ML20037D695
| ML20037D695 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 08/24/1981 |
| From: | Gotchy R Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20037D694 | List: |
| References | |
| NUDOCS 8108310102 | |
| Download: ML20037D695 (8) | |
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UNITED STATES OF AMERICA NUCLE!,R REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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Decket Nos. 50-387
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50-388 PENNSYLVANIA POWER AND LIGHT CO.
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ALLEGEHENY ELECTRIC COOPERATIVE, INC.
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(Susquehanna Steam Electric Station,
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Units 1 and 2)
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AFFIDAVIT OF REGINALD L. GOTCHY I, Reginald L. Gotchy, being duly sworn, depose and state:
1.
I am employed by the U.S. Nuclear Regulatory Commission as a Senior Radiobiologist in the Division of Systems Integration, Office of Nucl ear Reactor Regulation. A copy of my statement of professional qualifications is attached.
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In this position I am responsible for assessing the environmental impacts of nuclear facilities and alternative fuel cycle facilities.
2.
I have read the Applicant's Motion for Summary Disposition of Contention 1 and the Affidavit of Dr. Morton I. Goldman which accompanies and supports the Motion.
Radon-222 Releases Per RRY
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3.
With respect to Radon-222 release portion of Contention 1 I view the Applicant's request as appropriate and based on the record of the Atomic Safety and Licensing Appeal Board decision of May 13,1981 (Peach Bottom proceeding, ALAB-640) which accepted detailed testimony on Radon-222 releases by Dr. Goldman.
The relatively minor differences in the release estimatss by Dr. Goldman in his supporting affidavit and ALAB-640 release estimates are due to slightly different assumptions regarding such things as average ore grade and projected ore recovery methods, and considering the uncertainties, do not substantially conflict with the Appeal Board decision (ALAB-640) regarding Radon releases per RRY.
I, therefore, support the Applicant's request for summary disposition of the Rn-222 release estimates.
W 8108310102 81082f PDR ADOCK 05000387 O
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Radiological Impact of Radon-222 Releases 4.
I have also reviewed the Applicant's request for summary disposition of the Radon-222 health effects issue and the supporting affidavit of Dr. Goldmac.
I fully agree that the Radon-222 population doses from the radon releases per RRY are ins 1gnificant relative to the same type of doses from other sources of naturally occurring radon-222, and that the radon-222 releases resulting from operation of the Susquehanna facility would be undetectable, and further that.the impact on the health and safety of the public would be insignificant.
5.
However, I feel this approach, while true, does not completely ventilate the question of potential health impacts per RRY.
That is why the staff presented a brief assessment of the potential health imoacts per RRY in the DES for the Susquehanna facility (pp. 4-33 through 4-34).
Therefore, I wish to support the Applicant's request for summary disposition by providing additional discussion of the potee.iial incremental increases in health effects due to the radon releases which were estimated by the Appeal Board in ALAB-640.
6.
I presented testimony on the health effects of Radon-222 in the Perkins pro-ceeding)(Duke Power Co.,1978).
In my testimony, I concluded that the potential health impacts (assuming the wor'd and the American people remain essentially the same as they are today) would be on the order of 0.11 to 1.2 cancer deaths and 0.036 to 0.40 genetic effects per RRY over periods ranging from 100 to 1,000 years into a dim and uncertain future. Since, the Perkins hearing, new estimates of collective population doses per curie (C1) of radon-222 and the potential cancer and genetic risks have been developed by the Staff based on the most recent information available.* NUREG-0757 has summarized all of the pertinent changes since the Perkins hearing except the estimates of health effects per million person-rem, which, using the 1980 estimates of the Committee on the Biological Effects of Ionizing Radiation, can now also be updated.
7.
Table 1 summarizes the major changes since the Perkins hearing. The potential health effects estimates in the Perkins record have not been substantially changed by subsequent events.
They represent a reasonably conservative estimate of the risks over reasonable periods of time and are not substantially different from estimates derived from NUREG-0757.
8.
The fact that less than one potential cancer or serious genetic effect is pre-dicted to occur among a constant population of 300-million people for each RRY is a clear indication that the impacts of Radon-222 are de ninimus and unworthy of further. serious consideration.
