Health Impacts


   Overview

THE FACTS
  Re-licensing
   Security
   Radioactive Waste
   Structural Issues
   Health
   Environment
   Emissions
   Monitoring
   Emergency Planning
   Oversight
   Economics
   Energy Alternatives

   Take Action!

   Links

   Contact

 

PILGRIM-STUDIES OF RADIATION LINKED DISEASE

OVERVIEW


Infant Deaths - Sternglass, 1986: A Massachusetts state task force found an unexplained 38% "spike" in the infant death rate (IDR) in Boston from 1981 to 1982. This was the first increase in the IDR in 9 years, and the largest in 17 years. A June, 1986, study by Dr. Ernest Sternglass, professor emeritus of radiation physics at the University of Pittsburgh, School of Medicine, connected the increase with large radioactive releases from Pilgrim during June, 1982. 

Myelogenous Leukemia – Cobb, 1987: An epidemiological analysis of five towns around Pilgrim shows a 60 percent increase in leukemia rate, excluding leukemias not caused by radiation exposure. - Dr. Sidney Cobb, et.al., Lancet, 1987. The rate of myelogenous leukemia (the type most likely to be triggered by exposure to radiation) among males in the 5 towns around the Pilgrim reactor was found to be 2 1/2 times greater than the statewide average. - Dr. Sydney Cobb, et al., "Leukemia in Five Massachusetts Coastal Towns", Abstract for the American Epidemiologic Society, March 18, 1987; and, Clapp RW, Cobb S, Chan CK, Walker B Leukemia near Massachusetts Nuclear Power Plant, letter. Lancet 1987; 2:1324-5. 

Adult Leukemia - Massachusetts Department of Health, 1990: Adults living and working within ten miles of the Pilgrim reactor had a fourfold increased risk of contracting leukemia between the years of 1978 and 1983 when compared with people living more than 20 miles away, according to a 1990 study by the Massachusetts Department of Public Health. The report stated "a dose-response relationship was observed in that the relative risk of leukemia increased as the potential for exposure to plant emissions also increased." - Morris MS, Knorr RS, Southeastern Massachusetts Health Study 1978-1986, Massachusetts Department of Health, Southeastern Massachusetts Health Study, Oct., 1990. Archives of Environmental Health, Vol. 51, p266, 1996, July-Aug. #4). 

Recommendations Made by MDPH’s Southeastern Massachusetts Study and their Implementation, as of 2004

1. That a system of real-time monitoring of radionuclide emissions be implemented so that reliable and timely data are available by which exposure can be assessed more precisely; (not done – bogus system put into place instead – see Monitoring section, Sage System)

2. That a state air quality standard more stringent than that currently in use by federal regulatory agencies and other states be developed and implemented; (not done)

3. That the DPH continue its surveillance of cancer occurrence in the Plymouth area through data collected by the Massachusetts Cancer Registry; (Massachusetts Cancer Registry data available however the Registry does not have data refined to see patterns of disease at the neighborhood level; no registry for birth defects and reproductive disorders)

4. That, based upon the availability of resources, interviews of the families of childhood leukemia cases be conducted. (not done)

Denial: Response to MDPH’s Southeastern Massachusetts Health Study

The Southeastern Massachusetts Health Study was conducted, peer reviewed, and made public during the Dukakis Administration. The department (MDPH) began the process to address the first two recommendations – monitoring and establishing a more conservative radioactive air emission standard. 

However, there was a complete about face in November 1990 when Governor Weld took office. December 1990, Governor Weld sent his Executive Secretary to accompany Pilgrim’s Vice President and Pilgrim’s Health Physicist to visit Massachusetts’ Interim Commissioner of Public Health, David Mulligan. 

At that meeting Pilgrim gave their wish list. Pilgrim, the implicated industry, would be allowed to appoint a second peer review panel to re-review the Southeastern Massachusetts Health Study; and, until their own peer review panel decided whether the study was credible all the study’s recommendations would be put on hold.

The second peer review panel could find nothing wrong with the study’s methodology. The re-review panel stated clearly in their Executive Summary that, “The [original SMHS] study team adhered to generally accepted epidemiologic principles…” and “the findings of the SMHS cannot be readily dismissed on the basis of methodology errors or proven biases…”

But somehow they just couldn’t believe it - given Pilgrim’s emissions.
However for emissions data, they relied on data collected and provided by Pilgrim - not surprisingly it indicated that Pilgrim hardly emitted any radiation. 

The story gets worse. Massachusetts Department of Public Health allowed Pilgrim, the implicated industry, to provide all the sound bites, press releases and public announcements about the re-reviews findings and refused to let their employees, who conducted the original study, speak to the press. 

