ML20091G577

Testimony of Jj Mauro & SA Schaffer on Joint Contention Ii(E) Re Fly Ash.Related Correspondence

ML20091G577
Person / Time
Site:	Harris
Issue date:	05/31/1984
From:	Mauro J, Schaffer S EBASCO SERVICES, INC., ENVIROSPHERE CO.
To:
Shared Package
ML20091G548	List: ML20091G546 ML20091G556 ML20091G577 ML20091G604
References
OL, NUDOCS 8406040320
Download: ML20091G577 (35)

Text

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. .s 00CKETED REgTED CORggsp0NDNICE U3Nac M

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- l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

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) )

.c APPLICANTS' TESTIMONY OF JOHN J. MAURO AND STEVEN A. SCHAFFER ON JOINT CONTENTION II(e)

(FLY ASH) 1

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Table of Contents Page I. Introduction........................................... 1 II. Inhalation Dosimetry................................... 3 A. Significance of Joint Contention II(e) for Inhaled Radionuclides................... 4 B. Inhalation Dose Model............................. 5 C. Particulate Material in the Ambient Environment.............................. 10 D. Inhalation Dose Comparison....................... 13 III. Doses from Particle Deposition into Food Crops....................................... 14 IV. Conclusion............................................ 15 Attachment 1A - Resume of John J. Mauro Attachment 1B - Resume of Steven A. Schaffer Attachment 2 - Adsorption of Noble Gases onto Airborne Fly Ash References i

I 1.

i

• 1 I. Introduction My name is John J. Mauro. I am the Director of the Radiological Assessment and Health Physics Department of Envirosphere Company, a division of Ebasco Services, Inc.

Ebasco is the architect-engineer for the Shearon Harris Nuclear Power Plant. As indicated in Attachment lA to this testimony, I have a doctorate in biology and radiological health and am a certified health physicist. I have worked for the last twelve years in the field of radiological assessment, and have written a number of publications in this field.

My name is Steven A. Schaffer. I am Senior Radiological Assessment Engineer at Envirosphere Company. As indicated in Attachment 1B, I have a doctorate in biology and environmental health science. I have worked for the last ten years in the field of environmental assessment. I also have published in my field.

We have assisted Carolina Power & Light Company (CP&L) in the preparation of the radiological assessments contained in the Harris Plant Environmental Report (ER). We also have re-viewed the Draft and Final Environmnental Statements (DES and FES) prepared by the NRC Staff which assess the environmental impact of operation of the Harris Plant.

The purpose of this testimony is to respond to part of Joint Contention II(e), which states:

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The long term somatic and genetic health ef-fects of radiation releases from the facility during normal operations, even where such re-leases are within existing guidelines, have been seriously underestimated for the follow-ing reasons ... e) the radionuclide concen-tration models used by Applicants and the NRC

. are inadequate because they underestimate or exclude the fcilowing means of concentrating radionuclides in the environment .... radio-nuclides absorbed in or attached to fly ash from coal plants which are in the air around the SHNPP site.

A review of the pleadings on Contention II(e) reveals that the contention may be interpreted.as follows. The radio-1 nuclides in the routine gaseous effluent from the Harris Plant may become associated with fine airborne particles originating from the combustion of fossil fuels. It is contended that once bound to the. particles, the radionuclides will behave differ-ently than that assumed in the calculation performed by Appli-cants and the NRC Staff and, as a consequence, result in doses which are greater than those presented in the ER and the FES for the Harris Plant.

More particularly, Contention II(e) is concerned with two distinct. issues. The first issue is whether doses calculated via the inhalation route are underestimated because radio-nuclide adsorption onto respirable fly ash in the ambient atmo-sphere was not taken into account. It.is contended that this particle adsorption would cause more of the radionuclides in the gaseous effluent to penetrate deeper into the lungs and be retained forElonger periods of time. The second issue is u --

a whether the doses from the radioactive gaseous emissions, cal-culated by Applicants and the NRC Staff for the crop-food-chain pathway, are underestimated because the calculations did not account for radionuclides bound to particles depositing more readily cnto the ground, pasture and crops. It should be noted that these two concerns are not mutually exclusive. Increased radionuclide deposition on the ground due to particle adsorp-tion decreases the quantity of radionuclides available to be inhaled. However, for simplicity and conservativism, we will neglect the inverse relationship between particle deposition rate and inhalation dose and deal with the two issues sepa-rately.

With regard to the first issue, Joint Intervenors are challenging the inhalation dose conversion factors tabulated in Regulatory Guide 1.109. With regard to the second issue, Joint Intervenors are challenging the deposition velocities assumed in Regulatory Guide 1.111. This testimony demonstrates that neither of the concerns identified in Joint Contention II(e) invalidates the dose calculations performed by Applicants and the NRC Staff. ,

II. Inhalation Dosimetry In this portion of our testimony, we review the inhalation dose calculation methodology used by Applicants and the NRC Staff. First, we consider the significance of the phenomenon r.

L_i _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . . _ . _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

of radionuclides attaching to fly ash. Detailed consideration is then given to the bases for the inhalation dose conversion factors because this is where the exposure model treats parti-cle adsorption and subsequent lung deposition and retention.

