ML19224B795
| ML19224B795 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Hope Creek, Sterling, 05000484, Crane  |
| Issue date: | 05/25/1979 |
| From: | Conner T, Silberg J, Silbert J, Voigt H CONNER, MOORE & CORBER, LEBOEUF, LAMB, LEIBY & MACRAE, SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | |
| Shared Package | |
| ML19224B794 | List: |
| References | |
| NUDOCS 7906230110 | |
| Download: ML19224B795 (36) | |
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NUCLEAR REGULATORY COMMISSION
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BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARDS In tne Matters of
)
)
PdILADELPHIA ELECTRIC COMPANY at al.
) Docket Nos. 50-277 (Peacn Bottom Atomic Power Station,
)
50-278 Units 2 and 3)
)
)
)
METROPOLITAN EDISON COMPANY et al.
) Docket No. 50-320 (Three Mila Island Nuclear Station,
)
Unit No. 2)
)
)
)
PUBLIC 3ERVICE ELECTRIC AND G AS CO.
) Docket Nos. 50-354 (Hope Cr eek Gene rating Station,
)
50-355 Units 1 and 2)
)
)
)
)
NORTHERN STATES POWER COMPANY st al.
) Docket No. STN 50-134 (Tyrone Energy Park, Unit 1)
)
)
)
ROCHESTER GA3 AND ELECTRIC
) Docket No. 3TN 50-435 CORPJR;r!ON et 31.
)
(3tarling Power Project,
)
Nuclear Unit 1)
)
STATEMENT OF AATERIAL FACTS AS TO i?HICH THERE IS NO GENUINE ISSUE TO BE HEARD For tne purposes of Licensees' Joint Motion For Summary Disposition of Radon Issues, Licensees contend that the following ara material facts as to whicn there is no genuine issue to be heard:
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4
.;11egel deficiency no. 1 1.
The phys 31 parameters of a mine required to compute precisely the radon amissions from enat mine, and tne correlation coefficients for these parameters, are not available and change with tima.
Affidavit of Dr. Morton I.
Gollman (her3inafter "Goldman Aff."),
para.
7.
2.
The best generic correlatio; that can be made between uranium ore mined and radon-222 releasa rates is to correlate radon emissions and productions in a /ariety of mines in order to obtain results wnich are representative of tne industry as a wnole.
Goldman Aff., para.
7.
3.
Tha documents citeJ by Inter 72nors in their alleged deficiency no. 1 in fact demonstrate that the radon-222 r313232 rates from uranium mining operations estimated by the Nuclaar Regulatory Commission Staff (hereinafter " Staff") and testified to by the Staff in the Perkins proceeding (Duke Power Company P ar kins 'Jacle a r Station Units 1, 2 and 3, Docket Nos. STN 50-433, 50-439 and 50-490), are higher, 2.2.,
more conservati/e, than the release rates measured at uranium mines.
Goldman Affidavit, paras.
3-7.
4.
If tne average radon emissions measured at domestic uranium mines are weigated to taka into account the mines' production rates, this weighted average is roughly one-half of the radon emission estimatas offered by the Staff in Perkins.
Goldman Aff., par 2.
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5.
The Staff's estimates in Perkins of radon-222 releases from uranium mining operations constituts reasonable estimates of the release rates that will be experienced in any domastic uranium mines.
Goldman Aff., para.
7.
5.
Even if the highest measured radon release rata 3991 3 I' 3"
claim 3d by Intervenors (48 Ci per ton U 03) 3 resulted "in a release rate from mining in excess of 10,000 curies per AFR",
this rate would only apply during the active mine operation since release rates are essentially zaro when the ventilation fans are shut off.
Tr. 2542 (Wilde).1 Allag2', deficiency no. 2 3
7.
The Staff's assumotion that 2.71 x 10 metric tons
("MT") of uranium ore will need to be mined in crdar to provide one annual fuel requirement ("AFR") for a raf?rence reactor is appropriata and is directly derivad from the reactor Suty factors that were determined generically in two licensing proceedings and upheld in each instanca by the Appeal Boards.
Licensees' Brief In Support of Motion for Summary Disposition (hereinafter "Br.")
at pp. 3-4.
Alleged de.ciency no. 3 3.
Sealing of underground uranium mines after active ope atic 3 is not detarminative of radon emissions since radon 1
The notation "Tr.
refers to the appropriate pages of the transcript of tne Perkins hearing on radon. 2"JJ nq:
Ec cv i
releases essentially go to zero when ventilation fans are shut down.
Tr. 2541-2542 (Wilde); and see Duka Power Co. (Perkins Nuclear Station Units 1, 2 and 3), LBP-79-25, 3 NRC 37, 90 (1978).
9.
Long term radon releases from unreclaimed open pit uranium mines would be in the order of 100-200 Ci/yr/AFR.
Tr.
2509-2513 (Wilde); 2539-2640 (Goldman).
10.
The testimony of Betty Perkins cited by Intarvanors does not quantify radon amissions at abandoned mines.
Uranium Mill Tailings Control:
Hearings on H.R.
13382, 12933, 12535 and 13049 Before tne Subcommittee on Energy and The Environment of the Housa Committee on Interior and Insular Affairs, 95th Cong., 2d Sess., pp. 103-111.
11.
The Parkins record contains an adequate examination of the radon-222 releases from open pit mines.
Tr. 2553-2553, 2609-2513, 2513-2619 (Wilde); 2539-2540 (Goldman).
Alleged deficiency no. 4 12.
The Sweatwater DES projects a radon-222 release rate of 6090 Ci/yr or about 3640 Ci/yr/AFR during the active mining period, not 250 Ci/yr/AFR as stated in alleged deficiency no.
4.
Goldman Aff., para.
9.
13.
The radon-222 release rate estimated in the Sweetwater DE5 is lass than the 4060 Ci/yr/AFR rate estimated by the Staff in Parkins for releases during active mine operations.
Goldman Aff., para.
9.
m-
14.
