ML20031D695
| ML20031D695 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 10/09/1981 |
| From: | Gotchy R Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20031D662 | List: |
| References | |
| NUDOCS 8110140018 | |
| Download: ML20031D695 (7) | |
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> e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE AT0;ilC SAFETY AND LICENSING BOARD In the Matter of '
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HOUSTON LIGHTING & POWER COMPANY
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Docket No. 50-466
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(Allens Creek Nuclear Generating
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Station, Unit 1)
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NRC STAFF TESTIM 0riY OF DR. REGINALD L. GOTCHY CONCERNING THE POTENTIAL PUBLIC HEALTH IMPACTS OF 0F RN-222 RELEASES RESULTING FROM URANIUM MINING AND MILLING Q2 What is your name and position with the NRC?
A.
My name is Reginald L. Gotchy.
I am employed at the Nuclear Regulatory Commission as c Senior Radiobiologist in the Radiological Assessment Branch.
A statement of my professional qualifications was previously furnished with my testimony on Radioactivity in the Cooling Lake (Tr. 3242).
l Q.
What is the purp0se of this testimony?
A.
The purpose of this testimony is to respond to the Licensing Board's request (Tr.17,178 to 17,189) for the latest Staff information on the potential public health impacts of Rn-222 releases resulting from uranium mining and milling operations in order that the doard may make its findings on this matter as required by the National Environmental Policy Act.
Generally, the Board has requested the Staff to update the Rn-222 infor-mation presented in the Allens Creek FSFES (Staff Ex.12) which was prepared in 1978.
81'10140018 811009' PDR ADOCK 05000466 T
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Q.
Initially, the Board noted what appeared to be an arror on page S.5-34 of the FSFES (Tr.17,185) relating to a radon source term release value for mining of 400 curies.
Is the Board correct in this observation?
A.
Yes. There is an error in the table at the bottom of page S.5-34 of the FSFES which gives a value of 400 curies of radon from mining operations.
Although, the values in the first table were 4,060 curies from mining and 1,130 curies from milling, the values in the second table were intended to have been rounded to two significant figures: 4,100 (not 400) and 1,100 curies, respectively. UnQrtunately, the typographical error was not corrected before publication of the FSFES.
Q.
The Board has also questioned whether there are any :
errors contained in Paragraph E of Section S.5.5 (Uranium Fuel Cycle Impacts) of the FSFES. What are your comments?
A.
Paragraph E is the Staff's assessment of radioactive effluents estimated to be released from the uranium fuel cycle and their corresponding environmental dose comitments. The dose commitments were based on radio-active effluent values set forth in Table S-3, except for the value of Rn-222.
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l The remainder of Paragraph E is the Staff's assessment of the radiological I
l impacts associated with radon-222 releases. This information is out-of-date l
and contains several typorgraphical errors. Accordingly, I am providing the Board with my latest impact to NRC environmental statements concerning redon l
l as Attachment 1 to this testimony.
it should be noted, however, that the Atomic Safety and Licensing Appeal Board is still considering the question of potential public health impacts of Rn-222.
(See ALAB-654, Sept.11,1981).
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f Accordingly, final updating of the Staff's health effects assessment should await th'e' outcome of the Appeal Board's consideration.
Q.
Recognizing that the Commission has not adopted a fir,a1 rule with respect to a Rn-222 value to be includad in Table S-3, is it possible to show the Staff's updated assessmert of the potential health impacts associated with Rn-222 releases and i..mpare these impacts to those presented in the FSFES?
A.
Yes.
First, I would note that the Rn-222 data and resulting esti-mates of potential health impacts set fortF in the FSFES appear to be based on the testimony of Staff witnesses in the St. Lucie proceeding (Docket No. 50-389) in February 1978.
(See FSFES references 30, 31, 32 on p. S.5-40. )
The St. Lucie testimony is the same testimcny presented by the Staff in the Perkins proceeding.
Except for the errors noted above, the FSFES Rn-222 analysis reflects the same evaluation that the Staff presented in the Perkirs proceeding. Accordingly, the starting point of the following updated Rn-222 evaluation will be the Staff testimony in the Perkins proceeding (dated January 25,1978) which was the " lead case" adopted by the Appeal Board in its pending proceedings.
Q.
What are the sources of the more recent information that the Staff has used to update its radon analysis?
A.