Once again, we see political science used to re-write real science on behalf of industry.

The Southeastern Massachusetts Childhood Leukemia Study, 
Massachusetts Department of Public Health
 

The study was funded and in the planning phase, 2002. However, the project was cancelled because funds appropriated were insufficient to perform a study that would be statistically significant. 



HEALTH: ISSUE IN PILGRIM'S LICENSE RENEWAL

Pilgrim Watch, Request for a Hearing and Petition to Intervene, Contention 5, May 25, 2006

To view Pilgrim Watch’s Motion to Intervene, see: NRC Document library at http://www.nrc.gov/reading-rm/adams/web-based.html. Adams Accession Number ML061630125 -To read the Atomic Safety Board’s Ruling on Pilgrim Watch’s Motion to Intervene, see: NRC Document library at http://www.nrc.gov/reading-rm/adams/web-based.html. Adams Accession Number ML 062890259

Contention 5:  New Information shows that another twenty years of operations at Pilgrim may result in greater off-site radiological impacts on human health than was previously known. 

5.0 Contention 

          New and significant information about cancer rates in the communities around Pilgrim and the demographics of these communities has become available.  In addition, new studies show that even low doses of ionizing radiation can be harmful to human health.  Epidemiological studies of cancer rates in the communities around Pilgrim show an increase of radiation-linked disease that can be attributed to past operations of the plant.  The demographics of the population immediately surrounding the plant, including its age and geographical distribution, make this population more susceptible to radiation-linked damage than was contemplated when the plant was licensed.  Pilgrim does not currently have off-site monitoring capabilities that can properly track releases of radiation into the community.

5.1 The Contention is within the Scope of these proceedings

           Under 10 CFR 2.309, a petitioner is required to show that the issue raised in the contention is within the scope of the proceeding.  The National Environmental Policy Act, NEPA, 42 USC § 4332, is the “basic charter for protection of the environment.”  40 CFR § 1500.1(a).  Its fundamental purpose is to “help public officials make decisions that are based on understanding of environmental consequences, and take decisions that protect, restore and enhance the environment.” 40 CFR § 1500.1(c).  The NRC regulations implementing NEPA for Nuclear Plant license renewals are in 10 CFR § 51(c) “Operating license renewal stage.”  In its application for license renewal of Pilgrim, Entergy was required under 10 CFR § 51 to provide an analysis of the impacts on the environment that will result if it is allowed to continue beyond the initial license.   The primary method by which NEPA ensures that its mandate is met is the “action-forcing” requirement for preparation of an EIS.  Robertson v. Methow Valley, 490 U.S. at 348-49 (1989).  The environmental impacts that must be considered in an EIS include those which are “reasonably foreseeable” and have “catastrophic consequences, even if their probability of occurrence is low.”  40 CFR §1502.22(b)(1).  The fact that the likelihood of an impact may not be easily quantifiable is not an excuse for failing to address it in an EIS.  NRC regulations require that “to the extent that there are important qualitative considerations or factors that cannot be quantified, these considerations or factors will be discussed in qualitative terms.”  10 CFR§51.71.    The regulation governing licensing renewals requires the Applicant for renewal to submit an Environmental Report.  10 CFR 51.53(c)(1).  The NRC then uses the ER to prepare an EIS or Environmental Assessment, although it has an independent obligation to “evaluate and be responsible for the reliability” of the information.  10 CFR §51.70.  In a petition for intervention, contentions that seek compliance with NEPA must be based on the applicant’s Environmental Report (ER).  10 CFR§2.309(f)(2).  

5.2 The issue raised in the Contention is Material to the findings of these proceedings

          10 CFR 2.309(f)(iv) requires that the Petitioner “Demonstrate that the issue raised in the contention is material to the findings the NRC must make to support the action that is involved in the proceeding.” In discussing the materiality requirement, the Atomic Safety and Licensing Board considering the license renewal for Millstone Nuclear Power Station stated “In order to be admissible, the regulations require that all contentions assert an issue of law or fact that is material to the outcome of a licensing proceeding; that is, the subject matter of the contention must impact the grant or denial of a pending license application. Where a contention alleges a deficiency or error in the application, the deficiency or error must have some independent health and safety significance.” In the Matter of Dominion Nuclear Connecticut, Inc. (Millstone Nuclear Power Station, Units 2 and 3) Docket Nos. 50-336-LR, 50-423-LR ASLBP No. 04-824-01-LR July 28, 2004, p. 7.  See Private Fuel Storage, L.L.C. (Independent Spent Fuel Storage Installation), LBP- 98-7, 47 NRC 142, 179-80 (1998), aff’d in part, CLI-98-13, 48 NRC 26 (1998).  The deficiency highlighted in this contention has enormous independent health and safety significance.  Off-site radiological consequences of operations at nuclear power plants are one of the biggest health and safety concerns of both the industry and the public.  If new and significant information can demonstrate that the Environmental Report needs to take these into account that is material to the findings of these proceedings.

