ML20091M569
| ML20091M569 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/05/1984 |
| From: | Eddleman W EDDLEMAN, W. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20091M518 | List: |
| References | |
| 82-468-01-OL, 82-468-1-OL, OL, PLAD-840605, NUDOCS 8406110347 | |
| Download: ML20091M569 (15) | |
Text
_
p CORRE.SW DOCKETED UNC UNITED STATES OF AMERICA i
i Jug 5,Qhh2 55 NUCLEAR REGULATORY COMMISSION
. c c - ~- - c :
ter (1er:af -
BEFORE THE A'!OMIC SAFETY AND LICENSING BOARD 1
Glenn O. Bright Dr. James H. Carpenter James L. Kelley, Chairman In the Matter of
)
Docket 50 400 OL CAROLINA POWER AND LIGHT CO. et al.
)
I ar Harris Nuclear Power Plant,
)
ASLBP No. 82-k68-01
)
OL Wells Eddleman's Response to Summary Disnosition on contention 132(c)(2)
This is going to be an unusaal a response.
I have had an interrogatory to Applicants for some time to provide layouts of the instrumentation on the fronts of the control panels referenced in this contention.
Some small prints, totally illegible, were provided.
CP&L agreed to provide batter prints, and on May 81984 delivered a roll of blueprints, the outer one of which showed wiring to a control panel, and which were identified to me as 132(c)(2) prints.
However, on digging into them today, I find that they are cable tray blueprints related perhaps to Eddleman 116.
Thus I don't have the specific information requested from Applicants.
Their motion (p.7) notes my response on 4-12-84 saying the information of what specific instruments,(sizes, locations are obviously relevant) were on the panel fronts, was necessary for me to respond to their question.
1Judge Kelley orally auproved filing this today.
Staff response was rexceived May 30; a-signed affidavit with no exolanation was sent also, later, and received June h.
It anpears identical with the unsigned affidavit received 5-30-84
^
e406110347 840605 PDR ADOCK 05000
.G.
j
. Applicants neglected to state, however, that as of 4-212-8h they had~not provided such information.
When I realized that the specific references I needed were not available, I contacted Applicants' counsel Hill Carrow, who promised to look into it.
We have agreed as follows: If he finds that indeed the prints of the control panels were not delivered to me, I'll get 3 or 4 more days after delivery of them, to respond to the motions.
If he thinkgs the correct information has been delivered, he will respond to the Board, and allow me two days to respond to his response.
I am now going to check the 132(c)(2) discovery files for other relevant info showing the configuration and instruments on the fronts of the panels referred to in the contention.
After an extensive search, b u d d (J LR all I have found is a list of the drawings (Whe& the conies og were illegible), a not-tdscale sketch of the RCP vibration monitors on Panel 1, a not-t(scale drawing of the displays on Panel ih's panel for the keyboard, and a not-to-scale drawing of the Panel 15 Deewriter II keyboard.
Given the size that 'the jacks are drawn on Panel 1, it appears the sice is about 1;l (no scales are given), and if so, i
it would be difficult to read the RCP vibration monitors without l
L coming right up close to the panel.
This cannot be done directly from the locations specified.
Copies of these 3 documents and of a note from Edie Seykora McCrea of CP&L with my notes on it re receipt of. panel cover info, are attached.
The main response I can give without the panel front information is that radiation monitoring info displayed on panels some distance from ordinary operating locations, is not addressed.
But this information must be known to protect the health and safety of the public in an accident where radiation is being, or ght,be, released.
Ek' e
Wells Eddleman
Memomndum from 1
EDie Sxrxou D OY) a>an <ahn Wc z8/2$59-4/,'N lIfy g)))D
~
4di \\
GdCQ fPvo l34()
9 me)EOcal P. O. Box Jg1, Baleigh, N. c. g7eng
I l
CHAPTER 1 OPERATOR'S GUIDE
' Panel * /S dnbr
[carc[
LS12G OPERATOR CONTROLS AND INDICATORS (Figure 1-1) 02(4)riter E NOTE Det on switch indicates function of switch when pressed.
l r
(010FFl l04 (t)
,, r,cp gg F-moot --4-eaun mart i ese m
A
(
)
+l*
eacs
,,g g
. *atset e cT.