From this review, it will be seen that the assumptions used to develop the inhalation dose conversion factors account for the concerns raised by the Joint Intervenors. Next, we describe the nature of ambient atmospheric particles, especially coal combustion fly ash, and show that the calculational models properly account for the presence of these particles. Finally, we present two calculations of inhaled dose, first assuming radionuclide binding to very small particles and then assuming low solubility. They demonstrate that, notwithstanding these assumptions, the calculated doses from inhalation remain unchanged.

A. Significance of Joint Contention II(e) for Inhaled Radionuclides It is important to understand that the phenomenon of con-cern in Joint Contention II(e), namely, radionuclides attaching to fly. ash in the atmosphere and then lodging in the lung, is only applicable to radionuclides that can take particulate form. This is because radionuclides that cannot take

- particulate form will not stay in the lung, but will be immedi-ately exhaled or absorbed into the body fluids. Tritium is not

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v in particulate form; it is inhaled as water vapor and, hence, that fraction not exhaled is immediately absorbed. Tritium makes up over 98 percent of the whole body dose from inhalation. See Table 1. Thus, the concern identified in

. Join,t Contention II(e) only applies to the remaining two per-cent of the inhalation dose.

Notwithstanding the fact that the fly ash phenomenon of concern in Joint Contention II(e) can have little impact since it only affects a small. fraction of the dose received by the public, this testimony considers whether the inhalation dose ,

model used by Applicants and the NRC Staff adequately accounts for this phenomenon.

B. Inhalation Dose Model The calculational method used by both Applicants and the NRC Staff is in accord with Regulatory Guide 1.109. The calcu-lation requireo four pieces of information:

1) the source term, expressed as curies per year (Ci/yr);

2) the atmospheric dispersion factor at the location of the maximally exposed individual, expressed in units 3

of curies per cubic meter (ci/m ) at a point offsite, per curies released from the plant per sec-ond (Ci/sec);

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3) the inhalation rate of the maximally exposed individ-ual expressed as cubic meters per second (m /sec); and

4) the inhalation dose conversion factor, expressed as millirem per picocurie (mrem /pCi) inhaled.

The product of these four terms, with appropriate unit conver-sion, yields the inhalation dose, as presented in the ER and the FES.

A discussion of the bases for the fourth factor, the inhalation dose conversion factor, is important because it is this factor which accounts for radionuclide lung deposition and clearance, which is the subject of Joint Contention II(e). The inhalation dose conversion factors used by Applicants and the NRC Staff are listed by radionuclide, organ and age group, in Tables C-1 through C-4 of Regulatory Guide 1.109. These values are expressed as the 50-year integrated dose commitment to the specified organ per unit of radionuclide activity inhaled (i.e., mrem /pci).

In order to derive the dose conversion factor values, a two-compartment lung model was daveloped which aimulates the behavior of radionuclides following inhalation. The model was first desscribed in ICRP-2 (1959). Upon inhalation of any ma-terial, the material is either immediately exhaled or it is de-posited in two areas of the respiratory region (the upper and lower respiratory passages). Once deposited in the two compartments of the respiratory system, the material is cleared at varying rates depending on the chemistry of the particle and the site of deposition. Once cleared from the lung, the mate-rial is translocated to other locations in the body and is eventually eliminated via radioactive decay and excretion. The dose conversion factors listed in Regulatory Guide 1.109 for

' inhalation reflect the time-integrated dose to each organ as the radionuclides are transported through the body following inhalation.

Deposition and retention of radionuclides in the lungs depend on many factors such as size, shape and density of the radioactive material, the chemical form and whether or not the person is a mouth-breather. At the time the lung model was developed, there was limited emperical data to determine the actual effects of particle size, shape and chemistry on lung deposition patterns. The model therefore makes assumptions about the deposition and clearance pattern of the inhaled radionuclides. Specifically, the model assumes that 75 percent of the inhaled material is deposited and 25 percent is immedi-ately exhaled. Of the 75 percent deposited, 50 percent is de-posited in the upper respiratory tract and 25 percent in the deep lung. The model also assumes that half of the insoluble particles deposited in the deep lung are removed in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and half are retained with a half life of 120 days (ICRP-2).

Soluble particles are assumed to pass through the lung.

7 b; _ _ _ _ _

More recently, several studies using human subjects have measured particle deposition in the lung as a function of par-ticle aerodynamic diameter. The term aerodynamic diameter re-fers to the diameter of a unit density sphere having the same terminal settling velocity as the particle under consideration.

Terminal eattling velocity is the equilibrium velocity of a particle that is falling under the influence of gravity and fluid resistance and is dependent upon particle size, shape and density.

A comparison of the experimental data and the assumptions in the lung model for percent deposition and distribution shows the model used to derive the dose conversion factors to be somewhat conservative. The percent particle deposition in the total respiratory system (upper and lower lung compartments) ranges from less than 10 to 100 percent of the total particles inhaled, depending upon particle size. (EPA 1982). However, the size of respirable fly ash particles in ambient atmospheres has a median aerodynamic diameter of about 2.0 micrometer (,pm)

(see next section). As indicated in the review by the EPA (EPA 1982), the deposition fraction for most particles in the size range of fly ash is about 30 percent but can approach 60 per-cent for sizes near the 2.Opm diameter. These fractions can be compared to the 75 percent fraction assumed in the model.

