United States
Environmental Protection
Agency
Office of Radiation Programs
Washington DC 20460
ORP/CSD-78-2
May 1978
Radiation
&EPA
Proceedings of a Public Forum
on Environmental Protection
Criteria for Radioactive Wastes
30March-1 April 1978
Denver, Colorado
-------
PROCEEDINGS OF
A PUBLIC FORUM ON
ENVIRONMENTAL PROTECTION CRITERIA
FOR RADIOACTIVE WASTES
30 March - 1 April 1978
Stouffer's Denver Inn, Denver, Colorado
Sponsored by
Office of Radiation Programs
U.S. Environmental Protection Agency
-------
PROCEEDINGS OF
A PUBLIC FORUM ON
ENVIRONMENTAL PROTECTION CRITERIA
FOR RADIOACTIVE WASTES
CONTENTS
Preface 1
Introduction 3
Address to the Forum
Hon. Gary Hart 5
EPA's Welcome
William D. Rowe 9
TOPIC I: WHAT IS RADIOACTIVE WASTE?
Criteria for Designating Material as Radioactive Waste:
A Statement of Issues and Objectives of Working Group I
Harry 3. Pettengill 15
Summary and Conclusions of Working Group I 19
Responses of Forum Participants to Summary and
Conclusions of Working Group I 25
TOPIC II: WHAT ARE THE CHARACTERISTICS OF AN
ADEQUATE RISK ASSESSMENT AND OF
ACCEPTABLE RISKS FROM RADIOACTIVE WASTE?
Risk in Radioactive Waste Management:
A Statement of Issues and Objectives of Working Group II
Stanley Lichtman 31
Summary and Conclusions of Working Group II 37
Responses of Forum Participants to Summary and
Conclusions of Working Group II 47
TOPIC HI: WHAT CONTROL MEASURES SHOULD BE
UNDERTAKEN FOR RADIOACTIVE WASTES?
Control Measures for Radioactive Waste:
A Statement of Issues and Objectives of Working Group III
Joseph E. Fitzgerald, Jr. 55
Summary and Conclusions of Working Group III 59
-------
Responses of Forum Participants to Summary and
Conclusions of Working Group III 63
PREPARED STATEMENTS FROM THE PUBLIC 67
ATTENDEES
-------
PREFACE
The Environmental Protection Agency has been empowered to provide radiation pro-
tection guidance for use by Federal agencies which develop standards for various
radiation exposure circumstances. This authority was transferred to EPA from the
former Federal Radiation Council by Reorganization Plan No. 3 on December 2, 1970.
Presently, EPA's Office of Radiation Programs is developing environmental protection
criteria for radioactive wastes to ensure protection of public health and the general
environment.
To facilitate public input to this program, EPA has sponsored two public Workshops (held
at Reston, Virginia, on 3-3 February 1977 and at Albuquerque, New Mexico, on 12-14
April 1977) and the Forum reported herein. Each was attended by approximately 300
individuals, representing public interest groups, government, industry, and academia.
The two Workshops were general and were designed to allow the public to identify and
discuss the issues regarding radioactive waste management which they perceived as
relevant to environmental criteria.- The output of those workshops was utilized by EPA
in the preparation of its initial formulation of environmental protection criteria, which
was published as Background Report—Considerations of Environmental Protection Cri-
teria for Radioactive Waste (February 1978). The third meeting, the Denver Forum,
was intended to focus on this Background Report and to provide recommendations to
EPA on ways to improve the initial formulation of the criteria before the Agency puts
forth formal proposals later this summer. The purpose of this document is to record in
summarized form the proceedings of the Denver Forum.
-------
INTRODUCTION
The Environmental Protection Agency is currently conducting a program to develop
environmental radiation protection criteria and generally applicable environmental
standards for radioactive wastes. These environmental radiation protection criteria for
waste management will consist of general policy statements, which detail the basic
philosophy, conditions, and issues that will be considered and reflected in the devel-
opment of generally applicable environmental radiation standards and in the selection of
appropriate waste disposal technologies and sites. The generally applicable environ-
mental standards for specific sources of radioactive wastes will provide numerical limits
that necessarily will be implemented by the Department of Energy (DOE) and the Nu-
clear Regulatory Commission (NRC) through their respective responsibilities in the field
of radioactive waste management. In addition to these activities, additional standards
will be developed as required by the Ocean Dumping Act and the Resource Conservation
Recovery Act.
In the program to develop environmental protection criteria for radioactive wastes, EPA
recognized that certain human value judgments would have to be made. Formulation
of criteria, it is felt, would best include input from the public, industry, academia,
and the responsible Federal and State authorities.
As mentioned in the preface to this document, two public workshops were held by EPA
prior to the Denver Forum. Proceedings of those workshops are available, free, by
writing to the EPA Office of Radiation Programs. Please refer to the Reston Workshop
as U.S. EPA Report ORP/CSD-77-1 and the Albuquerque Workshop as U.S. EPA Report
ORP/CSD-77-2.
The first day of the Denver Forum included three topical presentations by members of
EPA's Office of Radiation Programs (ORP). These presentations were designed to pro-
vide the rationale established by EPA in arriving at its initial formulation of environ-
mental criteria. Consequently, three separate working groups were formed to review
and provide recommendations on the initial form of the criteria as published in the
Background Report for the Denver Forum entitled "Considerations of Environmental
Protection Criteria for Radioactive Waste." During the first two days, the working
groups each convened for three discussion sessions, which were presided over by mod-
erators unaffiliated with ORP. The moderators allowed the working groups autonomy,
within the boundaries of order and relevance to the topic of discussion. After the gen-
eral sessions, each working group outlined the contents for its summary report and se-
lected a committee to write it. On the final day of the Forum a review period was
scheduled to permit each entire working group to evaluate its report and agree on any
changes before finalizing it. During the final plenary session, a selected participant
read each working group report and the report committee fielded questions from
participants.
This document serves as a record of the proceedings of the Denver Forum. It is divided
into three topical sections, each made up of a statement of issues and objectives of the
working group, the summary and conclusions of the working group, and the responses
of Forum participants to the working group's summary and conclusions. Prepared
statements from the public were accepted for ten business days following the Forum and
they have also been included in this report.
-------
The Agency will consider those comments put forth by the participants at the Denver
Forum and other submitted statements before publication of environmental criteria in
proposed form later this year.
-------
ADDRESS TO THE FORUM
Hon. Gary Hart
U.S. Senator (Colorado)
Nuclear waste disposal is one of the most serious environmental and public health issues
facing our country today. Some say it is the Achilles' heel of nuclear energy. This
matter is so serious that, if an acceptable solution is not found, we may be forced to
look seriously at halting further development of nuclear power as an energy resource.
Yet, for thirty years, since the dawn of our atomic age, we have failed to come to
terms with this problem. We have failed to find permanent, safe, and acceptable so-
lutions. We have failed to include the cost of waste disposal in the projected cost of
nuclear energy. We have failed to outline government or industry responsibility. And
we have failed to confront the frightening long-range implications of having created a
substance that will last thousands of years longer than all recorded human history.
We are here today to give this issue the high priority and focus it requires.
We have been accumulating nuclear waste since 1945, when the first atomic bomb was
exploded. Today we have 50 million cubic feet of radioactive waste -- enough to make
a pile 1,000 feet high on the football field at Denver's Mile High Stadium.
Since the first commercial nuclear power plant went on line at Shippingport, Pennsyl-
vania in 1957, we have accumulated 5,000 tons of commercial waste, and each of the
68 nuclear reactors in use today is adding to the waste problem at the rate of 30 tons
per year.
Yet, to this day, we have no plan for the safe and permanent disposal of any of these
nuclear wastes. All of our solutions have been temporary—merely holding actions
waiting for the right solution, the right policy, or the right time.
The stakes involve more than public health and the environment. Our energy future is at
stake too. Sixty-eight nuclear reactors are operating in this country today. By the year
2000, nuclear advocates project 500 reactors contributing to energy supplies. But
recent trends indicate we may never reach that goal. Expansion of nuclear energy fa-
cilities is absolutely dependent on location of nuclear waste repositories satisfactory in
every sense.
The political climate is changing. The public and its elected representatives will demand
a halt to nuclear energy development if answers are not provided.
In fact, the public reaction to the nuclear waste problems has already surfaced in sev-
eral states. As a result of plutonium leakage from Maxey Flats, Kentucky may ban
nuclear waste disposal within the state. There is strong support for a similar move in
Illinois, even though half its electricity comes from nuclear power. And California, by
law, has prohibited licensing any more nuclear power plants until a method has been
demonstrated and approved for permanent disposal of high-level nuclear waste.
It comes down to this: We must devise and build a nuclear waste repository which will
handle all of the waste we have now, as well as that we will generate in the future. That
repository must be capable of safely isolating nuclear wastes from man and the
-------
environment. And that repository must last for thousands of years withoout relying on
inspectors or guards to maintain it.
Most scientists believe that safe, permanent storage is feasible, and various ideas have
been explored. We could shoot the wastes into outer space; we could store them on the
ocean floor; or we could bury them in deep geological formations. Yet, despite the fact
that we have produced nuclear weapons for 30 years and used nuclear power for 20, none
of these possible solutions has been satisfactorily developed.
For years, the government has promised that a final solution was just around the corner.
As early as 1955, the Atomic Energy Commission directed the National Academy of
Sciences to study the problem and find a solution. Seventeen years later, in 1972, the
AEC began talking about building a permanent geological storage facility and set a date
in the early 1980s. Then, in 1976, the Administration [ERDA, successor to AEC] was
forced to revise its schedule and called for the establishment of a geological repository
by 1985. It now appears even that timetable cannot be met. Just two weeks ago the
Department of Energy announced that the 1985 deadline for building a waste disposal
facility will be delayed a minimum of three years.
With growing amounts of nuclear wastes in temporary storage, this kind of open-ended
delay is disturbing. And, it is all too reminiscent of the flawed history of our past nu-
clear waste management efforts.
To date, we have avoided disaster. Despite the lack of a clear and concrete nuclear
waste program, there have been no immediate casualties and there has been no whole-
sale contamination of large parts of our environment. But short of that, we have com-
piled a complete catalogue of errors.
Undertakings by the nuclear industry have failed. In West Valley, New York, an
industry fuel reprocessing project was abandoned in 1972 when resolution of safety
concerns made the venture unprofitable. It will cost over half a billion dollars to clean
up the West Valley plant and dispose of the orphaned high-level radioactive wastes in
temporary storage there.
The government, too, has made costly mistakes. Despite the long history of our nuclear
weapons program, 70 million gallons of high-level waste are still in temporary storage
in Washington State and South Carolina. Over a half million gallons of this corrosive
and toxic liquid have leaked out of steel containers onto the ground. Moving the rest
of the waste into permanent storage will cost the taxpayer almost $20 billion.
Nor have federal regulations been adequate to confront the problem. In the absence of
government standards, builders used cheap, but radioactive, uranium mill tailings to
construct homes and schools in Grand Junction, Colorado. Cleaning up that mistake is
costing the taxpayer over $15 million. At least another $100 million will have to be
spent cleaning up exposed and unattended mill tailings at 19 other sites around the
country.
Federal attempts to solve the problem have been futile. In two states, Kansas and Mi-
chigan, attempts to find a waste repository had to be aborted because of public outcry
against exploratory testing.
These mistakes and others led the government's General Accounting Office to conclude
that progress toward placing wastes in deep geological sites "has been negligible to date"
-------
and that "future program goals are overly optimistic because the administration faces
many unsolved social, regulatory, and geological obstacles."
All of this adds up to our having created a monster with no cage to keep it in. Building
that cage is a problem which must be solved and solved soon.
Last week, the Senate Subcommittee on Nuclear Regulation, which I chair, began a
series of hearings on nuclear waste management. The end result of these hearings should
be comprehensive legislation to deal with some of the roadblocks to satisfactory reso-
lution of the waste disposal problem.
One problem we have identified already is the regulatory jungle surrrounding our nuclear
waste efforts. Federal authority to regulate nuclear waste is confused and inadequate.
Although the Nuclear Regulatory Commission has the primary responsibility for ensuring
safe disposal of nuclear waste, there are significant gaps in NRC's authority to license
and regulate nuclear wastes. Uranium mill tailings, federal R & D waste facilities, and
short-term storage of high-level military wastes are just three of the more than a dozen
examples identified at the Subcommittee's hearing last week.
I will introduce legislation to fill these gaps and give the Nuclear Regulatory Commis-
sion the authority it needs to license and regulate all forms of nuclear waste.
But developing a Federal nuclear waste management program involves more than
legislation to fill the gaps. The Federal agencies with the regulatory authority must do
their part, too. The Environmental Protection Agency must formulate the general en-
vironmental criteria for nuclear waste management. The Nuclear Regulatory Commis-
sion must develop its licensing regulations. And the Department of Energy must build
the repository facilities. Or, put another way, EPA has to set the speed limit; NRC
must control the throttle to stay within it; and DOE must build and maintain the car.
You are here to help accomplish the first task—to participate in developing EPA's cri-
teria and standards for protecting public health and the environment against nuclear
contamination. The results of your efforts will enable the EPA to "set the speed limit."
Without this effort, the waste management program cannot proceed.
Environmental criteria for radioactive waste disposal are urgently needed. They have
already been more than five years in coming. Surely EPA can achieve the goal of ade-
quate public participation and at the same time propose regulations before another year
is past.
-------
EPA'S WELCOME
W. D. Rowe, Ph.D.
Deputy Assistant Administrator for Radiation Programs
U.S. Environmental Projection Agency
Washington, D.C.
Ladies and Gentlemen: It is my pleasure to welcome you to EPA's Public Forum on
Environmental Protection Criteria for Radioactive Wastes. We sincerely appreciate
your participation.
We think Denver is a particularly good location for this Forum since it is accessible to
a good representation of the interested public, and because a number of waste manage-
ment problems exist in this general region.
As many of you know, we have already held two workshops on this subject: one in
Reston, Virginia, in February 1977, and the other in Albuquerque, New Mexico, in
April 1977. Those meetings identified issues of concern for developing criteria, and we
believe we have fairly used the output of those workshops in preparing the initial for-
mulations of environmental protection criteria to be discussed in this Forum.
I want to emphasize at the outset that the initial formulations are just that. We expect
your discussion and recommendations to result in revisions and perhaps the addition or
deletion of subjects addressed by the criteria before they are formally proposed. We
believe your input is essential to true public participation in the development of Federal
policy. We will revise these criteria to reflect the results of your discussion, and only
then will they be issued as a formal EPA proposal. Consequently, they are still in a
developmental stage.
In regard to suggestions made at the previous workshops, we purposely scheduled this
Forum to include Saturday sessions and evening sessions tonight and tomorrow evening
so that interested people in the local area who have regular daily jobs can have suffi-
cient time to participate. We will do appropriate recapping at the beginning of each
evening session so that those people who can only attend outside normal working hours
will be able to keep abreast and contribute.
The basic format for the Forum emphasizes working sessions, which will begin after a
short plenary session this afternoon. We will divide into three or more working groups,
depending on the number of interested participants. EPA will provide moderators for
these sessions strictly to provide order and nothing else. We believe the working group
method provides the maximum opportunity for individuals to participate actively. This
format means that all the information and consensus opinions brought forth at this
Forum are entirely up to you. We hope to receive extensive discussion of the Back-
ground Report, "Considerations of Environmental Protection Criteria for Radioactive
Waste"; you can of course introduce any new material you believe is basic to formulating
environmental protection criteria for radioactive waste.
The Agency will utilize your recommendations from this Forum in the preparation of
a formal proposal for environmental protection criteria. Those proposed criteria will
then appear in the Federal Register for formal public comment. The formal proposal
will be made pursuant to the broad Federal radiation guidance authority which was
transferred to EPA from former Federal Radiation Council.
-------
The criteria we will propose can best be described as generalized policy statements that
address the key value judgments on issues that must be explicitly considered in the
development of basic philosophy, policy, and conditions for establishment of environ-
mental and public health protection standards for radioactive waste disposal. The issues
involved cover moral, social, and technical problems that must be addressed. There
are no "right" answers to be expected, but a series of value judgments reflecting con-
sideration of all sides of the issues which have been aired extensively through an open
public process.
Moral value judgments involve issues such as "Should we treat future generations
differently from our own?" and "Should environmental nondegradation be a major ob-
jective, that is, should we subscribe to a philosophy of containment rather than
dispersion?"
Social value judgments involve issues such as the balancing of risks to future generations
for benefits received now, how long institutional controls may be relied upon, and how
long into the future we can estimate risks on both absolute and relative bases.
Technical value judgments involve such problems as what models we can use to estimate
present and future risks, and how we characterize and make meaningful decisions in the
face of large uncertainties.
Three criteria in our initial formulations address many of these value judgments
explicitly:
1. The goal of waste management should be containment of wastes to prevent
environmental degradation over the hazardous lifetime of the wastes, rather
than dispersal.
2. Institutions should not be depended on to provide environmental protection from
radioactive wastes for more than a given period of time (e.g., 100 years) by
limiting public access, etc.; following that period, no restrictions on customary
uses of associated land areas and surface and ground waters should be required
("the institutional criterion").
3. Risk estimates are to be the primary determinants for decision; these should be
performed for human individuals and populations for a period of at least 1,000
years on an absolute basis; where estimates of adverse effects for longer
periods could significantly influence selection of a disposal option, relative risk
assessments would be meaningful (the "risk assessment criterion").
Absolute risk estimates depend upon models and hypotheses of what the future will be
like. Relative risk estimates are less sensitive to such model assumptions, but allow
us to ask the "what ifs" for various options in a useful way. These concepts are not easy
to describe, but I have discussed some of the problems inherent in using absolute and
relative risk assessments in a document entitled "Rationale for Establishing Risk
Acceptability Levels for Radioactive Waste Criteria." Copies of this document are
available for you.
Both the timeframes and the substance of these criteria represent initial formulations
and are subject to discussion and change as a result of this Forum.
EPA's standards, which will be numerical performance requirements, will be based upon
the criteria that are eventually developed from this process. The first numerical stan-
dard the Agency will develop will be for high-level radioactive waste. This effort will
be followed by generally applicable environmental standards for low-level wastes,
10
-------
uranium and phosphate mining and milling wastes, and wastes from decommissioning.
Such numerical standards will be neither site- nor method-specific. "The regulation of
waste management operations rests with the Nuclear Regulatory Commission INK(_J,
whose regulations when promulgated will assure that EPA standards are met.
We will devote the remainder of this session to presentations by EPA on the initial
formulations of the criteria. The EPA staff presentations are designed to provide our
perspectives and reasoning in arriving at the criteria formulations. Also, the first
Working Group sessions are scheduled to begin this evening. The objective of tonights
Working Group sessions is to establish the format and the agenda to be used for dis-
cussion throughout the entire Forum.
I hope that our combined efforts will make this third Forum the most productive to date.
Thank you for your attention.
11
-------
TOPIC I
WHAT IS RADIOACTIVE WASTE?
-------
CRITERIA FOR DESIGNATING MATERIAL AS RADIOACTIVE WASTE:
A STATEMENT OF ISSUES AND OBJECTIVES OF WORKING GROUP I
Harry 3. Pettengill, Ph.D.
Waste Environmental Standards Program
U.S. Environmental Protection Agency
INTRODUCTION
When EPA was formed in 1970, one of its charges was to "advise the President with
respect to radiation matters, directly or indirectly affecting health, including guidance
for Federal agencies in the formulation of radiation standards... ." This responsibility
includes protection of the public health from potential hazards associated with the
various forms of radioactive waste. The Agency has established a program to provide
such guidance through the development of environmental protection criteria for all types
of radioactive waste.
In developing our initial formulations of draft environmental criteria, EPA was espe-
cially mindful of issues and recommendations from our two previous public Workshops
held in Reston, Virginia, and Albuquerque, New Mexico, in early 1977. Since then we
have thoroughly researched issues discussed at the Workshops and other relevant ones in
our attempt to determine those considerations that need to be addressed in the criteria.
The issues EPA has dealt with in its Background Report* and the initial formulations of
criteria are (1) features of radioactive materials that require them to be designated as
radioactive wastes and their hazard potential over time and at various levels of con-
trols, (2) the importance of risk estimates in arriving at levels of control and the factors
that should be reflected in such determinations, (3) the goals of control and the types
of institutional, engineered, and natural-barrier controls for meeting such goals, (4)
the approaches for determining the allowable levels of short- and long-term risks asso-
ciated with various means of disposal for varying types of waste materials, and (5) other
considerations for environmental protection, such as retrievability, monitoring, and
the transfer of information to succeeding generations.
Obviously, the first consideration in putting forth criteria for radioactive waste is to
determine what they apply to. This requires a clear distinction as to what constitutes
radioactive waste materials and the basis for designating certain materials as such. This
presentation is a brief overview of the areas and items reviewed by EPA with respect to
the first chapter in the Background Report and the first criterion. The discussion of the
other key factors such as risk perspectives, control technology, long-term implications,
and other operational controls will be discussed by other speakers on today's program,
WASTE CATEGORIES AND INVENTORIES
EPA has reviewed and, as you will note in the Background Report, documented a wide
range of sources and inventories of radioactive wastes that were considered in formu-
lating the criteria. Some are artificially produced and others result from activities
involving naturally occurring radionuclides.
•"•Background Report—Considerations of Environmental Protection Criteria for Radio-
active Waste. February 1978. Waste Environmental Standards Program, Office of
Radiation Programs, U.S. Environmental Protection Agency, Washington, D.C. 20460.
15
-------
Those in the first group, artificially produced, result mainly from activities within the
nuclear fuel cycle, i.e., reactor operations and spent-fuel reprocessing, and from
medical and industrial sources. Traditionally, these radioactive wastes have been
referred to as being either high-level or low- level. The major sources of the high-ievel
wastes are the spent fuel and/or the by-products of reprocessing of the fuel, with the
Federal goverment having generated, at this time, over 98 percent of the volume of
those wastes.
"Low-level" waste has generally been a catch-all category for wastes, including
everything other than high-level, and covers a broad range of origins and many different
substances. Again, the Federal government has generated over 75 percent of the ex-
isting volume of low-level wastes.
Wastes containing naturally occurring radionuclides result mainly from the mineral
extraction and processing industries—primarily uranium, thorium, and phosphates.
There are over 400 million tons of uranium and phosphate mill tailings presently accu-
mulated in this country, with the uranium industry accounting for about 32 percent of
that quantity.
HAZARDS FROM RADIOACTIVE WASTE
In looking at the hazards of various types of wastes, we find that high-level wastes
typically present both an external gamma radiation hazard, and, in the event of an
uncontrolled release, an inhalation and ingestion hazard. Acute exposures are the con-
cern with high-level wastes because of the activity level and the highly penetrating
gamma radiation. The gamma radiation is produced mostly by short-lived fission prod-
ucts; therefore, after a few hundred years, the remaining predominant hazard from
high-level wastes would result from ingestion or inhalation of the long-lived alpha
emitters of such wastes.
Most low-level wastes would not present an acute hazard but, in the event of release to
the biosphere, could present a potential chronic hazard to the public. The current
practice of shallow land burial of low-level wastes means that the most probable hazard
would result from ingestion, primarily through a water pathway. There also are some
transuranics found in most low-level fuel-cycle wastes; however, these do not appear to
be easily transported through most food chains and consequently would pose only a slight
ingestion hazard. More likely, they would pose a greater hazard from inhalation during
handling or from resuspension into the air.
Low-level wastes which contain naturally occurring radionuclides, because of their
diffuse activity concentrations, typically represent a chronic rather than an acute ex-
posure hazard. In the case of naturally occurring nuclides, the isotopes of major con-
cern are Ra-226 and its daughters. Since radon is a gaseous daughter of radium, it
diffuses readily into the atmosphere and presents a hazard due to inhalation.
WHAT ARE RADIOACTIVE WASTES?
Thus far, I have only summarized the materials, activities, volumes, and major po-
tential hazards from wastes which contain significant levels of radioactivity. In our
attempt to formulate a definition for radioactive waste, EPA put forth a "straw man"
definition for discussions at our previous workshops. That definition stated,
"Radioactive wastes are all retained radioactive materials of no immediate or fore-
seeable value generated as by-products of man's activities." Working Group 1 at the
Reston Workshop responded to this proposition with the following recommendation:
16
-------
EPA should not develop or define specific and detailed categories of radioactive
waste. The following broad definition of radioactive waste (offered in full recog-
nition of the existence of more detailed definitions) is proposed for the purpose of
environmental protection criteria: Radioactive waste is all that radioactive mate-
rial with respect to which a decision has been made by the cognizant authority to
place the same in permanent storage or a permanent mode of disposal at discrete
sites designated for those purposes, and shall exclude radioactive material for
which a determination to withhold has been made. Also excluded are radioactive
releases from facilities involved in production or reprocessing of nuclear fuel and
the generation of electricity from nuclear fuel, which are subject to federal and
state licensing and regulation. (Note: This definition does not preclude the
possibility that materials designated as "waste" may or may not have value now or
in the future.)
The first Working Group at the Albuquerque Workshop also deliberated this issue but was
not able to reach such a clear consensus; however, they did state the following:
There was no agreement of how to determine that a waste had no future use which
might affect management of that waste.
On one hand, there was concern that calling a material "waste" might lead to its
irrevocable disposal, thus denying its value. On the other hand, some felt that a
material might not be designated as "waste" to avoid the environmental control that
designation might entail. It was noted that few (if any) methods of disposal are
irrevocable if cost is no object. An objection was also made to the semantic im-
plications of the terms high-level and low-level, in that they might misleadingly
imply relative importance.
Likewise, EPA has viewed this issue from the aspect of its desire to cover all sources
of radioactive waste materials under one general criterion. It is evident that there is
a need to enumerate some basic assumptions in order to narrow the definition of ra-
dioactive waste, since almost any material could be designated as radioactive waste if
the only requirement were that it contain measurable radioactivity. For example, the
human body contains some quantities of isotopes such as K-40 and C-14. Therefore, we
felt there was a genuine need to propose some baseline conditions to more realistically
define a radioactive waste.
First, materials should be declared waste on the basis that they have no foreseen value.
EPA has not made an attempt in the Background Document or its formulation of criteria
to establish who should declare those materials as having no value. Obviously, this is
an issue which will eventually require resolution.
Second, radioactive wastes should include only those materials under some form of
regulatory control. Such a basis works well for source material and by-product materials
covered by the Atomic Energy Act, but one should recognize that other sources, such
as some naturally occurring radioactivity and accelerator-produced nuclides, are not
so clearly under strict regulatory control. However, current activities and regulations
being developed under the Resource Recovery and Conservation Act of 1976 and the
Clean Air Act as amended in 1977 may provide a mechanism for regulation of such
materials.
As a third consideration we felt that, because naturally occurring radioactivity is ever
present in the environment, some basic differentiation was needed between naturally
occurring radioactive materials and nuclear wastes of human manufacture. In differ-
17
-------
entiating between these two types of waste we reasoned that if the waste materials
contained naturally occurring radioactivity but nothing was done to make that radio-
activity more accessible for exposure of humans than under normal natural conditions,
then any radiological impacts due to the management of such wastes would be of limited
importance. This, in essence, classifies some types of waste materials as being non-
radioactive waste for practical purposes, even though there may be trace amounts of
naturally occurring radionuclides involved.
Using this philosophy one should be able to assume that disposal of any material con-
taining naturally occurring nuclides which would not increase the pre-existing exposure
level to humans via any pathway would not require special care strictly on the basis of
radioactivity.
The final consideration is that human-produced nuclides under specific regulatory con-
trol (including discrete radium sources) should be assumed to be radioactive waste where
there is no longer a use for such materials. The reason that our initial formulation of
a criterion for radioactive wastes is so encompassing for human-produced radioactive
materials is our belief that such materials are already controlled to reduce potential
human exposure, and that their control should be extended through eventual disposal,
DESIGNATION OF RADIOACTIVE WASTE
In summary we have put forth for your deliberation at this Forum a criterion for defining
radwaste which states:
Radioactive material which has no designated resource or product value should be
considered radioactive waste requiring environmental protection if it (a) is produced
by nuclear fission or activation, (b) contains naturally occurring radioactive mate-
rial that if disposed into the biosphere would increase exposure above that normally
occurring in pathways owing to the natural state of the area, or (c) is restricted
from routine release to the biosphere. Examples* of such radioactive waste mate-
rials that should be subject to environmental protection requirements are
all radioactive materials associated with the operation and decommissioning of
nuclear reactors for either military or other purposes and the supporting fuel
cycles, including spent fuel, fuel reprocessing waste, and radionuclides
removed from effluents,
artificially produced radioisotopes for medical, industrial, and research use,
including discrete radium sources, and waste materials contaminated with
them, and
the naturally radioactive residues of uranium and phosphate ore recovery and
associated milling and conversion operations.
The EPA has determined that the materials listed should be subject to environmental
protection criteria even though some such materials may not upon examination
require any control above that they would receive as ordinary wastes; other radio-
active materials may also be included if they are found to satisfy similar
considerations.
18
-------
SUMMARY AND CONCLUSIONS OF WORKING GROUP
INTRODUCTION
The first session of this group was spent, following introductions and explanation of the
task to be accomplished, in general discussion of the basic topic. After the break, a
tentative agenda was identified. The agenda called for the group to develop, that
evening, a list of issues to be discussed the following morning. The Friday afternoon
session was to be devoted to discussion of the content of the Background Document. It
was later found that the group's interest was centered on the list cf issues developed,
and, since the background document would be rewritten as a result of the Forum, a
detailed discussion of the document was deleted from "he group's agenda.
The provided list of suggested topics was augmented by the group at the first session
to cover not only the criterion of the definition of radioactive waste but also a limited
number of issues under the criteria being addressed by Working Groups II and III. Ad-
ditionally, a small list of general issues was developed,, This report summarizes the
issues identified by the group and its concerns for how these matters might be addressed
in the criteria and by EPA. A total of 25 issues \vere identified.
DEFINITION OF RADIOACTIVE WASTE ISSUES
A. How are the criteria to be used by the standard-setting agencies in the development
of their individual regulations and manual chapters?
The group was given to understand that the criteria developed by EPA could be used by
EPA in the development of their own regulations and possibly as guidance to other
federal agencies in the development of specific regulations implementing the basic
philosophical statement. States having agreements with the Nuclear Regulatory Com-
mission (NRC) for regulation and control of certain radioactive material would most
probably be required to adopt similar regulations compatible with the NRC and the
criteria if implemented. Some people felt that individual s~;ate? should have the right to
promulgate stricter regulations.
B. Are the criteria as presently suggested considered adequate for development of
standards?
It was the general consensus of the group that, owing to the number of issues available
for discussion and the divergent opinions of the participants, the criteria were currently
unacceptable.
C. How could the term "radioactive waste" be more simply defined?
An opinion of the group was that the criteria should consider all radioactive material
regardless of origin, i.e., manmade and naturally occurring materials, and that the
material should not have resource or product value. Some felt that resource or product
value should not be included in the definition. The matter of who designates a waste
and when a material becomes a waste was addressed under Issue D.
19
-------
D. Should the criterion attempt to address the designation of no resource or product
value, and who should make that decision?
It was suggested that the licensee or possessor of the radioactive material identify the
value or nonvalue of a source and that the regulatory agency involved review such de-
terminations for appropriateness. It was also suggested that a time limitation be con-
sidered on the determination of planned use or value and that the inventory be continually
updated to reflect properly the full scope of the possession of radioactive material. An
assignment of use or value shall not exempt the radioactive substance from regulatory
control. The question of spent fuel being a waste or having resource value was a point
of contention.
E. When is a radioactive waste material no longer considered radioactive by virtue of
decay processes?
It was the opinion, of the group that the basis for such a decision would be addressed by
the discussion of Issue F.
F. Should EPA specify in the criteria a minimum level of radiation or radioactivity for
defining radioactive wastes?
The group felt that such a designation should be included in the criteria and that it could
take several forms, i.e., a level for each radionuclide or classification of radioactive
material. An opinion was also expressed that, owing to the nonthreshold philosophy,
no acceptable minimum level could be identified. The method of determining a mini-
mum level was discussed under Issue G. Some people felt that when the minimum level
for the material is reached by decay, the material may be disposed of as nonradioactive
waste. Others felt that the label "radioactive" must remain with the material.
G. What methods could be used to derive a minimum level?
The following methods were suggested by the participants: as multiples or fractions of
natural background radiation; as radiation doses with consideration of the pathways in-
volved versus the measurement or calculation of radiation levels; as a statement of
absolute values; and in terms of anticipated health effects. Consideration should also be
given to the worst radionuclide that may be involved in a radioactive decay chain.
H. When is ultimate radioactive waste disposal requested or required?
Since the issue as originally drafted did not stipulate "ultimate" disposal, discussion
included whether storage should be considered or whether the term "disposal" should be
replaced with the term "waste management." With the insertion of the word "ultimate,"
there was a controversy as to whether ultimate disposal could be required if an ac-
ceptable method of ultimate disposal has not been demonstrated or proved. The im-
plication is that if an acceptable method of disposal is proved then the criteria should
possibly address when specific disposal would be required. Some people felt that ulti-
mate radioactive waste disposal should be required, and that if it cannot be provided, then
further radioactive material should not be produced.
I. Do current regulations provide assurance that radioactive materials that are re-
stricted from routine release to the biosphere will be properly classified as waste?
The consensus of the group after discussion was that the current reguJations do not
adequately address the designation of waste. There was concern expressed that routine
20
-------
effluent discharges be included in the definition of radioactive waste. There was also
discussion to the effect that standards for routine releases for the uranium fuel cycle
are already in place (EPA regulation 40 CFR 190).
J. Should the criteria address human contamination such as excreta and body burdens
of radioactive materials?
It was the opinion of the group that the subject of human contamination should be ad-
dressed in the criteria. Some felt that current procedures and regulations are adequate
to control the disposition of excreta from persons who had undergone diagnostic or
therapeutic use of radioactive materials.
K. Is the rationale for the classification of wastes on the basis of preexisting natural
levels of radiation reasonable?
If acceptable minimum levels of radiation to humans are defined in the criteria, then
there appears to be no need to define radioactive waste with respect to preexisting
levels.
L. Should redistributed naturally occurring radionuclides that increase human exposure
be considered radioactive waste?
The group concurred that such material should be considered for inclusion in the criteria.
Some felt it should definitely be included.
M. Should there be distinctions between high- and low-level wastes in the criterion
defining radioactive waste?
It was felt that distinctions should not be included in the definition of radioactive waste,
but that they should be incorporated in the criteria addressing the control measures or
in the standards promulgated by the regulatory agencies.
N. Should there be more categories of radioactive wastes?
It was felt that, in the context of the definition of radioactive wastes, multiple
categories should not be considered.
O. How do the criteria specifically address the definition of past, present, and future
radioactive wastes?
The criteria should definitely address the wastes generated in the future, and in some
cases should consider past generation of wastes and their disposal. The consequences of
exhumation of past disposals must also be considered. The treatment of wastes gener-
ated in the future should be dealt with on the basis of knowledge gained about the
biologic effects of radiation.
P. Should the criteria address activated and/or absorbed radioactive materials that are
not currently addressed by standard-setting agencies?
It was the consensus of the group that all radioactive materials regardless of origin be
included in the criterion defining radioactive waste and that they be appropriately ad-
dressed in regulatory documents.
21
-------
Q. When is the packaging material for radioactive waste considered a radioactive
waste?
It was the feeling of the group that if packaging materials are somehow contaminated or
included in the actual disposal technique, then the packaging materials, regardless of
the type of material, must be considered as a radioactive waste. However, if a con-
tainer that may have a value can be safely reused, then that container would not be con-
sidered radioactive waste.
DISCUSSION OF ISSUES OF WORKING GROUPS H AND HI
R0 What risk Is acceptable for radioactive waste disposal?
Since there were considerable differences in opinion on this matter, the issue could not
be properly addressed or resolved in the time provided. Some individuals expressed an
understanding and acceptance of what would constitute an unacceptable risk, such as
is suggested in the background document. Others expressed concern that an acceptable
risk could not be identified because of the long-term implications that may be involved
and the lack of an adequate data base.
