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I.dvarman, Assiiwarlt Geaaral NaMger for Btiical awl is stfl workd,ngon the earlia package ad may addmae the MU paper concurrentlywith the pravloua -. Yom ebuld receive an appropriate r8epcmae for both papera by abeut
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Aeaiatent General Ximager for llf.lita~Application Dear Gemral Grtrvae: you provideinformation upm which I a baas s reply, if nacoaeay. Major General, USA Mr. Lester glaback, AFRH
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James Morshall, Esq. De f2n:;e Nuclear Agency PALO ALTO, CA LII:. fj[jOl Edwin M. Zut,merrnan, Esq. 14 February, 1974 1. NRDC finds the “Draft Environmental Impact Statement, Clean Up, Rehabilitation, Resettlement of Enewetak Atoll -- Marshall Islands,” to be incomplete and inadequate. Furthermore, the proposed (preferred) clean up operation is totally inadequate to protect the health of “the Enewetak people from exposure to hct, particles of plutonium which carry The basis for these conclusionsa high risk of producing lung cancer. intended to be an integral part of these comments. 2. “Radiation Standards for Hot Particles,” was written in support of a petition by the Natural Resources Defense Council to the Environmental Protection Agency and the Atomic Energy Commission reapplicable to the internal exposure of man to insoluble alpha-emitti:-.g hot particles and (2) the establishment, with respect to such materials, of stdndards governing the maximum permissible concentrations in ai~ ar.d maximum permissible surface contamination le{’els in unrestricted are~.s. 30 The petition was filed with the AEC on February 14, 1974. It is totally irresponsible for the AEC Task Group on Recommendations for Clean Up and Rehabilitation of Enewetak Atoll to issue its report on “ June 19, 1974,-without acknowledging the serious implications of hct particles as detailed in our report. 4. It is NRDC’S position that the clean up of Enewetak should meet the standards summarized on pages 51-52 of our report’ (enclosure) .
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A REPORT ON THE INADEQUACY 017 EXISTING RADIATION PROTECTION STANDARDS RELATED TO INTERN;\L EXPGSURE OF hlAN TO INSOLUBLE PARTICLES OF PLUTONIU31 AND OTHER ALi’HA–EllITTING HOT PARTICLES.
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II plutonium Use and Public Health .............3 IV Calculating the Dose Due to Insoluble Alpha-Emitters . . 11 c The liot Particle Problem .............. 18 v Biological Data Related to the Cancer Risk from Insoluble Plutonium Exposure A The Geesaman Hypothesis B Related Human Experience VI Critical Particle Activity . A Exposure at Rocky Flats c Weapons Test Fallout. ............... 41 B Exposure of the General Public ........... 44 E As Low as Practicable Hearings ........... 50 VIII Summary of Recommendations ............... 51 Appendix A Radiation Standards Setting. Organizations and Appendix B Statement Submitted to Attorneys for Mr. Edward Gleason
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This report is written in support of a petition by Protection Agency (EPA)- and the Atomic Energy Commission protection standards ap~licable to the internal exposure of man to insoluble alpha .er,littlng hot particles and (2) the.- establisnment, witlh respect to such materials, of standards governing the maximum permissible concentrations in air and maximum permissible surface contamination levels in unBefore proposing modifications to existing radiation ~=~riew in the follor~ing section the qravity Of the public health concern as plutonium becomes a principal article of commerce in the n’uciear power industry. ~/ While much of this report foc’uses narrowly on plutonium-239, tne discussion is, nel.~ert~le~ess, gcrmaine to all raaionuclides in insoluble particles with a high specific activity. (The definition of specific activity and other technical terms in this repo~t are given in the Glossary) . The- justification for focusing on plutonium has been aptly stated by the International Commission on Radiological Protection (ICRP) : “the emphasis on plutonium is clearly a reflection of the qeneral consensus that, in terms of amount available, projected usage , extent of anticipated accidental human exposure, and radiotoxicity, plutonium is the most formidable radionuclide of Compounds of Plutonium and Other Actnides,” Pergamon Press,
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This is followed in Section 111 by a review of the specific radiation protection regulations that are in force in tl~e United Szdtes today and which are at issue. This is to be understood that, in this and subsequent sections, . it should be applied to all alpha-emitting radionuclides th~t meet the hot particle c~iceqia developed in this report. Before readinq Section 1111 those unfamiliar with the national and international organizations which have primary responsibility for recommending or establishing radiation protection standard~, may find it useful to read Appendix A, where these organizatiofis and their authority are reviewed.. Section IV-presents assumptions inherent in the existing radiation protection standards and identifies those assumpalpha-emitting particulate. The biological data which demonstrate that these assumptions are {appropriate when applied to hot particles are discussed in Section V. criteria that define a hot particle are developed in Section VI . Recommendations for exposure standards for hot particles I are then developed in Section VII and summarized in
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of support activities required both to provide raw fuel and to recover and recycle the uranium and”plutonium make up will be installed between 1970 and 2020 . Over the lifetimes of these plants this installed capacity could result in a cumulative flow of approximately 200 million kilograms of plutonium ++hrough the nuclear fuel cycle. In today’s commercial reactors, the plutonium is in oxide form, Puo~ . At various facilities in the nuclear fuel cycle, aerosols of- PU02 are released to the environment on a routine basis. In addktion, there are numerous points in the fuel cycle where accidents, particularly those associated with fire or explosions, can release significant amounts of Pu02 as aerosols that can be inhaled by man. .“ These small aerosol particles of Pu02 are highly radio-,, active. An appreciable fraction of th’e inhaled Pu02 particles are trapped in the deep respiratory tissue of the lung, where, because they are insoluble in human tissue,. 4/ Updated (1970) Cost-Benefit Analysis of the U. S. Breeder million megawatts (Mw) corresponds to 4000 nominal-size 5/ Some advanced ::eactors of the future may use fuel in carbide and nltride~ rather than oxide, form.
