ML20030D035

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Statement of Matl Facts as to Which No Geniune Issue Exists Re Contention 2 on Radioactive Doses.Certificate of Svc Encl.Related Correspondence
ML20030D035
Person / Time
Site: Susquehanna  Talen Energy icon.png
Issue date: 08/25/1981
From: Silberg J
ALLEGHENY ELECTRIC COOPERATIVE, INC., PENNSYLVANIA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:
Atomic Safety and Licensing Board Panel
References
NUDOCS 8108310328
Download: ML20030D035 (10)


Text

August 25, 1981 6

1 ELATED CORESPONDENCH

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UNITED STATES OF AMERICA Sh

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NUCLEAR REGULATORY COMMISSION d

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C=.L : L uu.a UO In the Matter of g

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PENNSYLVANIA POWER & LIGHT COMPANY

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Docket Nos. 50-387

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50-388 ALLEGHENY ELECTRIC COOPERATIVE, INC.

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(Susquehanna Steam Electric Station,

)

Units 1 and 2)

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APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD (CCNTENTION 2) (RADIOACTIVE DCSES)

Pursuant to 10 C.F.R. 5 2.749(a) Applicants state, in support of their Motion for Partial Summary Disposition of Contention 2 (Radioactive Doses) in this proceeding, that there is no genuine issue to be heard with respect to the following I

material facts:

l 1.

A set of pathways and internal dosimetry models was developed for the NRC Staff ("the Staf f") by Battelle Pacific Northwest Laboratories in the mid 1970's; these models are used for the pre-operational prediction of ' the dispersion of radioactive effluents from nuclear power plants into the atmosphere and water bodies, their transport to man through various exposure pathways, and the resulting radiation doses.

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8108310328 810825 PDR ADOCK 05000387 0

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Affidavit of Frazier L. Bronson in Support of Partial Summary Disposition of Contention 2 (Radioactive Doses) ("Bronson Aff."), para. 3.

2.

The pathways and internal dosimetry models developed for the Staff are described in Regulatory Guide 1.109, and have been put in the form of computer codes widely used by the nuclear industry.

The Staff regards these models and codes as acceptable for calculating the radiological impact of plant operation on individuals and populations and determin-ing compliance with Appendix I to 10 C.F.R. Part 50, and recommends their use by license applicants.

Id., para. 3.

3.

The radiation doses attributable to the releases from the Susquehanna Steen Electric Station ("Susquehanna")

were estimated utilizing the methods and assumptions in Regulatory Guide 1.109 and using two of the computer codes developed for the Staff, "GASPAR" and "LADTAP".

Id., paras.

3, 5, 15.

Doses from Gaseous Pathways 4.

There are several exposure pathways to man l

resulting from atmospheric release of' radionuclides.

Some of them result in external exposures: submersion in air and exposure to radionuclides deposited on the ground., other pathways result in internal doses: inhalation of radionuclides, or ingestion of radionuclides deposited in water, crops or vegetation.

Radionuclides reach crops and vegetation through direct deposition and through root uptake.

Man is exposed by

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eating such crops or vegetation, or by consuming milk and meat products from animals who have eaten such crops or vegetation.

Id., para.

4.

5.

Tne annual radiation doses resulting from the calculated radioactive gases and/or particulate releases from Susquehanna were estimated for individuals at distances up to 50 miles from the plant site and for the population in the contiguous 48 States utilizing the GASPAR computer code, which assumes as sources a semi-infinite cloud that originates from an elevated stack, and another source located at ground level, both emanating continuously for a period of one year.

Id.,

para. 5.

6.

The GASPAR code computes lung and skin doses due to inhalation and direct radiation from radioactive gases.

Id., para.

6.

7.

For particulate radioactive materials, the code calculates doses to six critical organs (bone, liver, thyroid, kidney, lung and gastro-intestinal tract) and whole-body doses.

d Ic., paras. 7, 9-12.

8.

