ML20081H641

Affidavit of Jj Mauro & D Michlewicz in Support of Motion for Summary Disposition of Eddleman Contention 8F. Certificate of Svc Encl

ML20081H641
Person / Time
Site:	Harris
Issue date:	11/02/1983
From:	Mauro J, Michlewicz D CAROLINA POWER & LIGHT CO., EBASCO SERVICES, INC.
To:
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ML20081H118	List: ML20081H116 ML20081H137 ML20081H141 ML20081H622 ML20081H641
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ISSUANCES-OL, NUDOCS 8311070536
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Text

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t 00CKETED USNRC

'83 UV-4 pji:n UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION I~'^"-

.I BEFORE THE ATOMIC SAFETY AND LICENSING BOARD +-

In the Matter of )

)

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

)

(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

AFFIDAVIT OF JOHN J. MAURO AND DAVID MICHLEWICZ IN SUPPORT OF APPLICANTS' MOIION FOR

SUMMARY

DISPOSITION OF INTERVENOR WELLS EDDLEMAN'S CONTENTION 8F(2)

City of New York )

) ss.

State of New York )

John J. Mauro, being duly sworn, deposes and says:

1. I am currently Director of the Radiological Assessment and Health Physics Department of Envirosphere Company, a division of Ebasco Services, Inc. My business address is Two World Trade Center, New York, N.Y. The statement of my background and qualifications is attached hereto as Attachment 1. I have personal knowledge of the matters stated herein and believe them to be true and correct.

David Michlewicz, bding duly sworn, deposes and says:

2. I am currently Supervisor of the Radiological Assessment and Health Physics Department of Envirosphere Company, a division of Ebasco Services, Inc. My business addre ss is Two World Trade Center, New York, N.Y. The statement of my background and qualifications is attached hereto as Attachment 2. I have personal knowledge of the matters stated herein and believe them to be true and correct.

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3. This Affidavit has been prepared in support of Applicants' Motion for Summary Disposition of Intervenor Wells Eddleman's Contention 8F (2) .

4. Eddleman's contention 8F(2) alleges that Appendix C of the Shearon Harris Draft Environmental Impact Statement (DES) underestimates the environmental impact of the effluents in Table S-3 because the DES assessment of health effects of the radiological effluents specified is inadequate. Contention 8F(2) does not, as we understand it, include radon releases from the nuclear fuel cycle. Four reasons are given by Mr. Eddleman for his contention. This Affidavit demonstrates that the reasons given are not correct and that the DES assessment of health effects of the radiological effluents specified in Table S-3 is reasonable.

5. The Affidavit contains two parts. The first part briefly describes the methods used by the NRC staff to calculate the doses due to the radionuclide releases listed in Table S-3, and is provided to facilitate understanding of the remainder of this Affidavit. The second pa rt , entitled " Analysis of Eddleman's Allegations," demonstrates that Mr. Eddleman's allegations are unfounded. Included in the second part are the results of our independent dose calculations which reveal that the NRC staff estimates of dose and health effects provided in the DES are reasonable and are not underestimated.

Overview of Methodology

6. Appendix C of the DES presents estimates of the population dose and potential health effects due to radionuclide releases from the uranium fuel cycle required to support one year of operation of a standard 1000 MWe light water reactor. The radionuclide releases used by the NRC staff to perform this calculation were obtained from Table S-3 of 10 CFR 51 for most radionuclides, and from the NRC staff's analysis of the releases of radon and technetium.

7. Using these radionuclide releases, the NRC staff calculated the population dose and health effects from the following pathways of exposure:

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• 1) external exposure to airborne radioactivity

2) inhalation of airborne radioactivity

3) external exposure to radioactivity deposited on the ground

4) ingestion of food stuffs containing radionuclides from terrestrial and aquatic food pathways

8. Using these population doses, the NRC staff then calculated health effects over a 100 and 1000 year period following release. Health effects were calculated using the health risk estimators provided in the DES. These estimates of health effects were then compared to the potential health effects from exposure to natural background radiation.

The comparison shows that the risks from the fuel cycle are an extremely small fraction of the risks from natural background.

Analysis of Mr. Eddleman's Allegations

9. Mr. Eddleman, in 8F(2)(1), alleges. that the effects are considered for too short a time period, and in 8F(2)(ii), (iii) and (iv),

Mr. Eddleman alleges that the doses are not correct because the food chain concentrations are wrong and radiation doses from internal and external emitters are underestimated. In support of these allegations, Mr. Eddleman cites NRC Translation 520.

10. This section addresses each of these allegations. However, it does not address these allegations as they pertain to Rn-222 emissions because this issue is currently undergoing generic review.

