, . .: . UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of CAROLINA POWER AND LIGHT COMPANY AND ) Docket Nos. 50-400-0L NORTH CAROLINA EASTERN MUNICIPAL ) 50-401-0L POWER AGENCY ) ) (Shearon Harris Nuclear Power Plant, ) Units 1 and 2) ) AFFIDAVIT OF CHARLES W. BILLUPS IN SUPPORT OF NRC STAFF M0TinN FOR SUMMARY DISPOSITION OF EDDLEMAN CONTENTION 8F(1) I, Charles W. Billups, being first duly sworn do depose and state: 1. I, Charles W. Billups, am an employee of the U.S. Nuclear Regulatory Commission. My present position is as an Aquatic Scientist in the Environmental and Hydrologic Engineering Branch, within the Office of Nuclear Reactor Regulation. A copy of my professional qualifications is attached. 2. I give this affidavit in support of Summary Disposition of Eddleman Contention 8F(1) in this proceeding, and I certify that I have | personal knowledge of the matters set forth herein and that the state- ments are true and correct to the best of my knowledge, information and belief. 3. Eddleman Contention 8F(1) in this proceeding states: < " Health effects of the coal particulates 1,154 MT per year, are not analyzed nor given sufficient | | weight." I 8312300270 831202 PDR ADOCK 05000400 0 PDR i , . .- -- W . - . - , . ~ . - . - . -. ,. - . _ . , ,. -2- 4. The purpose of this affidavit is to demonstrate (1) that the Table S-3 level of coal particulates released in the uranium fuel cycle is negligible with regard to the operation of the Harris Nuclear Plant, (2) that f.ie impacts including health effects of emitted particulates from coal combustion at the electrical generating stations or grids involved in the uranium fuel cycle have been thoroughly considered in the NEPA reviews for-the individual gaseous diffusion plants, the major source (96%) of emitted coal particulates in the uranium fuel cycle, and (3) that there is reasonable assurance that the 10 C.F.R. Part 51 Table S-3 level of emitted particulates provides a very conservative (over) estimate of such emissions based on current operating characteristics of the generating plants and electri- cal grids supporting the gaseous diffusion plants and based on current standards of performance and limitations on particulate emissions estab- lished by the Clean Air Act. Table S-3 Level of Particulates Negligible with Regard to Harris Environmental Review 5. Health effects of coal particulates were not analyzed specifically in the Harris DES (NUREG-0972, April 1983) and FES (NUREG-0972, October 1983). Those impacts of the LWR-supporting fuel cycle that reasonably appeared to have significance for individual reactor licensing sufficient to warrant attention for NEPA purposes were specifically addressed in the DES and FES (Section 5.10 and Appendix C). The judgement by the staff that health effects of coal particulates did not need to be addressed in the Harris environmental review was based on technical information sup- porting the Table S-3 rulemaking. 6. The documents supporting the Table S-3 rulemaking provide a basis for the finding that the particulates emitted from an equivalent ,- , . , . _ _._ _.. _. , . -3- 45 MWe fossil-fueled power plant are negligible. Of particular note is the document entitled, " Environmental Survey of the Uranium Fuel Cycle" (AEC,1974, WASH-1248) which includes the consideration of impacts from power generation in support of the fuel cycle. - 7. The electrical energy required per annual fuel requirement ; of the model LWR (Light Water Reactor) is given in Table S-3 to be 323 x 103 MW-hr. In comparison to the model 1000 MWe LWR which produces 7 x 106 MW-hr in annual operation at a load factor of 80% (ibid., WASH-1248, p. 5-17), the equivalent generating plant supporting the uranium fuel . cycle is about 46 MWe. It should be noted that this value is slightly higher but not significantly different from the 45 MWe given in Table S-3. The Table S-3 value of 45 MWe is based on energy requirements of 317 x 10 3MW-br which were increased subsequent to initial publication in consideration of the "back-end" of the fuel cycle. Since the equivalent power plant indicated in Table S-3 is 45 MWe, I have used that plant size in my analysis. Also, the rewits of my analysis and conclusions would not be altered if the analysis were based on the net output of the Harris plant. 8. The major user of electricity in the fuel cycle is the enrichment process, carried out at the three U.S. government-owned gaseous diffusion plants. As concluded in WASH-1248 "only the generation of electrical energy for the isotope enrichment step was judged to cause significant environmental effects." This step of the fuel cycle is estimated to require 310 x 103 MW-hr of the total 323 x 103 MW-hr of electricity for the annual fuel requirement of the model LWR. This requirement represents over 96" of the total electrical energy required by the fuel cycle. At the time of the development of g .