ML19256G278

Safety Evaluation Re Likelihood of Lng Accident Resulting in Significant Radioactive Release

ML19256G278
Person / Time
Site:	Calvert Cliffs
Issue date:	06/13/1978
From:	Office of Nuclear Reactor Regulation
To:
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ML19256G272	List: ML19256G271 ML19256G276 ML19256G278
References
NUDOCS 7912280646
Download: ML19256G278 (16)

Text

I UNITED STATES

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o NUCLEAR REGULATORY COMMISSION

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g WASHINGTON, D. C. 20555 E

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o SAFETY EVALUATION BY T5E OFFICE OF NUCLEAR REACkDR REGU

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REGARDING THE PROXIMITY OF COVE POINT LNG F[CILITY BALTIMORE GAS AND ELECTRIC COMPANY E-CALVERT CLIFFS NUCLEAR POWER PLANT, UNITS NOS.1 AND 2 is.p 00CKETS NOS. 50-317 AND 50-318

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1.0 Introduction On March 13,1978,(I4) we issued an interim Safety Evaluation (SE) that analyzed the short term effects on the Calvert Cliffs Nuclear Power Plant (CCNPP) of Liquefied Natural Gas (LNG) carrier accidents at or near the Cove Point Offshore Facility (CP0F) operated by Coltznbia LNG Corporation. This interim SE covered the arrival of up to six LNG carriers

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in approximately three months.

Due to liquefication problens at the Tne sixth

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Algeria plant, the LNG carrier arrival schedule has slipped.

ship is now expected to arrive sometite after July 1,1978.

This SE addresses the long term hazard associated with the arrival of LNG carriers at a rate consistent with the CP0F design capacity.

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2.0 History At The NRC staff began its review of this subject in the sumer of 1975.

that time 3 was believed the Cove Point LNG Terminal wcuH recin operaticn In response to our recuest,(I) Saltit cre Gas and in late fall of 1977.

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Electric Company (BG&E or the licensee) submitted a,n ' analysis of the 1976.(2,3) consequences of several selected LNG accidents in Mar h, These were reviewed by us and the results reported in Supplement 5 to b

the Calvert Cliffs SER,(4) in August 1976. This evaluation concluded that

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the consequences of the LNG accidents postulated in BG&E's submittal The would not adversely a'ffect the safety of the nuclear power plants.

evaluation noted, however, that "It was assumed in the applicant's analysis 7-that such massive failure (of an. LNG tanker) could occur no clo kilometers from the Calvert Cliffs site, and that LNG tankers would not We required that BG&E approach closer than 5.6 kilometers to the site."

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F Those requirements take further steps to assure the safety of the plants.

I.T appeared as paragraph 2.C.(3) of license DPR-53 IUnit No.1),(7) a paragraph 2.C.4 of license DPR-69 (Unit No. 2)(S), which are as follows:

5, "Liouefied Natural Gas (LNG) Traffic at Cove Point Termi_nal id The licensee shall provide one of the following items to

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I the Comission 60 days prior to the initiation of LNG ship traffic at the Cove Point LNG Receiving Terminal:

An analysis to show that the probability of an accident a.

that could affect plant safety due to an LNG tanker L

approaching closer to the plant than the distances assumed in the safety analyses (discussed in Supplement No. 5 to the Safety Evaluation Report issued August 10,1976) is acceptably small, as defined in Section 2.2.3 of NUREG-75/087; or 1650 247

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A comitment from the appropriate U. S Coas't Guard Port Authority that administrative limits will, b'e imposed to

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prevent LNG traffic from approaching Calvert Cliffs t

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Nuc1cer.'lant closer than the distances assumed in i.z the above-referenced analyses.

In addition, the licensee shall establish a mechanism whereby 5.f it will be promptly notified by the U.S. Coast Guard of abnomally dangerous occurrences involving LNG traffic in the '

vicinity of the Cove Point LNG Receiviiig Teminal."

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BG&E provided an LNG Hazards Study (6) in accordance with part a. of the n.

above license condition.

In response to NRC requests for additional information(9,12), BGAE provided further analyses (1.0,13) in which BG&E o

concluded that the probability of an accident affecting CCNPP safety is lii~b_

acceptably small and meets the NRC Standard Review Plan guidelines.