11. The section is divided into 2 part s. The first part, entitled " time period" addresses Mr. Eddleman's allegation that the effects are considered for too short a time period. The second part, entitled "modeling" addresses Mr. Eddleman's remaining allegations pertaining to food chain concentrations, NRC Translation 520 and doses from internal and external emitters.

l Time Period i

l 12. The cutoff point of 100 to 1000 years used by the NRC staff is appropriate because:

1) short-lived radionuclides like tritium, Kr-85 and I-131 will decay to negligible levels within that period, and 4672g

2) radionuclides deposited onto the soil or into surface waters will *oecome relatively unavailable to the biosphere through processes such as sedimentation, migration below the root zone, and transport to the deep ocean.

13. Because of these processes, the dose delivered to the population will decline as a function of time. As a result, the ratio of the dose commitment from the releases in Table S-3 to the dose commitment from background radiation over the same period of time will continually decrease.

14. In its assessment, the NRC staff expressly assumes no development in the prevention and cure of disease. It would be absurd to presume that there will be no advances in medical science for hundreds or thousands of years and such an assumption is clearly conservative. For example, a recent study published in the September issue of the Journal of the American Health Physics Society addresses this issue and demonstrates increases in life expectancy of cancer patients which have been realized since the 1940s.

15. In summary, the cutoff point of 100 to 1000 years used by the NRC is reasonable because beyond this time period the dose relative to background will continually decrease, and it would be absurd to presume no advances in medicine which could mitigate the potential harmful effects of radiation. It is therefore concluded that Mr. Eddleman's allegation is incorrect.

i Modeling

16. In &(2)(11), (iii) and (iv), Mr. Eddleman alleges that the health effects calculated by the NRC staff in Appendix C of the DES are inadequate because the food chain concentrations are wrong and the doses due to internal emitters are underestimated. This is not correct. In the paragraphs which follow it is shown that the food chain dose models used by the NRC are reasonable. An independent assessment of dose is provided, and the results confirm the validity of the NRC staff estimates.

17. As cited in the DES and in NRC staff responses to Eddleman's interrogatories, the mathematical models and parameters used by the

• B. L. Cohen, Health Physics 45(3):687 (1983).

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1 NRC staff to calculate doses from Table S-3 releases are described in NUREG-0002 " Final Generic Environmental Statement on the use of Recycle Plutonium in Mixed Oxide Fuel in Light Water Reactors" (1976). These models and parameters are derived from, and in most regards are identical to, standard methodologies used widely by the nuclear industry and which are the subject of continual review. As with Regulatory Guide 1.109 (covering dose calculations from releases during plant operation), the methodology in NUREG-0002 involves over 1000 calculational parameters.

Attachment 3 presents a list of studies where individual parts of the 4

models, and the models as a whole, have recently been evaluated. The most recent of these studies was perf ormed by Dr. Mauro and his staff for Battelle Memorial Institute and the Department of Energy.

18. Mr. Eddleman's allegations pertain specifically to the environmental transfer factors and the internal and external dose conversion factors used by the NRC. A review of the literature on these subjects reveals that a great deal of research has been and is being performed on these factors. A review of the recent literature reveals several findings which are pertinent to Mr. Eddleman's allegations:

(1) Contrary to the allegations by Eddleman set forth in response to interrogatories pertaining to Contention 29/30, environmental transfer factors used by the NRC staff to determine the concentrations of radionuclides in foods are based on empirical data. For example, the accumulation of radionuclides by plants via root absorption is one of the pathways of exposure which was modeled. In performing this calculation, the NRC staff used environmental transfer factors which relate radionuclide concentration in plants to that in soil. These transfer factors are based on a study by Dr. Y. Ng* and were obtained from measurements made of the concentration of radionuclides and stable elements in plants and soils. A review of Dr. Ng's report and several of the references cited in that report revealed that natural settings such as agricultural soils, meadows, forest s and gardens (not sterilized soils) were used to i

• Y. C. Ng et al. UCRL-50163 1968.

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^

l derive the proportionality constants. Plant concentrations of the different elements were also derived from material collected from the natural environment (not from transplanted plants given insufficient time to accumulate radionuclides).

(2) A comparison of the environmental transfer factors used by the NRC staff in NUREG-0002 with values for these factors reported in the recent literature (see Attachment 3) reveals that for some radionuclides listed in Table S-3 the factors have increased while for others they have de creased. Nevertheless all the values used by the NRC staff are within a reasonable range of values reported in the literature.

(3) Like the environmental transfer coefficients described in paragraph 18(1), which are used to calculate radionuclide concentrations in foods, the internal dose conversion factors, which relate dose to quantity of radionuclides inhaled . or ingested, are also based on empirical data.

These data are obtained from observations and experiments on the biological behavior of inhaled or ingested radionuclides. These observations and experiments directly measure the uptake and elimination of radionuclides by man and experimental animals following inhalation and ingestion and include over 5,000 separate studies. These data are then used to derive internal dose conversion factors. A comparison of the internal dose conversion factors used by the NRC staff in NUREG-0002 with those based on recent recommendations by the International Conunission on Radiological Protection (ICRP) and calculated by Oak Ridge National Laboratory (CRNL) reveals that, though new information and methodologies are available, the values used by the NRC staff remain reasonable.