S. Should there be a discounting of risks to future generations? How could this be
equitably accomplished?
Some members of the group felt that risks to future generations should not be
discounted. Others felt they should.
T. Should the criteria consider theories of risk other than the linear hypothesis?
The group felt that the criteria should consider other theories on the basis of the data
that support them,
GENERAL ISSUES
U. Should the production of radioactive wastes be allowed to continue?
It was concluded that an across-the-board "No" cannot be given. Consider Issue V.
V. Should there be a moratorium on nuclear power in the U.S. until a satisfactory waste
disposal technology has been approved?
The group provided strong opinions—both positive and negative—on the issue of a mora-
torium. The definition of a "satisfactory technology" and who should approve the
technology also brought diverse responses. Suggestions included a decision by the gen-
eral public, Congressional approval, and deciding "acceptability" according to govern-
mental rules of procedure. It was suggested by some that there should be broad public
participation and funding to present views of environmentalists.
W. What is the actual goal of ultimate disposal of radioactive waste?
Th^ group concurred with the first sentence of Item 4, page 52, in the Background
Report; "Controls should be applied with a goal of isolating radioactive wastes from the
biosphere over their hazardous lifetime to protect humans and minimize unnecessary
contamination of the environment."
22
-------
X. What should be EPA's format for broader public participation in the development of
criteria?
The suggestions for increasing participation were
1. that public hearings be held in every state at convenient times (e.g., weekends
and evenings) and places for the general public,
2. that all media be involved in publicizing the hearings and that the hearings
themselves be televised,
3. that materials be made available on semantics and terminology in advance of the
hearing,
4. that town meetings have been successful in the past and might be used,
5. that a jury be selected and that this jury be educated by advocates of the various
points of view to a very high level of understanding of the subject so that jury
members could discuss the issues and come to a consensus, which would be
made public through the press and television,
6. that discussions not demand the understanding of sophisticated technologies,
7- that legislative bodies, including Congress, deal with these problems instead
of the general public, and
8. that there be more participation of scientists who have no vested interest, and
that financial aid be provided to representative people.
Y. Additional suggestions were that an open forum be held on the subject of the nu-
clear industry and that public forums encourage the use of small group sessions.
ACKNOWLEDGMENTS
The entire group was instrumental in formulating the final draft of this report. We wish
to thank EPA's facilitators and Al Hazle, our excellent moderator.
WORKING GROUP I PRESENTATION COMMITTEE
Name Affiliation
Michael Buring Reading (Pennsylvania) Utility
Frances Connor Rocky Flats Monitoring Committee
Judy Wilkinson Boulder Mobilization for Survival
23
-------
RESPONSES OF FORUM PARTICIPANTS TO SUMMARY
AND CONCLUSIONS OF WORKING GROUP I
Second Plenary Session
LARRY C. OYEN (Sargent & Lundy) [comment on Item G of Summary and Conclusions]:
Minimum levels of low-level waste should be considered. Low-level waste after some
decay period should be considered nonradioactive. Criteria for this [are] being developed
by an Atomic Industrial Forum contract to Nuclear Safety Associates. These criteria
will state levels when radwaste reaches "de minimus" levels.
COMMENT ON ITEM M (name withheld): Any distinctions between high-level and low-
level waste which are made in the criterion or in later standards should be based on de-
terminations of toxicity and/or longevity of the wastes but not upon immediacy or
acuteness of the health effects (i.e., velocity). Whether you die from low exposure or
high exposure, slowly or rapidly, should not be a consideration—you are just as dead.
CYNTHIA BATES: First I want to say I'm very sorry about this. It was through an
oversight that this came about. It's about [Item] M, which says "Should there be a
distinction between high- and low-level waste in a criterion defining radioactive
waste?" In our group, different people projected different issues that they wanted to
discuss or comment on, and I projected this one, and I want to make a correction which
I'm afraid will probably lead to some disagreement among the group, but I didn't intend
it to be written at all this way...how I felt...the thing I was proposing was...I'll read it
as I had proposed it: It was felt that distinctions should not be included in the definition
of radioactive waste and they should not be incorporated in the criteria addressing the
control measures or in the standards promulgated by the regulatory agency. In other
words, all levels of radioactive waste would have a common disposal process involved,
and I did...it was an oversight...I'm very sorry that I didn't notice this earlier. It was
pointed out to me right before this meeting; I had no chance to really interact with my
group about it. If there is disagreement with that I suggest that we...if there was a
dissenting opinion...each opinion was presented on both sides. Our dissenting opinion in
Group I is that the change be made; I suggest that we rewrite it in here. Is there any
dissention from Group I about how that should be?
MIKE RAUDENBUSH: As a point of order, I would suggest that the summary document,
for all its flaws, does represent what we agreed to submit and any changes should be
in the form of follow-up minority statements.
DR. JAMES MARTIN, Chairman (Environmental Protection Agency, Washington D.C.):
I'd have to support that, I'm afraid, because regardless of the understanding of the group
that was the issue. They did write about the issue as they understood it. I would suggest
if you have some comment or correction state it as yours. We are not going to start
revising the reports here; we just don't have the time.
BATES: Pm very sorry.
ROY E. POST [comment on Item B]: In what way were the criteria unacceptable?
JUDY WILKINSON (panelist): The questions that we have outlined in the rest of the
report go into some of the ways in which we feel that they were not acceptable. For
some of us it was that we didn't feel good about the definition of waste as related to
background material or background levels and about the distinction between high- and
low-level waste. We didn't feel good about certain omissions such as...the omission of
25
-------
human contamination or of containers and also about the definition of waste as excluding
anything that could have resource value, and I'd like to hear what the other scientists
say,
MICHAEL BURING (panelist): I don't think that I should add any additional material to
what's in the report itself. I think that the viewpoints are pretty well summarized.
CAROLYN LANDES; Did the group really concur with sentence 1, Item 4, page 52 [of
Background Report]?
FRANCES CONNOR (panelist); The answer, I believe is yes.
UNIDENTIFIED SPEAKER; [inaudible comment]
Fm sorry, you're off the record. That's the advantage of stating your question
yourself. Please, let's move on. I don't want to get dictatorial, but many people are
looking at their watches and we have a lot to go through.
WILKINSON: I say if we don't have time to do it, then we shouldn't be doing it. If we're
going to do it, we ought to do it well.
LANDES; I remember opinions expressed that the goals of controls should be for zero
contamination to the environment and effects on human health and future.
CONNOR; There were some opinions expressed [to this effect].
COMMENT ON ITEM I (name withheld): [Let us] change the second sentence in the
conclusions on Item I to read "There was concern expressed that routine effluent dis-
ch^.-'ges and abnormal or transient releases be included in the definition of radioactive
waste."
ENGLISH (Jet Propulsion Laboratory, Pasadena, California): Issue D does
not explicitly take into account two major factors: (1) President Carter has deferred
reprocessing indefinitely. (2) Page 8 of the DOE Deutsch report places HIGHEST PRI-
ORITY on demonstrating the ultimate disposal of spent fuel. Hence, spent fuel is a
form of high-level radioactive waste.
BURING? No one can argue that President Carter has deferred reprocessing indefinitely;
that's a known fact. There was considerable discussion as to whether spent fuel was a
• esou:'ce or a waste; did it have intrinsic value, which took it out of the waste category,
or did it have no value and therefore [have to] be declared a waste? There were
dissenting opinions, and we tried to reflect that in the report.
WfLKINSON: We also said that, regardless of whether or not it was classified as a
waste, it should be dealt with through government control.
JONATHAN WEISS (Decisions and Designs, McLean, Virginia): This really addresses
Issue X, These are overall comments on the [Forum], not comments on the reports
themselves, (1) Better efforts should have been made to publicize the Forum to the
general publio-the present group was too polarized. Perhaps [there should have been]
some compensation or subsidy for participants, especially those who traveled long
distances. (2) Smaller discussion groups (10-12 would be optimal)! (3) Discussion leaders
were excellent, but the meetings should have had m^e background work (tone prior to
convening. In particular, (af tentative agendas and procedural rules, (b) clear
26
-------
definitions of the scope of discussion and the terms used (e.g., "risk"), (c) perhaps a
clearer statement of the desired format of the reports and of their use by EPA.
MARY SELL: I'd like to recognize the great efforts made by EPA to get public opinion,
but I would like to also point that, at least two to one, the nuclear industry outnumbers
the general public, so therefore the statement is not a public statement. I as an indi-
vidual would like to have some reassurance from the EPA that my input will be used,
that I wasn't just allowed to vent my feelings in order to cut down on very strong public
activity at this time, anti-nuclear activity, and therefore defuse a public forum that is
in action in the country at this time.
DR. WILLIAM ROWE (Environmental Protection Agency, Washington, D.C.): I guess I'm
called upon to answer that one, and my answer is twofold. One, we don't count numbers
from which side are here. [Two,] we count every individual and every comment and we
listen to every individual and every comment.
SELL: Thank you, Dr. Rowe.
COMMENT ON ITEM K (name withheld): Omitted from the report on this item was the
exception that definition of radioactive waste based on naturally occurring radioactivity
or radiation level should not be interpreted as requiring the disposer of wastes to meet
lower levels of such radioactivity than occurring at the disposal site.
PAUL H. LOHAUS [comment on Item B]: It does not appear that the "number of issues
available for discussion" and "divergent opinions of the participants" should be the only
basis for determining the acceptability or unacceptability of the criteria.
CONNOR: Well, that's your opinion.
ILENE YOUNGHEIN [comment on Item N]: I feel there should be multiple categories of
waste, due to the various hazards of various elements.
JACK W. LENTSCH (Portland General Electric Co.) [comment on Item Dh The desig-
nation of spent fuel as a waste is a national policy decision that is subject to Presidential
and Congressional mandate. It is quite incorrect to infer that a federal regulatory
agency can designate spent fuel to be a waste.
STEPHANIE J. BAKER (Western Nuclear, Inc., Denver, Colorado) [comment on Item Vl:
Environmentalists represent special-interest groups who wish to maintain the status
quo—i.e., environmentalists are a select few who want to retain their privileges.
Special funding should not go only to environmentalists.
CONNOR: I think the intent of the group was that, as a broad category,
"environmentalists" was mentioned as one group to receive [possible funding].
WILKINSON: In [Item] X we talked about public participation and pointed out that we
wanted to have people who were representative of all points of view and of all sections
of the country.
DR. FREDERICK FORSCHER (GASP Energy Committee): Radioactive material as a
result of nuclear explosions (for instance, rubble, debris, etc.) should also be included
in the definition of radioactive waste. Question: Is it included in the definition? It is
not a future waste; it is present waste now, for instance in Japan.
27
-------
WILKINSON: We weren't excluding present waste at all.
BURING: There was also the[ opinior] that all radioactive material could be considered
waste, and if there was a distinction it depended on whether it had resource value.
MARTIN: Before we go on to the reports of Working Groups II and III, a suggestion was
handed to me that we don't need to have the report read since we each have a copy;
thus, we should get right to the comments. Are there feelings on this?
UNIDENTIFIED SPEAKER: I agree with the panelist that we should do it right or not
do it.
TODD JOSEPH (Working Group II): Jim, Group II will read its report very fast.
MARTIN: OK, we'll go ahead as planned.
WRITTEN COMMENTS
J. P. CORLEYt comment on Item 9 : The consensus of Group I was not that the pro-
posed criteria were unacceptable as a whole, but that they were inadequate; this is a
real distinction.
WILLIAM A. LOCHSTET: Unwanted smoke detectors containing radioactive material
(such as Americium-2^1) definitely are radioactive waste.
28
-------
TOPIC II
WHAT ARE THE CHARACTERISTICS OF AN ADEQUATE
RISK ASSESSMENT AND OF ACCEPTABLE RISKS FROM
RADIOACTIVE WASTE?
-------
RISK IN RADIOACTIVE WASTE MANAGEMENT:
A STATEMENT OF ISSUES AND OBJECTIVES OF WORKING GROUP II
Stanley Lichtman, Ph.D
Waste Environmental Standards Program
U.S. Environmental Protection Agency
Risk is an essential factor in the determination of environmental protection require-
ments for radioactive wastes. Considerable emphasis was given to this subject in our
Background Report. Once a material has been designated a radioactive waste, risk, in
our judgment, should be the primary determinant of how it is to be stored and disposed
of. This precept raises two central issues: (1) What constitutes an adequate risk as-
sessment to support choices between alternative storage and disposal technologies?
(2) What are the principles according to which the acceptability, or alternatively
the unacceptability, of any resulting risks should be determined?
WHAT IS RISK?
As used in our Background Report, "risk" is a general concept encompassing both the
probabilities that certain events leading to adverse effects will occur and the health
consequences should they occur. Various more specific representations of the concept
have been discussed in technical literature, but they need not concern us here except to
note that the concept can be extended to include some measure of the social value of
the consequences.
WHY CONSIDER RISK?
The risks which concern us here are the health risks to current and future populations
associated with the existence of radioactive wastes. Generally speaking, such risks
cannot be eliminated entirely except by foregoing the benefits of the waste-producing
processes. Risk is therefore one of the costs to consider in determining whether an
activity provides a net benefit.
Risk is also the principal measure of the effectiveness of waste management systems,
whose purpose is, after all, the limitation of risk. It is therefore a key factor in tech-
nological choice both before and after radioactive waste is produced.
It may be noted at this point that EPA's policy regarding the relationship of radiation
dose and health effects is that, considering the current body of relevant scientific
knowledge, it is prudent to assume that health effects are in proportion to dose, and
that no threshhold dose exists below which radiation exposure is totally safe. Until
evidence indicates otherwise, this will be EPA's basis for estimating the consequences
of radiation exposure for public health protection purposes.
WHY PERFORM RISK ASSESSMENTS?
A risk assessment for radioactive waste is an analysis of the potential adverse effects
and the circumstances under which they might arise (see below).
Some of the reasons for performing a risk assessment have been discussed previously,
and follow from the relationship between risk and technological choice. Some further
reasons may be given, which, however, are not necessarily distinctly different from
one another or those given previously:
31
-------
1. The performance of systematic risk assessment helps assure that decisions are
made with knowledge of possible consequences. The process of performing the
assessment also establishes a record which then can be independently examined
for its technical adequacy and completeness.
2. Systematic risk assessment should help uncover aspects of a proposed waste
management system for which reduction of uncertainty is desirable, or
necessary.
3. Risk assessment illuminates the relationships between risks and control
mechanisms, and should produce guidance for improved control technology.
It should be noted that in making these observations EPA does not intend that each
individual possessor of radioactive waste necessarily should perform these analyses. The
need to do so under given circumstances should be established in the regulatory process.
The main objectives here are rather to determine EPA's own policies for radioactive
waste, to govern its standard-setting and other functions, and also to provide guidance
to other agencies with responsibility regarding such materials.
WHAT CONSTITUTES AN ADEQUATE RISK ASSESSMENT FOR
RADIOACTIVE WASTE?
The working group should consider the adequacy of the following elements, which the
EPA staff judges to be essential to a risk assessment for radioactive waste:
1. The assessment should consider the physical properties of the waste, including
the quantity and types of radioactivity, the persistence of both the radioac-
tivity and the form of the material, and the concentration of radionuclides.
Generally speaking, these are necessary to broad characterization of the
hazard potential of the material.
2. For each form and level of control mechanism the consequences of releases of
the material should be examined, as a function of time. The word "releases" in
this context refers to leakages and migrations of radionuclides, whether an-
ticipated or not.
3. The probability of these releases occurring should be evaluated, as a function of
time.
k. Consideration of the uncertainties in each aspect of the evaluation should be
part of the assessment process.
To summarize, since the risk assessment is an analysis of the health hazard associated
with a radioactive waste, any factors that characterize or contribute to the hazard
should be included. To be most useful as a decision making tool, the uncertainties
should be an explicit element of the assessment.
FOR HOW LONG INTO THE FUTURE SHOULD RISKS BE ASSESSED?
This issue has ethical, technical, and economic aspects. To the extent that risk as-
sessment forms a basis for social and technical choice, it is possible that the time period
over which the assessment is performed will significantly influence decisions.
32
-------
Ethical Considerations
It is clear from the record established by our earlier Workshops that a wide diversity of
opinion exists on the length of time into the future for which the current generation
should be concerned about the potential environmental impacts of its radioactive waste.
Moreover, those who believe in limiting consideration to a few hundred years or less are
not necessarily motivated by selfish interests; the arguments supporting these views
(which are reviewed in our Background Report) appear to us to be substantial. Never-
theless, EPA believes the most ethical and prudent position for it to adopt in the
exercise of its public responsibility is to consider to the extent it can the consequences
of its actions for all time. This position is in accord with the goal stated in the National
Environmental Policy Act of 1969 (NEPA), to "fulfill the responsibilities of each gen-
eration as trustee of the environment for succeeding generations."
Technical Considerations
The assessment of health effects and other environmental impacts requires knowledge
of populations, food chains, medical effectiveness, and uses of water, air, and mineral
resources. On the basis of past experience, these data cannot be reliably predicted for
more than a period of decades; educated guesses can perhaps be made for some hundreds
of years, and beyond that estimations are increasingly speculative. There is therefore
certainly an intrinsic, though not sharply defined, limitation on our ability to perform
detailed assessments of future risks in a scientific fashion. Nevertheless, it may be
argued that certain evaluations may be performed far into the future, if they are based
upon only basic biological and physical facts.
Economic Considerations
One purpose of performing risk assessments is to examine the relationship between the
incidence of health effects and other impacts and the means of control of the radioac-
tive material. For long-lived materials, the longer the time for which we give consid-
eration, the greater will be the risks and, presumably, the greater the justification for
expenditure on additional controls. Thus a long-term view of risk may result in different
choices than would result from a shorter-term consideration.
The conclusions we have tentatively reached, consistent with both the requirement of
NEPA to use "practicable means" and with our own analysis, are the following:
1. Risk assessments should be performed as well as can be done to estimate health
effects due to radioactive wastes for 1,000 years. This is not expected to yield
unarguable scientific truth, but should provide a basis for comparison of
technologies and judgment of impacts. Of course all assumptions should be
fully described.
2. Even longer-term risks should be considered if they might substantially influ-
ence the choice of control systems.
HOW SHOULD ALLOWABLE RISKS TO FUTURE GENERATIONS RELATE TO RISK
ALLOWED TO CURRENT POPULATIONS?
I have just presented our conclusion that risks for at least 1,000 years into the future
should be considered in our waste management decisions. Now I wish to address the
relationship we should adopt between allowable future and current levels of risk. Should
our management objectives for radioactive waste be more or less stringent regarding
33
-------
future impacts than we find to be acceptable for ourselves? Here again there are sub-
stantial arguments on both sides of the issue. It has been argued that future people are
likely to be scientifically more advanced than we, with both improved remedial tech-
nology for inadequacies in our waste disposal and better medical interventions for any
resulting health effects. Furthermore, the argument goes, since they are beneficiaries
of our technical progress, it is fair for them to share in the risks. On the other hand,
future people will have had no voice or choice in our technical and social decisions.
Their preferences or needs for environmental purity may be less than or greater than
our own. Given these substantial views supporting both more and less stringent stan-
dards for the future, EPA has tentatively concluded that its responsibility will be
exercised if future impacts are at least as highly restricted as those allowed for current
populations. Combined with our other criteria for environmental protection, this ap-
pears to us a fair principle, which should allow ample prerogatives to both current and
future societies.
In practice this equity principle would imply, for example, that any waste management
plan would be unacceptable which would lead to future levels of radiation in the general
environment or in drinking water in excess of those allowed under current standards.
Standards specifically addressing radioactive waste as a radiation source are currently
under development at EPA, and these too will provide limitations on future risks at least
as stringent as those on near-term risks.
HOW ARE WE TO DECIDE "HOW SAFE IS SAFE ENOUGH?"
The question "how safe is safe enough?" is so familiar as to have become trite, yet it
expresses the profound concept that some risks may be worth taking. It should be noted,
however, that we are concerned here with the methods and principles according to
which agencies such as EPA should address the issue, and not with the answer itself. Of
course our immediate goal is to lay a basis for development of standards and regulations
for radioactive waste, but most of you will recognize that the underlying philosophical
concepts are among the most important and characteristic issues of our time.
Some of the methods and approaches that have been suggested as a basis for determining
acceptability of risks have been discussed in the Background Report. The subject cannot
be fully discussed in the time available here, but I would like to summarize the scope
of our analysis, and the conclusions.
We have examined the possibility of determining the acceptability of risks due to ra-
dioactive wastes solely by
1. reference to risk and benefit relationships established by past experience with
activities and situations not directly involving radioactive waste (for example,
it might be proposed that standards for disposal of radioactive waste should
be set in some definite relation to past and current disposal practices for other
industrial waste), or
2. comparison with risks due to natural background radiation, or with commonly
understood risks not related to radiation (here for example, one might deter-
mine acceptable exposure levels for radioactive waste as being below some
fraction of natural background radiation exposure), or
3. assessment of public attitudes and opinions.
-------
We conclude that each of these methods contributes insight and perspective regarding
the acceptability of risks due to radioactive waste, but no single approach satisfies all
the logical and practical requirements to serve as a basis for setting public health pro-
tection standards. We therefore feel that the foundation does not now exist for a spe-
cific prescription according to which numerical standards may be developed independ-
ently of the specific circumstances which apply to a category of radioactive waste.
The absence of any single completely satisfactory procedure has not prevented and
should not prevent effective regulation of radiation exposure. A framework for decision
making has evolved in which the specific circumstances corresponding to each source
of exposure are examined, and standards are then developed to assure that any allowed
exposures are reasonable, under the circumstances. The guiding principles of this ap-
proach to radiation protection are
1. that any allowed exposures be associated with some justifying benefit,
2. that they be as low as is reasonable in view of technical, economic, and social
considerations,
3. that inequitable distribution of risks be minimized, and
4. that certain stated levels of exposure of the general population not be exceeded,
virtually without regard to circumstances.
We have concluded that this framework is adequate to guide the development of public
health protection standards and regulations for radioactive wastes. To the extent that
we have proposed significant new principles of public health protection for these mate-
rials, it is not because a new method of examination has been adopted, but rather that
the established broad principles of radiation protection permit us to reach specific
conclusions applicable to radioactive wastes.
WHAT RISKS ASSOCIATED WITH RADIOACTIVE WASTES ARE UNACCEPTABLE?
The principles of radiation protection require that exposures (or risks of exposure) be
kept as low as is reasonable in view of technical, economic, and social considerations.
Our Background Report and the other speakers present a survey of the characteristics of
radioactive wastes, and certain broad considerations relating to their control. It ap-
pears to us, as a result of these considerations, that certain risks associated with the
storage or disposal of radioactive wastes should be considered unacceptable, since they
appear unreasonable in view of technical, economic, and social considerations. As an
example consider a waste system where there would be a high probability of events that
could result in acute effects, and this risk could not be reduced by reasonable controls.
A waste system with these characteristics is unacceptable, in our view. Similarly,
radioactive waste control systems are unacceptable if high-probability chronic risks are
not at least as low as those that are socially acceptable under comparable circum-
stances. Furthermore, we feel that the probability of occurrence of events that could
lead to high consequences should be lower for radioactive waste systems than is gener-
ally acceptable for productive technologies.
These conclusions follow from a broad examination of all radioactive wastes. EPA
intends, through its standards development program, to examine each class of radio-
active waste in detail and further define the risks to public health and the general en-
vironment which it considers unacceptable in view of the pertinent technical, economic,
and social circumstances.
-------
SUMMARY AND CONCLUSIONS OF WORKING GROUP II
INTRODUCTION
In the discussion below, the quoted items represent topics that were discussed rather
than agreed-upon resolutions. Any consensus reached has been clearly marked as such,
and the clear implication is that other assertions merely represent the views of some
individual(s) within the group.
The management of existing wastes was discussed separately from that of prospective
wastes. The following discussion of Items 1-8 applies to existing wastes.
ITEMS FOR DISCUSSION
Item 1; "Our responsibility to future people has no time limit."
It was the consensus of the group that our responsibility to future people has no time
limit. Risk considerations are therefore necessary beyond the present generation. It
was also expressed by members of the group that the responsibility to the future was
not limited to future humans, but included responsibility to all forms of life.
Item 2; "An adequate risk assessment for radioactive wastes should estimate the po-
tential health effects on humans for 1,000 years."
There was general agreement that the arbitrary selection of a 1,000-year risk assess-
ment is not the correct approach. Several persons recommended that the population risk
assessment should be carried out in time and distance until the risk to individuals in the
population becomes statistically insignificant relative to natural background radiation
or until uncertainties in risk estimates become too large for the estimates to be useful.
Objection was made to the suggestion that there is any level of risk that is insignificant.
Several persons expressed the opinion that the risk assessment should state the degree
of uncertainty. There was disagreement as to whether the EPA should do risk as-
sessment in the process of setting radioactive waste standards.
The question was raised, "Why is only human risk being considered when other elements
of the biosphere could also be affected?" The EPA representative stated that it was
EPA's decision that the human species is considered to be as sensitive to radiation as
any other element in the biosphere and therefore the use of the human standard is
justified. There was not a consensus agreement with the EPA decision. Other opinions
were that the human species may not be the best indicator but that other biota, such
as viruses, might be more sensitive to mutagenesis and to other effects of radiation on
the entire life systems. It was also stated that humans should not be the only protected
life form.
A suggestion was made that the EPA should be concentrating more on the development
of acceptable criteria using deterministic methods (or past experience) rather than
attempting to develop a probabilistic assessment to establish criteria. It was argued
that such probabilistic assessment cannot be realistically done without specific data
related to geologic data at the repository site and specific facility design information
for the proposed repository, and that these analyses will be performed using
deterministic (or past experience) or probabilistic methods at the time of the safety
analysis report submittal prior to licensing hearings. A suggested starting point for EPA
criteria determination was the existing radiation protection standards, 40 CFR 190.
37
-------
It was suggested that geologic uplift of locations for potential repositories after 1,000
years should be considered, and it was pointed out that the present Department of
Energy (DOE) program was gathering data necessary to include such risks in the Safety
Analysis Report risk assessment prior to construction licensing.
EPA's acceptance of the linear hypothesis as a basis for risk assessment was challenged
by some members of the group who believe that there is a threshold level for radiation
dose-response. Some people alluded to recent research suggesting that low levels of
radiation exposure may be more dangerous than higher levels. A divergence of opinion
existed as to whether the linear hypothesis was acceptable, nonconservative, or overly
conservative. The consensus was that any standard selected would be subject to future
change as future data became available. A question was raised as to which
radiobiologists were to make that determination. EPA responded that they have a re-
view team to evaluate radiation data; the discussion was inconclusive. It was suggested
that EPA should clearly state the assumptions used with respect to the dose-response
relationship.
A question was raised with respect to the methodology to be used in evaluating risk.
Individual dose was suggested as an adequate measure of risk. Much discussion followed,
and the following points were made:
1. Statistical risk to the total population should be included in the criteria.
2. The individual's probabilities should be multiplied by the total population to
determine the population at risk.
3. The assessment should be done for the life of the radiation.
4. Probabilities of individual risk for the persons at risk should be aggregated over
the total population to determine population risk.
It was also suggested that the individual should not be lost sight of in estimating sta-
tistical risks to whole populations.
There was disagreement and impasse on the methodology for evaluating risk statisti-
cally.
Item 3; "If consideration of adverse effects for a longer period might result in choosing
a more effective disposal technique, then general estimates should be made
for more than 1,000 years into the future."
There was general consensus that the arbitrary selection of a 1,000-year period was not
the correct approach. There was also consensus that the meaningfulness of the analysis
should be a determinant of the period for the analysis, but there was disagreement as
to whether there was any level of risk that could be considered insignificant.
Item 4; "An adequate risk assessment should consider the quantity and persistence of
the waste, and examine the projected effectiveness of alternative methods of
control; an adequate risk assessment should also consider the probabilities of
releases due to failures of controls and the uncertainties in all these
evaluations."
38
-------
In discussing risk assessment methodology for waste disposal the following sources were
used:
1. the EPA Background Document,
2. criteria mentioned in Forurn Agenda for Item 4 (above),
3. a resolution introduced from the floor stating that
"A risk assessment should
a. be performed to such time as the risk to an individual becomes sta-
tistically insignificant or the uncertainties in risk make results
meaningless,
b. consider physical and chemical characteristics as well as quantities and
persistence of waste,
c. address mechanisms of local release of wastes from the repository and
the likelihood of release,
d. consider movement of radioactive wastes through the environment and
the resultant human uptake, taking into account the effect of
assumptions of future climate, land use, and demography,
e. consider resultant health effects and assumptions of the relation of
radiation dose to health effects,
f. be as realistic as possible,
g. estimate, to the extent possible, uncertainties in risk,
h. identify processes and events which significantly contribute to either
release of wastes or the human health consequences of release,
i. identify those physical parameters which most influence risk and those
parameters which have little effects on calculated risk."
It was stated that risk acceptability is a different concept from risk assessment meth-
odology.
The discussion that followed resulted in these controversies, on which there was sig-
nificant dichotomy:
1. It was debated who should perform the risk assessments. There was opposition
to its performance by the NRC and private industry because of questions of
credibility, accuracy, and past programs. It was questioned whether EPA has
statutory authority for performance of risk assessments and whether risk as-
sessments are appropriate to the development of criteria and standards. It was
suggested that the risk assessment be performed by the National Academy of
Sciences. It was also suggested that risk assessment should be performed only
by persons who have undergone the experience of seeing a child die of
leukemia.
39
-------
2. It was questioned whose data and model of risk effects and probabilities will be
and should be used in the risk assessments which are to be used in establishing
waste disposal criteria. The assumption that statisticians as a class are nec-
essarily objective was challenged.
3. Different opinions were voiced on how to contend with uncertainties surrounding
risk assessments.
a. Some argued that we lack enough reliable data to perform a risk assess-r
ment with certainty, and therefore insisted on a moratorium on waste
generation.
b. Others argued that, in view of the greater risk of exposed waste as opposed
to buried waste, we should proceed with waste disposal, and that better
criteria and methods will evolve, based on experience gained in the
process.
c. The point was made that, as experience is gained, standards of safe expo-
sure to radioactivity change.
4. It was questioned how we can ensure that all risks are included in a risk as-
sessment that is based solely on calculations and judgment.
5. It was debated which alternatives should be included in a risk assessment. It was
suggested that in order to expedite implementation of waste disposal only
commercially available alternatives should be considered. In rebuttal one
participant asked what we would do if none of the commercially available
alternatives meet the established EPA criteria.
6. It was discussed how to consider or include the following important items having
potentially large uncertainties as factors in risk assessment: human error,
changes in weather, demography (including population size and land uses), and
failure of engineered or environmental barriers. Quantity and persistence of
nuclear materials was also discussed.
The following factors on risk assessment were agreed upon:
A. The assessment should include a survey of public opinion, and dissemination of
the result of the assessment to the public is desirable.
B. Risk assessment must be performed as responsibly as possible.
C. The elements of a risk assessment contained in the floor resolution were adopted
as a consensus.*
D. The necessity of performing a risk assessment for the transportation of radio-
active wastes was adopted as a consensus item.
Item A of the floor resolution was not a consensus opinion (see comment of William
Lochstet, p. 50).
-------
Item 5: "No prescription can be stated at this time for judging an adequate degree of
protection for radioactive waste independent of circumstances."
Several individuals felt that this agenda item was unclear, but the proposition was
vigorously defended by the EPA resource person. He justified the proposition on the
ground that long discussions had led EPA to conclude that no single commonly used
method of determining risk acceptability (i.e., solely by cost-benefit analysis, or by
comparison with other technologies, or by means of polling public opinion) was by itself
adequate for dealing with the problem of nuclear waste management, and that, there-
fore, a complex set of assessments involving all these factors needed to be undertaken.
Reactions from the floor included skepticism that others, after a full discussion, would
agree that "no single prescription" could prove adequate. Two prescriptions were
offered by individual participants as limiting statements that held up regardless of
circumstance. One of these was that we could never accept a disposal system that
might kill everybody, and the other was that human life was infinitely valuable and
should be extended boundless protection.
It was suggested that an adequate degree of protection from radioactive waste should
be zero exposure. Practically, if some release is allowable, there is then a pathway
for release, which may lead to greater future releases. This should be proscribed.
Item 6; "Risks due to radioactive wastes should be unacceptable unless more complete
isolation is unreasonable in view of technical, economic, and social
considerations."
A portion of the group agreed with the EPA statement. It was suggested that this
statement was to be a paraphrase of the ALARA ("as low as reasonably achievable")
principle. It was criticized, on one hand, as offering only shifting ground to
technologists, who, in the present waste crisis, need a clear and stable zone of
acceptability at which to aim in their efforts to design a waste management system. On
the other hand, this principle was condemned by several participants, first on the
ground that the implied cost-benefit analysis was irrelevant as there were no benefits
whatever from nuclear technology and, second, on the ground that economic consid-
erations were totally inappropriate for determining the number of deaths from radiation
exposure that might be acceptable. It was stated that, with enough money, scientists
could provide a disposal system that would guarantee the safety of future generations.
There was disagreement that this would be a proper allocation of taxpayers' or society's
resources. It was strongly emphasized that actual human lives and not statistics were
in question. It was argued that if vast resources were available for programs such as
weapons and LMFBR, it was hypocritical to object to the proposal of a zero release
criterion on the ground that resources were limited. There was considerable disagree-
ment over this matter and the point was forcefully made by one member that the dis-
cussion was that of a life-life rather than a life-cost tradeoff. A comparison was made
to emphasize the point that other energy technologies (e.g., coal) also had risks and
these risks should be used to place a perspective on nuclear waste risks. There was
mixed response to this comparison, and several members considered it invalid. They
expressed the belief that any technological risk to human life was unacceptable, and
one opinion was that the use of coal could be made clean and safe. Others concurred
that the safest total package (comparative risk) should be used. One person argued that
since even when perfect isolation is promised (e.g., in the case of Lyons, Kansas)
perfect isolation may not occur, we must not settle for less than perfect containment
as a goal. No consensus was reached.
-------
A portion of the group maintained that zero risk should be a goal, while another part of
the group felt that mitigating factors (social, economic, and technical) needed to be
considered (e.g., that the disposal of waste underground even with less than perfect
containment was better than the current situation). Some participants also felt that
zero risk was unattainable.
Item 7: "Risks to future generations due to our radioactive waste should be no greater
~ than those accepted by the current generation (as expressed in its standards
and regulations for radioactive waste)."
There was consensus that risks to future generations due to our radioactive waste should
be no greater than those accepted by the current generation. However, there was a
strong division between the following two points of view:
a. Future generations are not the beneficiaries of the waste-producing activities
and have no voice in the matter. Those holding this view believed that risks
to future generations should definitely be less. Many holding this view felt that
the risk to future generations should be zero. Some also felt that the use of the
word "beneficiary" was inappropriate on the grounds that existing wastes have
no benefit.
b. Future generations inherit the technology developed by the present one, and thus
are beneficiaries of the waste-producing activities. Those holding this view
believed that it is therefore reasonable that future generations share the risk.
This concept of "equity" was proposed as being implementable considering
future uncertainties and that there is a societal and cultural continuum. Some
felt that waste resulted from past and continuing activities which do have
social benefit.
Other points made included the following:
It was urged that the concept of equity apply not only for future generations but also for
all segments of the population in the present generation, and that the populations of
certain geographical locales not be asked to shoulder a disproportionate burden. The
question of "consent" was also raised in relation to the rights of states and citizens to
determine whether or not to accept radioactive wastes for disposal and the need for
uniform enforcement of such criteria as are determined.
It was suggested that EPA apply consistent criteria to nonradioactive hazardous wastes
and to radioactive waste to achieve equity in regulation. On the other hand, it was
suggested that there be special consideration for radioactive material.
Item 8; "Certain risks due to radioactive waste should be considered unacceptable.
These would be associated with circumstances in which
a. any exposure having a high probability of occurrence could result in more
than a chronic risk which could not be further reduced by reasonable
controls,
b. the levels of any chronic risks are not less than those for comparable figh-
probability circumstances acceptable to society, or
-------
c. high-consequence events do not have a probability of occurrence less than
that for comparable high-consequence events accepted by society for
similar productive technologies."
