ML19208D599
| ML19208D599 | |
| Person / Time | |
|---|---|
| Site: | 05000471 |
| Issue date: | 08/13/1979 |
| From: | Burt L MASSACHUSETTS, COMMONWEALTH OF |
| To: | NRC COMMISSION (OCM) |
| References | |
| NUDOCS 7909280691 | |
| Download: ML19208D599 (13) | |
Text
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NUCLEAR REGULATORY COMMISSION "d (h /
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AND LICENSING BOARD
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In the Matter of: )
)
BOSTON EDISON COMPANY, et al. ) Docket No. 50-471 (Pilgrim Nuclear Generating )
Station, Unit 2) )
)
COMMONWEALTH OF MASSACHUSETTS' INTERROGATORIES TO THE NUCLEAR REGULATORY COMMISSION STAFF Pursuant to 10 CFR SS2.740(b) and 2.720, the Intervenor Commonwealth of Massachasetts requests that the attached Interrogatories be answered fully, in writing, and under oath by John Sears and any other officers or employees of the Staff who have personal knowledge thereof or are the closest to having personal knowledge thereof. If the Interrogatories are answered not only by Mr. Sears but by other persons, whether or not he or she has verified the answer, and whether or not he or she is an official or employee of the Staff, such person's name and title should be set forth together with an identification of which Interrogatories he or she is responsible for answering.
Each question is instructed to be answered in 5 parts as follows:
A. Provide the direct answer to the question 1037 ;
7900280(c>7/'t
B. Identify all documents and studies, and the particular parts thereof, relied upon by the Staff, now or in the past, which serve as the basis for the answer. In lieu thereof, at Staff's option, a copy of such document and study may be attached to the answer.
C. Identify all documents and studies, and the particular parts thereof, examined but not relied upon by the Staff, which pertain to the subject matter questioned. In lieu thereof, at Staff's Option, a copy of each such document and study may be attached to the answer.
D. Explain whether the Staff is presently engaged in or intends to engage in further research or work which may affect the Staff's answer. Please identify such research or work.
E. Identify the expert (s), if any, whom the Staff intends to have testify on the subject matter questioned. State the qualifications of each such expert.
INTERROGATORIES
- 1. Table 1 of the Final Supplement to the Final Environmental Statement (NUREG-0549) purports to present the population distribution at concentric distances from the Plymouth site.
- a. Please identify the specific section, page and revision date references in the Pilgrim PSAR and 1037 _l
Environmental Reports which were relied upon by the staff in preparing Table 1 of the Final Supplement.
- b. If other demographic information was used by the staff, identify its source and describe its contents.
- c. Explain in detail how " cumulative" population and
" population density" were calculated for each distance in Table 1 for seasonal population.
- d. Footnote 2 on Table 1 indicates that seasonal populations were " weighted to reflect an equivalent permanent population". Explain what types of transient population groups were included in this calculation, and whether the same transient groups were included in the calculations of population for each annual ring presented in Table 1.
- e. Explain in detail how each transient population group included in Table 1 was " weighted to reflect an equivalent permanent population." Provide the documentation supporting the use of these weighting factors.
- 2. Some of the cumulative population and population density figures for the Pilgrim site presented in Table 1 of the Draft Supplement differ from the corresponding figures in Table 1 of the Final Supplement to the Final Environmental Statement (NUREG-0530). Explain in detail the disparity in these figures, including what new source information, if any, was utilized in the Final Supplement which was not used or referenced in the Draft Supplement.
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- 3. Appendix E, 10 CFR Part 50 and the interim guidance to the proposed rule thereto, 43 Fed Reg. 37473 require consideration of " surrounding population distributions" including transients,
- a. What are the surrounding population distributions at the Pilgrim site relied upon by the staff in its review of emergency plans? Explain in detail what permanent and seasonal population figures, and their respective sources, are being used by the staff.
- b. What categories of " transient" populations are considered for purposes of assessing the feasibility and adequacy of emergency plans for the Pilgrim site.
- c. At what radial distances from the Pilgrim site is the Staff co-',idering " surrounding population" distributionu? Explain in detail the justification and purpose of the maximum radial distance considered,
- d. If population distributions are considered by sectors, i.e. 22.5 c 45 , provide the population distribution used by the staff for each sector including separate statistics for permanent, seasonal, transient and other population groups.
Identify in detail the source of these population statistics.
