ML18026A299

Forwards Comments on Draft Suppl to Des,Addl Comments on Des & Util News Release.Draft Suppl to Des Re Pond Hill Reservoir Is Inadequate & Incomplete.News Release Bolsters Contention That Need for Plant Was Inadequately Assessed

ML18026A299
Person / Time
Site:	Susquehanna
Issue date:	06/10/1980
From:	Mann D, Sade T SUSQUEHANNA ALLIANCE, LEWISBURG, PA
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 8006170503
Download: ML18026A299 (49)

Text

Susquehanna Alliance P 0 Box 249 Lewisburg, Pa 17837 June 10, 1980 U S Nuclear Regulatory Commission rFashington, D.C. 20555 Mt: Director, Division of Site Safety &

Environmental Analysis

Dear Sm/Madam,

Ne are enclosing several documents which we hope wiLL be of help in improving the quality of the Draft Envt"onmental Statement and its Supplement which have been ozepared in relat'on to the planned operation of the Susquehanna Steam Elect"ic Station Units L & 2 (Docket No's 50-387 and 50-388). On May 26 we requested and were granted a 15 day extension of time in which to submit. these comments by Mr Singh Bajwa, the %C Envtzonmental Project Manager for the project.

The documents enclosed include 1) a sunanazy of the reasons we feel the Draft supplmsent to the Draft mvtronmental impact statement vith ega.rd to tha pond Hill Y R~e

'r is tnadeguate and incomplete; 2) comments on tha Draft Statmsant itself to supplement our comments submitted on August 17 which reinforce our bel'ef that as an Environmental Impact Statement this document is inadequate and incomplete, and

3) a copy of a recent PP&L news release which bolsters our contention that an inadequate assessment oz the need for the pLant has been done.

Ne hope that these comments will be of value to the staff in continuing the crocess od dully and diligently evaluating the .uii ~an e od impacts of the proposed operation of the Susquehanna Steam Electric Station. Tt is our opinion that in order to adecuately add ess the azeas of concern raised by us and other commenters, extensiv revisions to the dzaft must be made. Zn this context we request that a second d"aft, be 'ssued and be made available for further public comment before the final EZS is adopted. Please let us Resow if this request wiLL be honored.

Sincezely, for the Suscuehanna Alliance

COMMENTS ON DRAFT SUPPLEMZÃ2 TO DRAFT EIS FOR THE SUSQUZ2RNNA ST~ ~CTRIC STATION l) One of the conclusions drawn by the Staff of the %AC's office of Nuclear Reactor Regulation and of paramount concern to residents of the vicinity is that construction of the "Pond Hill" water storage eservoi will have a significantly negative impact on water quality. Zn particular, the supplement states that nutrient levels, specifically phosphorous, "will considerably exceed" the criteria established hy the Environmental Protection Aqency for nutrient levels and thus "Ne aatential that eutzophic conditions i will occuz in the pond Hill reservoir is relatively high". Missing fram the statement

's a polution abatement or mitigat an plan by the applicant. Until such a plan is included, this d aft supplement is incomplete.

2) The safety analysis of the project is clearly insufficient, especially given the unpredictable nature of the Susquehanna River and its tributaries, and the fact that severe flooding has occured in the egion twice within the last eight years as a result of ext"aordinarily heavy rains from t "opical storms Agnes (L972) and Eloise (l975) in unprecedented concentrations. The maximum flood danger and impacts of overtapping the dam have not been adequately assessed, a rathez glaring ammission in light of the NRC's mandate to arotect the health and safety of the public. Specifically, the staff

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i noted in sect'on 4.4.2.3 that:

Zf <<the dam were to he overtopped the staff believes <<that the dam could fail.

The loading that would result from failure of the dam would pzoduce rapidly rising water eLevations downstream of the dam site. The aotential exists to t aa and drown aersons and wildlife in the downst earn flood lain durin such flo~d~cl (emphasis added). The potential for hearn to pattens using Route 239 and the railroad during such flooding also exists.

The issue of safety should he settLed on <<the conservative side, with the maxi@nun benefit to and ozotection of the public the ove iding consideration. These hazards aze not acceptable and a plan to mit'gate these dangers should he included.

3) The report daes not adequately address the consideration of alternatives ta the const=action of the Pond Hill Reservoir. The use of the Any Corp of Enqineers Cowanesque Reservoir now under constwction in Pennsylvania has not been ully explored, espec'ally in Light of the aaplicant's own admission that the costs of this alternative over a 30 year per'ad would be $ 12 million" (as compared with the $ 48-50 million cast of Pand if Hill, $ 63 mil'ion aroperty taxes are t eated as an additional project cost). In fact the Staf has concluded that:

The best economic alternative would a gear to be the use-an-existina-zeservoir-alternative (emphasis added). Based on the information available, Cowanesque appears to be the most economic among all alteznat've reservoizs, given hat concerned authorities grant the use of water for f'ow augmentat'an.

The Baltimore Dist=ict Carps of Engineers is currently studying the feasibility af madi ying the existing project to include water supply storage as a project purpose in addit on to flood cont ol and recreation. Zt is elt that Axis modification would increase the economic efficiency of <<the Cowanesque Lake P oject. Preliminary findings indicate that "Ms could be done without affecting the flood control capabilities, that substantiaL releases could be azovided 'nto the Susquehanna River during law stream flow periods and these releases would generally improve the riverine envi onment during naturaLLy Low st eamf low periods. Rather than expend over $ 63 million on what may become a put=id, stinking lake at Pond Hill, "he utili"y and "Ne public would be better served hy the applicant's agqzessive.investigation of the esources required to effectuate

SUPP'~ CCMHEHTS CONTXNUED the necessary approval foz their use of the Cowanescgxe pro)ect.

Zn addition to the foxegoing c iticism regarding alternatives to De proposed IQ pro)ect, the applicant and staff have not fairly treated the "No Action" oz "River Following" alternative, whereby SSES would merely shut down during times of low flow in the Susquehanna River. Based on an average annual occurence of Low flow of 4 days (a roughly 904 pxobability according to table Ss3) "the cost of Pond HiLL Reservoir alternative weald be very class ta tbe replaaeseat cast ad elsctrlalty cadet tbe rivex'ollowing alternative". Given <<the excess capacity figures of both the applicant and the PJM interconnection, the staff concluded that "PPQ could provide reliable sezvice to its customers even during a short interval of shut down of SSES". The attached press release fzom PPQ. provides support for this statement.

