ML19318D199
| ML19318D199 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Hope Creek, Sterling, Crane  |
| Issue date: | 06/20/1980 |
| From: | Caplan R ECOLOGY ACTION OF OSWEGO |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| NUDOCS 8007080046 | |
| Download: ML19318D199 (2) | |
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NUCLEAR REGUIATCRY COWISSION USNRC JUN 2 41980 >
Ecfore the Atomic Safet;r and Licensing Appeal Boards 9,"
g, Docketing & Mce J In the ttatter of
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L Branch
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C Philade).fnia Electric Co. et. al.
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Docket Nos. 50-277, 50-27 o) w Peach Bottom Unita 2 and 3 Metiopolitan Edison Co. et. al.
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Docket No. 50-320 Three Eile Island Unit 2
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Public Service Electric and Gas Co.
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Docket Wos. 50--35h, 50-355 Hope Creek Uni's 1 and 2
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Rochester Gas and Electric Corp. et. al.)
Docket No. STN 50-h85 Sterling Unit 1
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Response to Board Request on Deficiency No.1 The evidence presented by staff at the Harrisburg hearing demonstrates that intervencrs were ccrrect when they alleged in Deficiency No.1 that there was doubtful, if any, correlation between radon releases from underground uranium mines, and the amount of uranium fuel (AFRs) obtained frcu the nine. Such a correlation was, and still is, assu ed by staff; it is inherent in the relationship that assigns I number of curies per AFR to uraniun mining.
The proof of the staff's error is in the dratatic change in staff witnese Wilde's testimony between the Perkins hameing and the Harrisburg proceeding. In Perkinc, Wilde testified that the release of radon from an active underground =ine anounted to h,060 C1/AFR. At ihrrisburg, the number rose almost 100 per cent, to 8,000 Ci/AFR (TR 363, Wilde).
Wilde based his Har$isburg testimony on an ongoing study by Battelle of radon releases from underground and open pit uranium mines. The Battelle study had feund since its initial stages that the correlation between radon mleases and AFRs from mire s is doubtful. Intervenors cited stateents to this effect from a Battelle prognss report dated in 1978 when they brought up Deficiency No.1.
In the latest Battelle report, which was nade available to parties at the Harrisburg hearing, Battelle reiterates this position. The latest report says, however, t
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- Ecology Action page 2 that there appears to be some correlation between radon releases and cu=ulative
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~ tons of uranium ore mined; that is, the mare ore that has already been produced by a cine, the higher the radon releases will be fcr each additional ton of ore (TR 391, Wilde). This appears reasonable. A larger mine will have more surface area from which radon can emanate and a greater volume of air to exhaust. It wculd appear from the Battelle report that the relationship between raden and ATRs is not the straight line assumed by staff, but closer to a curve whose slope increases with each additional AFR. Even this relationship wculd fall apart if the:S were vagaries in the yellowcake and cre production rate.
We believe the Appeal Board =ust reverse its decision rejecting Deficiency No.1. in light of the Harrisburg testimony. I!cwever, despite the initial ruling, the issue was explored fair 37 extensively at Harrisburg in relation to the staff's testimony on releases from abandoned unsealed underground mines. We see no need for further hearings on the matter, unless the Board decides there are specific i
aspects of the issue on which it needs mere evidence.
The evidence presented at Harrisburg invalidates the values given for radon releases from underground mines in Perkins. Some may argue that the Board should simply accept the staff's new figure of 8,000 Ci/ATR. But if the ccrrelation itself is suspect, why should the new number be any."cre reliable than the old one?
Wilde testified that he is sure the' new number will change also (TR 397), and that if production figures dropped by 50 per cent, the number for radon releases would double (TR 398).
Theref are, we ask that the Board zwverse its previous decision on Deficiency No. le and, at the same ti:ne, vacate that portion o' the Perkins decision that concluded that radon releases from underground mines were h,060 Ci/AFR. Instead, the Board should find that no correlation between radon releases and AFRs has been demonstrated.
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rum 1 Caplan June 20, 1990 for Ecology Action of Oswego
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