During the discussion of these questions, a general feeling emerged that the wording was
confusing. However, no substitute wording was generally agreed upon.
a. There was little dispute that the risk due to radioactive waste would be con-
sidered unacceptable if there were a high probability of exposure resulting in
more than a chronic risk that could not be further reduced by reasonable con-
trols. Opposition to this statement was on the grounds that it was too
ambiguous.
Two other points were discussed, and no consensus was reached. As suggested by the
EPA, these points were the following:
b. Levels of chronic risk would be unacceptable if they were not less than those
for comparable high-probability circumstances acceptable to society.
c. Risks associated with events having high consequences would be unacceptable
unless the probability of such events was less than the probability of compara-
ble high-consequence events accepted by society for similar productive
technologies.
Divisions of opinion with respect to questions b and c were basically similar. Three
points of view were fairly widely held:
1. Some participants felt that risks from radioactive wastes should be less than
other comparable risks.
2. Some members felt that the risks for radioactive wastes should not be required
to be less than comparable risks; they should only be considered unacceptable
if they are greater.
3. Some felt that risks from radioactive wastes are unique and that therefore
there is no such thing as a "comparable" or "similar" risk.
A number of other ideas were mentioned, including the following:
1. There was disagreement with the term "acceptable to society" because it im-
plies consent, where none has been given with respect to radioactive waste.
2. In judging acceptability, the risks due to radioactive wastes should be compared
with the risks of other activities having a social benefit comparable to the
benefits of the waste-producing activities.
3. Wastes should not be subjected to especially severe restrictions on the grounds
that they have no benefit associated with them; instead, they should be judged
in the context of the benefits of the waste-producing activities.
-------
DISCUSSION OF PROSPECTIVE WASTES
The management of prospective wastes was discussed separately from that of existing
wastes. This discussion focused on risk and risk acceptability from disposal of
prospective radioactive wastes, including low-level, medical, and high-level wastes.
Points considered were the following:
1. In developing and applying risk acceptability criteria, should existing and
prospective radioactive wastes be considered independently?
2. How should the determination of risk acceptability and the assessment differ?
(It may be appropriate to review Items 1-8).
A. Risk Acceptability
Some members of the group believed that the existing and prospective risks from ra-
dioactive wastes should be treated the same; however, costs for waste management
could be different for each.
Other members of the group, while desiring to keep the existing wastes under as strict
a control as possible, were not willing to accept any risks from future radioactive
wastes and called for a moratorium. Some suggested zero release; others said zero
release is not possible.
There were two viewpoints on the adequacy of existing technology for safe disposal of
high-level radioactive wastes. Quotations from the California Energy Resources Con-
servation and Development Commission draft report on High Level Waste Disposal and
a letter from the Director of the Executive Office of Science and Technology Policy
supported the view that an adequate scientific data base for geologic disposal does not
exist at present; however, a report to the American Physical Society by the study group
on nuclear fuel cycles and waste management in the January 1978 issue of Reviews of
Modern Physics (Vol. 50, No. 1, Part II) disagreed (see Appendix following this
summary).
There was concern expressed that the present status of existing wastes is dangerous and
that the waste disposal management program should address that problem. However,
there should be no compromise in establishing regulations for future waste, and these
regulations should be as strict as necessary to protect public health. Indeed, future
standards should be determined by public discussion to quantify what is an acceptable
risk.
It was pointed out that if one is to accept the position of zero release of radioactive
wastes from the nuclear fuel cycle, then one should also be willing to require a similar
strict control of hazards from other sources presenting radiation risks (e.g., coal,
geothermal, x rays, phosphates).
Another member argued that the risks from stored wastes will be influenced by the
amount of Congressional funding that would be available for the management of ra-
dioactive wastes.
The issue of voluntary versus involuntary risk was raised. With respect to risks from
future wastes, it was pointed out that unborn populations would be denied the
constitutional right to choose that risk.
-------
B. Cost of Waste Disposal
A side issue discussed by members of the group dealt with assessments of cost for waste
disposal. Some felt that the costs should be paid by the beneficiaries, namely the
present generation. Others shifted the burden of cost to the utility owners. Some sug-
gested that costs may be higher for present wastes than for future wastes because of the
potential different form of future wastes. Some insisted that the cost of disposal was
not an issue and that wastes should be disposed of safely regardless of cost.
C. Philosophic and Moral Discussions
Alternative power sources were briefly discussed. It was suggested that future tech-
nologies might have more difficult or hazardous waste disposal problems. When the risks
from coal were raised, it was pointed out that the technology exists to clean up the
effluents from coal-fired plants and that the health effects from mill tailings outweigh
the effects from coal-fired plants. There was disagreement on the extent of the relative
risks in comparing coal with nuclear power. It was also pointed out that other power
generation technologies also have health risks.
A fair basis on which EPA should derive acceptable risk standards for electricity gen-
eration should be per unit of electricity generated, independent of the method of gen-
eration.
Several moral issues were raised:
"We must turn away from a nuclear future... reliance on nuclear technologies or
weapons [is] an arrogance to the earth. Indeed, any planned release is premedi-
tated murder."
"There should be a moratorium on the future generation of radioactive wastes until
acceptable storage solutions are proved safe and publicly accepted."
The issue was raised that the lack of generation of power and the consumption of
nonrecoverable fossil fuels are also moral issues, because the effects on people may
be much more damaging than the risks associated with the nuclear-fueled genera-
tion of electric power.
"Regarding public health risks—one case of leukemia is one too many."
"There should be greater public education, such as town meetings, in order to
increase public discussion of risks versus benefits associated with nuclear tech-
nologies, and to allow the public to choose whether or not to license individual
nuclear plants."
APPENDIX
The geologic and hydrogeologic conditions that can provide for satisfactory isolation of
radioactive waste exist in enough places that we anticipate no difficulty in locating
several suitable sites in different geologic media within the immediate future.(l)
Current knowledge and technology are adequate to design and locate a suitable waste
repository of the conventional mined type, if utilized with appropriate site selection
criteria.(l)
-------
Since geology is not a predictive science, it may not be possible to reduce the
uncertainties inherent in geologic disposal to a level where there is a high degree of
confidence that the wastes can be confined for 100,000's of years. In conclusion, if we
proceed with geologic disposal on the basis of technical optimism in the face of scien-
tific uncertainty, then we are no better off than having the waste in an engineered
surface facility and we will have to maintain the same perpetual surveillance by mankind
of the repository (which in concept should not require it).(2)
Nonetheless, [the Analysis of the Back End of the Nuclear Fuel Cycle with Emphasis
on High-Level Waste Management] has identified some areas where problems are seen
to persist. As given in the report's summary, these include:
...(6) a lack of an adequate scientific data base for the geologic storage of nuclear
wastes.
I feel strongly that adequate resolution of the political, institutional and remaining
technical problems is crucial to public acceptance of the government's waste manage-
ment plans and to the success of the nuclear component of the President's energy pro-
gram. We have a collective responsibility to work with DOE, EPA and CEQ to assure
the success of the waste management program.
Signed, Frank Press, Director (3)
WORKING GROUP II PRESENTATION COMMITTEE
Name Affiliation
Albert Bates Catfish Alliance, Tennessee
William S. Brown Westinghouse Electric Corporation
Debby Browne Greenpeace Foundation
Marc W. Goldsmith Energy Research Group, Inc.
Judy Hurley Cactus Alliance
3. W. Lentsch Portland General Electric Company
W. A. Lochstet Pennsylvania State University
Henry Morton Nuclear Safety Associates
Neil Norman Bechtel National, Inc.
Alexis Parks (writer)
Christopher Taaffe Boulder Mobilization for Survival
David C. Williams Americans for Rational Energy Alternatives
(1) From Reviews of Modern Physics 50 (No. 1, Part II) (1978).
(2) California Energy Resources Conservation and Development Commission report on
high-level waste disposal.
(3) Executive office of the President, Office of Science and Technology Policy, letter
dated 3 November 1977.
-------
RESPONSES OF FORUM PARTICIPANTS TO SUMMARY
AND CONCLUSIONS OF WORKING GROUP II
Second Plenary Session
HENRY MORTON (Nuclear Safety Asociates, Bethesda, Maryland) [comment on Item
5]: EPA resource persons stated that the EPA has already concluded that Item 5 is
correct and strongly defended it. It is inappropriate and is a sham for the EPA to in-
clude such an item in the agenda on which it has already drawn a conclusion.
JUDY WILKINSON (Boulder Mobilization for Survival): What agreements were made
about how to develop an adequate data base when scientists are silenced by the industry?
MARC GOLDSMITH (panelist): I don't know that that's something that we can respond
to.
TODD JOSEPH (moderator): I don't think that the topic was discussed, except for the
references made to...some argued that we lack enough reliable data to perform a risk
assessment successfully, and insisted on a moratorium on [inaudible]. Others argued
that, in view of the greater risk with exposed waste as opposed to buried waste, we
should proceed with waste disposal, and that better criteria must be evolved through
experiences gained in the process...
ED HARTOWICZ (Dames & Moore, Lexington, Kentucky): Risk assessments are
couched in terms of direct health risks to humans. Should there not also be included
those additive risks to agricultural productivity, impact on the economy, and loss of
habitable areas where ground water contamination would preclude the use of the water
for irrigation or consumption?
KATHRYN PARTRIDGE: My basic questions and comments are included in the Fourth
Report, which we were not allowed to read before the body and tape recorders. I would
like to emphasize the non-democratic way the proceeding was held, calling for many
more hearings in more accessible locations (to the general public). This session cannot
be considered an adequate forum reflecting public opinion. Many key issues were not
adequately addressed by the formation of a rather strict agenda in Group II. The central
question of whether nuclear industries can be allowed to continue was not allowed an
adequate debate. However, I must applaud the EPA for this step in the right direction
toward true citizen input in the decisions which mortally affect them.
Items 3 and 4 of the Risk Assessment summary [do not] include comments I made that
risk assessment must be carried farther into the future than "statistically significant"
and/or "containing uncertainties." The analysis should be carried out to the lifetime of
the radioactivity, with uncertainties in data and standard deviations and other statis-
tical variations clearly stated. It should be publicly decided at which point these figures
become meaningless.
BEN BILLINGS (Environmental Action of Colorado, Denver): Thirty-five years have
elapsed since the birth of the nuclear age. In that time, there has never been a gov-
ernmentally sponsored forurn to discuss the social, ethical, and/or human acceptability
of nuclear power. Discussions of basic acceptability are always ruled "out of order" at
public meetings. It was pointed out many times at this meeting that this is "not the
proper forum" for such discussions. I urge that the "proper forum" be created to foster
full discussion of the basics. Thousands of meetings, discussions, presentations
-------
need to be held in all parts of the country, so that the American people, regaruless of
where they live, can participate, be heard, and decide.
COMMENT (name withheld): The EPA should soon, or next, address itself to the
question of the safe operation of nuclear power plants and weapons facilities, using the
standards of acceptable risks that will have by then been formulated in a way that takes
into account all implications of the operation of these facilities.
ARTHUR J. SOINSKI (Energy Resources, Conservation, and Development Commission,
Sacramento, California) [question on Item 3) : Please define "life of radiation."
GOLDSMITH: I don't think we discussed the technical details of half-life or life of
radiation. I think there is an indication in the toxicity for time and for long half-lives of
time that the waste must be kept isolated, but we did not discuss technical definitions
about life of radiation.
CARL J. JOHNSON (Jefferson County Health Dept., Lakewood, Colorado): Who are the
members of the EPA review team that will evaluate radiation data, and have they been
associated with the Atomic Energy Commission, the Nuclear Regulatory Commission,
or with nuclear industry or large university projects funded by AEC?
JOSEPH: The review team that is referred to is a committee of the National Academy
of Sciences, the BEIR Committee, and is not an EPA body as such.
JOHNSON: I apologize for my writing... The last part of that question was "...with
nuclear-related industry or with large research projects in universities funded by the
AEC." The reason for this question, and this may still apply to the BEIR Committee (I'm
not really certain), is that it is my opinion that persons who have worked with the AEC
or with the industry, or who have worked with university projects whose life depends
on funding by the AEC (of course, now the Department of Energy) really have some at
least unconscious bias in favor of less conservative standards. I feel strongly about this.
I don't feel you've answered my question.
JOSEPH: We understand the implication of your question, and I think we answered it.
JOHNSON: Thank you.
"JOHN GALT"[ pseudonym] : What in life, from childbirth to living in a quiet little town
like Waverly, Tennessee, has zero risk or a certainty about the future? Has the Amer-
ican citizenry been reduced to a point where its own personal safety is placed above
higher goals such as political freedom and economic responsibility, i.e. paying one's way
through life instead of living off the efforts of others? Would you ask any of the anti-
nuclear participants who are perfect to stand up and define "perfect containment?"
DAVID C. WILLIAMS (Americans for Rational Energy Alternatives, Albuquerque, New
Mexico): It was pointed out during this group's discussion of Item 2 that risk assessments
should prove useful even if relative uncertainties are large, provided it can be shown
that the risk is less than some upper limit value which is itself sufficiently small to be
acceptable. The group's drafting committee omitted this observation in its report.
ANDREW SNOW: I feel saddened by the fact that much of the basically humanitarian
inputs expressed by the environmentalists present at these meetings will be suppressed
by the strength of the corporate interests, especially through behind-the-scenes
finagling. Only when we come to a realization as a society that economic interests must
48
-------
come second to concerns for our health and the health of our descendents are we ever
going to be able to create a chance for our species' survival. That's the key. Survival...
I find it very hard to swallow that many of my contemporaries don't care about leaving
deadly nuclear waste time bombs for our unsuspecting descendents, if we are lucky
enough to have any.
JOHNSON: Why not reference radiation protection guides on the 4-millirem annual
dosage limit to any organ or total body established by the 1976 EPA Drinking Water
Regulations?
3OSEPH: Well, again, I'm not sure that's a question about what the report says...is it
a general suggestion?
JOHNSON: Perhaps it should be taken as a comment or suggestion rather than a
question... I think the 4-millirem standard is well supported by the EPA's Support Doc-
ument, and I think that it might be a good reference point for standards for radiation
exposure from other environmental sources.
ROWE: One point of clarification: That is only for drinking water.
JOHNSON: The regulation does apply to drinking water. There's a separate section,
however, of the standard which relates to exposure to radium and manmade beta and
photon emitters and water, and I think that the importance of this regulation is that it's
well-researched [andj well-supported and applies to one source of environmental expo-
sure. I think it's very relevant to the question here today. Thank you.
CHRIS TAAFE: A cost-benefit analysis, in its broadest sense, lies close to the heart
of this matter of establishing risk acceptability. My opinion is that no risk is acceptable.
For some reason, although costs were addressed, no probing exploration of the nature
of the benefits claimed was conducted. My question is: What are the real benefits of
nuclear power—and don't most of them actually accrue to corporations inequitably as
enormous profits at the expense of the health and emotional security of people today,
their children, and the children of future generations?
COMMENT (name withheld): Risk from radioactive wastes are indeed different from
other high toxicity wastes. Radioactivity decreases with time while others, such as
arsenic, lead, many carcinogens do not diminish. This involuntary risk is assigned by
our society to future generations as a by-product of society on the basis of a de facto
cost/benefit assessment.
STEVE DAVIS: The EPA should choose a location for its future public forums where the
freedoms of speech and assembly are allowed to be adequately expressed. Some
members of this conference were once threatened with arrest, when peacefully pre-
senting their views. This occurrence happened the first day of the conference, and I was
one of them that was threatened, and believe me, it's a very bad way to start out a
conference.
DR. JAMES MARTIN (Chairman): I can't let this one rest. The hotel approached us
after (whatever this event was) as to whether or not they should preclude this, and we
said, "No, these people are here, they're part of the public, they have a right to do
whatever they wish, and unless they somehow endanger your property or your resources
here...If you take any action, it's on your own, not on behalf of this agency."
COMMENT FROM AUDIENCE: What were they doing?
-------
MARTIN: I frankly don't know; it didn't interest me,
ALEXIS PARKS (panelist): It was a street demonstration out in front of the hotel...is
there a better definition of it? All right, demonstration is the wrong word, it was
just...there were several people involved.
3OSEPH: The point of the matter is that, when the question was brought to EPA, the
hotel was instructed that we did not wish to preclude any such demonstration.
MIKERAUDENBUSH: It seems to me that the Group II report was an adversary report—
pro-nuclear side, anti-nuclear side, pro, anti—and I compare that with the Group I
report, in which, although there [ werej plenty of adversary positions expressed, there
was some kind of a consensus that came out of that group, with minority views. I would
simply suggest to EPA that, from my point of view, the smaller the group discussing the
subject the better, and that for future meetings you might try to break up into smaller
groups to avoid this kind of "I'm right"/"No, you're not."
DR. WILLIAM HARDING (Drexei Uniyersity); The EPA should explicitly point out in
any public document that people in fact make cost-risk and/or risk-benefit decisions
inherently in their daily lives though they may not be aware of this reality.
JUDITH HURLEY (Boulder Mobilization for Survival, Cactus Alliance): The failure to
thoroughly review the nuclear weapons industry as a source of hazardous nuclear mate-
rials was an overwhelmingly serious limitation on the meaningfulness of these
discussions. While I'm up here, I would like to explain also what the "offensive" street
theater was that got the police down on us. We had a 6-foot globe, that's all—a 6-foot
earth—as a symbol of what these discussions were about, and the police said that unless
we got this representation of the earth off of hotel property we would be immediately
arrested.
STEPHANIE J. BAKER (Western Nuclear, Inc., Denver, Colorado): A basic premise of
our free society is that continued industrial development is compatible with appropriate
control of radioactive wastes. To suggest a moratorium on nuclear power development
until the radwaste issue is resolved is absurd.
WILLIAM A. LOCHSTET (rapporteur, Working Group II): In Item 4 of the Report.under
Factors on Risk Assessmentf the following point wa^ agreed upon: Item C might imply
an endorsement of the entire floor resolution. The elements of risk assessment con-
tained there in Items B,C,D,E,F,G,H,I were generally agreed to. However, Item A of
the floor resolution was not endorsed, as is clearly indicated elesewhere in the Group II
report, particularly as appears under Item 2. The self-contradiction was not deliberate.
CAROLYN LANDES [comment on Item 7(b| : The question of passing on the nuclear
technology and all the risks involved with it cannot be related to the general premise
that future generations inherit the technology developed by the present one. Nuclear
energy has been proven to be more destructive than any other technology man has
developed. It's hard for me to consider (b) as a valid argument for it being reasonable
to expect future generations to share the risk. Passing on a nuclear technology feels
very different to me than passing on a solar technology.
PAUL BURMEISTER (Mid-American Coalition for Energy Alternatives) [ comment on
Item 4, part 3 (h] : I feel that it is important that the EPA always consider the risks
of possible human intrusion [or] any proposed terrestrial radioactive waste repository
in such activities as drilling or mining sometime in the future, which could damage the
50
-------
geological integrity of the repository, leading to possible exposure of the waste to the
biosohere.
biosphere.
WRITTEN COMMENTS
LOCHSTET: Item 2 stated that an adequate risk assessment should estimate the po-
tential health effects for 1,000 years. I would not consider a risk assessment adequate
unless it estimated the potential health effects on humans for much more than 1,000
years, preferably millions of years.
51
-------
TOPIC m
WHAT CONTROL MEASURES SHOULD BE UNDERTAKEN
FOR RADIOACTIVE WASTES?
-------
CONTROL MEASURES FOR RADIOACTIVE WASTE: A STATEMENT
OF ISSUES AND OB3ECTIVES OF WORKING GROUP III
Joseph E. Fitzgerald, Jr.
Waste Environmental Standards Program
U.S. Environmental Protection Agency
INTRODUCTION
The purpose of this presentation is to provide a perspective on the proposed criteria as
they relate to requirements for control of radioactive wastes. The goal of radioactive
waste control was deliberated at the Workshops in Reston, Virginia, and Albuquerque,
New Mexico, and by EPA both within and outside the Agency. Notwithstanding some
reservations, a general consensus exists, we believe, that the goal of control should be
to isolate radioactive wastes fromthe biosphere over their hazardous lifetime. This goal
should be pursued not only to prevent adverse effects on humans, but also to prevent
long-term environmental contamination. In pursuit of such a generalized goal, there are
a number of specific controls, existing and proposed, for various wastes. They basically
involve either institutional approaches or isolation by environmental barriers. The
balance of this presentation deals with judgments pertaining to acceptable types and
degrees of control via these approaches.
INSTITUTIONAL CONTROLS
A judgment was reached from our past two Workshops and subsequent deliberations
within EPA that, recognizing the increasing uncertainties associated with institutional
continuity over time, there is a need to establish a limit to our planned reliance on
institutional control. Given the perspectives of human, institutional, and environmental
time scales, and the "relative predictability" of events over these time frames, it was
our judgment that 100 years represents an appropriately conservative figure. It should
be emphasized, though, that this does not purport to suggest how long these institutions
may actually survive; only how long any form of control for radioactive wastes should
depend on them.
While a numerical criterion such as this one carries with it some rather obvious impli-
cations for current and proposed management practice, there are other, perhaps less
recognized implications that bear on the acceptability of institutional control. To a
large extent, these involve institution-related measures which may offer net advantages
in safety beyond 100 years. Examples are monitoring, retrievability, and passive
communication using records or markers. In terms of long-term environmental isolation
of wastes, serious questions have been raised as to the effectiveness of these measures
and whether any reliance on them is acceptable. It is clear that it is difficult to design
for retrievability or conduct a monitoring program without compromising isolation to
some degree. Likewise, passive communication cannot be relied on over the long term,
and may, in fact, prove detrimental if the presence of such a record improves the
probability that site intrusion will take place.
On the other hand, it is also recognized that, given certain circumstances and
limitations, these provisions may enhance the overall protection from the wastes. One
such limitation is the 100-year institutional control limitation proposed by EPA, which
would make longer reliance on any of these measures unacceptable. For passive
communication, however, reliance on institutions would not necessarily be required.
Likewise, a designed capability for waste retrieval or postoperational monitoring would
be acceptable with the caveat that safety is not to be compromised, which represents a
-------
second restriction. In this regard, if monitoring activities, designed retrieval, or even
the piacement of markers could decrease waste isolation now or in the distant future,
application of these measures should not be allowed since no net improvement would be
expected in environmental and public health protection.
ENVIRONMENTAL CONTROLS
In contrast to institutional controls, environmental controls entail the use of natural
and/or engineered barriers to ensure isolation. As commonly applied, the main barrier
is the geological medium in which the waste is interred. These media are chosen be-
cause of their physical properties, which inhibit the movement of waste both physically
and chemically. They are normally supplemented with engineered barriers, such as
containers or the form in which the waste is managed. Despite the fact that some
engineered barriers have survived intact over time, others of like design have not. Since
the primary consideration for waste management is reliable isolation, it is our conclu-
sion that engineered controls should only be depended upon for interim institutional
management or for use in conjunction with natural barriers.
In ensuring the acceptability of environmental barriers, proper site selection is impor-
tant in maintaining protection of the materials over the time periods in question. On
this basis, then, it would seem prudent to select environs where stability would be
enhanced, not decreased, by the effects of natural forces, such as erosion, sedimen-
tation, and crystallization. For example, a pile of radioactive low-level diffuse waste
would probably be better "disposed of" in an abandoned open pit mine than left exposed
to the natural elements of the surface. In this case, earth cover would be expected to
increase with time and would be more desirable. We have therefore concluded in the
criteria that, all other safety factors being equal, disposal sites should be chosen which
would have a long-term positive effect on isolation.
RADIOACTIVE WASTE CATEGORIES AND CONTROL:
CURRENT AND PROPOSED PRACTICE
The various categories of radioactive waste and their respective characteristics and
magnitudes have been described in the first presentation. A similar overview would be
appropriate to put the available control options into like perspective. Waste manage-
ment alternatives can be broadly classed into three categories:
1. generally accepted alternatives based on existing technology,
2. currently unacceptable alternatives based on existing technology,
3. concepts based on future technological developments.
The first group includes control concepts and methodologies that require state-of-the-
art technology for implementation, although the concepts themselves may be unproven.
For example, deep geological disposal requires the selection of a suitable geological
formation whose characteristics ensure the isolation of the disposed waste. While the
disposal technology is largely defined, much of the research is currently centered on
the selection process. Current candidates receiving attention in this country and
elsewhere are rock salt, as found in both bedded and dome formations, argillaceous
(clay) formations, and various hard rock formations (granite, basalt, and limestone,
to cite a few). All of these formations have physical characteristics which minimize
the possibility of release via groundwater intrusion, the primary potential pathway. Al-
most all of the current practical knowledge of radioactive waste disposal derives from
56
-------
experience with shallow land burial. There are presently four active and two inactive
commercial burial sites in the United States. The wastes disposed in them, although
made up of predominantly short-lived fission products, also contain a fairly broad
cross-section of radionuclides with significantly longer half-lives and higher
radiotoxicity (e.g., radium-226 and transuranics). Operating experience at a number of
burial sites in this country has shown that, in some cases, actual contact between the
waste and ground water has occurred, with detectable contamination monitored off-site.
In contrast to deep geological disposal, proper isolation as defined for this methodology
is almost entirely dependent on institutional management.
The second group of control practices covers state-of-the-art management concepts
whose acceptability is in question, such as ocean and terrestrial dispersion. These two
techniques make use of the "dilute and disperse" principle, which we judge not to be an
appropriate solution for the disposal of radioactive waste. Ocean dumping (as opposed
to deep seabed disposal) has been employed by this country in the past and is currently
being used by a number of foreign countries. There is, however, concern over
maintaining acceptable isolation of wastes interred in this matter.
The third group of control alternatives encompasses technologies which have yet to be
developed. These include such techniques as deep space disposal, ice cap disposal, and
waste partitioning and subsequent isotopic transmutation. It is clear that some of these
may offer advantages over methods that are available for immediate use. We are paying
particular heed, though, to the views repeatedly emphasized in the workshops and other
similar forums that it is the responsibility of this generation to pursue options which
offer solutions for the near term, as opposed to creating a further legacy of our waste
management problem.
With regard to existing control technologies, therefore, the degree to which particular
control options are applicable is dependent on the characteristics of the waste to be
managed. High-activity long-lived waste includes what traditionally is called high-level
waste, meaning reactor fission products as well as unreprocessed spent fuel. It also
encompasses discarded medical and industrial sources which meet.the criterion of being
capable of producing radiation exposures with immediate, or acute, effects. These
wastes, because of the nature of the hazard they represent, need to be completely
isolated from the biosphere for the extent of their hazard. The degree of control ne-
cessary to ensure acceptable isolation is dependent on the effectiveness of a number of
engineered and natural barriers. These include the form of the waste, use of suitable
containers, the integrity of the geological formation, and the retardation of waste
migration within the medium itself. Because the half-lives of the critical nuclides are
typically hundreds to thousands of years, disposal is being proposed in deep geological
formations whose stability will conceivably outlast the hazard.
For high-activity waste whose hazards are relatively short-lived, acceptable isolation
would require a combination of institutional and environmental barriers of sufficient
duration to ensure acceptable control over the period in question. For wastes whose
recognized hazard would exceed 100 years, reliance on institutions of any kind would
not be justifiable on the basis of the EPA criterion proposed. Present practices for
disposing of some of these wastes by shallow land burial, therefore, may need to be
modified, in particular by restricting disposal of certain materials by this method.
Few control techniques are available for low-activity long-lived wastes, and those that
exist are not completely acceptable. Because of the characteristics of the waste in-
volved, the associated hazard is chronic, entailing a relatively small degree of control
over an extended period of time. Of the two forms of wastes in this category, discrete
57
-------
and diffuse, acceptable control of the latter has proved to be particularly difficult to
resolve. Sometimes termed "naturally occurring diffuse waste," they include materials
such as uranium mill tailings and phosphate wastes, whose large volumes make conven-
tional management impractical. Currently, these wastes are stored on or very near the
surface, with initial but nonuniform stabilization and/or reclamation being performed.
With the proposed restriction on institutional reliance, though, stabilization as now
practiced could prove to be unacceptable.
SUMMARY
To summarize, there are two available means of control for radioactive waste man-
agement: institutional and environmental. For institutional management, EPA has
proposed a 100-year limitation on reliance. In this regard, no restrictions on customary
uses of land areas and surface and ground waters due to residual waste hazard can be
permitted. This criterion would therefore be of consequence with regard to current
shallow-burial and surface-storage modes of management. Other institutional manage-
ment provisions, such as monitoring, retrievability, and passive communication, would
be acceptable if they satisfied all of the EPA criteria and if a net improvement in safety
could be shown.
With regard to environmental control, proper site selection is a primary consideration.
Whenever practicable, locations for radioactive waste disposal should be chosen such
that the effect of natural forces such as erosion and sedimentation is positive. For
waste isolation in geological media, sites should be chosen to reduce the effect of
potential interaction of the waste with ground water to the greatest extent possible.
-------
SUMMARY AND CONCLUSIONS OF WORKING GROUP III
At the initial evening meeting of Working Group III, organizational and agenda questions
dominated the deliberation. The suggested questions prepared by EPA were discussed,
and several additional questions relative to the proposed control criteria were added (see
asterisked questions in Attachment 1). These questions were then used as the basis for
the discussion on the proposed control criteria presented in the EPA Background Report.
The issue of using 1,000 years in the cost-benefit analysis was questioned and strongly
criticized. Bill Rowe of EPA stated that the figure was a "straw man" and was intended
to elicit comment from the group. There was also extensive discussion at this initial
meeting that centered around clarification and/or definition of such terms as reliability,
predictability, and effectiveness. The need for clarification and definition were the
bases for including additional questions on the proposed list.
Even though EPA expressed the opinion that this was "A Public Forum on Environmental
Protection Criteria for Radioactive Waste," there were questions from the group as to
its adequacy in this regard. The validity of relative hazard indices was discussed without
resolution, as were questions of reimbursement for property cases and incentives to
communities to accept waste repository siting. The question of the proper role of con-
trol criteria in specifying a release probability was raised, but was not addressed by the
group.
An opinion was expressed that the entire Forum was predicated on the acceptance of
a nuclear economy. One individual wished to enter into the record his strong dis-
agreement with such a premise. This item was not discussed by the group.
The second day of deliberation was devoted to criteria proposed in the Background
Report. These criteria were written as follows:
4. Controls should be applied with a goal of isolating radioactive wastes from the
biosphere over their hazardous lifetime to protect humans and minimize
unnecessary contamination of the environment. When institutional control is
the method chosen to provide environmental protection of radioactive wastes,
no restrictions on customary uses of associated land areas and surface and
ground waters due to any residual risks should be required after 100 years;
radioactive wastes that would require protection beyond 100 years should not
be isolated by institutional means, but rather by as many physical and natural
barriers as is practicable to minimize environmental impact if one or more fails
or is accidentally or intentionally breached.
5. Locations for radioactive waste disposal should be chosen whenever practicable
such that the action over time of natural forces such as erosion, sedimenta-
tion, and crystallization could be projected to improve, rather than reduce,
environmental isolation; if used to isolate wastes, geological media should
reduce the effect of potential interaction of the waste with water to the
greatest extent possible.
6. Certain additional procedures and techniques should also be applied to waste
disposal systems which otherwise satisfy these criteria if they provide a net
improvement in environmental and public health protection; among these are:
a. monitoring prior to completion of disposal to determine for timely correc-
tion any unanticipated effects which could result in releases of radioac-
tivity to the general environment,
59
-------
b. procedures or techniques designed to enhance the retrievability of the
waste, and
c. passive methods of communicating to future people the potential hazards
which could result from an accidental or intentional disturbance of ra-
dioactive wastes.
DISCUSSION OF CRITERION 4
Discussion of Criterion 4 revealed the problems of various group members with terms
such as "unnecessary," institutional control," "ground waters" (in the general sense),
"100 years," "physical," "natural," "practicable," and "minimize." It was also pointed
out that there was no mention of cost-benefit analysis or cost-effectiveness in the
criteria. The word "unnecessary" was felt to be somewhat subjective and superfluous,
and the group recommended that it be deleted. Further, it was felt that the word
"continuously" should be added to make it clear that controls should apply from the time
when the material is defined as waste, including transportation and handling.
The group did not agree with the definition of "institutional controls." The problem with
the original definition derived from the feeling that "devices" were not properly part
of institutional controls. Accordingly, it was recommended that the definition be
changed to
Institutional controls—Activities that involve the performance of functions by
human beings to limit contact between the waste and the human environment.
The group felt that 100 years was too arbitrary a length of time to predictably rely on
institutional controls. Accordingly, the consensus was that it should not be included in
the criteria. There was also some discussion on the advisability of using historical
precedents as a basis for predicting the reliability of institutional controls.
The words "physical" and "natural" were used in such a way as to imply that natural
could not be physical and vice versa. The group thought this was an obvious error and
that "physical" should be replaced by ''engineered."
The group recommended that Criterion 4 be reworded accordingly:
Controls should be continuously applied with a goal of isolating radioactive waste
from the biosphere over their hazardous lifetime to protect humans and minimize
contamination of the environment. Reliance on institutional controls should be
minimized; primary reliance should be placed on engineered and natural barriers to
protect the environment and public health. It is recognized that such actions as
operational controls during disposal operation, temporary restrictions on land use at
certain disposal sites, and monitoring to ensure continuing adequacy of the
engineered and natural barriers may be necessary. Institutional controls shall cease
when there is no longer any need to restrict land use. Public health, safety, and
full-cost analysis are all essential components of control criteria.
This rewording allowed consensus and satisfied many of the objections voiced relative to
the words used in the proposed criteria. However, after extended discussion no
consensus could be reached on the relative importance of cost factors in Criterion k. All
agreed that cost was an important factor, but no consensus could be reached on its
significance. Some felt that, as was the case with safety, cost was a paramount con-
sideration, while others felt that it was secondary in importance, that safety decisions
60
-------
could not be based on cost considerations, and that costs should not be limited to eco-
nomic considerations.
Other points which were discussed under Criterion 4 but on which no consensus was
reached included the following:
1. It was thought that some criteria were extremely general and needed to be made
more specific, whereas others were too specific and needed to be generalized.
2. Criteria should not require isolation and controls so stringent that the radiation
levels that result from disposal are lower than those that would have occurred
had the material been left in its natural state.
3. A "bottomline" acceptable risk must be specified before criteria are formulated.
4. All cost of control and disposal should be borne by those benefiting fromthe use
of the technology producing the radioactive waste.
DISCUSSION OF CRITERION 5
Discussion of Criterion 5 centered around the need for it in general waste-disposal
criteria. It was generally felt that the site-specific aspects of the criterion were
incomplete and that they were more applicable to standards. Further, Criterion 5 as
written provided no real guidance. Accordingly, the group recommended that the cri-
terion be deleted or reworded to read as follows:
Locations for radioactive waste disposal should be chosen so as to minimize envi-
ronmental and human health impacts and, wherever possible, to enhance isolation
over time.
DISCUSSION OF CRITERION 6
Discussion of Criterion 6 led to the consensus that 6a was adequately covered by the
rewritten Criterion 4 and should be deleted, and that the phrase "and other societal
values" should be added after "public health protection."
Other points with regard to proposed Criterion 6 on which no clear consensus was
reached included the following:
1. Retrievability of high-level waste seems incompatible with isolation and the
minimization of institutional controls.
2. Criterion 6b should be broken up into two statements covering high-level and
low-level wastes. To some, it seemed clear that it is often desirable to
retrieve certain phosphate and uranium wastes which might have intrinsic value
as a resource. On the other hand, others felt that high-level wastes, excluding
spent fuel, had no apparent intrinsic value, and that the need for retrievability
was based on some expectation of extracting transuranics or finding a future
use for the material. The net benefits in this latter case may not justify de-
signing for retrievability. It was also pointed out that, because of cost, it was
probably impossible, short of extraterrestrial disposal, to prevent a determined
future generation from getting to the waste.
61
-------
3. Some said that in the initial 5- to 10-year period of the operation of a high-level
waste depository, retrievability is necessary to confirm site suitability.