(4) The external dose conversion factors used by the NRC staff in NUREG-0002 have also been the subject of ongoing research. However, unlike environmental transfer factors and internal dose conversion factors which are obtained 4672g

empirically, research on external dose conversion factors j involves the development of improved mathematical models. l A recent report by Kocher* updates the external dose conversion factors using more refined calculational techniques. A comparison of these factors with those used by the NRC staff in NUREG-0002, reveals that the NRC factors are generally conservative.

19. Our review of the recent literature described above in paragraph 18 reveals that in light of these studies, many of the parameters used by the NRC staff remain unchanged while some have increased and others have decreased. Overall, it is our judgment that the dose and health effects calculated by the NRC staff in the DES, using the methods in NUREG-0002, are reasonable and within the range of values observed or calculated in the scientific literature. In order to demonstrate the validity of this judgment, a series of calculations were performed independently to quantify dose and health effects of the radionuclide releases estimated by the NRC staff. The calculations were performed using recent data on environmental transfer factors and dose conversion factors.

20. As stated in Appendix C of the DES, the NRC staff estimated a population dose of approximately 600 man rem **, not including radon, delivered over a 100 year period due to the radionuclide releases required to support 1 year of operation of a reference light water reactor. Our calculation resulted in estimates of man rems over a 100 year period which are comparable to the 600 man rem value reported in the DES. Specifically, given the radionuclide releases estimated by the NRC staff, we calculated a total 100 year dose commitment of 620 man

( re m. A description of the calculational method is provided in Attachment 5. Based on these results, we conclude that the NRC staff estimates of dose and health effects provided in the DES, and which w..re based on models in NUREG-0002, are reasonable and have not been underestimated given the uncertainties in the calculational parameters.

• D. C. Kocher, Dose Rate Conversion Factors for External Exposure to Photons and Electrons - Health Physics 45(3):665 (1983) l **400 man rem from gaseous emissions,100 man rem from liquid emissions and less than 100 man rem from the release of Tc-99.

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21. The DES also presents an estimate of about .13 cancer deaths

• per 1000 years due to the release of radionuclides, not including radon, from the uranium fuel cycle required to support one year of operation of a reference 1000 MWe light water reactor. Our independent calculation resulted in less than 1 cancer death per 1000 years and therefore compares favorably with the NRC staf f estimate of .13.

22. Intervenor has relied on the so-called "Heidelberg Report" (NRC Translation 520) as a credible source of information representing an overview of the literature concerning transfer of radionuclides through environmental pathways. This reliance is misplaced. The Heidelberg )

Report purports to assess the environmental radiological impact of a proposed PWR to be built near Wyhl, West Germany. A review of the Heidelberg Report and much of the correspondence regarding the report revealed several gross inaccuracies and the fact that the literature referenced by it did not represent an accurate overview of the data concerning model transfer factors. Many U.S. and German scientists and government agencies have severely criticized the entire document to the extent that the report has been thoroughly discredited by the scientific community. These criticisms are summarized in Attachment 4. In addition, the authors offer no credentials supporting their expertise, and list no publications or experience in the fields of radiobiology, health physics, radioecology, internal dosimetry or nuclear power plant operations.

23. Notwithstanding the criticisms of the Heidelberg Report, we believed it would be instructive to recalculate the population doses from the uranium fuel cycle using environmental transfer factors and dose conversion factors recommended in the Heidelberg Report. A review of the report revealed that factors are provided only for some of the radionuclides listed in Table S-3. Accordingly , our calculation used Heidelberg Report factors where such factors are provided, and our factors where the Heidelberg Report does not provide the necessary inf ormation. The basic calculational approach is that described in

• .12 cancer deaths from all radionuclides not including radon and Tc-99; plus about .01 cancer deaths from Tc-99.

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i l

l Attachment 5. The results of the calculation revealed that even using  ;

Heidelberg factors the 100 year and 1000 year population dose still i remains extremely small compared to background and the calculated health effects are still less than 1 cancer death.

24. As a final point, it is important to note that the scientific disciplines of radiobiology and radioecology are the subject of active res earch. As a result, new information is continually being acquired on environmental transfer and dose conversion factors. However, this does not mean that standard methods used to calculate doses, such as those described in NUREG-0002, are inappropriate. The models must be looked at as a whole and a determination made whether the new information gathered can significantly affect the bottom line conclusions. As demonstrated in paragraphs 18 through 21, though the NRC methods in NUREG-0002 were published in 1976, the results remain valid.