The Sweetwater DES does not include radon amanation estimates after the active mining period because the mine aill be reclaimed and radon r31 eases after reclamation would be negligible.
Goldman Aff., para. 10.
15.
The 200 Ci/yr/AFR rate cited in alleged deficiency no. 4 is the astimated upper limit of radon-222 emissions attributable to abandonad, unraclaimed open pi" mines.
Goldman Aff., para.
3.
16.
The 100-200 Ci/yr/AFR emission rate estimates from an abandoned open pit mine were independently computed by two witnesses in the Perkins proceeding.
Tr. 2603-2613, 2613-2619 (Wilda); 2633-2640 (Goldman).
The Licensing 30ard consar-vati/ely chose to use tne higher end of the bound testificd to by witness Goldman.
See LBP-73-25, supra, 3 NRC at 90-91.
17.
Long-term radon raleases from open pit. nines will not be significant since open pit mines will be reclaimed as required by state reclamation laws, thus reducing radon releases to insignificant levels, Tr. 2554-2556 (Nilde), and because fewer and fewer deposits vill be available for open pit mining in the future.
Tr. 2550-2552 (Wilde).
Alleged deficiency no. 5 13.
Radon releases from oferburden were inulad:d in the Perkins estimates of emissions from abandoned unreclaimed open pit mines.
Tr. 2639-2640 (Goldman), Goldman Aff., para.
11.
19.
Overburden removed from an open pit uranium mine can be returned co the mine from which it came.
Goldman Aff.,
para. 12.
9 6 h P
20.
The G:'7tessional testimony cited by Intarvanors deals with the ratio between the volume of overburden removed and the volume of ore removed, not the volume of overburden removed and the volume of the mine.
Goldman Aff., para. 12.
Alleged deficiency no. 6 21.
A typical test hole drilled in search of uranium would, if successful, expose an area of 12.6 sq. ft. of ore at a depth of 900 ft.,
wher.as the area of the mill tailings pile assumed by the Staff in Perkins is 125,000 sq. ft.
Goldman Aff., para. 13.
22.
There is no significant driving force to delivar to the surface any radon emanated in a test hola tens to hundreds of feet below grade.
Goldman Aff., para. 13.
23.
A test hole is likely to become at least partially filled with water, whi;h would greatly in'ibit the diffusion of a
cadon to the surface.
Goldman Aff., para. 13.
24.
fillad or partially filled test nolas becom2 insignificant sources of raduit in comparison with the mine if a mineable deposit is found and commercial exploitation in undertakan.
Goldman Aff., para. 13.
25.
If no mineable deposits are found, the " dry" tast hole emits substantially no radon.
Goldman Aff., para. 13, 26.
Tes holes drilled in search of uranium release negligible amounts of radon.
Goldman Aff., para. 13.
Alleged deficiency no. 7 27.
The Envirvomental Protection Agency report cited in alleged deficiancy no. 7 does not address radon releases in 255 204 drinking water, nor does it discuss hydrolcgic pathways for radon to the atmosphere.
Goldman Aff., para. 14.
29.
The existence of hydrologic pathways for radon releases may change the location where radon is formed t_c not the amount of radon generated.
Goldman Aff., para. 14.
29.
The diffusion rate of radon through water is en the order of ten thousand times lower than that in air.
Coldman Aff., para. 15.
30.
Because of the lower diffusion rate of radon through water, postulated hydrologic pathways for radon contamination will probably decr3ase the amount of raion-222 discharged to the atmosphere.
Goldman Aff., para. 15.
Alleged deficiency no. 9 31.
Radon emissions which might be attributable to foreign mines need not be considered for the reasons sat forth at Br.,
pp.
5-6.
Alleged deficiency no. 10 32.
The Staff's estimates in Perkins of tha radon-222 releases associated with uranium ore milling are reasonablf conservative.
Goldman Aff., para. 16.
Alleged deficiency no. 11 33.
The emanating power of mill t2ilings is ore and process specific, varies with the composition 1f the tailings pile, changes with time and cannot be known in advance.
Goldman Aff., para. 19.
255 205 34.
The emanating power of mill tailings can only oe estimated on an average basis.
Goldman Aff., para. 19.
35.
The Ford, Bacon and Davis Utah, Inc. study cited in alleged deficiency 11 reports measuring an average amanating pcwer of (15+7)% and adopts 20% as the emanating power in subsequent analyses.
Goldman Aff., para. 18.
Alleged deficiency no. 12 36.
Consideration was given in Perkins to radon emissions from uranium stockpiled at the mill.
Tr. 2559-2560 (Magno).
37.
The Staff in Perkins did not include the radon emissions from uranium stockpiled at the mill in the total radon emissions attributable to milling because the amount was small compared to the total.
Tr. 2559-2560 (Magno).
38.
The Staff in Perkins estimated the radon amissions from uranium stockpiled at the mill to be 11 curias per AFR.
Tr. 2559-2560 (Magno).
Alleged deficiency no. 13 39.
The i rkins record contains information concerning those steps nacassary to stabilize mill tailings so that radon emissions f rom them are nc greater than twice natural background.
Tr. 2399-2400 (Miller); Magno Aff. following Tr.
2369 at pp.
6, 3-9.
40.
The measures necessary to stabilize mill tailings so that radon emissions from them are no greater than twice natural background include covering the tailings pile with
')Nb L 0
_s_
m
Cover matarial to a depth depending upon specific soil characteristics, and below grade burial.
Magno Aff. following Tr. 2369, at pp.
8-9.
41.
The NRC Staff's performance objectives on radon emissions from mill tailings provide that tne baseline for comparing radon emissions from tailings is the radan relaase rate from the natural soils in the surrounding envi:
13.
Magno Aff. following Tr. 2369, at p.
6.
Alleged deficiency no. 14 42.
Mill tailings piles stabilized in accordance with the Commission's licensing requirements will maintain their int 2grity over extended periods of time 2nd will suffer littla or no spatial diffusion as a result of erosion.
