ML18026A356
| ML18026A356 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 05/14/1981 |
| From: | Heinemann J FEDERAL ENERGY REGULATORY COMMISSION |
| To: | Youngblood B Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8105220265 | |
| Download: ML18026A356 (42) | |
Text
FEDERAL ENERGY REGULATORY COMMISSION WASHINGTON 20426 IH IlKPLY REFER TO<
May 14, 1981 Mr,. B. J. Youngblood Chief, Licensing Branch No. 1 Division of Licensing U.S. Nuclear Regulatory Comm.
Washington, D. C. 20555
Dear Mr. Youngblood:
I am replying to your request of May 8, 1981 to the Federal Energy Regulatory Commission for comments on the Draft Environmental epact Statement on the E."-'c Fermi Atomic Power Plant, Unit No. 2. This Draft EXS has been reviewed by appro-priate FERC staff components upon whose evaluation this response is based.
This staff concentrates its review of other agencies'n-t vironmental impact statements basically on those areas of the electric power, natural gas, and oil pipeline industries for which the Commission has jurisdiction by law, or where staff has special expertise in evaluating environmental impacts in-voled with the proposed action. Zt does not appear that there would be any significant impacts in these areas of concern nor.
serious conflicts with this agency's responsibilities should this action be undertaken.
Thank you for the opportunity to review this statement.
I Sincerely, ack M-. Heinemann Advisor. on Environmental Quality 6-39
ttlt Os United States Department of,the Interior OFFICE OF THE SECRETARY WASHINGTON, D.C. 20240 ER 81/573 MAY 18 1981 Mr. B. J. Youngblood, Chief Licensing Branch No. 1 Division of Licensing Nuclear Regulatory Commission Washington, D.C. 20555
Dear Mr. Youngblood:
Thank you for your letter of March 31, 1981, which transmitted copies of Supplement No. 2 to the draft environmental statement for the Susquehanna Steam Electric Station, Units 1 and 2, Luzerne County, Pennsylvania. We have the following comments.
h The final supplement should assess potential impacts to fish and wildlife resources from a nuclear accident. The impacts such radioactive releases to water or the atmosphere would have on aquatic and terrestrial ecosystems should be assessed. In particular, the effect on fish and wildlife growth and repro-duction from radioactive materials likely to accumulate or magnify in the food chain during and after an acciden~t should be described. The short>> and long-term effects on the human use of fish and wildlife resources, especially in downstream reaches of the Susquehanna River and Chesapeake Bay, which otherwise would be consumed if 'not exposed or'ontaminated by accidentally released radioactive materials should be presented.
Our Bureau of Mines Mineral Industry Location System (MILS) shows that an active sand and gravel pit and processing plant is located ZIOlP) within the 3-mile radius of the low population zone (LPZ) as defined on page 6-8 of the supplement. This operation should be mentioned in section 6.1.3.2, Site Features, of the supplement. An active nineral producer witlhit the LPZ would include a work farce that +g7(S) requires the "appropriate and effective measures...in the event of a serious accident,",referred to in the f'irst paragraph on page 6-8.
'f We hope these comments will be helpful to you in the preparation a final statement.
inq 1 CKClL S. HOFF "IN Special Assistant to
-~ ~ istan% SECRETARY 6-40
-DOI (1)
Only localized impacts on terrestrial ecosystems from atmospheric releases of radionuclides in serious reactor accidents are likely to occur. Such local impacts (over areas of a few square miles or less) would not significantly affect the ecological stability of widely distributed species, since normal mortality is relatively high in most species. Impacts on aquatic or terrestrial ecosystems from the releases to the ground water would be very small because of long travel times of the radionuclides before any contamination of the surface waters would occur.
-DOI(2)
The discussion of Site Features in the DES is intended to provide a general overview and how the site complies with. the NRC's siting regulation, 10 CFR Part 100. The staff's Safety Evaluation Report (NUREG-0776) did note the existence of two sand and gravel processing facilities about 2.5 miles
~ southwest of the Susquehanna plant, and indicated that no,explosives were
~used or stored there. Section 6.1.3.2 of the FES has been revised to reflect this.
-DOI (3)
New NRC'emergency planning regulations 10CFR50 and Appendix E thereto require emergency plans and the ability .to take protective action for a plume exposure pathway Emer gency Planning Zone (EPZ) of about 10 miles (NUREG-0654 provides further guidance). There, is no requirement for spe-cifically addressing industry or institutions in the LPZ. Susquehanna is pr ocurring and installing a prompt alerting system with about 105 'sirens to warn the public within the 10 mile EPZ within about 15 minutes of a decision to war n the public. This system should be capable of warning the mining operation referenced in the comment. Later, after installation of the. Siren Systems, FEMA (Federal. Emergency Management Agency) will conduct surveys to determine the effectiveness of the Warning System as well as the ability to take offsite protective actions.
6-41
tqggl S.d pI UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
~C dqqOX6+
REGION III 6l'H AND WALNUT STREETS PHILADELPHIA. PEiViVSYLVANIA 19106 MAY 28 1987 Hr. B. J. Youngblood, Chief Licensing Branch No. 1 Division of Licensing 116'6Aa ggaurarC i 3 ION U. S. Nuclear Regulatory Commission gOAAJei I eeg Washington, D. C. 20555
Dear Mr. Youngblood:
We have completed our review of the Supplement to the Draft Environmental Impact Statement related to the operation of the Susquehanna Steam Electric Station Units 1 and 2. We offer the following comments for your consideration.
The Commission is to be commended for its decision to prepare this Supplement discussing the environmental and societal impacts of a core melt down accident.
EPA has emphasized the need to review an evaluation of the environmental impacts resulting from different LWR accident scenarios including Class 9 accidents.
The assessment of environmental impacts relating to severe accidents at the plant employs methods originally developed in the Reactor 'Safety Study (WASH-400). These two studies will be the basis for similar environmental assess-ments of other nuclear power plant's so that we recommend that NRC refer to EPA's original technical comments on these studies. The comments are included in the publication "Reactor Safety Study (WASH-1400): A Review of the Final Report" and a letter from EPA's Office of Federal Activities to NRC dated February 8, 1977.
The Table 6.1.4-4 (p. 6-26) should correspond on a one-to-one basis with the accident sequence or sequence groups og Table 6.1.4-2 (p. 6-23). The notations /PA (~)
relating to this Table (6.1.4-2) and described in Appendix 8 needs clarification.
The uninitiated reading this, we believe would be very confused.
The discussion of impacts of infrequent accidents and limiting faults, in both the original DES and the Supplement, addresses probabilities of occurrence qualitatively. In the discussion, however, of the more severe core melt acci-dents, the probabilities of occurrence are quantified (Table 6.1.4-2). For uniformity in the presentation of all environmental risks, the probabilities
/Pit of occurrence of infrequent accidents and limiting faults Design Basis Accidents should be provided.
It is not clear whether the risks listed in Table 6.1.4-3, Annual. ~Ayers e Values of Environmental Risks Due to Accidents, include those fiom infrequent accidents 6-42
and limiting faults (Table 6.1.4-1), postulated accidents (Table 6.2 of the original Draft Environmental Impact Statement)., and accidents leading to thd sequence groups listed in Table 6.1.4-2. The Final Environmental Impact State-ment should include all risks from moderate frequency accidents, infrequent accidents, limiting faults and severe core melt accidents. The risk of the infreguent accidents, and limit1ng faults is "fudged to be extremely small" FPF (
but should be fully presented and not overshadowed by the risks from core melt
)
accidents. The risks from the more probable yet lower consequence accidents may indeed be significant to the individual risk and should be listed. It would also be informative to extend Figures 6.1.4-3 and 6.1.4-5 to include higher probability accidents.
It would also be helpful to develop a summary table-of the annual average value of the environmental risks from operation of all the reactors at the Susqueme hanna site. The risks should include those from nozmal operations, modetate frequency accidents, infrequent accidents, limiting faults and severe cord g)f (Q) melt accidents; societal and individual risks should also be addressed.
The Three defile Island-2 accident demonstrated a factor that should be address4dl The cost of reactor building decontamination and the replacement power economics have proved to be very sizeable items. These factors are significant and g<j} P important to the benefit-cost analysis. These facts underscore the need td , ~l develop standard methods for estimating the contribution of these costs to economic risks. Impact Statements or Supplements should include these economics in their benefit-cost balance.'e would classify this document in EPA's Reporting Category ER-2. This means we have reservations concerning the manner in which the accidents are treated and we also believe s
additional clarification is required.
We'hank you for the opportunity to review the document and await the issuance of the final.
