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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-

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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

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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

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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

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efficient et the lov thse-ratas of long-term, internal radiation exposures from ingested or inholed isotopes then the direct effect on DNA thatis dominent for the high intensity flesh of bomb radiation or short diagnostic or therapeutic radletion exposures on vMch the existing theoretical estimates of expected heelth effects from fellout have been based. More recent laboratory studies with mics using strontium-89 how shown that bens- seeking radioisotopes preferentially demogs the natural killer (NK) cells dowloping in the bone marrov (13). TMs vould explain why the function of the NK colle is not only most strongly reduced in ) AIDS pottents with the most sewre symptoms (14), but why NK cell function is also reduced in f I healthy hemosexual males independent of the frequency of their sexuel contacts ( 15 ). These observatione are consistent vith the hypothesis that the high susceptibility of this population group to infections and the irobility to fight the development of certain types of concer meg have origineted during earlyintra-utorine exposure to strontium-89 and 90 when the immune system developed. Furthermore, studios on mice injected with reistiwig small amounts of strontium-90 how shown that the dese-response eta ve for long-leeting effects on the immune agetsm es mesoured by the risponse of homelytic plaque-forming celle to sheep red bicad-cells rises more rapidly et lov then et Mgh doses (16) es expected for a free-radical type of machenism, similar to the case of the low-dose bone marrow cell depletion effect discowred by Stokka et ei (9) shownin figure 2. Demage to the immune system of the newborn produced both by long-lived bone-seeking radioisotopes such as strontium-90 that accumulatedin the mother's bones prior to pregnancy,

, and by the short-lived isotopes such as strontium-89 and berium- 140 acting during pregnancy, I is further supported by a helt and brief rewrselin the priviously steady decline of pneumonia I I and influenze mortality among US. infants 0-1 yeerof ego during the height of nucleer voepone testing shown in figure 3 (17). Infant mortality due to these infectious diseases resumed its decline only after Sr-90 and other radioisotopes in the diet and human bone decreased in the late I '60', following the end oflarge-scale etmospheric tests by the US., the U.K., and the USS.R. in

1963. Significant demoge to the immune defenses of the body due to follout is also supported by the fact that during the period of nuclear veopons testitu;, thers vos sa otherwise unexplained epidemic of encephalitis in artes of the United States hoevily exposed to fellout, such as New York City (18). The number of cases in New York City rose nearly ten-fold from a lov of 33 cases in 1947 to | I 309 cases at the height of short-lived nuclear fellout frum lov altitude nuclear detonations in Nevede, the Pacific and Siberie in 1957, followed by a decline to 97 cases in 1960 during the test-morstorium. This was in turn followed by e second rise in 196I to 216 censo vith the first l i

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etmospheric tests bg Frsace in 1960 in the Sohors and by the high altituds H-bomb tests by the USS.R. in northern Siberie in 1961.0nig when the follout in the diet had decreased during the lets 1960's did the number of cases per year decline to e nov lov of 11 cases for 1973, es stava in figurs 4,where the number oor million has been plotted for each year from 1935 to 1970 to correct for changes in the population. Aa examinstion of the annual number of reportable diseases for New York City ginn in Table 22 of Refersace 18 indicates that the other infectious diseases also showed rises during the two perleds of heaviest fellout 1951-53 and 1961-66, the rises and declines being superimposed on a generalig declining trend similar in the pattern for encephalitis illetreted in figurs 4, though oflessor magnitude.These rivs occurred for pulumnery tuberculosis, messies, scarlet fene, chickenpox, whoopng cough, s mai nglococcel meni ngitis, poliomgelitis, sgphilis, gonorrhes, hepatitis, and rubells, consistent with a generalind effect on immons competence. The hypsthesis that redistwa damage during early dswlopment of the immuns system is e esfactor in tte AIDS epidemie is else supported bg the finding that infants in utern that survived radletion exposure in Hiroshima and Negeseki showed evidence of impaired immune function when studied many yearslater (19). Furthermort, recent pnsspective studies of patients in the New York eres with gmarelized lymphedonopathy examined 'Jefore tie onest of opportunistic infections and malignent complications associated with the AIDS syndrome showed en atmormally high number of multiple chromseemet translocations and breaks in the Igmph nodes and peripherst blood cells (20). Chrommesnu obnormalities how else basa found in ttu A-bomb surviveriin direct relation to their calculated radiation exposure (21), as well as in populations exposed to high lewis of natural background radiation in Breril (22) and Kersie, India (23).These 11ndings are consistent with the hypothesis that individuals et high risk of dowloping AIDS vere exposed f_q .ghnto chronic, internal redletion deses to their blood forming organs sufficient to result in clinically detectable chromosome abnormalities in their circulating 1gmphocytes, despite the relativelylov total dosesinnIved. To summarize, both the timing of the sharp onset of the AIDS epidemic and its geographical pattern that showed eninitial rise in the high-reinfall areas of Central Africa and North-America, as well es the striking absence of AIDS disease among individuals of East-Asian origin, can be explained by early developmental damage to the immune system by bone-seeking felloutisotopes that enter the mother's body through the food-chsin and produce their effect es a attacking the membranes of the dowloping lymphocytes in the bone result of free-redical 02

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A more detailed study correlating vorld-vide strwtiun- 901evels in the diet and bone with the incidence of AIDS in different geographical erees is in progress.

References

1. Kankt PJ, Atrog J, and Essex, M. Isolation of T-lymphotropic retrovirus related to HTLY/ LAY from vild-cought African Green monkeys "dalDgg 1985,230: 951-954. 2. Clusek CS. Strontium-90 in the U.S. Diet 1982, Report No. EML-429, Environmental Measurement Laboratory, U.S. Dept. of Energy (July 1984). 3. Shoorer GM and Levy RM. Non-infectious cofactors in susceptibility to AIDS: Posible contribution of sonen, HLA elloentigens, and lack of natural resistence.annels N.Y. Acad. A 1984,437 : 49-57. 4. Zeguri D, Bernard J, Leonard R et al. Long termcultures of HTLY-ill-infected T cellr. A model of cytopathology of T cell depletionin AIDS. Science 1986,fJ11850-853. 5. United Natione Scientific Committee on the Effects of Atomic Radiation (UNSCEAR) Report

Table A, p.330. United Netions, Mrv York 1962.

6. Bertholomew C, Charles W, Gallo R et al. The ethnic distribution of HTLY-1 and HTLY-ill associated diseases in Trinidad, West Indies, international Symposium on African AIDS, Program and Abstrwts, Abstract PO4, November 22-23,1985,Clumsc N, Thiry L, Burny A, Editors. 7. Yoshide M, Hettori S and Seiki M. Molecular biology of human T-cell leukemie virus ' essscisted with adult T-cell leutenda. Current Tootes in rterotf oloau and Immunolosu 1985, J11157-175. 8. Arakeve ET. Radiation dosimetry in Hiroshime and Nogeseki atomic bomb surYivors. New

Frmland J. Mad 1960. 251488-493. 9. Stokke T,0ftedel P, and Peppes A. Effects of small doses of strontium-90 on the ret bone morrow, Acts Radiolooica !968; 7,: 321.

I 10. Petkeu A . Effect of sxtium-22 on a phospholipid membrane. Health Phusics 1972, 22239 11. Sternglass EJ. The role ofincirect raaietion effects on cell membranes in the immune response. In: Radietion end the lumchetic sustem . Proceedinos of the 14th Annos) Henford Biolocu Sumoosium Seotemter 30-October 2. t 97 A J. E Bellou, Editor,I 976 Technical

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Information Center, Energy Reeserch and Development Administration (CDNf-740930):

185-191. 12. Petkau A. Radiation certinogenesis from a membrane perspect!w. Acta Phusioloaica Scand. ,

Sunclement- t980,4.22;81-90. 13. Heller 0 and Wigall H. Suppression of neturei killer cell activity with radioactin strontium: Effector cells are marrow dependent.J. of immunolocu 1977, L13, 1503-t506. 14. Bakest JG, Tseng P, Lev f, et al. Functional integrity of T,8 and natural killer cells in homosexual subjects with prodromote and in patients with AIDS, Annals NY Acad Sc. 1984,4]2,29-38. 15. Hendrell IT, Gel 111-Weistub R, Burnstein Y et al. Immune derangements in esgmptomstic male homosexuels in Israel: A pre-AIDS condition? Annels NY Acad. SgL 1984, f]2, 549-553, 16. Its T, Negne K, Xavemure Y et al. Studies on the Lauksmogenic and Immunological Effects of Radiostrontium and X-rege in mics. In: Redistion and the lumrM2 setem . Proceedinae of the 14th Annual Hanford Blotoau Sumassium September 30-Octotter 2.1974.J. E Bellos, Editor,1976 Technical Informetton Center, Energy Reeserth and Development Administration (CONF-740930):209- 217. 17. Sterngless EJ. Radianctivity, Chyt.XY In: Envir....; ate; CM&;f 4, J. 0T1. Boetris, Editor, New York and Lonen, Plenum Press 1977 (47"l-514). 18. Summary of Y1tel Stettstics, Department of Health,The City of New York , Bureau of thalth Statistics and Ansigsis,1983, New York, NY 10013 19. Akignme M et al. Peripheral igmphocyte response to PHA and T- cell population among atomic bomb survivors. Red. Res. 1983,}},572-580. 20. Metroka CE, Cunnigham-Rundlee S, Krim M et al. Generalized 1ymphedenopathy in homosexue' ..an: An update of the New York experience. Annals N.Y Acad. Sc.1983, f}2, .400-409. 21. Seseki MS and Mgete H. Biological dosimetry in atomic bomb survivors. Neture 1968,222, 1189-1193. 22. Costa-Ribeiro C et al. Redlobiological espects and radiation levels associated with the milling of monazite sende. Health Phwies 1975,21: 225. 23. Kochupilei N,Yerno IC, Grevel MS et al. Down's syndrome and reisted ebnormalities in en area of high background radiation in coastal Kerale. Nature 1976,262. 60-61.

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Fiaure Caetiore

ffours 1 Strontium-90 in the total diet for Nov York, Chicage and Sen f rancisco (Ref.2).

f_ioure 2 Percent depression in bone marrw cellularity at lw doses of strontium-90 in rats. (Deta of Ref.9). Dotted line represents a fit to e 01M form for the dose-response.

floure 3 Pneumonia and influenza mortality rate per thousand live births in the US. for the age , group 0- 1 year before, during end efter large scele etmospheric veepons testing. (US. Yital Stettstics)

figure 4 incidence of encephalitis in Nov York City per million population before, during and efter lertje-scale atmospheric testing (Ref.18).

