ML19317H352
| ML19317H352 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Hope Creek, Sterling, Crane  |
| Issue date: | 04/25/1980 |
| From: | Goldman M AFFILIATION NOT ASSIGNED |
| To: | |
| Shared Package | |
| ML19317H349 | List: |
| References | |
| NUDOCS 8005290374 | |
| Download: ML19317H352 (9) | |
Text
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N 00GED UNITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION -
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3 BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD 8tdf,7,y '
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e In the Matter of
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PHTLADELPhIA ELECTRIC COMPANY et al.
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Docket Nos. 50-277 (Peach Bottom Atomic Power Station,
)
50-278 Unites 2 and 3)
)
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METROPOLITAN EDISON COMPANY et al.
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Docket No. 50-320 (Three Mile Island Nuclear Station,
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Unit 2)
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PUBLIC SERVICE ELECTRIC AND GAS CO.
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Docket Nos. 50-354 (Hope Creek Generating Station,
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50-355 Units 1 and 2)
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ROCHESTER GAS AND ELECTRIC CORPORATION
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Docket No. STN 50-485 et al.
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(Sterling Power Project, Nuclear Unit 1)
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AFFIDAVIT OF DR. MORTON I. GOLDMAN State of Maryland
)) ss.
County of Montgomery)
Morton I.
Goldman, being duly sworn, deposes and says as follows:
1.
I am Senior Vice President, Environmental Systems Group, NUS Corporation, Rockville, Maryland.
A statement of my professional qualifications is attached as Exhibit "A"
to my earlier affidavit filed in support of Licensee's Joint Motion for Summary Disposition of Radon Issues, filed on May 25, 1979.
80 052 9 03 7 t/
2.
I have been asked to address the technical aspects of the question raised by the Appeal Boards in their March 7, 1980 Order, namely, whether information on radon releases from under-ground uranium mines contained in the recent draft Battelle-Northwest report (NUREG/CR-1273, February, 1980) ("the Battelle draft report") warrants reconsideration of the Appeal Boards' disposition of Alleged Deficiency No. 1 in this proceeding.
3.
Alleged Deficiency No. 1 dealt with the ability to t
predict the radon released as a consequence of mining uranium.
In granting summary disposition of this alleged deficiency, the Boards in ALAB-562 relied to some extent upon my analysis of the preliminary data presented by Battelle Pacific Northwest Laboratories regarding radon emissions from active underground mines.
4.
At the outset, it must be recognized that the data base upon which I derived the analysis referred to in ALAB-562 represented a small sample of the mining industry.
I estimate the total production represented by those mines to be in the range of 20-25% of the total underground uranium production in the referenced year.
5.
The most recent data available are those contained in the Battelle draft report, referred to by Mr. Wilde in his testimony (Tr. 345 et. seq.), which are much more comprehensive than Battelle's earlier preliminary data, representing as they i
do 63% of the uranium produced in the United States in 1978 by underground mining.
Thus, they provide a substantially more reliable base upon which estimates of radon release from this -
source category can be extrapolated.
6.
Thus, I believe that the active uranium mining source term of 5,150 curies per AFR testified to at the hearing (Tr. 348-349 (Wilde)), found from extrapolation of the releases from mines accounting for 63% of the United States underground mine production, is indeed representative of the industry as a whole, and might in fact overstate the radon releases from this source category since the remaining 37% production is most likely to come from smaller mines producing lower radon releases.
While it is conceivable that some of the remaining 37% of unsampled underground mine productica might come from the larger under-ground mines, Battelle concentrated the sampling efforts on the larger mines; therefore, it is unlikely that the average radon releases from the unsampled mines would be higher than that. from the mines sampled.
..ee Tr. 405 (Wilde).
7.
For the Boards' information, I have computed upper and i
lower limits to the radon releases from active underground mines in the unlikely event that radon releases from the unsampled mines were to differ significantly from those emitted by the sampled mines.