4) The finaL area of comment in regard to this pro5ect concerns the impact of the pro)cot on the cultural resources of the area. Although the appLicant is committed to cd out an archeological survey" and certain preventative measures i resources are discovezed, the applicant. does not specify in sufficient detail what those measures if will be and what, any, action will be <<Men (including halting construction) if substantiaL resources are in fact discovered. This suxvey should be performed before an EZS is prepared and the resul<<ts included. The applicant has illust"ated in the cons~motion undertaken at the recreation azea near the plant that cuLtuzal esources. A repeat of this performance must not be allowed.

it has no regard for

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ADDZTXONhL COMMENTS ON DRAPE KVTERONMENTAL STATEMENT FOR SSES

1) The report does not adecpxately address the cont'nuing and even escalating contx'ovezsy regarding the health effects of continued exposure to low level radiation. Zn addition,"

no mention is given to what has been dubbed the "Heidelberg Report" which has also been t"anslated and printed by the NRC as "Radioecological Assessment of tM Whyl Ql$ Nucleaz Power Plant". ln studying existing data on the t ansfer actors to plant Life (and ultimately human tissue) of certain radioactive isotopes emanating from operating nuclear powex'eactors, tha authors of the report conc3.uded that the NRC's judgments on how much plutonium, cesium, st"ontium, etc was picked up from tha soil g((- were "between 10 and 1,000 times to low". Even mora out"ageous than the error factor calculated by the W German scientists is their contention that the oLd AEC in an attempt to moLLify c itics of earlier nucLear policy, deliberately rigged the experiments to minixdze the high transfer factors inherent in the isotopes. The steps inc3.ude, but weza not Lated. toe

a. pze-testing and selection of soi3.s so as to choose those which absorbed the minimum amount of the isotope

b. adding radiotoxic substances to the soil short3y before hazvestingg thereby avoiding realistic conditions, where plants would grow from seeds in the contaminated soil

c. cooking the soil in ovens to reduce the hactexiological ef ect upon tha isotope and thus assuxe lower readings The Heidelberg Report is the first time t Mt independent scientists have examined the VRC's safety assurances about routine emmissions from operating plants. Although, in all airness, or only it should be noted that the report may have come into the NRC's hands after short3.y before the release of the Draft Environmental Statement for SSES, its conclusions wa=ant a thorough review of the issues raised, not only by tha KC, but envi onment before it can he considered complete.

2) It is interesting to note that in the Draft Supplement to the Draxt EZS, the applicant orcmises that it is "committed to carry out an axchaeological survey" and to take whatever preventative measures are necessary to protect cultural resources.

inherent in that position is that no such survey was undertaken or even alluded The'rony to for the or'ginal project itself, one that involves considerable mora expense, area, and intensity of constzuction than the Pond Hill Reservoi . In addition, part of the plant's secondary construe<<d.on involves establishment of a recreation area on the Low-Tying flat3.ands adjacent to the Suscg:ehanna River, similar areas of which have proven to he archeoLogical motherlodes of information on and relics of pre-ex'ting indigenous popuLations. As the applicant itself notes in Appendix 8 to the Draft Supplement ...

Such assessments (inventories of historic or archeological resources which may 36 ~ he impacted by the proposed const action aze to he made oursuant to 800, Section 106 of the National Historic Preservation Act of 1966 as amended (16 USC 470) . hy Executive Ordex 11593, May 13, 1971, "Protection and ~ancement of the Cultuzal Environment", and by the President's Memorandum on Environmental Quality and Water Resources Management, July 12, '78.

The appLicant should he zecpxized to conduct, such an inventory in compliance with the

lf CGMKWZS QN DRAFT EIS CQNTZHUEO above-cited Legislation, regulations, and executive pronouncements, before constmction continues and an opera~~ g license is granted. In addition a plan or mitigating the damage one by const~ction should be implemented.

3) The Staff and app3icant's cost-benefit analysis do not adequately reflect the impact of a renewed anthxacite industry on the region. In an analysis prepared recently xo r the Susquehanna Alliance entitled "Economi.,, Social, and Envi"onmental Impacts of Renewe) Mining in the AntMacite Region", it was found that a revitalization of this

'ndus +, especiaLly one employing new open-pit mining technolcgies, could remove al 3.

econo cally ext"actable coal and xestore pxesently unusable areas to productive land uses, rove water cuality beyond ~Joe requirements of the Pennsylvania Clean Streams Law, create 1500 new jobs in mining and related indust ies, and stem the outmigzation of young people zom the area. All of this could be accomplished in the process of producing a fuel cost-competive (based on BTU equivalents) with those currently in use.

Again we state our belief tMt the operation of SSES will preclude the need for such an industry and the loss of these benefits should be indluded in the cost-benefit analysis.

4) As with all othex'nvi"onmental Impact Statements relating to the constzuct'on of.

nuc3.ear power plants, the Staff and the utility concerned have dismissed out of hand the possiblity of a serious, or Class IX accident and the health effects of such a catastrophe on De Local population. Although th's omission will be addressed shortly a suaanazy of the President's Council on Environmental Quality's generic criticisms of, the entire EZS process, it is especialLy glaring both in Light of the recent events at T.'G and SSES's proximity to that cxippled reactor, whexe in the Staff's own estimation (made in conjunction with a proceeding dealing with the Salem plant) a Class ZX accident did occur. A thorough eview of the possibilities of such an occurrence at SSES should be made <ut is site-specific not only to the nature of "".e technology employed by De applicant in the constwction of the plant and certain geographic and geologic feature but which also t."aroughly reviews, analyxes, and assesses the probabi3.'ty of success of a Laxge-scale evacuation of area residents should such a measure be necessitated by ex" aozdinazy events at the site. Zf the NRC 's to even begin to estoze public confidence in its ability to safely regulate the nuclear indust~, the attitude that "it can't happen here" must no longer be standard operating proceduze.

5) In a x'ecent letter to John Ahearne, Chairman of the NRC, Gus Speth of the President's Council on EnvizonmentaL Quality outLined severa3. generic deficiencies, which he characterised as "disturbing in the NRC Impact Statement Process of nuclear power eac ors.

The most damning of C Q's cxiticisms was that the, discussion of potential accidents and their environmental impacts in these ~<act statements was "perfunctory, remarkably standardized, and uninformative to the public". Speth found that despite wide variations in the si"e, locat'on, and design of nucLear power plants that have been

(.licensed by the SEC, "viN:nally every Eya cnntains essentially identiaal "beilesylate"

'anguage written in an unvarying format". The ailure to consider the worst case, ox'lass ZX accident is exemplified in the Statement prepared for the Licensing of TNZ Units I 5 IZ, where no consideration is given to the C3.ass ZX scenar'o. his omission looms quite large in view of the Staff's own view that such an acc'dent did occur on Narch 28, 3.979.

Speth also urges the Commission to "broaden its ange of variables (e.g. rad'at'on pathways) in determining accident's impacts, and expand 'ts discussions in EZS's of the

CCK2KNTS QN OBAPT EIS CONTINUED impacts of nuclear accidents on human health, the natural environment, and Local economies". Once again, t&s criticism seems to stem from the belief that EZS's as currently prepared are simply general zegurgitations of pre-existing data and positions that bear Limited if any relevance to particular and unique site-specific information.

The inability to t anslate this information in non-technical terms easily comprehensible to the general public also meets with C Q's disapproval.

"-inally, Soeth suggests that the %C vigorously pursue the goal of fulfilling to the u'cost extent the requirements of the National Envi onmental Protection Act and the "Legi~te public interest in full disclosure of nuclear plant hazards" (emphasis added) in the obvious belief that such disclosure has not been a top priority of the NRC's agenda in pzeparing Environmental Impact Statements for the operation of nuclear powez plants.

We believe it is the 'responsibility of the NRC to bring the EZS's they pzepare wit~

the guidelines set by CEQ. Until this is done fcr the d"aft EIS in question here, emafns wholly inadequate and incomnlete.

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V 09 1979 f\

i VIEHORAffDUli FOR:. Donald E. Sells, Acting Chief Environmental Projects Branch 2, DSE

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FRO! t: 'ho-as D. Yiurphy, Chic'f

=,'adiological Assessnent Branch, DSE

SUBJECT:

'. s RESPO"!SE TO CO lf~IE!fTS Of'/ DINFT Efl'JIROÃi~iEHTAL STATEt",E;"T Orf SUSgUEHAf,tfA U.'fITS 1 R."fo 2

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'In response to your memorandum dated September 20, 1979, enclosed are our responses to cor.".-,ents on the Draft Environmental Statement

'QES) on Susquehanna Ug~ and 2 (IIUREG-0564); Several changes are needed, in the radiological sections of the Final Environmental Statement because of a change in source terms. Changes to Sections 4.5 and 5.3 of the. DES will bo sent to you .after we receive new source terms from ETSB.*

Thomas D. fiurphy, Chief Radiological Assessment Branch Division of Site Safety and Environmental Analysis, ERR

./I!ote: Stone our response to corn.;est(i5-I Is also dependent on the

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new source term, it will be sent'fith" our marked-up copy of Sections 4.5 and 5.3 of the DE .

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Enclosure:

as stated cc: 0. ffuller H. Kreger F< .Congel

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RESPONSE TO COHHENTS ON DRAFT ENVIRONMENTAL STATEHENT ON

'US(UEHANNA UNITS 1 AND 2 Comment 85-4, H. L. Hershey I strongly disapprove 'the issuance of any license to operate the Susquehanna plant until you have:

... can be sure through independent studies that the effects of low level radiation emitted from the plant over the 30 to 40 year life span will not harm the public.

Response

See response to comment 85-1.

Comment 88-2, T. A. Drazdowski Sierra Club A preliminary review finds the report flawed and incomplete in the following:

...2. Discussion of the health effects of radiation and radioactive waste disposal do not note the present controversy among scientists concerning risks, safe dosage, and waste disposal techniques.

Response

The risks from waste disposal are addressed in Section 4.5.5 "Uranium Fuel Cycle" of NUREG-0564. See response to comment 85-1 for additional information on potential health effects associated with effluents from Susquehanna Units 1 and 2.

Comment $ 9-1 EPA

)v'e request the NRC to explain the changes which allowed a five to seven fold increase in projected gaseous iodine releases (found by comparison of the Statements of 1973 and 1979) and to explain why the increases did not result in any substantial change in the associated doses to a child's thyroid. (For details, see the Draft Statement, page 4-16 versus page G-56, and 4-18 versus G-75, 77.)

In support of this request, it may be noted that our 1973 comments on projected gaseous iodine releases and associated doses were sharply critical, and we recommended the use of engineered iodine control systems and other design modifications to reduce iodine release such that the offsite dose to a child's thyroid did not exceed 5 mi llirem per year. Our comments are reproduced in the Draft Statement, pages G-151, 152.

Comment 89-1, EPA - cont'd The 1973 response to those comments, shown on page G-123, item 11.13, stipulated use of design modifications, and referenced a revised radiological impact as described on page G-77, section 5.4.1. Even though section 5.4.1 noted the existence of uncertainties in the cal-culational model, and the dose impact has now been recalculated using new source-term calculations, per page 4-1, but the Statement. does not contain any specific discussion of lessened impact per unit of iodine release. This discussion of lessened impact per unit of iodine release must be incorporated in the Final Environmental Impact Statement.

Response

The models used in estimating doses in the environmentaI statement for the operating license are state-of-the-art models. The source term, meteorological dosimetry models have been improved since the issuance of the construction permit. These models have been reviewed by the U.S. Environmental Protection Agency in regards to implementing the Uranium Fuel Cycle Standard (40 CFR 190). The doses calculated by these models are thought to be conservative (i.e., the models probably overestimate actual doses).

Comment f9-3, EPA He are encouraged that the NRC is now calculating annual population dose commitments to the U.S. population, which is a partial evaluation of the total potential environmental dose commitments (EDC) of H-3, Kr-85, C-14: iodines and "particulates." This is a big step toward evaluating the EDC, which we have urged for several years. However, it should be recognized that several of these radionuclides (parti-cularly C-14 and Kr-85) will contribute to long-term population dose impacts on a world-wide basis, rather than just in the U.S. To the extent that this draft statement (1) has limited the EDC to the annual discharge of these radionuclides, (2) is based on the assumption of a population of constant size, and (3) assesses the doses during 50 years only following each release, it does not fully provide the total environmental impact. Assessment of the total impact would (1) incor-porate...by estimating the health impact for a period reflecting multi-generation times.

Response - Comment 89-3, EPA The staff does not believe that presently available worldwide dose models are capable of making such projections with meaningful results.

The staff has determined that present models for the U.S. sufficiently represent the population exposure due to operation of this plant.

Environmental impacts from uranium mining and milling are addressed in Section 4.5.5, "Uranium Fuel Cycle Impacts", of NUREG-0564.

Comment f9-7, EPA The assessment of the direct radiation from the nitrogen-16 is not discussed in sufficient detail to allow meaningful interpretation (see pages 4-16 to 4-21). For example, it is stated that the applicant calculated a direct radiation dose of 2.7 mrem/year per unit at 0.55km south of the plant...therefore should be more fully discussed in the final EIS.

Response

The calculated value for the direct radiation dose (20 mrem/yr at a typical site boundary of 0.6 km from the turbine huilding) given in giVE the Braun Safety Analysis Report is for a standard implant design. The direct radiation dose of 2.7 mrad/yr in NUREG-0564 is an estimated dose for the specific design incorporated in the Susquehanna plant.

Since the direct radiation dose is dependent on the shielding incor-porated in the specific plant design the above values are not directly comparable. Nonetheless, since the actual direct radiation dose could be higher (or lower) than 2.7 mrad/yr a survey wi 11 be required at the time of plant operations. If the survey indicates that the limits of 40 CFR 190 could be exceeded then steps will be taken to reduce the dose.

Comment 89-8, EPA The health risk conversion factor slisted on page 4-27 appear low and are inconsistent with the factors used in the Generic EIS on Uranium Milling (NUREG-0511). These values should be made consistent with those used in NUREG-0511.

~Res onse The basis for the risk estimators on p. 4-27 of NUREG-0564 is more fully described in Ch. 4, Section 3, Appendix 8, "Health Risks from Irradiation",

of the Final Environmental Statement on the Use of Recycle Plutonium in Mixed Oxide Fuel in Light plater Cooled Reactors "(NUREG-0002). As stated in NUREG-0002, Though these risk estimates are the upper bound estimates given in the Rasmussen Report, higher estimates can be developed by use of the "relative risk" model along with the assumption that risk pervails for the duration of 'life. This would produce r jar values up to sevenfold greater than those used in GESNO." Consequently, the risk estimators in NUREG-0511 are consistent with those used in NUREG-0002.

Comment <10-4, D. Mann, Susquehanna Alliance The report does not fairly represent the growing controversy over the effects of low level radiation. Time after time...federal standards be lowered.

~Res onse lie are not aware of any studies that have established that there is no safe level of radiation. However, as a conservative and prudent j

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of radiation is safe.

assumption,~assume/that no amount For more

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Response to Comment 810-4 - cont'd than four decades, radiation has been the most thoroughly studied carcinogen. Numerous major biological research programs have been well documented and may be found in the open literature. While the United States has been the forerunner in radiation research, many other countries also have pursued similar programs and have contributed substantially to the knowledge. While the relationship between ionizing radiation dose and bio1ogical effects among humans is not ~recise1 known for all levels of radiation, the principal uncertainty exists at very low dose levels where natural souces of radiation (cosmic and terrestrial) and the variations in these sources are comparable to the doses being evaluated. The most important biological effects from radiation are somatic diseases (principally cancer) and hereditary diseases. Both of these are identical to those which occur normally among humans from other causes. It is this last point in combination with other confounding factors, e.g., magnitude and variations (1) in normal incidence of diseases, (2) in doses from natural radiation sources, (3) in radiation doses from man-made sources other than the nuclear industry, and (4) in exposures to other (non-nuclear) carcinogens, which is responsible for much of the uncertainty in the dose-risk relationship at low dose levels.

Data from studies of animals and humans, are reviewed continuously by teams of scientific experts which evaluate radiological information and provide recommendations. In the United States, the principal expertise in radiological matters lies with the National Council on Radiological Protection (NCRP) and the National Academy of Science/

National Research Council (HAS/NRC). Federal agencies also retain t, s ~ ~ ~

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Res onse to Comment ~$ 10-4 - cont'd expertise in the radiologic disciplines in order to fulfill their responsibilities, however, these agencies rely heavily on recommendations of these advisory organizations. Other countries have national advisory organizations similar to those of the United States. Further, there are cooperative international organizations which evaluate data from all sources and present recommendations and conclusions, for example, the United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR) and the International Commission on Radiological Protection (ICRP).

In summary, not only have the radiological data been ascertained by the world's outstanding biologists and epidemiologists, but the data have been evaluated independently by their. peers.

In lieu of precise knowledge of this relationship, a linear non-threshold extrapolation from high radiation levels to the lower levels is assumed for radiation protection purposes. This means that it is assumed that any dose of radiation, no matter how low, may be harmful.

Several federal agencies, principally the Environmental Protection Agency, Occupational Safety and Health Administration and the Nuclear Regulatory Commission, have responsibilities for regulating exposures to radiation or radiop'active material. In all cases, the staffs of these agencies are well aware of the potential health effects and have expertise in biology and the other disciplines needed either within the staff or available to them.

Comment 811-3, F. L. Shell Uranium Fuel Cycle Impacts - Radon-222 I refer you to the transcript of the TNI-2 Operating License Hearing July 5, 1977, page 2890 and the testimony of Or. Chauncy Kepford and Or. Reginald Gotchy...The naturally occurring costs are bad enough without adding to them.

~Res onse I

With regard to Dr. Kepford's testimony regarding use of $ 1,000 per man-rem for environmental health costs, the Staff would like to make the following points.

(1) The $ 1,000 per man-rem vaIue was selected by the Commissioners as the upper bound of all the numerical estimates, in the literature.

The purpose was to estimate the potential monetary costs of health effects during the lifetimes of persons living within 50 miles of a nuclear power plant (no other facilit ) so that those potential costs could be compared with the real costs of adding additional radiological waste treatment systems to each proposed nuclear power plant to determine if the operation of the plant would result in meeting the 10 CFR Part 50, Appendix I "as low as reasonably achievable" rule. It was never the intent of the Commissioners to use that monetary value for any other purpose, such as estimating the monetary costs of future health effects from other sources on today's populations or future populations.

The obsurdity of future monetary costs can be demonstrated very simply ~assumin human institutions and the human race persist into the future in the same manner as today. Ignoring the real possi-bility that radon health effects may not occur in the future due

to technological advances in the cure and prevention of such effects, it is possible to calculate how much money would have to be deposited in a savings account now to meet "future monetary costs" of 10 billion dollars per reference reactor year.

As a conservative estimate, it was assumed a 5 percent simple interest rate would demonstrate the meaninglessness of such calculations. Conservative Staff estimates indicate only a few health effects might occur within 1,000 years. It is obvious that essentially all of Dr. Kepford's "health effects" would occur over periods of time which exceed the probable life expectancy of the human-race and our solar system. Nevertheless, tongue-in-cheek, it can be shown that if the utility were to deposit one-cent in a perpetual savings account to pay for any future health costs that might occur, that fund would contain contain nearly'$16 million-trillion after only 1,000 years. Clearly, one-cent would not significantly modify the future costs of

..,.. -,,electrical power generated today.

With regard to Dr. Kepford's estimates of millions of future deaths from radon-222 per Reference Reactor Year, the Staff response to comment 16-1 are also relevant here.

v Comment gl6-1. . . Lochstet The Long Term Health Con eauences of Susquehanna Steam Electric Station by William A Lochstet The Pennsylvania State Universit+

August 1979 Thc Nuclear Regulatory Commission has attempted to evaluate the health consequences of ppcration of thc Susauehanna Steam Electric Station, Units 1 and 2 in its draft environmental statement HURB - 0564 health consequences o8 radon-222 release's from the

'he uranium fuel c~cle are estimated for thc first 1000 years in section 4.5.5. In evaluating the radon-222 emissions from the coal fuel cycle in section S..4.4., ( item g7 on page S-10),

the staff recognizes that the emissions continue for "millions of years"~ Neither approach is correct. Footnote 12 of NRDC v. USNRC, 547 F.2d 633 (1976) reouires that th ~astes be consiaered for their entire toxic life. Thus, the only proper evaluation is srLth ne temporal cutoff. Such an evaluaticn is attached as an appendix to this statement ("Comments on NUREG-0332"). This evaluaticn shows that the Staff has underestimated the health conseauences of both the coaL and uranium fuel cycles.

cons The HRC apparently 5ustifies auenc s by comparison with i¹ back allowing o health ound ( P. 4,-27 to 4<<2S).

This is tot"lly irrhlevant and contr"ry to HZPA. N"P. reauires an evaluation of the benefits and all of the costs of th Federal action under consider"tion ( Susquehanna 1 2). Ec.

Background radiation is not a justified federal acticn. The.

harm caused by background cannot justify other ham. TMs improper comp-'rison of costs to background is contrary to the decis on in Calvert Cliffs Coordinating Comittee v. USA'".

449 F.2d LLO" ,12.15 (1971) ~

The opi. :=ans and calculations presen"ed herc are mv oem ;.n 1, not necks"s.-.;r" ly. those of The Pennsylvania State Universit-..

Ny affil:;=.tion is given here for identifica-'on purpo e c'~'.,--

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10 . e Comments on lERM-0332 by Dr. Viilliam L- Lochstet The Pennsylvania State University November 1977 Xn th document NURZG-0332 (Draft), the NRC estimates the excess deaths per 0.8 gigawat -year electric (CVy'(e)) to ba about 8.5 for an all nuclear economy and about 15.to 120 f'r the use of coal(Ref. 1) These estimates are much too

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small because they igno~ the health ef'fects due to the slow release of radon-222 resulting from the decay of'.'.

radioactive components of the coal, uranium mill tailings, and of the tai1"ngs from the uranium enrichment process Xf the nealth effects a= estimated, by'he procedure used by the ERG~ then the cxce s de"ths =re about 600,000 in the nuclear case and .'twentythousand fc= coal. The estimates presented here are all based on the produ-. '.o.'.: of 0.8 G'.fy(e) ~

Radon Produced by the Uranium ~ ~'..'. i:":cle T!.e produc ion of 0.8 G3'i'y of* ..'e tricity by a 5~

reouir>> abou~ 29 metric tons o=" ..:-.--'..hed urani~.fcr fuel.

Vitn ur.n ~ en='eh=en =lants ".:: .ting with a 0.2,~ t ils assa.r, ll.6 metric tons o natura..::: =-niun will be reauired.

, Xn the absence of the L~.;."BR, 117 m.=.-.ric tons of depleted uranium

>i~uld be left over. pith a urani z mil1 which ex racts 96/ of'

~ ~

the uranium from the ore ( Ref. 2}, a total of 90,000 metric tons of ore is mined, containing 152 metric tons of uranium The uranium m%11 tailings will contain 2.6 kiXograms and 6 metric tons of'ranium@. As Pohl has of'horium-230 pointed out (Ref.3) the thorium - 230 decays to radium - 226, which in turn decays Co radon 222. This process results in the generation of 3.9xlO curies of radon-222, with the time scale determined by'he 8xl0~ year half life of'horium >> 230.

The 6.metric tons of uranium contained in the mill tailings decay by several steps to radon - 222 thru thorium - 230. This process occurs on a time scale governed by Che A. ~ 5x10 year half life of uranium -. 238> the major isotope present { 99.3+F3 The total amount of radon 222 which will result from this decay is 8.6x 1011 curies.

The 117 metric tons of depl a-ed uranium from the enrichment process s also mainly uranium - 23S wnich also decays The decay o." these enricI ent taiIings results i" - total of 1,.7xl0"'..uries of radon - 222. This is Ii::";:.:8 n Table 1, along ~.i-;'-.. the othe radon yields.

instructive to co;;-are these G::=: ..es of activity to the:-:..".'vity o the fission products ~:hi...-esult from the u e:.;" the fuel which they are associ"-::=':.ith. The total r

fission r.:.oduct inventory resulting f"om 0. ':"':y(e) with half lives o" 25 years or more is about 10 curies, This is much less than any of the numbers in Table l. ':ie should be more careful with these tailings.

Radon Produced by the Coal Fuel Cycle Item 2 i of Appendix A of NUTMEG-0332 ( Ref') assumes a 75$ capacity factor, which for a 1000 Mfe plant vuuld produce only 0.75 GYy(e). h capacity factor of'0fo wi2Q. be used here The production of O.S G'.vy(e) by a coal plant operating at 40/.

efficiency, using 12,000 BTU per pound coal would reouire 2.5 million short tons of coal. This is close to the value of 3 million tons suggested on page 9 of NUREG-0332 ( Ref. I).

There is great variability in the amount of uranium contained in coal. An analysis of coal samples at one TVA plant reported by the EPA ( Ref. 4.) indicates a range of almost a fac or of ten in uranium content. Eisenbud and.Petrow (Ref. 5)

..port " ~flu of about l part per million. A recent survey b-. the USGS based on several hundred samples suggests that in the Uni- .'rates coal conuins an average of 1.S part.

per millie.- ".;. ura~ ium( Ref. 6) 'oth values of 1.0 and 1.S p~

~

>i'll be us(i  !:;::"e, .'~us 2 ~ $

v,'~,. u sand million tons of coal >d.ll contain betwe n 2..';".:-;; L!.1:':.ilo~s l,

of uranium. Using ';he as ~o~ion of HUR"=G-03'::. {:-'.e~', .'.) that there is 99/ partic~lr~te removal from plan-. c::.:'..s ior.=-, I',4 of this uranium vill be ='disp -sed into the ai nd th~ remainder carted away as a'has for land burial. Table I in" cates 'hat with 1.0 ppm coal the uranium in the resul"ing ash will decay to a total oi 3.2xlO 1 curies

13 of radon - 222, while the stack emissions will lead to 3.2xl.O curies. For'l.8 ppm coal the values are 5.8x>0 11 curies from ash and 5 'x10 curies from emissions Evaluation of the Health Effects Xt is necessary to evaluate the number of deaths which result from the release of one curie of radon - 222.-~or the purpose evaluation the population and population distributions of'h's are assumed to remain at the present: values. This should provide a good first estimate NUR~-0332 (Ref. 1) suggests that a release of 4,800 curies of radon' '222 from the mines ( page 11) would result in 0 023 excess de"ths ( Table la, page 18). This prox des a ratio of g.gx10 dea"hs per cu='. Data from Chapte= ZV of GER)0 (Ref. 7) suggests a value of 1.7-=0 deaths per curie as a lover 1'z:it.

The value of l.8xlO d-:.=" hs p r curie s~U~ be used here:-.: the L~C estimate. lt is ~..-=-=-tood that this is very appro--~.r-=.'..:.:.

The Ep's e ,1-;":.-:'"'he health effec-s of a model '... um J

mill tailings pile. Ti.".:.!'stimate a total of 200 health "... ts c (Ref. 8, p e 73) fo= .: ,.'le which emits at nos 20,000 c". s- '.

o radon - 222 for 10C . ars. The resulting estimate is

~l deaths per cu=ie and ~d.ll be used here as the EP::.

estimate.

l I

14 5'valuation of Health:"ffects - Nuclear At present some recent uranium mill tailings piles have 2 feet of- dirt coverin~. Xn this case the PA estimate (Ref. 8) is that about 1/20 of the radon produced escapes into the air.

This factor of 20 is listed in "'.Table 1 and is use'd to find the effective releases. Thus the 3.9x10 8 curies of.'vadon which results from tho ium in the mill tailin s results in a.release of 1,9x107 curies into the a mosphere, which w'th th NRC estimate of 4 8x10 deaths per curie results in 90 deaths. ".'ith the EPA, estimate 1900 deaths result. A similar treatment applied to 896x10 curies of radon from the uranium in the m. 11 tailings results in 200,000 dead for. the )BC estimate and 4..3 million for the SPA estimate. It is here assumed that no futu e gene ation will see fit to take any better care of the mill tailings th"n is presently practiced.

The uranium enrichment tailings are presently located in the eas em part of the country. It is assmed that these are buried nea; their present loc'-'tions. Radon will not escape so easily h cu-gch wec soll. P rc.!action factor of 100 is cse6 to estimate t.".i~ effect. The acc:."- cy of this estimate d pends on the particul:".:

o the burial which can onlv be projected. An" ad='itional factor of 2 is used, to reduce the e feet due to the fact that much of this radon would decay over the ocean rather than populated

]5 land areas. No compensation is taken for the greater population density near the point of release as compared to the uranium mill tailings piles of the western states. M.th this total reduction factor of 200 the NRC estimate is 400,000 dead while the EPA va:lue is 8 million.

Evaluation of Health Effects Coal lt is assumed that the ashes from the 'c'oal plants will be buried in a manner similar to the 'tailings from the uranium enrichment process. Thus a. reduction factor of 200 is used in this case also. -Again the higher population density is ignored.

The particulate which is released into the air by th. coal plant is taken to contain lp of'he contained uranium. Since most such plants are in the eas"em part of the country it is estira ed that half vo.ll fall into the ocean rather than onto land. I. second factor of 2 is used to reduce the f ect of the resulting radon due to the fact that some of this radon we'll ecay'ver ocean as with the radon from the u;anium in the eric"..i.'icnt tailings. Again no compensation is taken for the

~c:=";-.:.r population density ne"r the point of release.'his g=v:".= .he total reduction facto'f 4 sho"~ in table 1.

'::.th these reduction fa";;o= s applic'o the radon released by '.::e ashes and emissions, n the two c-..ses of'.0 ppm and 1.6'v-:.. uranium content coal, the health e:"fects are calculated.;

These are shown in table 1, and range frc; 7,700 dead from ashes and 3,800additional dead from airborn emissions .for 1.0 ppm coal in the NHC estimate to 2o0,000dead from ashes and 140y000 dead from airborn releases in the case of 1.8 ppm coal in the ZPA estimate.

t h

h II "

4 ~

3

\

4

I

~ ~

16 Discussion It is obviously very difficult to estimate with any precision how many hea'1th effects result from the release of a given curie of radon - 222 from some specific site in the west The estimates presented here differ by a factor of 20. This might best be used as a range of expected deaths. The reduction 'factors used here are crude estimates in some cases, and could be improved upon. Changes in publid policy could also change the m="nner in which this material is disposed., thus greatly c~gin these'actors. In particular deep burial could practically eliminate the escape of radon to the atmospnere (Ref. 8) ~

It is E important to compare Table 1 here with Table 1 og NUP~~-0332 (Ref. 1),,which shows 0.47 dead for the nuclear case and at most 120 dead for coal ~ These last numbers totallv ignore the e= ects of long term radon emissions, which result in 1

at leas- 100 times higher mortality. These long term effects are not only signigicant, but dominate the effect

-:s important to use Table 1 to compare the re1ative r s'-: i-:." -'e nucl '"= and coal option in the'r present forms.

1n -h='.- c se de;-.'hs due to all causes considered in I&K-0332 ca:. '-... '-.,=..nore.". -: insignificant, since they are so ~'.

Thr; -".l:-. ~lute n>al c.r of deaths per curie rel ased is rrelevant si.-.c:-,,'nter.; 3".. both cases. The relativ:. risk i determin d so" .'.'v the or.n'tities of radon - 222 generated and the reduction fact"::. Unless there is a clear decision to Nreat coal as..as -

di ~er=-ntly from uranium enrichment tailin=s, the health effects from the tailings will be 50 times greate since the e is

~ ~ ~~C45yaSg~ov w

17 50 times more uranium there. The nuclear option remains more hazardous than coal unless the releases from all of the tailings piles can bg reduced below the releases from the airborn I

particulates of th coal plant. This is not the present policy r

Additional Comment There is 8 typographical error on page 25."of NURSE>--0332 Reference f33 is listed there as being in volume 14.8 of Sciance, she eas it appears in volume 14'.

Acknowledgment

.The above comments ~ere inspired by the 5 July l977 testimony of Dr. Chauncey R. Kepford in the matter of'he Three iH.le Island Unit 2 (Docket No. 50-320) operating license entitled: " Fealth effects Comparison for Coal and Nuclear Po~'er" ~

I r I

h 0 *4 P

18 Table l Energy Source Excess 1Iortality per O.S GÃy(e) due to Radon - 222 emissions Origin of Radon Reduction Deaths Racon Generated Factor HRC-Curies prtlcl BR-Thorium in 3.9xlp 20 90 l900 Rill Tails Uranium in S.6xloll Rill Tails 20 200~ 000 4.3xlp Uranium in En ic?~ent 1.7x1013 200 400,000 Sx106 Tails Co=-1 1.0 p~ U Ashes ~011 7~700 l.6xl05 Ai= ";..2xl09 3,800 Sxl04 Particulate taO I~

~

Coal~

lgB Dpz U Ashes 5.8xlp 200 14, 0"..0 2.9"10-5 Air 5.8xl09 6,8M 1.4x105 Particulate

19 References 1 "Health Effects Attributable to Coal and Nuclear Fuel Cycle Alternatives" NUR G-0332,Draft, U.S. Nuclear Regulatory Commission (September 1977) vironmental Ana3.ysis of The Uranium Fuel Cycle, Part I-Fuel Supply" EPA-520/9-73-003-B, U.S. Environmental Protection Agency, (October 1973)

R.O. Pohl, "Health Effects of Radon - 222 from Uranium P~ing" Search, 7(5),345-350 (August 1976)

P.H. Bedrosian, D.G. Easterly, and S.L. Cummings,"Radiological Survey Around Po~er Plants Using Fossil Fuel" EERL 71-3; U.S. Environmental Protection Agency', (July 1970) 5 I$ . Eisenbud, and H.G. Petrow," Radioactivity in .the Ataosphe Qc Effluents of Power Plants that Use Fossil Fuels," Science

'1114,:288-289 (1964) 6 V.E. Swanson et al,"Collection, Chemical Analysis, and Evaluatio:

of Coal Samples in 1975", Open-file report;76-468' S.

Depart-ent of th I:.terior, Geological Survey, (1976) 7 "Final Generic Env'"~nmental Statement on the Use of

.=.ecyc e . lutoniur. ='.. -H.xed Oxide Fuel in Light Vater Cooled

?cactors," HURD-".,',":C:.". U.S. Nuclear Regulatory Commissio",

iAugust 1976) 8: - i?ef. 2

~ -

gpss 4

J 20

Response

Or. Lochstet's comments are inaccurate and erroneous in so many areas, it would be impossible to respond completely in a meaningful way. Our major differences center around:

(1) Or. Lochstet's insistence on calculating radon-222 releases (both coal and nuclear) and resultant health effects over periods of time

~

exceeding the life expectancy of the solar system much less the probable life expectancy of the human species.

(2) Incorrect use of prev'ious NRC estimates of cancer mortality per curie of Rn-222 released.

(3) Incorrectly equating EPA estimates of health effects with cancer mortality.

(4) Improper assumptions of Rn-222 releases from uranium mill tailings and uranium enrichment tailings.

It is the staff's position that the cure and/or prevention of cancer is likely to occur well within the 100 to 1,000 year period evaluated by the staff in the Summer OL-OES. Although population dose commitments may continue into the future, the staff does not believe there will be any significant cancer mortality associated with such dose commitments.

Therefore, it is reasonable to truncate estimates of cancer mortality at 100 to 1,000 years from the present time.

Or. Lochstet incorrectly drived 4.8 X 10 deaths per Ci of Rn-222 released to the atmosphere from draft NUREG-0332. He assumed that the 0.023 cancer deaths listed in the NUREG came from release of 4,800 Ci of Rn-222, also mentioned in the NUREG. The 0.023 cancer death estimate

21 Response to Comment 816-1 - cont'd actually comes from the estimated 1130 curie release during active milling only. Therefore, a more appropriate value would be 20 X 10 deaths per Ci (i.e., about a factor of 4 higher than he assumed.)

Or. Lochstet misused the EPA estimate of health effects (his Ref. 8) by equating it with cancer mortality. In addition, the EPA later (1975) reduced their estimate of health effects in the Eastern U.S. from 120 to 30 giving a total of. 110 health effects. Still later, EPA concluded their estimate of 80 health effects in the Northern Hemisphere was too high. More recent EPA estimates of cancer mortality are included in the Perkins Hearing record in testimony by Or. R. L. Gotchy, author of NUREG-0332. In March, 1978, Or. W. H. Ellet, U.S. EPA, provided Or. Gotchy with his latest estimates, which resulted in about twice as many cancer deaths per curie of Rn-222 released as shown in the Summer OES.

Finally, Or. Lochstet chooses to ignore current NRC licensing and industrial practice which will result in much smaller releases of radon-222 than he assumed for his calculations. In fact, deeply buried mi 11 tailings may result in long-term radon releases which are less than could occur in nature had the uranium not been mined, milled and used to generate electricity. This is because over 90% of the long-lived U-238 and U-234 is removed from an ore-body which geologic processes could eventually bring to the surface of the earth. Once on the surface, the radon-222 releases could occur undiminished over millions or billions of years.

22 Response to Comment >16-1 - cont'd Furthermore, Or. Lochstet's assumption of radon-222 releases from uranium enrichment tailings are without any factual basis. Such tailings I

are being held for use in breeder reactors. In the event the U.S.

doesn't use this valuable resource domestically, other nations will be purchasing the depleted uranium for their own breeder programs. In the interim period, no radon-222 will be released from enrichment tailings.

In conclusion, the staff finds Or. Lochstet 's evaluation of the radon-222 impacts to be unrealistic and incorrect, both philosophically and technically.

~ ~'

0 23 Comment 817-3, M. Huntin ton Another major point that I contend in this report is the establishment of the uranium mining and milling necessary for this plant as having an "acceptable" impact upon the environment...of another group of 1.2 million people per year in this situation too.

Response

The contenti'on by Mr. Huntington that "The NRC itself has been unable to disagree with Or. Chauncey Kepford's findings that 1.2 million people per year will die in the future from the effects of radon gas emitted from the tailings produced just to fuel TMI", is incorrect. The NRC Staff has refuted such claims in several hearings as meaningless for many reasons. Some of the more important reasons are discussed in responses 11-3 to tlr. Shelly, and 16-1 to Or. Lochstet, and need not be repeated here.

Comment -,".18-2, S. Lau hland Radiation causes cancer. This is an accepted medical fact. The United States has a surplus of power plant, so why add the Berwick plant to the long list of environmental and health hazards of this country.

Response

See response to Comment f10-4.

Comment 819-13, N.i<. Curtis, Penns lvania Power and Li ht Com an ENVIRONMENTAL MONITORING

1. Table 5.1, pg. 5.3 - This table has been updated to reflect changes in sampling locations and station nomenclature corrections. The lower limits of detection have also been revised per NUREG-0473.

A copy of the table with corrections indicated will be forwarded under separate cover.

Response

The above revisions will be used in establishing that the environmental radiation monitoring program meets the staff's position on environmental monitoring. Lower limits of detection will be incorporated in the applicant's technical specifications.

~ ~ g+ C 1

24 Comment -..20-2 C. L. Jones Oe t. of Environmental Resources Commonwealth o Penns van>a S ent Fuel Stor a e Section 4.5.5 - Radioactive Wastes - This section should be expanded to include contingencies for the long-term storage of spent fuel 'on site.

This may be required if a decision has not been made on the final disposition of spent fuel after the plant has been operating for a few years.

Response

'Ehe storage of spent fuel is addressed in an NRC document entitled "Final Generic Enviornmental Impact Statement on Handling and Storage of Spent Light Water Power Reactor Fuel" (NUREG-0575). The storage of spent fuel addressed in NUREG-0575 is considered to be an interim action, not a final solution. The commission has clearly distinguished between permanent disposal and interim storage.

One of the findings of NUREG-0575 is that the storage of light water reactor (LWR) spent fuels in water pools has an insignificant impact on the environment, whether stored at a reactor or away from a reactor.

Primarily this is because the physical form of the material, sintered ceramic oxide fuel pellets hermetically sealed in 7ircaloy cladding tubes. Zircaloy is a zirconium-tin alloy which was developed for nuclear power applications because of its high resistance to water corrosion in addition to its favorable nuclear properties. Even in cases where defective tubes expose the fuel material to the water

,\

environment, there is little attack on the ceramic fuel.

i + ~ ~

25 Res onse to Comment 020-2 - cont'd TYhe technology of water pool storage is well developed; radioactivity levels are routinely maintained at about 5 X 10 ~Ci/ml. Maintenance of this A purity requires treatment (filtration and ion exchange) of the pool water. Radioactive waste that is generated is readily confined and represents little potential hazard to the health and safety of the public.

There may be small quantities of Kr released to the environment from defective fuel elements. However, for the fuel involved (fuel at least one year after discharge), experience has shown this to be not detectable beyond the immediate environs of a storage pool.

There will be no significant discharge of radioactive liquid effluents from a spent fuel storage operation as wastes will be in solid form.

This statement supports the finding that the storage of spent fuel in away-from-reactor facilities is economically and environmentally acceptable.

References

'I. Natural Resources Defense Council, Denial of Petition for Rulemaking, July 5, 1977, 42 FR 34391. Available in the NRC Public Document Room.

Comment 820-3a C. L. Jones De artment of Environmental Resources, Commonwealth o Penns lvania Radiation Releases Section 4.5.2 - Direct Radiation - The direct radiation dose of 2.7 mrad/yr calculated by the applicant could be low by about an order of magnitude based on a more...measurements taken near several of the operating boiling water reactors (BWR's).

Response

See response to Comment 89-7.

26 Coment ~20-4 , C. L. Jones, De t. of Environmental Resources, Commonwealth o Penns vanya The calculated radionuclide releases in liquid effluents is discussed in terms of dose commitments (pages 4-14, 4-15). The Department believes that the impact of radionuclide releases and resulting river quality concentrations should be compared to the National Drinking Water Standards.

~Res ense Annual doses per site from liquid effluents were given in Table 4.10.

The estimated dose to the total body or any organ of the hypothetical maximum individual from all pathways was about 1.0 mrem/yr. This dose includes the dose from ingestion of fish as well as consumption of water. The dose to the average individual using the nearest comunity water system would be less than 1.0 mrem/yr,~he Environ-al mental Protection Agency'.s National Interim Primary Drinking Hater Regulation" states that "the average annual concentration of beta particle and photon radioactivity from man-made radionuclides in drinking water shall not produce an annual dose equivalent to the total body or any internal organ greater than 4 mi llirem/year", (Sect. 141.16).

The annual doses from liquid effluents from Susquehanna Units 182 are below the above limits.

Comment >21-4, T. R. Duck The statements in Section 4 which state that radioactive releases, both occupationally and environmentally, will have no significant environmental impact are misleading when one considers that the effects of low level radiation are unknown. Groups such as the National Academy of Sciences hesitate to place acceptable low dose limits on human health effects.

Response

See response to Comments g5-1 and 10-4.

27 Comment 821-8, T. R. Duck The tables in Section 8 dealing with the effects of coal versus nuclear plants presumably used coal in the general sense. The SESS is located near the heart of the anthracite coal region. Anthracite, because it is a cleaner burning coal, has been exempted from any EPA air pollution regulations. Since this is the coal that should be used at SESS, it is the coal that should be used in any comparative studies.

Response 'I As stated in NUREG-0564, there is a considerable amount of uncertainty in estimating health effects over long periods of time (greater than 100 years). The overall uncertainty in the nuclear fuel cycle is probably about an order of magnitude (increased or decreased by a factor of 10) over 100 years and about two or more orders of magnitude over 1000 years. The uncertainty associated with the coal fuel cycle tends to be much larger because of the inability to estimate total health impacts from all the pollutants released to the environment from that cycle. However, if one assumes most of the public impact over a period of several decades is caused by inhalation of sulfur compounds and associated pollutants, there is as much-as a two-order-of-magnitude uncertainty in the assessment of the coal fuel cycle.

In view of the large uncertainties in any comparison of the health effects of coal versus nuclear power plants, a site specific comparison is not warranted.

Comment;"'.23-1, L. E. llatson There was quite a bit of data collected on fish and wildlife but there was none collected on humans no health picture of the human population within 10 miles of the plant--before the startup of operation. I feel this should have been done to have some comparison with data that might be taken a few years later, with respect to effects of radiation

28 Comment f23 cont'd etc., with normal operation of the plant and also in case of an accident such as at T.M. I.

Response

Animal and food crop samples were taken prior to the startup of the plant. The background activity in these samples is determined by destructive means. Similar destructive testing of humans would not be possible. Although whole body counting (a non-destructive test) could be done of humans near the site, this would not be effective because of the mobility of the human population and the cost of whole body counting.

Comment 823-3, L. E. Watson On page G87, 6.2.2 in the Environmental Statement of June 1973, the staff comments "the applicant does not appear to have made arrangements for interchange of data as yet, with nearby radiological monitoring programs at Peach Hottom, TMI, Oyster Creek, Indian Point, Shoreham, Forked River, Newbold Island, Salem, or Limerick. In the revised Draft Statement of June 1979, this omission has not been corrected.

Response

Results of environmental monitoring programs at nuclear power reactors are routinely made available to the public. For example, see an NRC document entitled "Radioactive Materials Released from Nuclear Power Plants, Annual Report 1977" (NUREG-0521).

29 Comment, 823-4, L. E. Watson In the section 4.5.5 on Uranium Fuel Cycle Impacts, we object to the conclusion that both the dose commitment and health effects of the uranium cycle are insignificant when compared with dose commitment and potential health effects to the U.S. population resulting from all the natural background sour ces. The effects are additive, and even the natural background sources are considered ersponsible for mutations, cancer, and other diseases. Just because one must tolerate natural background sources it does not follow that radiation from the uranium fuel cycle is harmless. It could be the "straw that breaks the camel's back"..

Response

See response to comments <5-1 and 10-4.

Comment 825-5 L. E. Meierotto, U.S. Dept. of Interior

~Pa e 5-2 We agree with the staff that the applicant should monitor groundwater both upgradient and downgradient on a monthly basis. We note that the potential for radionuclide contamination of groundwater is implied on page D-l of Appendix '0 (item 1.6); however, figure 4.1 (p. 4-13) does not indicate groundwater as an exposure pathway to humans.

Response

The applicant states that "In general, ground water in the Paleozoic rock formations of the Appalachian Highlands flows from the topographically higher areas (recharge areas) to the valleys (Ref. 2.4-25). This ground-water, it is believed, discharges to springs and to the streams and rivers of the region, except at flood stage."* Consequently, the doses from ingestion of groundwater should be no greater than the doses from ingestion of water from the river. Any use of groundwater as a drinking water supply should be balanced by a decrease in river water as a drinking water supply.

+Susquehanna SES-ER-OL, p. 2.4-12