ML19305B695
| ML19305B695 | |
| Person / Time | |
|---|---|
| Site: | 05000574 |
| Issue date: | 02/29/1980 |
| From: | Dorian T NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | NRC COMMISSION (OCM) |
| References | |
| NUDOCS 8003200109 | |
| Download: ML19305B695 (9) | |
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FEB 2 91980
,y DOCKET NUMBER EXPORT.lMPORT.,.M8f.'M_ _ f M
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occKETED NUCLEAR REGULATORY COMMISSION usuno FEB 291980> 3 BEFORE THE COMMISSION t
Ofica of the W 7 Docketing & W 6
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Docket No. 110-0495 03
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Application No. XR-120 (Exports to the Philippines)
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Application No. XCOM-0013
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NRC STAFF SUBMISSION IN RESPONSE TO COMMISSION ORDER OF FEBRUARY 8, 1980 By an order dated February 8,1980, the Commission invited coment upor:
(a)' the health, safety or environmental effects the proposed nuclear exports to the Philippines would have upon the global comons or the territory of the
' United States, and (b) the relationship of these effects to the common defehse and security of the United States.
For purposes of these coments, the term " global comons" means geographical areas such as the high seas, Antarctica, and the portions of the atmosphere that are not within the territorial jurisdiction of a single nation state; and the term " United States" means territory of the 50 States, as well as U.S. trust territories and possessions.
In orner to provide an approximate evaluation of the potential radicionical icoact of ~ the Philippine's Napot Doint nuclear power olant in response to the '
Copmission's February 8,1980 Order, NRR, which orecared the technical analysis,
- ias had to make numerous assumptions and judgments based on other related nodels and studies.
Since the Comission's Order clearly confines the staff considerations to ootential impacts outside the territorial jurisdiction of the Philippines (i.e., the "globak comons" and the " United States"), the issue is reduced orinarily to one of performing a worst case analysis, i.e., of considerino the potential irnact 80032001081
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...a of Class 9 core melt accidents. While there does not seem to exist universal agreement as to what consitutes the limits of a state's sovereianty, it was assumed here that a 12-mile territorial limit off the Philippine coast would apply.
However, such a limit would not be applied between islands that are cart of the Philippine Archipelago (there are a total of about 7,100 islands '
with a total area of 116,000 sq. miles).
Based on 'available evidence (NUREG-0002 on GESMO (1976)), the staff has determined that routine releases (gaseous and liquid).from individual nuclear power stations do not result in significent impacts on the global comons and that the same would be true of core malts which do not escape into the atmosphere.
Al thouah the liquid releases from such accidents might cause local contamination of aquifers, estuaries or oceans, the radiological and ecological impacts on the global commons would generally be small.
The staff has also' determined that, in the event of a most serious core melt accident which would result in direct releases to the atmosphere (such as PWR cases 1-5 in WASH-1400), the health, safety and environmvntal effects beyond the 12-mile limit would not be more significant than those related to natural causes.
Finally, the staff has determined that, in the event of such an accident, a large liquid pathway dose would be highly unlikely.
It should be noted that, in or' der to provide a prelirninary upperbound est'imate
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of such an accident at the Philippine nuc??ar power plant, the staff has had to make several assumptions which it has not had time to verify, but feels are
'reilistically conservative.
At=c:pheric Releases Rainfall is particularly important for controlling global impacts from atmo-spheric releases. 'In general, the greater the rainfall, the greater the local 4
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fallout and the lower the potential impacts on the global commons.
The rainfall rate in the Philippines is quite high for July through February, and as many as 200 typhoons may hit the islands each year.
The PSAR indicates an average annual rainfall rate in excess of 2,400 mm.
The Philippine plant is a 1,876 MWt Westinghouse PWR which, incidentally, is t-essentially the same. plant as the proprsed North Coast Unit One plant in Puerto Rico.
The reactor containment is a double shell, as opposed to the single containment system used for the model PWR (Surry plant, also built by Westinghouse) for the Reactor Safety Study.
However, the staff believes the two plants would be approximately comparable in the event of a core melt accident, and the staff bases its assessment on that belief.
In order to be reasonably conservative, the staff has also assumed that members of an exposed population would be located outdoors without protection or shelter during the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the exposure (including plume passage and ground deposition).
This would account for essentially all of the inhalation dose and the ground deposition dose (assuming no evacuation durino that period).
How-ever, evacuation and protective actions could areatly reduce the doses.
Under the same meteorolooical assumptions, calculations for a U.S. olant of rouchiv simil'ar design, located also alono the coastline, should yield about the same estimated effects on the global commons.
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.The results of the CRAC code / analysis of the Philippine nuclear power. station are shown in. Table 1 on page 5.
The results lead to the conclusion that it is very unlikely that there would be a single early fatality (occurring within one year) outside a 12-mile territorial boundary as a result of radiation doses receiv'ed.
Whole b'ody and thyroid doses, on the orcer of 24 and 1,400 rem 1#See App. VI, WASH-1400 (1975) for. details.
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respectively, could theoretically be received by exposed persons on ships at sea or small, inhabited islands just beyond the 12-mile limit (assuming no evacuation or treatment).
At that dose (and with no effort to seek shelter or to decontaminate), the total incremental lifetime risk of latent cancer mortality related to the postulated accident would be on the order of 20 chances in a thousand (85% of those deaths would be from thyroid cancer), compared with the normal lifetime risk of cancer mortality in the Philippines of about 50 chances
. in a t'houu.nd.2/ However, ships provida good shelter and can be decontaminated quickly by hosing.