5.3 Basis

          Petitioners will be relying on the expert testimony of Richard W. Clapp, DSc, MPH.  Dr. Clapp is a Professor of Environmental Health, Boston University School of Public Health. Dr. Clapp founded and served as Director of the Massachusetts Cancer Registry from 1980-1989 and worked in two environmental health consulting groups in addition to his teaching and research activities. He was a consultant to the U.S. EPA Science Advisory Board in its 1995 and 2000 reviews of the dioxin reassessment; and has performed extensive research on health effects from radiation exposure in communities near Pilgrim.

          Pilgrim releases radiation as part of its normal operations. This contention presents new and significant information supporting our contention that twenty additional years of operations will be harmful to public health.  Radiation-linked diseases are documented in communities around Pilgrim.  This fact and projected demographic data indicate that this population will be at an increased risk.  The National Academy of Sciences (NAS) latest report on low-dose radiation risk,  Health Risks from Exposure to Low Levels of Ionizing Radiation: BEIR VII Phase 2 (June, 2005) concluded that no amount of radiation is safe.  The documented radionuclide releases from Pilgrim in the past have long half-lives and bioaccumulate in the environment.  Petitioners submit that if the Applicant disputes a causal link between the radiation released by Pilgrim and the cancers seen in its neighboring towns, the current systems in place to monitor releases are inadequate and should be improved. 

5.3.1 The Population Directly Abutting Pilgrim is Increasing Substantially and the Population is Older and thus More Susceptible to Radiation Damage                                                                                                                 

In this contention, Petitioners will demonstrate that the changing demographics in communities impacted by Pilgrim are such that the dose effect on the population will be far greater than originally anticipated when the plant was licensed. 

          When Pilgrim was licensed and built in 1972, its location was in an area that was remote and undeveloped.  Although sited half-way between Boston and Cape Cod, most vacationers from Boston passed right through Plymouth on the way to more attractive summer resort towns on Cape Cod, Martha’s Vineyard and Nantucket.  Because of inadequate highway infra-structure, commuting to Boston from this area was not practical.  At the project planning stage, the initial site chosen by Boston Edison at the Quincy Naval Air Station was rejected because the area was too heavily populated.  The ultimate site in Plymouth was chosen because it was a sparsely populated area. 

          The population around the plant has changed drastically in the last 30 years, and this aging plant is now located in the fastest growing region in Massachusetts.  In Pilgrim’s backyard, Pine Hills, the largest housing development in New England, is under construction. The build-out includes 2,877 homes on 3,060 acres, and Pine Hills, Inc. is actively trying to acquire more land to build in this area. The distance from Pilgrim to Pine Hills is < 3 ½ miles. The current Pine Hills household size is 1.95 people per building. Based on these numbers, there will soon be 5, 850 people living just a few miles from this nuclear plant.[1]

          In its Environmental Report, Entergy provided a population projection in section 2-16 which showed the population changes and projected changes for all or parts of 15 counties and the cities of Boston, Massachusetts and Providence, Rhode Island.  The chart presented the percent annual growth in these regions – a number which minimizes the appearance of the population changes in the immediate area, and as such is misleading.  What Entergy did not highlight in its projections is the fact that the region is expected to add 465,000 people by 2030 and this group will be aging with a dramatic spike in the over 55 population. The largest population increases are expected in urban centers such as Boston and Cambridge and in a half-dozen suburban towns, such as Plymouth and Weymouth which have very large housing developments on the horizon. The Boston Metropolitan Area Planning Council Report on Population and Employment Projections 2010 -2030, http://www.mapc.org/2006 projections.html. The methodology used by MAPC is described in the report. (see Exhibit F-1).  According to the report the area south of Boston is expected to grow faster in population and jobs than any other section of Greater Boston through the year 2030.  Communities south of Boston will grow 13% and Plymouth is expected to add the most, about 10,000 residents – a population jump of over 20%.   By 2030, 1 in 3 people will be over the age of 55, compared to 1 in 5 now. This is relevant to any analysis of health impacts, as studies have shown an increased sensitivity to low levels of ionizing radiation in older populations. Greater Sensitivity to Ionizing Radiation At Older Age: follow-up of workers at Oak Ridge National Laboratory through 1990. Richardson, D.B. and Wing, S. Int. J. Epidemiol., 1999, 28:428-436;  The Hanford Data:  Issues of Age at Exposure and Dose.  Stewart, A.M., Kneale, G.W., PSR Quarterly Vol. 3, No.3 (Sept. 1993) 3:101-111; and  Leukaemia near nuclear power plant in  Massachusetts, Richard Clapp, Sidney Cobb, C K Chan, Bailus Walker, 924 , Lancet, 1987.

