ML20076F011
| ML20076F011 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/19/1983 |
| From: | Eddleman W EDDLEMAN, W. |
| To: | CAROLINA POWER & LIGHT CO. |
| Shared Package | |
| ML20076F014 | List: |
| References | |
| 82-468-01-OL, 82-468-1-OL, ISSUANCES-OL, NUDOCS 8308250189 | |
| Download: ML20076F011 (58) | |
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(U B0CKETED uss.ec UNITED STATES OF AMERICA Lugust 19, 1983 NUCLEAR BEGULATORY COMMISSION ,U AUG 24 N0:23 CCQ;ff;Chatin L;i m . o e BEFORE THE A'IOMIC SAFETY AND LICENSING BOARD 5:wicI '
Glenn O. Bright Dr. James H. Carpenter James L. Kelley, Chairman In the Matter of
) Dockets 50 400 OL CAROLINA POWER AND LIGHT CO. et al. ) 50-401 OL (Shearon Harris Nuclear Power Plant, )
Units 1 and 2) ) ASLBP No. 82-h66-01
) OL Wells Eddlenan's Resnonse to Annlicants' Interrogatories (Fifth Set) re Contentions 29 and 37B This response is filed under an extension of time agreed to by Apnlicants' attorney 3axter. Pequested docunents will be nade available for inspection and copying at a nutually agreeable tine and place within 30 days. Applicants should contact ne, 919-286-3076, to nake arrangenents for this.
! RESPG:!SE TO GENEPAL IIERROGATORIES G-1(a) Most persons who provided this information are unknown.
To the extent they delivered, nailed or otherwise provide d this infornation I do not believe their names are relevant unit ,a they have kncwledge of the facts relied on, probably first-hand knowledge.
Where I know the organization which sunnlied information but og C'OQ 5E' do not know the nerson who did, I read this interrogatory as not 88 requesting the name of the organization or grouo. In many cases I mg w do not even recall if anyone whose nano mg oc was ever knoun to me was the actual provider of the inf orma tion ,
l @@
f G3JECTIONS: To the extent this interrogatory requests identification of individuals who sino17 handed over, mailed, or g
o o i
l
~2-otherwise transferred information to ne, but who have no firs t-hand
- or exnert knowledge of the facts involved, I object that the identity of these persons, even where known, is irrelevant. There is no way that the identity of such persons can lead to adnissible evidence.
But there is a way that the identity of these persons could lead to discovery of protected information, i.e. the identity of non-witness experts consulted. Where a non-wi+ ness expert nay be involved, I add the objection that discovery of the " innocent provider" I
as described above (pp 1-2) identities could lead to discovery of the protecteu identities of non-witness exnerts. Aop11 cants , as usual, show no special circunstances or need for the identity of the non-witness exports. i' hey cannot do so on this set of contentions since their resnonse to my General Interrogatory G-$(a) is that they have available expertise and infornation on the subject natter of these contentions 29 and 37B (6-17-83 response at 8).
1 Concerning the identity of non-witness exnerts, my objections to revealing this have been set forth in resnonses (1st and pd set, 4th set) to past Apr11 cants' interrogatories G-2(a) and (b), and to l
l 4-1(a) and (c), 4-2, and 4-3 (Applicants ' Fourth Set); and also in ny answer to Applicants' Motion to Compel on the first set response l
re identities of experts. I adopt those objections again here, incornorating then by reference as if fully set out at this ooint. "D Collateral information, e.g. address, ennloyer, is not provi'ded. Ager 503c (b) ANSUER: If I renenber who provided it or have a name available, I will (1) not provide it if the person is a non-witness expert; (2) answer or object for other personse not covered by the objections to 1-(a) above, where the information is requested.
OBJECTION: To identifying any " innocent provider": their nanes are irrelevant, as set forth above in objection to 1(a).
To identifying any non-witness expert, for reasons incornorated by I
"eference above, re non-witness experts. Where the identity is unknown or an organization is known but no persons, it would be both burdensono and not called for as I read the interrogatory to tag the information as " source unknown". It is reasonable to assume I don't know a name of a source if no psuedonyn is provided in a response where a nane is recuested under this interrogatory's part (a),
(c) As explained in ny objecticns to Genewal Interrogatories in Apulicants ' Fourth Set (response by no, 8/h/83), I object to this question in all its parts. I don't have to show anything about these experts unless the Apulicants have first nade a showing ert that it is inpracticable for then to obtain information or exn- .-
advice on the sane subject natter by other neans. Applicants have not done so and cannot, if thexir response to ny interrogatory G-5(a)
(6-17-83 response re 29 and 37B, page 8) be true. That response is that Ann 11 cants have available expertise and inforration on the subject natter of these contentions.
Under the Ager decision, only when such a showing is nade is there to be any inquiry into the expertise, specially retained or encloyed status, and so on, and then only by the Court (Board t
in this case) in camera. While the Board in this case has indicated
! that it wouldn't go quite this far, it desires to deal on a case by l
case basis, and in no case have Applicants nado any suffici.nt showing of need to obtain the identity of nonwitness experts 5.ho have assisted ne in answering interrogatories or provided infornation l relied on in answering interrogatories. The req,uested info is thus l irrelevant.
l Also, of course, the nrivileges for work nroduct, advice, strategy and so on (10 CFR 2.7kO(b)) apply.
i
a
-h-G-2(a) Documents including f acts and exnert opinions not privileged will be identified (pages cited as anpropriate, or chanters. The or secticns, etc .
entire work is relied upon where no pages are cited ). 03JECTION:
To identifying work product of experts or of nyself acting as my attorney (or as ny own source of expert opinion, advice, strategy etc).
This material is nrivileged and not discoverable. Applicants' resnonse to my interrogatory G-5(a) (6-17-83 resnonse at 8) precludes their naking the showing required by 10 CFR 2.7kO(b) to obtain any discovery of these matters. Since discovery cannot be obtained, identification of the documents would be supenfluous.
(b) Response will be identified with the document. In general, though this interrogatory does not require it, the part(s) of a resnonse to which a docunent apnlies will be identified.
G-3(a) Other sources of information, whose identification is not objected to above, will either be identified where called for under this interrogatory, or an objection will be made at that point.
(b) Such resnonses are the " point" referred to in vesponse to (a) above. Each will be identified at that point or referenced to another ooint at which the answer or objection apnlicable is set out.
RESPONSES ON EDDLEyAN 29 General discussion (anplicable throughout these responses):
l
' Apelicants' language is sometimes vague and I will set out what I l
think they nean where I think it can be figured out. A policants repeatedly use the word " fully" underlined; in cases where my analysis (or that of nonwitness exnerts, if any) is incomnlete, the information presently known, and results so far, will be set out, but that should not be read as fully covering the answer where analysis is insconnlete.
I can't divulge what hasn't yet been figured out in detail.
-g-
"29-18. Which NRC regulatory linits or guidelines do vou contend Anplicants have not net?" I presune this means '" complied with "
where the word " net" is used. Note that conn 11ance with or "' meeting" guidelines does not establish conpliance with "egulations.
I believe you have not demonstrated cono11ance with Annendix I for radiciodines. Appendix I is f ull of exceptions, qualifiers, and less-than-strict vequirenents.
As I road it, it requires CP&L to have demonstrated by calculations based on both nodels and data (Soc. III. A .1) "such pathways that actual exnosure of an individual through approuriate -
is unlikely te be substantially underestinated"when all exposune pathways are considered and all uncertainties are considered together. Among the pathways, Ann 11 cants admit they haven't dealt with rainout and that their nodels can't handle it.
(The attenpt to clain dry deposition is " rainout" is not consistent with my definition of rainout, i.e. water, snow, ice or other precipitation, which is a lot nowe than dry denosition; entrainnent in downdrafts and precipitation, e.g. rain, snow, is also included).
NRC translation $20 shows how vastly the kinds of models NRC annroves in its regulato"y guides can underestincto =adiciodine doses. See Table 9-2 therein, (starts u.100), also pp 113 and 126 for sone results. I rely on the entire discussion of radio-iodires therein, noting that the study appears to onit decay into radio-iodines which if included would increase its estinates of radio-I exnosure. The Translation $20 nodels are less likely to underestinate exnosure than NRC's and CPsL'a nodels are, but they still don't include rainout effects and nar*ow pludes being in the rainout.
As to guidelines, it's burdensene to dig then all uo; I have critiqued NRC Peg Guides on radio-iodines in some detail; analysis is incennlete and I nay be able to supplement this resnonse later.
h 29-19(a) I have not calculated the extent to which Arnlicants have underestimated radiolodine releases during novnal onorations.
It is clear they have done so (underestinated), e.g. due to the use of urinary fission products only in estinating rad'.olodines released (ignoring those wh!ch decay into radiolodines), ignoring the effects of I-129 and other isotones (see rosnonse to interrogatory 29-1(r) nade by Applicants 6-17-83 at 32), not includirs releases from the points cited in original Eddlenan 29, not including rainout and humidity effects, underestinating bio-concentration 1
effects, not verifying the sealing ability of radiciodine control systens under conditions of long-tern radiation exnosure, etc.
The above have already been explained in answers to other interwogatories c In a ddition, Atelicants have not nrovided data en fitun dinensions, filter changing and other infornation needed to helo nake such a connutation, nor an I obligated to nake such a connutation.
OBJECTION To the extent this interrogatory reauires ne to do additional research, I object to it. Interrogatories can only ask what I know or can readily figure out; radiciodine enissions are a very connicx l
l matter. While certain tech spec and atmosnheric data nrovided since h-22 1
can be helnful, they are far f ron sufficient to nake the calculations.
( I still don't have enough information to calculate this nunber.
(b) See (a) above. Citations are in (a) and in resnonses previously.
UPDATE to interrog 29-2: see 29-19 above.
29-20(a ) What guidelines? I presune you nean regulatory guides since Anpendix I is a rule (regulation) All I can find in the ER
& ER 5.2.2.1 (e.g. section 6.1 3) and FSAR (e.g. sec.11.5.2) are unsupported statenents that the nethods of various reg. guides, e.g. 1.109, 1.113 "connletely nixed, closed loop nodel", and 9G "1.XXX" which is 1.145, Gere used. Aeplicants do not urovide a calculation of the radio-iodine release estinate so far as I have been able to find, in the FSAR or ER.
l
f 1
29-19(a) continued.
As a result, I don't know whether the radiciodine release estinates were calculated in accordance with such guidance. I don't whether Ann 11 cants did or did not, think it natters nuch, since the guidance doesn't comply with Apoendix I. The Staff, see resnonse to my interrogatory 27 re Eddlenan 29 (Staff response June 1983 at 60) calculates releaser about 1.5 tines what CF&L did. They have not completed their anpendix I analysis according to the DES, but will nake it later.
(b) Analysis inconplete. Answer above is not affirmative now.
(c) See (b). Applicants clain their assunctions re collard green consunption (ER 5.2.1.2.1 at p. 5.2.1-3, Andt h) is consistent with NRC guidance, but it underestinates possible dose for neonle who eat collard greens throughout the year. Leary vegetables like collard greens are prine biological collectors for narticulates and radiciodines, through dry deposition, washout (raincut) and air flow.
Poor folks (and others who like collards) are likely to eat then far nore than 60 days a year. Sone folks eat then virtually every day.
(d) Answer to (a) is not negative, but Aunlicants do under-estinate releases. I have answered elsewhere re factors (e.gl unnonitoref decay of other isotenes, non-inclusion of certain isotones of "adio-I release points, leaks) that contribute to that. Even URC staff agrees that Applicants have underestinated normal radiciodine releases. See (a) above for cite. Further analysis is inconnlete now re this.
(e) I don't know that the " guidelines are responsible" for underestinates. CP&L is "esncnsible for its underestinates. But I have already critiqued (and do so fu"ther in these resnonses) "G 1.109 and 1.113, nixing and dispersion nodels used by HDC and Aunlicants, and so on. There is no NRC guidance which I know does not contribute to the underestinate of radioiodine releases, but analysis is inconnlete.
(f) By leaving out isotones decaying into radio *.odines, other
radiciodine isotones (e.g. I-129, I-135; list is in ER and I believe g, ) (r) r DJ (, - l M "
in an interrogatory respons l'ron Aunlicants thaWeatrtt leent6--Fight now), not taking account of transients that could raise " normal operation" radiolodine levels (note analysis of MUPEG-0017 still inconplete at present 8-19-83), and otherwise: analysis of this question is inconnlete. Answer to (d) above is only partly affirmative and was supnlied voluntarily for conpleteness of information; $1nce nnsuer to (a) is not negative, I could have declined to ansuer.
