ML19303A298

Comments Negatively on Des.Environ Dose Estimate Calculation Disputed.Cumulative Effects Are Unavoidable & Should Be Accounted for

ML19303A298
Person / Time
Site:	Callaway
Issue date:	11/30/1981
From:	Chovan K AFFILIATION NOT ASSIGNED
To:	Office of Nuclear Reactor Regulation
References
RTR-NUREG-0813, RTR-NUREG-813 NUDOCS 8112040544
Download: ML19303A298 (3)

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ENCLOSURE 2 i

ACCIDENT EVALUATION BRANCH RESPONSE TO COMMENTS ON DES FOR CALLAWAY.

REED #5 Table 5.5 on page 5-36 of the DES gives the inventory of radionuclides including the significant daughter products of Kryptons and Xenons. 3 Daughter products of noble gases released to the atmosphere are not '

significant contributors to the environmental impacts and are neglected. [

REED #6 Section 5.9.4 deals with the environmental impacts of accidents only.

The Emergency Preparedness for Callaway is discussed.in the Appendix '

F to the staff's Safety Evaluation Report.

REED #7 Although the staff's analysis of the severe acr.ident risks in the .

Section 5.9.4 is based upon the methodology of the Reactor Safety Study (RSS),theprobabilities and the release fraction information was y rebaselined as discussed in Appendix E and takes into account the '

comments made on RSS.

' REED #8 Staff's judgement that "it is more likely that the calculated results are overestimates of the consequences rather than underestimates" is I based on the fact that the uncertainties in the values of the para-meters used in the analysis are overcome by conservative assumptions.

REED #9 Staff disagrees with this comment. Staff's analysis of the probabilistic risk of severe accidents is a detailed analysis. Staff has also pre-sented a detailed plan for E~ercency Preparedness in Appendix F of the Safety Evaluation Report. '

REED #10 Enrico Fermi Atomic Power Plant Unit No.1 was a Sodium Cooled fast  :

breeder demonstration reactor, and is not to be confused with Enrico '

Fermi Atomic Power Plant Unit No. 2,which is a light water reactor currently undergoing a review for an operating license. The statement '

regarding Fermi Unit 1 reaching full power and completing all phases (

of its original mission is referen' in the Oak Ridge National Laboratory Report ORNL/NSIC - 176, m ed April 1980.

EPA #3 The design basis accidents (DBAs) are pastulated for the purpose of i the design of the reactor safety systems. They are judged not to be significant contributors to the risks since the safety systems have been designed to mitigate the consequences of such accidents.

Therefore, these (DBAs) accidents have not been subjected to the same level of probabilistic analysis as the more severe accidents analyzed in the DES.

SANDLER #1 Section 5.9.4.5 does .ot conclude that all accidents are unlikely to '

occur. It states "These (environmental) impacts could be severe, but the likelihood of their occurrence is judged to be small." The NRC regulations require the reporting of unusual occurrences as Licensee Event Reports (LERs). Very few of these LERs report any environmental consequences. Large numbers of LERs do not mean that the probabilities of accidents with severe environmental impacts are high.

.. ..-- . . . - ~ . ... . .-- -

SANDLER #2 The paragraph referred to in this comment recognizes that fission products in excess of 100,000 Curies were released, and primarily  :

consisted of Xenons and Kryptons. Third paragraph on page 5-38 ,

quantifies the population exposures, resulting from release of radioactive material following the accident at Three Mile Island,- '

to range from 1000 to 3000 person rems.

SANDLER #3 Incidents mentioned in the comment refer to the accidents of moder- .

ate frequency.."i.e., events that can reasonably be expected to occur during a year of operation." The radiological consequences of these incidents are discussed in Section 5.9.3 (See Section 5.9.4.4 of the DES).

SANDLER #4 On page 5-38, it is the staff's judgement regarding past accidents that "None is known to have caused any radiation injury or fatality i

to any member of the public ------ any significant contamination of -

the environment." Exposures deduced from Licensee Event Reports are not known to have caused any injury or fatality. ,

SANDLER #5 As stated in the DES, on page 5-42, the radiological consequences of the events, that could be reasonably be expected to occur during any year of operation, are discussed in Section 5.9.3.

