IA-87-347, Forwards List of Meetings Ref in 860910 Response to Congressman Markey Re Emergency Preparedness Issues
| ML20235N942 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/12/1986 |
| From: | Bellamy R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20235N846 | List: |
| References | |
| FOIA-87-347 NUDOCS 8707200279 | |
| Download: ML20235N942 (18) | |
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NOV 121986 l
l MEMORANDUM FOR: Thomas T. Martin, Director, Division of Radiation '
Safety and Safeguards FROM: Ronald R. Bellamy, Chief. Emergency Preparedness and Radiological Protection Branch, DRSS !
SUBJECT:
MARKEY REQUEST FOR NOTES OF SEABROOK MEETINGS (ACTIONITEM86-117) i
. Enclosed is a list of meetings referred to in the September 10, 1986 response j to Congressman Markey concerning emergency preparedness issues. Region I did !
not attend any of the meetings. l l
%.arG &R4 y Ronald R. Bellamy, Chief I Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards
Enclosure:
Meeting List j cc w/ encl: i T. Murley J. Allan W. Kane ;
W. Lazarus E. Fr>x
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N, ,,1 Enclosure 4
- List of internal _Decume_nts__ _ Seebrook 09/09/85 Notes on conference call with Nerses, Perlis and Dignan to discuss EP from Massachusetts, 10/10/85 Notes on conference call with Nerses Perlis, Dignan, Cenningham, Reis. Christenbury, Turk, Scinto to discuss reduction of EPZ.
10/11/05 Notes of conference call with Bernero, Cerrickson, Nerses to discuss Seabrook approach on demonstrating ability to reduce EPZ.
07/25/86 Notes on staff meetin's with Noonan and Doolittle.
07/25/86 Notes on meeting with Bernero Novak, Rossi, Benaroya, Hoonan, Crccker, Israel, Matthews, Perlis, Doolittle to discuss content of study.
07/29/66 Notes on staff meeting with Novak, Rossi Doolittle. .
07/29/86 Notes on meeting with Jordan Doolittle, Long, Rossi, Novak, Matthews, Kantor, Benaroya, Crocker to discuss content of study. _
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07/30/86 Notec en staff meeting with Novak, Rossi, 'Dooltttle.
G7/30/56 Hetes en staff meeting with Noonin and Dooiittie to discuss plans fer August 26, 1986 meeting, 08/05/86 Notes to prepare for EDO briefing on 8/5/86.
08/06/86 Notes en meeting with T. Pratt, C. Hofuyer, Novak, Rossi, Benaroya, Doolittle, Noonan Fioravante to discuss Bill scope of work.
08/06/86 Draf t BNL Scope of Work: Review of the Emertrency Planning sensi-tivity Study for Seabrook, Project Descript' on.
02/06/66 Draf t bht $ Cope of Work! Review of the Krergency Planning Sensi-tivity Study for Seabrook, Project Descriptiofi.
08/06/86 Notes en meeting with PSHH to discuss contents of study. #
08/n/86 Notes on staff meeting with bevak, Rossi, f!conan, Benareya, Leng, 0001ittle to discuss BNL review and r.,emo to go to Denton on status of review of study.