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Plutonium occurs in nature, althouqh in such small element . Plutonium is bred in nuclear reactors by the tia~ture of neutrons in uranium-238. To date, the nuclear weapons program has been the principal source of plutonium. ~lowever, it is anticipated that the commel-cial nuclear power industry will become the principal source of this material within the next two decades . In today’s commercial reactors plutonium is produced as a by-product in the production of As a result of the growth of the nuclear power industry, ~lutonium in the corimercial sector of the United States will be some 4.5 million kilograms by the year 2000 . Since ~iutonium, like uranium, can serve as a reactcr iuei, botlh are ~ecovered from spent reactor fuel in anticipation that they will be’ recycled. The reactor together with the variety 2/ The ratio of the concentrations of Pluton~~~ -239 to Chapter VI, The Chemistry of Actinide Elements, Methuen and ~/ Environmental Statement, Liauid Metal Fast Breeder Reactor
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interlse radiation dose to the surrounding lunq tissue. agents known to man. A machinist of plutonium metal carried the puncture wound i.n the palm of his hand. Within the four it ;,?2sexcized, it prcduced a nod-~le which displayed precancerous changes~. There is little doubt fromcxperimental animal st’~dies that inhaled pl’~tonium is one of the most potent respiratory carcir,ogens known. There is experimental and observed evidence that plutonium concentrations in the lungs of doqs as 1cT47as 0.2 microcuries (3 micro200 million kilograms of plutonium represents a flow of over @7 cancer doses, a staggering number which, as will be cancer doses by several orders of magnitude. The persistence of this toxic mater;al, once the environment, is measured in terms of thousands 6/ Lushbauch, C.C. and J. Langham, “A Dermal Lesion from ~mplant”ed Plutonium,” Archives of Dermatology, 86, October 7/ There are 0.061 curies per gram of plutonium-239. fro-tenths of a microcurie of plutonium-238 would have a mass of only 0.01 ,micrograms since plutonium-238 has a much higher specific activity, 17.47 curies per gram.
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fuel cycle will be plutonium-239 which has a 24,400 year halflife. In other words, in 240,000 years the inventory of this due to natural radioactive decay. This mattrial must b.e isolated from the environment in perpetuity. Radiation exposure standards have been established because radiation is known to produce cancer and genetic mutations in individuals irradiated. The mutations can in tur”n cause genetic defects in subsequent generations. The intent of the exposure standards is to limit this biological shown to be related to the radiation dose. The higher tlhe dose the greater the effect. Therefore, the primar~j radiadose; This primary standard is generally referred to as the maximum permissible dose and is given in units of rek\yr. lie shall discuss the nature of this unit subsequently. . An individual can be exposed to radiation from sources that are external to his body as, for example, an X-ray machine or from radionuclides which emit X-ray like radiation deposited on the ground (this occurred with fallout from nuclear weapon tests) . Alternately, an individual can be
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irradiated by internal sources; that is, by radionuclides incorporated in body tissues. These radionuclides gain trmr,inated food or water. Once inside they behave like their accumulates in the thyroid gland in the same fashion as iodine , and radioactive strontium or calcium accumulate bone similar to their naturally occurring non-radioa dosage to the thyroid qland that is many times larger than that to the other organs or to the whole body, and the radioactive strontium and ca}cium will mainly irradiate the Because of the uneven distribution of radionuclides in the body organs , radiation exposure standards have been developed not yust for the whole body, but also for individual org~ns. In this report we will be referr+ng to the maximum permissible whole body and lunq doses. Largely as a matter of convenience, secondary or derived radiation standards have been developed. These secondary standards, which limit radionuclide concentrations or organ burdens, are often more easily employed than the primary dose standards. We shall examine two secondary standards in this
