Environmental Impact Statement - radioactive monticello

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Appendix A months, -years, thousands and millions of years. Despite of its relatively short half-life (12 y) tritium is of high concern. It is a highly mobile radionuclide moving anywhere hydrogen does. While it is a relatively weak beta emitter, humans can inhale, ingest and absorb tritiated water and food, where it becomes an internal hazard, irradiating the tissue. Tritium can bioaccumulate through the aquatic foodchain. However, NRC's generic EIS at 4.6.1.1 (Radionuclide Deposition) argues on the one hand that Tritium is not known to build up, but admits on the other hand that buildup is not explicitly accounted for in the aquatic food pathway. NRC's tritium release limits remain lax, despite animal, human cell and DNA studies indicating its toxicity. Paragraph 4.6.1 on public exposure falls woefully short on what needs to be considered at Monticello, and seems more intent to deliver assurances than science based information. (MS-Y-1 1) Comment: The EIS needs to consider physiological or ecological interactions that would mitigate exposures. Radionuclides can unite with carbon in the human body, plants, or animals. Even though Tritium passes through the human body in 12 days, some becomes organically bound and can remain in a person for much longer (450 to 650 days). One study even found traces of tritium in the body 10 years after exposure. Similar processes happen in the natural environment: As released <strong>radioactive</strong> gases decay, some form particulate and join other persistent <strong>radioactive</strong> isotopes released as fallout. Long-lived isotopes persist, accumulate and "bio-magnify". in biota through the food chain. (MS-Y-1 2) Comment: The EIS needs to accurately estimate radiation-induced health risks in the general population both at Monticello and the larger region. NRC needs to include emerging evidence on health effects in its EIS. More specifically the 1992 Energy Policy Act requires EPA to set public health and safety standards "based upon and consistent withu the recommendations of the National Academy of Sciences. NAS just published their latest report on radiation risk in June 2005 (BEIR VII report). Sixty years after Hiroshima, the full scope of effects of radiation on human beings is still incompletely understood, but progress has been made in the past 10 years since writing of NRC's (sic) generic EIS. (MS-Y-14) Comment: The EIS needs to consider that NRC's radiation protection standards are not protective of the majority of the US population. (MS-Y-1 6) Comment: The EIS needs to consider that cancer risks from radiation exposure are higher than previously estimated. The BEIR VII report is an improvement in so far as it estimates cancer incidence and mortality according to age of exposure, gender and by cancer type. The average risks to the population are estimated to be 10-15 % higher than the reference value currently used for radiation protection of the general population (565 cancer fatalities per million rem exposure in BEIR VII compared to 500). (MS-Y-17) Comment: The EIS needs to consider non-cancer health risks. Newly emerging evidence points to the fact that radiation can cause a spectrum of effects, such as reproductive and NUREG-1 437, Supplement 26 A-20 August 2006 1
Appendix A cognitive impairment. We now know that certain life stages and situations exist, when exposure to both radiation and hormonally-active compounds pose an increased risk to human health. As the BEIR VII report does not touch on publications after 2000, it is likely still underestimating the true health impact. See below. (MS-Y-1 8) Comment: The EIS needs to show how NRC intends to monitor for health effects in the general population. The EIS needs to specify how NRC would achieve the monitoring rather than relying on projections assisted by third parties with significant interest in a downplaying of effects. In the absence of other tracking systems in Minnesota this should include at a minimum an annual review of data from the state's cancer surveillance and birth defect registry, and the specification as to who would pay for the monitoring of health effects. (MS-Y-1 9) Comment: The EIS needs to account for sensitive subpopulations. NRC models still use a hypothetical 154-lb. adult white male for dosimetric modeling and protection standard setting. This does not take sensitive or divergent populations into account, such as a) women b) infants and children c) the unborn d) the elderly e) immunocompromised (MS-Y-20) Comment: The EIS needs to account for women's increased vulnerability. Women's critical organ doses and effective doses (as defined in International Commission on Radiological Protection 60) are about 25% higher than for men. Women's gonad doses may even be as much as factors of 10-30 higher than in men. The risk for women to contract solid tumors like lung, breast, kidney, and liver cancer due to radiation exposure is about double those for men. The cancer mortality risks for females are 38% higher. Only for a few cancers, including leukemia, the risk estimates for men are higher. The special hormonal status of females increases cancer risk from exposure to ionizing radiation. Pregnant women appear to have an increased risk of cancer. Furthermore, research in both humans and animals has shown that interactions between hormonally-active chemicals and ionizing radiation may increase some types of cancer. For instance, low doses of neutrons were more effective in inducing breast cancer in female rats in combination with prolactin than without it. Hence radiation during pregnancy, when prolactin is increased is adding to the cancer risk. (MS-Y-21) Comment: The EIS needs to account for infants and children's increased vulnerability. Current NRC standards and models do not consider newborn's special vulnerability to radiation. Many radionuclides are excreted in breast milk, providing a special exposure pathway for infants. The brain continues to develop during the first 2 years of life. Numerous studies show August 2006 A-21 NUREG-1437, Supplement 26 1
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NUREG-1437 Supplement 26 Generic En
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Generic Environmental Impact Statem
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Abstract The U.S. Nuclear Regulator
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Contents Abstract........... ......
