GENERIC ENVIRONMENTAL STATEMENT MIXED
OXIDE FUELS FOR RECYCLE PLUTONIUM
IN LIGHT WATER COOLED REACTORS,
COMMENTS BY THE ENVIRONMENTAL
PROTECTION AGENCY.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
2 1 NOV 1974
Dr. S. H. Smiley
Deputy Director for Fuels
and Materials
Directorate of Licensing
U.S. Atomic Energy Commission
Washington, D.C. 20545
Dear Dr. Smiley:
The Environmental Protection Agency has reviewed the draft Generic
Environmental Statement Mixed Oxide Fuels for Recycle Plutonium in
Light Water Cooled Reactors. Our detailed comments are enclosed.
We would like to thank you and your staff for the time spent in
meeting with EPA staff members to discuss the issues raised during
the review of GESMO. These meetings were helpful to EPA for the
purposes of narrowing issues and hopefully prepared your staff for
responding to our comments on GESMO. Recognizing the scope of the
problems and the difficulty of addressing them at a level of detail
not heretofore approached, we commend the ABC staff for earnestly
attempting to present a fair picture of the plutonium recycle problem.
In its review, EPA has attempted to determine whether the infor-
mation provided is complete and adequate to support the conclusions
reached in the draft statement. The EPA comments do not, however,
address the completeness or adequacy of the technical aspects of
plutonium safeguards since this Agency does not have expertise for
such a technical analysis and hopefully, such a detailed review will
be made by those agencies of the U.S. Government having this expertise.
Because of the extreme importance of adequate safeguards, our comments
do reflect concern with the general and cost/benefit aspects of the
safeguards program. The EPA review of the GESMO was also based on the
premise that the program as proposed does not include the exportation
of plutonium.
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Until the information requested by EPA to be included in the
final statement is available, no final judgment can be made on the
environmental acceptability of this program. However, our preliminary
findings are that the implementation of plutonium recycle on an
industry-wide basis appears to be marginally acceptable from a
cost/benefit balance. This analysis indicates that the timeliness
of the program implementation does not appear to be critical. With
the application of the revised cost/benefit analysis methodology that
we recommend, the timeliness may be even less critical and the cost/
benefit balance even more marginal. It also appears that the program
could result in some environmental advantages. Within this perspective,
the principal conclusions reached by EPA on the plutonium recycle
program are as follows:
1. Before a full scale mixed oxide recycle program is implemented
a commitment should be made to an acceptable safeguards program.
Such commitment should include the completion of the necessary selection
of a procedure, its development and the securing of regulatory or
legislative approvals for its implementation, including funding
mechanisms.
2. Before actual full-scale mixed oxide fabrication and fueling
of light water reactors is commenced, the following should be accomplished:
(a) the safeguards program should be implemented;
(b) the waste disposal concerns about transuranic wastes
identified in EPA's review of the draft statement, "Management
of Commercial High-level and Transuranium — Contaminated
Radioactive Waste," and the proposed rulemaking on transuranic
waste should be resolved; and
(c) accident analysis of specific plutonium recycle
reactor designs should be completed for each proposed application
and deemed satisfactory.
Relative to the adequacy of the draft GESMO, EPA has commented
on several subject areas. First, the methodology used to compare thfl
costs of using recycled plutonium to the base case. Second, the role
of population exposures from uranium processing and occupational
exposures in the reported reduction of dose from use of mixed oxide
fuels. Third, our review includes comments on thfl uncertainties of
plutonium toxicity and pathways of radionuclides to man.
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EPA is very much aware of the controversy that exists relative
to transuranium uncertainties. We are attempting to resolve these
through a program of information development and consideration of the
need to establish generally applicable environmental standards for the
transuranium elements. EPA has stated this intent and requested
relevant information in a Federal Register Notice, Vol. 39, No. 185 -
Monday, September 23, 1974. We are confident that any standards
promulgated through this process will be implemented by the Commission.
We feel that these parallel efforts of the EPA and the AEC will
adequately protect the public health and safety and the environment.
Based on our reservations about safeguards and in accordance with
EPA procedure, we have classified the project as ER (Environmental
Reservations) and rated the draft statement as Category 2 (Insufficient
Information). If you or your staff have any questions concerning our
classification or comments, please do not hesitate to call on us.
Sincerely yours,
Sheldon Meyers
Director
Office of Federal Activities (A-104)
Enclosure
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Table of Contents
Page
I. Introduction and Overview 1
II. Plutonium Considerations 4
a. Radiation Dose and Plutonium Toxicity 4
b. Radionuclide Pathways in the Environment 5
c. Safeguards 6
III. Waste Management 7
IV. Safety 11
a. Reactor Plant 11
b. Transportation 12
V. Fuel Reprocessing, Fuels and Reactor 12
VI. Cost Benefit 16
VII. Additional Comments 31
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I. INTRODUCTION AND CONCLUSIONS
The Environmental Protection Agency (EPA) has completed
its review of the Generic Environmental Statement Mixed Oxide
Fuel (GESMO) on Recycle Plutonium in Light Water Cooled
Reactors issued on August 23, 1974. The conclusion stated by
AEC based on their analysis is that the recycle of plutonium in
light water reactors should be approved subject to continuation
of detailed case-by-case licensing procedures and upgraded
safeguards. Both environmental and economic factors were
analyzed in GESMO by AEC.
In its review, EPA has attempted to determine whether the
information provided is complete and adequate to support the
conclusions reached in the draft statement. The EPA comments
do not, however, address the completeness or adequacy of the
technical aspects of plutonium safeguards since this Agency does
not have expertise for such a technical analysis. We would expect
that such a detailed review will be made by those agencies of the
U.S. Government having this expertise. Because of the great
importance of adequate safeguards, our comments do reflect
concern with the general and cost/benefit aspects of the safeguards
program. The EPA review of the GESMO was also based on the
premise that the program as proposed does not include the expor-
tation of plutonium. A decision to export plutonium and the related
safeguards considerations should be a separate issue.
EPA has included comments on the cost/benefit analysis
since it considers factors which are environmental and public
health related, and since it is relevant to potential risks assumed.
EPA reviewed the analysis from the standpoint of methodology, data
utilized and the degree to which it presents an independent evaluation
of program costs and benefits. Additionally, there have been cases
within the nuclear industry where abandonment of economically
marginal operations have left State and Federal governments with
a legacy of environmental radiation problems. Example of these
operations include abandoned uranium mill tailings and low-level
waste storage sites. In order to assess the probability of similar
occurrences in the future, EPA must evaluate the economic
viability of proposed projects which could result in undesirable
environmental legacies.
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The implementation of plutonium recycle on an industry-
wide basis appears at best to be marginally acceptable from
a cost/ benefit balance. The AEC analysis indicates that the
timeliness of the program implementation does not appear to
be critical. With the application of the revised cost/benefit
analysis methodology that we recommend, the timeliness may
be even less critical and the cost/benefit balance even more
marginal. It also appears that the program could result in
some environmental advantages. Within this perspective, the
principal conclusions reached by EPA on the GESMO program
are as follows:
1. Before a mixed oxide recycle program is initiated, a
commitment should be made to an acceptable safeguards program.
Such a commitment should include the completion of the necessary
selection of a procedure, its development, and the securing of
regulatory or legislative approvals for its implementation
including funding mechanisms.
2. Before actual full scale mixed oxide fabrication and
fueling of light water reactors is commenced, the following should
be accomplished:
(a) the safeguards program should be implemented or
operational, (b) the waste disposal concerns about transuranium
waste identified in EPA's current NEPA review of the draft
statement, "Management of Commercial High-Level and
Transuranium -- Contaminated Radioactive Waste," and the
proposed rulemaking on transuranic waste should be resolved:
and (c) accident analysis of specific plutonium recycle reactor
designs should be completed for each proposed application and
deemed satisfactory. These conclusions are not different in
concept from AEC's approach, but rely on specific milestones
as decision points as opposed to time intervals as specified
by AEC.
Relative to the adequacy of the draft GESMO EIS, EPA makes
the following additional comments:
1. The methodology used to compare the costs of using recycled
plutonium to the base case of not recycling can be significantly
improved. We recommend that a sensitivity analyses be performed
to determine how sensitive the cost savings from recycling are to
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changes in the growth of electrical energy demand, uranium
availability, and changes in estimated capital costs of
mixed oxide facilities and safeguards measures. The final
statement should also expand the discussion of the economic
timing of the commercialization of plutonium recycle. Appli-
cation of improved cost/benefit methodology may indicate that
the economic incentives for introduction of plutonium recycle
may influence the time of introduction.
The cost benefit analysis should consider any inherent
government subsidy of plutonium recycle. In particular, the
safeguards proposals describe government actions which may
involve direct or indirect government subsidies, such that a
program that is marginally acceptable to society as a whole,
might otherwise be unsually attractive to industry.
2. In the draft statement the increased population
exposures from mixed oxide fuel processing are said to be
offset by reduced exposures from mining and milling of
uranium ore. It is not made clear the extent to which plutonium
is or is not the dominant environmental consideration. The
application of "As Low As Practicable" concepts to uranium
processing are not included in the statement.
3. Occuptional exposures are not discussed in detail. Al-
though these deficiencies may not be crucial for final conclusions
regarding acceptability of plutonium recycle, it is possible the dose
savings may not exceed the increased exposures from the rest of
the mixed oxide cycle.
4. The values of radiation dose equivalents and population
dose reported in GESMO were calculated using assumptions and a
data base that were not included in the statement. To evaluate the
adequacy of the transport of radionuclides in the environment, the
assumptions and pathways used in these calculations should be
included in the final statement.
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II. PLUTONIUM CONSIDERATIONS
a. Radiation dose and Plutonium Toxicity
Basically two comparisions relative to radiation dose
and health effects can be made between the MOX cycle and
the base LWR case. One is for occupational exposure and
the other for the general population. Neither of these dis-
cernments are clearly delineated.
In the case of occupational exposures it would be helpful
to identify the types of workers at risk and the sources of infor-
mation on their exposure. It is not clear in the EIS whether
uranium miners were included and if so if their occupational
hazards not due to radiation were considered as part of the
health impact.
