ML19263E999
| ML19263E999 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Hope Creek, Sterling, 05000484, Crane  |
| Issue date: | 06/26/1979 |
| From: | Kepford C Environmental Coalition on Nuclear Power |
| To: | |
| Shared Package | |
| ML19263F000 | List: |
| References | |
| NUDOCS 7910190230 | |
| Download: ML19263E999 (6) | |
Text
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Us:tRo UNITED STATES OF AMERICA 3i-NUCLEAR REGULATORY COMMISSION JUL 21979 >
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), fica of the Secretary NRC PUBLIC DOCUMENT ROOM U '**fr!n N 3
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BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARDS In the Matters of
)
)
PHILADELPHIA 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.
50-330 (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 50-485 CORPORATION et al.
(Sterling Power Project,
)
Nuclear Unit 1)
)
Affidavit of Dr. Chauncey Keoford Settina Forth the Intervenors' Statement of the Facts as to Which There is a Material Dispute _._
Chauncey Kepford, being duly sworn, states as follows:
1.
I am a member of the Executive Board of the Environmental Coalition on Nuclear Power.
I serve also as a censultant to this organization and its member groups on legal and technical matters.
I have appeared as an expert witness on the radon issue on behalf of the intervening citizen groups (" Inter-venors")in the TMI-2 licensing proceedings.
I also have appeared as an expert witness on the radon issue on the behalf of citizen intervenors in the Perkins 1, 2, and 3 proceedings.
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2.
TMs affidavit was prepared by me for the purpose of establishing before the Appeal Board that there are material facts as to which there is a dispute in this proceeding. The comments herein will refer specifically to the numbered paragraphs of the Applicant's " Statement of Material Facts as to Which There is no Genuine Issue to be Heard" (" Statement") and the " Affidavit of Morton I. Goldman" ("Goldman").
5 3.
The use by the Staff of a value of 2.71 x 10 metric tons (MT) of uranium ore per reactor year is inaccurate to the extent that it defines a quantity of are of a certain (unstated) set of reactor parameters (Statement, at 7).
In reality, the average grade of ore being mined in the U.S. has dropped significantly in recent years and there is no reason to expect that it will not continue to decline as higher grades of ore are depleted.
4.
The ore grade problem is complicated by the fact that as the ore grade drops, the percentage of material to be recovered from the ore drops also.
tons of 0.2% U 03 ore does not, af ter milling, What this means is that 10 3
produce the same quantity of recovered U308 as would 106 tons of 0.02% U 03 8 ore.
In fact, it would take more of the 0.02% ore, because a lower level of recovery of U 03 8 would be realized.
Since more of the lower grade are will have to be mined than the 106 tons, a larger radon-222 source term may result per reactor year, in addition to having the problem of stabilizing more than 10 times the volume and weight of the mill tailings than for the 0.2% ore.
Compare Statement, para. 49, 50, Goldman, para. 22, 23.
5.
The assumption that deep mines produce no radon gas after shutdown
.cannot be accepted as correct. A reading of the Perkins transcript (Statement 6,8)\\ '
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cited (tr. 2542)'s' hows clearly that Witness Wilde acknowledged that natural 2220 027 ventilation could bring up radon from the mine interior to the external environ-ment.
Neither the TMI-2 nor the Perkins proceedings addressed the question of how long-whatever " seals" which are applied to underground mines would be effective at containing all radon emissions within the mines.
6.
The Perkins record contains a wholly inadequate examination of radon-222 releases from openpit mines (Statement, at 9-11, 15, 16, 17, 18).
The calculations offered by the Applicant are based on sweeping and unsubstan-t1ated assumptions; they are not finnly based on experimental evidence.
In addition, Witness Wilde freely admitted his calculation was " quick and dirty" (tr. 2610).
Furthennore, Witness Goldman used an overburden in his calculation with an apparent volume of 270,000 MT (tr. 2640), just that of one year's requirements. This value is refuted in his own affidavit (Goldman,12).
Contrary to the Statement in his affidavit (Goldman,11) that his Perkins calculations included open pit mine emissions, the 100 curie and 200 curie values refer to emissions of radon from the overburden for two specific uranium concentrations (tr. 2640,19-13).
7.
Radon-222 is a naturally-occurring radioactive decay product in the middle of a radioactive decay series which begins with uranium-238 and tenninates with stable lead-206.
Radon-222 is of particular concern for a number cf reasons:
(a) While raden-222 has a short, 3.8 day half-life, it has parent radioa.tive materials with long half-lives:
uranium-238 (4.5 billion years) and thorium-230 (80,000 years).
(b) Rad:n is the only naturally-occurring radioactive noble gas, and radon-222 is the only naturally-occurring radon isotope with a half-life longer than about one minute.
As a result, radon-222 has by far the greatest opportunity to diffuse away from its point of origin prior to undergoing decay.
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. (.c) Radon-222 has three short-lived daughter products which emit alpha particles, which are among the most damaging of the ionizing radiations. These daughter products, when in-haled, are known to cause lung cancer.
