ML19261A296
| ML19261A296 | |
| Person / Time | |
|---|---|
| Issue date: | 11/22/1978 |
| From: | Costello J, Hale C, Jerrica Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19261A293 | List: |
| References | |
| REF-QA-99900403 NUDOCS 7901050107 | |
| Download: ML19261A296 (24) | |
Text
16 o
ccmputation of the LPZ and PCD.
The Appeal Board, however, 1j simply ccmputed these areas, ascertained that the dose 1
limits would be met and ended its inquiry there.
The Appeal
,I Eoard wrote cut as irrelevant to the regulation the health and safety consequences of "an accident to persons bevond 1
I the LP2.
]
These consequences will be severe.
In the evidentiary hearings NECNP, follcwing the guidelines of the NRC Staff, ii conservatively calculated that an acciden at Seabrcck wculd result in pcpulation exposures in excess of acceptable 3
A levels.
SECNP also off ered testi=cny en the health ef fects
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which could reascnably be ass'med to result frca exposures u
to the public at the calculated levels.
With a populat, ion
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of the size projected for Seabrock in such c1cse proximity to the plant, a conservatively calculated acciden: at the Seabrcok plant will cause 60-70 deaths,90-100 generic i
effects (congenital defects), 60-70 ncn-fatal cancers and ISO-250 cases of thyroid cancer.
Tr. 2688-89, Cert. Rec.,
J Vol. 10, page 4700; Staff Testimeny post 4404, T able 1;
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Cert. Rec., Vol 39, page 18064; NECNP Ex. No.
6, Cert. Rec.,
a Vol 38, page 17732. 4_/
1i J
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The actual censecuences will be nore severe since the numbers of people used in the calculaticns assumed the exis-1 tence of an evacuation plan for removing pecple frem the site area.
In ALAB 390, the Appeal Board held that no evacuation plan is required by the NRC's regulaticns for
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areas curside of the LPC.
5 NRC 733 (1977), Cert., Rec.,
Vol., 73, page 38162.
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17 An obvious example of the agency's refusal to fully examine the population issue is the fact that the health and I
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safetv disadvantages of the Seabrook site were ignored when i
it was cc= pared to alternatives.
Part of the 1cng standing Staf f practice in evaluating sires and implementing the requirement of 10 CFR S100.11(c) (3) to recuire in-depth analys1s c:. asternative sites where is j
populaticn density in excess of 500 perscas per squarc m.Lles exists cumulatively at any point up to 50 miles frc= the site.
(Staf f Testincny, pos: 4403,
- c. c. 2-3: Cert. Rec., Vol.
ij 39, page 18064; Tr. 4411-12, 4414-15; Cert. Rec., Vol. 29, cac.e 18064.)
Seabrook has in excess of 500 ersons c.er r
scuare mile within 10 miles of the site and cut to.50 miles frca the site.
NECNP Ex. No. 11, Cert. Rec., Vol. 38, page 17732; Tr. 4451-52, Tr. 4473-74, 4477, cert. Rec., Vol. 39, pace 18064.
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In evaluating alternate sites, the Staff located several which were generally acceptable for a reactor and.which had I
pcpulatien densities less than Seabrcok, Tr. 10301-10303, Cert. Rec., Vol. 53, page 25360, and thus, a lower risk of adverse consequences to the public health and safety.
Tr.
1j 44401, Cert. Rec., Vol. 39, page 18064.
Ecwever, the Staff did not quantify any econcaic or health value of the lcwer i,
populaticn densities of the alternate sites, Tr. 10346-
^
10350, 10361, Cert. Rec., Vol. 53, page 25360, even though it claimed to de a mini-cost benefit comparisen of sites, Tr.
10328, Cert. Rec., Vol. 53, page 25360.
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The Licensing Board refused to allow an exa=ination into the possible use of the man-rem 5/ cost of. 51,000 utilized in evaluations of what radiaticn releases are "as icw as reasonably achievable" in normal reacter cperation.
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Tr. 10352-358, Cert. Rec., Vol. 53, page 25360.