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FIG. 4 .

. o certain key information, such as that ethe . : Imminent MatketmvD of ~~v]killed by the below AIDS virus 200 Tlus. * 1 information would have to be present before A Z T R d % (,8 g@$ the prescription could be honored." Would [Q such a system work? "It's never been tried before," says King. "No one knows precisely AZT can keep some AIDS patients alive and even reverse the best way to go, but an allotment proce- their dementtas, but it is so toxic that a majority ofpatients durc is onc of chc m st rc1s*"*blc co *c- - tempt." King says that Burroughs Wellcome 2nay 220t he able to take it will be able to supply enough AZT for the narrowly defined population it thinks voiced uneasiness with the limited amount should get the drug, but will not have for Health in the United Kingdom of information on AZT. Ellen Cooper, an enough drug on hand to treat all AIDS and O N announced4 March, that the the anti AIDS Secretary FDA medical officer, of State said at the January ARC patients. drug azidothymidine is approved for mar- advisory committee meeting that there are Martin Shenvood, a spokesperson for keting. The next week, the governments of no good data from in vitro studies that Burroughs Wellcome in Iondon, says that France and Norway approved the drug.The would explain how the drug stems AIDS the company hopes to limit distribution of Food and Drug Administration of the Unit- infections in patients. "This absence of con- the drug in the United Kingdom by requir- ed States is expected to announce its approv- vincing virologic data may be primarily ing that only physicians who have experi- al of AZT within weeks. For the first time, a methodological and certainly is not for lack ence in treating AIDS be allowed to pre- drug that is effective against AIDS is on the of effort. But the fact remains that for the scribe it. "Although it is a clinical decision, market. approval of an anti infective agent we nor- we are encouraging physicians only to pre- However, although AIDS patients are mally require in vitro evidence of specific scribe it for patients who fit into the catego- clamoring for the drug, a number ofinvesti- anti infective activity," she declared. ries [ defined by the U.S. clinical trial]," he gators have serious concems about its safety The AZT clinical trial did clearly show says. The company expects that in the U.K., and efficacy. Toxicity is so serious in some that the drug extends the lives of some such a system will restrict AZT's availability. cases that patients cannot tolerate AZT. patients. The question that is troubling in- In Nonvay and in France, according to Moreover, Burroughs Wellcome, which vestigators now is whether patients outside Shenvood, Burroughs Wellcome is making manufactures AZT, is still trying to work these narrowly defined groups will benefit a "similar effort" to limit the distribution of out a system for allocating the drug onic to from the drug. The clinical trial patients AZT. patients for whom it is thought to prolong "were highly selected," says Jerome Groop- A number ofinvestigators who are treat- life. Ordinarily, any drug approved for mar- man of the New England Deaconess Hospi- ing patients with AZT are concemed that keting is available to anyone with a prescrip- tal in Boston. "They had either just recov- the drug is more toxic than is generally tion for it. cred from a first bout with Pncunu9stis recognized. This is not to cast doubt on the AZT is the only drug demonstrated to ran'nii and were newly diagnosed with clinical trial results, notes Martin Hirsch of help AIDS patients in a randomized, con- AIDS or they had ARC [ AIDS related com- Harvard Medical School. "I don't think trolled clinical trial, and it has been rushed plex). Clearly, they represent a very small anything has developed since the initial trial through the FDA with unusual speed. The component of the spectrum of AIDS." Bur- to even suggest that AZT doesn't work or expected FDA approval,"does not mean the roughs Wellcome and the National Insti- doesn't prolong life," he says. But more than drug has been comprehensively studied," tutes of Health are now conducting studies half of all AIDS patients may not benefit says Dannie King, Wellcome's AZT project of AZT in AIDS patients with Kaposi's from the drug because it is more toxic for director. "It also does not mean we know sarcoma, in children with AIDS, and in them than their AIDS infection. which patient populations will benefit from persons who have antibodies to the AIDS The most serious side effect of AZT is to it. We are going fonvard very quickly with virus but who have not yet shown symp- suppress the bone marrow, leaving patients

, minimal data to answer one of the critical toms of the disease. These studies should highly vulnerable to bacterial infections (see medical needs of the decade." provide some answers, but the drug is ex- box). Once this occurs, they either have to l' The drug was " developed under emergen- pected to be on the market before those stop taking AZT altogether or take a re- cy conditions," says Samuel Broder of the answers are in. duced dose. But there is no information on National Cancer Institute. "It was first Burroughs Wellcome wants to "crr on the whether a reduced dose is effective, because found to be active against HIV [the AIDS side of a very cautious approach," says King. there is no way of measuring the effects of virus) in February of 1985. We gave it to the "We will try to target the drug so it is given AZT except to look for increased sunival first patient in July of 1985." to patients that are very close if not identical and lessening of opportunistic infections. In September of 1986, a placebo con- to the patient population that was already There is no simple way to see if the drug is trolled study of the drug was prematurely evaluated. At least philosophically, that's the working. terminated when it became clear that signifi- approach we're taking." Researchers have tried looking at AIDS cantly more AIDS patients taking placebo Yet, King continues, "One of our major antibodies, reasoning that if the drug were were dying than patients taking AZT. concems is, Will there be a black market for preventing the virus from replicating, AZT On 16 January, an FDA advisory commir- the drug! We feel very strongly that we patients would have fewer antibodies. Ac- tee recommended that AZT be approved for don't want that to happen. But wishing is cording to that measure, Groopman says, use by AIDS patients. AZT went from in not enough. We are building a system of preliminary data indicate that reduced doses vitro observations to a recommendation for allocating the drug. Our idea is that physi- of AZT seem to be less effective. Burroughs market approval in less than 2 years. cians will write prescriptions and that they Wellcome has trials under way to determine But, at the same time, some FDA officials would have to write on the prescription if lower doses of the drug are effective. But

8462 SCIENCE, Vot 2U '

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me . " . ' ' though thev were trapped in a prison of include tlut of Groopman who hopes to . _ _ . . ^ darkness," Broder says. But he reports that boost the bone marrow's functioning by giv- _ ;. A \ '- seven AZT patients regained some of their ing homiones that stimulate blood cell pro- . , I * . $ - ( f }4 . lost mental functions. "Some patients could duction at the same time as he gives AZT. . . ! ' ' /t ., j l return to work and interact with friends. "Within broad limits, the most important ' \ . ; ^N.,,/ / One patient told me that he had returned lesson of AZT is that somethirg can be done from the dead," Broder says. for AIDS patients, even if they have ad- soman ' Yet no one thinks that AZT is anywhere vanced disease," Broder says. "Before the near the answer to AIDS. Broder is looking advent of AZT, there was a significant ques- w . .* forward to the second generation of AZT- tion of whether anti retroviral therapy was ,, sY,/ N like drugs, which he hopes will be less toxic. even possible. I believe as a first step that any I'- Og~!.. Aiso, there are indications that if acyciovir is time you can start reaiistic discussions of 'g 1{g .'. h f:S, , given along with AZT, the two drugs may long term toxicity of a drug, you've got a - '-- ' - 2 ) * * " ** work together to control the infection and partial victory." patients may get by with lower doses of AZT, says Hirsch, "is by no n cans a cure AZT protects against AIDS in AZT. This drug combination is now being for AIDS, b.? Ms the only sho v in town tritro. T cells are destroyed by the AIDS rested in clinical trials. Other new approaches right now." a GmA h,W rims, as occun in the top panel. The photo on the lep ir a clump of T eritt before the AIDS . . *> 6 dd

ao MARCH 1987 REsEARCH NEWS 1463 , * is unclear whether people who are infected " Mathematical M* odel -S w - - - rest of their sexually acuve lives. Yet, says | Mav,"The long. term view of what's going i to harren >s cructal>f eceeneent on these Predicts AIDS Soread.L answers, and we just don't have them." The AIDS epidemic is still in a phase of The AIDS epidemic among heterosexuals may die out ofits exponential growth, but May and Anderson

Predict that it will, slow down and the own accord number of cases will increase linearly; m fact, there is evidence from San Francisco HE AIDS epidemic,says Robe t May conclude that gonorrhea was being main- that this is already happening. At first, when of Princeton University, is much less tained in the population by a core ofsexuauy essentially everyone in the sexually active predictable than people think. Al- active infected people and that the most homosexual populations oflarge cities such though it is possible to project how many effective strategy to control the disease as San Francisco was vuberable, the AIDS people will develop AIDS in the next year or would be to identify and treat that core infection rate took off. But now, those pop- two, for example, there is no way of know- group. The AIDS epidemic is similar, May ulations are already infected and it takes

ing how many will be infected in 5 years. says. "It is just essential that you recognize longer for the virus to spread to less sexually i Crucial data are missing, but it may be the great degree of sexual activity of the active groups. For this reason, the epidemic i possible to estimate some important features group at risk," he remarks, is slowing. of the epidemic indirectly from mathemati- But gonorrhea was endemic in the popu- The problem in modeling thie epidemic is 2 cal models of how the disease spreads. lation--but the rates ofinfection were nei- that it is nonlinear and no simple mathemat- May and his colleague Roy Anderson of ther increasing nor decreasing. The problem ical formula predicts how the number of Imperial College in London have developed was how to bring it under control. cases will increase. Public health officials- a model of the AIDS epidemic which not AIDS is an epidemic, and so May and who are trying to predict the AIDS epidem- only provides rough estimates ofsuch things Anderson's model focuses on the rates at ic curve fit-they use today's data to decide as the length of time between infection with which people are being infected and on how what will happen in the next few years. B it the AIDS virus and onset of actual disease, to predict the total number of cases, because the shape of the curve is changing, but which also suggests questions about the The model brings into sharp focus a num- this approach will not be accurate for projec- | epidemic that can lead to a much clearer ber of imponant unanswered questions tions of even 5 years in the future, May says. ' picture of how AIDS will spread, particular- about AIDS. For example, it is not known The only way to make long-term predictions ly among heterosexuals. They reported on for certain how long people are infectious. is to have answers to some of the crucial their model in the 12 March issue ofNature. Nor is it certain what fraction of those who questions about the course of the disease. Among their conclusions are that it is by are infected will eventually get AIDS. And it Nonetheless, May says, "we can use the no means clear that the AIDS epidemic will model to estimate combinations of parame- be the Black Death of our age. AIDS may -.Q ters that by themselves may not be amenable j to observation." For example, the rate at die out naturally, in particular, May and } ] Anderson conclude that whether an AIDS which the incidences ofinfection doubled in 1 epidemic among heterosexuals can be sus- the initial phase of the epidemic is known, tained depends on how long infected peop!c This is proportional to the probability that