Sincerely yours, izP ohn R. Pomponio Chief
=
EIS & Wetlands Review Section 6-43
-EPA(1)
Six (6) tables could have been provided to show the impact contributions of each of the six accident sequences or sequence groups. It is the staff's judgement,. however, that the summary table, reflecting the. sums of contr ibutions from all of the sequences and sequence groups, provides a better overview, while giving sufficient detail to support the staff's conclusions.
Notations. used in the Table 6. 1.4-2 and Appendix H are the same as used in HASH-1400. .A copy of the page 82 of .WASH-1400 Main Report which provides the key to BWR accident sequence symbols is now provided as on page H-4.
-EPA(2)
Accidents bounded by the envelope of the design basis accidents are not sig-nificant contributors to environmental risk, and therefore have not been subjected to the same kind of probabilistic analysis.
-EPA(3)
Table 6.1.4-5 contains annual average values of environmental risks calculated for the accident sequences or sequence groups shown .in Table 6.1.4-2. Accidents falling within the design basis envelope are negligible contribuiors to either individual or societal risk. The risk estimates would not noticeably change even if the precisely calculated contributions from the accidents within the design basis accidents envelope would be added to these values..It may be concluded, therefore, that the Table 6.1.4-5 presents the-total annual average values of environmental risks from the entire spectrum of reactor accidents.
-EPA(4)
The risk from normal operation has been analysed for all (i.e. two) reactors at the Susquehanna site. (See chapter 4 of the FES) Tfie accident risks have been calculated for one reactor to facilitate easy comparison with other sites and facilities. To obtain an estimate of the accident risk from two reactors, the reported risk values should be doubled.
-EPA(5)
See Section 6.1.4.6, Risk Considerations.
6-44
.p,W Ilf0y
~o UNITED STATES Op NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS WASHINGTON, D. C. 20555
+>>*++ May 13, 1981 MEMORANDUM FOR: Mr. Richard Stark, Project Manager Susquehanna Steam Electric Station, Units 1 and 2 FROM: Garry. G. Young Staff Engineer PJ ~ f
SUBJECT:
NUREG-0564, SUPPLEMENT NO. 2, "SUPPLEMENT TO DRAFT ENVIRONMENTAL STATEMENT RELATED TO THE OPERATION OF SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2" In preparation for the ACRS Subcommittee Meeting on Susquehanna, cur-rently scheduled for July 23 and 24, 1981, Dr. Kerr has requested that the NRC Staff b'e prepared to respond to the attached comments, questions and suggestions concerning the Draft Environmental Statement, Supplement No. 2, for Susquehanna (NUREG-0564). These comments were forwarded to Dr. Kerr by another ACRS Member based on his personal review of the environmental statement. If you have any questions concerning this re-quest, please contact me.
Attachment:
Comments on NUREG-0564, Supplement No. 2 cc: W. Kerr, ACRS C. Mark, ACRS D. Moeller, ACRS R. Fraley, ACRS'.
Libarkin, ACRS J. McKinley, ACRS R. Tedesco, NRR B. Youngblood, NRR 6-45
COMMENTS ON NUREG-0564, SUPPLEMENT NO. 2 (1) Subsection 6.1.2 (4th Para.)
"The same population receives each year from natural background radia-
'tfnn about 240,000 person-rem and approximately a half-million can-cers are expected ...."
The two statements should be separated since, as put, it could be taken to imply about 2 cancers per person-rem. The person-rem datum should be moved up to where it compares directly with the
'pstimated person-rem from the accident; and the cancer estimates (accident-induced vs. normal incidence) should similarly be brought together for a direct comparison.
(2) Subqection 6.1.4.3 (Top Page 6-14)
Mqch more is needed concerning the evacuation model:
a) Is a "down wind direction" what is actually used?, or is it radial?
b) Is this really the most effective tactic? Or is it merely a limitation of the CRAG code? Since people out to a distance of about 7 miles on the axis of the sector are closer to the edge of the sector than they are to the 10-mile radial point, it might seem preferable for them to proceed cross-wind. Sup- it posing this restriction to be a limitation of the code, why is deemed useful to publish the results?
(3) Is it assumed (as the text would seem to suggest) that the evacuees wou)d come to a halt at the 10-mile point? If so, why make this assumption?
(4) Subsection 6.1.4.5 (3rd Para. P. 6-16)
Tge discussion of "travel times" could rather easily be clarified by stating:
p) That the travel time for water has been estimated to be 9.2 years.
b) Tgat the travel time for materials transported by the water is ag least this long; and usually considerably longer, becau'se of physico-chemical interactions between the water, the soil, and the material considered.
6-46
c) That the degree of retardation in the motion of some particular material is strongly dependent on the chemical properties of the material, the physical and chemical properties of the rock or soil through which it is moving, and the chemical properties of the ground water; and, as a consequence, that the arrival of any such transported material though it may begin at 9.2 years is stretched out over a considerable period (and in some cases over an enormously extended period) after the first arrival of the groundwater itself.
d) (in the following paragraph)
The statement that, "We therefore conclude that the contribution--
is smaller ." could much better be replaced by a statement to the effect that the contribution is trivial.
- 5) Subsection 6.1.5 (final Paragraph, P 6-21)
Since there is no indication on the part of the NRC Staff to allow any credit for "additional" engineered safety features, this is a vacuous statement.
- 6) Subsection Table 6.1.4-5 The only "protection action" described in the body of the text is that of dashing off "downwind" to the 10-mile marker, and piling up there.
It is true that in Subsection 6.1.4.6 it is said that "early evacuation of the population within 10 miles and other protective actions" are con-sidered. None of this prepares one to imagine what (if any) protective actions may have been taken into account at distances greater than 50 miles.
However, this Table claims that by "protective action" the person-rem beyond 50 miles is reduced from 600 to 290. What. does the Table actually show?
- 7) Subsection Figure 6.1.4-2 The curve for m 300 rem to the thyroid shows, for example, 200,000 affected people, with a probability of 10-8 per year. -Does this include the ingestion estimates of WASH-1400, whereby everyone drinks 0:7 liters per day of milk from cows on contaminated pasturel If If it does it does not, OK.
(and this term is significant), then the curve is nonsense; since there is nothing more straightforward and certain than that such milk would be impounded as it was at Windscale, without any "benefits" from Class 9 and emergency procedures r ulemakings.
6-.47
ACRS(1)
In the FES, "pri'mari ly from causes other than radiation". has been added at the end of the sentence for clarification.
ACRS(2)
See Appendix I in the FES for more information on the evacuation model.
CRAC code the code.
treats the wind directions as radial Evacuation model assumed movement only - it is a limitation 'f of evacuees in the downwind direction only for assessment of radiation exposure. This 'is a limitation of the evacuation model in CRAC. Actual movement of the people will involve intelligent use of the available road net-work to avoid the radioactive plume.
ACRS(3) h The particular sentence in the. text. in DES was inadvertently mi.s-structured.
The Sections 6.1.4.2 and 6.1.4.3 have been re-written for the FES.
ACRS(5)
The final paragraph has been revised in the FES.
ACRS(6)
Please see the revised text in Section 6.1.4.2 ACRS(7)
Please see the foot-note in Section 6.1.4.3 6-48
Susquehanna Alliance P 0 Box 249 Levrisburg, PA 178'57 Hay 23, 1981 Office of Nuclear Reactor Regulation U.S. Nuclear regulatory C'om=ission
'Sashington, D.C. 20555 Att: Director, Division of Licensing Sir/Madam:
Since so much time has elapsed from the date of the original Jra~
>~a <
it would be in the highest public interest to issue a 2nd full incorporating all previous, comments and NBC responses.
This 2nd full draft would provide the vommission with further inform-
~E ation with which to oase its decision regarding'the environmental impacts of operating the Susquehanna Steam iZectric Station.
Sincerely, X cc dichael ~. 'Lolesev'ch for the Susquehanna Alliance 6-49
COlZtK'.ITS 0?1'.AFT SUP~~Z';AN TO DR'.FT 8 S FOP. TPZ SUSQU"'H" 2'Ik STZA34
" iZCTRZC STAT10N, iVURZG-0564, SUPPL"'h AT iVO. 2 I) '2he curcose of this succlement vas to assess the acditional envir- '
onmental risks due to class nine accidents. These acc'dents previously have been considered to have minimal environmental ei'fects because their probabil'ties have been thought to be low. However, since the accidert at Three i'ile Island, the conclusion of this supplement has not changed from the conclusion of the original'Draft, EIS, of June 1979. Supplement: "These impacts could. be severe, but the li'~elihood of their occurrence is judged. to be small." Page 6-2 of the, original cdraft states: >>Their consequences could be severe. However, the probability of their occurrence is judged so small that their environ-mental rise is extremely low.>> Zt is obvious that this supplement does not achieve its purpose. Therefore, the Susauehanna Alliance requests that another supplement be made available that adeouately addresses the additional environmental risks due to class nine accidents.
