ML20024E846

Motion for Partial Summary Disposition of Eddleman Contention 80 Re Rainout.No Genuine Issue of Matl Fact Exists

ML20024E846
Person / Time
Site:	Harris
Issue date:	08/31/1983
From:	Eddleman W EDDLEMAN, W.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20024E830	List: ML20024E829 ML20024E832 ML20024E834 ML20024E840 ML20024E846 ML20024E850 ML20024E853 ML20024E856 ML20024E858 ML20024E862
References
82-468-01-OL, 82-468-1-OL, ISSUANCES-OL, NUDOCS 8309070132
Download: ML20024E846 (4)

Text

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, e, f2 er cs f-31 -E2 UNITED STATES OF AMERICA August 31, 1983 EUCIEAR REGUIATORY COMMISSION B550RE THE ATOMIC SAFETY AND LICENSING BOARD Glenn O. Bright Dr. James H. Carpenter James L. Kelley, Chairman In the Matter of

) Dockets 50-400 OL CAB 0 LINA POWER AND LIGHT CO. et al. ) 50-401 OL (Shearon Harris Nuclear Power Plant, Units 1 and 2) ASLBP No. 82-b68-01 OL

)

MOTION FOR PARTIAL SUMPANY DISPOSITION ON EDDLEMAN CON M TION 80 I. BACKGROUND On May 14, 1982, Wells Eddlenan, pro se, subnitted Eddleman contention 80 on nixing and dispersion nodels for radionuclides.

In its Menorandan and Order (Reflecting Decisions Made Following Prehearing Conference), dated September 22, 1982, the Board adnitted Eddleman contention 80 (see at 62) saying it balleges that the mixing and dispersion models f or radionuclide emissions from Harris are deficient because they . .. do not adequately account for rainout."

Wells Edd1pman now seeks partial summary diseosition on the rainout issue. There is no genuine issue to be heard as to the facts that Eddleman 80 reads in full: "The mixing and dispersion models for radioactive gas, liould and other radiological releases fron SHNPP under 10 CFR part 20 are deficient in that they assume more complete mixing and dispersion of such radionuclides released than will actually take place, take insufficient account of rainout of l such a release plume in a sna11 area (rain precipitating the radio-nuclides in the plume) and thus do not assure that releases comely with 10 CFR 20.106 and the protection of the oublic health and safety, including holding individual doses below 25 ren whole body & thyroid doses below 300 ren in an accident, and below 10-> of those values in normal operation.

B309070132 830831 PDR ADOCK 05000400 PDR 0 . . . _ . _ _ _ .. ._ , ,

Applicants', mixing and dispersion models (which are NRC models) cannot model rainout. Likewise, there is no dispute that rainout can increase nuclide deposition several orders of magnitude (i.e. 100 to 1000 times)3 . There is no dispute that such an increase in the deposition of nuclides would bring Applicants' and Staff's estimates of population dose (calculated per Appendix I) into violation of the limit of 25 mren/ year whole body and 300 mrem / year thyroid to at least one individual in violation of 10 CFR 20.106 and Appendix I.

Taking ER Table 5.2.5-2 '. values for these doses (the NRC computes a higher release of radioiodines, see answer to my interrogatory 27, page 60,6/2h/83), if we multiply the licuid dose by 100 (a value of 2 orders of magnitude, which is small in the range of "several orders of magnitude") it becones 158 nrem/ year whole body. Likewise, the gaseous whole body dose becomes 104 mrem /y' ear (100 x 1.0h) and the maximun dose to any organ becomes 5.2 x 100 or $20 mrem / year.

'IE. ACTION RE GME STED Protection of the public health and safety from radioactive material released by operating nucicar power clants is among the highest of the Nuclear Regulatory Commission's resnonsibilities.

Since the above* cited uncontested facts show that rainout can lead to exposures to radioactive material, and doses to the public, unacceptable under NRC regulations as cited in Eddlenan cor.tention 80, I respectfully request relief as follows:

21 i

Applicants ' response to Eddleman interrogatory 80-2(a ),h-28-83

at pp 31-32

, 3BNL-3391, Diffusion and Denosition in Relation to Reactor l' Safety Problems, Summary and Conclusions at p.16, "The typical rainfall l l

which is relatively li 6ht greatl increases the denosition close to l

the source and usually exkends th is ines of taninet*hSNer rv n we to much greater distances than would be e case i 60bpft Copt1t4aS ON {'O 7 ..

Under authorit? 6 1ven the Board by 10 CFR 2.749, the Board ahould decline to grant an operating license to the Applicants until they heve accurately modeled the effects of plume rainout on radionuclide doses to the public and concentrations allowed under 10 CFR part 20, and shown the doses to the public from radioactive emissions from the Harris plant do not exceed applicable NRC limits (e.g.10 CFw 20.106,10 CFR 50 Anvendix I) when the effect of rainout is accurately included in nodeling of such concentrations, exposures and doses to the public.

Respectfully submitted, 31 August 1983 Wells Eddlenan ANNEX of material facts as to which there is no genuine issue to be heard, is attached herdb.

i I

fgotnote 3 continued:.. .In dry weather, an initial rise of only a few hundred meters may reduce contamination downwind by several orders of magnitude. This rule cannot be anplied during precipitation, and may in fact be reversed because of the more rapid novenent of the debris." BNjL 3391 at 16, Conclusions

. Figures 10,11,12 and 13 (labeled 6,10,11 and 12 in the copy of BNL 3391 I have) dramatically show the very high deposition of radionuclides within 10 kn (6 ni) of a nuclear site due to reinout. These should be contrasted with the figures showing deposition without rainout, see figs 2 and 39 +8 The rainout depositions Eive depositions at 10 kn uniformly about 1000 times as high, as can be seen from the figures.

9 ANNEK to Wells Eddleman's 8-31-83 Motion for partial summary disnosition of Eddleman 80 re rainout.

Material facts as to which there is no genuine issue to be heard:

1. Applicants' (NRC) models of radionuclide mixing and dispersion (XOQD0Q and RG 1.145) cannot account for rainout.

2. Rainout significantly increases denosition of radionuclides, up to several orders of magnitude.

3

"'several orders of magnitude" neans at least 100 times.

4 Apnlicants dose estimates, corrected for rainout10, per 11,the& 13) summary of BNL 3391 (p.16)(see fig. 0L thereof, and rigs exceed applicable NRC linits, including Appendix I and the limits cited for normal operation in Eddleman 80.

5. Applicants ' models for radionuclide airborne disrersion are NRC's XOQD0Q and RG 1.145 radiation

6. Populationfgdoses in excess of NFC rules should certainly not be allowed.

7 Figures 10,11,12 and 13 of DNL 3391 showing denosition of nuclides with rainout, are generally 1000 times higher in denosition showan, than the deposition without rainout shown in Figs 2,3,7 and 8 thereof.

8. 1000 is nore than 100.

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