ML20093G121

Proposed Findings & Conclusions of Law on Eddlemen Contention 8F1 Re Health Effects of Coal Particulates.Nrc Consideration of Effects in Fes Inadequate

ML20093G121
Person / Time
Site:	Harris
Issue date:	07/20/1984
From:	Eddleman W EDDLEMAN, W.
To:
Shared Package
ML20093G124	List: ML20093G121 ML20093G134
References
82-468-01-OL, 82-468-1-OL, OL, NUDOCS 8407230331
Download: ML20093G121 (5)

Text

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2 UNITED STATES OF AMERICA ,

July 20, 198ligr.,

NUCLEAR REGULATORY COMMISSION %7c

'84 N 23 '

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 04 Glenn O. Bright l*( _ U Dr. James M. Carpenter ?il -*

James L. Kelley, Chairman In the Matter of

) Docket 50 400 OL CAROLINA POWER AND LIGHT CO. et al. ~

S ar Harris Nuclear Power Plant, ASLBP 11o. 82-1468-01

> oL Wells Eddleman's Proposed Findings and Conclusions Concerning Contention 8F1 (Coal Particulates)

As ordered orally by the Board on June 19, 198l, 4 I hereby attach a copy of my proposed findings of fact and conclusions of law concerning Eddleman contention 8P1 concerning the health effects of coal particulates.

Wells Eddleman l

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8407230331 840720 S gDRADOCK05000 hO

FINDINGS T FACT

1. Contention 8F11) states:. '.

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Appendix C of the DEIS underestimatos the environmental impact of the effluents in Table S-3 for tho following reasons:

(1) health effects of the coal particulates 1,1514 MT per year,  !

are not analyzed nor given sufficient weight. I

2. Applicants ' submitted the testimony and exhibits of Dr.

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Leonard Hamilton, Head of the Biomedical and Environments 1 Assessment

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Division in the National Centar for/ Analysis of Energy Systems at Brookhaven Nationn1 Labbratory.

3 The NRC Staff submitted the testimony and exhibits of Drs.

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I.oren J. Habegger (etivironnantal systems engineer in the Energy and Environmental Systems ^ Divisien, Argonne ' National Laboratory),

A. Haluk 6zkaynak (research fello$t and project Director for the Study on Health Effects of Exnosures to Airborne Particulates in the Energy and Environmental Policy Center at the John F. Kennedy School of Government, Harvard University) and Mr. Ronald L. Ballard, Chief' of the Environmental and Hydrologic Engineering Branch, Division o'f Engineering, Office of Nucle'ar Reactor Megulation at the_ Nuclear Regulatory ' Commission; these 3 witnesses anpeared as a panel.

1.

4 Wells Ed.dleman' presented one Exhibit', a. typescript by G.I,.

Fischer and D.F.S.' Natusch,," Size Dependenceof the Physical and Chemical Properties of Fly Ashk'.'(Tr. 1319) Witness Hamilton stated his opinion of this document' was . that "I .think on the' whole I 'an impressed by th& work of Fisher and Natusch _ f habe _ seen it, and i ,

it seems to b' oretty standard, liigh-quah.ity Nork." '(Tr. 1317-18).

5. The lower limit of health effects ofs coal particulates as set forth in Talale S-3 of 10 CPR 51.20 or the NRc rules, is'zero.

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l All witnesses agreed on this point. (See Tr. 1229, Hamilton; Staff Panel (witness 'dzkaynak) Tr. 1576-77) (See also Tr.1308, Hamilton,

" doe sn't make sens6 '. . .' . that bereathing these particle s- is. good f or you?"

l A: " Correct.")

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6. The upper bound of the health effects of the Table S-3 a

particulate emissions also needs to be examined, as all witnesses agreed. (Hamilton, Tr.1229 "And one really needs , if you are being realistic, to use both models ... rather than ... just ... this upper boundary of damage." Staff Panel, Tr.

Dr. Hamilton stated it is conservatuive to use the upner limit (Tr.1332)

7. Dr. Hamilton testified repeatedly daat particulates, as regards their health effects, were being used as a " surrogate for air pollution in general" (Tr. 1225; see also 1233-34 (Hamilton) fine particulates damage f unctions "are surrogates for air pollution as a whole. That's the way they are really being used and functioning."

See also Tr. 1237 ("very clear that when we use (damage functions) we are using them as a surrogate . . ."),1309, surrogate "for air pollution as a whole"; 1350-51, particle as a surrogate for air collution.) ,

7A. Total pollution related deaths range up to 50,000 -100,000/ year (Tr. 1309-10) {

8. Staff Exhibit # 1 (the Shearon Harris Final Environmental Statement, NUREG-0972) statea at page 0-2 that the air pollutants associated with the nuclear fuel cycle for Harris (per Table S-3) are about 0.02% of the national emissions of such pollutants. This is 2/10,000 of the national total (Tr.1311). The Staff panel testified, based on Council on Environmental Quality Reports (see Tr. 1478-81) that stationary source combu(ion products were 1.7 to 2.8 million (metric) tons per year (tr. 1480-81).

The Table S-31154 metric tons is , at minimum, a 0.04% increase in these emissions; at maximum, a 0.07% increase (Tr. 1485-86).

9. There is evidence both ways on whether coal particulates are more or less, dangerous than other pollutants in dae air, or other .

' See Staff panel, Tr. 1h13.

particulates . There are metallic ITr.1197) and organic (Tr.1326, e.g. ) .

All witnesses stated that these effects were captured in the uncertainty of the particulate damage functions. (Tr. 1h13-1414; Tr. )

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- s l 3 10 Howaysr, the croso-scetional studios do not ocpture air pollution data except for the year of a person's death. se(Tr In1 Witness

'dzkaynak, Tr. 1420 -21: "the variable . . . used for air pollution there is a concentration of pollutants in the year of a person's death?