remain infectious, how likely it is that an an infected person will infect a sexual part- i I infected man will give the disease to a woman, j . .| ner multiplied by the number of sexual and how likely it is that an infected woman partners that person has. Ifit is assumed that I will give AIDS to a man. If everyone infected [)f the average number of partners is ten, the dies within 10 years, for example, the epidem- # chance of transmitting the disease to a part- ic will look quite different than if only 30% * ner is one chance in ten. die and the rest go on infecting others for the o The model also leads May to conclude rest of their sexually active lives. ' that it is " rubbish" to argue from the African The AIDS epidemic, says May, has taken I)7 data that it is as likely that AIDS is transmit- people unaware because mathematician- f red from man to woman as it is from woman have tended to study epidemiology in the to man. In Africa, equal numbers of men abstract, unencumbered by any need to -. b and women are infected. But, says May, I *( | I study messy but realistic data, and public , "The sex ratio in Africa is more in the nature health specialists have not had many true of a problem to be explained than a proof epidemics to deal with. In the 6 years since that the virus is equally likely to be transmit- AIDS was first recognized as a disease, On Om red to men as women." One possible expla- molecular biologists have learned an incredi. Swedish condom symbol. The Srrd'3 nation, he says,is that most African men are ble amount about the AIDS virus, but epi- hare bccn promotin,g condomsfor more than a relative!v promiscuous and most women are | demiologists have learned relatively little #"#f# ' ' n re cs em m rical modcl ''I* *I"'IY * ". Sam u5 cxccPt for a core, about how AIDS spreads in populations. of the AIDS cpidemic indicates that if condom gr up of prostitutes. It could casdy be that it | ! The precedent for the current AIDS mod- use can decrcast by afactor of5 the chance is less likely for a woman to give AIDS to a el is a model of gonorrhea proposed in the that a man mth 21DS willinfect a man than vice versa, but AIDS infections mid 1970s by James Yorke of the University honwscrualpanner, the epidemic rill die out asnong these prostitutes would be such an ! of Maryland. Yorke's model led him to in the homosexual community. important reason for the spread of the AIDS i | 1464 SCIENCE, VOL 235 ,

. virus that the sex ratio of AIDS infections in epidemic alive. For heterosexual transmis- AIDS-a ume that agrees with other esti. sion, it is unknown whether Ra is greater mates that come from clinical data. + Africa could still be 1:1. In the end, May and Anderson's model - In estimating how many will die from than or less than I, according to May. AIDS, investigators often assume that the The mathematics of estimating Ro among raises more questions than it answers. But more likely it is that an infected person will homosexual men also leads May and Ander- its importance lies in its new approach to the develop full-blown AIDS, the higher the son to an independent estimate of the incu- AIDS epidemic. Says May, " Population death rate. But May and Anderson's model bation time of the virus. According to their models can give insights into the dynamics leads them to take issue with that assump- model and the San Francisco data on infec- of an epidemic and can help people think tion incidences, it takes more than 5 years about the disease more clearly." a tion. GINA KOL m Suppose, says May, that you assume that from infection with the virus to the disease everyone infected with the AIDS virus will die within 10 years. And then suppose you consider an alternative scenario-that 30% will die within 6 years and the rest will . _ met 1_f e,c,-<**e ly active lives, for about 30 to 40 years. In Life Thrives L nder the second case, the total number who will . get infected is larger. The virus will continue Cm RVCS to penetrate the less sexually active group of NaGG the population for 30 to 40 years. You can't say intuitively if there will be more deaths from 100% of a smaller number of people or Biologicalproductivity in intertidal communities that are ' ^ * '~""?'t??n?'"hi i$e''''re"I"~Wtoa |*| constantly battered by wavesgreatly exceeds what is achieved sa * long* term view in developed countries of by Cven the mostf^uithd5 CrOf Cal rainforests heterosexual transmission of AIDS." May explains that if the AIDS epidemic NYONE who has felt the force of forces with Paine, Quinn, and Suchanck to can take off through heterosexual transmis. (( sion of the virus, it will, of course, begin a large wave breaking on an analyze the energy flow in such communities among the most promiscuous heterosexuals. ocean beach knows that it dissi- in more detail Most of their work was done But, he says, "if all these people are dead pates a large amount of energy when it on Tatoosh Island, Washington, which has within 10 years, the epidemic will likely run crashes against the shore. Can intertidal long been a popular spot for ecological its course. If 70% of those infected remain organisms put this energy to use!" research by Paine r,nd his associates. infectious, there is more chance for the This question was posed by Egbert Leigh, The energy delivered to the shoreline by epidemic to spread more slowly." What will of the Smithsonian Tropical Research Insti- ocean waves in this region is enormous, and happen, he says," depends on knc,vledge we tute in Panama, and his colleagues Robert greatly exceeds that from solar radiation. On don't have on how many will die and how Paine, James Quinn, and Thomas Suchanck. average, waves deliver 0.335 watt per square long people remain infectious. We just don't The answer,it seems,is yes. In fact, say these centimeter of energy to the coastline, which know? researchers, many intertidal communities is about 15 times more than comes from the But May can use the data at hand on that are subject to constant wave battering sun. Even during the calmest months, wave homosexual infections to estimate how diffe are several times more biologically produc- energy exceeds solar energy by more than cult it might be to contain the AIDS epi- tive than the world's lushest rain forests, 100%. So, the potential for enhanced pro- demic in that group. The argument hinges which are usually thought of as being at the ductivity is great, if only the energy can be on a parameter called Ro, which is the basic apogee of the living world. The means by hamessed. Leigh and his colleagues soon found that reproductive rate of an epidemic-the num- which wave energy is converted into living ber of new infections each person with the material is, however, rather indirect: the key among the individual species in intertidal virus is likely to initiate. If Ro is less than 1, to the story is not so much raw energy as communities, those with the highest stand- ing crops are restricted to the most wave- an epidemic can't take off. And the greater disturbance. beaten areas. These species are the lower than 1 Ro is, the harder it is to contain an in addition to trying to unravel the net- epidemic. Since 50 to 70% of homosexual work ofinfluences that shape the composi- intertidal mussels, sea palms, and shrubby men in San Francisco are infected with the tion of biological communities, ecologists kelps. Now, although rain forests have enor- AIDS virus, Ro must be greater than 5, are interested in what governs the use of mous standing crops, much higher than in according to May. "That leads to a rather energy within them. In otner words, why is intertidal communities, a very large propor- depressing epidemic," he says. "The only the biological productivity of one type of tion ofit is locked up in woody tissue, which way to halt the epidemic is to change Ro by a zone different from that of another! Avail- is essentially dead. By contrast, a compari- factor of 5." It would mean that infected ability of nutrients is clearly one important son oficaf(or frond) area between the two individuals muss. have one fifth as many factor, as is the source and flow of usable types of community gives a different per- sexual partners as they had in the past or that energy. No wonder then that tropical rain spective. For instance, the shrubby kelp in they practice safe sex, with condoms, so as forests are so very fruitful, given their propi- the Tatoosh intertidal zone bears around 20 square meters of frond per square meter of to decrease by at least a factor of 5 the tious k> cation on the globe, It wa; something of a surprise, therefore, growing surface compared with around 8 chance that they will infect their partners. And, hke gonorrhea, any efibrts at reducing when Leigh first noticed that some intertidal square meters per square meter for tropical Ro must concentrate on the core group of kelp communities appeared to be even more rain forests. in terms of productivity, which is mea. sexually active men who are keeping the productive than rain forests. He joined RF. SEARCH NEWS 14 63 2o MARCH 1987 Pe:ge 97 - Low-Level Radiation and Fo o d , Feople, Anim al s 354 Sternglose report on " Changes in Inf ant Morte11ty Patterne FbilowinE the Arrival of Fallout from the 9-2r-76 Chineee Nuclear weapon Test" pre- sented to the BEIR ComT.ittee on July 18, 1977 On 9-26-76 a nuclear bomb of less than 200 kilotons was detonated by the Republic of Chine et Lop Nor. A l arg e r ai ne to rm l ed to very heavy weehout of redioactivity over e narrow etrip of coast etretching from Lelaware and New Jersey, across Connecticut, , Rhod e Isl and , Massachusette, Cew Hampshire and Maine. Measurements o f the lodine in the milk indicated that raw milk at certain dairies reacned levels in the range of 300 to 800 picoeuries per liter compared with the 100 pC1/1 limit eet by the Federal Radiation Council in 1961 em the maximum that should be allowed for continuous consumption and which would lead, on an annuel basi s , to an estimated dose to the thyroid of an inf ant of 1,500 mR, com- p are6 wi th the no r= al backgro und do s e o f abo u t 100 m R. Since this limit have been increased 10-fold by the FRC in 1964 for the case of sin 61 e events to 2000 pC1/1 there was no mand atory requirement to take counter- measures such es placing dairy cattle on uncontaminated stored feed or di- ' verting fresh milk to other uses. As a result, only the Health Depts of UY and Mass. decided to udua some protective action. Farmere in a few counties of southern NY Memlla neerest to the fallout zone were urged to place their dairy cattle on etored feed, and in Mas s . , a similar suggestion was made by the Heelth Dept. Since RI imports some 703 of its milk from nearby Mass, upstate NY and Vermont, these countermeasures also effectirly reduced the intake of I-131 in this state to about the same levels as those of Maes. Heavily exposed co nstal states of Delaware, NJ, Conn. , UH and Maine with heavy f allout and no countermeasures, inf ant morts11ty roee by anywhere from 13 to 60b, while it d eclined for the US se a whole by 6 5%. Even more striking is the f act that in c: ass. and RI, where the milk was either produced by cowe placed on stored feed or where it had been imported from inland areae . . .inf ant mortality declined by 30%. ( A Laveuit to End Atomic Power, HONICKER VS. HENDRIE, pgs 26 & 27) 355 Low concentratione of Polonium 210, an alpha-emitter, were obe erved in tobacco smoke by Radford and Hunt in 1964 Higher concentrations of Po-210 were found at the bronchial tissue eites in smokers compared to non- smokers by Little, et al in 1965 These authore euggested that the cumula- tive alpha radiation dose from inhaled Po-210 deposited in the lung by smokins may be an important f actor in the initiation of lung cancer. In 1974- Martell published findings that another longer-lived radionuclide, , Pb- 210 , is highly concentrated in a small number of ineoluble smoke particles. ' Long term exposure to insoluble reepirable particles lende to their accumu- lation in the lung, lymphnodes, liver, bone marrow, end elsewhere. Martell nodes,euggested liver that tissue, because the residence times for insoluble aerosole in lymph induction is quite likely.and bone(IBID, marrow pg 30) range up to several d ecades , c anc er 356. The possibility that alpha radiation may be the mutagenic _ agent in etherosclerosis plaque formation is indicated by the resulte of Elkeles (1961, 1966, 1968), who found anomalously high concentrations of alpha activity at the calcified plaque sites of atheroscleroels victims. sclerosis plaques usally occur in the main and abdominal aortas in theAthero- coronary arteries, but rarely in the pulmonary arteries (Elkeles,1966; Mitchell and Schwarte,1965) . This distribution, plue other considerations, suggeste a poesible respiratory origin for the mutagenic agent. The high ancid ence of early coronaries among cigarette smokers may conceivably be ezplained by the accumulation of ineoluble radioactive emoke particles at the pl aque sites . (IBID, pg 32) 357. It le noteworthy that the tiesue sites at which insoluble particles of respiratory origin ere known or expected to accumulate include all of th e in t ern al o rg an e i t es at whi ch hum an c an c ers are known to occur. Hum an

