr
We know that the design and fabrication of the
fuel ar.ounts to only about 25 percent of the fuel
cost. (Most of it, nearly ?0 percent, is the in-
herent fuel value of enriched uranium and plutoni-
un.) Hence, the fabrication service cost is 0.40
nills/kwhr. Of this value, only about 5 percent
can be charged to facility depreciation; i.e.,
0.02 rdlls/kuhr represents the facility cost. If
the hardening of the PFMP doubles this cost, we
would be paying another 0.02 mjlls/kwhr for the
safety and reliability of our fuel supply.
The same argument, of course, can be made
in terns of dollars per kg of fuel, which is the
preferred marketing method. Manufactured fuel may
-------
r. mi
-
cost $60/kg, plutonlum (recycle) fuel may cost,
perhaps, $100/kg, all exclusive of the Intrinsic
value of the U or Pu In the fuel. If the 5 per-
cent doubles because of the hardening of the fa-
cility, It would cost $105/kg to buy plutonlum
fuel. No doubt, the plant capacity and, more Im-
portantly, its annual throughput will have a major
effect on the unit cost.
We must remember that the foregoing assump-
tion, of doubling the facility cost because of
hardening, Is very conservative and unlikely. A
fuel plant that could normally be built for $12
million, will not likely require a $24 million in-
vestment under these hardened circumstances. But
even with the assumption of doubled facility cost,
we conclude that the effect on the "generating
cost" would be much less than 1 percent (i.e.,
0.02 mills/lcwhr in 7.50 mllls/kwhr). In any cost-
benefit analysis, that would weigh heavily in
favor of hardening the plants, particularly when
plutonlum Is Involved.
ACKNOWLEDGMENT
Parts of this paper are based on delibera-
tions and discussions of ANSI's standards commit-
tee H101-4 (now N46-4) of which the author has the
honor to be chairman. The contribution of the
comnlttee members are appreciated. The charter
for this committee covers all nuclear fuel fabri-
cation facilities. The parent committee N101 (now
N46) is sponsored by the AIChE.
-------
741
Dr. Mills: Thank you.
Are there any comments or questions from the panel?
Dr. Radford?
Dr. Radford: Dr. Forscher, you are an engineer, correct?
Dr. Forscher: Yes.
Dr. Radford: What are the professional backgrounds of the ANSI
standard setting committee? This particular one.
Dr. Forscher: This particular committee was composed of members
who had experience in plutonium work and are currently employed by
organizations such as insurance pools, contractors, AEC (general man-
agers side as well as from the standards group), EPA, health and
safety group.
Dr. Radford: Basically, are they all engineers or are there any
biomedical people on the Committee?
Dr. Forscher: There are no biomedical people on this committee.
This is a group, N 46.4 which is chartered to develop standards for
fuel fabrication facilities, in other words, consideration of design,
operation and quality assurance of these structures.
These are the components, that we must maintain the safety.
Dr. Radford: Have you compared the emission rates that would apply
to these accident conditions, I presume, in Table 2? Would you compare
these with standard emissions that might occur from other facilities or
even fuel fabricating facilities under the current regulations?
Dr. Forscher: Yes, we have. They are tighter, more conservative.
Dr. Radford: They require closer containment of plutonium than do
the current standards?
-------
742
Dr. Forscher: Yes but, as I mentioned in the objective, the
numbers which appear in Tables 1 and 2, are achievable with present
technology by consensus of many people in the AEG, EPA and contractors.
As I also mentioned, these people on the committee do not re-
present these organizations. They represent themselves and use their
best judgment on this problem. We come up with a consensus.
Whether they are employed by EPA or AEG or insurance pools, et
cetera, I do not think they express official views. As I said in the
beginning, this standard has not been accepted by the AEC or EPA.
Ur. Radford: Can you give us a ballpark figure, how much more
restrictive this kind of emission standard would be compared with the
emission standard now permitted?
Dr. Forscher: I cannot really give you a number there because we
have tried to translate, interpret, the MFC's which appear in Part 20
into dose commitment, and this translation of exposure to dose commit-
ment is 50 years by itself.
Dr. Radford: So it is a reduction of about 50? These knowledge-
able people who work for the industry feel that this is attainable
and therefore, it comes under the as low as practicable aegis; that it
is practicable and therefore it should be achieved. Would that be a
fair statement of the committee's feeling?
Dr. Forscher: The committee feels that the standard as presented
is practical. This committee does not speak for industry. Whether
industry feels that it is practical is another thing.
Dr. Mills: Dr. Morgan?
-------
743
Dr. Morgan: Dr. Forscher, I notice that in Condition Four, you
gave the dose limits of 25 rem total, along with 150 rem to the bone,
and 75 to lung. But these figures omitted the levels for the thyroid,
which might receive the highest part of the dose from any type of
accident.
Is that intentional?
Dr. Forscher: It is not intentional, Dr. Morgan.
Dr. Morgan: There might be reason.
Dr. Forscher: In the appendix table, we list dose commitments
to the whole body, skin, bone and thyroids and other critical organs.
Dr. Morgan: I notice in your Table 2, that you use plutonium 239
equivalents, but there is not indication, for example, what the equi-
valence might be of plutonium 238.
Do you happen to know what was used as the equivalent per gram
basis?
Dr. Forscher: No. I do not. You understand, this standard was
written for a specific type facility, a manufacturing facility, manu-
facturing commercially available large scale mixed oxides of plutonium
which makes uranium oxide.
There is very little plutonium 238 in there, so we have not
concerned ourselves with plutonium 238.
Dr. Morgan: There is quite a bit of plutonium 238 in alloys,
though, as well of course as plutonium 241.
Dr. Forscher: Yes, there is a whole range of isotopes. Under-
stand, I do not have it with me. I will send it to you.
-------
744
We have calculations of the equivalents. I am not sure if we
included conventional points to 238.
Dr. Mills: Dr. First?
Dr. First: I would like to just clarify a point of the release
limits. It is my understanding that the ANSI committee's objective is
to develop engineering, construction, maintenance, et cetera, standards
for achieving particular standards, and that it is not the part of the
ANSI committee to establish the standards here, but only the method of
achieving them.
Is this not correct? In other words, these are not standards
which are recommended by the committee that differ in any way from
those that have been published. Is that not correct?
Dr. Forscher: They should not contradict or be different from
any of the others that have been published. We have, in our committee,
attempted to be as quantitative as possible and stay away from general-
ities such as "as much as is practical" and "economically feasible,"
and also to help the designer to overcome this judgmental gap.
This is what the purpose of the ANSI committee is. To provide
the limiting conditions, the criteria, so that the designer, within
these limited conditions, can design facilities which are economical
and at the same time safe. If you do not give him the numbers of the
emission limits to shoot for, he would not know where to begin.
Dr. First: I think we can agree that criteria are needed, but I
think we are talking about several different criteria here. This is
the point I am trying to get to.
-------
745
The objective of the committee is not to establish new criteria
for uptake of radioactive materials. Is that correct?
Dr. Forscher: That is correct.
Dr. First: So you have worked on the criteria which are in
existance, the existing ones. You are not suggesting that these should
be changed in any way. Is that correct?
Dr. Forscher: That is correct, but in order to provide guidance
to the designer on this, we had to start with some assumption of dose
commitment. Working backwards from this dose commitment, including
meteorological models which distribute —
Dr. First: I think we understand this, but the point I am trying
to make is you have accepted the standard which now exists as being the
one to which the ANSI standard is addressed.
You have not considered whether or not this standard, environmental
standard, should be increased or decreased.
Is that correct?
Dr. Forscher: We have interpreted the current standard in terms
of dose commitment, which I do not think is generally interpreted
this way.
Dr. First: You have interpreted it, if I understand you correctly,
in terms of emission standard. Is that correct?
In other words, you have taken the permissible dose to the popula-
tion and you have extrapolated that to some distance from the plant,
through a stack of a certain height. You have then concluded that
based on the standard, you are permitted to emit certain quantities of
-------
746
plutonium for a year.
Is that a correct interpretation?
Dr. Forscher: That is right.
Dr. First: You say this is attainable and your figures show
this. Is a lower standard attainable as a practical matter?
Dr. Forscher: I do not think there is a generally applicable
answer to this question. I can only report that our preparation advised
itself of this for ours.
We came away with a consensus feeling that our emission limit is
about as low as is practicably, attainable, with current technology.
Dr. First: So, from the standpoint of the committee, the present
standard is as low as practicable. Is this a correct interpretation?
Dr. Forscher: Yes.
Dr. First: Thank you.
Dr. Mills: One question having to do with clarifying the status
of the standard as you proposed. Knowing how most of the ANSI com-
mittees work, it is usually one man's effort to actually put the docu-
ment together.
When you say it is up for formal balloting, are you saying that
the members of the subcommittee have not voted on this as yet?
Dr. Forscher: In our committee at least, it is not a one man
effort. It has gone through many internal reviews before we went out
to have the working group comment on it.
Then, after these comments were accommodated in Draft Five, it was
allowed to go for voting by the full committee; N 46 committee is a
-------
747
subcommittee of ANSI. All standards for fuel cycle facilities are
under N 46. This voting is a formal voting which is advertised in the
ANSI Bulletin, which announces all such actions, not only for nuclear
standards.
Consequently, we got considerable comments from societies, industry,
regulatory agencies and so forth. These comments are being resolved.
After they are resolved, the standard with the resolution and the
reason for the resolution is then submitted to the Board of Standards
Review, BSR, for formal approval of the standard.
If they are satisfied with our resolution of the questions that
came in with this formal voting, balloting, then they will agree that
the standard should be issued as another voluntary type standard under
ANSI auspices, based on voluntary, technical consensus.
Dr. Mills: To date, the subcommittee members have not voted or
commented on it?
Dr. Forscher: We are in the process of resolving all the comments
we have. We have formally balloted and got all the comments in, and
we are in the process of resolving all comments which have come in.
We are one week away from finalizing it.
Dr. Mills: Thank you very much, Dr. Forscher.
We will adjourn until 1:30.
(Whereupon, the hearing in the above entitled matter recessed at
12:50, to reconvene at 1:30 that same day.)
-------
-------
749
AFTERNOON SESSION
Dr. Mills: We will get started this afternoon. For the remainder
of the day, we have a very full schedule, so I hope everyone will make
the effort to do what they can to help the schedule along.
We will start out this afternoon with Mr. Lester Rogers, from the
U. S. Atomic Energy Commission speaking on the regulatory aspects of
this problem.
Dr. Radford: Mr. Chairman, before we go on, could 1 ask what the
schedule will be? We have four panelists who wanted to try to get away
by four o'clock, as I recall.
When will they be put on the program?
Dr. Mills: 1 intend to try to get an opportunity to hear them. I
hope they will stick around. 1 realize most have very tight plane
schedules and it will be necessary that they leave some time before
four o'clock.
We have Mr. Rogers; we have the representatives of the Westinghouse
Electric Corporation; we have Dr. Tamplin. And we have Ms. Judith
Johnsrud from the Environmental Coalition on Nuclear Power.
To the extent that we can get these in and questions and comments
on each particular one, then the other panel members left over from the
Biomedical will be around to answer questions.
I would suggest if they cannot remain, that the members of the
panel put together their questions and we will submit these or have them
submitted from the Environmental Protection Agency to the panel members
-------
750
for response.
I realize that this is at the heart of the matter, but we will try
to get out at some reasonable time tonight.
Dr. Radford: Mr. Chairman, can I suggest that, if it would be
agreeable to Westinghouse people and Dr. Tamplin and the other people,
that after Mr. Rogers presents his presentation that we bring back the
AEG to finish that up?
I stress this because it seems to me, in my estimation, the
information presented by the witnesses this morning was very crucial
and very critical, and in no way would submission of questions to them
subsequent to this event really get the issues thrashed out as thoroughly
as I think we could do them now.
Dr. Mills: I can appreciate that, Dr. Radford. However, the
representatives from Westinghouse also have a tight schedule. We had
scheduled some time this morning for this group.
I believe I have no objection if Dr. Tamplin wishes to come on
after Dr. Wright and Mr. Kramer of Westinghouse, but to allow the earlier
panel to be around for questioning, I do not think I can hold up the
Westinghouse people any longer.
Dr. Radford: Let me just say for the record, then, that the fact
that we will probably not have an adequate opportunity to question much
more extensively, particularly Dr. Bair and Dr. Richmond who presented
such important information today, in effect vitiates a considerable
amount of the input of the AEC to these hearings.
-------
751
Dr. Mills: Well, their testimony will be put in the record.
As I have stated, I recognize the difficulty with trying to
answer some of these questions. However, they have commitments to
meet as well as the rest of us.
With that, I would like to proceed.
(Note: The panel was questioned at the end of the day and this is
a part of the record placed directly after the previous AEG testimony.)
Mr. Rogers:
-------
752
STATEMENT OF LESTER ROGERS
DIRECTOR OF REGULATORY STANDARDS
U. S. ATOMIC ENERGY COMMISSION
PRESENTED AT
EPA HEARING ON TRANSURANIUM ELEMENTS
DECEMBER 11, 1974
I am pleased to appear in this hearing to present a statement as a
member of the Regulatory staff of the Atomic Energy Commission. We
understand the purpose of the hearings is to gather information to
assist the Environmental Protection Agency in evaluating the potential
environmental impact of transuranium elements,and to consider whether
additional EPA guidelines or standards are needed to assure adequate
protection of the general ambient environment and the public health from
potential contamination by radionuclides of the transuranium elements.
We believe that it is appropriate and timely that EPA thoroughly examine
this question.
In this brief statement I plan to summarize some of the principal
considerations given to limiting exposures to the public by the AEC as
the Federal regulatory agency responsible for implementing and enforcing
radiation protection standards in the nuclear industry. We look forward
to continued cooperation with EPA as they move forward in examining
standards for transuranium elements,and will provide any information
available to us that might be helpful. Attached as Appendix A to my
testimony is a bibliography of recently issued environmental statements,
regulations, and guides prepared by the AEC Regulatory staff and related
Lo the subject of this hearing.
-------
753
- 2 -
Regulatory Responsibilities of the AEG
The commercial use of atomic energy was the first technology to be
subject to comprehensive Federal regulatory control from its inception.
Under the Atomic Energy Act of 1954, as amended, no person may construct or
operate a nuclear facility, such as a nuclear power plant or nuclear fuel
reprocessing plant, or possess or use source, byproduct, or special nuclear
materials except as authorized by an AEC permit or license (this includes
all of the transuranium elements of interest in this hearing). In addition,
the Atomic Energy Act authorized the AEC to promulgate regulations specifying
design, siting, and operating requirements for nuclear facilities to protect
against possible accidental radiation hazards. The Act requires the AEC
to take measures to protect against accidental releases of radioactive
materials, and to set limits on the amounts of radioactive material that
may be released during normal operations of nuclear facilities and other
activities involving nuclear materials.
Under the Atomic Energy Act the AEC has established a comprehensive
Regulatory program involving licensing, standard setting, inspections,
and enforcement. Detailed regulations concerning siting, design, and other
aspects of regulation of nuclear facilities and activities have been
published in 10 CFR Chapter 1. In addition, we have issued some 207 Regu-
latory Guides to provide guidance on methods acceptable to the Regulatory
staff for implementing specific parts of the Commission's regulations, to
delineate techniques used by the staff in evaluating specific problems
-------
754
_ o _
or postulated accidents, and to provide other guidance to applicants and
licensees. The Regulatory program that I have just outlined is continued
by the legislation that has created the new Nuclear Regulatory Commission.
Implementation of Radiation Protection Standards
Since its inception, the AEC has as a matter of policy used the
recommendations of the International Commission on Radiological Protection
(ICRP) and the National Council on Radiation Protection and Measurements
(NCRP) as the bases for regulations and safety requirements in its Regu-
latory program. In 1959 the Atomic Energy Act was amended to establish the
Federal Radiation Council (FRC), whose function was to advise the President
on radiation matters affecting health, including guidance for all Federal
agencies in the formulation of radiation standards.
