ML18018A585

Comments on Des (NUREG-0972) Re Plant Operation.Requesting Public Comments After Decision Supporting Issuance of OL Made Inappropriate

ML18018A585
Person / Time
Site:	Harris
Issue date:	07/01/1983
From:	Lotchin P AFFILIATION NOT ASSIGNED
To:	Office of Nuclear Reactor Regulation
References
RTR-NUREG-0972, RTR-NUREG-972 NUDOCS 8307060258
Download: ML18018A585 (8)

Text

REGULATO INFORMATION DISTRIBUTION TEM (RIDS)

ACCESSION NBR;8307060258 DOC ~ DATE: 83/07/01 NOTARIZED:

NO FACIL:50-000 Shearon Harris Nuclear Power Plantg Unit lg Carolina 50 401 Shearon Harris Nuclear Power Planti Unit 2i Carolina AUTH,NAME AUTHOR AFFILIATION LOTCHINiP, Affi 1 iation Unknown RECIP,NAME

'ECIPIENT AFFILIATION Division of Licqnsing

SUBJECT:

Comments on DES (NUREG 0972) re plant operation, Requesting public comments after decision supporting issuance of OL made inappropriate

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DISTRIBUTION CODER C0028 COPIES RECEIVEDRLTR i ENCL, SIZEt-TiTLE: Public Comment on Environmental Statement NOTES; DOCKET RECIPIENT IO COOK/NAME NRA LB3 BC 06 NL:

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RECIPIENT ID CODE/NAME NRR L83 LA KADAMBIeP COPIES LTTR ENCL INTERNAL6 ELD/HDS1 ARA/DE/AEAB NRA/DE/EHEB NRA/DSI/AE8 NRA/DSI/RA8 RGA2 20 19 17 NRR NORRIS' NRR/DE/EEB 16 NRR/DE/SAB i8 NRR/DS I/METB i5 0L4 EXTERNALS ACHS NA'l L LAB NSIC 21 05 6

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10B Bridle Run Chapel Hill~

> North Carolina Duly 1, 19B3 Nuclear Regulatory Commission Washington, Dm CD 20555 Att: Director~ Division of Licensing Docket No:

STN 50>>400 STN 50&01

Dear Sir or Pladam:

This letter is in response to the Draft Environmental Statement (NUREG-0972) relited to the operation of Shearon Harris Nuclear Power Plant, Units 1 and 2~ Carolina Power and Light Company, My responses are in the form of criticisms and questions,

1) I think it is inappropriate to ask the public for comments after the decision has been made to support issuing an operating license to the plant, "The action called for is the issuance of an operating license for Shearon Harris Plant, Units 1 and 2o" (page iii, signed by Dr, Prasad

Kadambi, NRC)

2) Throughout the document~

does estimates and effects of radiation exposure are given as ave~acus doses to ths population or a stats, region, atc, Is this a deliberate attempt by the NRC to camouflage the effects'?

Anyone who thinks about the situation understands that not everyone will receive equal doses of radiation+

By using averages, the true impact tends to be washed outi Is this the intention of the NRC'?

An example of this doublethink is on page 5-26 "The annual dose commitment is calculated to be the total dose that would be received over a 50-year period~ following the intake of radioactivity for 1 year under the conditions existing 20 years after the station begins operation,"

I understand why the power companies want to maintain this confusion; I don' understand the motivation for the NRC's=dPjng~fhism Cm

3) The graphs on pages 4-63 are set up to be unreadable by a lay persono Is this the intention of the NRC'? If all those who are potentially victims of radiation damage were trained mathematicians or physicists~

then it would be fair to put the information concerning their safety and welfare in these

terms, As it is, very ordinary people risk getting cancer or seeing their children die of leukemia, It is the worst kind of elitism, it seems to me ~ to toy with them in this way, People must, know the risers they face'y living within 20 or so miles of an operating plant, 'and the NRC is the government agency which has the mandate to be honest with themm People must know the risks in order to take responsibility for their own welfare; this is the essense of a democratic govern-mentm Because these figures are obscure, I will use the'stimates made by the NRC for the Sumner Plant when I talk to the press or to groups in the community, These estimates indicate.that Chapel Hill, which is 20 miles from the Shearon Harris Plant, faces the possibility of 50 to 500 early fatalities from a worst case accident, which, as we have seen from TNI, may be remote as a

meteor hitting the White Mouse or may be a one out of one chance~

Any statistician knows that probability calculations are nearly useless when an event/as rare as the ones we are considering+

Let's all be honest and say that what we are dealing wit/ when probability figures are set'down is an act of faithm Again, what is the payoff for the NRC in couching these figures in graphs that are virtually unreadable by ordinary people7 8307060258'83070i PDR ADOCK 05000400, D"

