ML20071M532

Revised Contention 4,curing Defects in Original Contention by Specifically Addressing Des Analysis & Detailing Why Des Projections of Radiological Genetic & Somatic Effects of Plant Operation Inadequate.Certificate of Svc Encl

ML20071M532
Person / Time
Site:	Catawba
Issue date:	09/19/1982
From:	Presler H CHARLOTTE-MECKLENBERG ENVIRONMENTAL COALITION
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8209270163
Download: ML20071M532 (6)

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!b67/U 12 S9 24 Pi 49 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 0FFl --

ATOMIC SAFITY AND LICENSING EDARD I

g N:k Charlotte-Mecklenburg Environmental Coalition, Intervenor, In the Matter of:

Duke Power Company, et al. Docket Hos. 50-413 (Catawba Nuclear Station, 50-414 Units 1 & 2),

Applicants CMEC'S REVISED CONTENTION g4

Introduction:

fhe Board's Order admitting and reaecting the Intervenors' contentions admitted CMEC's contentions

1. 1-3 without conditions;it admitted contention #4 conditionally.

30th the Staff and the Board f aulted contention #4 on the Grounds that (a) #4 was not sufficiently specific, and (b)

1. 4 ought to be directed toward the Staff's statutory NEPA obli5ations as fulfilled in its ES. 3ut the DES had notHow issued at the time Intervenor framed his contentions.

that the DES has issued, CMEC tries, in this document, to cure the defects in its fourth contention by (a) stating in some detail reasons why we find the DES's projections of the radiological genetic and somatic effects of CHS operations to be inadequate and (b) specifically addressing the DES analysis.

CMEC's Revised Contention f4:The methods used in the DES (HUREG-0921) for estimating somatic and genetic effects to the population that will be exposed to releases of radioactivity from CHS inadequately assess these somatic and Senetic effects.

(' Releases of radioactivity' includes routine releases of radioactivty into the hydrosphere and atmosphere resultin5 l from normal plant operation and releases of the sort specified in CHEC's contentions.#1 & #2.) Intervenor's objections to the DES methodologies include the following.

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1. The DES (page 5-18) bases its estimations of health effects kDR G

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J O as regards cancer mortality risks on the 'absoluto-risk' i

model. Intervenor's position is that this method fails to take into account the time cancers take to develop after tissue irradiation and that, in failing to express risk as a percent increase in mortality rates per rad of exposure, it seriously underestimates cancer morality risk for a population continuously exposed to irradiation over a lon5 period of time. The DES (page 5-18) takes notice of

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the ' alternative (and in the Intervenor's view, proper)

' relative risk model.' The DES suG5ests that the relative risk model would give risk values of up to four times those produced by its ' absolute-risk' model. However, Intervenor is prepared to show that the ' absolute-risk' method produces risk values that are lower than ' relative-risk' values by f actors much greater than four and that are lower than I observed mortality rates by f actors much greater than four.

For instance, analysis of data collected by Saccomanno indicates that the ' absolute-risk' model predicts cancer mortality rates for smokin5 uranium miners that are less than the observed mortality rate by a factor of }8.1

2. The DES does not appear to take seriously the 1

linear hypothesis that the incidence of radiation induced cancers in an irradiated population is directly proportional to the amount of radiation sustained. For example, the DES accepts 3EIR-III as authoritative;but 3EIR-III rejects the linear hypothesis in favor of a combination of 1.inear and quadratic models , a combination that had no basis in any epidemiological evidence whatsoever. (The i lack of basis for 3EIR--III's position was presented in a detailed dissenting discussion by Chairman R'adford (3EIR-III, 1980, pages 287-314).) Statements like "The lower limit of the range (of health effects) would be l zero because health effects have not been detected at doses in this dose-rate range " (DES page 5-18) suggest that Staff accepts a threshold hypothesis. But Intervenor argues that the evidence overwhelmingly supports the linear hypothesis;the linear hypothesis ought to be the basis of DES met,hodoloSy in assessing radiolo5 i cal effects of

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, 3. DES (page 5-18) basis its risk estimates on 3EIR-I, BEIR-III and UNSCEAR. We find these documents seriously '

defficient in methodolgy. For example BEIR-III obliterates the difference in sensitivities of young and old at irradiation;

, its methodology assumes without warrant the model of a ten-year latent period followed by a lifetime plateau;as we have noted above, 3EIR-III rejects data on the incidence of cancer caused by irradiation of the young ,without warrant,and assumes without any evidence that a combination of the linear and quadratic models should be used in its analysis.