(5ELI g
2 3
4 5
6 7
8 9
0
- CE 3
eaoo e,o soo Q
w E
R T
Y U
I o
P c
(
L'y, Q',
LSCS C"'
- k",'
si,a,=o a,ro
= tat s
A S
D F
G H
J K
I
[
sairT sairi stPta7 o o o o o
'L'[?s" e*E:n I?t" "" 2'li u' set J
C* 2939
)
Figure 1-1 Keyboard k
PRINTER ON (1)/OFF (0) Switch l
The PRINTER ON (1)/OFF (0) switch connects and disconnects the line voltage to the LS120 DEC-writer Ill. The PRINTER switch should be in the ON position for normal operation. When changing paper or ribbon, adjusting the print head, or servicing the unit, the switch should be set in the OFF position. However, when the power is OFF, some of the preset conditions must be reset.
j PRIT4TER ON (1) Indicator i
When the PRINTER ON (1)/OFF (0) switch is set to the ON position, the PRINTER ON (1)in-dicator is illuminated. This indicates that the LS120 is receiving power and ready for operation. The PRINTER ON (1) indicator will blink after a paper out condition is detected or when the plastic paper cover is not properly closed. The blinking will continue until the operator types the paper out-reset (ESCO) on the keyboard.
l G
I l
'~'
000599
I
'D cb 1/3 O
O D
SYSTEM SPECIAL FUNCTIONS CilANNEL MONIT0il CONT!10 L SYS PillNTEll STOP PftlNT FLOW flLT PullGE C/S SEL 7
D ACK OFF LINE Lub.
CitT.
GRID
. Gill 0 GillD Gil00P TREND TilEND TilEND 1
2 3
MENU 10 MIN 110UllLY DAILY GiliD GRID GillD LOG MON CllA;J STATUS 4
5 G
MENU ITEMS ITEMS CLEAR ALARM
~
SCREEN ll!ST SYSTEM DISPLAYS -
CllANNEL DISPLAYS N0flMAL LAMP TEST SUPERV!SOR EL-33Cl-l Fig. 3-1.
R.'l-1 L licyliuant panel layout ihnel*/4-Rad A1on Console
'/
m 4
(
N-4ll enclosed A.w.
s t skefelies req,encec/ h ceaes,wt/mg Lej 1p.
KG.
?[e Rnel
- 1) 2CP l/;b /non: hor - Inst./1% vl (see Note / below)
- 2) Grass Rdled thel bek. - las4-asa shs. - /and 3 _. _
a) toose Ports /no46, - /sc 4-49e24.. _ s A s. - / a,,A 3. _ _..
M) Seismic /YlonLho - 13 & 4 - 44 3 5 9.. -...-_. _.. -. __.. - __ _.. __.
5} /9PD/h __(see nobe_A}.
.. C) Cig lioe) River A-U Lont -./36 4-Atoa.I.
.37 Cond Boasher Nycl. Cpi Cont ~. A/o Oukee Conheels- _-. _ _...
g
_.S3 Gen Peg - /A - /364 dt sva3
. _ _ 9) Gen Eekg- /B - /% 4:A s s a 9 _ _. __ _ _ _ ___
..to) S-U Xfme-IA - /36 4 - AI TG 4
(
/i) S-u W r - /B - /3 64 - Aless _
/$ Rhd &n S4 - /364-3s0Y7 and /364-so3a.s (W)
/3) End #!on 68- /364 - 3so'ts nct /364: 503A5 (ugen))
a i+) Rad An Console - Tech. Anal (see. note 3) -
/s) PA /non Petn+er -
reck. /%A - keyboard (Decuri$erE) 4/edere f'7000 5 shems qscationlAi.,benancs flanalsofas sevies 3
/\\
/
Sechion.G-
/
.x Dauving - l'i'l53 - L/iew AP Cabine Enserts
./%6 0 - D-Sia,'hions ihon%s k he placed in lnserts
/
\\
A&,>,A pg. A 2-a,/
x Fiure A3 I -/ Front t) sew of Rv:ek GppIy g
see en c iog eo(,kesci,e s D.riI
- I C005%
8 e
e,u @ @ on :n8 me os, a~ w6 ne -ino ora: s-t i
a
..ma 1
(Bicek cdrawlng^fo be 6 r i.hW ushtc1 Js +o ec 4e e-received ort.she lxber-[91w]).ee - --
1 A'tt. &.Gea<mI Atomte Teck siea,ml E-Jislos 1 Rns.-ii ops cm. tale.
o P e2=3 Etyre.3-L(kegloadJLeJ %out}.-
y m.m r<
em -
ea
-me=*
Nm9-h 6e*
w eami-
+9N we a-wwe
+h e
w eme-w e
e
,e-p mei>M
- 4***
N-h*--+
we
-N--4mm e
eA
-h p=
m e
M*
We we em -- enDh a-m meisimum e.
- em m o w <
e ce = M-6*
en-
+h eN-e m.em-e*w
-h emme e-m mw m.
m
.e gm,_
e iheg 4
em
- 8 6-*
6*
- h 6
N atm + N N6-e.mem-
--um-m
- - +
e g - demuume wege=
w a
m 6
e4-
.g
.mese.m Decem e
awe.
g
-e m
m.,,
m
,...,e e
% g, peg.
e w
,eis.
- M h
eku-e w
g=
q um 9
e e
r&g e
e-e me
-ma6i Ge d6
-eng e-.e e,.
,g,g.
m.
9 e
.e W
r-a T-'
CQL.