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[eh b O \O 3Dy AGENDA Seabrook Emergency Planning Zone Coordination Committee January 21, 1986
- 1. FEDERAL AGENCIES
- Discussion of Purpose of Coordination Meetitigs FEMA - Vickers/ Thomas
- Protective Action Decision Making and Implementation: FEMA - Thomas /Dolan Minimum Time Requirements NRC - Terry Harpster
- Protective Actions for Beach Population: Status of. FEMA - Thomas /Dolan RAC P.eview of This Issue
- FRERP Capabilities Conference FEMA - Dolan
- Status of RAC Review of New Hampshire Plans FEMA - Dolan NRC - Bill Lazarus 3y 6 kR4c+, p., (NH (b.') tMTc ht-p,,,,,Q Status of Service of Plans to Participants in NRC - Attorney S. Turk ds ," I ASLB Hearings jh, ly-sat %AA kandry bN bW p g gg g , ,
- Full Scale Exercise N)O mnkw; b c)N FEMA - Thomas /Dolan W +[,cgue,_ Icf NRC - Bill Lazarus 5
_ lhud2H4 II. STATES g,p ff/hA4 11Rc - 2 A. Massachusetts
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- Status of Plan Submissions abduktw qA toTeohc7 Status of Training b2b&%p/
- Status of ETE- UCON b E bbM N'Y $b7 "
A4 Lessons from Hawley Other items B. New Hampshire Status of Training Other Items III. UTI LIT,Y. , Construction Schedule Other Issues @p lg % m (sajgg g q pe bl&twilo JOyNcb ND/
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D}GNhd fhEMD fMok iD be ,M " o lnWerVCnot-c l FEMORANDUM - l This meracrandum addresses three misconceptions which i I have arisen as to the standards to which state and municipal emergency plans will be held in an NRC licensing proceeding. These misconceptions are: A. That the plans must be shown to guarantee that no adverse effects on the public health and safety will occur no matter what kind of accident occurs at Seabrook. B. That it must be demonstrated that the plans will assure that all persons 'ocated l in the Emergancy l l Planning Zone or scme certain portion of it can be , i l evacuated in some certain time. i In particular, there have been assertions that the plans must assure the sheltering or evacuation of persons from the beaches in approximately 1/2 hour. C. That the plans must be designed, and shown to be able, to cope with a particular type of accident -- in particular, one involving an early release of radioactivity off-site. Each of these propositions is false as a matter of law. First, the issue of absolute safety: Neither the Atomic Energy Act nor any regulation of NRC, whether dealing with emergency planning or not,, requires absolute assurance of
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6 perfect safety. Indeed, it has been recognized from the i outset of the formulation of the current emergency planning j l regulations that if one assumes a major accident with j offsite releases, some adverse effect on the public will, by I l definition, occur. The purpose of emergency planning is to l have in place means and methods of coping with such an event in order to keep those effects to as low a level as I reasonab3y possible given the facilities at hand. Southern California Edison Co. (San Onofre Nuclear. Generating Station, Units 2 and 3), CLI-63-lO, 17 NRC 528, 533 (1983). Second, as to the proposition that the plans must be demonstrated to be capable of asshring evacuation of certain areas within a certain time: This simply is not the law. The Appeal Boards of the Commission have so held - flatly l and without equivocation. Cincinnati Gas & Electric Company (Wm. H. Zimmer Nuclear Power Station, Uni t No. 1, ALAB-727, 17 NRC 760, 770 (1983); The Detroit Edison Co. (Enrico Fermi Atomic Power Plant, Unit 2), ALAB-730, 17 NRC 1057, 1069 i n.13 (1983). Indeed, the only activity which the j regulations specifically require to be capable of i accomplishment in one-half hour is public notification. And it is in that context the 1/2 hour rule is discussed in NUREG-0654, the NRC emergency planning guidance document. Third , the proposition that the plans will be judged as l to adequacy against a certain type of accident and in '! particular one involving g release as soon as 1/2 hour:
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e e That proposition is not only bad law, it is directly contrary to the theory of the NRC emergency planning criteria. The theory upon which the regulations were based was that the planners should consider a spectrum of l accidents. The key is that the plan be shown to be flexible 1 and capable of reducing the adverse effects to the greatest extent reasonably possible. The Commission itself has stated:
"Since a range of accidents with widely differing offsite consequences can be postulated, the regulation does not depend on the assumption that a particular type of accident may or will 1
occur. In fact, ao specific accident sequences should be spdcified because each accident could have different consequences both in nature and degree. Although the emergency planning basis is independent of specific accident sequences, a number of accident descriptions were considered in development of the Commission's regulations, including the core melt accident release categories of the Reactor Safety Study (WASH-1400). I I
"It was never the intent of the regulation to require directly or indirectly that state and local governments adopt extraordinary measures, such as construction of additional hospitals or recruitment of substantial additional medical personnel, just to deal with nuclear plant accidents. The emphasis is on prudent risk reduction measures. The j regulation does not require dedication i l
of resources to handle every possible accident that can be imagined. " CLI-83-10, 17 NRC at 533, ) 1 I 3-j
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Furthermore, there is no requirement that it be demonstrated that a plan will cope with any wor't s case accident. NUREG-0654 simply does not require an adequate response for the worst possible accident. Long Island Lighting Co. (Shoreham Nuclear Power Station), LBP-85-12, 21 NRC 603,.888 (1985). In short, the standard by which any emergency plan is to be judged is whether or not it represents the best efforts of knowledgeable people through the use of reasonably available facilities to reduce to the maximum extent reasonably possible the' adverse effects-on the public health and safety which will result fromioff-site releases resulting from a spectrum of accident scenarios. The guiding principles, as recently stated by an NRC Licensing Board are:
"The purpose of emergency planning is to achieve dose savings to the general public in the event that radioactive material is accidentally released off site. There is no minimum standard of public radiation dose which must be met in emergency planning.