4. Cost-benefit analysis as a necessary element in any control criteria or delib-
erations on controls was discussed extensively.
The group had no problem with Criterion 6c as written in the EPA Background Report.
Some additional comments by individuals on the proposed criteria included the following:
1. An opportunity for involvement and comment on criteria (through workshops, for
example) should be provided for state governments.
2. The problem of current wastes should be addressed as soon as feasible through
the issuance of criteria and, ultimately, standards. However, the issue of
criteria for and generation of future wastes needs to be held in abeyance
pending the establishment of an adequate data base.
3. Since the "best possible" approach was being used in formulating the waste-
disposal criteria under consideration, these criteria should be applicable to all
waste—present and future.
WORKING GROUP III PRESENTATION COMMITTEE
Name Affiliation
Stephanie J. Baker Western Nuclear, Inc.
Tom English California Institute of Technology/Jet Propulsion
Laboratory
E. Lee Gronemyer Washington State Health Division
William H. Harding Drexel University
Judith Johnsrud (with Environmental Coalition on Nuclear Power)
George W. Leddicotte (with Florida Power & Light and a member of the
Utility Waste Management Group)
Bob Mason Gold Hill, Colorado
Philip L. Paull Vermont Public Service Board
Tom Philbin Ecological Analysts, Inc.
Roy G. Post (with Univ. of Arizona Nuclear Engineering Dept.)
Roy Young Colorado Recycling Cooperative Association
62
-------
RESPONSES OF FORUM PARTICIPANTS TO SUMMARY
AND CONCLUSIONS OF WORKING GROUP HI*
Second Plenary Session
CAROLYN LANDES: I wish Group III could have come up with a little more criteria to
help me have some peace of mind about the current waste sitting around or shallowly
buried and possibly leaking in the U.S. right now.
MIKE DOYLE: What this conference ultimately addresses is not radioactive waste
disposal techniques, but [whether] we, as a society, will continue support of extremely
high-technology, inherently dangerous, isolated energy production technologies. In-
stead, [we should] consider change in our lifestyle and ultimate values and begin support
of permanent benevolent energy production.
STEPHANIE J. BAKER (Western Nuclear, Inc., Denver, Colorado): Regarding the term
"consensus": The chairman of Group III insisted that only unanimity could be used to
express "consensus"—I disagree; when only 2-3 individuals within a group dissent but the
majority agrees, this should be so stated in the text of the proceedings. A minority
opinion could also be included.
GEORGE W. LEDDICOTTE(Utility Waste Management Group): The responsibility of the
EPA should be to establish an acceptable degree of risk to environment and public health
associated with any activity judged necessary for the public welfare, in this instance
the generation of power. In establishing the risks acceptable from radioactive wastes,
the risks associated with producing electrical power by other means must also be con-
sidered. These risks should include such aspects as effects on public health, the national
economy, depletion of natural resources useful for other purposes, etc.
We believe that nuclear power is a benefit to every individual in the U.S. It is now a
necessary part of our national economy. Overall, nuclear energy, in both absolute and
comparative terms, has already provided copious benefits in saving natural resources,
preserving the environment, and in reducing health effects, thus saving lives.
However, the continuance of its beneficialities demands expeditious actions by the EPA
and other regulatory agencies to provide satisfactory criteria and standards for waste
management.
KATHRYN PARTRIDGE: Comments on the "irrationality" and "vested interests" of the
anti-nuclear advocates have been made. Yes, I am irrational, if irrationality means
sensitivity for others' welfare, concern for the future, and emotional insistence that we
are dealing with living beings and not statistics.
Yes, I have a vested interest. I am 22 years old and hope to have children in the
upcoming years. I do not wish these children to suffer the effects of radiation-
leukemia, cancer, and heart disease. What technician or scientist has the right to
dictate over the life and death of my child?
Owing to failure of the tape recording system, only those comments submitted in
written form are included here. However, this includes most of what was said.
63
-------
COMMENT (name withheld): The use of the word "consensus" to mean 100 percent vote
(not even one dissenter) made much discussion meaningless. The tactic overweights the
feeling of the minority. As a result I think little was accomplished. I had the usual
feeling of frustration at trying to design something by committee. We seem mostly to
agree that it is indeed important to "get on with it." I don't think this is the way to do
it.
BEVERLY HANNA THORPE (Ontario Ministry of the Environment): In establishing
criteria for controls, it should be emphasized that there may be non-radiological com-
ponents which pose health and environmental risks that must be contained. This is
particularly important in such wastes as uranium mill tailings. Separate consideration
of the radiological and non-radiological components, especially separation of
jurisdictional control, should be avoided.
ALBERT BATES: Present shallow land-burial sites which contain long-lived or highly
toxic radioactive wastes or which are now considered inadequate by any organization of
government to actually contain the hazard should be considered, along with other forms
of interim storage, as impermanent conditions. A timetable for transfer to permanent
isolation should be developed and adhered to. This timetable should fall within a short
term.
GARY BEACH (DEQ - Land Quality Division, Cheyenne, Wyoming): While establishing
criteria, administrative capabilities as well as technological capabilities should be
considered by EPA. This point is particularly important to extending the control criteria
to encompass "mass waste," i.e., tailings, where institutional control shall be necessary
for existing and produced wastes of the immediate future. State and local governments
must be considered as institutions of control when relating to administrative capabili-
ties.
FRANK ANDERS: What right does EPA have in pursuing controls of radioactive
wastes—especially in light of the CoPIRG vs. Train Supreme Court decision?
DR. JAMES MARTIN (EPA): We have no doubt about our responsibility or authority to
set environmental standards for radioactive wastes.
HENRY C. RAIBOURN: Should the nuclear industry involved be required to bear the
total cost of disposal of all future waste in order to relieve the burden to the taxpayer
and minimize the production of radioactive wastes?
STORM [so identified on card : Battelle Northwest Laboratory Report BNWL 1900 was
of the opinion that legal barriers in the form of treaties signed by the U.S. Government
preclude [extraterrestrial^ ice cap, or sea bed disposal of high-level wast€] .
C. B. PEARSON (Colorado Public Interest Research Group): All costs associated with
the use or abuse of the various radioactive materials should be aboveboard and
transmitted to the public. While the general public must eventually pay for all positive
and negative aspects, these costs are not revealed to the public either through docu-
mentation of Federal tax money contribution to the nuclear industry and radioactive
material research or through the standard utility bill. This should be done..
DR. CARL J. JOHNSON (Jefferson County Health Dept.): Because the EPA's proposed
guidelines for exposure to plutonium and other transuranic elements (and their fission
products) will relate to the control measures undertaken for radioactive waste, will the
EPA have a hearing for those proposed guidelines?
-------
MARTIN: These guidelines are in a formal process in EPA. A decision has not yet been
made on whether to hold a hearing for the plutonium guidelines.
BOB MASON: General comment: Group III was able to achieve a significant and com-
mendable dialogue within a remarkably short time. I believe that this demonstrates both
the possibility and [ th<3 desirability of extensive additional efforts on the part of the
EPA to extend both the range and depth of these discussions. This extension must focus
sharply on increased participation by the general public in face-to-face encounters with
specialists representing industry, government, and a broad range of scientific and en-
gineering disciplines. Only by this means, I believe, can irrational responses on all sides
of this vital issue be replaced by reasoned, effective decision making.
STEPHEN K. BRESLAUER (NUS Corp., Rockville, Maryland): I am disturbed and dis-
appointed in the attitude of many attendees that any individual who is not opposed to
nuclear power or who does not espouse a radical position related to waste disposal is a
tool of "industry" who is acting against the public interest. Professional and responsible
environmentalists may in good conscience support nuclear energy and may even work
for nuclear industries without compromising their integrity. Being "anti" is not neces-
sarily "good." Being "pro" is not necessarily "bad." Individual issues should be dealt with
constructively.
MIKE RAUDENBUSH: People in the industry are also citizens with a right to speak.
ROBERT W. POWITZ, Ph.D. (National Environmental Health Association): The concept
of "multiple etiology" of health and environmental insults is widely recognized.
Therefore, I recommend that any proposed criteria be reviewed and commented on by
other branches of the EPA and other agencies such as: DOE, HEW etc. so as to assure
consistency and compatability with other regulations and agency missions.
I strongly recommend that any law specifying numerical criteria/standards promulgated
by the EPA be so worded that adjustments due to emerging technology and new epi-
demiological findings can be made in either direction by consensus (or science court)
rather than resubjecting the law to the entire legislative process. The error of the
Occupational Health & Safety Act should not be repeated.
DAVID C. WILLIAMS (Americans for Rational Energy Alternatives, Albuquerque, New
Mexico): The EPA is to be commended on trying to run the Forum fairly, but it should
not make any pretense "The Public" was represented here. Most participants were either
technically trained individuals strongly supporting nuclear energy or else individuals with
a strong vested interest in opposing nuclear energy. Neither subgroup can be viewed as
being at all typical of the general public.
DAVID LANDES: Concerning Criterion 5: I think it should read "Locations for radio-
active waste disposal should be chosen for zero environmental and human health impacts
and to enhance isolation over time."
BOB BOLAND (DOE, Las Vegas, Nevada): The difference between shallow land burial
(confinement of waste) and the disposal (isolation) of high-level and TRU waste must
be defined. Burial is confinement. Disposal is isolation, i.e. in a deep geological medi-
um.
We have used "high level" and "low level" without definition. High-level waste is defined
in 10 CFR Part 50 Append. F. This has some transuranics and all fission products.
Low-level waste includes low concentrations of transuranics and all fission products—
65
-------
and these are considered suitable for a shallow land burial type waste management
operation.
DR. TOM ENGLISH (Jet Propulsion Laboratory, Pasadena, California) [comment on
agenda Issue 6]: "Is best available technology necessarily acceptable?" Are bedded salt,
sea-bed, transmutation, and space disposal considered "available technologies" for
high-level waste disposal? Are there any available technologies for high-level waste
disposal? Furthermore, does the United States even have a spent-fuel policy which
allows electric utilities to transfer spent fuel to the government for ultimate disposal?
MARTIN: Before we adjourn I'd like to thank each of you for attending this Forum and
giving your time and effort on our behalf. I'd also like to compliment you on the hard
work you did and the commitment to stick to the job, which at times went well into the
night. You have made sure that EPA has its work cut out in order to finalize the cri-
teria. I'd also like to compliment the EPA staff for their contributions, and to extend
gratitude to Al Hazle of Colorado and Hall Bohlinger of Louisiana for pitching in on
short notice to moderate working sessions for us. Finally, I'd like to thank our
contractor, Ecological Analysts, Inc., for running a smooth meeting so the rest of us
could devote our efforts to the work of the Forum. Thank you for coming.
66
-------
PREPARED STATEMENTS FROM THE PUBLIC
-------
STATEMENT OF AMERICANS FOR RATIONAL ENERGY ALTERNATIVES, INC.
(PREPARED BY DAVID C. WILLIAMS, PH.D.*)
BIOGRAPHICAL NOTE
Dr. David C. Williams received a bachelor's degree in chemistry from Harvard Univer-
sity in 1957 and a Ph.D. in nuclear chemistry from the Massachusetts Institute of
Technology in 1962. He was a postdoctoral fellow specializing in nuclear research from
1962 to 1966, first at Princeton University and then at Los Alamos Scientific Labora-
tory. From 1966 to the present, he has been a member of the technical staff at Sandia
Laboratories, Albuquerque, N.M. Major work areas have included safety analysis on
radioisotope powered generators intended for space use, vulnerability studies on reentry
vehicles, and LMFBR safety research. He has also performed evaluations of the hazard
potentials of nuclear wastes for Americans for Rational Energy Alternatives (AREA), a
New Mexico citizens' group concerned with energy and environmental problems.
INTRODUCTORY
The following comments on the Background Report and the proposed Environmental
Protection Criteria for Radioactive Waste are divided into two parts. The first part
includes commentary on the report in general, while the second is restricted to com-
ments specific to the proposed criteria. The Background Report is understood to reflect
the factual and philosophic basis that underlies the proposed criteria, and we likewise
believe that the comments offered with respect to it are necessary to fully appreciate
the basis of our suggestions with respect to the criteria. Hence, it is our strong hope
that the Environmental Protection Agency will carefully consider all parts of our com-
mentary.
I. COMMENTS ON THE BACKGROUND REPORT
General
The discussion of the risks associated with very long-lived wastes is unnecessarily vague
and nonquantitative. Partly for this reason, and partly because of the repeated allusions
to the longest-lived isotopes and to very long time periods (e.g., pp. 1, 9, 10, 16, 17,
18, 19, 20, 21, etc, etc., etc.), the report appears to give excessive emphasis to the
small fraction of the total radiological hazard that actually is longer-lived than a few
hundred years. Nowhere in the report is it pointed out that the longest-lived materials
are produced in correspondingly smaller amounts, in terms of radiological hazard
measures. More quantitative discussions of some aspects of this point are given later.
Page 1, Paragraph 2. The assertion is made that "It is generally conceded that risk es-
timates for many of the long-lived radionuclides would depend on numerous imprecise
variables which would be little more than speculation after certain time periods." It is
then concluded there could result "intense controversy over any calculations" underlying
any criteria or standards, etc. At best such statements would be true only of the exact
values of the numerical risk estimates. Such estimates are not necessary for environ-
mental protection criteria or standards, however; it suffices only to convincingly
*1300 Espanola N.E., Albuquerque, New Mexico 87110.
69
-------
demonstrate that the risk is Jess than some upper limit value which is itself acceptably
small. Strong arguments can be advanced (e.g., Cohen 1977) for believing that this is
indeed the case; in fact, we are not aware of any quantitative arguments to the contrary
that cannot be readily refuted.
Page 9, First Paragraph. The statement "Long-lived wastes are especially significant
...''is subject to the general comment made at the beginning of this review. Implications
of these materials' long lifetimes is considerably mitigated by their relatively low total
hazard potential, at least insofar as ingestion is concerned. For transuranics (TRU),
inhalation hazard potential per gram is much greater than the ingestion hazard potential
per gram. Thus, the "special significance" does not seem warranted unless exposure
paths involving dispersal as a respirable aerosol are likely. Acareful evaluation of these
clearly would be appropriate.
Page 10, Second Paragraph. The statements concerning 1-129 and C-14 seem unneces-
sarily alarmist unaccompanied as they are by any qualifying remarks concerning the
amount assumed to be released or resulting radiation exposures. 1-129, for example,
will probably not be "volatile" in any form chosen for long-term disposal, and in any
case, it is produced in such small amounts that it is difficult to see how significant ex-
posures could occur except locally.* The statement that C-14 "if released to the bio-
sphere, would represent exposure of the entire world's population" is true only in the
sense that "a single breath exhaled by a single human being pollutes the entire
atmosphere" represents a true statement. Either C-14 release must be enormously large
or the dose will be meaninglessly small. Unfortunately, the average reader will have
little appreciation of this fact.
Page Ifr, Paragraph 2. Here and elsewhere (e.g., page 30), reference is made to the
linear dose-response hypothesis (for estimating health effects due to low radiation
exposures) as if this hypothesis were among the most well-established of natural laws.
Actually, as the EPA is surely aware, this assumption is highly controversial. It is our
understanding that linear dose-response is considered fairly respectable for estimating
effects due to alpha radiation and other high-LETt radiation, but that it almost cer-
tainly seriously overestimates the risks due to low levels of beta and gamma radiation.
Concerning the latter, Report #43 of the National Council on Radiation Protection and
Measurements holds that risk estimates based on linear dose-response "cannot be ex-
pected to provide realistic estimates of the actual risks from low-level, low-LETt
radiations, and have such a high probability of overestimating the actual risks as to be
of only marginal value, if any, for purposes of realistic risk-benefit evaluation." (NCRP
1975; emphasis original.)
*At current world-wide production rates, if all 1-129 were disposed of by simply dumping
it in the ocean, over 1,000,000 years would be required to reach a few tenths of one
per cent of the most conservative of the maximum permissible concentrations that
have been established for 1-129 in drinking water. Even allowing for the biological
activity of iodine, it seems most difficult to construct an environmentalist doomsday
scenario based upon this nuclide.
tLET E linear energy transfer. Alpha radiation is high-LET, beta and gamma (e.g.,
fission products) are low-LET.
70
-------
In view of the very controversial nature of the linear dose-response assumption, we find
it both surprising and disturbing that the EPA Background Report simply asserts it as
law without debate, comment, or even a reference to the technical literature on the
subject.
Page 15, First Paragraph. We believe nothing useful is accomplished by distinguishing
between existing wastes and wastes to be produced in the future. We cannot imagine
why the amount of time, effort, resources, etc., that is justified in being spent in order
to mitigate a specific health effect, for example, should have any explicit dependence
upon whether the waste responsible for that effect was produced before or after some
particular date. The argument that existing waste has no benefit associated with it
seems specious: there obviously was a benefit associated with it at the time it was
produced, and the fact that the association of this benefit with the waste is no longer
immediate or directly observable is hardly a reason for treating the waste differently
from that to be generated by similar activity in the future. By the time that future
waste is ready for disposal, the benefit associated with its production will be "past" also.
As a matter of fact, many human activities (mining, automobiles, etc.) can be inter-
preted as generating adverse environmental impacts (e.g., land spoilage and water
pollution from mining, automobile exhaust gases, etc.) which have no use. For obvious
reasons, these purely adverse impacts are regarded as being part of the price paid for
the benefits. We see no rational reason for treating nuclear waste in a very different
manner, i.e., artificially divorcing it from the benefits of the activity producing it and
then announcing that it will be subject to uniquely severe restrictions on the grounds
that its risk now has no "benefit" associated with it.
Page 13, Paragraph 2. We are disturbed to see the credence EPA seems to be giving
to the notion that the benefits of activities producing radioactive wastes might not
justify the risks associated with the wastes. All evidence available to us indicates these
risks can be kept very small. In contrast, the activities producing such wastes are vital
to our nation's defense and probably equally vital to our national energy programs: two
of the most urgent and potentially dangerous problems confronting our nation today.
Risks to our national and even personal survival would be incalculable if all nuclear ac-
tivities were abandoned. Nowhere does the Background Report seriously acknowledge
these risks. Yet the report seems to be giving credence to the notion these risks
might have to be accepted because of the alleged "menace" posed by radioactive
wastes; worse, it seems willing to allow this notion to affect the formulation of
policy in disposing of radioactive wastes.
Furthermore this question clearly transcends the jurisdiction of the EPA; society as a
whole must make the ultimate risk-benefit decision. The EPA should limit itself to es-
tablishing reasonably conservative (but not excessively conservative) criteria in ac-
cordance with society's (admittedly vagueFsTandards for making risk/benefit decisions in
general. Here the "benefit" is not the benefit of the waste-producing activity: it is only
the benefit of saving the additional costs associated with further reduction of risks.
Once this approximated break-even point is (roughly) determined, it is up to a broader
segment of society to decide whether the residual risk is indeed worth the benefit of the
waste-producing activity.
Page 16, Top of Page. We do not see how serious attention can be given to the notion
that risks to future generations must be zero, since it would be totally impossible to
apply such a notion on a society-wide basis: almost any human activity involves some
degree of risk. The most that could be rationally argued is that future generations,
being uninvolved, should be subject to no more risk than we consider acceptable for
71
-------
other "third party risks," i.e., risks to people who are not involved in the activity,
receive no direct benefit from it, and have no choice in being subjected to it (the risk
to people on the ground from falling aircraft is a commonly cited example).
We ourselves strongly endorse the belief that future generations are indeed beneficiaries
of properly designed technological activities. Indeed, all societal decisions, positive and
negative, affect the future in some degree and therefore leave "legacies" of some kind.
For example, we can think of few "legacies" for future generations more "immoral" than
a planet stripped of easily exploited fossil energy reserves combined with a society
devoid of the technologies needed to exploit advanced energy sources. Nonetheless, we
believe the "third-party risk" viewpoint is one that can at least be reasonably admitted
to discussion; indeed we believe risks probably can be kept within the limits such a
viewpoint would suggest,
Pages 17-21. Here and elsewhere the discussion appears to give excessive emphasis to
extremely long time periods, "legacies," and uncertainties involving the distant future
—at least, insofar as the man-made radionuclides are concerned. We believe actual
risks to future generations will be very small and the excessive emphasis on legacies,
etc., is unjustified. We will illustrate our point with the hazard posed by wastes from
light-water reactors (LWR's) since these are currently the largest single source of man-
made waste generation. We assume wastes will be buried in deep-lying, stable geolog-
ical formations and analyze the problem in terms of the ingestion hazard potential,
since ingestion following migration in ground water is generally believed to be the most
likely pathway for human exposure, as is implied in the Background Report, page 28 and
elsewhere. We would note the following main points (additional details on some of these
points are given in Appendix A):
1. Hazard potential of LWRwastes initially declines rapidly during the first fewyears
following removal from the reactor. During the period of a few years to a few
centuries, the ingestion hazard potential is dominated by Sr-90 and, to a lesser
extent, Cs-137, both of which decay with half-lives of slightly under 30 years. At
300 years, the total residual hazard potential is about 1,000 times less than its
value at 10 years; at 1,000 years it is over 10,000 times smaller than the 10-year
value (Cohen 1977). Only a portion of even this very small remainder lasts for the
very long times (hundreds of thousands or even millions of years) commonly cited
in popular literature, including the Background Report.
2. Because of the relatively rapid decay of the wastes, if future generations produce
waste at the same or greater rates as "we" produce it, most of the total hazard
potential present at that time will be "theirs," not "ours." In this case, the much-
discussed question of "legacy" scarcely arises. Only if waste-producing activities
decline at rates greater than the decay rate of the wastes might future generations
find themselves with a hazard potential "bequeathed" from past generations
greater than what they themselves were producing. Though not impossible, we
consider this unlikely; see Appendix A [of this statement].
3. Actual risk at any future time is roughly proportional to the hazard potential at that
time multiplied by the probability of being exposed to the waste (or any given
fraction of it) at that time, other things being equal. Emplacement of the waste
in a permanent repository should represent a large reduction in the exposure
probability compared with the exposure probability associated with management in
temporary facilities at the terrestrial surface (tanks, cooling pools, etc.). Prob-
ability of exposure at any given time should remain small in the distant future and
may even continue to decline (Appendix A). We know of no mechanism permitting
72
-------
exposure probability to increase with time sufficiently to compensate for
the very large reduction in hazard potential. Hence, risks, in the distant
future should be very small compared with present risks, even though all technical
estimates show the latter are themselves very small by normal societal standards.
4. In the Background Report and in much popular discussion of the issue, there seems
to be a tendency to confuse two quite different concepts: the probability of ex-
posure to the wastes at some specified time in the distant future (directly related
to the risk experienced by the generations living at that time), and the total
probability that release might occur sometime in the future. The latter probability
obviously does increase as "the future" is indefinitely extended.
5. It might be argued that the goal should be limiting the total future expectation of
harm, i.e., the risk integrated (summed) over all time, to being less than the ex-
pectation of harm we are willing to accept for just the present generation. Though
we believe this more stringent goal may indeed be achievable, we do not believe
it can rationally be required as a necessary condition for reasons which include the
following:
a. In addition to producing radioactive materials, nuclear reactors destroy
uranium isotopes, and, hence, reduce future environmental exposures due
to uranium + daughters (Ra-226, Rn-222, etc.).
b0 If integrated indefinitely over geologic time, the hazard potential of the
radionuclides eliminated from the environment greatly exceeds the time
integrated hazard potential of radionuclides added to the environment [the
difference is two to three orders of magnitude at least (Cohen 1977, Wil-
liams 1977)].
c. By careful selection of the burial site, it should prove possible to keep the
probability of exposure to the wastes small compared with the probability
of exposure to the natural uranium + daughters, which are disturbed more
or less at random. Hence, the time-integrated expectation of harm due
to the uranium + daughters destroyed by the reactor should exceed that of
the wastes produced by factors even larger than those applicable to the
hazard potentials.
d. Current NRC regulations for LWR's require radiation reduction to levels as
low as practicable at costs of up to $1,000 per man-rem reduction of dose-
commitment. Rough calculations (Williams 1977) show that the reduction
of ultimate dose-commitment by destroying uranium in reactors is likely
to be approximately an order of magnitude more cost-effective, and thus
mandatory if one combines current standards of acceptable radiological risk
with the time-integrated expectation of harm concept.
We believe it is very questionable to place mandatory limits on the expection of harm
due to an activity while ignoring a benefit resulting from the activity that is the same in
kind and much larger in magnitude. It likewise makes no sense to require a given level
of expenditure to reduce a man-made hazard when the same level of expenditure would
result in a reduction of a natural hazard that is similar in kind and greater in magnitude.
We conclude, therefore, that this condition (assuring the time-integrated expectation
harm to be less than that which the generation producing wastes will accept for itself)
cannot rationally be made a necessary condition.
6. Additional assurance that future risks can be kept very small may be gained from
the following perspectives:
73
-------
a. If wastes are to be deeply buried, it is reasonable to compare their hazard
potential with that of the natural radioactivity, especially Ra-226, already
present in the ground down to comparable depths (2,000 feet, say). Even
if all U.S. electric power generation were nuclear, the hazard potential of
one year's wastes at the time of disposal would be less than 0.1 percent of
that of the Ra-226 in the U.S.; after 1,000 years, it would be less than
0.00001 percent of that of the radium (less, in fact, than that of the radium
underlying just one square kilometer and within 2,000 feet of the surface).
b. After only 250 years, the wastes' hazard potential is less than that of the
uranium ore from which the wastes were ultimately derived; leaving this
ore in the ground would not be generally considered unacceptably hazardous
even though the ore is much less carefully buried than the wastes can be
and has an effective half life of 4.5 billion years (that of U-238).
c. The fact that the wastes are more concentrated than the natural radioac-
tivity does not invalidate comparisons such as these (see Appendix'A).
d. From these facts, it is readily shown that future risks will be extremely
small provided the wastes are managed so as to be no more accessible, on
the average, to the biosphere than is the natural radioactivity within the
top few thousand feet of the ground. We consider it less than credible that
modern technology cannot achieve this goal, at least to the extent that the
full burden of proof must rest with the contrary view.
To Sum Up: We believe there are very strong reasons for expecting that risks to future
generations from man-made radioactive wastes can be kept minute indeed, and the
vague and ominous tone of many of the discussions in the Background Report seems quite
unwarranted. We also recommend that the EPA consider the following two guidelines
in setting environmental protection criteria for radioactive wastes:
1. A necessary criterion is that risks to no future generation exceed risks we the
producers of the wastes are willing to accept ourselves.
2. A sufficient criterion shall be that the time-integrated expectation of harm be no
greater than what the waste producers will accept for themselves. This criterion
is clearly not necessary since its consistent application would require that we
spend enormous sums of a fission reactor program for the sole purpose of
eliminating uranium from the environment, and we judge it very improbable that
such a program implemented for this purpose only could win public acceptance.
Page 22, Paragraph 1; Page 29, Paragraph 1. Here and elsewhere, reference to "total
isolation" over the "hazardous lifetimes" seems to imply an absolutist, either-or, on-
off approach to radioactive wastes that we feel is very inappropriate, since (a) EPA
makes risk assessments on the basis of the linear dose-response hypothesis, and (b) the
"hazardous lifetime" is very ill-defined, the wastes' hazards varying continuously with
time as they do. Evaluation of acceptabiliy must likewise be in graded terms, e.g.,
times, probabilities and amounts of possible release, and amount of hazard potential
at the time of release.
Pages 24 - 27. We find the discussion of uncertainties here to be of questionable utility,
partly for reasons already noted previously. The use of Rochlin's "three time periods"
seems especially dubious for the current problem. We would, of course, agree that
safeguarding some wastes should not be relegated indefinitely to human institutions,
but not because the latter show a rapid increase in "breakdown probability" after 100
years. We know of no reason to believe this probability should increase rapidly after the
next 100 years. Indeed, it could be rationally argued that there are a number of crises
74
-------
confronting mankind (population, economics, energy, resources, environment, etc.)
all capable of causing social breakdown in less than 100 years if not properly addressed,
while breakdown would then be less probable after this period if these problems are met.
Once again, there seems to be confusion between the probability of an event occurring
per unit time versus the integrated probability that it will occur at some time in the
future.
The reason that engineered/environmental barriers are to be preferred is that, if
properly chosen, they should prove far more reliable than institutional safeguards-
today, tomorrow, and forever, unless drastic improvements in the reliability of human
institutions occurs.
Page 30, Paragraph 2. All societies, not just those dependent upon high technology,
involve nonzero risks; indeed, risks are typically much greater in nontechnological
societies.
Page 30, Paragraph 3. See comments concerning Page 14, Paragraph 2 with respect
to application of the linear dose-response hypothesis.
Page 31, Bottom—Page 32 Top. The proposal offered by Starr for risk acceptance seems
to nave been dealt with unnecessarily negatively in view of the fact that the objections
raised to it can be at least partially answered:
1. Though the risk-benefit relations would indeed be difficult to assess at all accu-
rately, it often would be possible to demonstrate that a given risk is very small
compared with other accepted risks of comparable benefit. In this case, a precise
relationship would not be necessary.
2. Though the results would describe "circumstantial" rather than "optimal" risk-
benefit relations, certain influences do exist to force some rough approximation to
whatever society considers "optimal," perhaps more so than could be done by ar-
bitrary regulatory decree.
3. The problem of changing perspectives applies to all present-day decisions insofar
as they affect the future.
Page 32, Second Paragraph. Though exposure to the risk of natural background radiation
is involuntary, exposure to variations in this background is not involuntary. Consider-
able variation in background exposure is associated with one's choice of geographical
location, construction materials for dwelling, etc. Generally speaking, these variations
are universally ignored by the public. Few if any are those who choose their place and
type of residence with minimization of background radiation as an important factor.
Perhaps the most eloquent testimony to the lack of importance generally ascribed to
these variations is that they are rarely if ever used even in ulterior promotional appeals.
That is, appeals based on reduced background radiation are not used to promote wooden
home construction; real estate developers in low-radiation regions make no appeal to
this fact nor do they try to scare people into leaving high-background regions such as
Albuquerque, New Mexico and Denver, Colorado. For that matter, we are not aware of
antidevelopmental groups in the latter areas using the high background radiation levels
in their attempts to get people to stay away.
Variations in background are, then (a) generally ignored as trivial, and (b) associated
with risks of the same kind as those associated with radioactive wastes. Hence we
75
-------
recommend these variations as a potentially very useful yardstick for measuring the
acceptability of the latter risks.
Pages 33-36. Several good points are made in the discussion of assessing attitudes and
opinions of the public toward risk. However, the most important reason of all for not
basing policy solely on "acceptability" in the public opinion sense is omitted: the public
itself may have a grossly distorted impression of the hazard, greatly exaggerating it (or
underestimating it, for that matter). We believe that this is unquestionably the case
for radioactive wastes. There are many reasons for this exaggerated perception of the
risks; one is the treatment of the subject by certain elements in the news media.
Under our system of government, a great many decisions must be made by duly au-
thorized agencies, not the general public, especially when complex technical issues are
involved. At the Albuquerque Workshop, pollster B.W. Roper pointed out that a large
majority (64 to 24 percent) of the public itself believes that the proper disposal of nu-
clear wastes is a question that should be resolved by expert groups, not the public (EPA
1977). In passing, we note that opinion gathering in public forums and the like
(Background Report, p. 33) would be extremely misleading: inevitably, the majority
who believe the question should be left to experts are unlikely to participate in such
forums, and the "sampling" will be drawn very largely from the minority.
We are not, of course asserting that the basic value judgments which ultimately underlie
any risk/benefit decision should be "left to the experts." This judgment is to be made
by society as a whole, in some sense. However, evaluation of what the risks are, and
thus determination of whether society's criteria for the risks being worth the benefit
have been met, is something that must be left to the experts. Opinion polling, to be
very useful, would have to separate the public's attitude toward what constitutes an
acceptable risk from public belief as to how large a particular risk is, since the latter
may well be factually in error.
Page 37, Main Paragraph (end). Whenever referring to prevention of exposures "in
excess of background levels," one should include a qualifying word such as "signifi-
cantly," e.g. "significantly in excess of... ." It is often impossible to avoid some in-
crease, though the increase may not be directly measurable. Here "significant" might
be defined to mean equaling or exceeding the routinely ignored variations in background
levels noted earlier.
Similar qualifications should be added elsewhere, e.g., page 41, second paragraph, etc.
Page 39, Top Half. Considering that they are advanced as "necessary conditions to be
satisfied . . ." (emphasis supplied), some very questionable statements are asserted here
with essentially no admission that opposing views might exist. An example would include
the assertion that chronic exposures to any organ (emphasis supplied) must be small
compared with the natural background. The "necessity" for this restriction is far from
established and in any case is more likely to be plausible for some organs (gonads, whole
body) than for others (thyroid, lymph nodes).
Page 40, First Full Paragraph. As noted earlier (comments on Page 15) we do not
consider it valid to separate the "useless" waste from the beneficial activity producing
it and then subject waste management to especially severe restrictions on the grounds
the waste has no "benefit" associated with it.
Page 40, Bottom. We agree that it is not useful to be greatly concerned about designing
against events which would independently have consequences much more severe than
76
-------
the effects of the wastes. With some qualifications, we would include the notion that
future generations might forget about or lose track of the wastes as being such an event.
The qualifications are that we assume major repositories will not be unlimited in number
and might be supplied with some kind of passive advisory marker. Major repositories
will then be very substantial installations, and loss of all records as to their purpose plus
loss of ability to interpret the marker implies a truly catastrophic collapse of our civ-
ilization such as might result from nuclear war, social chaos due to an extreme energy
famine, etc. Thus, this problem appears to fall in the category of "events independently
having much greater consequences."
Page 41, First Full Paragraph. We agree that risks should be "equitably distributed,"
provided that it is clearly understood that "equitably" does not necessarily mean
"equally." Risks are almost invariably unevenly distributed; for example, the risk to
people on the ground from falling aircraft is obviously much greater for people living
near airports than for people far from airports. "Equitable" should be defined to mean
that no one individual or group of individuals be subjected to excessive risk; that is, the
risk must be kept reasonably small even for those whom the risk is largest.
II. COMMENTS ON THE PROPOSED CRITERIA
The following comments are keyed to the numbering system used in the Background
Report, pages 50-53.
Item I. We are not certain that it serves any useful purpose to have the origin of ra-
dioactive materials (e.g., fission reactors) included in the definition of radioactive
waste. The ultimate goal of environmental protection criteria is to control public
radiation exposure in both the present and the future; the origin of the radionuclides
involved is at most of secondary concern. Singling out specific sources seems to invite
applying disproportionate attention to some sources while other sources of comparable
significance may be neglected. We would suggest that radioactive waste be defined as
material that:
(a) has no likely resource or product value; and
(b) could result in a significant increase over natural background exposure to human
beings, either in the present or in the future, if discharged into the environment
in an uncontrolled manner.
Here as elsewhere in our discussion we would define "significant increases" such that
increases in exposure small compared with the routinely ignored variations in background
radiation would not be considered significant. In applying this criterion, we believe that
it might be reasonable to exclude certain highly anomalous extremes in the natural
background (e.g., monazite sand regions) that affect relatively few people. We would
also agree that it might be reasonable to control smaller radiation doses provided the
cost is not excessive as judged by some realistic cost-benefit criterion (see below).
Item 2. We endorse the concept that environmental protection determinations should
be based "primarily on an assessment of risk to individuals and populations." We believe,
however, that here and elsewhere it will be necessary to judge risk reductions according
to some cost-benefit criterion. Implicitly, some such criterion will always be involved,
since at least some further reduction of risk can always be achieved if cost is truly no
object at all. So long as such criteria are left implicit, there may be some danger that
efforts not be allocated as effectively as possible (an example would be the dispropor-
tionately small amount of effort devoted to minimizing unnecessary medical radiation
exposure in comparison with the standards of the nuclear industry). For this reason and
others, we believe the EPA might consider using explicit cost-benefit criteria, at least
77
-------
in an advisory role or perhaps in conjunction with other factors, in determining at what
point further precautions would no longer be justified.
