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Package of Six Comments Opposing Proposed Rule

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Package of Six Comments Opposing Proposed Rule /- 1 | 4 J0CKET NUMBER . | 8 monwn gg - d(/ |' ' - ,_ WALBRIDGE J. POWELL [62 g-' .n: I ENGINEER & GEOLOGIST (206) 232- 5295 w 4314 island crest way mercer island,WA 98040 JUNE 23,1987 * 7 JUN 29 P2 :21 d SECRETARY A/OTE $ /VS0 YI /Q usNRC defnhoh n menp#&& 9' 1 WASHINGTON K 23 55 a '' ! i ATIN: DOCKETIfG AND A ND SERVICE BRANCH | 1 GENTLEENJ SUBJECT: INTENTION OF Tm NRC TO REVISE THE DEFINITION OF " HIGHtEVEL ! RADICACTIVE WASTE." l REQUEST THAT 'YOU CEASE AND DESIST IN YOUR EFFORTS TO LIBERALIZE THE DEFINITION OF HIGH L'EVEL RADI0ACTIVELIT WOULD ONLY RESULT IN DISASTROUS EXPOSURE OF THE POPULATION TO RADICACTIVITY. 1 ALL OF THE RADI0 ACTIVE WASTE THAT IS CURRENTLY CONSIDERED "HIGH1EVEL" SHOULD ret %IN IN M AT CATEGORY. SOE OF THE RADICACTIVE WASTE CURRENTLY CONSIDERED '" LOW 1EVEL" SHOULD BE PLACED IN THE "HIGHtEVEL CATEGORY". NRC SH0llD CONSIDER t%TERIALS THAT ARE EITHER LOJG-LIVED OR HIGH Y RADICACTIVE OR BOTH AS"HIGH-LEVELRADIDACTIVEWASTE".TEYSWULDNOTNEEDTOBEBOTH. 4 ETHER IT IS TERMED "HIGHtEVEL, "LovtEVEL", TRANSURANIC, OR SOE OTHER DESIGNATION, ALL WASTE SHOULD BE ISOLATED FOR AS LONG AS IT ret % INS HAZARDOUS. CURRENT LAWS.AND REGULATIONS DO NOT REQUIRE ALL HIGH LEVEL WASTE GO TO TK HIGH LEVEL WASTE DlNP THAT MAY SOE DAY BE ESTAB.!SKD. IDR IS IT NECESSARY THAT WASTE BE CLASSIFIED AS HIGHtEVEL IN ORDER TO BE PLACED THERE. ITiDOES SEEM LOGICAL, HWEVER, TO CATEGORIZE ALL L0tG-LIVED WASTE AS HIGH LEVEL SO AS NOTTDMINIMIZEITSHAZARD.THISREDEFINITIONSHOULDNOTREQUIREOVERAPONTHTOIMPLEMEMT. IT 1%S COME TO MY. ATTENTION WHILE READING NUREGM REPORT TO CONGRESS ON ABtORt%L @CURRENCES AND f0 REG /BR@51 PtMER REACTOR EVENTS THE THE NUCLEAR REGULATORY C0fNISSION HAS ' BEEN EXCEEDINGLY LAX''IN THE ENFORCEMENT OF CURRENT REGULATIONS WHICH ARE tOCP ' AND NARROW IN TEIR SCOPE. ID LATITUDE SHolLD BE ALLOWED IN FOLLOWItG THESE DIRECTIVES. AFTERCONSIDERINGRECENTCOURTPROCEEDINGSINWHICHSERVICEMENANDOTHERSWEREDENIED ANY COPENSATION FOR RADIATION INDUCED CANCERS I WOULD SUGGEST THAT THE NRC PERFORM IN ACCORDANCE WITH ITS CHARTER AND PRO ULGATE RULES WHICH WILL PROTECT WORKERS IN NUCLEAR INDUSTRIES AS WELL AS THE CITIZENS AT LARGE. PRESENTLY THEY ONLY PROTECT THE NUCLEAR INDUSTRY. I AM ATTACHING A REPORT BY E J STERNGLASS AND J SCHEER IN WHICH THEY HYPOTHESIZE %g " RADIATION EXPOSURE OF BONE MARROW CELLS TO STRONTIUM $ DURING EARLY DEVELOPMENT AS A POSSIBLE i COFACTOR IN Tm ETIOLOW OF AIDS'i TEIR STUDY SHNS A VERY CLOSE CORRELATION BETWEEN THE.PAES M N OF FALLOUT' FROM THE WEAPONS '.TESTItE IN Tm PACIFIC OCEAN AND SIMILAR LATITUDES NO THEI , sk WIDESPREAD . Itt0NE DEFICIENCY INDUCED BY IT IN INFANTS IN LTTERO OR DURING THE FIRST PONTHS 0F LIFE. LAXITY IN PREVENTItG EXPOSURE TO RADI0 ACTIVE GASESPARTICLES ETC POST NOT BE TOLERATED.. % IHERE IS N0 t0RE ROOM FOR ERROR IN THE TRAINING OF NUCLEAR PLAMT OPEPATORS, INSPECTIONS N i BY TE lE, OR ANY OTHER FUNCTION OF THE NRC, ANY OTHER GOVERtNENTS BUREAU OR OVERSIGHT GROUP. AT PRESENT WE ARE THREATENED WITH AN INSURMOUNTABLE BURDEN OF TERATOGENIC BIRTHS, CANCERS 4 s AND OTHER AILNENTS RUNNING RMPANT THROUGH OUR CITIZEtG,PLUS EE