(g) I ely on the FSAR,11.1.2, which is not analysis, but just a clain that regulatory guides were followed, and tables of results and sone assunptions used (in ways not specified in the FSAR) in calculating those results, so it is said. Basis of answer to (d) is in other answerm herein and h-22-82. I don't have time to look then all up if I'm going to get this filed on tine. Applicants have declined to agree to even a one day further extension beyond 8-19-83 Basis of (e), see critiques of those Reg Guides in ny 4-22-83 responses and resnonses to 29-41 thru 29-60 (and possibly others I don't have tine to look un and cite now. I will suunlenent re this and (d) when nore research is done and I have other things to connunicate supplenenting this response) in this set. See also answers to 29-63 thru 65, 29-68 thru 29-70, 29-73, and so on. see for (f) 29-74, 29-20(a ) above, onissions from data or pathways cited in resnonses listed above for (e), and so on. There is such a nass of response to this set I don't have tine to sort it all out, but the question is answered at many noints in this resnonse. As noted above, I will suuplenent. If you will informally ask what you need to particularly know, I will resnond to that first.
i
29-21(a) The ultinate source is the IIarris reactors, including isotopes that decay into radiciodines. The answer to 29-3 does not say Anplicants cannot control then; but it is obvious that where releases cannot be detected they cannot be controlled,e.g. fron stean dunp valves. The other sources include liquid radwaste, offgas, containnent atmosphere, and the waste nrocessing systen.
Since I haven 't "'naintained"that Apr.licants cannot c entrol these releases", but that they "nay not be able to continuously tran radiciodines to the levels Annlicants state" and that they "cannot detect "adiolodine releases fren numerous noints" (h-22-82 resnonse at 10), I really don't have to answer this cuestion but an doing so voluntarily.
(b) That reactors produce radiciodines; 10 CFR 50 Annendk I, etc.
That nuclides can decay Into radioiodines: expert oninion of "Xerxes Xoe"; decay of isotopes (see for exannle Table of Isotones refd by Arnlicants , 6-17-83 at pn 32-33 in "esnonse to interrogatory by ne on this cuestion, 29-1-r(iv)). It appears Applicants effectively admit it does hannen, in that answer.
Applicants have not supplied sufficient information to identify which specific seals in gas and liquid "adioiodine control systens at liarris can leak; certainly the PVC containment floor drains can be degraded by radiation and leak; neoprene can crack and leak ny interrogatories See responses to 29-1(s) and (t). (6-17-83 by Applicants at 33-37)
I an requesting more data on sealers and nositions, sizes of seale=s and rarts sealed, thru interrogatories and a notion to connel, which will provide nore data about the ability of sealing systens to leak. I also rely on the FSAR's statements about where radiolodine is in the plant. These are burdensome to list off, but I presune Applicants know their own FSAR.
Analysis of this matter is incomplete now. The above and answer to (c) below cover nuch of what's been found out.
29-21(b ) continued.
I emphasize that this answer is voluntarily nrovided, since the auestion (c' includes a f alse prenise, so I don't have to provide a fully c o plete answer. I an doing ny best within tine constraints.
(c) In addition to radioactive gases ete decaying into radiolodines ("Xerxes Xoe" nrovided confirmation of this fact),
see resnonses to WE interrogatories 29-1(h)(ii)(iii)(iv) and (v).
(6-17-083 resnonse at 21-22)
Applicants' clain in response to 29-1(h)(vi) is not true for direct samnling: see (ii) thru (v) responses 6-17-83 at 21; also see resrrnse to 29-1(a)(vi) and (v), same Auslicants' response at 14 29-22. There's nothing about leaks in the descrintion of how the release is estinated. Look at your own descriution for sources, please.
29-23(a) Possibly. Analysis inconplete; Anulicants' refusal to provide tines of changing filmters and odaer conconents nakes it impossible to connlete this analysis now even given olenty of time to do so.
Answer is not affirnative fully, (b)(c)(d) See resnonse to (a).
but is conditionally. Analysis is inconnlete.
29-24 That'8 not what the answer to 29-3 says. I checked thru the G1 b and c resconse also (4-22-83 at 4-10 inel 29-3 response) and can find no s uch statenent. However, I do believe it and so will voluntarily answer: ,
In addition to CP&L's ability to have unnoinitored offsite releases (e.g. of Cs-137 at Brunswick), and although ny analysis is inconnlete (in part due to lack of data on fittings where leaks can occur, locations of nonitors, etc, though I have checked the FSAR ac cited in answer 6-17-83 to my interrog 29-1(a)(1) thru (iv), p.1hd
w The data for filter locations do not annear to be locatable in 9.h.0 of the FSAR, as referenced from section 12 3 4 In Section 11.5.2, the table 11.5.2-1 of monitors "efers to tynes listed in 11.5.2.7.1 11.5.2.7.1 (hereaf ter "X"') .1 refers t o 11.5.2.6.2 which refers to 11.5.2.5.7 for descrintion of the monitor. This " liquid detect..or" has no source given for the clains about its perfornance.
- 11.5.2.5 7 says background is " expected to be " less than 1.0 nR/hr. No source <
X.2 gives the same reference for the nonitor. X'.3 ditto. X.4 ditto X...$ ditto.
X.6 (gas nonitors) references 11.5.2.6.6 which desc=ibes noble gas (only) nonitors referring to 11.5.2.5.5 for descriution. The nonitor described in 11.5.2.5.5 is actually an " Iodine and Noble Gas Detectror".
bv nfr. or type The dete:t ,r is not identified nor is any source given for the clains nade for its perfornance in FSAR 11.5.2.5.5.
Only the X.6 nonitors in this set annear to be able to detect radiciodines, and then not indenendently of noble gases.
Of co urse, sone of the noble gases can be decaying into "adiciodines.
Table 11.5.2-2 also lists nonitors with "section of 11.5.2.7.1 described 3r" but these monitors and section nunbers don't natch.
i I believe Applicants mean (and should say, if so),"11.5.2.7.2" l
("Y" hereinaf:er).
Y.1 references 11.5.2.6.2 (sane as X.1 thru X.5 above:
see under X.5 for critique). These do not apnear to handle radioindines.
At least radiciodines aren't mentioned for then.
Y.2 is an airborne xparticulate, iodine and noble gas nonitor referenced to 11.5.2.6 4 Y.3 and Y.4 ditto. Y.h also references the 11.5.2.5.11 section descrintion of high-range nonitor. Y.7, Y.8 are Y.1 type monitors. Y.9 is the high-range nonitor of Y.h. Y.13k and &.1h are Y-1 tyr,e. Continuous containment purge is unnonitored.(11.5.2.7.2.15)
Y.5, t.6 is X.1 again, 11.5.2.6.2, as are Y.10,11 and 12 (sane type)
Y.15, Y.16 and Y.17 nonitors as discussed in those sections (Y is 11.5.2.7.2) do not nentions radiciodines. 9, lease noints 1 and 5A are the only ones identified in this section as having radiciodine nonitors before then. Thus, releases from other release
29-24 continued coints, as well as unnonitored release fron continuous containnent curge lines (Y.15) is not detected.
I havo dug through the FSAR 12 3.4, 9.k.0, and 11.5.1 and .2 and find no references to leaks in ducting being detected or estinated or dealth with. This is so even though the HVAC (9.h.0) operates many parts on an intermittent basis so that (1) naterial and gases, including radiotodines and nuclides that can decay into radioiodines, can be drawn into then through leaks when they start un, and (2) the sane naterials and gases can escape from then through leaks, seals, joints etc as they depressurize after shutdown of the systen or internittent cessation of operation.
As noted above, only the Y.2,3,h,7,8,13 and 14 nonitors are radiolodine type; the high range nonitors for Y.h and 9 can nick up noble gases. Looking at Table 11.5.2-2, w6 find sone inconsistency, e.g. the (Y presumed: X is wrong).2,3,4 conitors are referenced to 11.5.2.5.10 which is a radiciodine and noble gas detector, although on the second page of that table they are alnost all listed just as noble gas detectors. (p.11.5.2.-23) 11.5.2.2 The nost etriking thing onitted from this section is that (so far as I can find) there are no onerability criteria for these nonitors. They don't appear to have to be constinuousiv operable. If that's so, then just about anything can get unast then.
1 kW There do not generally anpear to be redundant nonitors if one Redundancy is sunnosed to be in the tables, but it isn't.
breaks down.
p Section 11.5.2.1 says they will be continuous excent when
\ they're out of" service for naintenance, repairk, calibration ete"
% (p.136.2-1) and then goes on to say that redundancy is only for the safety-related ones. If you look at Table 11.5.2-2, only the h ONed Coolig9 WaW I
l water cooler nonitors RY21 get power off the safety related bus.
<double (is In sun, the descriution is of a sieve.
i J) r $ Tghie (/, ir 2- l .
checked all this with conies of the Raleigh LPDF FSA9 nade 8-18.
u _.
29-23(a) No. It includes part of the basis (b) NUREG/CR 2157, the expert opinion of " Helen Hoe" that nolyners would enbrittle when exposed to radiation, oxygen, heat, etc expansion-contraction exnosure of sealers at stress Harris due to such to warning andrad radiation, cooling na $erial, heat, fiae noccibly,the references in NUREG/CR 2877 and NUREG/ CR 2157 (and, I believe, NUREG/ CR E-763 -- see 29-26(a) below), the data on swelling, radiation-induced enbrittlenent and oxidation, and deterioration of polyners and nixtures used in sealers, plus ny crnerience with sealers and connectors made of nolyners or fitted into netal parts (e.g. duct work) in consulting and ny knowledge of nodes of deterioration of such naterials, is the basis (in general).
See also Clough and Gillen, Investigation of Cable Deterioration Inside Reactor Containment, Nuclear Technology $9:344 Nov 1982, Also RL Clough & KT Gillon, J. Pblyner Sci- Dolyner Chen Education 19:20hl-51 (1981) and Clough and Gillen, articles in Fadiation Physics & Chenistry 18:661669 and 18:679-687 (both 1981).
Moreover, netals expand and contract with heat and cold, and are embrittled by radiation exposure. For cites on these facts, see any text on metallurgy or industrial engineering --
I don't have tine to dig then out for you; Annlicants are as able as I an to know and find these facts; I don't have to do research for then and to that extent I make an.
OBJECTION to providing the infornati on at least at this time, both generally (I rely on it entire) and 29-26(a) It is part of it,/particularly as relating to swellirg and distortion. Just look at the rhotos in it and you won't need ny background with sea 7 e ' naterials to see how sealers could b"eak up or swell or twist so as to open leaks in thin netal (e.g. ductwork and connectors) or other connections. The distortion observed is substantial, and docunented in NU'EG/CR 2763 (b) See (a); additional basis is radicactive material passing through the sealed systens at Harris for gaseous and liguid
29-26(b) continued i
radwaste, ny experience with polyner/ flexible sealers in connercial and industrial systems; also, oxidation shrinkage can also have the effect of causing leaks. Swelling in one part and shrinking in another can ouen gaes in a sealer. For basis of these effects, see response re enbrittlenent and failure (which includes shrinkage) to 29-25(a) and (b) above.
29-27(a) It is part of it. Other codes of degradation and failure are discussed in the sources cited in response to 29-25(a) and (b) and 29-26(b) and (a) above.
(b)The chemical bond-branking effects of radiation and the process of oxidation are essentially the sane for neoprene as for materials tested in IIUREG/CR-2157 's text. More details and on the fire-retardant fonn, self-extinguishing rubber-based naterials (identified with neoprene, 6-17-83 resnonse to interrogatories 29-1(s) subparts by Apnlicants, pp 3h-35) is needed to analyze then. I have filed interrogatories on this matter. The Cohtlastic R-10h80 is a "nediun silicone rubber" (Apps resp p.34 to ny Interrogatory 29-1(l)) and silicone rubber is shown to lose nearly half of its elongat'on ability (stretch 7 .i n NUPEG/C9 2763, p.17.
Other materials degrade more than silicone and also lose tensile strength. These is no reason to believe that neoprene is not subject to the radiation degradation effects other hydrocarbon polyners (silicone, obviously, is not a hydrocarbon) spffer as shown in NUREG-CR 2157, 2763 and 2877. " Helen Hoe", expert, uoints polyneric out that for materials which are not high-density (none of the Enrris natorials for seals which are polyneric are labeled high-density) repair of brcken bonds will be less effective and oxygen diffusion into the nolymer is nore, leading to more degradation.
