[ RadSafe ] [Fwd: 2.802 request to modify exposure and environmental limits of heavy metal radionuclides]

Sat May 7 04:52:01 CEST 2005

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Subject: 2.802 request to modify exposure and environmental limits of 
heavy metal radionuclides
Date: Fri, 06 May 2005 19:45:16 -0700
From: James Salsman <james at bovik.org>
To: secy at nrc.gov

Secretary
Attn: Rulemakings and Adjudications Staff
U.S. Nuclear Regulatory Commission
BY EMAIL AS PER 10 CFR 2.802

      PETITION FOR RULEMAKING TO AMEND 10 CFR 20

Dear NRC Secretary and Rulemakings Staff:

I request that the regulations comprised of all the values in
10 CFR Part 20 specifying limits for ingestion and inhalation
occupational values, effluent concentrations, and releases to
sewers, for all heavy metal radionuclides with nonradiological
chemical toxicity hazards exceeding that of their radiological
hazards be revised and amended such that those limits properly
reflect the hazards associated with reproductive toxicity,
danger to organs, and all other known nonradiological aspects
of heavy metal toxicity.

Many of those limits specified above apparently consider the
radiological hazard of certain chemically toxic radionuclides
with slight radiological dangers, for example Uranium-238,
without regard to their greater nonradiological hazard.  For
example, the soluble forms of Uranium-238 compounds, which are
more toxic if inhaled than the insoluble compounds, are allowed
in greater quantities than their insoluble compounds.  Other
examples may include but are not necessarily limited to
Uranium-232, Plutonium-239, and other long half-life isotopes
of the heavy metal elements.

Please note:  This petition does not request increasing the
permissible quantities given by any of those limits specified.

I further request that the classification for uranium trioxide
within Class W, given in the Class column of the table for
Uranium-230 in 10 CFR 20, be amended to Class D in light of
P.E. Morrow, et al., "Inhalation Studies of Uranium Trioxide,"
(Health Physics, vol. 23 (1972), pp. 273-280), which states:
"inhalation studies with uranium trioxide (UO3) indicated that
the material was more similar to soluble uranyl salts than to
the so-called insoluble oxides ... UO3 is rapidly removed from
the lungs, with most following a 4.7 day biological half time."

I further request that monomeric (monomolecular) uranium
trioxide gas, such as is produced by the oxidation of U3O8 at
temperatures above 1000 Celsius (R.J. Ackermann, R.J. Thorn,
C. Alexander, and M. Tetenbaum, in "Free Energies of Formation
of Gaseous Uranium, Molybdenum, and Tungsten Trioxides,"
Journal of Physical Chemistry, vol. 64 (1960) pp. 350-355:
"gaseous monomeric uranium trioxide is the principal species
produced by the reaction of U3O8 with oxygen" at 1200 Kelvin
and above) be assigned its own unique solubility class if
necessary, at such time in the future that its solubility
characteristics become known.

I am interested in this action because my health and the
reproductive health of my family depends in part that those
limits specified above correctly reflecting the risk of a
chemical toxicity hazard when it is greater than a
radionuclide's radiological hazard.

In support of this petition, I include below my email of
4 May 2004 to Tom Essig of the NRC, submitted in response to
his questions to me during the 2.206 pre-review petition
presentation concerning pyrophoric uranium munitions that day.

I do not request suspension of any other proceedings, including
the licensing proceeding to which I am currently a party; I ask
that proceeding continue concurrently with this rulemaking.

Sincerely,
James Salsman

...

---- from: http://www.bovik.org/du/du-petition.html#app-b ----

Subject: air concentration for uranium compound inhalation limits
Date: Wed, 04 May 2005 14:02:31 -0700
From: James Salsman <james at bovik.org>
To: Tom Essig <THE at nrc.gov>, Joe DeCicco <JXD1 at nrc.gov>

[Dear Mr. DeCicco:  I am appending this message to my copy
of the petition, and I ask that you distribute it to the
Petition Review Board and the licensees.  Thank you.
Sincerely, James Salsman]

Dear Mr. Essig:

Thank you for your questions during the 2.206 pre-petition review
presentation today.  If I understood the last one correctly,
you asked for my assessment of the current regulations for
soluble uranium compound inhalation, as specified in 10 CFR
20.1201(e) and footnote 3 of appendix B to part 20.  In
particular, you asked for peer-reviewed medical or scientific
articles pertaining to the proper way to determine such
values when chemical toxicity rather than radioactivity is
the primary hazard, as is the case with depleted uranium.

