ML18030A049
| ML18030A049 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 06/01/1981 |
| From: | Lochstet W PENNSYLVANIA STATE UNIV., UNIVERSITY PARK, PA |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0564, RTR-NUREG-564 NUDOCS 8106090408 | |
| Download: ML18030A049 (8) | |
Text
REGULATOR NFORMATION DISTR IBUT'ION 8 EM'RIDS)
ACCESSION NBR:8106090408 OUC ~ DATE: gi/06/01 NOTARIZED:
NO DOCKET FACIL:50 387 Susquehanna Steam Electrfc Statfont Unit. 1<
Pennsylva"=
05000385 50 388 Susquehanna Steam Electric Stations Unit 2'< Pennsylv ~If%)00388 AUTH,MAHE AUTHOR AFF ILIATIOM LOCHSTET'~W ~ A ~
Pennsyl vanfa State Unf v ~
'ECIP ~ VAHE RECIPIENl AFFILIATION Division of Lfcensfnq
SUBJECT:
Forwards comments on Suppl 2,to NUREG 0654i "Suppl to Operatfon of Susquehanna Steam Electric StatfoniUnits 1
2 '
Rept not adequate to descrioe environ 8 public health consequences of postulated accidents'ISTRIBUTION CODE:
C002S COPIES RECEIVED:LTR ENCL SIZE:
TITLE: Environ.
Commen ts ~
NOTES:Send ICE 3 copies FSAR 8 al l amends.i cy:BAR-LRG P~(L.RIB)
Send IEE 3 copies FSAR 8 al l
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104 Davey Laboratory The Penn.
State University
.University Park Pa.,
16802 1 June 1981 U.S. Nuclear Regulatory Commission washington, D.C.,
20555 Attention: Director, Division of Licensing
Dear Director:
Enclosed are my comments on Supplement 2 to the Draft EIS on the Susquenanna Steam Electric Station Units 1 and 2.
Please note that the opinions and calculations presented here are my o~m, and not necessarily those of The Pennsylvania State University, which affiliation is given for identification purposes on y.
I should note that I reouestea a copy of the draft in a letter to the Director, Technical In ormation and Document
- Control, NRC, postmarked may 13, but did not receive the document until Pay 30. It was thus impossible to meet your
<<ay 26 deadline, which I assume to be extended under the circumstances. I have attemoted to respond as quickly as possible.
I hope these comments are useful in developing the Final Environmental Impact Statement.
Sincerel Nm. A. Lochstet, PQ.D.
(~i/ ~
s 8IO6OOO o>
Environmental Impact of'ostulated Accidengs Susquehanna 1
E-2 by (iilliam A. Lochstet,Ph.D.
The Pennsylvania State University "
'June 1981 The Nuclear Regulatory Commission (NRC) has attempted to evaluate the environmental and public health consequences of postulated accidents at Susquehanna 1
Ec 2 in its "Supplement to Draft Environmental Statement related to=the operation of Susouehanna Steam Electric Station Units 1 and 2,"
NUREG-0564, Supplement No.
2 (Ref. 1). Unfortunately, the mere 41 pages of this report are not adeouate to describe a calculation that was previouhly presented in the eight volumes of the Reactor Safety Study (RSS)
NASH-1/00. I should add that the attempt to do something about this issue is a giant stip improvement over the past practice of doing nothing.
For severe accidents the assessment is carried out considering the entire population within radii of 80 km (50 miles) and 800 km (500 miles) (Ref.l, section 6.1.4.2, page 6-12-')'hich would include part of Kaine to the north and North Carolina to the south.
The use of such large radii is certainly approoriate.
As is properly recognized in Sec. 6.1.1.2
( Ref. 1, P. 6-3) at larger distances from the release site, the exposure per parson decreases, but the number of people exposed increases.
- Thus, as it was recognized in 1975 by the APS study (Ref. 2) the major health impact may be located at the larger distances from the release site.
The opinions and calculations contained herein are my own, and do not necessarily represent those of The Pennsylvania State University, which is well known for its encouragement of diverse thinking.
'usquehanna June 1981 The next item to examine is for what time period are the exposures to the populations considered.
It is stated in S 6.1.4..2 (Ref. 1, P.6-12) that:
Unless otherwise specified the calculations for Suscuehanna incorporate this provision for relocation following seven days of exposure.
Since other alternatives for earlier evacuation are also considered, it would appear that the population is permanently relocated seven days after the accident or less.
This issue arises further in 5 6.1.4..4.