Tr. 2396-2397, 2402 (Miller); Magno Aff. following Tr. 2369, at p.
9; LBP-73-25, supra, 3 NRC at 100.
43.
The radon release ratas for mill tailings estimated by the Staff take into consi3eration the uncertainty as to the stability of tailings piles over long periods of time.
Tr.
2395-2396 (Magno).
Alleged deficiency no. 15 44.
Heap leachi.:q contributes a very small percentage (one to two percan: ) of tne total U.S.
uranium supply.
Goldman Aff., para. 20.
45.
Radon releases from mills using the heap leaching process nave been investigated.
Goldman Aff., para. 21.
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46.
To the extent that uranium is obtained through heap leaching, the radon releases to the atmosphere associated with the heap leaching process will be far less than the releases that would have been emitted had a standard milling process been utilized.
Goldman Aff., para. 21.
Allegad deficiency no. 16 47.
Under existing federal and state laws, mill tailing piles are required to be properly isolated and stabilized.
3r.
pp.
6-7.
Alleged deficiency no. 17 43.
Equilibrium concentration of radon parents is directly proportional to the ore grada.
Goldman Aff., par?.
22.
49.
The increased volume of ore required with lower ora grades is offset by the proportional decrease in the concentta-tion of radon parents with lower ore grades.
Goldman Aff.,
para. 22.
50.
Stabilization of larger tailing piles presents no greater technological difficulty than stabilization of smaller ones.
Goldman Aff., para. 23.
Alleged deficiency no. 16 53.
Possible exposure to radium-226 to people drilling for wster into below grade mill tailings disposal areas is unrelat=d to radon-222 releases or impacts.
Goldman Aff.,
para.
- 24. 9R~
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52.
Assuming that mill tailings deposited below grade are leached by the groundwater, and that perple drilling for water at the burial sites drill into the leached tailings, the radon emissions through such water well drill holes will be insignificant for the same reasons that emissions from a mine test hole are insignificant.
Goldman Aff., para. 24.
Alleged deficiency no. 20 53.
Radon emissions attributable tc foreign mills should not be considered for the reasons set forth at Br.,
p 7.
Alleged deficiency no. 21 54.
This alleged deficiency should not be considered for the reasons set forth at Br.,
pp. 8 - 9, and because the stabilized mill tailings piles will maintain their integrity over extended periods of time so that they will not be subject to " migration" problems.
Tr. 2402 (Miller); Magno Aff. fol.
Tr. 2369, at p.
9.
Alleged deficiency no. 22 55.
Enrichment tails are stored in sealed containers at the enrichment plant sites; these tails are expected to remain in containment entil their ultimate use as breeder fuel or their final disposition as wasta or otherwise, is determined.
Goldman Aff., para. 25.
56.
Enrichment tails do not concain either the parent (radium-226) or grandparent (thorium-230) of radon-222 and their content of radon's great-grandparent (uranium-234) is
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gr2atly depleted.
For radon to be generated from enrichment tails, the complete decay chain from uranium-238 to radon-222 must first take place.
Goldman Aff., para. 26.
57.
If enrienment tails were released from containment at some point in the future and allowed to decay forever exposed to the atmosphere, for many thousands of years the radon release rate from them would b2 negligibla in comparison to releases from mines and mill tailings.
Goldman Aff., para.
27.
58.
The " full period of toxicity" for enrichment tallings refarred to in alleged deficiency no. 22 is over 30 billion years.
Goldman Aff., para. 27.
Alleged deficienc[ no. 23 59.
]ver a 25 year period, 0.034 curias of radon-222 would be released as a result of UF-conversion to yield fuel O
for 4,551 gigawatt-years of electric energy.
Goldman Aff.,
para. 28.
60.
The radon raleases attributable to UF-conversion are 0
approximately.000006 Ci/AFR.
Goldman Aff., para. 28.
61.
The radon releases atttibutable to UF conversion are 6
negligible in comparison to thosa attributable to mining and milling of uranium.
Goldman Aff., para. 28.
Alleged deficiency no. 24 62.
Radon releases during the enrichment, UO fuel 2
fabrication, reactor operation, transportation, waste "r~
2JD
<o10
management a n.'
sat fuel storage phases of tne nuclear fuel cycle are zero ot near zero.
Goldman Aff., para. 29.
63.
Uracium in the fuel cycle beyond conversion is essentially devoid of radon parents, grandparents and great grandparents, thus resulting in near zero radon releases.
Goldmca Aff., para. 29.
64.
The amount of uranium feed inventory at other fuel cycle facilities is small compared to inventory at the enrichment plant.
Goldman Aff., para. 29.
65.
Since depleted uranium at the enrichment plant produces only 13 curies of radon after a thousand years of decay, the far smaller quantities of uranium at other steps of the fuel cycle, 12:aying for short periods of time, will produce essentially no measurable radon releases.
Goldman Aff., para.
29.
Alleged deficiency nc. 26 66.
Radon emanations occur during the processas of phosphate manufacture whether or not uranium is recovered.
Goldman Aff., para. 30.
67.
Recovery of uranium as a by-product of phosphate fertilizer production results in no radon releases beyond tnose that would in any elant occur as a result of fertilizer production.
Goldman Aff., para. 30.
68.
To the extent that one attributes any radon releases to the recovery of uranium as a by-product of phosphate
,(3
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/3 L
fertilizer production, tne slight radon releases produced by this process would be more than offset by greater radon releases avoided by not having to mine and mill uranium ore to produce the uranium obtained from fertilizer.
Goldman Aff.,
para. 31.
Respectfully submitted, SHAW, PITTMAN, POTTS & TR0dBRIDGE h
A
/ /
'/ Q L}C1q Jay (S. Silberg gg7" Matibs F.} Travieso-Diaz Counsel for Metropolitan Edison Company, et. al.
and Northern States Power Company, et. al.
1800 M Street, N.W.
Washington, D.C.
20036 (202) 331-4100 LeBOEUF, LAMB, LEIBY & Mac RAE d Alt 1A Hatry HQ Voigt
~y Lex K.