,2) Th's supplement does not address the long-term, man-made, and natural surface contamination rom radionucleides. According to one source the delayed cancers and genetic defects due to r d'ion from ground and buildings contamin ted with long-lived radioactive cesium could oe the most severe consequence from a major release. J. Beyea, Some Long-'l'erm Cense 'uences of':". uothetical Ma or 'Eeleases ( oZ nadfoactivit to the At os"c,.here f'rom three Voile Island, Pre~si ent's Wouncf on Environm,ntal ~ualit , Eentemher, ~1979 3) will To always receive
-ssume that downwind recipients of radioactive less dosage than those closer to the pl nt (source of f llout radionucleides) is false. (Section 6 .1.2) The plume does not always disperse more radionucleides closer and less further away due to certain meteorlogical conditions, i.e. ground base inversion. Also, the dosi-meter readings 9 miles northeast of T!LE, near Harrisburg, we e higher than were the readings closer to the plant.
- 4) The supplement relies too much on sheltering and cuation measures to help mitigate the effects on the local population.ev this the poten ial for for the sequences of an accident which c n ignores take pl ce in a very short time.(6.1.1.3) Por example, anticipated iransients without SCP. UJ which, according to Qr. Richard Ylebb can breach the reactor vessel within 6 seconds.
- 5) On page 6-5, section 6.1.2 the supplement st=tes, "This experience base is not large enough to p rmit a reliable quantitative statistical
.in erence.>> 'fo large-scale-commercial reactor has yet gone through a cor pl=te life cycle. Therefore, to state that, >>...signi icant environmental impacts due to accidents are very unlikely to occur over time periods of' few decades.", is an inaccurate conclusion.
- 6) To state that, >>...a few million curies of'enon-13'5,..." were that at least z~~ ~
released, at i'hX implies a lesser severity when the NHC has s ated.
~ curies were released..
e 6-50
(Page' SUPPIZ~lPZ COKrSNTS CO!iTIPUED
- 7) The Unit
~
2 reactor at TVI was very young. The fuel was only in ervice (fissioning) for three
~
months. ~ Had an ccident of this severity occured with'an'lder fuel assembly, then the inventory of .ne fission products availaole for release to the environment would nave oeen
'much greater.
- 8) There are many assumptions based on the eventh, data, and results on the accident at TMI. however, there are zany uncertainties in the analysis, of the accident itself. Ylhile the supplement recognizes that t}.e numbers used for population exposures are estimates, not discuss the uncertainties within those estimates.(6.1.2) it does "It has been estimated that..." For example, the monitors located on the stack vents were pegged off scale,'and many of the off-'site dosimeters were not oro'ught into service until 3 days after the accident when most of the radionucleides had already escaped.
- 9) The psychological impacts of the population surrounding the plant for at least a 75-mile radius must also be considered.
that the psychological effects of the people surrounding T~Z and of It is obvious central Pennsylvania ivere profound and continue today.
lOi The supplezent assumes that the owners of the Susquehan.".a Plant will have control of the water from the river by restricting its use during and after an accident. (6.1.4e5) thereoy claiming that the consequences would be more economic and social, and, not adi'ological.
t The supplement does not address the use of water from tne river by:
the borough of'anv'ie, the city of Sunbury and other downstream commun ties who withdraw their drinking water from the river, farmers that use water from the river for irrigation and other ag icultu al related activities (and especially Amish farmers who might not oe aware of an accident miles d,omnstream), industries that are 1'cated on tne river that also use its water i.e. }ierck Co. in manville, and unalerted people who may be fishing the river at the time of the accident. The supplement should also address he uptake of radionucleides into the aquatic food chain.
ll) The sta ement that arrangements have al.eady been made to c"ntrol highway traffic (6.1.3.2) seen premature since the .emergency Prepared-ness Plans for Susquehanna are in an advanced. but not fully completed stage.
- 12) The supplement recognizes the substantial unce tainties calculated by the Heactor S fety. Study. Forever, these uncertainties are not reflected in the tables where firm numbers are used. These taoles should-.use ranges of numbers to reflect .hese uncertainties. Also, the range of accidents do not a~pear to have been adjusted to reflect the accident at ~J.'}K. (6.1..<.7)
- 13) The calculated, estimated, economic risk per year,(p.6-19) reflects an inconsistency in the use of the Reactor Safety Study. In taking the example of an average aecontamination cost of one billion dollars, the supplement assumes We-probability of 2.4 chances of this occuring in 100,000 reactor years. "'hus yielding an estimated economic cost of 6-51
Page )
'SUPP L:"MENT COsiBI:"NTS COilTXMH)
,.24,000 doll rs per year. However, on page 6-20, section 6.1.4.7, it is implied that the reactor safety study predicted the probability of a TUI-type accident as greater than one chance in 400 reactor y ars. Since this accident has an stimated clean-up cost of at least one billion dollars, then the'economic risk could be calculated that this figure is somewhat la ger .than 24,000 Collars.
- 14) An obvious shortcoming of the accident at T.'G was that there'was no plan of recovery-either with" the facility itself or the off-site pr'esent they are developing the strategy and p ans f'r the recoveryAtof'he consequences.
of that accident along with its environmental impact.
pub'ic in mind, this should have Geen'prepared 7iith the safety before the accident had occurred. Ther fore, a plan of recovery and.
its environmental impact should be included. in the analysis of an accident.
ination ~~
- 15) The economic risk associated with protective action and decontam-be compared with the property damage costs assoc'ted with alternative energy technologies especially anthracite coal.
Anthracite does not have the same amount of sulfur compounds that most other coals have and. would not lead to a substantial amount of acid rain as would the use of bituminous. Also, the incre sed use of anthracite can only lead to improved environmental conditions in that area. Since much of the area is already impacted then more mining would alleviate such problems found in that a ea such as:
acid mine drainage, abandoned mines. and spoils, a distressed economy, and the elimination of under~~ound mine fires, ope: sha-xs and. pits, and other dangerous conditions. This would" be possible oecause al" new/
recent mining would meet stringent environmental laws and guidel'nes that were not in effect years ago when most of'he damage .was done.
Page 6-18,(sect. 6.1.4.6) 16'iFigr are there no thyroid doses included on table '6.1.4-.1'?
- 17) accident seouence or sequence groups should be expressed in terms rather than symbols or letters. (table 6.1.4-2)
- 18) Probability should be expressed as a range in.table 6.1.4-2.
- 19) Other tables should include sum totals of land/surface accumula-tions of radionucleides based on probability and. economics of decon-tamination.(table 6.1.4-4)
- 20) Evacuation item can also be considered probabilistically and the, health effects should be more properly treated using site specific "
data. Considering the range of susceptibility to the health effects of radiation and other factors would be helpful to place on the figures the background, radiation and other data from TM>> . (, figures 6.1.4-1, -2, -5, -4, -5)
- 21) The consequences of the accident't THZ should a"so be included in figure 6.1.4-6.
6-52
4 Page 4 SUPP'.'(Za T COlsBu NTS C"'i~TIHUE3
- 22) The maps are of the poo est'uality and should be improved. so that they could be read, more clearly. (figures '6.1.4-7 and. 6.1.4-8)
- 23) Add a map or 'maps that would show the isopleths of costs of mitigation.
- 24) The speed of groundwater movement seems to bg highly underestim ted, especially in the local glacial material, and. easpecially und.er saturated, ground conditions.(6.1.4.5)
- 25) There should oe references sit d of past wor'z or studies that show effective isolation of radioactive cont minants i g oundwater.
(6.1.4.5) 26'his supplement should, address site-specific conditions and not generic-conditions as it seems to have done.
6-53
Susq. Alliance(l)
Ths staff believes that this FES provides a fair evaluation of impacts of reactor accidents and that the analysis as presented in the FES meets'he intent of the Commission's Statement of the Interim Policy on plant accidents.
The detailed analyses of severe core melt accidents included in this evaluation supports the conclusion that the risks of reactor accidents are low compared to the risks associated with many other human activities, even when accidents in the category previously identified as "Class 9" are included.
k Susq. Alliance(2)
Contributions to risks 'from long-term (Chronic) exposure fnom the contaminated environment are included in the risks presented in Section 6.
Susq. Alliance(3)
The analysis of accident consequences,. is based on actual meteorological data collected at the Susquehanna site. Although the observation concerning possible meteorological conditions is correct this observation does not negate the validity of the FES analysis, sioce the extent to which such conditions occur at the Susquehanna site have been included in the analysis.