5.3.2 Radioactive Emissions from Pilgrim  

          When an EIS is prepared, NEPA requires the NRC to “disclose the significant health, socioeconomic and cumulative consequences of the environmental impact of a proposed action.”  The CEQ defines cumulative impacts as:  “the impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or person undertakes such actions.  Cumulative impacts can result from individually minor but collectively significant actions taking place over a period of time.” Baltimore Gas and Electric Co. v. Natural Resources Defense Council, 462 U.S. 87, 106-7 (1983), citing Council on Environmental Quality (“CEQ”) regulations at 40 CFR §§1508.7 and 1508.8.

          In its Final Environmental Impact Statement, the 1972 owners of Pilgrim stated in the Summary of Environmental Impacts and Effects, Section 5-c. that, “The effluents from the facility, if operated as described by the Applicant and in accordance with the technical specifications and rules and regulations of the Commission, will not endanger the public health or the natural environs of the station.” Final Environmental Impact Statement, Pilgrim Nuclear Power Station, Boston Edison Company, Docket 50-293, 5-c, p. iii, US Atomic Energy Commission Division of Radiological and Environmental Protection, (May 1972).   In its current Application, Appendix E, Applicant states “Very low levels of radioactivity may be released in plant effluents if they meet the limits specified in NRC’s regulations. These releases are closely monitored and evaluated for compliance with the NRC restrictions in accordance with the PNPS Offsite Dose Calculation Manual.” ER Appendix E.3.2.3.1.  Essentially the same was stated regarding solid and gaseous releases. Therefore the assumption is that there will be no danger to public health from routine releases since they will be monitored and will not exceed federal limits.[2]  However, despite this confidence written into the Application, Petitioners bring forward new and significant information that demonstrates that there has already been documented radiation linked disease in the communities near PNPS.  In addition, a recent report was published by the National Academy of Sciences that demonstrates that there is no safe dose of radiation for humans. 

 5.3.3 Radiation-Linked Diseases in Communities near Pilgrim  

          There is new information since Pilgrim began operations in 1972 that shows increases in radiation-linked diseases in the communities around Pilgrim.  The increases were in part attributed to operating with defective fuel; operating without the off-gas treatment system in the first years; poor management and practices culminating in the releases in June 1982 that coincided with weather conditions that held the releases over the area.  Southeastern Massachusetts Health Study 1978-1986, Morris, Martha and Knorr, Robert, Commonwealth of Massachusetts Executive office of Human Services, Department of Public health, 1990 and Meteorological Analysis of Radiation Releases For the Coastal Areas of The State of Massachusetts For June 3rd to June 20th,  1982, William T. Land.

The cancers found in the communities around the power station were studied by Dr. Sidney Cobb and Dr. Richard Clapp and their results were published in a peer reviewed journal in 1987.  They included elevated rates of Myelogenous Leukemia – a type of cancer most likely to be triggered by exposure to radiation.[3]  This led to a case- control study carried out by the Massachusetts Department of Public Health that showed a four fold increase in adult Leukemia between 1978 and 1983. The report stated "a dose-response relationship was observed in that the relative risk of leukemia increased as the potential for exposure to plant emissions also increased.”[4]

          Evidence of radiation-linked disease continued. In a statement before the Southeastern Massachusetts Health Study Review Committee [June 26, 1992] Dr. Richard W. Clapp, the founder and former director of the Massachusetts Cancer Registry, presented a graphical assessment of the pattern of leukemia and thyroid cancer in the towns closest to Pilgrim during the period 1982-1989.  Analysis of 1974-1989 Massachusetts Cancer Registry for Leukemia & Thyroid Cancer, Dr. Richard Clapp, DSc, MPH (2006), personal communication.   Exhibit F-4 shows graphs of the incidence leukemia and thyroid cancer in the Plymouth area.  The incidence of leukemia peaked in 1982 and subsequently declined until 1986. Then there was a second, smaller peak in 1987 and 1988 while declined in 1989. The number of cases exceeded the number expected in 1982-85 and 1987-88. The second graph depicts the pattern of thyroid cancer in the same set of towns. It shows a peak in the years 1987-1988.  These patterns of cancer incidence are consistent with the predicted health effects of the radiation released in the early 1980s.  A graph showing the predicted health effects is also shown in Exhibit F.  A statistically significant increase in childhood leukemia was noted in communities near Pilgrim, too.  Although Massachusetts Department of Public Health recommended a state sponsored case controlled childhood leukemia study, it was not done.