Larson Michael F.
McBride "r jc J J;r
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L' I &
Counsel for Rocnester Gas and Electric Corporation, et 31.
1333 New Hempshire Avenue, N.W.
Washington, D.
C.
20036 (202)t57-7500 CONNER, MCORE & CORSER
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Troy B.
Conner, Jr.
Robert M. 'Rader Counsel for Philadelphia Electric Company et al.
and Public Service Electric and 3a3 C o?.p iny Suite 1050 1747 Pennsylvania Avenue, N.
W.
Washington, D.
C.
20006 (202)333-3550 Dated:
May 25, 1979
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NUCLEAR REGULATORY COMMISSION
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BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARDS In the Matters of
)
)
PHILA DELPH I A ELECTRIC COMPANY et al.
)
Docket Nos. 50-277 (Peach Bottom Atomic Power Station,
)
50-278 Units 2 and 3)
)
)
)
METROPOLITAN EDISON COMPANY et al.
)
Docket No. 50-320 (Three Mile Island Nuclear Station,
)
Unit No. 2)
)
)
)
PUBLIC SERVICE ELECTRIC AND GAS CO.
)
Docket Nos. 50-354 (Hope Creek Generating Station,
)
50-355 Units 1 and 2)
)
)
NORTHERN STATES POWER COMPANY et al.
)
Docket No. STN 50-484 (Tyrone Energy Park, Unit 1)
)
)
)
ROCHESTER GAS AND ELECTRIC
)
Docket No. STN 50-435 CORPORATION et al.
)
(Sterling Power Project,
)
Nuclear Unit 1)
)
AFFIDAVIT OF DR. MORTON I.
GOLDMAN City of Washington
)
ss.
District of Columbia
)
MORTON I.
GOLDMAN, being duly sworn, deposes and says as follows:
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1.
I am Senior Vice President, Environmental Systems Group, NUS Corporation, Rockville, Maryland.
I have been a consultant on environmental and radiological matters since 1959.
I was a consultant to and witness for the applicant in the Perkins proceeding (Duke Power Company (Perkins Nuclear Station Units 1, 2 and 3), Docket Nos. STN 40-488, 50-489 and 50-490) with respect to the radon-222 issue.
A statement of my professional qualifications is attached as Exhibit "A" to this Affidavit.
2.
I have been asked to review the allegations made by Ecology Action of Oswego and Northern Thunder, Inc. ("the Intervenors") to the effect that certain deficiencies exist in the Perkins record and the initial decision of the Licensing Board in that proceeding (Duke Power Company (Perkins Nuclear Station, Units 1, 2 and 3), LBP-78-25, 8 NRC 87 (1978)) with respect to the radon-222 emissions associated with mining and milling of uranium for use in nuclear power plants.
I have examined alleged deficiencies nos.
1, 4,
5, 6,
7, 10, 11, 15, 17, 18, 22, 23, 24, and 26.
The results of my analysis are given below.
3.
Alleged deficiency no.
1.
This alleged deficiency challenges the estimate of radon-222 releases from uranium mining offered by the Nuclear Regulatory Commission's Staf f
("the Staff") in the Perkins proceeding.
The Staff's estimate -
oir Jcb c!3
was given as.0148 Ci of radon per MT (metric ton) of.1%
uranium ore mined (i.e., 14.8 Ci/MT of U 03 8 produced).
The Intervenors question the correlation of raden-222 releases with amount of ore mined, and cite in support two letter reports from Battelle Pacific Northwest ' ;bor atories to Dr. Landon of the Staff.(1' 2)*/
- Those letter reports do indicate that a variety of parameters influence the radon emission rates from an individual mine; among these parameters are the surface areas exposed in the ventilated segments of a mine, the ore production rate and grade, and the porosity and permeability of the rock.
These repo;ts, however, provide no basis for rejecting the correlation between raden-222 releases and ore mined in developing generalized radon-222 release values.
- 4. of reference (1) presents the results of a literature search on radon-222 emission rates from U.S.
uranium mines.
The first table of that Attachment, entitled
" Radon Emission From Uranium Mines," indicates that the average of the release rates measured at seven mines was 13 Ci of radon-222 per ST (short ton) of U 03 8 pr duced, with a range of values between 1.8 and 48 Ci/ST U 0 This average measured 3 g.
value is quite close to the 14.8 Ci/MT (or 13.5 Ci/ST) estimate made by the Staff.
The geometric mean of the measured release 1/
References cited are listed at the end of this Affidavit. sp-b
rates, which may more realistically represent the " expected" value of a set with such a wide variation, is 8 Ci/ST U 0 3
8*
This lower value is attributable to the fact that, as the data in the referenced table indicate, radon-222 emissions per ST of U0 in six of the seven mines were less than the average of 13 38 in nly one instance (i.e.,
the 48 Ci/ST Ci/ST U 03 8; measurement cited by the intervenors) was the release rate in excess of the average.
- 5. to reference (1) also contains a second table entitled " Radon Emission Rates From Seven Kerr-McGee Mines," which shows an average radon-222 release rate of 10.6 Ci/ST U 0 and a geometric mean of 7.1 Ci/ST U 0 with a range 3 g 38, from 2.0 to 27 Ci/ST U 0 Ag in, me surec radon-222 release 38 rates in five of the seven mines are lower than the Staff's estimate of 13.5 Ci/ST U 0 3g.
6.
The mines from which radon-222 releases were measured vary widely in production rates, from a high of 30 ST U 0 m nth to a low of.75 ST U 03 g/ month in the first table, 3 8 and from a high of 1.9 ST U 0 / day to a low of.46 ST U 0 / day 3g 3g in the second table.
If the radon-222 emission rates are weighted by the productivity of the respective mines (i.e.,
emission rates from mines producing less U 0 are accorded less 3g weight than those from mines producing more U 03 8), the radon-222 emission rate per
' of U 0 mined can be obtaine !;
3g that is perhaps a more representative figure than the one 255 217
arrived at by averaging emission rates of individual mines without taking into account their production rates.