- 4. NRC Regulatory Guide 1.101, Annex A (Revision 1 March 1977) defines " Population at risk" ar se persons for whom protective actions are being or would be taken. Explain in 1037 .l
detail the geographic scope of the population at risk surrounding the Pilgrim site. Explain the basis and identify documents relied on for this assumption.
- 5. Has NRC Regulatory Guide 1.101, Annex A (Revision 1, March 1977) been updated or revised since issuance of the Commission's interim guidance to Appendix E, 10 CFR Part 50, 43
_ Fed. Rec. 37473? If it has not been updated, is such an update being prepared or contemplated? Please provide copies of all such updates or revisions, whether in draf t or final form, including but not limited to staff working papers, memoranda, or other reference of guidance materials rel.tting to Reg. Guide 1.101.
- 6. In SECY-79-450, the Commission was provided with a summary of the staff's plans to improve emergency preparedness. Item number 5 (page 2) concerned assurance of capability to take appropriate emergency actions, and stated that this capability will be exte .ded to a distance of ten miles as soon as practical, but not later than January 1, 1981,
- a. Identify and provide copies of all materials used by the staff in determining that the appropriate zcoe of concern extends to a distance of ten mileF
- b. Identify and provide copies of any additional factual data that was used by the staff in making the above-mentioned determination.
- c. In determining that the appropriate zone of concern should extend to a distance of ten miler, what assumptions were made with respect to:
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e
- 1. the type and magnitude of the postulated accidents
- 2. the source term and fuel iraantories
- 3. release heights
- 4. meteorology and topology
- 5. surrounding population densities.
The following questions pertain to the analysis now being performed by the Staff in response to the Commonwealth's contention, accepted by the licensing Board on May 24, 1979 and redrafted by stipulation of the parties as follows:
Given the guidelines established in Appendix E to 10 CFR Part 50 and the proposed amendment thereto (43 FR 37433),
- 1) An acceptable emergency plan cannot be developed to protect persons within and beyond the LPZ of the proposed site; and
- 2) The Applicant's preliminary emergency plans as set forth in its Preliminary Safety Analysis Report, are inadequate.
- 7. With respect to the following variables, please describe the data base, assumptions, standards and methodology used in analyzing each. If any of the above-mentioned information was derived from other reports, studies, materials, etc. please identify each and the portion thereof that was utilized. If the variable was not considered in determining the feasibility of emergency measures, please explain why.
b0b J
- a. the type and magnitude of the postulated accident (s)
- b. the source term
- c. the amount and variety of radioactive material actually released
- d. The release height (s)
- e. The time delays between:
- i. Initiation of the hypothetical accident and actual release of radioactive material from containment.
ii. operator awareness of impending release and the actual release iii. operator awareness of impending release and notification of authorities iv. notification of authorities and initiation of protective measures.
- f. Wind direction, speed and turbulence, weather variability, precipitation and inversion conditions.
- g. topography
- h. deposition rates
- 1. the size and configuration of the zone within which it is assumed that emergency measures must be taken.
- j. Population distribution within the above-mentioned zone, including seasonal residents and daily transients (In answering this question, specify for what years the population figures or estimates apply).
037 ;
- k. The extent to which the proximity of Cape Cod will effect the emergeacy measures to be taken in Plymouth and cther towns near the facility; the extent to which any emergency measures need be taken for the Cape itself, or any portion thereof.
- 1. The time of year, time of week and time of day the accident is postulated to happen.
- m. The types of exposure to radiation (i.e.,
inhalation, exposure to external penetrating radiation from the passing cloud, etc.).
- n. The types of public health effects that are of concern.
- o. The types of protective strategies to be employed. (In answering this question, please indicate the standards that were used in determir:ing just which strategy - i.e., evacuation, sheltering, medical prophylaxis, etc. - was necessary or sufficient.
- p. To the extent that evacuation was considered necessary, the effective evacuation speed, automobile capacity and the road network and land capacity within the evacuation zone.
- q. To the extent that sheltering was considered sufficient, the building inventory within the zone of concern and the shielding factors assigned to each type of structure, c,,
,y
- 8. What standards and methodology were employed in reaching an overall conclusion as to the effectiveness of postulated emergency measures in the event of a major reactor accident?
- 9. What the the shielding factors assumed for homes within a 10, 20 and 50 mile radius of the Rocky Point Site. Please identify all references and the portion thereof relied upon by the Staff?
- 10. What percentage of the buildings, within a 10, 20 and 50 mile radius of the Rocky Point site, are assumed to be wood or brick, with and without basements? Please identify all references and the portion thereof relied upon by the Staff.