The Massachusetts Cancer Registry also shows, for the years 1998-2002, a continuing increase of leukemia and thyroid cancer in the towns around PNPS.  Specifically, there were 83 cases of leukemia reported to the Massachusetts Cancer Registry (MCR), where 72.9 would have been expected based on statewide rates. This results in a Standardized Incidence Ratio (SIR) of 114 (95% conf. int. = 91-143).  In addition, there was excess thyroid cancer in these same towns for the same time period. The thyroid cancer SIR was 122 (95% conf. int. = 96-155).  In other words, leukemia was 14% elevated over the statewide rate and thyroid cancer was 22% elevated.  Neither of these calculations were statistically significantly elevated by the usual convention (P<.05), but there were more cases than expected nevertheless.  This means there is a continuing excess of these two radiation-related cancers in the population, as there was in the 1980s. Analysis of 1998-2002 Massachusetts Cancer Registry for Leukemia & Thyroid Cancer, Dr. Richard Clapp, 2006, personal communication. 

Prostate cancer and multiple myeloma, both radiation-linked diseases, are also elevated and statistically significant for the years 1998-2002 in the seven towns most likely to be impacted near Pilgrim (Carver, Duxbury, Kingston, Marshfield, Pembroke, Plymouth, and Plympton).  Health Risks from Exposure to Low Levels of Ionizing Radiation: BEIR VII Phase 2 (2006). Occupational Radiation Studies, Chapter 8,, National Academies Press, 2006.Specifically, data from the Massachusetts Cancer Registry indicates 613 cases of prostate cancer vs. 513.5 expected, SIR=119 (95% C.I.=110-129); multiple myeloma: 47 cases vs. 31.7 expected, SIR=148 (95% C.I.=108-198).  Analysis of 1998-2002 Massachusetts Cancer Registry for Leukemia & Thyroid Cancer, Dr. Richard Clapp, 2006, personal communication
   

5.3.4  BEIR Vll:  Health Effects of Low Level Ionizing Radiation          

The National Academies Committee to Assess Health Risks from Exposure to Low Levels of Ionizing Radiation, the National Research Council, published

Health Risks from Exposure to Low Levels of Ionizing Radiation: BEIR VII Phase 2 in 2005.  Drawing upon new data in both epidemiologic and experimental research, they concluded that no amount of radiation is safe. There is a linear no threshold response to radiation, and exposure to low levels of radiation is approximately three-times more dangerous than previously thought.  BEIR VII: Health Risks from Exposure to Low Levels of Ionizing Radiation, Report in Brief, June 2005. Therefore it is not surprising that radiation-linked disease rates are higher than expected in communities exposed to Pilgrim’s past releases.

          A summary of cancer deaths estimated at NRC’s permissible dose release is provided in the BEIR VII Report.  The report shows the number of cancer cases and deaths expected to result in 100,000 persons (with an age distribution similar to that of the entire U.S. population) exposed to 100mSv per year over a 70 year lifetime.   On average, assuming a sex and age distribution similar to that of the entire U.S. population, the BEIR VII lifetime risk model predicts approximately one individual in 100 persons would be expected to develop cancer (solid cancer or leukemia) and approximately one in 175 would be expected to die from cancer from a the permissible dose of 100 mSv. Lower doses would produce proportionately lower risks. For example one in 1000 would develop cancer from an exposure to 10 mSv.

          This new report validates concerns raised by Petitioners and helps explain the radiation-linked disease observed near Pilgrim NPS.  When the standards were set by the NRC for permissible release of off-site radiation, low levels of radiation were considered harmless.  However, the BEIR VII report now reveals that any exposure is potentially dangerous.  Therefore it is not surprising that radiation-linked disease rates are higher than expected in communities exposed to Pilgrim’s past radiological releases.

          This new information is particularly relevant to the issue of re-licensing Pilgrim because twenty additional years of exposure will harm an already damaged population. Both BEIR VII and previous nuclear worker studies show that the health effects of radiation are cumulative.  Effects of Radiation and Chemical Exposures on Cancer Mortality Among Rocketdyne Workers: A Review of Three Cohort Studies.  Morgenstern, H and Ritz, B.,  Journal: Occupational Medicine: State of the Art Reviews, Vol. 16, No. 2, April-June 2001, pages 219-238.  And as shown previously, there is a growing and aging population in the area immediately surrounding the plant.  This population has already been harmed by the effects of radiation from Pilgrim and as a result is more susceptible to even permissible levels of off-site radiation.  An additional twenty years of operations would put a group that is already damaged at further risk.           