I Susq. Alliance(4)
All accident sequences and sequence groups included in Table 6.1.4-2 have values of time to release, release duration and warning time of at least 1.5 hr, 0.5 hr, and 1.0 hr. respectively (See WASH-1400, Appendix VI, Section 2 for definitions of these times). The staff has not taken any extra credit for public evacuation, sheltering or relocation which is not consistant with these times associated with the accident sequences and sequence groups used, and the evacuation parameters h
(see:FES Appendix I) for the Susquehanna site.
Regarding the speculation of the six-second accident scenario credited to Or. Richard Webb, the staff is familiar with it and considers it to be highly unlikely for the Susquehanna HWRs. Even if such a sequence would occur, the associated release magnitudes would be small since the core would take a much longer time than six-seconds to melt. Risks from such speculated sequence would be small compared to those from the sequences in Table 6.1.4-2.
6-54
C Susq. Alliance(5)
The staff's conclusions concerning the likelihood of severe accidents are based on about 500 reactor years of power reactor operation, as well as sound engineering principle and .conservatism employeed in their evaluation.
The stated conclusion is supported by analytical evaluations of the nuclear power plant systems together with the fact that the experience base to date is accommodated within th'e theoretical calculations.
Susq. Alliance(6) 13 million curies as the magnitude of xe-133 release from TMI-2 accident was the result of early and preliminary estimate. This figure has been revised and 1.5 million curies is. considered .as the best estimate of xe-133 release from that accident. See Rogovin Report, vol. 2, Pt. 2, pp 359-360.
Susq. Alliance(7)
This comment is a correct statement. The Susquehanna FES analysis is based on a fully irradiated equilibrium core.
-Susq. Alliance(8)
A number of estimates of population exposures were made following the accident based largely on thermoluminescent dosimeters (TLDs) located around the plant site to distances of several miles. Estimates of radioactive releases and of total dose have been independently made by several groups including the President's commission and the NRC s internal investigation by M. Rogovin. In addition, A. Hull of Brookhaven National Lab. and K. Woodard of Pickard, Lowe 8 Garrick have estimated radioactivity releases and public doses. All these sources provide confirmation that the maximum individual dose was less than 100 mrem and the integrated population dose was less than 3500 person-rem with some estimates lower than 1000 person-rem.
Susq. Alliance(9)
It is the judgement of the Comnission that the. assessment of psychological 1 impact is not required under the scope of NEPA.
6-55
-Susq. Alliance(10)
The staff has adequately demonstrated that the potential consequences of releases from core melt accidents to the ground water system would be much smaller than those .of-, a "typical" generic site used in the. Liquid Pathway Generic Study (NUREG-0440). The current NRC practice in evaluating core melt accident liquid pathway consequences relies on the comparison of the existing site with those sites, presented in NUREG-0440.
The staff. clearly states in section 6.1.4.5 that the minimum travel time for radioactive contamination via the ground water pathway would be 9.2 years, and that the travel time for Sr-90 and Cs-137 would be much greater. The staff has further concluded that there would be .ample time for engineering measures to isolate the contaminated water from, the river if it were found to be necessary.
-Susq. Alliance(11)
The NRC's siting regulation, 10 CFR Part 100, requires an applicant to show that arrangements have been made to control traffic on any transportation routes traversing the exclusion area, thus, the discussion in Section 6.1.3.2 was intended to show how the applicant was in compliance with the NRC's site criteria. There was no implication that the Emergency Plans, or the staff's review, has been completed.
6-56
=-Susq. Aliiance(12)
~ With regard to the comnent that the DES writeup does acknowledge the uncertainties calculated by the Reactor Safety Study (RSS) but that the OES tables do not reflect these uncertainties, the staff assumes that this comment reflects an editorial preference by the Commentor. For example, we have acknowledged the uncertainties on Table 6.1.4-2 which contains consequence model inputs quite similar to the RSS tables (although the RSS tables did not contain such an acknowledgement as has been done in OES). The staff will accept this editorial comment and explicitly include such an acknowledgement of uncertainties on tables where none now appears.
With regard to the comment that the tables do not 'appear to have been adjusted'o reflect the accident at TMI (which involved PWR accident sequences of the type previously identified in the RSS for the PWR deisgn therein) the staff believes it is not necessary to include the PWR sequences into sequences for the BWR design- although this could be done. However, we believe that the overal'I health related risks to the public shown in the OES for various BWR core damage
.accidents dominate and adequately cover those from the TMI accident.
6-57
(
-Susq. Alliance(13)
The RSS economic modeling consider ed only the off-site costs as public property damage. The on-site costs and loss'f returns to the plant owner(s) associated with plant damage, downtime purchased power, cleanup etc. were assumed to be
. private costs and were not included in the RSS modeling. If private costs associated with plant d'amage, loss of returns etc. were to be included into the RSS modeling then it is obvious that accidents (core damage or otherwise) ipvolving long plant downtimes - whether or not such accidents present 'any off-site radiological health impacts - which would have large economic losses could be predicted. It is an arguable question whether or not the RSS should have included such private costs into an assessment of the public risk from reactor accidents. One point should be obvious from TMI-2 and that is that the plant owners should have considerable economic incentive to maintain a high level of safety in their plant design and operations or the private economic risks can far outweigh those predicted for the public off-site. Please also see responses to JP(7) and JP(9).
6-58
Susq. Alliance(14)
Procedures for plant recovery following an accident would depend on the type of the accident the plant would actually experience and the actual conditions prevai,ling io the plant in the post accident period. The environmental impact of such recovery procedures cannot be determined at this time. The impact of a specific recovery operation would be assessed at that time when th'e need for such an operation arises.
-Susq. Alliance(15)
The staff does not state that such risk cannot be compared because of philo-sophical differences; the DES states that such comparisons cannot be made because the costs of acid rain, etc. have not been "sufficiently quantified to draw a useful comparison at this time." Such comparisons may become possible in the years ahead as better data becomes available. The argument of the use of anthracite vs. bituminous coal is irrelevant since all fossil fuels emit sulfur and nitrogen oxides (and therefore acid rain) only the quantities vary. Secondly, anthracite is a very limited and irreplaceable resource that is seldom used for generating electricity. Because of its low sulfur content, the major use of anthracite is the manufacture of metallurgical coke for smelting iron ore. Byproducts include benzene (used in unleaded gasoline and pharmaceuaticals, for example), toluene, xylenes, naphthalene, anthracene, phenol, cresol and pyridine. These chemicals in turn are used to make many of the materials necessary for moder n life such as medicines, dyes, explosives, preservatives, fungicides, lubricants and plastics.
Susq. Alliance(16)
Thyroid doses from the accidents. included in Table 6.1.4-1 were not reported explicity because these doses would not show any trends different from that which is demonstrated by the WB doses shown in the table.. It should be noted that the coosequences of the exposure of the thyroid (i.e. thyroid nodules) from the more severe accidents are shown in Fig. 6. 1.4-5. The risk from the thyroid exposure for the accidents within the design basis are negligible by comparison .
The staff's experience with the methodologies and assumptions used for calculation of realistic doses such as shown in Table 6. 1.4-1 (See Section 6.1.4.1) is that these doses are in the range of factors of 10 to 1000 lower than the doses calculated conservatively for the Safety Evaluation Report (SER).
6-59
Susq. Alliance(17)
A table of keys to BWR accident sequence symbols is provided on page H-4.
-Susq. Alliance(18)
This comment appears to reflect an editorial preference similar to that reflected in comment 812. The staff believes that the foot note on table 6.1.4-2 should suffice as acknowledgement of uncertainties.
Susq. Alliance(19)
The a culations of areas of decontamination and interdiction are intermediate calcul steps in the determination of the costs of decontamination and interdiction of land areas. The latter results are reported in order to provide a complete assessment of the costs associated with ground contamination.
Susq. Alliance(20)
Probabilistic treatment of evacuation parameters wou'jd substantial]y increase the complexity of the reported results. The effects of changing the evacuation parameters, however, have been, analysed, and are, discussed in Appendix I in FES. With respect to using THI-as a reference point for health effects estimates, it should be noted that measurable consequences at TMI were.so small that they would be ff- 1 lfg g f 1 PP1 Fgg.
Susq. Alliance(21)
Accurate cost figures for TNI-2 accident mitigation measures are not available at this time. It is the staff!s.judgement, however, that these costs would not exceed those shown in Figure 6.1.4-6. =
Susq. Alliance(22)
A different map is now provided, 6-60
Susq. Alliance(23)
'Risk isopleths for cost, as well as, other consequences would have trends and patterns similar to those evidient from Fig. 6.1.4-8
-Susq. Alliance(24)
The ground water velocities used in our analysis are based on well-founded principles of hydrology and on conservative values of hydrologic parameters measured at the site.