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3.0 Discussion and Evaluation 3.1 Character of the Hazard i=

Should the Calvert Cliffs nuclear plant be severely damaged as a result

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of the ignition of gas evolved from an LNG spill, a significant release f, -

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of radioactivity might result. However, only a small number of postulated scenarios involving the LNG operations could even theoretically produce k..

Potential hazards to the Calvert Cliffs facility could such a result.

result only from a large spill of LNG onto water from a major tanker accident.

Other scenarios, such as breaks in a transfer pipe or failure of 1650 248 e

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land tanks, have been examined and found not to pre,sent a hazard to the facility because the rate of cas evolution would be slow enough to assure that dispersal of LNG into the air would occur and a hazardous gas cloud 4

could not reach the plant.

Ignition of the flamable cloud from a very large spill would not present a potential hazard to the facility unless the flamable gas were within or among the facility structures at the time of ignition. This i.s because the vital areas of the plant are protected F

by concrete structures and radiant heat or overpressures which might result h

from a deflagration of the cloud near the plant would not likely result in

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damage to vital equipment.

The small class of spills which could adversely affect the plant is made h

even smaller by the fact that the cloud must remain unignited while it leaves the ship and transits to the plant.

Nearly all impacts or internal ship events large enough to cause a major LNG release would involve fire i.

b or ignition scurces from electrical equipment.

In our analysis we k

h conservatively assumed that only 90% of such cases would iny'olve an ignition E

source at the time of release.

Any hazard to the nuclear facility would be eliminated by ignition at the silip.

e 3.2 Review of Licensee's Submittals In BG&E's submittals(6,10,13) they state that the probability of an LNG accident adversely affecting the safety of the CCNPP in any future year

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p is on the order of 10-7 This result is represented by BG&E as being an adequate measure of inherently low probability, such that further provisions to prevent or mitigate the consequences of LNG accidents from affecting g

the CCNPP are not required.

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i Provisions to mitigate LNG accident consequences at CCNPP which the licensee has documented include the ins,ta11ation of private telephone comunications between the control rooms at the power station and the LNG terminal, and

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efforts to render the terminal management sensitive to the safety require-

'M ments of the nuclear facility.

i BG&E's -argument rests heavily upon there being an extremely low likelihood

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of a major LNG accident off the Calvert County shore.

Other factors in F

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L the argument, namely that LNG spills are likely to be ignitied a't the accident scene and the likelihood that wind conditions at the time of

' 7; the accident would be such as to blow gas from the accident to the plant are estimated to have a joint probability of 1.9%.

The bulk of their i..

argument, therefore, lies in the inherent low likel.ihood that an accident b

of great magnitude will occur in the-vicinity of or north of the Cove Point Offshore Facility.

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BG&E has forwarded two arguments that such an accident is of very low i

likelihood:

1)

Accidents at that location are no more likely than accidents anywhere else in the Chesapeake Bay. Under this assumption, the probabi.lity of a given tanker visit having a relevant accident is the product of the average ship accident rate times IE-the ratio of areas of the waters within 9 km of the plant to

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the total navigable area of the bay.

This method of estimation is considered by us to be non. conservative because very little of the navigable areas of the bay is expected ever to have an LNG tanker upon it.

Were this 1650 250 e

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v [c method to be properly applied, the area sysceptible to an LNG tanker accident would be a path, perhaps 100 meters wide M

by 250 kms long, through which each tanker would pass in going from the Capes to Cove Point. This would yield a much '

e 2 used by BG&E.

smaller navigable area at risk than the 5000 km

2) Accidents in the vicinity of CPdF have a likelihood equf 7alent y

to that computed for New York harbor in an earlier LNG fj ry licensing study, multiplied by the ratio of overall marine E

4 accidents and expected traffic ratio between the two bodies of water. This argument is problematic, since the original

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estimation for New York harbor was unsuccessful in justifying its purpose, and since there are differences between the proposed traffic in New York and that at Cove Point other bL E

E than the two factors used. While it is tempting to suppose that ship traffic is more dangerous in Raritan Bay "and Arthur Kill off New York City's shore than it is in the Chesapeake Bay, it is also true that proposed supervision of the New York City traffic was far more rigid than that presently expected in the Chesapeake.

In brief, the BG&E analysis does not adequately support their conclusions that the LNG traffic would be safer at Cove Point than New York City, or that the safety would have been as great in New York City as suggested by the study cited.