In the EIS, the increased occupational and population
exposures from mixed oxide fuel processing are said to be off-
set by reduced exposures from mining and milling of uranium
ore. Indeed an actual overall dose savings is indicated.
However, it does not appear that the two cases were similarly
treated. To the degree that the dose estimates for mining
and milling were based on models which do not reflect the
control technology forecast for the 1990's, and exposures
from the mixed oxide cycle were evaluated on more realistic
effluent releases (ALAP), it is possible that the dose savings
shown in the EIS for reduced uranium processing may not balance
so favorably the increased exposure from the rest of the MOX
cycle. Therefore, the AEC should review the bases for the dose
estimates from mining and milling to see if they are compatible
with assumptions used to evaluate the dose from other sources
of exposure.
Throughout the discussion on toxicity, dose and health
effects, numerous points are in need of clarification or other
resolution. These individual points are presented in the additional
comments section. However, some issues so pervade the whole
discussion that some remarks are appropriate at this point.
Primary among these is the manner of utilizing and extra-
polating animal data to interpretation of effects on man. As
precarious as this manner always is, the EIS seems to make it
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even more so by implying a false sense of security in the stated
conclusions. A prime example is the area of lung effects utilizing
data from dogs and cats which have no common denominator for
comparision with human lung effects. This general situation is
compounded by a lack of information on experimental procedure,
such as chemical form for experiments at high dose rates as a
basis to infer effects on man at low dose rates.
Some other issues include the need to examine the potential
effects of other transplutonium radionuclides in order to place
them in perspective and premature biological conclusions such as
assuming the gonads to not be a potential internal organ. These
areas of ambiguity present a case which may well be misleading
and this matter should be resolved in the final EIS. We feel that our
detailed comments previously referred to along with the references
we have presented should be of assistance in carrying this out.
Although the results will probably not change conclusions relative
to the program's acceptability they will certainly more clearly state
the related impact and the degree of uncentainty associated with it.
b. Radionuclide Pathways in the Environment
The primary area of concern relative to environmental pathways
is the direct inhalation interface involved with the resuspension of
plutonium from soils. Several specific comments relative to the dis-
cussion of this are included in the additional comments. In general
however, it is felt that this is an area where much more effort is
required although it is realized it may be sometime before it is
entirely resolved. The present sparsity of data is compounded by
the fact that much of it is from desert test areas and may not be
at all applicable to the urban and suburban areas of most concern.
The program to determine this parameter is all the more critical
due to the sensitivity of lung doses to the resuspension variables.
We hope that a vigorous effort will be pursued and to the extent
possible the planned program be described in the final EIS.
The other major comment on environmental impact assessment
is that the pathways used are not described in enough detail to make
an assessment of the thoroughness of the analysis. However, when
comparing the dose per curie released used in this report with the
dose per curie release from the EPA analysis of the uranium fuel
cycle, similar results are obtained. Thus, it appears that the
analysis of long-lived isotopes-particularly tritium, krypton-85,
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iodine-129-did include the use of long-time -span pathways even
though the report does not describe these pathways. However, the
population dose commitment estimates presented in the draft state-
ment do not appear to consider world population growth over the time
period of the released radionuclides exist in the environment. We
feel that calculations of population dose commitments which extend
over many decades should take into consideration world population
growth during that period.
Several sections of G lilSMO describe the expected radiation dose
from transuranium elements. Information should be included in the
final statement which should indicate the pathways for transport of
transuranium elements to man. Any differences in chemical behavior
assumed for elements other than plutonium should be included.
c. Safeguards
I-]PA does not have the expertise to evaluate the adequacy of
safeguards programs. We do see the issue as a prime factor in
the feasibility of a mixed oxide recycle program however, for this
reason we do not feel that a commitment should be made to the
program until an extensive set of safeguard measures are committed
to and the necessary approvals are obtained for their implementation.
We hope that other government agencies, such as Justice or Defense
where an expertise exists will review these measures to assure their
adequacy. As safeguards are such an integral part of the program
we would expect that the incurred expense be fully reflected into the
cost benefit evaluation. If the devised measures are to be carried
out by Federal agencies this should be recognized as a form of
government subsidy and either this fact reflected or some means
of charging the industry should be arranged.
We are pleased to note that the GESMO includes a lengthy and
comprehensive discussion of the safeguards problem; we believe the
magnitude of the impact that could potentially derive from a failure of
the safeguards system merits this attention. We also concur that con-
tinuing study and effort should be devoted to upgrading the safeguards
provisions, as outlined in section V-1I and elsewhere in Chapter V,
and urge the A ICC to follow through with their- planning in this area.
It should be understood that lill'A's comments are based on the
premise of no U.S. export of plutonium. The consideration of such
an action should be handled as a separate issue. Such a decision should
not be taken lightly as it is apparent that a deficiency in safeguards
provisions or a breakdown of safeguards in another nation to which
we might export MOX fuel, or which moves to plutonium recycle on
its own, could effectively negate the safeguards developed in this
country. We recognize that such considerations are beyond the
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state j scope of the AEC's safeguards objectives. However, we
believe that discussions with other nations urging them to implement.
more stringent physical security measures, mentioned on p V-38,
are a vital element in overall safeguards considerations. Effective
accountability and physical security safeguards must exist in other
countries which utilize plutonium and other SNM if this country's
safeguards efforts are to have meaning.
The example calculation on p. V-48 quantifies the risk to selected
individuals from a postulated dispersion of plutonium oxide; however,
of more interest would be total risk in terms of deaths and cancers,
assuming the dispersion occurred in a densely populated area. Also,
it would be helpful in evaluating the magnitude of the risk to know
what assumptions are used to perform the calculation. For example,
is any credit given for evacuation of the affected area? What assump-
tions are made regarding resuspension? The final EIS should also
indicate what kinds of cleanup operations would be required to restore
the affected area to a habitable condition.
For the example calculation on p. V-49, of risk from uniformly
dispersed plutonium oxide, the area chosen (1/4 acre) is so small
that an "inhabitant" would have to be carefully defined. A large
area would seem to be more appropriate, corresponding to something
less than unity risk for the inhabitants developing bone cancer.
Again, total risk should be given for a representative population
density, and the bases for the calculation indicated.
III. WASTE MANAGEMENT
Definition of Wastes
The A EC; has defined only three catagories of "other-than high-
level" wastes; low-level beta-gamma waste, low-level plutonium
bearing or alpha waste, and fuel cladding hulls. The present classi-
fication system for "other-than" waste, however, gives no indication
of the activity, content, or hazard potential of the waste, except that
it is not "high-level" waste. The lack of clear definitions for these
wastes presents great difficulties for those who ship wastes, for
those who receive wastes, and for I1]PA, particularly, in determining
the potential health and environmental impact of the wastes, and we
therefore, would like to see the AEC develop a more detailed, formal
classification for "other-than" wastes.
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Our concerns about the waste classification problem were dis-
cussed in EPA's comments on the LMFBR program draft environ-
mental statement and will be discussed in more detail in comments
on the Management of Commercial High Level and Transuranium
- Contaminated Radioactive Waste draft environmental statement.
Predicated Volumes for "Other-Than" Wastes
There appears to be some discrepancies between the volumes
of the "other-than" wastes currently being buried and the amounts
predicted in the draft statement EPA has recently completed a
preliminary assessment of commercial "other-than" waste volumes,
activity, and space requirements(l). In particular the AEC estimates
yearly and accumulated quantities of radioactive wastes buried
appear to be somewhat underestimated when compared with the
results of the EPA assessment. The AEC should re-evaluate
their estimates based on the EPA information and other AEC
information (2).
The AEC should be more explicit in the final statement con-
cerning the methods used to estimate the volume of future "other-
than" wastes from the MOX fuel cycle and how these predicted
volumes fit into the total nuclear waste disposal picture. EPA
feels that resolution of these points is essential to an evaluation
of the environmental impact of the proposed MOX waste manage-
ment program.
Segregation of Transuranic Contaminated Wastes
"Other-than" wastes from the MOX fuel cycle are expected to be
richer in Pu and other alpha contaminants than wastes from the other
fuel cycles. This will mean that significant quantities of MOX wastes.
which would have been channeled into land burial at commercial burial
grounds, would now be placed in interim storage and later transferred
to a national repository for disposal or treatment. The economic
impact of this policy change on the total costs of power production and
on the operations of the commercial burial industry should be con-
sidered.
The final statement should indicate the technical arrangements
that will be made to screen the "other-than" wastes for transuranium
contamination and to prevent the accidental dilution of the trans-
uranium - contaminated wastes to less than 10 nanocuries per gram.
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Commercial Burial Grounds
Shallow land burial is the present and proposed method for dis-
posing of the nontransuranic "other-than" wastes. The AEC should
present or directly reference in the final statement the results of any
studies which have been conducted at the commercial burial sites,
subsequent to the beginning of burial operations which could corrob-
orate or validate the conclusions reached in the original evaluation
that buried radioactive waste will not migrate from the sites. Also
any monitoring data or other evidence which confirms that the radio-
active waste now buried has remained immobile at the place of burial
should be submitted or directly referenced.
Interim Storage/Ultimate Disposal
While we have significant concerns about the proper execution of the
interim engineered storage and ultimate disposal concepts for "high-
level" waste we will not include detailed discussion of them in these
comments.
We feel that, while they apply to the MOX program, they are more
relevant to the draft environmental statement on the Management
of Commercial High-Level and Transuranium-Contaminated Radio-
active Waste.
Miscellaneous Comments on GESMO: The draft EIS indicated the
maximum credible accident at any RSSF to be the rupture of a single
cannister. However, since the AEC indicated the possibility of a
loss-of-cooling accident, we feel that the environmental impact of
this type of accident should be discussed in the same degree of detail
as the single cannister accident. These analyses address the additional
30% heat loads and higher radiation levels affect safety margins,
facility designs, or costs.
With the increase of total transuranics present in the high-level
MOX wastes and the change in the mix of these transuranics, the
final statement should discuss how this affects the time required
to retain the wastes in some ultimate disposal site and which radio-
nuclides are of primary concern after 10, 100, 1,000, 10,000,
100,000, and 1, 000,000 years.