For the mines from which releases were measured, one would get values of 6.8 Ci of radon-222 per average ST U 0 fr the mines in the 38 first table and 7.3 Ci per average ST U 0 fr those in the 38 second table.
Again, both of these figures are lower than the 13.5 Ci/ST ettimate used by the Staff in Perkins.
7.
I can find no basis in the references cited by the Intervenors, or anywhere else, for questioning the Staff's estimated release rate of.0148 Ci/MT U 03 g; in fact, the foregoing analysis indicates that the Staff's estimate may be high by almost a factor of two.
Furthermore, while for a particular operating mine one could in theory compute more precisely what the radon emissions would be, this cer.putatien cannot be done in practice because the physical parameters of the mine required for such a computation (for exam 3 te, surface areas and ventilation rates in mineralized and non-m>neralized zones, rock permeability and porosity, and others), and the correlation coefficients for those parameters, are not avail-able and change with time.
Since such information is not available, the best generic correlation that can be made is to correlate radon emissions and production in a varie'.y of mines in order to obtain results which are representative of the industry as a whole.
On that basis, the 5tsff's estimates in Perkins are conservatively high. 6_
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8.
Alleged deficiency no.
4.
In this instance, the Intervenors claim that the Perkins decision (LBP-7G-25, supra, 8 NRC at 90-91) is in error because it adopts my estimate of an upper limit of 200 Ci/ year / annual fuel requirement ("AFR") to the ra5cn-222 emissions attributable to abandoned, unreclaimed open pit mines.
See Tr. 2640 (Golaman).
The Intervenors cite the Sweetwater Uranium Project Draft Environmental Statement, NUREG-0403 ("Sweetwater DCS") as indicating a release rate of 6,090 Ci/ year of radon-222, and derive from that figure an annual radon-222 release rate of 250 Ci/yr/AFR which, if correct, would be greater than the Perkins estimates.
- However, the Intervenors' figures are not correct.
9.
As noted above, the testimony in Perkins on releases from open pit mines referred to abandoned, unreclaimed mines.
See Tr. 2609-2610 (Wilde); 2639-2640 (Goldman).*/
By contrast, the release rate from mining cited in the Sweetwater DES, 6090 Ci/yr, refers to the active mining period, during which 410 MT/ year of U 0 will be recovered;I3I assuming, as the 38 Intervenors did in this alleged deficiency, 245 MT of U 0 P*'
3 8 AFR, this production rate yields a radon-222 emission rate of approximately 3,640 Ci/yr/AFR (not 250 Ci/yr/AFR as claimed by the Intervenors), which is less than the 4,060 Ci/yr/AFR estimated by the Staff in Perkins.
Thus, the 6,090 Ci/yr
- /
The notation "Tr.
" refers to the appropriate pages of the Transcript of the Perkins hearing on radon. 2.6 I
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figure in the Sweetwater DES cannot be used to test the validity of the Perkins, estimates of.adon releases from abandoned open pit mines, although it serves to confirm the Staff's estimates with respect to relecses from active mines.
10.
The Sweetwater DES does not include radon emanation estimates after the active mining period because the mine will be reclaimed and radon releases after reclamation would be neglig ible. ( 4 )
11.
Alleged deficiency no.
5.
The Intervenors also claim that the radon emission rates from open pit mines given in the Perkins record are incorrect in that they give no consideration to radon releases from overburden.
The significance of this alleged omission is said to be that the overburden has a volume of "8 to 35 times the volume of the mine [t]herefore all the overburden cannot be returned to the mine." The first allegation is factually incorrect, since the estimates of radon releases from open pit mines whica I gave in Perkins included the contribution from overburden.
Tr.
2639-2640 (Goldman).
12.
The second allegation is also incorrect and mischaracterizes testimony given before a congressional ccmmittee(5) in 1978.
The testimony cited by the Intervenors actually indicates that there is an 8:1 to 35:1 ratio between the volume of overburden removed and the volume of ore removed from a mine, rather than the volume of the mine as intervenors 255 220 claim.
The volume of the overburden physically can not be greater than the volume of the mine from which the ore and overburden came.
The overburden can be returned to the mine, and the problem often encountered by mine operators is the opposite from that alleged by the Intervenors: the overburden volume is not enough to completely fill the mined volume because there is insufficient material to replace the ore that has been removed.
13.
Alleged deficiency no.
6.
Another war in which the Perkins record is claimed to be deficient is that it does not include radon emissions from unsealed test holes drilled in search of uranium deposits.
Such holes, however, would constitute a trivial source of radon, for the following reasons:
(a)
A test hole would expose a relatively small area of ore even were it to be drilled directly into a uranium deposit.
Based on U.S.
Department of Energy uranium reserve data,(6) the average dr.pth of a uranium ore deposit is greater than 900 feet, and its average thickness less than 12 feet.
Typical diameters for test holes range from two to four inches.
Thus, a typical four-inch diameter test hole would expose, on the average, an area of Tt x 4/12 ft. x 12 ft.
12.6 sq. ft. of
=
ore at a depth of 900 ft.
The tailings area per AFR assumed by a Staff witness (Magno affidavit foll. Tr. 2369, at p.4) is 2.87 acres or 125,000 sq. ft.
Thus, if the radon from the ore 255 221 exposed in the test hole were as free to diffuse (which it is not) as dry mill tailings, each hole would emit one-ten thousandth of the exhalation from an unstabilized pile per AFR, or about.01 Ci/ year.
(b)
Also, there is no significant driving force to deliver to the surface radon emanated tens to hundreds of feet below grade.
Neither molecular dif f usic!n nor changes in atmospheric pressure are sufficient to cause significant transport of emanated radon to the surface.
Further, it is hardly likely that a test hole penetrating several hundreds of feet below grade would remain dry; water would further inhibit any radon diffusion toward the surface.