Thus, the model assumes a greater quantity of particles of the size of fly ash is deposited in the total lung than has actually been observed to occur.

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With respect to particle deposition in the deep lung, L where long term retention can occur, the emperical data indi-cate that 10 to 30 percent of the inhaled particles in the size range of 0.1 to 2.Opm is deposited (Figure 1) . This fraction als estimated to be less for nose-breathing (Figure 1).

Comparing the measured deposition fraction (10 to 30 percent) to the fraction assumed in the model (25 percent), it can be seen that the model is reasonable, if not somewhat conserva-tive, in its assumption of radionuclide deposition fraction in the deep lung. Therefore, the inhalation doses calculated by Applicants and the !!RC have not been underestimated due to in-appropriate lung deposition patterns.

Joint Contention II(e) focuses on the retention of parti-cles in the lung. Particle retention in, as well as subsequent translocation from the lung is also dependent upon the solubil-ity of inhaled material. The less soluble a radioactive parti-cle, the greater dose it will deliver to the lung. Thus, solu-ble radionuclides are rapidly transported into the body which tends to reduce the lung done, whereas insoluble radionuclides remain in the lung for a much longer time producing a greater dose to the lung and a much smaller dose to the rest of the body.

The inhalation dose conversion factors in Regulatory Guide 1.109 take into account lung retention based upon a solubility classification. Radioelements'are classified as soluble or unsoluble as follows:

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1 1

Radioelement Solubility H-3, C-14, Na-22, Na-24, I-129, I-131, Soluble I-132, I-133, I-135, Cs-134, Cs-137 Mn-54, Fe-55, Fe-59, Co-58, Co-60, l Ni-63, Sr-89, Sr-90, Zr-95, Nb-95, Insoluble l Ru-103, Ru-106, Te-132 Cr-51, Cu-64, /n-65, Mo-99, Ba-140, La-140, Ce-141, Ce-144 This classification is based upon the recommendations of the ICRP Task Group on lung dynamics (ICRP, 1966). Thus, the model accounts for the retention characteristics of radionuclides.

There is one group of radionuclides that has not yet been addressed in this discussion about inhalation dosimetry. These are the noble gases, xenon, krypton and argon. Because of their inert nature they do not bind significantly to particles or adsorb onto surfaces. This fact is confirmed by the calcu-lation described in Attachment 2 to this testimony. However, even if one assumes significant particle binding by noble gases, this is inconsequential to the resulting dose because the source terms of these radioactive gases would also signifi-cantly decrease due to holdup and removal of gases in the HVAC charcoal filtration system.

C. Particulate Material in the Ambient Environment In addition to the model's consideration of particle depo-sition and retention behavior in the lungs, data about ambient particle-size, especially coal fly ash,' confirms that the model

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effectively accounts for coal fly ash lung deposition and re-tention.

Data collected during the 1970s, which describe the dis-tribution of-atmospheric particulate matter in the United States, indicate the existence of three separate particle size modes having independent behavior in ambient air (EPA, 1982).

The first mode, the nuclei mode, is below 0.1 pm and generally consists of primary particles emitted as a result of fuel com-bustion (oil, gasoline, natural gas and coal). These particles are formed by condensation from the gaseous phase and only exist for short times due to rapid coagulation and aggregation.

The second size mode falls between 0. lpm and about 2.0,pm.

These particles typically remain airborne for several days, and this mode is called the accumulation mode. These particles are largely formed by coagulation of particles from the smaller mode and by aggregation of additional particles. Because of their relatively long life, these particles are the ones most easily transported from point source emissions. The third and final mode includes particles above 'about 2.Opm, generally pro-duced through mechanical action and easily' removed by washout and sedimentation. These particles exist in the atmosphere for only a few hours.

The most. prevalent particle mode present in the atmosphere

_around the Shearon Harris site,from an industrial source would be the accumulation mode. _This is because'the plant is located o l in a forested region with no major industrial combustion source within five miles of the plant (FSAR Section 2.2.1). In this rural, non-industrial area, larger particles ( > 2.0,pm) emitted from faraway sources would not be present because they would have rapidly settled out; however, smaller particles ( < 0.1pm) transported from faraway industrial sources would have aggre-gated and thus grown in size by the time they reach the site.

Not only can the particle size from industrial combustion sources transported to the Harris Plant vicinity generally be deduced based on area conditions, but it is possible to make certain assumptions about coal fly ash particle size in partic-ular. The results of a survey for coal plants equipped with electrostatic precipitators show a typical size distribution for fly ash with a median aerodynamic diameter of approximately 2.Opm (Figure 2). Thus, fly ash in the' atmosphere will be in the size range that is implied in the model. This is because the inhalation dose model used by Applicants and the NRC Staff assumes particle deposition fractions for the lung representa-tive of particles in the size range of about 0.1 to 2.0pm.

In summary, considering the sizes of ambient atmospheric particles generally, and fly ash in particular, it can be con-cluded that the inhalation dosimetry model accurately accounts L

.for lung deposition of inhaled ambient particles including fly ash at-the site.

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. D. Inhalation Dose Comparison Notwithstanding the above analyses, the doses calculated for the Harris. Plant vicinity would not change even if one as-sumes greater lung particle deposition, or longer lung reten-tion of radionuclides (due to decreased solubility) than are assumed in the calculation performed in accordance with Reg.

