ML18018A589

Forwards Comments on Des Re Operation of Facilities (NUREG-0972).Opinions & Calculations Presented Do Not Necessarily Reflect Pennsylvania State Univ Position

ML18018A589
Person / Time
Site:	Harris
Issue date:	06/30/1983
From:	Lochstet W PENNSYLVANIA STATE UNIV., UNIVERSITY PARK, PA
To:	Office of Nuclear Reactor Regulation
References
RTR-NUREG-0972, RTR-NUREG-972, TASK-07, TASK-11, TASK-7, TASK-GB NUDOCS 8307070054
Download: ML18018A589 (11)

Text

r REGULATO INFORMATION DISTRIBUTION TEM (BIDS)

ACCESSION,NBR:e30707005rl . DOC.DATE: 83/06/30 NOTARIZED: NO DOCKET FACIL:50000 Shearon Har-ris Nuclear Power Planti Unjt 1i Car'olina 05000rl00 50 001 Shearon Harris Nuclear Power Planti Unit 2i Carolina 05000401 AUTH. NAME. AUTHOR AFFILIATION LOCHSTETPN.A. PennsvlvaniaState Univ, RECIP. NAME RECIPIENT AFFILIATION Division of I icensina r

SUBJECT'- For war ds comment s.on DES, re ooeration of feei i t,ies 1

(NUREG 0972) Ooi nions 8 calculations oresented do not NOTES'l necessarilv refl ect DISTRIBUTION CODE: C0028 TITLE: Pu6lic Comment RECIPIENT ID CODE/NAME on PA State Univ aosition.

COPIES RECEIVES:LTR Environmental Statement COPTFS LTTR ENCL RECIPIENT ENCL ID CODE/NAME

~L~ SIZE:

COPIES LTTR ENCL NRR L83 BC 06 7 7 NRR L83 LA 1 1 NL: ORNL 1 1 KADAMBIiP 01 1 1 INTERNAL: ELD/HDS1 1 1 NRR NORRIS i J 1 1 NRR/DE/AEAB 20 1 1 NRR/DE/EEB 16 1 1 NRR/DE/EHEB 1 1 PJRR/DE/SAB 18 1 1 NRR/DSI/AEB 19 1 1 8 15 1 1 NRR/DSI/RAB 17 1 1 REG F IL 04 1 . 1 RGN2 1 1 EXTERNAL: ACRS 6 6 LPDR 03 1 1 NATL LAB 21 5 5 NRC PDR 02 1 1 NSIC 05 1 1 NTIS 1 1 TOTAL NUMBER OF COPIES REQUIRED: LTTR 36 ENCL 36

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THE PENNSYLVANIA STATE UNIVERSITY 104 DAVEY LABORATORY UNIVERSITY PARK, PENNSYLVANIA 16802 Area Code 814 College o'f Science Dcpartmcnt of Physics 30 June 1983 U.S. Nuclear Regulatory Commission Mashington, D.C., 20555 Attention:

Director, Division of Licensing

Dear Director:

Enclosed are my comments on the Draft EnvirIbnmental Statement related to the operation of the Shearon Harris Plant,'nits 1 and 2, NUREG-0972. Please note that the opinions and calculations presented do not necessarily reflect the position of the Pennsylvania State University.

T. will be looking forward to the Final Environmental Statement. Mould you also please send me a copy of that Final EXS when ti is available.

Sincerely, Nm. A. Lochstet, Ph.D.

8307070054 830630 PDR ADOCK 05000400(

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' " PDR >, AN EQUAL OPPORTUNITY UNIVERSITY

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Some Health Consequences of Shearon Harris 1 and 2 by William A. Lochstet, Ph.D.

The Pennsylvania State Universit+

June 3.9S3 The Nuclear Regulatory Conunission (NRC) has attempted to evaluate the health consequences of the operation of the Shearon Harris nuclear plants in Che Draft Environmental Statement, SHE-0972 (Ref. 1). The health consequences of the radon-222

,released from the mill tailings and mines, needed Co fuel the plant, are evaluated for the first 1000 years in Appendix CD This .

evaluation states that the radon emissions increa'se with time (Page C-5, Ref. 1), and there is no suggestion Chat there is any reason to believe that these emissions will stop after 1000 years, or even to decrease.

