COMMENTS ON ENVIRONMENTAL IMPACT STATEMENT
The Radiation and Public Health Project (RPHP) is an independent, non-profit research and educational organization. The focus of RPHP's work is to assess the health effects of exposures to radioactive chemicals released into the environment by nuclear weapons tests and nuclear reactor operations. Founded in 1985, RPHP has assembled an interdisciplinary team of professionals from the fields of radiation physics, toxicology, epidemiology, medicine, and statistics. RPHP Research Assocaites have published numerous medical journal articles and books on the radiation health issue (see Appendix 1).
RPHP has documented substantial evidence linking environmental nuclear radioactivity with increased cancer risk. Perhaps the strongest evidence is the correlation of rising and declining levels of radioactive Strontium-90 in baby teeth with risk of childhood cancer in Long Island. The following comment outlines RPHP’s findings and considers implications of these findings, including the Florida Report, for the environmental impact of extending the operating license of the Turkey Point 3 and 4 reactors.
II. NUCLEAR REACTOR EMISSIONS AND HEALTH
More Reactors Produce More Radioactivity. Currently, 103 nuclear power reactors (at 72 sites) are operating in the U.S., producing about 20% of the nation's electricity. (1) About two-thirds of Americans, or approximately 190 million people, live within 100 miles of at least one nuclear reactor. Operating utilities have permanently closed a total of 22 reactors. In addition, 128 reactors that were proposed by utilities to federal regulators were later cancelled before commencing operations. (2)
Startup of new reactors and increased use of existing ones have caused the generation of electricity from reactors to nearly triple (248 million to 727 million gigawatthours) from 1980 to 1999. (1) Present trends suggest that use of nuclear power reactors may proliferate in the future. The U.S. Nuclear Regulatory Commission (NRC) has received applications to extend the licenses of 43 reactors from the current life span of 40 years to 60 years. In addition, at its annual meeting in May 2001,the Nuclear Energy Institute announced a goal of starting 50 new nuclear reactors in the U.S. over the next 20 years.
Problems Presented by Aging Reactors. Increasing use of aging nuclear reactors raises environmental health issues that need to be addressed, namely:
The focus of RPHP's work is primarily issue #1, health effects of routine, federally-permitted emissions of radioactive chemicals into the environment.
Government Assessment of Risks to Health is Deficient. Because radioactivity can damage human health, an accurate assessment of risk to the public is warranted. However, current regulatory policies do not include an adequate risk assessment for low-dose exposures. The U.S. Nuclear Regulatory Commission has approved the first five applications for reactor license extension, with no consideration of disease rates, including cancer, in persons living closest to reactors.
RPHP has investigated health effects of exposures to reactor emissions from the Turkey Point reactors to residents of Miami-Dade County and has published its findings in the Florida Report, a copy of which is being submitted to the NRC along with these Comments.
III. HEALTH STUDIES HAVE BEEN LIMITED
Reactor Operations Release Many Cancer-Causing Chemicals. Nuclear reactors employ fission of uranium atoms to generate electricity. The fission process creates over 100 radioactive chemicals not found in nature, which may damage the immune, genetic, and hormonal systems. These products include strontium, plutonium, iodine, and other carcinogenic isotopes. The only other source of these man-made chemicals is nuclear weapons explosions. Most fission products generated by reactors are contained as radioactive waste, but some is emitted into air and water.
The NRC requires that electric utilities measure emissions of radioactive chemicals from nuclear reactors, along with levels of these chemicals in air, water, soil, and food. It does not require environmental measurements of Strontium-90, one of the most toxic radioactive chemical produced by reactors.
Health Studies Are Lacking. The NRC does not conduct or authorize health studies of radioactive chemical emissions or environmental levels. If levels fall below the federal "permissible limit," the NRC makes a presumption that public health is unaffected.
There has been a dearth of scientific, peer-reviewed studies evaluating disease rates near U.S. nuclear power plants since the first reactor opened in 1957. Only one national study has been done. In 1990, at the request of Senator Edward M. Kennedy, the National Cancer Institute (NCI) published data on cancer near nuclear plants.
The report concluded there was no connection between radioactive emissions and cancer deaths, because the methodology compared cancer rates in counties containing nuclear reactors with "control" counties often situated nearby. As a result, there was no significant difference between counties with nuclear plants and the "control" counties. However the NCI did find that cancer rates near many reactors rose after reactor startup. (3) Since 1990, no federal agency, including the Environmental Protection Agency and Nuclear Regulatory Commission, has undertaken any studies of disease rates near nuclear power plants.