B&tk7 Lev NEVAPA EQuie Hest g
/- RCP lmb /helfor b"S l I
) ea. -
e e
Power. sorew n o o fb u ert serrty
- 3. i n n t e c recoa u ret
_vm' v w
-v O
O O
2 7<>a c, c e t u, e
er came Rc47 1.Anf T6s7 g
g
-,, / 2 78: 9 C PC sc L NY
@,,M O
k44.~
L CC.d 6 D Rotot G C CA ED KCTOS H ONivo R.
CMANNGL I
G l
t 2
I Luwo t o anx 0 0
0 nw os7 0
0 ma O.on 0 000597 c
e
~_
C.OL
%E ccT L E y N Et/ >l P r)
EQv>P l-Rcp ins /nis.
CD
,e
- vingarion visaa vieu y ec..
M OM t T J 6T, M O N # To it '
5--30 M
fl i**!$
e n,
bh 4* 5- -10 r A r5 x
0--O N
t/ve; (j7gg> c,g g,ggo}
AL6tf o FA
,3 3 ng u f ss, p
W
-- l 70CCLt S kt He d 'I'o 44 'D' REA P CAP 2.
T ES t'
'JACKI D
, - ~..
Q'T E '
3 Eu.
V 15. Ho Ni-ro n.5 Havs O-30 P// Hits Via. scg6 J
3 ea.
0 - 10
.. ~
f g
8 l
i i
m; Y-r Dockgt 50-400 This is the full text of Dr. Carl Johnson's 3
l l
Appandix B.
It includes the ovan-numborad tier 'A error.
I pages left out due to ahy pdA%w~-
6-5-%
pt/
l l Wells Eddlemy,,, m 8
4 No. 3 tsep e=sberk pp. 309-813. 1983 g 3933 Hulth Physics socorty l
Fergamos Pms Ltd.
LETTERS TO THE EDITORS f
Letters reflect the personal view of the author (s) and not n~essarily that of the Editors. Letters are reviewed only to determine the appropriateness of the subject matter, to exclude obvious errors and to assure good taste.
t I
Anonymous letters are not published.
Epidemiologic Investigation of Cancer Incidence The radiotoxicity of plutonium is of considerable in People Living near Nuclear Installations controversy. Dr. Morgan, calculates that permissible exposures of plutonium m bone should be reduced t
about 240 times (Mo75). Dr. Myers suggests a reduc-i (Received 18 August 1982) tion of the maximum permissible lung burden to 0.07 nCi (70 pCi, based on radiotoxicity to put-
Dear Editors:
monary lymph nodes,'a reduction by about 228 times Dama et al. calculated the feasibility of epi-of the official guidelines for maximum lung doses for demiologic studies of cancer in people living near the nuclear plant workers) (My72). A hundred. fold re-Rocky Flats plant (RFP) (Dr82). Such feasibility duction in these recommended occupational max-cvaluations and estimates of statistical power are imum permissib'e doses for the public would permit based on a chain of assumptions which must be a lung burden of only 70 fCi, and a body burden of considered step-by-step. Dreyer et al. state "fea-only 166fCi. A study of RFP workers found that sibility can be determined by reviewing the magnitude workers who have only 1-10'4 of the body burden of population exposure and estimating (a) how many permitted by current DOE guidelines (40G 5000 pCi)
. cxtra radiation-induced cancers may be expected to have about a 33*; increase in the rate of chromo-occur and (b) the statistical probability that the somal aberrations in blood lymphocytes (Br76).
occurrence of these extra cancers could be detected." These findings suggest that the current official esti-I Dreyer et al. focus on exposure to 0.37 fCi/m' of mate of the radiotoxicity of plutonium is not protec-
- Pu in air in 1975 as a basis for their dose estimates.'
tive by a factor of about 200.
In fact, SU alone accounts for a greater proportion Another area of controversy is the number of of the -emitters released in the plant's exhaust than. Denver area residents exposed to radionuclides from does "Pu (FRDA77). Americium-241 and "Pu RFP. Figure t in the Dreyer et al. report is taken.
from the plant may be more important than "Pu.
from "Krey and Hardy, HASL-255,1970" (un.
Plutonium-241 accounts for.more than 8 times more published) indicating contamination from RFP ex-radioactivity in the main exhaust plume than does tending for about 6 miles from the plant. Krey later
. "Pu (ERDA77). In addition, a number of other published a report in Health Physics showing a radionuclides other than actinides are released different figure, indica' ting plutonium contamination (ERDA77; CDH80; JO81). Thus, Dreyer et al. by of soil extending completely across Denver, to the considering only *Pu, consider only one of a broad southeast, well over 30km from the plant (Kr76).
spectrum of radionuclides released by RFP.
