ML19290D210

Provides Subcommittee on Nuclear Regulation W/Comments on Draft Rept, Some Long-Term Consequences of Hypothetical Major Releases of Radioactivity to Atmosphere from TMI, in Response to 791102 Request

ML19290D210
Person / Time
Issue date:	01/21/1980
From:	Ahearne J NRC COMMISSION (OCM)
To:	Hart G SENATE, ENVIRONMENT & PUBLIC WORKS
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ML19290D211	List: ML19290D210 ML19290D214
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NUDOCS 8002200371
Download: ML19290D210 (4)

Text

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RWHouston C!'ull er The Honorable Gary Hart, Chairman Jeanne Cook Sd:crittee or.':uclear Re;ulati' SECY-79-3015 Crittee on Environment anc Pur

. Works CA United States Senate Washington, D. C.

20510

Dear Mr. Chairman:

In your letter dated November 2,1979, you requested our assessment of a draft report entitled "Some Long-Term Consequences of Hypothetical Major Releases of Radioactivity to the Atmosphere from Three Mile Island" by Jan Seyea and Frank von Hippel.

Earlier the NRC staf # provided brief comments on this report to W. James J. MacKenzie, a staf# member of :ne Council on En,ironmental Cuality, and a copy of that response is enclosed.

.e find that the study's calculations are presented in a clear anc straight-forward manner.

The consequences model is generally similar to models employed by the NRC staff, althougn there are differences in many details.

Clearly tne most significant assumptions are the accident release scenarios that are hycothesized and it is these, ratner thar. the details cf consecuence modeling, which tenc to dictate tne general nature of tne results of the consequence calculations.

The fact that there is an increased risk of healtn effects at substantial distances from a nuclear power plant, assuming the occurrence of a serious release of radioactive materials into the atma-sphere, is well known and follows directly from nunerous studies that have been published, e.g., the Reacto Safety Study (MSH-1400).

Reoresentations of oossible radiation dose levels at distances out to a few huncred miles from a plant, assuming serious releases, are exolicitly given i:: a joint GRC/ EPA Task Force Report, NUREG-0396, " Planning Easis for the Development of State and Local Government Radiological Emerger.cy Response Plans In Support of Light Water Nuclear Power Plants" whicn was publisned in November 1978.

Ors. Beyea and von Hippel have not addressed accicent probabilities in their report.

The Risk Assessment Review Group, NUREG/CR-0400, of which Dr. von Hippel was a member, highlighted the importance of the use of relative probabili ty perspective.

Without the relative orcbability perspective, the

" worst case" accident cominates all others.

It therefore follows that Ors. Beyea and von Hippel primarily draw their conciusions basec upon the results of the " worst case" accident scenario (TMI-2'.

It is important to note tnat relative probabilities were useo in tne rationale for ne emergency plar.Hn; :one cistan:es of 10 anc 50 miles civen in cJREG-0396.

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The Ho^orable Gary Hart With respect to the major conclusions of the draft report (p.3), we have the following comments:

1.

We agree that long term health impacts from major releases of radioactivity in reactor accidents could affect larger numbers of people at larger distances than the short term consecuences whicn can :e reducec by timely evacuation-We agree that, if long lived radioactive materials such as cesium and strontium nuclides were to be broadcast over large distances, tnere would be a concern for the resultant land contamination and if decontamination were not successful this could last for decades.

2.

Whether emergency planning which focuses on areas close to nuclear power plants, even out to 50 miles, is sufficient or not is a significant public policy ouestion.

Tne NRC has recently published in the Federal Recister (Octcoer 23,1979) a statement of policy tnat encorses guidance contained in tne aforementioned NRC/ EPA Task Force report.

This guidance recommends tnat State and local governments establish Emargency Planning Zones arounc each nuclear power plant, extending to approximately ten miles radius for the airborne piume exposure pathway and to about 50 miles radius for tne ingestion pathway.

The policy statement notes that implementation of this guidance is needed to improve emergency response planning and preparedness around nuclear power reactors.

It also calls attention to rulemaking in progress on the matter of emergency planning and preparedness.

The Commission has, in its Advance Notice of Proposed Rulemaking published on July 17, 1979, requested public comment on these matters anc will continue to seek the widest possible public input during the rulemaking process.