All functions of the Federal Radiation Council were transferred to the
Administrator of the Environmental Protection Agency (EPA) by Reorganization
Plan No. 3 of 1970. Also transferred to EPA were "The functions of the
Atomic Energy Commission under the Atomic Energy Act of 1954, as amended,
administered through its Division of Radiation Protection Standards, to the
extent that such functions of the Commission consist of establishing
generally applicable environmental standards for the protection of the
general environment from radioactive material. As used herein, standards
mean limits on radiation exposures or levels, or concentrations or quantities
of radioactive material, in the general environment outside the boundaries
of locations under the control of persons possessing or using radioactive
-------
755
_ 4 -
material." The AEC retained the responsibility for implementation and
enforcement of EPA standards.
In its first Memorandum for the President dated May 13, I960, the FRC
recommended adoption of Radiation Protection Guides for Federal use in
normal peacetime operations. Subsequently, additional radiation protection
guides were recommended and adopted in Reports No. 2 and 8. AEC regu-
lations have been modified to conform to the FRC guidance to Federal
agencies approved by the President. EPA has not altered the guidance
issued by the Federal Radiation Council and the Commission's regulations
remain consistent with FRC guidance to Federal agencies.
The FRC, ICRP and NCRP guidance includes, but is not restricted to,
quantitative radiation protection guides and dose limits. Since any
exposure may involve some degree of risk, these standards setting groups
also have recommended that radiation doses be kept "as low as practicable"
or, as stated by the ICRP, "as low as reasonably achievable, social and
economic considerations being taken into account." Therefore, the AEC
system of implementing FRC guidance is aimed at the following principal
objectives:
1. To keep doses from all sources of exposure, other than natural
background and medical procedures, well within the FRC numerical radiation
protection guides.
-------
756
- 5 -
2. To avoid unnecessary sources of exposure and to ensure that doses
received are justifiable in terms of benefits that would not otherwise have
been received.
3. To provide for design and operational control of specific facilities
and uses of materials, both individually and in combination, so that the
resulting doses are sufficiently low that any further reduction in risk
would not be considered to justify the effort required to accomplish it;
that is, the doses are "as low as practicable", or as some prefer to say, as
low as reasonably achievable.
These objectives are achieved by:
1. Establishing and enforcing "regulatory upper limits" on doses
and releases of radioactive material to the environment applicable to
all licensed activities. These limits are not intended to be exceeded.
They are set forth in the Commission's regulation, 10 CFR Part 20, "Standards
for Protection Against Radiation."
2. Establishing and enforcing design objectives and limiting
conditions of operation applicable to specific classes of nuclear facilities
and uses of radioactive material to assure that persons engaged in activ-
ities licensed by the AEG make every reasonable effort to maintain radia-
tion doses and releases of radioactive material in effluents to the environ-
ment as far below the regulatory upper limits as is reasonably achievable.
This approach to design objectives and limiting conditions of
operation implies a cost-benefit methodology focused on the differential in
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- 6 -
costs and benefits that might be involved in requiring the activity to be
carried out at one level of exposure rather than another. The most defin-
itive guidance, of which we are aware, on the application of this method-
ology as related to radiation protection is set forth in the Recommendations
of the International Commission on Radiological Protection, ICRP Publica-
tion 22, "Implications of Commission Recommendations that Doses Be Kept As
Low As Readily Achievable." I request that this document be incorporated
into the record of this hearing, and we do have a copy to submit.
We believe that the application of this type of methodology in the
regulatory process, with emphasis on design criteria and operating procedures,
effectively controls releases of radioactive material and assures that the
risk from exposure to radiation resulting from the nuclear industry is kept
at an extremely low level.
We also believe that this approach to regulation is highly responsive
to the recommendations of the Advisory Committee on the Biological Effects
of Ionizing Radiation, National Academy of Sciences, as reflected in their
November 1972 report on "The Effects on Populations of Exposure to Low
Levels of Ionizing Radiation" (BEIR Report). Chapter II of the report,
"Needs of the Times," emphasizes the need for quantifying risk and the use
of cost-benefit analyses in decision-making. The report very wisely points
out that this methodology brings into the decision-making process such
important considerations as whether the public interests are better served
by spending our limited resources on health gains from reducing contamination
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or by spending for other societal needs. In discussing the difficulties
and uncertainties in cost-benefit analyses, the report concludes, and I
quote:
"Despite these uncertainties, there are important advantages in
attempting cost-benefit analyses. There is a focus on the biological
and environmental cost from technological developments and the need
for specific information becomes apparent. Thus, for example, we find
relatively little data available on the health risks of effluents from
the combustion of fossil fuels. Furthermore, it is becoming increas-
ingly important that society not expend enormously large resources to
reduce very small risks still further, at the expense of greater risks
that go unattended; such imbalances may pass unnoticed unless a cost-
benefit analysis is attempted. If these matters are not explored, the
decision will still be made and the complex issues resolved either
arbitrarily or by default since the setting and implementation of
standards represent such a resolution."
I would like to observe that, based on our experience to date, perhaps
the most urgently needed guidance is in those areas identified by the BEIR
Committee regarding how we should properly take into account the comparative
benefits to society from the expenditure of resources to reduce risk from
radiation exposures relative to the benefits to be gained by the expendi-
ture of resources on reducing other health risks. We believe a balanced
approach is a necessity and that this would be a productive area for EPA's
.attention.
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Experience in Implementing the "As Low As Reasonably Achievable" Concept
The effectiveness of the implementation of the "as low as reasonably
achievable" concept in the regulatory process is confirmed by experience in
the nuclear industry. This experience shows that licensees have generally
kept releases of radioactive material in effluents at such low levels that
resultant exposures to persons living in the immediate vicinity of nuclear
facilities have been less than about 5 percent of the FRC radiation pro-
tection guides for individual members of the public. The Atomic Energy
Commission has published numerical guidance on design objectives- and
limiting conditions of operation for light-water-cooled nuclear power
reactors in a proposed Appendix I to its Part 50 regulations. This proposed
regulation has been the subject of extensive public rule making hearings,
including a detailed environmental statement with extensive cost-benefit
analysis. The matter is now pending before the Commission for decision.
However, as a practical matter all existing operating power reactors,
as well as those under construction, either meet or are being modified to
meet the design objectives and limiting conditions of operation in the
range of the revised Appendix I recommended by the staff in its Concluding
*
Statement of Position filed on February 20, 1974. It is expected that
conformance with the guides on design objectives and limiting conditions of
operation will continue to provide reasonable assurance that annual total
body doses to individuals living near the boundary of a site, from radioactive
*Regulatory Staff Concluding Statement of Position, Docket RM-50-2
February 20, 1974.
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material released in either liquid or gaseous effluent from all reactors at
the site, will generally be less than 5 percent of average doses from
natural background radiation.— The level of doses to the total body or
any organ is expected to be generally less than 1 percent of Federal radia-
tion protection guides for individual members of the public. Furthermore,
annual average total body doses to the U.S. population from radioactive
material released in either liquid or gaseous effluents from all light-
water-cooled nuclear power reactors on all sites in the United States for
the foreseeable future will be less than 1 percent of doses from natural
background radiation.
Parallel to this, we have been working on comprehensive engineering
and environmental studies to form the basis for numerical guidance on as low
as practicable effluent releases for fuel cycle facilities other than
reactors. Included are nuclear fuel reprocessing plants, plutonium pro-
cessing and fuel fabrication plants, and uranium mills.
I would now like to turn to specific considerations related to the
transuranium elements.
Implications of Existing FRC Guidance for Transuranium Elements
The FRC numerical radiation protection guides pertinent to the trans-
uranium elements (transuranics) have been implemented by the AEC in 10 CFR
Part 20, "Standards for Protection Against Radiation," as upper limits on
occupational exposures and concentrations in effluents released to the
environment. Consistent with FRC guidance, we have used the "maximum per-
missible body burden" and "maximum permissible concentrations of radionuclides
— Average total body doses due to natural background radiation in the
United States are in the range of 100-125 millirems per year.
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in air and water" derived from the radiation protection guides recommended
by the ICRP and NCRP. These values are used as regulatory upper limits of
individual exposure for normal operations and as indices of relative risk.
Research and studies on the relation between intake of the transuranics and
biological effect should continue, and we will keep the standards under
review to assure that they reflect the best available knowledge.
However, it is not appropriate to arbitrarily project estimates of
possible releases of transuranics to the environment, or possible health
effects to the public, from commercial nuclear operations on the assumption
that significant numbers of people are going to be permitted to be exposed
to these upper limits of radiation exposure. Regulatory implementation of
the "as low as reasonably achievable" concept through close attention to
plant design requirements and operational controls will prevent this from
happening. Based on information now being submitted in license applications,
on operational data obtained from existing plants, and on evidence developed
in studies now underway on available technology and cost-benefit considera-
tions for fuel fabrication and reprocessing plants, it appears that normal
operational releases of the transuranics to the environment will keep radia-
tion exposures to individual members of the public on the order of 1000
times lower than would exposures at Part 20 concentration limits. In this
regard we agree with EPA's findings in their February 1974 report, "Environ-
mental Radiation Dose Commitment: An Application to the Nuclear Power
Industry," that "current control practices for actinide releases at a single
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operation, such as nuclear fuel chemical reprocessing, are expected to
-8 —9
restrict releases to the order of 10 to 10 of the total amount processed,
and future experience ray justify the assumption of even smaller release
fractions." Even so, EPA conservatively assumed that 10 of the total
amount handled in any given year would be released for purposes of projecting
cumulative potential health effects tothe Year 2020. The EPA estimates as
reflected in the report show that the cumulative future potential health
effects (i.e., number of lung cancers) from all assumed transuranic releases
through the Year 2020 froa the entire nuclear fuel cycle would not exceed
(That's assuming a linear dose-effect relationship.) £<3(!dfd cr)\ tettiti
21. A The current normal incidence of lung cancer in the U.S. population
when extrapolated over a 50 year period would indicate several million
cases fron all causes.
Protection Against Accidents
Protection against releases of radioactive materials that could result
from accidents is a. principal objective of the AEC regulatory program.
Applicants and licensees are obligated to assure the AEC that safety
considerations are a part of every step in the design, construction, and
operation of each nuclear facility or plant.
The AEC has the responsibility to see that Safety requirements are met
by the plant operator. Licenses are issued only for those activities which,
on careful and detailed review, can meet prescribed safety standards and
criteria within the bounds of conservative engineering practices. AEC
regulations require that nuclear facilities and plants be soundly and conservatively
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designed with ample safety margins and redundancy of components and systems
to compensate for the fact that no body of knowledge can ever be complete
enough to reduce uncertainties and risks to zero.
Many requirements are imposed to achieve these safety objectives.
Prominent among them is the defense-in-depth concept employed in the
design of all nuclear facilities. The implementation of this concept
includes the requirement of a comprehensive quality assurance program for
the design, construction, and operation of the facility; the provision of
multiple safety systems and physical barriers to prevent the uncontrolled
release of radioactive material; and the requirements for extensive testing
and inspection of plant equipment and systems, both before and during
operation.
Although the operation of nuclear facilities is not completely risk-
free, it is the safety objective of the AEC, through the licensing process,
to require applicants and licensees to take those actions necessary to
assure that the risks from design basis accidents are reduced to acceptable
levels and to assure that the likelihood of accidents more severe than
design basis accidents is extremely small.
In addition the licensee is required to develop a comprehensive emergency
plan to take appropriate protective action to minimize the risk to public
health and safety in the highly unlikely event that there is a significant
release of radioactive material offsite. In this regard, we believe that
EPA should give consideration to developing protective action guides for
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- 13 -
the transuranic elements similar to those issued by the FRC in Reports
Numbers 5 and 7 for iodine-131, cesium-137, strontium-90, and strontium-89.
In addition to requiring licensee emergency plans, the AEG, in exercising
its "Lead Operating Agency" role among Federal agencies having assigned
responsibilities for nuclear incident emergency planning, is actively
pursuing a program to assist State and local governments in developing and
improving their Radiological Emergency Response Plans.
Summary
In summary, we are pleased that EPA is examining whether there is a
need for additional guidelines on standards to further assure adequate
protection of the ambient environment and public health and safety from
potential releases of transuranium elements to the environment. We are
confident that AEC regulatory requirements on the design and operation of
nuclear fuel cycle facilities and the state of development of waste treat-
ment technology will assure that the risk to public health and safety from
the release of transuranium elements is kept at an extremely low level.
Research to better define potential pathways of exposure and the relationship
between intake of transuranics and biological risk should continue to be
supported. Existing standards should be critically reviewed as additional
information is developed on the dose-risk relationship. Guidance is needed
on how to account properly, in cost-benefit analyses, for the comparative
benefits to society from the expenditures of resources to reduce risk from
radiation exposures relative to the benefits to be gained by the expenditure
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of resources on reducing other health risks. Further guidance is also
needed in the form of protective action guides for the transuranium elements
similar to the guides for strontium-89, strontium-90, cesium-137, and
iodine-131, as set forth in Reports Numbers 5 and 7 of the FRC. This
concludes my statement and I will be pleased to respond to any questions
you may have. In addition I have attached to my testimony an Appendix B
which provides more of the detailed information requested in the Notice of
Hearing. (Added oral testimony) Dr. Mills, I think you are aware that
there are many documents in the public domain that are related to this
subject, all of which are available for your use.
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766
APPENDIX A
Bibliography of Recent
AEC - Regulatory Issuances Pertaining
to Plutonium and Transuranium Elements
1. Generic Environmental Statement Mixed Oxide Fuel. WASH-1327, August
1974.
2. Staff Testimony and Record of Barnwell Operating License Hearing,
Docket 50-332, 1974.
3. Proposed amendment to 10 CFR Part 50, General Design Criteria for Fuel
Reprocessing Plants, 39 FR 26293, August 18, 1974.
4. Proposed Amendment to 10 CFR Part 50, Technical Specifications for
Fuel Reprocessing Plants, 39 FR 24626, July 5, 1974.
5. Proposed Amendments to 10 CFR Parts 40 and 70, Effluent Monitoring and
Reporting (for fuel cycle facilities), 39 FR 38392, October 31, 1974.
6. Proposed Amendment to 10 CFR Part 20, Transuranic Waste Disposal,
39 FR 32921, September 12, 1974.
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— 2 —
Bibliography Cont'd
7. Division 3 Regulatory Guides as follows:
3.1 Use of Borosilicate-Glass Raschig Rings as a Neutron Absorber in
Solutions of Fissile Material
3.2 Efficiency Testing of Air-Cleaning Systems Containing Devices for
Removal of Particles
3.3 Quality Assurance Program Requirements for Fuel Reprocessing Plants
and for Plutonium Processing and Fuel Fabrication Plants (Rev. 1)
3.4 Nuclear Criticality Safety in Operations with Fissionable Materials
Outside Reactors
3.6 Content of Technical Specifications for Fuel Reprocessing Plants
3.7 Monitoring of Combustible Gases and Vapors in Plutonium Processing
and Fuel Fabrication Plants
3.10 Liquid Waste Treatment System Design Guide for Plutonium Processing
and Fuel Fabrication Plants
3.12 General Design Guide for Ventilation Systems of Plutonium Processing
and Fuel Fabrication Plants
3.14 Seismic Design Classification for Plutonium Processing and Fuel
Fabrication Plants
3.16 General Fire Protection Guide for Plutonium Processing and Fuel
Fabrication Plants
3.17 Earthquake Instrumentation for Fuel Reprocessing Plants
3.18 Confinement Barriers and Systems for Fuel Reprocessing Plants
3.19 Reporting of Operating Information for Fuel Reprocessing Plants
3.20 Process Offgas Systems for Fuel Reprocessing Plants
3.21 Quality Assurance Requirements for Protective Coatings Applied to
Fuel Reprocessing and to Plutonium Processing and Fuel Fabrication
Plants
3.22 Periodic Testing of Fuel Reprocessing Plant Protection System
Actuation Functions
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APPENDIX B
SUPPORTING INFORMATION TO THE STATEMENT OF
LESTER ROGERS CONCERNING AEC REGULATION OF
TRANSURANIUM ELEMENTS IN THE NUCLEAR
FUEL CYCLE
The purpose of this Appendix is to describe where plutonium and other
transuranium elements appear in the light-water-reactor fuel cycle, with
and without plutonium recycle; to characterize the plants which process
significant quantities of transuranics; to illustrate how the AEC Regulatory
process is being applied to these plants; and to estimate the potential
source terms.
