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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)

JULY 17,2001

COMMENT 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)

JULY 17,2001

By the Radiation and Public Health Project
New York, NY


Principal Author:
Joseph Mangano, MPH, MBA, National Coordinator
(718) 857-9825

Research Associates

Jay M. Gould, PhD, Director
Ernest J. Sternglass, PhD, Chief Scientist
Jerry Brown, PhD
William McDonnell, MA
Marcia Marks, ACSW, LCSW
Janette Sherman, MD
William Reid, MD

TABLE OF CONTENTS

A) Executive Summary
B) Comments on the Generic Environmental Impact Statement
C) Responses to NRC Comments in the Generic Environmental Impact Statement
D) Comments on other Health-Related Topics
Appendices
1. RPHP Recent Professional Publications
2. Rhabdomyosarcoma and Its Link with Radiation
3. Mechanism of Nuclear Radiation Injury
4. Risk from Low-Dose Radioactive Nuclides
5. Radioactive Strontium-90 (Sr-90) in Baby Teeth
6. Nuclear Radiation and Childhood Cancer
7. The Relationship between PicoCuries and Dose in Millirems
8. Statement of Dr. Sidel and Dr. Geiger on the baby teeth study 
References 


EXECUTIVE SUMMARY

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 5 (GEIS).

This information 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.

A. General

1.     Need 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.

  • Electric utilities 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.

  • The nuclear industry has declared a goal of building 50 new U.S. nuclear reactors.

2.     Current 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 reactors.

  • 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.

3.     RPHP Information on In-body Levels of Radiation and Cancer Risk

  • The Radiation 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.

  • During the 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.

  • In Suffolk 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.

  • Results of the baby teeth study have been published in three peer-reviewed medical journals.

B.     Radiation and Childhood Cancer in Miami-Dade County

1.     Turkey 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:

  • The Turkey 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 Mile Island.

  • The highest average Sr-90 concentration in five U.S. states has been documented in 86 baby teeth from persons born after 1979 in Miami-Dade County.

  • 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.

2.    The 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.

  • The cancer 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.

  • Annual rises and declines in cancer incidence in Miami-Dade children under age five match those in radiation detected in local precipitation.

  • Infant mortality 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 1.2%.

  • 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).

C.     NRC's 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.

D.     Recommendations

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 samples.

  • 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 health.

  • 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.

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