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Contents 4.8.7 Conclusions Regardin
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Figures Figure 2-1. Figure 2-2. Fig
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Contents Table 5-1. Category 1 Issu
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Executive Summary The Commission ha
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Executive Summary NMC and the staff
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0 degree pCi microcurie(s) pCi/mL m
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Abbreviations/Acronyms IPE IPEEE J
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Abbreviations/Acronyms rem REMP RHR
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Introduction and (4) present the st
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Introduction (1) The environmental
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Introduction I assessment of the re
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Introduction This definition of pur
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2.0 Description of Nuclear Power Pl
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Description of Site and Environment
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Descfiption of Site and Environment
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Table 2-10. Land Use in Sherburne C
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Environmental Impacts of Refurbishm
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Environmental Impacts of Refurbishm
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Environmental Impacts of Operation
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Environmental Impacts of the Uraniu
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Environmental Impacts of Decommissi
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Environmental Impacts of Decommissi
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Page 239: Summary and Conclusions U.S. Nuclea
Page 243 and 244: Appendix A: Comments Received on th
Page 245 and 246: Appendix A Commenter ID Commenter A
Page 247 and 248: Appendix A A.1 Comments and Respons
Page 249 and 250: Monticello Nuclear Generating Plant
Page 251 and 252: 3. General Comments Regarding Licen
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Page 309 and 310: Appendix A Yes CHUCK HOSTOVSKY: I t
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Appendix A Return-path: Received:
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Appendix A tAY-W8-2006 11! 07 'ENCL
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Appendix A ta W.Y United States Dep
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Appendix A MAY-17-206 13:11 P.04 U.
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Appendix A IMAY-17-20O6 13:12 P.06
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Appendix B Contributors to the Supp
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Appendix B Name Karen McWilliams Na
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Appendix C: Chronology of NRC Staff
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Appendix C May 27, 2005 May 27, 200
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Appendix C June 1,2005 June 2, 2005
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Appendix C January 23, 2006 Februar
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Appendix D Organizations Contacted
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Appendix D Wright County Assessor,
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Appendix E: Nuclear Management Comp
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Cn N0 Table E-2. (contd) Expiration
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Appendix E UNITED STATES -" NUCLEAR
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Appendix E N. Archabal -2- potentia
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Appendix E D. Stinnett -2- miles of
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Appendix E FIGURE 2.1-3 SITE BOUNDA
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Appendix E Common Name Scientific N
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Appendix E A. Stinnet : -2- ' !We a
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Appendix E 1.0 Introdution. The U.S
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Appendix E 6-M.LE SITE VICINITY Fig
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Appendix E agriculture and industri
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Appendix E -" .. " MWNTICELLO 345-K
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Appendix E Table 2. Terrestrial and
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Appendix E During the June 2005 sit
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Appendix E Vegetation management ma
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Appendix E Lehman, R.N. 2001. Rapto
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Appendix E MAY-31-206 15:31 P.02 MI
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Appendix F GElS Environmental Issue
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Appendix F References 10 CFR Part 5
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Appendix G: NRC Staff Evaluation of
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Appendix G Table G-1. Monticello Co
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Appendix G * The MACCS2 analyses pe
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Appendix G relative risk significan
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" Permanently posting an operator a
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Appendix G accident sequences to em
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Appendix G The staff noted that the
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Appendix G (testing of the boron in
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somewhat higher than what would act
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C Cn N, a) % Risk Reduction Total B
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Appendix G G.6 Cost-Benefit Compari
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Appendix G monetary equivalent of u
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Appendix G * SAMA 16- provide passi
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Appendix G several other SAMAs, res
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Appendix G Generating Plant, Docket
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NRC FORM 335 U.S. NUCLEAR REGULATOR
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