ML20082B540

Response Opposing NRC Responses Re Summary Disposition of Contentions 80 & 83/84 on Individual Dose Exposure. Certificate of Svc Encl

ML20082B540
Person / Time
Site:	Harris
Issue date:	11/15/1983
From:	Eddleman W EDDLEMAN, W.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20082B518	List: ML20082B516 ML20082B540
References
82-468-01-OL, 82-468-1-OL, ISSUANCES-OL, NUDOCS 8311210233
Download: ML20082B540 (4)

Text

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y UNITED STATES OF AMERICA

'if?/P s

Nogmber 15, 1983 NUCLEAR REGULATORY COMMISSION D 18 g ,.y LhffSEchy I

BEFORE THE ATOMIC SAFETY AND LICENSING BOANfC8 Glenn O. Bri Dr. James H.ght 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 ani 2) ) ASLFP No. 82-b6P-01

) OL Wells Eddleman's Resnonse to NRC Staff on Summary Disposition of Contentions 80 and 83/84*

By telephone conference call last week, the Board kindly provided me with an onnortunity to resnond further to Summary Disposition responses by the Staff which themselves are in the nature of motions for Summary Disposition.

Eddleman 80: The Staff itself characterized this contention (see 6/214/83 discovery resnonses at 96) as "' Rain During Accident".

The contention as admitted (and retyned by Apolicants), snecifically refers to holding

• individual (radia@n) doses below 25 rem whole body"knd 300 rem to the thyroid "'in an f accident". (SEE Applicants' 2/18/83 typed version of admitted l contentions in this proceeding at 22). 10 CPR 100.11 requires l consideration of an accident which exceeds any other accident

• By oral order of 11-15-83, the Board allowed me until 11/18 to .

respond further on 83/84 since I only received the Staff report on

"'Organohalogen Products from 6hlorination of Cooling Water at Nuclear Power Stations"' on 11-14. A brief resnonse re that report is included here, and, per Order, I will notify the Board by phone if more is sent.

8311210233 831115 PDR ADOCK 05000400 0 PDR ,

considered credible. Such an accident may be the SST1 of NUDEG/CR 2239.

See at pp 2-12,13 Yet, in this con 61 tion (see pp 2-h0, 2-h2, and 2-102) peak early fatal'i'ti occur due to rainout over cities; and Table 2.7.h-3 thereof, p.2-93, gives 1.6 early fatalities (normalized to 1120 MWe reactor and 100 persons per square mile) with the best emergency response. Thus for 900 MWe thered still be an early fatality.

immediate or early Since you can't haveAfatalities without going well over 25 rem whole body, it annears that this study contradicts the claims of the staff

?ad Applicants.

The 591ckler analysis (Exhibit A to Staff Resnonse on E-80),

evidently nrepared by E.H. Markee and signed by W. Gammill (see p.3 thereof), shows (p.2) that at the worst point, wet deoosition (rainout) using NRC models increases doses by a factor of 1.38 to 1.92.

While this analysis them claims (p.3) that tha fraction of annual rainfall "f" is usually much less than 0.10, the hours of observed rainfall (NUREG/CR 2239, page A-17) for stations nearest Harris are 586 (Cape Hatteras) and 578 (Nashville), about 0.065; the amount l

of rain in NC is 40-50 inches (1000-1250 mm, roughly), or about 2mm per hcur. Since there is some uncertainty as to the amount of rainfall at any point, the increase in dose based on NFC models could readily be a factor of 1.5 on annual average due to rainout.

l Markee says this is within the uncertainty already in the NRC modal, but admits effectively that it isn't taken into account in that model.

l Staff presents no site-specific analysis of Harris site data to show that rainout would not increase doses further at the Harris site (i.e. above 1.5 times). Multiolication by 1.5 brings several or the Harris site doses close to annlicable limits, e.g. 1.5 times the 5.2 mrem calculated organ dose is 7.8 mren, close to 10 (the limit).

If the Staff's maximum multiplier of 1.92 were used, 1.92 x 5.2 mren gives 9.98% mrem, which is 10 within the limits of uncertainty.