//n-t hn J. Mauro uDia -David Michlewfcz

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MNUE A. PETRAITIS Netcry F:Mi:, Otate of New York No. CIPE4ECSCC3 QW;f:cd in Kings County Cert. T; Ed in New York Ceunty Ccmm.ss:.a E4iras March 30,1985 il 9- f,3 4672g

ATTACHMENT 1 4/g3 Page 1 of 4 3)tN ISEPH MAURO -

Certified Health Physicist

SUMMARY

OF EXPERIENCE (Since 1970)

Total Experience - 12 years total experience. Six years experience in calculating projected exposures of radionuclides in the environment and evaluating the biological significance of these exposures. Six years experience in managing radiological and hazarocus chemical consulting projects.

l Professional Affiliations - Health Physics Society ANSI Committee N18 - Guide to Standard Fomat and Content of Emergency Plan's for Nuclear Power Generating Facilities Education - PhD, New York University,1973 - Biology, Radiological Health MS, New York University,1970 - Biology, Raolological Health BS, Lorg Island University,1967 - Biology, Bacteriology .

- Awards - Alvin Gruder Memorial Award Founders Day Award EPRESENTATIVE ENVIROSPtERE PROICT EXERIENCE (Since 1973) a 1973 to Present

! Radiological Assessment Scientist / Director Raolological Assessment and Health Physics Department Responsible for evaluating the radiological inpact of nuclear power plant operation for Ebasco's client utilities. Prepareo the requisite sections of the Envirormental Reports and Safety Analysis Reports and defended these analyses before the NRC, the Advisory Comittee on Reactor Safeguards, State Site Certification Boards and the Atomic Safety ano Licensing Boards. Provided these services for 10 nuclear power plants.

Responsible for the calculation of projected radionuclioe inventories ano liquid and gaseous source terms associated with various aspects of normal l plant operation and hypothetical accidents. Experienceo in the calculation of the projected environmental transport, distribution ano concentration of radionuclides released in the liquid and gaseous leffluent of nuclear power facilities; the calculation of the projecteo exposures to man and organisms other than man due to radionuclides in the envirornent; and the evaluation biological effects of, exposure to

! radiation.

1

l Page 2 of 4 JOHN JOSEPH MAURO (Continued) .

Experienced in the design of enviromental radiological surveillance programs for nuclear power facilities. Has installe0 and calibrateo radiation detection instrumentation at low level radiological laboratories and participated in the training of laboratory personnel.

Has managed the preparation of several emergency response plans ano implementation procecures for comercial nuclear power facilities ano for state agencies responsible for emergency response planning.

Has provided radiological and emergency response training to health physicists, nuclear engineers and members of state and local agencies responsible for emergency planning.

Has managed the preparation of the enviromental/ radiological technical specifications ano offsite cose calculation manuals for several nuclear power facilities.

Has managed numerous consulting projects in the area of oecommissioning, .

environmental monitoring, environmental cosimetry in-plant health physics for the nuclear fuel cycls.

Has performed several toxic chemical stuales in s@ port of nuclear power plant control room cesign and in the assessment of the raciological ano l

chemical toxicity of low level radioactive wastes.

1 PRIOR EXPERIENCE (2 years)

Private part-time consulting work.

Worked on the radiological effects sections of a nuclear power plant environmental impact report. Drafted answers to interrogatories from an AEC licensing hearing.

New York University Institute of Enviromental Medicine Assistant Research Scientist (2 years)

Performed research work on the life history of white perch in the Huoson River. Aided in the cataloging and entperation of invertebrates in the Hudson River. Participated in a project to oevelop techniques to I

determine and ability of various micro-organisms to organify inorganic mercury.

Publications and Presentations Mauro, J J and M E Wrem 1972. A review of radiocesium in acpatic biota. PIesented at the Health Physics Society Annual Meeting, Las Vegas, Nevada, June 12-16.

~

Pqe 3 of 4 M JOSEPH MAURO (Continued)

Mauro, J J and M E Wrem 1973. Reasons for the absence of a trophic level effect for raciocesium in the Hudson River Estuary. Presented at the IRPA meeting held in Washington, D.C. in October. Published in the proceedings of that meeting.

Mauro, J J, and J Porrovecchio. Numerical criteria for in-plant as low as is reasonably achievable proceecings of the 9th Mid-Year Topical Sy mosium of the Health Physics Society.

Mauro, J J, D Michlewicz and A Letizia 1977. Evaluation of environmental dosimetry models for applicability to possible racioactive waste repository discharges, Y/0W1/SLB-77/45705, September.

Mauro, J J *1978. Comparison of gaseous effluent stanoarcs for nuclear and fossil fuel power proouction facilities. Proceecings of the December 1978 Annual Meeting of the American Nuclear Society.

Mauro, J J, J Thomas, J Ryniker ano R Fellman 1979. Airborne uranium, its concentration and toxicity in uranium enrichment facilities, .

K/P0/SUB-79/31057/1, February.

Mauro, J J, K E Lino, J D Levine, L Yemin, H J Howe, Jr anc C W Pierce 1979. Safety relateo research requireo to stoport future fusion research reactors. Presented at the Annual Meeting of the American Nuclear Society-San Francisco, November.