" Absolute protection of the public against all radiation doses cannot be guaranteed and is not required for all possible accident scenarios.
"The emergency response-plan should not be developed for any specific preconceived accident sequence. It should instead be framed to cope with a spectrum of accident possibilities including the worst accidents.
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I "There in no standard time required to l be met for evacuation in a radiological emergency. Estimates are necessary to determine accurately the actual time required for evacuation. These estimates are needed to aid in ) protective action decisionmaking. i 1 ! "No massive investment of resources ! (stockpiling of supplies or construction l of hospitals) are required for emergency planning. We will apply a practical i standard of efficience of utilization of l existing resources (such as roadways and manpower) in evaluating the i acceptability of the evacuation plan." l LBP-85-12 at 782. , J s l 1 o l l l
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- CONSEQUENCES TO THE BEACH POPULATION AT SEABROOK STATION ]
FRO *4 THE WASH-1400 ACCIDENTS WITH THE SHORTEST RELEASE TIMES _SU,MMARY NUREG-0654 (Reference 1) requires that the emergency plan for a nuclear power plant consider radionuclides releases, defined in the Reactor Safety Study, WASH-1400 (Reference 2), which have release times of 0.5 hour to 24 hours. During a warm summer day, the beaches can have a high population density in proximity to the site. This population density l must be considered should an evacuation.be necessary. Calculations have been completed to determine the whole-body doses that could occur at-the ! closest beach location from the accidents that, as determined. in WASH-1400, have a release time of 0.5 hour. The closest location of a ., beach to the plant is 1.75 miles east of the Seabrook site. Assumptions regarding the release of radioactive materials were taken'from WASH-1400. Only the PWR-8 and PWR-9 releases have short release times of 0.5 hour. All other releases listed in WASH-1400 have release times of' 2 hours or longer. The PWR-8 release is more severe than the PWR-9 , release. The results of the calculations for PWR-8 are summarized in {; Table 1. A whole-body dose of 5 rem, which was established by the EPA as the protective action guideline (PAG) (Reference 3) for implementing { population protection measures, is not reached at any time, given a l release typified by the PWR-8 release. category. Furthermore, for a PWR-8 j release, the thyroid PAG dose of 25 rem is also not exceeded at the beach for the beach weather scenarios. The integrated mean (or average) ) ' whole-body dose, assuming an. accident occurs at any random time, would be O.1 rem within 8 hours after the accident. The maximum integrated whole-body dose under weather conditions conducive.to large beach populations would be less than 1 rem at 1.75 miles from the plaat. The doses from a PWR-9 release are even lower. .The methodology and assumptions used for the calculations are described below.