1. The Light-Water-Reactor Fuel Cycle
The uranium fuel cycle is illustrated in Figure 1. It begins
with the mining and milling of uranium. The uranium is then converted
to UF,, enriched in U-235, converted to U00, and fabricated into
o /
reactor fuel. The uranium oxide fuel is irradiated in reactors and,
after several months, is reprocessed. In the reactors, some uranium
is converted into plutonium and other transuranics and fission prod-
ucts. The reprocessing plants separate plutonium, other trans-
uranics, and uranium from the spent fuel. The transuranics, other
than plutonium, are normally disposed of as high-level radioactive
waste along with the fission products. The recovered uranium is
normally returned to the enrichment plants for recycling, and the
plutonium is placed in storage.
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769
FUEL
ASSEMBLIES
13800 MTU
SPENT FUEL
8800 MTM
UO2 FUEL
FABRICATION
REPROCESSING
ENRICHED
UF6
13800 MTU
PLUTONIUM
53000 Kg Puf
V
r
309200 Kg Puf
PLUTONIUM
STORAGE/INVENTORY
ENRICHMENT
77900 MT SWU
(48000 US, 30000 FOREIGN)
00 MTU
°°uu
NATURAL UFg
80700 MTU
U
2800 CANISTERS
CONVERSION
TOUF6
LEVEL WASTE
WASTE STORAGE
URANIUM MINES
& MILLS
ORE 52.2 x106MT
'Cumulative To 1990
Figure I • Annual Industry-wide Fuel Cycle Requirements for Light Water Reactors
for about 1990 Without Plutonium Recycle (AEC-OPA 1974 Projection)
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In the event that the use of recycle plutonium is approved, the
LWR fuel cycle with the use of recycled plutonium is illustrated in
Figure 2. Plutonium and other transuranics may be present in five
phases of the LWR fuel cycle: (1) the reactor, (2) the fuel repro-
cessing plant, (3) plutonium storage, (4) high-level radioactive waste
storage, and (5) the mixed oxide fuel fabrication plant.
In the reactor and in the storage facilities, the plutonium and
other transuranics are contained by passive devices and not subjected
to mechanical processing. It is expected that there will be a
neglible discharge of plutonium and other transuranics to the environ-
ment in these phases of the fuel cycle.
The two phases of the fuel cycle which include processing of
large quantities of plutonium and other transuranics are the fuel
reprocessing plants (FRPs) and the mixed oxide fuel fabrication plants
(MOFFPs). These plants are the most likely to discharge measurable
quantities of plutonium and other transuranium elements to the environ-
ment and are described in more detail below.
a. Fuel Reprocessing Plants (FRPs)
The functions of a fuel reprocessing plant are to recover the
residual fuel materials, uranium and plutonium, in a form suitable
for re-use and to isolate radioactive wastes for storage and ultimate
disposal. Spent fuel is transported from the reactor to the
reprocessing plant in heavily shielded casks after a normal period
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771
FUEL
ASSEMBLIES
13800 MTM
430,000 MWe
LWR POWER REACTORS
SPENT FUEL
8800 MTM
prTT3
NA
U02
i
7 (U, Pu)02 RODS 1500 MTM
^^^ », . ^\
^^1 \ \
UQ7 MIXED OXIDE
n
PLUTONIUM
62000 Kg Puf
II
1450 MTU FUEL FABRICATION II
tj l_
Pu02
44300 Kg Puf
S
\
_J
V
r— - £^T~~"-1
41700 Kg Puf*
•— g |
ED UF6 PLUTONIUM
MTU STORAGE/INVENTORY
J
/f^~^
— V""*^- — ^
— "I <^
rl ^ RECOVERED
ENRICHMENT URANIUM
69400 MT SWU 8600 MTU
(42800 US, 26600 FOREIGN) 280o CAf
1
^^H
' I ' 1
) NATURAL UF6
71800 MTU ._.
i D
1
^f
i fi ii r1
4> 1_>
A
i -^^\
^
J/flf ,
//\ V <"
ISTERS
CONVERSION ^ 1 £ORAGE ~ HIGH-LEVEL WASTE
URANIUM MINES
& MILLS
ORE 47.4 x 106 MT
•"Material Indicated In Storage May Be
All or Largely Present Elsewhere in the
Fuel Cycle as Material in Process
Figure 2. Annual Industry-wide Fuel Cycle Requirements for Light Water Reactors
for About 1990 With Plutonium Recycle (AEC-OPA 1974 Projection)
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of storage at the reactor of about 150 - 160 days. Commercial
fuel reprocessing plants will use processes that are variations of the
process that has been used in USAEC facilities for many years. After
removal of the process tube and end-hardware of the fuel assembly,
the next step in reprocessing irradiated nuclear fuels is to shear the
long fuel assemblies into approximately 1-in. pieces to expose the
fuel material for subsequent dissolution in nitric acid.
In the dissolver, the fuel material is dissolved in nitric acid,
leaving the cladding hulls as a residue. The dissolver solution
containing uranium, plutonium, other actinides, and fission products
is assayed and transferred to a feed tank for the separation process.
The residual hulls are examined to assure that fuel dissolution is
complete and then are transferred to a solid waste storage area.
Uranium and plutonium are recovered and purified by a solvent
extraction process in which uranium and plutonium preferentially
transfer into the organic solvent, and the other transuranics and
fission products remain in the acidic waste. The co-extracted uranium
and plutonium then are separated from one another in a second solvent
extraction operation. After similar purification steps, the purified
uranium and plutonium products are packaged for future use. The
highly radioactive acidic wastes from the solvent extraction system
are concentrated by evaporation and stored in stainless steel tanks.
Present AEC regulations (Appendix F, 10 CFR Part 50) require that
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these liquid wastes be converted to a dry solid and transferred to a
Federal repository no later than 10 years following separation of
fission products from the irradiated fuel.
Gaseous waste streams from fuel reprocessing plants entrain
small quantities of particulate plutonium and other transuranium
elements. These waste streams are treated by gaseous radwaste
systems prior to release to the atmosphere through tall stacks
(typically 100 meters). The particulate removal efficiency of these
systems, on the basis of current technology, is estimated to yield a
system decontamination factor of 1 x 10 for 2 HEPAs in series.
A commercial scale FRP is expected to process about 1,500 metric
tons per year of fuel irradiated to 33,000 MWD/metric ton at 30 kW/kg.
After 160 days of radioactive decay, the calculated amounts of
plutonium and other significant transuranics entering the facility
per year would be as follows:
Nuclide
Pu-238
Pu-239
Pu-240
Pu-241 (beta)
Pu-242
Am-241
Am-243
Cm-242
Cm-244
Expected FRP Throughput
(Ci/yr)
Alpha curie total:
Beta curie total:
Total:
4.2 x 10,
4.9 x 10;
7.1 x 10
1.5 x 10
2.0 x 10;
2.4 x 10-
2.7 x 10.
2.5 x 10'
3.6 x 10
3.4 x 10'
1.5 x 10l
1.8 x 10*
8
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- 7 -
b. Plutonium Fuel Fabrication Plants
The function of a plutonium fuel fabrication plant is to manu-
facture plutonium bearing fuel assemblies for nuclear reactors from
plutonium oxide and uranium oxide feed materials. The fuel is often
referred to as "mixed oxide" fuel, and the plant a mixed oxide fuel
fabrication plant (MOFFP). The transuranium nuclide Am-241 entering
a fabrication plant is that from the decay of Pu-241 following an
aging time of about two years after plutonium separation in a fuel
reprocessing plant.
Fuel pellets are fabricated from uranium and plutonium oxide
powders. The pellets are inserted into zirconium alloy tubes and
shipped to an enriched uranium fuel fabrication plant for placement in
assemblies prior to shipment to LWR power plants.
All processing steps which involve radioactive materials are
performed in process vessels, process cells, or alpha enclosures (such
as glove boxes). The gaseous waste streams from the processing steps
each receive a separate pretreatment. The treated process gases and
alpha enclosure ventilation air are combined with ventilation air from
personnel operating areas for final treatment with high efficiency
filters prior to release to the atmosphere through a short stack
(typically A~6 meters). The particulate removal efficiency of this
treatment system, on the basis of current technology, is estimated to
yield a system decontamination factor of 3 xlO for 3 HEPA filter
banks in series.
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Liquid effluent treatment systems are used to recover uranium,
plutonium, and nonradioactive materials, such as nitric acid and
water, and to recycle these materials to the processing operations.
No radioactive process liquids are expected to be released from the
plant. Residues from the treatment of liquid radwastes are already
being solidified and shipped offsite for disposal.
Commercial scale plants expected to be built in the near future
will typically have a throughput of one metric ton per day of mixed
oxide fuel. The amounts of plutonium and transuranium nuclides
entering a MOFFP per year are calculated to be as follows:
Nuclide
Pu-238
Pu-239
Pu-240
Pu-241
Pu-242
Am-241
Alpha curie total:
Beta curie total:
Total:
Expected MOFFP Throughput
(Curies/Year)
6.6 x 10,
3.5 x 10;
7.7 x 10
1.7 x 10
4.9 x 10;
5.7 x 10"
8.3 x 10*
1.7 x 10
8
8
1.8 x 10
8
2. The AEC Regulatory Process
a. General Design Criteria
The Atomic Energy Commission establishes regulations which
set general requirements for the primary safety related features
of nuclear facilities. These regulations are called General
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Design Criteria. License applicants are required to show, by
engineering analyses and tests, that individual facilities meet
the general design criteria. The general design criteria spec-
ifically treat the design, inspection, and testing of components
and systems which confine radionuclides including transuranium elements,
In 1972, the Atomic Energy Commission began to develop
amendments to its regulations to provide general design criteria
for fuel reprocessing plants and for plutonium processing and
fuel fabrication plants. Proposed General Design Criteria for
Fuel Reprocessing plants were published in August 1974. General
Design Criteria for Plutonium Processing and Fuel Fabrication Plants
are being developed. These criteria will assist license applicants in
developing a description and safety assessment of the design bases for
the principal structures, systems, and components of the plant, in-
cluding provisions for protection against natural phenomena, and a
description of the quality assurance program. Specific criteria which
affect normal operational releases include those which refer to
testing and maintenance of equipment, design of confinement barriers,
ventilation and off-gas systems, protection systems, instrumentation
and control systems, effluent systems, and effluent monitoring.
b. Siting Criteria
Revisions of AEC regulations giving siting criteria for fuel
cycle facilities are being developed. The purpose of siting criteria
is to control the risk to the general population by restricting the
location of the sites.
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In developing siting criteria, consideration is given to the
potential releases of plutonium and other transuranics and to the
pathways by which these nuclides can reach man. The criteria will
be used in a screening process to identify suitable candidate sites
for these facilities. The decision to build a plant on a specific
site will be based on a detailed evaluation of the proposed site-
plant combination, and a cost-benefit analysis comparing that
combination with alternative site-plant combinations.
In 1972, the AEC began studies to provide the technical bases
for developing generic siting criteria for fuel cycle facilities
handling large quantities of plutonium and other transuranics.
This work is still in progress.
c. The Policy of "As Low As Practicable"
In 1973 the Commission initiated comprehensive engineering
and environmental studies to form the basis for numerical
guidance for as-low-as-practicable effluent releases for fuel
cycle facilities other than reactors. These studies included
nuclear fuel reprocessing plants and plutonium processing and fuel
fabrication plants.
The studies began with the development of conceptual designs
of model plants. Calculations were then made of the quantity of
radioactive material that would be released to the envionment
(in liquid and gaseous effluents) and the resulting dose commitments
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778
- ii -
to individuals and the population. The model plants included
sufficient radwaste treatment equipment to limit radioactive
materials in liquid and gaseous effluents at or below the levels in
10 CFR Part 20.
The next phase of the studies consisted of adding to the
conceptual model plant successive stages of radwaste treatment
equipment to limit radioactive materials in effluents to succes-
sively lower levels. The cost was estimated for each increment of
added radwaste treatment. The quantity of radioactive material '
released to the environment and the resultant dose commitment to
individuals and the population were also calculated for each
increment.
The third phase of the studies was to determine the cost
effectiveness of each increment of radwaste equipment that was
added to the model plant. This was done by dividing the cost of
each increment of treatment by the reduction in dose commitment to
the population that the equipment achieved. The cost effectiveness
was thus determined in units of dollars per person-rem of reduction
in population dose commitment.
The final phase of the studies is to select for each fuel
cycle facility numerical guidelines for as-low-as-practicable
releases. This includes limits on the quantities of radioactive
material released to the environment and the maximum annual dose
commitment that an individual can receive at the site boundary.
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The numerical values will be chosen so that doses are at a very low
level where further reduction in risk would not be justified by the
effort required to accomplish it; i.e. the doses are as low as
reasonably achievable.
The proposed rule changes and draft environmental statements
relating to ALAP for fuel reprocessing plants and mixed oxide fuel
fabrication plants are being developed.
d. The Use of Technical Specifications, Monitoring, and Inspections
In licensing individual nuclear plants such, a? PKPa and MOFFPs,
certain factors quantified in the analysis of. the plant may be
specified in the technical specif±cations or license conditions which
become part of license to operate the plant. These requirements
provide assurance that the plant is operated so that normal releases do
not exceed those evaluated in the licensing process.
Further assurance that actual releases do not exceed those
specified in the technical specifications is provided by monitoring
gaseous and liquid effluents from the facilities. For fuel reprocessing
and plutonium fuel fabrication plants, emphasis is placed on sampling
of gaseous effluents from the exhaust stack, since evidence' indicates
that inhalation (both during plume passage and from resuspension of
deposited particles) is the critical pathway for dose commitments
from plutonium and other transuranics. As a result, the major
monitoring effort in such plants is directed toward measurement
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of the small quantities of plutonium and other transuranium elements
which penetrate the final confinement barrier (the final filter
bank) and are released to the atmosphere. In addition, environ-
mental monitoring is performed for plutonium and other transuranics,
and is generally done to (1) establish baseline data (e.g., fallout
plutonium from weapons tests or burnup of systems nuclear auxiliary
power (SNAP) generators returning to the earth from space applica-
tions) , (2) provide confirmation that plutonium is not accumulating
in the environment, or (3) provide environmental contamination data
following an accidental release of plutonium. Effluent monitoring
guides are now being developed for FRPs and MOFFPs and are expected
to be issued for comment in 1975.
In addition to the monitoring efforts required of licensees,
periodic and extensive on-site inspections of each plant are carried
out by the Regulatory staff. The purpose is to provide further
assurance that the requirements of Regulatory standards and the
technical specifications at each plant are being complied with. In
the event of violations by licensees, Regulatory response may range
from written admonitions to correct unsatisfactory conditions,
to monetary fines or plant enclosure in the event of serious
violations.
e. The AEC Policy for Radioactive Waste
The Atomic Energy Commission is considering the amendment of
its regulations to prohibit the disposal by burial in soil of
-------
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- 14 -
plutonium and other transuranics (39 FR 32921, 9/12/74). Wastes
containing plutonium and other transuranium elements generally
consist of (a) expendable material such as absorbent tissues,
clothing, gloves, and equipment; (b) solids such as filters from
effluent treatment systems; (c) liquid and solidified liquid wastes;
(d) fuel hulls which remain after fuel reprocessing operations; and
(e) wastes which contain or are contaminated with transuranics
resulting from reprocessing operations, but which are not classified
as high-level waste.
Presently, the AEC regulations permit the disposal of specified
small quantities of transuranics by burial without the specific
approval of the Commission. The proposed amendment would require
waste containing transuranium elements to be solidified (if necessary),
packaged, and transferred to the AEC for storage as soon as practicable
but within five years after its generation.
3. Source Terms of Plutonium and Other Transuranium Elements
With the implementation of the Regulatory process which has
been outlined above to include general design criteria, siting
criteria, ALAP numerical guidelines, monitoring and inspections,
and waste disposal policy, it is possible to make projections of
the releases of plutonium and other transuranics from the commercial
scale FRPs and MOFFPs of the near future. Such estimates are
largely theoretical in nature, based on limited experience with
-------
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- 15 -
much smaller facilities. Until larger facilities have been licensed
and operating it will be difficult to precisely define such releases.