.- C --
29-27(b) continued I an also seeking further expert oninions on this informally.
(c) Dose rates ann 11ed are given in UUSEG/CR 2157 at Figs 1,2,3 and k, pp 13-16. They =ange fron 1.h kilorad per hour to 1.2 negarad per hour, being somewhat lower f or the last 2 naterials (Figs 3 and 4). I think this is what you nean by test
" dose rate observed by the material in HUEG/C3 2157".
Note that NUREG/CR 2877 and 2763 eroerinents are also relevant.
I have not calculated the dose rates for radiciodine handling and nonitoring systens at Harris, but the figures 1 through 4 of NUPEG-CR 2157 clearly show that the degradation is more rapid for the lower dose rates. Thus, if the rates are less than those cited here, the degradation effect per rad of dose will be pronortionately la rger. I do not expect that mos t narts of the Harris radiolodine handling and monitoring systens will usually exnerience dose rates above a negardd ner hourn, but in an accident dose rates of over 100 nega"ad per hour could well occur.
I believe it doesn't natter, so far as degradation of the systens you ask about at Harris is concerned, what the dose rate to the systens is as long as it is less than about 1 to 10 negarad rates, per hour. At lower dosex, the degradation will be greater for a given dose. I cannot find a statenent of nine that "similar doses will be observed by radiciodine handling and nonitoring sys tens during normal operations at SENPP" or anything to that effect, but similar
~ { ,,-
29-27(c) continued O or lower doses are alnost certain to occur, since the nresence of radioactive natorial inn 11es sone dose and the radiciodine-controlling systems are also exposed to other radionuclides in waste streans.
(d) Look at responses to 29-27(a) and things it cites, niease.
'~ fore info is in (b) and (c) above re 29-27 (e) Apnlicants have refused to provide data on tining of insnecticns they plan at Harris. I don't have any idea whether they will comply with ?eg. Guide 1.1h0. Aunlicants have provided no replacement criteria or schedules in response to ny interrogatories, so even if one assumes (arguendo)that Annlicant s wculd conduct the inscoctions and that oG 1.1h0's instection frecuency is enough to detect all degradation that could result in a leak, if the degraded naterial is not replaced or retai=ed (replacenent ifs to be preferred because the material is degrading all over in some degree: I'd say replacement is necessary) then nothing is done to ston leaks. CP&L's failure to chlorinate their PHR at Brunswick for over 2 years nakes ne skentical whether routine inspection like this (which would recuire an outage to actually view some of the seals, and radiation exrosure to see virtually all of them) will be carried out as neticulously as Annlicants seen to suggest. In sun, I have no evidence that Annlicants will carry out inspections per Reg. Guide 1.1h0 or that these insnec tions will detect degradation of sealers nrior to leakage.
Harris 29-28(a ) Yes. There are 31 atmosnheric dump velves per unit; See also your response to 29-1( ) of June 17.
(b) Any coint where you don't have a detector or nearby monitor could release radiciodine without Apnlicants detecting it.
Once into the environnent, quite a large amount could get by environne tal a nonitoring systen because the nonitd$ys can't nick up a release much
~~
29-28(b) continued (if at all) smaller than a billion tines the lower linit of sensitivity of any nonitor. Because I-131 has a half-life of about 8 days, it would be even less likely to be detected on checking these nonitors because a good bit of it can have decayed away since the last time the nonitor was checked or its contents analyzed.
(c) Applicants' answers to ne confian answer to (a): See (a ).
As to (b), Bisello paper on TMI radiation releases gives the billion-tines limit. I hooe to accuire the full cite and nut it in here.
Sex & 29 - % lo% u. TV ddv+ Cwa ( 2p ?-M.
(d) Analysis inconnlete, but it would certainly help to put both low-range and high range radiciodine nonitors, and noble gas nonitors able to detect snecific nuclides abic to decay into radiciodines (or, put on wide-range nressu=ined ionization nonitors)
- at all the possible radioicdine release noints so far identified by Applicants or NRC Staff.
Other places where releases have occuv=ed, e.g. Auxiliary Building vents (incidents at Ginna, TMI) need nonitors of these types too. I nay find odier places they are needed and supplenent this response. As to odaer neasures, analysis fully is incomplete and I cannot specify what other neasuaes wotdd be needed A
at this tine. Means to tran the escanirg noble gases and radiotodines
{
would be best, but they need to be high1; reliable and effective, even given that they will be used only internittently; they need to be well naintained at all tines.
29-29(a) Yes. Auplicants have not provided sufficient info to change ny past answer. The referenced sections of the FSAR (6-17-83 response to 29-1(a)(1)-(iv) do not contain the info, nor does section 9.hD which 12 3.4 references, re filters. The setup and specific location and orientation of the area radiation monitors is also not nrovided in FSAR 12.3.4 (this is also relevant to29-2h above:
v 29-29(n) continuad (rer to 29-24 supolenenting it, continued) given that the nonitors don't ain at the leaks or are not near then, they very well can niss then).
(b) Until Apolicants nrovide more infornation resnonsive to ny interrogatories 29-1(a)(1)-(iv) etc, I cannot give this kind of detail. Even the nunber and location of the filters could not be found in the FSAR sections 12 3.h,9.4.0 (refd therein) or 11.5.2 (copies made 8-18-83 at LPDR Palgigh fron undated connlete FSAR for this checking).
(c) Analysis is incomplete, in large part due to lack of information which Annlicants have declined to provide so far.
See responses to (a) and (b) above. I rely on the FSAR and your past responses to ny interrogatories, e.g. 29-1(a)(1)-(iv).
If you will supply specific references or the infornation, I nay be able to give a more detailed answer.
for which OBJECTION: To having to answer a question Apnlicants have thenselves declined to provide the infornation needed to answer.
29-30 'a) Yes.
(b) metal-to-netal seals, elastoneric sealing naterials l that Apnlicants have identified (reso to 29-1(ms ) 6-17-83), and metal joints; PVC piping; piping joints; punps' seals; all these can or leak l
fail under thernal, radiation, air and water pressure changes to be expected at Harris; can also f ail due to fires and low-oxygen conditions leading to swelling of elastoners and warpage of netal including expansion of netal.
00 (c) Asked and answered for elastomers and netal-to-netal.
See G-1 response re 29, h-22-83, and 29-26,27,26 etc resnonses herein.
! Leaking pipes are a connonplace. Seal, pump leaks, see ER Table Leaks may be worse, analysis inconnlets
}.5.1-6 which is only assudntions.
tal warpage and expansion when heated: basic naterials ccience.
Also, ny experience with thin-netal and netal joint systens.
-- /
k 29-31(a) Yos, both.
(b) See your answer to ny interrogatory 29-1(p) and the information ref erenced therein. No " variations in plant radiciodine releases"are cited' to ny knowledge for the " standard plant".
I was advised infornally that the release points that were nonitored were the only ones considered in the source tern, and believe this to be correct.
(c) Variations including Xenon transients which recui*e the offgassing of nuclides which can decay into radiciodines, and variations in nower and radiciodine production, co nared to the " standard plant" used in connuting Applicants ' radiciodine source tern.
(d) Analysis not connlete. It is obvious tha t the more sources of radiciodine there are, including fission products decaying into radiciodines, which are not included in the source tern, and the more release noirts not included in the source tern, the larger the actual anount of radiciodines will be in the environnent, compared to calculations made on the scurce tern. The source tern also includes sone credit for waste nrocessing at das nlant, so leaks bypassing this systen (gaseous or licuid radwaste) or fren waste nrocessing systens would increase the radioicdine veleased.
29-32(a). Apnlicants do their nodeling by NRC nodels. They say so in resnonses, e.g. on Eddlenan 80 (XOCD0Q progran and Dog.
Guide 1.145 and basis for Reg. Guide 1.1h5). NRC nodeled TMI nlunes with the sane nodels so far as I know. The diffusion models are sinilar in that they are Gaussian diffusion nodels in any case, and the less snread and nore rainout effects cited in ny resnonse to 29-5 on h-22-82 would not be affected by ninor differences.
(b) Resnonse to ry interrogatory 29-3(p)(v) by Anvlicants, llo (co**ect sp) i Reg Guides 1.109 and 1.113 as cited therein g -j9-b paper, citation y % g g,f- Mp if y, P sevd ph SE.g
() --
29-33(x) Yes. I have not received a cony of the study yet, the it wss to be sent. Analysis is therefore inconnlete.
(a) Yes. Not that it natters a lot, since the lesser exnansion of the plune and the tendency to cone to ground earlier (closer to plant) than predicted are princinal conclusions not affected nuch by terrain, but Harris is in a river valley (though higher un than TMI which is nid-river) in rolling, sonewhat hilly terrain. .
Pisello (b) requires the paner and nove analysis of TMI to state.
May be burdensone. As noted in (a) above, if they are not similar in all or even nost respects, inportant results of the Disello naner would not be affected.
(c) See (a) and (b) above also. Requires more analysis of paper not yet received, to get a fuller answer. It had been nronised for delivery 8-18 or 19 at latest, did not arrive yet. The behavior of the nlune itself in air would be similar. Hillier terrain around Harris would just give more things for the plune to run ?nto sooner.
Harris area hunidity and rainout night increase the derosition of radiciodines connared to TMI niune. The tendency of radio-nuclides to stay together in the nlune would still be similar i
at Har-is as at TMI: terrain would not affect this until the plune began to interact with the ground; rainout could occur with thenplune still off the ground but more cohnesive as the Pisello raner sa ys (this from ny mencry of it).
(d)(e)(f) Dont' know in any detail. Need the Pisello et al i
report, paper to answer. Will supplement. Harris actual release conditions not provided to me, but can figure then. They anpear to be close to the TMI in-containnent temps at the Kr-85 release time ad I recall then. Pressure of venting and Harris gaseous "eleases anpear to be similar. TnI used vent stack, so will Harris.
similar heights to Kogf to"nb e Stgggan dunn or vent release at Harris,
4-29-3k(a) Yes.
(b) Apn11 cants say they cannot nonitor turbine gland seal radiciodine leaknge due to hi Eh humidity. The hunidity in this 3-area is quite high an average (see monthly and hour renorts of Raleigh Durhan airnort weathe" station by MOAA)x, and the hunidity at Harris should be higher due to dae lakes near it (nain and auxiliary lakes); prasence of Jordan lake should also raise hunidity in tho Har~is plant area. The lakes will tend te raise the humidity (1) because water evarorttes (2) because the more organic natter or sediment susnended in then, the more effectively they will absorb solar energy and warn themselves, Icading to higher evanoraticn "ates (higher varor pressure). Re vanor pressuwe, see any basic chenis try text.
29-35(a) They could, particularly if rainout and lowe" plune spread and blocencentration effects are fully taken into account.
Apnendix : would be violcted if any irdividual we"e exposed over its limits. Analysis is inconnlete, but it is clear diat " daughter (sic) radiciodines" increase the anount of radiciodine naesent outside the Harris plant if their "narent" nuclides are released.
(b) Opinion of "Xerxes Xoe" that these nuclides decaying into rad'.o'odines increase radiciodine "cleased; notential of concentrated plune of radiciodine and paaent materials (and other rad naterials) to be rained out onto persons or their food supply (e.g. a garden). Annlicants have failed to analyze these points together and thus have not demonstrated compliance wi th Anpendix I (which is what the contention says. It does not say, as you appear to nisroad it in asking this cue stion, that the radiciodines will exceed those limits).
7__ 7 29-36(a) I an annalled by it. It reads "Hewe and elsewhere in this annendix background neans radicactive natovials in the environnent and in the effluents from light-water-ccoled nover reactors not Seneratei in, or attributable to, d1e reactors of which snecific account is recuired in deternining design objectives."
I translate this to nean that no natter how high the radiat'on
! levels in the environment fron other sources (including other nuclear nlants, nuclcar weanons and weapons tests, radioactive material use, radioactive naterial misunse, leaks, and so on), each nuclear power up to a uniforn amount plant can add4nore to that dose, unless (as stated e.g. in II.B.2(a) of Appendix I to 10 CFR 50) the NRC sets a lower dose. On the other hand, as in II.3.2(b), they can set a higher dose.
(b) Please note that sinca Ur.is is an UDC rule, I cannot challenge it for purposes of litigating this contention. Therefore the reouested information as to what I think should be done about it is irrelevant.