~ . .. - . - - . - . _ . - - . - . - - ., , ,- - . ~ _ , - - - - -- - . - 4 -- f technical'information which was subsequently presented in WASH-1248 (as ' Table S-3 data), most of the electricity generated in the United States ' was being produced (as now) in power plants that burn fossil fuels. The conservative assumption (i.e., over-estimating the potential environmental effects) was made in WASH-1248 that coal-fired power plants supplied all .of the required. energy; thus _ the energy requirements and associated air -pollutant emissions were assumed to correspond to a typical, existing coal-fired power plant.(i.e., existing in 1972 when the technical review - of.the fuel cycle impacts was first conducted). The Table S-3 estimates -of effluents from the burning of fossil fuel are based on the equivalent 45 MWe coal-fired plant with characteristics of a typical 1000 MWe coal-fired plant given in Table D-6 of WASH-1248. The equivalent plant zis not to be misinterpreted as an actual 45 MWe plant at a specific loca- tion. Rather it is the energy drawn from the power grids of the-large utility complexes supporting the gaseous diffusion plants. Thus,'no single power supply-source is identifiable as producing the total gaseous effluent level set forth in Table S-3. The term gaseous effluent is used in this affidavit, since the particulate emissions are i listed in Table S-3 under the heading " gaseous." Also, to the extent that power in the grids is produced by nuclear or other fuel types, the total I quantity of the fossil fuel combustion emissions would be reduced pro- | | portionally. Power for the three gaseous diffusion plants in the U.S. is drawn primarily from the grids of three utilities systems: Tennessee Valley Authority, Ohio Valley Electric Corporation, and Electric Energy Inc. Characteristics of these systems supporting the gaseous diffusion plants are | , described below. The equivalent 45 MWe of power when distributed over i these systems results in insignificant impacts at any particular loca- . tion within 'the applicable grid systems, as addressed below. L - v ' , .- . :2:: : =::=w . - - _ - - - =:2 :2._. - - _ _ _ _ _-__- _____ ____ * .-. , -5- 9. - The estimated level of particulates in Table S-3 gaseous efflu- ents-is. based on a particulate emission rate of 22 lb/ metric ton of coal (WASH-1248, Table D-6) or 3.6 metric tons /hr, WASH-1248, Table D-7) for a typical (1972 vintage) 1000 MWe coal-fired plant. For later comparison with current new stationary sources performance standards for electric utility . steam generating units under the Clean Air Act, 42 USC-7401 et sec, the equivalent particulate emission (in units of lbs per 100 Btu) for the Table S-3 " equivalent plant" is .768 lb/106 Btu. This value is obtained by dividing 22 lb/MT by 28.6 x 106 Btu /MT (or 13,000 Btu /lb as given in Table D-6 of WASH-1248). NEPA Reviews of Impacts for the Individual Gaseous Diffusion Plants 10. Environmental reviews pursuant to NEPA have been performed for each of the three gaseous diffusion plants. Included in these reviews were considerations of impacts of the electrical generating plants and/or systems providing power to the gaseous diffusion plants. ERDA 1977 " Ports- mouth Gaseous Diffusion Plant Site Piketon, Ohio;" " Environmental Assess- ment of the Oak Ridge Gaseous Diffusion Plant Site;" " Final Environmental Impact Assessment of the Paducah Gaseous Diffusion Plant Site." In each . of the NEPA environmental review documents, coal particulates and other air pollutant emissions are specifically addressed. Therefore, based on my review of these documents. I believe them to be directly applicable to the Staff consideration of summary disposition of contention 8F(1). 11. Pertinent information from the three environmental reviews are summarized below. The health effects associated with air pollutant ' emissions from two " dedicated" coal-fired plants have been evaluated, in detail, in the Final Environmental Impact Statement for the Portsmouth Gasaous Diffusion Plant site. The Portsmouth plant represents a worst . ._ .._ ~ . , - . _ . _ . _ . _. - _ _ _ _ _ _ _ _ _ | , . -6- case, in terms of particulate emissions from " dedicated plants", for our present consideration. DOE's evaluation of health effects for the coal- fired plant emissions is provided as an attachment to this affidavit '(ExhibitA). 12. Enriched uranium is produced at the three federally owned gaseous diffusion plants (GDP) located near Oak Ridge, Tennessee, Paducah, Kentucky and Piketon, Ohio. Upon completion of planned expansion programs for the three plants, the nation's enrichment capacity will be approximately 27.7 million separative work units (SWU) per year (ERDA,1977), or about 250 times the average annual fuel requirements of the Harris plant.