Guide 1.109.

Table 1 lists the breakdown of doses by organ and radio-nuclide. These are maximum adult doses which are expected to occur from the annual releases at Shearon Harris and were cal-culated using standard Reg. Guide 1.109 methodology. Based on these doses, the whole body dose is about 0.075 mrem and the critical organ dose (thyroid) is about 0.14 mrem. .

Table 2 lists a similar dose breakdown; however, the doses listed in this table were calculated assuming 60 percent radio-nuclide deposition in the deep lung. This is the maximum frac-tion observed from human studies (EPA 1982) as opposed to the 25 percent deposition assumed in the model. Doses were ad-

. justed using IC3P-30 (ICRP,-1979) correction equations for dif-ferent deposition fractions. Assuming a 60 percent deposition fraction, the whole-body dose remains about 0.075 mrem, and the dose.to the critical organ (thyrcid) is about 0.16 mrem.

In order to-assess the significance of alternative assump-tions regarding solubility, another calculation was performed.

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TABLE 2 Inhalation Dose Assuming All Radionuclides 0.lua AMAD Critical Organ (m rem)

Total GI Lung Skin

/Nuclide Body Tract Bone Liver Kidney Thyroid 7.44(-2) 0 7.44(-2) 7.44(-2) 7.44(-2) 7.44(-2) 7.44(-2)

H 7.44(-2) 3.69(-4) 7.17(-2) 0 0

I-131 1.23(-4) 3.78(-5) 1.51(-4) 2.15(-4) 1.79(-4) 1.49(-2) 0 0 I-133 3.14(-5) 6.15(-5) 5.99(-5) 1.03(-4)

'Mn-54 '6.23(-6) 7.65(-5) 0 3.92(-5) 9.75(-6) 0 1.39(-3) 0 Fe-59 3.39(-6) 6.01(-5). 3.77(-6) 8.89(-6) 0 0 3.25(-4) O Co-58 6.82(-6) 3.50(-4) 0 5.21(-6) 0 0 3.05(-3) O Co-60 2.31(-5) 4.44(-4) 0 1.80(-5) 0 0 9.31(-3) O Sr-89 6.46(-7) 2.59(-5) 2.25(-5) 0 0 0 1.03(-4) O Sr-90 5.59(-5) 6.61(-6) 8.64(-4) 0 0 0 8.01(-5) O 6.28(-6) 2.25(-4) 5.13(-4) 1.78(-4) 0 5.89(-5) O Cs-134 4 '. 39 (-4) 6.28(-4) 2.25(-4) 0 7.60(-5) 0 Cs-137 4.32(-4) ,8.50(-6) 4.84(-4) 7.55(-2) 1.81(-3) 7.59(-2) 7.54(-2) 1.61(-1) 8.88(-2) 7.44 (-2)

TOTAL 7.55(-2) w

1 1

Table 3, which presents the results of that calculation, illus-trates the dose breakdown assuming all radionuclides (except tritium) are insoluble. This calculation results in a whole body dose of about 0.74 mrem, and the critical organ dose (lung) is about 0.084 mrem.

When comparing the results listed in Tables 1 through 3, it can be seen that some organ doses increase, others decrease and others remain unchanged. However, the overall conclusion

-is that particle size and solubility have no significant effect on the final dose outcome.

In summary, the phenomenon of radionuclides attaching to fly ash impacts only a small fraction of the inhaled dose and, with respect to that fraction, the inhalation dose model used by Applicants and the NRC Staff effectively accounts for the attachment of radionuclides to fly ash particles in the-atmo-sphere around the Harris Plant.

. III. Doses from Particle Deposition onto Food Crops In order to assess whether the phenomenon of radionuclides attaching'to fly ash impacts the calculation made by Applicants and the NRC Staff of the food pathway dose for the Harris Plant, it.is necessary to examine the assumptions used in Reg-tilatory Guide 1.111 as to particle deposition velocities. This is because, in general, the' greater the deposition rate, the higher the dose from the food: ingestion pathways. Analysis of.

t

, o

..--m.-.-

_ m .

w

TABLE 3 Inha1ation Dose Assuming All Radionuclides Insoluble Critical Organ (m rem)

Total GI

.Nuclide Body- Tract Bone Liver Kidney Thyroid Lung Skin H-3 7.44(-2) ' 7.44 (-2) 0 7.44(-2) 7.44(-2) 7.44(-2) 7.44(-2) 7.44(-2)

'I-131 7.15(-6) 1.59(-3) 1.84(-5). 4. 0(-5) 1.12(-5) 0 1.59(-3) 0 1-133 1.36(-6) 1.73(-3) 3.50(-6) 8.54(-6) 2.12(-6) 0 3.02(-4) O Mn-54 2.64 (-6) 3.24(-5) 0 1.66(-5) 4.13(-6) 0 5.87(-4) 0 Fe-59 1.45(-6) 2.57(-5) 1.61(-6) 3.80(-6) 0 0 1.39(-4) O Co-58 2.84(-6) 1.46(-4) 0 2.17(-6) 0 0 1.27(-3) O Co-60 9.63(-6) 1.85(-4) -0 7.49(-6) 0 0 3.88(-3) 0 Sr-89 2.69(-7). 1.08(-5) 9.37(-6) 0 0 0 4.31(-5) 0 Sr-90 3.39(-5) 4.01(-6) 5.52(-4) 0 0 0 5.34(-5) 0

