ML20010J625

Affidavit Supporting NRC Motion for Summary Disposition of Portion of Contention 1 Re Radiological Health Effects of Isotopes Other than Rn-222 & Tc-99.Certificate of Svc Encl

ML20010J625
Person / Time
Site:	Susquehanna
Issue date:	09/29/1981
From:	Linnemann R RADIATION MANAGEMENT CORP. (RMC)
To:
Shared Package
ML20010J624	List: ML20010J623 ML20010J625
References
NUDOCS 8110060289
Download: ML20010J625 (6)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

PENNSYLVANIA POWER & LIGHT COMPANY )

)

AND ) Docket Nos. 50-387

) 50-388 ALLEGHENY ELECTRIC COOPERATIVE, INC. )

)

(Sus'uehanna Steam Electric Station, )

Units 1 and 2) )

, AFFIDAVIT OF ROGER E. LINNEMANN IN SUPPORT OF STAFF'S MOTION FOR

SUMMARY

DISPOSITION OF A PORTION OF CONTENTION 1 County of Philadelphia )

ss.

Commonwealth of Pennsylvania )

Roger E. Linnemann, being duly sworn, deposes and says as follows:

1. I am President, Radiation Management Corporation

( " RMC " ) . My business address is 3508 Market Street, Philadelphia, Pennsylvania. A summary of my professional qualifications and experience was attached as Exhibit "A" to my Affidavit in Support of Staff's Motion for Summary Disposition of A Portion of Contention 2, dated September 18, 1981. (" Contention 2 Affidavit"). I have personal knowledge of the matters set forth herein and believe them to be true and correct.

2. I have reviewed the "NRC Staff Response Supporting Applicants' Motion for Partial Summary Disposition of Contention 1 (Fuel Cycle Doses) and NRC Staff Motion for Summary Disposition of a WTe!PS@fR C

Port of Contention 1" (" Staff Motion") and supporting documents, including the Affidavit of Reginald L. Gotchy ("Gatchy Affidavit").

I give this Affidavit in support of the Staff's Motion.

3. The Staff Motion and the Gotchy Affidavit state that the Staff assessed, in the Final Environmental Statement NUREG-0564 ("FES"), the health effects of fuel cycle releases or radionuclides other than radon-222 and technetium-99 attributable to the Susquehanna Steam Electric Station ("Susquehanna"). The Staff computed a 100-year environuantal dose commitment to the U.S.

population of about 500 person-rem (total body) per reference reactor year ("RRY") from radioactive releases during the fuel cycle for a reference reactor. Based on that dose commitment, and a risk estimator of 135 excess cancer deaths per million person-rem, it estimated that an additional 0.08 to 0.12 cancer deaths per RRY might occur over the next 100 to 1000 years from exposure to fuel cycle radioactive releases.

4. As set forth in the Affidavit of Dr. Morton I. GotAman in support of Partial Summary Disposition of Contention 1 (Fuel Cycle Doses) ("Goldman Affidavit"), the doses per RRY can be translated 1

into doses for the lifetime of Susquehanna by multiplying by 64.

t Therefore, the Staff's dose assessment for Susquehanna would be 500 x 64 = 32,000 person-rem (total body). At 135 excess cancer deaths per million person-rem, this would give 0.043 excess cancer deaths per year over a 100-year period as the Staff's estimate of the health effects of the radioactive releases attributable to the nuclear fuel cycle for Susquehanna.

5. The Goldman Affidavit computes an upper bound dose of 42,240 total body person-rem over 100 years. Consequently, l L

utilizing a risk estimator of 100 excess deaths per million total body person-rem (see my Contention 2 Affidavit) , I estimate an upper bound of 0.042 cxcess cancer deaths per year over 100 years as a result of fuel cycle releases attributable to Susquehanna.

This estimate is consistent with, and very similar to, the Staff's estimate.