___ 4 * Pago 98 - Low-Lovel Rad 10 tion and Food, People, Animals

e cancer for which the carcinogenic agent is known haa involved alpha radio- ' activity: (1) lung carcinoma in uranium miners from Po-218 and Po-214; (2) bone sarcomas in radium dial workers from ingested Ra-226; (3) bone sarcomas in children and adults from repeated injections of Ra-224 (Spiees and Mays,1970) ; (4) and liver c ancer and leukemia in " Thoro thrast" p atients from colloidal Th02 injections. In addition, the observations that carci- nomas of the stomach, the esophagus, and other internal organs almost invariably occur at sites immediately adjoin /ng lymph tissue with visible accumulations of insoluble particles and measurable radioactivity indicate that insoluble cipha emitters transported through the lymph system may be the carcinogenic agent at these sites (Watson,1965; Oliver and Watson, 1966.) ( A lawsuit to end Atomic Power, HONICKER VS. HENDRIE, pg 31) 358. Synergy of Carcinogens - The enhanced incidence of lung cancer among miners who smoke cigarettee can be attributed to a combina^, ion of sources of lung irradiation by alpha-emitters; Po-218 and Po-214 on the surf ace o f inhaled mine dusts, Po-210 from inhaled cigarette smoke, and Po-210 which grows into the Pb-210-enriched insoluble smoke p articles . For miners who smoke cigarettes in the mine, there may be the add ed accumulation of Pb-210 coated mine dust particles on the tobacco trichomes in the cigarette before it is burned, resulting in higher Pb-210- activity of the inhaled ineoluble smoke particles. (IBID, pg 32)

359 In 1974, Viadana and Broes studied the relationship between dieense history and leukemia in 1345 adults with leukemia and 1237 controls from a random s ample . Positive relations were found between leukemia and 13 other diseases, which occurred at least 5 yeare prior to the leukemia. The indi- cator diseases were asthma, hay fever, hives, eczema, goiter, diabetes, herpes zoster, psoriasis, tuberculosis, pneumonia, heart disease and rheum atism . In 1977, Bross and Cataraj an publiebed findings that the incressked risk of leukemia and certain other diseases in the more sensitive subgroup of genetically affected newborn is on the order of 500% for low level parental exposures, usually less than 1 rad / year (from X-rays) . This constrasts with a 50). increase for the larger population including the non-cusceptible subgroup . Broes and Mataraj an confirmed that. among the indicator diseases for the seneitive subseries were esthma, urticaria, eczema, pneumonia, dysentery, and rheumatic fever. (IBID, pg 35) 360. Testifyin5 before the NRC on April 7,1978, Dr. Bross e nid , "...we shcald not permit genetic damage to worker in the nuclear plants by allowing the exposures in the one rad range which are currently allowed under the NRC stand ard e . Let me go one step further and s ay flatly I think that it should be an URC policy that persone in the childbearing ages, men or women, should not be working in these areas where there are these high level exposures. If somebody has to work there, it should at least be a pereon who is past the childbearing age, who is not d amage into future generations . . ." (IBID, pge 35 & 36) goin3 to put genetic

361. Natural background radiation may be responsible for 50% of all disease, 75% of all non-accidental deaths. Present evidence sugg.ests that for all cancer the increased risk may be from 1% per mrem to 0 5h for each rem whole body ezposure when ezpoeures are brief, and 10 to 100 times greater for prolonged low doses. For leukemia, the doubling dose may be 1 to 5 rade in adults, and 15 times less in developing e=bryos. An annu al dose of 25 mrem from environmental exposure may give at least 1.0 to 10% increas ed c ancer risk. (IBID, pg 36)

I ,

4 ~

6 Janusry 15, 1986 o ' Walbridge J. Powell 4314 Island Crest Way Mercer Island,' WA 98040

Dekr'Mr. Powell, I took the following information from the Energy News Digest, November 1985, #294, pages 1 and 8 as info taken from a letter to the NY Times which was not printed. The likelihood that a nuclear war wouldproduce a very large increase in the incidence of AIDS due to the effect of radiation and other stresses among the survivors was reported in a 9/21/85 article by Philip M. Boffey. An impli- cation of this report is that the current AIDS epidemic may.be an unantici- pated consequence of damage to the immune systems produced by the massive fallout of radioactivity during the bomb tests of the 1950s and 60s when many present AIDS victims were in their most sensitive state of early intro-uterine development. As pointed out by Dr. David S. Green and his associates at a symposium sponsored by the Natl. Academy of Science's Institute of Medicine, epidemis of infectious diseases such as AIDS would be expected among the sur- vivors of a nuclear war not killed immediately by blast, fire and massive radiation doses in the following months and years at a rate much greater than estimated in previous studies that did not adequately consider indirect effects such as those on the immune system. Damage to the developing immune system would ! explain why infant mortality due to influenza and pneumonia halted its long de- cline beginning in the early 1950s and actually started to rise sharply in 1958-59 despite steady advances in medical care and did not resume its normal decline until f&llout from large tests gradually disappeared from the diet during the late 1960s. It would also explain the puzzling fact that the sharp rise in AIDS all over thetorld began so suddenly in the early 1980s since that was the time when those affected in their ability to resist infection during the period of heaviest worldwide fallout reached sexual maturity. Ernest J. Stern- glass and Jens Scher (Prof. of Nuclear Physics, U. of Bremen, Germany) . /, This is listed as #897 of page 218 (of 226 pager) of my new paper - LOW-LEVEL 'l RADIATION AND FOOD, PEOPLE, ANIMALS by Naomi F. Jacobson. It was just received from being bound this week. It will sell for $12.00 I believe and has an , ' index for handy reference - including AIDS as noted above. j Enclosed is information from Citizens Energy Council (Larry Bogart) - the group ' publishing the Energy News Digest, and the Radioactive Waste Review Board on a possible dump site for Wisconsin.

- Sincerely, 017Z5 W (Mrs.) Nao i Jacobson 525 River Road Rudolph, WI. 54475 | Enc. - Rad Waste Updates -Fall 1984 and Fall 1985 Slide Show Brochure,1/2/86 ltr from Sen Strohl about 1/16/86 annemt ! Citizens Energy Council info } ~

. L Kitching and S. L Pimm), wetland her- propic as far away as upstate New York responsibility and the legal claims of the petofaunas (M. P. Simbotwe end G. R. received heavy doses of strontium 90 and downwinders, as he ca!!s them, for compen-

, Friend), nectar feeding birds (H. A. Ford), iodine 131. Howard Ball, on the other sation. He blames the AEC not only for hand, concentrates on those living down- negligence in the way it conducted the tests 4 breeding biology of insectivorous birds (J. C. L Woinarski), small mammal succession wind from the Nevada test site who experi- but also for deceiving the affected people after fire (B. J. Fox ct al.), and general enced sufficient radiation to increase greatly about the risk of cancer and leukemia stem- community structure (A. V. Milewski and their chances of coming down with cancer ming from their exposure to the radioactive R. M. Cowling). These papers provide a and leukemia. Both authors condemn the fallout. In tracing the downwinders' efforts good sampling of the state of the art of Atomic Energy Commission for using the to achieve justice, he praises federal judge intercontinental comparison. im;>cratives of the Cold War to hide from Bruce C. Jenkins, who ruled in their favor in The sta af the art is, unfortunately, still the American people the real danger to 1982, but is critical both of the govern- rather primitive. Nonetheless, the southem public health and safety from the more than ment's refusal to accept that verdict and of continents offer some of the best opportuni- 100 stomic tests conducted at Yucca Flat. the Congress for its failure to extend legista- ties for comparisons because of the relative The casualties included not only the troops tive relief to the radiation victims of south- taxonomic uniqueness of their floras and foolishly placed widde a few miles of em Utah. faunas, their long isolation from one anoth- ground zero or the nearby live stock callously The key issue is the degree to whicM er and from the porthern continents, and destroyed, but potentially all Americans higher rate of cancer and especially lcukemia 1 their relative tectonic stability. What is need- who lived for more than a decade under this among the 100,000 downwinders can be ed soon is a second symposium or, better, a ominous shadow. tied directly to their exposure to radiation workshop to identify ecosystems and fea- The strength of Miller's book lies in the from the atomic tests. Ball acknowledges the tures best suited for further comparison, the detai|ed account of the individual tests and inability of scientists to prove conclusively

nature of the data needed, and the ways in the careful tracking of the fallout partems that low doses of radiation can cause cancer , which future studies can be made more across the nation. He shows both the nor- in humans, but he endorses the views of comparative than the past ones. mal course of the clouds, across the Middle Chase Peterson of the University of Utah This volume represents a first step in a West and upstate New York, and variations Medical School, who told a congressional j long road. It is easy to read, and there are that took the deadly material over the South committee in 1979 that " scientific proofwill relatively few typographical errors. The art and sometimes even back westward across never be 100%, and you should not be work is varied in quality, and q particular Arizona and Califomia. His account, to- looking for it" (p.138). Instead, Ball argues copy of the book quickly fell apart, even gether with fallout maps in the appendix, that there is a large enough body of statisti- with gentle handling. clearly supports his assertion that "every cal and epidemiological evidence to establish GoRooN H. ORIANS person alive [in the United States) during "tughly signi6 cant associations between the Institurefor Environmenta15tudier and the 1950s and 1960s lived under the atomic fallout and the ensuing cancers and leuke- Deprrment of2 oology, cloud" (p. 9). mias" (p. 200). ' Unircnity of Washington, His book, however, is too detailed and Although Ball too often pleads the case Startle, WA 98195 impressionistic. He fails to offer any sus- for the downwinders, he does succeed in 4 tained analysis of why this serious risk to showing how irresponsibly the AEC acted public health continued for so long without at the height of the Cold War. The ultimate any effective public protest. By focusing on irony is that the people most affected, the Fallout from Yucca Flat the tests themselves, he tends to slight the largely Mormon population of the small i policy issues they raised, and particularly the towns of southem Utah, were staunchly k Under the Cloud. The Decades of Nudear Test- movement that led to the moratorium in patriotic citizet.s who believed that the Ne- ing. PacHARD L MHUK. Free Press (Macmil- 1958 and the limited test ban treaty five vada tests were necessary to maintain Ameri- len), New York,1986. xii, 547 pp., illus., + years later Miller ignores the problem of can nuclear superiority over the Soviet Pl ates. $24.93. global fallout from the American shots in Union in the 1950s. They were forced to

