Source: Steve Tetreault in the Las Vegas Review-Journal, 8/11/02

Your Health: Radiation Exposure

Each radionuclide represents a somewhat different health risk. However, health physicists currently estimate that overall, if each person in a group of 10,000 people is exposed to 1 rem of ionizing radiation, in small doses over a life time, we would expect 5 or 6 more people to die of cancer than would otherwise.

In this group of 10,000 people, we can expect about 2,000 to die of cancer from all non-radiation causes. The accumulated exposure to 1 rem of radiation would increase that number to about 2005 or 2006.

To give you an idea of the usual rate of exposure, most people receive about 3 tenths of a rem (300 mrem) every year from natural background sources of radiation (mostly radon).

Other than cancer, the most prominent long-term health effects are teratogenic and genetic mutations.

Teratogenic mutations result from the exposure of fetuses (unborn children) to radiation. They can include smaller head or brain size, poorly formed eyes, abnormally slow growth, and mental retardation. Studies indicate that fetuses are most sensitive between about eight to fifteen weeks after conception. They remain somewhat less sensitive between six and twenty-five weeks old.

The relationship between dose and mental retardation is not known exactly. However, scientists estimate that if 1,000 fetuses that were between eight and fifteen weeks old were exposed to one rem, four fetuses would become mentally retarded. If the fetuses were between sixteen and twenty-five weeks old, it is estimated that one of them would be mentally retarded.

Genetic effects are those that can be passed from parent to child. Health physicists estimate that about fifty severe hereditary effects will occur in a group of one million live-born children whose parents were both exposed to 1 rem. About one hundred twenty severe hereditary effects would occur in all descendants.

In comparison, all other causes of genetic effects result in as many as 100,000 severe hereditary effects in one million live-born children. These genetic effects include those that occur spontaneously ("just happen") as well as those that have non-radioactive causes.

Health physicists generally agree on limiting a person’s exposure beyond background radiation to about 100 mrem per year from all sources. Exceptions are occupational, medical or accidental exposures. (Medical x-rays generally deliver less than 10 mrem). EPA and other regulatory agencies generally limit exposures from specific source to the public to levels well under 100 mrem. This is far below the exposure levels that cause acute health effects.

In most cases, the radiation hazard is much greater than the chemical (toxic) hazard. Radiation protection limits are lower than the chemical hazard protection limits would be. By issuing radiation protection regulations, EPA can protect people from both the radiation and the chemical hazard. However, deciding which hazard is greater is not always straightforward. Several factors can tip the balance:

• toxicity of the radionuclide
• strength of the ionizing radiation
• how quickly the radionuclide emits radiation (half-life)
• relative abundance of the radioactive and non-radioactive forms

For example:

Uranium-238 is radioactive and very toxic. Its half-life of 4.5 billion years means that only a few atoms emit radiation at a time. A sample containing enough atoms to pose a radiation hazard contains enough atoms to pose a chemical hazard. As a result, EPA regulates uranium-238 as both a chemical and a radiation hazard.

Radioactive isotopes of lead are both radioactive and toxic. In spite of severe effects of lead on the brain and the nervous system, the radiation hazard is greater. However, the radioactive forms of lead are so uncommon that paint or other lead containing products do not contain enough radioactive lead to present a radiation hazard. As a result, EPA regulates lead as a chemical hazard.

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Joe Strolin, Administrator of the Planning Division of Nevada’s Agency for Nuclear Projects, provided the following list of reasons why Nevada will not negotiate with the DOE on the Yucca Mountain Project when he addressed the White Pine County Commission on September 11, 2002.

No amount of money or benefits will change the fact that Yucca Mountain is an unsafe site. How do you put a dollar figure on people’s lives, a safe environment, clean water or the health and safety of future generations? DOE plans to contaminate the Amargosa Valley aquifer as part of its "waste isolation strategy" for Yucca Mountain, using dilution of the radioactive waste in the underground water as a way of making it appear that the site is able to meet the EPA’s radiation health protection standards. The only argument is when, not if, that contamination will occur. Yucca Mountain is such a poor repository site, geologically speaking, that it would be irresponsible, even unconscionable, for any State official to entertain the notion of accepting the facility in exchange for monetary or other benefits.

Yucca Mountain would cost the State billions in expenses associated with dealing with the direct effects of the program and tens of thousands of waste shipments that are a part of it. If there is an accident involving radiation, the costs to Nevada would be in the tens of billions of dollars, and the potential damage to the state’s tourism economy would be devastating. Because of the way the State’s tax and revenue systems operate, any impacts to tourism/gaming revenues would dramatically impact local governments with long-term effects far exceeding any "compensation" DOE might offer.