- 1. INTRODUCTION The guidelines for emergency planning at nuclear power facilities are defined in NUREG-0654 (Reference 1). These guidelines re' quire that radionuclides release times that range from one-half hour to 24 hours be considered. The technical bases for these emergency- planning guidelines are defined in NUREG-0396 (Reference 4). The analyses of doses performed in NUREG-0396 are based on radionuclides releases, which were determined in the Reactor Safety Study, WASH-1400 (Reference 2). Therefore, the range of release times for the radionuclides releases, which are required to be considered in developing the offsite emergency plan for Seabrook Station, are traced directly to the release categories defined in the Reactor Safety Study. Table 2 reprodu'ces the radionuclides release {
j categories determined in WASH-1400 for pressurized water reactors. These are labeled PWR-1 through PWR-9. From Table '2 it is seen that only i release categories PWR-B and PWR-9 have release times of one-half hour. l All other release categories have release times of 2 hours or mare. It ! is also noted that the fractiohal release of all radionuclides for PWR-8
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and PWR-9 is very small. Therefore, the manner in which one-half hour release times are considered in the Seabrook offsite emergency plan depends on the dose consequences for the population from these two release categories, PWR-8 and PWR-9. The Seabrook and Habpton beaches represent the closest distance from the site at which high population 3 ' densities could exist during a potential accident at Seabrook Station. Population protective measures are implemented if the doses from an accident are projected to exceed the upper protective action guideline levels of 5-rem whole-body exposure or 25-rem thyroid exposure. l Determination of accident doses is based on the WASH-1400 methodology. Evacuation is one of the available population protection measures. Whether or not the upper PAG 1evels are exceeded depenas on a combination l I of factors,. including the time of release, the magnitude of release, and the weather conditions at the time of release. It is the objective of this study to determine the dose levels on the , Seabrook beaches for those WASH-1400 releases that have a 0.5-hour release time and to place these dose levels into perspective relative to the upper limits.
- 2. SOURCE TERMS The shortest release times for accidents evaluated in the Reactor Safety Study, WASH-1400, is 0.5 hour. This occurs for the accident scenarios designated PWR-8 and PWR-9. All other accident scenarios for PWRs have release start times cf 2 hours or greater. While release categories PWR-1 to PWR-7 are considered in emergency planning, they should not affect the consideration of half-hour releases, according to the emergency planning guidelines. The PWR-8 scenario involves a design :
I basis loss of coolant accident combined with a failure to isolate the containment. The PWR-9 scenario is characterized by a design basis loss of coolant accident with successful containment isolation. Table 2 shows the fraction of the total core inventory released from the containment for each of eight isotope groups. All release frar.tions for the PWR-9 isotope groups are less than for the corresponding PWR-8 ; release. Therefore, dose calculations in this study are made for the PWR-8 category, which has the larger of the two accident releases.
- 3. WEATHER SCENARIOS A 1-year period of meteorological data, measured on the Seabrook site tower fron April 1979 to March 1980, was available for evaluation of appropriate meteorological scenarios for this study. The Seabrook meteoroingical tower was designed and operated in accordance with the applicable Nuclear Regulatory Commission (NRC) guidelines (Reference 5).
It provides hourly data representing the site meteorological conditions that are specific to the Seabrook site.' Because this study is focused on the beach location, only data for periods when the weather is conducive to significant beach use were , l selected for evaluation. The times when a large beach population could be present are in the daytime (between 9:00 a.m. and 6:00 p.m.) during 4 2 1340P0ll586 q . i
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the summer season (from May 30 to September 7). Accordingly, there are ! 891 beach hours in a . year. In addition, the beach population is only at l risk if, at the time of. a'n accidental release.of' radioactivity from the i plant, the wind direction is from the site toward the'beacn (winds- ! generally blow from the WNW, west, and WSW sectors). An' hour-by-hour ! Search of the meteorological data tape was made to isolate the weather l conditions that met'these criteria.- Of' the 891 beach hours, the wind ; direction is from the site to the beach during 282 hours, or one-third of j the time. Table 3.shows how these 282' beach hours, with winds from the west, are' distributed with respect-to wind speed and atmospheric l It.is noted that atmospheric stability conditions E and F are stability. not observed. Atmospheric stability conditions E and F represent stable I atmospheres that only occur during temperature inversion conditions when
-the ground is colder than the atmosphere. These conditions can occur
.during the night or during cold sea-breeze conditions, but not on sunny days with westerly winds. Based on inspection of this table, six combinations of wind speed and stability were-selected for analysis. The.