Dreyer et al. report that " leaking cutting oil drums Plutonium-239,240 in surface soil can serve as a were determined to be the actual source of con-surrogate to indicate the presence of a host of other tamination which began in about 1967." Actually, radionuclides released by RFP, although higher rela-this source of contamination began in 1959 and was j
tive activity may make other ra,dionuclides of greater a problem until 1968 (Se71). However, a Src and importance in air. Thus, *Pu which is released from explosion in 1957 blew out all 620 industrial high-the main stack in a ratio of 2:100 to "J"Pu, has been efliciency particulate air (hepa) filters in the main reported to account for 20-.19'4 of plutonium found exhaust system at the Rocky Flats plant and was a
. in air borne soil (Se77).
much more serious incident (DOE 70; DOE 58; Ow63; Wo71). The filters had not been changed in the 4 yr
- Although Dreyer et al., refer to an estimate based of the plant's operation. He p! ant requires this on air concentrations of "J"Pu, their estimate is extensive filter system to prevent large releases of
. based on the air ' oncentration of "Pu in 1975 plutonium and uranium to the environment, but is c
(0.37 fCi/m') reported by the D.O.E. Environmental only partially successful (Ow63).The rate of accumu-Measurements Laboratory (EML).
lation of plutonium on the filters was described in 809 8
e
,y 7
Yil 810 LETTERS TO THE EDITORS several RFP reports and a single filter could accumu-
\\
l late more plutonium than the ERDA-EIS acknowl-exposures. They cite Hardy et al who stud
\\
\\'
edges releasing throughout the period of the plant's sediment core taken from Standley Lake, loc operation (Ow63; Wo71). Most of the plutonium on about 4 miles from the plant site, and use their d the filters was for *>*Pu to make estimates of air concentrations
\\,
water-soluble plutonium nitrate
. (Ha70), which would not be represented by a core
- >"Pu between 1967 and 1974, and then make sample of sludge on the bottom of a nearby lake, calculations of 52*Pu in air in fCi/m' at EML site
')
upon which Dreyer et al. depend for most of their# 4 (To79).
estimates in their Table 1.
The only data for release of a radiation emitters A survey by plant personnel conducted after the that is complete for the period 1953-76 is that for kilogram (dpm/kg) of"possibic enriched uranium"infire found 12,000 d Rocky Flats plant, expressed in mci /yr (ERDA77).
the schoolyard at the Ralston Elementary School 12 These values can be disputed by reference to other miles southwest of the plant,16,000 dpm/kg of soilin reports (Jo81; DOE 70; DOE 58; Ow63; Wo the schoolyard at the Semper Elementary School 6 do represent one estimate of the relative rel plutonium" on pr,ivate land. (Plutonium concen-miles cast and 18 000d the plant over this period. Average plutonium con-centration measured in the exhaust, from the main trations were not reported for the schools (Ha58 )
stack at RFP has been reported (Ow63) and ranged
' was published last August by the Royal SwedishThis 1957 survey w from 27.27fCi/m' in 1954 (the first full year of in 1962. Stack air monitors were not operat Academy of Sciences (Jo81), and is not cited in the report by Dreyer er al.
during the fire and explosion (11 September 1957),
in addition to the release of plutonium oxide, but when put back in operation on 19 September plutonium nitrate and uranium on the filters, an 1957, recorded an average of 948,000 fCi/m' for that i
additional 12-20 kg of plutonium metal were burned day (Ow63). Daily exhi:ust volume is about 13 mil-j in the fire. An RFP report not'es that burning plu-lion m from the main stack.
8 tonium forms sub-micron sized particulates in air and
.Dreyer er al. refer to monitoring of plutonium in that these particulates do not settle out from indus-the ambient air in the vicinity of the plant "over the trial exhaust plumes, and do not account for the last 10 yr" by EML which, however, they did not cite (Kr70). The same comment would apply to thepattern of soil corbmination in air at site # 4 in 1976 for their dose estimates. S accumulation of filtered uranium and plutonium in# 4 is about one-half mile due east of the plant and the exhaust filter system which blew out in the' more distant from the usual direction of exhaust explo'sion, and to the routine releases of plutonium, plumes from,the plant than site # 1 (Kr76). The uranium and other radionuclides in the plant exhaust.
EML report indicates 1890 aCi/m of *Pu at site # 1 3
Plutonium and uranium and other 2 emitters are for June in 1970, rising to a peak of 2260aCi/m'in subject to the a recoil ph'enumenon, described in November, an average for the 7 months reported of Hea/r/ phyd:: in 1977 (Mc77). The highly energetic 1256 aCi/m (1.26 fCijm'). In 1971 levels were as high t
8
-projection of 2 particles from a emitters produces as 9730aCilm' an energetic recoil which drives off single atoms age for the year (9.73 fCi/m') for April, a of 5070 aCi/m' or 5.07 fCi/m'. An-and groups of atoms from the surface of par-nual average concentrations of "Pu at site # 1 in ticles. The effect is that small particles of plu-fCi/m were 2.90 in 1972,2.13 in 1973,1.76 in 1974, 3
tonium and uranium and other a emitters con-1.18 in 1975,1.18 in 1976, and 1.09 fCi/m' in 1977, i
tinuously are sub-dividing and self-scattering, and 2.07(Ci/m', or aboutor an average concentration over this 8 i.
