ML19275A064

Submits Comments on Des.Comparison of Health Consequences to Background Is Totally Irrelevant & Contrary to NEPA

ML19275A064
Person / Time
Site:	New England Power
Issue date:	08/12/1979
From:	Lochstet W AFFILIATION NOT ASSIGNED
To:	Office of Nuclear Reactor Regulation
References
RTR-NUREG-0332, RTR-NUREG-0529, RTR-NUREG-332 NUDOCS 7908300684
Download: ML19275A064 (12)

Text

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104 Davey Laboratory Penn. State University University Park, Pa.

16802 12 August 1979 Director, Division of Site Safety and Environmental Analysis U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Gentlemen:

Enclosed are my comments on the Draft Environmental Statement for NEP - 1 and NEP - 2 (NUREG-0529). Please note that the information is my own and not necessarily the position of The Pennsylvania State University, which affiliation is given for identification purposes only.

I wish to apologize for being late, but did not receive the Draft until 9 August 1979, having requested it on 25 July.

Due to the time considerations, my comments consist of one page of main text with ten pages of appendix which I would like to have considered in entirety.

Sincerely, WY A Wm. A. Lochstet

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The Long Term Eealth consequences of NEP 1 & ?

By

'flilliam A. Lochstet The Pennsylvania State University

• August 1979 The Nuclear Regulatory Commission has attempted to evaluate the health consequences of operation of New England Power Units 1 & 2 in its draft environmental statement (NUREG - 0529).

The health consecuences of radon releases are estimated for the first 1000 years in section 5.4.3 5. The comparison with coal is made is nection 9.1.3 1, where at the top of page 9-26 it is recognized that radon will emanate from the uranius of coal

'for millions of years". Footnote 12 of NRDC v. USNRC, 547 F. 2nd 633 (D.C. Cir. 1976) reonires that the wastes be considered for their entire toxic life. This statement contradices and a takes precident over the statements of the Atomic Safety and Licensing Boards in the Perkins and Black Fox cases.

Such an evaluation for a z nominal 1000 MWe plant is attached as an appendix ( " Comments on NUREG-0?32"). This shows that in the long term the health consequences of coal or nuclear are enormous.

The comparison of health consequences to background is totally irrelevant and contrary to NEPA. NEPA reauires the evaluation of the health consequences of the federal action under question (NEP 1 & 2), and an evaluation of the benefits.

Background radiation is not a Federal Action. Background radiation does harm, but this does not justify ibrther harm.

Only the benefits can justify the harm. This comparison of costs and benefits must be conducted fully and in good faith as pointed out in Calvert Cliffs Coordinating Comnittee v.

USAEC, 649 F. 2nd 1109 (D.C. Cir., 1971).

• Tre opinions and calculations presented here are my own, and not necessarily those of The Pennsylvania State University.

My affiliation is kiven here for identification curposes only.

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Comments on MUREG-0331 by Dr. William A. Lochstet The 'ennsylvania State University November 1977 In the document NUEEG-0332 (Draft), the NRC estimates the excess deaths per 0.8 gigawatt-year electric (GWy(e)) to be about 0.5 for an all nuclear economy and about 15 to 120 for the use of coal (Ref.1). These estimates are much too -

small because they ignore the health effects due to the slow release of radon-222 resulting from the decay of radioactive components of the coal, uranium mill tailings, and of the tailings from the uranium enrichment process. ,

If the health effects are estimated by the procedure used by the NRC3 then the excess deaths are about 600,000 in the nuclear case and twentythousand for coal. The estimates presented here ars.all based on the production of 0.8 GWy(e).

Radon Produced by the Uranium Fuel Cycle The production of 0.8 GWy of electricity by a LWR will recuire about 29 metric tons of enriched uranium for fuel.

With uranium enrichment olants operating with a 0.2% tails assay,146 metric tons of natural uranium will be recuired.

In the absence of the U.IFBR,117 metric tons of depleted uranium would be left over. With a uranium mill which extracts 969 of

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2 the uranium from the ore ( Ref. 2), a total of 90,cc0 metric tons of ore is mined, containing 152 metric tons of uranium.

The uranium mill tailings will contain 2.6 kilograms of thorita-230 and 6 metric tons of uraniug. As Pohl has pointed out (Ref.3) the thorium - 230 decays to radium - 226, which in turn decays to radon - 222. This process results in the generation 8

of 3.9x10 curies of radon-222, with the time scale determined by the 8xlO k year half life of thorium - 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 the 4.5x109 year half life of uranium - 238, the. major isotope present ( 99.374.

The total amount of radon - 222 which will result from this decay is 8.6x 10 11 curies.

