ML20082F787

Response Opposing NRC Position on Summary Disposition of Contention 37B Re Effects of Low Level Radiation.Joint Intervenors 831031 Counterarguments Adopted

ML20082F787
Person / Time
Site:	Harris
Issue date:	11/22/1983
From:	Eddleman W EDDLEMAN, W.
To:	Bright G, Carpenter J, Kelley J Atomic Safety and Licensing Board Panel
Shared Package
ML20082F772	List: ML20082F768 ML20082F787 ML20082F793
References
82-468-01-OL, 82-468-1-OL, ISSUANCES-OL, NUDOCS 8311290246
Download: ML20082F787 (1)

Text

1 Staff's slavish adherence to Applicants is shown by their l

adontion of the size-increase argument (upl3-1k). This argunent is silly when what is attaching to a particle is an aton.

The Branagan affidavit cited by Staff does not state that 1

the coal-particle route was considered at all by the Staff.

I It simply defends their DES as valid because it says what it says.

Since the Staff DES didn't consider this means of exposure, there l

IS an issue of fact.

Staff says the Pu-239 which they adnit is forned by decay l

of Np-239 released from Harris is " insignificant because of the difference in half lives". If Np-239 is the parent and decays j into Pu-239, the quantity of Pue-239 forned must be the sane as the quantity of NP-239 present (aton-for-aton decay). We guess the Staff neans that the same quantity of Pum-239 is less curies because it has a longer half-life thar NPan-239. However, Pu-239 l

is an alnha enitter (a noint the Staff f ails to address), and aloha particles do nuch nore danage than the beta and ganna from Np-239 (9BE of up to 20 for alpha radiation is cited by ICRP).

Staff is simply dodging the issue, not stating facts.

l Because of the above-cited facts and argunents, the Staff resnonse, which is really a sont of notion for sunnary disposit!_on tied to Applicants for the nost part, must fail.

i fM V Wells Eddlenan l for the Joint Intervenors I

j Joint Intervenors wish to thank the Board for giving then this onnortunity to resnond to the Staff on this contention.

l ((bY;$ 1 10 Y N E @ b' F $ IV l l g-72-<s 8311290246 831122 PDR ADOCK 05000400 0 PDR

UNITED STATES OF AMERICA Novenber 22, 1983 NUCLEAR REGULATOBY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Glenn O. Bright Dr. James H. Carpenter James L. Kelley, Chairman In the Matter of

) Dockets 50 400 OL CAROLINA POWER AND LIGHT CO. et al. ) 50-401 OL (Shearon Harris Nuclear Power Plant, )

Units 1 ani 2) ) ASLBP No. 82-L68-01

) OL Wells Eldleman's Response to NRC Staff on Summary Disposition of Contention 37B I hereby adopt, in resnonse to Staff's leFa1 argunents, the counter-arguments made by the Joint Intervenors in regard to Joint Contention II by Daniel 9ead, dated 10-31-83 but served 10-29 (see attached certificate of service thereto).

Staff Resnonse (31 October 1983 at 15) does not address the substance of contention 37B which is that health effects besides cancer and genetic disease can be caused by low-level radiation, and that the pain and suffering of victims of cancer and genetic defects and other radiation-caused diseases was not taken into account in the cost-ben fit balance for Harris.

40'ElS4%

Wells Eddleman.

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