migrate through filters and do not settle out 'to any 6 times greater than the great extent from industrial plumes, but can provide 0.37fCi/m' figure used by Dreyer et al. for dose
. a risk ofinhalation to persons in the path of those calculations, the concentration reported by Toonkel
. plumes.
er al. for EML site # 4 in 1975 (To79). Further, the Dreyer rr al. take inhalation as the only significant ERDA EIS report for the Rocky Flats plant states on
. pathway for human exposure to plutenium andp. 2-175 "as of 1975 the total site release from Rocky "therefore, sirborne plutonium must be estimated Flats had been reduced nearly 1000 times from 1965 l
from 19/7, the estimated time of the initial environ-levels" (ERDA77). Yet Dreyer et al. state "for the j
'RFP Hvidnm:%sta! emmination"(Dr82).'As iidicated by the purpose of estimating a 50-yr s dose it is assumed ental Impact Staten.ent, and data that the air concentrations as measured at site # 4 in from RFP eports sumrrarized in a recent report 1975(emphasis added) will persist without reduction (Jo81), thy have overlooked some very important from sam,pling site # 4 to other sites acco h
a e
'D A
~
4 LETTdRS TO THE EDITORS 811 ratio of the measured *2*Pu in soil." According to should bring us to question the apparently trivial the ERDA EIS, the concentrations of *Pu in air at emissions of a radiation from RFP reported by site #4 were about 1000 times higher in 1965, or ERDA (ERDA77). In any event,it is quite clear that equivalent to about 370 fCi/m'. At site # 1, nearer in looking at earlier years, the routine releases were the usual direction of exhaust plumes from the Rocky very much higher. His is confirmed both by the EIS Flats plant, the concentration of *Pu was report and by the AEC internal report indicating the 1.18 fCi/m' in 1975, and so could have been about measured releases of plutonium in the main exhaust 1180 fCi/m' in 1965 and earlier.
from the plant (ERDA77; Ow63). The trend over The calculated air concentrations by Dreyer et al.
time and the RFP reports suggest exposures ranging ranging from 0.27 fCi/m' in 1967 to a peak of 2.1 in from about 80 fCi/m' in 1959 to over 300 fCi/m' in
=
1969, can be compared to the measured releases 1965, four orders of magnitude higher than fallout between 1954 and 1962 from the main stack (Jo81; levels. Further, there is very good evidence that Ow63) and the reported " normal operational release" exposures in 1957 and 1958 were much larger than from all Rocky Flats glutonium facilities (ERDA77). these (Jo81).
The average concentration of plutonium in the ex.
Dreyer er al. cite Krey's estimate that the mean haust plume reported for 1962 was 1059 fCi/m', plutonium Icvels from world-wide fallout in soil in 2
equivalent to 5025pCi of plutonium released from the Denver area were 1.7 0.5 mci /km, and they the main stack alone that year (daily exhaust volume say that an equal or greater exposure than that from is about 13 million m'). This can be contrasted with world wide fallout would be necessary from RFP the ERDA claim that there was "a normal oper-before one could distinguish the cause of any in-ational release" of 2974 pCi from all facilities in 1962 creased disease in the pcpulation. However, the sub-(ERDA77).
micron sized plutonium partic!cs in exhaust plumes Since only 28*4 of 2 radiation released in the main simply do not settle out to any appreciable extent exhaust plume is ma"Pu, the amount of a radiation (Kr70). Isopleths of plutonium concentrations in soil released from the main exhaust stack alone in 1962 can only serse to identify the usual direction of can be calculated to be about 18,000 pCi, not consid-exhaust plumes from the plant over a period of years,
' cring releases from many of the other stacks or from and do not represent actual exposures to populations radioactive waste stored outside (ERDA77).
in the area.
The D.O.E. EML fallout data for New York City A study of surface dust on private land found the may approximate levels for plutonium from world-concentration of plutonium to be as much as 3390 wide fallout from nuclear weapons testing, although times higher than background levels in the area where there is more precipitation there than in more arid Krey shows plutonium in whole sois samples to bc parts of the U.S. such as Colorado (To79). The only about 30 times higher than fallout levels (Jo81).
annual average concentrations of plutonium in air for Further,the type of soil survey done by Krey et al.
New York City range from 0.006 fCi/m' in 1976 to a is designed to measure soilinventories of plutonium high of 0.07 fCi/m' in 1,970, probably cae to occa-to a depth of 10 cm (including fine gravel) and does sional weapons testing and perhaps n' o due to not get at levels of contamination of plutonium in nuclear installations located around New York City. surface dust or the windblown material on the surface j
The average concentration for the eight-yr period of soil as described by reports in Science (Jo76; Jo77).
,1 reported (1970-77) was 0.03 fCi/m'. This "back.