Furthermore, recent advancesln the treatment
- aFinal Generic Envirornental Impact Statement en Uranium Milling, NUREG-0706 (September,1980).
b adon Releases from Uranium Mining and Milling and their calculated Health Effects R
NUREG-0757, (February,1981).
cThe Effects on Populations of Exposure to Low Levels of Ionizing Radiation,1980, Science (BEIR I I Report-1980)the Biological Effects of Ionizing Radiation of National Academ Committee on
and prevention of cancer suggest that the impacts per RRY are likely to be even smaller than the most current estimates in Table 1.
9.
Given that the potential health effects of Radon-222 have been shown to be de;minimus, I fully support the Applicant's Motion Summary Disposition on Contention 1.
- 10. The statements given above are true and correct to the best of my knowledge.
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(A nW /v664 RefifIldL.Gotchy AugustJ/
1981
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flotary Afy Commission Expires October 1+,1983 7-**
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Ta bl e 1.
Update of the Potential Health Impacts of Radon-222 Releases From Uranium Mining and Milling Per RRY
.I Based on the Based on Current Estimates Perkins Record NUREG-0757 Based on BEIR III Source Term (Ci) a.100-yr Environmental Dose 5,300 6,800 Same Commitment
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- b. 1.000-yr Environmental Dose 59,000 31,000 Same Commitment Population Doses (Person-rem) a.100-yr Environmental Dose Commitment Total Body 140 58 Same Lung
- 3,000 670 Bone 3,600 920 b.1,000-yr Environmental 1
Dose Commitment Total Body 1,500 31 0 Lung 33,000 3,100 i
Bone 41,000 4,200 Potential Health Impacts a.100-yr Environmental Dose Commitment Cancer Mortality 0.11 0.06 0.08 Genetic Effects **
0.036 0.02***
0.02 b.1.000-yr Environmental Dose Commitment
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Cancer Mortality 1.2 0.3 0.4 Genetic Effects 0.4 0.08***
0.07
- Bronchial epithelium l
- All serious defects over next 5 generations.
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- Genetic effects were incorrectly based on total-body equivalent dose, as shown, it is j
corrected for total body dose only.
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h DR. R. L. GOTCHY Professional Qualifications My name is Reginald L. Gotchy.
I am a Senior Radiobiologist on assignment with the Radiological Assessment Branch in the Office of Nuclear Reactor Regulation.
In this capacity, I am responsible for coordinating the technical review and evaluation of the environmental radiological impact of nuclear facility operations.
I received a B.S. in Zoology from the University of Washington in 1958, an M.S. in Radiation Health from the Colorado State University in 1966, a Ph.D. in Radiation Biology from the Colorado State University in 1968, and attended the University of Washington Graduate School 1958-l%3 as an AEC Radiological Physics Fellow.
S I have 19 years of professional experience in health physics, industrial hygiene, radiation physics, radiation biology, environmental sciences, project coordination of research and development programs, and development of AEC and NRC standards. This experience has included operational and ufety responsibilitiet, and review and coordination of facility operations under contract to the AEC.~ I have been employed by the Lawrence Radiation Laboratory, the U.S. Public Health Service, Reynolds and Electrical Engineering Company, the AEC Nevada Operations Office, and the NRC Office of Standards Development prior to my assignment in the Office of Nuclear Reactor Regulation in 1975.
I was' an adjunct professor of Radiation Health Technology at the University of Nevada, Las Vegas (1969-1972).
I am a member of Sigma Xi (Research Society of North America), the American Nuclear Society, the Health Physics Society and the International Radiation Protection Association, and the Radiation Research Society.
I am a past member of the American Association for the Advancement of Science and the American Industrial Hygiene Association.
I am certified by the American Board of Health Physics, and served as a member of the Panel of Examiners (1972-1976).
I remain active in the development of examination questions and updating my professional standing by periodic post-graduate work and training.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE TH,E ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
PENNSYLVANIA POWER AND LIGHT CO.
Docket Nos. 50-387 ALLEGHENY ELECTRIC COOPERATIVE, INC.
)
50-388
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(Susquehanna Steam Electric Station,
)
Units 1 and 2)
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NOTICE OF APPEARANCE Notice is hereby given that the undersigned attorney herewith enters an appearance la the captioned matter.
In accordance with 12.713(a),10 C.F.R. Part 2, the following information is provided:
Name Lucinda low Swartz Address U.S. Nuclear Regulatory Commission Office of the Executive Legal Director Washirigton, D. C.
20555 Telephone Number Area Code 301-492-7519 Admissions
-- District of Columbia Court of Appealsf'
-- Court of Appeals of Maryland
-- United States District Court for the District of Columbia i
-- United States Court of Appeals for the District of Columbia Circuit Name of Party NRC Staff U.S. Nuclear Regulatory Commission i
Washington, D. C.
20555 AJ/Nhf? U 0
h Lucinda low Swartz Counsel for NRC Staff Dated at Bethesda, Maryland this 27th day of August,1981
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UNITED STATES OF AMERICA NUCLEAR REGULATORY C0!tilSSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of PENNSYLVANIA POWER AND LIGHT.CO.
Docket Nos. 50-387 ALLEGHENY ELECTRIC COOPERATIVE, INC.
50-388 (Susquehanna Steam Electric Station, Units 1 and 2)
.'l CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF RESPONSE SUPPORTING APPLICANTS' MOTION FOR
SUMMARY
DISPOSITION OF CONTENTION 1 (Radon)", " AFFIDAVIT OF REGINALD L. GOTCHY" and " NOTICE OF APPEARANCE" dated August 27,1981, in the above-captioned proceeding have been served on the following by deposit in the United States mail, or as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 27th day of August,1981:
James P. Gleason, Cnairman Dr. Judith H. Johnsrud Administrative Judge Co-Director 513 Gilmoure Drive Environmental Coalition on Silver Spring, Maryland 20901 Nuclear Power 433 Orlando Avenue
- Nr. Glenn 0. Bright State College, Pennsylvania 16801
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Administrative Judge Atomic Safety and Licensing Board Mr. Thomas M. Gerusky, Director U.S. Nuclear Reguletcry Cc=ission Bureau of Radiation Protection Washington, D. C.
20555 Department of Environmental Resources Commonwealth of Pennsylvania i
Dr. Paul W. Purdom P. O. Box 2063 Administrative Judge Harrisburg, Pennsylvania 17120 l
245 Gulph Hills Road Radnor, Pennsylvania 19087 Ms. Colleen Marsh Box 538A, RD#4 Mountain Top, Pennsylvania 17120 Mr. Thomas J. Halligan Jay Silberg. Esq.
Shaw, Pittthan, Potts and Trowbridge Correspondent:
CAND 1800 M Str@t, N.W.
P. O. Box 5 Washington? D.C.
20036 Scranton, Pennsylvania 18501 l
Bryan A. Snapp, Esq.
Pennsylvania Power & Light Company i
Two North Ninth Street Allentown, Pennsylvania 18101 l
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- Richard S. Salzman, Esq., Chairman, Susquehanna Environmental Administrative Judge Advocates Atomic Safety and Licensing Appeal Board c/o Gerald Schultz, Esq.
U.S. Nuclear Regulatory Commission P.O. Box 1560 Washington, D.C.
20555.....
Wilkes-Barre, PA 18703
- Dr;. John H. Buck, Administrative Judge Mr. Robert M. Gallo Atomic-Safety and Licensing Appeal Board Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 52 Washington, D.C.
20555 Shickshinny, Pennsylvania 1G655
- Hr. Thomas S. Moore, Administrative Judge Robert W. Adler Atomic Safety and Licensing Appeal Board Dept. of Environmental Resources U.S. Nuclear Regulatory CoAmission 505 Executive House Washington, D.C.
20555 P.O. Box 2357
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Harrisburg, Pennsylvania 17120
- Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory C'mmission Mr. DeWitt C. Smith, Director Washington, D.C.
20555 Pennsylvania Emergency Management' Agency Transportation and Safety Building
- Atomic Safety & Licensing Appeal Board Harrisburg, Pennsylvania 17120.
Panel U.S. Nuclear Regulatory Commis'eion Washington, D.C.
20555
- Secretary i
U.S. Huclear Regulatory Commission ATTH: Chief, Docketing & Service Branch Washington, D.C.
20555
$(6end N d n ?'
Lucinda Low Swartz c17 Counsel for NRC Staff b
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