Based on current projections, there will be several commercial
scale FRPs in operation by 1990, reprocessing on the order of 8,800
metric tons of LWR fuel per year. For each typical, commercial
scale FRP, the Regulatory staff estimates that less than 0.1 curie
(alpha) of plutonium and other transuranics will be released in
gaseous effluents per plant-year. In addition, less than one curie
(beta) of plutonium-241 would be released in gaseous effluents per
plant-year. No liquid releases are anticipated. The maximum
annual organ dose (bone) to an individual living near the site
boundary has been estimated to be less than 1.0 mrem from plutonium
and other transuranics. The annual dose to the whole body is much
lower than the maximum organ dose to the bone. These estimates
include dose contributions from inhalation and ingestion.
The decision regarding the use of recycle plutonium for LWR
fuel has not yet been made. Current projections indicate that if
plutonium recycle is initiated, there will be several commercial
scale MOFFPs in operation by 1990, fabricating about 1,500 metric
tons of mixed oxide fuel per year. The Regulatory staff estimates
that less than 0.0001 curie (alpha) of plutonium and other trans-
uranium elements would be released in gaseous effluents per plant-
year for a MOFFP of commercial scale. About 0.001 curie of
-------
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- 16 -
plutonium-241 (beta) would be released in gaseous effluents per
plant-year. The maximum annual organ dose (bone) to an individual
living near the site boundary has been estimated to be less than one
millirem. The annual whole body dose would be much lower than the
maximum annual organ dose. These estimates include dose contributions
from inhalations and ingestion.
Thus, for the uranium fuel cycle, with or without plutonium
recycle, the maximum dose to any organ or to the whole body of an
individual from plutonium and other transuranium elements would
amount to no more than one percent of the natural background
radiation dose.
-------
784
RADIATION PROTI ( I ION
ICRP PUBLICATION ?..
Implications of Commission
Recommendations that Doses be kept as
Low as Readily Achievable
A Report by Committee 4 of the
International Commission on
Radiological Protection
ADOPTED BY THK COMMISSION IN \PKII. 197.1
PUBLISHF-D I OR
The Intcrn;ilion
-------
785
Dr. Mills: Thank you very much, Mr. Rogers.
Dr. Morgan, do you have any questions?
Dr. Morgan: I have just one question, Mr. Rogers.
You indicated that for the foreseeable future, it was not
anticipated that the doses to the population from the operation of the
light-water-cooled reactors would exceed more than about one percent
of the natural background radiation.
Perhaps I could break this into two questions.
Does this include the occupational dose and the accident dose?
The other question, then, would be what about the LMFBR and the
fuel fabrication and the rest of the fuel cycle?
I think it would be much more meaningful if you could give us the
percent in reference to the whole fuel cycle.
Mr. Rogers: This does not include occupational exposure inside
the facility. It relates only to the population exposure received off-
site.
Dr. Morgan: It does not include accidents?
Mr. Rogers: It does not include accidents.
Dr. Morgan: What about LMFBR?
Mr. Rogers: It does not include the LMFBR. The information that
is presently available on technology would lead us to believe that the
levels of release from any LMFBR would be at least as low as those from
the light- water reactor and should not be significantly different.
With respect to the remainder of the fuel cycle as related to
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population dose, we would expect again that the average population
dose would not exceed the order of one percent of the natural
background.
Mr. Morgan: The two percent total would be —
Mr. Rogers: In that range somewhere. As you know, these are
estimates and projections, so I would not want to refine those numbers
any further.
One or two percent, somewhere around that figure.
Dr. Mills: Dr. Garner?
Dr. Garner: As a follow up to what Dr. Morgan was saying, you
say you think approximately the same amount of transuranics will be
released from the recovery operation, or do you mean to say that per-
centage of the total inventory will be released?
Mr. Rogers: With the LMFBR, I was really referring to the
relative dose offsite from the LMFBR.
Dr. Garner: That does not mean, does it, that since you are going
to have a total greater throughput of transuranics, that you must be
cutting down the releases to the environment, the percentage of the
total handled that is released to the environment will be cut down?
Mr. Rogers: I think that is correct.
Dr. Garner: So you are going to improve the hold-up. I do not
know what percentage you normally take of material in the processing
plant, what percentage you take as released, escaping to the environ-
ment. Could you give me a figure on that, a working figure?
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787
Mr. Rogers: We are doing detailed studies on that at the moment.
I do not think I have specific figures as to percentage other than the
decontamination factors that we get, on the order of 108 or 109 with
respect to fuel reprocessing and 109 or lO1^ for mixed oxide fuel
fabrication plants.
Dr. Garner: I think that is all I have to say.
Dr. Mills: Dr. Radford?
Dr. Radford: Mr. Rogers, you referred to these estimates of the
dose commitment that EPA has made in a publication. Are you familiar
with the model on which they based these estimates, the exposure
conditions that they assume, and so on?
Mr. Rogers: I am generally familiar with it. It is in the
published report.
Dr. Radford: On page 6 of your appendix B, you give the through-
put for a 1500 metric ton per year fuel reprocessing plant?
Mr. Rogers: That is correct.
Dr. Radford: In curie amounts, curium 242 and 244 constitute far
and away the most important throughput of alpha activity. Now, I am
only talking about alpha activity.
Mr. Rogers: I am not sure I would characterize it as the most
important. It is the largest number.
Dr. Radford: Well, OK. It is far and away the largest fraction.
If my quick arithmetic is right, something on the order of 95 percent
of all the alpha activity through fuel reprocessing plants is curium
isotopes.
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788
Now, I am not quite sure, this is entering a facility, but the
plutonium will be recycled out, so the plutonium becomes an even smaller
fraction once it is recycled out. Is that correct, if you assume a
recycle?
Mr. Rogers: A smaller fraction of —
Dr. Radford: You have a certain amount of activity of plutonium
isotopes coming in, right?
Mr. Rogers: Yes.
Dr. Radford: Now the waste stream will not contain much of that
plutonium. You hope it will only be, as we said yesterday, something
like a half percent.
Therefore, the amount released in the waste and potentially capable
of reaching the environment, plutonium isotopes on a curie basis now,
would be very small indeed, proportionate to the americium even?
Mr. Rogers: But the curium that is retained in the process, of
course, goes into solidified waste. It is not released to the environ-
ment.
Dr. Radford: The point I am making is, it is not recovered. It
is simply put aside or maybe lost in the process.
Now, the question I would ask pertinent to this dose commitment,
what assumptions were made about releases from the waste system, from
the throughput system, and so on as far as the activities of these alpha
emitters are concerned?
Mr. Rogers: Again, I believe the same assumptions that decontami-
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789
nation factors of 108 and 10 were used.
Dr. Radford: So that would apply to curium isotopes also?
Mr. Rogers: That is right.
Dr. Radford: We could then use these across the board as the
estimates of what would escape?
Mr. Rogers: Right.
Dr. Radford: OK. Now, in view of the fact that the curium
isotopes are in far greater alpha activity concentration, do you know
if the dose estimates were based on curium uptake?
Mr. Rogers: I believe the dose estimates did include curium.
Dr. Radford: We would have to include mostly curium, since on an
activity basis, it is mostly curium. I think I heard today and we have
the people in the audience who can correct this, that some recent
experiments have indicated that curium was unusually hazardous, as
least as far as per rad dose base was concerned; the assumption being
that it was uniformly distributed rather than perhaps aggregating in
a lymph node, such as some of the plutonium.
Therefore, the question would be has an adequate evaluation of
this new information changed the picture as far ar perhaps the curium
toxicity might be?
Mr. Rogers: I do not think I would want to comment on that with
respect to the curium toxicity, Dr. Radford. But, I do not think it
changes the picture of our basic approach to isolate this material
through good design objectives and conditions of operation, to simply
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790
avoid letting any significant quantity enter the environment, thereby
avoiding the risk fostered by unwarrented exposure.
Dr. Radford: That might influence whether the number of lung
cancers was 21, 21,000, 20 million or something.
Mr. Rogers: I really would not argue about the risk; if the
estimate is 21, 30 or 40, from that standpoint. I think the basic
message that I would like to get across is that from a regulatory
standpoint, our emphasis is on design objectives and limiting condi-
tions of operation, using technology on a reasonable cost-benefit
basis to keep the material out of the environment and to isolate.
Our best estimates, I think, both with respect to EPA and the
AEC and all the estimates that have been made in the environmental
statement on the breeder and the details of the envioronmental state-
ment on plutonium recycling, shows that it is technically feasible to
keep these levels down to extremely low levels as far as exposure is
concerned.
So I think that is the basic message. Surely, we should continue
to carefully study our dose risk relationship, so that we will be act-
ing on the best available information. But from the standpoint of the
end result of reducing exposures, I do not think that we are waiting
on that kind of information to go ahead and apply technology to keep
these releases at extremely low levels.
Dr. Radford: We heard from Mr. Forscher of ANSI earlier. I
believe you were here. He indicated that the ANSI standard, in effect,
led to a 50-fold reduction in the calculated emission limit.
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791
These were fuel fabrication facilities only. Do you think that
50-fold reduction is a relatively easy thing to achieve?
Mr. Rogers: I would like to make two comments. First, I would
not want any misunderstanding with respect to the status of the draft
standard that Dr. Forscher talked about this morning. That is still in
committee work.
We do not subscribe to the specific numbers that are in the
standard. We really think the question of effluent limitation,
numerical effluent limitation, is really a prerogative of the regula-
tory agencies to establish.
Having said that, I would not want to be associated with that
standard as being any type of official document. But having said
that, I think I have just indicated in my testimony, that as a practi-
cal matter we feel by applying the "as low as reasonably achievable"
concept on a cost-benefit basis, that in normal operations and most of
the time, we can achieve levels of exposure from the transuranics
which are perhaps less than one percent of the existing basic radiation
protection standards. So that would indicate a reduction in terms of
exposure of a factor of 100. We are doing that as you well know in
the light-water-cooled reactors.
We feel that the exposures can be kept generally down to this
range of one percent of existing radiation protection basic standards
from these individual sources.
Dr. Radford: A final question: There has been some concern
expressed, including by myself, that if you set, let us say, environ-
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792
mental limits either by emission limitations or by ambient measurements,
however they are specified, below the detection limit, below the
practical detection limit, that in effect you have really an unregu-
lated situation.
Mr. Rogers: Well, I understand what you are saying. Let me say
I think the feasibility of detection depends on the point of measure-
ment.
If you wait until the radioactive material is dispersed in the
environment, and you go out and try to measure environmental levels,
it becomes extremely difficult at these low levels. Although with
research instrumentation, as you well know, you can get extremely low.
But, if you do put your emphasis on the point of control, on the
source, and do your measurement there, just behind the HEPA filters,
to measure materials while you have it in a small volume, then you
can detect extremely low levels.
Dr. Radford: Does not that pose certain special problems when
you are talking about particulates coming out?
Mr. Rogers: No question. There is no question that it does pose
problems and it takes a very substantial technology and very sub-
stantial effort to contain the material and then to do the right
kind of monitoring programs to show what you are doing.
But we feel we should go ahead and take those kinds of measures.
Let me emphasize one thing. I think there is a good deal of misunder-
standing as to what the AEC is doing in trying to define design objec-
tives and limiting conditions of operations for individual kinds of
-------
793
facilities. Those are derived working limits, working levels for
the purpose of design objectives. Many people are confusing that with
the basic standards and saying we have reduced the basic standards.
That is not true.
The basic standards apply with all sources of exposure, except
natural background and medical exposures. When an engineer goes to
design a reactor or reprocessing plant, he has to define system per-
formance requirements. Therefore, there have to be numbers to design
against. It is these design objectives which we are defining, which
is based strictly on the basis of technology.
It so happens that with technology, you can get down to a level
of risk which we consider to be approaching the trivial level,
extremely low levels. Having reached those levels, we feel that the
problem then is solved, that those are design objectives for limiting
conditions of operation, not lowering the basic standard, nor are they
considered as limits as such.
Dr. Radford: I understand.
Dr. Mills: Dr. First?
Dr. First: In all of your statement, you qualified your environ-
mental limit as for normal operations. What would be a practical number
considering perturbations and upset conditions and so on? Would this
change in any way?
Mr. Rogers: What I use in normal operations takes into account
perturbations and unusual kinds of operation. What I am trying to do
is differentiate between accidents and normal operations.
-------
794
Dr. First: I take it, accidents then, are those in which some
considerable amount of activity escapes the containment, et cetera?
Mr. Rogers: Our basic approach to accidents is to require the
design and safety system to make the probability of the accidents
extremely low.
Dr. First: Just one other minor point I would like to ask about.
In Appendix B, where you discuss how you arrived at the least
reasonably achievable levels, you state that you keep looking at
the problem go lower and lower in emissions. I am on page 11.
You say the cost effectiveness is determined at a point where
further reduction of risk would not be justified by the effort to
accomplish it, as you get less and less risk reduction per unit cost.
What is the other end of that equation? How do you make this
determination, when the dollars are no longer worthwhile?
Mr. Rogers: Of course, this is one of the most difficult and,
perhaps, one of the most controversial areas. It is in this area that
I suggest that the EPA might help us in providing some guidance.
If you look in the light-water reactor area, let me say first, we
feel that you have to consider both the population dose as well as the
dose for the individual. These both have to be considered, both the
individual as well as population dose.
There are going to be times when the dose to the individual will
be controlling over the population dose. It is a very difficult,
subjective kind of decision to make, but in the light water reactor
-------
795
area, the design objectives and limiting conditions of operation are
recommended by the staff in their final concluding statement.
I think for whole body doses, it turns out the range is on the
order of 200, 250, 300 dollars, perhaps, per man-rem; some lower than
that.
In the literature, suggestion has been made of dollars per man-
rem from a few pounds sterling, I believe, up to ranges, perhaps, to
$1,000 or less than $1,000 per man-rem. There are estimates all within
that range.
I do not know how valid these numbers are, and this is where
judgment is very difficult. I think this is where we really need
guidance.
Dr. Mills: Dr. First asked my question about the selected number.
As you know, we have been battling about this number for some time as
to where it should be.
I think you are right. It is very complex, a complex decision to
make.
The only minor question I have has to do with this question of
background. Are you proposing that the process for establishing the
standard for the nuclear industry as a whole should be related to
natural background, or should we use natural background to put the
inner risk that we might assign in the proper perspective?
From time to time, I have heard people say there should be some
percentage of background.
-------
796
Mr. Rogers: No. I think our basic approach to controlling the
releases that I have outlined here is with emphasis on developing
of sound technology with the basic philosophy of trying to contain
the materials.
You know, it turns out that with technology, it is feasible to
get down to levels which are on the order of just a few percent of
natural background.
It is my own judgment, and this is my personal feeling, that you
reach a level where the residual risk is so small, and it is in this
range of percent or so of natural background radiation, that you reach
a level of risk where the risk is so small it is simply not worth the
effort to try to eliminate that residual risk.
I think our cost-benefit analysis generally supports that when you
get down into that range, your costs start going up rather rapidly.
Certainly, natural background radiation is probably the most
valid indicator that we have as to the relative risk of radiation as
a comparison.
Dr. Mills: No more questions.
Thank you very much.
I have been asked to make an announcement. EPA will have a copy
of all the written material submitted available for inspection on
Monday, December 16, in the EPA Freedom of Information Office.
As was announced earlier, the transcript will be available within
30 days.
Next we have the representatives of the Westinghouse Electric
-------
797
Corporation, Power Systems Division, Mr. Kramer and Dr. Wright.
Dr. Kramer: Good afternoon, gentlemen.
Before I begin, may I ask if it will be possible for Dr. Wright's
talk and mine to be consecutive and then have the questions afterwards?
Dr. Mills: Fine.
-------
798
STATEMENT BY
FREDERICK W. KRAMER
ENGINEERING MANAGER, NUCLEAR FUEL DIVISION
WESTINGHOUSE ELECTRIC CORPORATION
BEFORE THE
TM\/T DOMMCMTAI D nnTrrTT AM « P--HCM/
DECEMBER 10, 1974
-------
799
My name is Frederick W. Kramer. I am the Engineering Manager of the
Nuclear Fuel Division of the Westinghouse Electric Corporation. I am
accompanied by Dr. James H. Wright, Director of the Environmental Systems
*
Department, who will also speak, and Roger E. Wills of the Westinghouse
Law Department.