As an example of the type of criterion that might be used, we note the NRC require-
ment of expending up to $1,000 per man-rem reduction in dose commitment (we are only
illustrating the concept, not endorsing the numerical value). This approach could be
refined; for example, the formula could take into account whether the whole body or
just one or some specific organ(s) would be exposed; available information on the
radiosensitivity of the exposed organ (e.g., BEIR 1972) could be factored into the
criterion. It would also be necessary to distinguish population exposures that would be
accumulated over time periods of the order of a human lifetime or less from those that
would be accumulated over much longer time periods. A probabilistic approach might
be applied to exposures that would occur only in the event of mishaps.
We realize any such guidelines could only be imprecise at best and would be attacked as
"putting a price on human life," etc. However, some such decision on cost-benefit will
always be implicit in any regulatory decision as to what should or should not be required,
and the charge of "putting a price on human life" will always be leveled by those who
find their interests to be advanced by making such charges. We believe the net effect
will be beneficial if we make our implicit cost-benefit criteria more explicit and more
nearly objective, provided always that it is set at a reasonable level as judged by
society's willingness in general to increase economic costs in order to reduce risks.
Item 3. The notion that any risk is somehow unjustified is totally discordant with
society's attitude toward all other risks (below certain ill-defined levels, they are simply
ignored). The qualification starting with "unless..." is too vague to be very useful; taken
literally, it is universally applicable and thus applies to the risks just noted that society
accepts because further risk reduction would be "unreasonable in view of technical,
economic, and social considerations." We believe it would be more helpful to use lan-
guage such as the following: "The acceptability of risks due to radioactive waste must
ultimately be judged in terms of:
a. risk-benefit criteria applied to the activity producing the waste; and
b. cost-benefit criteria as applied to the social and economic cost of imposing addi-
tional restrictions to achieve further risk reduction.
The second criterion is the one of primary concern to the EPA; a much broader segment
of society must be involved in the first judgment.
jtem 3, Second Sentence. We would suggest simply saying "risk" here, not "potential
risk." "Risk" associated with an unplanned or accidental event may be defined as being
equal to the probability of the event's occurring multiplied by the consequences resulting
if it does occur. In loose discussion, "potential risk" is sometimes used to mean conse-
quences only, not allowing for the probability of the event; no end of confusion often
results in such discussions of "risk."
jtem 3a. The wording here is confusing. Is it intended to say that disposal methods will
be unacceptable if they result in a high probability of there being radiation exposures
producing acute effects, and further application of reasonable controls could not reduce
the magnitude or the probability of such exposures? Or is something else intended? In
any case, we found the meaning obscure.
Items 3b and 3c. These reiterate the notion that to be acceptable, risks associated with
radioactive wastes must be less than other acceptable risks. The only justificiation
offered was the very artificial separation of the wastes from the beneficial activities
78
-------
producing them and subsequent characterization of the wastes as being "without bene-
fit." As noted in our Comment with respect to Page 15, we believe this unique ap-
proach to radioactive wastes is totally unjustified. Hence, we cannot accept the notion
that risks associated with radioactive wastes must in principle be kept less than other
acceptable risks. In practice, we believe application of reasonable cost-benefit criteria
to risk reduction will result in levels that are low compared with many risks. What we
do not accept is the notion that comparisons with other accepted risks may not be "good
enough"; that radiation risks are somehow special and must meet criteria not generally
imposed in other areas.
Item 4. We would question the wisdom of issuing specific, definite restrictions on policy
which are intended to be universally applicable, as was done here in prohibiting re-
strictions on "customary uses" of land areas and surface and ground water lasting longer
than 100 years. Natural characteristics (mineral content, presence or absence of water,
etc.) of many parts of the terrestrial surface and subsurface often impose restrictions on
usage which last indefinitely. It may be unreasonable or impractical to require that
human activity involve no such restriction. This is especially true when the human ac-
tivity only involves relocation of natural radioactive materials. Probably aquifers
penetrating natural uranium ore bodies would be at least locally unfit for human con-
sumption, and we are not certain that it will be practicable or reasonable to require the
tailings resulting from mining such ore to be disposed of in such a way that no future
restrictions are needed. For example, the nature of the tailings piles is such that, were
it not for their radioactivity, a "customary use" might be construction materials. Ac-
tivities involving removal of any covering applied to the tailings might have to be re-
stricted, water in and below the tailings may be nonpotable, etc. Note that similar
restrictions, especially for water usage, may result from other landfill operations, e.g.,
disposal of fly ash and sulfate sludge from coal-fired plants. Even a deeply buried waste
repository could be interpreted as imposing restrictions on subsurface land and water
use.
We believe a better approach might be to formulate guidelines such that the total land
area dedicated to waste disposal in any way would be acceptably small even if it were
assumed disposal activities continued for a very long time in the future. This should not
present any great difficulty. Mill tailings will never occupy more than a modest amount
of land because of the limited amount of uranium ore in existence. Disposal require-
ments for high-level wastes should also be small, with about 150 square miles reportedly
being adequate for the order of 1,000 years' U.S. waste production even assuming major
usage of nuclear energy throughout the period (Cohen 1977), and long-term restrictions
would only be required for the deep strata actually used for disposal.
The requirement that "as many physical and natural barriers as is practicable" be used
for long-lived wastes should, of course, be subject to cost-benefit' analysis.
Item 5. We are not certain as to what is meant by choosing locations such that "natural
forces...improve...isolation"; this concept was not discussed in any detail in the text. Is
the idea to prefer regions where net deposition currently exceeds net erosion? If so,
we have misgivings; areas of net deposition may be regions of high geological activity,
high permeability to ground water, etc., that would be less suitable than highly stable
geological formations that are currently undergoing net erosional effects but at a low
and relatively predictable rate. The key point is the importance of future predictability.
In any case, the idea advanced here needs much more explanation and analysis before
accepting it as a general criterion for waste disposal.
79
-------
Concerning the last sentence of Item 5, this shouid specify moving or circulating water.
Stagnant water (e.g., the aqueous inclusions found in rock salt) may be much less im-
portant if it can be demonstrated that subsequent migration is improbable even if the
wastes do interact with such water.
Item 6. Any "additional procedures and techniques" introduced should be judged by some
reasonable cost-benefit criterion.
GeneraL We believe there is a need for a much greater emphasis on cost-benefit cri-
teria than is found in the detailed wording of the environmental protection criteria.
Other things being equal, it will obviously be desirable to meet the various criteria
offered in the Background Report, but some of them shouid be offered as optional
guidelines or rules of thumb helpful in forming judgments, not rigid dictates to be
obeyed slavishly without regard for whether the cost required to do so in specific
instances is in any way justified by the benefit obtained. In estimating "cost" of addi-
tional control measures, all costs (indirect impact on other activities, costs of delay,
etc.) should be included, not just the direct financial outlays required. Indeed, cost
estimation should be about as conservative as risk estimation.
As we noted earlier, when time periods long compared with human lifetimes are in-
volved, it is necessary to distinguish between the risks to any one generation and the
total, time-integrated expectation of harm. A similar distinction is required when
discussing population exposures over very long time periods. If the ultimate time-
integrated values of these quantities are ascribed any significance at all, the ultimate
radiological benefit resulting from activities that eliminate uranium from the environ-
ment cannot be neglected.
Finally, our greatest concern has to do with the possibility that the EPA may be setting
the stage for a degree of restrictiveness that cannot be justified on any technical or
objective grounds. We find especially disturbing the repeated denigration of quanti-
tative risk estimates that appears in the Background Report from Page 1 to the final
summary, e.g., the assertion on Page 48 that, for long time periods (over 1,000 years),
risk predictions "for practical purposes...would not generally be dependable, informa-
tive, and therefore not very useful... ." Though the relative uncertainty in the risk may
indeed be large, such predictions would still be fully useful if the absolute uncertainty
is small, i.e., if they can show the risk to be less than some upper limit which is itself
very small. We believe detailed risk evaluation studies now in progress will prove this
to be the case; at the very least, the EPA should acknowledge the possibility.
Unfortunately, the EPA gives the- impression—perhaps unintentionally—of laying the
groundwork for discounting the results of the best technical estimates of risks and per-
mitting regulation, instead, to at least partially reflect the widespread fears that ra-
dioactive wastes represent some unprecedented threat to the environment requiring
uniquely different standards of control.
We are all too aware that such fears are indeed widespread today and that they have
built up a potent sociopolitical momentum. Powerful individuals and groups have com-
mitted themselves to the idea that the radioactive waste problem exceeds human capa-
bilities to find solutions; these interests would find it difficult or impossible to admit
error on the question without losing much of their prestige, political influence, and
sense of personal importance and worth. The EPA must, however, stand firm against
pressures from all such vested interests and base policies solely on the best technical
analyses available. To do otherwise would violate the trust bestowed upon the EPA by
80
-------
the lawof the land—a trust to protect the environment without unnecessary interference
in the activities essential to the very survival of our civilization.
APPENDIX A
RISKS IN THE DISTANT FUTURE: THE QUESTION OF "LEGACY"
In this Appendix, we elaborate on certain aspects of the comments offered with respect
to the Background Report, Pages 17-21, concerning the longevity of radioactive wastes
and the so-called "legacy" they constitute for future generations.
As noted in the main text of our comments, over 99.9 percent of the initial ingestion
hazard potential of the wastes decays with an effective half-life of 30 years or less.
This means that most of the hazard potential of wastes on hand in the future will have
been produced by the generations living then, not past generations,_if_ waste production
continues at current rates or increases. In this case, it is not very meaningful to speak
of the "legacy" of the present generation's wastes.
Only if future waste-producing activities decline at a rate greater than the decay rate
of the wastes might future generations find themselves with a hazard potential
"bequeathed" from past generations greater than what they themselves were producing.
Whether this is credible is difficult to say. Given the abrupt onset on universal
brotherhood and good will, production of defense wastes could terminate almost over-
night; unfortunately, there is little in human history or current events that suggests this
is about to occur. In any case, wastes from civilian energy generation now dominate the
total hazard potential of all wastes currently being produced, and this trend is expected
to continue in the foreseeable future. Historically, about sixty years has been required
to engineer major changes in energy use patterns (ERDA 1974). Thus, it seems likely
that the use of nuclear energy for civilian purposes will not decline more rapidly than
the decay rate of the wastes themselves, even assuming better energy sources are de-
veloped.
Future Exposure Probabilities
Roughly speaking, actual risk at any given future time, other things being equal, is
proportional to the product of the hazard potential of the waste at that time multiplied
by the probability of exposure to the waste (or any given fraction of it) at that time.
If the probability of exposure per unit time increases more rapidly than the hazard po-
tential decays, then the actual risks can increase with time. Thus, for current LWR
wastes, if the probability of ingesting them in the year 3000 A.D. will be 100,000 times
greater than the probablility of ingesting them in the year 2000 A.D., the risks in the
former year will be greater even though the hazard potential will have declined by a
factor of 10,000 or so.
Actually, we believe the likelihood of exposure at any given time in the future should
be less than the likelihood of exposure of the present generation. Radioactive materials
are presently produced, used, and stored in a variety of activities at the terrestrial
surface where they would be more or less accessible to the biosphere if released. What-
ever final disposal technique is selected, there is general agreement that it should be an
improvement over surface storage in tanks, fuel pools, and the like. Hence, a sharp re-
duction in exposure probability should accompany final disposition.
Behavior of the exposure probability per unit time in the distant future is more difficult
to predict and, in any case, depends upon the disposal method. For some exotic disposal
81
-------
methods that have been proposed (deep space disposal, nuclear transmutation) this
release probability is obviously zero for the distant future. Even for the more likely
method of burial in deep, stable geological formations this release probability may well
decline with time. To see this, we note that the intent of any such repository would
presumably be to isolate the wastes until essentially harmless if the repository functions
as designed; the risk is therefore that associated with unpredicated breaching of the
repository. Events potentially capable of causing such breaching can be divided into
various categories:
1. Natural events unrelated to the fact that waste burial has taken place.
2. Events involving a combination of natural events plus effects due to waste burial
(e.g., improperly sealed mine shafts).
3. Inadvertent future human penetration.
4. Deliberate future human penetration.
The first probability will not vary strongly as a function of time, and the second will
likely decrease (faults due to improper mine shaft backfill, say, are more likely to turn
up in the first century than in any one century in the remote future, e.g., during the
period 10,000 - 10,100 A.D.). The last two are more difficult to assess, but we argued
in the main text (comment on Page 40, bottom, of the Background Report) that //3
should be given at most a secondary consideration. As for //4, if the penetration is
"authorized," it is obviously for the authorities of that age to judge the risks.
Deliberate "unauthorized" or clandestine removal is again very difficult to evaluate,
especially in view of the difficulty of determining an adequate motive. If for terror-
ism—a common suggestion—the difficulty of clandestinely recovering deeply buried
wastes is so disproportionate with respect to what could be accomplished with them that
we can only hope that future terrorists will indeed dissipate their efforts on such
enterprises.
The preceding arguments are oversimplified in many ways; for example, they neglect
environmental behavior after release and neglect the fact that, for the more plausible
mechanisms such as water penetration, release itself would be an extremely slow pro-
cess. Detailed modeling of the relevant phenomena is necessary (results of such model-
ing to date tend to confirm the conclusion that future risks are very small). It is at
least plausible that the release probability per unit time will tend to decrease, not in-
crease. Certainly it is extremely unlikely that the probability of release per unit time
could increase sufficiently to compensate for the decay of the hazard potential. Hence,
we think there is virtually no likelihood that the risk to distant future generations could
be within orders of magnitude of being as large as that accepted by the generation pro-
ducing the waste, even though all technical estimates show even the latter risk to be
very small, as judged by normal societal risks.
Effect of Concentration
In the main text of our Comments, we gave some comparisons between the radiological
hazard potentials of man-made wastes and the radiological hazard potentials of natural
radionuclides, especially Ra-226, already in the ground. This type of comparison is
often attacked on the grounds that the wastes are relatively concentrated, while the
radium is very dilute. This fact, however, turns out to make surprisingly little differ-
ence for two reasons:
82
-------
1. Even if moving ground water does reach the wastes and eventually carries some to
where human exposure might occur, long-distance migration and long times would
be required because of the nature of the site chosen for disposal. By then, decay
and dilution would reduce the concentration drastically, and it would make little
difference whether the source were initially highly concentrated or not.
2. These comparisons are based upon hazard potentials estimated using the linear
dose-response hypothesis (LDRH), which is probably conservative (i.e., over-
estimates the risks). If LDRH is valid, total hazard potential is proportional to
total quantity and independent of concentration. A dilute source corresponds to a
proportionately lower risk to an individual exposed to it, but this risk is present
over a proportionately larger area and, hence, on the average a proportionately
larger population is exposed than for a concentrated source having the same total
activity. As a first approximation, these effects cancel out and the total number
of people one would expect to be harmed is the same. If this expected number is
extremely small, as work by Prof. B. L. Cohen of the University of Pittsburgh
suggests (less than 1 person over the next million years for all existing waste),
then one cares little whether it is "concentrated" or "dilute" (Cohen 1977).
Finally, if LDRH is not valid, the risk is even less, perhaps zero.
REFERENCES
BEIR 1977: "The Effects on Populations of Exposure to Low Levels of Ionizing
Radiation," Advisory Committee on the Biological Effects of Ionizing
Radiation, National Academy of Sciences - National Research Council
(1972).
Cohen 1977: Bernard L. Cohen, "High Level Radioactive Waste from Light Water
Reactors," Revs. Mod. Phys. 49, 1 (1977).
EPA 1977: B. W. Roper, paper entitled, "Public Acceptability of Risks from Radioac-
tive Waste," in the Proceedings of the Albuquerque EPA Workshop, April
12-14, 1977.
ERDA 1974: "A National Plan for Energy Research, Development, and Demonstration:
Creating Energy Choices for the Future," Vol. 1, U.S. Energy Research
and Development Administration, ERDA A-4S, June 2S. 1975.
NCRP 1975: NCRP Report No. 43, "Review of the Current Status of Radiation Pro-
tection Philosophy," National Council on Radiation Protection and Meas-
urements, Washington, D.C. (1975).
Williams 1977: David C. Williams, "The Net Advantages of Destroying Environmental
Radionuclides in Breeder Reactors," unpublished (summary available from
the author).
S3
-------
STATEMENT OF VIRGINIA S. ANDERSON, R.N.*
I am unable to attend, but suggest radioactive material waste deposits might be made in
the original proving grounds in New Mexico, where, I hear, there are holes as large as
or larger than the Empire State Building.
Furthermore, my opinion is that nuclear energy has proved to be not as efficient as
hoped, very expensive, and very dangerous.
There are [alternatives that are safer] and, in the long run, cheaper. If the amount of
money expended on the alternatives was as much as that spent on nuclear power and for
as long a period, we would by now have more advances and cheaper production of solar,
wind, or geothermal power.
It is frequently difficult for laymen to get the truth in these matters in our country-
let alone what can happen in less responsible governments who are gradually achieving
access to radioactive power.
Unfortunately wind and water carry poisons throughout the world. It all becomes a
worldwide problem very difficult if not impossible to control.
2926 Rogue R. Hy., Gold Hill, Oregon 97525
-------
STATEMENT OF EDWARD BALLEN
To establish a maximum permissible dose of radiation is at best gross negligence, at
worst premeditated murder. An industry that was born out of secrecy, that has been
bred by secrecy, and that is maintained with secrecy admits by the process of its actions
the dangers inherent in radiation. Recent studies by Dr. Thomas Mancuso, Dr. Thomas
Najarian, and Dr. Irwin Bross confirm the deleterious effects of [a] low level of
radiation. The government in its part has consistently conspired to block the presen-
tation of these reports.
Dr. Najarian in his study of Portsmouth shipyard employees exposed to radiation found
a cancer death rate of more than twice the national average. According to the Boston
Globe, the two month study showed cancer death rates for workers exposed to radiation
was 38.4 percent, compared [with] 21.7 percent for workers not exposed and 18 percent
for the general population. The leukemia death rate of exposed workers was 4 percent,
compared to 1 percent for the general population. Deaths from cancer of the lymph
glands were 125 percent higher than the national rate. More alarming, though, was the
nearly 60 percent death rate of exposed workers between the ages of 60 and 69. This
suggests the long germination period of cancer, and the concomitant attitude of benign
concern. According to the Boston Globe, which assisted Najarian with his study, the
Navy refused cooperation in the study.
While many of us are not shipyard workers or atomic plant workers, the sigh of relief
we breathe is upstaged by the work of Dr. Irwin Bross, director of biostatistics at
Roswell Park Memorial Cancer Institute in Buffalo, New York. During 9 years of study
on the effect of ordinary radiation, Bross found that infants whose parents had been
exposed to x rays had a higher rate of genetic damage, and that x rays nearly doubled
the rate of leukemia in men. Two months after he presented his report, his grant by
the National Cancer Institute was discontinued.
Dr. Thomas Mancuso studied the effect of low-level radiation under the authorization
of the AEC. Using population groups from Hanford and Oak Ridge, Dr. Mancuso con-
cluded, "Our findings are that levels of radiation in so-called "safe" areas definitely
cause cancer, specific types of cancer. And the findings show that levels much below
the safe standards are carcinogenic. This means that low levels of radiation, much
below what anyone had recognized before, [are] a common contributing cause toward
the development of cancers." [As in the cases of] Najarian and Bross, efforts were made
by the government to squelch his findings. The House Commerce Subcommittee on
Health and Environment has [looked] and is looking into Mancuso's study and the ordeals
that Mancuso has undergone.
I'm sure that this information (as well as much more) that I have presented is well known
by you. In the face of increasing scientifically based knowledge on the effects of low-
level radiation the only adequate risk assessment is zero release. Until Dr. Mancuso's
study on the long-term delayed effects of low level radiation, the biological and genetic
effects remained veiled. The fact that the nuclear industry has been and is producing
bombs, weapons, and power plants without public accountability and has imposed a
radioactive waste problem on future generations robs the nuclear industry of its
credibility. At the very least, a moratorium on the production of radioactive waste
needs to take place. I accept no standards of acceptable risks from radioactive waste
and I resent standards that are "benevolently" determined by others. Zero release and a
moratorium present viable alternatives to the present unflinching policy of destruction.
85
-------
STATEMENT OF JOHN W. BARBEE*
I would like to share my comments with you on the proposed environmental criteria for
nuclear waste disposal: I do not believe that economic feasibility should be a mitigator
for accepting environmental risk over either the short or long term. This would mean
that criteria 3 and 5 as worded are both unacceptable to me. I also feel that we must
recognize the cumulative effects of masses of relatively lower level radiation wastes
under item 2. We must look at both short and long term effects, even beyond 1,000
years. As far as acceptable minimum levels fo radioactive contamination is concerned,
I believe that the only acceptable level is NONE. Thank you for your attention.
*P.O. Box 179, Paonia, Colorado 81428
86
-------
STATEMENT OF L. BERNATH*
1. Ambiguity of Terms
The proposed criteria are too nebulous, too subject to interpretation, and insufficiently
quantitative. For example, "prevent any unnecessary contamination"—how many atoms
constitute any? None? What is "necessary contamination"? What is "reasonably
achievable"?
Since the "interaction" of wastes with mankind is unstated, how is one to define the
"hazardous lifetime" of the waste? If it remains sequested, is it hazardous? Ever? If
it is subject to release, how? How much? When? All need to be quantified to decide
whether such release could be hazardous.
Why is it "obvious that unplanned events...are more probable subsequent to lapse of
institutional care by virtue of eventual degradation of barriers which provide isolation
through natural...barriers"? Once a waste repository is backfilled and sealed, how are
natural barriers degraded? If properly sited, e.g., in an arid, seismically stable for-
mation, what events are expected to degrade the "natural barriers"?
How is "equity of risk transference" defined? Isn't this bureaucratic gobble-degook?
What is "a reasonable range of future population sizes and distributions and land, air,
water, and mineral resources"?
2. Definition of Radioactive Waste Materials
Material under subsection (b), i.e., natural-occurring, per this definition would have
to include flue gas and ash from coal-fired power plants. Is this intended?
3. Definition of Risk from Radioactive Waste Materials
The fundamental shortcoming of the EPAreport is the avoidance of attempts to quantify
the risks and to establish quantitative criteria to which NRC could apply licensing reg-
ulations and DOE could validate (or improve, if necessary) the underlying technology.
Specifically, EPA criteria should recognize the quantitative significance of variations in
natural background radiation doses.
For example, the background dose in Colorado is about 200 mrem/yr while that in Con-
necticut is about 70 mrem/yr. Since there is a factor of 3 difference and since the
cancer rate in Colorado is significantly lower than in Connecticut, it should be recog-
nized that there is no detectable risk to the increased dose in Colorado. Thus, EPA
criteria should be formulated to permit slight increases in dose to the population in areas
of technological implementation of radiation-related activities (industrial, medical,
etc.). Perhaps, increases in dose deemed allowable in regions of high background should
be less than those in regions of low background. Thus, a 10% increase (200 to 220 mrem
per year) would be reasonable in Colorado, while a 300% increase would be acceptable
in Connecticut.
87
-------
The benefits of establishing a quantitative basis for criteria clearly far outweigh the
detrimental effect on society of imposing too stringent a cut-off dose rate, such as only
allowing an increase of 10% above background.
*Manager - Nuclear, Sundesert Nuclear Plant, San Diego Gas & Electric Co., P.O. Box
2748, San Diego, California 92112.
88
-------
STATEMENT OF DAVID D. BILLINGS*
After reading [the Background Report] some major questions remain in. my mind. The
definition of radioactive waste is, I think, overcomplicated. Any product of mining or
processing of radioactive mineral which remains after the usable portion is removed
would be waste. If the waste is a hazard to health, then it should be stored in a place
where human exposure is, as nearly as practical, impossible for the toxic life of that
material. The order of priority would naturally dictate that high-level waste would be
isolated first and in the most secure location.
Strong procedures are complicated by lack of knowledge of the health hazards of the
waste; unfortunately much of the data on cancer and mutation from radiation exposure
has been presented by members of the reactor industry or the pro-reactor ERDA spokes-
men. We are told that no one has ever died from a nuclear reactor accident. Fragments
of information are reported occasionally, but usually in imprecise form. Such reports
have indicated increased thyroid cancer in natives exposed to radiation from the Bikini
tests. There have been reports of increased rate of cancer in the Grand Junction [Colo-
rado] area from mill tailings used as foundations for buildings. There are reports of
high cancer rate among uranium miners. There is conflicting information as to the con-
tamination of ground east of the Rocky Flats Plant, and data on health hazards from
this installation indicate higher cancer rate in its work force.
Based on what we have learned from the long range effects of radiation, the logical
procedure would be to cease all mining, milling, and use of radioactive materials until
data could be collected that would define precisely the danger from various uses of these
materials. Extrapolating from our present information would lead to the conclusion that
many people in good health will die prematurely from past exposure to radioactive ma-
terial.
Massive propaganda warnings that reactors are the only solution to our increased power
needs and stating that there has never been a reactor accident have convinced enough
of the public to prevent anti-reactor measures from passing. The threat of loss of jobs
is always used.
My direct experience with radioactive waste was a one year consulting contract on the
classification of atomic waste from the Hanford atomic bomb installation. This short
exposure was enough to inform me of the complexity of the disposal of this waste and
of the time required for completion of the waste disposal project. My contract has been
terminated because of lack of funds. At my last conference with the group working on
the glass project, morale was low because of the funding restrictions, blamed on
Carter's curtailment of the fast breeder program. The original program called for
starting of the glass project in 1985, with completion by early 2000. At the present
rate, this timetable seems unlikely.
In my opinion the glass or other methods could be worked out in a reasonable length of
time if funds were available to hire people knowledgeable in glass technology. Under
the present arrangement, people in the field are reluctant to become involved in a
project dominated by people with very limited knowledge of glass and by the red tape
of government contract work.
*Glass technology consultant. Address: 1958 Mt. Zion Dr., Golden, Colorado 80^-01
89
-------
Based on my experience as listed above, I would want a moratorium on any further re-
actor building. I am also skeptical of the need for further construction of nuclear
weapons. As we do not know the effects of radioactive waste over long periods of time,
we should put our present waste into the most chemically stable glass or similar material
that can be produced with existing technology. Storage in a geologically inert setting
or in an ocean trench appears the best solution with present knowledge.
Based on our handling of the tobacco industry, which is known to kill thousands of people
yearly, the outlook for controlling nuclear waste doesn't seem promising. Economic
advisers to the federal government are locked into the concept of the necessity for
economic growth regardless of the depletion of resources and the loss of health and
lives. This concept is popular with most business executives and is the "party line" for
the scientists they employ. Until there is a turnaround in this short term thinking, the
pressure for an increasing number of atomic energy installations and risky disposal of
atomic waste will persist.
90
-------
STATEMENT OF JACK BRIGGS
The entire thrust of EPA is a bitter disappointment to me and probably to a growing
number of Americans who are slowly learning of the true dangers of nuclear radiation.
Organized to protect us from environmental hazards, the EPA is now supporting the
nuclear establishment in accepting the idea that nuclear power is going to dominate our
economy or at least make a major "contribution" to it. This is still questionable. Rather
than give credence to the nuclear hazard, EPA should be fighting it tooth and nail to
adequately protect the people and environment. Particularly disappointing have been
the EPA meetings here and at Albuquerque. They both were predicated upon an ac-
ceptance of an untenable nuclear economy (the very antithesis of what EPA should stand
for):
The carefully prepared topics are so set up as to make it appear that the "public" par-
ticipants are also accepting nuclear energy. This is not necessarily the case. Some of us
will not accept the idea that nuclear power is necessary. Furthermore, there are
growing indications that nuclear reactor programs are failing. We should do all in our
power to stop the present nuclear polluting practices which are contaminating our once
fair and relatively clean land. We need to stop the radioactivity NOW before the
radiation buildup in the atmosphere reaches a point of "no return," so to speak.
The main thrust of this meeting should be to STOP nuclear power.
The secondary thrust should be to stringently regulate and safeguard America from the
present abomination of radioactive wastes, not to condone future collections and gen-
eration of contamination.
In solving the present waste problem we will be learning how to handle future waste (as
best we can), but we should not be anticipating (almost joyfully?) more of the nuclear
wastes.
Most specially we should not in any way give aid and comfort to the nuclear profiteers
by assuming that a nuclear economy is necessary or inevitable.
Yet this is precisely what this meeting seems to be doing, although EPA's mission should
be to stop any polluting devices.
It is to be hoped that the recommendations from this meeting will be to ensure much
more careful disposal, transportation, etc. of nuclear wastes than has been effected
in the past. The past record is indeed bad. Spills and radioactive releases seem to be
on the increase. The inspections, surveillance, and controls must be much tighter and
[more] effective—which seems to be EPA's goal.
As Dr. Thomas English (California Institute of Technology) has indicated, EPA's
suggestion of adopting a time limit of 1,000 years upon which to base health effect
estimates to future people is totally unacceptable, since this approach ignores the
potentially catastrophic health consequences to humans after 1,000 years (quoted by
permission of Dr. English). As I understand it, this position is not in accord with NEPA
goals as published, i.e., "to fulfill the responsibilities of each generation as trustee of
the environment for succeeding generations."
A criticism which is hopefully constructive is that the language used is in many cases too
"heavy," too bureaucratic and/or technical in terms used. It is difficult for me to
91
-------
understand without rereading carefully. I am sure that it is difficult for the average
"John Q. Citizen" to understand. I'm sure that the concepts etc. can be written more
simply and clearly with the result of better communication.
The integrity of reproductive germ cells [is] of course known to be threatened by nu-
clear-induced mutations.
There is a crucial subject to which the private sector of American science should address
itself on the issue of radiation damage to human reproduction.
It is a rather delicate subject one hesitates to mention in a mixed audience but one
which must be faced if procreation is to continue normally.
In short, what are the hard facts of radiation effects on penile turgidity?
What scientific research has been done in depth on the radiation effects of this
elemental but extremely important male condition upon which human reproduction
normally and enjoyably depends?
In other words, are we on the threshold of an era in which Homo sapiens is to depend
upon the technology of artificial insemination for his own continuation on this planet?
Independent American scientists are obligated to get at the root of this problem before
it is too late to prevent extinction of the human race.
In spite of many dedicated people in the Environmental Protection Agency, it is still the
tool of the Jimmy Carter Administration, which is dominated by James Schlesinger, an
unemotional radiation-monger devoted to the unwholesome doctrine of Gov. "Pixy" Dixy
Lee Ray. Miss Ray, to the detriment of womankind, is urging us to cover this planet
with deadly radioactivity (from breeder reactors), while she, spinster-like, overlooks
the good breeding necessary for human reproduction.
She even objects to President Carter's feeble and impotent gestures to slow down the
catastrophic breeder reactors.
With people in government forcing us to accept a diabolical nuclear fission economy
(while propagandizing us with our own tax money), it is clearly evident that independent
scientists in the private sector must investigate at once the sensitive but vital matter
of radiation effects upon penile turgidity. The urgency is such that this should be done
in a crash program beginning today.
92
-------
STATEMENT OF STEVEN H. BROWN*
As a participant in [the Forum] I would iike to take this opportunity to express some
observations and opinions which I hope might assist EPAin the development of guidelines
by which this critical problem might move toward resolution.
One of the most controversial issues that concerned many participants of the Forum was
risk assessment; i.e., what is an acceptable level of risk, and how should it be deter-
mined. In the text that follows, allow me to present my own personal views on these
matters.
I was particularly concerned and surprised with the lack of acceptance and/or knowledge
by many participants of existing risks associated with all forms of energy conversion for
electric power generation. Many participants expressed the viewthat there is something
special or unique with the very existence of risks associated with nuclear fuel cycle
activities and, in particular, radioactive waste disposal. Along these lines, many par-
ticipants expressed [that] associated risks as the result of these activities should be
literally zero, and effluent releases or the potential for same should also be zero. It
is my view that, in the context of man's present activities in the real world, this is an
absurdity. EPA, as well as sister Federal agencies (NRC, DOE, etc.), must mutually
pursue the resolution of what is an acceptable total risk or an acceptable "price to pay"
for present and future generations, in a generic sense as a baseline, regardless of the
specific type of energy conversions involved to produce a unit of electric power.
As would be expected and certainly justifiable, many participants were concerned about
toxic effects, particularly carcinogenic effects on present and future generations as-
sociated with even low levels of chronic exposure to ionizing radiation and radioactive
materials. Ignoring all other factors that would be incorporated in a risk assessment and
focusing only on "identifiable" toxic effects (in the context of present medical and epi-
demiological knowledge), i.e., potential health effects to individuals or populations,
allow me to discuss similar risks associated with non-nuclear processes for energy gen-
eration.
The obvious potentialities for health effects associated with the use of fossil fuels both
as the result of routine effluent releases of and/or human exposures to a variety of
"toxic materials" are well documented. We are all very familiar with the volumes of
federal and state regulations on effluent release limits as well as occupational exposure
limits. Carcinogenic effects to coal miners as the result of coal dust exposures
(pneumoconiosis), hydrocarbon and organic effluents released during combustion of fossil
fuels (CO, NOX, SOX, etc.), as well as the release of natural radioactive materials
during the burning of petroleum products, coal, natural gas, and even wood all have
associated risk functions inherent in them. Naturally occurring radioactive materials,
e.g., C-14, K-40, many uranium daughter products, etc., are released into the envi-
ronment by virtually everyone each day in the processes of heating and lighting our
homes, running our automobiles, burning wood in the fireplace, etc. (There fare] even
minimal amounts of natural radioactive materials in human excreta.) Radioactive ef-
fluent releases associated with these or similar day-to-day human acitivites can be
quantified.
* 4673 South Vivian Court, Morrison, Colorado 80465
93
-------
Assessment of the health risks associated with any fuel cycle should include both
occupational health and safety effects, chronic and acute, as well as environmental
impacts to populations as the result of effluent releases. Health risks of each fuel cycle
could be assessed in the context of these two parameters by subdividing into the fol-
lowing broad categories:
1. Mining or otherwise extracting the raw material from its natural environment.
2. Processing of the raw material into the ultimate fuel product.
3. Transportation of the raw product, intermediate products, and the final fuel
product.
4. Activities directly involved in the conversion of the fuel product to
commercially available energy.
5. If not directly associated with routine or non-routine effluents associated with
each of the above, assessment of risks inherent in waste generation and man-
agement of each fuel cycle stage must be separately considered if applicable.
It is my opinion that the Federal government, through the EPA, DOE, NRC, etc., must
define for the scientific community and the public at large what is an acceptable level
of risk associated with the generation of one unit of electrical power as a probability
function. In other words, what would be an acceptable percentage in any population,
present or future, of expected health effects as the result of energy production activ-
ities. This finite, quantifiable risk should be constant, or at a minimum, consistent for
any fuel cycle, nuclear, fossil fuel, or otherwise.
Once this "number" has been established, the scientific and technical community can
then proceed to evaluate how much of X can be extracted, how much of Y can be re-
leased, how much energy can be produced by a particular fuel cycle economy (all as
some function of time) that would result in this acceptable risk.
It is this author's opinion that until this "bottom line" can be quantified, rhetoric,
emotionality, and misinformation will continue as insurmountable obstacles impeding
the resolution of these most critical societal issues. Definition and implementation of
prudent, practical, and acceptable energy policies as they affect the present genera-
tion and those to come are paramount to the future of spaceship earth and its
inhabitants.
I extend my appreciation to the U.S. EPA for the opportunity to submit these remarks.
-------
STATEMENT* OF FERDINAND H. BURMEISTER"
I am a 44-year old Barton County, Kansas grain farmer who has resided on Barton
County farms my entire life except the time spent in college at Fort Mays Kansas State
College and at Kansas University and the time spent in the United States Army. I served
in the United States Army in Korea during the final months of the Korean conflict and
for a few months immediately thereafter, and after this service I completed the re-
quirements for a degree in agriculture from Fort Mays Kansas State College. I reside
near Galatia, Kansas with my wife and our three sons.
The construction and use of the proposed Wolf Creek nuclear plant, as well as any other
nuclear plant, is objectionable from health, environmental, economic, and moral
standpoints.