PLAGUE OF Tm Alm VIRUS. \ ANY MOVETNT T0dARD THE LIBERALIZItG OF REGULATIONS CAN ONLY BE VIEWED BY WOSE IN THE - TEONICAL' FIELDS' AND LAYEN AS AN INDICATION THAT B E NRC AND OTHER REGULATORY BODIES ARE IN DIRECT COLLABORATION WITH THE OPERATORS OR NUCLEARS PLANTS , PRODUCERS OF WASTE, AND OTHER ~ ENTITIES CONCERNED, THE PUBLIC BE DAMNED, WITH t% KING GREAT PROFITS WHILE SELLING OUR FUTURE kNy I REQUEST THAT THESE OBSERVATIONS BE INCLUDED IN T K PROCEEDItGS . ] ATTAONENT: RADIATION EXPOSLRE OF 80NE MARRN CELLSYOUP Y, ,, TO STR0VrltM $ DURitG EARLY DEVELOPMENT AS A Yg POSSIBLE COFACTOR IN TK ETIOLOGY OF AIDS. E J WALBRIDGEJ. a.L Q STERNGLASS, UNIV. OF PmSBURGH SCHOOL OF ltDICINE 8707060645 870629 PmSBURGH,PA 152618 J SCRER UNIV. OF BREMEN, PDR PR 60 52FR5992 PDR \{. \ kPT. OF PHYSICS,2E BREMEN SkDowledged33, WST GERf%NYby card..M ku.h. a e- 9 . * . RADIATION EXPOSURE OF BONE MAREDW CEl.t.S TO STRONflUN-90 00RitC EARI.Y DEYELOPMENT AS A POSS181.E C0 FACTOR IN THE ET101.0GY Of AIDS. E. J.Sterngless, Uniwrsity of Pittsburgh School of Medicine, Pittsburgh, PA 15261 - and J.Scheer,Universityof Bremen Department of Physics,2800 Bremen 33, West-Germeng i Tve of the principal unexplained aspects of tte AIDS epidemic are the timing of the sharp rises beginning in 1980-82 end the initial geographic concentration in Central Africe, the Caribbean, and the East and West Coasts of the U.S. These findings can be explained by the hgpsthesis that bets irradation of bons marrow colle by strontium-90 and otter bone seeking radioiestopes in the det during the period of etnesphede nuclear testing msg have led to the mutation of en A40S i reisted indigenous human or animal retrovirus (1), and also produced a cohort of susceptible individuals vtaas immune defeness vers impsired during intro-utorine development. Alttmugh A-tests began in 1945, its world-wide incrases in strontium- 90 in tis det dd not I teks place until after tta large H-tasts of the mid- 50's, rising trast sharpig betvesa 1962 sad 1963, as illustrated by the graph for strontium-90 in the dist of New York City, Chicags and Sen francisco (2) shsvnin figure 1.The greetsstincreensin AIDS occurred some18-19 years later or between 1980 and 1982, when the large cohort ofimmune deficient infants reached meturity and vers exposed to sexually transadtted dssues and altogenic leutneyts: (3), cousing the T-cells with the HTI.Y-Ill/ LAY to be entigenically stimulated (4) and the virus to spread wherever conditions fevered high rets:of sexual contact or other efficient means of transmission directly to tte bloodstream. ; I Sines 90% of fallout enmes devn with precipitation, this hypothesis orpleins why the AIDS epidemic began inmes of high rainfall such as Central Africa and the Cardboen Islands close to the latittds of the Pacific test-sites and ross most rapidig in tte tdgh reinfall artes of the East and West Coasts of North America, vith fever cases occurringin drier regions such as North and South Africa or tta Central Fisins states of the U.S. Because Sr-90 is transmitted mainly through through tte det,it also explains why South-Esst Asie, eithough high in rainfall, shows few AIDS cases, since rics and fish have e much ) lover Sr-90 to calcium retto then milk, breed, most, fruit, potatoes, beans and vegetables (2) dominent