BOLEF #1 The word "also" in the 4th paragraph on page 5-34 has been deleted

from the text.

l BOLEF #2 Reference to Table 5.5 has been deleted from the text.

BOLEF #3 Staff disagrees with this comment., Staff has performed a realistic -

analysis of-the consequences of severe accidents, and has assumed that i

should- a severe accident occur, the people would take steps to avoid ,

the consequences of such accidents rather than do nothing. l 3

l UEC #15 The text-has been corrected to reflect the NRC conclusions, regarding i

emergency preparedness, as stated in Appendix F of Safety Evaluation '

j Report (NUREG-0830) which was issued subseqt ut to the issuance of DES.  !

UEC #16. '

The text has been corrected to show that Columbia is 30 miles from the site.

, WINGER #1 Release of radionuclides through the plant waste streams during acci-i l dents are included in the incidents of moderate frequency and as stated in Section 5.9.4.4 (page 5-42) of DES, the radiological consecuences of these occurrences are discussed in Section 5.9.3 of DES. i l

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, ENCLOSURE 3 CHANGES IN DES RESULTING FROM RESPONSE TO COMMENTS k

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f. gases and iodine, a much smaller tendency to escape from degraded fuel unless j the temperature of the fuel becomes quite high. By the same taken, such materials, if they escape by volatilization from the fuel, tend to condense quite rapidly to solid form again when transported to a lower temperature i region and/or dissolve in water when present. The former mechanism can have

i the result of producing some solid particles of sufficiently small size to be

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i carried scme distance by a moving stream of gas or air. If such particulate j i: materials are dispersed into the atmosphere as a result of failure of the

containment barrier, they will tend to be carried downwind and deposit on surface features by gravitational settling or by precipitation (fallout),

where they will become " contamination" hazards in the environment.

I

! All of these radioactive materials exhibit the property of radioactive decay

', with characteristic half-lives ranging from fractions of a second to many days j! or years See Tabh EWMany of them decay through sequence or chain-of-l decay processes and all eventually become stable (no'nradioactive) materials. I j The radiation emitted during these decay processes is the reason that they are j hazardous materials. '

i l Excosure Pathways i The radiatinn exposure (hazard) to individuals is determined by their proximity j to the mdioactive material, the duration of exposure, and factors that act to j shi eld the individual from the radiation. Pathways for the transport of j rac.iation and radioactive materials that lead to radiation exposure hazards to j humans are generally the same for accidental as for " normal" releases. These are depicted in Fioure 5.2. There are two additional possible pathways that could be significant for accidental releases that are not shown in that figure.

One of these is the f allout onto open bodies of water of radioactivity ini-tially carried in the air. The second would be unicue to an accident that l results in temperatures inside the reactor core sufficiently high to cause

melting and subsequent penetration of the basemat underlying the reactor by the molten core debris. This creates the potential for the release of radio-

]:; active material into the hydrosphere through contact with groundwater. These

lI pathways may lead to external exposure to radiation, and to internal exposures

j. if radioactivity is inhaled or ingested from contaminated food or water.

.l It is characteristic of these pathways that during the transport of radioactive

!> material by wind or by water, the material tends to spread and disperse, like a plume of smoke from a smokestack, becoming less concentrated in larger

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, volumes of air or water. The result of these natural orocesses is to lessen i the intensity of exposure to individuals downwind or downstream of the point

. of release, but they also tend to increase the number of individuals who may il be exposed. For a release into the atmosphere, the degree to which dispersion

' ,f reduces the concentration in the plume at any downwind point is governed by

!i the turbulence characteristics of the atmosphere, which vary considerably with

!j time and from place to place. This fact, taken in conjunction with the vari- l 1- ability of wind direction and the presence or absence of precipitation, means I! that accident consequences are very much dependent on the weauer conditions 1, existing at the time.