frequency of occurrence for each combination was determined and expressed -i as a fraction of the 282 beach hours having westerly. winds. These six combinations and their respective frequencies are shown in Table 1. The "best" beach days are characterized by sunny skies and moderate wind speeds. These conditions often result in onshore breezes (so-called sea breezes) that would carry any releases: from the plant away from the beach to the west of }he plant. Thus, the conditions selected for evaluation in which the winds are blowing from the plant- toward the beach are not necessarily characteristic of the "best" beach days. It is also of interest to note that th'e clear' sunny days would result in- considerable atmospheric turbulence due to thermal convection from the ground that has - been heated by the sun. These conditions are typified by stability classes A through C and result .in the lowest doses, as shown in Table 1.
- 4. METHODOLOGY Atmospheric dispersion was modeled by using the straight-line' Gaussian plume model described in WASH-1400, Appendix VI, Sections 4 and 6. Dose calculations were based on the dosimetric models described in Wash-1400, Appendix VI, Section 8.2. The computerized version of these models are included in the CRAC (Calculation of Reactor Accident Consequences) l computer program that was used to produce the WASH-1400 results. - Both the dispersion and the dose models in CRAC were used in a version of CRAC thet was modified by Pickard, Lowe and Garrick, Inc.~ (PLG), and is -
referred to as CRACIT (Calculation of Reactor Accident Conseq;ences Including Trajectories). In this study, all weather scenarios were assumed to be straight-line; therefore, there are no significant differences between results produced by CRAC or by CRACIT. The six weather conditions selected for evaluation in this study (see Table 1) were processed through CRACIT separately. Because' dose as a function of time was of interest, four CRACIT runs in whicn the time was varied were made for each combination of release and weather scenario. The exposur.e times for each of the four runs were set at 1, 2, 4 and 8 hours. Since the release dur'ation is only one-half hour, tne increasing-l
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doses observed for the longer time periods are due to exposure from isotopes that are deposited on the ground. . Evacuation is not modeled for dose calculations. Therefore, the calculated doses could only be obtained by a stationary incividual located 1.75 miles downwind from the point of release during the entire duration. As a quality assurance verification check, the source terms for the PWR-8 release category were run through a second computer program referred to as MIDAS (Meteorological Information and Dose Assessment System), which is used by PLG in support of emergency response activities. lhe results were in substantial agreement with those determined by using CRACIT.
- 5. RESULTS The whole body doses computed using the methodology described above are listed for each weather category in Table 1. As shown, none of the weather scenarios, including the worst case resulted in exposures above the upper PAG limit of 5-rem whole body for any time period out to 8 hours. In fact, even the highest calculated dose of 0.4 rem is well below the lower whole-body PAG level of 1 rem. Also shown in Table 1 are the weather category frequencies. Mean.(or average) doses are computed by weighting the dose for each weather. category. They are also shown in Table 1. The megn values for all exposure times are well below the PAG 1 i
doses. It is also interesting to note that after the first time period doses do not increase rapidly. This is due to the relatively small fraction of particulate isotopes ~ assumed to be released in the PWR-8 release category and. deposited on the ground. Thus, most of the dose is ! received during the time period of about one-half hour as the plume passes the beach. Thyroid doses have also been determined although less emphasis would be ) l placed on the thyroid PAGs due to the high cure rate for thyroid cancers. The maximum thyroid dose, calculated for combination D-2 (atmospheric stability category D, with 2 meters per second wind), is 9 rem. This dose is well below the thyroid PAG dose of 25 rem.
- 6. CONCLUSIONS !