Mauro, J J and E P 0'Donnell 1979. A cost-benefit comparison of nuclear and nonnuclear health and safety protective measures and regulations, Nuclear Safety, Vol. 20 No. 5, September-October.

l Mauro, J J 1960. A real time computer program for offsite radiological

! igact assessment. Presented at the 1980 Annual Meeting of the American Nuclear Society. TANSAO 34 1-899.

! Mauro, J J, R Bhatia and G Martin 1980. Effects of containment purge on the consequences of a loss of coolant accioent. Presentea at the 1960 Annual Meeting of the American Nuclear Society. TANSAO 34 1-899.

l l Mauro, J J and S Marschke 1980. Radiocesium transport into reservoir bottom sediments - a licensing apprcach. Presented at the 1960 Annual Meeting of the ANS. TANSAO 34 1-899.

Mauro, J J and D Michlewicz 1981 deployment concepts for Real Time Jnviromental Dosimetry Systems. Presented at the 1981 Anrnal Meeting if I

the Health Physics Society.

i Mauro, J J and E P 0'Donnell 1982. The role of the Architect / Engineer in the Emergency Planning Process. Presenteo at the Annual Meeting of the j American Nuclear Society. June 6-10, 1982.

l l

a Page 4 of 4 J0tti IlSEPH MAURO (Continuec)

Mauro, J J and W R Rish 1982. Dealing with Uncertainties in Examining Safety Goals for Nuclear Power Plants. In NUREG/CP-0027. Proceedings of the International Meeting on Thermal Reactor Safety.

Mauro, J J, S Schaffer, J Ryniker, and J Roetzer. Survey of Chemical ano Radiological Indices Evaluating Toxicity. National Low-Level Racioactive Waste Management Pmgram. 00E/LLW-17T. March, 1983.

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ATTACHMENT 2 3/83 Page 1 of 3 '

DAVID MICH.EWICZ Supervising Radiological Assessment Engineer Total Experience - Seven years of experience in the field of nuclear safety and radiological protection.

Professional Affiliations - American Nuclear Society Health Physics Society Atomic Industrial Forun, Committee on Reactor Licensing and Safety, Subcommittee on Emergency Preparedness and Siting.

Education - MS, Colunbia University,1974 - Nuclear Engineering

, BS, Colunbia University,1972 - Nuclear Engineering SLNMARY OF EXPERIEEE (Since 1974)

From 1974 to 1976, worked as a health physicist for the Environmental Protection Agency's Office of Radiation Programs. Work included the i analysis of the environmental effects of postulated accidents at nuclear  !

power facilities, and development of methodologies for assessing offsite ,

radiological consequences of these accidents. Developed procedures for l use by state and local agencies for mitigating the impacts of radionuclide releasing accidents and developed the draft Appendix D,

" Technical Bases for Dose Projection Methods", to the " Manual of Protective Action Guides and Protective Actions for Nuclear Incidents".

Reviewed and participated in development of state radiological emergency response plans, maintained liaison with state emergency response officials and provided training assistance. In addition, participated in the development of agency guidance regardin0 technologically enhanced sources of radiation such as uranium tailings and byproducts of phosphate production. As part of this effort, developed a comuter code ( AREAC) for analyzing the radiological effects of redon emissions from area sources.

In 1976, joined Ebasco Services, Incorporated (now Envirosphere). Work involves modelling the in-plant and environmental behavior of radionuclides for the pumnme of assessing the licensability of in-house projects and providing design r,uidance to engineering disciplines. In the course of this work, performed numerous studies of the environmental and radiological ig acts of both accidental and routine radiological i effluent releases from nuclear fuels cycle facilities including reactors, I utenlun enrictment plants and high level waste repositories. This l involved the generation of the appropriate radionuclide source terms, and evaluation of the potential pathways of exposure and health impacts.

i

. . - - . , - _ _ _ . , . _ _ . - - _ . . _ _ . . _ _ . _ _ . _ _ _ _ _ . _ . _ _ _ . _ _ _ ~ . _ . _ _ _ _ _ _ , . _ _ . _ . - . _ _ _ _ . . ~ . . . _ _ . . . _ . _ _ _ . _ .

! DAVID MICH.EWICZ (Cont'd) Page 2 of 3 Area of specialization is application of computer programming to the development of models describing environmental transport of effluents from point to area sources. Developed numerous computer programs currently used in in-house licensing applications, and is familiar with other codes utilized in the industry as well as NRC codes such as GALE, GASPAR, LADTAP and mAC.

Established design requirements for control room habitability in the event of radiological accidents and releases of toxic chemicals.

Developed a cceputer program for modeling chemical release and dispersion to assess the potential risk from such releases and applied to a number of sites, including one with over two hundred discrete sources of toxic chemicals.

Has extensive experience in the development and implementation of nuclear i facility emergency response plans. Is responsible for developing l methodologies for assessing the radiological consequences of potential accidents at nuclear power facilities and for developing procedures for evaluating their. impacts. Participated in several training programs on emergency response planning, including the REAC/TS course on Health Physics in Radiation Accidents and the Federal interagency course on radiation emergencies.