I! Health Effects ii li The cause-and-ef fect relationships between radiation exposure and adverse J.

health ef fects are quite complex (Ref. 34, pp. 517-534, and Ref. 35), but il l'

I" 5-41 these activities will not interfere with normal plant operation, as required by Part 100. f j

Second, beyond and surrounding the exclusion area is a low population zone

(LPZ), also required by 10 CFR Part 100. This is a circular area with a radius of 4 km (2.5 mi). Within this zone the applicant must assure that j there is a reasonable probability that appropriate and effective measures

'; could be taken on behalf of the residents and other members of the public in ,

the event of a serious accident. ]

Third, Part 100 also requires that the nearest population center of about 25,000 or more persons be no closer than one and one-third times the outer radius of the LPZ. The purpose of this criterion is a recognition that, although accidents cf greater potential hazards than those commonly postulated j as representing an t;pper limit are conceivable, but highly improbable, it was

! considered desirable to add the population-center distance requirement to i provide for protection against excessive doses to people in large centers.

I No commercial or industrial facilities are located within the LPZ. In 1970,

' 116 residents lived within it, and the 1980 population has been estimated at

76. There are no sources of seasonal population in the LPZ with the exception of Lost Canyon Lake (a trailer park used seasonally), and the Reform Wildlife Management Area, which attracts hunters and fishermen. There is no working-day concentration that would create a significant transient population. The nearest population center is Jefferson City, Missouri, located about 40 km (25 mi) west-southwest of the plant. The City of Fulton, Missouri, located about 16 km (10 mi) southeast of the plant, had a 1970 population of 12,248.

Fulton is not expected to reach a population of 25,000 by 2020. The population-center distance is more than one and one-third times the LPZ, as required by Part 100.

The safety evaluation of the Callaway site has also included a review of potential external hazards, i . e. activities offsite that might adversely

{ affect the operation of the plant and cause an accident. This review encom-j passed nearby industrial, transportation, and military facilities that might

create explosive, missile, toxic gas, or similar hazards. The staff has con-cluded that the hazards from nearby industrial and military facilities, pipe-i lines, air transportation, waterways, and railways are acceptably low. A more j detailed discussion of the site features will be included in the staff's i safety evaluation report.

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! Emergency Preoaredness l g%@c%+4 ma 6

1 m&{vfp a{ tw hy." y b,Cmcuded i *+ .bj >

Emergency preparedness plans jncludLng protective-action measures for the Callaway Plant and environs ar576PWancedrbttt-not-yet-f*My-complete (

stage. In 1recorttanch i.h the provisions of 10 CFR Section 50.4706-t-is 5

, 3 iwveen-1980r-an-operating-license-wiH-not-be-issued-to-the--appMcMi,Mwy e

rqF Ae b i l%unless a finding is made by the NRC that the & tate-cMnsite and offsite emer-f pugo

-* gency preparedness provides reasonable assurance that adequate protective p g4 g '

4 measures can and will be taken in the event of a radiological emergency. Il , 1 l Among the standards that%t V met by these plans are provisions for two M

! Emergency Planning Zones '(EPZ). b plume-exposure pathway EPZ of about 16 km

(10 mi) in radius and an ingestion exposure pathway EPZ of about 80 km (50 mi) in radius are required. Other standards include appropriate ranges of protec-tive actions for each of these EPZs, provisions for dissemination to the

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r v s 5-42 public of basic emergency planning information, provisions for rapid notifi-cation of the public during a serious reactor emergency, and methods, systems, and equipment for assessing and monitoring actual or potential offsite conse-quences in the EPZs of radiological-emergency conditions.

a x e.

The NRC findingsj'Ei" Qbased on a review of the Federal Emergency Management Agency findings and determinations as to whether state and local government emergency plans are adequate and capable of being implemented, and on the NRC assessment as to whether the applicant's onsite plans are adequate and capable of being implemented. Although the presence of adequate and tested emergency plans cannot prevent the occurrence of an accident, it is the judgment of the staff that they can and will substantially mitigate the consequences to the public should one occur.

5.9.4.4 Accident Risk and Impact Assessment Design-Basis Accidents t As a means of assuring that certain features of the Callaway Units 1 and 2 meet acceptable design and performance criteria, both the applicant and the staff have analyzed the potential consequences of a number of postulated accidents. Some of these could lead to significant releases of radioactive materials to the environment, and calculations have been performed to estimate the potential radiological consequences to persons offsite. For each postu-lated initiating event, the pctential radiological consequences cover a consi-derable range of values depending on the particular course taken by the acci-dent and the conditions, including wind direction and weather, prevalent during the accident.