. the Pacific and Russian explosions in Sibe- pay a high price for this belief. r a, u hich pmvided the primary frus of the ROBER'T A. DMNE Po a in the 1 Os o AK B Oxf r nuclear fallout debate of the '50s. It was the Department ofHirrory, University Press, New York,1986. xviii,280 pp., Unircnity of Texas, illus. $21.95. massive contamination of the atmosphere from the hydrogen bomb tests conducted by Aurrin, TX 78712 Fellout from nuclear testing, which began the two superpowers, not the smaller in the Nevada desert in 1951 and continued amount from the Nevada atomic tests, that

regularly, except for the moratorium from !cd to the pubhc outcry that finally forced , 1958 to 1962, until the limited test ban the United States and the Soviet Union to Books Received treaty was signed in 1963, created a serious restrict their testing to underground shots. Adolescent Abortion. Psycho f hazard for the American people at the height In Jurrice Dornrind, Ball focuses on the ,ue,. Rebrt or the interdivisionalbicalmee on Ado- ! and legal is. Icacrat m. American Psychdc cal Anocim f of the Cold War. The authors of these two impact of the Nevada tests on the 100,000 " books give complementary accounts of the people in Nevada, Arizona, and especia!!y O*Jan,' $s'E Iijs2 fp"."i1'7sE7.sNNrefa"d

the In , deadly nature of the resulting radiation. The southem Utah who lived downwind from o n' $ ",*,'[,'"d * @ *[*@n[i, g amapc,ge difference lies in their points of focus. In the test site. This population, Ball contends, |' Under the Cloud, Richard Miller makes it received 30% of the total fallout generated haoa Apphcanon** to Phytogathogenic BactenaI'*"' Arun clear dat all Americans, nm just those living by the atmospheric tests conducted at Yucca, ; ,, N'yt D,'$ pp'd'}'' $'['*''. downwind from the Nevada test dte, were Flat between 1951 and 1963. Advances tr, the Psychology of Religion L B.

, 3, exposed to heavy amounts of radiation. The As a political scientist, Ball is primarily $ U fg' M 'Q'h!9j5"N,3Mi~ vagaries of wind and rainf:ll meant that concerned with the issi.es of government ogy. a 11. from a meetmg. omford. UK. May 1982.

9 I ANUARY 1987 ! Book REVIEWS 2a7

1 1 e

.

e For Concord:nca in Archaeologic:1 Analysis- . SOMATIC CELL AND 3,;3 n 1986, sii, 205 pp., iUus.159.50. Procee6ngs in Ufc * "'",Y", n,,, 3,,uc,,,c, ou, nota,iv, T,ch,uque, and Sc ences. nased on a conference, riorence,iune i985. ' P"" C'" "#"" * ' "P'''" " '"' "' Y'"'''d' " ''"'' C "'"' W"" '"d MOLECULAR GENETICS with the Insuruw for Quancitauve Archaeok Therapeutic Processes. Henry L Lennard m couatora- WORKSHOP sity d Arkansa, by Warpwt, Kansas Cay,1985, 3, Uruver.t on with Alczander Grainick. Human Sciences Press, xx,622 pp.,illus 155. New York, 1986.2221 pp., illus. 524.95. Forensic Neuropsychology. Charles I. Golden and Ousntum Theory of Collective Phenomena. G. L An NCl sponsored workshop in Denver, Mary Ann 5tnder, Eds. Plenum, New York,1986. x,190 Sewell Clarendon (Oxford University rress), New York, Colorado, July 30 August 14, 1987, PP. 539.50. Nebraska Neuropsychology Symposis Sc. 1986. xiv, 229 pp., illus. 555. Monographs on the combining key procedures in. both nes, vol.1. From a symposium, Omaha, M'ay 1985. Physics and Chemutry of Maienals. somatic cell and molecular genetics for The Forest Resources of the ECE Hegion. (Eu. The Quark Structure of Matter. M. Jacob and K. rope, the USSR, North America). United Nauons Eco- Winter, Lis. World Scienofic, Singapore,1986 (U.S. cloning and functional analysis of norrue Commission for Euro Organizauon, Geneva,1985.pe, Food and Agneulturedistnbutor, Taylor and Francis, Phdadelphia). xiv, 786 mammalian genes. Laboratory exercises vi, 223 pp., iUus. Paper, pp.,iUus. 374. Frorn a meetin5, Strasbourg, France and will include isolation of somatic cell 121. Karlsruhe, FRG, Sept.1985. rnutants, sornatic cell hybndiZation for The Forgotten Peninsula. A Naturahst in Baja Real and Stochastic Anafysis. m .'... Rao, Ed. Cahfomia. Joseph Wood Krutch. University of Anzona Wiley, New York,1986. xiv,347 pp. 539.95. complernentation and dominance analysis, Press. Tucson,1986. xviii,277 pp., illus. Paper,19.95. DNA rnediated gone tran sf e r, and Textbook of Histology. Finn Geneser. Munksgaard, Augmented reprint,196 edacon. Copenhagen, and tea and Febiger, Philadelphia,1986. preparation of CDNA and genomic DNA From Dirth to Five. A Study of the Health and 831 pp., dlus. 549.50. libtarie s. The current exercises are Behaviour of Bricam's 5 year. olds. N. R. Butler and Jean Theory of Hotors. A Generalization ofTensors. Parry dasigned to provide an intensive Golding, Eds. Brian Howlett rt al, Data Eds. Pergamon, Moon and Domina Eberle Spencer. Cambndge Univer. New iork,1986. xxxii, 439 pp., illus.137.50, paper, siry Press, New York,1986. xx, 392 pp., illus. 569.50. sntroduction to current genetic technology 522.50. for professional researchers wishing to 'The Therapeutic Perspective. Medical Practice, From Physician Shortage to Patient Shortage. Knowled 1820-1885.Jofm apply these techniques to active programs. The Uncertam Future of Med cal Practice. Eli Guuberg, Harley %ge, and Identity in America, amer. Harvard University Press, Cambrkige, Those with research interests in Ed. Westview, Boulder, CO,1986. xii,172 MA,1986. xii, 367 pp., iUus. 332.50, malignancy are particularly encouraged to 525. Conservat on of Human Resourecsrudio $pp., in illaThe Thorny Way of Truth. Part IL Stefan Mannov. apply. No registration or tuition fees are Heahh Pobey. Based on a conference, New York, Feb. 3rd ed. International Pubbshers " East West," Graz, Aus- 1986. charged, and a per diem will be provided to tna,1986. iv,351 pp.,iUus. Paper,525. introduction to Higher Order Categorical Logic. Time, Science, end Society in China and the help with living exponses during the J. I.ambek and P. J. Scott. Cambndge University Press, West.1. T. Fruer, N. Lawrence, and F. C. Haber, Eds. course. Applicants should submit New York,1986. x, 293 pp., iuus. 349.50. Cambndge University of Massachusetts Press, Amherst,1986. xx, curriculum vitas and a short para 9raph Studies in Advanced Mathematics,7. 262 pp., illa $35. The Study of Time, 5. Frorn a desenbing research interests and expected An introduction to identification. J. P. Norton. conference, Castello di Gargonza, Italv,1983. contributions of this course to their program Academic Press, Orlando, FL,1986. xiv,310 pp., iUus. Time Travel and Papa Joe's Pip'e. Alan Lightman by February 1,1987 to: 547.50; paper, 522. A treatment "at a fairly modest with ten illustrations by Laszlo Kubmvi. Penguin, New mathemaccal level" of model.buildmg frorn measure- York,19% viii,168 pp. Paper,55.95. Repnnt,1984 ments on a dynanucal system. edacon. Dr. Mchael Sinersky. Prtvam Drector. An introduction to' Aumen Studies. J. W. Czer- Tin in Antiquity. Its Mining and Trade Throur.hout Somatle Ces and Molendar Genetics wo* shop k2wski. Pergai. on. New York,1986. x, 236 pp., iDus. the Ancient World with Parocular Reference to Corn. Deanor Roosevet inststute for Cancer Research $29.50; pape*,516.50. wall. R. D. Penhauurick. The Insatute of Metals, lon- ,,99 g, gg Introduct,on to Supersymmetry and Supergravity. don,1986 (U.S. distributor, The Insorure of Metals Denver. Com M6 P. West. W rki Scient 6c, Philadelphia,1986. x, 289 Nonh American Publications Center, Brookfeld, VP). U.S.Cittzens Only, pp., illus. 337; paper,522. xiv,271 pp., illus. 548; to members, 538.40. introduction to the Graphical Kernel System To Advance Knowledge. he Growth of Ameican (GKS). F. R. A. Hopgood tr al. 2nd ed, revised for the Research Universities, 1900-1940. Roger L. Geiger. Internaconal Standard. Academic Press, Orlando, FI., Oxford Uruversiry Press, New York,1986. x,325 pp. % My 1986. xiv, 250 pp., iUus. Paper, 523 95. 327.50. P LI 4 A'E An Introduction to Three-Dimensional Climate Tokamak Start Up. Problems and Scenanos Related Doq Modenng. Warren M. Washington and Claire L. Parkin- to the Transient Phases of a Thermonuclear Fusion I 4, 9 son. Uruversiry Science Books, Miu Valley, CA, and Reactor Heinz Knoeyfel, Ed. Plenurn, New York,1986. Oxford Uruversity Pren, New York,1986. xvi,422 pp., x,432 Lp., iuus. 5/5. Ettore Majorana Intemaconal CHARTS AND ' in- 528- 5 a-u6. r- a a . taor. i* The Last Extinction. Les Kaufman and Kenneth 1985. G N HS mad ry, Eds. Pubished in cooperation with the New Touching. The Human S;gnificance of the Skin. En land A uanum to MIT Press, Cambndge, MA, Ashley Montag,L 3rd ed. Perennial Library (Harper and from your IBM PC, XT, AT 19 til 2 8 PP, iun 316.95. Fm a lectun sena, Rowh New Boston,1984. and HP or compatible plotter, paper,59.95.Jork, -1986. xvi, 495 pp., illus. S'18.95; Lattice Dynamical Foundations of Continuum Toward a New Security. Lessons of the F Theories. Elasocity, Piezoelectnci,ry, Viscoetasocirv, Since Tnniry. Union of Concernedsts, Cam- Scienuony Years ,,, i oo , '; Plasocity. Attila Askar World Scienu6c, Sin bndge, MA, 1985.73 ., iUus. Pa r, 53.50. 9 ! ti!* *%^ +L* 1985 (U.S. distnbutor, Tavlor and Francis, Pbapore,adel- Trace Elements in uman an[ Animal Nutrition. | M* % N( phia). xiv.192 pp., dius. 528. Senes in Theorcocal and 5th ed. Vol. 2. Waher Mertz, Ed. Academic Press, 5 \' , * * * * * Appbed Mecharucs, vol. 2 8 * , ' Orlando, FL,1986. xii, 499 pp., iUus. 552.50. g . ,, Learning and Memory. A Biological View. Joe L Transport of Suspended Solids in Open Channels. S '' ? . , Marunez, Jr. and Raymond P. Kesner. Eds. Acadenue W. Bechteler, Ed. Balkema, Accord, MA,1986. x,268 9 \ * '' i | Press, Orlando, FL,1986. xviii 452 pp., illus. 549.50; pp., suus. 350. From a symposium, Munich, June 1985. J ; * * pa r.124 50. da Ultraviolet Spectioscopy of Proteins. Alexander P. | 8 , ./ " * * ' ' ' ' " " arning and Memory. Mechanisms ofInformation Demchenko. Spnnger Verlag, New York,1986. xii,312 I , Storage in the Nervous System. Hansjurgen Marthics. pp.,illus. 595. Translated with revisions from the Rus- e is na 30 *o a u 'o W (***" I Pergamon, New York,1986. xiv 414 pp., iUus. 585 sian ediuon (Kiev,1981). Advances in the Biosciences, vol. 59. From a symposium, The Venus internettonal Reference Atmosphere. SICM A I>LOTwsof tware -$350. Ma deburg. GDR, Oct.1985. A. J. Kliore, V. L Moroz, and G. M. Keating, Eds. Error bars de Lectins Properties, Funcuons, and AppbcaoonsPublished for the Commance on Space Research by And Nowl in BxAogy and Medicine. Irvin E. Liener, Nithan Shar- Snuxith Lines Pergarnon, New York,1986. viii. 305 pp., aun Paper'. Multiple graphs on, and Irw n J Gokistein, Fds. Acadenue Press, Orlan- $52. Advances in Space Research, vol. 5, no.11. Clean diagonals per page do FL,1986. xviii 600 pp., illus. 372.50. Molecular Verification. How Much is Enough! Allan S. Krass. Movable labels a Curve fittinN B'u % Lexinn n Books (Heath), Lexington, MA,1986. x,273 logisemi-log Lectures on Special Relativity. M. G. Bowler. * 1aser printer h.,emah[ illus. Pa Peace Research Insurute'.r,313.95. Sponsored by Sipn, Stockhotrn ,cales support Perpn, New York,1986 t,72 ppsDa $15 paper, 37.50. Viral Structure. Jarnes R. Harns and Roben W. In.nl data from keyboard. ASCil or Lessons An Autobio Horne, Eds. Academic Press, Orlando, FL,1966. su, Landen AdJuon.Weslev, graphy. An Wang with Eufene I)lf files lincludmg IDTUS 1231 Readmg, MA,1986 xa,248 452 pp., illus. 598. Electron Microscopy of Procems, vol. pp + plares $1795. 5. Call or wrile lor rnore information. The Lexical Dar. David Corson. Pergarnon, New Ylruses, immunity, and Immunodeficioney. An- , | York,1985. tu,130 dor Szentnanvi and Herman Fnedman, Eds. Picnum, ' J ANDEL SCIENTIFlC Moiecuiar and ch.,illus.ar upects 329; paper,313 of caicium 75 in New York,1986. siv. 365 pp., iUus. 555. Un,verury of m o a i wru rs u ra w n s H ur rne M ir N rts r Plant Developrnerit. A. J. Trewavas, Ed Pknum, New South Flonda Intemaoonal Biomedical Symposia Senet 2656 Hridgeway. Sansahin. CA 94fE5 York. Im sn. 452 pp, iUut 375 NAFO Advanced From a sympos um, Tampa, FL. Apni Ib4 800-8741888 (outside CA) 5'''"'c Insunan Senes A, vol 1% From a workshop, With Our Own Hands, Research for Third World 415 3313022 h.nside. CA) Lt nbur-h, Juh 1985 Development: Canada's Contnbut on Through the in. Molecular Aspects of Neurobiology Raa Len ternauonal Development Research Centre 1970-1985 Cpcle No 103 on Readers' Service Card Mont.iluiu et al.1.ds 'spnnger Verlag. New York. IDRC, Ottawa, Ontano, 1986.206pp , illa Paper.