There are always health dangers in the areas of nuclear energy; if that were not so, why
are so many attempts made to safeguard the transportation and disposal of the nuclear
waste? Perhaps, then, a person may conclude that such safeguards would eliminate
inherent dangers; nevertheless, the-risks involved are too great. Unfortunately, all
people make mistakes; the most capable, conscientious, and ambitious persons some-
times will cause a blunder. Would anyone be willing to handle nuclear material if he
suddenly became aware that it had been placed into the wrong facility? And, even in
situations where the radioactive material is handled strictly according to plans, does
anyone wish to dwell or spend the greater part of his life near it? Surely nobody wants
the radiation-induced cancer and genetic defects that could develop from this radiation.
The detrimental effects on the environment by the use of nuclear power must not be
overlooked , both from the standpoint of the aesthetic value of the environment and the
practical use of the environment. Promoters of nuclear power plants often make the
misleading argument that such plants do not pollute the atomosphere as do conventional
coal-burning or oil-burning plants; the truth is that nuclear power plants do not create
the same kind of pollution that fossil-fuel plants create but they do intensify an existing
form of pollution—thermal—and in addition present a dangerous new form of pollution
—radioactive. Why, then, should we be willing to sacrifice scenic splendors such as
Pike's Peak and the Appalachian Mountains, to strip mountains for the tiny fraction of
concentrated energy which they contain?
The use of nuclear energy at first appeared to show promise of being economical and
abundant, but technology has not been sufficient to bring these conditions into exis-
tence. Experience now clearly shows that nuclear plants are at least twenty percent
costlier to construct than conventional plants of equal generating capacity. And it has
been estimated that after the operating life of a plant (expected to be only thirty
years), the initial entombment of one large plant would cost $900,000 and that an ad-
ditional $300,000 would be spent annually thereafter for maintenance through the years
and centuries. Do we want to place this financial burden upon our children and our
children's children?
*Originally presented at evidentiary hearings pertaining to proposed Wolf Creek Gener-
ating Station, Unit No. 1 (held at Coffey County Courthouse, Burlington, Kansas, 12
November 1975). Docket No. STN 50-482.
tRRl, Otis, Kansas 67565.
95
-------
The grave moral issue involved in the Wolf Creek power plant proposal consists of the
infringements on the personal rights and property rights of individuals and private es-
tablishments. The intent of the founding fathers of our Federal government and our
state government of Kansas was that people and private establishments have a right to
obtain, maintain, and retain their property as long as this right did not interfere with
the rights of other parties. However, that privilege has been abused time and time
again as land and other property has been yielded by its owners involuntarily for various
projects; this abuse has occurred so often that society tends more and more to become
unconcerned about the implications, particularly that segment of society which is not
adversely affected. Nevertheless, might does not necessarily make right, the wishes of
the majority are not neccessariiy best for any society, and the rights of the minority
must be protected. Additionally, the reduction in the amount of productive farm land
is always inadvisable and is particularly inadvisable now in a time of excessive demand
for food throughout the world. Sentiment has been pushed to the background in this
particular case as in so many other cases, particularly in recent years; unfortunately,
the prevailing attitude has tended to be, in reference to confiscated property, "If they
are paid for it, they have no right to complain." Such an idea overlooks the awareness
of things that money cannot buy. Should not a law-abiding citizen have a desire to
retain his farm or other property, even if only for sentimental reasons? How many
people are willing to exchange their wedding ring or other personal jewelry for compa-
rable items of equal market value or even greater market value? Economics also enters
into the matter of property condemnation. Whenever anyone must move his residence or
business to a new location, many financial losses and other difficulties occur which
often are overlooked by others. The financial compensation for the property may be less
than could be obtained elsewhere, and there are the expenses involved in moving and
relocating; often there is great difficulty in finding suitable property elsewhere, and in
many cases one chooses a new location which is only partially suitable.
In stating my position I have shown the negative aspects of the plant proposal; I now
briefly present positive alternatives.
We in the United States, Kansas, and the Burlington area are able to reduce the amount
of energy used in forms such as electricity; nevertheless, we can expect to use it con-
siderably in the future. Some alternative sources of energy are quite easily available
and are more economical than nuclear energy. Because of the actual high cost of nu-
clear power, certainly no definite proof has been made regarding its economic competi-
tiveness with fossil fuels. Coal is available in this country and therefore could be
used considerably as a source of energy in this area or elsewhere. The use of solar
energy (including wind energy) is showing great promises. One certain publicly held
company in Colorado manufactures and markets a complete solar space heating system,
and this heating system has been installed on numerous buildings since 1944. Such
a system is expected to have as long a life as the building itself, without any mainte-
nance costs. Such a system meets or exceeds the performance criteria — for solar
—developed by the National Bureau of Standards for the Department of Housing and
Urban Development under the Federal Solar Heating and Cooling Demonstration Act
of 1974. And wind power is highly desirable when absence of pollution is included
in efficiency ratings. For years many farmers depended on wind-driven mills to
pump their supply of water, and during the past many farms had small wind generators
which produced electricity. Opportunity for a much greater production of electricity
through the use of wind generators appears encouraging; if as much financial support
— public and/or private —would have been provided for research in solar energy as in
nuclear energy, it is entirely possible that by this time solar heating systems would
have been as prevalent as other heating systems and large wind generators would have
been as common as radio and television stations. Could not all of us benefit from the
96
-------
greater use of the sun and the wind for these purposes? Why can't we, why don't we,
make greater use of such resources as these, such resources which are available to all,
such resources on which no one in the area would have a monopoly or special advantage?
In closing, I wish to emphasize that I formed my above opinions on the basis of my back-
ground experience, studies, and observation; I studied the various sides of the issue with
an open mind; I have not been swayed by any emotions, by any glitter, by any promises.
I have kept in mind the needs of all people as consumers, and I remain aware that I too
am a consumer and that all of us consumers want and need energy. I have kept in mind
the environment; I want the various facets of our environment to be preserved as much
as possible. I strongly demand that no segment of our environment be completely elim-
inated or unnecessarily damaged; however, if necessary I am willing to accept some
sacrifices of the beauties of nature in order to provide a higher standard of living for
mankind. I have no vested interest in the Wolf Creek proposal; I have no agricultural
connections in the Burlington area, and I am not associated financially with production
of nuclear power plants or with production of solar energy systems. I have not wanted
any financial payment for taking any position on this issue; neither have I been offered
any such payment. As a concerned citizen, for this issue I have chosen to support firmly
and without reservation the most mutually beneficial position for the citizens of the
Wolf Creek area, the surrounding areas of Kansas, and beyond Kansas; I therefore stand
opposed to the installation and use of the proposed Wolf Creek nuclear power plant in
the Burlington, Kansas area.
97
-------
STATEMENT OF PAUL BURMEISTER*
I attended [the Forum], where I participated as a member of Working Group U, which
dealt with the question, "What are the characteristics of an adequate risk assessment
and of acceptable risks from radioactive wastes?."
With this writing I would like to make some comments concerning some of the contents
of the EPA Background Report, "Considerations of Environmental Protection Criteria
for Radioactive Waste" (February 1978), the "Issues for Discussion by the Working
Groups," and statements made at the Forum.
On page 12 of the Background Report, first paragraph, it is stated that the cost of
control technologies is an important consideration "in determining management of these
materials;" and Item 6 of the Working Group II agenda was "Risks due to radioactive
wastes should be unacceptable unless more complete isolation is unreasonable in view
of technical, economic, and social considerations." Since it is known that the billions
of curies of existing radioactive wastes and any prospective wastes must not under any
circumstances be released into the biosphere, in my view it is not appropriate to give
economic considerations high priority in determining whether or not more complete
isolation of radioactive wastes is unreasonable. Since the problem is so critical, the
long-term health of mankind and the biosphere being at stake, if necessary great eco-
nomic investments should be made to reduce the risks due to radioactive wastes.
On page 14 of the Background Report it is pointed out that prohibiting their production
is the only way to guarantee absolute protection from pollutants such as radioactive
materials, which are assumed to have no threshold for effects. I feel it is important for
EPA always to keep this fact in consideration.
Near the top of page 17 of the Background Report it is stated, "Any potential risks
should also be no greater than those acceptable to the producers, and preferably should
be less in view of the unavoidably greater uncertainties in risk determination for the
long term." I respond in saying that much should be done to make arrangements such
that the risks to future generations, from the nuclear fission technology by which
possibly only our generation will receive any benefit, will be much less than we impose
on our own generation. I certainly believe that we of our generation have no right to
force future generations to live under new, unnatural risks to which the public was not
exposed only thirty-five or forty years ago.
On page 18 of the Background Report, paragraph 2, it is stated, "...it still remains to
be decided how far into the future responsibility should extend." I believe an ethical
approach is one in which it is assumed that man and other living things will continue
having basically the same physiologic designs, habits, and traits for an indefinite num-
ber of hundreds of thousands of years into the future, as they have continued the past
thousands of years (according to my understanding, remains of human-type organisms
which seem to be one to three millions of years old have been uncovered in Africa); and
that responsibility should extend for as long as the radionuclides generated or uncovered
through man's activities are projected to be a serious biological hazard. I do not see
what right mankind has to use any approach less conservative, which applies a time-
frame shorter than this.
*RR 1, Box 168, Claflin, Kansas 67525
98
-------
At the Forum, one view was presented that future people either might or might not have
superior technology and medicine. In my view, if the future people would have superior
technology, it might turn out to be a technology in which they were not adapted for
dealing with this particular problem of producing, detecting, and handling radioactive
wastes which generally cannot be detected with the human senses alone. I believe the
criteria should be based on the assumption that the survival and health of future people
and other living things should not be made to depend upon the use of special equipment
harmful radioactive substances in the environment.
Concerning superior medicine, I ask how the superior medicine would be applied to the
various non-human forms of living things which keep the biosphere balanced for all.
Concerning the last paragraph of page 40 of the Background Report, I do not agree that,
"...consideration need not be devoted to designing against major disruptions of waste by
... nuclear war, ice ages, or comparable cataclysms." I believe it is important to design
against disruptions of radioactive waste by war, which disruptions, I believe, could be
extremely harmful even when compared to other forms of disruption by the war. An ice
age might cause an area to be unlivable for a time which could be short relative to the
hazardous life of the radioactive waste which could spread to other areas of the world
biosphere following its exposure.
Item 8 of the Working Group II agenda says for consideration, "Certain risks due to
radioactive waste should be considered unacceptable. These would be associated with
circumstances in which:
a. any exposure having a high probability of occurrence could result in more than a
chronic risk which could not be further reduced by reasonable controls."
It seems quite possible that a "chronic risk," itself, could turn out to be very unac-
ceptable.
b. "the levels of any chronic risks are not less than those for comparable high probability
circumstances acceptable to society, or"
I believe we should work to prevent adding any serious new, unnatural risks to the so-
matic and genetic health of man and the biosphere, even if it might appear that the
level of that risk is somewhat less than the level of some other risk.
c. "high-consequence events do not have a probability of occurrence less than that for
comparable high-consequence events accepted by society for similar productive
technologies."
In the near future, society could decide that the previously accepted risks of certain
high-consequence events are unacceptable. Also, I question the implication that there
is any productive technology which produces a product similar to radioactive wastes.
High-consequence events of radioactive waste storage or disposal would probably have
much longer lasting effects on the somatic and genetic health of man and other living
thing than would events of most other technologies, since the damaging effects of ra-
dioactive wastes, which when dispersed appear to be irretrievable, are determined by
the instability of the atoms themselves, which instability becomes reduced only by
"decay" over a preset length of time, as compared to nonradioactive waste products,
many of which are molecular in makeup and eventually "break down" in time, and which
generally require intake of larger amounts to be harmful to health.
99
-------
Concerning "passive methods of communicating to future people the potential hazards
which could result from an accidental or intention disturbance of radioactive wastes"
(page 53 of the Background Report), I question an assumption that future people would
be able to interpret the information as originally communicated.
In my opinion some of the views in the Background Report seem to be too anthropo-
centric; that is, there is a lack of discussion on the potential risks from radioactive
wastes to plant and animal life, including the accumulation of certain radionuclides in
some food chains. When comparing the effects of radioactivity from artificially pro-
duced wastes with natural background radioactivity, it seems to be very important to
consider the kinds of radionuclides involved. An important fact is that certain fission
products and actinides tend to be concentrated by the biosphere, concentration factors
of 10^-10^ being not unusual. Estimates of radionuclides' sequestration in the biosphere
should be made and applied for determining risks associated with radioactive wastes.
In the glossary on page 54 of the Background Report, in the definitions of "institutional
controls1' and "isolation, radioactive waste," is the phrase, "contact between the waste
and the human environment." I suggest that the goal of controls and isolation should be
to prevent contact between the waste and the "life environment" or "biosphere" and not
only the "human environment."
I have wondered whether, perhaps, the waste should be stored deep underground in
strong containers (if suitable containers can be made) in a retrievable condition and
position for some decades or longer while a great deal of research is done in finding
improved methods of disposal. For example, it may be possible that a safe, technically
and economically feasible way to dispose of the existing radioactive wastes extrater-
restrially, such as placement around the sun or into the sun, could be developed. Or
possibly methods of terrestrial disposal safer than those which have been tried up to this
time can be developed for the existing wastes.
I am appreciative of the work that the EPA is doing in developing environmental pro-
tection criteria for radioactive waste. In my opinion the EPA Background Report con-
tains many useful, important suggestions and conclusions (for example, on page 32, the
implication that, because of the long-term persistence of the potential hazards pre-
sented by radioactive wastes, "most of the people potentially at risk are not yet born;"
and on page 22, "...the goal for control of radioactive wastes should be to prevent its
introduction into the biosphere over its hazardous lifetime").
I thank you very much for your attention to these matters.
100
-------
STATEMENT OF DR. GEORGE I. J. DIXON*
[Comments (submitted to Wisconsin Public Service Commission and to EPA) on utilities'
Advance Plans]:
My statement deals with a significant economic and safety problem completely omitted
from the Advance Plans of the electric utilities. This problem can be expected to in-
crease considerably if more nuclear power plants are built. I believe it essential that the
Public Service Commission study the condition deeply, for it involves both the safety
and economic interest of Wisconsin citizens.
I refer to the storage of nuclear wastes in Wisconsin, although not to the deep geologic
storage of reprocessed wastes at some possible Wisconsin site proposed recently by the
U.S. Energy Research and Development Agency (ERDA) which aroused such immediate
and vehement objections from state legislators and officials and has led to a flurry of
resolutions against any such permanent "storage" plans. The Town of Rudolph led the
way in passing a resolution against the storage and transportation of such wastes in
Wisconsin. I refer to the real waste storage problem: what to do with highly radioactive
spent fuel from reactors is precisely a result of the growing uncertainty that either
reprocessing or any permanent waste disposal method will be developed or approved in
the foreseeable future.
[The Wisconsin Public Service Commission! has already recognized that spent-fuel
storage at the reactor sites constitutes an economic burden to Wisconsin rate-payers.
A rate increase granted WEPCO on Aug. 5, 1976 was necessitated in part by expansion
of the spent-fuel storage pool to accommodate radiated fuel rods since no reprocessing
plant is ready to handle them. Commissioner Matthew Holden objected to the increase,
stating that he believed it was "a violation of the cost-of-service principle to assign the
extra costs of nuclear fuel storage to the rate-payers...50 percent of the total electric
increase granted here is attributable to added costs storing spent or used nuclear fuel,
and these costs had not been anticipated or brought before the Commission at any
previous proceedings. These are, if one may say so, surprise costs." (State of Wisconsin
Office of Emergency Energy Assistance, 3rd Quarter Report, Oct. 1, 1976). These
costs are still not being "anticipated or brought before the Commission" in the Advance
Plans under discussion.
However, there can be no question now that the utilities MUST anticipate a multipli-
cation of these costs which are passed on to the consumer. The plans were clearly
stated by Victor Gilinsky, Commissioner of the U.S. Nuclear Regulatory Commission
(NRC) in testimony before the California Energy Resources Conservation and Develop-
ment Commission Informational Hearing on Nuclear Fuel Reprocessing and Waste Dis-
posal at Sacramento, Jan. 31, 1977 (U.S. Nuclear Regulatory Commission News
Releases, Vol. 3, No. 4, Week Ending Feb. 2, 1977).
Future rate increases to further expand pools at existing or planned reactors in
Wisconsin are a certainty. Already the pools at Genoa and Point Beach have been ap-
proximately doubled. And although the pool at the Kewaunee plant presently contains
the used fuel rods from only one refueling, the NRC has asked the utility to plan to
expand storage capacity. Gilinsky states pools are designed "...large enough to store the
spent fuel output for about five years of operation." The reason for this premature
* Research Assistant, Land Educational Association Foundation (LEAF)
101
-------
expansion at Kewaunee may be explained by a possibility stated by Mr. Gilinsky that "a
considerable amount of shipment from sites with overflow to sites with excess capacity"
may be necessary. Will the planned expansion of the Kewaunee spent fuel pool be used
to store nuclear wastes from other plants in, or out of the state?
Mr. Gilinsky's conclusion is that by 1985 pools at reactors will be expanded to capacity.
What then? He states: "A question that ought to be on everyone's mind by now is what
will happen if neither reprocessing nor a repository materializes by 1985? The answer
must be continued interim storage in pools" (my underscore). Where? ERDA gave the
answer in May, 1976: "Independent pools, not associated with any other nuclear fa-
cility, have been proposed to alleviate the lack of storage space for fuel presently being
discharged from operating nuclear power stations, but for which storage capacity is
rapidly diminishing" (ERDA, 76-43, Vol. 1, p. 2.28). Will continued production of nu-
clear wastes from Wisconsin reactors necessitate such "independent pools" at other
Wisconsin sites which rate-payers will finance?
How long will nuclear wastes be stored at spent-fuel pools? No one knows for sure.
Commissioner Gilinsky admits 20 years or more, A utility representative commented
informally a few weeks ago that he wasn't worried about the nuclear waste because it
can be stored at the plant for 200 years. However, Mr. Gilinsky admits there is no ex-
perience with storing spent fuel in pools for more than 10 years--"relative paucity of
published information" will necessitate "further study" to determine "that it is safe to
let spent fuel assemblies sit in pools, perhaps for as long as 20 or more years."
The problem of safety arises from increased radiation to the atmosphere from pools as
well as the hazard of accident. The NRC Regulatory Guide (4.2, Rev. 2—Preparation of
Environmental Reports for Nuclear Power Stations, 3uly 1976) lists the fuel pool water
as a source of "releases of radioactive materials in gaseous effluents due to evaporation"
and requires utilities to assess the potential radiation dose to the public from several
possible "spent-fuel handling accidents."
A recent ERDA study (ERDA 76-43 - Alternatives for Managing Wastes from Reactors
and Post-Fission Operations in the LWR Fuel Cycle, May 1976) explains that "Pools will
be a source of both wet and dry solid wastes that will require shipping, storage and as-
sociated management operations" (p. 2.28). In fact, since "short-lived isotopes have
decayed before fuel is introduced to the pool (at a reprocessing center), the chance of
radioactive contamination is less than at the reactor pools" (p. 2.39). This "fresh" ra-
dioactive waste in spent fuel assemblies "will have a beta-gamma radiation dose rate
at discharge of more than 10,000,000 Roentgen/hour (R/hr) at the most radioactive
surface" (p. 2.34). In fact, "about 200 times the amount of uranium and plutonium
normally expected in the high-level waste (from recycling) would be discarded with the
spent fuel assemblies" (p. 1.2).
In our neighboring state of Minnesota, citizens are much more aware of the hazards of
continual storage of wastes in fuel pools. The Minnesota Pollution Control Agency and
Northern Thunder (Eau Claire, Wisconsin) have petitioned to intervene at NRC hearings
on the proposal that the Prairie Island reactor be allowed to store 3/2 times as many
spent fuel assemblies in the storage pool as the pool was originally designed to
accommodate. The spent fuel would be crowded so close that it would be within a 5
percent margin of a condition of criticality—setting off a chain reaction and a resultant
runaway reactor. Minnesota citizens point out that "irradiated fuel storage pools at
Monticello contain an estimated 33,800,000 Curies. Having de facto high-level radio-
activity storage areas at these two Mississippi River sites near the Twin Cities raises a
number of questions relating to public health and safety. Of the 484 fuel bundles in the
102
-------
Monti cello pool, "...237 are known to contain leaking fuel rods. How radioactive is the
water that cools these highly contaminated leaking fuel rods? What levels of radioac-
tivity enter the atmosphere from such spent fuel storage pools? Are any of these pools
leaking to the ground water whose direction is to the Mississippi River? Is this a threat
to the integrity of the water supply of the Twin Cities?" (from statement to Minnesota
Control Agency from representatives of Northern Environmental Council, Friends of
the Earth, Clear Air Clear Water Unlimited, and Minnesota Environmental Control
Citizens Association, October 26, 1976).
Wisconsin citizens should be aware of these hazards which are directly upwind on the
Mississippi River. Because of the problems with fuel cladding defects at Point Beach,
many of the fuel rods, which rate-payers are paying to store there, are leaking into the
cooling water and the atmosphere.
State officials have responded with anger to the Federal proposals to store nuclear
wastes in geologic sites in the state. But no state official has intervened in the
expansion of waste storage AT PRESENT REACTORS in the state, nor have they asked
the utilities to make clear their plans for the capacity and the radiation dose from
future nuclear plants. NRC Commissioner Gilinsky states that the NRC may be
"entitled to require augmentation by the industry of spent-fuel storage capacity." How-
ever, he does suggest that all states might not accede to such requirements: "Will the
states, in exercising their own responsibilities, be content to leave the matter in the
hands of the power companies?" I hope not.
I believe it is within the province of the Public Service Commission to require the
utilities to outline now the economics and safety of predictable continued augmentation
of waste storage in spent-fuel pools.
Bibliography
Victor Gilinsky, testimony before the California Energy Resources Conservation and
Development Commission Informational Hearing on Nuclear Fuel Reprocessing and
Waste Disposal, Sacramento, Calif., January 31, 1977, in U.S. Nuclear Regulatory
Commission News Releases, Vol. 3, No. 4, week ending February 2, 1977.
U.S. Energy Research and Development Administration, Alternatives for Managing
Wastes from Reactors and Post-Fission Operations in the LWR Fuel Cycle (ERDA-76-
43), May 1976.
U.S. Nuclear Regulatory Commission, Regulatory Guide 4.2, Rev. 2, Preparation of
Environmental Reports for Nuclear Power Stations, July 1976.
Northern Environmental Council, Friends of the Earth, Clear Air Clear Water, and
Minnesota Environmental Control Citizens Association, Letter to Minnesota Control
Agency, October 26, 1976.
Wisconsin Office of Emergency Energy Assistance 3rd Quarter Report, October 1, 1976.
103
-------
STATEMENT OF THE DOW CHEMICAL COMPANY*
Please let the record show that The Dow Chemical Company wishes to comment on the
establishment of criteria for radioactive waste.
To set protection criteria for radioactive waste it is necessary to define "radioactive":
precedence has been set by the Department of Transportation as defined by Title 49,
Code of Federal Regulations, Part 173.389, Radioactive Materials, definitions, (5),
(e), and would appear appropriate. The regulation reads as follows:
(e) "Radioactive material" means any material, or combination of materials, which
spontaneously emits ionizing radiation. Materials in which the estimated specific
activity is not greater than 0.002 microcuries per gram of material, and in which
the radioactivity is essentially uniformly distributed, are not considered to be
radioactive materials.
In Nuclear Regulatory Commission licensed facilities the licensee should determine what
is or is not waste. This determination need not be reviewed by a regulatory agency other
than during the periodic license auditing process.
Technologically enhanced radioactive materials which reach the definition of
"radioactive material" should be treated as such by the producer of the material.
Before disposal (meaning no recovery) be done we suggest that "radioactive wastes" be
segregated into categories based on specific activity, half-life of radionuclides, and
toxicity of radionuclides. Disposal is probably necessary for some radioactive wastes
but must be done with care. All "radioactive waste" need not and should not be treated
the same. Spent fuel rods are so valuable, future generations will probably want to
retrieve unprocessed fuel rods as an example.
In choosing where to begin, control of individual doses should be a key to risk assess-
ment. Controlling population doses by controlling individual doses to a risk level which
is comparable to background risk levels is a basis for establishing a reasonable radio-
active waste policy.
Pre-existing criteria for the population regarding radioacitve material now exist. These
are adequate in that they are well below background levels in most instances; see Title
10, Code of Federal Regulations, part 20, Appendix B, Table 2. There is no evidence
to show that these limits have any detrimental effect on man and his environment.
Zero risk and complete safety are impossible to achieve in society. There should be
consistent risk criteria applied to radioactive material and non-radioactive material
based on scientific data not prejudices of a few uninformed.
^Received from R. R. Langner, Director, and D. L. Barsten, Health Physicist, U.S.
Area Industrial Hygiene, Dow Chemical Company.
-------
STATEMENT OF THERESA ERICKSON, PAUL FRANK, 3OAN SCHAUM, PETER
ALPERT, JEFF TRACY, AND C. B. PEARSON
We would like to be recorded as supporting the Fourth Report [pp. 139-1*2, this volume]
submitted by those opposed to the continued manufacturing of radioactive wastes. This
continued manufacturing of radioactive wastes in lethal doses seems to be leading us
on a course of self-destruction without adequate knowledge of nuclear waste disposal.
We feel that EPA is rushing headlong into setting criteria without considering the con-
sequences. The hypocrisy of the present scientific data on radioactive wastes leads one
to doubt the present risk that we are subjected to even though some call it necessary
(i.e., Sen. Paul Rogers' efforts). The establishment of criteria does not insure safe and
persistent disposal. The present day American attitude of out of sight out of mind, we
fear, will tend to carry over into the disposal of radioactive wastes. Can EPA permit
this to happen?
To say that this information that we so diligently worked on is going to be used in the
final preparation of disposal of radioactive waste is for us to believe that the maze of
bureacratic agencies will not reflect their own bias and that of the industry. For
example, the present situation with the NRC is like letting the fox watch the chickens,
like making a turnkey put his own son in jail.
We feel that the EPA is responsible for the induction of many more public hearings for
the public to participate in this most important decision. EPA should also be responsible
for "cluing the public in" on the process under which these decisions are maintained,
implemented, regulated, and enforced. What impact does public opinion truly have?
The bare truth is that the three national meetings held on the management of nuclear
waste disposal is hardly a conclusive feeling of the public pulse. We urge the EPA to
expand the scope of their hearings to include the PUBLIC. This means holding meetings
at times and in places that are comfortable and accessible to the common public. As
Einstein said, "Nuclear power and all it implies should be debated from every public
square before the uses for nuclear power are decided upon."
105
-------
STATEMENT OF FREDERICK FORSCHER*
This letter points out two aspects of nuclear waste that have not been brought out during
any of the workshop sessions, but which must be seriously considered in the formulation
of criteria and standards. These new aspects are: military considerations, and the po-
tential benefits of nuclear waste (as an energy source). I am an independent energy
consultant, strongly pro-environment but not anti-nuclear, who has attended all three
EPA Forums (Reston, Virginia; Albuquerque, New Mexico; and Denver, Colorado) and
the preceding EPA/ERDA/NSF/etc. meeting in Chicago. The comments are arranged
and discussed under the Topics as presented at the Denver meeting.
Topic 1: What is Radioactive Waste?
Comment: The rubble, debris, etc, resulting from a nuclear explosion must be included
in the contemplated definition of radioactive waste to be covered by disposal criteria.
Discussion. True, the generic definition covers this type of waste. However, I feel
strongly that bomb waste should be specifically called out, as are waste reprocessing,
mine tailings, medical waste, etc. By including this waste into consideration of criteria
development and waste management, one puts a completely new perspective on the
probability of generating nuclear waste, on the volume of waste to be disposed, and on
the location where it may be found.
Topic 2; What are the Characteristics of an Adequate Risk Assessment?
Comment: In view of the real, and possibly imminent, risk of severe damage by nuclear
bombs (nuclear explosive devices), it makes absolutely no sense to estimate the health
effects of waste disposal schemes for 1,000 years or longer. If we have to use a time
limitation I would suggest 50 years.
Discussion. I remember the German enthusiam to design the Third Reich for 1,000
years. Our anti-nuclear groups show the same enthusiasm to rid the world of nuclear
menace. But hopes or fears are poor guideposts toward rational criteria. Introducing
military considerations puts a new perspective on the subject of risk assessment.
True, everybody is against war, particularly nuclear war. But, closing down Rocky
Flats will not stop the Russians. Anti-nuclear and anti-war groups must address the
question of what constitutes an "adequate national defense." This is a constitutional
responsibility of the Federal government. Wishing away all nuclear explosives does not
substitute for real and present Federal responsibility.
It is disappointing to hear Congressional testimony by David Hawkins, Assistant
Administrator for Air and Waste Management, EPA (March 22, 1978) to the effect that
"risk estimates are to be the primary determinates for decision; these should be per-
formed for human individuals and populations for at least one thousand years on an ab-
solute basis... ."
^Energy management consultant. Address: 6580 Beacon Street, Pittsburgh, Pennsyl-
vania 15217
106
-------
Topic 2; What are Acceptable Risks from Radioactive Waste?
Comment; Acceptability implies that the perceived benefits outweigh the perceived
risks. Hence, there is no way to discuss acceptability without entering the debate of
real or perceived "benefits" of nuclear waste.
Discussion. It is heresy today to claim that high-level waste, per se, has benefits to us
and future generations. Yet, there is no doubt that nuclear waste represents a unique
source of energy. In an energy-short world, no source of energy should be considered
useless or a waste. I would like to consider it as "boxed sunshine." If we ever are faced
by an epidemic of bacterial origin (e.g., Legionnaire's disease) nuclear waste will be
godsent for water purification and sewage sterilization.
The benefits of the reactor-generated plutoniumfor present and future power generation
have been discussed. Safeguards must be provided to prevent this valuable material
[from being] used for malevolent use. Safeguards can be considered to represent a new
protective institution of society of the same dimension as law enforcement, or fire
protection. Many capable organizations are now developing this new institution, both
on a national and international scale. The idea is to establish a viable fire protection
instead of searching for ways to eliminate flammable materials.
107
-------
STATEMENT OF NINA HERSH*
[I participated in the Forum], although because no child care had be arranged for par-
ticipants [I] was able to attend only one day and one night session. I wish now to put in
writing my emphatic views that large segments of the public, particularly those who
are really aware of the issues, are not willing to accept the risks posed by continued
production of radioactive wastes. Of course I realize that the existing ones will have
to be disposed of in some way; there no expense should be spared as it is not only
ourselves but future generations we are endangering. But for God's sake let's quit
making the stuff unless and until we have much more extensive genetic information and
evidence on its effects, and unless and until we find a truly safe way to dispose of it.
The expression "isolating the wastes from the biosphere" was bandied about at the
conference. That's what we have, that's what they gave us to live on and work with;
that's what the materials and people are from and part of, and it is difficult for me to
comprehend how it can be isolated from it. (I don't consider shooting the stuff in rockets
toward the sun a reasonable alternative, if that's what people have in mind as getting
the wastes away from the bioshpere.) I have been doing some rather serious study of the
nuclear issue for the last few months, and am horrified at the arrogant and callous
attitude displayed by the industry representatives at [the Forum] in light of what is now
known. Not to mention that it seems that every increment in knowledge we have about
the effects of radiation on people and their enviroment seems to show that the potential
for damage is worse than ever contemplated.
I consider the past actions of this government irresponsible, to say the least, when we
continued to produce these hazardous substances without real understanding of what
harm they might do and no clear ideas about how to get rid of the wastes. To continue
their production with the clearer understandings we now have of the dangers is totally
reprehensible. If there are any future generations I expect they will judge us in the
harshest terms.
It is my understanding that the Enviromental Protection Agency is charged by Congress
with the task of protecting the enviroment. Therefore I cannot comprehend why, in
light of the clear and known dangers that result from the production of radioactive ma-
terials, the EPA itself has not taken a firm stand against their continued production.
Truly, I believe if a massive education program were undertaken in this country (How
about by EPA?) as was done in Sweden, ther would be such a massive outcry on the
subject that nuclear facilities would come to a screeching halt.
Yours for a healthy and safe world, with a tiny bit of hope that the right people may
listen.
Juniper Avenue, Boulder, Colorado
108
-------
STATEMENT OF MARY HEY*
Because I have a small child, I was unable to attend [the Forum]. So I thought I perhaps
might write a few words for consideration and say to you what I would have said had I
been there.
Living so close to the Rocky Flats Nuclear Weapons Facility, the danger of nuclear by-
products is in my mind a great deal. When I take a walk I wonder about the air and
which day it will be that an accident at Rocky Flats will belch particulate plutonium in
it. When I see my daughter carefully inspect a clod of dirt and pop it into her mouth
(one-year-olds have very catholic tastes), I wonder about the "acceptable" levels of
plutonium in our soil, levels that become more conservative as the years go by. And
I wonder about that single particle of radioactive dust that is known to cause cancer and
if and when it will find its way into the miraculous little body that I spend my days
caring for, unseen.
I have worked in enough places (government, private enterprise) to notice how decisions
are made, how the appearance of full control, of complete understanding becomes far
more important than the reality. I have also seen people make mistakes that they have
sworn were impossible, myself included. Given the nature of radioactive waste and its
longevity, the pretense of control is madness. Yet the stuff exists, and we must deal
with it.
The least we can do for ourselves and our children, and the children beyond, is to ask
for the tightest controls possible. Or even more heroic, to demand standards that are
impossible to meet in order to squeeze tight the valve of poison that our arrogance has
allowed to open. Please have the courage to stand up to the powerful, short-sighted
interests that seek only to protect their investments and establish criteria on the basis
of human life and its future only.
* 1531 17th Street, Boulder, Colorado 80302
109
-------
STATEMENT OF MARY HUBBARD*
I attended [the Forum] and I learned so much that I wanted to let you know how I feel
about the nuclear industry.
That radiation in any dosage is dangerous is well documented. Living in Denver I feel
a threat from Rock Flats to the millions of people who live here. They have had over
200 plutonium-related fires in RFP, releasing much of the dangerous substance into
environment. I think it's unconstitutional and inhumane to expose anyone to radiation
without their knowledge and consent. I don't think most people would want to accept
the risk if give the choice. I'd like to see the nuclear industry admit its errors of the
past, close down, and spend all that money instead on cleaning up the mess and devel-
oping alternate safe power sources. Solar technology could safely light us up for 7
billion years. On the other hand nuclear technology poses such a dangerous threat to
all life force on the planet. I pray daily that we can come to a global disarmament
which would take us a step closer to true Peace on Earth.
I think the conference was not well publicized for the importance of the subject. For
people to make clear decisions on the nuclear issue they must have access to much more
in formation (that is factual evidence to support both points of view). I think the media
up until now has been and is heavily pro-industry slanted. Fd like to see more real sci-
entific data about effects of radiation on life [and more] radiation emission checks and
from that make moral decisions about how to protect all life.
We have a man living with us who worked in uranium mines for eight years with abso-
lutely no protection aganinst the heavy exposure he had daily. At one time he took some
of the hot rock home and had it on his bedside table. He had to shift to the coal mines
when he got sick with emphysema. He now has multiple sclerosis fifteen years later.
He has very little control over his body so he is bed and wheelchair bound. We are only
beginning to understand why he is so sick. We love him a lot and pray for miracles with
him.
I know your job is not particularly easy. It's hard to be objective about a subject which
is so controversial. I know you can all be strong and make decisions on the basis of
moral principles that will hold true for our children's children and on.
*2046 Emerson, Denver, Colorado 80205
110
-------
STATEMENT OF 3UDITH HURLEY*
The greening of earth in spring. Water flowing. My cat's ear tufts and three (only three)
eyebrow hairs. The fragrance of hyacinths when you get down close to the ground. My
very young friend Emily whose only word is "Hi" (she says "hi" to concrete walls and to
peanuts as well as to me).
There is nothing abstract about what I love and seek to protect. That there should be
anything—at all—is so dazzlingly unlikely that I have spent half my life simply
marvelling at being. And that on this round rock there should be life—there should be
me, there should be Emily, to say "Hi" and to smell the hyacinths is what you must keep
before your minds' eyes all the time.