Revised the emeIgency response plan for the Waterford-3 project in accordance with NUREG-0654. Performed a critical review of the Emergency Response Plans for the State and counties of Louisiana and prepared the Implementing Procedures for the Utility Plan. .

Was the project Technical Director for the preparation of radiological emergency response plans and procedures for the California Department of Health Services, Radiologic Health Section. Was responsible for technical content and coordination of technical irput.

Served on a task force to revise the Long Island Lighting Company's offsite radiological response plan for the Shoreham Nuclear Power Station.

Currently, serves as a task leader for licensing support to the Office of Nuclear Waste Isolation Program for high level waste disposal.

l Publications Michlewicz, D 1976. Area Source Radiological Emission Analysis Code (AREAC), DfF-EAD-76-6, U.S. Environmental Protection AQency, October.

Mauro, J J, D Michlewicz and A Letizia 1977. Evaluation of Environmental Dosimetry Models for Applicability to Possible Radioactive Waste Repository Discharges, Y/DWI/SUB.-77/45705, September.

i 4

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l DAVID MICH.EWIC'. (Cont'd) Page 3 of 3 Martin, G, Jr, D Michlewicz and J Thomas 1978. Fissicn 2120: A Program for Assessing the Need for Engineered Safety Feature Grade Air Cleaning Systems in Post-accident Envirorvnents,15th DOE Nuclear Air Cleaning Conference.

Ryniker, J, J Roetzer, 8 Macdonald, D Michlewicz and J-C Dehmel 1979. An Evaluation of a Model for Dispersion of Uranlun Hexafluoride and a Review of Potential Health Ef fects on Offsite Populations, K/P0/SUB-79/31057/4, November.

Michlewicz, D, J Mauro and E Vold. Deployment Concepts for Real-Time Environmental Dosimetry Systems. 26th Annual Meeting of the Health Physics Society, June 21-25, 19 81.

Michlewicz, D, J Mauro and E Vold. Protective Action Guides and Derived Response Levels for Residual Contamination of Habitable Areas Following a Nuclear Reactor Accident. 109th Annual Meeting of the American Public Health Association, November 1-5, 1981.

4 m

i (b

Attachment 3 Review Articles on Modeling karten,C.T.1978. A review of parameter values used to assess the transport of plutonium, uranium and thorium in terrestrial food chains. Environmental Res.17(3): 437-452.

NUREG/CR-1004. 1979. A statistical analysis of selected parameters for predicting food chain transport and internal dose of radionuclides. Hoffman, F.O. and C.F. Baes III.

Ng, Y.C. 1982. A review of transfer factors for assessing the dose from radionuclides in agricultural products. Nuclear Safety 23(1): 57-71.

NUREG/CR-2612 1981. Variability in dose estimates associated with food chain transport and ingestion of selected radionuclides. By Hoffman, F.O.,

R.H. Gardner and K.F. Eckerman.

Mauro, J.J., W.R. Rish and S.A. Schaffer (1983). Final Report to Battelle Project Management Division for the Department of Energy. Analysis of Uncertainties in the EPA Ore Body Release and River Mode Exposure Pathway Models Used as the Bases for Draft 40 CFR 191.

ICRP-30. 1980. International Commission on Radiological Protection, limits for Intakes of Radionuclides by Workers. Annals of ICRP.

NUREG/CR-0150. 1981. Estimates of internal dose equivalent to 22 target grgans for radionuclides occurring in routine release from nuclear fuel cycle fac~ilities. Volume 3. Oak Ridge National Laboratories. :.

6 Attachment 4 5

Summary of Critiques of the "Heidelberg Recort"

• I. NRC Review, NUREG-0668 The NRC critique of the Heidelberg Report focused on the key elements of the source terms, atmospheric dispersion factors and dose conversion factors. The NRC found that the liquid and gaseous source terms used in the report were many times greater than the average source terms from operating plants in the U.S. and therefore do not reflect U.S. operating experience.

The NRC found that the atmospheric dispersion factors were derived using data assembled from five separate meteorological stations. No single station was used to obtain the basic wind speed, stability class and wind direction joint frequency data.

As a result, combinations of wind speed, direction and stabili-ty class are used which have no meaning in reality. Using ap-proximations, the NRC believes that the peak X/Q used in the Heidelberg Report may be high by a factor of 10 or more.

The NRC found that the soil to plant concentration factors (Biv values) were not supported by the literature cited. Spe-cifically, the Cs and Sr Biv values were selected at the high end or well beyond the high end of the experimental data.

Also, the dose conversion factors for Cs-137 and Sr-90 are much higher than those used by the NRC and are not supported by

~

experimental data. The NRC factors are based on International Council on Radiation Protection ("ICRP") guidelines.

As its final critique, the NRC reviewed environmental radiological surveillance data around operating reactors in the U.S. The NRC determined that if Heidelberg models were valid, then high, easily detectable levels of I-131 and Cs-137 would be found in the vicinity of operating reactors, when in fact they are not.