We look forward, therefore, to the final report of Drs. Beyea and von Hippel, as well as the results of peer review thereof as inputs to this process.

3.

The draft report recommends that research cn decontaminaticn of ground anc buildings contaminated with long lived radioactive cesium should be given high priority.

The report itself does not address what is already well known and has been studied on this subject.

It would be helpful in giving consideration to tnis rucommendation if the authors could be more explicit as to what kinds of research efforts tney believe are yet neeced.

It snould alsc be noted in passing that the exoerience to ce gained in tne cleaning and cecontamination of ;he Three Shie Isianc-2 faci;ity should orovide adcitional valuable insient intc this matter.

The Honorable Gary Hart The draft report also notes that its results shculd motivate improvements in safety related design and calls particular atten-tion to the concept of filtered vented containment.

This concept falls within the scope of recommendatiens recently mace to us by members of the NRC staff in NUREG-0585, "TMI-2 Lessons Learned Task Force Final Report", as well as within the scope of the recommendation of the President's Commission on the Accident at Tnree **ile Island for the NRC "to incluce, as part of its licens-ing requirements, olans for the mitigation of the consecuences of accidents,...". The NRC staff and contractors are currently investigating the feasibility and risk reduction potential of filtered vented containment and of other safety features designed to mitigate the consequences of core melt accicents. A parallel investigation is being performed by the operators of Indian Point Units 2 and 3, and Zion Units 1 and 2.

The results of these studies will be compared in March 1980 to determine a strategy toward the implementation of mitigating systems.

If the Commis-sion decides to proceed with the proposed rulemaking as suggested in NUREG-0585, we will ask Drs. Beyea and von Hippel to give us the benefit of their expertise and in responding to the types of questions that the Lessens Learned Task Corce has suggested be published for public comment.

You also asked that we respond to four specific questions, as follows:

Q.

What do you view as the colicy implications of the results of the subject paper, especially with respect to the Commission's ongoing consideration of whether to include Class 9 accidents in the licensing of nuclear power plants?

A.

Assuming the results of the paper are not significantly modified wnen issued as a final report and tha they are sustained during peer review of the report, it is clear that some weight must be given to the judgments and conclusions therein as we proceed to the final stages of the emergency planning and preparecness rulemaking proceeding noted above.

In this connection, however, we must take cognizance of the fact that, as the draft report itself notes, "this report focuses on tne consecuences of releases of radioactivity from a reactor accident.

Their probability is a separate (although equally important) subject whicn is net addressed quantitatively here." Given the stated assumptions, the conse-ouences are not inconsistent with the consecuences published in the Reactor Safety Study for the very low probacility events.

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It:antion a - a i /E?A Task Brce finding that "These margency planning) ;istancas are consicerad larg3 encugn :o ;r; vide i response base..hich would support activities outside.ne planning

ene should this ever be needed."

Q.

'ihat types cf accidents might lead to cor.:ideration of emergency measures at uch distances?

A.

The types cf accidents that m1pt leac to consideratica of 2r.ergency reasures at su:n di:tances, i.e., beyond SO miles, would be a rc-scheric relea:2: # rom core melt-containment failure accidents.

Q.

.. hat is the cost-effectiveness of the use of thyroid-blocking agents?

A.

The MF.C is now evaluating the results of a study by Sandia Labcratories of the use of potassium iodide as a blocking agent, which addresses the cc ts, risks, and benefits of this use.

'.ie will be able to provide you a more specific answer to this question after this evaluation has been completed. The use of potassium iodide as a thyroid blocking agent is an appropriate part of any ccmplete radiological energency preparedness plan. There remains the question of the extent to which it can be used effectively during nuclear emergencies.

The staff is concerned that potassium iodide is only effective if taken shortly before or after radioicdine intake and that it protects only the thyroid, whercas other orotec-tive actions (e.g., evacuation, staying indoors) could provice protection for all organs.

In many instances these other actions could be carried out sooner and possibly more easily than wide.

spread distribution of potassium iodide. However, the staff believes that potassium fodide should be used at places where institutional controls can be maintained for extended periods of time (e.g., reactor control rooms, hospitals, fails, etc.).