The study concluded no evidence existed of a radiation-cancer link despite the rises in cancer near many reactors after startup. The NCI also indicated that there was no difference in cancer rates between "exposed" counties with reactors and "unexposed control" counties. However, many control counties were located close to reactors, some as close as 30 to 50 miles.
Childhood cancer is generally believed to be one of the diseases most affected by radiation exposure. In the U.S., only two medical journal articles have documented elevated childhood cancer near nuclear power reactors. (4) (5) By contrast, there are at least 11 articles on childhood cancer in areas near various power plants in the United Kingdom (6-16), plus additional studies in other nations.
In-Body Measurements Are Lacking. The lack of health studies near American nuclear reactors is complemented by a lack of measurements of in-body levels of radioactivity for persons living near nuclear reactors. Government-supported programs to measure Strontium-90 in St. Louis baby teeth (17) and in New York City and San Francisco bones (18) were terminated in 1976 and 1982, respectively. Both were designed to measure the effects of bomb test fallout rather than nuclear power reactor emissions.
IV. SR-90 IN BABY TEETH AND CANCER RISK
RPHP Baby Teeth Study. RPHP addresses the shortage of information on radiation's health effects by documenting radioactivity levels in the human body and comparing them with cancer and other health patterns.
RPHP researchers are conducting the first-ever national baby teeth study that measures radioactivity in the bodies of persons living near nuclear power reactors and in more remote locations. In 1996, RPHP launched the Tooth Fairy Project, which uses the same methodology of calculating levels of Strontium-90 (Sr-90) in baby teeth employed in St. Louis during the 1950s and 1960s. The chemical enters baby teeth through the mother's diet during pregnancy, from what is stored in the mother's bones, and through the infant's diet during the first year of life.
In addition to being a known carcinogen, Sr-90 is also a marker for the 100+ radioactive chemicals that are released in nuclear reactor operations, but it is a critical one. Like calcium, Sr-90 attaches to the bone and teeth when it enters the body, where it remains for many years due to its slow rate of decay (half-life of 28.7 years) and the slow rate of removal of calcium in bone, typically with a 5-10 year half-life in adults and 2 years in infants. Sr-90 kills and impairs bone cells, and penetrates the bone marrow, in which the white blood cells critical to immune function are formed, making it a risk factor for all cancers.
Of all man-made radioactive chemicals, Sr-90 was the one that caused the greatest health concern during the atmospheric atomic bomb test years in the 1950s and 1960s. In 1956, Presidential candidate Adlai Stevenson remarked that Sr-90 was "the most dreadful poison in the world." (19) The growing presence of Sr-90 and other radioactive chemicals in the diet and bodies of Americans contributed to President John F. Kennedy’s decision to sign the Partial Test Ban Treaty in 1963.
To date, RPHP has collected over 3000 baby teeth, mostly from the states of California, Connecticut, Florida, New Jersey, New York, and Pennsylvania. Strontium-90 concentrations have been measured in nearly half (1463) of these teeth by Radiation Environmental Management Systems Inc. (REMS), an independent laboratory in Waterloo, Canada.
The average current concentration of Sr-90 is similar to that in St. Louis in 1956, in the midst of the period of atmospheric nuclear weapons testing. Results of the baby teeth study have been published in three peer-reviewed medical journals. (20-22)
Link Between Sr-90 in Teeth and Childhood Cancer - Long Island. The largest number of teeth (563) has been measured for residents of Suffolk County New York, site of the Brookhaven National Lab and an area surrounded by eight nearby reactors in Connecticut, New Jersey and New York. Results show that the average level of Sr-90 has steadily increased 40.0% from the early 1980s to the mid-1990s. Because U.S. above-ground bomb testing ceased in the early 1960s, and old bomb fallout is decaying steadily, this trend indicates that a current source of radioactive emissions is contributing to the buildup of Sr-90 in teeth. This source can only be nuclear reactors, since the last atmospheric bomb test took place in China in 1980.
During the same time period, the rate of cancer diagnosed in Suffolk County children less than 10 years old steadily rose a nearly identical 48.9%. (23) The data support the theory that exposure to radioactivity increases the risk of cancer, especially in young persons.
Southeastern Florida - Highest in Sr-90, Highest in Childhood Cancer. In southeastern Florida, the four reactors at Turkey Point and St. Lucie reported releases of 10.39 trillion picocuries of radioactivity (only chemicals with a half-life over eight days) into the air from 1970-93. A picocurie is a measure of radioactivity, representing one-trillionth of a curie. About two-thirds of the southeastern Florida total (6.69 trillion) originated from Turkey Point, nearly one-half of the 14.20 trillion picocuries emitted during the Three Mile Island accident in March 1979. (24) The Turkey Point plant is located 25 miles south of Miami; its two reactors began operation in 1972 and 1973.