II. The University of Heidelberg Dr. E. K. F . B rutz , Dean - Faculty of Biology of the Uni-versity of Heidelberg, in a letter to the NRC, stated that the Heidelberg Report was not prepared or sponsored by the Univer-sity, but rather was prepared by a group of graduate students aided by a few junior faculty members. The group represented itself as being sponsored by the University, against the direct l instructions of the President of the University. Dr. Brutz l

referred to the group as a " bunch of students setting out to j 1

prove their philosophy right" and coming up with " data based I l

more on fancy than fact." He was also apologetic that the NRC had to "go through the pains having to referee such silly claims."

The degree to which the University was concerned with the Heidelberg Report is demonstrated by the legal action brought by the University to restrain the authors of the Report from referring to their group as the Tutorium Environmental Protection at the University of Heidelberg.

1 III. Ministerium Fur Arbeit Gesundheit Und Sozialordnung Baden (German government nuclear cower plant licensing agency)

J. Narrog of the German licensing agency was extremely critical of the Report, referring to it as "less a serious sci-entific report but rather a public relations paper of opponents against nuclear energy. All European institutions, which dealt with the report, came to similar statements."

On a more technical side, J. Narrog demonstrated that there was no agreement between the average radionuclide release rates for operating power plants in Germany and the Heidelberg Report source terms. In addition, site specific meteorological data have shown the Heidelberg dispersion factors to be at least 2 fold too high. Finally, J. Narrog stated that environ-mental surveillance programs at operating plants in Germany have "never showed numbers in the magnitude of the estimated i

concentration values of the Heidelberg Report for CS-137, CS-134 and I-131."

IV. Federal Energy Production Office -

Nuclear ' Installation Safety a

Division (Germany)

Drs. J. Czarencki, J. Halter, H. Pfeiffer, H. Fritz-Niggli and H. Brunnen published an extensive critique of the Heidelberg Report. Quoting from the critique, "The selection of the literature is one sided, obsolete and incomplete . . . .

Insufficient or missing scientific knowledge and deficient

1 i

I knowledge of the literature result in serious assumptions and assertions and incorrect conclusions . . . . In its conclu-sions, it is based on unsubstantiated statements, incorrect as-sumptions, unidentifiable calculations, exaggerated and unre-alistic numerical values for the parameters used."

V. National Radiological Protection Board, Harwell, England:

G. S. Linsley echoed many of the above statements. In addition, he cited experimental work in England which supported the Biv values used by the NRC.

VI. Society for Reactor Safety (GRS)

The German Society for Reactor Safety was very critical of meteorological modeling used in the Heidelberg Report. The Society believesthe Report's long-term diffusion factor is high by a factor of 3, and the deposition velocity of airborne particles is high by a factor of 4. The critique also included a retrac-tion statement made by D. Teufel, co-author of the Heidelberg Report, regarding previous statements made in support of the Report's dose conversion factors. Teufel admitted to'the administrative court that, "[t]his cannot be checked by us precisely. The statement was probably made a little prematurely. It fell back to me, to my graduate work, in which this statement was made and which I must now retract."

Il ATTACHMENT 5 DOSE CALCULATION METHODOLOGY

~

1.0 ~ Introduction

'This attachment presents the method used to calculate the population. dose presented in paragraph 20 of this affidavit.

The method was developed based on a review of alternative models, including that described by the NRC in NUREG-0002. Models and parsmeters were selected to provide realistic estimate of dose given the source tems cited by the NRC for the fuel cycle. A recent review of this subject

.which we perfomed for Battelle Memorial Institute (1) under contract with the Department of Energy provided a great deal of the infomation required for this analysis.

2.0 Gaseous Effluents The models described in NUREG-0002 were reviewed and used with the following modifications:

1) External dose conversions factors published by Kocher (2) were used

2) Internal dose conversion factors published by ORNL (3) were used

3) Environmental transfer factors by Ng (4) and Hoffman and Baes (5)

_ were used

[ 4) The model included depletion of radionuclides in soil v,ia natural processes as cited by Smith (6) or calculated based on: methods described in reference 5.

[ 1s

-~

5) Shielding of external exposures due to ground roughness

~

and remaining indoors was included in the model.

6) Global doses were calculated using the methods described by X111ough (7) and Benioson (0)

7) The model included reduction of activity in foods due to handling and preparation I9) 3.0 Liquid Effluents The doses from the liquid effluents were calculated assuming the Table S-3 releases are uniformly mixed in the entire fresh water river flow in the U.S. and exposures occur from the ingestion of irrigated crops, l

- fish, water and from recreational use of the river. The method used is based on Smith (6) However, it was modified to consider removal of radionuclides from water by sedimentation II) and municipal treatment (9) .

I9)

The model also included removal of radionuclides in food by processing .