In summary, since we do not fully accept the assumptions used by BG&E in their analysis, we have perfonned our own independent analysis which is discussed in the following sections of this evaluation.

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3.3 Independent Staff Analysi,s,

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3.3.1 Hazard Distances We have considered several hazard models in an attempt to quantify the 7

potential hazard to CCNPp from a large, unignited LNG spill at the CPDF.

None of these models has been verified by experiment due to the difficulty of conducting experiments of spills of this postulated size and of scaling the results of experiments of small spills to predict the results of a

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large spill. As a result, the various models predict a wide range of e

potential hazard distances under the same meteorological conditions and

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predict different trends for hazard distances for high wind speeds.

The Gaussian' plume models, which predict increasing hazard distances with poor ambient dispersion conditions, contain some physical contradictions

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which are discussed briefly in Appendix C to SER Supplement No. 5(4) 7

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and in greater detail in the Coast Guard report CG-M-09-77, " Predictability of LNG Vapor Dispersion from Catastrophic Spills onto Water," dated Anril 1977.

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As a result of these contradictions and the prediction of other models

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which do not have the same contradictions, we believe that the maxi.num E{

range of distances over which severe consequences from an LNG carrier

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spill are possible is significantly less~than estimated in the NRC

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. Requirements on LNG carrier movements in the Chesapeake Bay and other ship traffic in the vicinity of the terminal are documented in the Chesapeake Bay LNG OplanIII) which has the force of law.

The Coast Guard has also agreed to require the LNG carrier traffic to be conducted in such a manner as to minimize risk to the CCNPP(15,16).

These rules (Enclosure 1) are designed to protect the plant not only during routine LNG traffic, but also.in the event of potential accidents and p

malfunctions and the rapid advent of severe weather.

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3.3.2 Assessment of Hazard The above discussion indicates that a risk remains, although pro.iected LNG spill tests and proposed improvements in Coast Guard veasel

' control systems will reduce these uncertainties and the risk to the CCNPP.

In our interim.SE(I4) of the likelihood of the. hazard to CCNPP, we estimated that the likelihood of an unignited cloud reaching the facility was significantly less than one in one milli,on for as many as ten dockages and perhaps less than one in ten million. This SE considers up to 200 dockages per year.

As the result of further review, we have concluded that some factors assumed in our interim SE may have been overly conservative.

In particular, the frequency of major collisions at the dock is expected to be substan-tially lower tnan estimated in the March 13, 1978 SE because of the Coast 1650 253 L

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I Guard restrictions on all traffic near the tenninal,whenever an LNG carrier p.

is docked there and on available tugs during LNG carrier approaches and

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departures.

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I Other potential conservatisms in the estimates (reference 14) of the likelihood of a major release of LNG, include the applicability of general U.S. tanker accident statistics to the El Paso LNG carriers; the assumption that each serious accident leads to an instantaneous spill; and the _

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assumption that a large LNG spill has one chance in ten of not igniting at the ship.

However, events over which we have no control may tend to reduce the level of conservatism incorporated in the estimates.

For example, Coast Guard r

restrictions on other traffic in the vicinity of the CP0F may be ineffec-tive under the very conditions which may make collisions more likely (heavy fog). Also, LNG carriers of lesser capacity but poorer design than the El Paso LNG carriers may be employed at the tenninal over the life of CP0F. We have, therefore, not been able to quantify the lower probability with high confidence.

Furthennore, although the U. S. Coast Guard has agreed to restrict laden LNG carrier traffic to distances of

{c; at least 5 km from the CCNPP site and to adopt, with the effect of regula-tion, certain other LNG carrier practices as given in the enclosure to this SE, they are bound by law to act in the manner they deem safe in the event of unusual circumstances such as adverse weather or LNG carrier malfunction.

These actions may not always fall within the assumptions we have used in our estimate of the likelihood of a hazard. The U.S.

v Coast Guard has agreed to notify NRC of changes to its regulations and the LNG carrier practices which may affect CCNPP in as timely a manner 1650 254

as possible to permit NRC response, but unforeseen circumstances may require the Captain of the Port (C0TP) to make decisions on an imediate, p

basis which directly conflict with the NRC staff's view of safety relative to CCNPP.

We understand that shallow draft trials may be authorized by the Coast Guard with "unladen" LNG vessels carrying up to 4000 cubic meters of LNG in the vicinity of the CCNPP.