(c) I rely (see (b) also) on Arwendix I Section III.A.1 which says "confornity with the guides on design objcetives of Section II shall be denonstrated by calculatienal nrocedures based upon nodels and data such that the actual exnosure of an individual through a propriate "abhways is unlikely to be substantially underestinated."
when all uncertainties are censidered together, taking into account "all sources and pathways within the- t plant contributing to the particular tyne of effluent being censidered" and the pathways of i exnosure which could actually cxist during the period of plant onoration.
Frankly, I Unink it would be best to sinnly renove the reference to "above background" wherever it appears in Appendix I and its footnotes, and renove footnote 1. That would take a PFM. Since this
" background" definition is an NRC rule, I can't challenge it in this case.
(d) Appendix I; URC Translation $20; basis of Eddlenan 29.
Applicants don't anpear to have a background nunber, at least not neasured or calculated: See FSAR 11.5.2.5.7 and resnonse to 29-37 below.
+
29-37(a) I can't see that it has been neasured by Auplicants.
FSAR11.5.2.5.7 says the background is expected to be under 1 mR/hr for certain detectors described therein, but it doesn't mention .
radiciodines. I can't find a neasuronnent of background levels of radiciodines in the ER or the FSAR.
(b) See answer to (a) above. If You suun17 a reference, I will check the estinate in the reference (or neasurenent) and resnond further.
OBJECTION re 24 18div:e. Full answer would take writing a book. Answer is resn6n given 2D*38Y Analysis inconplete. The basic noint is that the thyroids of these creatures (voles and other ani6als ) process and concentrate lodine in the sane way hunan thyroids do. Because aninals smaller than humana ingest more food ner unit of their
! wie'ght, and much of the food of voles, nice and other animals i
is directly exnosed to radicactive emissions from nuclear plants (i.e. it grows near plants, rather than being grought in fron areas far renoved from the nearbay power plant as much human food is ),
they serve as "environnental nonitors" of =adiciodine emissions fron nuclear nlants by concentrating then, especially in their thyroid glands. For ex-osition, see L. van Middlesworth, Scall 131 I in Thyroids of Sheen fron Wales, Health Physics Quantities of h0: 525-527, 1981. See also p.5 of my h-22-82 answers to Aunlicants and the paners (2 letters) cited therein. These have already been nade available to Apnlicants for insnection and conying, in May '83, i.e. the le ttens have been. They are all I nossess of th8se cites; I also have the van Middlesworth paper.
l l
-] - .
29-39(c) No. Thora is no justification or test procedurs for it, in FSA9 surn11ers & n?rs.
Applicants have dodged the question by saying their zexhnmetans do the tents, when I asked details of the testing in inte"rogatories.
I have filed a notion to concel asking this stuff be revealed.
I have read FSAF 11.5 and see some clained lower limits in there. However, in Section 16 (I can't find a " Chanter 16" in the Raleigh LPDR FSAR, 8-18), if there is a Table 4.12-1, I can't find it -- the copy was sonewhat out of order, but Section 16 is the tech suecs. I did cony the only relevant tech specs Tech spec 4 12-1 refers to a Table 4.12-1, but no table is there.
I found. 3
.11.2.1 restricts conbined dose above background to $ ren/yr to todtal body and less than 3 ren/yr to skin and infant dose to 1.5 ren/yrear. That Inst is 100 times the KAnnendix I limit, so this tech spec is really useless.
Tech spect 3/h.11.2.2 re dose from noble gases uses reg. guides 1.111 and 1.109 and thus can be expected to underestimate doses.
s See critique of disnerion nodels and dose nodels already given and given in response to other interrogatories in this set.
(1,109 and 1.111)
Tech spec 3/411.23 uses the sane guides No numbe-s are given and also annears to underestinate the pathways.
for the release rates. The spec doesn't appear to do anything.
3/h.11.2.h re gaseous radwaste treatment is vague enough to get alnost anything by: " requirements that the aunropriate portions of these systens (gaseous radwaste treatment and ventilation exhaust treatment) be used when specified" is just about meaningless l without a definition of the appropriate portiens and when they are to be used. What is a " suitable fraction" of the dose 2xtbuduur design objectives? It doesn't say.
l l
The FSAR also addresses General Design Criterion 60, at section 3 1.51 on page 3 1-40. It says (fresh coJy 8-18 fron Paleigh These do not explain LPDR FSAR) to look at FSAR 11.2 thru 11.5 or even clain, as ifar as I can tell, to conply with GDC 60. One references FSAR 31, which I presume is this 31.51- circular reference.
. 25' 29-39(b) See response to (a). The lack of information nrovided nakes it inpossible to answer in tore detail, but the i FSAR itself appears to lack key information and does not exnlain how GDC 60 is net in any systenatic way. It looks like technical bull-slinging to ne, and is at least inconnlete.
29-40(a) I don't know. Applicants haven't tested the devices and haven't documented tests in resnonse to my interrogatories (I've filed a notion to conpel to get the info). I see nothing in the FSAR that even says any test or calculation was used to get the lower linits clained for instrunents e.g. in 11.5.2.5.
- See 29-39 (a) and (b) above
- (b) See (a) above and 29-39 (a) and (b) above. It really i
is difficult to answer a c.uestion without infornation, but the 1
lack of information nrovided in the FSAR to docunent these clains (either by test or by analysis), when the FSAR has already been so extensively updated, suggests to ne that Applicants don't think it's worth documenting, or that they can't document it.
In either case, there is no reason to accent unsunnorted, unreferenced clains. I tried to get supnorting information and none was nrovided. I've filed a notion to conpel to still try to get it.
Applicants resist the notion. Then they ask ne to answer this.
i If Applicants have the inform.ation, they're surely not making it available. I think if they have the info to sunnert these clains, they should nut it in the FSAR and allow it to be anaheed .
If they do that, then I can answer in more detail.
i
29-!;1 Do you nean nonitoring or nodeling of the Har=is site (neteorological)? I have detailed my disagreements with their including noteorological nodeling in other responses, re Eddleran 80.
Applicants can locate and sunnarize these disagroenents as well as I can. The extent of them is clear f rom context, e.g. Applicants should include rainout in their nodels and they don't. I don't possess their actual nodel (if one exists) for site neteorology, to my knowledge.
As to notecroloB ical monitoring, they don't knew where the rain falls around the plant or distributions thereof, they aren't checking the cetual dixffusion of anything at the site, and I continue to also believe they don't havo enough data to accurately sinulate the variations to be expected within 20 to 40 years of nossible onorations. They still clain they'll use unit 2 for 25 years or more, which is the year 2015 at nininun, if that unit 's not delayed more.
29-h2(a) Yes.
(b) There is more variability in a 30 or h0_ year time span of weather than there is in a'few years. You could nodel that by widening variances of tenperature, hunidity, rainfall, nax and nin droughts, rainfall, snowfall, hail, freezing rain, hurricanes, l probability of tornadoes, and inversions, diffusion, wind sneed and direction, and so on, to account for the greater variability over a longer period. Or you could collect 30 or ho years of data.
Modeling is easier and, if done well, would include more of the things that could occur over dhe plant 's monsible onerating life.
Of course, the weather continues and varies whether nlant operations are nornal or not. NRC staff has not analyzed the effect of weather on nuclear accidents at Harris; see DES. - -
I rely on connon sense, statistical principles re sample sizes (a f ew years ' weather is a smaller sample than 30 or 10 years '
1 weather) and the clinatological records of the US governnent for Raleigh NC (later RDU airport) and other locations.
29-42(c) You could determine these for a 30 to h5 year period (approx) of operation (the latter takes the 40 year nax design life and assunes the second unit cane 5 years after the first) either by fairly detailed analysis of the variables of weather duration and variability of (e.g. as listed off under 29-42(b) above, includingbatmoseheric windso stability and instability conditions) for a nunber of). neriods (you would need about 20 to get a reasonable statistical sannle) of that length (30 to 45 years) for sites similar to Harris, seeing what the naxinun variation was between the extrenes and paitbrns of the weather variables (all of then) between several 5-year' (or so) periods at each such site and the longer
' peri $d s extrenes and patterns, and nake a model that adjusts your site data to give effect to the greater variations to be expected over a 30 ro h5 year period, taking the greater variations that . night be anticipated (e.g. to a nrobability of less than one occurrence in 100 such veriods), and that would give you a reasonable nodel of "all the neteorological variations that could be exuected m
during the tern of the Harris license". Of course you would also have to consider unusual events like the double hurricane of 1916
~
~ which ficoded' Western NC. I don't know how long it would take you
. to do that. The only real alternative, though, is to collect data for 30 to 45 years.
29-43 (a) Answering hynothetically, as you ask (i.e. under your assunctions), the plune starts at ground level. Thus it
'annot c (at the start) in a real situation be " brought to ground level" m
nyre cohesively than just stadting at heigh zero with no net velocity.
However, becaus e 3he plune may be rained out, and likely will n_ot diffuse to greater width as fast as your nodels assune, it can at jother noints be brought to ground level in a more " cohesive" or j .
~
q /
r -
- f. ,
29-13(a) 4 continued concentrated forn trian 'the m;lel would give at those other points.
In addition, by sinnly diffusing less to the sides as the wind novos it, the plune would cone to ground at points other than the noint of release '(in real situations) nore concentrated (nore
" cohesive" as you say) than under your assunptions about diffusion.
(b) Elenentary: the less the plume spreads, the more cchesive it is, regardless of the starting conditions. Over tine, then, a real ulune spread!ng less fast than the hynothetical plume starting at ground level, can still cone to ground more concentrated. This is a theoretical connon-sense apnraach. For a real situation, the TI-2 Kr-85 (etc) releases had a vertical comonent of notion and a release point about as tall as containnent there. Nevertheless, these plunes cane to ground in terrain (a river valley and rolling hills) nbt dissinilar to that arotad Harris, in much more concentrated form
(" cohesive") than NRC nodels Annlicants use did or would predict.
That's reality, with the plune starting conditions realistic ina.tead of ground-level zero-velocity (which night be annronriate for sone neltdown scenarios where the release cones out from the ground, though real zero-velocity can't be had in reality if the plume gets into the azir, i.e. it nust nove to get there).
8-19 TMI plune. Pisello study: copy of study has not yet arrived.
Will resnond;then. For reference see 29-77 resnonse (or update l if article does not arrive by due date of these interrogatories).
l I've not conpletely analyzed this issue, having niles of l information from Annlicants about disnersion, nodeling, diffusion and neteorology. While I can't be required to research it to answer this interrogatory, additional info recconsive to this l questien will be provided as a supolenent.
l (c) The diffusion models could be inadequate even if the initial l
conditions you assume are correct. Since they do not annly (see (a) and (b) above) this question is not annlicable, and nisleading.
29-h4(a) If the release were really at ground level, notion of air around the structure near ground level (where friction with wind is greatest) could turbulate the release and spread it faster than a release diffusing at dae sane rate but from a higher noint. See also resconses to 29-43(a) and (b) above which exclain how the plune of a real releast could be more concentrated or cohesive than a hycothetical ground-level release due to slower real diffusion, rainout, etc.
(b)The curving winds around the base of structures are shown in actual tests and wi nd tunnel nodeling in documents the Aeolicants sunnlied to ne. I can't recall which ones and it's burdensone to search then out of the hundreds of docunents I got on disnersicn etc (Eddlenan 60). If I can find then, I will suoplement this resconse, but it is information Anolicants already ,
have because I got it from then. h/M IE b M [
For disnersion being able to be less than nodeled in weal situations, see Richard H. Thuillier, Discersion Characteristics in the Lee of Ccnolex Structures, J. Air Follution Control Assn
(? nonth, 1982, at p.526). I thought I had a copy, but can only locate the first page right now. See also Pisello TMI study, cited above.
29-45(a) " Washout" or rainout would bring down virtually the entire radioiodine contents of a olune, and entrain gaseous nuclides that decay into radiciodines, washing out E0I, narticulates, organic iodines not entrained (largely if not fully washed out),
and aerosols. An example is a thunderstorn or a steady vain with significant rainfall. Aeplicants say the cartition coefficient for radiciodines fron air to water is 10,000 to 1. I have filed discovery nyself to get a cite on that nunber.
' G O
29-45(b) BN_L 3391, CP&L Document coo 0k7, neteorological study for the original Brookhaven Reeort (WASH 740?), " Diffusion and Denosition in Relation to Reactor Safety Problens" by Smith & Singer (1957), says rainout is incortant in estinating how much radioactivity will reach neople (and crors) on One ground.