More recent information concerning the releases of Rn-222 from mining and milling operations is contained in NUREG-0706 (Final Generic Environmental Impact Statement on Uranium tiilling, Sept.1980), and
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NUREG-0757 (Radon Releases from Uranium Mising and Milling and Their Cal-culated Eealth Effects, February 1981). More recent infomation concerning potential health effects estinctes is set forth in NUREG-0757 and the BEIR III Report (The Effects on Populations of Exposure to Low Levels of Ionizing Radiation:
1980).
Q.
Based on the record before it, including Staff testimony reflecting i
the above-listed recent information, the Appeal Board recently issued a decision on radon soura terms (ALAB-640,13 NRC (May 13,1981)). Can the radon source terms as decided by the Appeal Board be compared to the Perkins Staff testimony and more recent Staff infomation on redoni A.
Yes. Such a comparison is provided in the attached Table 1.
Table 1 provides a more detailed breakdown for the Rn-222 release values, population dose comitments, and poten.ial health impacts with specific referencer for all data.
Q.
What is the current Staff position with respect to Rn-222 release values to be considered by the Comission in its determination of a revised source term for Rn-222 in Table S-37 A.
The NRC Staff has concluded that the Rn-222 source terms reflected in NUREG-0757 represent the best estimates based on current infomation and has proposed them to be included in the revised Tab e S-3.
The Staff has recognized the differences between NUREG-0757 and ALAB-640, but has con-cluded that there are no substantive differences between the most probable releases in ALAB-640 (Case 1) and NUREG-0757.
I would only note that
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J the major difference between the release estimates of ALAB-640 and NUREG-0757 rests on the assumption that it will take 271 MT U 03 8 (in uranium ore) per RRY for the former (based on NUREG-0002, GESMO), and the more recent Staff I
estimate of 201 MT U 0 used in NUREG-0757. Accordingly, the ALAB-640 values 38 are 35% higher per RRY than the values in NUREG-0757.
Q.
Based on this more recent information, what is your conclusion with respect to the FSFES analysis and conclusion on the impact of Rn-2227 A.
Table 1 indicates that the FSFES health effects estimates (which are I
based on Staff testimony presented in Perkins) are indeed conservative esti-mates for the impact of Rn-222 when compared with the latest estimates.
Therefore, since the health effects estimates in the FSFES did not affect the cost / benefit balance for ACNGS, the latest estimates make the cost / benefit conjarisons even more favorable than before.
Q.
Finally, the Board has requested data regarding natural radon-222 releases and dose cormitments from natural radioactivity (Tr.17,188). Do you have this data and what do you conclude from that data?
A.
In resoonse to the Board's request for data regarding natural radon-222 releases and dose comitments from natural radioactivity, I con-clude the following:
i a.
The natural radon-222 releases to the atmosphere in the con-tiguous U.S. is about 120-million curies per year, while technological en-hancement (tilling the soil, use of phosphate fertilizers, phosphate mining, coal nining, etc.) releases an additional 3.3-million curies per year to the atmosphere in the U.S. (
Reference:
C. C. Trains, et al., "A Radiological Assessment of Radon-222 Released from Uranium Mills and other Natural and Technologically Enhanced Sources," NUREG/CR-0573, U.S. NRC, Feb. 1979, pp. 106 and 202).
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The average annual individual radiation doses (mrem /yr)*
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resulting'from naturally occurring radioactivity are as follows:
Bror chial Epithelium Cells Lin>.vg Tota 1_ Body (Luna) the Bone External Radiation 63 63 63 Internal Radiation K-40 15 17 15 i
Rn-222+D 8
1,650**
37 I
others 3
s60 38 Totals:
89 si,800 150 l
c.
Comparing the average doses in the U.S. per RRY (Values from NUREG ^757 divided by 300-million population), I conclude the following:
(1) The average dose per year per person per RRY is greater l
over the first 100 years than over the first 1,000 years by about a factor of 2 (i.e.; the people who derive the greatest benefit also receive the highest radiation exposure).
(2) The fractional increase in the dose from natural background radiation per RRY due to Rn-222 is as follows:
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Total Body:
(1.1 - 2.5) 10 Lung:
(0.56 - 1.2) 10-8 Bone:
(0.93 - 2.1) 10-7 Assumes a quality factor of 10 for alpha particles. Reference Tables 30 and 31, UNSCEAR Report (1977), pp. 80 and 81.
Including indoor air and outdoor exposures to Rn-222 and progeny in air.
-8 For example:
68 person-ren/100 years /RRY
= 2
- 5 x 10 /RRY 300-million persons x 0.089 rem / year
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, 0 (3) The average increases in dose per RRY over natural back-ground are il relative to annual natural background as to be insignifica.
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