The foillowing is the final
draft of RPHP Comments on DRAFT REPORT AND SUBMISSION OF NEW
INFORMATION GENERIC ENVIRONMENTAL IMPACT STATEMENT, SUPPLEMENT
5 REGARDING FLORIDA POWER AND LIGHT COMPANY’S PROPOSAL TO
THE U.S. NUCLEAR REGULATORY COMMISSION TO RE-LICENSE THE TURKEY
POINT 3 AND 4 REACTORS (NUREG-1437, SUPPLEMENT 5)
ON DRAFT REPORT
AND SUBMISSION OF NEW INFORMATION
ENVIRONMENTAL IMPACT STATEMENT, SUPPLEMENT 5
REGARDING FLORIDA POWER AND LIGHT COMPANY’S PROPOSAL
TO THE U.S. NUCLEAR REGULATORY COMMISSION
TO RE-LICENSE THE TURKEY POINT 3 AND 4 REACTORS
(NUREG-1437, SUPPLEMENT 5)
the Radiation and Public Health Project
New York, NY
Joseph Mangano, MPH, MBA, National Coordinator
Jay M. Gould,
Ernest J. Sternglass, PhD, Chief Scientist
Jerry Brown, PhD
William McDonnell, MA
Marcia Marks, ACSW, LCSW
Janette Sherman, MD
William Reid, MD
The Radiation and
Public Health Project (RPHP) welcomes the opportunity to comment
and submit new and significant information to the U.S. Nuclear
Regulatory Commission (NRC), Draft Report, Generic Environmental
Impact Statement for License Renewal of Nuclear Plants, Supplement
is being submitted with reference to the Turkey Point 3 and 4 nuclear
reactors, located in south Miami-Dade County, Florida. However,
RPHP findings of a link between in body radiation levels and increased
childhood cancer risk should be considered in the NRC’s review
of all applications to extend the operating licenses of aging nuclear
power plants throughout the United States.
to protect public from radioactive emissions from nuclear reactors
From 1980 to
1999, electricity generated from America's nuclear power reactors
increased from 248 to 727 million gigawatt-hours.
have requested that the U.S. Nuclear Regulatory Commission
(NRC) extend the operating licenses of 43 of 103 aging nuclear
reactors for 20 years beyond the existing 40-year license period.
industry has declared a goal of building 50 new U.S. nuclear
Health Risk Assessment Policies are Deficient
The NRC requires
that electric utilities measure emissions of radioactive chemicals
from nuclear reactors, and levels of these chemicals in the
air, water, soil, and food. If these levels fall below federal "permissible
limits," the NRC presumes there is no detectable health risk
to residents living near reactors.
The NRC does
not require environmental measurements of Strontium-90, one
of the most toxic radioactive chemicals emitted by nuclear
The NRC, electric
utilities, and public health departments have never measured
levels of Strontium-90 or any other radioactive chemical in
bodies of persons living near nuclear reactors.
The NRC, electric
utilities, and public health departments made no studies of
cancer in persons living near nuclear reactors from 1957 to
1990. The only study, by the National Cancer Institute in 1990,
made a controversial conclusion that nuclear reactors did not
affect local cancer rates, a result that would be expected
based on the methodology used.
- The NRC has
approved the first five applications for extending the operating
licenses of nuclear reactors an additional 20 years without examining
the possible impact of federally-allowed emissions of radioactive
chemicals on local cancer rates.
Information on In-body Levels of Radiation and Cancer Risk
and Public Health Project's (RPHP) baby teeth study ("Tooth
Fairy Project"), which measures Strontium-90 (Sr-90) in baby
teeth (and thus in their bones) is the first to study in-body
radioactivity levels of persons living near nuclear power reactors
and in more remote locations. Proximity to nuclear power reactors
is one of several controls built into the baby teeth study.
1950s and 1960s, concerns about increased Sr-90 levels in St.
Louis baby teeth, which corresponded to increased childhood
cancer and leukemia rates, were factors in President John F.
Kennedy's decision to sign the 1963 Partial Test Ban Treaty,
which ended all atmospheric testing of nuclear weapons.
RPHP has collected
over 3000 teeth, and has measured Sr-90 levels in about half
of these. Current concentrations of Sr-90 near nuclear power
plants have risen to levels similar to those measured in St.
Louis children born in 1956, during the period of above-ground
atomic bomb testing in Nevada.