Because of the deposition of particulate radioac-tive material on the ground, a ground plane source is assumed by the code to be created and to contribute a dose to each organ.

Id.,

para.

8.

9.

The code computes the doses to infants, children, teenagers and adults from immersion in the radioactive cloud and from standing on contaminated soil, and the ingestion dose -. _.

from vegetation contaminated by deposition.

The ingestion dose to people is the sum of that produced directly by the con-sumption of vegetables and that resulting indirectly from consumption of milk and meat from animals grazing on contami-nated pastures.

Id., paras. 7, 13.

10.

The computed doses obtained from the GASPAR code utilizing input parameters applicable to Susquehanna are set forth ir. Table 5.2-26 of the Susquehanna Environmental Report

("ER") and represent conservatively high estimatos of the radioactive doses that will be received by members of the public due to gaseous releases from the Susquehanna facility.

i Id.,

paras. 13, 14.

Doses From Liquid Pathways 11.

Another of the above referenced computer codes developed for the Staff, LADTAP, was usec to calculate the annual radioactive doses to individuals from releasas of radionuclides from Susquehanna to waterways, and specifically to the Susquehanna River.

Id.,

para. 15.

12.

The following are the principal liquid pathways l

l through which radioactive doses may be received by individuals l

l outside the plant: (1) drinking water; (2) aquatic foods; (3) exposure from deposition at the shoreline; (4) exposure from swimming or boating; and (5) irrigation of crops.

Each of these potential pathways is included in the LADTAP model.

Id.,

paras. 16, 18, 19, 21.

The dose to an individual from any of these pathways is modified by several factors, all of which are recognized and incorporated into LADTAP.

Id.,

para. 17.

l 13.

Dilution of radioactive materials in the waterway is based on accepted dilution models set forth in Regulatory Guide 1.113, which discusses in detail the equations used for dilution and dispersion in the river, as well as water use factors that affect dilution or mixing and sediment uptake and transport.

Id.,

paras. 20, 21.

14.

Doses were calculated for infant, child, teenager, and adult for each nuclide, in the same six organs plus whole-body doses considered for gaseous releases.

Id.,

para. 21.

15.

The computed doses obtained from the LADTAP code utilizing input parameters applicable to Susquehanna are set forth in Table 5.2-24 of the Susquehanna ER, and represent conservatively high estimates of the radioactive doses that will be received by members of the public due to liquid releases from the Susquehanna facility.

Id., paras. 21, 22.

Doses From All Pathways 16.

Tables 5.2-33 through 5.2-35 of the Susquehanna ER summarize the calculated combined population doses within a 50 mile radius of the Susquehanna facility and to the pop-ulation in tha contiguous 48 States as a result of gaseous and liquid effluents from Susquehanna.

The dose estimates set forth in those tables are conservatively high.

Id., para. 23.

17.

The population dose estimates contained in the so-called "Heidelberg Report" are erroneous and grossly overstate the doses that will be produced by the radioactive 1

effluents from a facility such as Susquehanna.

Id., para. 23, n.5.

Doses From Cesium-137 and Cobalt-60 in Drinking Water 18.

The radioactive doses associated with the release of cesium-137 and cobalt-60 by Susquehanna into the Susquehanna River were computed utilizing the LADTAP program and making very conservative (on the high side) assumptions as to site-specific parameters.

The computation was based on a concentration of 3.9 x 10-3 pCi/ liter of cesium-137 and 1.5 x 10-3 pCi/ liter of cobalt-60 at the Danville intake structure.

Id., para. 24.

19.

The computed dose to a Danville resident from cesium-137 in drinking water releases from Susquehanna is 2.03 x 10-4 mrem / year.

Id., para. 26.

The dose for cobalt-60 is

-4 2.07 x 10 mrem / year.

Id., para. 27.

20.

The total combined dose to each resident of Danville attributable to casium-137 and cobalt-60 in his

-4 drinking water is 4.1 x 10 mrem / year.