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References
1. M. F. O'Connell and W. F. Holcomb, "A Summary of Low-Level
Radioactive Wastes Buried at commercial Sites Betwen 1962-1973,
with Projections to the Year 200", to be published in Radiation Data
and Reports for December 1974.
2. U.S. AEC "The Nuclear Industry 1973, WASH 1174-73
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IV. Safety
a. Reactor Plant
The discussion of the relationship of mixed oxide cores to
reactor safety margins generally presented qualitative evaluations
of the MOX to reactor kinetics and reactor control capabilities. In
conclusion the AEC stated that there were no limitations in the use
of MOX related to safety. In view of the fact that the draft statement
did not consider specific or reference reactor designs, we believe
some quantitative details should be presented in support of the
conclusion that no safety limitations are necessary. This is partic-
ularly important since the MOX, as discussed in the draft statement
statement will have both positive and negative impacts on the levels
of margin relative to reactor safety. In order to better delineate
the overall quantitative aspects of MOX on the level of the margin
of safety, we recommend that the final statement assess the overall
change in pertinent safety parameters, as itemized in the draft
statement, for reference PWR and BWR core designs for several
different MOX fuel loadings in the range under consideration. The
resulting changes should then be compared, if possible, with the
ranges of existing margins in light-water reactors. Although the
reference core design may not necessarily be identical to designs
or specific reactors, this analysis will enable a conclusion to be
reached on quantitative analyses regarding the impact of MOX on
safety margins and on the need for specific safety limitations. We
assume that, before any operating nuclear plant is licensed to
operate with recycle MOX, the AEC will perform detailed safety
assessments of the specific core design and will issue an independent
safety evaluation report of the results.
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b. Transportation
The analysis of transportation accidents appears incomplete
since no quantitative information is presented for either the pro-
bability of an accident in which radioactive materials are released
or the conquences of such an accident. The primary reference used
to support the A EC conclusion that the radiation risk is small
is WASH-1238 which suffers from a similar lack of quantitative
information. In particular, with regard to the probability of an ac-
cident involving a release there is no analysis relating the shipping
container test conditions to the severity of the accident. Thus,
the conclusion that the container should withstand a Category 3
(severe) accident without being breached is not substantiated.
With regard to the consequences of an accident involving a release,
no estimate of the radiation dose to emergency crews, controversy
concerning the quantity of fission products, especially cesium,
which may be released is made. An estimate of the external
exposure to humans from released radioactive materials was made
in WASH-1238. However, it appears the dose to humans from
inhalation of the released material may be much greater than
received externally.
A complete risk analysis for the shipment of plutonium in DOT
approved containers has recently been completed by Battelle North-
west Laboratories (BNWL-1846). This analysis is an important first
step in resolving the issues concerning radiation risk in the trans-
portation of nuclear materials. While this study has not yet received
the detailed scrutiny of the scientific community to determine
its acceptability, it appears to be of sufficient quality to warrant
inclusion of its findings in the final statement. A commitment
to perform similar analyses for other shipping pathways
should also be made in the final statement.
V. FUEL REPROCESSING, FUELS AND REACTOR
Fuel Reprocessing
The iodine-129 and -131 source terms for the model fuel repro-
cessing plant listed in table 13-8 are not in agreement with present
estimates by the Oak Ridge National Laboratory based on currently
available technology. In the past many uncertainties have been as-
sociated with iodine source terms and control technology that will be
utilized to obtain the release rates presented in the draft statement.
Also the final statement should provide a separate listing in the tables
of the doses (both individual and population) resulting from the
projected radioiodine releases.
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The draft statement does not present information on carbon-14
release rates from either reactors or fuel reprocessing plants.
Because of its long half-life and its persistence in the environ-
ment, carbon-14 which has been discharged from these facilities
may result in a population dose commitment significantly greater
than from either kryton-85 or tritium. Therefore, we feel that
the final statement should present the following information on
carbon-14:
a. release rates from both reactors and fuel repro-
cessing plant.
b. local doses and population dose commitments.
c. a discussion of control technology at both reactors
and fuel reprocessing plants.
Fuels
The statement is made in several places in the draft EIS (e.g. ,
on pages IV C-20 and IV C-58) that depleted uranium (diffusion
plant tails) could be used instead of natural uranium as the
diluent for blending with recycled plutonium during fabrication
of MOX fuel. This implies a benefit owing to the reduced ore
mining and milling requirements and utilization of existing stores
of depleted uranium. Elsewhere, however (e.g. , on pages 1-14,
11-44 and 11-55) it is noted that natural uranium shows an economic
advantage over depleted uranium. The conditions under which
stores of depleted uranium might be used, even though such use
is described as "uneconomic,' should be discussed in the final EIS.
If utilization of depleted uranium or tails is not reasonably antic-
ipated the references to such possible use should be deleted.
Reactor
According to Chapter IV, page IV C-73 of GESMO, WASH-1258
(Final Environmental Statement Concerning Proposed Rule Making
Action for Operation to Meet Criterion "As Low As Practicable")
served as the basis for the source term calculations. However,
comparision of the source term parameters in GESMO (Tables
IV C-9 and IV C-10) with corresponding tables in WASH-1258
reveal certain discrepancies:
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BWR Source Term Parameters
Parameter
Reactor Cleanup
Flow Rate
D. F. , Clean Waste
Demineralizer
Table IV C-9
GESMO
1.54 x 105 Ib/hr
10(10)
Table 2-1
WASH-1258
1. 3 x 105lb/hr
1(10)
PWR Source Term Parameters
Parameter
Te Escape Rate
Coefficient
Sr, Ba Escape Rate
Coefficient
Weight of water in
primary system
Weight of water in
secondary system
Table IV C-10
GESMO
1.0 x 10-n/sec
1.0 x
/sec
5.5 x 10lb
3.7 x 106lb
Table 2-2
WASH-1258
1. 0 x 10-9 /sec
1.0 x 10-41 /sec
5.0 x 10° Ib
4. 1 x 10slb
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In addition to these differences in basic source term para-
metric values, the waste treatment systems assumed for the
GESMO model reactors are in may instances unlike those systems
presented in WASH-1258. These discrepancies should be clarified
with respect to the potential effects on environmental releases.
Table IV C-12 of GESMO has apparently excluded the BWR
mechanical vacuum pump (at startup) source term, 2,300 Ci/yr
ofXe-133, 350 Ci/yr of Xe-135, and radioiodine (unspecified).
Table IV C-21 and C-22 are apparently mixed-up. Table IV C-12
shows a higher noble gas source term for the UO fueled BWR but
doses from this reactor (i.e. , skin and total body doses) are lower
than the corresponding doses from the mixed oxide fueled BWR.
Similarly for radioiodine, a higher source term is listed for the
mixed oxide fueled BWR but higher thyroid doses are listed for
the UO fueled BWR. It is not clear whether this confusion may
have filtered to Tables IV C-27 and IV C-28 for annual man-rem
doses.
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VI. BENEFIT/COST ANALYSIS
INTRODUCTION
EPA considers the benefit/cost study to be insufficient in detail
and depth of analysis. In our opinion, the methodology used is incorrect
for a number of reason, which will be discussed in the following sections.
Even before correction of methodology the cost savings from plutonium
recycle are small relative to nuclear electricity generation costs. There
are indications that, if corrected procedures for the analysis were used,
the cost savings from plutonium recycle may prove to be smaller than
reported.
The debate over recycling revolves around the issues of increased
environmental risks to man and the environment, which should be weighed
against the benefits to be derived from producing somewhat cheaper power
with plutonium recycling. Since risks are balanced against the cost
advantages of plutonium recycling, the smaller the cost advantage, the
smaller the risks that may be acceptable to society.
METHODOLOGY
The method of analysis employed in the AEC benefit/cost study does
not provide the cummulative LWR fuel cycle industry cost figures for the
years 1974 through 1995. Table XI-7 does supply cummulative figures for
resource and service commitments, but this table is of limited
usefulness since it does not include capital costs.
Instead the major thrust of the AEC benefit/cost study is a
projection of the LWR fuel cycle industry under various alternatives at
a "...mature operating level, about 1990..." The cost figures for this
year are in Tables XI-4 through XI-6. AEC chose this year because they
believe it represents an "...approximate average industry condition for
the time span 1974 - 1995" (p.XI-3).
The methodology used for this AEC benefit/cost study is to measure
the fuel cycle costs for a base case, labeled Alternative 1. This base
case is then used as a standard of comparison for five alternative
cases. The base case represents the reprocessing of the spent fuel and
the storage of the plutonium for future use.
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17
Although this methodology appears to be acceptable, since the LWR's
will be operating in either case, it is reasonable to suspect that
little reprocessing of spent fuel will occurr if plutonium recycle in
LWR's is not permitted. With no plutonium recycle, it is likely that
most of the spent fuel would be stored for some future use rather than
reprocessed within a short time. Such a scenario could lead to
significantly smaller impacts in both the reprocessing and
transportation areas. We believe that AEC should present more evidence
to justify this choice of the base case.
The five alternatives represent different dispositions of the
plutonium and uranium contained in the spent fuel. Alternatives 3 and 4
represent plutonium recycling. The difference between these two is that
Alternative U includes an upgraded safeguards program. The alternatives
representing plutonium recycling are the only cases considered that
result in lower fuel cycle costs below those for the base case. The
AEC's recommended course of action is to proceed with plutonium
recycling. Therefore, this discussion of the benefit/cost analysis will
be directed towards plutonium recycling.
The benefits to be derived from plutonium recycling are defined as
the cost savings gained from plutonium recycling. There are two
categories of potential social costs associated with plutonium
recycling: those that involve an impact upon the environment and those
that have an effect on the level of safety.
Table XI-2 is a summary of the environmental factors for the
alternative spent fuel dispositions. No attempt has been made to attach
dollar values to these environmental factors. However, it is argued by
the AEC that plutonium recycling reduces, to a small extent, the overall
impact on the environment. The primary source of this reduction is a
decrease in uranium mining, UF^ conversion and uranium enrichment. In
turn, this reduces the need for land and resource inputs, and results in
diminished fossil fuel needs. There are some increases in environmental
impacts but they are believed to be negligible in comparison to the
reduced environmental factors.
