ML20010J623

Response Supporting NRC 810911 Motion for Summary Disposition of Portion of Contention 1 Re Radiological Health Effects of Isotopes Other than Rn-222 & Tc-99.Health Effects Adequately Addressed in Fes

ML20010J623
Person / Time
Site:	Susquehanna
Issue date:	09/30/1981
From:	Traviesodiaz ALLEGHENY ELECTRIC COOPERATIVE, INC., PENNSYLVANIA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20010J624	List: ML20010J623 ML20010J625
References
NUDOCS 8110060287
Download: ML20010J623 (3)

Text

. Sg.*. embar 30, 1981 UNITED STATES OF AMERICA --- -

NUCLEAR REGULATORY COMMISSION ,Il f,3~ -

BEFORE frq ATOMIC SAFETY AND LICENSING BOARD gy 3 3 JQ IN frm

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In the Matter of ) 2 b. .. > $l

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PENNSYLVANIA POWER & LIGHT COMPANY } \ .

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and Docket Nos. 50 ALLEGHENY ELECTRIC COOPERATIVE, INC. ) y g

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(Susquehanna Steam Electric Station, ) 0  %

Units 1 and 2) )

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OCT G 1981n u,

APPLICANTS' . RESPONSE IN SUPPORT OF co/Jdgroc, Y NRC STAFF MOTION FOR

SUMMARY

DISPOSITION OF A PORTION OF CONTENTION 1 ,

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On September 11, 1981, the NP.C Staff (" Staff") filed ,

a Motion for Summary Msposition G _ortion of Contention 1, seeking summary dispositior of etion of Contention 1 which alleges that the radiologica' *aalth effects of all isotopes other than radon-222 and technetium-99 which will be released during the fuel cycle required for the Susquehanna Steam Electric Station

("Susquehanna") have been underestimated. The Staff's motion and accompanying affidavit state that the radiological health risks from fuel cycle releases of radionuclides other than radon-222 and technetium-99 nave been adequately assessed in the Final Environmer.tal Statement ("FES') for Susquehanna, NUREG-0564, and have been found to be inconsequential and incapable of affecting the cost-benefit analysis for the operation of Susquehanna.

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8110060287 810930 Y'fI G I PDR ADOCK 05000387 G PDR

. o Applicants support the Staff's motion for summary 1/

disposition of this portion of Contention 1. As discussed in the Affidavic of Reger E. Linnemann in Support of Staff's Motion for Summary Disposition of a Portion of Contention 1, attached hereto, the risk computation performed by the Staff and set forth in the FES utilized a risk estimator of 135 excess cancer deaths per million person-rem. Based on that risk estimat6r, the Staff computed an additional 0 08 to 0.12 excess cancer deaths per reference reactor year ("RRY") over the next 100 to 1000 years from exposure to fuel cycle radioactive releases. The Staff's computation, which is based on the 1972 BEIR-I Report risk estimators and a dose commitment of 500 person-rem (total body) per RRY, would yield 0.043 excess cancer deaths per year as the potential health risk associated with the fuel cycle releases attributable to Susquehanna.

Dr. Linnemann's independent risk computation, made utilizing a risk estimator of 100 additional cancer deaths per million person-rem exposure based on the 19 80 BEIR-III Report, 1/ On August 7 and 28, 1981 Applicants filed motions for partial summary disposition of two portions of Contention 1. The first motion was directed at that portion of Contention 1 which addresses the magnitude of the releases of radon-222 attributable to the fuel cycle for Susquehanna and the health effects of those releases. The second j summary disposition motion was directed at the radioactive doses resulting from thT releases of radionuclides, other than radon-222 and I technetium-99, attributable to the fuel cycle for Susquehanna. In its Memorandum and Order on Pending Motions dated September 23, 1981, the Board accepted a stipulation .5y the parties removing the radon-222 issue from the proceeding; the Board also granted Applicants' i motion for summary disposition of the issuo of radioactive doses l

from radionuclide releases attributable to the Susquehanna fuel cycle.

Consequently, if the instant motion by the Staff is granted, the only l portion of Contention 1 that will be left for hearing will be the one l addressing the magnitude and health effects of technetium-99 releases attributable to the Susquehanna fuel cycle.

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gives an upper bound of 0.042 excess cancer deaths per year resulting from the radionuclide releases attributable to the Susquehanna fuel cycle. Dr. Linnemann's estimate, therefore, confirms that of the Staff, and supports the staff's conclusions that the health effects resulting from the radionuclide releases for the Susquehanna fuel cycle are inconsequential, will have no discernible impact on public health, and will not tip the cost-benefit balance against operatic,. of the facility.

For the above stated reasons, the Staff's motion for summary disposition of that portion of Contention 1 which relates to the risks of potential releases of radionuclides other than radon-222 and technetium-99 from the fuel cycle for Susquehanna should be granted.

Dated: September 30, 1981.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE By ANM" #

7 Jay E. Silberg Matias F. Travieso-Diaz Counsel for Applicants 1800 M Street, N.W.

Washington, D. C. 20036 Telephone: (202) 822-1000

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