We have noted our objections to the ' absolute-risk' model used in 3EIR-I. Our objections to UNSCEAR are of a similar nature. For these and other reasons, we argue that the ' risk estimator' of 135 radiation induced cancer deaths per million person-rems ought to be increased I by a factor of at least 25.2 4 As regards genetic effects in exposed populations, DES (page 5-18) states that " Values for risk estimators range from 60-1500 potential cases of all forms of genetic disorders." DES takes this statement from BEIR-I issued in 1972. But considerable advances have taken place in radiology in the past decade; projections for genetic disorders are now much higher, e.g. Gofman's projections of a range of up to 20,000.3 The DES, as far as we can determine, fails to address the more r5 cent work.

DES (page 5-21) states that in respect to the low level radiation from CUS "the upper bound limits of deleterious effects are well established and amenable to standard methods of risk analysis." Generally, as indicated by the above

. remarks, we argue that "the upper bound limits" accepted by the DES in respect to somatic and genetic effects can only be maintained by ignoring recent studies that indicate that ' upper bound limits of deleterious effects' are.in fact many times higher than the DES assumes.

Notes 1 Saccomanno G., Comments on lung cancer in cigarette-smoking and non-qmoking uranium mi.ners. Final Report:Cluff Lake 3oard of Inquiry:61, Sas Dept. of the Environment, Regina, Saskatchewang_1978. _.

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2. For the basis of this view, see Gofman J.h'. , Radiation and lluman Health;5ierra Club 3ooks, San Francisco,1981, pp. 314-323 and passim.

3 ibid. p. 849 and 707-853 passim.

4. ibid and e.g. Sternglass, Low-level Radiation from Hiroshima to Three-Mile Island McGraw-Hill, New York,1981 passim.

ntnry Prehler Charlotte-Mecklenburg Environmental Coalition 945 Henley Place, Charlotte, H.C.

704-333-8589 September 19, 1982 Service:A1 Carr by hand.

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DOCKEin US!;Rf UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 82 SEP 24 p1 g BEFORE THE ATOMIC SAFETY AND LICENSING BOAR 4pg _

g h-In the Matter of )

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DUKE POWER COMPANY, et al. ) Docket Nos. 50-413

) 50-414 (Catawba Nuclear Station, )

Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of "CMEC's Revised Contention #4" in the above docket have been served upon the following by deposit in the United States Mail this 22nd day of September, 1982:

James L. Kelley, Chairman George E. Johnson, Esq.

Atomic Safety and Licensing Office of the Executive Legal Board Panel Director U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555 Dr. A. Dixon Callihan J. Michael McGarry, III,-Esq.

Union Carbide Corporation Debevoise & Liberman P. O. Box Y 1200 Seventeenth Street, N.W.

Oak Ridge, Tennessee 37830 Washington, D. C. 20036 Dr. Richard F. Foster Richard P. Wilson, Esq.

P. O. Box 4263 Assistant Attorney General Sunriver, Oregon 97701 State of South Carolina P. O. Box 11549 Chairman Columbia, South Carolina 29211 Atomic Safety and Licensing Board Panel Robert Guild, Esq.

U. S. Nuclear Regulatory Commission Attorney-at-Law Washington, D. C. 20555 314 Pall Mall Columbia, South Carolina 29201 Chairman Atomic Safety and Licensing Palmetto Alliance Appeal Board 2135- Devine Street U. S. Nuclear Regulatory Commission Columbia, South Carolina 29205 Washington, D. C. 20555

Mr. Jesse L. Riley 854 Henley Place Charlotte, North Carolina 28207 Mr. Henry A. Presler 943 Henley Place Claarlotte, North Carolina 28207 Mr. Scott Stucky Docketing and Service Section U. S. Nuclear Regulatory Commission Washington, D. C. 20555

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Albert V. Carr['Jr.

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