See at 10-12. At tage 16, it says " light rainfall . . . greatly increases denosition close to the source" and "usually extends the isolines of significant contanination to much larger distances than would be the case in dry weather." Table VI gives sone denosition data for small particles.
See also CP&L document #000135, Lectures on Air Vollution Modeling, Chanter 7 beginning page 228, see esuecially at 235) ' !-
238 re limits of s tudies, difficulties o modeling rainaut.
The sources sneak pretty well for thennselves, but the downwash (entrainnent) effect for gases and earticles requires some knowledge of thysics, and dissolution of gases, aerosols and narticles not entrained is basic nhysical chenistry.
29-46(a) Because they don't use rainout in their nodels.
l BNL-3391, cited above re 29-h5(b), exclains why such nodeling is needed to account for health effects below the niune. Particularly for Anoendix I, where a naxinun exnosure to any individual is involved, rainout or " washout" effects can be critical, by i brir]%ng higher concentrations of nuclides (e.g. radiciodine and nuclides that can decay into radiciodines) to the nerson, 1
their food supply, and their air during and after a rain (gases, narticles, radioiodines on/in particles that dry out and become j
airborne af ter a rain, e.g. for someone gardening, earticles they j
s tir up in digging, weeding, cultivating, plowing, ricking, walking, e tc.
l
O s)> (~
29-46(b) Applicants' own answer that the, don't include rainout in their nodels (they 1ater clain to include dry denosit'on, but that's not rainout in ny terns); sources cited under 29-h5(b) above; NFC translation $20; for particles and gaseous inhalation risk, see Gofman, Radiation and Human Health. Radiciodine denosition on vegetables, getting into various good foods, see LEAF study (Methodologies for the Study of LowaLevel Radiation),
LAND Educational Associates Foundation, Stevens Point, WI I. I have located a full cony of the sunnary of this study, entitled " Nuclear Waste: Tino Bonb in our Bones", which I will sunn17 for insne ction
& conying. Also see NRC trans. 520 for radiciodine nathways through air and food. Analysis of this issue not complete vet.
29-47(a) I an unable to snecify all such variations.
OBJECTION: To doing research Anplicants can do themselves. I exnlain what kinds of variations are involved, includir,g unusual events, in responses to 29-k1 and 29-42 above.
(b) B asis, see answer to . 29-h2(a) & (b) & (c) above.
It 's really silly to think you have as nuch variation in about 5 years as you could have in 30 or 45 tilLO I* 4 E 29-k8./ S CCYes, wet denosition or " washout" renoves radioactive material from a cloud, and nuts it on the ground, mixed with water or snow or ice, etc. Assuming ground level releases (of a clo_,ud of radioactive material), sone of it would diffuse up and some outward (sideways), and if it weren't rained out on-site, the whole cloud (less whatever had denosited on the ground as it noved by wind or diffusion across the site fron ground level) would be available to be rained out at any niace across (beyond) the site boundary.
A thunderstorn, a storn or rain nassing by the site, a xxxnxx scuall, hails $prn or ice storn, freezing rain, snow, etc could do th is .
I see no reason to assume a real groundlevel release only, when virtually all the real release noints are at elevations above ground.
. . . - = __
29-49 (a) It can. It will, given (a) longer neriods of inversion, (b) nore thunderstorns (nore raincut) (c) nore snowfall, esnecially steady snowfall or wet flakes (d) nore freezing rain (e) nove hail (f) nore fog (water absorbing radiciodines) (g) nore downxdrafts (h) other variations not yet analysed: analysis is inconnlete.
(b) Inversions increase concentrations of pollutants under then. This is elementary air collution/neteorology and is pointed out in many documents trovided ne by CV&L re Eddlenan 80.
I really don't have time to dig out cites for you now, but the fact is well known and is in those documents. (b),(c),(d),(e)
All these things cause rainout. Nucleation and accretion of drops, hailstones, ice crystals, snowflakes absorb carticulates from air; downward notion of precipitation increases deposition and entrainnent.
3NL-3391, CP&L Document 0000k7, explains some of this; the rest is scattered throughout documents CP&L has provided to ne and other documents which are accunulated knowledge but which it would be burdensone to search out references in.
(c) Answer to (a) is affirnative. Further analysis inconnlete.
29 '.50. Apolicants, in onnosing admission of Eddlenan contention 1h2, Said that the conditions at a flat-terrain site such as RDU airuort were not related to those in hilly terrain like that around the Earris plant. If these variations were not
" considerable", Applicants ' objection wouldn't be very truthful.
See also the docunents Applicants have nrovided re simulation and neteorology of rolling and hilly and uneven terrain, re Eddlenan 80 (burdensone for me to dig out all the info, and Apulicants possess it anyway, since I got it from then). Applicants ' site data is auparently just from one point (FSAR section 2) and can't account for variations around it. Applicants ' data also enly covers about 3 years as they use it in atmosrheric analysis. (See FSAR 2) uhich doesn't cover anything like the tine needed for plant clained lifetimes of 25 years or more. Extrene weather in FSAR 2 not used in diso, nodel.
Q r
Q 29-51(a) Yes.
(b) I have no nerdentage in nind, although I'd say over 10% above is " considerably" higher. In the case of rainout, though, the concentrations could be nany tines higher than predicted by sinnie diffusion nodeling (even including dry derosition), and even without rainout, the niune not disnersing as nuch as modeled, and running into a hillside or coning down to earth due to variation in wind, could " nile up" the conneentrations of radiciodine delivered to an area or group of people or garden (etc). "Considerabiny higher" thus has a very high upper range.
(c) Variations in wind and weather can bring the ulune to earth in hilly terrain (or even flat terrain) by carrying it into dhe ground or into a line or edge of a stand of g trees, into the sides of buildings, or by rainout. See resnonse to 29-45(a) and (b) and 29-h6(a) and (b) above for why concontrations would be higher.
(d) (b) asks ny oninion. See answers cited for other authorities.
(e) Ancwer to (a ) is affirnative.
29-52. OBJECTION. Thie question is overly broad in the extreme.
all I don't even know the uses Apnlicants are naking of SENPP site neteorological data. I have critiqued their nodels and data l
in other resconses and Arnlicants can sunnarize that as readily l
l l
as I can. I an not required to act as their secretary. See answers to specific questions, e.g. 29-h1 thru $1 above, for l
snecific disagreenents. There are urobably others, but I don't have to dig then out when I don 't even krow what they are doing with the data.
29-53 Asked and answered as to Innoundnent nodels (p.12-13 ) (h-22 s3 ) .
l For dilution, the nodels are for discharges into a river, and say they are for high-velocity discharges. There are nodels referenced, l - -.- - _ _ , _ . - - _ _ __ - _ _ _ _ _ .
~
~
29-53 continued but not given in the Reg. Guide , which may or may not be annliacable.
I do not possess these and have not reviewed then.
To continue briefly, the Harris lake is not a non-tidal river of an ocean or Great Lake (nodels of RG 1.113 pp h-11; it is not an open coast (ibid pp 11-16) or an estuary (pp 17 -25). Thusk, none of these nodels apnly to Harris. The impoundment models (ibid pp 26-h0) are shown to be inannlicable for Harrisin h-22-823, for the reasons stated.
How can you use a one-dinensional nodel for a 3-D lake? The Staff used a cooling nodel involving vertical as well as horizonatal water notion in the DES, and Aunlicants did not object to it as far as I know. (Indeed, they adopted the cosition that Staff was correct, when they onnosed ad11csion of Eddleman contentions 85 and 66 after the DES was issued.) The stratified model (nn3k- 7) is anpropriate (not so w arris)(see 37).
whereThe the lake wateris use downstream nodels of the discharge (pp 41-kh) nay have sone analication I haven't analyzed then in any detail (that's research)(I'm not required to do detailed studies in answering interrogatories).
But I do note that the annual average concentration (Fig 17, pl.113-h3) annears to underestinate the actual average of daily and nonthly concentrations.
& transnort Sedinent uptake nodels (nn kh-h5 of CG 1.113) is nainly a It says "until discussion of how MRC doesn't have models of this.
reliable nodels becone available," the Staff will rely on field core"Itants' studies & their & ._ J exce-lence. "No nodel"cannot be an "ap ropriate" nodel.
29-54(a) The completely nixed nodel (unrealistic in the extrene; it assunos instant dilution throughout the lake for is what Apolicants have used. See ER 5.2.2.1, radiciodines) page 5.2.2-1 ( Andt 4) (double checked at Raleigh LPDR 8-18-83).
~
29-5h continued R.G. 1.113 itself says (page 1.113-30) that the " completely mixed nodel (see Figure 8) is adequate for substances with long half lives". This is the loop nodel, as you can see fron Fig. 8.
No other nodel of RG 1.113 has the nane " completely nixed loop nodel" but it is the tank nodel because the loop shows blowdown in and punping out (see RG 1.113 Fig 8).
The only long-lived (extrenely long) radiciodine is I-129, which Aonlicants ignore. Shorter-lived radiciodines, like I-131 and 133, are by RG 1.113's own statenent not annronriately handled by the nodel Annlicants have used,(as Applicants say in ER 5.2.P.1)
(b) see above re (a) and see R.G.1.113 (a) 29-55 'dhile a simple nodel can give good results if correctly used, these nodels ignore bioconcentration effedts IN release the lake, the actual disnersion from the siteg do not handle sedinent at all, and are not applicable to the Harris plant (see resnonse to 29-53 and 29-54 above). These conditions preclude an accurate estimate, because how can you have an accurate estinate from an inapplicable nodel hd. d$o + (A d h Z P f 6 M b (b) See response to (a) above and resnonses cited in it.
29-56(a) Analysis is inconplete. Iodine is biochenicallyactive and this activity nay invalidate RG 1113 estinates even where those estinates (hypothetically) were valid. Chenical and biochenical interactions can produce effects that nhysical nodels would not credict at all, and the Harris lake will be an environnent of chenical and biochenical activity, e specially in photosynthesis, str decay, and organic chent ay in w ater. Really, nore analysis is needed. I'll see if " George Goe" can do sone,
~
29-56(a) continued It is nost important to note that this question is answered hypothetically since the RG 1.113 models are not annlicable for radiciodines (excent maybe I-129, which Apolicants say they ignore in dose calculations anyway) at Harris. (I-1P9 should of course be included in such estinates, but it is only one of the nuclides involved).
J{ A further reason the RG 1.113 nodels are inapplicable is that they take no account of added radioiodines from decay of other isotopes into radiciodines.
(b) See resconse to (a) above and 29-$h and 29-55 and all things cited in all of them.
29-57 The underwater release point (it's ER 5.2.1.P.1 --
there is no FSAR 5.2.1.2.1 and FSAR 5.P.1.2. concerns reactor vessel code compliance. Note that I answer anyway -- not dodging the question) is at a point where the lake is deep enough that stratification would be expected to occur. Thus, (1) warm releases containing radiciodines could disrupt the stratification and burst through to the unter layers of the lake or to the surface, and (2) annual i tunnover would bring up not only current radiciodine releases, l
but sedinents and bioconcentrated radiciodines in decaying natter and organisms. The stratified nodel of RG 1.113 wouldn't be any good for the Harris lake anyway. It says it's a " gross approxination" (p.1.113-34) and assumes conplete nixing of both uoper and lower layers and constant vclune of each. The lower layer at the Harris lake would vary in volune; conplete mixing is an error and lowers the concentration available for biological uptake and chemical reactions. In ny 4-22-83 response, I had overlooked the stratified nodel on page 3h; however, as noted above, it isn't apolicable for accurate deterrinations for EnPrip. It also isn't used for Harris
( as far as I can tell.
l
- = . - - ---
~
29-$8. Analysis is still inconplete. My answen is limited to radiciodines here, but that doesn't nean I endorre any nart of RG 1.109 for other nuclides (necessarily). It's burdensone to re-list ny past challenges. Apolicants nossess then anyway, see e.g. pg.