The only reason DOE and the nuclear industry are trying to entice Nevada and its local communities with promises of benefits is that they realize Yucca Mountain can only be built if the State drops its opposition. Once Nevada indicates even a willingness to talk benefits or compensation, the battle is over and the state will have capitulated. That is exactly what the nuclear industry lobbyists are hoping for.

The State has been preparing to contest the project in the legal and technical arenas for almost two decades and has already engaged DOE in numerous legal areas. Unlike the political fight, DOE is going to be forced to defend its shoddy science and faulty conclusions in the courts and before the NRC’s licensing board, where DOE’s contentions will be subject to cross examination by some of the best attorneys in the country, supported by Nevada’s first-rate scientific and technical experts. The only thing that can bail DOE out at this point is for Nevada to voluntarily give up the fight. Any negotiations for benefits would irreparably damage Nevada’s legal cases and seriously weaken the State’s credibility in challenging the project in the technical arena.

People who think negotiating with DOE or the industry is a good idea need to understand that once Yucca Mountain gets the go-ahead and waste begins to flow, there is no longer any incentive for DOE or Congress to live up to any commitments made for compensating the State or local governments. For one thing, the nuclear waste fund that supports the program using a fee collected on electricity generated by nuclear power plants is already woefully inadequate to pay for the cost of constructing and operating a repository. That means taxpayers will have to pick up the tab and any "benefits" the State might negotiate for will be competing with all of the other project costs every year in the annual congressional appropriation process. The reality of the federal appropriations process is that there is no way to bind an administration or Congress into a funding commitment made by a previous administration or Congress. In effect, any benefits agreement that might be negotiated is, essentially, unenforceable.

One need only look at the situation New Mexico finds itself in with regard to the Waste Isolation Pilot Plant (WIPP) project, a repository for transuranic waste and the only facility that is remotely similar to the proposed Yucca Mountain repository. New Mexico early on chose not to contest the project and negotiated with DOE to accept the WIPP nuclear waste facility in exchange for promises of funds for roads and other things. All New Mexico ever got was a few million dollars a year for highway improvements - money the state probably would have gotten anyway from the federal highway trust fund. DOE reneged on every other commitment. In addition, DOE continues to hold the promised highway funds hostage whenever New Mexico complains about health and safety violations at WIPP.

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The Nuclear Regulatory Commission's (NRC) list of 293 "unresolved" scientific issues at Yucca Mountain often has been the center of debate about the project.

The list -- a compilation of requests from the NRC for more information -- is expected to play a starring role in the ongoing saga of Yucca as the DOE scrambles to submit an application for a license to construct the dump.

DOE officials view the 293 data requests as a collection of mere loose ends, not "show-stoppers."

But Yucca critics say many will be difficult to answer, ultimately casting even more doubt on the project they say has been plagued by missing and flawed research.

The DOE fought for years to earn its final victory in Congress, which came when the Senate approved Yucca in July. Now the DOE faces a more formidable hurdle than layman lawmakers: an army of NRC scientists and engineers.

Nevada officials welcome the venue change, saying they have always had a better chance of killing the project in a scientific or legal arena, as opposed to a political one.

"There is no question in my mind that on a level playing field, under a strict and impartial technical review, the site doesn't stand a chance," Nevada Nuclear Projects Agency Director Bob Loux said.

Still, state officials are skeptical of the NRC, which is closely tied to the pro-Yucca industry it regulates and not likely to be a "neutral arbiter of fact," Loux said.

Many observers disagree, saying the NRC is staffed by some of the nation's leading scientists who are committed to an impartial Yucca review. But they acknowledge that the five-member panel atop the agency is under tremendous political pressure to approve the site.

DOE officials are confident Yucca will hold up under NRC scrutiny. They believe the site is backed by impressive scientific data, with more on the way.

"Some of the world's best scientists examined every aspect of (Yucca Mountain)," Energy Secretary Spencer Abraham told lawmakers in May. He told President Bush that he never would have recommended Yucca if it was dangerous to the public, "including those Americans living in the immediate vicinity, now and into the future."

But critics say the 293 issues prove the jury is still out.

The list was compiled last year as the DOE was finalizing many of its studies. The DOE spent 20 years compiling thousands of studies and reports about the desert ridge's hydrology, geology and history.

But DOE officials still didn't know if they had amassed enough data for the NRC to consider their license application. They needed to know if they were close.

So NRC staffers drew up an itemized accounting of notable "gaps" in the DOE’s research.

In September 2001 a 37-page document emerged listing the 293 gaps. Both agencies agreed the DOE would need to provide more data on each issue — in some cases a lot more — before the NRC would consider it complete.