128 SCthNCli, VOL 2U t

e

VALBRIDGE J. POWELL e . . 4314 Islard Crest Vay Mercer Island, Va. 9'4 0 206-23205295 December 9, 1985

SUBJECTS COULD F TURE CASES OF AIDS BE CAUSED BY EXFOSURE TQ > SHIPMENTS OF RADICACTIVE WASTE OR EMISSIONS FROM NUGLun komi.H FLANTS 7 Is it possible that reduced immunity causedby persons being subjected to radiation exposure could result in their being more sus- ceptible to AIDS ( acquired immunodeficiency syndrome ) than would ordinarily be the case? I am not necessarily speaking of persons involved in the handlire, transpostation or processing of radioactive waste or the mining of uranium, refining of it, or workers employed in the services or in private industry who handle weapons and the substances going into them. They wouldeof course, be subjected to massivo doses of radiation and the inevitable compromising of their immune systems. I am referring specifically to emergency crews, motorists, pedestrians, hemoownere, and other citizens who are exposed to ionizing radiation - and vented gases and vapors emitted by radioactive substances in transit by air, rail, or truck as well as those being used in nuclear power plants. f All radioactive substances build up pressure and must be vented to the air. They must be cooled and are therefore surrounded by coolants which must , in turn be vented to the air. Shipping casks are not sufficiently impact j resistant to contain their cargo followird an accident. According to an article by Terry Kreiger and Dr. Cesar Caceres ! [ The Unnoticed Link in AIDS Caeg Vall Street Journal, October 24,19853 abusers of int ~ ravenous and oral drugs damage their immune systems and are highly susceptible to MLTT- III , Human T-cell Lymphotropic Virus, or AIDS. Turther Dr. Jay Levy of San Francisco 09neral Hospital called the | virus HLTV-III AIDS- associated retro-virus. [ Atlantic Magazine October j 1985 A Crists in Puolie Health ] = A retrovirus is a virus that integrates itself with the chromosomes of an invaded cell. In effect, the invaded cell . , becomes a factory for the retrovirus."As the cell divides, more viruses are produced. Let us now substitute cells weakened , not by drug abuse or other ! activities, but by radiation or ingested radioactive materials (gases or dustb.-)t Logic then dictates that these cells would be susceptible to invasion by the e same or mutated retroviruses since radiation causes disorientation of cells. Could we then conclude that exposure to radioactive substances alone would increase the probability that one could acquire AIDS.? In the next few months, a minimum of 36 casks of high level radioactive waste will be shipped across our country from west coast ports to Savannah ) / River, Geogia. This vaste originates in in Taiwan, as spent fuel from a I "research reactor. Are we to put ourselves e.nd our children at risk in order for some Taiwanese and U. S. Businessmen to make vast sums. of money ? These shipments are 'the tip of the iceberg. Vespons are shipped daily dcyn our highways.

I

The US Department of energy is planning to use the freewayn of our nation to transport vast quantities of radioactive waste to dumps. This includes that albeady overloading the holding pools at operating nuclear power reactors.

AIDS is a natural plague while radioactivity is our own man-made | plague. Vill we ut.e the two to eliminate ouroelves from this planet ?

hh''.hWfValbridge J Towell

|

.,v j ___ amr maan ! EERGEDRIU dd rxxtrEe" - 22iune 1987 oo@aWW E DI 29 A9:17 _ c o t.u M B ' R, . d!rt, Wa 99122 v .g 3 2sme ; E ga g (509) 725-6666 gg/r ( | HANFORD ~ mM G |i, , BRI.W ______.Hanford- - - Richland Reach : Pasco x,,,,, Proj. ect | Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555

Attn: Docketing and Service Branch COMMENT on the DEFINITION OF "HIGH-LEVEL RADIOACTIVE WASTE"

Dear Mr. Seemtary:

SEARCH Technical Services is a scientific consulting fum studying pathways of contaminated groundwater entering the Hanford Reach of the Columbia River, in the public intemst.~ Inasmuch as the definition of High-level Radioactive Waste affects the final plac~ement and engineered confinement of Hanford wastes, SEARCH is interested in that dermition. Therefore, to assure reasonable futum health, safety, and environmental quality of the region, SEARCH presents the following technical comments re'sponsive to your Advance Notice _o.f, Proposed Rulemaking on the Definition of "High-Level Radioactive Waste." SUMMARY . . The proposed Definition is seriously flawed. It would allow all waste which is presently classified as High-level Waste to be diluted or otherwise processed and excluded from the Dermition of High-Ievel Waste. This is inconsistent with sound waste management. 3 SEARCH recommends that NRC not alter the Definition of High-Level Radioactive Waste, in ! the pmposed manner. Particular problems with the Proposed Definition are... |

4 * 1 * The objective of making the Definition more risk-based is valuable but is not served N 4 by the proposed Definition because that Definition is actually not risk-based. To the extent that Q G> the proposed Definition is less soume-based,it allows the dilution of radioactive waste in order % i the feasibility of its isolation from the environment. , , %. to lower the Defined risk of that waste. Such dilution would increase waste mass and decrease ' + 2 * The conceptual model for the pmposed definition does not accord with the stated - objective of making the Defimition more risk-based. In particular, the concepts " Radioactivity * Level" and " Degree of [ Required) Isolation" are not appropriate components of risk for the y Definition of High-level Radioactive Waste, k 3 The actual summations proposed for these conceptual components do.not accord with these components. .Indeed, a summation of only short-Lived radionuclide. concentrations is 3N proposed to represent " Radioactivity Level", and a summation of only long-lived radionuclide - ~ concentrations is proposed to represent " Degree of Isolation." The net' effect of these proposals % is to define High-Level Radioactive Waste as waste having high concentrations of both short- Q lived and long-lived radionuclides. 'Ihis introduces several opportunities for mischief. I\ acknowledged by...... w card.214.1.... 1987m

, .

