ML092170567
| ML092170567 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 08/24/2009 |
| From: | Leeds E Office of Nuclear Reactor Regulation |
| To: | Goodman S - No Known Affiliation |
| ENNIS R, NRR/DORL, 415-1453 | |
| Shared Package | |
| ML092170541 | List: |
| References | |
| G20090436, LTR-09-0382, SECY-2009-0374, TAC ME1812 | |
| Download: ML092170567 (5) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 August 24, 2009 Mr. Sidney J. Goodman 158 Grandview Lane Mahwah, NJ 07430
Dear Mr. Goodman:
On behalf of the U.S. Nuclear Regulatory Commission (NRC), I am responding to your July 18, 2009, letter addressed to NRC Chairman Gregory B. Jaczko. In your letter, you raised a number of concerns related to the following topics: (1) geological issues pertaining to Hope Creek Generating Station (Hope Creek) and Salem Nuclear Generating Station, Unit Nos. 1 and 2 (Salem); (2) the size of the evacuation zone surrounding nuclear plants; (3) nuclear liability insurance; (4) potassium iodide; (5) license renewal; and (6) NRC policies. Each of these issues is discussed below.
Geological Issues Your letter raised concerns about the potential effects that an earthquake could have on the Hope Creek and Salem plants. Specifically, you raised concerns about the construction of these plants on "soft ground" near an earthquake fault. You also raised concerns about the licensee potentially building a fourth nuclear plant at this site.
The Hope Creek and Salem plants are located on a man-made peninsula called "Artificial Island" on the Delaware River in New Jersey. Prior to plant construction, the upper soils (approximately 25 to 30 feet deep) on Artificial Island were comprised of hydraulic fill material (composed of a mixture of silt, silty clay, fine sand, and organic material) placed there by the U.S. Army Corps of Engineers as a result of dredging operations in the Delaware River. During the construction of safety-related structures for each of the plants, the hydraulic fill material and other soil below the hydraulic fill was excavated and replaced with compacted engineered 'fill material or concrete (in the associated areas for the structures), down to a depth of approximately 70 feet.
During the construction and operating license review phases for the plants, the NRC staff reviewed the licensee's analysis of the geology and seismology for the site. These reviews included an assessment of the potential for soil liquefaction, the location of earthquake faults, and the intensity of potential earthquakes. Based on these reviews, the NRC staff concluded that the site was acceptable relative to geology and seismology (i.e., the foundation is adequate to support safety-related plant structures in the event of an earthquake). If the licensee for Hope Creek and Salem proposes to build a fourth nuclear plant on Artificial Island, the NRC staff will perform similar reviews to determine the acceptability of the site location for that plant.
Size of Evacuation Zone Your letter questioned the NRC as to why it is satisfied with a 1O-mile evacuation zone surrounding a nuclear power plant given that the effects of an accident could potentially reach beyond this zone.
S. Goodman
- 2 Federal regulations require nuclear power reactor licensees to prepare comprehensive emergency plans to ensure that prompt and effective actions can and will be taken to notify and protect citizens in the vicinity of a nuclear facility in the unlikely event of a radiological emergency. Emergency plans for nuclear power plants specify two concentric emergency planning zones (EPZs), centered around each plant, which represent areas for which detailed planning is needed. The first zone, called the plume exposure pathway EPZ, is an area with a radius of about 10 miles from the center of the plant. The major protective actions planned for the 10-mile EPZ are evacuation and sheltering. Beyond 10 miles, direct exposure is expected to be sufficiently low that evacuation or sheltering would not be necessary. The second zone, called the ingestion pathway EPZ, is an area with a radius of about 50 miles from the center of the plant. Within the 50-mile EPZ, precautionary actions such as putting livestock on stored feed and other protective actions may be used to reduce exposure to the public from the ingestion of potentially contaminated food and water. These precautionary or protective actions would only be necessary for the population within the segment or "slice" of the EPZ that is actually impacted by the path of the plume. For either EPZ, protective actions could be expanded, as necessary, depending on the conditions of a radiological emergency or changes in weather conditions.
Nuclear Liability Insurance Your letter raised concerns about the Price Anderson Act, suggesting that the potential damage which could be incurred, as a result of a reactor accident, would exceed the coverage provided.
