ML17139A433
| ML17139A433 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 09/24/1981 |
| From: | Tedesco R Office of Nuclear Reactor Regulation |
| To: | Clint Jones PENNSYLVANIA, COMMONWEALTH OF |
| References | |
| NUDOCS 8110080320 | |
| Download: ML17139A433 (12) | |
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I V-SEP 24 ice Docket Nos. 50-387 and 50-388 Hr. Clifford L. Jones Commonwealth of Pennsylvania Department of Environmental Resources Post Office Box 2063 Harrisburg, Pennsylvania 17120
Dear Hr. Jones:
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Subject:
NRC Staff Responses to Coments on Susquehanna DES Your Hay 27, 1981 letter to the U.S. Nuclear Regulatory Commission provided your coments on Supplement 2 to the Susquehanna Draft Environmental State-ment.
Unfortunately the time required to process your responses through the; Pennsylvania State Clearinghouse resulted in the late receipt of your comments."-
The NRC staff was therefore unable to respond to your comments in the Final Environmental Statement which was published in June 1981.
Nevertheless, the NRC staff has reviewed your comments and provides the enclosed staff responses for your information.
I Sincerely,
Enclosure:
NRC Staff Responses
@pe atgncd Sg
+beet I Tedesoo Robert L. Tedesco.
Assistant Director for Licen'sing Division of Licensing
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Docket Nos.
50-387/388 P%
'p Clifford L. Jones Conmonwealth of Pennsylvania Department of Environmental Resources P. 0. Box 2063 Har risburg, Pennsyl vania 17120 ub$ ect:
NRC Staff Responses'.
To Coments On Susquehanna DES ear Nr. Jones:
yg~ Q~iIa41JJ CelhJSSLOII Your flay 27, 1981 letter to the %NtC provided your coments on Supplement 2 to the Susquehanna Draft Environmental Statement.
Unfortunately the time required to process your responses through the Pennsylvania State 4feaHnghouse resulted in the late receipt of your comments.
The NRC staff was therefore unable to respond to your comIments in the Final'Environmental Statement which was published in June 1981.
Never'theless, the NRC staff has reviewed your comments and provides the enclosed staff responses for your
= information.
Sincer ely,
Enclosure:
PEC'~ ksponscs Distribution:
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Rober t L. Tedesco, Assistant Director W Division of Licensing OFFICE/
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Vice President'.
'ngineering and Construction Pennsylvania Power 5 Light Canpany Al 1 entown, Pennsylvania 18101 Jay Silberg, Esquire
Shaw, Pittman, Potts 5 Trowbridge 1800 M Street, N.
W.
Washington, D. C. 20036 Edward M. Nagel, Esquire General Counsel and Secretary Pennsylvania Power 8 Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Hr. Willian E. Barberich
. Nuclear Licensing Group Supervisor Pennsylvania Power 8 Light Company 2 North Ninth Street Allentown, Pennsyl vani a 18101 Mr. G.
Rhodes Resident Inspector P. 0.
Box 52 Shickshinny, Pennsyl vani a 18655 Gerald R. Schultz, Esquire Susquehanna Environmental Advocates P.
0.
Box 1560 Wilkes-Barre, Pennsylvania 18703 4
Mr. E. B. Poser Project Engineer Bechtel Power Corporation P. 0.
Box -3965 San Francisco, California 94119 Ms. Colleen Marsh P. 0.
Box 538A, RD 84 Mountain Top, Pennsylvania 18707 Mr. Thomas J. Halligan Correspondent The Citizens Against Nuclear Dangers P. 0.
Box 5
- Scranton, Pennsylvania 18501 Mr. J.
W. Millard Project Manager Mail Code 395 General Electric Company 175 Curtner Avenue San Jose, California 95125 Robert W. Adler, Esquire Office of Attorney General 505 Executive House P. 0.