The other potential social cost of plutonium reycling is increased
safety hazards. Plutonium recycling expands the quantity of plutonium
in use in the fuel cycle. This plutonium must be transported and
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handled in the process of recycling and is therefore vulnerable to
attempted acts of theft or sabotage. The upgraded safeguards program in
Alternative U is directed towards that danger. Alternative 3 includes a
safeguards program much like that for Alternative 1, but extended to
take into account the increased quantities of plutonium present with
plutonium recycling.
SENSITIVITY ANALYSIS OF SUPPLY AND DEMAND ASSUMPTIONS
Estimates of uranium resources are uncertain. If future nuclear
fuel requirements can be met only by the mining of low grade ores,
extraction costs will rise above today's level. Plutonium recycle has
the potential for somewhat reducing future uranium requirements and
costs. The primary source of reduction in costs is the reduction in
extraction and enrichment costs, since plutonium can be used as a
substitute for a portion of the uranium fuel.
AEC estimates of U. S. uranium resources are shown in Table
XI-(A-2). Given the AEC estimates of uranium reserves, and the AEC's
estimates of the need for uranium fuel under the different alternatives,
the future price for ^03 can also be estimated. These prices are shown
for every five-year interval from 1975 through 1995 in Table XI-11. No
attempt has been made to determine how sensitive the cost savings from
plutonium recycle are to alternative assumptions for uranium reserves,
potential changes in enrichment technology, rates of growth of
electrical energy demand, rates of substitution of nuclear for fossil
plants, or different mixes of nuclear reactors (e.g. HTGRs or HWRs). In
our opinion, it seems reasonable to expect that the estimated cost
savings shown in Table XI-11 could vary quite significantly if different
assumptions were used.
The growth of nuclear power is obviously derived from the overall
growth in demand for electrical energy. The overall electrical demand
projection used in the AEC Draft statement is based upon Assumption Set
D of the AEC projection. Nuclear Power Growth 197a-2QOO. WASH-1139 (74).
That demand projection corresponds to an average annual growth of 6.2%
for all electrical power and 21.5* for nuclear power over the period
1970-1995. Growth of electrical energy demand could be much lower (e.g.
as low as 4X) as a result of the substantial price increases and
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Dnservation efforts now in progress. There is also considerable
icertainty about the size of the nuclear share of electricity
ineration. This uncertainty arises from recent trends in capital
instruction costs and lower-than-expected reactor availability
:perience. The cost savings from Pu recycle can reasonably be assumed
3 be quite sensitive to these assumptions.
Table 1 shows the eight combinations that EPA considers essential
Dr the sensitivity analysis. The first combination shown represents
le case analyzed in the Draft EIS.
Two cases for the supply of U^Og are of interest. The first is the
ame as projected in the Draft EIS and the second is a 100 % increase in
ranium resources. This increase would be an additional 100X of the
. S. uranium resources (both reasonably assured and estimated
iditional) corresponding to each price level as shown in Table XI-
^-2) .
Two cases for the projected growth in nuclear power are proposed.
le first would be the same as projected in the Draft EIS and the second
ould reflect an average annual growth rate of 4X in electrical power
smand and 10X growth for installed nuclear power demand over the period
974-1995. Two cases are proposed for capital construction costs. The
irst would be the same as projected in the Draft EIS and the second
ould represent a 100% increase in the capital equipment and
onstruction costs of all facilities needed for plutonium recycle. This
icrease would allow for the uncertainties of present day capital
onstruction costs.
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TABLE 1
SENSITIVITY ANALYSIS
Jranium Supply
Growth in Nuclear
Power Industry
Capital Costs
Same as Presented
in the Draft EIS
Same as Projected
in the Draft EIS
Same as Presented
in the Draft EIS
100% Greater than Presented
Lower than Projected
(4% growth in
electrical power)
(10% growth in nuclear
power)
Same as Presented
in the Draft EIS
100* Greater than Presented
100% Larger than
Estimated in the
Draft EIS
Same as Projected
in the Draft EIS
Same as Presented
in the Draft EIS
100% Greater than Presented
Lower than Projected
(U% growth in
electrical power)
(10% growth in nuclear
power)
Same as Presented
in the Draft EIS
100% Greater than Presented
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THE OPTIMAL DATE FOR FULL COMMERCIALIZATION
The EPA believes that the AEC methodology places too much emphasis
on the date of introduction of plutonium recycle. There is often a
great deal of difficulty in progressing from introduction to full
commercialization. The time projections for full commercialization
often miss by years. The EPA believes that a better concept to be used
in considering the timing of a program is the date of "full
commercialization." This is defined to be the time when commercial
development has progressed to the point where the future expansion path
of the industry can be reliably predicted. Once this point has been
reached, there will be comparatively less doubt as to the date a fully
developed industry will be achieved. AEC might wish to empirically
define the point of full commercialization as the point when recycled
plutonium accounts for more than X percentage of LWR fissile fuel.
If plutonium recycling is fully commercialized too early, the price
of uranium will still be too low, decreasing the discounted present
value of cost savings derived from plutonium recycle. Delay in the date
will increase the discounted present value of cost savings. However, if
plutonium recycle is fully commercialized too late, future cost savings
will occur too far in the future and their discounted value will be
smaller than if the date were moved earlier in time. Thus, the
discounted present value of the cost savings from plutonium recycle will
first rise and then fall as the date of full commercialization is moved
outward in time. The optimal date for full commercialization is the
date for which the present discounted value of cost savings is
maximized.
The Final EIS should include calculations of the present discounted
value of cost savings for each different date. These calculations
should be performed not only for base case parametric conditions, but
also for the other sensitivity cases identified in this review. In
order not to bias the analysis against later full commercialization
dates, it will probably be necessary to extend the ending period of the
analysis past 1995.
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2OST SAVINGS AND THE CROSSOVER POINT
The EPA believes that early initiation of plutonium recycle requires
the demonstration that the savings are significant in comparison to
mclear electrical generation costs and that they are realized early in
the recycle program. Deferred initiation of plutonium recycle should be
considered to be an alternative if the cost savings are not realized
early in the fuel recycle program. The remainder of this section
provides the framework for this argument.
First, it should be demonstrated that there are savings from
plutonium recycle. They should be apparent from the analysis of the
cumulative costs of operation for the period 1974-1995. These savings
should be realized for the whole program, including reactor costs as
well as fuel cycle costs. In addition, these savings should be large
enough to warrant the additional risks inherent in plutonium recycle.
As discussed elsewhere in this review, the draft EIS does not
satisfactorily describe or quantify the costs of an adequate safeguards
program. Some safeguards measures (e.g. spiked plutonium) may
substantially increase the costs of plutonium recycle. These costs are
difficult to predict, and could be considerably higher than the AEC
presently estimates.
If analysis demonstrates that there are substantial savings from
plutonium recycle, steps to proceed immediately are justified only if it
is shown that the savings derived will begin soon after the program is
implemented. In order to determine how soon plutonium recycle reaches
this point, which can be termed the crossover point, an analysis of the
costs of operation of each alternative, on a year by year basis is
needed,
EPA considers the determination of the crossover point to be quite
important. If this point will not be reached until many years in the
future then there is less incentive to make a present commitment to the
future use of plutonium recycle for routine fueling of LWR's. A more
limited present commitment could be considered without foreclosing the
future option of using routine plutonium recycling. The crossover point
concept could be usefully incorporated into sensitivity analysis.
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PRIORITY USE OF PLUTONIUM
AEG gives first priority to the production of the plutonium needed
to fuel fast breeder reactors. Therefore, 26% of the plutonium produced
in LWRs over the time span 1974-1995 is to be withheld from plutonium
recycle for that purpose. The choice of the 26% figure is not explained
or justified, except to state that there will be large quantities of
plutonium left over after meeting the requirements for the first fuel
loadings for the new breeder reactors, since the savings from plutonium
recycle is responsive to changes in the fuel cycle, EPA believes that
the Final EIS should explain how the 26% figure was determined because
there can obviously be important environmental consequences from saving
different percentages of LWR-generated plutonium. The interrelationship
between the fast breeder reactor program and plutonium recycle will be
explored in the Appendix which describes a method that can be used to determine
the appropriate amount of plutonium to be withheld from recycle for the fueling
of fast breeder reactors.
THE ROLE OF THE HTGR
There is virtually no discussion of the role of the HTGR in the
nuclear reactor field through 1995. Figure 3-1 and Table VIII-2 shows
that it is expected to make a relatively small contribution. An obvious
question is whether or not the cost advantage to plutonium recycling is
sensitive to the relative mix of LWRs and HTGRs. Some supplementary
analysis could be usefully employed to pursue this question.
DISCOUNTING
No discounting has been used in assembling the data for Tables XI-U
through XI-7. Therefore, there is no adjustment for the fact that
capital and operating expenditures take place at different times. For
example, the capital in place in 1990 will be composed of a mix of
capital of various ages. The accepted procedure for taking this into
account is to use discount rates to evaluate time distributed costs and
benefits in present value terms. This procedure is described in
Circular A-9U, Efivised, issued by the Office of Management and Budget.
This circular requires the use of a 10% discount rate.
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It is impossible to determine with the present analysis precisely
what discounting will do to the apparent cost savings gained from
plutonium recycling, for the changes in the present value are
functionally related to the time-distribution of expenditures. Time
distributions of cost data are not provided in the Draft EIS. However,
if the time distribution of expenditures is roughly the same for the
alternative cases, it is to be expected that the use of discounting
would reduce the absolute size of the cost savings that can be
attributed to plutonium recycling. Table XI-6 shows the fuel cycle
costs for the year 1990. There appears to be one billion dollar saved
from plutonium recycling as compared to the base case. Since no
discounting has been used, the corrected value of this cost savings
cannot be determined.
The failure to discount to present value leads to even greater
misconceptions when considering Table XI-7. This table is a tabulation
of expenditures for resources and services for the period from 1974
through 1995. These expenditures do not represent any capital
investment over this period, just the expenditures for resources and
services incurred in operation each year. Since the costs of operation
are not discounted for future years of operation, the contribution for
those years in the distant future are much greater than they would be if
evaluated in present value terms. With discounting, the differential
costs for each alternative dispostion of plutonium would be reduced in a
like manner, thus decreasing the magnitude of the apparent cost savings
when plutonium is recycled.