RG 1.109 (page 1.109-1) assunes that the maximun individual 12 resn.etc exposed has "these characteristics that renrecent the averages for their corresnonding age group in the general ponulation" . In the first place, this could be literally read to reverse the age level specifics (see 2d to last paragraph of text on paEe 1.109-1) to group characteristics. But nore inportantly, it will violate Appendix I's requirements, because the weight, eating habits, activity and so on of individuals vary, and an individual in the maxinun exuosure location could well also have higher a-than average metabolic rate, breathing, activity, contact w/ soil, consunction of food and water, and so on. To assune that the "naxinun" individual is average in all respects is a contradiction in terns and violates Appendix I, IIIAl's requirenent that the estinate of dose be done in a way that it is unlikely to be exceeded when all uncertainties are taken together. Clearly, the variation of individuals from the average can have a significant effect on their dose and dose connitnent (e.g, through the factors discussed above)
(and through others -- analysis inconplete).
The concentration nodels in biota and peorle (ppl.109-7) are subject to flaws identified in 29-12(a) response of ft-22-83 and in NRC translation $20 (see 29-59(a) below also). The nuclide to organ doses are likely subjedt to sinilar fudge factors as identfried in NFC translation $20 and Wash post 11/11/79 (cited under 29-78 below).
The shielding factor does not take into account exnosure to dust and doll and particulates (e.g. coal-fired vower plant nicro- ,
narticulates) carrying radioiodines, nor do the fornulas on pages 6 and 7 and Apnendix d.
29-$8 continued At page 1.109-10, the staff appears to take no position on water use being involved in radio-iodine dose; it ignores rainout.
The modela, again, are the old-fudge-factor type 11/11/79 Wash ?ost and NRC translation $20 point out. A better nodel is that of the LEAF study cited in 11/11/79 post article (29-78 gives cite of article) and nublished in Methodologies for the Study of Low-Level Radiation, but rainout and other factors need to be considered which add to even that dose: air dose, dust / particulate dose, piggy-backing of radiciodines on particles (e.g. coal nicro '
particulates which stay in the lungs). It may also be (it could be read literally into this table) that Staff thinks it's OK to get one 15 nren dose fron air and fcod, and another fron water, from radiolodines. Ap endix A contains the liquid pathway calculat!cns, but the liquid pathway equations are not used in the table on page 10.
(they have nunbe-s.with A's in then; eqs 12,13 and 1h are for air and foods w/o water input).
f The accunulation factors and transwer factors of WG 1.109 are too low in nany cases (see the references and tables in NDC translation $20 for examples and better factors) . The benefit of the doubt should be given to involuntary radiation victins and the environnent by using the highest factors known (see Berte11 "op cit", see 373-15(d)).
Arpendix C of 9G 1.109, page 26, says only elenental iodine is considered. Other forns are nore biologically active. Although it says " wet deposition" is considered, it doesn't say how, and says that " washout" of radiciodines would not be considered at nost sites. CP&L's ER doesn't nention washout and it is not ch ar if " washout or rainout" has been considered for radiciodines
- at Harris. If so, they don't say so in the ER and they should have since this is a plant specific variable.
-} k 29-58 continued l At page 27, RG 1.109 appears to ignore the direct deposition of airborne radiciodines onto stored feeds. The 90 day delay assuned for then is 11 halflives of I-131 which reduces its concentration greatly (by a factor of about 2000: 2 is 20h8).
But actually feed (e.g. hay) is often stored in the open, or in barns exuosed to air circulation and rain denosition on roofs and around the storage site can increase concentrations there in the air and on the ground. Particulates stirred up from the ground or breathed by the aninals or eaten by then are ignored excent as they adhere to feed. These apnly to both neat and milk nathways.
Lose received while gardening, farning, stirring up soil is evidently ignored for hunans. Dose contribution of dirt on hands when eating, dust and dirt particles stirred up in work (e .g. construc tion, outdoor sports , vehicles en dirt or gravel roads, as well as farning and other outdoor work) apnears to b 4 [ ' N 0 6 M k/> 6 I4' N A'['
be ignored.
S ma/1 huIt isn't nentioned.
C h?,,4 L s. tJ M /J6 t, , ? 7 g P4%, s, RG 1.109 itself is the basic authority for this. Halflife of I-131 is basic physical info -- you can look it un. N9C trans. 520 and the 11/11/79 nost article are cited " fully" ureviously a below.
29-$9(a) Yes. There were tests criticized in that articlo, and it says (1) NRC admits the charge about the fraudulent experinents; (22) NRC now acknowledges its safety calculation is based in part on the dubious experinents of the 1950s. See also NRC translation $20 where the experinentally found tranaxfer factors and concentration factors of independent investigators are conpared with those used in US and W Gernan regulatory nodels. URC translation $20 is specifically about the dose hunans really receive. It covers radiciodines in sone detail. You kncw the cite on N9C translatior $20.
(b) neo (a) above. There may be more information to be found.
Analysis not fully cenplete.
29-60 That radiciodine doses to humans can far exccod the limits of Anpendix I when realistic calculations of doses and dose connitnents (NOT including the upper end of all uncertainties as Apnendix I requires, see at III.A.1) are used.
29-61(a) RM $Q-2 and Apnendix I design objectives for radio-iodines are the sane (see RG 1.109 at 10) except RM $0-2 requires a limit of 1 curie per year per reactor on I-131 releases. Part C of RM-50-2 appears to contradict part A.1 which limits total dose
- or dose connitnent to "any organ" or the " total body" to 5 milliren.
Part C allows 15 to an organ or total body from narticulate radio-lodines alone. CP&L hasn't submitted any of the analyisis which would be required under paragraph C.3 of PM $0-2. The C.1 limits apnly to the total enitted by all reactors at a site.
CP&L appears to have calculated releases for one unit only.
(See FSAR 11.1.2) 'Jhile this nay be a " leak" of the likelihood that everything excent Unit 1 will be cancelled, it nay be an error also. l RM $0-2 part B does not apply to racioiodines sixxn with half-lives of less than or equal to one year.
I an not sure Waen the Harris CP was docketed. If it was before Jan 2,1971 (date of docketing for CP annlication) RM-50-2 would not apply at all to Harris. Since it says that if RM-50-2 applies (see Appendix I, II.D, p469 in 1983 edition of rules),
the " Guides" on Design Objectives (enphasis added) nust be satisfied, it appears that the stricter 11 nit of RM-50-2 A ($ nren per year to any organ or total body from all sources conbined, not just radiciodines) would have to be complied with if RM-50-2 were used.
That is, radiciodine dose from all types would have to be under 5 nren nas I have sunnarized what I do know about apnlicabinility of RM-50-2 to Harris, but within the limits set out above, I don't know if Harris qualifies for the exemption or not (to use EM $0-2). It only could Then itif th C annlica wou9.dn{t be mangign werenor docketed between 3 '
a cry, would it excent1-21-71 and June fron parts A ,3,& C.76. '
lf--
29-61(b). Harris nust s till comply with carts A, B, and C of 10 part II, and section III CFR Appendix I; RM $0-2 only gets you out of Annendix I tant II section D. Therefore, the answer to (a) construed as asking about all of annendix I is "No" and the basis fon this answer and for discussion under (a) above is Annendix I itself.
29-62(a) I rechecked this Table in the updated ER (Table 5.2.5-2) 6-18-83 I copied it and the section surrounding it, inter alia.
It does not conply with RM $0-2. It gives NO radiciodine estinate (Scopied page is from Anendnent 4); it says the linit to any organ is 15 nren a year, ac tually it is 5 (see RM $0-2 at A.1, p.k71 of 1983 edition of 10 CFR). The SENPP calculated exnosure given for maxinun dose to any organ for all pathways is 5.2 n en (out of conpliance, 5.2 is more unan 5), just for gaseous effluents.
If liquids were added in, the total could be up to 7 36 nren/yr vs. a $ linit, in RM $0-2. The lack of radiciodine dose estinates shows noncompliance with Apnendix I. Now, nind you, conn 11ance with RM-50-2 is NOT conn 11ance with Annendix I. It just cot:Id (see 29-61(a) and (b) resconses above) avoid conpliance with 1 criterion in ^puendix I, namely II.D cost-benefit calculation.
29-62(b) Ecok at Apnendix I and RM $0-2, please. Then connare with the table. As an undate to 29-15(b) of h-22-83, Annendix I is anparently not being used in Table $.2.5-2. It linits total pa5fDLei dose to 3 nren whole body or 10 nren to any organ, and the table Ut6 d 13ut C2 doesn't . The table doesn't include radioQ iodine indenendent dose estinates.
29-63(a) See above resnonses re radiolod'ne underestinates.
The table, nore correctly, does not apnear to include radio-lodines a t all.
(b) I don't know if it has to go into that table, but an accurate radiciodine estimate complying with Annendix I as
29-63(b) continued
[f )~' i (all, inel esp 29-18, 19 and 20) detailed in responses above (and below, e.g. 29-71,72,7h, analysis when completed re 29-73, and 29-53 thra 29-6h above, and others, see e.g. 29-69 and 29-70 and citations therein and cites in their citatinns). You sinoly have to conply with Anvendix I, and in ny responses ir Sae last set and this set (throughout) re Eddleman 29 I an exnlaning what you need to do and take account of to produce an estimate in conpliance with that Appendix and particulably III.A.1 thereof which requires an estinate by a nethod such that the dose is unlikely to be significantly exceeded by any individual when all uncertainties are taken into a ccount.
Analysis is, of course, still inconnlete on some natte"s related to this.
29-64(a) Read literally, this would ask if the Table is so radioactive it exceeds the dose guidelines of Appendix I.
I believe you mean, do the estinates in the table (ER 5.2.5-2) exceed dose guidelines in Aenendix I. First, the estinates aren't made in a way that conplies with Appendix I (see, e.g. response to 29-63(b) and cites therein, above; reso to 29-18, 19,20) so the question is basically irrelevant to the contention.
The table dose not include radiolodine doses. Annendix D and RM 50-2's limits are not conplied with in any way, e.g. the 5 nrem total-dose limit of RM 50-2A is exceeded.
(b) The table,ER 5.2.5-2; Anvendix I including RM 50-2.
Do I need to cito a book of arithmetic or will you accent that 5.2 is bi6Cer than 5? (Sorry, this fully business is often a silly question for citing elenentary facts, and provokes sinilar answers for .
such.) Please note that analysis is incomplete and nore info nay be produced.
L/ 3 -
UPDATE to 29-5k8. Rain and precinitation a re significant at and around the Harris site. No rain data was used in analysis of noteorriogy (FSAR 2 3 3 2 at nage 2.3.3-3, Andt 1, LPDR FSAR cocy 8-18-83); but nost days have nensurable precinitation at airnorts over the general area of the State of NC near Harris.
See FRAR Table 2 3 2-20 page 2 3 2-53 for closest exannie, FDU.
Greensboro and Charlotte are likewise.
29-65 Analysis is inconnlete, see 29-63(b) above for critiques.
ER 5.2 decends on Reg Guide 1.109 (see at 5.2.0-1) for human d_oses.
3 iota doses not yet analysed (5.2.1.1). The updated ER (8-18-83) refers for humans (5.2.1.2 at page 5.2.1-2) to a f!gure 5.P.1-3 which isn't there. The discharge fron the reservoir is about lo billion gallons a year (relevant to 83/8E also, count this as a sunnlenent re them) . Gardens other than the nearest are not taken into account. The assunption re collards (5.2.1.2.1) underestinates dose, particularly for things derositing on then, like radioicdines. People can eat nore collards d:an you assune.
A naxinum individual taking all uncertainties into account, surely would.
Section 5.2.2 (see also all other e resnonses in this set)
% Idaccwafe
- Louyecheb-SOwce NPft INYo .hwH""> U h depends on (1) )underestinate of release of radiciodines and nuclides #FJ4g that decay into daem (2) underestinate through faulty noteoroglogical nodels (3) insufficient variation of noteorological data ($k) overestinates of dilution and dispersion (5) ignoring particulates in air that pick up radionuclides (6) ignoring dust stir-up and outdoor work as sources of exposure (7) all criticized flaws in RG 1.109 (8) cl1 criticized flaws in 'G 1.113 (9) underestinate of bloconcentration of nuclides (10) underestinate of transfer of nuclides (see NRC trans $20)(for 9,10,7 esp); (11) inaccurate
29-65 continued nodel of liquid radwaste in the reservoir (12) inaccurate source terms (13) assunption of complete nixing in the reservoir (1h) ignoring bloconcentration in the reservoir for exnosure to hunans from swinning and drinking (15) aquatic food nodels not assuning fish and biota are fron near the discharge point of liquids, but near the plant instead. Air done to fish is not much; the liquids do the dana 6e. (5.P.2.1 3 of ER, reference) (16) inaccurate estinates of dilution to critical recentor locations (Table 5.2.P-1.)