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In the licensing proceedings NECNP performed the simple J
calculations which showed Seabrock to be not only the wors:
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the worst cost site as well. It showed, for example, that
<a if the pcpulatica density for the Mccre's Pcnd site is assumed to be 37 person per square mile within five miles cf the plant, Tr. 10327, Cert. Rec., Vol. 53, page 25360, and the population density for Seabrock is assumed to be 1
3 0,000 within five miles, NECNP Ex. No. 12, pp. 10-11, Cert.
.t Rec., Vol. 38, page 17732, in the event of a 10 CTR Part 100 accident resulting in a 3 rem exposure to every person at each site (which is the calculated dose at 1.75 miles 3
I frcm Seabrock where the bulk of the populaticn will be I,
after two hours, Table I,
-cost Tr. 4404; A c c. l i c. Readwav.
b Netwcrk and Ivac. Study, Cert. Rec., Vol. 39, page 18064)
}i the cost of "ocre 's Pcnd would be less than $9,000,000 and the cost of Seabrcok would be S90,000,000.
i The National Environmental Policy Act calls fer an assessment cf all the ccsts and benefits of a preposed federal acticn.
Calver: Cliffs Coordinatinc Cc=nittee v.
i 1
5/
A man-rem is a measure of the dose of radiation received 57 cne persen in terms of its estimated biolegical effect relative to a dcse of one rcentgen of X-ravs.
The man-rem 6
cost is an attemet to cuantify the cost of exr. osinc. the public to radiation.
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il AEC, 449 F.2d 409.
Health consequences to me=bers of the
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public ought to have a prominent place in any cost-benefit S
4 balance struck for a nuclear power plant.
At Seabrook the risk of ublic exe.csure to radiation makes the site unaccep-r
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table.
3.
P art 100 was intended to encourage the
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e with engineered safeguards as a secondary prcrecticn.
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3509) included the N
with the regulation in 1962 (27 Fed. Rec.
following statements:
J3 1.
In connection with the Cc =issicn's intended 1ssuance c:. numerica_3 sitanc c.ulces, 6 1
is statec
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test reacters away frem densely pcpulated centers.' 2. Further, since accidents of greater potential hazarc : nan tncse cc=menly postula:ed as representing an upper limit are conce var _,e, altncuen .w.a c.. _, v w 1.7 t = o. r e c a r l e, 1: was censicerec cesiracle to provide
- cr prctecnicn against excessive deses to pecple in large centers, where effective protective measures might not be feasible Hence, the pcpulaticn jB center distance was added as a site requirement when it was fcund for several projects evaluated that the srecificaticn of such a distance requirement IN wculd'arrreximatelv fulfill the desired objectives anc reflec a =cre accurate c.ulce to curren: s ininc.
eractice. __ e _/ At this time, the AEC apparently planned to issue nu=eri-6 cal siting criteria. No such criteria have been prcmulgated to date. j
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_..c _4 c c-e s .". e e' r C ' s _4.. e.. -.'. a. '.k.. e _- a_ c " _' _= - e+ / 2 tion reflect the possibility of the cccurrence of an accident more severe than ene generally restulated and representing n t.a the maximum crecible accident. -en
20 } }- 3. To the extent possible, AEC review of the land uce aurrounding a proposed -ite includes con-siderations of potential residential grow-" mhe guices tenc toward recuiring su.::.c'ent 1 solation c to preclude any imnediate problem. The Cenmission also stated that it had inadecuate know-j- + ledge to provide clear siging criteria, and that it would = "give further study to the subject," in part to determine, on the basis of the oc.eratinc. ex erience to be acc.uired, ) er n-tzve asis :cr weigning tn.e ef:.ec veness or-s ,,a =cre c. 1 engineered safeguards versus pla..: isola:icn as a public 3 safeguard." j The Ccnmissicn has never published any "further study," and has never substantially revised Par: 100, which is des-t cribed in 5100.l(b) as an " interim guide" for use "in approving } cr disappreving proposed sites." The burden remains en the Licensing 3 cards to apply this interim guide in a rational ar,d flexible way. p i, 1_ E A. P e e a_ J_ ,1 =}}