County New York, which is within 60 miles of eight nuclear
power reactors, RPHP has analyzed over 500 teeth and documented
a 40.0% rise in average Sr-90 concentrations and a nearly similar
48.9% rise in leukemia and cancer among children under 10 from
the early 1980s to the mid-1990s.
the baby teeth study have been published in three peer-reviewed
and Childhood Cancer in Miami-Dade County
Point operations and environmental radioactivity
In March, 2001,
RPHP released a Special Report on the Florida Baby Teeth Study,
entitled Environmental Radiation from Nuclear Reactor’s
and Increasing Children’s Cancer in Southeastern Florida,
(the "Florida Report") which noted that:
Point 3 and 4 nuclear reactors located approximately 25 miles
south of Miami have been operating since 1972 and 1973, respectively.
From 1972 to
1993, Turkey Point reported the emission of 6.69 trillion picocuries
of radioactive chemicals (including Sr-90) into the air, nearly
half of the total released during the 1979 accident at Three
average Sr-90 concentration in five U.S. states has been documented
in 86 baby teeth from persons born after 1979 in Miami-Dade
- For persons
born in Miami-Dade during the period 1988-94, the average Sr-90
level in baby teeth was 21.5% greater than the average for the
seven previous years.
Link Between Radiation and Cancer in Southeastern Florida Children
The rate of
childhood leukemia and cancer in Miami-Dade County plus four
counties to its north has risen to become one of the highest
in the U.S., suggesting a link with the area's high Sr-90 levels.
incidence rate in Miami-Dade children under age ten rose 6.8%
from 1981-87 to 1988-94, an increase roughly comparable to
the Sr-90 trend.
and declines in cancer incidence in Miami-Dade children under
age five match those in radiation detected in local precipitation.
declined 19.1% in Dade and Broward Counties in 1983-84, when
Turkey Point's defective steam generators were being replaced
and the reactors were mostly inactive. The following two years,
when the reactors re-started, the infant death rate increased
Cancer in children
under age 10 in Miami-Dade and four other southeastern Florida
counties (the region where four nuclear reactors are located),
rose 35.2% from the early 1980s to the late 1990s, but declined
8.1% in the rest of the state (which has only one nuclear reactor).
Environmental Impact Statement is Flawed
The NRC has prepared
a draft Generic Environmental Impact Statement, Supplement 5 (GEIS),
on the application to extend the Turkey Point licenses, as required
by law. The NRC's conclusion that the application represents no
threat to local health included numerous comments about RPHP research
that are not based in fact or are misleading.
The GEIS statement
that the baby teeth study represents no new information on
the issue of radiation and public health does not acknowledge
that the research is the first to measure in-body radioactivity
specifically near nuclear power reactors.
The GEIS fails
to cite numerous medical journal articles documenting links
between radiation exposure from nuclear reactor emissions and
cancer, especially in children.
The GEIS does
not adequately address the evidence that the fetus and developing
infant are at significantly higher risk of cancer and brain
damage from low-level radiation that had been previously understood.
This evidence is presented in the 1990 report of the Committee
on the Biological Effects of Ionizing Radiation, National Research
Council (BEIR V), which concluded that there are no safe levels
of radiation exposure.
The GEIS asserts
that the doubling in cancer in the past half-century is not
due to any environmental cause, other than cigarette smoking,
failing to cite the considerable research documenting links
between cancer and environmental toxins like radiation. The
NRC ignores the rise in cancer rates among children, who do
not smoke and whose parents are smoking less than a generation
or two ago
The GEIS makes
no mention of the increased sensitivity of the fetus and infant
to radiation exposure.
By no longer
requiring Strontium-90 to be measured, either in environmental
samples or humans, it has been possible for the NRC to characterize
the radiation threat from the Turkey Point plant and all other
nuclear power reactors as "microscopic." In this way, the NRC
obscures the true magnitude of the threat to human life and
health presented by fission products released into the environment.
The Radiation and
Public Health Project recommends that several actions be taken
by the NRC in regard to the re-licensing process for Turkey Point,
and subsequent re-licensing applications for all reactors:
The NRC should
require that Sr-90 be once again measured in environmental
The NRC should
institute a program of measuring levels of radioactivity in
bodies of persons living near nuclear reactors, and should
publicly report its findings in a timely manner.
The NRC should
authorize periodic studies comparing in-body levels of radioactivity
with local rates of childhood and adult cancer and other diseases
susceptible to radiation exposure.
The NRC should
postpone a decision on extending the license of Turkey Point
and all other reactors until it has thoroughly evaluated all
available information, including recent reports and significant
research in progress, on nuclear reactor emissions and public
- The NRC should
include risks to health (i.e., links between local cancer patterns
and radioactivity in the environment and body) as a criterion
for extending licenses of existing nuclear reactors and for granting
future licenses to operate new reactors.