(17) Inaccurate radiciodine estinates (Table 5.2.2-P) for on-ground and in-hnvegetation. The vegetation has less than the ground, though it could and alnost certainly would have radiciodines depesited ON it too. See NRC translation $20 and Wash Fast 11/11/79 article for description of why this sofrt of estinate is wrong.
The extent of these errors has not generally been numerically evaluated yet. That is research, which I'm not required to do to answer an interrogatory. As pointed out above (all resnonses to specific questiens about nodels and data in this set are responsive to this question. I incl ude dr.en all by reference here, questicn and answer to each, entire, with any suuplements made later also incornorated), the rainout effect alone cah nroduce nuch higher radiciodine concentrations where people would be exposed to then through ground, air, stirred up dustk, and food, e.g. working in their gardens after a rainout onto the garden. Other info received has not been reviewed in detail vs. 29-11 response and analysis of it remains incomplete.
This response does take into account the info received, but not all of it, and it is impossible to separate out in detail what has and has not been considered so far. All of it has been read.
bf 29-66(a) It is annropriate because Appendix I calls for nodeling in such a way that the estinated dose is unlikely to be exceeded when all uncertainties are taken into account. The way to do that is to take all the uncertainties on the high side, i.e. to use the highest known transfer and deposition factors.
(b) Look at NPC translation 520 : The use of lower factors biases the estinated doses low. See also 10 CFR 50 Annendix I f t+oo + T 22 : geg 39 4 f 2 2 Yh?!F3 section IIIA1. See also Berte11, on cit (see resnonse to 373-15(d) herein, citing p.17 response to G-$a h-22-83 re 29 and 373, for%ite) v aAs to why it is anpropriate to use the high effect estinates when dealing with risks like radiation. I also think it is just are irreversible and good sense to estinate risks conservatively when theygnay be bigger than you think they are. The conservative estinate is then to take a high estinate of the risk. Once neerle absorb the radiciodines, they're stuck with the resulting effects no matter how wrong the estimate night be. If you overestimated the effect, they get less harn than you expect, and tha t 's go od .
If you underestinated the effect, they, like the victins of agont Orgnge and nuclear weapons testing, are justifiab17 Eoing to conplain that they were used and lied to about the risks.
W hen you are inposing a risk on ueople, it is rarticularly appropriate to estinate the risk high, and reduce it as nuch as you can, as a natter of ethics. Since the people are given no choice in accepting the risks, the estinates given then of the risk imposed should be the high ones -- those unlikely to be exceeded, as Apnendix I requires.
As to authorities on which I rely for ethics, as regards this natter the Golden Fule is aperopriate: Do unto others as you would have then do unto you, or in another forn, do not do to others what you would not want then to do to you.
.__. __ . r _. _ :
s _
g ths "r"~was x'd out. ._
29-67 "Evapotransipirati.on" is a tyno -- an extra "1" -- for "Evanotranspirttion", which is the release of water vapor into the air by evaporation and by transniration by plants.
The resnonse to 29-17(4-22-83at17)saysthatevapo-transpiration should be fully factored into an analysis of radio-or other radiciodine fow iodine untake. Evaporation of water containing HOI would concentrate h then. Transniration of water containing radiciodines by nlants would increase the flow of radiciodines into the plants and perhans release into the air (this last, I'm not sure of). There are high evapotranspiration rates in areas near Harris. It's another source of noisture for washout. Note the high frequency of scne rainfall at RDU airport, FSAR Table 2.3.P-20 at rage 2 3 2-58 M
29-68(a) Asked and answered above re " washout" (and " rainout"),
(ii)re changes in land use, the nore use that b=ings gardens, food crons,
' people and aninals near Harris (e.g. folks fool enough to indulge in recreation, hunting and fishing near the plant, swinning in the lake, boating on it, etc), the nore exposure is nossible and the higher doses these folks can receive from being there, crops, gardening, outdoor activity, and so on. Even RG 1.109 sunnorts this.
(iii) growth in surroudding nunicipalisties, nore people to be f exposed, more parking lots and flat areas and roofs for rainout to fall on and be funther concentrated in runoff, e .g. into gardens
! (iv) l near houses, into creeks, sewers, water supulies, wells. (k) soil l
perneability, see NRC translation 520 Intensive gardening and any cultivation increase soil perneability and allow nore untake and biological interaction and chenical interaction with radionuclides.
See Wash Post 11/11/79, NRC translation $20.
(v) internal radiation: obviously, the more radionuclides absorbed, i the higher the internal dose. See NRC translation 520, Gofnan 81 Radiation & Hunan Health, etc.
C 29-68(a) continu3d (vi) evapotranspiration ("evaportransipibation, which is an error in retranscribing your error in transcribing ny typo for this word),
see e.g. 29-67 above; (vii) "all nossible release and uptake nathways",
Aprendix I is basis, you need to because wherever radionuclides can go and be uptaken, they will be. Appendix I requires an estinate including all possible pathways, not just nost of then.
Further analysis is inconplete on all these issues.
(b) In addition to the above, see all answers to your more specific questions on these points above and .below in this setz, and see previous set of resnonses 4-22-83. Burdensone to relist here.
You can find Eben as easily as I can, axinx actually easier because there's only one of ne and you can assign lots of neonle to do it.
29-69(a) Analysis is incomplete. Where I know a better nodel, I have suggested it. NRC translation $20 is one good starting noint for doses, but more needs to be done (as noted above in other resnonses) to handle dose effects it doesn't capture.
"' rainout" is a catastrephe phenonenon and ordinary equations wouldn't handle it all that well; " washout" you nay define differently, but I take it as rainout, i.e. beyond RG 1.109's " washout".
In general, upper limit assunptions on all these ' issues should be used to include all uncertaxinties (per requirenent of Appendix I).
I have not found equations or fornulae for most of these (none in mind) .
(b) Basic authority is Appendix I. See also NPC translation $20, and natters cited in resnonse to other interrogatories herein on all these natters. Applicants can compile this info fron ny other reanonses as readily (or nore readily -- see P9-68(b)) than I can.
29-79(a) Analysis incomnlete. However, see rennonses to 29-h7, 29-41,k2,k3,hh,h5,E6,h8,h9,50,51,5P,68,69 etc. Need to take all possible variatiens into account is established by Ap-endix I which requires a nodel that calculates taking all uncertainties into account.
Al (b)Se (&cSes cJelw d 4tes w he (c)A urch pae reat@0) c @ w/ M .T see n9-ls
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29-71. Of Course. That'swhatAgendixI,sectionIII.A.1, requires. When you say "regardless of the probability of occurrence",
I presume you mean, regardless of estinates of the probability .of occurrence. Nobody knows the true probability of thinge that haven't happened yet, and the nuclear industry has a talent for underestinating.
See, e.g., TMI-2 accident, UCS Critique of (WASH-1400) Reactor Safety Study, etc. What would you have said in January 1983 was the probability of NC State's men's basketball team winning the NCAA championship after Whittenburg was injured? Estinated erobabilittes are basically worthless when you're looking for results "unlikely to be significantly exceeded", as Apnendix I requires. "all uncertainties
" in the language of Appendix I, surely inclu des " improbable" events.
29-72(a). There nay be more factors. Appendix I, section III.A.1, requires an estinate nade in such a way that it is unlikely to be signiff ?antly exceeded when all uncertainties are taken together.
Thus, those factors, and perhaps others (analysis still not fully complete) need to be taken into account.
(b) Asked and answered,e.g. re 29-68(a). Annendix I, III.A.1; Berte11 "op cit" at 400 and 922 (cite given under 37B-15(d)) for why you need to give the benefit of the doubt to the high estinates for risks like radiati on exuosure. NRC translation 520 shows higher intake of radiciodines than NRC nodels predict. That's an uncertainty you have to take into account under Appendix I, III.A.1. And so on.
This is really answered in detail re questions above.
29-73(a).
My analysis of \S
&eh NUREG-0017 is inconolete.
4 ff (Nc%og 9 Iwes w% & $t h#gg CP&L, in FSAR section 11.1.2,, simply asserts it has used the NUREG-0017 method and gives one table comparing SENPP with NUREG-0017. Nothing is said in that section (or elsewhere in the FSAR and ER to my knowledge, and I've been looking in sone depth) about how the SHNPP narameters and the 0017 assunptions are adjusted to give results. I haven't checked CP&L's work. (, g) analysis (b)(c) not apulicable -- see (a); (d) will sunnlen(en)t whenjis done.
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29-74(a) Yes, although I have not checked most of the ER data versus the sources and other sources yet.
(b) According to ER section 2.1 3, there is no data on gardens except for those which are the nearest ones to the nlant. Thus, garden use is being lef t out of nodels based on the land use dkta.
It also apnears (though the data are not given in the ER) that CP&I. is relying on NC nrojections of nonulation, which have been inaccurate in the nast, e.g. in underestinating growth of the Apex and Cary areas near the plant.
Analysis is inconnlete as noted above.
29-75 As stated in (7) of L-22-83 response (please see 1st 2 lines of nart (7), p.7) it is NU9EG/CR 2877, SAND 81-2613 (August 1982), and the authors (see last line of 7) are Kenneth T. Gillen, Roger L. Clough and Lowell H. Jones. This citation was connlete in the original response.
4-22 83 29-76. As stated, 1st two lines under (8) re G-1(a), pp7 8, it is NUREG/CR 2763, SAND 82-1071 (printed July 1982). A uthors ,
as stated in the last line of naragranh (8) (4-22-83 p.8), are f Gillen, Clough, Ganouna-Cohen, Chenion and Delnas. This citation I was complete in the original response.
29-77 Citation will be nrovided as scon as I have a cony, if pre 8-19 filing deadline for this. f' /et e M kgg l &usamvetuwspwegw m
- V/Washington Poxst, 11/11/79, page B1 and Bh. Colunns not 29-78.
known. Edition not known. I have located a copy and will nake it available to CP&L.
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50-RESPONSES RE 37-B 37-B-7 The " constant and naxinum" R3E (relative biological effectiveness) for causing mutations at low dose rates shows that the RBE for radiation causing mutations is higher at low dose rates, and stays high (i.e. at the sane lovel, high connared to that at higher dose rates) as the dose rate goes lower. The sane total radiation dose, delive"ed at low dose rates, does nore genetic danage.
Many diseases are either genetically caused or have a genetic conponent. As an exanple, there is a genetic co ponent in heart and blood vessel diseases. ( s e e , gene rally , the work of Gofnan on heart disease. I haven't researched it in detail, but know that it establishes this link. I can't cite chanter and verse. )
Moreover, nutations are thought to be causes not only of cancer but of degernerative diseases and the "nrenature aging" effect (a cause of death, i.e. death at an earlier age than a nerson not subject to this radiation effect would have died at).
Mutations also innair general bodily functiening, making the body nore vulnerable to disease and less able to naintain itself.
Radiation particularly can disable or damage the immune sys ten, Icading to higher death rates and worse consecuences of diseases because the innune systen can't fight then as effectively. Constant maxinun RBE means the danage will stay high at low doses of radiation.
Innune systen danage and excitation can increase the risk of a_cquiring allergies.
Cancer, other diseases, allergies and causes of death including heart disease are natters of Eddleman 37B.
You have asked what this constant and naxinun RBE for causing nutation " suggests" to "you". "You" singular means just ne; plural I'd take it to nean ne and any nonwitness exnerts.
I have said what it "neans" because I am unable to answer succinctly or without lots of research what it " suggests". It could "suggest" a virtual- infinity of things.
Re low-dose genetic damage, the letter of I.D.J. Bross, Health Physics 4h:3, 283-285 (March 1983) and sources cited therein (please look at the cites on page 285 if you want to know then),
is also relevant to this n-oblem. Bross has shown that low-dose radiation genetic effects exceed those from high doses.
37-B-8(a) O3JECTION: The conclusions are not snecified, they are not shown to be connected to this contention excent as to estinates of =adiation health offects, and I don't nossess conins of most of BEIR-III, all of UNSCEAR except a few nages, and all of the ICRP's informatien except naybe a co y of a few small papers.
The ICRF has a host of nublications which would annear to fill a library shelf. As to radiation health effects, I have answered many snecific questions about what I think is wrong with the s So that is a redundant question.
BEIR*III and UNSCEAR'extimates. jg As to the rest, to the extent it requires research (I can't say what weight I would give to a docunent or " conclusion" I have not exanined nor exanined the basis of), I object to the question. I'm not reauired to do research for Anplicants' benefit.