Contentions 83/84 The just-received report "organohalogen Products from Chlorination of Cooling Water at Nuclear Power Stations" NUSEG/C93h08, by Roger M. Bean of Pacific Northwest Laboratories, gives the lie to the Staff / Applicant argument (Staff Motion for Summary Disposition

" Response" at 6-7) that discharges fron Harris"'will meet Federal and State limits which have been established based on substantial research as to the environmental innact of discharges which neet such limits" As already stated in resnonse to Anrlicants, the State perforned no environmental innact assessment for organochlorines from Harris. Worse, EPA has not established limits for nost of the numerous organohalogens identified in NUWEG/CR 3h08. Consider, for exannle, the increase in halogenated thenols at Beaver Valley (a plant declared similar to Harris in NC Util Connn. Docket E-2 sub 203 similar order authorizing construction of the Harris nlant), with a cooling 4

tower, fron 0.03 ppb intake to 0.67 pub (22-fold) at discharge.

Peaks #2,3,4, 6 thru 10 inclusive,12,3 3,and 15 thru 19, a total of 15 halogenated uhenols, are found in its discharges.

The residual chlorine levels in this study (see n.8) were under 1/2 Harris' EPA hasn't set standards for most of these, nor has it considered 0.5 ppm interactions among then when living beings (includiry humans) are exnosed to a conbitiation of then. (NUDEG/09 3h08 at nage h0 lists phenols. )

81: 5x increase in organohalogens in Beaver Valley sedinent.

See NU9EG also p/CR 3h08 says (p. vii) that data need to be obtained on the toxicity and notential for bioaccumulation of the broninated and chlorobrominated phenols. Note also the sunnary table, at ix (page #)

showing considerable increases in nethylene chloride, chloroform, and dichlorobronomethane in Beaver Valley's discharges. Other niants l in the sane study also show increased discharges of num< erous chemicals, not all of which EPA has established stan" hards for.

As noted h Nf en i e's for nower stations do not address carcinogens at all.IE W b k !A MkO M (h0CFRhP3)%

M e

__ _. _ = _ . _ . _ _ - , - _ _ . _ _ _ __

UNITED STATES OF AMERICA NUCLT.AR REGUIAToRY COMMISSION

) Dockets 50-400 In the matter of CAROLUA POWER k LIGHT Co. Et al. ) and Sokol o.L.

Shearon Harris Nuclear Power Plant. Units 1 and 2 CEftTIFICAT' eof SERVICE We Resnonse to NRC Staff on -

I hersby certify that copies of _

Summary Disposition of Contentions d8 80gainteb/8hoFAtNa=fWE o Av.,

and 15AA Resnonse to Annlicanta e Rae a e +-

day of November 198,1,, by deposit in HAVE been served this 15 the US Mail, first-class postage prepaid, upon all parties whose names are listed below, except those whose names are marked with an asterisk, for whom service was acconplished by

• Interrogatory resnor.ses to Judge Kelley and CA Barth only, ner oral order

• Judges James Kelley, Glenn Bright and Jams Carpenter (1 egy each)

Atomic Safety and Licensing Board US Nuclear Megulatory Comission Washington DC 20555 George F. Trowbridge (attorney for Applicants)

Shaw, Pittman, Potts & Trowbridge *R.uthanne G. Miller 1800 M St. NW ASLB Panel Washington, DC 20036 USNRC Washington DC 255 5

%ffice of the Executive Legal Director Phyllis Lotchin, Ph.D.

Attn Docke ts 50-400/k010.L. 105 Bridle Run USNRC Chanel Hill NC 2751h Washington DC 2o555 Dan Read Docketing and Service Section[3g) CEAUGE/ELP Attn Dockets 50-koo/hol o.L. Box 52h l

Office of the Secretary Chapel Hill NC 2751h ,

USNMC Wasuington DC 20555 Robert eruber, axee. Dir.

Public Staff ..gox 991 John Runkle Raleigh, RCC 27602 ..

CCNC .

307 Granville Rd

• Bradley W. Jones Chapel Hill Nc 2751k USNRC Region II ,

'Travi s Fayne 101 Marietta St. '

Edelstein k Payne Atlanta GA 303o3 Mox 12601 '

Raleigh NC 27605 Certified by h Richard Wilson, M.D.

729 Hunter St.

Apex NC 27502