ML20154E349

Licensee Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard (Contention 5d).*

ML20154E349
Person / Time
Site:	Three Mile Island
Issue date:	05/16/1988
From:	Doris Lewis GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20154E212	List: ML20154E208 ML20154E230 ML20154E247 ML20154E268 ML20154E285 ML20154E293 ML20154E313 ML20154E325 ML20154E349 ML20154E368 ML20154E383 ML20154E406
References
OLA, NUDOCS 8805200184
Download: ML20154E349 (4)

Text

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3 May 16, 1988 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE' ATOMIC SAFETY AND I.ICENSING BOARD In the Matter of )

)

GPU NUCLEAR CORPORATION ) Docket No. 50-320-OLA

) (Disposal of Accident (Three Mile Island Nuclear ) Generated Water)

Statior., Unit 2) )

LICENSEE'S STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD (Contention 5d)

Pursuant to 10 C.F.R. 5 2.749(a), Licensee states, in sup-port of its Motion for Summary Disposition of Contention 5d, that there is no genuine issue to be heard with respect to the follow-ing material facts:

1. Both Licensee and the NRC (through the U.S. Department of Energy's Radiological and Environmental Sciences Laboratory) have analyzed processed accident generated water to determine its radionuclide constituents, including alpha emitters such as transuranics.

2. Licensee has also performed a technical evaluation of

. accident generated water and, using the ORIGEN Code, has calcu-lated the radionuclides (including tritium and alpha emitters 8805200104 080516

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such as transuranics) of any significance potentially present'in

, the water.,

3. There are transuranics on the Periodic Table other than those identified as present in the accident generated water, since not every transuranic is produced by a reactor to an appre-ciable extent.

4. Licensee has calculated individual and population doses due to evaporation using the Meteorological Information and Dose Assessment System (MIDAS), a code which has been approved by the NRC and which is based on the methodology in the NRC's Regulatory Guides 1.109 and 1.111.

5. Licensee calculates that the dose to the maximally ex-posed individual from evaporation is 2.0 mrem to the total body and ?.6 mrem to the, bone; and of these doses, 1.4 mrem to the total body is attributable to tritium, and essentially all of the 3.6 mrem to the bone is attributable to Sr-90.

6. Licensee has assessed the contribution of uraniums and

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transuranics identified as potentially present in evaporator effluent and has determined that none contribute even as much as 1% of the dose attributable to strontium.

7. The NRC has independently calculated doses to the maxi-mally exposed individual and to the population from evaporation, and has assumed for purposes of these calculations that uraniums and transuranics are present at the lower limit of detection.

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8. The NRC calculates that the maximally exposed individ-ual will receive 0.7 mrem to the total body; 0.8 mrem to the bone, and'4 mrem to the thyroid.

9. Tritium has been extensively studied, is the subject of the National Council on Radiation Protection and Measurements (NCRP) Report No. 62 and NRCP Report No._63, and is addressed in the 1980 Report of the National Academy of Science's Committee on the Biological Effects of Ionizing Radiation (BEIR III).

10. Based on many studies of tritrium, the NCRP has stated that:

". . . it is reasonably conservative to assume, for the purpose of practical hazards considerations, that there is no significant transmutation effect for tritium incorporated in DNA, and that one may er.timate hazards solely on the basis of absorbed beta dose. . . . There is, at present no reason to consider the RBE for chromosome aberration production by beta rays from incorporated tritium to be different from one." (NCRP Report No. 63)

11. Applying the conservative risk estimators from the BEIR III Report to the population dose calculated by Licensee and to the population dose calculated by the NRC, the risk from evapora-tion of a single fatal cancer among the 2.2 million people residing within 50 miles of TMI ranges from 0.0003 to 0.005.

12. The risk of a genetic effect or fetal injury is considerably smaller.

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13. The contribution to' risk from transuranics, due either-to chemical toxicity or to radiotoxicity, is inconsequential.

14. Thus, tritrium and alpha emitters such.as_transuranics have been fully evaluated in connection with the proposed evapo-ration of accident generated water.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE N _

DbE-/h]

Thomas A. Baxter, P.C.

David R. Lewis Counsel for Licensee 2300 N Street, N.W.

Washington, D.C. 20037 (202) 663-8000 Dated: May 16, 1988.

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