To accomplish this, I have recognized (as presented in the Battelle report) that older, larger mines appear to emit more radon per ton of ore removed that do the younger, smaller mines.
Thus, the upper release limit would be achieved if one assumed that the remaining 37% of underground uranium mine production came from large underground mines similar to those sampled by Battelle.
Conversely, the lower radon release limit would result if (as is likely to be the case) the remaining 37%
of underground mine production came from younger, smaller mines with lower average releases per ton of ore (or U 0 I
- 38 -
8.
To provide an upper range for the emission from active underground mining, I calculated the total releases for underground mines essuming that the remaining 37% of production came from mines falling in the two largest classes of mines in the Battelle report, i.e.,
those with cumulative productions. of greater than 2 million tons.
These mines, identified in Table 11 of the draft Battelle report as Mines E, F, H, J, R
and Y.,
emitted a total of 96,100 curies per year and had an estimated 1978 U 03 8 pr duction of 2,091 tons, for an average release per ton of 46 curies in that year.
If this average rate for these two largest classes of mines were extrapolated to the residual 37% of 1978 production (3,440 tons) the total underground releases would have been 311,830 curies, or 10,100 curies per AFR based on 271 metric tons per AFR.
9.
With 60% of the production assumed to come from underground mines and 40% from surface mines, the total release from active mines would be approximately 6,440 curies per AFR, about 24% greater than the 5,150 Ci/AFR value obtained by assuming the current Battelle underground mine sample to represent the underground mining industry as a whole.
10.
To compute the lower limit on the active underground mining releases, I assumed that the unsampled 37% of production comes from the smaller two classes of mines as categorized in the draft Battelle report.
For the nine mining operations in Table 11._
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of that report which fall in the less than 2 million ton cumulative ore mined categories, the average release is 10.6 curies per ton of U3 8'
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mining assuming the 37% to be made up of this smaller size category (which is more likely the case) would be 6,160 curies per AFR from underground mining.
11.
Again, with the 60:40 production ratio of under-ground to surface mines, the total active mining radon source term would be 4,070 curies per AFR, which is almost precisely the value proposed by the Staff in the Perkins hearing.
12.
In summary, I would characterize the active uranium 1,300 mining source term as 5,150 + 1,080 curies per AFR, with the most likely value being the average or lying between the average and the lower limit of the range.
13.
It should be noted that Battelle examined the relationship between cumulative ore production and radon releases, and indicated (p. 40) that "The correlation is significant, but not highly significant."
Nevertheless, even the existence of a perfect correlation would not, of itself, permit the development of a more precise prediction of future radon releases based on cumulative ore production.
For, to compute future radon releases based on cumulative ore production, the distribution of sizes of underground mine,s would have to be known as a function of time into the future; I know of no way to make such a prediction with a reasonable degree of confidence.
Thus, at present, the best estimate that can be made is that obtained by correlating radon emissions and yearly ore production using all the available data, and recognizing the possible ranges identified in this af fidavit. -- _
14.
Ac o finn 1 point, the possibic effects on the estimate resulting from variations in production rates should be mentioned.
Table 1 in the Battelle draft report lists (current) daily ore production (normalized to a 250 day working year), years in production and total cumulative ore production for 17 mines.
With these data, the average ore production rates can be determined and compared with the current rates.
For the 17 mines, my calculations show that current ore production rates are about 15% above the average production over the age of the mine o
date.
Thus, if one were to assume that the current radon releases would be applicable to the average production rates (rather that current rates), the releases per AFR for underground mines would be 15% higher than those given by Battelle.
These higher emissions would be encompassed by the upper limit deviation of 24% cited in the Battelle draft report.
The 15% figure should be regarded as an upper limit, since radon releases during each previous year in the mine's operating life should be smaller than current releases because the mines would have been smaller.
Sworn to and subscribed before me this.
day of April, 1980.
l Y~
Notary Public My Commission expires
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