-Susq. Alliance(25)
It is a well-established fact that many radioactive and stable elements are retarded by the process of "sorption" and therefore move at a rate much slower than that of the water itself. Rather than list references, which are too numerous to mention, the staff, refers you to a survey article:
M. P. Anderson, "Using models to simulate the. movement of contaminants through ,
ground water flow systems" in CRC Critical Reviews in Environmental Control, Vol. 9, Issue 2, pp 97-156, 1979.
O Susq. Alliance(26)
The Supplement mostly addressed site specific conditions.
6-61
gCF'hI l.I:.O'IS
%Of BRAI)YORI>TERR .jQ
'I swa.nnru A(A. PeNN p==
l~J I 49 28 APR ~N lgsl Di Divisoin of Ticensing Office of ~RR RC Ylashington, D.C. 20555
~orget &~" 5+( ':;arvfn I. Rests 6504 3radfordterrace
- Z8'-27-91.
z7 philu. FA 1914$
Director ,Division of Iicensing lac.3 Office 4 :nuclear Regulation US.'li? C
Dear SIR; ,
=,'. p-'g "-i g) 9 51 Please accept the following comments as'y comments on both the Supplement 2 HURZG 0564 Supplenent to DES Susquehanna Untidy, 2:.,and; QQ.
and. also 2fUR=-G 0490 Supplement to DES San 8nofre Units 2 apa";3>"CYANO;-l Both zof these HUHZGB are very ,, very similar . In fact , they are exactly the same page for page. Except for using the'umber 7 in NURZG 0490 aid the number 6 in Hureg 0564 , 4hey both have identical Table of Contents.
The use of hxzxxhxa boilerplate ( identical forms and wording )
is acceptable in many instances. I do not believe that boilerplate shows reasonable care where human lives anl the safety of the ggl (()
public is at stake. Boilerplate can tooqeasily hide the reality of inadequate care and attention to detail. There is no way to see 'beyond tb 'boilerpMe'o verify the correctness of the prose and techgnical detaihs.
ParagraD?1 7 1$ 1 ( UPEGX+zgg 0490 ) 6 1 3 1 (q~P G 0564)
.Thisparagraph in their respective .'TURZQs refer to mitigative measures included in the Desi~ Features. Several of the design features discussed to mitigate accidents do not appear to be ESP, enginee&dd safety features , which have fulfilled all'he GDC, General Design Criteria . For a feature to be ESP and for that feature to be considered a mitigative feature in an accident , Shat feature must meet all applicable Gsaeral Design Criteria. In both nuregs , mitigative features discussed in the paragraph Design Features have not all passed XXX applicable General Desipn Criteria.
Apparently, some mitigative value is attached to non- S systems This is in direct conflict vvitha GQC requirements and the Atomic Energy Act.
l Although there are many extremely misleading and error-Xilled sections in this x~xhx report, I shall limit my comments to the very wors and most mislea&ing paragraphs in these .'IUKGS; 6.1,~ (1'NBEQ 0564) and 7.1.1e3 (-<Ui?E& 0490) .
6-63
2
- oth these s'J.=a~ start the respective .-.eslth ffects jra~'ra"h 0
ex"ctly the save". "The cause and effects relationships between radiation and adverse health effects are quite complex but they have been, ox'8 ezhall stively studi GP than any o ther environ;QentQ.
carta inant." he point is aot tnat radiation nas been studied more than any othe environmental cortaainant, the point is what has this study accomplished. To understand what this
'exhaustive studv has accomplished, we ruat loolc.at '.vnat this evhaustivo studge8 was..supposed to acco.".y1ish.
For instance the purposely and goal of a 1964 federal study /ez(~)
a nd related radiation exposure anon'vorkers at US oX'ancer acilities divas ori:finally undertaken for 'Political to thwart 'voters efforts to obtain compensation t'or
'easons'amely, illness. These findings were reoorted by the House subco:ulttee on Health and the Environ.sent in Feb, 1978 and confimed oy a Preedom of Info~ation Request fvow L'r .4ancuso anP. the Public Cifi"en X,i'ti--ation Group. ( Cx.it'cal (i j l$ ass Journal Peb 1.979.)
Obviously research done fox such nefarious and unworthy reasons cannot bs trusted. TRio is the xesea ch that Dr Botchy, who wrote this chapter,wouldhave us believe. (NURZQ 0564 Page vii)
The entire fiehd of xadiation research is tainted with questionable research by Goveqmaent and other intexests who have a stake in lulling the Justifiable fears of an informed public.
I respectfully request that the reviewers of ny comments reaP.
A."-,Z"p""" P~Z" r:UT't by-"'rnest Gtern~haas(;~cGraw Hill. 1991.) The government and the nuclear industries are. still atte~pting to cover up the dan~ers of radiation. Dr Fokuhata (Penna Eo Health )
is still xessaging data in a most sinuous way to coze out vith distorted data. (Coamonzealth of PA , Testiaony o'f Qe Tokuhata HRC Locket 50 -289, 'Subaitted 4-$ 6-81.)
To demonstrate the backround that Dr 'Tokuhata co mes frow, he and the State of "erma are presently being sued for sex discriminatioy.
This is the type of person" that we axe entrusting our radiati'on research to.
There has been Good radiation researdh. The vested interests an .
the 'lRv have consist'ently shied away fro:a any research that displ"yed r~diation effects hi~'her than those deter~ined by
. Govc~aent and industry backe" cscarch. 'ven Seeds:gaia h:"-i fa11en prey to bein@. a vested interest . i'undi ng is few and far bet:veen for researchers like Or i'.Osalio 3ertellyGS'.l.
6-64
) ~ ~
Ms':cuso tnd orcus have <otten their funding cut o=f. "r. 'terngXss'as been the object of sluxs and vituperation. Dr /eh~.x 7iebb has x."~
had difficulty findin" employment despite unique credentia s.
uch ~-,ood re:;eirch ha co-..e from ac-o"s ihe sr.a only to be it,no cd
,by the .'.to;::ic ZEt. blici:vent. (!leidelber': Report 197EHRC "r~nslation 520 TXCi" 520) z.-ually good resea=ch has been done in ~america aO.".'onsistently i;"r:oxed by the .4to, ic "stablishnent.
h0""7 t."~I'.") "'CR T":-'TUOY OZ 1~0K'~V~2'i BADXl'VXQh I;i .;ipse 5', ID~.'=.3T It Dixon Anvil 'ress 1979 ~
8,',T'IATH;8 STAHi)ARDS A3H TUBXXC P::AXTH Proceedings of a econd Congaeesional Seminar on ~>ow s evel Radiation ,2-10-76 Lib of Congress' Truly excellent and telling research has been accomplished in the USSR on the fauna and flora exposed to nucleax radiation in the relea..e ata place called Kyshtym. How'his release happened and, how tb xesearch the data in the literatt'xe.is detailed in an iriteresting book by Zhores A. a"edvedev entitled ÃtJC1'>>DiR DISASTER R ZN T'-"'BALS,(Vantage 3.980 )
All of these source s have been consistently ignored because the data show, clearly that the effect of'ow, level mediation is higher by orders cf magnitude than thai which the hPC use@ .
The remainder 5 the pa a raph o- sec ion is as laved as he opening sentence.
"10 tb 500 gz-sczxze~sxxys~x~i~~~isa poten ial cancer deaths per -illion person-re~"
In order to We"conservative, ~'he highest number of deaths must be iced in the calculations. The choice of"150"in not conservative!
The sa-e argument is valid fox'sing 260 genetic changes per ni11ion pe eon-re-..s instead of 220.
Disclaim..er: I h .ve neither the time nor incli.."-tion.to co..ment upon all the insufficiencies, errors, and gust plain lies in these KUiVGS. This is a arce .that will eveniuall y take the live: o-American Citizens quet as surely as'xz-- K'ar.
liay God forgive this re>>"t t ivil o ?nuclear a>ver for I do not heve it in re to fo"..".ive this trespass against Mankind.
If anyone wishes o contact 'e confidentially, Ly nu~ber is 0!:xg9x"SPgz 215 CU 9 5964. You need no give your na.a and, all infer~ation'r:ill be used without giving the souxce..
For a betier tomorrow,
<<rvin X ~ I e:vis. I 6-65
MIL(1)
The staff does not agree that an identical Table of Contents for several environmental statements demonstrates a lac o care. concerning the health and safety of the public. By following a detailed, standardized outline, the staff assures that all significant environmental impacts are proper ly addressed for .each application. Sections of the FES having the same or similar prose are intended for general and background information for'he reader, addressing common aspects. of reactor accidents, and the methods of analysis employed. by the staff.
MIL(2)
The term "pressure suppression system" has been substituted for "heat removal system" to clarify the specific engineered safety feature discussed in this section. This system, as well as the other systems and features described in this section are indeed engin'eered safety features meeting the requirements of Part 50.