This value represents a conservatively high estimate of the radioactive doses to the I. - _ _

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Danville residents from releases of those radionuclides with the liquid effluents from Susquehanna.

Id.,

para. 28.

Dated:

August 25, 1981.

Respectfully submitted, SHAW, PITTMAN, PCTTS & TROWBRIDGE By M

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Jay))

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Mati% q. Travieso-Diad Counsel for Applicants 1800 M Street, N. W.

Washington, D.

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20036 Telephone:

(202) 822-1000 _

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION g

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD; AUG 2 71981 >

C"adNLOCOffkl Uh C;&'. a L EIN3 In the Matter of

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'd PENNSYLVANIA POWER & LIGHT COMPANY

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Docket Nos. 50-387

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50-388 ALLEGHENY ELECTRIC COOPERATIVE, INC.

)

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(Susquehanna Steam Electric Station,

)

Units 1 and 2)

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l CERTIFICATE OF SERVICE This is to certify that copies of the foregoing " Applicants' Motion for Partial Summary Disposition of Contention 2 (Radioactive Doses)", " Applicants' Statement of Material Facts As To Which There Is No Genuine Issue To Be Heard (Contention 2) (Radioactive Doses) ",

and " Affidavit of Frazier L. Bronson in support of Partial Summary Disposition of Contention 2 (Radioactive Doses)", were served by deposit in the U. S. Mail First Class, postage prepaid, this 25th day of August, 1981 to all those on the attached Service List.

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Dated:

August 25, 1981.

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

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I

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PENNSYLVANIA POWER & LIGHT COMPANY

)

)

AND

)

Docket Nos. 50-387

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50-388 ALLEGHENY ELECTRIC COOPERATIVE, INC.

)

)

(Susquehanna Steam Electric St' tion,

)

a Units 1 and 2)

)

q SERVICE LIST Secretary of the Commission Dr. Judith E. Johnsrud T.

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

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Silver Spring, Maryland 20901 Susquehanna Environmental Advocates yr. Glenn O.

Bright c/o Gerald Schultz, Esquire Atomic Safety and Licensing Post Office Box 1560 Board Panel Wilkes-Barre, Pennsylvania 18703 T.

S. Nuclear Regulatory Commission ashington, D.

C.

20555 Mr. Thomas J.

Halligan, Correspondent The Citizens Against Nuclear Dangers Ir. Paul if Purdom Post Office' Box 5 245 Gulph Hills Road Scranton, Pennsylvania 18501 Radner, Pennsylvania 19087 Ms. Colleen Marsh l A:cmic Safety and Licensing Box 558 A, R.

D..# 4 l

Board Panel Mt. Top, Pennsylvania 18707 T.

S. Nuclear Regulatory Commission Washingron, D.

C.

20555 Jessica H.

Laverty, Esquire Office of the Executive Legal Director

':ocketing and Service Section U.

S. Nuclear Regulatory Commission

-"# ice of the Secretary S. Nuclear igulatory Commission Washa.ngton, D.

C.

205mo ashington, D.

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20555 l

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  • Robert W.-Adler, Esquire Mr. Thomas M.

Gerusky, Director Zepartment of Environmental Resources Bureau of Radiation Protection ccmonwealth of Pennsylvania Department of Environmental 505 Executive House Resources Post Office Sox 2357 Commonwealth of Pennsylvania Earrisburg, Pennsylvania 17120 Post Office Box 2063 Janes ". Curchin, IV, Esquire Office of the Executive Legal Atomic Safety and Licensing Appeal Director Board Panel C.

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Nuclea'- Regulatory Commission U.

S.

Nuclear Regulatory Cor:=tissio:

Wcshington, D.

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2'0555 Washington, D.

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20555 CoWitt C.

Smith Director Pennsylvania Emergency Management Agency Trcnsportation and Safety Building Earrisburg,' Pennsylvania 17120 O

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