345 South 39th Street, Boulder, Colorado 80303
111
-------
STATEMENT OF ROGER E. KASPERSON, ROBERT W. KATES, AND BONNIE BRAINE
General
As the [Background Report] indicates, there exists a substantial divergence between
"expert" and "public" opinion in risk acceptability for the nuclear fuel cycle. Continuing
public reaction to the transport and storage of nuclear wastes, experimental psychologi-
cal research (Fischhoff, 1976), and a series of analyses of public attitudes (Maynard et
al., 1976; Brooks, 1976) suggest that the risk of nuclear energy have attributes particu-
larly feared by the public, such as their catastrophic potential and the fact that radia-
tion is invisible and results in a dreaded disease (cancer). Radioactive waste manage-
ment may well prove to be the most sensitive of all the "nuclear" issues in terms of
public acceptability: existing wastes provide no direct benefits to future generations,
and few perceived benefits to the present population. Futhermore, nuclear power has
become, for many, a symbol of the negative aspects of centralized, government-
sponsored technology, and of decision making processes with little allowance for public
decision. It is clear that extraordinary public consultation and participation will be
required to create a waste management policy acceptable both to the nation and the
affected localities.
Specific Comments on the Proposed Criteria
1. An adequate risk assessment should consider not only health effects, but also the
social-psychological impacts of waste management activities. Fear is a very real
cost in radioactive waste management, and will affect public acceptance of gov-
ernment programs. The criteria eventually adopted by the Environmental Protec-
tion Agency should acknowledge the perceived as well as the simulated (statistical)
risks associated with radioactive wastes. Although perceived risk factors cannot
easily be factored into risk criteria, what is already known about public perception
of nuclear risk argues for a different position than that taken by the Background
Report, Risk criteria for nuclear waste management, to be acceptable to the
public, will likely require greater stringency than those in other technological
areas.
2. The Background Report does well in seeking to limit the use of institutional controls.
To be publicly acceptable, reliance on institutional controls should be minimized
whenever possible, and primary reliance instead placed on engineered and natural
barriers to protect the public. The period employed for institutional controls should
not exceed 100 years and should probably be less.
3, The use of 1,000 years as an outer limit for the performance of detailed risk as-
sessments will imply that sufficient attention has not been directed to specific
waste categories and storage options. Widespread public concern is focused on
long-lived isotopes. Risk estimates should be projected for the length of time ne-
cessary to determine the most effective disposal technique for the particular type
of waste under consideration. In the case of uranium mill tailings, for example,
adverse effects should be calculated for the lifetime of the exposure hazard, which
is defined in the Background Report as the half-life of thorium-230, or 80,000
years. The inability to perform detailed risk assessments of human health effects
beyond a certain time should not be a limiting factor in extending the analysis.
4. As a general principle, risks within a given population (present or future) should not
be distributed inequitably unless this is done in relation to concentrated benefits.
112
-------
Concentration of potential hazards will occur, however, due to the location
of storage areas, tranportation corridors, and long-term repositories. Therefore,
standards should be developed that ar,e as stringent as possible to minimize
exposure risks in site- and corridor-specific areas. Regions with high background
radiation levels and/or pre-existing radiation hazards (such as sites or structures
previously contaminated with uranium mill tailings) should not be selected for
storage of radioactive wastes. And site locations should be chosen with a view
to minimize transport corridor exposure.
5. Risks to future populations should be less than those to the present, because future
generations are unlikely to derive any benefits from existing wastes, and have no
voice in the selection of disposal sites, technology, and the setting of environ-
mental radiological standards. Also, it is entirely possible that future generations
will be more exacting on risk acceptability; in fact, recent experience in the U.S.
with technological hazards suggests that this is likely. The recommended criteria
should be for diminished risk to future generations.
Comments on Procedures
The EPA should be commended for its continuing efforts to open their decision-making
process to the general public. We urge the EPA, and all other Federal agencies with
responsibility for nuclear waste management, to continue to expand this program of
sharing of general, and specific, policy issues with the public. Regulatory criteria for
the different aspects of the waste management process need to be brought together in
a common public process regardless of administrative responsibility. Thus there should
be ah integrating process that allows for collective discussion on criteria to protect
workers, publics, and the environment for waste definition, processing, transport, and
storage.
Notes
Brooks, Harvey, "The Public Concern in Radioactive Waste Management"
(mimeographed, 1976).
Fischhoff, Baruch, et al., "How safe is Safe Enough? A Psychometric Study of Atti-
tudes Toward Technological Risks and Benefits" (mimeographed, 1976).
Maynard, William S., et al., Public Values Associated with Nuclear Waste Disposal
(Seattle: Battelle Memorial Institute, Human Affairs Research Center, 1976).
U.S. Environmental Protection Agency, Office of Radiation Programs, Considerations
of Environmental Protection Criteria for Radioactive Waste (Washington, 1978).
113
-------
STATEMENT OF CYNTHIA LEPTHIEN
[Comment on proceeding on the assumption of infinite disposal space]:
Future radioactive wastes may be more hazardous as you approach the limits of space
and absorbablity of the biosphere. I would like to see the EPA (or whoever) do a study
with an eye to possibly estimating the amount of space available for waste, whether we
can overload the biosphere, and at what point the limits will be reached. The future
nuclear wastes should be considered separately, at least to the extent that they may
bring us to that limit.
-------
STATEMENT OF NORMA B. LINSKY
I was unable to attend [the Forum]. I have, however, read the report [pp. 139-142, this
volume] submitted in opposition to the continued manufacture of radioactive wastes. I
wish to go on record in support of this report and add some comments of my own.
In the past eight years I have worked in research laboratories in the biological sciences;
in physiology, biochemistry, and molecular biology. These laboratories were licensed
to use radioactive isotopes.
Without exception in each laboratory I have seen criminal disregard for the potential
danger of contamination. Most labs have too few containers for the disposal of glass
vials and used pipets and test tubes. Those charged with the disposal are often
uninformed as to what shield must be used with which isotope, and how to contend with
spills.
In one lab, I witnessed a principal investigator dumping liquid waste down a drain and
explaining that with enough water poured down with it, a sufficient dilution factor
would eliminate any further contamination.
A postdoctoral fellow broke a bottle of liquid waste and, as it spread, exclaimed he was
too busy to clean it up at the moment but would be back.
And what about the undergraduate who comes in to wash dishes and treats all those
unlabelled vessels the same.
These horror stories were perpetrated and condoned by trained professionals. The
thought of the continued production of radioactive wastes by an entire industry without
adequate caution and knowledge of disposal is fearsome.
I only wish that you consider carefully before you condone potential abuse and harm.
115
-------
STATEMENT OF CYNTHIA AND IRVING LORD*
We cannot attend the workshop in Denver, but wish to add our testimony. We have
heard Dr. Teller assure us that we will develop the technology to contain or reuse nu-
clear wastes safely when that technology is needed. We have heard other renowned
scientists state that this is far from the case.
It is our opinion that the burden of proof of safety lies with the industry. Steel con-
tainers rust. The near meltdown at Brown's Ferry demonstrates our fallibility.
Safe disposal of wastes is obviously going to be hideously expensive, if it is even
possible, and we are not yet convinced it is possible. We recommend that security
provisions at existing plants be made more stringent. We recommend no further permits
for nuclear installations be granted until scientists are agreed that the plants are safe
and that the waste materials are safely stored, and until economists can assure us that
all this is worth the money it costs.
*710 North Mountain Avenue, Ashland, Oregon 97520
116
-------
STATEMENT OF MR. & MRS. WILLIAM B. NEWBY*
It is urgent to have a MORATORIUM on Nuclear Energy.
It seems to me after exhaustive study that radioactive waste was not a problem till nu-
clear energy was developed at the close of World War II. First it was for military use
only followed by great expectation that this form of energy was our great hope for an
unlimited source of future energy. Now we are realizing that this form of energy is an
uncontrollable monster that can destroy our civilization. Not only that but it now ap-
pears that instead of being a cheap source of energy it is turning out to be the most
expensive form yet discovered.
THE COST is: TOO GREAT MONETARILY-and FAR too GREAT a threat to our
health—in cancer, genetic defects, and long-term pollution of our air, water, and soil
for present and future generations.
NUCLEAR ACCIDENTS. Who can afford a nuclear catastrophe? The utilities can't.
Even the Federal government can't afford 14 billion accidents—the result of a reactor
meltdown or severe earthquake where lethal gases have been released with resulting high
loss of life and astronomical property damage.
RADIOACTIVE WASTE. There is no safe place in the U.S. for the expected 1 billion cu.
ft. of lethal radioactive waste by the year 2000 (if present plans for reactors are
implemented)—enough to cover a 4-lane highway coast to coast 1 foot deep.
Sweden has wisely called a moratorium on nuclear energy and France has cut back on
their program.
Dr. John W. Goffman, M.D., Ph.D., professor of Medical Physics at the University of
California, says, "What is really at issue is a moral question—the right of one generation
of humans to take upon itself the arrogance of possibly compromising the earth as an
habitable place for this and essentially all future generations."
THEREFORE—We should call a moratorium, civilian and military, in the U.S. before
any more huge sums are expended on nuclear. Then begin the massive development of
"SAFE" energy alternatives such as SOLAR, WIND, and THERMAL coupled with a
well-rounded, comprehensive conservation program, with tax incentives for coopera-
tion. I feel sure nuclear energy, the polluter, the killer, and uncontrollable would not
be needed. And what an economic drain would be lifted and relief to be free of the
dread of catastrophe.
* 604 Draper Valley Rd., Selma, Oregon 97538
117
-------
STATEMENT OF ALEXIS PARKS*
Please include this letter as well as the enclosed letters from Drs. Bertell, Mancuso,
Martell, and Najarian in the [proceedings].
I've enclosed a copy of the letter sent to Drs. Martell, Mancuso, et al. and have
submitted their responses to the EPA with the understanding that permission for their
publication has been granted.
In response to my request for a statement from Dr. Martell, I received, in the mail, a
copy of his February 24th (1978) correspondence with EPA. For the sake of brevity, I
have included only the introduction to Dr. Martell's discussion of alpha radiation and
cancer. You have my permission to print the first page and a half of that corres-
pondence and then refer interested readers directly to Dr. Martell for a complete copy
of the 11-page correspondence.
I would like the enclosed letters entered into the record as a further indication of the
inadequacies of current radiation standards as these standards address the issue of
chronic public health effects from low levels of radiation, and as these standards rely
for support upon the BEIR reports of the past.
While some established criteria and standards are better than none, I would recommend
that the EPA lean heavily toward the conservative side in estimating permissible levels
of radiation, perhaps even concluding that in the light of uncertainties in public health
risks, a moratorium on the further generation of radioactive wastes will be necessary
in order to enable the EPA to properly assess the seriousness [of the effects] of the low-
level emissions upon public health. I understand the suggested "need" of commercial
pressures to get the job done, but an established Congressional fund would do the same
thing and thereby place nuclear power in its proper perspective: as an interim energy
source.
In addition, I would recommend that it is essential that spent fuel rods and uranium mine
and mill tailings be included as radioactive wastes and subject to strictest control by
EPA.
P.O. Box 1917, Boulder, Colorado 80306
118
-------
March 6, 1978
Dear Ed,
Members of the Colorado Friends of the Earth,
Boulder Mobilization for Survival, (former) Goloradoans
for Safe Pow^r, Rocky Flats Action and others* have
been encouraging active citizen involvement in the up-
coming Environmental Protection Agency's (EPA) public
workshop on "Environmental Protection Criteria for
Radioactive Wastes." The workshop will be held in
Denver, March 30, 31, and April 1st.
We are concerned about the term "acceptable risks
from radioactive wastes" because we feel that
insufficient government attention has been focused upon
scientific research which deals with potential and/or
actual public .health effects from low levels of
radiation.
Because of your research efforts in this area, we
would like to request a written statement from you
illuminating—within a paragraph or two—your primary
concerns about the public health risks/effects from
low level radiation.
Although we have papers relating to the general
nature of your work, we feel that such a statement
can be effective in two ways:
. We woi Id like to quote from it to support our
lay fears about possible risks from low levels
of radiation.
. We will ask that it be entered into the formal
records of the national workshop.
Because the EPA workshop is scheduled to begin a
few weeks from the date of this request, will you please
send your letter to Ms. Alexis Parks, PO Box 1917,
Boulder, Colorado 80306, by March 27. Thanks.
Alexis
(for *)
cc: Drs. Martell, Mancuso, Morgan, Najarian, Puck, Sternglass;
and others.
-------
ROSWELL PARK MEMORIAL INSTITUTE
Department of Health « State of New York
666 Elm Street • Buffalo, New York, 14263
Gerald P. Murphy, M.D., D.Sc.
Robert P. Whalen, M.D. //7jf/f(yfe D/rec(or
Commissioner of Health
March 28, 1978
Environmental Action Reprint Service
2239 East Colfax
Denver, Colorado 80206
Dear Ben Billings,
My concerns relative to the Radwaste Criteria have to
do with the exposures of workers and of the general public
to radiation. The low-level radiation effects have been
seriously underestimated, and the present federal guidelines
for exposure are seriously out of line with current research
findings.
I would recommend that workers be allowed to accumulate
no more than C.I rad whole body exposure per year after age
25 and before age !+5- All other members of the general public
should be protected as far as possible from all, unnecessary
radiation, and there should be no planned-in exposure in excess
of 0.01 rad. Since a chest x-ray gives a bone marrow dose of
0.001 to 0.010 rad, and since a chest x-ray is a serious hazard
to health only to be risked when there is an over-riding benefit
to the person Deceiving it, even this permissible level is a
risk. I suggest it only in an effort to safely dispose of the
nuclear waste which is already generated by this life-threatening
technology. I do not condone further pollution of the environ-
ment. I would further caution you against meaningless average
estimates of radiation exposure. Upper limits to persons are needed.
Sincerely,
c/ ^ -
/vX c/s;^'>-,— j,.^:.: uJJ\
Rosalie Bertell, Ph.D.,GNSH
-------
University of Pittsburgh
GRADUATE SCHOOL OF PUBLIC HEALTH
Department of Industrial Environmental Health Sciences
March 16, 1978
Ms . Alexis Parks
P. 0. Box 1917
Boulder, CO 80306
Dear Ms . Parks :
This is in reference to your letter. I have just
returned from an extensive trip.
Our jgonclus ions basically are that the so^-called
"safe" radiation standards which have been used as a guide to
protect the industrial workers, are not safe at all; that workers
_J^JLJ^£!LJ?®£!L. expciggAjto, radiation greatly, below that level
have developed an increased risk for"" certain types of cancer.
The radiation induced cancers identified were bone marrow
cjL_nc_ers (multiple myeloma and myelogenous leukemia) , cancer
°f jjie pancreas and cancer of the lung.
i The estimated doubling dose, the amount of radiation
to double the so-called "normal" risk for developing cancer
among workers was for bone marrow cancer, 3^6 rads ; lung
cancer 13.7 rads; cancer of the pancreas, 15.6 rads; all
\cancers, 33.7 rads.
SjLn_ce_we__estimate that the risk is 10 times greater
than was recognized before then the' radiaton standard should
be reduced 10 times.
Secondly ,_ _ the estimate permissible level for poupla -
tipns around nuclear~Tac:3.1ities ,
^^
standard for workers, would have to be reduced 10 fold .
Sincerely ,
':<•--.-..-, ~T '•"-'"••-"'- •"'-'•--<= '—!-£_
Thomas F. Mancuso, M.D
Research Professor
TFM:alb
Enclosure
-------
24 February 1978
TO: Director, Criteria and Standards Division, Office of Radiation
Programs, U. S. Environmental Protection Agency, Washington, D. C,
FROM: Dr. Edward A. Kartell, National Center for Atmospheric Research,*
Boulder, Colorado
SUBJECT: Comments on "Proposed Guidance on Dose Limits for Persons Exposed
to Transuranium Elements in the Environment," Report of the U. S.
Environmental Protection Agency, September 1977.
1 . Introduction
In response to Federal Register Notice FRL 808-5 issued 30 November 1977,
I submit comments, below, on the proposed guidance. The question of accept-
able levels of public exposure to alpha radiation emitting contaminants is of
sufficient consequence to demand the attention of jible . objective scientists
who are sensitive to the limitations of our understanding of the chronic
healr.h effects of alpha emitters £_ Alpha emitters are extremely effective
rautagens and well established agents of cancer in man. Any serious consider-
ation of the unresolved questions regarding the contributions of alpha emit-
ters to the general incidence of genetic effects and cancer in man would raise
more questions than answers.^ A s s e _s sm e n t __ o f the^microdistribution_.af_:Lnt.exnal
alpha emi_t tgrs_and theirjjole^in spontaneous..,mutatj,pji^_iagj.ngmand^aiialigaan&y
Ts"7"*i n my view, the most ^serious , neglected area of_.radiation_heajj;h
In_this ^context , the proposed guidance is hopelessly unacceptable .
Its estimates of health risks are based on the models and recommendations of
.the National Academy of Sciences ^BEIR_ Commit tee reports of 1972 and 1976 which
have v e r y^ se r i_o u s short comingswith regard to the internal organ distribution
of 'naTural and pollutant alpha emitters and their effects (see below). The
guidance is based on an assumed linear relationship between alpha radiation
dose and cancer risk, an assumption which may be completely inapplicable and
which can result in a substantial underestimation of 'the cancer risks (see
,ow) . Authors of the_guidance admit^ thatT the uncertainty _in estimating
-V.?.ri_ Laj ge.r__t'han. that_f.or_cancer_r.i_s.k_s- in the face of such
__-.. ._
unknowns and uncertainties, it is most remarkable that the unidentified
authors of the guidance could find it possible to propose that it is accept-
*The National Center for Atmospheric Research is sponsored by the National
Science Foundation
-------
able Co expose Che public Co plutonium contamination in. surface soils aC a
level of 0.2 PCi/m in Che Cop l cm layer about 200 times the level of
fallout plutonium in.surface soils of eastern Colorado
On the basis of considerations discussed below, insoluble alpha emitcing
parcicles which accumulaCe aC Cumor sites and germ cell sites should be
singled out for particular attention as possible agents of the rising inci-
dence of cancer and genetic effects in man. These are very serious possibil-
icies Chat can be tested experimentally. Picocurie quantities of alpha emit-
ters may very well explain the. high incidence of bronchial cancer in smokers
(see below). Organ burdens of fallout plutonium in the general public have
already reached levels of ~ 0.5 pCi/kg in lung tissue, ~ 0.7 pCi/kg in the
liver, and comparable levels in Che gonads and other organs (Moss and
Campbell, 1972). Depending on Che microdistribution of this alpha activity in
the gonads and at tumor sites and on the mechanism of cancer induction, this
fallout level of alpha activity may be contributing substantially to the
rising general incidence of cancer and genetic effects in man. If so, expo-
sure of large sectors of the general public to 200 times higher levels would
have tragic consequences. What is now urgently needed is intensified research
on the microdistribution of alpha emitters in man and an objective assessment
of the chronic health implications of such distributions. Based on present
knowledgej the cnly responsible recommendation regarding public .exposure_C.o
insoluble alpha emitting_particles would be that such exposures be .restricted
to the practical minimum. That practical minimum is, unfortunately, the
of fallout plutonium in surface soils.
-------
Copy of handwritten letter'.
March 11, 1978
Dear Ms Parks,
All I have to say at this time is that the complete study
on former nuclear shipyard workers will be completed in perhaps
2-3 years. Ill "be working with the CDC on this project.
My preliminary study, which is beings prepared for publication
at ^his time, 'seems to_ indicate a greater health risk
than previously TnoushT . riy own theory is that exposure
•co radioactive materials as opposed to X-rays or radiation
from an external source, may cause more tissue damage from
within than would be indicaTea oy measurements from a
radiation cade.
At any rate, it is clear to me that up to now there
are very few studies on the occupational exposure to "safe"
levels of radiation ana radioactive materials. ""The newer
studies (mine, Mancuso, "Smokey" done by the. CDC J seem to
indicate an increased risk for cancer and leukemia for
low leveis of radiation. Previous studies (mostly A- bomb
Sarvi'vCrs In" "aSa?. an-3 ueople exposed to medical X-rays)
do not come c~±ose to "predicting the amount 01 disease
from a. ^IT5IT radiation sxnosare,, vv^rerr ens1 i~ exrassd to
radioactive dusx , materials, etc., and the ..exposure is
measured in "HEMS bv a radiation badse.
Yours sincerely,
Thomas ITajarian, M.D.
-------
STATEMENT OF C. B. PEARSON*
[Comment on Opinion 3b on p. 40 of Summary and Conclusions of Working Group Ifl
The risks involved with the proposition of burial are not adequately known. Therefore,
basing your analysis of risks on comparison of exposed versus [buried material] is making
an inadequate statement of comparison; i.e. [there is] no data base for [the] assumption.
*CoPIRG/UNC
125
-------
STATEMENT OF THE COMMONWEALTH OF PENNSYLVANIA*
The Commonwealth of PennsJvania appreciates this opportunity to comment on EPA's
Background Report on Considerations of Enviromentai Protection Criteria for Radio-
active Waste, February 1976. In general, we feel that the report is very vague and
philosophical in nature and as such may not fully address the many technical and social
parameters that require investigation before generally applicable environmental pro-
tection criteria can be formulated.
We are very concerned about the pace of the EPA program for development of criteria
for radioactive waste disposal. In particular, we are concerned that the low-level pro-
gram is not as aggressive as the current situation dictates. As you are no doubt aware,
recent occurrences in the commercial low-level waste disposal field have essentially
eliminated the availability of burial space in the eastern part of the United States for
future additional sources of this waste. Not only does the pace of the EPA program fail
to recognize this critical situation, but it also appears to be lagging the NRC program
for development of criteria and standards. This situation appears unsatisfactory since
it is apparent that EPA's generally applicable criteria should be in place prior to the
finalization of NRC's licensing criteria and standards, so that the two are compatible.
The failure to respond in an aggressive manner in this area could be more crucial in the
short term to the many widely varied users of radioactive material, in that lack of au-
thorized burial space could cause an immediate shutdown of essential services in these
areas.
It is perceived by many technical people in the waste disposal field that the environ-
mentally acceptable disposal of hazardous waste is more of a problem then the disposal
of radioactive waste. This is due in part to the enormous quantities that are generated
by various industries and their current methods of storage. In addition, their persistence
as a hazard and the limited knowledge of their health effects make them in some cases
as hazardous as transuranic radioactive waste. It is therefore recommended that any
enviromental protection criteria developed for radioactive waste be applicable to all
hazardous wastes so that the public can be assured that equal hazards are being treated
equally.
Our specific comments on the Background Report are as follows:
1. The report discusses the philosophical concepts of zero release and zero risk. In this
context it should be recognized that zero risk cannot be guaranteed for any techno-
logical undertaking, nor can zero releases be guaranteed for any waste disposal op-
eration. It is therefore recommended any reference to these concepts be deleted
in the criteria document in favor of more reasonable goals which are achievable.
2. It is suggested in the report that risk estimates should be performed for at least 1,000
years, regardless of the type of waste. While reasonable for high level and TRU
wastes, it may be inconsistant with other considerations (pp. 38 and 43) for typical
low-level waste. The longest-lived significant contributor to LLW have at most a
30-yea, half-life. After 1,000 years, based on the typical initial specific activities
of this waste, the specific activity would be several orders of magnitude lower than
^Received from Thomas M. Garusky, Director, Bureau of Radiological Health, Dept.
of Environmental Resources, P.O. Box 2063, Harrisburg, Pennsylvania 17120.
126
-------
the average natural activity of the soil. This would therefore suggest that the du-
ration of risk be based on the persistence of the type of waste considered. The
longer-lived contributors inherent in LLW could be controlled by placing a maximum
allowable limit on these particular long-lived isotopes. This limit should be based
on a pathway analysis for each specific long-lived isotope.
3. Ra-226 sources are mentioned in the report as an example of fabricated naturally
radioactive wastes. It is understood that this radioactive material will be included
as a hazardous waste in future EPA regulations. Since this isotope has one of the
lowest MFC's in water, it is equivalent in hazard to TRU waste. Therefore, its
treatment in a less restrictive manner as a hazardous waste is not consistent and
further supports the above recommendation that any environmental protection cri-
teria developed for radioactive waste be applicable for all hazardous waste.
<4. One of the few items in the report which can be called criteria appears as item 5 on
page 53. While these features may in some cases be desirable, they are not neces-
sary to assure adequate containment over the hazardous lifetime of low-level wastes.
In fact, sedimentation could lead to a surface water infiltration problem, instead
of providing additional containment.
5. The report states that engineered barriers generally can be considered only as interim
measures for containment. Including this concept in the criteria may be too re-
strictive, especially for low-level wastes. State of the art advances may be such
that engineered structures could prove to be the primary barrier to release.
We would hope that these comments receive your utmost consideration.
127
-------
STATEMENT OF MICHAEL H. RAUDENBUSH*
I participated in the recent EPA public meeting on radioactive waste criteria held in
Denver, and I wish to submit for the record the following comments. These are my
personal views.
BACKGROUND
I attended most of the meetings of Working Group I ("What is Radioactive Waste?), and
am only familiar with the proceedings of the other two groups insofar as they were
presented at the final plenary session.
COMMENTS PERTINENT TO GENERAL MEETING
1. I believe that public meetings such as this can be productive in dealing with genuine
public concerns. However, they can also be abused by special interest groups, both
pro and con. Applying this general observation to the specifics of the meeting, it
was my observation that Working Groups I and III were considerably more successful
than Working Group II at allowing the various points of view to come together to
a consensus. Whether this was due to the group size, the time allotted, or the
quality of the moderator is not clear. What was clear was that the final report for
Group II consisted almost exclusively of positive and negative statements
juxtaposed, with no real resolution of issues. I would therefore suggest that in the
future such meetings be very carefully structured to allow for smaller working
groups with highly qualified moderators. The maximum size of a working group
should be 20, the time allotted for discussion should be ample so that no one feels
he must present speeches, and the moderator must occupy a middle ground in
viewpoint and be reasonable and articulate. Mr. Al Hazle, who moderated Group
I, is a splendid example of a highly qualified moderator.
It is clear that some of the participants (a minority) were present not to solve
problems but to use the exposure to promote various special goals which were not
necessarily related to the purpose of the meeting. The participation of these in-
dividuals, although unavoidable, was nonproductive. Specifically directing my
attention to the final meeting report, I would point to various gratuitous comments
inserted by these individuals. As a case in point, I refer to the Group II report,
page [39, last sentence]. Such remarks should certainly be stricken from any
records other than verbatim.
2. A particularly obnoxious idea threaded its way through much of this meeting and this
idea was promulgated by the antigrowth, antitechnology special interests. This idea
was that no risk from radioactive waste is acceptable. I believe that when pressed
on this issue, this position really may be read to be "no risk from nuclear power is
acceptable," as the proponents are quick to add that risks from use of radioisotopes
for medical purposes, for example, are acceptable.
* 765 Lafayette St., Denver, Colorado 80218
128
-------
The "no risk from radioactive wastes is acceptable" viewpoint may, in my opinion,
be interpreted in one of two ways: either a fundamental lack of understanding of
the nature of technology, or the pursual of an ulterior goal: to wit, the
promulgation of criteria which are impossible to meet by nuclear technology, and
therefore a moratorium on nuclear technology. Such a viewpoint should, in the
name of reason, be vigorously assailed.
3. The goal of radioactive waste management should be to maximize societal benefits
relative to potential damage. This goal must be applied across the board to include
alternative technologies to those which produce radioactive wastes. I believe that
this fundamental goal was not adequately addressed in the meeting and I would like
to insert this position for the record. Although it may be argued that the
maximization of benefit/damage ratios is outside the scope of ERA'S responsi-
bilities, I would argue that this is not the case. The reason for this is that ERA'S
responsibility is to protect the general public from the entire spectrum of potential
environmental risks. It is impossible to do this without understanding the tradeoffs
between alternative courses of action. This observation applies to all radioactive
wastes, whether produced in the field of medicine, nuclear power generation, or
weapons. In each case, there is a benefit to be derived, although not necessarily
quantifiable. Although the quantification of these benefits may be subjective, it is
essential that this exercise be performed, or the designation of acceptable risks
from radioactive waste management becomes a criterion adrift without an objective
anchor.
4. It is my personal opinion that it is necessary to include in the criteria for radioactive
waste mangement some sort of discounting of risks into the future. Especially after
long periods of time (perhaps after several hundred years), perceived risks from a
single health effect must be discounted by some percentage. This is necessary, in
my opinion, in order to account for the uncertainty of technology which may be
available in the future for dealing with cancers, or removal of hazardous isotopes
from the environment, or simply uncertainties in the future of the human race.
5. The idea that it is necessary to have an absolutely proven method of radioactive
waste disposal before the generation of additional wastes may be allowed is of
questionable merit, in view of the large quantities of wastes existing now and being
generated every day. To arbitrarily cut off the generation of such wastes, pending
a "solution" to radioactive waste mangement, would be arbitrary and capricious.
It appears to me that the proponents of this philosophy are simply utilizing this
suggestion as a backdoor entrance to promote a nuclear moratorium. The propo-
nents of this point of view generally wish it to be applied only to nuclear power
generation and weapons production, not to "beneficial" (in their eyes) uses such as
medical research or medical therapy. The existence of radioactive waste is de
facto. It is the management of this waste which must be addressed, and it is not
productive to simply demand an end to the generation of such waste.
REMARKS SPECIFIC TO WORKING GROUP I
Regarding items F and K of the Working Group I final report, I would like to express the
opinion that any criteria generated must clearly state that an individual or an industry
is not required to reduce radioactive effluents below the existing background at the
specific site in question. For example, it is nonsensical to require that water returned
to a stream be cleaner than when it was removed, be it regarding radioactivity or any
other pollutant. I believe this point was obscured in the report as presented.
129
-------
Regarding Item N of the Group I report, I believe that multiple categories of radioactive
waste must be addressed and differentiated, based upon hazard to humans. For
example, I believe it is important to differentiate between high-level fission products,
transuranic contaminated low-level wastes, non-TRU low-level wastes, etc. The reason
for making this categorization is that the handling procedures and degree of isolation
should clearly be different between these various waste categories.
[In Item V] of the Group I report the last sentence reads "It was suggested by some that
there should be broad public participation and funding to present views of
environmentalists." It is my opinion that environmentalists represent a special interest
group and therefore this sentence should be changed to read "the public" instead of
"environmentalists."
[In Item X], Group I discusses suggestions for public participation in the future. I take
issue with one specific suggestion, and that is that proceedings of such meetings be
"dumbed down" to satisfy the nontechnical public. I object to the "dumbing down" of
any issue, technological or otherwise. Attempting to reduce discussions of technologies
or public policy to the lowest common denominator are counterproductive. It is neces-
sary to speak in precise technical language when discussing precise technical subjects.
Another comment I have regarding public meetings is that, while I generally agree with
the value of such meetings if they serve the purpose of responding to genuine broadly
perceived public concerns, I believe that increasingly in the future we will see this type
of meeting abused by special interest groups to slow down the development of various
projects to which they are opposed. I would simply caution that EPA use sound judgment
in determining whether the true interest in a particular issue is a broad public interest
or is simply the interest of a narrowly focused group in delaying a particular rule-making
or technological advance.
I very much appreciate the opportunity to include these remarks as background infor-
mation for the Denver meeting.
130
-------
STATEMENT OF SAM SCHERF*
While your public forum deals with the environmental criteria for radioactive wastes>
my main purpose in writing is to inform you that most any decision that would aid the
United States in national policy regarding energy should be one of the main criteria.
Without this issue being settled, it appears that immediate needs of energy cannot be
taken care of as evidenced by the recent imbalance of energy production sources which
caused many people in the mid-central and eastern United States to lose their job em-
ployment, productivity, etc. during the recent coal strike. You are discussing a problem
that for the short term needs immediate action. If later you find that you have not
made the best alternative, then change the location of storing of this waste at that
time.
In addition to urging you to take as expedient action in developing your solution as
possible, as a laymen I would offer a solution of storage within underground areas that
would be safe from ground water flows. I'm sure the containers you would choose would
be safe, but I personally would like this extra protection, knowing that if there was any
leakage, it would not be distributed by the way of any fluid flows such as water, air,
etc.
^Executive Vice President, Chamber of Commerce, 124 West 4th Street (P.O. Box 367),
Cedar Falls, Iowa 50613.
131
-------
STATEMENT OF ANNA E. WASSERBACH*
Would very much have liked to attend the Denver forum. However, since. I cannot, I
would like to endorse some of the proposals presented at the Reston, Virginia, and
Albuquerque, New Mexico, 1977, workshops.
I am pleased to see, in Background Report, Considerations of Environmental Protection
Criteria for Radioactive Waste, Feb. 1978, for what is to me the first time, the ethics
of leaving radioactive wastes to future generations being considered along with the
technicalities of disposal and/or containment. We would certainly not find ourselves
with such a degenerating environment if morality had always been a consideration in
man's actions. Unfortunately, reality, or perceived reality, and technicalities have
been the driving forces on whether a certain activity should or should not be engaged in.
Those who would add the third dimension of morality were called "cry babies" as with
Dr. R. Oppenheimer, or some other derogatory characterization.
I also endorse the concept that waste disposal be considered in terms of 1,000 years,
rather that the "interim" storage now used of life-of-plant. I do not endorse the Dept.
of Energy's proposal to accept radioactive wastes from utilities on a one-time-fee basis.
The cost of disposing of wastes, whatever the manner deemed feasible, should be the
responsibility of those creating the wastes. The same holds true for medical and in-
dustrial radioactive wastes, and particularly so since it is expected that the amounts of
wastes from such sources (in addition to agricultural uses) will increase. If the people
generating the wastes have to pay to clean up what they do, they may be a little more
conservative in finding new "commercial" uses simply because it is profitable, but,
again, without really knowing the long-term consequences of such uses. This March
1978 forum would not be taking place if those promoting nuclear power had had to face
the waste disposal problem as they created it.
I have repeatedly seen the term "remedial action" to be taken when wastes migrate from
a site into surrounding water, air, and soil. When I asked specifically in relation to West
Valley, N.Y., what this "remedial action" is, I was told it was yet to be determined. I
hope that "remedial action" is not just a catch phrase awaiting another technological
solution.
I also endorse the proposal that radioactive wastes should be provided greater security
against major adverse consequences of failure than is acceptable for dams, dikes, etc.
(pp. 41-42 of Background Report). While any of these "commonly accepted risks" (as the
nuclear industry is so fond of referring to) can cause great human and environmental
devastation, man has not ever, in recorded history, experienced any dangers of such
long range as those posed by nuclear wastes.
In the preface, Dr. James E. Martin states that EPA's charge as of 1970 was to "advise
the President with respect to radiation matters, directly or indirectly affecting health,
including guidance for Federal agencies in the formulation of radiation standards... ."
It must be very difficult for EPA to fully carry out this mandate if it does not know what
is now in the environment. The NRC appears to be in a mad scramble to grant
* Chairman, New York Federation for Safe Energy, Box 2308, W. Saugerties Rd.,
Saugerties, N.Y. 12477
132
-------
special licenses for nuclear materials. One way for them to solve their waste problem
is by finding "commercial" applications, again, without long-term consequences. While
each research, medical, commercial, etc. application may be considered small in itself,
NOWHERE have I seen [considered] the cumulative effects on human health of the total
use of radioactive materials. Each nuclear generating station is given its "permissible
dose" of release into the air and water, but, again, not cumulative amounts for what
is or will be in the environemnt. I would like to suggest the ultimate "interim" solution,
and that is ceasing the generation of any more radioactive wastes (with the exception
of medical applications) and including research applications, until we really know what
to do with what is already here. Certainly those now employed in radioactive waste
management jobs will have enough to do for the next 1,000 years. However, as critical
as I may sound, I am completely opposed to the Dept. of Energy taking charge of all
environmental monitoring to do with energy generation. That would be the final assault
on humanity. If there is any support I can lend to EPA to ensure that they retain moni-
toring of the environment, please let me know.
133
-------
STATEMENT OF JUDITH K. WILKINSON*
I participated in [the Forum] and below are some corrections I have for our working
group's report.