6-66
-MIL (3)
With regard to his claim that the staff estimate of 150 cancer deaths per million person-rem and 260 genetic effects per million person-rem are not conservative, the staff makes the following response.
P The National Academy of Sciences BEIR III range of 10 to 500 cancer deaths per million person-rems shows the latest authoritative estimates of uncertainty are k
fairly wide, (and for radiation of the type released from nuclear power reactors, could be zero). However, it also shows that the value used by the staff (140) is about a factor of 4 below the maximum possible value and about a factor of 14 above the lowest value considered plausible by this dedicated and responsible group of expert scientists. Eve'n Dr. Radford, whose dissenting views have been widely was only arguing that cancer risks are a factor of 2 to 3 times higher
'ublicized, than the "best estimates" of the majority of the BEIR III committee. Since the staff risk estimate is much nearer the upper .end of the possible range, it is regarded as realistically conservative.
Similarly, 260 genetic effects per million person-rem over all future generations represents the geometric mean of the range of possible values in BEIR I. Since the genetic effects estimates are based primarily on animal data (the survivors of the Japanese A-bomb suryivors have not yet shown any detectable increase in mutations),
such a value appear s to be reasonable arid is in fact higher (i .e., more conservative) than the value derived from the BEIR III report in the same manner. However, the l
value used by the staff is a factor of 4 lower than the maximum possible value and about a factor of 4 higher than the lowest 'possible value considered plausible by the BEIR III Committee.
6-67
Stat'olle.-e, 158G1 c~)
.'.;.ay 22, lpS1 C..fic,e o" '.-.uclear reactor =;e~mlation R/K IIQ -"
S -C WAY 2 S 1981
.7 shin-.cn, 3C 2C55>
~8JCm J '"'1'. Dir ctor division g 0 Licensing
.".ello:
Att ched is a. copy of =;; comments on the Su~element:.,'='2 to t."e O'S
- o Susc uehaxL'1a 1 and 2 ~ Doc'acts 50-$ 87, 388.
"he co;ments ~e divic.ed into uv!o pa ts. irst co.;le speci ic respo>".ses .o specif'c claims 7. no od as I re"." 'the dr". t.::ezt ~
is 1>>a "onger trea~=.ent of the sec ion dealin= .!ith estimated ec'oncmic Y,l s= ~
Zt '"- in his second section that Z thin'>> the dr"-"t is at its ':!erst.
.'.:y analyses indicate tha. the c.r" t's estim" tes "--e los: oy a "c.o fi
~
of 100 to 1 0. ."hese "-e the ~es that "f="ect .he cost e."-. i.-. tes or the plant.
Tf 1 di dna t ~op! better g:'!oui d s y th- t the dr ="93 consultants hired by the App icant to shed the "e.'t ,possible li=ht on the situation. h I firmly believe draft. that this draft is so inadecu"te that '" it ca~~sot se "v~ as a inal As un~own a= as it Day be:.i t'.=e:.ez l ur;e
~
- !"ve cc:~in,". f;.om tl e '.c."inistr=;t=:on and he .-.il:, ..e i'ZC to prepare a rea1 draft, one th"t tre"ts the :roblea e~;. the econor;.ics ~ operly. A~en ass again for public corzent and t lell p=oceed to the 7-S. E ea~ize t!:is is not a.p'easant prospect; ne.'ther '.vas eading this draft " p e"-sant ezperience
~
2he role of the TP?C is to resist reassures =."rom .he A"..plicants, the opponents and the "overnment officials in order to ensure th "os ' thorou-h review of the problems ssociated .::ith his not let yourself be b~a~lied into accepting a h"lf-he~. ueG )obo Sincerely, Cop'es: ~lien -rtel av 1 d ) ~o'NQ
~
Jim Pe=~vins
...o is UGall
'"ichc.rd Ottinger 6-'68
Comments on Svpplement;o Draft "nvirormen."1 S." fremont rel.".ted to the Ope ation of, Susave!.ma "te.".m electric S."tion, Units " ~d 2 +ocl:ets 5C-307, 308 Selected cor.~.ents,beloe! re"ult xrom a gener"l reaaing ox the text.
Co;.ts.. nts on the economic "ssessment ely, in addition, on infor.".:a~ion o'ot;.in'ea by asl=in"- from P'<...L. This inform tion r ovid surely h"ve been available to the prepare=-of this docv..ent.
- p. 6-4, sec.ion 6.1.1.3 T!re numbers cited rom the ZEiH III repor ';are c~ iticized by the
~
~
co".mittee head s being unduly generous, i.e. non-conse v.".tive. ~g($
A =scent article w Science indic-"tes tl~iat the ir "or"c-,'ion rel'ei gP(
uuon b the ZZt.. cot;,a .-'ee overes-'imatei the in iuence oi neutrons in ri oshima; !Mnce, he conservative fight'e shovlc. prob".bly 'oe revi" ea. up'vozd b<< t!>e factor of 2 or 3 indic".ted by 5r. ",adford.
PUl uhermore, I.:a~~1 !.'organ and Alice Ste'vert, among ot!rers, are begir~iing to c:.uestion .he conservativeness of .he linear hypothesis.
As a esponsiole agency, not an ad judicative board of scientific studies the J:<C shcv1d "-ssume the :ror'z of .hese reput"ble scientists defines the ccnservative "line>>. That': hat being conserv:.tive means, not that one accepts the averages I
- p. 6-5, section 6.1.2
'Jhere the dr"ft g"'rs ".;fore is lmo'm to h"ve caused any.r."".'.a ion in jury ox' t 1" ty to ly member ox the public," covld ecua ly h"-ve been vni "en, ';one is ego::m.not to h"-ve caused any radia.ion i~>vry J or f";t"lity ~o any member of the public. It is clearly the case tha no stuay has been done;Ihich v~ould indic"-te that t'e d=.".='t's cl"im is true. I .~auld suggest ~hat such cor~ents, .Ihich are unnecess.""y to the I'.2C's c"-se, al .hough pe h"ps no to the Applicants, be eliminated.
? e==rci:n the e is tse's oz .-ele.".ses i'~on T!".X-2, h-"-s the=e been +P~
~a-'ubl'shed e"timates of the releases had q".,'I-2 not h.".Q the extra-thic'- cont".ident~
"It h"s been estimated that the nazism cv~aulative offsite =".diation dose to an individual v:as less than 100 millirem." The St"x= has failed to note that there have been far higher est=:m tes presented to it; to vihich it has failed .to =espond. In particular, 'n Docket
.-'='50-272 .lith egard to the interv ntion by Lo:!e Alloviays.C eels
~os:.~ship Intervenor submitted a report in response to Zo" "d Question on the accident at h"ee r~.ile Island 'Utilizing the
~
methodology provided in the T:lI-2 final Saxety Analysis .-.eport the report's author calcvlated that the rele"se of:.enon-133 from the accident at Tr,;I vfould have provided a 280 rem dose for a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> ex.:osure at the exc"usion boundary and a 45 rem dose for a thirty day exposure at the lo.v popul ion zone ac;tndary.
The.:e ficvres have been in the h~ds ox the ~L=.C since August, 1979.
6-69
'f
-ln the continuin' .".fteraath of the "cc~dent .".t n I r"c'.iot.".oto-.e-"
seve al different t"~es than iodine and 'xenon h"ve oeen =ound ou,side the cl. nt, in cater s:coulee. '~p(/+~
- p. 6-S, sect~on 6.1.3.2
'I ~vonder ho;! the residents of the Borough ox L~erv!ionic, 6 miles to the south of the plmt site, v!ill feel to le"m they a e not a population center. zeCs)
'p. 6-14, section 6.1.4.4 The draft neglects the costs associ "ted v!ithth physical and psychological heal:th ex=ects of an accident iih sub tantial asards 'being sade by courts to individual's or i'-niliee of ~
JPg) indiv deals for the loss of one li="e, ihe costs associ.".ted:vith the loss ox tens or hundreds or thousands should not be shru.=-".ed off.