Since no time-specific cost data is provided in the draft statement
it is impossible to determine how much the cost savings claimed exceed
those that would be incurred if evaluated in present value terms. In
our opinion, they could be substantial. The nuclear power industry is
projected to grow continuously through 1995, so that the total operating
expenses for each of the six alternatives will be larger in the later
years of the period evaluated. Therefore, these later years make the
greatest contribution to the expenses recorded in this table. But the
expenses for the later years are the ones that will be subject to the
greatest discount. The present value of the cost savings may be greatly
reduced from those recorded in the table.
SAFEGUARDS COSTS
The safeguards program is described in Chapter V of the Draft
Statement and its costs are estimated in Chapters VIII and XI. A wide
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variety of safeguards programs are discussed. Some have estimates of
costs attached to them, others do not. The measures considered include
the incorporation of integrated fuel cycle facilities which would reduce
transportation requirements, a Federal security force that would not be
restricted by state and local limitations and could respond on a
nationwide basis if necessary, hardening of barriers against theft and
sabotage, suggested protection of transportation functions, spiked
Plutonium, and a variety of other measures. Since the particular form
of the safeguards program is not resolved in the Draft EIS, the costs of
implementation cannot be determined with certainty. AEC states that the
cost figures are to be used to "...give a perspective, a point of view
and an order of magnitude for these costs." AEC maintains that these
costs would be small enough that they would not be a significant
economic consideration.1 The remainder of this section and the next
section of this EPA review demonstrate that the estimated costs of these
safeguards programs are large enough to have an impact on the economics
of plutonium recycling.
In the summary of Chapter XI, under the discussion of Materials and
Plant Protection Considerations, p.XI-19, it is stated that although
"...projected materials and plant protection costs in 1990 will be
significantly higher for Alternative 4 than for the base case, the
resultant effect on the overall economics of the fuel cycle is judged to
be inconsequential." This statement is in reference to an upgraded
safeguards program, estimated to cost 74 million dollars in 1990. This
cost is indeed small when compared to the total fuel cycle costs.
However, it is much larger in comparison to the costs savings incurred
in 1990, representing approximately 6% of the cost savings attributable
to plutonium recycling without safeguards (Table XI-6, Alternative 3).
For this reason EPA suggests that the term "inconsequential" is not an
appropriate descriptor of potential safeguards costs.
SPIKED PLUTONIUM
Spiked plutonium is discussed in various places in the draft
environmental impact statement, but has not been included in estimated
costs of materials and plant protection. Nowhere is its use explicitly
•"-See page VIII-75.
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26
rejected. The reader is left with no definite indication whether spiked
Plutonium is considered to be a likely additional safeguard measure.
The cost of incorporating spiked plutonium is estimated to be 170
million dollars for the year 1990 and to be in the order of three
billion dollars for the period through 1995.2 By telephone inquiry, the
EPA was informed that spiked plutonium was not included in the fuel
cycle since its cost is small compared to total fuel cycle costs.
However, comparing these costs to total fuel cycle costs is not
relevant. Spiked plutonium costs are more appropriately compared to the
savings associated with plutonium recycling. Inspection of Table XI-6
reveals that the inclusion of spiked plutonium as an additional
safeguard will lower the cost advantage of Alternative 4 from 980
million dollars to 810 million dollars, a reduction of 17%. If spiked
plutonium is some day determined to be a necessary safeguard measure,
its use will significantly reduce the cost savings derived from
plutonium recycling.3
STANDARDS FOR COMPARISON OF COST SAVINGS
In Table XI-6, AEC calculates the cost savings from Alternative 4 to
be approximately one billion dollars as compared to the base case, for
the year 1990. This cost savings results in a calcualted savings in
"Total Operating mills/kwh" of 3.89-3.54=0.35 mills/kwh. These costs
are not busbar costs, for they include only fuel cycle costs. Costs not
contributed by the fuel cycle have not been included in Table XI-6.
There is a question as to the appropriateness of not giving an estimate
of the busbar costs. An uninformed reader of the Draft EIS might assume
the reported costs represent the total costs of generating electricity,
and arrive at the incorrect conclusion that the cost savings from
plutonium recycle represent approximately a 10X savings (i.e. 0.35
mills/kwh saved from a base cost of 3.89 mills/kwh).
The 1974 busbar cost of generating electricity is approximately 16
mills/kwh. The cost savings for Alternative 4 as compared to
Alternative 1 could then be calculated to be (3.89-3.54)/16 = .022 or
approximately 2.2* of the total costs.*
When the savings for plutonium recycle are viewed as a component of
total nuclear power generating costs, they are much smaller than they
2
This estimate is found on page VIII-75. A contradictory estimate of its cost is
found on page V-45. Inquiry of the AEC established that the correct figure is
170 million dollars.
No discounting has been used here, because the necessary data is not available in
the Draft EIS.
No discounting has been used here, because the necessary data is not available.
However, the use of discounting would not change these conclusions.
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.re when considered as a component of fuel cycle costs only. It is
mportant to view the cost savings from this perspective. Should it
>ecome necessary to forego plutonium recycle someday, because of some
mvironmental or safeguards problem, it is clear that the absence of
>lutonium recycle would have only a marginal impact on electricity
:osts. EPA recommends that AEC consider total LWR busbar costs to be
:he appropriate standard against which the cost savings from plutonium
recycle be compared. This standard of comparison would be more
eaningful to a reader of the final EIS. The Final EIS should at least
.nclude this kind of comparison, and it should be given equal prominence
the comparison to fuel cycle costs presented in the Draft EIS.
:ONCLUSION
The methodology used to compare the costs of using recycled
plutonium to the base case of not recycling can be significantly
improved. There is considerable reason to believe that the cost savings
from plutonium recycling may not be as large as shown in the Draft EIS.
SPA recommends that all the calculated costs of alternative spent fuel
iispositions be redone with all expenditures discounted to 1974 values.
Discounting is the only way to bring expenditures that take place in
different time periods into proper perspective.
It is further recommended that the capital and operating costs of
reactors be included in the costs of six alternatives. This will make
it possible to judge all cost savings in relationship to the total costs
of using nuclear reactors to generate electricity.
EPA also recommends that the sensitivity analyses described in an
earlier section of this review be incorporated into the benefit/cost
study so that readers of the Final EIS will be able to determine how
sensitive the cost savings from plutonium recycling are to changes in
the growth of electrical energy demand, changes in the uranium
resources, and changes in the estimated capital costs of mixed oxide
facilities.
The EPA does not consider the analysis of fuel cycle costs for only
one year, 1990, to be adequate for judging the merits of plutonium
recycle. This would be true even if the analysis were methodologically
correct. The cumulative costs for the years 1974 through 1995,
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appropriately discounted, must be shown for each alternative. The
information the AEC provides in Table XI-7 is not sufficient, for it
floes not include capital costs.
The Draft EIS does not adequately treat the subject of the economic
aiming of the commercialization of plutonium recycle. Timing is very
important because new information is continually being developed in the
areas of plutonium toxicity, the costs and feasibility of safeguards
neasures, and the magnitude of transportation hazards. Thus, the Final
EIS should contain a thorough analysis of when the cost savings of
plutonium recycle are expected to begin and how large they are likely to
be. This information will be highly useful to interested groups and
could be a valuable input to future public discussions about the timing
of plutonium recycle.
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APPENDIX
It is assumed here that uranium resources, the growth or the nuclear
power industry, and the date of LMFBR introduction are all given. The
horizontal axis in Figure I represents units of plutonium. The total
horizontal dimension represents the total amount of plutonium generated
from LWRs. Movement from left to right represents more use of plutonium
for LWR recycle and less use for LMFBR fueling. Movement from right to
left, on the other hand, represents more use of plutonium for LMFBRs at
the expense of LWR recycle. Each point on the horizontal axis
represents a different allocation of plutonium between plutonium recycle
and fuel for LMFBRs. The verticle axis measures the present value of a
unit of plutonium.
Figure 1
OJ
Q.
t-
(O
o
-a
••- o
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The line AB represents the preset value of plutonium used in LWR
Plutonium recycle, and is expressed in dollars per unit. The downward
slope of the line reflects the fact that the present value of each
additional unit of plutonium will decline as the amount of plutonium
used in recycle increases for any given year. This is because plutonium
replaces uranium as a fuel in LWRs and the higher cost uranium ores will
be the first to be replaced by plutonium.
The line CDE represents the present value of plutonium used for
fueling LMFBRs, and is expressed in dollars per unit. The downward
slope of this line (moving from right to left) reflects the fact that
the present value of each additional unit of plutonium will decline as
the amount of plutonium reserved for fueling LMFBRs increases. The
"kink" in the line is to indicate that there may be a minimum amount of
plutonium needed to satisfy the rapid rates of LMFBR commercialization
projected by the AEC.
Point "0," where the two lines cross, represents the optimal
distribution of plutonium between plutonium recycle and fuel for LMFBRs.
EPA does not consider it unreasonable to ask that the above type of
analysis be performed. The only significant obstacle to performing such
an analysis would be the present uncertainty about the dates and rates
of LMFBR introduction. This obstacle can be overcome by using the dates
and rates specified in Table 10.U in Volume III of the AEC Draft
Environmental Impact Statement for the LMFBR Program (WASH-1535).
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VII. ADDITIONAL COMMENTS
1. Tables IV C-12, IV C-21 and IV C-22 are not con-
sistent; e.g. , MOX skin doses are higher but for
the mix of noble gases in effluents given, they should
be lower. Also, while iodines in MOX gaseous effluents
are shown higher, thyroid doses are lower.
2. Figure IV C-24 does not appear to be drawn correctly.
The reduced central temperature in the MOX rod is
stated to be a consequence of the higher neutron cross
section of Pu, which causes a higher peripheral heat
generation rate and lower central flux. This being
the case, one would expect the termperature profile
of the MOX to be higher in the periphery, reflecting
the increased heat flux at that location.