- 11. Where are the relocation centers for the 10 mile evacuation zone for the Pilgrim 2 site? Please identify the name, location, building type and sheltering capacity of the relocation centers.
The following questions refers to a study prepared for the NRC Office of State Programs, entitled " Examination of Offset Radiological Emergency Measures for Nuclear Reactor Accidents Involving Core Melts," by D.C. Aldrich et al., June 1978 (SAND 78-0454) (hereafter the "Aldrich report")
- 12. The Aldrich evacuation model does not consider the possibility of a nonparticipating segmont of the population.
What percentage of the nonparticipating population does the NRC assume in the event of an evacuation? Describe in detail the basis and references relied upon for this assumption.
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., )
- 13. In the 1974 EPA Study " Evacuation Risks - An Evaluation" (EPA-520/6-74-002) the authors state:
There is no reason to believe that because the disaster agent is radiation rather than some other agent, that is, in itself, will provide sufficient motivation to leave. Rather, the opposite viewpoint should be taken--people will be hesitant to leave.
Cognizance should be given in the planning stage to this problem and appropriate thought given to its remedy.
What does the NRC require as a part of emergency planning to ensure that people will be sufficiently motivated to evacuate during a nuclear accident if ordered to do so?
- 14. The Aldrich evacuation model provides the upper bound estimates of effectiveness, given a specific delay time and evacuation speed, in other words the best case. What are the lower bound estimates, and what variables will reduce the effectiveness of this protective action strategy?
- 15. In Aldrich's model of sheltering and population relocation, he assumes exposure to ground and surface deposited radionuclides (ground contamination) to occur only while sheltered. (See SAND 78-0454, p. 56) Explain in detail why people are assumed to receive no specific exposure to ground contamination while relocating, and how the NRC factors relocation exposure into its assessment of the sheltering strategy. Please identify all sources on which the Staff relies.
- 16. What shielding factor (cloud and ground) is assumed by the NRC for persons located outside of the evacuation zone for the Rocky Point site?
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- 17. What are the shielding factors estimated by Burson and Profio (Ref. 20, Aldrich Report) for the preferential sheltering strategies, by specific building type?
- 18. Identify the name, sheltering capacity, location, and building type of the preferred shelters which would be utilized during a PWR atmospheric accident at the Rocky Point site.
- 19. Has the NRC staff run the RSS consequence model with site specific data for the Pilgrim site? If so, please provide the parameters, inputs and results of such an analysis. Describe and explain in detail any modifications made to the consequence model.
- 20. The Aldrich report uses 91 stratified weather sequences to calculate a frequency distribution of projected dose, and the resulting mean projected dose is said to represent the mean of this distribution.
- a. What is the frequency of occurence of the weathec sequence which produced the mean projected dose?
- b. In calculating the mean projected dose, were the weather sequences given equal weignt, or was the frequency of occurence of each weather sequence considered?
- c. What is the frequency of occurence at the Pilgrim site of the 91 weather sequences considered b7 the Aldrich report?
- d. What is the standard deviation and normal distribution around the mean projected dose presented in the Aldrich report, b3[ ,i
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- 21. The Aldrich report indicates that, in the event of a PWR atmospheric accident, unless iodine prophylaxis is administered immediately over very large distances (i.e. 100 miles), the accident will result in high numbers of thyroid nodules from early exposure of the thyroid,
- a. How much stable iodine would be required to Se administered to protect persons from excessive early exposure to thyroid around the Pilgrim site mder the above accident conditions ,
- b. What repositories in the vicinity of the Pilgrim site presently stock stable iodine in preparedness of a PWR atmospheric accident, and what quantities of stable iodine are maintained?
- 22. The Aldrich report cautions that there is a considerable degree of uncertainty associated with the absolute results of the projected doses and public health effects determined for the protective actions analyzed (see SAND 78-0454, p. 66-67).
What degree of uncertainty (error factor) is associated with the following inputs into the Aldrich study; Explain the reason for the uncertainty for each variable:
(1) the release magnitude, probabilities and physical characteristics assumed; (2) the modeling of atmospheric dispersion and cloud depletion; (3) the dosimetry modeling; and the (4) dose-response criteria used for the calculation of health effects.
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Respectfully submitted, o r.
N n ic4 0 ) l 'n)
LAURfE BURT "
Assistant Attorney General Environmental Protection Division Public Protection Bureau One Ashburton Place, 19th Floor Boston, Massachusetts 02108 (617) 727-2265 Dated at Boston: August 13, 1979 1CJ7 .)