In fact, these egissions continue for a very long time, being governed by the 80,000 year half life of Che thorium-230, and the @.5 billion year half lifeof the'uranium-238 in the mill tai>ings. The amount of material covering the tailings also effects the amount of radon released to the'tmosphere The thorium situation has been adequately'iscussed by Pohl (Ref. 2) in 1976 The impact of the uranium-238 as a source of radon was recognised by the NRC in GEPii0 (Ref 3), which is one of the references of Appendix C of thks Draft Report (Ref 1)

Appendix C of this Draft (Ref 1) is mitten on the presumption of a 100045fe LMt plant operated at an 8'apacity factor (Page C-1). This vill require about 29 metric tons of reactor fuel >Pith uranium enrichment plants operating at a 4 Affiliationfor identification purposes only

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Shaaron Harris June 1983 '.

'.2$ tails assay, 146 metric tone of natural uranium will be required;. and 117 metric tons of depleted uranium will be left over 7Eith a uranium mill which extracts 96+~ of the uranium from the ore, a total. of 90,000 metric tons of ore is 'mined, containing 152 metric tons of uranium (Ref..4.). The uranium mill tailings

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wi11 contain 2 6 kilograms of thorium-230 and 6 metric tons of'ranium As Poh1 has pointed. out (Re8.2), the thorium decays to radium-226, which in turn decays to radon-222. This process results in the generation of 3.9 x 10 curies of radon-222, on a time scale determined by the 8 x 10~ year half life of

• thorium-230 The 6 metric tons of uranium contained in the mill tailings decays by several steps thru thorium-230 to radon-222 This 4

process occurs on a time ecale governed by the A..5 x 10 year

-half life'of the uranium-238, the major isotope present(99 3$ ).

The total amount of radon-222 which will resuLt- from this-decay is 8~6 x 10 curies.

The 117 metric tons of depleted uranium from t~ enrich ent process is also mainly uranium-238, which also decays. The decay 5fthese enrichnent tails results in a total of 1 7 x 10 curies of radon-222.,The impact of these decays werc listed by the NRC in GESI40 (Ref 3).

The population at risk is taken to be a stabilized USA at its present level and present distribution This is similar to that taken by the Draft (Page C-3, Ref 1) The NRC has suggested that a- release of 4,800 curies of radon-222 from the mines would result in 0 023 excess deaths (Ref 5). This provides a ratio of'. 8 x 10 deaths per curie At present some recent uranium mill tailings piles have two feet of dirt covering. Xn this case, the EPA estimate (Ref 4,)

is that about 1/20 of the radon produced escapes into the air.

Thus, of the 3.9 x 10 8 curies of radon from the thorium in the

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Shearon Harris June 1983 t 3 II mill tailings, only 1 9 x 10 curies will get into.the air

'.Q.th.the estimate of-I+ 8 x 10 deaths per curie, this results in a total of 90 deaths The 8 6 x 10 curies of radon produced by the,.uranium in the mill taili~s will similarly have 1/20 escape.to the air~:fith the same method as was used above, the resu3.t is 'I 200,000 deaths The uranium enri.chment tailings are presently located in the eastern part of the USA If these are buried near their present location it is taken that 1/100 of the radon"will escape to the air, due to the hi@er moisture content of the covering soil. An additional reduction factor of-"2 is taken to account Sor the more eastern location, and the fewer people downwind, to the east of the sites. '."xth the NRC estimate of $ .8 x 10 -6 deaths per curie, the result is 400,000 deaths.

The NRC estimate is about 2 deaths in the draf't'Ref. X) is thus more than 100,000 times too low as compared ta the sum of 600,000 deaths as shown above. This is due largely to the arbitrary, erronious, immoral, incorrect procedure of stopping at the end of the first 1000 years The fact that these doses and death rates are less than background is interesting (Page C-6, Ref. 1), but absolutely irrelevant The mayor federal action to be considered by the the NRC is not whether or not to license background radiation, but whether or not to license the Catawba plants. This is what NK'L requires It is hoped that thesd comments are useful in preparing the Final EIS

Shearon Harris June 1983 References 1 Draft Environmental Statement related to the operation of the Shearon Harris Nuclear Power Plant, Units 1 and 2.; NUREG-0972,

.. Draft, NRC, April 19S3 2 R.O, Pohl, "Health Effects of Radon-222 from . Uranium Mining", Search, 7(5), 345 350 (August 1976) 3 <>Final f Generic Environmental Statement on the Use o P e cycled Plutonium in Mixed Oxide Fuel in Light ci'ater Cooled Reactors",

NUREG-0002, NRC, f August 1976)

4. "Envxronmental Analysis of the Uranium Fuel Cycle, Part I Fuel. Supp).y'~~ EPA-520/9-73-003-E, US E.P.A ~ , (October 1973) 5 "Health Effects Attributable to Coal and Nuclear Fuel Cycle Alternatives" NUREG-0332, Draft, U.S. N.R.C., (September lg77)

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