.cs-134. 3.43(-6) 4.36(-5) 8.84(-6) 2.16(-5) 5.37(-6) 0 7.63(-4) O Cs-137- 5.41(-6) .7.50(-5). 1.39(-5) 3.39(-5) 8.44(-6) 0 1.20(-3) 0 TOTAL 7.44(-2) 7.81(-2) 6.11(-5) 7.44(-2) 7.44(-2) 7.44(-2) 8.42(-2) 7.44(-2) i

deposition velocities establishes that the food pathway dose calculation conservatively accounts for the attachment of radionuclides to fly ash particles and the effect this phenome-non may have on the rate at which radionuclides deposit on the grou,nd.

The particle deposition velocities on which the Regulatory Guide 1.111 calculation is based were taken from Markee (1967).

These velocities range from 0.12 cm/sec to 1.81 cm/sec. At issue here is the validity of these rates, assuming radio-nuclides are-attached to fly ash particles.

EPA has published data (EPA 1982) on deposition velocities which are based on field and laboratory measurements. For par-ticles 0.1, 1.0 and 10;pm in diameter, the corresponding deposi-tion velocity is 0.015, 0.21 and 4.0 centimeters per second.

The median size of fly ash is.about 2pm. See Figure 2. There-fore, an appropriate deposition velocity for fly ash is slightly above 0.21pm/sec. This is well within the range as-sumed in Regulatory Guide 1.111. Thus, the assumed-deposition velocities are appropriate, if not conse vative for fly ash particles.

IV. . Conclusion In summary, the inhalation dose conversion factors used by Applicants and the NRC Staff appropriately' account for

.radionuclide adsorption onto respirable fly ashlin the ambient

-we-

atmosphere. In addition, the calculation of doses from the crop-food-chain pathway appropriately accounts for the binding I

of re.dionuclides to particles deposited onto the ground, pas-

- ture and crops.

k.

N e

y-o s

4 a .-c-- c s e

3-- -- +-- p ,w .. ---y ~ , y -

'.I.

ATTACHMENT 1A l

l Resume JOHN J MAURO Education: BS - Long Island University 1963 .

MS - New York University 1970 PhD - New York University Medical Center - Institute of Envirorsnental Medicine 1973 Awards: - Alvin Gruder Memcrial Award for Excellence in Biological Sciences

- Member of the Optimates Society for Academic Achievement

- Founder's Day Award for Doctoral Dissertation Societies: - Health Physics Society

- American National Standards Committee on Emergency Planning Certifications: Certified by the American Board of Health Physics Consultancies: - Radiological Health Bureau of the California Office of Emergency Services '

! - Battelle Memorial Institute

- Louisiana Power and light Company

- Shaw Pittman, Potts and Trowbridge

- EG&G Idaho

- Union Carbide Corporation - Nuclear Division Current Position: Director of the Radiological Assessment and Health Physics Department of Envirosphere Company in New York City.

Simnary of While a graduate student at the Institute of Environmental Professional Medicine of New York' University, I was also a full-time Experience: Research Assistant from 1970 to 1973. In this position I 4 assisted Principal Investigators on numerous research projects on the ecology and radioecology of the lower Wdson River Estuary. These activities included the collection of aquatic organisms from the estuary to detennine species abundance and

,~

diversity, the life history of white perch and the concentration of radionuclides in aquatic organisms, water and sediment. -

These activities also included experimentation into the ability of microorganisms collected from the Hudson River sediment to organify inorganic mercury.

In addition to my responsibilities as Research Assistant, I was a full-time graduate student, studying environmental health, health physics and radioecology. My doctoral research was on the radioecological behavior of Cs-137 in the lower Hudson River Estuary. Research for my thesis covered a three-year period which included extensive field studies and lab-j .. ortatory experimentation to identify and mathematically model

( the . uptake and elimination of Cs-137 by aquatic organisms.

/

- , , . . , _ . , _ . . _ _ . . , _ - . _ _ _ . - . _ , . , . . . _ _ . _ .a..__...-

, 9 After receiving my doctoral degree in 1973, I joined Ebasco Services as a Radiological Assessment Engineer. Ebasco Services is a major architect-engineer-constructor for power generating facilities. My initial responsibilities at Ebasco were to evaluate the radionuclide release rates from proposed and operating nuclear power facilities under normal plant operation and following postulated accidents, and to determine the radiation exposures and health risks to workers and members

' of the nearby general population. In this capacity I developed several models for perfonning radiological impact assessment, and have prepared the radiological impact assessment sections of license applications.

Since. joining Ebasco I have held positions of increasing responsibility, and am currently Director of the Radiological Assessment and Health Physics Department in Envirosphere Company, the Nuclear Licensing and Environmental Health Division of Ebasco Services. .In this position, I report directly to the Vice President of Nuclear Operations and, I am responsible for all radiological health and emergency

i. planning services provided by Envirosphere Company.

! I manage

! a technical staff of 10 senior level consultants with advanced degrees in nuclear and biological sciences, with a combined 150 years of professional experience in technological risk management.

My responsibilities as Director of the department are divided into radiological health consulting (40%), project management (30%), marketing and business development (20%), and department administration (10%). A brief description of each of these areas of responsibilities follows.