Sincerely, Cleared wi h all Cmes' Offices t

by SECY C/R. Typeo in final in SECY C/R to incorporate Cmr.

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Enclosure:

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The Honorable Gary Hart, Chairman Subcommittee on Nuclear Regulation Comittee on Environment and Public Works United States Senate Washington, D. C.

20510

Dear Mr. Chainnan:

In your letter dated November 2,1979 you requested our assessment of a draft report entitled "Some Long-Term Consequences of Hypothetical flajor Releases of Radioactivity to the Atmosphere from Three Mile Island" by Jan Beyea and Frank von Hippel.

Earlier the NRC staff provided brief comments on this report to Mr. James J. tiacKenzie, a staff member of the Council on Environmental Quality, and a copy of that response is enclosed.

We find that the study's calculations are presented in a clear and straight forward manner. The consequence model is generally similar to models employed by the NRC staff although there are differences in

-m m certairi details. Clearly the most significant assumptions are the

.4n#.atrc phcric release scenarios that are hypothesized and it is these, rather than the details of consequence modeling, which tend to dictate the general nature of the results of the consequence calculations.

The fact that there is an increased risk of health effects at substantial distances f.om a nuclear power plant, assuming the occurrence of a serious release of radioactive materials into the atmosphere, is well known and rollcws directly from numerous studies that have been published, e.g., the Reactor Safety Study (WASH-1400).

Representations of possible radiation dose levels at distances out to a few hundred miles from a plant, assuming serious releases, are explicitly given in a joint NRC/ EPA Task Force Report, NUREG-0396, " Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans In Support of Light Water Nuclear Power Plants" which was published in IdSG.Thovember 1978.

N With respect to the major conclusions of the draft report (p.3), we have the following comments:

1.

We agree that long term health impacts from major releases of radioactivity in reactor accidents could affect larger numbers of people at larger distances than the short term consequences which can be reduced by timely evacuation. We agree that, if long live radioactive materials such as cesium and strontium nuclides were to be broadcast over large distances, there would be a concern for the resultant land contamination and if decontamination were not successful this could last for decades.

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11/28/79 SE Drs. Beyea and Von Hippel have not addressed accident probabilities in their report., Risk Assessment Review Group, NUREG/CR-0400, of which Dr. Von Hippel was a member, highlighted the importance of the u.'.e of v.JA dsa._ymp74 hc;,um ~ y relative probability perspective,Nthe "wo'rst case" accident dominates all others.

It therefore follows that Drs. Beyea and Von Hipple primarily draw their conclusions based upon the results of their

" worst case" accident scenario (TMI-5).

It is important to note that relative probabilities were used in the rationale for the emergency 5

planning zone distance cf 10 and 50 miles given in NUREG-0396.

Decisionscannotbebasedsoldyontheabsoluteconsequencesof the worst hypothetical accidents.

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T*:a draf t rport aisa notus i at its.x.sults shculd rotivate i pcon ants in safety rein.:d :,:ign and calls particular it' :ntion

'.o a car.c ist of a fil;.c.cr.d vented ccataic.lant.

inis concapt llis within the <ccia uf.mcc :ndations recently aada to us by.rciars of the MC staf f in.UAEG-0535, "iMI-2 Lassons Learned Task Force Fir.al Report", as well as within the scope of the reco!rc.cndation of the President's Cc:miission on the accident at Three Mile Island for the NRC "to include, as part of its licansing requirexnts, plans for the mitigation of tha consaquancas of accidents,...".

If the Cc;alission d,.

'.; 10 proc ad with the propesad rulcmaking as suggestad in NUREG-0585, I wculd hope that Ors. Cayea and von Hippel would give us the benefit of their expertise in responding to the types of questicns that the Lessons Learned Task Force has suggestmi be published for public cc.nient.

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The Hoccrible Gary Hart ':u 11:o n%2d that.e r!s. sand to four specific questions, as follu.:s:

Q.

' hat do you view as the Policy inplications of de results of the subject Japer, especially with raspect to the Cconission's ongoing considanticn of thether r.o include Class 9 accidvs in the licensing of nuclear po.ser plants?

A.