- p. 6-19, section 6.1.4.6 This section re.=arding the chance of an accident 'bose deccnta:".emanation cost is Ql billion is ludicrouss ":his I believe matzes a moct=ery of the v!hole effort, <<if the p obability of m accident s".erious enough .o rec:uire extensive cleanup and decont-mination is t".'.en as . ~ . 2.4 chances in lCC,OOO per. yern', and if the "average decon-tamination co"t . ; . is assumed to oe one billion doll""s, th n th'e estiz"ted risk,:!ould be about 924,000 per yew.>> I v!cn'i cuioole v(ith this 'oec use it is merely a mathematic 1 statement.. H', horvever~
the .draft's authors mean to sup<est.that the hypoihesis of tL~e st .e-nent is re"son ble, then Z ~!ill a=>me. On the very next p"-e, as the authors ry to explain their ehiance on the reactor S"- ty Siudy, th y '.vite, >>The accident at Three;Iile Zslvmd occut"red in I'arch 1979 "t a tire .!hen the accvmulated ex".er'ence record;!as about 400 reactor years. Zt is of intere t to note th"t this .!as ';r=:thin the ramie ox xrec~uencies estimated by the 'RSS xor an accideni of this seve ity,>>
The authors cannot h ve the best of'ach: orld,
'he i'Z acci"ent v!ill cost at leas.t Sl billion to decontazin" te. ~!ence it ='is Zt occc edT(f v.'it hths average accident cited by the vtho s v!iihin the rea~e ox frecuencies su@"ested by the >SS ~ Hence 2.4 /)
in 100,000>>er year is not a reason cle estimate ".ath cle" ly
.1 in 400 per ye."'. is ihe reaonable assumption if v!e are not allo.!ing for the impact of "lessons le"-ned>>, as the draxt's authoxs have claimed. So~ let's use the methodolo~~J'f the sentence exacted above:
~ 1 -31,000,000,000 = 82,500,000 per year as the es='.i;ated economic r s'~,
The draft errs by a factor of 100.
Pvzther v!ould su=. est- that Cl billion may not be a ze"-son ble estimate.
1
'.Vhere did it cove from?
6-7D
~C,ontinuinc on section 6.1.4 6 ~
The co"t of the "1 acc'dent decont"vernation is no;7 esti,",ated at Ql.3 bi%lion. The cost ox re@i"cement po':er for r".te~at.erc is es.imated. at .~1.2 billion t."xovgh 1985 "lone. The aroposed i".~vstry iasvrance "-cheme for replacement .o'.:e= s sonsoreC; bg Electric Enm;rance T.i.-;sited ox .".ermuda viovld h.".ve provided "
th: vcle~
m -inurn ox 0156 million for the GPU rate@ yers h d it So vie can reduce costs to G=U ratep"ye s to ".1.05 billion through been in place.
1985, and add on for the folioiing yeas some figv=e ~ Since T.=.l-2 couldn't possibly be put bac3 into service vntil seems conserv"tive to add, "-nother Cl billion for the yea~s 1990,'t 1985 to 1990..i!a'~in~ the generous ssvaption th" recon. aa'n"t'ion doesn't cost more thm: 1.3 billion,:.ve are thus aced '.iith a. cost of at least Q3.35 'billion. Hence, the nnual estimated economic risk is novi Q8,375,000.
Fvz the more, if the 2SS ".ias reasonably accurate T1iZ-tyre accident 'oe ore 1985 '
':ie can e- sect another Missin" from .he draft vias any mention of control rod f"i'vres
-of the sort that occurred at pro."m's 'erry 3 in June of 1980.
Also missing, though vnderstandably, '; "s t any comment on t.'e neVc co .cern aoout coiling "iate reactor s sc am s jsteQs resorted on "y the;:=C~s Oxfice for Analys's ~cd =valuation of O-,erational Data. These gals shovld 'oe fil ed ~
6-71
Page 6-19, Section6.1.4. 6 Comments on the;vorst case sue~ected by the draft's authors and on the proposed ca."e to be studied,
/
7(orst c":se: Cne unit lost in first yern. The dr the result on the other in this scenario, so I .vill take their ft doesnt t sv""".es three year estimate for a delay in restart.
rying ch"-yes for the lost at 18 per year of final cost. plant Ca are,estim"ted by the comply Assuming a,">3.5 billion fin"1 cost and. mx even distrioution of the costs bet'.veen the t;vo un'ts, the carrying charges on the undamaged: .cility r:ould total 5945 zillion~"
The lost carrying ch~-".es on the damaged f'acility:vould tot 1
)9.128 'oillion dolls."s. (Levelized 16.3 ~ocr ew'"or 32 eel's)
Net repl cement po.ver at 40 mills per 1",vh at the company's expected 88.94 'capacity rvould otM ~456 million per year addition, the company v!ould. lose out on its sales to the PJI,: lnby f j(Q) some predicted 5 to 6 billion Wvh per yeech. At a split s'vinzm profit of'6 mills per lavh, the loss of each unit vould cost ratep yers at least "40 million per year.
- ,7e r,ill assume a "1 billion cost to decontaminate and. five years.
Then v!e 'vill assume that the ccmpany still has su:"ficient r!he er(ithall to ouild, a replacement f'r the damaged unit. That ..ill t"~.-e ten years and:vill be p id, for in inflated dollars, not in 1980. d.ollars.
Thus the f'inal cost of'he accident, neglec~ing the costs dwarves and settlements~ can be calculated. of'ffsite dama ed, Unit undGza.~ed lent t (mi>>ions 8) c" rying chm~es 92128 8945 ruined uel replacement por!er 3,42& 684 lost sales to <mid 600 3.20 cost of cleanup + 1,000
$ 14,1o8 ~1t 749
>lvs a plmt const "ucted and paid for in ye"".1998 doll" .s.-:ill h."-.ve a substantiallg~ hi~0her cost to r"tepayers. For the. moment
>ve'll neglect that 0 The bill, ne~lectin=
accidents
".ther lot, is .",15,947,000,000 ="or ,".1 billion draft's
~'.or! uti~ csin; 'the technioues of the/'rece ding pq~amaph and the Rasmussean p:obability of' in 400 ~er ye~ rre .".at an .""-u~
estim"ted economic rj.sk of ~39 867'500 a""';:.'.in- fifteen years until cc;.:"city re>laced.
6-72
the ':roposec. ca"e: Pi
~
the "econc. i" c'.ovn Jor g ye:.r" vn'til re.".t::"t 1 Q ryin~ ch '~e 12.2',>> per yen ~
f'r th lost pl. Q vl u 6 c'u .1 a leve'zed
'Assv.'nc a C3.5>> lio>>in"-1 cos ~ " c"" '~ ""."
c;i tri'..ution of'he cosu" be~:;can the f.".ciliuie the
~ ch"r"es =or the lost plant:;oulc; to..".1 C5.119 billion. Lost c.".rryia~
chare's 0 J the vndmcgec4 """ciliuy v!ov ld tot" 1 885 mil1 ion. ( "hose fi~m=es ""e in mixed dollars.),et rep'aceI-dnt po'::er at 40 1:ills (1980 mills) ".er hvh at th.. conpany's ex-..ec ed c.".p"city of 70 '
viould to u"1 Qoc6 million o the vndamaged -".cili-'.y and "3.".'8
~
billion for he fifteen years vntil the capaci uy is replaced.
Again the company v!ovid lose out on i.s s"les to uhe PJIi g ic'. oJ
$ 40 million (1900 dollars) per ye"-r ~
Assvming a .",1 b'illion cleanup (in 1980 dolla s, =o consis uency) and..the can t uc.tion,of repl came& cap..c'ty in~ =" xed. c.ollars -'hich
>vill be c pi . lized in 2006,;;.e can compile uhe folio'iilllg chart e daIQa ed vni u vndamar ed vnit (.".mills.on,'arrying ch "c,es "5,119 $ 885 ruined f'uel 50 "repl"-cement pov!er 3,480 69'6 ~s(~)
lost sales to g id 600 120 cost of cleanup + 1 000 210i249 $ 1 ~703 ce rying char.-.es are in 'mixed dollars, 1991 to 2014 for tl e d."=="aged
.unit anc'991 to 1993 for the unc'.ma'.-ed'll others are in 1980 dollars. To ~et the 1991 fig<re 've can assvae a ccnservative 1G;~
annual inf'lation ,rate f'r fvel, replacement po:;er, lost sales, cost. '~rom. 1983 'to 1991 a compovnded-.10 anovnts to a 114 inc ease.
damaged vnit undam ged unit (" m) carrying charges $ 59119 S885 fuel 107 replacement pov!er 79447 1,489 lost sales'o grid 1,284 257 cost of'le~sup + 2 140 S16i097 ~+29 631 So fi in corn..ari."-on l'lith the w~re on he preceec'.ia.-. Sage re.;resentin,-:
the "ivorsti4 case, "Ie h"-ve an equal economic ris.~ of "46,820,GGO.
mostly in 1991 dolla=,s.