A. That's Correct. Q. No previous years? A. No ") Both witness i

Hamilton and the Staff panel agreed that cross-sectional data do not pick up the effects of past exposure (beyond the year in which a person died) to particulates. *dzkaynak, Tr.142F22; Hamilton, Tr.1334

" . .. mortality you see represents not the mortality that is due to the year in which you are making the measurement but .. . it is this previous longstanding exposure to those pollutants that have gone on ,

30 or 40 years earlier. And that (mortality) is the result". See also Tr.1335 "...What you are seeing is the effect, either in the induction of cancer or the induction of chronic lung disease, (of) the very long term exposure to these particles in order to get the cancer or the lung disease manifest.")

11. Thus, even though all witnesses agreed the damage coefficients from the cross-sectional studies of air pollution health effects were statistically significant, and the best data available (Staff panel testimony at 33,3h; Dr. Hamilton, testimony p.10; tr. 1225), they do not capture these long-term effects.

12. Therefore, an upper bound can be conservatikvely calculated by taking the fraction of emissions of Table S-3 air pollutants s

nationwide, which is represented by the Harris plant fuel cycle (0.02% or 2/10,000, Staff Exhibit 1 p. C-2) and multiplying it by Dr. Hamilton's upper limit of total deaths due to air pollution (100,000 a year, see finding 7A, supra, Tr. 1309-10) times a 40 year plant operating life (as set in Staff Exhibit 1 for radioactive effluent extimates). This is approximately 800 deaths. This number is conserva-tive since not all deaths are solely due to particulates (Tr. 1310).

But the effects solely of particulates may not be separable. Dr. Hamilgton says they are not, see e.g. Tr. 1237.

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-h-13 Having established both an upper and lower end, it is appropriate to try to locate the middle, or more likely effects of the 1154 metric coal particulate tons org air pollutants specified for the Harris plant fuel cycle by Table S-x3 14 It is not annropriate to limit consideration of such health effects to just a 50-mile radius around the sources from which these particulates would be emitted. (See Tr. 1259: the same particle has the same health effects no matter where it comes from; health effects throughout the US are considered in Dr. Hamilton's second analysis; See also Tr.1569 (Staff panel) nothing stops the health effects at 50 miles, but the Staff's modeling is unable to capture effects beyond that distance (Tr. 1569-70)).

15 In considering nationwide health effects of coal particulates, it is appropriate to use Dr. Hamilton's 90 person-microgram /m3 por U.S. ton expmosure f unction. While this estimate could be improved stack by using the actual plant location and *

• height limited to 200 g(Cp fM T(v-BNL meters l 2 9'?L 51305, Hamilton reference 4, see Tr.1292, identifying Fig. 7, p.11 thereof; Tr. 1292, 1297, it shows isopleths of exposure depending on where the plant is located. The U.S. average expzosure 3

for a plant located randomly within the US is 92.6 person /pg/m pop g3 ton. (Tr. 1268; Tr.1271 (plant location); Tr. 1285 (US tons).))

Since a metric ton (2204 lbs) is 1.102 US tons, we can take 100 person pg/m3 per me tric ton emission as a good round number.

(see Tr. 1270 re round numbers).

16. The latest and most appropriate danage function is the Harvard fine particulate damago function of P.31 + 0.81 deaths per 10 5 3 persons per microgram /m year of exnosure. (See Tr. 1435-36)

A 95% confidence interval is apnropriate to use for thia data (2 l

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standard deviations ) (Hamilton, Tr.1331; 6+.S*

Staff4ct@M) f 3 2-panel Tr.1437) l l This range is 0.69 to 3 93 deaths /10 5person ug/m3 year. (see Tr. 1438-39 and correcting math by direct calcula tion.)

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This coefficient has a reduction of standard error, and increased statistical significance, compared to other measures (Tr. 11441-112 ) .

And it is based on fine particulates, the kind most emitted from coal-fired power plants. Witness Habegger testified he could not tell how much, if any, conservatism there was in assu-ing that all the fine particulates were emitted from the coal-fired power plant.

(Tr. 1473).

17 Applying the damage coefficient of finding no.16 and the nationwide exposure data to the 1154 metric tons of particulates specified in Table S-3, the following 95% confidence interval of likely deaths is calculated: 100 person pg/m3-Metric Ton, times 1154 metric tons, is 115,400 person-jug /m 3 of exposure per year.

The lower limit of the 95% confidence interval is 0.7 deaths per year per 100,000 (10 ) person-pg/m3 exposure (28 deaths over the 10-year 4 "politicant life" of the Harrt s plant), or about 32 deaths over the operating life of the plant for pollution calculation nurposes.

(115,400 x 28/100,000 is about 32). The unper limit is 3 9 deaths /

year (156 deaths / plant life) per unit of exposure, or about 180 deaths over the operating life of the plant. These estimates may be too hgigh in the sense that only 68% of the output of the coal plants is fine particulates, and the respirable particulate damage function is less than the FP function. See Tr.1287 Won-campling and samnling statistical errors could also affect it. (Tr.

18. Morbidity due to Table S-3 pollution ('ataff testimony, Table

3) ranges from 0 to about 3 emergency room visits, and 0 to about 45 respiratory disease incidents per year. This is about an upper limit l

l of 120 emergency room visits and 1800 disease incidents over a l;0-year plant life; lower limit is zero for all. (95% confidence limits. )

l CONCLUSIONS l

1. Staff's entire consideration of coal particulates was 2 lines ITP- 1315) This is inadequate.

in the FES

2. Adequate analysis would include the findings and conclusions above. i

1. fA d N N m m l i

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