1 Though my management responsibilities have increased considerably since joining Ebasco, I continue to personally provide consulting services to our clients. These services include the analysis of radiological source terms, environmental transport, radio-ecology, internal and external dosimetry, health risk assessment, radiological surveillance, emergency planning, regulatory analysis and the preparation and defense of expert testimony on these subjects. Recently I have also become involved in l the evaluation of toxic chemical hazards at industrial sites and low-level radioactive waste management. These services have been provided for a large number of clients representing the nuclear power industry and federal and state agencies and their subcontractors.

[.

h

~. .

1 i

- i

~

I have also managed several consulting contracts in the areas of radiological and chemical toxicology, health physics, and emergency planning. A detailed description of these projects will be provided upon request. Most of these projects have been of a multidisciplined nature and included participation of specialists in the areas of toxicology, nuclear engineering, mathematical modelling, meteorology, hydrology and computer ,

- sciences. On these projects I had overall responsibility for budget, schedule and technical quality of deliverables.

As director of the Radiological Assessment and Health Physics Department, I am also responsible for developing and meeting an annual budget. The budget includes staff and non-staff salaries and out-of-pocket expenses for client billable work, department overhead and business development. My effectiveness as Director is judged by my ability to achieve or exceed the budget for billable work and to effectively control non-billable expenses. Non-billable expenses include business development, training and publications, presentations, participation on standards comittees and other professional practices. I have responsibility for hiring new staff and for staff perfomance review, promotions and merit increases. In this l

capacity I am assisted by 2 department managers who report directly to me.

Publications and Mauro, J J and M E Wrenn 1972. A Review of Radiocesium in Presentations: Aquatic Biota. Presented at the Health Physics Society Annual i Meeting, Las Vegas, Nevada, June 12-16,1972.

4 Mauro, J J and M E Wrenn 1973. Reasons for the Absence of a Trophic Level Effect for Radiocesian in the Hudson River Estuary. Presen ed at the IRPA meeting held in Washington, D C in October. Published in the proceedings of that meeting.

Mauro, J J and J Porrovecchio 1976. Numerical Criteria for

In-plant As low as is Reasonably Achievable. In " Operational

Health Physics". Proceedings of the 9th Mid-Year Topical Symposium of the Health Physics Society. ,

Mauro, J J D Michlewicz and A Letizia 1977. Evaluation of Environmental Dosimetry Models for Applicability to Possible Radioactive Waste Repository Discharges, Y/0WI/SUB-77/45705.

I Mauro, J J 1978. Comparison of Gaseous Effluent Standards i for Nuclear and Fossile Fuel Power Production Facilities. l Proceedings of the December 1979 Annual Meeting of the American Nuclear Society.

J Thomas, J J Mauro, J Ryniker and R Fellman 1979. Airborne

~ Uranium Its concentration and Toxicity in Uraniun Enrichment Facilities, K/P0/SUB -79/31057/1, February.

l

-4 Lind K E Mauro, J J. J D Levine, L Yemin, H J Howe, Jr and C W Pierce 1979. Safety Related Research Required to Support Future Fusion Research Reactors. Presented at the Annual Meeting of the American Nuclear Society-San Francisco, November,1979.

O'Donnell E P, and Mauro J J 1979. A Cost-Benefit Comparison i

of Nuclear and Nonnuclear Health and Safety Protective Measures and Regulations. Nuclear Safety, Vol 20 No. 5 September-October,1979.

Mauro, J J 1980. A Real Time Computer Program for Offsite i Radiological Impact Assessment. Presented at the 1980 Annual Meeting of the American Nuclear Society. TANSAO 34 1-899.

Bhatia D., Mauro, J J and G Martin 1980. Effects of Contain-ment Purge on the Consequences of a loss of Coolant Accident.

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

Marschke S, and Mauro, J J 1980. Radiocestun Transport Into Reservoir Bottom Sediments - A Licensing Approach. Presented at the 1980 Annual Meeting of the ANS. TANSA0 34 1-899.

Mauro, J J and D Michlewicz 1981. Deployment Concepts for Real Time Environmental Dosimetry Systems. Presented at I the 1981 Annual Meeting of the Health Physics Society.

Mauro, J J and E P 0'Donnell 1982. The Role of the Architect /

I Engineer in the Emergency Planning Process. Presented at the Annual Meeting of the American Nuclear Society. June l

6-10, 1982.

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 and Radiological Indices Evaluating Toxicity.

National low-Level Radioactive Waste Mana9ement Program.

l DOE /LLW-17T. March, 1983.

Vold E, J J Mauro and D Michlewicz 1984. Dose Projection I for Nuclear Emergency Response on a Microcomputer. Published in " Computer Applications in Health Physics." Proceedings of the Health Physics Midyear Topical Meeting, Pasco, Washington. February 5-9, 1984.

Mauro, J J S Schaffer, W Rish and J Parry. Application of Probabilistic Techniques to Dose and Risk Assessment Performed by EPA in Support of 40 CFR 191. Submitted for Publication.

8:

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> < = ..

ATTACHMENT 1B

STEVEN A. SCHAFFER Senior Radiological Assessment Engineer i

SUMMARY

OF EXPERIENCE (Since 1973)

Total' Experience - Ten years. experience in the design and i

implementation of-research and assessment projects addressing

the problems of environmental contamination and human health affairs.

