ML20009B992

Forwards Comments on Des for Facility.Rept Erroneously Suggests That Rn-22 Emissions Will Stop After 1,000 Yrs

ML20009B992
Person / Time
Site:	Fermi
Issue date:	07/14/1981
From:	Lochstet W AFFILIATION NOT ASSIGNED
To:	Office of Nuclear Reactor Regulation
References
RTR-NUREG-0769, RTR-NUREG-769 810713-02, 810713-2, NUDOCS 8107200126
Download: ML20009B992 (2)

Text

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s-104 Davey Laboratory The Penn. State University University Park

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Pa,, 16802 13 July 1981 Director, Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.

20555

Dear Director:

Attached are my comments on the Draft Environmental Statement en the operation of the Enrice Fermi Unit 2, (NUREG-0769).

Please note that the opinions and calculations are my own, and not ~necessarily those of The Pennsylvania State University, which affiliation si hiven for identification purposes only.

1 should note that I requested a copy of the draft from Document Control on 23 June, but did not receive it until 10 July.

It is particularly distressing to see the "Rebaselining" that is done in this Draft without the kind of Peer Review that the NRC recognized was necessary for WASH-lk00 in its Janyary 18, 1979 "NRC Statement on Risk Assessment and the Reactor Safety Study Report in light of the Risk Assessment Review Group Report". (P 3).

I hope these comments are useful in developing the Final EIS required by NEPA.

Sincerely, W

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W.A. Lochstet, Ph.D.

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8107200126 810713

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PDR ADDCK 05000341 H

PDR

The Long Term Health Consequences of Enrico Fermi, Unit 2 by William A. Lochstet The Pennsylvania State University

• July 1981 The Nuclear Regulatory Commission (NRC) has attempted to evaluate the health consequences of the-operation of the Enrico Fermi Atenic Power Plant, Unit 2, in its draft Environmental Statement NUREG-0769-The health consequences of the raden-222 released from the mii1 tailings and the open pit mines are evaluated for the first 1000 years from new in Appendix C.

This evaluation suggests ( Page C-8) that the raden emissions increase after the first 500 years hafe elaphed. There is no suggestion that there is any reason to believe that these emissions will stop at that time,9r after 1000 years.

The fact is that these radon emissions are governed by the 80,000 year half life of thorium-230 and the 4.5 billion year half life of uranium-239. The thorium sit &ation had been adequately discussed by Pohl (Search, 2(5),345-350, August 1976).

The impact of the uranium-238 as a source of radon was recognized in GESMO (NUREG-0002)(1976) and is discussed in the Final Environmental Statement for the Split Rock Mill ( NUREG- 0639 l

Pages A-57 to A-60). The result is that the uranium in the mill tailings is estimated to cause 200,000 deaths,<

for t he amount of activity to generate the fuel for i one 1000 Mwe plant operating at 80 $ capacity factor. This is the generic case taken in the i

Draft, NUREG-0769.

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The opinions and calculations presented here are my own. and l

not necessarily those of the Pennsylvania State University.

My affiliation is given here far identification purposes only.

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