5.3.5 Bio-Accumulation of Radionuclides in the Environment from 1972-2032

          The effects of radiation exposure are cumulative. Some types of nuclear power plant emissions stay radioactive for a long time and, because they can enter biological food chains, those materials can accumulate in the environment and adversely affect public health. “If radioactive emissions persist for years, decades or even centuries within the environment, then even modest reductions in annual discharges may not be sufficient to prevent an environmental build up of those materials over time.” Estimates of Environmental Accumulations of radioactivity Resulting from Routine Operation of New England Nuclear Power Plants (1973-84), Dr. Richard W. England,, Mr. Eric Mitchell, p.4, A Report of the Nuclear Emission Research Project, Whittemore School of Business and Economics, University of New Hampshire, Durham, N.H., August 1987.

          It is known for example that the following radionuclides have been released from Pilgrim into neighboring communities:  plutonium 239 (half life 24,400 years); neptunium 236 or 237 (half life ranging from 120,000years -2.1 million years); cesium 137 (half life 30.2 years); strontium 90 (half life 28.5 years); tritium (half life 12.3 years), and xenon (half life 9.17 hours).  Xenon transforms after its emission into cesium 135, which persists almost indefinitely in the environment.  Examples of previous releases have been reported in the Annual Radiological Environmental Monitoring Program Reports [REMP].[5] These releases include substances that will remain active in the local environment for the foreseeable future and should be taken into account when actual on-going doses to the public are evaluated.  

5.3.6 Pilgrim has operated, and most likely will continue to operate with defective fuel

          Pilgrim began operations in 1972 with defective fuel. The Massachusetts Department of Public Health’s Southeastern Massachusetts Health Study 1978-1986 stated, Pilgrim, which began operations in 1972, had a history of emissions during the 1970s that were above currently acceptable EPA guidelines as a result of a fuel rod problem.”  Southeastern Massachusetts Health Study 1978-1986, Morris M.S., Knorr R.S., Executive Summary, Massachusetts Department of Health (October, 1990).

          In the March 2005 and April 2006 Pilgrim SALP (Systematic Assessment of License Performance, performed by the NRC) Reports, NRC Resident Inspector, William Raymond, stated that Pilgrim operated in 2004 and 2005 with defective radioactive fuel – that is, fuel with perforated cladding. Fuel cladding provides the first barrier to prevent radiation from getting out and harming workers and the public.  Degraded fuel is an on going issue for the industry.  NRC Commissioner Merrifield has admitted nearly 1/3 reactors now have failed fuel, and the trend is increasing, not decreasing. Briefing on Nuclear Fuel Performance, Transcript, p.4, (February 24, 2005), http://www.nrc.gov.

          Use of degraded fuel will increase exposure to both the public and workers. For example, according to the NRC, “a plant operating with 0.125 percent pin-hole fuel cladding defects showed a general five-fold increase in whole-body radiation exposure rates in some areas of the plant when compared to a sister plant with high-integrity fuel (<0.01 percent leaks). Around certain plant systems the degraded fuel may elevate radiation exposure rates even more.” United States Nuclear Regulatory Commission, Information Notice No. 87-39, Control Of Hot Particle Contamination At Nuclear plants, (August 21, 1987).    

5.3.7 Monitoring Radioactive Emissions  

          The Petitioners would like to submit that if Applicant disputes a causal link between the radiation released by Pilgrim and the cancers seen in its neighboring towns, the current systems in place to monitor releases are inadequate and should be improved.  The Comments to the Southeastern Massachusetts Leukemia Study made by Dr. Richard Clapp illustrate this point:

“I would like to reiterate a point that Drs. Knorr and Morris [Massachusetts Department of Public Health epidemiologists, authors of the Southeastern Massachusetts Health Study] made to you in one of their memoranda, e.g., that the emissions data provided by the utility are not reliable. I have had numerous discussions with individuals in the Department of Public health as well as colleagues who previously worked in a job monitoring worker exposure to Pilgrim contractors in the mid-1970’s. From these discussions, I am convinced that the actual emissions were considerably worse than what has appeared in public documents and has been available to researchers to date. In particular, there were transuranic isotopes[6]released that should never have been emitted to the general environment.”  Richard C. Clapp, MPH,Sc,D., Statement before the Southeastern Massachusetts health Study Review Committee, (June 26, 1992)

In the years since that statement was made, the quality of the environmental monitoring by Pilgrim has, if anything, decreased.  (see Exhibit F-4).    Petitioners can not be required to prove a causal link between the radiation released and the statistically significant increase in cancers if there is no effective monitoring system in place to measure those releases nor can the Applicant claim that a causal link does not exist.