6-73
3ecavse the ~"lysis above included= some mixed dollms for cm"ryin= ch~~es, I decided to ta3 e the '.!or" c.". e ence more, tl is time c .lcul" tin" tt.e ef ects in 1":D3 do>> "rs. For every yc."~ of the convwy's pro";osed carryin char,.e schedule 7 h.".ve v"cd,a fac:or baseC. on a 10'; inx 1 .'i on rate to d Just. the fi:~J=e 'o" ck to ." '
3 dollar co"t. -'he draft's st"ff used~40 nills "s a net replace ent co t, a fibre prob"b" y conservative~for 1903. 7 h.".ve used 16 mill per k';h r- te of earnings f: om the g id for 1983, 'o""ed upon some analysis of the p"st record of .he co:.~pwvg.,",1 .billion is the dr"ft's estima.e,of cost. Assume a ".3.5 bil"'on fin"1 cost and. an even dist"ioution bet-.'een the tv!o units ~ The comply assumes an average c 'pacity of 68.9,o for e"-ch vnit;
~educed as described, the carrying charges xoregone, for the damaged facility v!ovid- total ':2,959,000,000 ~~ 3.983 dollars. The three years of carrying charge~s for the undamaged pint:"!ovid total S861',000,0OO.
damaged unit. undama.ed. unit carrying charges G2g 959 8861 damaged fuel 50 replacement po';er 3',420 684 los u sales uo 600 120 cost of cleanup + 1,000 +
S 8p029 $ 1,665 So, in cons.ant 1983 dollars the, coot. of a hypothetic".1 ""3. oillion accident:!hich des royed one unit and =,e'"dered tL>>..other oot of service fo. three years .!ould be ~9,694,0C0,000. this ne=lects entirely ofxsite d"nages and injuries and th".t a utility tr..~in-to handle a "9 billion loss and xjor cleanvp ':!ovid h"ve a h.". d time ente"ing the capital market for construe-'.ion funds
/
At the 3SS .fibre cuoted by the draft's authors of 1 in 400 per F07 year for a billion dollar .".c0ident, this figs"e translates to es-.im".ted 24 2 -,illion economic risk for the first ye"= ox ~uscue-hema's o",er"tion. '>his figue is m're tn"t 100 times "s-hi.-h as the draft~s.
+ conse vative, used here, means lovr 6-74
JP(1)
The staff agrees that the BEIR III values may be affected by the reevaluation of the Hiroshima and Nagasaki doses to survivors and that preliminary estimates indicate the BEIR III risk estimates could increase by factors of 2 or 3.
However, it is far .too early to revise estimates of risk N
based on such unconfirmed estimates. When all the work has been completed and reviewed by the scientific community, and the BEIR III Committee has r'eevaluated its recommendations and provided new guidance for Federal agencies, the NRC will I
move quickly to implement any recommended changes. In the interim, an increase still C
of a factor or 2 or 3 in the recommended BEIR III r isk estimators would be within the range of l0 to 500 deaths per million person-rem provided by the present BEIR III report. Finally, it is worth nothing that while the BEIR III Chairman criticized the BEIR III committee for being non-conservative, three other members criticized it for being overly-conservative:
-JP(2)
Staff agrees it cannot be demonstrated whether injury has or has not been caused, and only pointed out the fact that no one knows.
-CP(3)
Thickness of the containment did not play any role in the amouht df radioactivity release from the TNI-2 'accident.
~
I 6-75
-JP(4)
Th i bi 1 i lvb ~hl i 1 1 1 di doses resulting from assumed worst case releases and meteorology, and the real measured doses resulting from the THI-2 accident.
Iodine and xenon (as well as several 'krypton radionuclides and.some radio-active particulate progency) were detected in gaseous effluents from THI-2.
In addition, tritium and traces of Cs-137 have been found in on-site test borings taken near the Unit-1 borated water storage tank due to a leaking valve to the tank. However, the leak occurred ~rior to the Unit-2 accident, and no radioactivity has been identified off-site as a result of liquid releases from THI-2 since the accident.
-JP(5)
The NRC's siting regulation, 10 CFR Part 100, defines the term nearest population center to be the nearest "densely populated center containing more-than about 25,000 residents". Since the Borough of Berwick had a 1980 esti-mated population of 11,781 (1970 population of 12,2?4), it was not identified as the nearest population center, according to the above definition.
-JP(6)
'While the o'nly identifiable health effects resulting from the THI-2 accident were psychological in nature, the Commission has concluded such impacts are outside the scope of NEPA 6-76
-JP(7), JP(9)
The commentor computes an annual economic risk for the Susquehanna nuclear ~
units under three different scenarios and arrives at figures of approximately
, $ 40 million, p7 million and $ 24 mi lliog respectively, for the three scenarios compared to the staff's calculated total annual economic risk of $ 142 thousand spread over several years. The commentor's calculation is thus about 150 to 350 times that of the staff. We believe that tho commentor has erred in
(
three principal ways for each of the three scenarios:
(1) an improper probability factor, (2) improper application of fixed charges, and (3) double counting of certain costs The principle difference lies in the probability factor used. Staff used a probability factor of 2.4 x 10 (2.4 chances in 100,000) whereas the com-mentor used a factor of 2.5 x 10 (2.5 chances in 1,QOO); a difference of more than 100 times. The commentor's probability factor was derived based on the TMI accident happening after about 400 years of reactor operation.
A single event cannot be used to determine a probability factor. The best way to describe this for one not versed in statistical methods is to note that the probability of throwing snake eyes cannot be determined by a single throw of the dice. The commentor supports his factor in part by noting that the one chance in 40Q is within the range of frequencies estimated by the RSS (1975 Reactor Safety Study) for an accident of this severity. The range estimated by the RSS varied from 1 in 30Q to 1 in 30,0QO reactor years of operation. Thus, the 1 in 400 value is at the very upper end of the range in frequencies" Conversely, the 2.4 x 10 probability factor used in the 6-77
Supplement to Draft Environmental Statement is lower than the lower range of frequencies given in the 1975 RSS. However, as noted in Appendix H-1 of the DES, the RSS has been re-baselined since 1975 to reflect use of advanced
'modeling of the processes involved.
Other than the probability factor, another major difference between the commentor's calculations and those of the staff is in the computation of carrying charges. Carrying charges include interest charges and return on investment, depreciation or recovery of the capital, interim replacements, taxes and insurance. Carrying charges must be paid if the plant is operating or not operating. These do:not therefore, represent additional costs whil.e the facilities are shut down. While the generating units are not operating and until the damaged unit is replaced or decommissioned, the loss in benefits of not being able to operate the units is fully reflected by the replacement power costs. To charge for both the costs, and the benefits not realized, would be double counting.
After the damaged unit is replaced, the only carrying charges applicable for the replaced unit are those associated with interest charges and recovery of capital. Interim replacements, taxes and insurance are no longer applicable to the damaged unit after it .is replaced or decommissioned.
Susan M. Shanaman, Chairman of the Pennsylvania Public Utility Commission, appeared before the Subcommittee on Oversight and Investigations of the House Committee on Energy and Commerce. On March 30, 1981, Ms. Shanaman gave the following costs for Three Mile Island in prepared testimony:
6-.78
4 Decontamination $ 1,000 Million Reconstruction Cost 600 Million Less Insurance 300 Net Investment Cost $ 1,300 Million The above costs compares to staff estimates in the Supplement"No'. 2 *of the Susquehanna DES of $ 1,000 Million for decontamination plus return and capital recovery costs of $ 60 million for 22 years for re'construction. The $ 60 million for 22 years is equivalent to a present worth lump sum of $ 491 million at an 11/'discount rate. Although the Three Mile Island costs are not necessarily appropriate for Susquehanna, these estimates indicate that the staff's estimates are of a proper order of magnitude.
The commentor calculates additional carrying charges of $ 10,073 million,
$ 6,004 million and $ 3,820 million, respectively, for the three scenarios that were developed. Staff believes that the only appropriate additional carrying charges due to the accident at Three Nile I Island are those reflected by the $ 600 million reconstruction cost in Ms. Shanaman's testimony.
t The commentor also estimates an additional charge for damaged fuel of $ 50-million. This would already, be included in the $ 600 million reconstruction cost.
The commentor's calculations also include charges for lost sales to the grid.
Staff believes that these costs are already reflected in the replacement power costs. It is double counting to charge for costs of buying power (or generating power) and also for not selling power.
6-79
Regarding the comment that the DES d,id not address the Browns Ferry, Unit 3 scram system malfunctions in June 1980, it is not clear to the staff that this reflects any gap 'or new NRC concern. The matter of ATWS initiated core damage accidents has been a generic safety issue in NRC for some time now for which analyses have been completed and rule making is presently underway independent 1
of the DES (See NUREG-0460). Furthermore, the risk analysis presented in the DES for the BWR design contains sequences that involve total failure to shutdown the reactor (including failure to insert all control rods). This particular sequence was in fact found to dominate the overall risks as these are presented in the DES (i.e. sequences designated as TC).
6-80