I am pleased to have this opportunity to appear before you on behalf
of Westinghouse and to participate in the Environmental Protection Agency's
effort to ascertain whether there is a need to establish new environmental
guidelines or standards at this time. I will direct my remarks to cate-
gories 1, 4 and 5 of the Federal Register announcement. Dr. Wright will
address his remarks tc categories 2 and 3.
We believe that the most complete information on the social and
economic implications of using plutonium as applied to our environment
and to the national economy is available in the AEC draft publications,
WASH-1535 (March 1974), "Environmental Impact Statement for LMFBR Industry,"
and WASH-1327 (August 1974), "Generic Environmental Impact Statement for
Mixed-Oxide Fuels." The statements represent two uses of plutonium in
generating nuclear power. As explained later, these applications are
expected to utilize virtually all of the plutonium made available commer-
cially for several decades. Basically, WASH-1327 describes the near-term
-------
800
- 2 -
situation where plutonium will be recycled in LWRs, while WASH-1535 covers
the transition from this usage to application in a breeder industry through
the year 2000 and beyond.
Both reports provide extensive reviews of the benefits of plutonium
utilization in power generation, and both include relevant information on
potential environmental and public health impacts. Additionally, the AEC
is currently reviewing various aspects of the entire fuel cycle. These
activities should provide an important base for any reviews of plutonium
and transuranic guidelines or standards, and we anticipate that the EPA
will work closely with the AEC to develop coordinated and integrated
radiation protection guidelines in a systematic manner.
We recognize the benefits and risks of plutonium are a subject area
which commands a great deal of attention, and we welcome the EPA's public
airing of this subject. While this public hearing and related AEC efforts
can go far toward placing the use of plutonium in perspective, it is
important in considering possible new standards for plutonium that such
efforts eliminate any alternatives which on balance offer little or no
benefit at a significant cost.
-------
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- 3 -
For example, if a standard were to be adopted which permitted, as a
limit, releases from nuclear facilities of only a small fraction of fall-
out levels, environmental measurements and effluent control systems required
to prove that such limits were not approached or exceeded could be very
extensive. To adopt standards without carefully considering the total
risks and benefits associated with nuclear and non-nuclear options (and
in the context of effects from widespread fallout versus localized effects
from a few facilities) would be unwise.
As part of any facility environmental report, a description of various'
control alternatives is presented in the context of a cost-benefit analysis.
Tiiis cobl-uenefit approacn would be continued and, as required, extended to
include entire fuel cycle or plutonium usage activities, such as were
included in the AEC's Generic Environmental Impact Statements. In this
regard, we would suggest that the EPA consider the value of preparing an
environmental impact statement for any contemplated new standards — one
which includes a detailed cost-benefit analysis -- in view of the desirable
social results of sucn preparation.
For instance5 preparation of the impact statement would provide for
improved planning and coordination, a greater likelihood that decisions
to further one environmental goal will be taken with the awareness of
-------
802
- 4 -
possible impacts on other environmental concerns, fuller use of available
expertise through the extensive review process, substantial benefits of
public participation, and careful decision making through weighing of costs
*
and benefits. A complete discussion of alternatives would allow for
stimulated and factual debate with constructive results.
The implementation of general ambient environmental guidelines or
standards for plutonium and the transuranium elements will eventually
require a determination of an emission standard for each source of con-
tamination. The validity of the ambient environmental standard as well
as the method for establishing the emission standard could greatly affect
the direct costs of facilities anu iiitiireclly affect the cost of energy
to the American consumer. This latter issue has been raised in AEC
hearings, and it is appropriate that the extrapolation of the costs to
the American consumer should be addressed.
In our detailed statement being submitted for the record, Westinghouse
identifies the general factors to be considered in the cost-benefit analysis
Westinghouse has long held a position of leadership in the nuclear
industry, and we have accumulated substantial experience and knowledge to
demonstrate that plutonium can be handled and utilized safely. The
Westinghouse Plutonium Fuels Development Laboratory has been on-line for
-------
803
- 5 -
five years. The Fast Flux Test Facility is approaching completion. The
Liquid Metal Fast Breeder Reactor- represents a new generation in reactor
development. The Hestinghouse Recycle Fuels Plant is in the licensing
*
process today and is destined to be the industry's first full-scale
Plutonium fuel fabrication facility.
In recent months, Mestinghouse has been engaged in detailed evaluations
of the impact of plutonium on the environment for each of the programs
mentioned above. These environmental reports are in the public domain,
and I would encourage interested citizens to inspect them. Only in this
manner can the depth of study involved be fully appreciated.
Our actual operating experience with plutonium handling and processing
has been achieved at the Plutonium Fuels Development Laboratory (PFDL)
located at Cheswick, Pennsylvania. This laboratory has provided extensive,
practical experience in the fabrication of plutonium fuels and is the
source of mixed-oxide (PuO^ - U0?) fuel elements which have already been
successfully demonstrated in operating reactors.
Since 1969, Westinghouse has conducted a program of monitoring,
measuring and controlling both gaseous and liquid effluents at PFDL.
Detailed data are presented in our written submission but a few summary
notes are significant:
-------
804
- 6 -
1. Monitored airborne releases from PFDL have been found to be
less than detectable levels, even while minimum detectable
levels have been reduced through the increased sophistication
of measurement methods.
2. Liquid releases at the point of discharge are less than four
percent of the maximum permissible concentration.
3. Activity levels in the plant sanitary sewer are approximately
three orders of magnitude lower than the maximum permissible
concentration, and those levels measured in the Allegheny
River are approximately seven orders of magnitude lower than
MFC, which is indistinguishable from the plutonium present in
the environment due to fallout background.
It should be stressed that these are normal, anticipated levels
expected as a function of plant design and operational control as well
as environmental background. This is pertinent experience and should
be carefully considered in judging the adequacy of existing standards.
-------
805
- 7 -
Of further interest is our study to identify and to quantify potentjjj
radiation exposure pathways for humans and other biota living within the
sphere of influence of the several facilities. These are necessary to
establish an environmental monitoring program which will effectively
quantify unusual conditions as well as monitor normal conditions antici-
pated. My written statement discusses the exposure pathways related to
PFDL and compares their maximum impact with natural background levels.
In each instance, the maximum potential exposure is a small fraction of
the natural background. It is important that a continuing study be con-
ducted to 'refine models as knowledge is gained and to evaluate operating
data as it is generated, and Westinghouse is doing this.
Several reliable predictions are available projecting uses of
plutonium, both in light-water and breeder reactors for commercial power
generation. The Westinghouse forecast is presented in the written state-
ment for the period 1975-1990, and the data are consistent with those
estimated by the AEC. It shows a cumulative usage of less than 200
metric tons of plutonium by 1985 and approximately 1400 metric tons by
the year 2000. The curve shows slow initial growth in usage, relatively
large increases after 1985, and ultimately the changeover in application
from recycle in LWR plants to use by the breeder industry. The gradual
start means another decade is available for resolution of ultimate waste
disposal and for refinement of safeguards.
-------
806
- 8 -
The Westinghouse Recycle Fuels Plant (RFP) will be the first fuel
fabrication facility sized to process large quantities of plutonium.
Environmental and safety analysis reports for this facility are detailed
in Docket No. 70-1432, wherein the plutonium confinement practices are
evaluated in depth. Briefly, the manufacturing building will be designed
to withstand earthquake and tornado conditions and, within this structure,
a second specially shielded "canyon" will house all the equipment required
to fabricate plutonium fuel. Jhis canyon serves the dual purpose of
positively confining the plutonium to a restricted area together with
providing protection for all personnel. Of particular interest is the
ventilation system which is designed to remain functional under design
basis accident concli Liuiib including a Lornado or earthquake. Ihe high
efficiency filtering system is also protected with a fire suppression
system and, of course, all exhausts will be continuously monitored.
Current regulations require that the facility must have the capability
of being decontaminated and decommissioned. Since the design of the canyon
must necessarily provide for equipment maintenance and replacement, many
features required for decommissioning are inherent in the design. The
systems and barriers can all be removed and packaged for ultimate disposal.
-------
807
- 9 -
Conclusion
At present, the number of commercial facilities handling plutonium
is small. The environmental and safety requirements for such facilities
are already rigorous and demanding. These requirements reflect the
cumulative experience of a variety of operations under AEC control and
the newer demands of NEPA. Benefits are also resulting from the continu-
ing and extensive AEC-supported R&D programs related to environmental
transport and health effects.
Much of this information is new, and its application will be factored
iriio the new or planned commercial facilities. Consequently, it may be a
few years before extensive experience and data are obtained on the actual
releases from such facilities and their environmental pathways. While we
are confident that the results will confirm what we are finding at the
PFDL -- that plant operation has a negligible effect on the environment --
it is appropriate to obtain further data before modifying the existing
standards. We believe that the current regulations and procedures for
controlling releases, of plutonium and the other transuranium elements are
adequate, and there is merit in obtaining further operational experience
and R&D results before developing revised or additional standards.
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- ID -
The slow increase in plutonium utilization during the next decade
affords an opportunity to institute a well planned program of data
acquisition and environmental impact confirmation. Environmental
standards for plutonium can then be rationally modified, if necessary,
based on experience and need. Westinghouse endorses an effort of this
type and pledges its cooperation with the cognizant regulatory agencies,
In the interim, it would be appropriate to continue to utilize the
currently conservative regulations and guidelines for plutonium.
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ATTACHMENT
DETAILED COMMENTS
General
The general factors to be considered in the cost-benefit analysis
include the following:
a. present environmental standards:
(i) costs of equipment and energy
(ii) risks
b. present operational standards
(i) costs of equipment and energy
(i i) ri s ks
c. reliability of extrapolation from operational limits to ambient
environmental standards
d. incremental costs and risks from the sources within the fuel
cycle
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- 2 -
e
. differences between known potential adverse consequences and
estimates of upper limits of potential adverse consequences
f. existing or presently planned facilities
(i) equipment costs
(ii) energy costs by requiring modifications
(iii) risks if retrofitting is not applied.
Applications Using Plutonium
The principal use of plutonium will be as a fuel in the generation
of commercial nuclear power, West.ingho'.i^p, ?s a supplier to the nuclear
industry, is involved and concerned with that application both in Light
Water Reactors (LWRs) and Liquid Metal Fast Breeder Reactors (LMFBRs).
The actual amounts of plutonium available for fabrication as fuel
at any point in time will be dependent primarily on the prior size of
the nuclear power industry, and many forecasts are available in the
literature. Two of these predictions considered to be most reliable
are those published by the AEC in the draft environmental impact state-
ments for the breeder industry (WASH-1535) , and for plutonium recycle
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811
"" 3 "*
o
(WASH-1327) . Values for plutonium production and usage over a 50-year
period trace the development of the breeder industry in the earlier of
these documents, and the shorter-range recycle within LWR plants is
covered in the other. The Westinghouse forecast for plutonium usage
during the period through 1990 is shown in Figure 1, and agreement within
the range of AEC sensitivity studies is reasonable.
Some significant points in this prediction are the slow initial
growth in plutonium usage, the relatively large increases after about
1985, and the changeover in application from recycle in LWR plants to
use by the breeder industry. The slow start provides another decade
for full development of solutions to safeguards and waste disposal
situations currently under continuing evaluations. During the period
of fast growth in plutonium supply through the 1990's, a commercial
breeder industry is also expected to expand rapidly. At some point
around year 2000, plutonium recycle will no longer be able to compete
economically, and the breeder industry should utilize essentially all
plutonium supplies. Pinpointing-that date is relatively unimportant
in respect to environmental factors, since adequate safeguards and
safety measures will be provided to protect both the public and the
environment regardless of the specific application. Hestingnouse also
expects to be involved in fabrication of both fuel types well in advance
of that date.
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812
- 4 -
In respect to the inquiry concerning possible releases to the
environment, Westinghouse has accumulated release data from five years
of operation of the Plutonium Fuels Development Laboratory (PFDL) at
Cheswick, Pennsylvania, and this information is detailed in the site
environmental report Docket Number 70-1142. Based on this operational
experience of PFDL and in compliance with criteria set forth in 10CFR20,
70, 73 and other federal, state and local requirements, the Westinghouse
Recycle Fuels Plant (RFP) is being designed for operation in about 1979.
An environmental report for this site and facility is detailed in Docket
Number 70-1432.
A'ltnough the recycle of plutonium as a fuel in nuclear reactors
increases the quantity of in-core plutonium, this material is not a
significant component of the radioactivity in the waste and effluents,
nor will it increase the volume of waste and effluents. Also, no
significant contribution is expected from the LMFBR system where the
in-core plutonium content will be higher than in LWRs.
The overall environmental effects of reactor utilization of plutonium
1 2
are discussed in detail in the AEC environmental reports ' . Westinghcuse
concurs with the conclusions in these documents, that plutonium can be and
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- 5 -
should be utilized for economic power generation with adequate protection
to the environment. These documents stress the fact that existing environ-
mental design requirements and features are constantly being evaluated and
improved. A principal concern in the utilization of plutonium has been
application of proper security and safeguards measures, and continuing
efforts on the part of both the AEC and industry are improving these
aspects of plutonium utilization.
Con tro 1 _ and C_1_e an up Te ch no 1 o qy
Plutonium fuel fabrication operations are performed in facilities
with engineered physical barriers and ventilation systems designed to
confine plutonium. In general, existing facilities utilize glove boxes
as physical barriers, and directional air flow to protect and isolate
the workers from plutonium and also to eliminate release to the
environment.
The air and gaseous effluents pass through at least two high
efficiency particulate air (HEPA) filters in series. These filters are
tested individually and in place using DOP (diocty phthalate) to assure
a minimum efficiency of 99.97%. In addition, the exhaust is continuously
monitored and shut down in the unlikely event that plutonium is detected
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- 6 -
in the exhaust air. The air is also sampled and sensitive analysis of
the samples made in order to monitor the operations at very low concen-
trations.
Liquid waste from operations within the confinement system is
solidified or evaporated and packaged for transport to a transuranium
solid waste disposal site. Liquid effluents from areas outside of the
confinement systems are quarantined and analyzed to verify that the
Plutonium concentration is acceptable prior to release. If plutonium
is found, techniques such as precipitation, filtration, evaporation anr<
ion exchange are employed to remove the plutonium, and the effluent is
ctyain quarantined and analyzed to verify the removal prior to release.
1'Iestinghouse is convinced that technology to control and restrict
the release of plutonium to the environment from fuel fabrication opera-
tions is feasible and has been demonstrated at the Westinghouse PFDL
and further extended into the design for the RFP.
Another inquiry was made concerning availability of technology to
restore fuel fabrication facilities which become obsolete or are shut-
down for other reasons to general use. Hith the exception of the
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815
- 7 -
confinement system, these facilities will be maintained free of plutonium
contamination during the operational period. These confinement systems
must then be decontaminated to levels required for disposal and the
remaining contamination must be fixed in place to aid in contamination
control during removal and transportation. These systems or barriers
can then be removed and packaged for disposal at a designated transuranium
waste disposal facility. Final cleanup of the basic structures can then
be completed. Features to facilitate decontamination and decommissioning
will be included in the facility design. Thus, current cleanup and con-
trol technologies are adequate for fuel fabrication facility decommission-
ing. The plutonium fabrication facility owned by Gulf-United Nuclear and
located in Pawling, New York, is illustrative of a plant being returned
to general use. According to a former Gulf-United Nuclear official, the
facility has been decontaminated and a request is being made to the AEC
to release the facility. The decommissioning of the Elk River Reactor
Plant is another example that available technology is suitable. This
decontamination program is reported in a series identified as Docket
Number 70-1151.
A document entitled "Program Plan for Decontamination and Decommis-
sioning the EBR-1 Complex at NRTS" (CONF-740406-21, 1974) has also been
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816
- 8 -
submitted to the AEC by Aerojet Nuclear Company. This program provides
for the removal and processing of the EBR alkali metal coolant (the
eutectic alloy of sodium and potassium), the decontamination of all
radioactive contaminated portions of the complex, the demolition and
removal of those portions which could not be made safe and/or detract
from general appearance of the area, and rendering of EBR-1 safe for the
public use and enjoyment as a registered national historic monument.
These examples cited demonstrate that the necessary technology and
expertise is available to restore nuclear facilities to conditions
acceptable for general use by the public.