Fewer baby teeth have been tested from persons born in Miami-Dade County than in Long Island. The average Sr-90 levels for 86 county residents born after 1979 is 2.21 picocuries of Sr-90 per gram calcium, making Miami-Dade the area with the highest Sr-90 content in the U.S. measured to date by the baby teeth study, (i.e., the five states for which at least 20 teeth have been measured).
The average concentration of Sr-90 in Miami-Dade baby teeth increased 21.5% from 1981-87 to 1988-94. During this period, the cancer incidence rate in Miami-Dade children under age ten rose 6.8%. Here, Sr-90 and childhood cancer are rising together, as was found in Suffolk County NY, implying a cause-and-effect relationship.
More teeth are needed from Miami-Dade to undertake a more sophisticated analysis. This number will be achieved by the year 2002. In the three months since the presentation of initial tooth study results in the Florida Report on March 28, 2001, the number of teeth submitted from Florida has jumped from 239 to 542, most of them from the Miami-Dade area.
The childhood cancer situation in southeastern Florida is worsening. Since the early 1980s, the cancer incidence rate in the area has risen +35.2%; but in all other parts of Florida, the rate has fallen by -8.1%. The five southeastern Florida counties are flanked by the two St. Lucie reactors to the north and the two Turkey Point reactors to the south. There is only one other nuclear reactor in the rest of the state (Crystal River, 70 miles north of Tampa). These divergent trends provide additional reason to fully study the radiation-cancer link in Miami-Dade.
Link Between Radioactivity in Miami-Dade Precipitation and Childhood Cancer. Even before additional teeth are tested, independent evidence exists for a radiation-childhood cancer link in Miami-Dade. The U.S. Environmental Protection Agency has reported levels of "gross beta", or radioactive chemicals that emit beta particles, in Miami precipitation for more than a decade. RPHP discovered that trends in gross beta levels are followed by similar trends in cancer incidence for Miami-Dade children under five just three years later (Figure 1). This is an important piece of evidence in support of a cause-and-effect relationship and of an environmental radiation-childhood cancer link.
V. IMPROVED INFANT AND CHILD HEALTH AFTER REACTOR SHUTDOWN
In 2000, RPHP staff published an article documenting that in five of five areas near closed nuclear power plants, the infant death rate improved dramatically in the first two years after closing. In addition, rates of birth defects and childhood cancer also improved. (25)
Soon after Turkey Point started operations, Florida Power and Light staff began to have trouble with corrosion and tube leaks in the steam generators. Turkey Point 3 and 4 were closed, one after the other, to repair the generators. The NRC GEIS notes that, "If primary-to-secondary leakage occurs, then these can also be unmonitored radioactive airborne releases from the secondary steam systems of each unit" (2-11).
During the period 1983-84, when radioactive exposures to fetuses and infants were greatly reduced,infant mortality in Miami-Dade and Broward Counties fell 19.1% from the previous two years, significantly different from the 6.4% national drop. In 1985-86, when the reactors had returned to full power, the infant mortality rate increased 1.2%, while it fell 4.3% in the U.S. These findings are consistent with research on other closed reactors.
Since atomic bombs were first manufactured and used during World War II, exposure to man-made fission products has been a critical environmental health issue. The relative novelty of these chemicals in the environment underscores the need for thorough and objective studies.
Since the conclusion of the Cold War a decade ago, nuclear weapons are no longer tested by the United States. However, electricity production from American nuclear power reactors has reached an all-time high, and the nuclear industry is now considering a large-scale expansion of new nuclear power plants in the U.S. These developments indicate that efforts to protect humans from the potentially harmful effects of exposure to radioactive emissions in the environment will be critical.
Southeastern Florida has Sr-90 concentrations in baby teeth childhood cancer rates well above national averages. Both Sr-90 and childhood cancer are rising at roughly the same rate locally. There is a link between radioactivity in precipitation and childhood cancer in the region. And local infant mortality declined sharply when Turkey Point closed down in the early 1980s.
Thus, the need for additional study of the relationship between environmental radiation and cancer is essential. It is essential that this information should be considered by the U.S. Nuclear Regulatory Commission in their review of the Florida Power and Light application to re-license the Turkey Point 3 and 4 reactors, and in all future licensure and re-licensure applications.