Another study reports 50,000 fCi of plutonium i
. ground from world-wide fallout from weapons-per g in air-borne soil (Se77) in the area (there may testing" can be compared to the estimates by Dreyer be 0.01-0.02 g dust /m' of air *), which can be et al. for the period 1967-74 for site # 4 at RFP.The compared to the 0.37 fCi/m of plutonium used by 2
average of the estimates of Dreyer et al. is Dreyer et al. to calculate population doses (Dr82). In 1.05 fCi/m', about 30 times higher than that for New fact, they based their estimates on air concentrations York City. The average concentration for *Pu at of plutonium, not on soil concentrations, because
'RFP site # 1 reported by the Toonkel group for the " inhalation is the only significant pathway for human period 1971-76 was 2.37 fCi/m'. This was over twice exposure to plutonium and other actinides (Dr82). It the average concentration for site # 4 estimated by seems that even the air concentration of plutonium Dreyer er al., and about 80 times the fallout level. selected by Dreyer er al. a concentration about 30 It is clear that these levels of plutonium in the air times greater than background levels ofplutonium in are due to RFP and not,to world wide fallout, and air, would meet their criterion for an exposure equal or greater than that from worldwide fallout necessary
'The frequency of dust storms of ambient concen-to produce detectable disease in a population.
3 tration 12 mg/m is approximately 14 days per yr over Dreyer et al. continue with their assumptions:
10 Great Plains states.(Sh74).
" Fifty-year a-dose estimates for basal cells in the a
S P
g
_2 ywm;
.mf.
h it 812 LETTERS TO THE EDITORS
\\
)
trachiobronchial tree and bone surface cells are 1974 June 1975, the average concentration of ura-
. shown in Table 2." Relying on the 0.37(Ci/ra' con. nium in air-borne particulates in the Denver area was centration of "J'Pu (actually only "Pu) measured 0.08 fCi/m' (EPA 76). The overall network summary in 1975 by EML at site # 4, they a* rive at a dose of for uranium, which includes sampling locations in 1
0.3 mrad to the basal cells in the trachiobronchial Alabama, California, Colorado, Fiorida, Idaho, tree, and 1.8 mrad to cells on bone surfaces over a North Dakota, New Mexico Nevada, New York, 50-yr period beginning in 1967, with correspondingly Ohio, Oklahoma, Oregon Pennsylvania, South Car.
smaller doses farther from the plant. The estimated olina and Virginia, was 0.05 fCi/m'(EPA 76). Some of average concentration of plutonium in the air over the uranium may have come from world-wide nuclear the period 1%7-75 i dicated by figures in Table I weapons fallout, some from nuclear installations.
l n
(Dreyer et al.) are 0.98 fCi/m'. The average venti-This view is supported by the measureable levels of s
lation volume of a person per yr is about 7000 m, or fissionable mU in air-borne particulates, which in y
3 for the 9-yr period in Table I, about 63,000 m'. If a Denver accounted for 0.005 fCi/m'. Are these levels 1-person absorbed most of the sub-micron plutonium of uranium in air important? Not in comparison with inhaled, using the air concentration of plutonium the much more radiotoxic plutonium.
i I
assumed by Dreyer et al., this would amount to an Dreyer et al. assumed that the air concentrations as intake of about 62 pCi of *Pu for that 9-yr period. measured at site p 4 in 1975 (see their Fig.1) would
.The total intake (adding 41 more years of the 1975 persist without reduction for 50 yr into the future.
concentration of 0.37 fCi/m') would be about Why not consider the effect of RFPs releases since it 170 pCi. A study of plutonium radiotoxicity in which began operation in 1953 and consider the much dogs were allowed to inhale I pCi of *Pu produced higher dosage levels which must have been sustained y
the following doses: 863 rem to lung,43.700 rem to by people in the Denver area in the 1930s and 1960s, pulmonary lymph nodes,3250 rem to bone,1320 rem and develop population radiation dose estimates i
to liver,170 rem to kidney and 46 rem to gonads from that data?
(Ba74). Similar doses were produced by the in-In summary, Dreyer er al. report that "the statisti-halation of I uCi of 2Am,52*Pu. Persons inhaling cal power for detecting one extra cancer against (an 170 pCi of "Pu alone, by these estimates (assuming equal effects in man) would receive about 144 mrem expected) background of either 4400 (lung cancea s) or 4
70 (bone cancers) would be no greater than 6%" and to lung, 7.4 rem to pulmonary lymph nodes, " generally, an epidemiological study would not be 552 mrem to bone,224 mrem to liver and 29 mrem to indicated unless the statistical power was at least kidney. This dosage estimate is several orders of 75%." This estimate of" statistical power"is based on i
. magnitude greater than that provided by Dreyer et al.
very questionable assumptions about radiation ex.
