ML20081H622

Statement of Matl Facts as to Which There Is No Genuine Issue Re Motion for Summary Disposition of Contention 8F

ML20081H622
Person / Time
Site:	Harris
Issue date:	11/02/1983
From:	Oneill J CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20081H118	List: ML20081H116 ML20081H137 ML20081H141 ML20081H622 ML20081H641
References
ISSUANCES-OL, NUDOCS 8311070529
Download: ML20081H622 (4)

Text

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's UNITED STATES OF AMERICA SfggIEO NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOAfb NOV -4 A;; :j; CFFICE 07 Sgcgy,,n ,

DOCKETING & SEpyy;r' In the Matter of ) BRANCH

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CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL and NORTH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )

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(Shearon Harris Nuclear Power )

Plant, Units 1 and 2)

APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD ON WELLS EDDLEMAN'S CONTENTION 8F (2)

Pursuant to 10 C.F.R. S 2.749 (a) , Applicants state, in support of their Motion for Summary Disposition of Wells Eddleman's Contention 8F (2) in this proceeding, that there is no genuine issue to be heard with respect to the following material facts:

1. The NRC Staff's assessment of the health effects of the radiological effluents specified in Table S-3 asset forth in the Draft Environmental Impact Statement (" DES") for the Shearon Harris Nuclear Power Plant is adequate.

2. The DES does not consider health effects for too short a period of time. Contrary to Mr. Eddleman's .

contention, health effects need not be considered over thousands and millions of years.

3. The food chain concentration _ analyses:.used to calculate dose from the.. uranium. fuel. cycle.in_the_ DES _are not wrong.

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4. Radiation doses from internal and external emitters are not underestimated in calculating the dose from radionuclide releases from the uranium fuel cycle.

5. The 100-year and 1000-year periods used by the NRC Staff in calculating the dose and health effects from the uranium fuel cycle in the DES are appropriate because: (a) short-lived radionuclides like tritium, Kr-85 and I-131 will decay to negligible levels within that period, and (b) radionuclides deposited onto the soil or into surface waters will become relatively unavailable to the biosphere through processes such as sedimentation, migration below the root zone, and transport to the deep ocean.

6. Because of the processes discussed in statement 5 above, the dose delivered to population from radionuclide releases from the uranium fuel cycle will decline as a function of time. As a resu,lt, the ratio of the dose commitment from the releases from the uranium fuel cycle to the dose commitment from background radiation over the same period of time will continualy decrease.

7. The NRC Staff analysis in the DES for dose calculation and health effects from the uranium fuel cycle expressly assumes no development in the prevention and cure of disease. It would be absurd to presume that there will

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be no advances in medical science for hundreds or thousands of years and such an assumption is clearly conservative.

8. Environmental transfer factors used by the NRC Staff to determine the concentrations of radionuclides in foods are based on empirical data.

9. Natural settings and materials obtained from the natural environment were used to measure concentration of radionuclides and stable elements in plants and soils; no artificial selection was involved.

10. Internal dose conversion factors are obtained from observed behavior of radionuclides in man and animals.

11. External dose conversion factors used by the NRC Staff were obtained from mathematical models. Recent studies reveal that the dose conversion factors used by the NRC Staff are conservative.

12. A review of the most recent literature regarding studies of the parameters used in dose calculations reveal that many of the parameters used by the NRC Staff in its 1976 analysis of the uranium fuel cycle remain unchanged while some have increased and others have decreased.

13. The NRC Staff's estimates in the DES of dose and health effects for the uranium fuel cycle are reasonable and have not been underestimated.

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l l 14. The NRC Staff's estimates of dose and health effects

! from radionuclide releases from the uranium fuel cycle have been confirmed by the independent analyses of Dr. Mauro and Mr. Michlewicz.

15. NRC Translation 520 (the so-called "Heidelberg Report") has been thoroughly discredited by the scientific community.

16. Even if the environmental transfer factors and dose conversion factors recommended in NRC Translation 520 are used to calculate the dose and health effects from the uranium fuel cycle for a 100-year and 1000-year l

period, population dose still remains extremely small compared to background radiation dose and the calculated health effects are still less than one cancer death per thousand years.

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Washington, D.C. 20036 (202) 822-1000 Richard E. Jones Samantha Francis Flynn CAROLINA POWER & LIGHT COMPANY Post Office Box 1551 Raleigh, North Carolina 27602 (919) 836-6517 Counsel for Applicants Dated: November 2, 1983

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