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DC
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II
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°i
LU S
&^
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818
PLUTONIUM AND THE TRANSURANIUM ELEMENTS
Testimony of
Dr. James H. Wright, Director
Westinghouse Environmental Systems Department
Before the
Hearing Panel of the Office of Radiation Programs
Environmental Protection Agency
December 11, 1974
Washington, D.C.
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819
I am James H. Wright. I reside at 1195 Colgate Drive, Monroeville,
Pennsylvania. I am director of the Westinghouse Environmental Systems
Department. My educational background, including a Ph.D. in Chemical
Engineering, and 30 years of professional experience in the field of
energy systems and related environmental effects are detailed in the
attached biographical information.
The following comments relate to your questions on environmental
effects and on environmental levels and pathways.
It seems to me that any discussion regarding these factors as related
to plutonium and transuranic elements must be continuously reviewed in the
light of general ambient environmental levels of plutonium from bomb fallout,
In the time period 1951 to 1962 approximately 300,000 Curies of
plutonium were dispersed in the world atmosphere with approximately
10 to 25,000 Curies over the United States. It would seem clear that a
study of the dispersion and ultimate distribution of this high quantity
of plutonium would provide profoundly significant results regarding overall
plutonium migration and pathways to man. We have made only a cursory
appraisal of this situation, using data reported in the literature, and
are convinced that much important information bearing on your deliberations
here can be obtained.
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820
In our simple study we attempted to develop a material balance
based on reported plutonium concentrations in the environment. Starting
with the atmospheric source terms just mentioned, we find that most of
the plutonium is in soil and sediment and water with only a few Curies
remaining in the atmosphere. From other data we have estimated that the
total human population of the world has a burden of plutonium, at the
present time, of probably less than 1/10 of a Curie. This point suggests
that gross effects of all pathways to man from atmospheric plutonium
releases has an attenuation factor through the environment of 3,000,000
to 30,000,000: for each million units of plutonium released to the
atmosphere less than one unit of plutonium vectors to and is retained by
the world population. (Bair, W. J., Richmond, C. R., and Wachholz,
B. W., A Radiological Assessment of the Spatial Distribution of Radiation
Dose from Inhaled Plutonium, U.S.A.E.C., September 1974, p. 29, WASH-1320.)
(UNSCEAR, Ionizing Radiation Levels and Effects, Volume I: Levels, United
Nations, 1972, p. 54.)
This preliminary study poses some interesting considerations with
regard to the regulation of plutonium in the environment:
1. The world's population may have had a higher burden in the lungs
in the recent past when atmospheric contamination from plutonium was
much higher, and the pathway from lungs through the blood to bone,
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821
kidneys, liver, and lymph nodes could account for most of the
current body burden.
2. The soil seems to be the principal repository for environmental
Plutonium. This repository seemingly provides a highly limited
mechanism for a pathway to man. This suggests the possible
concept of "environmentally inactive" plutonium.
3. Leafy plants consumed by man may be significant pathways to man-
particularly smokers.
4. The data provided by Bair, et al., also suggests that the body
burdens of the non-occupationally exposed man near facilities
handling plutonium do not vary greatly from the general
population. This could mean that the dominant pathway is not
associated with distance, but is related to some common trans-
port system, such as smoking, that is essentially independent
of distance.
5. The consideration of fallout plutonium seems to establish
considerable doubt on the pathway and dose modeling used by EPA
(EPA 520/4-73-002) studies on environmental dose commitment as
applied to nuclear power. Specifically, we have several
problems with this study:
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822
(1) The source terms for a given plutonlum handling facility
o
were suggested to have an atmospheric release of 10 or
_g
10 of the plutonium throughput. It is also suggested
in this report that future operations may even be lower
than this. Our experience verifies the latter statement.
But, the report then proceeds to integrate over several
facilities and erroneously concludes that the summation
or fraction released for the total industry is 100 times
greater than the fraction released from a single operation.
This is patently absurd. The fraction is, after all, a
fraction of the total throughput or inventory. This EPA
estimate of source term is high by a factor of at least
100.
(2) The pathway model to man contains an apparent gross error
(overestimate) in that the plutonium concentration was
obtained from a X/Q dispersion of atmospheric releases
at 3 km from the plant and, then, this concentration was
uniformly applied to 1,500,000 to 15,000,000 people
assumed to be living within 80 km of the plant. At the
Recycle Fuels Plant and the Clinch River Breeder Reactor
Plant, a population density of less than 10,000 people
within 3 km is a more typical population density. For
fifty such facilities sometime in the next century, the
population dose actually expected would be 100 to 1000
times less than the exposure model apparently incorporated
in this EPA report.
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823
(3) The effective pathway beyond the 3 km dispersion zone
would be best approximated using the dispersal, pathway
and uptake information which can be inferred and derived
from plutonium fallout. These data infer that only one
part per 30,000,000 of the plutonium released found its
way to man. The EPA vectors more than 1000 times as
much to man. The concept of resuspension of plutonium
from the soil was incorporated by EPA but is clearly not
demonstrated in the behavior of the fallout plutonium.
(4) We certainly agree that standards for protecting the
public health of our citizens should be established
from a reasonable consideration of probable source terms,
pathways through the environment and reconcentration in
the ecosystem, and dose effects. We take no issue with
the increased dose conversion factor which EPA incorporated
but we feel that a study containing accumulative errors
(overestimates) of more than 10,000,000 from source to
man in predicting health effects serves no useful value
whatsoever but it does alarm, unnecessarily, government
regulators, industry and the general public.
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824
We would strongly urge EPA to Intensively Investigate the environ-
mental fate of prior weapons plutonium fallout 1n hope of developing and
testing pathway models in the total environment and, hence, provide
much better interpretation of the significance of general ambient environ-
mental plutonium.
Residual plutonium from bomb fallout also has a significant effect
on the relative impact of plutonium released from the fuel cycle operation
and on our ability to discriminate plutonium from fuel cycle operations
in the environment.
We are conducting environmental studies of the Westinghouse Plutonium
Fuel Development Laboratory (PFDL) located at Cheswick, Pennsylvania.
Liquid and gaseous effluents have been measured during the five years
of operation of this plant in order to determine compliance with
10 CFR 20. The effluent releases of plutonium and transuranic elements
from this facility have been held to a very low level -- within a small
fraction of 10 CFR 20. From our experience it would appear that plutonium
fabrication plants will not be a significant source of environmental
plutonium.
Environmental monitoring has been conducted at this plant over the
past year and many samples reflect less than detectable concentrations
of plutonium. At these very low environmental levels resulting from
plant operations, the problem of discriminating background plutonium from
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825
plant released plutonium is a most difficult problem. Furthermore, the
plutonium background fluctuates widely (a factor of 8 or 10 in air, for
example) further compounding the problem of discrimination. These
data are contained in our environmental report on that facility recently
submitted to the AEC. (Note: environmental reports in four large
volumes were submitted for the record. They are available for
review in the Office of Radiation Programs, EPA, Washington, D.C.)
Additional studies have been conducted by WESD at proposed sites
for new plutonium handling facilities -- the Recycle Fuels Plant -- a
facility for the fabrication of plutonium recycle fuel to light water
reactors, and the Clinch River Breeder Demonstration Plant. In these
cases we felt that is was particularly important to make an accurate
determination of plutonium background long before any plutonium was
brought on the site. We have encountered continued difficulties in satis-
factorily determining background levels to the precision required to allow
us to discriminate the small additional plutonium burden anticipated from
the operation of these facilities. Particular difficulty has been encoun-
tered in obtaining reliable sampling and analysis of the biota.
In all of these cases, we have attempted to determine, by calculation,
the dose through pathways to man (See Figure 1) as well as the resulting
effects on the general ambient environment including biota. We have
encountered particular difficulty with regard to monitoring animals -- fish
and mice. Using duplicate samples and, eventually, spiked samples, we found
that the problems involved in sampling and analyzing low level plutonium
gave a wide variation in results. Retrospectively, it would appear that the
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826 s
costs of these low level determinations are not justified by the benefits
of the results to ourselves, our clients or to our society.
We believe that low level releases (one hundredth or less of MPC)
can be monitored at the plant with reasonable accuracy but that the
probable error in environmental sampling and analysis at or below general
background in an environment having wide fluctuations in that background
can be expected to be very large. In the case of animal sampling, the
error, generally an overestimate, can be as high as a factor of 10 or
even 100.
Our conclusions are that calculated concentrations and doses through
the various pathways are more meaningful than environmental sampling at
the low concentrations found in the operation of PFDL.
The dispersion of plutonium releases to water have been both calcu-
lated and measured at PFDL. The results indicate that the calculated
dispersion pathway was in reasonable agreement with the environmental
monitoring. At PFDL, the principal pathway of plutonium to man was calcu-
lated to be through fish feeding in the creek receiving the storm sewer
outfall from the plant. A human's diet of 50 grams per day of fish from
that creek could produce a plutonium bone dose of less than 1 mrem/yr.
In the fish survey conducted, no edible fish were found in that creek.
A few hundred feet downstream from the plant, the creek flows into the
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827
Allegheny River. The dilution occurring here greatly reduces the plu-
tonium content in the water and in biota growing there.
Air dispersion of plutonium from the plant stacks to the ambient
air have been both calculated and measured. Calculated dispersion
concentrations yield results that are less than 1% of background
plutonium at our on-site monitors and, hence, have not provided a
quantitative basis for comparison of calculated and measured dispersed
concentrations.
During the five years of PFDL operations, gross a has been monitored
in the stack effluent. For conservatism, the gross a has been assumed to
be due to plutonium 238, 239 and 240. During the past year, isotopic
analysis measurements of a emitters in the stack effluent have indicated
that the plutonium represents less than 10% of the gross a activity. Sub-
sequent analysis has identified that most of the remaining a activity is
from uranium. In the identification of the plutonium isotopes, we have
used the a energy to discriminate between Pu 238 and Pu 239. Americium
241 is included with the Pu 238 because the energies are so similiar we
have not been able to discriminate at this time. The dose calculations
have been based on the assumption that all of the a activity including
uranium and americium is soluble plutonium.
In the present fuel used at the PFDL the specific activity of
plutonium 241 is 34 times greater than the specific activity of all
the a emitting plutonium isotopes. Therefore, in dose calculations,
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828 10
we assume that there is 34 times as much Pu 241 beta activity as measured
or calculated a activity. Attempts to check this assumption suggest
that a 3 to a specific activity ratio of 20 to 1 is indicated. Because
of higher volatility americium should conform to our estimated atmospheric
dispersion models as well as or better than Pu.
-------
ii 829
Recommendations
From our experience in environmental studies of transuranic elements it
would most certainly appear that the general ambient environment has a
(variable) plutonium content generally much higher than the increment of
Plutonium from fuel fabrication. I recommend these actions for EPA with
regard to this problem:
1. EPA should establish standard sampling and analytical
procedures for environmental plutonium.
2. EPA should consider qualifying vendors for plutonium
analysis.
3. EPA should prepare environmental monitoring guidelines for
plutonium and transuranics with specific considerations for
tracing low level plutonium; e.g. when environmental concentra-
tion of plant plutonium is calculated to be a small fraction of
ambient plutonium background, infrequent environmental monitor-
ing is required just to verify the general low level. With
regard to other transuranic elements I recommend that EPA suggest
guidelines for routine industrial isotopic analysis in order to
be certain emission monitoring is conducted and reported on a
consistent basis.
-------
830
12
I recommend that EPA conduct such research on the chemical fate of plutonium
and other transuranics such that dispersion in air and water can be treated
on a more realistic basis (particularly resolving the solubility question).
I strongly urge that EPA conduct extensive analyses of the fate of bomb
fallout plutonium in the environment with the specific objective of determining
demonstrated paths to man and, then, to use these results in future pathway and
dose models used evaluating or setting future standards.
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831
NOUV1VHNI ONV ONINNIMS
o
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832
ATTACHMENT
BIOGRAPHY
OF
DR. JAMES H. WRIGHT
Dr. James H. Wright is Director of the Environmental Systems Department
of the Westinghouse Electric Corporation. In this position he is responsible
for organizing and managing a unique team of environmental experts involved
in analyzing and interpreting environmental problems associated with electric
power production and transmission and in assisting utilities and government
regulatory agencies in solving these problems. His Department has con-
ducted environmental studies for industry or governmental agencies in
over half of the fifty states in the United States, the Commonwealth of
Puerto Rico, Italy, France, Romania and Japan, and many of its members
are internationally recognized experts in the environmental impact of
power systems operations. His Department also conducts the Westinghouse
International School for Environmental Management.
Dr. Wright holds a bachelor's degree in Chemical Engineering from
Texas Tech University and a master's and Ph.D. degree in chemical
engineering from the University of Pittsburgh. His professional career
began in the oil fields of Texas developing and operating the first
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833
industrial desulfurization plant for natural gas and he continued his
research in desulfurization of petroleum and ionizing radiation in later
work at Mellon Institute of Industrial Research.
Dr. Wright joined the Westinghouse nuclear program in 1956 as a
reactor physicist and has since held key positions (Manager, Advanced
Reactor Systems and Technical Director, Advanced Reactors Divisions) of
responsibility in designing, development and planning nuclear tehcnology
and projects. Before his present assignment, he was Senior Consultant
to the Executive Vice President for Westinghouse Nuclear Energy Systems.
Dr. Wright has been working the fields of energy systems and pollution
abatement in areas of design, research and development, construction,
operation of energy use processes and environmental effects for more than
20 years and has published more than ninety papers in the technical
literature, holding numerous patents for pollution abatement processes.
Dr. Wright is a member of several professional societies including the
American Institute of Chemical Engineers, the American Chemical Society,
the American Society of Engineering Education and the American Nuclear
Society and is a registered professional engineer in the State of Penn-
sylvania. He is also a consultant to various government agencies, including
the President's National Water Commission, and serves on the Committee on
Power Plant Siting for the National Academy of Engineers.
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834
Dr. Wright is a dedicated conservationist, an ardent fisherman, an
amateur mountaineer and maintains an active membership in the Sierra
Club, Trout Unlimited and other responsible environmental organizations,
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835
Dr. Mills: Thank you, Dr. Wright.
I notice in your recommendation you do not recommend that EPA
set standards for plutonium.
Dr. Wright: No, I did not.
Dr. Mills: I have an initial question for Mr. Kramer. Could you
give me a comment, please?
In one case we are talking about planned releases of plutonium in
fuel fabrication plants and so forth; in another case, we are talking
about those I would classify as activities in which our concern is
with standards that are to keep the plutonium out of the environment.
Is it the decommission aspect we are talking about, or restorative kind,
to put the environment back? Would you care to comment on how you see
the differences in these two types of standards?
Mr. Kramer: I think the first commitment we have is to be certain
in the design of the plant that any possible releases and exposures,
not only to the public at large, but to the people working in the plant,
are kept to an absolute minimum.
I think in a sense by doing that you already have come part of
the way in achieving the second part of the goal, the ultimate restora-
tion of the environment.
I cannot really speak in great detail to that latter aspect. I
did note in reading this article which I referred to, they have pretty
high levels of activities. I guess it was at the Savannah River Plant
where this dismantling took place.
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836
By going through a very carefully planned program, I believe they
were able to package up the material and equipment and actually dispose
of it.
Our particular design in our recycled fuels plant is going to be
devoted more towards internal, inside the plant decontamination of equip-
ment in a special facility, away from the basic process which will allow
us to reuse or repair equipment and keep it on plant site rather than
ship things offsite unnecessarily.
Dr. Mills: What I had in mind, let us take the current standards.
The current federal radiation guides that were incorporated under the
AEG regulations, that is, recognizing that you are not planning to
release in any kind of fashion — What I am trying to get to is, is it
reasonable to assume that we may, in fact, have to establish one type
of standard to restore the environment as opposed to a different kind
of standard when you are talking of preventive modes?
In this reasonable? I could discuss, Dr. Wright, to some length
the EPA environmental dose commitment paper; however, I do not think we
have the time. But I will write to you and respond.
One point having to do with the resuspension or the loss in
inventory; you made the comment that the number had been taken from
one single operation to the end. I think the careful reading of that
would probably indicate the extension to the industry as a whole was
the loss in the whole inventory, not what each plant was supposed
to do from a single operation.