Such trials could present a hazard

.e e e.e me to the facility should they result in a spill of the ship's contents; within 2 to 3 km of the nuclear facilit'y. We have this matter under review and g.

a have requested the Coast Guard to reconsider their use of the waters off

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CCNPP for this purpose.

Although it is difficult to quantify the contribution that these Coast Guard provisions will make to the reduction of accident probabilities, we conclude that it will be sufficient so that the likelihood of a

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hazard to the CCNPP from an LNG spill in transit or at the dock at.CP0F E

is within the current NRC staff guidelines as described in Standard Review P1an 2.2.3.

In our interim evaluation we stated that anchorages much closer than 3 km could present a substantially higher hazard as any unignited plume released i t.-

would be much more likely to reach the nuclear facility.

As discussed in our interim evaluation all areat less than about 2 km and most areas less than 3km are not feasible anchorage locations because of shallow water near the plant.

We have discussed this matter with the Coast Guard and have obtained their agreement to assure that laden LNG carriers will 1650 255

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l not be allowed to approach closer to the CCNPP than is necessary and will

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be required to approach the Cove Point facility by the most direct route

7 that can be safely executed.

The Coast Guani has assured us that this h

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will effectively prevent anchorages north of the terminal and will assure that anchorages are greater than about Skm under foreseeable conditions.

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Under emergency conditions, the LNG carriers will attempt to maneuver so as not to be upwind of the nuclear plant or north of the tenninal. _We 1.

conclude that these conditions will provide reasonable assurance that i

anchorages near the plant will not occur.

However, unknown factors associated with operation of the LNG carriers,

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the behavior of a large LNG spill and the likelihood of the notification of an event are of sufficient concern that additional measures by the licensee are prudent to. assure that the response to a potential or actual spill of LNG in the vicinity of the CCNPP will be appmpriate.

Meetings woro bid on E y 30, 1978, with the licensee to discuss practicable j

measures which would increase our confidence in the detection of an unignited cloud of LNG.

The objective of these measures is to improve assurance of CCNPP being aware of an impending problem so that they may take appropriate

1 emergency actions.

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mr-We ' conclude that the development of contingency plans is a prudent step which will add setstantial confidence that the response to a potential or actual spill of LNG in the vicinity of the CCNPP is appropriate.

The details of the contingency plan are given on page 13.

The licensee has been requested and has agreed to submit the LNG contingency plan within 90 days.

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' l 4.0 Surrery We have concluded that, although the likelihood of an " instantaneous" I

LNG spill is very low, the BG&E staff should be prepared to effectively respond to conditions resulting from an LNG spill at or i

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near CP0F.

Therefore, we have asked for and BG&E has agreed to provide L

a contingency plan within 90 days,of the date of these amendments.

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LNG Contingency Plan will describe the steps to be taken to protect the l,["

facility from a serious LNG spill; including but not limited to: (a)

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description of the potential hazard, (b) prescrib'ed use of the comitted i':

telephone line between CCNPP and CPDF control rooms, including routine

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verification of operability,. and details of the comunications with the

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U. S. Coast Guard, (c) detailed procedure for determining the extent of the hazard, (d) directions for response necessary to protect the plant, such as 6

e control of ventilation systems, use of contained air systems and criteria y:

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for shutdown of operating units (e) comunication procedures of BG&E as

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required with Coast Guard, NRC, Maryland State, and local responsible

!M representatives including telephone numbers, (f) provisions for obtaining ix rapid response from offsite BG&E. personnel capable of assisting in plant i A@

t shutdown in a post-fire situation 6r providing assurance of the protection l

for on site personnel and equipm':nt, and (g) appropriate training require-l ments.

Development of the Contiagency Plan will include confirmation of the j

t feasibility of remote detection of unignited spills and, when determined j

feasible, provision of a schedule for installation of an appropriate device. A t 6 i :::

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description will also be provided of what additional provisions will be made to:

(a) shutdown both units safely and (b) maintain an ultimate heat L..

sink.

Incluue a schedule for implementation of the provisions of the p,; _ _,

t contingency plan.

Requirements for updating the contingency plan to reflect

"~2 current LNG traffic characteristics will be developed during review of the

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plan.

5.0 Environmental Consideration We have determined that th'is evaluation does not authorize a change in' effluent types or total amounts nor an increase in power level and will I

not result in any significant environmental impact.