          As stated previously, it is the assertion of Petitioners that the system in place to monitor off-site radiological releases at Pilgrim is inadequate.  Although there are documented increases in radiation-linked cancers in the communities around the plant, this aging plant does not use monitors which would allow state or federal authorities to confidently measure radiation releases.   Some of the deficiencies of the monitoring system currently used by Pilgrim are described in Exhibit C, as well as suggested improvements that could be made to the Pilgrim environmental monitoring program.

5.4 Conclusion  

          Petitioners have presented new and significant information that shows that the off-site radiological consequences of another twenty years of operations by Pilgrim may be greater than previously thought.  Epidemiological studies of cancer rates in the communities around Pilgrim show an increase of radiation-linked disease that can be attributed to past operations of the plant.  The demographics of the population immediately surrounding the plant, including its age and geographical distribution, make this population more susceptible to more radiation-linked damage than was contemplated when the plant was licensed. Finally, Petitioners propose an improved monitoring system which would allow the effects of off-site radiation on neighboring communities to be reliably and accurately assessed during operations and decommissioning. 


[1] This number does not include transients either visiting or working at Pine Hills. 

[2]  “The NRC, in 10CFR 20.1301 (Reference 8) limits the levels of radiation to unrestricted areas resulting from the possession or use of radioactive materials such that they limit any individual to a dose of: less than or equal to 100 mrem per year to the total body. In addition to this dose limit, the NRC has established design objectives for nuclear plant licensees. Conformance to these guidelines ensures that nuclear power reactor effluents are maintained as far below the legal limits as is reasonably achievable. The NRC, in 10CFR 50 Appendix I (Reference 9) establishes design objectives for the dose to a member of the general public from radioactive material in liquid effluents released to unrestricted areas to be limited to: * less than or equal to 3 mrem per year to the total body; and, * less than or equal to 10 mrem per year to any organ. The air dose due to release of noble gases in gaseous effluents is restricted to:* less than or equal to 10 mrad per year for gamma radiation; and, * less than or equal to 20 mrad per year for beta radiation.The dose to a member of the general public from iodine-131, tritium, and all particulate radionuclides with half-lives greater than 8 days in gaseous effluents is limited to:* less than or equal to 15 mrem per year to any organ. The EPA, in 40CFR190.10 Subpart B (Reference 10), sets forth the environmental standards for the uranium fuel cycle. During normal operation, the annual dose to any member of the public from the entire uranium fuel cycle shall be limited to:* less than or equal to 25 mrem per year to the total body; * less than or equal to 75 mrem per year to the thyroid; and, * less than or equal to 25 mrem per year to any other organ.” Pilgrim Nuclear Power Station Radiological Environmental Monitoring Program Report, p.20 (2004).

[3]An epidemiological analysis of five towns around Pilgrim shows a 60 percent increase in leukemia rate, excluding leukemias not caused by radiation exposure. - Dr. Sidney Cobb, et.al., Lancet, 1987. The rate of myelogenous leukemia (the type most likely to be triggered by exposure to radiation) among males in the 5 towns around the Pilgrim reactor was found to be 2 1/2 times greater than the statewide average. Leukemia in Five Massachusetts Coastal Towns, Dr. Sydney Cobb, et al., Abstract for the American Epidemiologic Society, March 18, 1987; and Leukemia near Massachusetts Nuclear Power Plant, letter, Clapp, R.W., Cobb, S, Chan, C.K., Walker, B., Lancet 1987; 2:1324-5. 

[4]Adults living and working within ten miles of the Pilgrim reactor had a fourfold increased risk of contracting leukemia between the years of 1978 and 1983 when compared with people living more than 20 miles away, according to a 1990 study by the Massachusetts Department of Public Health.  Southeastern Massachusetts Health Study 1978-1986, Morris, M.S., Knorr, R.S., Massachusetts Department of Health, Southeastern Massachusetts Health Study, Oct., 1990. Archives of Environmental Health, Vol. 51, p266, 1996, July-Aug. #4. 

[5] For example, in June 1982, Pilgrim blew its filters and released contaminated resin material off site into surrounding communities. The licensee’s own Radiological Environmental Monitoring Program Report for 1982 showed for example: Cesium -137, (1,000,000) times higher than expected in milk tested at the indicator sampling farm 12 miles west of the reactor and no elevation at the control station, 22 miles away; Cesium-137 again (1,000,000) higher in vegetation samples from indicator farms .7 miles and 1.5 miles from the reactor.   Plutonium 239/240: Radiological Environmental Reports(REMP) 1998, Plutonium found in indictor samples and Duxbury Beach; REMP 1999, Plutonium found Duxbury Beach; REMP 2000, Plutonium in indicator samples and Duxbury Beach, later excused by stating contamination must have resulted from a dirty beaker; REMP 2001 Plutonium Duxbury Beach; REMP 2003 forward stopped testing for Plutonium on Duxbury Beach.

