ML20083A274
| ML20083A274 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 12/16/1983 |
| From: | Eddleman W EDDLEMAN, W. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20083A262 | List: |
| References | |
| 82-468-01-OL, 82-468-1-OL, ISSUANCES-OL, NUDOCS 8312200237 | |
| Download: ML20083A274 (4) | |
Text
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1 UNITED STATES OF AMERICA 16 December 1983 NUCLEAR BEGULATOBY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Glenn O. Bright Dr. James H. 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 1 and 2)
)
ASLFP No. 82-h68-01
)
OL Wells Eddleman's Resnonse to Final Environmental Statement (FES) on deferred contentions 85B, 8F(3)
I received the FES on 16 November by United Parcel Service.
Today is 30 days from that date; in line with the Board's 3-10-83 order and an oral order, here is my resnonse:
The FES, pages J-5 and J-6 (back of Anpendix J) describes the changes made from the DES in response to the Board's concerns on contentions 8F(3) and 85B.
On 85B, Staff cites revisions to section 5.3.1.2, apprently l
referring to section 5.3 1.2.1 on pages 5-2 thru 5-4 of the FES.
Since the CP, the design velocity of the plume has trinled, the discharge method has been changed to single-port (from 2 multi-port diffusers), and the discharge has been relocated. (p.5-2).
All of this info is the same as in the DES.
But the staff analysis does "O
j not anpear to fully resolve the issues.
For one thing (v.5-3 PES)
O Sg it assumes the reservoir is not stratified.
It likely will be.
So gg The Staff's rationale for assuming no stratification is that it n
R$
"would give conservative results because stratification and natural currents would urovide additional mixing of the effluent before it i
reaches the water surface."' (p.5-3).
But it looke to me as though
-2 such ndditional mixing would result in less ranid heat dissination from the lake surface, since the mixed water woald be cooler.
- Thus, in reality, heat dissipation would not be as efficient as in the Staff's model, and more of the clume heat would innact the lake, and be retained longer in it.
Fish do not just live on the surface (or very near it) In lakes like the Harris lake.
Moreover, the Staff does not exnlain how its model treats the main parameters (cited on o.5-2) of Applicants' model, e.g. wind speed, air temnerature, and air vanor-Dressure (nlus evanoration rates ).
It does not annear that tennerature or wind speed (or anything else other than the ulume tenperature above ambient) that affects cooling rates was entered into the Staff model (see list at botton of p.5-3).
The Staff describes its results yet again (p.5-h), but does not give the equations used to get them or tell where in the work of Shirazi and Davis the model they used is found, or even whether that model recuires or may use other innuts.
Surely such things as air temoerature, wind sneed, and cloud cover (as it affects radiant heat-loss from the reservoir, anc rates of evanoration) and insolation (solar heat incut to the reservoir surface) are innortant to heat-loss modeling, but they are not discussed by the Staff in the FES.
Indeed, Staff's entire revision is about a nage long, and their justification in Appendix J 1ess than another full nage.
The Board ordered (8/18/83 at 13) that Staff's " analysis must be nresented in a reviewable form... the DES fails to document or explain Staff's analysis."
The Board also said (p.1h) "Undating the forecast of the discharge plume behavior should be necessary in any event for other contentions that involve substances (rather than heat )... '"
Since the Board has left the carcinogenic chenical portion of 83/8h in dispute for the hearings, this should be done, but the FES does not appear to address the plume dispersion of these chenicals.
A surface
[
hot plume would tend to evanor to such chonicals mora (ecnecially TEMs, etc), whereas it apnears a well-mixed clume would tend to out then e
into water and sediment (and living organisms by infest $ on) nove, o
for creatures and nlants living in water or on the botton.
Finally, the Board stated (8/18/S3 at 13) that the Staff is
" required to factor the impacts resulting from the NPDES permit into a
its NEPA cost / benefit analysis."
I can't quite figure out how the Staff did that in the FES, as it annears to have the sane cost / benefit analysis as the DES on aquatic resources, conna-ing page 6-2 of the DES and nage 6-2 of the FES (summary of benefit-cost, Table 6-1).
CONKTENTION 8F(3):
Staff states, n. J-5, that it has revised Appendix C in the FES.
There, they cite only nage C-7.
But in Appendix C itself, other changes are made and marked in the FFS.
Staff used an estimate of 135 cancer deaths ner nillion nermson-rens for total body radiation exposure (n.C-h), which is the BFI9-I estimate (compare FES pp. 5-29/30).
Staff admits that up to 4 times these risks are nossible under BEI9-III's " relative risk" model (which is the sane model I have challenged individually i
and as a Joint Intervenor in contentions 37B and Joint II) (n.5-30),
but Anpendix C (pp C-8/9) does not even mention the higher estimates of BEIR*III, much less discuss alternative nodels that give hi her F
i estimates of cancer or genetic health effects.
(FES App.C uses 258 genetic erfects/million verson-ren, again a BEIn-I estimate).
i The revision does not annear to cite additional documents excent one on C-lh and the Branagan TMI testimony which annea"s to be on doses to the' kidney, etc.
The source of overall est! mates appears to be the same NUREG-0002 cited in the DES, for dose l
commitments, Apolication of the nodel to Harris is asserted but i
not exclained very well (FES op C-2 and C-3).
l
The relatively small changes in Appendix C do not anpear i
to show in any detail how the calculations were made by the Staff to figure the dose commitments.
At page C-h, the FES says section 5.9 3 1.1 describes the exnosure models in more detail.
But the only changes from the DES (per the side-linings) in that section (nn5-28 to 5-31) appear-to relate to occunational doses, not health effects models.
In sum, the Staff has added a few naragranhs and changed quite a few sentences, in all adding about a page to Annendix C.
I can't figure out their modeling of dose commitments from this.
CONCLUSION For the above-stated reasons, it does not appear to me that the Staff has really resolved the questions raised by the Board in deferring contentions 8F(3) and 85B.
Therefore I resnectfully request that these contentions be admitted on an aporopriate schedule (e.g. to be heard with the management capability contention in summer of 1984).
/h hM}9x_
Wells Eddleman