(c)
If uranium are deposits of any significance are found, sooner or later the test hole will be encompassed by a mining operation whose radon releases will greatly overshadow those fr m. the tr :s t hole itself.
Conversely, if no significant uranium ore deposits exist, there can be no significant radon releases from the test nole.
14.
Alleged deficiency no.
7.
Still another alleged deficiency claimed to exist in the Perkins estimates of the radon releaser from mining uranium _re is that only atmospheric pathways ror radon emissions were considered and " hydrologic pathways for radon contamination" were not considered.
The Environmental Protection Agency report cited by the Intervenors, however, does not address radon releases in
_9_
26I c' c c) 7' uoJ
drinking water ; nor does it di: cons hydrologic pathways for radon to the atmosphere.
Moreover, the pathway to the environment does not change the total amount of radon generated.
Each atom of thorium-230 can give rise to only one atom of radium-226, which in turn can decay only once to form radon-222.
Thus, if the radon parents (thorium and radium) are leached from mine tailings or ore particles to locations in streams or groundwater and decay there to produce radon gas which is then released to the atmosphere, all that takes place is a charge in the location where radon is formed; the amount of radon released to the atmosphere is not increased and may be Secreaseo in the process.
15.
The diffusion rate of radon through water is on the order of ten thousand times lower than that in air.
Therefore, if radon parents are leached from mine tailings, waste rock or ore particles into streams or the groundwater, it is quite probable that some a::
of radon that would have escaped into the atmosphere from those sources will faii to do so.
- Thus, the postulated hydrologic pathways for radon contamination may actually decrease the amount of radon-222 that is discharged into the atmosphere from uranium mining.
16.
Alleged deficiency no. 10.
Intervenors dispute the estimates of radon-222 emissions from the milling of uranium ore offered by the Staff in the Perkins proceeding (1,130 Ci/yr/AFR prior to tailings pile stabilization and 1 to 100 9Fc ng-cJJ ccj
Ci/yr/AFR thereafter).
Ir.tervenors claim that they "are prepared to submit evidence, based on government docuruents, that measured emissions at actual mills are greater than computed" by the Staff.
While it is clearly impossible to analyze the validity of this allegation, whose basis is not stated by the Intervenors, I believe, as I stated in Perkins
('estimony of Mcrton I. Goldman fol. Tr. 2266 at p.1), that the Staff's estimates of radon-222 emissions associated with milling are reasonably conservative.
17.
Alleged deficiency no, 11.
The Intervenors cite a study by Ford, Bacon and Davis Utah, Inc. (tentatively identified here as reference 7 of the same title and originating organization) as supporting the propositions that the emanating power of radon in tailings is site-specific and that the value of 20% for this parameter assumed in the Perkins estimates is not justified.
18.
The study cited by the Int cs, however, refutes their claim that there is no justification for a 20% value of emanating power.
The study contains a Table I setting forth "the emanating power and radium content of 22 mill tailings and soil samples collected in tb: Wyoming and New Mexico mining United States."
Of the 22 samples, i6 are of regions tailings, and for 15 of the tailings samples measured values of emanating power are reported:
The averace of :hese values is (15+7)%; of the 15 tailing samples, only two exceeded 20% in c m ';r o9 9 r. J E
LJ
emanating power.
In their analyses, the authots of this study
.dopted 20% as the emanating power (Ref.
7, Table TI).
19.
The emanating power of mill tailing piles is are and process specific, varies with the composition of the tailings pile, enanges with time, cannot be known in advance, and can only be estimated on an average basis.
20.
Alleged deficiency no. 15.
Another deficiency in the Perkins record, according to the Intervenors, is its failure to consider the radon emissions which will result from the process of " heap leaching."
The Intervenors cite the Sweetwater DES as an example of a milling operation using the process and argua that, since it may be a possible source of uranium for nuclear power plants, "an inv2stigation into the possible emissions from such mills must be conducted."
Yet heap leaching provides and will provide a very small percentage (one to two percent)(3) of the total U.S.
uranium supply.
21.
To the extent that uranium is obtained through heap leaching, the radon releases to the atmosphere will be less tnan what they would be had the standard milling process been utilized.
Indeed, the same Sweetwater DE3 cited by the Intervenors gives the total radon release from a heap leach 24.24.5 Ci/yr.I I Since the 3weetwater mill will pile as produce 65 ST (i.e.,
60 MT) of U 0 a year by this 3 g (10)
- process, and assuming 245 MT of U 03 3 per AFR, the result r-n n r-2 J D L, D
is that the heap leach pile emits about 100 Ci/yr/AFR of radon-222.
The Staff in Perkins calculated that about 1,130 Ci/yr/AFR would be released during the standard milling process that heap leac i.ng would replace.
Thus, assuming as was done in Perkins that all uranium is obtained by the standard milling process result-in a ar7 conser"at'ive estimate of the radon source term tha' we a - would be ot.
Ted had the contribution from the smali i.70a..
-f uranium potentially supplied by heap leaching ceen c v a.eu separately.
- 22. Alleg d d'ficiency no. 17.
The Intervenors also observe (correctly) that the uranium industry is turning to lower grades of ore.
However, this trend is irrelevant to radon emissions for the radon source term from mill tailings areas remains essentially unchanged.
As the ore grade de-creases the volume of ore processed per ton of U 0 recovered 3g must increase, but the aquilibrium concentration of radon parents is directly proportional to the ore grade; hence, for a given quantity of U 0 produced, radon emissions vill remain 3g the same regardless of ore grade (assuming, as is required by faderal and state law, that tne same stabilization practices are maintained).
23.
Stabilization of larger tailing piles presents no greater technological difficulty than stabilization of smaller ones. ~
24.
Alleged deficiency no. 18.
Intervenors point out the possibility that, if mill tailings are stabilized by be?.ow grade disposal, " buried tailings [may] be leached by groundwater" and " people drilling for water may be attracted to the burial sites and be exposed to large radiation exposures through radium-226."