In the safety analysis and evaluation of Callaway Units 1 and 2, three cate-gories of accidents have been considered by the applicant and the staff.

These categories are based upon their probability of occurrence and include (1) incidents of moderate frequency, i.e. events that can reasonably be expected to occur during any year of operation; (2) infrequent accidents, i.e. events that might occur once during the lifetime of the plant; and (3) limiting faults, i.e. accidents not expected to occur but that have the potential for significant releases of radioactivity. The radiological con =equences of inci-dents in the first category, also called anticipated operational occurrences, are discussed in Section 5.9.3. Initiating events postulated in the second and third categories for the Callaway Units 1 and 2 are shown in Table 5.6.

These are designated design-basis accidents in that specific design and operating features as described in Section 5.9.4.3 Design Features are provided to limit their potential radiological consequences. Approximate radiation doses that might be received by a person at the most adverse location along the site boundary (1200 m or 3900 ft from the plant) are also shown in the table, along with a characterization of the time duration of the releases.

The staff has used conservative models for calculations to estimate the poten-tial upper bounds for individual exposures summarized in Table 5.6 for the purpose of implementing the provisions of 10 CFR Part 100, " Reactor Site Criteria." For these calculations, pessimistic (conservative or worst case) assumptions are made as to the course taken by the accident and the prevailing conditions. These assumptions include much larger than expected amounts of radioactive material released by the initiating events, additional single f

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1 5-46 the RSS there are substantial uncertainties in these probabilities. This is due, in part, to difficulties associated with the quantification of human  ;

error and to inadequacies in the data base on failure rates of individual '

plant components that were used to calculate the probabilities (Ref. 42) (see Sec. 5.9.4.4 Uncertainties). The probability of accident sequences from the Surry plant were used to give a perspective of the societal risk at Callaway ,

Units 1 and 2 because, although the probabilities of particular accident l sequences may be substantially different for Callaway, the overall effect of all sequences taken together is likely to be within the uncertainties (see Sec. 5.9.4.4 Uncertainties).

The magnitudes (curies) of radioactivity releases for each accident sequence or release category are obtained by multiplying the release fractions shown in Table 5.7 by the amounts that would be present in the core at the time of the hypothetical accident. These are shown in Table 5.5 for a Callaway reactor core at the thermal power level of 3636 megawatts. i

, The potential radiological consequences of these releases have been calcu- 1

! lated by the consequence model used in the RSS (Ref. 43) and adapted to apply l to a specific site. The essential el.ements are shown in schematic form in i Figure 5.3. Environmental parameters specific to the Callaway site have been  !

used and include the following:

j l

1. One full year of consecutive hourly averages of 1974/1975 meteorological ,

and precipitation l L data from the from data obtained site meteorological-monitoring Columbia, which is about N systems,1i) km (15 from the site; '

, d98 M j 2. Projected population for the year 2000 extending throughout regions of a 80- and 560-km (50- and 350-mi) radii from the site;

3. The habitable land fraction within the 560-km (350-mi) radius; and t

f 4. Land-use statistics, on a state-wide basis, including farm land values, farm product values including dairy production, and growing-season infor-mation, for the State of Missouri and each surrounding state within the 560-km (350-mi) region.

To obtain a probability distribution of consequences, the calculations are performed assuming the occurrence of each accident release sequence at each of 91 different " start" times throughout a one year period. Each calculation uses the site-specific hourly meteorological data and seasonal information for the time period following each " start" time. The consequence model also a contains provisions for incorporating the consequence-reduction benefits of L evacuation and other protective actions. Early evacuation of people would j considerably reduce the exposure from the radioactive cloud and the contami-nated ground in the wake of the cloud passage. The evacuation model used, as

[

~ discussed in Appendix F, has been revised from that used in the RSS for better site-specific application. The quantitative characteristics of the evacuation model used for the Callaway site are best estimate valtes made by the staff i and based on evacuation-time estimates prepared by the applicant. Actual evacuation effectiveness could be greater or less than that characterized, but would not be expected to be very much different.

,