3. No mention is made of the magnitude of possible tramp
plutonium problems with MOX fuel. This should be
addressed in the final statement.
4. Another possible alternative that should be considered
relative to the timelessness of initiating a mixed oxide
recycle program in LWRs is the diversion of surplus
enriched weapons uranium to such utilization as naval
reactors. While the diversion may be completely
infeasible such a move make available present
inventories of new uranium and enrichment capacity
to LWRs alleviating short term shortage problems,
Because of the interest in such trade offs, this
alternative should be discussed in the final EIS.
5. Vol. 1, Pages S-38 to S-40: Table S-8
The titles of these two tables refer to two fuels being
considered but only one set of numbers is given.
6. Vol. 2, Page 11-29, last sentence of part b: This sentence
is not totally true. Some plutonium has been left in wounds
when surgery was expected to result in a worse situation
than by leaving the plutonium there.
7. Vol. 2, Page 11-29, part c: This part could be made specific
for environmental radioactive material received into the body
via inhalation or ingestion. Wound or injection entry is of
little concern in the environment, but important for occu-
pational workers.
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8. Vol. 2. Page 11-32, part j; and Vol. 3, Page IV. J
(c)-l last sentence: There are data available which
suggest an increase with time in plant plutonium uptake
from soil. (See J. Environ. Quality. Vol. 2, No. 1, 1973,
and Health Physics Journal 19:487-491, 1970. ) These data
should be discussed here.
9. Vol. 3, Page IV. A-13, last sentence of second paragraph:
the standard referred to in this sentence should be refer-
enced or discussed. Such a standard has not been, to our
knowledge, proposed by a recognized radiation standard
setting group.
10. Vol. 3, Page IV. J. (A)-9: The numbers used in the
population dose commitment equation cannot be considered
conservative since higher P/A and lower deposition velocity
values have been strongly suggested. Both of these trends
would increase the dose.
11. Vol. 3, Page IV. J. (C-7, second paragraph: The ingestion
pathway should not be dismissed as a potential pathway for
exposure to actinides. If gut absorption increases and plant
uptake increases (both are possibilities), then this pathway
could be as important as important as the air pathway.
12. There is apparently a contradiction in philosophy concerning
fission-gas-release in MOX fuels (p. IV C-51). Since this
aspect is related to fuel rod performance (and safety) charac-
teristics, the question of significant or insignificant increases
in fission-gas-release should be resolved and included in
the final statement.
13. p. IV J (A)-2 A semi-infinite cloud dose calculation was
utilized in WASH-1327 to compute the dose due irradiation
by nuclides in the atmosphere. A comparison of external
gamma whole body dose calculations using finite and semi-
infinite cloud dose models is presented in EPA-520/ 1-74-
004(1). It is noted that at close distances to the facility
stack a semi-infinite cloud assumption results in a very
low ground level concentration and gross underestimates
of dose since it ignores gamma rays emanating aloft.
Therefore, a finite cloud rather than a seminfinite cloud
dose model should be utilized to compute close in external
doses from evaluated atmospheric emissions of radionuclides.
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14. p. IV •} (A)-2 A value of 7mg/cm was assumed for the
density thickness of the dead layer of the outside of
human skin in computing " the beta dose. New values of
epidermal thickness are reported by Judi T. Whitton (2)
and it is recommended that "for radiological protection
purposes it is appropriate to replace the value of 7mg/
cm , currently used for minimal epidermal thickness on
all body sites, by a value of 4mg/cm for average epidermal
thickness. " We concur with the recommendation by Whitton.
15. In determining the dose rate from airborne beta radio-
activity, it is stated that a graph (Fig. 7.5, Meteorology
and Atomic Energy, 1968, p. 332) was utilized to determine
the maximum beta rad dose versus maximum beta energy
through a 7mg/cm absorber. Because of an error in the
apparent absorption coefficient, the dose at a depth of
7mg/cm is low in Fig. 7. 5 of Meteorology and Atomic
Energy, 1968 (3). The depth dose values in Figure 7.5
utilizes results from equation 7. 25c on p. 331 (3) which
is in error by a factor of 2. The correct simplified
expression for the apparent absorption coefficient
obtained from Loevinger, et al. (4) is as follows:
v - 18.6 cm /gm
(E - 0.036) 1. 37
where v - apparent absortion coefficient
E = maximum beta energy emitted
Therefore, the low beta depth dose values presented
in WASH-1327 should be recomputed based on an average
epidermal thickness of 4mg/cm and corrected apparent
absorption coefficient values. The graph on p. 332 of Meteor-
ology and Atomic Energy, 1968 (3) should not be utilized
for depth dose values.
16. pp. IV J (A)-3-4 Since the INREM computer code was used
to compute the 50-year dose commitment from the inhalation
and ingestion of radionuclides, the pertinent assumptions
utilized in this code should be presented in WASH-1327. The
information presented in WASH-1327 regarding INREM is not
complete enough to allow an evaluation of dose assessment
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34
techniques to be made so conclusions cannot be reached
regarding the validity of the presented dose com-
mitment estimates in WASH-1327. A complete copy of the
code with an explanatory text should be made available
to all reviewers so that an evaluation of the INREM
dose assessment techniques can be made.
17. pp. IV J (A) -7-8 In the analysis of the aeolian pathway, only
the Pasquil D dispersion regime was considered in computing
the generalized aeolian dilution factor values. Ignoring other
representative dispersion regimes significantly underestimates
the annual average X/Q value for the 100 m chimney release at
500 meter downwind. More representative assumptions would
result in a value of similar magnitude to those presented for
downwind distances of 1, 1. 3, and 2. 5 kilometers. Reference
5 presents annual average X /Q values at 500 meters for 25 LWR
site regimes and an average value of 6.157 x 10 sec/m is
reported for a 100 meter release hight. The 500 m value for the
m chimney release in Table IV J-(A. 1) should be modified to
reflect more reasonable dispersion values and any dose cal-
culations made using this dilution factor should be corrected
since they underestimate the dose by approximately 10,000.
References for comments 14-17:
1. Martin, J. A. . C. B. Nelson, and P. A. Cury, AIREM
Program Manual- A Computer Code for Calculating Doses,
Population Doses, and Ground Depositions Due to Atmospheric
Emissions of Radionuclides, Office of Radiation Programs,
U.S. Environmental Protection Agency, Washington, D. C. ,
EPA-520/1-84-004 (May 1974).
2. Whitton, Judi T. , "New Values for Epidermal Thickness
and Their Importance, "Health Physics, Vol. 24, pp. 1-8
(January 1973).
3. Slade, D. H. , ED. , Meteorology and Atomic Energy
1968, U.S. Atomic Energy Commission/Division of Technical
Information (July 1968).
4. Loevinger, R. , E. M. Japha, and G. L. Brownell,
"Discrete Radioisotope Sources," Chap. 16, Radiation
Dosimetry, Academic Press Inc., New York (1956).
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5. Final Environmental Statement Concerning Proposed
Rule Making Action: Numercial Guides for Design Objectives
and Limiting Conditions for Operation to Meet the Criterion
"As Low As Practicable" for Radioactive Material in Light -
Water-Cooled Nuclear Power Reactor Effluents, Prepared
by the Directorate of Regulatory Standards, U. S. Atomic
Energy Commission, Vol. 1, p. 6B-32, Table 6B-2. WASH-
1258 (July 1973).
18. Page IV H-2; lines 26 and 27
Indicate the basis for the waste generation rate of
4 x 10 ft per year and the burial ground acreage require-
ment. These values appear to be quite different from
numbers obtained from WASH-1539 and ORNL TM-3965.
Page IV H-4; Accident and General Exposure Sections
Indicate or reference the basis used for the factor
numbers and original dose numbers.
19. Page IV H-4; Accident and General Exposure Sections
Indicate or reference the basis used for the factor
numbers and the original dose numbers.
20. Page IV H-7; Uranium Mills Section
Indicate the basis used for calculating the curie
release.
21. Page IV 11-10; line 20
Indicate basis for volume and radioactivity of waste
generated in 1990.
22. Page IV H-32; lines 6 and 7
Indicate other kinds of low-level liquid wastes which
will be produced and why they can't be cleaned up and
recycled. In considering solidification indicate other
alternatives which are available besides cementing.
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23. Page IV H-39; lines 13-15
Could the radioactive liquid wastes be recycled?
In considering solidification indicates other viable
alternatives available besides cement.
24. Page IV H-40; lines 4-6
After the processing of the contaminated water
for the removal of radioactivity indicate what is done
with the processed water. Indicate what methods and
limits will be used to distinguish between uncontaminated
and contaminated water.
25. Page IV H-46; lines 14 and 15
Since the AEC is eliminating the routine use of surface
and near surface techniques that depend on soil to remove
radioactivity from liquid wastes (WASH-1202-73 p. 27) the
statement concerning high absorptive capacity of the soil
should be further clarified as perhaps a 3rd or 4th order
protective device and not as a secondary backup as might
be inferred.
26. Page IV H-51; line 25
Show the basis for the assumption of waste radioactivity
concentration of 0. 003 Ci per ft .
27. Dose calcuations for the dropping and rupture of a waste
canister at the Retrievable Surface Storage Facility (RSSF)
are made at a distance of 5 miles from the facility stack. This
5 mile distance is stated to be the closest assumed access for a
member of the public. If this 5 mile exclusion distance is not
a documented siting policy for the RSSF then dose calculations
should be presented for distances closer to the facility stack.
As a minimum, the reason for the use of the 5 mile exclusion
distance should be presented.
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28. it is not made clear in the EIS the extent to which plutonium is
or is not the dominant environmental consideration. A thorough
discussion of the sources, biological availability, and the
metabolism of the transplutonic isotopes would be helpful for
evaluation of the EIS. Durbin has presented data on the differences
in metabolism of transplutonic elements (P. W. Durbin, Distribution
of the Transuranic Elements in Mammals, Health Physics 8:665-671
1962). Additional information on distribution and metabolism
variations both by isotopes and by species and age for plutonium and
transplutonic isotopes can be found in the P_roceedings of t;he Hanford
Symposium on the Biological Implications of the Transuranium Elements
Health Physics 22 16, 1972. Implications of these differences should
be included.