6. Based on its estimate, the Staff concluded that the health effects of fuel cycle releases of radionuclides attributable to Susquehanna will be inconsequential and will not tip the cost-benefit balance for the facility. I concur in the Staff's assessment and agree with its conclusion that the fuel cycle releases of radionuclides other than radon-222 and technetium-99 will have an inconsequential health impact and will not alter the cost-beaefit balance for operation of Susquehanna.

t J

'N}o e(r$& . I;innemann 2,'

Sworn to and subscrubed before me this - day of

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! , 1981.

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Notary Public SHELLY KOFFLER Notary Public Phila.. Phila Co.

Mt Commission Spires Marcn 23, m35

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

PENNSYLVANIA POWER & LIGHT COMPANY )

)

and ) Docket Nos. 50-387

) 50-388 ALLEGHENY ELECTRIC COOPERATIVE, INC. )

)

(Susquehanna Steam Electric Station, )

Units 1 and 2) )

CERTIFICATE OF SERVICE This is to certify that copies of the foregoing

" Applicants' Response in Support of NRC Staff Motion for Summary Disposition of a Portion of Contention 1" and " Affidavit of Roger E.

Linnemannin Support of Staff's Motion for Summary Disposition of a Portion of Contention 1", were served by deposit in the U.S.

Mail First Class, postage prepaid, this 30th day of September, 1981, to all those on the attached Service List.

Y 4"b - /h?

Matias F. Travieso-Diaz l

Dated: Septen6er 30, 1981 l

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UNITED STATES OF AMERICA N'JCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

PENNSYLVANIA POWER & LIGHT COMPANY )

)

AND -

) Docket Nos. 50-387

) 50-388 ALLEGHENY ELECTRIC COOPERATIVE, INC. )

)

(Susquehanna Steam Electric Station, )

Units 1 and 2) )

SERVICE LIST Secretary of the Commission Dr. Judith H. Johnsrud U. S. Nuclear Regulatory Commission Co-Director Washington, D. C. 20555 Environmental Coalition on Nuclear Power Administrative Judge James P. Gleason 433 Orlando Avenue 513 Gilmoure Drive State College, Pennsylvania 16801 Silver Spring, Maryland 20901 Susquehanna Environmental Advocates Mr. G,lenn O. Bright c/o Gerald Schultz, Esquire Atomic Safety and Licensing Post Office Box 1560 Board Panel- Wilkes-Barre, Pennsylvania 18703 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Mr. Thomas J. Halligan, Corresponder3 The Citizens Against Nuclear DangerE Dr. Paul W. Purdom Post Office Box 5 245 Gulph Hills Road Scranton, Pennsylvania 18501 Radnor, Pennsylvania 19087 Ms. Colleen Marsh l Atomic Safety and Licensing Box 558 A, R. D. #4 Board Panel Mt. Top, Pennsylvania 18707 U. S. Nucitar Regulatory Commission Washington, D. C. 20555 Jessica H. Laverty, Esquire

- _- Office of the Executive Legal Docketing and Service Section Director l Office of the Secretary U. S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D.C.'20555 l

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Q,s ~

Robart W.-Adler, Esquire Mr. Thomas M. Gerasky, Director Dnpartmenc of 2.nvironmental Resources Bure3u of Radiation Protection Commonwealth of Pennsylvania Department of Environmental 505 Executive House Resources Post Office Bcx 2357 Commonwealth of Pennsylvania Harrisburg, Pennsylvania 17120 Post Office' Box 2063 Janas I?. Cutchin, IV, Esquire office of the Executive Legal Atomic Safety and Licensing Appeal Director Board Panel U. S. Nuclear Regulatory Commission 'U . S. Nuclear Regulatory Commissica Washington, D. C. 20555 Washington, D. C. 20555 DeWitt C. Smith Director Pennsylvania Emergency Management Agency Transportation and Safety Building Harrisburg, Pennsylvania 17120 e

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