in the U.S., the Caribbean and African diets. As en exemple,in recent messurements for , New York City (1902), fresh fish contained only 0.13 pCi/gm Ce end rico 1.8 pC1/gm Ca, f I | . .. .. _ . .. .. .. - _ _ _ _ _ _ . ._ __ A - . .. .. compared with 23 pC1/gm Ce for fresh vegetables, potstoss and dry beans. Thus, depending on the tgps of diet, people living in the some aree con have as much as e ten-fold difference in their intets of strontium-90 for ewry gram of calcium needed for the formation of bons in the drwloping infant, the young cMId, and the adolescent before pregnancy. TMs is supported by the earliest sveilable direct measurements of structium-90 in human bons for the 5- 19 year ogs group containing young females of eMid-bearing ogs in Africe in 1 1957 published by the United Nstions Scientific Committee on the Biological Effects of Atomic Radetton (5).The dets reported in Table * of Referince (5) shows the highest concentretion of 1.2 pC1/gm Ca (10 -12 Curies per gram of calcium) in the 8sigion Congs out of 22 nations listed, as compared with oniy 0.4 pCi/gm Ce for the muh drier South Africa. The everegs wls for this ogs group in the U.S. that some year vos 0.6,VMie Thailand and inde reported only 0.3 and 0.2 1 ' respectively.Similarly, for the ogs group 19 gesrs old listed sepersteig for the soms geer, Table * shows the highest concentration ansag oil the nations listed in sawther tropical African country within 10 degress of the equier, nomsig Liberie, based on en even larger number of messaremen5 (12 ihr Liberie vs. 4 in the Congs). The cruclel role of diet could else explain the puzling fact that on the island of Trinidad in the West- Indies, with egal populettens of African and Asien Indian origin sad comparable percent homosecuals, there vere 45 cesse of AIDS diagnosed bg mid- 1985 anong those of African origin and nsas emang thess of East-Inden desesnt (6). A detailed study of the dietery dfperences and strontium-90 concentrations in bons for the two ethnic groups vould serve as a valuable test of the prisent hgpsthesis. Evidence supporting the possibility of virus mutetton by strontium-90 and other radioiestopse in bone morrow cells comes from the findings of a higher in:idence of defectiw HTLY provirm in Adult T-Call Leutemte in the Nugeseki eres as compared with other erees of the island of Kyshu (7), since hasyg fellout doses to the population vere found in the suburbs of Naguseki by Arekswa (8) following the stonde explosion in 1945. Laborsterg evidence for demage to the immuns system bg hans seeking radioisotopes et dose levels comparable to these encountered in erase of hoevy fellout comes frc m enimal studies showing clearly detectable decreases in bone morrow cellularity at strontium-90 deses in the 10- 100 millired range (9) plotted in figure 2.These does are of the some order as the everage roosived from astur31 background radiation of shout 80 millireds per gaar in the U.S. That such a surprisingly lov dass is able to produce visible radiation damage by chronic exposure to radiostrontium in bone morrov cells can be expleined in terms of an indirect,0 2 free-radical demogs to cell-membranes (10)(11)(12).This mechanism becomes 100 to 1000 times more 2 0 - i I '.
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