29. Page IV, J-2. Because only fatal cancers are enumerated in the
EIS, the somatic health effects listed underestimate the projected
impact by a factor of two. If the total cancer incidence, not just
cancer fatalities were included in the EIS, an additional perspective
would be provided.
30. Page IV, J-3, Table J-l, there is evidently a misprint. Appendix
A to Chapter IV-F is limited to some effluent information pertinent
to the uranium mining and/or milling industry; but it does not give
the basis for the man-rem number listed in the succeeding Tables.
31. Page IV, J-7 c, second paragraph. Differences between the
physical and chemical characteristics of Pu fallout and particulate
Pu from mixed oxide fuels should be described so that the reader can
judge the relevancy of fallout plutonium to the problem of interest
here. Indeed it would be helpful to discuss the particulate nature
of Pu in mixed oxide fuels early in the Chapter.
32. Page IV, J-7c, third paragraph. ICRP #6 page 8 would seem to
contradict the conclusion that the absence of a consideration of hot
particles is a satisfactory state of affairs to standard setting
bodies. The Los Alamos reference offered for the assertion given in
the EIS is inadequate support for this assertion in view of the
statement by Sanders, Thompson and Bair in AEC Symposium Series 18,
"Nonuniform irradiation of the lung from deposited radioactive
particulates is clearly more carcinogenic than uniform exposure (on
the basis of total lung dose), and alpha radiation is more
carcinogenic than beta irradiation."
33. Page IV, J-8, second paragraph. This one sentence paragraph
could mean that either the particulates in MO fuels are not subject
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38
to accidental distribution or that no health consequences due to
particulates would follow such an event. Either way, this important
conclusion should be discussed in full with better documentation.
34. Page J-14, Table J-13. In view of the possibility (see earlier
comment) that the increased dose from mixed oxide fuel fabrication
and reprocessing does not out weigh the reduced dose from less mining
use of the label of "Risk Reduction" may be premature.
35. Page IV, J(A)-2. From the text in "Meteorology and Atomic
Energy" it would appear that the Fig. 7.5 (ibid) referred to here was
based on an incorrect calculation of beta-ray attenuation in skin.
The sensitivity of the results presented to this error should be
evaluated or better yet use Martin Berger's more recent calcuations
in Health Physics, Vol. 26, No. 1, January 1974,
36. Page IV, J(A)-3, second paragraph. Applicability of data from
the "particular plot of ground" at ORNL to rest of the United States
should be discussed in terms of soil characteristics, climate,
cropping practices, etc., so that the importance of this study can be
placed in perspective by the reader.
37. Page IV, J(A)3. The estimate of environmental concentrations of
1-127 and H (water vapor) are quite critical to the final risk
evaluations and should be documented in full. Variations in these
parameters could affect large portions of the population, for example
persons living in regions with iodine deficient soils. Perhaps those
cases should be discussed also.
38. Page IV, J(A)-4d, first paragraph. The breathing rate used is
for a "reference man." Consideration should be given to other members
of the population also. Were women and children not considered?
39. Ibid, 1, fourth paragraph. That the range of resuspension varies
between 10~2 - 10-13 should be referenced to the original source
documents. It is not clear that this range is appropriate for
Plutonium in the environment or that 10-*' has been verified
experimently.
40. Ibid, 1, last paragraph. Has the purported decrease of
resuspension with time been observed in areas other than desert type
such as used for bomb testing? Changes in the amount of resuspended
Plutonium in the vicinity of Rocky Flats, which is more likely to be
similar to the problem of interest here, would help show the general
applicability of these data. In addition, particulate resuspension
in urban and suburban areas should also be considered in the EIS.
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1. Page IV, J(A)-5, fifth paragraph. If the longest study of
resuspension decreasing with time is, as reported in the EIS, eleven
lonths, the 50 day half life used here corresponds to a reduction of
ibout 30 in plutonium resuspension. The applicability of such data
:o a reduction of 100,000 (as is done in this EIS) should be
justified by an appropriate analysis, since the magnitude of the lung
loses is quite sensitive to the resuspension variables.
42. Page IV, J(8)-8. AEC reports documenting the k factors used to
calculate dose are not described in the EIS. The selected conversion
ractors may be valid but there is no way of examining the underlying
assumptions used in their development.
43. Page IV, J(B)-1, first paragraph. Animal experiments have
identified the need to know the physical and chemical forms of the
;ransuranics since any anticipated distribution is closely related to
these questions. Animal experiments have also identified definite
species differences which make extrapolation to man uncertain. As
pointed out by Engel (S. Engel, Comparative Anatomy and Pulmonary
Air-Cleansing Mechanisms in Man and Certain Experimental Animals,
Health Physics 10:967-971, 1964) : "I should .like to stress that
neither the lung of the dog nor cat are typical examples of the
mammalian lung. In other words, if either animal is used for
laboratory experiments, this fact must be borne in mind." Current
studies on morphometrics of the lungs of experimental animals at
Lovelace Foundation show definite differences between man and dogs,
rats and hamsters. The differences include branching angles,
branching angle as a factor of parent airway diameter and functional
anatomy. (Respiratory Tract Deposition Models Project Staff Reports,
Dec. 1972, March 1973, July 1973 and April 1974). Additional
information on species age and isotope interrelationships can be
found in the Handbook of Experimental Pharmacology XXXVIX
Uranium*Plutonium+TransBlutonic Elements, Springer-Verlog, New York,
1973. Particularly Chapter 10 (Distribution, Excretion and Effects
of Plutonium asa Bone-Seeker) and Chapter 18 (Metabolism and
Biological Effects of the Transplutonium Elements). Perhaps, the
relevance of animal data to the problem of interest here should be
critiqued so that the reader will not read too much into the reported
results.
44. Page IV, J(B)-1, third paragraph. The body of data on
distribution and retention of «3«pu in man is severely restricted bv
the fact that only selected tissues have been analyzed and they may
not be the appropriate ones. Transuranium Registry data show that
any of a wide variety of tissues may have the highest organ
concentration of plutonium and until sufficient data are obtained it
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40
will be difficult to adequately assess the problem in man (United
States Transuranium Registry Summary Report to June 30, 1974, HEHF
#22, 1974).
45. Ibid, last sentence. Comparative pathology is not so far
advanced that one can assume that pathological changes observed in
animals are a true or adequate picture of the hazards to man from
transuranics. For example the majority of lung malignancies reported
in animals after plutonium inhalation are adenocarcinomas or other
peripheral cancers. However as Kuschner points out:
I feel very strongly that the term tumors of the
lung is an unfortunate one. Even cancer of the lung is
an unfortunate term. I think all of us here know that
cancer is a disease of a tissue, not of an organ. There
are particular determinants that relate to the
production of a bronchogenic carcinoma that probably do
not hold for tumors of more peripheral sites.
I believe that we can study the mechanism of
malignant transformation and the factors that relate to
it in any part of the body and in any tissue. Perhaps
peripheral lung tumors are a convenient method of doing
this, but they don't relate to the immediate problem;
that is, what are the particular factors that go into
the induction of - and the pathogenesis of -
bronchogenic carcinoma in humans.
It is for this reason that I think the induction of
pulmonary adenomas, or adenocarcinomas, is not pertinent
to the lung tumor problem. They are pertinent to the
tumor problem, but not to specific induction of the lung
tumor that we are concerned with, bronchogenic
carcinoma.
I think it might be important, too, in regard to
Dr. Sanders' presentation these Proceedings, pp. 285-
3031, to point out that as far as I know the tumors
produced by J. F. Park and by C. L. Yulie were all
peripheral tumors of alveolar orgin. Some of the dosage
inconsistencies between alpha and beta emitters which
did produce bronchogenic carcinoma might perhaps be
explained by the fact that we are dealing with a
different tissue.
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(S. Laskin, M. Kuscher and R. T. Drew, Studies in Pulmonary
Carcinogenesis, pp 321-351 in Inhalation Carcinggenesis, AEC
Symposium Series 118, 1970). Also a discussion of the comparative
pathology of "lung tumors" is presented on pp 467-472 of the Panel
Discussion in Morphology of Experimental R,esp.iratory Carcinogenesis
(AEC Symposium Series #21, 1970). The use of such data to evaluate
health effects in humans should be fully explained.
Page IV, J(B)-2, third paragraph. The statement in the EIS that
"Unfortunately no evaluation of economic cost that might be due to
the linear assumptions, as compared to other assumptions, has yet
been done" might be more appropriate in the cost-benefit section.
The idea that the dose-risk relationships used to evaluate potential
health impacts from nuclear energy should be subject to a cost
benefit analysis has important public health policy implication and
should either be explored further in a "generic" impact statement of
this type or deleted.
46. Page IV, J(B)-4. The genetic effects calculations referred to in
Table IV, J(B-l) and in the fourth paragraph are adequate for a
population which replaces itself in a 50 year period, that is the
replacement rate ( birth rate) is 2% per year. If the birth rate is
more than 2X per year or less than 2% per year these genetic risk
estimates will proportionately increase and decrease accordingly.
This should be stated.
47. Page IV, J-(B-4), second paragraph. Reference if any should be
cited for the zero effects estimates and the value of the assumed
threshold dose rate used here.
48. Page IV, J(C)-7, 2, first paragraph. The statement that the BEIR
report calculates average dose and estimates tumor incidence on the
basis of the uniformly irradiated lung is inaccurate. BEIR report
lung tumor estimates are based on the radiation dose to cells of the
bronchial epithelium and it is explicitly so stated. (BEIR, Summary
of Risk Estimates for Bronchial Cancer, p. 150) . The specific risk
estimates are for irradiation of the basal cells of the bronchial
epithelium as indicated in the BEIR report (p 148, p 154 BEIR
Report). This EIS should be corrected to accurately reflect what the
BEIR report says of the BEIR report is referenced.