The 117 metric tons of depleated uranium from the enrichment process is also main.ly uranium - 23d which also decays. The decay of these enrichment tailings results in a total of 1.7x10 13 curies of radon - 222. This is listed in Table 1, along vdth the other radon yields.

It is instructive to compare these quantities of activity to, the activity of the fission products which result from the use of the fuel which they are associated with. The total fission product inventory resulting from 0.8G'!y(c) with half 7

lives of,25 years or more is about.10 curies. This is much less than any of the numbers in Table 1. 'cle should be more careful with these tailings.

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3 Radon Produced by the Coal Fuel Cycle Item 2 i of Appendix A of MUREG-0332 ( Ref.1) assumes a 75% cacacity factor, which for a 1000 ICle plant would produce only 0.75 GWy(e). A capacity factor of 80% will be used here.

The production of 0.8 GWy(e) by a coal plant operating at 40%

efficiency, using 12,000 BTU per pound coal would require 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. 1).

c There is great variability in the amount of uranium contained in coal. An analysis of coal samples at one T7A plant reported by the EPA -( Ref. h) indicates

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a range of almost a

. factor of ten in uranium content. Eisenbud and Petrow (Ref. 5) report a value of about 1 part per million. A recent survey by the USGS based on several hundred samples suggests that in the United States coal contains an average of 1.8 part per million of uranium ( Ref. 6). Both values of 1.0 and 1.8 ppm will be used here. Thus 2.5 million tons of coal will contain thousand between2.3and4.lf kilograms of uranium. Using the assumotion of NUREG-0332 (Ref. 1) that there is 99% particulate removal from plant emissions, 1% of this uranium will be idispersed into the air and the remainder carted away as ashes for land burial. Table 1 indicates that with 1.0 opa coal the uranium in the resulting ash will decay to a total of 3.2x10 curies

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E of radon - 222, while the stack emissions will lead to 3.2xlO 9 curies. For 1.8 ppm coal the values are 5.8x10lleuries from ash and 5.Sx109 euries from emissions.

Evaluation of the Health Effects It is necessary to evaluate the number of deaths which result from the release of one curie of radon - 222. For the purpose of this evaluation the population and population distributions are assumed to remain at the present values. This should provide e

a good first estimate.

NUREG-0332 (Ref. 1) suggests that a release of 4,800 curies of radon - 222 from the miries ( page ll:) would result in 0.023 excess deaths ( Table la, page 18). This urovides a ratio of 4.$x10-6 deaths per curie. Data from Chapter IV of GESMO (Ref. 7) suggests a value of 1.7x10-6 deaths per curie as a lower limit.

The value of 4.8x10- deaths per curie will be used here as the NRC estimate. It is understood that this is very approximate.

The EPA has evaluated the health effects of a model uranium mill tailings pile. They estimate a total of 200 health effects (Ref. 8, page 73) for a pile which emits at most 20,000 curies of radon - 222 for 100 years. The resulting estimate is 1.0x10-k deaths per curie and will be used here as the EPA estimate.

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5 Evaluation of Health Effects - Nuclear At present some recent uranium mill tailings piles have 2 feet of dirt covering. la this case the EPA 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 used to find the n -

effective releases. Thus the 3 9x10" curies of radon which results from thorium in the mill tailings results in a release of 1.9x107 curies into the atmosphere, which with the NRC estimate of L.8x10-6 deaths per curie results in 90 deaths. '<ith 'the EPA estimate 1900 deaths result. A similar treatment applied to 8,6x10 ll euries of radon from the uranium in the mill tailings results in 200,000 dead for the NRC estimate and E.3 million for the EPA estimate. It is here assumed that no future generation will see fit to take any better care of the mill tailings than is presently practiced.

The uranium enrichment tailings are presently located in the eastern part of the country. It is assumed that these are buried near their present locations. Radon will not escape so easily through wet soil. A reduction factor of 100 is used to estimate this effect. The accuracy of this estimate depends on the particulars of the burial which can only be projected. An additional factor of 2 is used to reduce the effect due to the fact that much of this radon would decay over the ocean rather than populated 2031 339 D**]D m.

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6 land areas. No compensation is taken for the greater uopulation density near the coint of release as compared to the uranium mill tailings piles of the western states. 'tiith this total reduction factor of 200 the NRC estimate is 400,000 dead while the EPA value is 8 million.

Evaluation of Health Effects - Coal ,

It is assumed that the ashes from the coal plants idll be buried in a manner similar to the tailings from the uranium enrichment process. Thus a reduction factor of 200 is usedein this case also. Again the higher population density is ignored.