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4) What does the f'irst sentence in"'. the second paragraph on page S-26 mean7 I tried to diagram it and parse it in various ways, but it doesn'8 workm It sounds as though it may be important, 5)

On page 5-72, the document estimates that a release into the groundwatBr would take 6,7 years to reach surf'ace water and that in that time eggineering measures could be taken so that "radioactive contamination may be isolated near the source,c is there at ~resent ths engineering capahiMty to do this~'r are those of us who will be asked to use that surf'ace water supposed to take this as a promise that there will.be such a capabili.ty 6~ 7 years from now2 If'uch an engineering f'eat is possible now, why isn '

this metho d being used to keep dioxin and other toxins f'rom reaching the underground wat er suppU.es that are presently endangeredW 6)

On page 5>>82, there is a discussion of'he "uncertainties of'he probabilistic and risk assessment methodologies used in this analysis; in other words, there are many important f'acts that are both unknown and unknowable+

One example cited in the discussion is as f'ollows: "In the consequence calcula-tions~ uncertainties arise f'rom an over-simplif'ied analysis of the magnitude and timing of'he f'ission product release, from uncertainties in calculated energy release~

f'rom radionuclide transport f'rom the core to the receptor, from lack oi'recise dosimetry~

and f'rom statistical variations of'ealth Bffectsm ThBre may be a variation "well over a factor of'0~ but are not U.kely to be as large as a i'actor oi'00 "

This says to me that all the probability calculations in this report could be up to a hundred times less or-and this is ths greater worry a hundred times worse than calculated hara, Ply question is this:

how can the INC in good conscience recommend that tha plant~ or any plant, be licensed~ if'here are areas as important as the onBs listed in the quote above in which the uncertainties are endemic~

Dust the lastmentioned item, health ef'f'acts and the statistical variations in knowing just what damagB radiation does or has done, would seem to be critical enough to h"ld up licansingm What kind of'eople and what kind of'overnment would allow such a potentially dangerous (with such great "uncertainties") entity to be operated within such close proximity to a really sizeable population7 Again> I understand why the power companies are cavalier about the uncertainties, dismissing them as inconsequentialo I don't understand why the NRC is so eager to license the plant, or any plant~ with such large areas oi'oncern unknowabl.e+

The report admitb. that it is possible for a certain kind of'ccident << take out a sizeable portion of'-North Carolina and that there are many variables which are not calculable and then suggests that the plant be licensedo Please tell me how the two sides of'his equation fit together+ It is f'rightening to read that you are suggesting that the plant be licensed on one page and to read on another that "the state of'he art f'r quantitative evaluation of'he uncer-tainties in the probabilistic risk analysis such as the type presented here is not well developed,"

7) It is my understanding that there is no baseline data on background radiation for the area of'orth Carolina,.where I liveo Yet this report speaks of'n "average" f'r the state of'orth Ca'rolinao Could you tell me where I might find a report of the study of'ackground radiation f'r this state~

and would you send me the data which applies to the Chapel Hill-Durham area specif'ically7 8)

On page F-3 in which you are talking about the evacuation model~ the report states:

"For these people outside of'he evacuation zone and within 40 km (2S miles)~

a reasonable relocation time span of' hours has been assumed~

during which Bach person is assumed to receive additional exposure to the ground contami,nation," It is my understanding that people outside the 10-mile zone

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will have no emergency warning sirens, no evacuation

planning, no in>>place monitoring capability, no training in sheltering, no potassium iodidee Nay I assume from this atatement about "relocation" within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (which is a f'ormidabls task even without the huge medical and university complex Chapel Hill has within its bounds) implies that we will be given these protective measures, Please clarif'y your meaning here, To say that we would be "relocated" without the things listed above is an empty statemento l

I am writing, this response because it makes me feel that I am doing the little bit I can do to counter the madness of'eing asked to live twenty miles from something that could exterminate me and everything I love at worst or give a portion of'ur number cancer, at the, least~

I have come to believe that those of'ou in the bureaucracy who are and have been planning this madness have Por whatever reason closed your minds to any concerns held by ordinary people, I

have an awful suspicion that you get letters like mind and have a good laugh~

dismissing them as misguided, subversive~

or whatever+

I hate being so cynical, but my three and a half years of'nvolvement with the nuclear industry and the NRC (my own involvement being solely as a private citizen) has given me little assurance that ths welf'are and saf'ety of'eople figure into the conclusions in any real way, Someone made a big mistake when CPAL was allowed to site the plant in the high-density area it is in~ and now the rest of'ou are engaged in a multi-bilU.on dollar cover up to save the initial investment and the rest of us don'4 coCrAto What real diff'erence does it make if' couple of children or so die of'eukemia because of'he neighborhood nuclear plantg That is, after all~ an "acceptable rate of'oss,"

I appreciate your hearing my concerns Sincerely~

(Dr )

hyllis Lotchin

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