22 June 1987 H nford Re ch Project PAGE 2 ,

TECHNICAL COMMENTS 1. OBJECTIVES

The objectives of the Proposed Rulemaking, as described by Daniel Fehringer of NRC at Waste Management 1987, are commendable and useful. In particular, by introducing the concept of quantitative risk management into the proposed Definition of High-Ievel Radioactive

- Waste NRC could significantly decrease the cost of required waste~' disp~' ~osal^ " ~ while~ ' ~ ^ reducing ~~ ' future risks to both humans and the environment. In order to base a Dermition of High-Level Radioactive Waste on risk, " Risk" must first be defined in a meaningful manner. Such a definition of " risk" must include risk to human populations over time and risk to the environment over time. For a particular radionuclide in a . particular waste package, those risks depend on the

Comoonents of Risk of a carticular radionuclide in a waste oackace , = (a) + weighting factor for tlie particular radionuclide, based on environmental ! and biological pathways and impacts, j * (b) . radionuclide concentration, t' * (c) volume of the waste package, j * (d) . physical and chemical fomi of the radionuclide in the waste package, and ; - (e) . management of the waste package. , i The first four, listed components of risk involve properties of the waste, itself, and could be used to define " Risk" quantitatively as part of a risk-based definition of High-Level Radioactive Waste. The final component of risk is the administrative component which would result from waste disposal practices in accord with regulations promulgated by NRC.

Unfortunately, NRC has only addressed the weighting factor (a) and concentration (b) ! components of risk. The omission of the other components is apparent in Issue 5 of the ANPR on which public comments are particularly sought. There NRC wonders whether particular kinds of waste materials [ Item (d)) and total activities [ Item (b) multiplied by Item (c)] need to be included in the definition of High-Level Radioactive Waste. Fmm the discussion I have just rovided, it is apparent that these considerations need to be incorporated in the definition of ;. p' Risk" rather than in the definition of "High-level Radioactive Waste." *

This failure to define Risk in the Proposed Rulemaking precludes a meaningful, risk- based definition of High-level Radioactive Waste. This failure introduces a loophole into the Proposed Definition which allows all waste which is presently defined as High-Level (based on , the source of that waste) to be diluted and excluded from the Proposed Defimtion of High-Level Radioactive Waste. For example, the " irradiated reactor fuel" which is specifically identified in the Proposed Definition could be " processed" by the addition of clean soil to form a mixture having concentrations of both short-lived and long-lived radionuclides below the limits specified in Tables 1 and 2 of the Proposed Definition.

Thus, in failing to define " Risk" in adequately, the Proposed Definition of High-Level Radioactive Waste is not actually risk-based and introduces the possibility of unsound (risky) management of high-level waste. j

i

___ -

,I 22 June 1987 Hanford Reach Project PAGE 3 .

2 * CONCEPTUAL MODEL . > The basic concept of the Proposed Rulemaking is to define High-Level Radioactive Waste l' in terms of " risk"; that is High-level Radioactive waste would be that Radioactive Waste which { would pose a high risk of hazard to future health, safety, and environmental quality if that waste I wem ever released. |

-- _NRC has sought to define " Risk", conceptually,in terms of two. compo,nents: _ ; i Radioactivitylevel > f - - Degme of[ required] isolation I ; This is mpresented by the following picture | RPl ( a n g HIGH-LEUEL $ LURSTE % 5 OTHER m %v E LURSTE E

l & , DEGREE OF ISOLRTION

.

Fig.1. CONCEli OF PROPOSED HIGH LEVEL WASTE , DEFINITION (from Fig. 2, D.E. Wood, M.H. Campbell, M.W. Shupe, " Impacts and Ramifications of Defining High-Level Waste)

in which "RPI" is a specified quantity, to the right of which the waste " Requires Permanent Isolation", and "HR" is a specified quantity, above which the waste is " Highly Radioactive." That is, NRC pro mses to equate "High-Level Radioactive Waste" to HIGHLY RADIOACTIVS waste which REQUIRES PERMANENT ISOLATION. From the discussion in the last section, it is clear that Radioactivity Level and Degree of [ Required] Isolation are not sufficient co'mponents for the definition of " Risk." In particular, two imponant characteristics of a waste package which affect its risk

* (c) * volume of the waste package and * (d) physical and chemical form of the radionuclide in the waste package

are excluded. Thus, the the Proposed Definition does not include sufficient components of risk to form an adequate risk-based Definition of High-level Radioactive Waste.

: 1 22 June 1987 Hanfcrd Reach Project PAGE 4 ; ' \ 3. IMPLEMENTATION 1,

NRC supposes that Radioactivity Level and Degree of Isolation can be quantified in accord with limits in Tables 1 and 2 of 10 CFR 61, as follows:

' Concentration (1) . RADIORCTIVITY LEUEL:li Limit (1)in Table 2 ~ ~ _ . _ _ . _ . _ _ . _ _. _ - ______, , _ _ , _ , _ , _ , , _ _ _ ,

DEGREE OF ISOLATIONLimit (1)in =l, Table Concentration i (1)

In words, these equations are

RADIORCTIVITY LEVEL " ! ! CONCENTRATIONS OF SHORT-LIVED RADIONUCLIDES i !! l ! DEGREE 0F [ REQUIRED] ISOLRTION . CONCENTRRTIONS OF LONG-LIUED RADIONUCLIDES

The first equation is nonsensical at face value. Radioactivity has units such as " Curies" or " Curies per cubic meter", which are not specific to "Short-Lived Radionuclides." If NRC seeks to define High-Level Radioactive waste as that waste which is both Highly Radioactive and requiring long term isolation, the activity of the long-lived fraction is important - not the short- lived fraction. In terms of Fig.1, the conceptual model could be sketched as i

eN J L RPI | *

< Long-Lived Concentration (1) Radionuclides g Limit (1)in Table 1 Fig. 2. HIGH LEVEL WASTE AS BOTH HIGHLY RADIOACTIVE AND REQUIRING PERMANENT ISOLATION in which the definition of High-Level Waste would not depend on the short-lived fraction of the waste. Instead, NRC proposes to define High-Level Radioactive Waste as containing high I levels of both shon lived and long-lived radionuclide wastes.

In order to appreciate the implications of the Proposed Definition of High-12 vel Radioactive Waste, consider three idealized examples:

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. - \ 22 June 1987 IIanford Re:ch Project PAGE 5 ,

' First, assume that there are two packages, each containing one cubic meter of waste. Suppose that Package #1 contains a thousand Curies of iodine-129 in otherwise clean sand and that Package #2 contains a million Curies of strontium-90 in otherwise clean sand. Then ! Package #1 far exceeds the limit (0.08 Ci/m3 for iodine-129) on long-term radionuclides in i Table 1 of 10 CFR 60, and Package #2 far exceeds the limit (7000 Ci/m3 for strontium-90) on short-lived radionuclide concentration specified in Table 2. Yet Package #1 contains no long- !) ' lived radionuclides, and Package #2 contains no short-lived radionuclides. Therefore, - according to the Proposed Definition of High-Level Radioactive Waste, neither package would be classified as IIigh-Level Radioactive Waste. , Now suppose the two hypothetical packages are placed side by side and wrapped together in a sheet of brown paper. The volume of this wrapped package is two cubic meters, and it , contains 500 Ci/m3 ofiodine-129 and 500,000 Ci/m3 of strontium-90. The " sum of fractions rule" proposed for Tables 1 and 2 provides a sum of 6321, which greatly exceeds one. Therefore, the addition of wrapping paper would make the waste Iligh-Level Radioactive under the proposed Definition.

Similarly, if a package of radioactive waste was High-level according to the Proposed Definition, then the waste would no longer be High-Level if it were processed into subpackages which were short-lived and long-lived.

This could be taken to an extreme by merely considering each atom in a batch of waste to be a " waste package" with the electrons acting as the container of the " waste" in the atomic ' nucleus within. Then any waste package (atom) would contain only one long-lived or one short-lived radionuclide (nucleus). Thus, the batch of waste, considered to be a collection of many atomic waste packages, would not be High-Level Radioactive Waste acconting to the Proposed Definition because no package would contain both a long-lived and a short lived radionuclide.

Although these examples are extreme, they demonstrate that th'e Proposed Definition of High-level Radioactive Waste has loopholes which would allow any and all waste to be processed, fabricated, or evaluated in ways to exclude it from the Proposed Definition.

If you have questions or remarks concerning these commeuts, please be free to contact me.

Respectfully yours, SERRCH tecFmt at servlees

Norm Buske xc: NIRS HEAL

- _ - _ _ _ - - _ _ _ - _ - _ _ - _ _ _ _ _ - _ _ - ______JOCKET NUMBER ' ! - I E8DEDSED ' RULE. Md Csz se 7992 - 000 d.E T E !SNEC

t ry 87 JUN 29 All:09 , 8uS NC Washington, D.C. 20555 [ OFF!c:. .. :. u< . June 23, 1987 00CK!)' A f .@U

Dear Secretary; b \ I am writing iri response to the NRC's intention of revising the - definition of "high-level" radioactive waste. I urge you to continue

considering all the liquid and sludge from reprocessing, and the solids ,

into which some of the liquids are converted, as "high-level" , ' radioactive waste. In addition, wastes which are currently considered ; " low-level", but which are either intensely radioactive or contain long-lived radionuclides, or both,.such as reactor pressure vessels, reactor shrouds, and other reactor internals, should be reclassified into the "high-level" waste category.

