ML17138A891
| ML17138A891 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 10/18/1979 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Prelesnik W AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML17138A892 | List: |
| References | |
| RULE-RM-50-2 NUDOCS 7911020047 | |
| Download: ML17138A891 (15) | |
Text
OCT 18
~gyp Mr. Warren L. Prelesnik
.424 Laurel Drive
- Hershey, Pennsylvania
- 17033
Dear,
Mr. Prelesnik:
I have been asked to respond to your letter of August 30, 1979 to Chairman Hendrie.
In. your letter you made a few general statements and asked a number of specific questions.
Our responses to your specific questions are contained in Enclosure 1.
Several of your general statements
,reflect some misunderstandings regarding NRC policy and positions.
Therefore, I have attempted to provide more detail on some of your concerns.
First, you state that "any low-level radiation releases are signifi-cant as has been admitted and proven, even by the old AEC and the NRC's own studies."
We are not aware of ary studies that have established that there is no safe level of radiation.
- However, as a conservative and prudent assumption, v<e assume that no amount of radiation is safe (see Enclosure 2).
- Secondly, you state that "The current standards were initially set in order to justify atomic bomb testing., Those standards were kept in order to justify nuclear power plants because the nuclear industry and our government recognizes that'o plant operates with-out
'normal 'eleases of radiation."
General information about radiation standards is provided in the NRC's "Radiation Standards Fact Sheet"
{Enclosure 3).
As noted in this enclosure and Enclosure 2, the radiation protection standards were based on the best scientific judgement available in the world.
Thirdly, you state that "the boiling reactor cores at the Beevick plant are untried and unproven as to their overall safety and functioning."
The General Electric (GE) boiling water reactor design (BWR/4) is not a new design.
General Electric BWR's have been operating safely for a number of years.
For example, the Peach Bottom Nuclear Power Plant located in southeastern
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Nr. Warren L. Prelesnik 2'ennsylvania, is a BWR/4 of identical core design.
The 8 x 8(R) fuel assemblies that will be used in the Berwick plant were first introduced in 1977.
As of April l979, there were about 1900 of these fuel assemblies in operation throughout the U.S.
These fuel asserrblies are bei'ng used routinely to reload all GE BWR plants.
The operational characteristics of these fuel asseohlies have been satisfactory.
Fourthly, you state that 'The safety equipment and men at the Berwick plant are untried and unproven just as they were at Tt1I."
The NRC has adopted minimum standards set by the American National Standards Institute for the selection and training. of nuclear power plant personnel.
The standard, ANSI 18.1, specifies the educational background and work experience required for positions such as plant superintendent, operations supervisor, maintenance supervisor, senior reactor'perators (SRO's),
reactor operators (RO's), etc.
The people who are at the controls of the reactor are licensed by the NRC.
The NRC issues two types of operator
The experience and qualifications required before NRC will administer an examination for an SRO license are (1) high school diploma or equivalent; (2) four years power plant experience; two of these years must be at a nuclear power plant; and (3) at least six months experi-ence at the reactor that the applicant seeks a license.
The reactor operator is given both a written and oral examination on all aspects of an operating nuclear power plant.
- However, as a
result of the accident at Three labile Island, Unit 2, we are
.reevaluating our requirements for licensed operators.
Lastly, you state that "let us use honest, straightforward language and tell the truth.
'The temporary loss of habitat may have signi-ficant adverse impacts on the aquatic community in the vicinity of the site,'eally means that it would kill all fish and wildlife currently living near the site." It is true that some fish would be killed by operation of the plant, particularly during periods of low river flo<<.
However, it is not true that "all-fish and i<ildlife currently living near the site would be killed."
The fish would be killed by becoming entrained or impinged on the water'intake screen.
This factor is considered before licensing OFFICE)
SURNAME DATEI
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Mr. Warren L. Prelesnik a nuclear plant, and it must be possible to take mitigating measures to limit any fish kill, in order that the plant be allowed to operate.
It is unlikely that there would be any other wildlife killed by the operation of a nuclear plant.
Our responses to your specific questions are contained in Enclosure 1.
Since a Final Environmental Statement on the operation of Susquehanna Units 1 and 2 is still in preparation, our response is preliminary at this time.
We will send you a copy of the Final Environmenta'I Statement when it is issued.
Sincerely, Origioai sic@ @
E G, Case arold R. Denton, Director Office of Nuclear Reactor Regulation A
DISTRIBUTION H. Denton R. Minogue E.
Case H. Berkow D. Vassallo F. Schroeder D. Eisenhut D. Muller W. Kreger TMI A/D File TMI f% File w/encl.