Box 2357 Harrisburg, Pennsylvania 17120 Dr. Judith H. Johnsrud Co-Director Environmental Coalition on Nuclear Poser 433 Orlando Avenue State College, Pennsylvania 16801 Mr. Thomas, M. Gerusky, Director Bureau of Radiation Protection Resources Commonwealth of Pennsylvania P. 0.
Box 2063 Harrisburg, Pennsyl vania 17120.-
'"-"" 'RESPONSE m THE'-;COMMENTS; FRN::PSG=~...=..":..<Q~~~~"'-.-.';V,.~~="<'".
'pSC(1) 4 The more pessimistic assumptions for evaluation of design basis accidents are described in NUREG-0776, "Safety Evaluation Report re7ated to the operation of Susquehanna Steam Electric Station, Units 1
and 2," April 1981, Chapter 15.
C PSC(2)
Doses presented in Table 6. 1.4-1 are calculated realistically.
The realistic evaluation reflects the expectation that engineered safety and operating features designed to mitioate the consequences of postulated design basis accidents (DBAs) would function as intended.
Therefore, the quantities of iodines and noble gases assumed to be released to the con-tainment in the realistic evaluation of the DBAs are not the same as could be, released to the containment if severe fuel damage or melting occurred;;
PSG(3)
Please see response to the coiiment identified as Susq. Alliances (16).in page 6-59 of the FES.
PSC(4)
.=lease seethe text
'~n the 1=-st =are=.raph,in page 6-11 of the F.S.
PSC(5)
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The sta f's Judcmeni'hat the calculated results of the consequences are
- ore likely overestimates than underestimates is based upon the following considerations.
'a)
The release fractions of fission products, shown in Table 6.1.4-2, are believed to be conservatively higii for those raoionucl'ides that are dominant risk contributors.
This is due to the complexities of modell-ing more accurately
.natural plate-out and aerosol. agglomeration and settling tendencies within containment.
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(b) The meteorological dispersion model employed is believed to be con-servative.
(c) The staff's estimates of the effectiveness of protective actions, particularly evacuation
- times, are believed to be conservative.
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psc(6)
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RESPONSE TO THE ZON<NETSgRON P5C tCont -),"; ":=~~~"--
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Melt-through of the containment is a possible result of core-melt whether it is in a PWR or BWR.
See Section 2.2.1.6 in page I-17 of Appendix I of MASH-1400.
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Ground-water contamination by core melt-through is a possible scenario even in a
BWR although the quantity of radioactivity that would contaminate the ground-water is likely to be less in 'a BWR than in a PWR melt-through.
The staff has ignored this difference and considered the seeping of the BWR core-melt accident consequences via the liquid pathways by comparing with the consequence magnitudes in the LPGS using scaling factors obtained from differences in travel times, pathway usages and sizes of population involved as adequate.
~ I PSC(7)
The staff appreciates the comment on the manner of'resenting the results of complex risk calculations and will continue to strive to reduce con-fusion..
The societal risks of acute fatality and latent cancer fatality shown in Table 6.1.4-5 are the values integrated over all radial distances (besides over the.site population).
Their ratio is not expected to agree with the apparent ratio between Figures 6.1.4-7 and &:13.-8" which the comment seems to expect.
PSC t', B)..
The staff's conclusion is "that there are eo special or unique features about the Susquehanna site and env'irons.hat would warrant special or adoitional encineered safety features for the Susquehanna plant."
This is not the same as concluding that (Class g) accidents do not warranL, addi-
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tional study.
The fact of rulemaking proceedings in process or being contemplated i s incorporated indirectly in the text by reference to the Statement of !sterim Policy in the very first al acl ap l of this sec'tlon.