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837
That is the fuel fabrication plant. It addressed the question of
the loss of plutonium across the board in the matter of transportation
or what have you.
Dr. Wright: I recognize that I could not tell where a major change
or effect occurred. I had assumed it had something to do with transpor-
tation, but I would like to discuss it with you at another time.
Dr. Mills: Dr. First?
Dr. First: First, on your discussion of the experience with the
PFDL and then the extrapolation of this information to the plant that
you are currently putting together, what are the relative sizes?
And will the emissions be in proportion to the scale up factor?
Mr. Kramer: The PFDL at this time has a capacity of approximately
five to ten metric tons of fabricated mixed oxide fuel per year. The
initial design level for the recycle fuels plant is 175 tons, but I
believe our environmental report and license application was based on
a 350 ton size.
So it is an extrapolation factor of 35 to 70.
I will let Jim answer the second part of the question.
Dr. Wright: In looking at the plutonium releases, we assume many
relationships between tons and releases. We used the performance
numbers of the little plant and said, that is what the big plant would
be.
Dr. First: Presumably, the emissions to the atmosphere, at least,
would land at about the same places in the environment. We would then
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838
have an increase of 35 to 70 times on the concentrations at maximum
ground level.
Is that correct?
Dr. Wright: No, because there is an entirely different air flow,
air mixing and dispersion scheme. There is an entirely different basis
of site parameters there.
So the calculated concentrations, while the quantity is up by a
factor of 35 to 70, the concentrations factor because of this, varies
by a factor of, I think, about three instead of 35 to 70.
Ur. First: Looking at your recommendation that we should look to
the fallout information for interpretation of plant emissions, I am
wondering whether the analogy is exact enough in terms of the chemical
form and physical form; the fact that around an operating plant, we will
have plutonium deposited in a steep gradient, I would think, rather than
a very uniform deposition.
~L am sure there are other differences. Would you care to comment
on that?
Dr. Wright: Yes. I believe as long as it is deposited, the fact
that it may be in a steep gradient or not, to my way of thinking, it
becomes a far less difficult problem to deal with.
It's that which is still in the air which is a greater concern to
me, because again, the resuspension is fairly low, probably.
In a country like Pennsylvania that has a fair amount of continuing
rain and moisture— I have forgotten the first part of your question.
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839
Dr. First: It was related to whether the analogy is close enough
with a good deal of certainty.
Dr. Wright: Yes. I certainly would not advise that there is a
one to one relationship, but I suspect, and this point has been made
twice by Dr. Radford in discussions but with others, it has been
discussed extensively in the halls —
Again, I did not understand in the EPA model, I do not believe the
gradient system was used. If it were, then the minimum dosage would
have been far, far less. I believe they used a much broader dispersal
area, because that is the only way to have gotten enough people exposed
to even get some indication of this.
I was more or less going along with the EPA idea saying, this would
be over a wide dispersion.
Point three, the comparison of the fallout with the plutonium from
fuel fabrication plants may be very close indeed. I am not beginning
to suggest that it is as similarly close for the processing plants, but
from the fuel fabrication plants, we have a typical mass median diameter
that would be 0.3 of a micron for plutonium oxide material.
Thermodynamically, one certainly would predict the bomb test
fallout is in the form of plutonium oxide. One finds also from other
evidence that they are using .4 particles in the air aerosols as a sink
for the plutonium that went into the atmosphere from the bomb.
So I think there is far more similarity there. I think this
hearing has done a great deal towards developing considerably more
similarity.
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Dr. First: Most of the material from the bomb, for example,
was under very high heat conditions; at least the few particles that
I have observed under the microscope has been sterile and quite distinct
in their shape and appearance.
I wonder whether this might have some influence in its redispersal
in the environment, for example. I am not saying this is true. I am
just bringing up the general question of the relationship.
Dr. Wright: Certainly I am not claiming one for one, but I think
the fact that these particles are said to go on to .4 micron aerosols
suggests that as far as pathways to man, there is a great deal of
similarity.
Dr. Mills: Dr. Radford?
Dr. Radford: I would like to ask Mr. Kramer first, at the end of
his presentation, he implied a change in the current standards for plu-
tonium could be modified at a subsequent time.
Based on experience and need, I think, is the wording here. Now,
we have heard from various people, including Dr. Parker and Dr. Morgan,
I believe also, and others, that maybe there should be some predominant
revision of the plutonium standard at this time, somewhere between a
factor of ten and 100, depending on the number of factors.
I get the impression from Jim Wright's presentation that this would
cause no difficulty whatever to Westinghouse in operating its fuel
fabrication facility. Is that correct?
Mr. Kramer: Based on the experience we have had today, I would
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have to say that we would be able to meet such new regulations.
Dr. Radford: All right. Now, you state that the environmental
safety requirements for such a facility, this is a commercial facility
handling plutonium, are already rigorous and demanding.
Does that mean that all plutonium handling facilities might have
difficulty in meeting more stringent standards?
Mr. Kramer: I am afraid that is a question which I have not got
the experience or information to be able to talk about. I can discuss
our facility, but I am really not aware of detailed experience from
others, whether that would be a true statement or not.
Dr. Radford: Well, I asked the representative from another company
which will remain nameless, whether he thought that the handling of plu-
tonium at other facilities had been appropriate, proper, et cetera,
other than his own, so I am asking you the same question.
Do you think that meeting these rigorous and demanding standards
has been achieved at other commercial facilities?
Dr. Wright: You threw me with that clause, you put "other
commercial facilities" right at the end.
Dr. Radford: OK. I am making it commercial facilities.
Dr. Wright: The reprocessing plants certainly constitute a pro-
blem to everyone; whether or not they constitute a problem at this
moment, as the growth of nuclear power suggests that it would be well
in time to establish a total curie limit in addition to 10 CFR 20 limits,
which to my mind, are probably reasonable at the present time, from
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everything I have heard over these two days.
Dr. Radford: With regard to operation of new plants, how would
you characterize, either of you gentlemen, the performance characteris-
tics so far in the whole nuclear cycle, as far as meeting emission limits
and things of that type? Would you say it has been good, bad, or
indifferent?
Dr. Wright: I would like refer on this to our plutonium fuel
fabrication here. I think, as far as I know— I was thinking about the
other, the unnamed guy. As far as they are concerned, I have no pro-
blem, but there are some other parties which suggest —
Now, what was your question?
Dr. Radford: One of the issues very central to this matter is that
much of the technology that we are talking about in dealing with alpha
emitters in plutonium recycling is not on line.
It is projected. We do not have a body of experience. You have
a pilot plant operation with five to ten tons per year. Are you going
to scale it up to 350?
The point I am trying to make is, when such scale-ups have occurred
throughout the nuclear industries, have in general the projections
panned out?
Dr. Wright: 1 am sorry. 1 misinterpreted your question. I think
generally, Dr. Radford, it certainly has projected out. What it amounted
to, when we got the large plants and started measuring, in every case
that I am aware of, we have found that large plants are better than
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we would have extrapolated them to be from the total information on
the smaller plants.
Dr. Radford: Specifically scaling up the number of fuel rods,
did not Westinghouse experience some unexpected cladding problems
when you went to scale up?
Dr. Wright: No. That was not a scale-up.
Mr. Kramer: This was not associated with scale-up, Dr. Radford.
They were associated with specific, single, and I might say one-time
occurrences, which were corrected and have not recurred.
The causes of the specific instances to which 1 think you are
referring were not in any way associated with the size or volume effects.
Dr. Radford: But it is fair to say there was an unanticipated
occurrence?
Dr. Wright: This was a design change; a new fuel element was
developed, and with just a small number of modifications, it created
problems.
But it really was not related to scale. I have no evidence that
would suggest that our problems come on as we go up in scale. My
evidence suggests the contrary.
Dr. Radford: Maybe the PWR has been lucky in this regard. What
is the throughput on the current leading plant, fuel fabrication plant?
Mr. Kramer: I do not know.
Dr. Radford: Is it bigger thai; yours or smaller than yours, the
one in Oklahoma?
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Mr. Kramer: Bigger than PFDL? I have no idea what the size of
that plant is.
Dr. Radford: Does it even make oxide fuel commercially?
Mr. Kramer: I do not know.
Dr. Wright: That is why I stopped.
Dr. Radford: I have, I think, just one more question here.
I have no disagreement with several of your recommendations
which obviously are aimed at fuel fabrication facilities.
Would you just make some record statement as to how much more
difficult you think the problem may be in the fuel reprocessing
facilities than you believe they may be for fuel fabrication
facilities in containing the transuranics?
Dr. Wright: Certainly they have a much more difficult problem
to begin with. They have all the radioactive isotopes from the fuel
to deal with. They, fortunately, take out most of the curium, or we
never see any.
They definitely have a much larger problem than we do from the
feedstock that they have to deal with. I am persuaded that a good
processing of fuel, considerable recycling of liquids, can do a good
job; but it is a much more difficult job than what we are involved in.
I think I would better leave by just saying that it is a much more
difficult job.
Dr. Mills: Dr. Garner?
Dr. Garner: I would like to make just one comment rather than put
in a question.
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Several people during the course of these hearings have suggested
that we have plenty of time to conduct research programs. You mentioned
there is going to be a slow building up that would give us plenty of
time to monitor such programs.
I would like to point out many of the research programs we need
to resolve the problems we are faced with take considerably longer
than ten years to accomplish, and we would be in a very much worse
position than we are.
I would like to say this. It has taken much foresight. We are
to start the second set of experiments.
Dr. Wright: My recommendations dealt specifically with your
comment. Let us get on with research now.
Dr. Mills: Dr. Morgan?
Dr. Morgan: Dr. Kramer, you indicated that Westinghouse engaged
in detailed evaluations of the impact of plutonium, perhaps mostly
from the LMFBR operations and associated operations.
Have you carried out detailed studies, also, in reference to the
fact breeder LMFBR and the light-water reactors?
Mr. Kramer: Most of the evaluations to which I referred and those
which I aia personally familiar with are in regard to recycle fuel in
light-water reactors.
I do not know, Jim, whether you can address the LMFBR question?
Dr. Wright: Yes. I think the question was answered by Dr. Rogers
just a few moments ago. We can certainly respect the performance of
the breeder in fabricated fuel as well as the operation of its reactor.
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846
We would expect the operation of the reactor would be comparable
in terms of transuranic elements, in this light-water reactor to be
comparable to what we are predicting for the mixed oxide fuels for
the light-water reactors. We can see no reason to predict otherwise.
Mr. Kramer: I might add that, to the extent that the breeder
uses a mixed oxide fuel, we do not see any differences in the basic
technology of fuel production between the light-water recycle or breeder
type fuel.
Dr. Morgan: One reason I asked is, I am a bit apprehensive in
studying over the draft reports of the analyzed fuel recycling, in
that they seem to assume that there be no additional problems, even in
the plant.
For example, working with gloveboxes when you have a fairly con-
sistent and effective neutron source and high gammas around from some
of the other actinide elements.
I hope these same inconsistencies are unreasonable assumptions,
that goes into the environment and estimates the risks.
I have another question. 1 suppose this refers more to some of
the discussions I'unfortunately missed yesterday; but in your text
and discussion, you mentioned it.
Namely, it is assumed, certainly in the draft report of the MOX
fuels that it is economically essential or very desirable to use this
plutonium mixed oxide in light-water reactors, but there are some nuclear
engineers that do not agree with this.
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847
They feel that if the LMFBRs are willing to make their imprint
in time and to supply their own sources, that there will be a scarcity
of plutonium and there will have to be some way of supplementing it.
Perhaps you have some comment on this?
Dr. Wright: Yes. I think that both points are right. If we had
the breeders and light-water reactors on an optimum schedule, we would
never perform any plutonium recycle. The plutonium would be, from the
first, fed into the breeder reactor.
The breeder reactor, in order for this to have happened, would
have to be entering into the commercial stage.
In 1980, where we would be building much or our breeders from
1980 on, use of the plutonium from light-water reactors in breeders
makes more sense, quite frankly; but our schedules are not coordinated.
The breeder is on a much more delayed schedule than the light-water
reactors. Instead of having a commercial industry starting up its first
breeders in 1980, there is some question whether or not we will have
a first prototype operating in 1980.
So the time scales on the breeder are such that it opens quite a
window for plutonium recycling.
Dr. Morgan: I gather, then, paraphrasing what you are saying,
is that this money that we have, it is better to invest it now at three
percent than wait later and invest it at ten percent?
Dr. Wright: Well stated, sir.
Dr. Morgan: Dr. Wright, I believe it was indicated that one over
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30 billion of the plutoniuia fallout found its way to man. Presumably,
this is the fallout that occurred, that which is accrued in man over the
relatively short period since atmospheric testing occurred.
But since even plutonium 239 has a long half-life, if we estimate
the infinity of these effects and assume continuous availability of
certain — this still may not be as good as we would like to have it.
Is that right?
Dr. Wright: I would view it somewhat differently, Dr. Morgan. I
would suggest if we integrated to infinity, we would get a diminishing
annual dose and therefore, any projections made on total dose today
would be because data shows that the atmospheric level where most of
our dose term has come from, up to the present time, is through the
atmosphere. It is diminishing quite rapidly, having reached a peak in
1963, and then falling.
Dr. Morgan: So this one part of 30 million was an annual basis?
Dr. Wright: That was a gross basis, total curies. It is inte-
grating over the 1950 to 1972 period. I think that is when the data
was actually produced, so it is an integral over a 20 year period, but
going down rather strongly since 1963 in man.
Dr. Morgan: I believe you have a greater confidence in monitoring
the plants than I would have from my limited experience. I gather that
if the levels were, I think you said, 100 or less of the MFC, that
monitoring the plant at least implied it can be relied upon.
Certainly, one would not neglect certain essential verification of
the released data because with some reactors the inputs released were
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849
not recognized, assumptions in meteorology that were not correct — So
I would think it would behoove us to store quite a bit of good data,
autopsy data, for example, from people living in the environment and
other information to verify this data we have, regardless of how low
the estimated releases are.
Dr. Wright: I certainly agree, and my conclusions recommend that
a frequent environmental monitoring certainly should be done to justify
the calculated low levels, that we must try to keep both ends of the
puzzle placed together.
I quite agree.
Dr. Mills: Thank you very much, gentlemen.
Dr. Rowe has indicated he would like to make an announcement.
Dr. Rowe: I just wanted to announce that we have scheduled
extensions of this hearing for January 10th at 9 o'clock in Denver,
at the Post Office Building.
It will be an extension of this record. It will not be a dupli-
cation of what has gone on. However, there will be new testimony
inserted.
We have five people who have requested us to have that hearing
in Denver, and the record will still be open for further entries at
that time.
Thank you.
Dr. Mills: Let us take a break and reconvene in ten minutes.
(Brief recess)
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850
The concluding participant on our agenda is Ms. Judith Johnsrud,
from the Environmental Coalition on Nuclear Power.
Ms. Johnsrud: Gentlemen, it is very late and you have questions
for the AEG panel.
My name is Judith Johnsrud from the state of Pennsylvania. I
am a geographer by profession.
As a geographer, and as a member of the Environmental Coalition
on Nuclear Power, which is one of the Middle Atlantic States organizations,
I looked rather carefully over the last few years at the Atomic Energy
Commission's documents and at industry publications.
I find a great deal to criticize, of course. I am distressed today
to hear the comment that we need not worry about plutonium that is
essentially grounded in the soil.
I wonder if perhaps the Westinghouse person who made this statement
has failed to consider deflations in periods of cyclical drought, for
example, which could very much change the locale. This is one example of
the kind of thing we find.
I am very much disturbed as this hearing has progressed at what I,
as a member of the public listening to the technical people speak, feel
is perhaps a diversion from the fundamental charge to this organization,
to EPA, and to this hearing board.
You are much wrapped up in the details of how much plutonium we
are to receive. This is how it appears to a member of the public. I
wonder, perhaps, if there is not a tendency in a standard setting body
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of this nature to consider the production, and therefore the need for
the standard to be a given of our society.
That is to say, in view of the manner in which the nuclear industry
has grown and the weapons industry as well, to say, well, yes, we must
have plutonium. Now our decision is to say how much plutonium.