If the DOE provides all the necessary information, only then will the NRC consider "docketing" the application and launching an in-depth review.

In the end, the NRC — not the DOE — will "resolve" whether the DOE’s data supports its case that Yucca is a safe site to permanently bury the nation's most radioactive waste, according to NRC high-level waste chief Janet Schlueter.

The 293 data requests vary widely. For example, the NRC wants supporting data on how the DOE approached evaluating seismic risks; additional documents on metal waste container corrosion tests; and more information on "thermohydrologic flow" -- how heat affects moisture in the tunnels.

Officials sorted the 293 points into nine groups called "key technical issues," which insiders call KTIs. One group consists of 23 requests for more information about how the design of the underground repository will affect heat and moisture inside it. Placing heat-emitting waste containers closer together would make the repository's temperature higher. The DOE has not yet chosen a "hot" or "cold" design.

The KTIs closely mirror many issues that Nevada officials for years have said made Yucca a bad place to bury waste.

"The best way to think of it is to follow the water," said Allison Macfarlane, director of a Yucca research project at the Massachusetts Institute of Technology. She supports the concept of a geologic waste dump, but has criticized much of the DOE’s research, including studies of whether water flow at Yucca may one day carry radioactive particles outside the mountain.

"It's unknown how much rain might fall in the future and unclear how the water moves through the repository now," she said.

Rain may seep through the mountain's cracks faster than expected, critics say. That means water could enter the tunnels, even drip on the metal containers, corroding even the most high-tech metals over time.

"We don't know what those travel times are with any precision. This is an area of concern for the NRC. They would like to understand it better," said Debra Knopman, a hydrology and systems analysis expert and a member of the 11-person Nuclear Waste Technical Review Board (NWTRB).

The DOE disagrees. Less than a half an inch of rain a year seeps beneath Yucca's surface, Abraham told Congress. "Our studies indicate that the vast majority of water samples taken from (inside) the mountain are thousands of years old."

Even opponents say it's unlikely that ancient volcanoes near Yucca could erupt during the next 10,000 years. But the DOE should know a lot more about how likely — and how damaging — "igneous activity" could be before they build a repository, Nevada officials say. A study published in July by a team of Dutch, English and U.S. scientists said molten rock could blast into the repository at 600 mph and fill it within hours if dormant volcanoes near Yucca awoke.

DOE officials say the chance of an eruption is one in 70 million each year for the next 10,000 years. Nevada officials don't trust that statistic.

"The probability of an eruption is pretty low," said Eugene Smith, a University of Nevada, Las Vegas professor who is leading a state-contracted study of eruption probability rates. "But I don't think (DOE) has calculated the probability of volcanic activity to the satisfaction of the NRC."

Of the 293 points, 58 were requests for more information about the giant metal containers that DOE officials say will encapsulate waste for 10,000 years.

Nevada officials say the casks may be the biggest flaw in the entire project, partly because the DOE plans to construct the containers out of a newly developed nickel-based alloy often called Alloy-22.

Alloy-22 is simply unproven over time, and scientists don't have enough data to make accurate performance predictions, Joe Egan, one of the state's lawyers, said.

DOE engineers disagree that Alloy-22 would corrode. They have been conducting tests on the metal, looking for signs of cracking or corrosion. The primary test dates back five years. "Hundreds, if not thousands" of 3- to 4-inch square samples of Alloy-22 have been submerged in water with varying chemical compositions at Lawrence Livermore National Laboratory in California, DOE engineer Paige Russell said.

The bottom line: The tests show "extremely low rates" of general corrosion that suggest an Alloy-22 waste container would not leak within 10,000 years, Russell said.

"This project does not depend on a miracle metal," added Rod McCullum, a senior project manager at the Nuclear Energy Institute, the nuclear industry's top trade group.

It's not clear whether the DOE can gather all the necessary data to satisfy the NRC by December 2004.

The General Accounting Office (GAO) is skeptical. The GAO concluded that the DOE needed until 2006 to adequately finish its studies, based largely on information provided by project contractor, Bechtel SAIC.

But Bechtel rejected a draft version of the GAO report, which Abraham said was "fatally flawed."

DOE officials are optimistic. They laid out a timeline for turning over all the research by December 2004. The DOE already has complied with 52 points — leaving 241.

The NRC’s Advisory Committee on Nuclear Waste has been critical of the project's science. In September 2001 it issued a sharply worded report on the DOE’s "total system performance assessment," essentially the DOE’s analysis of whether Yucca works.

The report said the DOE "relies on modeling assumptions that mask a realistic assessment of risk." And it said DOE "computations and analyses are assumption-based, not evidence-supported."