The Price Anderson Act requires nuclear power plant licensees to obtain nuclear liability insurance. Each nuclear power plant licensee must have primary insurance coverage of
$300 million for each reactor. The Price Anderson Act further requires these licensees to participate in the secondary retrospective insurance pool whereby they are required to contribute up to $111.9 million per reactor per accident in the event that a nuclear accident exceeds the required primary insurance coverage. The primary and second insurance layers result in a pool of more than $11 billion to cover an accident. If an accident costs more than this amount, responding organizations like State and local governments can petition Congress for additional disaster relief under the provisions of the Price Anderson Act.
Potassium Iodide Your letter questioned why the NRC supports the distribution of potassium iodide pills "as an assurance that no one will be harmed from a disaster."
As you correctly implied in your letter, potassium iodide is not a general anti-radiation pill.
Instead, it provides very specialized protection. Specifically, it can protect the thyroid gland against internal exposure to radioactive iodine. Potassium iodide cannot protect individuals from external radiation, and cannot protect individuals from radiation from other radionuclides.
Evacuation is the most effective protective measure in the event of a radiological emergency because it protects the whole body (including the thyroid gland and other organs) from all radionuclides and all exposure pathways, although in-place sheltering can be preferable during certain plant releases and weather conditions. Administering potassium iodide can be a reasonable, prudent, and inexpensive supplement to evacuation or other protective measures, such as in-place sheltering.
S. Goodman
- 3 License Renewal Your letter questioned the NRC's reputation based on your assertion that the license renewal of nuclear power plants was "automatic."
The NRC takes its responsibility of ensuring the public's safety very seriously and considers a license renewal to be a significant licensing action. The NRC's normal license renewal review requires almost 2 years and approximately 15,000 staff-hours of evaluation and inspection; hearings granted on a license renewal application can considerably extend this process. To date, the NRC has approved all of the applications for license renewals for which it has completed its reviews. However, several years ago, the NRC found an application insufficient to start the review and rejected that application. The NRC has also halted the review process until sufficient information was provided to continue the review. Although the NRC can deny a request to renew a license if the applicant did not provide appropriate or adequate information in its initial application, the NRC would identify the deficiencies and allow the applicant to resubmit the application or provide additional information. This process can continue until the NRC concludes that the application is sufficient to complete the review.
The NRC has more clearly defined the requirements for license renewal and the nuclear industry now has the experience of many successful license renewal requests to date. Because of the cost and the commitment associated with an application, it is unlikely that an applicant will now submit an application for license renewal that is so fundamentally flawed that the NRC staff would issue a denial. To support license renewal, licenses have planned or undertaken a number of costly plant modifications (e.g., steam generator replacements) prior to even applying to the NRC to upgrade the material condition of the facility. Finally, if problems with systems, structures or components of the facility were identified during the review, the applicant would likely choose to make the required modifications, or put in place an aging management plan that would be acceptable to the NRC, rather than withdraw the application. Problems with safety structures, systems, or components that affected their current operation or reliability would be addressed immediately, and any necessary changes made under the current operating license.
NRC Policies Your letter asked what the NRC was going to do to "inject some overdue reforms in NRC policy."
The NRC's job is to protect people and the environment from radiation hazards by regulating the various commercial and institutional uses of nuclear material, including nuclear power plants.
This mission is accomplished through: (1) the establishment of standards, regulations and requirements governing licensed activities; (2) the licensing of nuclear facilities; and (3) the inspection of facilities to ensure that they comply with the applicable requirements.
The NRC continually strives to improve its regulatory programs to better accomplish its mission.
The NRC has established or changed many of its regulations and policies based on the recommendations of the NRC staff and external stakeholders. In addition, reactor operating experience information is systematically evaluated by the NRC to help inform the rulemaking, licensing and reactor oversight processes.
S. Goodman
- 4 The NRC recognizes the public's interest in the safe regulation of nuclear activities and provides opportunities for citizens to make their opinions known, participate in regulatory proceedings, and ask questions about nuclear regulation. We appreciate feedback from the public to help inform our regulatory decision making.
I hope that this letter satisfactorily addresses your concerns.
Sincerely, Eric J. Leeds, Director Office of Nuclear Reactor Regulation Docket Nos. 50-354, 50-272, and 50-311 cc: ListServ
Incoming: ML092120301 Response: IVIL092170567 Package: ML092170541 via ernai '1 OFFICE LPL1-2/PM LPL1-2/LA TECH ED*
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