[6] The transuranic isotope referred to was Neptunium.  Neptunium releases were reported orally to Dr. Clapp by Stuart Shalat, who worked for the contractor doing the re-fueling in the 1980s.

_____________________________________________

Health Effects in the News

Pilgrim re-licensing should consider town’s cancer occurrence,Patriot Ledger, Sept. 2008 

BOSTON —

“America’s Hometown” is also the home of the state’s only operating nuclear power plant, Pilgrim Station.

The Massachusetts Department of Public Health’s finding that “Plymouth most exceeded the state’s expectations for all forms of cancer” is very troubling.

Of particular concern is the high number of Leukemia and Multiple Myeloma, given the connection between such diseases and continued exposure to radiation.

Not mentioned is another troubling statistic, continued higher than expected rates of thyroid cancer, also linked to radiation exposure.

In light of the potential re-licensing of Pilgrim Station Nuclear Power Plant, it should be a top priority of government at every level to protect the health and safety of residents living in the shadow of the reactor.

From the early 1900s, it has been known that ionizing radiation (IR) interferes with genes, damages cellular functions and has been linked to cancer and other long-term disorders, particularly in those exposed at older ages and the young.

The federal government has been asleep at the switch, and the state has not done its job either in closely monitoring Pilgrim’s daily releases of radiation into our air and waters and reporting those findings to the public.

They can – and should – do better.

LILAH GLICK,Global Warming Coordinator, Clean Water Action-Boston

________________________________________

Response to Industry Lobbyist's Letter Denying Health Effects

Pilgrim’s Cancers – “Tobacco Science” Versus Fact

Industries that can harm the public have their “tobacco scientists” and lobbyists to promote the message. Pilgrim is no exception as evidenced by the letter published Oct. 6 by Mass Area denying the pattern of radiation-linked cancers and disease around Pilgrim.  

Mass-Area chose to rely on fiction, not facts. Instead, we rely on the National Academy (our nation’s premier scientists) whose latest report said that exposure to even very low levels of radiation are 3 times more dangerous than previously expected – and more so for children and women; and on statistics from the Mass. Cancer Registry showing a continued increase in radiation-linked cancers in communities around Pilgrim (Carver, Duxbury, Kingston, Marshfield, Pembroke, Plymouth, and Plympton) – the 7 towns most impacted by Pilgrim’s daily emissions.  

The lobbyist misrepresented the Mass. Dept of Public Health’s leukemia Study. We didn’t. The study found a 4-fold increase in adult leukemia the closer one lived or worked at Pilgrim. Pilgrim did not like the results and cut a political deal allowing them to appoint a second peer review panel to re-review the study and write a report. Even their hand-picked panel concluded that, “The original study team adhered to generally accepted epidemiological principles… [And] …the findings of the study cannot be readily dismissed on the basis of methodological errors or proven biases… [and last]…the association found between leukemia and proximity to the Pilgrim nuclear facility was unexpectedly strong.”  

Mass-Area incorrectly said that radiation from Pilgrim is closely monitored and controlled. Not so. Pilgrim collects their own environmental samples; analyzes the samples in their own lab; and writes their own reports – the equivalent of letting students write and grade their own exams.  MDPH is given a few split samples; however, their lab has been insufficiently funded so that they have not analyzed samples. Pilgrim’s recently installed 4-monitoring wells onsite to catch radioactive leaks before they enter Cape Cod bay. The system was analyzed by Pilgrim Watch’s expert - a Professor of Hydrology at U. Mass, Amherst. He concluded that Pilgrim’s monitoring well program does not meet accepted design standards and a 4-well system is suited to a local gas station not to an ocean-front nuclear power plant. Last, Pilgrim refused to place real-time air monitors in off-site communities, as recommended by MDPH long ago.   

The lobbyist failed to mention operational history that affects us today. No mention that Pilgrim began operations with bad fuel and without filtration. In 1982, Pilgrim blew their toxic filters, spewing hot particles into neighborhoods. A state study showed that weather conditions then were worst-case for holding contamination over local communities and Cape Cod. Environmental samples showed Cesium-137 from milk samples from a farm close-by 1,000,000 times greater than expected, but not in control samples. A similar pattern was recorded by Pilgrim in other environmental samples. Pilgrim claimed it was not due to them but to Chinese test bombs. You decide. Did the Chinese have “smart” test bombs that targeted Pilgrim’s indicator samples but not their control samples?  

No industry, including Pilgrim, can raise the dead or make the sick well; and if the dead and sick have radiation-linked diseases that are significantly more prevalent near Pilgrim than in communities distant, the conclusion is obvious.

 


More about radiation health effects

 

 

PilgrimWatch.org