1 and 2 (w/o encl. A, T. Murphy F. Congel E. Branagan P.
Leech M. Parsont/R.
Baker R. Bangart/J.
Boegli S. Miner D. Houston G. Knighton TMI Site File SECY (3)
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Enclosures:
I. Response to Specific guestions from Warren L. Prelesnik with Enclosures A, B, C and D
- 2. Background Information on Assum tion of Linear Non-Threshold Hea t Effects Model
- 3. Radiation Standards Fact Sheet I
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W. Houston G. Ertter (EDO-7344)
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C DO NOT use this form as a RECORD of approvals, concurrences, disposals, clearances, and similar actions Room No.Bldg.
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Prescrlbect bV OSA FPMR 81 CFR) 101-lle206
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g ENCLOSURE 1
question 1:
Response
question 2:
Response
question 3:
What is your definition of significant, and how was it arrived at?
The NRC currently evaluates the radiological impact to both a hypothetical maximally exposed individual as'well as the population'within 80 km of the site.
Annual, dose commitments as well as risk estimators are given in the "Draft Environmental Statement related to the operation of Susquehanna Steam Elec-tric Station, Units I and 2" (NUREG-0564, pp. 4-12 to 4-28).
The radiological impacts from radioactive effluents from Susquehanna Units 1 and 2 are given in Enclosure, A.
The lifetime exposure from 'reactor releases
'over a 30 year period represents about a
6$ increase over background radiation to the maximum individual, and about a 0.01$ increase to the average person within 80 km of the site.
These lifetime risks correspond.to, about.0.016$
and about 2.7 x 10 increase in the natural iricidence of cancer for the maximum individual and the average individual, respec-tively.
The potential health impacts from these releases are so small that they could not be measured in a population of about one million persons.
Based on comparisons such as those in the attached table, we conclude that the potential health impacts from these releases present an insignificant impact on the public's health and safety.
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occurrences?
The Rasmussen Report has already been proven to be incorrect.
The anticipated occurrences to which you refer are based on operational occurrences and not accident considerations.
The Rasmussen Report is not used to calculate the impacts from operational occurrences.
Furthermore, the Rasmussen report has not been proven to be incorrect, but as a result of the Lewis Committee report, it has been suggested that the numerical results may have a wider range of, uncer-tainty than as suggested by the Rasmussen report.
How do you define "normal" ?
Normal operational levels of radiation emission are quite different and separate from normal background levels of radiation already existing in the environment.
Also, because of bomb testing and power plants, the "normal" levels of background radiation have increased over the past 30 years-
Response
The NRC regulations (10 CFR Part 50) require that light-water-cooled nuclear power stations be designeJ and..
operated in a.manner which will limit radiation exposures to any individuals in the'general population.to a small fraction of the ge'neral radiation standards during normal operations.
An extensive rulemaking proceeding (Docket No.
RH-2) was conducted over a several year'eriod (December 1970 to Hay 1975) to quantify the numerical guides for keeping levels of radioactive material in the effluents of light-water-cooled nuclear power reac-tors as low as is reasonably achievable during normal-"
operating conditions (Appendix I of 10 CFR Part 50).
The normal operating'onditions were characterized by the NRC staff for these reactors during the course of the rulemaking based primarily upon data obtained~
during operations.
Considerably more data has been obtai ned since 1975, The procedures used by staff in characterizing the =-radioactive material in the effluents're gi ven in Regulatory Guide 1.112, "Calculation'f '
'eleases of Radioactive Haterial in Gaseous and Liquid=.-,
Effluents from Light-Water-Cooled Power Reactors;"
This guide is used in conjunction with information ~
in NUREG-0016 and NUREG-0017 for boiling water reactors and pressurized water reactors, respectively (copies may be obtained from the NRC).
p At current levels of contribution of radi oacti vity to the environment from the entire nuclear fuel cycle, there may be an annual increase of 0.003$ in the radiation background (considering 70 nuclear power plants in operation) in the entire United States..
If all these plants had operated for.he past 30 years, it would still represent only a 0.1$ increase-in radi at ion background, an amount that is far far less thap the variation in going from sea level to =--. "-"-
the Denver, Colorado altitude, or in moving from.a....-....
wood house to a brick or concrete house.
guestion 4:
What individuals, by name, set these "normal" levels7
Response
The "normal" levels of radiation from radi oactive releases from nuclear reactors that you refer to are contained in Title 10 Code of Federal Regulations Part 50 Appendix I (10 CFR 50 App. I).
The annual dose design objectives set in 10 CFR $ 0 App. I were set in a rulemaking hearing by the Comoission.