(Ref. 1, P. 6-14) where the cost of decontaminating property is considered, "where practical". This would seem to indicate that the population is allowed to.return in some limited way to the area affected.
But this would involve additional radiation exposure which would seem to contridict 5 6.1.4..2.
Two cases will be examined here, permanent relocation, and temporary (indefinite) relocation.
In the case of permanent relocation, the radiation doses z
will indeed end after the seventh day. In the case of a large accident the affected area would be " the size of t.'".e state of Pennsylvania."
(Ref. 3). This is an area of 29 million acres, which at an average value of $1,000 per acre would total
$29 billion. This is somewhat beyond the largest dollar cost indicated by the lash data point in Fig. 6.1.4.-6 (Ref. 1, P. 6-33).
The last data point in this Figure would appear to be only'j15 billion. This case does not seemto fit the NRC estimate.
In the case of temporary relocation, the population of the affected area would return after a suitable waiting period and decontamination where practicle. In tha case of a large accident, with 29 million acres or so affected, it is not "practica3:" to decontaminate the large areas with fairly low contaminatien. In these areas, the population would return and.
receive a fairly small indi,viduaX dose for a ling time. This, in fact would be the major consequence of the accident (Ref. 2) ~
This does not seem to have been considered in the NRC estimate.
Susquehanna June 1981 The present study (Ref. 1) seems to be based on the RSS (Ref.
g) and >'Rebaselining" to incorperate peer group comments, better data and other developments since the iublication of RSS (Ref.l, P. 6-11)
~ In its January 1979 statement of policy refered to in 6 6.1.<.7 (Ref. 1) the Commission took the following actions:
The Peer Review Process:
The Commission agrees that the peer review process followed in publishing '/ASH-1400 was inadequate add that proper peer review is fundamental to making sound, technical decisions.
The Commission will take whatever corrective action is necessary to assure that effective peer review is an integral feature of the NRC's risk assessment program.
Accident Probabilities:
The Commission accepts the Review Group Report's conclusion that absolute values of the risks presented by NASH-1400 should not be used uncritically either in the regulatory process or for public policy purposes and has taken and will continue to take Steps to assure that any such use in the past will be corrected appropriately.
IN particular, in light of the Review Group conclusions on accident probabilities, the Commission does not regard as reliable the Reactor Safety Study's numerical e'stimate of the overall risk of reactor accident.
(Ref.
5, P.3)
The second statement would preclude She use of results from the RSS at this time.
The first statement-requires a thorough near review process 'for any such study. It is here suggested that the new "Rebaselinin>>".
has undergone less peer review than the RSS of 1975.
The present report (Ref. 1) is too incomplete for any hint at peer review.
It would appear that the NRC has at least two choices to face up to these important issues.
One choice is to publish a
new version of the RSS.
Another choice would be to expand the present report (Ref. 1) to be as comprehensive as the RSS.
In either case, thorough peer review would be necessary, of the scale that the 1975 RSS was reviewed.
Your efforts in this direction are appreciated.
Susquehanna June 1981 There are in addition a number of minor inaccuracies in the present report which should be poigted out.
In the second paragraph of I 6.1.1.3 (Ref. 1, P. 6-4.) it is stated that doses of ten to twenty times 25 rem received over a short period of time can be-expected to cause
" some fata% injuries".
Twenty times 25 rem is 500 rem.
This is the approximate value of LD 50, the dose lethal to 50jo of a mixed population. it is suggested that "some" is a bit of an understatement of half of the population.
In 5 6.1.1.1.
(Ref. 1, ?. 6-5) it is suggested that for soil contamination, the hazard can continue for even decades,.
'.fith some half lives in the order of 30 years, or longer for fission products, mere decades would seem to be a bit short.
References 1
"Supplement to Draft Envi onmental Statement related to the operation of Susouehanna Steam Electric Station, Units 1 and2."
NUREG-0564, Supplement No. 2, Draft, U.S. Nuclear Regalatory Commission, 1arch 1981 2
"Reoort to t'."e American Physical Society by the Study group on light-water reactor safety",
H.if. Lewis, et al.,
Reviews of I~modern Phvsics, Vol L7, Su"..p No. 1, Summer 1975 3
AEC, i~/ASH-740 update file, document 92, page h.
nReactor Safety Study"
'."ASH-'1400 (NUREG"-75/014),
1975 5
"NRC Statement on Risk Assessment and The Reactor Safety Study Report (3'~'ASH-14.UO) In Light of the Risk Assessment Review Group Report", U.S.
NRC, January 18, 1979.