Observers expect the 293 issues to be the beginning, not the end, of NRC requests for information. It is notorious for poring over every detail, industry insiders say.

Even if the DOE submits all the materials necessary to satisfy the NRC by December 2004, reviews will continue for decades after Yucca Mountain opens, advocates and opponents say.

The DOE plans to carry out a "performance confirmation program" in which scientists will carefully monitor the mountain for signs of flaws. That will go on until Yucca closes — decades, even a century or two.

In addition, many advocates and opponents say in-depth scientific research — beyond routine monitoring — should continue at Yucca for generations. The extent of the research has not been defined and likely will depend on how much Congress is willing to fund, observers say.

As part of its license application, the DOE must outline its "performance confirmation plan." It's likely the plan will include studies on the waste containers, including possible full-scale tests, which have never been conducted, said Tim McCartin, a senior NRC adviser for performance assessment.

Of course, years after Yucca opens, it will be difficult to cancel the project even if ongoing studies uncover serious flaws, most observers agree. But continued study will allow scientists to make necessary corrections.

Yucca critics fear the DOE’s promises of ongoing study may be designed to merely make a bad project more palatable to a doubting public.

And Nevada officials say they don't want promises of a future science experiment; they want all the answers before trucks and trains begin hauling waste from all over America to the desert ridge 90 miles northwest of Las Vegas.

For now, DOE officials are focused on meeting all of the NRC's 293 demands. They expect that by the end of 2004, the NWTRB will offer a more optimistic opinion of the science than one issued in January where the board concluded that the scientific evidence supporting Yucca Mountain was "weak to moderate."

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The Nuclear Regulatory Commission (NRC) review process for the Department of Energy (DOE) license application on the proposed Yucca Mountain repository includes the opportunity for adjudicatory hearings conducted by the NRC.

The Licensing Support Network (LSN) is an electronic system that can be accessed through the Internet by anyone. It contains all of the documents that may be used as evidence in the NRC licensing proceeding.

The LSN meets the NRC’s document "discovery" requirements associated with the Yucca Mountain repository hearings spelled out in Title 10 of the Code of Federal Regulations, Part 2, Subpart J.

The LSN is the single place where the parties and potential parties to the licensing hearing can search for materials from any or all of those parties’ documentary collections in a uniform way. Public availability of the LSN was a key feature of a 1988 negotiated rulemaking that established the system.

The parties and potential parties to the hearing must make their documents that may be used as evidence in the NRC licensing proceeding available via the LSN. Non-parties or non-potential parties may not enter documents.

There are no restrictions on who may use the LSN. Any Internet user worldwide can utilize the LSN to access Yucca Mountain repository licensing documents. Parties to the proceeding have priority access as needed to meet hearing schedules using ID’s and passwords. Priority users also have the ability to save their searches. No ID’s or passwords are needed by the public.

Log on to the LSN Internet web site at www.lsnnet.gov.

There is an easy to use "simple search" for new users and an "advanced search" for power searching.

Public access will be available in the DOE Reading Rooms at the following locations:

DOE’s Las Vegas Yucca Mountain

Science Center

4101-B Meadows Lane

Las Vegas, NV 89107

1-800-225-6972

DOE’s National Nuclear Security

Administration Office

2621 Losee Road, Building B-3

Las Vegas, NV 89193

702-295-1628

All the community libraries in Nevada have Internet access, and access is also available at the DOE’s Beatty and Pahrump Yucca Mountain Science Centers.

The NRC encourages you to visit the Licensing Support Network web site and welcomes your ideas for improving the site.

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Construction of the Yucca Mountain repository is at least five years away, but a DOE official is already saying it will be necessary to expand the facility or build a second repository.

Joe Davis, a spokesman for the Energy Department, said new estimates show the repository won’t be able to accommodate all of the glass logs from the agency’s liquid nuclear defense wastes.

After the spent fuel from civilian power reactors is entombed there, and once the conversion task is completed in 2035, only 8,275 of the 23,475 glass logs that are expected to be produced will fit into the repository Congress approved.

In addition, the cost of converting the nation’s highly radioactive liquid wastes into glass logs will exceed by $9 billion the price tag for the repository, according to calculations by DOE officials.

A second repository will be needed, or the one on the drawing board will need to be expanded.

Davis says Yucca Mountain is physically capable of holding all of the nuclear waste that is ever forseeably generated in the country, including the DOE waste.

The new estimates bolster concerns by Nevada officials that the repository described in the Yucca Mountain Project’s Final Environmental Impact Statement will be too small to store the highly radioactive materials contained in more than 90 million gallons of liquids, sludges and salts kept in tanks at four locations in the northwest and eastern United States.

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