Although many people participated in the rulemaking hearing
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guestions 5:
Response
guestion 6:
Response
(see pp. 1-6 of Enclosure B), Commissioners
- Anders, Rowden, Mason, Gilinsky and Kennedy made the final decision to.adopt, the limits set in 10 CFR 50 App. I.
A copy of the Commission opinion in the matter of--
10 CFR 50 App. I is attached for your. information (Enclosure B).
How much "normal" radiation will be expected to be released in Berwickf
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'he calculated releases of radioactive materials in.
liquid effluents are provided in Table 4.4 of NUREG-0564 and the calculated releases of radioactive materials in gaseous effluents are provided in Table 4.5.
These two calculated source terms represent annual releases per reactor from normal operation, including, anticipated operational occurrences, when averaged over the 30-year operating life of the plant.
These source terms were used to calculate exposures due to releases and are shown in Table 4.9 of HUREG-0564.
Dose estimates and lifetime risk estimates.
from these releases are given in our response to guestion l.
What are the NRC's recorded, documented levels of "gormal" radiation releases from the operating.-
plants in the United States2 The quantity of radioactive materials released from nuclear power plants in the year 1977 is contained in a document 'entitled "Radioactive Materials Released from Nuclear Power Plants - Annual Report 1977" (NUREG-0521).
HUREG-0521 contains a nuclide by nuclide summary of the radioactive effluents released from opeyating reactors in the year 1977, as-well as a categorical summary (i.e.
noble gases, I-131 and particulates, tritium, mixed fission and activation products) for earlier years.
Excerpts from HUREG-0521 are given in Enclosure C.
Population dose commitments for the year 1975 are given in Enclosure D.
Population dose commitments were calculated for the population between 2 and 80 km of each reactor site.
The average individual dose commitment to that population (about 0.02 mrem) represents about a 0.02$ annual increase over back-ground radiation.
The dose to the hypothetical maximum individual would be higher.
ENCLOSURE 2 r
BACKGROUND INFORMATION ON ASSUMPTION Of LINEAR NON-THRESHOLD HEALTH EfFECTS MODEL For more than four decades,.radiation has been the most throroughly studied carcinogen.
Numerous major biological research programs have been completed and others are in progress.
These programs have been well documented and may be found in the open literature.
While the United States has been the fore-runner in radiation research, many, other countries also have pursued similar programs and have contributed substantially to the knowledge.
While the relationship between ionizing radiation dose and biological effects among humans is not ~reciseI kno>vn for all levels of radiation, the principal uncertainty exists at very Iow dose levels where natural sources of radiation (cosmic and terrestrial) and the variations in these sources are comparable to the doses being evaluated.'he-most important biological effects from radiation are somatic diseases (principally cancer) and hereditary diseases.
Both of these are identical to those which occur..normally among humans,,from other causes.
It ~
is this last point in combination with other confounding factors, e.g.,
magni-tude and variations (1) in normal-incidence of diseases, (2) in doses from natural radiation sources-,
(3) in radiation doses from man-made sources other than the nuclear industry, and (4) in exposures to other (non-nuclear) carci-
- nogens, which is responsible for-much of the uncertainty in the dose-risk-relationship at low dose Ievels.-.-',
Data from studies of animals and humans are reviewed continuously by teams of scientific experts which evaluate radiological information and provide recommendations.
In the United States,'he principal expertise in radio-logical matters lies with the National. Council on Radiological Protection
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(NCRP) and the National Acadeop of Science/National Research Council (NAS/
NRC).
Federal agencies also retain expertise in the radiologic disciplines in order to fulfilltheir responsibilities,
- however, these agencies rely heavily on recommendations of these advisory organizations.
Other countries have national advisory organizations similar to those of the United States;
- Further, there are cooperative international organizations which evaluate data from all sources and present recommendations and conclusions, for
- example, the United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR) and,the International Commission on Radiological Protection (ICRP).
In summary notvonly.have the radiological data been ascertained by the world's outstanding biologists and epidemiologists, but the data have been evaluated independently by their peers.
In lieu of precise kno'(ledge of this relationship, a linear non-threshold extrapolation from high radiation levels to the lower levels is assumed for radiation protection purposes.
This means that it is assumed that any dose of radiation, no matter how Iow, may be harmful.
Several federal
- agencies, principally the Environmental Protection Agency, Occupational Safety and Health Administration and the Nuclear Regulatory Coranission, have responsibilities for regulating exposures to radiation or radioactive material.
In all cases, the staffs of these agencies are well aware of the potential health effects and have expertise in bioIogy and the other disciplines needed either within the staff or available to them.
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