Education - PhD,'. Biology / Environmental Health Science, New York University, June 1982 MS, Biology, 1978, Ne'w York University BS, Biology, 1973, State University of New York, 4

Oneonta REPRESENTATIVE ENVIROSPHERE PROJECT EXPERIENCE (Since 1981)

High Level. Waste Provide technical and regulatory support to the DOE concerning the proposed EPA standard on high-level. waste (40 CFR 191).

i This support: included:

~

- 1. Co-authoring a report submitted by the DOE to the EPA Sci-ence Advisory Board. .This work quantified the uncertainty in the EPA-health risk estimstes used as the basis of the proposed regulation.

2.- Critically; evaluated the REPRISK methodology'used by the  ;

EPA for determining the risk from high-level waste.

3. Acted as a technical liaison between DOE and EPA espe-ll -

~c ially in the area of environmentalLtransport.

' Provided' technical and regulatory. support to the DOE concerning high-level waste disposal in salt. Responsibilities included.

formulating a safety plan for a salt repository and developing-

~

- technical interpretations of current.high level 1 waste regula-tions..

L '

Low-Level Waste-s

~

- Aided:in the preparation of a toxicity index for the' radio-logical-and toxicological-hazard in low-level waste for the-

- DOE.

t M '

,9 .

. ,j -

tW D g r ~ - = < v e r e'" w - * + - -

• h e- -*- ---- ----'* - * -

5 IGeneral Radiological Assessment

Evaluated'the' radiological impact of nuclear power plant oper-

-ation for Ebasco client utilities. Prepared postulated source

' terms : and: subsequent doses to surrounding areas for Safety Analysis:and Environmental Reports. '

Aided'inithe preparation of testimony on the synergistic action oof' radiation and chemical carcinogens.

-AssistedJin the preparation and implementation of an environ-mental radiological. monitoring program for a nuclear power plant.

-Prepared testimony on the radiological effects of coal fired 4

s electric. generating facilities.

Developed uncertainty distributions for environmental pathway

' model parameters-that were utilized in an uncertainty analysis of the environmental' risks of high-level waste.

PRIOR EXPERIENCE (8 Years)

Research Scientist New York University Medical Center, Institute of Environmental Medicine, Laboratory for Environmental Studies, Tuxedo, New York'10987.

Member of a research group for.3 years, examining the transport and ultimate fate-of nuclear reactor produced radionuclides discharged into the Hudson River estuary. Responsible for the Beta / Gamma emitting nuclide portion of this project, Conducting-Ph.D, thesis research on the effects of~ alpha radia- -

tion'a'nd polychlorinated biphenyls (PCBs) on the biochemical energy production of algae.

~

. Assisted in laboratory'and field research which analyzed the aerobic and. anaerobic degradation of PCBs.

Assisted in a-field and laboratory research program which stud-L

'ied-the biological and physical transport of,PCBs and. heavy .

. metals in the Hudson; River.

i f

-Carried'out and-subsequently. published.the-results of labora-- '

tory experiments dealing'with the effects of.high LET radiation lon the-survivalfand energy metabolism of algae.

Supervised and conducted,Hfor'5 years, field sampling programs fortnuclear; power plant entrainment, studies'on the' Hudson

" River. Solely responsibleLfor a~research; project designed to

, ' Lassess.the effects of-different. sampling gear on:

( icthyoplankton.

M M-4 p g , A.' .y ,, g n , , . -

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

Assisted in an ichthyoplankton population survey of the Hudson River.

Conducted and reported on thermal tolerance and chlorination bioassays with fish and numerous invertebrate plankton as part of-a nuclear power plant entrainment study.

Masters-research involving the quantitative and qualitative chemical analysis of Hudson River water.

. Publications O'Connor, J.M. and S.A. Schaffer, 1977. The Effects of Sam-pling Gear on the Survival of Striped Bass Icthyoplankton, Chesapeake Science 18:312-315.

Schaffer, S.A. and C.C. Lee. Organic Carbon and Protein Con-centrations of Hudson River Water in the Vicinity of Indian Point. (abstract) American Society of Limnology and Oceanography Annual Meeting, 1978.

Steinhausler, F., S.A. Schaeffer, N. Cohen, C.C. Lee, J.M.

O'Connor, M.E. Wrenn. Effects of High LET Radiation on In-tracellular ATP Content of Prokaryotic and Eukaryotic Algae.

Abstracts of the 26th Annual Meetings of Radiation Research Society, Toronto, Canada, May 1978. Radiation Research 74:591-92.

Steinhausler, F., S.A. Schaffer, C.C. Lee, J. O'Connor, and M.E. Wrenn, 1980, Effects of Low-Level Alpha Radiation on

, 'Intracelular Energy Metabolism. Radiation Research 81:393-401.

Rish, W.R., J.J. Mauro, S.A. Schaffer. 1983. Uncertainties in EPA Modeling Used to Develop Draft Standard 40 CFR 191. ' Pro-E ceedings of the American Nuclear Society, Winter 1983.

Schaffer, S.A.-(accepted for publication). The bioenergetic

, response of chlorella vulgaris to alpha radiation. Environ-mental and Experimental Botany.