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Cosnmonwas Ith of Pennsylvania iVSRNGR'S OFFICE ICE Oi TI'.:" BUDGET P.O. BOX 1323. HARR(SBURG, PA. 17120 (717) 7674D46 783.3133 JUN 04
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PROZECT t Dea>> Applicant:
ta-e C cari"..=.-.o'se Sincerely,
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4 COMaiON'IVEAITIIOF; :PENNSYIVANIA~';~
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DEPARThfENT OF ENVIRONMENTAL'.RESOURCES
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Harrisburg,
'PA 37120' Hay 27, 1981
'll y
3ECT:
Review and Evaluation of PSCH tio.:
r Anne t:etchum, Supervisor Pennsylvania State Clearinghouse 5-81-04-004 Supplement to Draft Environmental Statement Related to Cperation of Susquehanna Steam Electric Sta-'ion, Luzerne County eI ~
'CLIFFORD L.
JONES
" Secretary of Envirqnm nt '1 Resources'he Department has reviewed, the subject, Draft Environmental Supplement.
[le would like to,offer the following comments.
(Section 6.1'.4.l)
.:The more pe ssimi'stic assumptions that are
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~sed for th= desicn basis accident analysis sh~"ld be exp,airled in more 4
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as.
m acr>I assessments are of the same magnitude as the source terms that a) e assu ed
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for Class 0 accidents, and therefore could not occur unless severe fuel
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da-;,:=oe or imelting had occurred.
For comparative
- purposes, Table
- 6. 1.4. 1 should inc1ude realisti'c
.hyroid doses and
.he calculated exposures using worst"cas assumptio s.
(Section
- 6. 1.4. 2) it should be stated that s igni!1cant changes have occurred in the.GE Bl!R design since the Peach Bottom design espectallJ'n the area of containment
- design, which should have lowered the overall probability of severe accidents.
These major design changes should be identified in summary fashion.
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A technical basis should be given for the statement that it is the staff's judgment that the calculated results of the consequences are.
more likely.overestimates than underestimates.
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- .(Sectioii 6.:.l.4.5)""-;Et,"do'es'"not'""appi'a'r",:tchaet.:aha'alt=br'ougli'-:.ac'cldent."
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Has considered to be' credible =scenario Vor;BMR's',in-tthe RSS'.-'-'- "Furthi rmoare'.,-;.~'-",~.-:,-.
the LPGS does not appeai to consider a
BMR des'ign".in'its"-assessmrent of~-',:-;"'. ~'",'.
"'"'-,'.I'and-based reactors
. Therefore,. additional'justification
.should be 'givenb Lor including this scenario. as part. of the assessment; and if included,'the'risk
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in terms of dose should be better quantified;.-..:.:.:
(Section 6.1.4.6)
The various methods by which risk is presented in both tabular and graphic form leads to confusion in interpreting the results.
For example, the ratio of acute fatalities to latent cancer fatalities in
('('I Table 8.1,4-3 does no't agree uith the'pparent" ratio betueen Figures 6.1.4-7 and 6.1.4-8.
It vrould be much more straightfonrard to show the average individual l isk versus distance from the reactor (including inside the ten-mile radius) 1e ither tabu'I ar or graphi c form for both acute and 1 atent cancer fatal ities
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with and without protective actions.
This same figure could then include the risk from other man-made and natural risks, including natural background radiation and background cancer risks, for comparative purposes.
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r It appears as if the risks from the realistic assessment of design basis accioents is less than the risk from the realistic assessments of Class 9 accidents, with or >rithout protective action. It is also apparent that.the. risk from Class 9 accidents is greater than the risk from normal
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operation..
Based on. this somewhat anomalous situation and coupled with the
.uncertaintjes which are attached to the assessmen't for Class 9 accidents, it would appear that further justification is necessary for the Staff to conclude that these accidents do not warrant additional study to, determine whether public health and safety is adequately protected; It should be noted that various rule making proceedings are currently in progress which should better cvanti=p
.he risk flom th se severe accidents and li<ay in act lead to a
'=- ".-=-.-."- for a"'"it'.ona':
s:-.-.e"uard ec'.i-.-.ent to deer as this ris!;.
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