I cannot identify how this alleged deficiency is relevant to this proceeding, for it deals with possible exposure to radium-226, not radon, by trespassers going onto the tailings disposal sites to drill water wells.
In any event, the radca emissions that would result under the circumstances hypothesized by the Intervenors are negligible for, as discussed in reference to alleged deficiencies nos. 6 and 7, only minute amounts of radon would be emitted through a water well drill hole.
25.
Alleged deficiency no. 22.
In alleged deficiency no.
22, the Intervenors assert that the Perkins record is incomplete in that it gives no consideration to radon emissions from enrichment tails.
Enrichment tails are currently being stored in sealed containers at the enrichment plant sites.
These tails are expected to remain in containment until their ultimate use as breeder fuel, or their final disposition as waste or otherwise, is determined.
26.
If one assumed that these enrichment tails would be released from containment at some point in the future and then allowed to decay forever exposed to the atmosphere, the radon 7rr on, 6JJ cd/
release rate from them would be negligible in comparison to releases from mine and mill tailings, or natural background.
Uranium-238 decays (through two or three brief intermediate steps) into uranium-234, which in turn decays into thorium-230, which decays into radium-226, which finally decays into r aa.c n-2 2 2.
The half-life of uranium-238 is about 4.5 billion years; that of uranium-234 is about 250,000 years; that of thorium-230, about 80,000 years; and that of radium-226, about 1,600 years.
Enrichment tails do not contain either radium-226 or thorium-230, and their content of uranium-234 is also depleted in the enrichment process.
For radon to be produced from the enrichment tails, therefore, the complete decay chain from uranium-238 to radon-222 would have to take place, an extremely slow process.
27.
For purposes of illustration, I refer to the release 13 cited by Intervenor of 1.7x10 Ci of radon-222 from the complete decay of 117 MT of uranium-238 left in the tails from enriching fuel to supply 800 MW-yr of electric energy.
The decay process from uranium-238 to radon-222 is so slow that during the first one thousand years after the tails are
-11 produced a total of only 10 Ci of radon (i.e.,
only 6x10 percent of the eventual total) would have been generated; after one million years, only 0.01 percent of the total amount of uranium would have been transformed to radon; and aftet six billion years (the estimated remaining lifetime of the solar ') I 7
()
L J D
L !" O
system)(ll) forty percent of th: u t ig in al uranium would still not have decayed to radon.
The " full period of toxicity" over which Intervenors compute the source term and resulting health effects of enrichment tails exceeds thirty billion years.
Enrichment tails (even assumed to be released from containment) add nothing to the radon emission rates presented by the Staff in Perkins.
28.
Alleged deficiency no. 23.
Intervenors ask that "in-formation quantifying [the radon released from UF conversion]
6 be supplied to the record."
The Perkins record actually does contain information on radon releases from UF ccnversion.
6 Table S(A)-1 of Enclosure 1 to the Supplemental Affidavit of Dr.
R.
L. Gotchy foll. Tr. 2425, (which is taken from Table VIII (A)-6 of GESMO (NUREG-0002)) gives a total release of 0.034 Ci of radon-222 over twenty five years as a result of UF6 conversion to yield fuel for 4,551 gigawatt-years of electcic energy.
On the basis of my experience, these figures f rom GE6MO are reasonable.
Assuming, as was done throughout the Perkins proceeding, a 1,000 MWe reference reactor operating at 301 capacity factor for one year, the radon release attribut-able to UF conversion for this reactor, using the GESMO fig-6 ures, is 0.000006 Ci/AFR--a negligible amount ecmpared, for in-stance, to the 4,060 Ci/AFR attributable to uranium mining.
255 229
_1,_
29.
Alleged deficiency no. 24.
Intervenors also seek to have on the record information on radon-222 releases attributable to the remaining steps in the nuclear fuel cycle.
Again, Table S(A)-1 of Enclosure 1 to Dr. Gotchy's supplemental Affidavit (i.e.,
Table VIII(A)-6 of GESMO) giver. value s of zero or near zero radon releases from the remainder of the nuclear fuel cycle (enrichment, U0 fuel fabrication, reactor 2
operation, transportation, waste management and spent fuel storage).
I believe these release values in GESMO to be reasonable. The near-zero radon releases occurring during the balance of the fuel cycle are due to two facts:
(1) uranium in the fuel cycle beyond conversion is essentially devoid of radon parents, grandparents and great-grandparents, and (2) the amount of uranium feed inventory at other fuel cycle facilities is small compared to the inventory at the enrichment plant.
Thus, if the 117 MT of depleted uranium at the enrichment plant postulated in alleged deficiency no. 22 yield only 10 Ci of radon after a thousand years of decay, it logically follows that the far smaller caour t of uranium available elsewhere in the fuel cycle, decaying for a few days, weeks or months, will produce essentially no measurable releases of radon.
30.
i.lleged deficiency no. 26.
Intervenors also seek quantification of the radon emissions attributable to the recovery of uranium as a byproduct of phosphate fertilizer 255 230
production.
However, no phosphate fertilizer is processed just to get the uranium byproduct; to the contrary, phosphate fertilizer production is the main objecti.e of the industrial operation, and radon emanations occur during the processes of phosphate manufacture whether or not uranium is recovered.
Recovery of uranium by ion exchange separation from phosphoric acid does not add in any way to those radon emanations, hence no radon releases are attributable to the production of uranium by this process.
31.
To the extent that one attributes any radon releases to the recovery of uranium as a byproduct of phosphate fertilizer production, the small radon releases produced by this process would be more than offset by the larger releases avoided in not having to mine and mill ore to produce the uranium obtained from fertilizer.
/
e:/
/f,
hfG4v
'Mo r to n I. Goldman Sworn to and subscribed before me this
)
day of May, 1979.
kAAfa o, i
h b LL/-
Notary Puol'1c
~'
My Commissica expires Ab f
/
References 1.
L. C.
Schwendiman, Battelle Pacific Northwest Laboratories, letter report to Dr. Harry Landon, Office of Nuclear Regulatory Research, U.S.