Professional Societies Society of Environmental Toxicology and Chemistry (SETAC).

4 l

-3.

' - e v

,. 1

'6 l

Attachment 2 Adsorption of Noble Gases onto Airborne Fly Ash The fraction of the annual release of radioactive noble gas from the Shearon Harris site absorbed onto airborne fly ash particles can be estimated by the following relationship:

Fraction Absorbed = Conc.g, Conc.t Where Conc.f, = weight of fly ash (g) .

Kd 3 3

m g

= stable gas (g) radioactive gas (g)

Conc.t .

m 3 ,3 Using these equations, we have calculated the fraction absorbed onto fly ash for Kr-85, Xe-133 and Ar-41. These radionuclides were chosen because they represent the three elemental types released and'are the worst case combination of half-life and release quantity.

Table A-1 lists the various parameters used in cur calcu-lation and Table A-2 lists our results. In summary, an insig-nificant fraction of radioactive noble gases released from Shearon. Harris ~would become associated with airborne fly ash' particles. -It should be noted that the actual fracticn wouldf

probably be lower than the quantity calculated, because the calculation assumes.a fly: ash concentration representative of:

the maximum total respirable airborne particle . load.for-2-1 L _

o.

northeastern cities, which is a higher concentration than ex-

- ists in the vicinity of the Harris Plant (Pedco 1982, EPA ,

1 1982). Moreover, our calculation is additionally conservative l

because it assumes that-all particles have surface adsorption j

. characteristics of activated charcoal, which is nanufactured for the specific purpose of efficiently adsorbing radio-nuclides.

4 i

e 2-2

%4 k

't Table A-1 List of Parameters Parameter Value Notes Fly ash concentration 1x10 -4 1 3

(g/m )

Adsorption coefficient (g/g)

-10 Krypton 1.5x10

~9 Xenon 2.3x10 2

-11 Argon- 1.07x10 Concentration of stable gas in atmosphere (g/m )

-3 Krypton 3.8x10

-4 Xenon 2.9x10 3 Argon 1.6 Radioactive gas concentration 4 3

in atmosphere (g/m )

-6 Krypton-85 1.7x10

-6 Xenon-133 4.4x10

-12 Argon-41 1.9x10 Notes:

1. The concentration of all respirable particles in large industrial N.E. cities can be as high as 1x10~4 3

g/m (Pedco 1982). .The calculation assumes the fly ash concentration around Shearon-Harris site to be equal to this concentration.

2. Adsorption coefficients for fly ash was assumed to be the same as activated charcoal (NUREG-0678) divided by-a reduc-tion-factor of 332 to account for the difference in specific surface < area.

3. Taken from CRC Handbook of Chemistry and Physics 64th ed.

4. Concentration of radioactive noble gases was calcu-lated by multiplying _the annual site releases by the annual av-erage atmospheric' dispersion factor for the critical residence (3.2 x 10-6 ,,c7,3),

2-3

r;

)

1 1

i Table A-2 Fraction of Annual Release of Radioactive Noble Gases Absorbed to Airborne Fly Ash Particles

- Radionuclide Fraction Absorbed 4

5 4 Kr-85 1.2x10 3

Xe-133 2.4x10 2.0x10 9 Ar-41 f

I A

L 4 f 9

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4 W 3-

~.;. . . .- - - ,

6- y- ---c. $ - pap. - <-pm-----4 y- -4.

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References CRC Handbook of Chemistry and Physics 64th ed. 1983-1984 R.C.

.Weast [ed.], CRC Press, Inc., Boca Raton, Fla.

EPA. 1982. Air quality criteria for particulate matter and sulfur oxides,.Vol. II and III. NTIS-PB84-120419.

.ICRP-2. 1959. Recommendations of the International Commission on Radiological Protection. Report of Committee 2 on Permissi-ble Dose for Internal Radiation. ICRP Publication 2, Pergamon

. Press, London.

ICRP. 1966. Deposition and retention model for. internal dosimetry of the human respiratory track. Health Physics, 12:173-207.

ICRP. 1979-82. Limits for intakes of radionuclides by workers. ICRP Publication 30. Pergamon Press, Oxford.

Markee, E.H. Jr. 1967. A parametric study of gaseous plume depletion by-ground surface adsorption, in Proceedings of USAEC Meteorological Information Meeting, C.A. Mawson [ed.],

-AECL-2784: 602-613.

Natusch, D.F.S. 1978. Potentially carcinogenic species emit-ted to the atmosphere by. fossil-fueled power plants. Environ-mental Health Perspective Vol. 22: 79-90.

NUREG-0678. The effects of temperature, moisture, concentra-tion,. pressure and mass transfer on the adsorption of krypton and xenon on activated carbon.

-Pedco, 1982. Ccmpilation of ambient particulate matter size and composition data. Pedco Environmental Inc.

Regulatory Guide 1.109. 1977. Calculation of annual doses to man from rectine releaset of reactor affluents for-the purpose of ovaluating compliance with 10 CER part 50, Appendix I. Rev.

1., U.S. Nuclear Regulatory Cornission.

Regulatory Guide'l.111. -1977. Methods for estimating atmo-spheric transport and dispersion of gaseous effluents in rou -

tine releases from light-water-cooled reactors. Rev. 1., U.S.

' Nuclear Regulatory Commission.

.