To Whom It May Concern:

I am an American citizen living in Boston, with a concern about the proposed advanced reactor licensing Rule currently being commented upon. I have no connection with the nuclear industry, but with a stake in the decisions that the NRC will take in the near future. According to press reports <1>, the original intention to include health metrics to assess public safety under the Rule, has been shelved including an NRC staff draft on health assessment. If  I understand correctly, the NRC Commissioners  oppose the inclusion of “quantitative health objectives” (QHOs) from the licensing Rule, on the grounds that low probability of significant radiation exposure can be assumed. In  other words, the low radiation-related excess risk of the QHOs will be hard to distinguish from the baseline lifetime risk of cancer, and would also impose significant time-burden and monetary directives for the nuclear industry and the NRC.

As a citizen and energy consumer with choices, I rank the protection of human health (for industry workers and community members near by the reactors) above alleged efficiency gains and profits.

 I urge you to review two studies referenced here <2-3> that disprove  the argument that low-level radiation is indistinguishable from background “noise”, and harmless.

The first study <2> , known as the International Nuclear WORKers study (INWORKS), assembled a cohort of 308,297 radiation-monitored workers employed for at least one year in nuclear facilities located in France, UK and USA. This added up to 8.2 million person-years. The study provided strong evidence of positive associations between protracted low-dose radiation exposure and leukemia. The excess relative risk of leukemia mortality was 2.96 per Gy, particularly mortality associated with chronic myeloid leukemia (excess RR : 10.45 per Gy). The authors make the stunning comparison between nuclear workers and atomic bomb survivors exposed at bomb detonations between 20-60 years of age, i.e. quantitative exposure to radiation and RR for leukemia are very close in both bomb survivors and nuclear workers.  Excess worker deaths were considerable in all three countries.

The second study <3> reassessed radiation exposure in communities within 10 miles of the TMI meltdown on March 28, 1979. Refuting earlier studies that doubted a measurable health effect on nearby towns, the authors found significant associations between accident doses and both leukemia and lung cancer, controlling for possibly confounding variables. The association increased with proximity to the plume path of emitted radiation and with longer latency, as expected. Because of dysfunctional external air monitoring equipment during large steam releases, these results are probably understated. Given TMI’s central importance in the widely-advertised second coming of the nuclear power industry,  I recommend two courses of action:

• Commission a long-term study of TMI workers and nearby community residents up to the present, to get the real picture before relicensing TMI to operational status  at considerable taxpayer expense, as these things go;
• Consider lowering the annual permissible dosage for workers, so that the RR for workers’ cancer incidence will not follow the predictable path cited in <2-3>. Every worker has  the right to work in safety and peace, for a fully enriched life. The OSHA standard (see below) could become the national standard, applicable to all nuclear facilities.

Comparisons: yearly permissible radiation exposure on the job (rem)

NRC: 5  OSHA: 1.25 EU: 2 Japan 25*

*Raised to handle Fukushima-Dachi cleanup that TOEPCO estimates will be completed in 2060.

Sincerely,

Joseph M. Hunt
Dorchester, MA 02124

References

1. NRC removes ‘quantitative health objectives’ from proposed advanced reactor licensing rules. Utility Dive 25 October 2024.
2. Leuraud, K. et al. Ionising radiation and risk of death from leukemia and lymphoma in radiation-monitored workers (INWORKS): an international cohort study.  The Lancet.com/haematology July 2015, Vol 2:276-281.
3. Wing, ,D. Richardson, D. Armstrong, D. Crawford-Brown. A reevaluation of cancer incidence near the Three Mile Island nuclear plant: the collision of evidence and assumptions. Environmental Health Perspectives
   Vol 105, No 1, January 1997:52-57.