The only part of the question not objectionable or redundant per the above is, in effect "Is there any other conclusien of BEIR-III (Committee or reno'rt), ICRP or UNSCEAR which you haven 't given a critique of in answer to previous questions, but which you have exanined and can S i ve (or have an exnert give) a weight to?" and "If so, what is that weight?" . To this I object because the question is vague, overly broad, and unfocused. 'dhat conclusions are being asked about? I haven't made a list of these conclusions and don't nossess them.
(b) Tha answer to (a)(1),(ii), and (iii) is other than "None",
but the questica wrongly implies that if the ueight is other than zero, a portion is conoletely unchallenged. I have not identified a
37-B-8-(b) continued set of " portions" (note that (a) asks about " conclusions",not
" portions") as " unchallenged", but clearly those portions of the facts and conclusinns set forth by BEIR-III, UNSCEAR or ICPP in conclusions or other publications or information on which I have relied or now rely, I do not challenge.
OBJECTIONS: To the forn of the question, which wrongly inclies that a non-zero weight given to any "' conclusion" of the agencies named in Interrogator 7 37-B-8(a) neans that there is therefore an " unchallenged" part. It is possible to give part weight to a conclusion while challenging part of it or part(s) of its basis.
To the burdensone research that would be recuired to dig through all nub 11 cations of the ICRP, BEIR-III, and UUFCEAR which I do not possess, to identify any " portions ... which (I) do not challenge" 37-B -9. It would nake it higher. I have not calculated a nunerical answer or had one calculated, but the increased risk could be an order of nagnitude, perhaps nore, higher, especially when the long-tern genetic consequences of (1) genetically-caused disease (ii) diseases with genetic cenponents (iii) less-than-otherwise achievable performance due to (a) genetic defects (b) increased disease (c) increased accidents and suicides (d) shorter life spans (e) innune disorders and degenerative diseases, (iv) directly caused diseases and disorders and decreased resistance to disease, including those to which radiation centributes, and (v) excess deaths and danage fron prenature aging (vi) excess disease, danage and deaths fron less effective innune systen functioning due to radiation danage, are taken into account over the full period of increased biological risk from the radionuclides
37-B-9 continued to be released in providing fuel for Har"is and operating it (both of which are necessary consecuences of Har=is oneration).
This period, as noted in other responses, is estinated by Prof.
B.L. Cohen, U, Pittsburgh, at 11 nillion years.
37-B-10(a). Yes, in the following sense only:
The risks attributable to radiation from the Shearon Harris facility increase the risk to which " nan" (sic), by which I assune you mean hunan beinga, is subject. The Harris risk is also worse than risks individuals choose to take because it is innosed on norsons*.
However, to assume that if the Harris risk were less than the total of all other risks, it therefore neans that the added risk fron Harris is acceptable because it is less than the total of other risks, or is less than scne other risks, is fallacious.
By that logic, a person who has just excaned being run over by a truck should then sten in front of a bus, then a van, then a big car, then a smaller car, then a small car, then a notorcycle, then a nopend, then a bicycle, because the wisk of being killed or injured by each is less than what was just taken. Likewise, any additional nunber of deaths becomes "accentable" by this logic, since it is less than the number of deaths which would otherwise take place. Murder would be excusable under this logic, since the nunber of deaths is increased only by one for each nurder, which is small conpared to the yearly death toll of sene 2 nillion in the USA and nillions nore worldwide. Attennted nurder and assault with intent to kill, by this logic, are evow nore accentable since the resulting number of deaths is less. Maining, injuring, or disabling peonle is also exc. usable under this logic, since these are"snall"' additions to the toll of nutilation, accidents, injuries and disablements taking place. Under this logic, risk can never be reduced, only increased, and each increase is "accentable".
,now and in the future.
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l 37-B-10(b). .
The answer to 37(B)-10(a) 15 positive. There is no 37-lo(a), but I presume 7ou nean 37-B-10(a).
(a) 37-B-11. There is no net benefit fron electricity that might -
be generated from the Shearon Harris facility. It is not;.needed for peak demands or kWh outuut, as it can be displaced f rom these ,
uses at le y cost than connleting the plant. The entironmental inpact of siternative reans ;to reduce kWh consumption and peak demand to disulace Harris is less than the environnental innact (including the risk to hunan beings) of Harris.
Since there is no net benefit, it vo uld - be invati nal to assune (or accent) any additionni pisk, since the risk brings no benefits and thus is just a straight s increase in risk.
(b) Look at (a). The cuestion presuttes A benefit that (despite the NRC's 3-26-82 " nee:1 for power /citernative energy sources"
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ru1e) coes not actually exist and will not exist. I an answering on. a factual basis as an expert in energy conservation and energy.
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systems. This answer is supnorted also by tthe affidavits of Dr.
G.G. Reeves filed by ne 6-30-83 re' 2.758 petition of Wells Eddlenan, and my affidavit and supporting do'eunents appended thereto, all filed with the petition. Many othen energy experts (e.g. Lovins and Lovins, Roger Sant, W.R.Z. Willey, etc ) sun-ort the basic idea underlying the above, i.e. that least-cos t energy sources should be used first before new powernlants of any sort are built. Given that Harris is not the least-cost source (CP&L Chairnan Sherwood Smith admitted to the 9aleigh, NC, News & Observer in an interview published in June 1982 that if CP&L had to start the Harris uroject ove" again, it would be a coal-fired plant, which is an admission that Harris is not a least-cost energy source even am.ong new power plants), it has no benefits, but only added costs.
c- -.c .
[ 5 , - -
37B-12. Where there is insufficient experimental and actual data to establish risk definitively, the higher est$ nates shon1d be used because they are more conservative, and thus avoid imposing higher risks than were known or assumed. For a good exanple of this in the radiation field, look at nuclear wearons testing by the US government, where low risk guesstinates and oninions ended up exuosing many arned forces personnel and civilians to levels of radiation /Naq1o ctive .v.aterial that resulted in deaths and disease bsvond e'xnectation. Another exannle is lowering exposure
's limits practiced by radiologists.
In a dditions higher radiation risk estinates should be used beenuse -adiation~ risk is beirg found to be higher than thought.
They should also be used because the nuclear indus try and nuclear weanons governments (sud other radiation users) ann 17 strong political pressure to Mininize the harmful effects of radiation,
- resulting in. erroneous estinates, falsified research (e.g. Wash Phst 11/11/79,_ cited under resnonse to 29-78 above), use of low
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valuea fcr radiv.tirn/radioactiva materials (see NRC translation 520 as cited re Joint, II and 37B and 29 nreviously), and higher casualties disease suffering and deaths among unsusnectirg victins.
A fully developed exnlanation of why this sort of thing goes
' on is innossible for ne to write out in any reasonable tine, but it is exnlained fairly well in several books, e.g. Gofman &
Tannlin, Poisoned Power; Tanplin & Gofnan, 'Ponulation Centrol' Through Nuclear Pollution; H. Wasserman et al, Killing Our Own; (author not recalled) Nuclear Witnesses, the Honicker V. Hendrie book and Shut Down (Nuclear Power On Trial), both nublished by The Book Publishing Co.
-126 Drakes Lane, Sumnertown, TN, and in Gorman 1981, Radiat d Hunan Health and Gofnan's sppeches (IRREVY: An Irreverent, Illustrated l
View of Nuclear Power), CNR, Main PO Box 11207, San Francisco CA 94101.
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37-B-12 continued Basically the problen is that unior political, nilitary and econenic pressure, the conservative approach to radiation risks is not used until it is too late (i.e. until the damage becomes obvious). In the case of genetic damage, it may be far too lata by the tine (about 10 generation) that the extent of damage becones nore obvious.
A nore accurate risk benefit assessnent, therefore, is necessary and would be obtained by using higher risk estinates than those used by the nuclear industry, NRC, and the BEIR - III connittee. I have also cited sou"ces in ny "esponse to 37-B-6 which support the view taken there. (4-22-83 resnonse at 22).
37-B-13 I believe these have been given for the conclusions and statenents relied on, nor ny undate. See Radford (the only one BEIRnIII I have a cony of) at 235-36 beginning last paragrarh on 235; alao inmediately above that on 235 (deflating Kellerer-Rossi theory as a counter to linear no-threshold dose-resnonse relationshie); higher offects of low doses are then covered, and the conclusion is that low-dose risk could be underestinated. This if for cancers, but radiation effects of life-shortening, white-cell damage (innune systen) etc are discussed , see e.g. at 23h,230. It is very difficult to separate out all the supnort for 37B in this discussion because the discussion depends on many things. The biological variables (see n 2h9) are innortant to other diseases besides cancer. Radford notes that a life shortening effect in hunans has not been observed, r d.w 1- ra ic( og -f u , (C ee IN S + ead G ee-t g (( ,
23h, but 7 2.wq Qucol og y 9:3ng (t-7 0') ) it would h human lives. But be thismost unethical ofrect to riskindeliberat$1v is observed and the is no reason aninals 23ld orten*nhe
-5 -
37-3-13 continued l to assuno humans are innune to it. Indeed, as Gofnan and others noint out, hunans are among the nost radiosensitive of al' species.
When I get a chance to look at Rossi and "febster I nay be able to provide some further details re their sepnante statements in BEIR-III. I intend to to this in connection with the research i for an undate on carcinogens (Eddlenan 83/84). I haven't had time to go and do this research yet and it is more efficient to do it all at once, 37-3-14(a )I would ornose having 37B censolidated w! th Joint II.
Having to work with other intervenors takes a lot of tine, complicates things enornously, and so on. Also, Ann 11 cants could have stipulated to 373 and refused to, thouEh they did stinulate to Joint II.
If Aonlicents will stinulate that 373 should be litigated, then I might reconsider this nosition. But the burden of going through 3 other intervenors is censiderable to ne since I have so .uch other work to do, in this case and othe" wise.
(b) Look at (a). I also see no useful purpose that consolidation at this late date, af ter goirg through all this discovery separately, would serve. I would have to clear this set and all past responses on 373 with Joint Intervenors, and so on.
It's just a lot of work for ne, with no benefits.
37-B-15(a) I don't recall specifically. If I had I would have l Berte11, J. Sur 379 (1977) said. The pape=s cited under G-$5(a)g. inC.icol. h-22-resnonse, 9: and under l 373-2 (p.20) by 3ross & Driscoll, Morgan (K.Z. ), and a p aper i
by J. Rotblat in the sano issue of Bulletin of the Atonic Scientists i
that Morgan's paper on Low-Level Radiation anneared in, are my best l recollection of the ones; there were probably sone others but I don't recall which.
-5t-37-B-15 (ab) I have no better cite in ny notes. This is a book collecting papers; it is in the UNC-Chapel Hill Health Sciences Libvary and I don't possess a cony. You can look it up as easily as I can, but I've made a note to do so the next time I'm over there.
(c)37(B)-h(b) resnonse (h-22-83 at 21). Look at the cites in the Bross-Driscoli and Bettell papers cited under 37-B-2 on p.20.
The Mancuso-Stewart-Kneale studies of Hanford workens are well known and show a hi 6her risk of low-level radiation errosure.
(d) "Berte11 op Cit" is given under G-$(a) on page 17 of 4-22 resconse. Co pare response to 37-B-2 at 20 where Bente11 on cit is given in sone nore detail. (Line 6 on that page should begin "921,922 (no threshold f or health effects )") . This is the only Berte11 paper cited which has page nunbers in it (and response to it) of 400 and 922.
PRODUCTION OF DOC M UTS See 1st paragranh on rage 1, supra.
CERTIF~CATE of NEGOTIATIONS I advised Applicants' attorney Baxter on 8-17 that I might not be able to finish these resnonses 8-19. I called hin again that day and described my objections to general interrogatories and specific objections as to breadth, vagueness, recuiring ne to do research. We did not nake any progress but he agreed to consider then when he sees then (sinilar to Applicants' h 8 83 negotiat!cn w/ne re their earlier re onses to ny 1st set of interrogatories). b P e / Lts e_2. G T r'ltuv CtJe d* <x+6fJQoM ~TW ff e M//*7 p%cse Cd CCPm+ed GN edemsrcw 1t%sleJ +u &
1 f-19 +30f % (N % arlfMt Mght.
I hereby affirn that the above certificate of negotiations Tf)1 hC14 ci and responses to interaceatories are true to the best of ny g/c/c-u present knowledge and befief. // s t Ff o fe 4 ttf % Y g g ,p y p/f-f3 Wells Eddlenan fJgg
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