10 CFR 20.1201(e) states, "In addition to the annual dose
limits, the licensee shall limit the soluble uranium intake
by an individual to 10 milligrams in a week in consideration
of chemical toxicity (see footnote 3 of appendix B to part 20)."

Footnote 3 is about eight paragraphs and a 7 x 8 table, at:
http://www.nrc.gov/reading-rm/doc-collections/cfr/part020/appb/footnotes.html#3

The Specific Activity chemical toxicity equivalence for
depleted uranium is given in Footnote 3 as 3.6*10^-7 curies per
gram of elemental uranium, or 0.36 microcuries per gram.

The tables for Uranium-238 Inhalation Occupational Values -- at:
http://www.nrc.gov/reading-rm/doc-collections/cfr/part020/appb/Uranium-238.html
-- specify:

     Class D (e.g. uranyl nitrate):
       1 microcurie "Bone Surf"(?) (2 microcurie) annual limit on intake
       6*10^-10 microcuries/milliliter derived air concentration

     Class W (e.g. uranium trioxide):
       0.8 microcurie annual limit on intake
       3*10^-10 microcuries/milliliter derived air concentration

     Class Y (e.g. UO2 or U3O8):
       0.04 microcurie annual limit on intake
       2*10^-11 microcuries/milliliter derived air concentration

My first question would be, why do these regulations allow more
soluble compounds than insoluble compounds?  It seems clear that
they were designed to address only the radiological hazard of
uranium, and not the heavy metal toxicity, which is known to be
about six orders of magnitude worse.  In practice, the soluble
compounds are far more toxic than the insoluble compounds.  This
should indicate that the long half-life uranium isotope regulation
standards need to be completely revised.

In any case, as they stand today, an annual inhalation of more
than two grams of uranium is allowed.  Given that the LD50/30 of
uranyl nitrate (which has considerably less uranyl ion per unit of
mass than uranium trioxide) is 2.1 mg/kg in rabbits, 12.6 mg/kg in
dogs, 48 mg/kg in rats, and 51 mg/kg in guinea pigs and albino mice
(Gmelin Handbook of Inorganic Chemistry, 8th edition, English
translation (1982), vol. U-A7, pp. 312-322,) two grams of UO3 seems
very likely to comprise a fatal dose for a 200 pound human.

Therefore, those values seem much too high.  I fear that they were
derived in order to avoid immediate kidney failure only, without
regard to reproductive toxicity.  And I do not believe they were
derived with sufficient care to avoid allowing lethal exposures.
Even 10 CFR 20.1201(e)'s explicit limit to 10 mg/day of soluble
uranium compounds (or about half a gram per year) seems likely to
allow substantial kidney damage and certain reproductive toxicity.

This urine study calculates an average initial lung burdens of
0.34 milligrams elemental uranium for those with isotopic signatures
consistent with exposure to depleted uranium in what I believe
were symptomatic exposure victims:

http://www.ncbi.nlm.nih.gov/entrez/query.fcgi?cmd=Retrieve&db=pubmed&dopt=Abstract&list_uids=12943033

HOWEVER:  That study is almost certainly flawed, as it assumes a
uranium compound biological half-time of 3.85 years in the lungs.
I am operating under the assumption that the primary mode of
uranium toxicity involves much greater solubility.  I predict
that monomeric uranium trioxide will turn out to be absorbed
more rapidly in the mammalian lung than uranyl nitrate, because
of its monomolecular gas nature, and not merely about as rapidly
as the studies of granular uranium trioxide by P.E. Morrow, et
al. ("Inhalation Studies of Uranium Trioxide," Health Physics,
vol. 23 (1972), pp. 273-280) indicate.  Therefore, even Class D
may not be appropriate for monomolecular uranium trioxide gas.

I believe the correct way to determine these values, to account
for the reproductive toxicity, is probably to measure resulting
mutations of mammalian peripheral lymphocytes, such as was
done in this study of Gulf War I veterans:
http://www.ncbi.nlm.nih.gov/entrez/query.fcgi?cmd=Retrieve&db=pubmed&dopt=Abstract&list_uids=11765683

... and similarly performed by H. Schroeder, A. Heimers,
R. Frentzel-Beyme, A. Schott and W. Hoffmann ("Chromosome
aberration analysis in peripheral lymphocytes of Gulf war and
Balkans war veterans," Radiation Protection Dosimetry, vol. 103
(2003) pp. 211-220), the full text of which is temporarily at:
   http://www.bovik.org/du/chromosome-abberations.pdf
with some overview PowerPoint slides at:
   http://www.bovik.org/du/chromosome-abberations.ppt

Please let me know if I can help in any other way to answer this
or any other questions you may have.

Sincerely,
James Salsman

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