ML20082F768
| ML20082F768 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/22/1983 |
| From: | Eddleman W EDDLEMAN, W., JOINT INTERVENORS - SHEARON HARRIS |
| To: | Bright G, Carpenter J, Kelley J Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20082F772 | List: |
| References | |
| 82-468-01-OL, 82-468-1-OL, ISSUANCES-OL, NUDOCS 8311290239 | |
| Download: ML20082F768 (3) | |
Text
,
m Z.
1.
l 00CHETfD UNITED STATES OF AMERICA November 22, 198 NUCLEAR REGULATOBY COMMISSION
'83 WV 28 #0:30
- CFFiCE OF SECRtB -
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD uCCwge sggyjg Glenn O. Bri Dr. James M.ght Carpenter James L. Kelley, Chairman In the Matter of J
Dockets 50 400 OL CAROLINA POWER AND LIGHT CO, et al.
)
50 401 OL (Shearon Harris Nuclear Power Plant,
)
Units i ani 2)
)
ASLBP No. 82-L68-01
)
OL Joint Intervenors' Resnonse to NDC Staff on Summary Disnosition of Joint Contention II Staff is wrong (and ns..-too-ing the Apolicants ) to state (p.9) that risk estimators at nost 2 tines higher than BEIP-or the unper estinate of Staff risk (BEIR I) are all Joint Intervenors rely on.
We have repeatedly cited Gorman, whose estinates are at least 10 tines higher than BEIP's.
Staff's argument (pp10-11) about dose estination over only 50 years being OK nisses the noint for genetic defects, which continue as long as the defective genes are nassed on (naybe forever).
This is a fact which they ignore, which is much more " reasonably foreseeable" than the hynothetical inorovements in nedicine that Staff (virtually ouoting Annlicants) cite on p.10.
What Staff says is that not only is 1000 years short enough to assess radiation health effects over, 50 years is short enough.
Not so, for genetic l
health effects will continue far beyond 50 years.
Staff cites no authority otherwise.
G j
Staff is wrong to say, vertical plume scread accounts for all of inconplete mixing (moreover, vertical spread is collansed by 9311290239 831122 3
PDR ADOCK 05000400 J
PT@
_2 I
rainout (see McFestters ' affidavit for CP&L, un to about 2/3 of plume could be renoved by rainout).
Hot soots affect the naximum exposure to individuals, and Staff's argument (it is not a fact) that this is accounted for by stable atnospheric conditions and low wind speed makes little sense.
They do not say HOW the hot spots are accounted for by these narameters. They show no actual conditions re hot spots, but just rely on their model.
Staff misstates Joint Intervenors ' nosition on fly ash (n.13):
fly ash from the USSR, Japan and Western Europe is nresent in air near the Harris plant, and radioactise material from the Harris plant can attach to.them, by electrostatic attraction when the radioactive particles decry.
Since it is well known (see the Table of Radioisotones 6th ed. cited by Apolicants in discovery) that gaseous radionuclides like Xe and Kr occur in decay chaings of many isotopes, with unstable nuclides occurring after Xe and Kr in many decay chains, the carrying of these radioactive particles (atom-sized) into the lungs by coal particulates is a real situation.
It is equally w911 known (see, e.g. Resnirable Particles, p.2, which states "Even when not inherently toxic, fine particulates can serve as carriers for toxic vapors and gases")
that fine particulates can adsorbs or abso*b gases in the air (e.g. radioactive Xe and Kr isotopes).
Likewise, (ibid, n.1)
" Fine carticules... generally defined as carticles smaller than 1 or 2 micrometers in diameter... nose a serious threat to human health.
They are small enough to elude the body's defense systen and to be breathed deen into the lower lung, where they can rennin-for long periods of time before being cleared.", citing Science 186 (1974) at p.695, DFS Natusch and J.R. Wallace.
See also citations re toxic vanor attachment to narticles, #10-12, of the Respirable Particles book by Derera & Ahmed (Ballinger, 1979).
.