- NRC, Feb. 6, 1978, with three attachments.
2.
L.
C.
Schwendiman, Battelle Pacific Northwest Laboratories, letter report to Dr. Harry Landon, Office of Nuclear Regulatory Research, U.S.
- NRC, Aug.
4, 1978.
3.
Sweetwater Uranium Project Draft Environmental Statement, NUREG-0403, App. G,
- p. G-2, Table G-1.1.
4.
Ibid, para.
3.1.4.
5.
Uranium Mill Site Restoration Act and Residual Radioactive Materials Act:
Hearings on S.3008, 3078 and 3053 Before the Subcomm. on Energy Production and Supply of the Senate Comm. on Energy and Natural Resources, o5th Cong., 2d Sess.
65-66.
(Statement of Dr. William D.
Rowe) 6.
GJO-100(78), Statistical Data of the Uranium
- Industry, U.S.
DOE, Jan.
1, 1978, pp. 46-47 7.
C.
M.
Jensen, et al.,
" Emanating Power and Diffussion of Radon Through Uranimum Mill Tailings," Ford, Bacon and Davis Utah Inc., presented at NEA Seminar on
" Management, Stabilization and Environmental Impact of Uranium Mill Tailings," Albuquerque, N.M.,
July 1978.
8.
Generic Environmental Impact Statement on Uranium Milling, NUREG-0511, para.
3.4.2.
9.
NUREG-0403, Supra, App.
G.,
para. G-1.5.
10.
Ibid, pp. 3-10.
11.
Freeman J.
Dyson, " Energy in the Universe,"
n 253 c'79 Scientific American, Sept. 1971.
c c
-t i s OJ, MORTCN I.
GXDMAN M
S 4
s SENIOR VICE PRESIDEST N*
A by \\j3Y d ENVIRONMENTAL S" STEMS GROUP i
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's EDUCATION JT ho / c3 {g Massachusetts Institute of Technology, Sc.D.,
1960 M.S.,
Nuclear Engineering, 1958 M.S.,
Sanitary Engineering, 1950 New York University, B.S.,
Civil Engineering, 1948 REGISTRATION Professional Engineer:
New York (1955); District of Colorbia (1965);
Maryland (1972); Aricona (1974); California (1977)
ENPERIENCE FUS C7RPOPJTION, 1961-Present U.S.
rublic Health Service, Division of Radiological Health, 1950-1961 Nuclear Installations Consultant, 1959-1961 M.I.T. Nuclear Engineering Department, 1956-1959 Reactor Safeguards Committee, Secretary Radioactive Waste Disposal Project, ?roject Leader ORNL Uaste Disposai Research Activity, Soils cna Engineering Section, Chief, 195/.-1956 Sanitary Engineering Center, Radiological Health Training Section, 1950-1954 M.I.T. Sanitary Engineering Department, Radicactivity Research Laboratory, Research Assistant, 1949-1950 New York University, Sanitary Engineering Rascarch Laboratory, Research and Teaching Assistant, 19e8-1949 NOT - Present assignment at NUS as Senior Vice Presider.t, Enviren-mental Systers Group, includes responsibility for managing all activities in site evaluation and selection, safety analyses, waste management system evaluations, environmental assessments and impar-t evaluations for nuclear and fossil-fueled power plants, industrial facilities, and aerospace nuclear activitics.
In 1968, served as U.S. represenative to and chairman of an IAEA expert panel en Radioactive Easte Management at Nuclear Power Plants, resulting in IAEA Safety Sciics No.23 of that title.
From 1972 to 1975, served cs consultant to and witness for the Consolldated Utility Group in the AEC/NRC ruleuaking hearing o-
"as low as practicable" radio-active waste discharge stands:ds.
Other activities include Chairman, Atomic Inda.ntrial Forum Ad Hoc Committee on Uranium Mining and Mi2 '. ing Environmental Ef fects and member of Steering Group, AIF Commi tee on Environment; representa-
- Chairnan, Vicplie tive, ASCE, to ANSI N18 " Nuclear Design Criteria";
ins JJ LaJ
.. ~ {...,44 s
! L\\
tLnlilJ11 NUS CORPCPABCN
MORTCN I.
GOLD:'.AU Psge Two Nuclear Effects Tack Committee, Environmental Engineering Division, ASCE; member, Cctmittee on Nuclear Standards, ASCE; member, Standards Committees AUS-2 " Site Evaluation" and ANS-13 " Environmental Inpact Evaluation".
Prior assignment as Technical Director of NUS, responsible for auditing the quality, scope and depth of the Corporation's technical capabil-ities; guiding the continuing development of those capabilities; serving as the senior corporate spokesman on all environmental and nuclear safety issues; and providing senior level consulting and pro-ject supervision for selected clients.
In the latter capacity serves as consultant to and witness for utilities and utility cr,ups in individual and generic proceedir ns involving energy / environmental activities including the GES::0 proceeding.
Public Health Service, provided technical consultation and At U.S.
assistance to state and federal agencies on health and sa2 ty prob-less of n aclear installations, including Peachbottom, Humboldt Bay, Yankee, Elk River, Pathfinder, CVTR, PM-3A, and Indian Point plants.
Served as mcabcr of working croup responsible for Radioactivity Section of USPHS Drinking Uater Standards (1960).
During MIT assign-directed research on fi::ation of high activity fission product
- ment, wastes which lead to successful development of low-solubility vitrecus fusion for several unste compositions.
Supervised research cn dis-posal of radioactive wastes at ORNL and ef fect of vaste solutions on soil chemistry and structure.
Conducted original research at NYU and MIT on removal of radionuclides from water by standard water trectnent techniques.
FEI2ERSHIPS American Society of Civil Enginecrs American Nuclear Society Air Pollution Ccncrol Association American Association for the Advancement of Science American Academy of Environmental Engineering, Diplomate dJ(~)~ 17-i 4.Je/
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s
( -
2 -
.tka.
10/78 NUS CORPORATCN
_ _ _ -. _. -. _.