Having made this

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detennination, we have further concluded that the action is insignificant from the standpoint of environmental impact and pursuant to 10 CFR

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651.5(d)(4) that an environmental impact statement or negative declaration and environmental impact appraisal need not be prepared.

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6.0 Conclusion t.-

We have concluded,' based on the considerations discussed above, that:

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(1) because the evaluation does not involve a significant increase in il.

the probability or consequences of accidents previously considered and does not involve a significant decrease in a safety margin, the action does not involve a significant hazards consideration, (2) there is reasonable assurance that the health and safety of the public will -

not be endangered by operation in _the proposed nanner, and (3) such activities will be conducted in compliance with the Commission's

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regulations and the action will not be inimical to the common defense and p.;.._.

security or to the health and safety of the public.

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m Dated: June 13, 1978 j

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REFERENCES 1.

NRC request for additional information concerning the LNG

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tenninal at Cove Point, O. D. Parr to J. W. Gore, December 5,1975.

2.

BG&E advises that the LNG investigation will be delayed, J. W. Gore

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to 0. D. Parr, December 23, 1975.

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BG&E submittal of Wesson and Associates report on investigation

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and literature survey to establish the hazard implication of LNG j

spills at the Columbia LNG Corporation, J.W. Gore to 0.D. Parr, March 15, 1976.

4.

NRC supplement No. 5 to' the SER for CCNPP Units Nos. I and 2, August 10, 1976.

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NRC issues license for CCNPP Unit No. 2-includes requirement for BG&E to provide probability analysis or Coast Guard administrative LNG carrier limits, August 13, 1976.

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6.

BG&E submittal of LNG hazards study, J.W. Gore to K. Kniel, December 31, 1976.

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NRC Amendment No. 20 for CCNPP Unit No. 1 - includes same requirement on LNG carriers as the Unit No. 2 license, D. L. Ziemann to A. E.

Lundvall, February ll,1977.

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8.

BG&E points out that they have met the license condition A. E.

M-Lundvall to D. K. Davis. October 19, 1977.

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NRC request for additional information on LNG hazard, D. K. Davis to A. E. Lundvall, November 9,1977.

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BG&E provides additional information on LNG hazard and correspondence s :

with the Coast Guard and Columbia LNG Corporation, A. E. Lundvall 1 :._..

to D. K. Davis, December 12, 1977.

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Maryland State provides information on the LNG carrier " dry run" and

.a copy of the Coast Guard LNG Oplan, S. M. Long to E. L. Conner,

{r February 17, 1978.

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NRC request for additional information on LNG traffic, R. W. Reid to A. E. Lundvall, February 22, 1978.

13.

BG&E provides additional information on LNG traffic A. E. Lundvall I2 to R. W. Reid, March 9, 1978.

14.

NRC issues interim SE on potential risks to CCNPP from LNG ship f5 traffic, R. W. Reid, to A. E. Lundvall, March 13, 1978.

15.

Letter, B, Grimes USNRC, to Captain k. Schumacher, U. S. Coast Guard, May 31, 1978.

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Letter, Captain K. Schumacher, U. S. Coast Guard to B. Grires USNR,C, June 8,1978.

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Letter, R. L. Mitti, Public Electric and Gas Services to A. Giambusso, September 30, 1974.

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[aate UNITED STATES

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- NUCLEAR REGULATORY COMMISSION ';

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Hay 31, 1978 l'

.c Dockets Hos. 50-317 h

and 50-318 lj R

u Captain Keith B. Schumacher

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Captain of the Port of Baltimore U. S. Custcm House Bal timore,. J'aryl and 21202 3

Dear Captain Schumacher:

This is to request your assistance in assuring the safety of the Calvert Cliffs Nuclear Power Plant (CC11PP) from any ha:ard resulting from an

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e accident of a LNG carrier at or near the Cove Point Of fshore Facility (CP0F) operated by Columbia LHG Corporation.

We appreciate the direct communication you have afforded us on this subject in meetings held at your office on April 1 and May 18, 1978.

Although our safety evaluation is not complete, our review to date t

indicates that the approach of a laden L!iG carrier closer than about 5 K= to CCNPP results in a potential unacceptable level of risk.

There-fore, we request that you as the Captain of the Port (C0TP), impose the six LNG Practices, contained in the enclosure to this letter, on the LNG carriers. These practices are essentially the product of our t

May 18, 1978 discussions.

