NUREG-0812, Forwards Response to Comments on Des.Only Lochstet Comments Require Reply

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Forwards Response to Comments on Des.Only Lochstet Comments Require Reply
ML20197F672
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 10/21/1981
From: Congel F
Office of Nuclear Reactor Regulation
To: Schwencer A
Office of Nuclear Reactor Regulation
References
CON-WNP-0857, CON-WNP-857, RTR-NUREG-0812, RTR-NUREG-812 NUDOCS 8111090051
Download: ML20197F672 (3)


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MEMORANDUM FOR: Albert Schwencer, Chief Licensing Branch. #2, DL FROM:

' Frank J. Congel, Acting Chief Radiological Assessment Branch, DSI

SUBJECT:

RESPONSE TO CO M NTS ON WPP85-2 DES (NUREG-0812)

We have reviewed the coments received as of this date on sections of the WPPS5-2 DES which were supplied by RAB. Only the coments from Dr. Lochstet require a response, which is attached for your use. The reviewer was R. L. Gettisy.

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it Frank J, Congel, Acting Chief Radiolo@jcal Assessment Branch Division of Systems Integration l

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Im, pacts From the Fuel Fuel Cycle Dr. Lochstet's basic contention is that the health consequences of radon-22 emissions from the uranium fuel cycle are improperly evaluated in the WPPSS-2 Draft Environmental Statenent (DES, NUREG-0812). The basis for Lochstet's contention is that the staff has arbitrarily evaluated the health impacts of radon-222 releases from the wastes generated in the fuel cycle for 1000 years or less, rather than over all time. Lochstet estimates that radon-222 emissions from the wastes from each annual reactor fuel requirement will cause about 200,000 deaths over some large but undefined period of time (but presumably many 100-million years).

The major difference between the staff's estimated number of health effects from radon-222 emissions and Lochstet's estimated values is the issue of the time period over which dose comitments and health effects from long-lived radio-active effluents should be evaluated. Lochstet has integr,ated dose commitments and health effects over what amounts to an infinite time interval, whereas the staff has integrated dose commitments from radon-222 releases over a 100-year period, a 500-year period, and a 1000-year period.

The staff has not estimated health eff'c0 fn i radon-222 emission beyond 1000 years because predictions over time pg M, e eater than 100 yearsIare subject' to such large uncerta'inties that the calculations are of doubtful meaning.

l These uncertainties result from, but are not limited to, political and social --

considerations, population size, health characteristics, and, for time periods on the order of thousands of years or longer, geologic ar.d climatologic effects.

a In contrast to Lochstet's conclusion, at least one author estimates that the

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-2 long-term (thousands of years) impacts from the uranium used in reactors will be less than the long -term impacts from an equivalent amount of uranium left undisturbed in the ground. Consequently, the staff has limited its period of j

consideration to 1,000 years or less for decision-making and impact-calculational

purposes, aB.L. Cohen, " Radon: Characteristics, Natural Occurrence, Technoloaical Enhancement, and Health Effects," Vol. 4, Progress in Nuclear Energy, 1979.

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