-(Talife 2), considers only one radionuclide of many posure levels ;o the population in the Denver area to released by.RFP, and considers not at all the much only one radioisotope, whose, air concentration was 1
larger releases actually recorded prior to 1975 and j
does not consider the really major releases in 1957 measured at one site in 1975 by"EML (Toonkel et al.
report only concentrations of-Pu in air). There are i
Also not addressed is the evidence that these larger a number ofimportant documents relative to offsite mrem doses of plutonium may actually be 200 or more times greater, due to an under-estimation of the contamination by the RFP which Dreyer et al. do not cite. One such report describes concentrations of radiotoxicity of plutonium (Mo75; My72; Br76). 50,000 fCi of plutonium per 3 n air-borne soil. Other i
l Thus the population dose estimates of radiation key studies of the efficiency of filters used to monitor exposure may under-estimate actual exposures by levels of plutonium in ambient air indicate gross l
more than five orders of magnitude.
underestimations of actual concentrations of plu.
To further minimize their estimates of. dosage, tonium in the air (cited in Jo81). Dreyer et al. do not Dreyer et al. estimate that the segmental bronchi of consider a host of other radionuclides other than th'e lung receive an a dose of about 140 rem over 50 yr "Pu acknowledged by the plant to be released from inhaled, naturally-occurring radon daughters, routinely, which would certainly contribute to the
., - and a dose to cells on bone surfaces of about 3 rem.
radiation exposure of persons dcwnwind from the However, the EPA estimates those doses to be only
+-
. 300 mrem to the whole body for a 50 yr period (or plant. Major releases of radionuclides by the RFP are
' 6 mrem yr)l and to the endosteal cells, I.2 rem for the simply not considered in the dose estimates made by Dreyer et al. and the chain of assumptions which
'50-yr period (24 mrem yr) for the average person in provide the foundation for dose estimates are abso-the U.S. (EPA 76).
Are the ambient levels pf uranium and its daugh-lutely criticat in any evaluation of the feasibility of the l
- ters really much higher in Colorado than elsewhere? type they have attempted to do. It is my view that the i,
Not according to the EPA. For the year of July weight of evidence presented in reports cited here indicates exposures to radionuclides released by the 4
e i
f..,
.l t
j q.
k odb ' :
1 7%
1m LETTERS TO THE EDITORS 813 l
1
. RFP to be more than five orders of magnitude greater Jo77 Jolmson C. J., Tidbdl R. R. and Severson R.
than those assumed by Dreyer et al.
C.,1977," Measuring Plutenium Concentrations in Respirable Dust", Science 196,1126.
Cant. J. Jomson Jo81 Johnson C. J.,1981, " Cancer Incidence in an University of Co!arado School of Medicine Area Contaminated with Radionuclides near a 42 Hillside Drive Nuclear Insta!!ation", 'Ihe Royal Swedish Acad-1 Denver, CO 80215 emy of Sciences, Stockholm Ambio 10, 176-182;
{
reprinted in Colorado Medicine 78,385-392.
i References Kr70 Krey P. N. and Hardy E. P.,1970, "Plu-
'Ba74 Barr N. F.,1974 " Quantitative Health Esti-tonium in Soil Around the Rocky Flats Plant",
mates of Transuranic Releases", Division of Bio-HASL-235, U.S. Atomic Energy Commission, medical and Environmemal Research, U.S.
Rocky Fla's Plant, Golden, CO.
Atomic Energy Commission, Washington, DC.
Kr76 Krey P. N.,1976, " Remote Plutonium Con-
.Br76 Brandon W., Bloom A., Saccomanno G.,
tamination and Total Inventories from Rocky Archer P., Archer V., Bistline R. and Lilienfield A.,
Flats", Health Phys. 30, 209.
1976, " Somatic Cell Chromosome and Sputum Mc77 McDowell W. J., Seeley F. G. and Ryan M.
Cell Cytology Changes in Humans Exposed to 222 T.,1977, " Penetration of HEPA. filters by Alpha Radon and 239 Plutonium", Progress Report, De-Recoil Aerosols", Health Phys. 32,445.
partment of Energy Contact No. E(2902) 3639 Mo75 Morgan K. Z.,1975," Suggested Reduction Rockwel! International, Rocky Flats Division, of Permissible Exposure to Plutonium and Other Health Sciences Group, Golden, CO.
Transuranium Elements", Am. Indust. Hygiene As-CDH80 Colorado Department of Health, U.S.
soc. J. 567-575.
Atomic Energy Commission, 1970-80, " Rocky My72 Myers D. S.,1972, "A Plea for Consistent Flats Plant Environmental Surveillance Reports",
Lung Burden Criteria for Insoluble Alpha. emitting The Colorado Department of Health.
Isotopes", Health Phys. 22, 905.
DOE 58 U.S. Department of Energy, Washington, Se71 Seed J. R., Calkins R. W., Illsley C. T., Miner DC,1958,"The Report ofInvestigation of Serious F. J. and Owen J. B.,1971,"Committec Evaluation Incident in Building 771 on September 11,1957",
of Plutonium Levels in Soil Within and Sur.
Dow Chemical Co.
rounding U.S. A.E.C. Installation at Rocky Flats, DOE 70 U.S. Department of Energy, Washington, Colorado", P F.P. IN%IO. The Dow Chemical l
D.C 1943-70. " Operational accidents and radi-Co., Rocky Flats Division, P.O. Box 888, Golden, l
ation exposure experience within the United States CO 80401.