We understand that these LMG practices may be modified by the COTP in r

an urgent situation when sucn action is necessary in the interest of F

LNG carrier safety.

We request that the Coast Guard notify the !!RC Division of Operating Reactors project manager for CCNPP or DOR duty

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officer as soon as practical in such cases.

These individuals can ce reached at any time through our central switchocard, telephone numoer (301) 492-7000.

Baltimore Gas and Electric nas received a tentative commitment frca Columbia LNG Corporation to be notified of any L!iG release. At the May 18, 1978 meeting we discusseo the possioility of the Coast Guard also notifying the CCNPP control rocn in tne case of any release as E

a backup. The norcal contact woulu ce the Snif t Sucervisor, telechone

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number (301) 234-7932.

Ee recuest that such notification be inclucee in the apprcpriate Coast Guarc procacure.

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i LNG carriers t: perforr.

We also request that you reconsider al. ow ng anyWe believe that other : arts of shallow water maneuvers close to CCNPP.

the Chesapeake Bay sitould be equally suitable for training caneuvers without affecting the assessed risk for CCNPP.

y' It is our intention to address your reply to this letter in our Safety 13, 1978.

If you have questions Evaluation due to be corcpleted by June on this subject, please ccntact R. W. Reid or E. L. Conner, of Our staff, s

at (301) 492-7435.

Sincerely, c

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Brian K. Grimes, Assistant Director for Engineering and Projects

. Division of Operating Reactors

Enclosure:

LNG Practices cc: See next page b'

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cc:

James A. Biddison, Jr.

General Counsel

~n G and E Building j

Charles Center Baltimore, Maryland 21203 g..

George F. Trowbridge, Esquire

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Shaw, Pittman, Potts and Trowbridge 1800 H Street, H.'J.

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Washington, D. C.

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.Mr. R. C. L. 01 son Baltimore ~ Gas and Electric Company Room 922 - G and E Building Post Office Box 1475 p

t-Baltimore, Maryland 21203 Mr. R. fl. Douglass, Chief Engineer Calvert Cliffs !!uclear Power Plant Balticore Gas and Electric Company Lusby, itaryland 20657 Bechtel Power Corporation ATTN: fir. J. C. Juod Chief Nuclear Engineer 15740 Shady Grove Road Gaithersburg, Maryland 20760 Combustion Engineering, Inc.

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ATTN: !!r. P. W. Kruse, itanager Engineering Services Post Office Box.500 Windsor, Connecticut 06095 Calvert County Library Prince Frederick, riaryland 20678 l1

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ENCLOSURE LNG Practices LNG carriers should not approach the CP0F unless weather conditions 4---

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are within limits set by the COTP (Chesapeake Bay Oplan III-B) for moving LNG carriers.

The conditions for safe transfer of cargo must be expected to fall within the Oplan limits.

Laden LNG carriers

• should not approach closer to the CCNPP than is 2.

necessary and should approach CP0F by the most direct route that can be sat ly executed.

While laden, LNG carriers shoul'd not attempt to moor to the CP0F -

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unless assisted by tugs of a size and number deemed appropriate by the COTP for a safe docking, consistent with weather and tide E.:

conditions.

While laden LNG carriers are moored at the CP0F, tugs or other p.._

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p assistant craft should be available to carry out actions proposed E

in the El Paso Emergency Plan.

In the event of an emergency disconnect or if a situation occurs

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when a LNG carrier must depart the CP0F with equipment operating E

at less thsn 100% operability, the LNG carrier shall attempt to maneuver so as not to be upwind of the CCNPP, allowing for extraordinary weather and tidal conditions and other accepted p+

safety practices.

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The COTP will not change any of its regulations affecting the 6.

interaction between the CP0F and CCNPP without attempting to notify p

the NRC and allowing a reasonable time for response consistent with the interest of nuclear safety.

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• A " laden LNG carrier" is defined as any carrier containing more than p[j 4000 cubic meters of LNG.

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s DEPARTMENT OF TRANSPORTATION e,,

UNITED STATES COA'ST GUARD commanding Ofi'icer i

U. S. Coast. Guard Marine Safety Office Custom House

• Baltimore, MD 21202 i

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i 16611 8 June 1578 1a.