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is the total ar,ount an average size man permissible lung burden (MPLB) and the 02 a given radionuclide in the lung of that will result in the lung being irradiated at the maximum permissible lunq dose (MPLD) . The MPCa is the concentration in air that will result in an averaae adult mlale obt=ining. a LIPLB and hence a 31PLD by breathing the air. It is important to recognize that the MPLD is the and are specific it applies to all radionuclides and c.or a radionuclide. These derived standards are related CO the biological properties of a radionuclide and to the fcrm Gf radiation ik emits. Table I lists the existing exposure standards for employees of the nuclear industry that apply to Pu-239 in insoiu.ble of the Internatic:lal Commission on Radiological Protection (ICRP)~ the National Council on Radiation Protection and Measurements (NCRP)9, and the Federal Radiation Council 8/ ICRP Publication 9, Recommendations of the International Pergamon Press, New York, 1966, p. 14. — 9\ NCRP Report No. 39, Basic Radiation Protection Criteria,
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(FRC)lO. The MPCa is included in the ICRP recommendations and is also an AEC radiation standard . Of the standards ;!c,,vever,this MPCa corresponds to that tabulated in ICRP Publication 213 which is derived on the basis of the MPLD listed in Table I. The MPLB is also derived on the basis of tions of ICRP, NCRP, the guidelines of FRC, or the AEC in AEC regulations) is consistent with the MPLD and MPLB. In Table I the MPLD applies to all forms of ionizing radiation. The MPLB and MPCa apply specifically to Pu-239 in insoluble 10/ FRC Report No. 1, OP. cit., !?. 38. The FRC has been ll\,’ICRP Publication 2, Report of Committee II on Permissible— Dose for Internal Radiation, pergamon press, New York, 1960. =llowing Acute Inhalation of Hiqhly Insoluble Pu02,” Health 15/ The MPLB could apply to most other alpha-emitting— radionuclides with lonq half-lives, since the alpha particle energies do not differ appreciably from the Pu-239 alpha
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that Apply to Pu-239 in Insoluble Form* *Note : See Glossary for definitions of symbols. The exposure guidelines for Pu-239 that apply to nonoccupational exposure of the general public are tabulated in Table II. Two guidelines are applied here. One is for the limiting exposure to an individual and the other is for the average exposure of a population sample. These two guidelines differ by a factor of 3. The ICRP recommendations include only the ,quidelines for individuals. The MPLD values within the,. p~rentheses in Table II correspond to tlfe latest recommendation have not, -at this tirtle,been incorporated into either the AEC or EPA regulations.
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Existing Exposure Guidelines for Non-Gcctipational Exposure * The MPLD values in parentheses refer to recommendations of tie NCRP. The MPLB and Iv. Calculating the Dose Due to Insoluble Alpha-Emitters The purpose of this section is to examine the assumptions in’the radiation standards above that ar~ inappropriate when applied to insoluble alpha -emitting particulate such as aerosols of Pu02. The assumptions are introduced through a review of basic definitions of radiation dose-and the factors used to calculate the dose. A. The Dose Equivalent When an X-ray or the radiation emitted by a radionuclide passes through tissue it transfers energy to the cells in
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the molecule of the cells; for example, such a chemical change could be a mutaticn in a cene. I’he rad..dtion dose is actually a measure of the enerqy transferred to or absorbed bj’ the tissue. The basic unit of dGse is the rad (one rad represents the absorption of 100 ergs of In addition to X-rays, radionuclides emit qamma rays particles (helium nuclei). In radiobiological experiments, it was determined that, while these various types of radiation produced the same biological effects, such as cancer, the magnitude Of c.ne effect was not the same per raci. For produce roughly 10 times as many cancers as 100 rad of X-rays . Moreover, it was found &hat because of the special ~“ay in which Pu-239 deposits in the bo,ne, its alpha particles were 5 times more effe:t~~-e in ~rod~cirig ‘bone cancer than the alpha particles from radium . TO account for these differences in the magnitude of the observed effects at” the same absorbed ,< dose in rad, the maximum permissible dose limits are given in rem rather than rad. The MPLD is given in rem in Tables I and II. The 17/ ICRP Publication 11, “A Rei’iew of the Radiosensitivity of
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rem is the unit of Dose Equivalent (DE) . The DE is obtained b~: multiplying the absorbed dose in rad by modifying factors to correct for these observed differences in the magnitude -t tile effect. As a consequence, the magnitude of the effect will be the same for a given DE regardless of the ncture of the rai!iation or the manner of radiation. At the present time, two modifying factors are employed . One is the Quality Factor (QF) which accounts for differences in producing biological effects amonq various forms of radiation. The other ‘is the Distribution Factor (DF) when a radionuclide, is nonuniformly distributed in an organ. For example, the DE for X-ray to bone tissue is determined …
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