The particulate which is released into the air by tha coal plant is taken to contain 1% of the contained uranium. Since most such plants are in the eastern part of the country it is estimated that half will fall into the ocean rather than onto land. A second factor of 2 is used to reduce the effect of the resulting radon due to the fact that some of this radon will dd*c ay over ocean as with the radon from the uranium in the enrichment tailings. Again no compensation is taken for the greater population density near the point of release. This gives the total reduction factor of 6 shown in table 1.

With these reduction factors applied to the radon released by the ashes and emissions, in the two cases of 1.0 ppm and 1.8 ppm uranium content coal, the health effects are calculated.

These are shown in Table 1, and range from 7,700 dead from ashee and 3,800 additional dead from airborn emissions for 1.0 ppm coal in the NRC estimate to 290,000 dead from ashes and 140,000 dead frca airborn releases in the case of 1.8 ppm coal in the EPA estimate.

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7 Discussion It is obviously very difficult to estimate with any precision how many health 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 manner in which this material is disposed, thus greatly changing these factors. In particular deep burial could practically

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eliminate the escape of radon to the atmosphere (Ref. 8).

It is imnortant to compare Table 1 here with Table 1 of NUREG-0332 (Ref.1), which shows 0.47 dead for the nuclear case and at most 120 dead for coal. These last numbers totally ignore the effects of long term radon emissions, which result in at least 100 times higher mortality. These long term effects are not only signiRicant, but dominate the effect.

It is important to use Table 1 to compare the relative risk of the nuclear and coal option in their present forms.

In this case deaths due to all causes considered in NUREG-0332 can be ignored as insignificant, since they are so small.

The absolute number of deaths per curie released is irrelevant since it enters in both cases. The relative risk is determined solely by the c.uantities of radon - 222 generated and the reduction factors. Unless there $ s a clear decision to treat : coal ashes differently from uranium enrichment tailings, the health effects from the tailings will be 50 times greater since there is 2031 341

8 50 times more uranium there. The nuclear option remains more hazardous than coal unless the releases from all of the tailings piles can be reduced below the releases from the airborn particulates of the coal plant. This is not the present policy.

Additional Comment There is a typographical error on page 25 of NUREG-0332.

Reference #33 is listed there as being in volume 148 of Science, whereas it appears in volume 144.

Acknowledgment

-e The above comments were inspired by the 5 July 1977 ,

testimony of Dr. Chauncey R. Kepford in the matter of the Three Mile Island Unit 2 (Docket No. 50-320) operating license entitled: " Health effects Comparison for Coal and Nuclear Power".

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9 Ta'ol e 1 Energy Source Excess Hortality cer 0.8 GNy(e) dde to Radon - 222 emissions Origin of Radon Reduction Deaths Deaths Radon Generated Factor NRC EPA Curies

!!uclear Thorium in 3.9x10 8 20 90 1900 Mill Tails ,,

1. 1. "i"" i" 6-8.6x10 ll 20 200,000 A.3x10 Hill Tails Uranium in Enrichment 1.7x10 13 200 A00,000 8x106

. Tails Coal 1.0 opm U Ashes - 3.2x10 ll 200 7,700 1.6x105 Air 3.2x109 A 3,800 8x10 b Particulate Coal 1.8 ppm U 11 5 Ashes 5.8x10 200 14,000 2.9x10 Air 5.8x109 A 6,800 1.4x10 5 Particulate 2031 343

10 References -

1 " Health Effects Attributable to Coal and Nuclear Fuel Cycle Alternatives" NUREG-0332, Draft, U.S. Nuclear Regulatory Commission (September 1977) 2 "Invironmental Analysis of The Uranium Fuel Cycle, Part I -

Fuel Supply" EPA-520/9-73-003-B, U.S. Environmental Protection Agency, (October 1973) 3 R.O. Pohl, " Health Effects of Radon - 222 from Uranium Mining" Search, 7( 5),365-3 50 ( August 1976)

E P.H. Bedrosian, D.G. Easterly, and S.L. Cummings," Radiological Survey Around Power Plants Using Fossil Fuel" EERL 71-3, U.S. Environmental Protection Agency, (July 1970) c 5 M. Eisenbud, and H.G. Petrow," Radioactivity in the Atmosphe~ric Effluents of Power Plants that Use Fossil Fuels," Science lha,:288-289 (1964) .

6 V.E. Swanson et al," Collection, chemical Analysis, and Evaluation of Coal Samples in 1975", Open-file recort 76-A68, U.S.

Decartment of the Interior, Geological Survey, (1976) 7 " Final Generic Environmental Statement on the Use of Recycle Plutonium in Mixed Oxide Fuel in Light '<ater Cooled Reactors," NUREG-0002. U.S. Nuclear Regulatory Commission,

( August 1976) 8 See Ref. 2 2031 544