U. S. Nuclear Regulatory Comission E....

Division of Operating Reactors E

i Attention Brian K. Grimes, Assistant Director for Digineering and Projects Washington, DC 20555

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Gentlemen:

In reply to your letter of May 31, 1978, I am agreeable to the " LNG Practices" enclosed with your letter and will follow the six practices covered. The first five of these practices are already covered in E

operations plans or contingency plans. The sixth, which is notifica-tion to your agency of any change will be incorporated in our documents.

For any modification of these practices in an urgent situation, our OPLAN calls for notifying you. We have noted the telephone immbers which you furniched in ;/our letter.

~~~

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~- H Captain, U. S. Coast Guard Captain of the Port

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n HOUSE OF DELEGATES ANNAPOLIS, MARYLANo 21401 GERALD W. WINEGR AD DELEGATION ADDRESS:

DISTRICT 30 5 212 HOUSE OFFICE BUILDING ANNE ARUNDEL COUNTY ANNAPOLIS. M ARYLAND 21401 ENVIRONMENTAL MATTERS 269 3262 269 3264 COM M RTEE HOME ADDRESS:

1428 CATLYN PLACE ANNAPOLIS. MARYLAND 21401 November 6,1979 2867425 Joseph M.

Hendrie Chairman Nuclear Regulatory Commission Washington, D.C.

20555

Dear Mr. Hendrie:

Your assistance in evaluating the enclosed materials relating to the radiological impact of the operation of the Calvert Cliffs Nuclear Power Plant is earnestly solicited.

The enclosed compilation of findings is taken from t'.e November 1978 " Power Plant Cumulative Environmental Impact Report" of the Maryland Power Plant Siting Program.

In addition to your overall evalue. ion of the degree and type cf radioactive releases into the water-of the Chesapeake Bay and the atmosphere it would be most '. 21pful if you could answer the following questions:

1.

In 1976, BG&E predicted amounts of only 19 radio-active elements entering the Eay as liquid effluents.

Through December 1977 at least 48 such elements were identified.

Is this cause for concern?

2.

Of the 19 predicted liquid radioactive effluents,

~BG&E's cumulative predictions through December 1977 were frequently underestimated by factors of at least 10 and in the case of Cr-51 the estimatas were off by a factor of over 9,000.

Is this cause for concern?

3.

Has. adequate research heen done to assess the long term impacts of the radiation releases, such as tritium, into the waters of the Chesapeake Bay?

What about the cumulative impact on such organisms as oysters and the people who may eat them?

4.

Is the release of the liquid radicactive effluents "as low as is reasonablv achievable" as required?

1650 267

.c A__ - g df _ e

5.

Storm water runoff samples at the Calvert Cliffs plant have contained these radioactive isotopes:

Co-60, Co-58, Mn-54, Cx-134, and Cs-137.

Is this cause for concern?

6.

Ag-110m has been found in oysters six miles from the plant.

This isotope was not one of the pre-dicted liquid effluents.

Is this concentration of Ag-110m in sediments and oysters near and as far as six miles from the plant cause for concern?

7.

Can you comment on the analysis on page IV-19 and the chart at Page IV-21 that Ag-110m, Co-58 and Co-60 doses found in oysters near the plant produce risk levels when eaten by humans that "are minuscule compared to the normal risk levels.

..of the U.S. population today"?

8.

BG&E predicted 18 radioactive isotopes in varying amounts would be released to the atmosphere.

However, 45 such isotopes, some at much higher rates than predicted, have been released.

Are these f ailures to predict and under-predictions cause for concern?

9.

Generating Unit 2 began commercial operation on April 1, 1977 so that the cumulative impact measured in the enclosed report only includes Unit 2's impact for nine months.

Are you satisfied t'..ar the accuracy of predictions and impacts of cumu -

lative discharges are and will be within safe limits?

10.

BG&E has recently applied for authorization to nearly double its storage of spent fuel rods.

Is this long term storage, perhaps into the 1990's, cause for concern?

11.

Are you convinced that the airborne and liquid ef fluent discharges from the Calvert Cliffs plant present no threat to human health or safety?

12.

Can you comment en the potential for serious calamity given the nearness to Calvert Cliffs of the Cove Point Liquid Natural Gas facility?

I am a member of the House Environmental Matters Committee.

This committee reviews legislation involving the operating of the Calvert Cliffs facility.

Your comments and answers will great 1y aid me in my legislative work.

1650 268 Thank you for your attention to this matter.

S'ncerelv, Y

I ff Gerald W. Wineg,r d GWW/pb C

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