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RESPONSES TO NUCLEAR REGULATORY COMMISSION COMMENTS IN TURKEY POINT ENVIRONMENTAL IMPACT STATEMENT

The GEIS Supplement 5, Section 4.7.1, Evaluation of Potential New and Significant Radiological Impacts on Human Health, discusses and dismisses the findings in the RPHP published report on "Strontium-90 in Deciduous Teeth in Early Childhood Cancer" (referred to as the "Gould report"). The main responses of the Radiation and Public Health Project (RPHP) to the Nuclear Regulatory Commission (NRC) evaluation are as follows:

1. The Gould report was not available to the NRC at the time the GEIS was written.

   The article by Gould and his associates in the International Journal of Health Services was published in September 2000, well before the EIS was completed in May 2001. (20) It has been available in medical libraries, plus online at www.nlm.nih.gov or www.radiation.org.

2. Comments that the GEIS should include adverse health effects of radioactive emissions and Sr-90 measurements in baby teeth are not new information.

   The Gould study represents the first assessment of in-body measurements of radioactivity and its health effects near U.S. nuclear reactors. The NRC, public health departments, including the Florida Department of Health, and utilities have never made such measurements.

3. Only one study (26) was cited by the GEIS as evidence that no causal association between nuclear facilities and cancer exists.

   There are numerous articles published in the medical literature that document elevated levels of cancer near nuclear facilities or after reactor accidents like Three Mile Island and Chernobyl. At least 11 studies in the United Kingdom alone show high levels of childhood cancer near various nuclear plants. (6-16)

4. NRC permissible limits for radioactive emissions are based on recommendations from organizations such as the International Commission on Radiological Protection and National Council on Radiation Protection and Measurements.

   The GEIS does not adequately address the evidence that the fetus and developing infant are at significantly higher risk of cancer and brain damage from low-level radiation that had been previously understood. This evidence is presented in the 1990 report of the Committee on the Biological Effects of Ionizing Radiation, National Research Council – National Academy of Science (BEIR V), in 1990. (27)

   The BEIR V report states "there is concern about radioactivity in the environment around nuclear facilities." It also notes that, "…the new data do not contradict the hypothesis, at least with respect to cancer induction and hereditary genetic effects, that the frequency of such effects increases with low-level radiation, as a linear, nonthreshold function of the dose." In other words, there are no safe limits for exposure to radiation, especially for the developing fetus.

5. The average value across the U.S. today from fallout of atmospheric nuclear weapons tests should be approximately 4 pCi of Sr-90 per gram of calcium in baby teeth.

   The average radioactivity concentration in St. Louis baby teeth from bomb test fallout plummeted from 11.03 to 4.60 pCi Sr-90/g Ca from 1964 to 1970, after the bomb testing ended. In addition, British researcher Janine Bell calculated that by the mid-1980s, the burden of radioactivity from bomb test fallout was below the 1951-52 levels, at the beginning of bomb testing. (28) Both constitute evidence that current levels of bomb test fallout should be well below 4 pCi, and perhaps close to zero. As opposed to the NRC’s projected Sr-90 levels in soil, RPHP is referring to projected Sr-90 levels in bone and teeth.

6. Rhabdomyosarcoma is not rare.

   Writing in the New England Journal of Medicine in 1999, two Mayo Clinic researchers estimated the number of new cases among the 60 million American children under age 15 to be only 250 per year (out of 8,000 total childhood cancer cases). (29) The rate of rhabdomyosarcoma in western Suffolk County NY, near a number of nuclear reactors, is 15 times higher than the national rate. (22) (See Appendix 2).

7. No association has been documented between the incidence of rhabdomyosarcoma and any environmental condition, including radiation exposure.

   In 1991, University of Pittsburgh researchers published a study showing that children of women who received X-rays during pregnancy had twice the risk of developing the disease. (30) In 1999, an Arizona research team demonstrated that one-quarter of mice who had Sr-90 applied to their skin developed rhabdomyosarcoma or a related soft-tissue cancer. (31)

8. While cancer risk has doubled in the past half-century, this increase does not appear to be due to environmental causes other than cigarette smoking.

   Cancer incidence in Connecticut children under age 10 has nearly doubled from the early 1940s to the mid-1990s, an increase similar to the adult population. (32) None of these cancers are caused by children using tobacco; and because the rate of smoking among adults (parents) has declined about 40% since the mid-1960s, (33) the increase is due to factors other than tobacco. Children are most susceptible to the effects of environmental toxins such as radiation.

9. It is not apparent that the Gould report included control groups.

   The baby teeth study contains several control groups, including temporal controls, distance from reactor controls, and Sr-90 levels before and after reactors open and/or close. In 10 teeth from children born at least 200 miles from nuclear reactors, the average Sr-90 concentration is about 60% below that of those born near reactors. In addition, Sr-90 levels in 19 teeth of children born in San Luis Obispo County CA, after the startup of the Diablo Canyon nuclear reactors in the mid-1980s, are 50% higher than for children born before the reactors opened. Additional control data are being analyzed.

10. The Gould report does not report factors such as where the mother lived while pregnant, nor consider the source of food that the children may have consumed.

    The report states that all baby teeth are classified according to where the mother lived during pregnancy. It also collects information on the type of water (bottled, municipal, other) consumed in the household. This data is clearly outlined in the methodology section of the Gould report.

11. The American Cancer Society reports that studies show cancer clusters do not occur more often near nuclear plants than they do by chance elsewhere in the population.

In counties within 30 miles of nuclear plants in the eastern U.S., rates of cancer in children under 10 years old from 1988-97 exceeded national rates in 13 of 13 areas (see below). The cancer rates in Miami-Dade County and in Martin/St. Lucie Counties are the highest of all these. (34)

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