I was in Working Group I: What is radioactive waste?
1. The report does not adequately reflect that a substantial number of us in the working
group were addressing atomic weapons as well as atomic power. [Item V] should
read, "Should there be a moratorium on nuclear weapons and nuclear power in the U.
S. until a satisfactory waste disposal technology has been approved?" Our group said
an overwhelming YES. In addition, whenever radioactive waste is referred to, waste
from nuclear weapons is included.
2. See [Item] M. Should there be distinctions between high- and low-level wastes in the
criterion defining radioactive waste? The consensus of the group was not as it is
reported. Our group (approximately 1/3 to 1/2 of the working group) intended that
distinctions should not be made between low-level and high-level wastes, either in
the definition of radioactive wastes or in the criteria addressing the control measures
or in the standards promulgated by the regulatory agencies. The reason for this is
that there is research which indicates that low-level radiation is much more dan-
gerous than was previously thought (see research done by Edward Martell of the
National Center for Atmospheric Research, Boulder, Colorado and reports from Karl
Z. Morgan at the Georgia Institute of Technology).
I appreciated the steps taken by the Environmental Protection Agency to involve the
public in these decisions. I found the conference very helpful as a way of putting
industry and environmentalists in better communication with each other as individuals.
*980 University Avenue, Boulder, Colorado 80302
-------
STATEMENT OF DAVID YOUNG* t
Since my personal participation in the Forum consisted mostly in attendance at and input
to the workshop session of Working Group II, I will confine my comments mainly to the
written report of that group to the EPA.
I felt privileged to sit at this particular workshop, since the questions of the reliability
of current methods of risk assessment, and of what level of risk is to be acceptable to
society, and of how it is to be determined that society as a whole does, indeed, accept
those risk, are, I feel, central to a wise structuring of standards for the nuclear indus-
try by the EPA.
I would like to state at the outset that, although I did not agree completely with the
method of selection of our group's drafting committee, I feel that their written report
gives an accurate reflection of the views expressed during the workshop session.
I feel called upon to make these comments both to emphasize my agreement with some
of the viewpoints expressed by members of the group and to point out some assumptions
which were made by others in expressing their viewpoints—assumptions which I find both
unfounded and also frequently quite disturbing in that they might be uncritically ac-
cepted by the EPA or others reading the Forum's written report.
My comments on statements made by members of the group will fall basically in the
order that the main issues came up during the general workshop discussion, with com-
ments on each issue being grouped together (as each issue was generally discussed
through the course of several agenda items in the actual workshop meeting).
First of all, I can say that I thoroughly agree with the statement formulated by the EPA
in Item 1 of the agenda, and concur with the group consensus .
As for Item 2, I feel that the choice of 1,000 years as the responsible limit for estimat-
ing the potential health effects of wastes is completely arbitrary and unrealistic, inas-
much as the wastes remain volatile for hundreds of thousands of years, and must there-
fore be guaranteed not to exceed acceptable risk standards for every bit of that time.
If uncertainty factors in risk assessment become extreme after 1,000 years, we must
consider that we are exposing generations following that time to an unknown level of
risk; a situation which we would surely never want to place our own generation in
(although it seems to me that we are willing to do even this, as I will attempt to make
clear later).
One of the most fearful uncertainty factors, to my mind, is the likelihood of future
geological upheaval or other basic changes on the face of the earth (Ice Age, etc.);
changes which increase in likelihood of occurrence as we get into the thousands and tens
of thousands of years, and any one of which could cause a major release of stored ra-
dioactive waste materials into the biosphere.
* 2046 Emerson St., Denver, Colorado
fThe following people, all attendees at the Forum, wish to signify their agreement with
the views expressed in this manuscript: Carolyn Landes; Eugene Hanus, 3r.; David
Landes.
135
-------
This question of the degree of uncertainty in risk assessment was a bone of much
contention throughout most of the workshop discussion. The setting of standards which
are designed to effectively hold the health risks within certain given limits presuppose
the existence of fairly accurate methods of determining just what those risks are. It
was assumed (and stated) by a number of people at the workshop that such methods are
available, but for a number of reasons I believe that this assumption is based on
misinformation, wishful thinking, and disregard of the past record of the nuclear
industry. Misinformation lies mainly in ignorance of the latest findings of researchers
into the biological effects of low-level radiation. One important study in this field is
currently being done by Dr. Edward Martell, a nuclear chemist at the National Center
for Atmospheric Research, in Boulder, Colorado. The findings of Dr. Martell and his
colleagues are already indicating that the power of low-level alpha radiation to effect
genetic changes in living cells (the cause of cancer) may have been previously under-
estimated by a factor of up to 10,000/1 (ten thousand to one).* It was a consensus of
our group that "any standard selected would be subject to future change as future data
become available." I would like to suggest, however, that no accurate standards can
be set which are based upon data from a field with such a rapidly shifting data base,
and that it might prove suicidal to err in any direction but the most conservative one
when risking exposure to such lethal substances over periods of many milienia.
Statistical verification in the human population of findings of Dr. Martell's researches
and any others currently going on may start coming in soon in the form of a rise in the
cancer rate across the general population, and specifically in those areas in close
proximity to nuclear facilities. Some of the cancers which can be induced by radiation
have latency periods of 20 to ^0 years. The nuclear power industry is still less than 25
years old.
Human error was mentioned several times in the discussions as a major factor contribu-
ting to the ultimate uncertainty of any risk assessment. This factor, which manifests
itself both in poor and unsafe design of facilities and in accidental wrong procedures
executed within those facilities (whether well-designed or not) is, I believe, perhaps
the largest and most immediately dangerous uncertainty factor to be dealt with. With-
out going into the hundreds of accidents that have occurred over the past 25 years at
both military and commercial nuclear plants, I will state my belief that an examination
of the past record of the industry would be enough to make anyone doubt the present
capability of that industry to guarantee to keep the level of its emissions of radioactive
material to any given standard—even today's liberal standards (much less the much
more conservative ones which I believe are needed).
1 feel it is an extreme and dangerous form of wishfull thinking to believe that the in-
dustry's performance will, for some reason, suddenly make a dramatic improvement—as
long as designers and technicians remain less than perfect (as they always will).
It should be fairly clear, to anyone who takes more than a casual look at the evidence,
that this radioactive material which we continue to produce in great quantiti.es is
something which we still know little about: neither of its real long-range effects on the
human organism, nor of how to effectively contain it within the limits of even our
guess-work standards.
*Alpha radiation is the most effective known agent for the producton of malignant
chromosome damage.
[36
-------
I have much more to comment on concerning the topics discussed by our group, but since
I have limited time left to conclude these comments, I will mention only one more issue
which I feel needs to be considered thoughtfully by the EPA in setting standards for the
nuclear industry. This is the question of the extent of public input which is desirable
in helping the EPA with the decision-making process. The way I see it, the EPA is an
agency whose purpose for creation is to serve as an agent of the people in executing
their will on matters of protection of the environment. This is explicit in the nature of
the democratic system within which it operates. For this reason, I feel that public input
on this matter should be as broad-based and as well informed as possible. For this reason
also, I find one statement made by the representatives of the EPA attending our work-
shop to be especially disturbing. That is the statement that, "no single commonly used
method of determining risk acceptability (i.e., solely by cost-benefit analysis, or by
comparison with other technologies, or by means of polling public opinion) was by itself
adequate for dealing with the problem of nuclear waste management, and that, there-
fore, a complex set of assessments involving all these factors needed to be undertaken."
I feel quite strongly that, rather than considering all of these factors equally or in some
form of conceptual balance, the determining factors in decision-making should be ac-
curate assessment of the people's will on. the matter (by voting or any other accurate
means), and that the people should be educated so that they can make the choice with
consideration to the other factors mentioned, rather than having their will balanced
against these abstact factors. I feel that the broadest possible public input is needed for
making these particular decisions, considering the cataclysmic magnitude and irre-
versible nature of the possible consequences of the wrong decisions. I do not wish to
place the burden of these decisions on any group of people as small as the EPA, and I
fear that their decisions may be influenced by such unfair but undeniably effective
pressures as concentrated propagandizing by the nuclear industry and pressures from
other governmental agencies and departments.
And now my time really has run out. I would like to thank you for your consideration of
the views expressed in these comments.
137
-------
STATEMENT OF PAUL C. ZUCKER*
There is substantial agreement that a long-term geological waste disposal site must be
designated to handle the ever-increasing amount of radioactive waste being generated.
In California, the Public Resources Code Section 25524.2 prohibits the certification of
any new nuclear power plants until it can be determined that a demonstrated technology
or means for permanent, terminal disposal of high-level nuclear waste exists and has
been approved by the appropriate federal agency. The California Energy Commission
has concluded that it is impossible to make an affirmative determination at this time.
Until the Nuclear Regulatory Commission (NRC) does bring a repository on-line, it
would seem imprudent to continue deployment of light water reactors throughout the
United States.
When a site has been chosen for waste disposal, the impacted jurisdictions should be
solicited for their opinions as to the feasibility and desirability of the site. By allowing
for local input, the public could be informed as to the risks inherent in the burial of
wastes in their area.
There has been grat concern among segments of the public about radiation leakage in
the area of high-level waste sites. To defuse this concern, a baseline public health
survey could be undertaken before any wastes are implaced and then dicennial surveys
undertaken thereafter to enable public health officials to monitor any effects the site
implacement has on employees of the plant, inhabitants of the area, and their offspring.
This data will enable scientists to be better able to gauge whether current safeguards
are adequate.
* Assistant Chief Administrative Officer, County of San Diego, County Administration
Center, 1600 Pacific Highway, San Diego, California 92101.
138
-------
STATEMENT DISTRIBUTED AS A FOURTH REPORT*
The following statement is submitted for the record on behalf of some individuals and
representatives of public interest nuclear opponent groups attending this EPA
conference on environmental protection criteria for radioactive wastes.
We commend EPA's undertaking to formulate sorely needed criteria as a necessary first
step toward a more rational approach to radioactive waste control. We recognize the
difficulty inherent in this endeavor to solve a problem many of us regard as unsolvable.
Many of us offer the agency our continuing assistance in these efforts and pledge our
help in making the American people aware of the unparalleled gravity of this national
and worldwide problem.
We urge EPA to consider carefully and to act upon our criticisms and recommendations.
First, we believe, in the absence of fully proven disposal technology, that there is no
moral justification for the commercial or military production of any additional quan-
tities of radioactive waste, except those generated by clean-up activities.
We ask EPA to join us in recommending to Congress and the President that a moratorium
be imposed on the further creation of radioactive wastes so that the pressure from such
a continued buildup of radioactive wastes will not force a hasty, less than acceptable
waste disposal solution.
Recognizing full well the possible short-term societal disruptions that could attend this
proposal, we anticipate submitting a subsequent discussion paper to EPA. We suggest,
however, that a 10% reduction in national electricity supply could provide a splendid
incentive for immediate implementation of conservation and alternative energy sources.
Secondly, although we appreciate the urgency of moving forward toward waste disposal
solutions, we sense and strongly protest the blind formulation of governmental policy
in the absence of sufficient data [and] knowledge and adequate participation by the
American people.
We offer the following criticisms of and objections to the purpose, structure, and
processes of this conference and to some of the philosophical and substantive issues
discussed, and not discussed, in the workshops:
Many of us are not so deeply immersed in nuclear power technology as EPA personnel
and are approaching these issues freshly, with a "layperson's" perspective. Thus, in
addition to the technical comments above, we feel that there are a number of ways in
which future public forums on this subject can be improved in procedure.
The American public should be more widely informed about the event, its contents, and
the ways in which response to the conference agenda can be carried out. More advance
notice about the forum should be given in the general public media, including nationwide
newspaper and television coverage. Future forums should be scheduled for evenings or
weekends to permit participation by working people.
*Received 10 April 1978 from 3. Hurley.
139
-------
The expectations of work to be done by participants should be defined in more detail in
advance. Defining these in advance would reduce the rush of formulating criteria in a
mere two days at the public forum.
One criticism, widely accepted, is that the background report is obscure and insuffi-
cient to the need; it should include much more about the procedures and conclusions of
the previous workshops.
The proceedings of the forum should be recorded verbatim. The lack of a verbatim
record has raised doubts about concern by EPA for public comment.
Further, many of us noted with distress that, among the EPA staff, women appeared
to be present only as receptionists, and that they appeared to be totally excluded from
the serious thinking within the Agency about the waste disposal problem. This fact is
perceived as being related to the extremely abstract, rationalistic, and emotionless
language in which the issues were presented to the public. We object to the divorce of
feeling from these considerations as having a numbing effect on our ability to appreciate
the real life and death implications of what is being decided.
We feel that several important technical questions were not discussed or were not given
appropriate weight in discussions which did occur, which nevertheless may have impor-
tant implications for the criteria. Among these are:
1. The role of alpha emitters as mutagens in nature. It is known that alpha par-
ticles exhibit powerful mutagenic effects under laboratory conditions and that
such effects can, in principle, lead to genetic abnormalities and malignancies.
If, contrary to current popular theory, alpha emitters play an important role
in the natural mutation process, such effects may have profound implications
for the criteria relating to the handling of actinide wastes and permissible
actinide leakage from nuclear processing facilities.
2. Hundreds of thousands of Americans were exposed to various amounts of
radiation as a result of their participation in the atmospheric testing of nuclear
weapons. The epidemiological studies of these people are only now beginning
and their findings surely will have important implications for our criteria.
Despite the risks of hasty evaluation, results of preliminary studies should be
made available within six months and evaluated by the EPA without delay.
Other epidemiological studies now in the literature have been given little
weight owing to the incongruence of their results with the wishes of the nuclear
community. These studies must be evaluated by competent and unbiased per-
sonnel and the result of those evaluations must be given due consideration by
the EPA.
3. Lithospheric disposal of radwastes is only one of several potentially viable
options. Clearly, such alternatives as space disposal and proton accelerator
transmutation have associated criteria which merit identification. This should
be accomplished through further public-professional agency discussion, as
should evaluation of alternative forms of geologic disposal.
4. Return of high-level radwastes from overseas has been accepted by the U.S. as
an option to be available to foreign purchasers of U.S. built and fueled reactors.
What are the criteria applicable to such shipments? What criteria, if any,
among those applicable in this country are appropriate to evaluations of foreign
operations?
-------
5. As stated in point 1 above, alpha emitters are known, powerful mutagens. Their
impact upon other organisms in the biosphere has clear implications for rational
control criteria, yet this issue has received little attention to date.
As the public, while we accept full responsibility for the comments offered by the
public-interest groups represented here, and while we recognize EPA's need to proceed
with the drafting of appropriate environmental protection criteria for radioactive
waste, we feel that the EPA has not sufficiently discharged its responsibility to solicit
informed public input to these criteria.
In particular, we feel that a substantial effort must be made by the EPA to solicit,
consider, and respond to the views of that portion of the scientific and professional
community holding views at variance with the currently popular theories. Further, the
gravity of the issues addressed by these criteria demands the fullest practicable par-
ticipation by the general public. This implies an extensive effort on the part of the EPA
to establish and maintain communication at the grass-roots level, the effect of which
will be to ensure a complete presentation of all substantive questions.
In the philosophical realm, we found the proceeding gave inadequate attention to the
issue of equity in the distribution of the burden of risk in time and space. We suggest
EPA give substantially greater consideration to the concept of distribution justice.
In the very formulation of the issues and the conduct of the conference, hubris, a lack
of humility in approaching this awesome task, permeated the forum.
A number of us felt that the forum seemed to be based on a view of humans as purely
rationalistic and unemotional beings, and that the issues and arguments sprang from
assumptions such as these. The conference appeared to some to be designed to
discourage and prevent the exploration of human values underlying the decisions on
nuclear waste creation and disposal. The expression of sensitivity to the well-being of
people in the future and sympathy for those suffering the painful and horrifying results
of present radiation exposure was also excluded.
It is dismaying and symptomatic of the destructive [character] of contemporary nuclear
technology that many features of this conference indicated a refusal to consider people
as much more than statistics. Worse still, it frequently seemed people just amounted
to a certain number of bodies which might display adverse health effects, or a certain
number of malleable opinions to be persuaded.
Some of us felt that the conference officials and the proponents of nuclear power rarely
revealed any awareness that we must address the needs of people as warm, emotional,
sensitive, and complex wholenesses. People around us have psychological and emotional
faculties, a sensitivity to pain, and a capacity for love and mutual concern that we
cannot let ourselves ignore. Not the least, we have a moral sense to govern our actions
surely as central to our nature as reason, logic, and the will to power. Yet because of
its risks and demands, a nuclear technology must run roughshod over the humanity, the
complex spirit, the intrinsic wholeness of people. But at no time were the costs of
nuclear power to our humanity assessed, and at no time were they justified, except in
mechanical, materialistic, and~soulless terms.
Moreover, many of us feel that to strip from the discussion its social-political-economic
context (in the broadest sense) is to deprive the discussion of meaning. A much fuller
discussion of the historical setting and implications would be extremely desirable.
-------
In the focus of this forum upon the health and safety of human beings, some of us found
a lack of concern for the intrinsic value of other biological organisms or of the earth's
environment as an entity. We urge EPA to view its criteria within a less
anthrotpo] centric framework.
Finally, it is extremely important that EPA proceed toward the promulgation of final
criteria with caution. The government has delayed this process for 30 years. Surely the
production of truly excellent criteria for radioactive waste management—and their
acceptance by the American people—are important enough to warrant a further delay in
order to conduct numerous public meetings on the draft criteria throughout the United
States. We offer to help you with these meetings. We nuclear opponents have been hard
on EPA, but we consider what you are doing of paramount importance to our society
and to the earth forever.
Despite all deficiencies, a number of us feel that useful, constructive dialogue was
achieved in some areas. Moreover, we feel that further efforts may be rewarded by a
deepening of mutual understanding and movement toward the goals of effective action
which we all are seeking.
Signed,
Judith Hurley
Chris Taaffe
Ben Billings
Sally Rodgers
John C. Cobb, M.D., M.P.H.
Edie de Chadenedes
Steve Davis
Michael E. Doyle
Paul Shaheen
Albert Bates
Carolyn Landes
David Landes
Kathryn Partridge
Alexis Parks
Andrew Snow
Judith H. Johnsrud
Bob Mason
Paul Burmeister
Mary Sell
Raymond Sell
Judy Wilkinson
Adrienne Harben
Cactus Alliance
Boulder Mobilization for Survival
Environmental Action of Colorado
Clearing House for Environmental
Action/F.O.E., New Mexico
Governor's Advisory Committee
on Science and Technology
Boulder, Colorado
Boulder Mobilization for Survival and WRL
Congressman Wirth's Office, Lakewood, Colorado
Denver, Colorado
Denver, Colorado
Boulder Mobilization for Survival
and Cactus Alliance
Boulder, Colorado
Boulder, Colorado
Environmental Coalition on Nuclear Power
Citizen
Mid-American Coalition for Energy
Alternatives
Medical Committee for Human Rights
Boulder, Colorado
Boulder Mobilization for Survival
Boulder Mobilization for Survival
and Another Mother for Peace
-------
ATTENDEES
-------
Ahmad Afrasiabian
Atomic Energy Organization of Iran,
Waste Management Division
Joseph Aimone
Fusion Energy Foundation
David C. Aldrich
Sandia Laboratories
Esfahani Ali
Atomic Energy Organization of Iran,
Waste Management Division
Peter Alpert
Colorado Public Interest Research
Group
Melvin D. Alsager
Phi'Jip M. Altomare
Mitre Corp.
David L. Anderson
Rockwell International
.Richard D. Andrews
Rocky Mountain Energy Co.
Claude Appel
Toichi Asano
Jane A. Axelrad
U.S. Nuclear Regulatory Comm.
George E. Backman
Battelle Pacific Northwest-
Laboratories
Randolph S, Baird
Eloise Parsons Baker
Associated Citizens for the
Protection of the Environment
Robert E. Baker
U.S, Nuclear Regulatory Comm.
Stephanie J, Baker
Western Nuclear, Inc.
Paul W. Barrow
Dennis L. Barsten
Dow Chemical Co.
V. F. Baston
Energy Inc.
Albert Bates & Cynthia Bates
Gary Beach
Wyoming Dept. of Environmental
Quality - Land Quality Division
Janice Bellipanni
David M. Berick
Environmental Policy Institute
Robert G. Beverly
Union Carbide Corp.
Ben Billings
Environmental Action of Colorado
David D. Billings
James Blackburn
Hall Bohlinger
Louisiana Nuclear Energy Div.
Bob Boland
U.S. Dept. of Energy
Wayne T. Boyles
City of Westminster, Colorado
Irene Bragg
Bonnie Braine
Clark Univ.
Eve M. Bratzler
Douglas W. Brendel
Stephen K. Breslauer
NUS Corp.
Jack Briggs
Gary Brobst
Arizona Public Service Co.
144
-------
H. Bryant Brooks
Tennessee Valley Authority
-Joyce Brooks
Stephen H. Brown
Wyoming Mineral Corp.
William S. Brown
Westinghouse Electric Corp.
Deborah K. Browne
Greenpeace Foundation
Dorie Bunting
Citizens Against Nuclear Threats
James W. Burch
South Carolina Nuclear Advisory
Council
Michael R. Buring
Reading (Pennsylvania) Utility
Paul F. Burmeister
Mid-America Coalition for Energy
Alternatives
Robert A. Buser
James E. Campbell
Sandia Laboratories
Thomas Cashman
New York State Department of
Environmental Conservation
Valerie Cassaday
James F. MacLaren Ltd.
Bob Catron
KLAK Radio
Maynard Chapman
Rocky Mountain Energy Summary
Thomas J. Charlton, Jr.
Wyoming State Planning Coordinator's
Office
Steve Chinn
David T. Clark
Kentucky Radiation Control Branch
H. Clyde Claiborne
Union Carbide Nuclear Div. - Office
of Waste Isolation
J. M. Cleveland
U.S. Geological Survey
Barbara Clunn
John C. Cobb, M.D., M.P.H.
Gov.'s Advisory Council on Science
and Technology, Colorado
Joseph C. Cocalis
U.S. Environmental Hygiene Agency
Jerry J. Cohen
Lawrence Livermore Laboratory
John T. Collins
U.S. Nuclear Regulatory Comm.
Frances R. Connor
Rocky Flats Monitoring Committee
J. Stewart Corbett
Chem-Nuclear Systems, Inc.
John P. Corley
Battelle Pacific Northwest
Laboratories
Thomas C. Crane
QIC Naval Nuclear Power Unit
Bert L. Crist
U.S. Dept. of Energy
Judy Danielson
American Friends' Service Committee
G. R. Davis
Atlantic Richfield Co.
Steven Davis
George D. DeBuchananne
U.S. Geological Survey
Edie de Chadenedes
People's Clinic, Boulder
Dale H. Denham
Lawrence Livermore Laboratory
145
-------
Jamieson K. Deuel
Deuel & Associates
James E. Dieckhoner
U.S. Dept. of Energy, Div. of Waste
Management
Fred A. Donath
Univ. of Illinois
Mike Doyle
Sara Janet Drake
Donald S. Duncan
Bechtel Inc.
Gary Echert
U.S. Dept. of Energy
D. A. Edling
Monsanto Research Corp.
Dan Egan
U.S. Environmental Protection Agency
David J. Ehrman
Office of Sen. Floyd Haskell
Douglas G. Elliott
Iowa Electric Light & Power Co.
Thomas D. English
Jet Propulsion Laboratory - NASA
Teresa Erickson
Colorado Public Interest Research
Group
V. G. Eschen
Will Evans
Margaret R. Farrell
Citizens Against Nuclear Threats
Donald J. Fehringer
U.S. Nuclear Regulatory Comm.
Joseph E. Fitzgerald, Jr.
U.S. Environmental Protection Agency
Trudi Foreman
Univ. of Colorado
Dr. Frederick Forscher
Energy Consultant & Chairman of GASP
Energy Committee
George M. France, III
Paul Frank
Dr. Stephen Freidland
Aerovironment Inc.
T. Fujii
Dennis Gallagher
Colorado Senate
Richard Gamewell
Lawrence P. Gazda
U.S. Environmental Protection Agency
W. S. Geiger
Wyoming Mineral Corp.
Paul A. Giardina
U.S. Environmental Protection Agency
John R. Giedt
U.S. Environmental Protection Agency
Stephen M. Goldberg
U.S. Dept. of Energy
Wendy J. Goldschmidt
N.Y. State Geological Survey
Marc W. Goldsmith
Energy Research Group, Inc.
Antoinette Gomez
Boulder Mobilization for Survival
Mary Floy van den Berg Green
Boulder Mobilization for Survival and
Cactus Alliance
Priscilla C. Grew
California Dept. of Conservation
Annette Griggsmiller
E. Lee Gronemyer
Washington State Health Division
1U6
-------
Frank A. Guevara
Los Alamos Scientific Laboratory
Richard Guimond
U.S. Environmental Protection Agency
Richard H. Hansen
Nebraska Dept. of Environmental
Control
Scott Hansen
Univ. of Nebraska, Lincoln
Eugene Hanus, Jr.
Dr. William Harding
Drexel Univ.
Frances Harshaw
Harshaw Medical Physics Consultants
Ed Hartowicz
Dames & Moore
Ray P. Hattenbach
Phillips Uranium Corp.
M. Hawkins
Allied-General Nuclear Services
Albert J. Hazle
Colorado Dept. of Health
T. G. Hedahl
EG&G Idaho, Inc.
Frederick C. Heller
Gilbert/Commonwealth Assoc.
Wayne A. Henninger
Westinghouse Nuclear Energy Systems
Stephen Henry
Citizens' Action for Safe Energy
Patricia Hermann
Nina Hersh
Elton R. Hewitt
FMC Corp.
John A. Hicks
Univ. of Arizona Dept. of Radiation
Oncology
R. B. Hill
Atlantic Richfield Co.
Norman Hilberry, Ph.D.
Arizona Atomic Energy Comm.
William Holcomb
U.S. Environmental Protection Agency
Mary Hubbard
Rayford Huggins
Colorado Nuclear
Judith Hurley
Boulder Mobilization for Survival
and Cactus Alliance
Charles T. Illsley
Rockwell International, Rocky Flats
Ellen Islauer
Boulder Mobilization for Survival
and World Citizens
Ahren Jacobson
Univ. of Louisville Radiation Center
Gerald A. Jacobson, D.V.M.
U.S. Environmental Protection Agency
Carl J. Johnson, M.D.
Catherine Johnson
Jefferson County Health Dept.
Dr. Judith H. Johnsrud
Environmental Coalition on Nuclear
Power
Donald Kardok
Colorado Daily
Paul T. Kay
Colorado Coalition for Science and
Industry
B. L. Kelchner
Rockwell International
147
-------
Donald S. Kell
Florida Dept. of Environmental
Regulation
Stephen K. Kent
U.S. Nuclear Regulatory Commission
Dr. K. S. Kim
United Engineers & Constructors, Inc.
Akihiko Kitano
Tokyo Electric Power Co.
David Klein
George Washington Univ.
Paul Krishna
Public Service Electric & Gas Co.
Bruce J. Kullen
Argonne National Laboratory
Noel Kurai
Union Oil Co.
Lenore Kuznick
Fusion Energy Foundation
Carolyn Landes
Farm Denver Center
David Landes
Farm Denver Center
Michael W. Lantz
Reynolds Electric and Engineering
Terry R. Lash
Natural Resources Defense Council,
Inc.
John Lathrop
Lawrence Livermore Laboratory
Philip C. LeClare
Ecological Analysts, Inc.
Joe 0. Ledbetter
Univ. of Texas
George W. Leddicotte
Florida Power & Light Co.
Jack W. Lentsch
Portland General Electric Co.
Cynthia Lepthien
Boulder Mobilization for Survival
Dr- John K. Lerohl
U.S. Nuclear Regulatory Comm.
Myron W. Levin
Rocky Mountain News
Stanley Lichtman
U.S. Environmental Protection Agency
Robert Lincoln
Landfill, Inc.
Richard A. Link
Rockwell International
Peter S. Littlefield
Yankee Atomic Electric Co.
Paul H. Lohaus
U.S. Nuclear Regulatory Comm.
W. A. Lochstet
Penn State Univ.
Arvin Lovaas
Colorado State Univ.
Leo M. Lowe
James F. MacLaren Ltd.
W. Roger Luhring
Nebraska Public Power District
Elizabeth H. McCarthy
U.S. Nuclear Regulatory Comm.
Tim McClure
Elizabeth McCrea
Mardie McCreary
Office of Colorado State Sen. Dennis
Gallagher
Norman H. MacKay
U.S. Dept. of Energy
148
-------
Stuart Madsen
Univ. of Texas
E. Magner
M. Magner
Florian Maldonado
U.S. Geological Survey
Martin G. Malsch
U.S. Nuclear Regulatory Comm.
Brad March
Office of Colorado State Sen.
L. Duane Woodard
James E. Martin
U.S. Environmental Protection Agency
Robert N. Mason
Henry D. May
U.S. Environmental Protection Agency
Larry Mehlhaff
Colorado Open Space Council and Colo-
rado Public Interest Research Group
Matthew Merry
British Nuclear Fuels Ltd.
Edward F. Miller, P.Ch.E.
Miller & Assoc.
Doyle L. Mitchell
Rockwell International
William H. Mitchell
National Conference of State
Legislatures
A. E. Morrison
Gardinier, Inc.
H. W. Morton
Nuclear Safety Associates
Philip W. Morton
E. F. Muller
Environmental Protection Service,
Canada
Colleen Murphy
Colorado Governor's Office
Anne Murray
New Mexico Legislative Council
Service
Stanley M. Nealey
Battelle Human Affairs Research
Centers
Regis M. Nicoll
Tennessee Valley Authority
Donald H. Nielson
State Science Advisor (Utah)
Neil A. Norman
Bechtel National, Inc.
Paul D. O'Brien
Sandia Laboratories
Herbert R. Oakley
Chem-Nuclear Systems, Inc.
J. Bruce Owen
Dow Chemical Co.
G. C. Owens
Rockwell Hanford Operations
Larry C. Oyen
Sargent & Lundy
M. S. Ozker
Detroit Edison Co.
Richard Park
NCRP
Alexis Parks
Jerry A. Partridge
Hanford Engineering Development
Laboratory
Kathryn Partridge
Joel D. Patterson
Middle South Services, Inc.
Philip Paull
Vermont Public Service Board
11*9
-------
C. B, Pearson
Colorado Public Interest Research
Group
William R. Pearson
U.S. Nuclear Regulatory Commission
Michael P- Pervich
"st Lt. Alan L. Peterson
U.S. Environmental Hygiene Agency
Harry J. Pettengill
U.S. Environmental Protection Agency
Richard A. Petzke
Public Service Company of Colorado
Thomas W. Philbin
Ecological Analysts, Inc.
Roy G. Post
Univ. of Arizona
Terry L. Poulos
Colorado Nuclear
Harold A. Powers
Ho"fle.stake Mining Co.
Hobftr-f W. Powitz, Ph.D.
National Environmental Health Assn.
Henry C, Raibourn
Karen H. Rasmussen
Gulf Mineral Resources Co.
Lyle A. Rathbun
Petrotomics Co.
Mike Raudenbush
John L, Razor
Nuclear Engineering Co.
Terry F. Rees
U.S. Geological Survey
Elizabeth Richardson
Rocky Mountain Energy
Doreen Richmond
D. C. Ridinger
Newmont Services Ltd.
Sally Rodgers
Friends of the Earth/Clearing House
for Environmental Action
John C. Rodgers
Los Alamos Scientific Laboratory
Mary Rogers
U.S. Environmental Protection Agency
William L. Rogers
Gulf Mineral Resources Co.
Dr. Srinivas R. G. Rao
Oak Ridge Nat'l. Lab./Union Carbide
Wyatt M. Rogers, Jr.
Quality Development Associates, Inc.
Carol Rothman
American Friends Service Committee
Jim V. Rouse
Envirologic Systems, Inc.
Robert J. Rushton
Rockwell International
Jack Russel
U.S. Environmental Protection Agency
Dr. Daniel P- Ryskiewich
CIBA-GEIGY Corp.
Charles F. Sanders
Westinghouse NFD
Joseph F. Sawyer
Joan Schaum
Colorado Public Interest Research
Group
Keith J. Schiager, Ph.D.
Univ. of Pittsburgh
William A. Schimming
CF Chemicals, Inc.
Henry C. Schroeder
U.S. Environmental Protection Agency
150
-------
Jeanne J. Schwendinger
Schwendinger Associates, Inc.
Richard B. Schwendinger
Schwendinger Associates, Inc.
Michael L. Scott
Office of the Speaker, State of Texas
Mary C. Sell
William A. N. Severance
E. I. DuPont de Nemours and Co., Inc.
Paul D. Shaheen
Office of Rep. Timonthy E. Wirth
Vee J. Sharp
Utah Legislature
Heyward G. Shealy
South Carolina D.H.E.C.
R. L. Shoup
Union Carbide Corporation—Nuclear
Division, Office of Waste Isolation
Robert Shropshire
Power Authority, State of N.Y.
Melvin J. Sires, III
U.S. Dept. of Energy
Harry W. Smedes
U.S. Geological Survey
David S. Smith
U.S. Environmental Protection Agency
James M. Smith, Jr-
General Electric Co.
Paul B. Smith
U.S. Environmental Protection Agency
Randall F. Smith
Battelle Human Affairs Research
Centers
Andrew Snow
Earth
Don Snow
Wyoming Outdoor Council
David T. Snow
Arthur J. Soinski
California Energy Resources Conser-
vation & Development Commission
Joseph K. Soldat
Battelle-Northwest
Harvey F. Soule
U.S. Dept. of Energy
Richard Spengler
Cpt. Steven J. Stone
U.S. Environmental Hygiene Agency
Gerald Stookey
Justice and Peace Office,
Catholic Pastoral Center
Else-Marie Storm
Laurence Storm
Edward G. Struxness
Oak Ridge National Laboratory
George L. Stukenbroeker
NL Industries, Inc.
Anice C. Swift
Univ. of Colorado Environmental
Center
Jerry J. Swift
U.S. Environmental Protection Agency
Christopher Taaffe
Boulder Mobilization for Survival
D. M. Talbert
Sandia Laboratories
Ronald A. Taylor
Environment Reporter - BNA
Lawrence P. Terrell
Gorsuch, Kirgis, Campbell, Walker &
Grover
Warren T. Thompson
Univ. of Texas
151
-------
Beverly Hanna Thorpe
Ontario Ministry of the Environment
Roy E. Tomlinson
Exxon Nuclear
Dr. S. V. Topp
DuPont Savannah River Laboratory
Jeff Tracy
Colorado Public Interest Research
Group
Juan R. Velasquez
Phillips Uranium Corp.
Wayne J. Viator
Earth
Milo D. Voss
Iowa State Univ.
H. Clyde Walker
Sandia Laboratories
Jim Walker
John L. Warren
Los Alamos Scientific Laboratory
Rose Warren
Dr. Stephen R. Watson
Decisions & Designs, Inc.
Clifford L. Weaver
Ross, Hardies, O'Keefe, Babcock &
Parsons
George Wehmann
Ford, Bacon, Davis
Dr. Jonathan J. Weiss
Decisions & Designs, Inc.
Jim Wells
U.S. General Accounting Office
Sally Westcott
Boulder Mobilization for Survival
Haven Whiteside
U.S. Senate Committee on
Environment & Public Works
G. D. Whittier
Florida Power & Light Co.
Larry Wilkins
G. E. Wilkinson
Gardinier, Inc.
Judy Wilkinson
Boulder Mobilization for Survival
David C. Williams
Americans for Rational Energy
Alternatives
Brian Wrenshall
Jim Wolf
Wyoming Dept. of Environmental
Quality - Land Quality Div.
Theodore Albert Wolff
New Mexico Environmental Improvement
Agency
Warren W. Wood
U.S. Geological Survey
David Young
Harold Young
Roy Young
Tolford R. Young
Sierra Club
Ilene Younghein
Citizens' Action for Safe Energy
152
*U.S. GGVILW
1978 U-720-33S/6096
------- |