Asswing the results of the paper are not significantly c.cdified.han issued as a Anal rr: ort, it is clear that scle

'eight.ust c' e given to the judrments and conclusions therein as tea procead to the final stap of the e acrgcacy planning and preparedness culemaking proceeding noted %cve.

In this connaction, hcc.ever, i.e must take cognizance of the fact t:nt, as the draft report itself notes, "this re, cort fccuses ca t'.a consegna cas of releases of ndioictivity fec.n a ecx tor ic~c~i d3 n t.

Their probability is a separate (although Onlly important) subject..hich is not addressed cuantita tively 4

here".

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To what exten[ does TGC consiuer cmargency iceasures out to 50 [

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.niles and beycnd for a nuclear reactor accident?

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A.

As noted in the discussion under 2. above, the current prima M

consideration is the adaquacy of caergency neasures out to MM about 50 miles.

Our policy state.aent issued in October, however, called attention to the l2C/ EPA Task Force finding that "These (emergency planning) distances are considered large enough to provide a respcase base which would support activities outside the planning zone should this ever be needed".

Q.

'dhat types of accidents might lead to consideration of emergaacy measures at such distances?

A.

The types of accidents that..ight lead to consideration of emergency measures at such distances, i.e., beyond 50 miles, i.culd be atmospheric releases from core melt-containment failure accidents.^xf ~; in :ci^c L.x;

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wosM b; woij to-injee t-ho. a wt'37Finto thrat-os phere ts wnsiderabie 41.4 LudPs-and in stifficicirtty--finely-divided (particuhth)- form-to-peratit them to -be-carried-such-Icng.

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The %C is currently studying tha cost c:f f. c.tvanass or the use of patassicu iadida (KI) in tablet form for broad sc11e d i s tr i b u t io n to Lae ::c bl ic i n.ae e'. ca t o f ++--w+:LLo ul ukas+ uk, i ' '

e.ot-y.,+.-i e es-.,i-r+hhni oe.

Tha. ;ults of,.ais study ara a,;ac t 2d to 'n r.'iilc bla by caa cad of calendar 1979.

The GC is <.cordinating with che F.:od.nd Drug

'.abinis tra tion on this altar.

Sincerely,

,?a s.;h M. l!a nd r i e, C h i r:'.a n U.S. Nuclear P :;ula tory Cc...aiss ion

Enclosure:

1.

Copy of Ltr. sent to J.J. PacKanzie cc:

Sen. '.lan Si g son li L e M _bIf5)IIfS

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UNITED STATES NUCLEAR REGULATORY COMMISSION 1 o

E WASHING TON. D. C. 20555

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.g' s-OCT 9 1979 i

Mr. James J. MacKen:ie Senior Staff Member for Energy Executive Office of the President Council en Environmental Quality 722 Jackson Place, N. W.

Washing cn, D. C.

2CC06

Dear Mr. MacKen-ie:

I am pleascd to transmit to you a few brief comments on the draf t rep;rt "Some Leng-Ter,m Cc'nsequences of Hyp:the:ical Major Peieases of 'iadio-a ivity to the Atmosphere from Three ",ile Island", pre:ared for the Council en Environmen.tal Quality by Drs. Seyea and von Hi:pel.

In :he time available we have not had the cpp:rtunity to conduct an exhaustive technical review and are therefore unable to confirm the accuracy or validity of quantitative results of tne calculations performed by the

?rince: n grou'p. Following are our ccc ents:

1.

Although the autners refrained from undertaking a cuantitative approach to tne probability of release questions asse:iated with each hypotnetical scenario, some qualitative ciscussi0n of plausible or credible circumstances which might have to Occur to produce such releases would be helpful to place the scenarios into perspe::ive.

It would be relevant :: discuss why significant quantities of the radioicdines and cesiums did not escape into the environment in the actual TMI at:ident, in 11gnt of the fact that such a significant part of the reactor ccre was subjected to considerable damage.

2'.

The language throughout the report used to characterize the consequences of low level raciation exposure could likely be underst:0d by a lay reader as meaning that the indicated health effe::s v.Ould be the certain :cnse:uences of the DUPLICATE DOCUMENT Entire document previously entered into system under:

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No. of pages: