ML20010C949

Statement of Matl Facts as to Which There Is No Geniune Issue to Be Heard Re Contention 17.Certificate of Svc Encl

ML20010C949
Person / Time
Site:	Susquehanna
Issue date:	08/18/1981
From:	Silberg J ALLEGHENY ELECTRIC COOPERATIVE, INC., PENNSYLVANIA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8108210260
Download: ML20010C949 (16)

Text

.

August 18, 1981 L:E,- Nl'%

')

UNITED STATES OF AMERICA /[ s A <f *b

,2 '% g% ML

,N NUCLEAR REGULATORY COMMISSION -

0- 4

- Qp! c?..P c BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

' y, '? y? . g In the Matter of )

b ij [f' '-

)

PENNSYLVANIA POWER & LIGHT COMPANY ) Docket Nos. 50-387

) 50-388 and )

)

ALLEGHENY ELECTRIC COOPERATIVE, INC. )

)

jgf' E 49 (Susquehanna Steam Electric Station, ) c cg 5.o N

)

'S ~~yac.c l Units 1 and 2) l jF' AUG 19 WBI * '$$

CHice ci tha set tarf APPLICANTS' STATEMENT OF MATERIAL FACTS pochtirZ a SCIdC" 8 AS TO WHICH THERE IS NO GENUINE ISSUE k BIECh

/

TO BE HEARD __(CONTENTION 17) cb cp Pursuant to 10 C.F.R. S 2.749(a) Applicants state, in support of their renewed motion for summary dispositicn of Contention 17 in this proceeding, that there is no genuine o issue to be heard with respect tc the following material facts:

1. There will be a maximum electric field gradient of 11 kV/m (kilovolts per meter) at ground level at the point of minimum clearance on the right-of-way, and 2.28 kV/m at the edge of the right-of-way, of the 500 kV lines to be utilized for transmitting the electric power produced by the Susquehanna Steam Electric Station ("the Susquehanna lines"). Licensing Board's Order of May 20, 1981, slip cp. at p.10.

)Sfi3 S

/ /

8108210260 810818 PDR ADOCK 05000387 G- PDR..

I

2. Living organisms respond to many stimuli as part of the process of living; such responses are examples of biological " effects." Since biological organisms have consi-derable tolerance to change, these " effects" may be well within the capability of the organism to maintain a normal equili-brium. If, on the other hand, an effect is of sucn a nature and/or duration that iu impairs the ;rganism's ability to function properly or overcomes the recovery capab:.lity of the organism, then the "effect" is regarded as " hazard." Affidavit of Solomon M. Michaelson in Support of Summary Disposition of Contention 17 ("Michaelson Aff."), para. 4.

3. Some biological " effects" on animals and humans have been observed as a result of exposure to the electric fields of similar magnitude to those produced by the Susquehanna lines. For instance,certain animal species are able to detect very small electric fields. Other species are reported to perceive fields in the range of 30 to 100 kV/m. A person standing in the 10 kV/m electric field set up by a high voltage transmission line may experience slight movement in the i

hair of an upwards-extended hand. However, an effect such as l detection of the field does not necessarily make the field hazardous. In fact, no substantiated effects of exposure to high vol>uge electric fields have been found which can be considered hazardous. Michaelson Aff., para. 5 and n.l.

4. Scientific knowledge of the biological effects of electric fields from transmission lines cones from theoretical, epidemiological, and experimental evidence. Id., pa a. 6.

The theoretical evidence indicates that the 5.

electric fields produced by the Susquehanna lines will induce an extremely-small electric field in the body of a person in the vicinity of the line, about 100,000 times smaller than the external field. Thc induced field will cause internal body currents to flow. Such eurrents are also very small, on the order of 0.1 to 1 milliamperes ("mA") per square meter, depending on the field strength. Such small currents are well below the perception level and consequently are imperceptible.

Id., para. 10.

l

6. In order for an induced electric field or the internal current it induces to produce recognizable effects on tissue,the external field strength would have to be one hundred times larger than the field strength at which air breaks down as an insulator and sparking occurs. This is a very large field, thousands of times larger than the maximum field in the vicinity of the Susquehanna lines. Therefore, it is practically impossible to induce dangerous currents in people by mere exposure to the electric fields produced by transmis-sion lines such as the Susquehanna lines. Id,., para. 11.

t

7. While the theoretical evidence predicts no recog-nizable biological effects from exposure to high voltage elec-l tric fields, some writers have postulated that behavioral and central nervous system modifications result from such exposure.

These effects, however, are not amenable to explanation using traditional theoretical analysis, and if indeed existing, are

9

~

caused by some yet unknown biophysical mechanism which is not explained by those postulating the effects. The majority of J

the scientists working in this field believe such unexplained )

effects to be highly improbable. Id., paras. 5, 12.

8. Epidemiological evidence is derived from analysis of health records of members of the population who are exposed to a substance or agent and comparison of those people with appropriate control groups. Id., para. 8.

I

9. The most comprehensive epidemiological studies on

^

-electrical workers were performed by scientists at Johns Hopkins University who conducted medical surveillance of eleven

linemen over a period of 42 months during the time they were i

performing live-line maintenance work on a 345 kV transmission 1

system. Those workers doing bare hand work were exposed to

! fields ranging from 20 kV/m to 470 kV/m. After nine years of i

observation, none of the workers showed any change in his physical, mental, or emotional characteristics, and their health was not changed in any way by their exposure to high i voltage lines. Id., para. 14.

i

10. Another epidemiological investigation of medical visits and druggist bills in a population living and working

close to high-voltage power lines, compared with a similar, but

)

unexposed population, did not disclose any significant differ-l ences between the health data for exposed and unexposed persons. Id., para. 15.

11. In another study, there was an evaluation of 56 individuals working in 735 kV switchyards for more than two 4

l .

4 years. No adverse health symptons were observed, and no j clinical pathological changes in general somatic health, neuropsychiatric symptomatology, ECG, X-ray of the lungs, audiometry or visual acuity were found. Id., para. 16.

12. In another epidemiologic study, 110 high voltage workers who worked bare-handed on 110-380 kV lines were compared with electrical maintenance men who were exposed to l

l similar physiological stresses but at field strengths less than 5 kV/m. Based on extensive clinical and psychological examina-tionr, no difference in state of health was seen between the exposed and the control group. Id., para. 17.

13. Soviet studies have reported measurable biologi-cal changes among electrical workers exposed to intense electric fields in electric switchyards. Evaluation of these studies, however, is difficult due to the incomplete nature of I

the material presented, the variable quality of the reported data, methodological deficiencies, and the absence of controls.

Id., paras. 18, 19. Moreover, the Soviet studies deal with

(

! exposure to high electric fields in a complev environment l

l (electric switchyard), which is not directly translatable to transmission line conditions. Id., para. 20.

I 14. By 1975 the' Soviets had already 150,000 kilometer-years of 500 kV transmission line operation, produc-ing fields in the order of 12-15 kV/m near ground level, l without having identified at siological effects from the lines' electric fields. The Soviets have instituted standards l l

i i

for the protection of substation workers, but do not apply them l

to infrequent exposure by the local population or by workers in l

transmission line rights-of-way. The Susquehanna lines would i

l meet the Soviet standards, as well as the more rigorous standards generally utilized by the electric power industry in the United States, Id., para. 21.

15. The Soviet results on the effects of electric fields on switchyard workers are contradicted by an official Swedish investigation of the effects of electric fields on personnel in Swedish 400 kV substations. In this study, 53 workers with long-term (more than five years) exposure to the electric fields of 400 kV substations were examined and compared with a matched control group of 53 non-exposed workers from the same power companies. The investigation, which

( included the nervous system, cardiovascular system,and the blood indicated no differences between the exposed and control groups I

that could be attributeu to long-term exposure to the electric i

i fields. Id., para. 22.

l l 16. In summary, epidemiological studies of workers exposed to electric fields set up by high voltage transmission lines have produced no credible evidence of organic injury to man caused by such exposure. This applies both to acute and chronic exposure. Comprehensive biochemical examinations have not indicated any evidence of a " stress" response. No occupa-l tional disease or deviation of general morbidity patterns has i

l been reliably reported among high voltage transmission line l

workers. Id., para. 23.

l l

t l

1 - _ _ . _ - - _ _ _ _

17. Experimental evidence results from direct exposure of animals or humans to electric fields under con-trolled conditions and observatl.on of any biological effects.

Id., para. 9. Experiments with human subjects (male and female volunteers) have examined reaction time, blood pressure, pulse, ECG, EEG, peripheral blood counts, coagulation time and sedimentation rate in the presence for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of strong electric fields, under test conditions equivalent to those under high voltage transmission lines up to. a ground field 4

strength of 12 kV/m. Deviations observed in both control and exposed subjects did not exceed normal physiological lim'ts.

These experiments led to the conclusion that there are no detrimental biological effects resulting from exposures to fields of these magnitudes. Id., para. 24.

18. In another human experiment, two test groups, each consisting of 10 males and 10 females, were exposed to an electric field between 90 kV/m and 110 kV/m for 75 minutes and were subjected to a series of psychological tests which measured reaction time, attention, memory and motor pre-paredness. No statistically significant effect on the perform-ance of the two groups could be observed. Id., para. 25.

19. Still another experimental study on humans, on serum triglyceride levels, found no differences in triglyceride values 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after subjects had been exposed for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> to a 50 Hz, 20 kV/m electric field. Id., para. 26.

' A number of animal experiments have been, and 20.

continue to be conducted on the biologic effects and potential

i

.szards of exposure to electric fields of high voltage trans-mission lines. For instance, extensive research programsare being sponsored by the Department of Energy (" DOE") and by the Electric Power Research Institute ("EPRI"). Id., para. 32.

21. While the DOE-sponsored research programs have not reached completion, there have been no reported significant effects in most organisms and areas studied, with the exception of some " subtle and small" r/fecta reported by one researcher on the nervous systems of rats and mice exposed for long periods of time to 60-Hz electric fields up to 130 kV/m. The -

1 results of the ongoing research projects have been consistent with previous studies in finding no significant effects which would adversely influence the health of animals exposed to low-frequency fields up to 100 kV/m. Id., para. 33.

J

22. The most numerous animal experiments have involved mice and rats. For example, in a study male mice were 4

j exposed to a 60 Hz field of 160 kV/m for 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br /> during the i

course of approximately 10-1/2 months. No effects were i observed on the general health, behavior or reproductive ability of these animals, and necropsies performed after exposure failed to show any pathologic iffects. Id., para. 34.

Another series of studies on chicks, voles and mice showed no adverse effect when the animals were exposed to high voltage electric fields of 50 to 80 kV/m. Id., para. 41, n.8.  ;

23. While a study by Marino has reported weight loss '

l and increase mortality among mice subjected to 15 kV/m vertical l

_c_

i electric fields, the results observed were most likely produced by "microshocks" which the exposed animals received when eating and drinking due to the experi. mental set-ap utilized. Id.,

para. 35.

24. Another experiment on mice by Noval et al.,

l which also showed weight loss by mice exposed to electric fields, was criticized by a committee of the National Academy

{ of Sciences that reviewed the experiment; the committee i

l concluded that no reliable data could emanate from a study 1

l conducted under the poor conditions in which that study was l

performed. Id., para. 36.

25. Phillips et al., using rats in the same type of experiment but at field strenghts six times higher than Marino, reported no effect. Mathewson et al., using rats, performed an l

experiment similar to Noval's and reported no effect.

Knickerbocker et al. used mice at a field strength 16 times greater than Marino, and concluded from the study of mice exposed for approximately 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br /> over a period of 10 to 12 months to a field of 160 kV/m that there was no signs of a detrimental effect of this field on the animals. Id., para.

37.

26. Another group of animal experiments have involved monkeys. Several studies have been performed on monkeys exposed tt 10, 45 and 75 Hz electric fields of differ-ent intensities (up to 7.4 kV/m) for various periods of time up to 42 days. Multiple psychological and behavioral studies did

_9_

I 1

not show any differences between exposed and control monkeys.

Id., para. 38. In another study, thirty experimental rhesus monkeys were matched with thirty controls and exposed for 3 years to a 20 V/m electric field and 2 Gauss magnetic field.

During this period all animals were subjected to cor.prehensive i clinical-pathological and behavioral examinations. There was no evidence of any detrimental affect of the exposure. Id.,

l para. 40.

1 l 27. An ongoing research project sponsored by EPRI is being conducted by Battelle Pacific Northwest Laboratcries

("PNL"). PNL has constructed a specially designed barn in l which three generations of female miniature swine have .2en subjected continuously to an electric field of 30 kV/m, with a l

matching control group of swine in a similar barn without the field. The results obtained in the experiment indicate no dif ferences among the exposed and control groups in growth rate, hematology, serum chemistry, immunology, cytogenics, or in naurophysiological tests. The experiment found, however, more instances of malformed fetuses among exposed sows than for those on the control group; more prenatal deaths among the control group; and resistance to mating among sows born and raised in the exposed barn. These differences between the

! exposure and control groups are not necessarily attributable to the electric field exposure because a serious outbreak of f

dycentery took place duritig the course of the experiment, so that the fetal mal formations and mating problems (all of which l l

1

i

occurred thereafter) may have been the result of the disease i and/or its treatment. Also, mating of exposed sows took place in a special pen outside the electric field, thus the resis-tance to mating may have been due to the change in the sows' environment. Id., paras. 41, 42.

! 28. Most of the animal studies to date have failed

^

to identify any biological effects that could be attributed to low frequency high voltage electric fields. Therefore, the i

indication from this, as well as other sources of evidence, is that no significant effects exist. Id., para. 43,

29. The animal experiments 'so demonstrate that there will be no adverse impact on animals that may graze on or l

otherwise occupy the right of way of a high voltage transmis-

]

sion line such r3 the Susquehanna lines. Confirmation of the

lack of adverse effects from exposure to high voltage transmis-

! sion lines is given by surveys of animal grazing in transmis-sion line rights-of-way, which show that livestock graze under

~

500 and 765 kV lines normally, and exhibit no reduction in

! growth or milk production or other detrimental effects. I d. . ,

para. 44.

30. The induced electric field inside the body of a person standing under a t ..ansmission line is very much smaller than the external electric field. There is such a tremendous reduction in terms of the field inside the body that it does not seem reasonable to expect electric field effects'. Using a biophysical approach combining physical laws with known 4

i

l i

( . .-

biolcgical properties, the conclusion is that there is no scientific basis for expecting that there will be significant effects induced by the transmission line's electric fields.

Id., para. 45.

31. Epidemiological studies and experimental studies on humans and animals indicate that there are no demonstrable biological ef 'ects which may be hazardous to health or safety or to the general biological environment as a result of exposure to electric fields from high voltage transmission lines. Id., para. 47. l

32. In North America, there are currently more than 200,000 circuit miles of overhead transmission lines rated 138 kV or higher, of which 14,000 miles constitute 500 kV and several thousands of miles of 765 kV lines have been operating since 1969. There is no evidence of harm to humans or animals from exposure to the electric fields set up by those high voltage transmission lines. Id., paras. 48-50.

l t

l - , . - . _ _ . _ _ _ _ _ . . . _ ._ ._ __ _ _ ,__ __ _ _

l .

33. Based on all the theoretical, epidemiological l

and experimental evidence, the electric fields from the l Susquehanna transmission lines will result in no detrimental effects to humans or animals. Id., para. 50.

Dated: August 18 , 1981.

j Respectfully submitted, 1

SHAW, PITTMAN, POTTS & TROWBkIDGE

\/ / t~

Jay Silberg' Mati F.LTravieso-Diaz]

Counsel for Applicants 1800 M Street, N. W.

Washington, D. C. 20036 (202) 822-1000 P

l

- Oa D

~

e .

@ 4

- UNITED STATES OF AMERICA g g _, g g NUCLEAR REGULATORY COMMISSION y u

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD BE AUG 101981 > ,

" ~

0!!!a of tb Se:tetarf g L W q & Serdce 8 In the Matter of ) Dr.d l )

PENNSYLVANIA POWER & LIGHT COMPANY ) m l )

and ) Docket Nos. 50-387

) 50-388  :

ALLEGHENY ELECTRIC COOPERATIVE, INC. )

)

(Susquehanna steam Elec'.ric Station, )

Units 1 and 2) )

CERTIFICATE OF SERVICE 1

This is to certify that copies of the foregoing " Applicants' Renewed Motior. for Partial Summary Disposition of Contention 17",

" Applicants' Stater'.cnt of Material Facts As To Which There Is No Genuine Issue To Be Heard (Contention 17)", " Memorandum in Support l

of Applicants ' Renewed Motion for Summary Dispc sition of Contention 1 17" and " Affidavit of Solomon M. Michaelson in Support of Summary Disposition of Contention 17", were served by deposit in the Uc S.

Mail First Class, postage prepaid, this 18th day of August, 1981 to all those on the attached Service List.

1 Q / , . Of Ja E,-S,Elberg J VI

! Dated: August 18, 1981.

l l

, e. *. l t

~

l UNITED STATES OF AMERICA .

NUCLEAR REGULATORY COMMISSION BEFORE THF ATOMIC SAFETY AND LICENSING BOARD  !

In the Matter of )

}

i PENNSYLVANIA POWER & LIGHT COMPANY )

)

AND ) Docket Nos. 50-387

) 50-388  ;

ALLEGHENY ELECTRIC COOPERATIVE, INC. ) {

)

j (Susquehanna steam Electric Station, )

3 Units 1 and 2) )

I j SERVICE LIST i

jSecretaryoftheCommission Dr. Judith H. Johnsrud  !

U. S. Nuclear Regulatory Commission Co-Director  !

] Washington, D. C. 20555 Environmental. coalition on i Nuclear Power jAdministrative Judge James P. Gleason 432 Orlando Avenue 1513 Gilmoure Drive State College, Pennsylvania 16801 l Silver Spring, Maryland 20901

Susquehanna Environmental Advocates

!Mr. Glenn O. Bright c/o Gerald Schultz, Esquire iAtomic Safety and Licensing Post Office Sox 1560

Board Panel Wilkes-Barre, Pennsylvania 18703 jU. S. Nuclear Regulatory Commission

! Washington, D. C. 20555 Mr. Thomas J. Halligan, Correspondenn

The Citizen

Against Nuclear Dangers IDr. Paul W. Purdom Post Office Box 5 l245 Gulph Hills Road Scranton, Pennsylvania 18501

!Kadnor, Pennsylvania 19087 Ms. Colleen Marsh

] Atomic Safety and Licensing Box 558 A, R. D. J4 i Board Panel Mt. Top, Pennsylvania 18707

!U. S. Nuclear Regulatory Commission

Washington, D. C. 20555 Jessica H. Laverty, Esquire

! Of fice of the Executive Legal

'Jocketing and Service Section Director

)ffice of the Secretary U. S. Nuclear Regulatory Commission 205s2 S. Nuclear Regulatory Commission Washington, D. C.

J.

fashington, D. C. 20555 I

E

Robor: W.-Adler, Esquire Mr. Thomas M. Gerusky, Director Department of Environmental Resources Bureau of Radiation Protection OLmmonwealth of Pennsylvania Department of Environmental 505 Executive House Resources Post Office Sox 2357 commonwealth of Pennsylvania

./arrisburg, Pennsylvania 17120 Post Office Box 2063 1

Harrisburg, Pennsylvania 17120

' James M. Cutchin, IV, Esquire Office of the Executive Legal Atomic Safety and Licensing Appeal l Director Board Panel

<U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission

Washington, D. C. 2'0555 Washington, D. C. 20555 I DeWitt C. Smith

] Director

] Pennsylvania Emergency Management Agency

< Transportation and Safety Building

Harrisburg, Pennsylvania 17120 i

1 r

b 1,

4 4

l.

1 i

)

1 1

1 4

i 4

e O

a f

f 4

f

} -

I 4