49. Page IV, J(C)-8a. Since the sample size in the Las Alamos study
referred to makes a negative finding almost inevitable, the
probability of a type II statistical error, false negative, should be
given to avoid possible erroneous conclusions. Rough calculations
using values of 1 rad/year bone exposure and 8 rad/year lung exposure
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(the approximate average annual dose rate for the maximum accumulated
organ dose reported in A Twenty-Seven Year Study of Selected Los
Alamos Plutonium Workers, LA-5148-MS, 1973) yield an annual dose
estimate of 250 man rem in bone and 2000 man rem in lung for the 25
workers in the Los Alamos study.
Using BEIR report risk estimates there would be an annual risk of
8 x 10~2 lung cancers and 3 x 10~3 lung cancers in the workers. If
the 1966-1968 Connecticut Tumor Registry mortality data are used the
follow-up time required to observe a radiation related increase in
mortality can be calculated.
To observe a difference in exposed and a normal populations at
the 90% level a 33 year follow-up would be required in the lung
cancer and a 667 year follow-up in the bone cancer evaluations. For
a 95% level 53 years and 1098 years respectively would be required.
The follow-up time required would be further increased by the
length of the latent period before induction of the cancer. If a 20
year latent period is used the difference between exposed and a
normal population, if present, probably would not be identifiable
until the year 2020, a period of time beyond the expected lives of
those workers discussed in the Los Alamos Study.
The low relevance of negative findings in the Los Alamos Study
population at the present time should be explained to put the
information in perspective.
50. Page IV, J(C)-7. Several general questions concerning LA-5483,
used here as part of the EIS should be answered before its
applicability to human risk evaluation is accepted by the AEC.
Can "oat cell" carcinomas be produced in animals by
irradiation with any radiation type or is it strictly a human cancer?
Have animals exposed to radiation, particularly external
radiation, been adequately examined to insure that reported lung
tumors are primaries, not secondaries to Harderian gland tumors
(rodents) or mammary tumors (dogs and rodents)?
51. Page IV, J(C)-9, 4. The "animal data" comment concerning use of
animal data for comparative pathology page IV, J(B)-11 also applies
here. In addition, the admonitions of Bair (W.J. Bair, Inhalation of
Radionuclides and Carcinogenesis, pp. 77-101 in Inhalatj.Oji
Carcinoqenesis, AEC Symposium Series #18) might also be considered:
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The experimental animal studies have clearly
demonstrated the carcinogenicity of radionuclides
deposited in the lung. Though we are tempted to
extrapolate these results to man, at least
qualitatively, we are well advised to exercise
caution, because radon and radon decay products
have not induced lung cancer in experimental
animals, yet are strongly suspect as being the
cause of lung cancer in miners. Extrapolation of
experimental animal data to man on a quantitative
basis can be even more misleading because a common
denominator for comparing radiation doses to lung
tissue has not been identified. Thus, it is
difficult to relate the doses estimated for the
bronchial tissues of the uranium miners to the
doses calculated for the experimental animals. It
would seem urgent that the next generation of
experiments be directed toward this problem.
Factors which need evaluation are the relative
susceptibilities of human and experimental animal
tissues to radiation-induced cancer, the relative
latent periods for the induction of cancer in man
and other species, possible species differences in
the rates of clearance and trans location of inhaled
radionuclides, and a number of other factors which
pertain to the still unknown mechanisms of tumor
induction. A serious obstacle to evaluating
results of animal experiments with inhaled
radionuclides and extrapolating them to man is the
difficulty in identifying the effective biological
target tissue in the lung and measuring the
radiation dose to that tissue.
That the state of the art has not advanced much beyond that point,
should be made clear to the readers of the EIS.
52. Page IV, J(C)-10, third paragraph. Implying that plutonium
deposition in lymph nodes only rarely induces tumors in lymphatic
tissue is probably erroneous and/or specious. Bair et al (W. J.
Bair, J. E. Ballou, J. F. Park and C. L. Sanders, Plutonium in Soft
Tissues with Emphasis on the Respiratory Tract, pp 502-568 in
Ijandbook of Experimental Pharmacology ^XXVf t Uranium -
Transplutonic Elements^ Springer-Verlog, New York 1973) mention some
reported malignant lymphomas and also the possibility that plutonium
deposited in lymph nodes may cause thoracic sarcomas by irradiating
local endothelial and mesothelial tissues.
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Of the malignant lymphomas, two observed in dogs and several in
rats after inhalation of plutonium were reported "..., but the
.ncidence was probably not greater than in controls." In the two
:ases reported for dogs the pattern of lymph nodes involved was not
readily relatable to the nodes with greatest plutonium deposition nor
:o natural lymph drainage patterns since one involved mandibular and
esenteric nodes the other all nodes and viscera (E. B. Howard, The
lophology of Experimental Lung Tumors in Beagle Dogs, pp 147-160 in
torphology of Experimental Respiratory garcinQgenesis, AEC Symposium
Series f21, 1970). One lymphoma was reported in a dog after
subcutaneous injection of plutonium oxide. However, in this case
also the distribution of lymph nodes involved suggests the retrograde
ovement of plutonium in the lymphatic system would be needed. Since
Dnly the prescapular lymph node (not involved in the malignant
.ymphoma) appears to have been radioassayed it is difficult to tell
.f there was any plutonium in other nodes (J. L. Lebel, E. H. Bull,
j. J. Johnson and R. L. Watters, Lymphosaicoma Associated with Nodal
Concentration of Plutonium in Dogs: A Preliminary Report, Amer J.
7et. Res 31: 1513-1516, 1970). In studies done by Bistline (R. W.
3istline,"~Translocation Dynamics of 239-Plutonium, COO-1787-20, 1973)
-here is no indication of transfer of Pu from regional lymph nodes to
sontralateral nodes or visceral nodes. Further, Dagle (G. E. Dagle,
jymph Node Clearance of Plutonium from Subcutaneous Wounds in
Beagles, COO-1787-18, 1973) reporting on pathology of lymph nodes
containing plutonium states:
"The eventual sequesting of plutonium in the scar tissue of lymph
lodes probably alleviates the potential of the alpha radiation
damaging the host. The alpha particles only penetrate soft tissues
ap to 50 and the presence for rather hypocellular scar tissue of
:his distance around the plutonium means that the alpha particles
lave ceased to come in contact with parenchymal cells. If
parenchymal cells are no longer damaged directly by irradiation,
ihere may be less chance of mutagenic or other action causing tumor
induction.
The final lymphoma reported was seen in a pig following
intradermal injection of plutonium. This lymphomas is also probably
lonrelevant since the doses administered were split to between 18 and
152 separate injection sites (J. W. Cable, V. G. Horstman, W. J.
21arke and L. K. Bustad, Effects of Intradermal Injections of
Plutonium in Swine, Health Physics 8:629-634, 1962) so that many
regional lymph nodes would be involved and irradiated. However, the
lymphosarcoma developed in a visceral node, the hepatic lymph node.
Thus, there is no causality demonstrated in any lymphatic tumors
associated with Pu. The observation of lymphoproliferative diseases
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in occasional animals is not unexpected and should be placed in
perspective if mentioned.
53. Page IV,J(C)-15. Inhalation studies in beagles are poor sources
of data since the doses administered were so large that radiation
fibrosis and edema were induced. These processes isolated that
inhaled material and destroyed normal physiology and histology. As
Howard reported (E. B. Howard, The Morphology of Experimental Lung
Tumors in Beagle Dogs pp 147-160 in Morphology of Experimental
Respiratory Carci,qpgenesis, AEC Symposium Series 121, 1970) in the
beagles the following relationships were observed, an alveolar
deposition of 0.1 yCi/g or more, associated with acute death, 1-12
months post exposure; 0.05 /g with subacute death, 1-5 years post
exposure and only at doses of about 0.01 uCi/g is the delayed effect
response observed. Bair etal (W. J. Bair, J. E. Ballou, J. F. Park
and C. L. Sanders, Chapter 11 Plutonium in the Soft Tissues with
Emphasis on the Respiratory Tract, pp 503-568 in Handbook of
Experimental Pharmacology XXXVI^ Uraqium*Plutonium«Transp3,utonic
Elements. Springer-Verlag, New York, 1973) report that 39% of the
beagles died of lung neoplasia and 100X of those surviving more
than 1600 days past exposure died of pulmonary neoplasia. There were
two mortality curves extractable from the data, one for fibrosis (5-
900 nCi/g deposited), the other for neoplasia (3-45 nCi/g deposited).
The exposure levels for most of the beagles was too high to allow
delayed effects-neoplasia-to develop Results are not at all
representative of what might be expected at lower exposure levels.
Current experiments using lower exposure levels may be more pertinent
to expected population exposures. These facts should be made clear
to the reader.
54. Page IV, J(C)-16, second paragraph. The assumption of
relationship of lymphopenia, lymph node pathology, reduced
immunocompetancy and pathogenesis of plutonium-induced lung tumors
should be explained and justified.
55. Ibid, fourth paragraph. It is premature to state the gonads are
not critical organs. Effects of plutonium on gonads have not been
examined for below the level of acute effects. Studies on pre- and
post-natal wastage, future reproductive capacity, teratogenesis or
other congential effects on progeny have not been tested for.
Ovcharenka (E. P. Ovcharenko, An Experimental Evaluation of the
Effects of Transuranic Elements on Reproductive Ability, Health
Physics 22:641, 1972) reported decreased viability, delayed physical
development, disturbance of blood formation, change of
radiosensitivity and depression of sex function in offspring of
animals receiving 23'Pu or 2*4Am and increased uterine death in
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46
offspring of males, receiving the same isotopes, mated to normal
females. These results imply direct effects on the gonads and/or the
reproductive tract. The data on biological distribution and
estimated dose provided by Fish etal (B. R. Fish, G. W. Keilholtz, W.
S. Snyder and S. D. Swisher, Calculation of Doses of Accidentally
Released Plutonium from an LMFBR, ORNL-NSIC-74, 1974) suggest that
the impact of Pu on the ovaries may not be negligible. The need for
further examination of the question should be considered.
56. Ibid, fifth paragraph. The experiments alluded to which are
still in progress, while not showing increased mortality in neonates
as stated here, have demonstrated an age-related difference in
development of tumors and other age differences in response to
Plutonium insult which is not mentioned. (Seattle 1974, IRRS
meeting.) Perhaps the EIS could be more inclusive in describing these
studies.
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