Let me ask you, please, as you conclude this phase of the hearings,
to keep very carefully in mind the real nature of the decision that you
will be making, which is a decision for society; not for our society,
really, so much as for future societies.
Your decision on a standard allowable, which will in turn determine
the economic factors of a growing nuclear industry and perhaps weapons
industry continuing to grow, will affect far beyond all of us.
I do not say this with disrespect to you, but I do have the feeling
that the details of standard setting, perhaps, have overwhelmed your
remembrance of this, as charged.
Now, I hope not to have offended you. May I give my very brief
prepared statement, which will be much more general than what you have
been hearing; but I hope you will find it pertinent.
This statement on the environmental impact of plutonium and the
transuranium elements is provided for inclusion in the record of the
Environmental Protection Agency hearings on that subj ect pursuant to the
September 23, 1974, Federal Register notice 38FR24098, by the Environ-
mental Coalition on Nuclear Power, representing some thirty non-profit
public-interest citizens' organizations (approximately 10,000 members)
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in Pennsylvania, New Jersey, Delaware, and Virginia. Our organization's
member groups have participated in numerous reactor licensing proceed-
ings (1), in state and federal agency hearings on nuclear reactor safety,
siting, licensing and insurance issues (2), in varied public education
programs, and in successful opposition to the sitings of both a Plowshare
underground gas storage project and a Liquid Metal Fast Breeder Reactor
demonstration plant in Pennsylvania (3).
The Environmental Coalition recommends, at least for the near term
future, that a zero release standard be imposed on plutonium until the
obviously fragmentary research on its impact upon ecosystems and upon
man as well as the procedures for containment and control of plutonium
is much greater advanced than it appears to be now. Plutonium is a
man-made element; its extraordinary toxicity is attested to by others
more expert than we elsewhere in these hearings; the length of its
half-life makes of it in a human time scale an essentially permanent
biological hazard when any amount is released to the environment.
That perfect containment of plutonium by the Atomic Energy
Commission and U.S. military forces, much less by commercial users, can
be achieved is not borne out by the record to date. Atmospheric testing
during the 1950" s; the loss of a nuclear power generator SNAP-9A in
1964 (4); the loss of the plutonium power source in the lunar module
during the re-entry of the ill-fated Apollo 13 in 1970 (5); the Dow
Chemical Company's Rocky Flats plutonium plant fire in 1969, as well as
numerous earlier fires; the Hanford works Z-9 trench plutonium storage
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853
problem; and the Mound Laboratory loss of plutonium to the Old Erie
Canal, discovered in 1974 (7) are among instances of unplanned releases
of plutonium to the environment. The Washington Post has recently
carried a brief account of the EPA report of plutonium contamination
of the lungs of cattle downwind from the Rocky Flats plant near Denver,
Colorado (8). We would, in fact, amend our recommendation for a zero
release standard to a negative release standard, and call for concerted
effort by AEC's successor agencies and the military to recover and
permanently store the plutonium already released to the environment.
The information which we submit to this hearing board relates to a
particular aspect of control of special nuclear materials — namely,
blackmarket sales of plutonium. I include it to bring us back from the
theoretical calculations that the industry has given you, its intention
for perfect containment, to the way the world really works. In November
1973, individuals in our member groups were offered, through a reputable
and reliable acquaintance, an opportunity to purchase alleged stolen
plutonium. The particulars, as I received them, were these; the person
known to us, who might be termed a dedicated environmentalist himself,
had encountered an unnamed man who, in the course of conversation, men-
tioned that he had access to very valuable material that would fetch a
high blackmarket price. The figure named was $1000/gram. Our acquain-
tance pursued the subject, discovered the man was talking about plutonium,
and suggested that he knew of persons who might be interested in proving
that a stolen plutonium blackmarket is more than mere conjecture. The
offer came to us shortly after conclusion of Atomic Safety and Licensing
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854
Board hearings on an operating license for Metropolitan Edison's Three
Mile Island I reactor near Harrisburg, Pennsylvania, at which then-Com-
missioner Herbert S. Denenberg of the Pennsylvania Insurance Department
had testified as a witness for our intervenors. Apparent effort on the
part of the applicant's attorneys to block Dr. Denenberg's appearance
aroused a certain subsequent question in our minds about the authenticity
of the plutonium offer that came to us, as I recall, within a week of
termination of the hearings.
We had no way of assessing the validity of the offer. We were
unfamiliar with the proper legal procedure in such a situation. As
law-abiding individuals, we were reluctant to pursue the offer at all;
and yet an opportunity to demonstrate the ease with which this hazardous
material might be obtained was tempting. Therefore, we suggested that
the acquaintance try to learn more about the man who had made the
initial proposal while we tried to find out what authorities we should
contact. I would emphasize that it appeared to us mainly as an opportunity
to gain public notice of what seemed to be the reality of a plutonium
blackmarket.
Two or three weeks later, in early December, I spoke with a well-
known investigative reporter in Washington about the matter. He advised
precisely what we were doing; obtain more firm information before going
to the authorities. A few days later, the initial installment of
John McPhee's profile of Theordore B. Taylor was published in the New
York magazine. Lacking any further information about the man who had
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originated the offer, I concluded that we had insufficient facts to
pursue the matter further. Nuclear theft and diversion became a much
publicized issue through the efforts of Dr. Taylor and Mason Willrich
during 1974 (9). Our small incident seemed insignificant, compared with
the scenarios of sabotage and rings of international terrorists.
The point which we believe is pertinent to these proceedings, however,
is this; in trying to figure out a way to maximize the publicity (10)
value to be gained by proving the availability of illicit plutonium, one
person suggested the following: rent a plane, fly over the nearby reactor,
scatter the small quantity of plutonium, and then contact the press and
the AEC to inquire how accruately the monitoring devices had been able
to measure the amount released in the reactor vicinity. Those of us
who understood the toxicity of plutonium were appalled by this suggestion
and promptly squelched it.
It should be noted that Willrich and Taylor in general make the
assumption of malicious intent to use plutonium as an anti-personnel
device. But I suggest to this hearing board that, if a person devoted
to environmental protection was so ignorant of the biological hazard
presented by a minute quantity of plutonium, how much more ignorant are
others who would be engaged in the commerce of this toxic substance in
the quantitities anticipated in a fully developed breeder reactor
program?
Next, we would direct your attention to an AEC document on "Reactor
Fuel Cycle Costs for Nuclear Power Evaluation," in which charts appear
to indicate anticipated losses of up to 1% of material at various stages
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856
of the fuel cycle. Whether this estimate refers only to "not economi-
cally recoverable" fissionable material that remains in contained
wastes or to that lost substance category, known as MUF, or "material
unaccounted for," seems unclear.
I would, parenthetically, add that in that same document, adding
to our skepticism of AEC predictions, I note that there is a cost state-
ment attached to the G. E. Midwest fuel recovery plant of 17.4 million
dollars. As you may recall, when it was announced that it would not go
into operation, something in excess of 60 million dollars had been
spent on the plant, the anticipation being that it would cost a factor
of ten higher to put it into working order. We would ask that this
board investigate and make public the records of the Numec Corporation
operations in Apollo, Pennsylvania, with respect to inventory losses of
fissionable materials during its years of operation. It seems clear
from the 20-30 year operational record of the nuclear industry that
materials handling systems are insufficiently perfected to ensure that
plutonium will not be diverted, intentional or otherwise, and thereby
reach the environment. Subsequent human injuries could not be compen-
sated since the chain of causality could not be proven by the damaged
party (12).
Finally, we suggest that the failure of the Atomic Energy Commission
in nearly 30 years of research to develop and adequately test long-term,
essentially permanent, effective storage methods for long-lived radio-
active wastes argues strongly for zero production of these wastes. In
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view of the faulty record during this full human generation of plutonium
production, we contend that only a rigidly enforced zero release standard
for plutonium is appropriate to the protection of present and future
public health and safety. The best way to enforce a zero release
standard is to set a standard of zero production of plutonium.
We appreciate the opportunity to present this information and our
recommendations to the Environmental Protection Agency.
NOTES
1. Since 1970, the Environmental Coalition on Nuclear Power, or its
member groups, have intervended in construction and operating license
hearings before Atomic Safety and Licensing Boards in the cases of
Philadelphia Electric Company's Limerick I and II reactors, Peach-
bottom I and II, and Fulton I and II; Public Service Electric and
Gas Company's Newbold Island I and II (Project cancelled at that site);
and Duquesne Light Company's Beaver Valley I and II.
2. See, for example, proceedings of the Pennsylvania Senate Select
Committee Hearings on Nuclear Power Plant Siting, Harrisburg, Pa., 1970;
Governor's Select Committee Hearings on Alleged Health Effects from the
Shipping port Reactor, Aliquippa, Pa., July, 1973; Pennsylvania Insurance
Department Hearings on Nuclear Safety and Insurance Risks, Philadelphia,
Pa., August, 1973; U.S. Congress, Appropriations Hearings, 1972; Joint
Committee on Atomic Energy, Hearings on Siting and Licensing Legislation,
March, 1972; Hearings on Proposed Siting and Licensing Legislation,
1974 (in press); Hearings on Possible Modifications or Extension of the
Price-Anderson Insurance and Indemnity Act: Phase I: Review, January,
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858
March, 1974; Phase II, May, 1974 (in press).
3. See Richard S. Lewis, The Nuclear Power Rebellion; Citizens vs
the Atomic Establishment, 1972
4. U.S. AEG, Major Activities in the Atomic Energy Programs, Jan-Dec.,
1965
5. See New York Times, April, 17, 22:7, April 18, 13:1, 1970
6. New York Times, June 25, 3:6; June 27, 10:3, 1969; Feb. 11, 1:5,
1970; Sept. 27, 77:2, Dec. 22, 9:4, 1973
7. New York Times, May 15, 48:2, 1974
8. The Washington Post, December 6, 1974
9. See Mason Willrich and Theodore B. Taylor, Nuclear Theft, Risks and
Safeguards; A Report to the Energy Policy Project of the Ford Foundation,
1974. Also see John McPhee, The Curve of Binding Energy, 1974, ori-
ginally appearing in The New Yorker, issues of December, 1973.
10. See accounts of Mr. Sam Lovejoy's encounter with the meterological
tower at the Montague reactor site in Massachusetts, New Times, November,
1974, also in the New York Times.
11. U.S. AEC, Reactor Fuel Cycle Costs jfir Nuclear Power Plant
Evaluation, WASH-109 December, 1971
12. See testimony of Dr. Chauncey R. Kepford, Joint Committee on
Atomic Energy, Hearings on Possible Modification and Extension of the
Price-Anderson Insurance and Indemnity Act, Jan.-March, 1974, pp. 200-
253.
Dr. Mills: Thank you very much.
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I appreciate your patience in waiting around to be able to have
the opportunity to make your statement.
Ms. Johnsrud: I have learned a great deal.
Dr. Mills: I have one comment. To perhaps clarify the function
of this particular hearing, I do not believe that we would be investi-
gating or able to investigate the Numec Corporation.
Ms. Johnsrud: I understand that, sir, certainly, although I
certainly would like for someone to let us know, really.
Dr. Mills: We appreciate the fact that you have stated so.
Let me also say, from the EPA's standpoint, that the concern with
the public is on our mind. We recognize the technical problem, but I
think if you were here at the first part to hear Dr. Rowe's opening
remarks, the concern with the public reaction is one reason we are
holding this hearing.
Ms. Johnsrud: Yes. I think perhaps I might add, if I may, the
Atomic Energy Commission was developed during a period of American
industrial growth and development. That certainly seems to be approach-
ing an end, at least in the manner in which it has been conducted for
much of the past half century.
I think the Environmental Protection Agency represents the
direction that our society wants to go in the future. Let me empha-
size, again, from the public point of view: We would feel much more
comfortable if Dr. Radford and Dr. Tamplin were discussing the existence
or non-existence of the hot particle problem while we had the cushion
of a zero release, or better, a zero production of plutonium.
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Maybe 30 years from now, your offspring can sit on such a committee
to decide that, yes, we know how to handle these materials and now is
the time to begin to go ahead.
What I am saying is, of course, that essentially we are dealing
with a highly hazardous and immature technology. Better to wait a
little. I think that really represents a public point of view, when
they understand what the hazard may be for them and their children.
Dr. Mills: Are there any questions?
Dr. Garner: I would like to make a comment.
It is a philosophical comment. I do appreciate what you say about
what the public feels. I personally do not think that we are resort-
ing to detail. I try very hard to put the problem of plutonium in
perspective. I just wish the public would try to do the same thing.
I am not trying to downgrade plutonium. We have heard enough about
it. We point out we live with a great many other risks that the public
is willing to accept; for example, we push the use of natural gas and
liquefied gas to the hilt because it is non-polluting source, but if
we scour the newspapers of this country, we would find that almost every
day, a life is lost because of an accident involving natural gas and
liquefied gas.
People do not seem to realize this, or if they do, they do not
seem to take account of it, that is what I want to say.
Ms. Johnsrud: If I may respond to that very briefly, I think
perhaps when the public looks at the major uses of plutonium which, on
the one hand, have recently been for nuclear weapons and on the other
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hand, for power production and electricity production; we do have to
consider also just what the nature of the cost benefit analysis that
you will be engaging in, presumably, really is.
What are these costs? Who gets the benefits? I would submit to
you that increasingly the American public is pretty unhappy with the
notion that the major benefits of massive quantities of plutonium will
accrue to the investors of utilities.
Dr, Morgan: Ms. Johnsrud, I would certainly commend you and I am
proud of the position you have taken in expressing your views.
However, I feel it would be a wonderful world if we had given the
same consideration to other environmental insults as we have given from
the beginning to nuclear energy.
If you feel a bit disillusioned by the discussions here, I think
it is because this is a rather new experience, to examine in detail
what effects something like plutonium in industry would have on this
and coming generations.
This has never been done with respect to some of the other pollu-
tants that we consider.
You suggest that the best solution would be to have no plutonium
released. I suspect all of us agree to that, except we are realists
and we know, as you are yourself, we know that if you have nuclear
industry, you will have some release. There will be some accidents.
So then, your suggestion would be or was, we would have no pro-
duction of plutonium, and discontinue the industry. Maybe if we could
back up 20 or 30 years, that might be done or might be considered.
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But even to give it consideration today, of course, would mean
tremendous sacrifices and inconveniences and poverty far greater, I
believe, than the risks we even dream of in reference to plutonium,
that we are talking about.
The plutonium will not be an important problem indefinitely. I
do not believe many of us feel that more than a few hundred years,
the use of plutonium will be an important contribution to our energy
needs.
Ms. Johnsrud: Quite so. I think that our difficulty with the
comment that you have just made would lie, perhaps, in the cumulative
curve that was shown to us yesterday with respect to the already exist-
ing accidental releases, plus the weapons program, and tthe ever-rising
nature of that curve within, again, the bounds of human time-scales.
Then, of course, when we speak of plutonium let loose in the
environment, I look at it as a geographer. I know the spatial distri-
bution, the possibility of tracing the various mechanisms that are
potentially available and subsequent damage to be done by the substance
that is produced now within our peculiar society, at this strange point
in human history, for a very short time and highly questionable uses.
There are reams of reports now with respect to energy conservation
alternatives. If we say, for example, we will pose a "no release"
standard, the fast breeder obviously is in trouble. What does that do?
That gives us, perhaps, the time period in the near-term future
while we do have available possible alternatives, to support adequately
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the funding needed for the development of other alternatives. It
solves our problem, or what it does is postpone the creation of the
problem that we do not now know enough about, nor how to contain, nor
how to control.
So, we would hope there would be a time in the future when all the
research that AEG says will be done in the next 10 or 20 years has been
accomplished. If they were right, and their research proves out correctly,
fine. Then we can go ahead.
But there are so many unresolved questions now that members of the
public who look to this source as essentially a prominent contaminant
are very unhappy about proceeding at this stage.
I hope that comes clear.
Dr. Mills: Thank you very much.
I suppose this brings us to a conclusion of this public hearing.
Before I close, I want to express my thanks to all participants
for the long time that you put into these efforts, especially to the
reporter, and the people who have been kind to sit with us.
Also, I would like to thank the panel members for volunteering to
be of some assistance to EPA in this effort.
Thank you very much.
(Whereupon, the hearing in the above-entitled matter was concluded
at 6:25 p.nu)
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