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, - - , . - - - - - - - - - - , - , - ,,--- --------------,,,w- . - - . . - ,

ei REFERENCES 0

. FOR ATTACHMENT 5

1. Mauro, J.M., S. Schaffer and W. Rish Final Report to Battelle Project Management Division (BPMD) for the Department of -

~ Energy. Analysis of uncertainties in the EPA Ore Body Release

~

and River Mode Exposure Pathway Models used as the bases for draft 40 CFR 191. 6/83.

2. Kocher, D.C. (1983) Dose Rate Conversion Factors. Health Physics 45(3):665.

3. NUREG/CR-0150 1981. Estimated of internal dose equivalent to

• 22 target organs for radionuclides occurring in routine releases from nuclear fuel cycle facilities.

4. Ng, Y.C. 1982. A review of transfer factors for assessing the dose from radionuclides in agricultural product. Nuclear Safety 23(1): 57-71

5. NUREG/CR-1004 (1979). A statistical analysis of selected parameters for predicting food chain transport and internal dose of radionuclides.

Hoffman, F. O. and C. F. Baes eds.

6. Smith, J. M. et al (1982) Environmental Pathway Models for estimating i

population risk from disposal of high level radioactive wastes in geologic repositories. EPA-520/5-80-002.

7. Killough, G. C. 1980. A dynamic model for estimating radiation dose l I

to the world population from releases of C-14 to the atmosphere. Health Physics 38(3): 269.

8. Beninson, D. Population dose resulting from radionuclides of worldwide

' ' distribution in " Population Dose Evaluation and Standards fog Man and His Envirorsnent".IAEA STI/ PUB /375 (1974).

9. HERMES (1971). A digital computer code for estimating regional radiological effects from nuclear power industry. HEDL-TME-71-168.

l

s

'P l'l ED UNITED STATES OF AMERICA U RC NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSIN183BWD-4 A]f :1j 0FFICE OF SECRCUn< -

00CKEIING & SERVicr "

In the Matter of ) BRANCH

)

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

)

(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of all the documents listed on the attached document list were served this 2nd day of November, 1983 by deposit in the United States mail, first class, postage prepaid, to the parties on the attached Service List.

I -

N '

f '

1 Johli' H. O 'Neill, Jr.

b Dated: November 2, 1983 n

t DOCUMENT LIST

1. Applicant's Motion for Summary Disposition of Wells Eddleman's Contention 8F(2)

2. Applicant's Response to Wells Eddleman's General Interrogatories and Interrogatories on Contention 8F(2) to Applicants Carolina Power & Light Company, et al. (SIXTH SET)

3. Applicants' Statement of Material Facts as to Which there is no Genuine Issue to be Heard ~on Wells Eddleman's Contention 8F(2)

4. Affidavit of John J. Mauro and David Michlewicz in-Support of Applicants' Motion for Summary Disposition of Intervenor Wells Eddleman's Contention 8F(2) n

1 4

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION E Ei:

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

'83 NOV -4 N1:12 In the Matter of ) CFFfcE OF 3hng7f..

) 00CKElmG & .SEFVU '

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

)

(Shearon Harris Nuclear Fower )

Plant, Units 1 and 2) )

SERVICE LIST James L. Kelley, Esquire John D. Runkle, Esquire Atomic Safety and Licensing Board Conservation Council of U.S. Nuclear Regulatory Commission North Carolina Washington, D.C. 20555 307 Granville Road Chapel Hill, North Carolina 27514 Mr. Glenn O. Bright Atomic Safety and Licensing Board M. Travis Payne, Esquire U.S. Nuclear Regulatory Commission Edelstein and Payne Washington, D.C. 20555 Post Office Box 12607 Raleigh, North Carolina 27605 Dr. James H. Carpenter Atomic Safety and Licensing Board Dr. Richard D. Wilson U.S. Nuclear Regulatory Commission 729 Hunter Street Washington, D.C. 20555 Apex, North Carolina 27502 Charles A. Sarth, Esquire (4) Mr. Wells Eddleman Myron Karman, Esquire 718-A Iredell Street Office of the Executive Legal Director Durham, North Carolina 27705 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Richard E. Jones, Esquire Vice President and Senior Counsel Docketing and Service Section (3) Carolina Power & Light Company Office of the Secretary Post Office Box 1551 U.S. Nuclear Regulatory Commission Raleigh, North Carolina 27602 Washington, D.C. 20555 Dr. Phyllis Lotchin Mr. Daniel F. Read, President 108 Bridle Run CHANGE /ELP Chapel Hill, North Carolina 27514 5707 Waycross Street Raleigh, North Carolina 27606 Dr. Linda Little Governor's Waste Management Board 513 Albemarle Building 325 North Salisbury Street Raleigh, North Carolina 27611 4

m 0-1 Ssrvico List Page Two Bradley W. Jones, Esquire U.S. Nuclear Regulatory Commission Region II 101 Marrietta Street Atlanta, Georgia 30303 Ruthanne G. Miller, Esquire -

Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Robert P. Gruber Executive Director Public Staff - NCUC Post Office Box 991 Raleigh, North Carolina 27602 i

4 k