ML20050C678
| ML20050C678 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 04/04/1982 |
| From: | Lochstet W PENNSYLVANIA STATE UNIV., UNIVERSITY PARK, PA |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0537, RTR-NUREG-537 NUDOCS 8204090244 | |
| Download: ML20050C678 (7) | |
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.T H E P ENNS YLVANI A S T ATE U NIV ERSITY
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104 DAVEY LAllORATORY UNIVLR$1TY PARK, Pl.NNSYl VANI A IM02
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Director, Division of Licensing L
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Dear Director:
j t 't Enclosed are my comvents on the Draft Environmental Statement
'related to the onoration of the Midland Plant Units 1 and 2, i
j N'JREG-0537. Please note that the oninions and calculations i
do not necessarily reflect the position of the Pennsylvania State' University.
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I will be looking forward to the Final Environmental Statement.
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Would you also nleane send me a copy of that Final EIS when it 1
is available.
Sincerely,
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En. A. Lochstet, Ph.D.
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i 8004090244 820404 PDR ADOCK 05000329 D
PDR AN t OVAL OPPOR TUNIT Y UNIVLRSITY
Some Health Consequences of the Midland Plant by William A. Lochstet, Ph.D.
The Pennsylvania State University
- April 1982 The Nuclear Regulatory Commission (NRC) has attempted to evaluate the health consecuences of the operation of the Midland nuclear power plants in the Draft Environmental Statement, ITUREG-0537 (Ref.1). The health consequences of the radon-222 released from the mill tailings and mines needed to fuel the nlant, are evaluated for the first 1000 years in Appendix G. This evalm tion states that the radon emissions increase with time ( Page G-6, Ref.1), and there is no suggestion that there is any reason to believe that these emissions will stop after 1000 years, or even to decrease.
In fa ct, these radon emissions are governed by the 80,000 year hal f life of the thol.um and the 4.5 billion i
year half life of the uranium-238 in the mill tailings, and the amount of material covering the tailings. The thorium situation has been adecuately discussed by Pohl (Ref. 2) in 1976 The imract of the uranium-238 as a source of radon was recognized by the NRC in GESMO ( Ref. 3), which is one of the references of Appendix G of this Draft Report (Ref. 1).
Annendix G of thh Draft ( Ref. 1) is written on the presumption of a 1000-MUe LUR plant operated at an 80%
ca pa city fa ctSt ( Pare G-2). This will reouire about 29 metric tone of reactor fuel.
With uranium enrichment plants orarating at a 0.2% tails assay,146 metric tons of natural uranium will be Affiliation for identification nurroses only
Midland 2
April 1982 required, and 117 metric tons of depleted uranium will be left over.
L'ith a uranium mill which extracts 96% of the uranium from the ore, a total of 00,000 metric tons of ore is mined, containing 152 metric tons of uranium ( Ref. 4). The uranium mill tailings will contain 2.6 kilograms of thorium-230 and 6 metric tons of uranium.
As Pohl has rointed out ( Ref. 2), the thorium decays to radium-226, which in turn decays to radon-222 This 8
process results in the generation of 3.9 x 10 curies of radon-222, on a time scald determined by the 8 x 10b year half life of thoriun -
230.
The 6 metric tons of uranium contained in the mill tailings decay by severalsteps thru thorium-230 to radon-222. This process occura on a time scale govorned by the 4.5 x 109 year half life of uranium-238, the major isotore present (99.3%).
The total amount of radon-222 which will result from this decay is 8.6 x 1011 curies.
The 117 metric tons of depleted uranium from the enrichment process is also mainly uranium-238 which also decays. The 13 decay of thene enrichment tails results in a total of 1.7 x 10 curies of radon-222. The impact of these decays were listed by the NRC in GESf'O ( flef. 3 ).
The nonulation at risk is taken to be a stabilized USA at its present level and present distribution. This is similar to that taken in the Draft ( Pare G-4, Ref.1). The NRC has succested that a rel ea se o f 4,800 curies d' radon-222 from the mines would resul t in 0.023 excess deaths ( Ref. 5). This provides a ra tio of 4.8 x 10-6 deaths per curie.
At present some recent uranium mill tailings niles bave two feet of dirt covering. In this case, the EPA estimate ( Ref.4) is that about 1/20 of the radon Produced escanes into the air.
N Thus, 6f the 3.9 x 10 curies of radon from the thoriun in the 7
mill tailings only 1.9 x 10 curies will ret into the air.
1.th the estimate of 4.F x 10-0 deaths per curie, results in a total of 90 deaths.
Midland 3
April 1992 11 The F.6 x 10 curies of radon produced by the uranium in the mill tailings td1] similarly have 1/20 esc 9ne to the air, vith the same method as used above the result is 200,000 deaths.
The uranium enrichment tailings are presently located in the eastern part of the USA.
If these are buried near their present location it is taken that 1/100 will edcape due to the hirher roisture,f the soil.
An additional reduction of 2 is taken to account for the more eastern location, and the rewer peonle downwind, to the east of the sites. With the URC esti ate of 4.8 x 10 6 deaths per curie, the result is 600,000 deaths.
The NRC estinate of about 2 deaths in the Draft (Ref. 1) in thus more than 100,000 too lou compared to the sun of 600,0C0 as shown above. This is due largely to the arbitrary, erronious, immoral, incorrect procedure of stonning at the end of the first 1000 years.
The fa c t that these doses and death rates are less than backcround is interesting ( Re f.1, Page G-6), but absolutely irrelevant.
The major federal action to be considered by the NRC is not whether or not to license background radiation, but whether or not to license the Fidland nlants.
Rebaselining:
The NRC ban attempted to evaluate the impact of " Class 9" accidents which night occur at IIidland. Unfortunately, the few pares of this report ( Ref. 1) devoted to this topic are not adeouate to describe the calculation that was modified from the presentation in the eight volumes of the Reactor Safety Study (RSS), DASH-1400 (Ref. 6). It should be noted that for severe accidents, the assessment is carried out considering the entire nonulation within radii of FO km (50 ni) and 563 km (350 mi) ( Re f.1, Section 5.9.4.5 (2 ) ). It is
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Fidland 4
April 1982 entirely apnronriate to use radii of 563 km, or more.
A recent DEIS ( Ref. 7) nroperly considered a radius of 800 km. At larger distances from the release point, the exposure per person is less, but the number of neople exposed increases, Thus, it was recognized in the 1975 APS study ( Ref
- 8) that the major health impact may be located at the larger distances from the reactor site.
TFe present study ( Ref. 1) seems to be based on the RSS
( Ref. 6) with modifications to include improvements since the nublication of the RSS, (Page 5-45, Ref. 1).
In its January 1979 statement of policy, the 11RC took the following action:
The Peer Review Process: The Ccmnission agrees that the peer review nrocess followed in publishing WASH-1400 was inadequate and that proper neer review is fundamental to m,kinc sound, technical decisions. The Commission will take whatever corrective action is necessary to assure that effective peer review is an integral feature of the IIRC's risk assessment program.
Accident Probabilities: The Commission accepts the Review Groun Renort's conclusion that absolute values of riska presented by WASH-1400 should not be used uncritically either in the regulatary process or for public policy purposes and has taken and will continue to take steps to assure that any such use in the past will be corrected anpropriately. In particular, in light of the Refiew Group conclusions on accident probabilities, the Commission does not regard as reliable the Reactor Sa fety Study's numerical estimate of the overall ri sk of a reactor accident.
( Ref. 9, nage 3 ).
The second statoment would preclude the use of the relults from the RSS in this action.
The first reouires a thorough peer review process for any such study. It is here sugeested that the "rebaselining" has undergone less neer review than the RSS of 1975. In fact it annears ( Pa ce 5-6 5, Rc f.1, Section 5.9.6.5 ( 2 ) )
that the neer review comments on only the RSS were included from the Levis Risk Assessment Review Groun Reoort, NUREG/CR-0400 (Ref. 10). The present work is too incomplete for any attempt at peer review of it.
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l'idland 5
April 1982 It would appear that the NRC has at least two choices to realize its January 1979 nolicy. One choice is to publish a new version of the "rebaselined" RSS. Another choice would be to publish an expanded version of the present report (Ref. 1) to be as comprehensive as the origional RSS..In either
- cace, thorough neer review would be needed on the scale of the 1975 RSS.
This is more practical and likely ao a single study.
Dow Chemical:
The economic innact of an accident at Fidland on Dow Chemical is imrcrtant. Food wran contaminated in a class 9 accident will not be too popular in the stores. Hershey Foods discovered this a fter the TIil accident for their products.
A map of the site including the Dow plant and the city of Fidland would improve the comprehendability of the Final EIS.
It is hoped tath these commetns are used in preparing the Final EIS.
l I
Midland 6
Aoril 1982 iteferences 1
Draf t Environmental Statement related to the operation of Midland Plant, Units 1 and 2; NUREG-0537, Draft, NRC, February 1982 2
ft.0. Pohl, " Health Ef fects of Radon-222 from Uranium fiining",
S ea rch, 7 (5), 345 - 350 (August 1976) 3
" Final Generic Environmental Statement on the Use of Recycled Plutonium in Mixed Oxide Fuel in Light Water Cooled Reactors",
NUREG-0002, IlftC, (August 1976) 4
" Environmental Analysis of The Uranium Fuel Cycle, Part I -
Fuel Sunnly" EPA-520/9-73-003-B,U.S.
E.P.A., (October 1973) 5
" Health Effects Attributable to Coal and Nuclear Fuel Cycle Altorna tives" NUREG-0332, Draft, U. S. N. !t.C., (September 1977) 6 "Ren ctor Sa fety Stydy", NASH-1400, ( NUREG-75/014 ), 1975 7
" Supplement t o Dra f t Environmental Statement related to the oneration of the Susquehanna Steam Electric 3tation, Units 1 nnd 2", NUREG-0564, Supplement 2, NRC, (I' Arch 1981), Draf t 8
"Renort to the Amerl7an Physical Society by the Study group on light - wa ter rea ctor safety", H.M. Lewis, et al.,
Reviews on I/odern Physics, 701 4 7, Supp. No. 1, Summer 1975 9
"NRC Statement on Risk Assessment and the Reactor Safety Study Renort (!' ASH-1400) In lir,ht of the Risk Assessment iteview Groun Renort", NRC, January 18, 1979.
10 H.W. Lewis et al., " Risk Assessment Review Groun Herort to the U.S. Nuclear Iter.ulatory Commission",
NUREG/CR-0400, September 1978.