The lower PAG dose of 1-rem whole body is not reached at the beach locations in the vicinity of Seabrook Station for those radionuclides releases in WASH-1400 that have a release time of less than 2 hours. l This conclusion is valid for all weather conditions that are conducive to ! large beach populations. Furthermore, the thyroid doses also are well below the upper PAG dose for the worst case analyzed. Therefore, even if ; release times as short as 0.5 hours are considered, it is concluded that the dose levels do not reach the level, for which emergency actions would be undertaken and evacuation would not be required. All other releases in WASH-1400 have release times of 2 hours or greater, with a typical plume travel time to the beach of 0.5 to I hour. W 4 1340P011586 t
- 7. REFERENCES
- 1. Federal Emergency Management Agency, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," prepared for the Nuclear Regulatory Commission, NUREG-0654,. January 1980.
l 2. U.S. Nuclear Regulatory Commission, " Reactor Safety Study: An Assessment of Accident Risks in U.S. Commercial Nuclear Power Plants," Reactor Safety Study, WASH-1400 (NUREG-75/014), October 1975. l 3. EPA, " Manual of Protective Action Guides and Protective Actions for Nuclear Incidents," EPA-520/1-75-001, September 1975. 4 Collins, H. E., et al., " Planning Basis for the Development of State l and Local Government Radiological Emergency Response Plans in Support of Light Water Nu: lear Power Plants," prepared for the U.S. Nuclear Regulatory Commission, NUREG-0396, December 1978.
- 5. U.S. Nuclear Regulatory Commission, "Onsite Meteorological Programs,"
LRegulatory Guide 1.23, 1972. I l d l l 5 l 1340P011586 l u____ _ _ _ _ _ _ _ . _ _ . _ _ _ . _ . _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ . . _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ __.
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SUMMARY
OF OOSE VERSUS TIME AFTER RELEASE FOR PWR-8* ACCIDENT 1 l l Weather Condition ** Whole Body Oose After:t Wind Speed Frequency 1 Hour 4 Hours 8 Hours PG 2 Ho'urs l Stability (m/sec)ti (f) (rem) (rem) (rem) (rem) A 3 0.13 0.01'o O.014 0.015 0.016 ) A 5 0.35 0.008 0.009 0.009 0.010 B 4 0.16 0.034 0.035 0.038 0.041 C 3 0.10 0.099 0.100 0.110 0.120 D 2 0.17 0.300 0.320 0.350 0.400 0 5 0.09 0.135 0.145 0.162 0.187 Mean 0.0829 0.0880 0.0962 0.1089
- Release rates for PWR-9 are lower than for PWR-8; therefore, doses would be lower.
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.O.
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N N .N -= m N N N , . . e. W e W W en 'f* e T T T 5 N. U @ he E WC T m g m. 8 J p e D 3 D e* a
- m. g .D =. Q
> e mu v U n G Q
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D w C w C L Q
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= = = = =
s 3 2 3 5 2 ,
;.6 et 2
L. n E. le $ im G to Or p u -m. Q g KQ, .e* =* . V) e 7 I 4
TABLE 3. BEACH HOURS PER YEAR WITH WESTERLY WINDS,* ** CATEGORIZED BY WIND SPEED AND ATriOSPMERIC STABILITYt Beach Hours per Year Wind Speed PG Atmospheric Stability Condition' ' (m/sec)ii , A B C D l 0-1 1 0 0 0 1-2, 0 0 1 8 2-3 12 4 2 24 3-4 31 12 5 15 4-5 36 12 11 16 5-6 40 14 5 8 6+ 18 2 3 2 TOTAL 138 44 27 73
- Winds from the plant toward the beach. -
** Based on Site Weather Records from April 1979 to I, March 1980. I t
Pasquill-Gifford (PG) Atmospheric Stability based on vertical temperature ditference measurements. ' 17 1 m/se: = 2.2 miles per hour. 4 12:1P010986 8 L- _ - - - - _ _ - . - - - - - . _ - - - - - - - - - - - - - - - - - - _ _ _ _ _ _ _ _ _ _ _ - - - - >}}