Atomic Energy Commission", WASH 1192.
Se77 Schme! G. A.,1977, "In Transactions of Dr82 Dreyer N. A., Laughlin J. E., Fahey F. H. and Meeting on Rocky Flats Buffer Zone", Ecological Harley N. H.,1982, "The Feasibility of Epi-and Environmental Research Meeting, Rockwell demiological Studies of Caricer in Residents ocar International, Rocky Flats Plant, Golden, CO.
the Rocky Flats Plant", Health Phys. 42, 65-68.
Sh74 Shinn J. H., Kennedy N. C., Keral J. S., Clegg ERDA77 U.S. Energy Research and Development B. R. and Porch W. M.,1974, " Observations of Administration, Golde 2, CO,1977, Draft Environ-dust flux in the surface boundary layer for steady mental Impact Statement, Rocky Flats Plant Site and non-steady cases", in: Atmosphere-Surface 1545.D.
Exchange of Particulates and Gaseous Pollutants, EPA 76 U.S. Environmental ' Protection Agency, ERDA Symp. Series # 38, Conf. 740921, pp.
~
1976," Radiological Quality of the Environment",
625-637 (Springfic!d, VA: NTIS).
O.R.P.E.P.A.-520/a 76 010 Washington, DC.
To79 Toonkel L E., Feely H. E. and Larsen R. J.,
Hag 70 Hagan P. G. and Miner F. J.,1970, " Water-1979," Radionuclides and Trace Metals in Surface soluble Plutonium on Plenum Filters", CROL Air", Environmental Quarterly of the Environ-950355-4, The Rocky Flats Plant, Golden, CO.
mental Measurements Laboratory.
U.S.
De-Hams 8 Hammond S. E.,1958," Determination of partment of Fnergy, New York, NY 10014.
Contamination from Rocky Flats Plant in the Ow63 Owen J. B.,1963, " Reviews of the Exhaust Environs", Interim Report, Rccky Flats Plant, Air Filtering and Air Sampling", Building 771,
.. Golden, CO.
Rocky Flats Plant, Golden, CO.
Jo76 Johnson C. J., Tidball R. R. and Severson R.
Wo71 Woodard R. W.,1971," Plutonium Particu.
C.,1976, " Evaluation of Soil Contaminated with late Studies on Booster System No. 3 (Building Plutonium: Potential Air. Borne Plutonium Particle 771) Filter Plenum" The Rocky Flats Plant, Hazard in Respirable Dust on the Surface of the Golden, CO.
Soil", Science 193, 488-490.
e
)
l l
UNITED STATES OF AMERICA NUCLTAR REGU1ATORY C0! MISSION In the teatter of CAKOL'3A POWER k LIGHT CD. Et al. )
Docket 50-400 Shearon Harris Nuclear Power Plant. Unit 1*
)
0.L.
l U Wce & ldf W o(o((dif d l0 4 2a petu baa &6Mo ff(2d)
CERTIFICATE 0F SERVICE n
j 6)
EftYddDn" I hereby certify that copies of n=
^
l Summary Disposition on 132(c)(2). and of cam Jnknann Appendix b in full June 19%, by deposit in HAVE been served this 5
day of the US Wil, first-class postage prepaid, upon all parties whose f
names are listed below, except those whose nanes are marked with l
l an asterisk, for whom service was accomplished by Hand delivery of Johnson Appendix b in full, also Judges James Kelley, Glenn Bright and Janas Carpenter (1 copy each)
Atomic Safety and Licensing Board US Nuclear 9egulatory Commission Washington DC 20555
- George F. Trowbridge (attorney for Applicants)
Shaw, Pittman, Potts & Trowbridge ILuthanne G. Miller 1600 M St. NW ASLB Panel WashinEton, DC 20036 USNRC Washington DC 2055 5 OfficeoftheExecutiveLegalDirector(h ce W. Perry flGd) goo C nooia go Attn Docke ts 50-400/401 0.L.
I St SW
- N) y,*hin8 ton DC 20740 USNRC Washington DC 20555 Dan Read Docketing and Service Section (3x)
CEA?tT/FLP f0 Soy 2lf)*
l Attn Docke ts 50-h00/h01 0.L.
Raleigh,' M ;_2760& R
.. m s NC Office of the Secretary USNRC e
Dr. Linda W. Little washington oc 20555 Governor's Waste Mst. Bd.
J hn Munkle 513,Albemarle B1dg 325 N. Salisbut v St.
I" ' b 8 Granville Rd Chapel Hill Nc 2751k Bradley W. Jones Robert Gruber USNRC Region II
'Travi s Payne Exec. Director 101 Marietta St.
Edelstein & Payne Public Staff Atlanta GA 30303 Slex 12601 gox 991 Raleigh NC 27605 naleish NC 27602 Richard Wilson, M.D.
Certified by h
729 Hunter St.
Apwx NC 27502
-n-
,,_m.
,