Sincerely, . .

Ann Fitzpatri 203 G Eagle Heights Madison, WI 53705

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'87 JLN 29 P4 :12 HC-74, Box 61C Chadron, NE 69337 ' f0C II53 s ''Ibf 3""" E0' 1987 BRANL- 3 Secretary j

USNRC 3 Washington D.C. 20555 . Attn. Docketing and Service Branch | ,

t I wish to subolt my comments on the intention to revise the definition of "high-level radioactive waste", Federal Register, 52 FR 39:5992. Radioactive n:aterial that is either long-lived, highly radioactive or both, should be classified as iigh-level radioactive waste. The Federal gevernment,through the NRC, licenses the generation of radioactive waste for which the states have no control. The fiRC requires 1GG years of institutional control of a so calle: " low-level" redioactive waste site followirg closure, at which time the site can legally be returned to unrestricted use.

The Federal government should take responsibility for all ' radioactive waste that remains hazardous beyond the 100 year institutional control period. Nickel-59, for instance, remains hazardous for 760,000 to 1,520,000 yeais.

The term, " low-level radioactive waste" suggests that the waste is less hazardous than actually is the case. It is a term without cefinition and is highly misleading to the general public. The NRC would gain a measure of public confidence by removing the intensely radioactive and long lived radionuclides that are associated with nuclear reactors from the " low-level" radioactive waste category.

Sincerely

i ||/f Ted Ho fr~ , Member Gover no r o Low-Level

Radioactive Waste Task Force 1

CC: Governor -% Orr Norm Thorson, Chair LLRW Tact. Force

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Connecticut Citizens for Safe Energy '87 JW 29 P4 :12 P.O. Box 848 Willimantic, CT 06226 . . vFVli .. .. 00CKEliM;<, M .w"qq 25 June 1987 gggggs . Secretary

U.S. Nuclear Regulatory Commission . Washington D.C. 20555 Attn: Docketing and Service Branch i i Dear sir: The membership of Connecticut Citizens f or Saf e Energy has authorized submission of the f ollowing comments relative to: Proposed rules to amend definition of high-level radioactive waste, as announced in the Federal Register (52 FR 39:5992).

1. All liquid and sludge from reprocessing, and solids into which some of the liquids are eventually converted, must continue to be considered "high level" radioactive waste. This because such wastes are either highly radioactive or long lived.

2. Some radioactive " low-level" wastes should be placed in the "hi gh-l evel " category. This includes contaminated and activated metals which are either intensely radioactive or contain long-lived radionuclides, such as: Reactor pressure vessels, Reactor shrouds, Irradiated primary system components and piping, Other reactor i nt ern al s , } Tanks used to store reprocessing liquids and sludges,

e . 9 ND 3. Another class of " low level" radioactive wastes which $ % must be moved into the s "high-level" category's.are those which - have hazardous liv h lo.nger than e , Nd are highly radioactive or " low-l evel " waste si tes are requi red to l ast, such as: 1 ]y 7 Poison curtains from reactor cores and irradiated fuel pocls,

Sk .. Control rods from reactor cores. N Crud (solid radioactive materials such as corrosion S products in the primary system), -- .1

Q( . " ys Resins, sludges, evaporator bottoms, filters from g h cleaning the reactor water, , qr Radioactive materials bound to chel ating agents. r

.___ ,, 4. The suggestion to cl assif y wastes as high level or low l evel based on certain as yet to be defined concentration ._ ,k,I levels is a dangerous precedent which is unacceptable.f,or,,,,_ ,_ , \q several reasons:

_ 196? - I . ~.,~ w osycon,., QJUL 1 i t* j ' i i

a. Such a scheme would act as an incentive to dilute dangerous quantities of curies of radioactivity into the f air, water, or soil so that reduced concentration would qualify the waste as "l ow-l evel ", or even "below regul atory .| concern". However, it is well established in radiological ' epidemiology that deaths (as well as poor health) are { proportional to total person-rads, and thus indirectly to total curies. I i l b. Such a scheme ignores the time during which the waste is dangerous, and would perpetuate the present system j under which dangerously long-lived radioactive wastes are { cl assi f i ed as l ow-l evel and placed in waste sites which must ; be subject to institutional control for periods much less than the periods for which they should logically be isolated from the environment. The proposal set forth in 52 FR 39:5992 could result in sites containing wastes currently considered "l ow-l evel " (such as nickle-59 with a hazardous life of about a million years) being legally returned to unrestricted use in only a hundred years,

c. The proposal is dangerous 1v unspecific as to what the l ow-l evel waste concentration limits will be, even if the concept of concentr at i on l i mi ts were acceptable.

Yours truly,

-- - Morgan Charles W. i

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CD ALITION ON WEST VALLEY NUCLE AR WASTES Sharp Street, East ae d NY 14055

June 24, 1 7 0FFid 19 - da Secretary of the Commission DEggcp e U.S. Nuclear Regulatory Commission Weshington, D.C. 20555 Attn.: Docketing and Service Branch

i; I have the following comments on the advance notice of proposed '' NRC rulemaking regarding definition of high-level radioactive waste ' (published in Federal Register, Feb. 27,1987, pp. 5992-6001):

1) Dilution of wastes (to downgrade them from a high-level to | a low-level classification) may be practiced by some waste generators ; if high-level waste (HLW) is defined in terms of radionuclide j| NRC must address this issue and must set cle ar, concentrations. } strict limits on dilution. ;, ! 2) The advance notice of propose rulemaking quotes the West Valley Demonstration Project Act defi ion of HLW, but does not indicate how the proposed rulemaking would affect the classification of existing wastes at West Valley. NRC must address this issue. , For example: a) The last paragraph on p. 599h of the Federal Register ! notice discusses the possibility that nonradioactive salts mixed j with residual amounts of radioactive contaminants may be removed from ; liquid HLW. A similar process is about to be undertaken at West t, V alle y. |l mixture beWill changed the classification by the proposed of therulemaking? resulting) bcontaminatedA certain amount salt of !| sludge-like HLW is expected to remain at the bottom of the HLW tank |l 8D-2 at West Valloy af ter the tank has been emptied and cle aned as : much as possible. Will the classification of the sludge-like HLW ! that remains in the tank be changed by the proposed rulemaking?

' 3) If the proposed rulemaking has the potential for changing the classification of any existing wastes at West Valley, or at j >> s Hanford ( as discussed on p. 5999 of the Federh1" Register notice),o Na or anywhere else, then the rulemaking will constitute a federal ' 5 g agency decision that has environmental consequences. An environmental % review under NEPA would be necessary to determine whether the effect M cn the environment would be significant. It seems appropriate to compere the environmental effects of the propoced alternatives (i.e., the options under both Clauses) by me ans of an environmental review " y before the decision is made on the HLW definition. ' , . ha) There is a pervasive misuse of the " Class C" waste classifi- cation throughout the advance notice of proposed rulemeking. The ) Q HLW definition need not refer explicitly to "C3 tass C" at all, yet the- { .. arguments and logic in the advance notice rely so he avily on " Class C" that this point must be addresse d by NRC . 1 b " Class C" was set up within the context of 10 CFR 61. An | g import)nt fe ature of 10 CFR 61 i s , as stated in the appendix to the \ Acknowledged by ca rd . . . . m ...... ; ! ' -2-

. , advance notice, that the "Part 61 regulation is intended to be : performance-oriented rather than prescriptive, with the result that ! the Part 61 technical criteria are written in relatively general 4 terms, allowing applicants to demonstrate how their proposals meet these criteria for various specific ne er-surf ace disposal methods." ! I c) Outside the context of 10 CFR 61, the " Class C" waste ; classification has not been properly defined and has received no | environmental review. d) The proper definition of " Class C" is based on both stability and radionuclide concentration, but many people who use the term " Class C" ignore the stability aspect of the definition. The stability aspect is made clear in both 10 CFR $61.7(b) and 10 CFR $61.55( a)(2) . In particular, the following subsection 61.55( a)(2)(iii) appe ers prior to any numerical specification regarding Class C and is either the primary definition, or a major part of the definition, of Class C: " Class C waste is waste that not only must meet more rigorous requirements on waste form to ensure stability but also requires s additional me asures at the disposal f acility to protect against inadvertant intrusion. The physical form and characteristics of Class C waste must meet both the minimum and stability requirements set forth in $61.56." e) An Environmental Impact Statement (NUBEG-09h5) was done for 10 CFR 61, but no environmental review of the " Class C" waste classi- fication has been done outside the 10 CFR 61 context. In particular, 10 CFR 61 does not apply to DOE operations, es was noted in $6.2.13 , of the 10 CFR 61 Environmental Impact Statement: " Disposal of LLW by DOE is exempted from NRC licensing authority and would remain so under the final Part 61 rule. Therefore, DOE 's LLW disposal operations would be unaffected by the rule and could not come under its purview ; without an amendment to the Energy Reorganization Act of 197h."

, f) Thus, it is false and misleading for NRC to suggest in the present advance notice that across-the-board " Class C concentration limits" have been established by proper rulemaking procedures. The so-called " Class C concentration limits" apply only to applicants -who will be regulated by NRC and who will comply with the performance- i oriented provisions of 10 CFR 61. " Class C concentration limits" were' never intended to apply to DOE operations that are not licensed by NRC. g) The inapplicability of 10 CFR 61 and " Class C concentration limits" to DOE operations is not merely a formality. DOE has made it cle ar that DOE will not be bound by the full set of 10 CFR 61 regulations. DOE re jects some of the provisions of 10 CFR 61 as "not I applicable." Other provisions of 10 CFR 61 are accepted by DOE but | are misinterpreted as prescriptive rather then performance-oriented, contrary to the intent of 10 CFR 61. DOE also refuses to submit to the 10 CFR 61 procedure of " allowing applicants to demonstrate how their proposals meet" the Part 61 technical criteria. I can provide specific exemoles of DOE's noncompliance with 10 CFR 61 upon request.

| h) Therefore, much of the logic and explanatory material | presented in the advance notice is f aulty because " Class C concentration . 3-

O limits" and other 10 CFR 61 concepts are being improperly applied to unlicensed low-level waste as a me ans of deriving a definition | of HDV. Sincerely,

.% \ I -

Raymond C. Vaughan i i

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