8.
In the process of obtaining fuel for nuclear reactors, naturally-occurring uranium ore is taken to mills where the ore is ground, about 90% of the uranium is removed, and the " tailings" are washed out to a pond where, when the mill ceases, operation, the tailings dry and radon, which otherwise would have been trapped in underground ore formations, can escape to the air.
Once the radon is in the air, it can be transported with the winds and taken 4r from the mill tailings dump.
9.
In the case of a mill tailings dump, the primary " parent" of radon-222 is thorium-230, since about 90% of the uranium.138 is generally removed during the milling process. This means that the emission of radon will be governed primarily by a source with an 80,000 year half-life.
Of course, when much of the thorium-230 has deca /ed, e.g., after about 3 half-lives, years, the main parent then becomes the very long half-lived uranium-238.
or 240,000
- 10. While the annual emissicas of radon from the mill tailings used to supply fuel to a commercial nuclear reactor for one year are appreciable, about 74.5 curies to 100 curies when this annual emissions rate is integrated over time, the total emission' is seen to be truly enormous.
In the case of TMI-2, the radon which will be produced by the radioactive decay of the remaining thorium-230 in the atandoned mill tailings piles is about 320 million curies of radon.
If the decay of the remaining 10% of uranium-238.not removed by the milling process is considered, the radon producea for each year of TMI-2 operation increases to about 1.8 trillion curies.
It must be emphasized that these emissions are the result of natural decay of the thorium and uranium in the tailings piles produced to operate a commercial reactor for pne year.
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,1 1.
During the TMI-2 licensing proceeding, the NRC, through the testi-l many of its witness, Gotchy, used a death rate of 0.023 premature deaths for each 4800 curies of radon released to the atmosphere.
From this value, a l
number can be computed for the premature deaths caused by these radon emissions due to operation of a commercial reactor such as TMI-2.
Gotchy's calculations i
assumed a future population model which, in essence, freezes the present i
society at a particular population level and extends it as far as necessary into the future.
On this basis, a value of 87,000 premature deaths for each i
i year of operation of TMI-2 can be comput.d.
12.
Using a conversion factor from curies emitted to deaths due to cancer derived by the EPA, which essentially differs from Gotchy's conversion
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factor in that it uses a different lung dosimetry model, a value of 1.2 million premature deaths is calculated for each year that TMI-2 will operate.(See testi-many of Dr. Chauncey Kepford in the TMI-2 licensing proceeding.)
- 13. An additional issue in calculating the cost in human lives of the radon emissions concerns the dosimetry of radon daughters in the human lung.
This dosimetry is complicated by the fact that radon concentrations vary widely in the natural environment.
In general, it is areas of more static air where I
the daughters of radon have a chance to accumulate.
Such more static conditions are more typical of underground uranium mines and, for even lower concentrations, the interiors of buildings.
l<.
Among researchers in the field, there does not seem to be an agreed upon valuh foh Mical" radon daughter concentrations for a given radon concentration. Nor is there a generally agreed upon depth of penetration by the emitted alpha particles into the sensitive tissue of the lung. As a result of these and other factors, there exists a wide range of factors which may be used to convert from a given exposure to a given concentration of radon into a radiation dose in the proper units, as rads or roentgens. The NRC Staf/ uses a 2220 030
valua near the low end of the published range, reducing the ef.fect of any calculated dose.
15.
Furthermore, it has recently been suggested that a number called the " relative biological effectiveness", or RBE, which converts rads or roentgens into the more customary unit, rems, may be underestimated by a lar.je factor, perhaps 19 or more, for low doses of high LET radiation (" Leukemia Risk from Neutrons", Rossi and Mays, Health Physics 34 p. 353-60,1978). The result of these above considerations (of dosimetry and low-level radiation effects) suggests that the above numerical estimates of premature deaths due to radon may be underestimated by a factor of at least 100.
16.
In addition to the 1.2 million or so avoidable, premature deaths attributable to the mill tailings emissions of radon for each year of commercial operation of a single nuclear reactor (based upon EPA's conversion factor), and in addition to the factor of 100 underestimation which this enormous number of deaths may represent (as explained above), one must also consider the radon-related deaths attributable to the mining of uranium ore (Perkins tr. 2465-67).
The prospects of serious mine reclamations efforts which would substantially reduce the long-term radon emissions attributable to, the mining portion of the nuclear fuel cycle appear dim or non-existent.
(See, e.g., Dr. Chauncey Kepford's February 19, 1979, response to the de minimus theory, at pages 10-16).
Neither of these sources of radon-222 is small, insignificant, or de minimus, 2220 031 NTH 1 / D GL%
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Sworn tc and subscrged to Dr. Chauncey Kepford j
before me this Me day of 433 Orlando Avenue June, 1979.
State College, Pa.16801 My Cortnission expires 63//df /
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NSt c
e e i h8' My Comm: mon Expires March 16193L