Furthermore, the staff is not aware of any inhabited islands outside the Philippines within 100 miles of the plant site. 3/ At that distance, whole.bedy doses could be on the order of 2.0 rem, with thyroid doses on the order of 200 rem assuming no evacuation.
In such a case, the total incremental lifetime risk of latent cancer mortality attributable to the core meltdown would be on the order of three chances in a thousand.
Risk of genetic defects (not mortality) would be on the order c' O.5 chances in a thousand over the subsequent five generations.
The estimated somatic impacts are believed to be conservative, since they are based on cancer risks in nations having greater life expectancies than the Philippines (i.e., in the Philippines more people would be expected to-die at an earlier aae of other. cau'ses, avoidina the very.high cancer risk years beyond age 60).
Thus, the analysis and data indicate that health effects likely to arise in the
- highest dose regions of the global commons can be expected to be considerably lowerthannohti lifetime cancer risks.
2/ Assumes a 60-year life expectancy (based ;J e V sear life expectancy 'in 196S),
and 1972-73 Philjppine cancer rates listd n, ',.ycer Facts and Figures 1979,"
Amer ~ican Cancer Society.
3/ It should'be notad that Philippine territory extends over 300 miles to the
- north of the site and over 500 miles to the so'Jth.
The nearest nation is Indenesis, nectly 600 miles to the SSW of the plant.
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TAELE 1:
Philippines Average Thyroid Dose Whole Body Dose Distance (Miles)
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(rem) 0.25 2.3PE + O2 2.94E M 02 0.75 2.90E + O2 2.12E + O2 1.25 3.15E + 02 1.57E + O2 1.75 3.61E + O2 1.39E + 02
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2.25.
4.31E + O2 1.28E + O2 p.
3.75 4.9'2E + O2 1.01E + 02 3.25 5.79E + O2 7.89E + 01 3.75 6.79E + 02 7.12E + 01 4.25
,'7.54E + O2 6.3SE + 01 4.75 9.lBE + O2 5.06E + 01 5.5 1.03E + 03 4.3SE + 01 6. 5.
1.15E + 03 3.72E +.01 7.75 1.2eE + 03 3.24E + 01 9.25 1.3SE + 03 2.93E + 01 11.2 1.41E + 03 2.40E + 01 13.7 1.3SE + 03 1.852 + 01 16.2 1.26E + 03 1.5cE + 01 18.7 1.22E + 03 1.26E + 01 22.5 1.06E + 03 1.09E + 01 27.5 1.17E + 03 5.75E + 01 32.5 1.04F.+ 03 4.15E + 01 37.5 8.95E + O2 3.29E'+ 01 42.5 7.69E'+ O2 2.49E + 01
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4_/ " st of the' calculated 47.5 6.30E + O2 1.79E + 01 thyroid do se is fror l52.5 5.44E + O2 1.44E + 01, internally denosited radiciodine which can 57.'5 4.80E + 0*9 1.13E + 01 be reduced by orochvlaxis 1.03E + 01 civen wi 5in hours of 62.5 3.83E + O2 67.5 3.57E + O2 7.40E + 00 7.75 3.30E + O2 5.60E + 00 92.5' 2.41E + O2 4.14E + 00 125 1.25E + 02 1.29E + 00 i
175 5.53E - 01 5.74E - 01 275' 1.80E + 01 1.96E. 01 g
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c Liquid Releases-A large liquid pathway dose from a core m21t accident would be highly unlikely.
The radioactivity released in a core melt accident would first nave to travel through groundwater to get to the sea, affording time to interdict at the source.
In the Liquid Pathway Generic Study (NUREG-0440),
the maximum uninterdicted dose to an individual at a generic coasta, site from the worst core melt scenario was conservatively estimated to be about 50 rems, whole body.
While the generic site does not duplicate exactly the conditions to be expecte<j at the Philippine site, the staff is of the opinion that the estimated maximum dose would be ' conservative (that is, an over-estimate).
Ovdr half of the dose, about 30 rems, would be attributable to the consumption of fish caught near the accident site.
No drinking water pathway would be
. involved at the site since only sea water pathways would need to be considered for.this plant site.
The beach exposure portion of the dose would be important only on Philippine beaches and would be negligible elsewhere.
Therefore, the only potentially significant liquid pathway dose which could enter the global cor. mons and also be ingested by individuals outside of the Philiocines would be due to the consumption of seafood caught close to the accident site and exported elsewhere.
It is highly likely that steps would be taken.to interd,ict the radictitive liquid release before it entered the sea.
Monitoring and confiscat ar. of commercial seafood, if necessary, would further reduce the dose es'.imate.
'On 'the basis of the above discussion, the staff concludes that health, safety and environmental impacts on the global commons can conservatively be estimated to be negligible, and that, consequently, these negligible effects
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7 can be deemed to have an insianificant impact on the common defense and security of the United States.
Respectfully submitted,
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s Thomas F. Dorian Counsel for the NRC Staff Dated at Bethesda, Maryland this 29th day of February, 1980 t
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the matter of
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WESTINGHOUSE ELECTRIC CORP.
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Docket.No. 110-0495
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Application No. XR-120
.(Exports to the Philippines)
)
Aoplication No. XCOM-0013 CERTIFICATE OF SERVICE I hereby certi fy that copies of "NRC STAFF SUBMISSION IN RESPONSE TO COMMISSION ORDER OF FEBRUARY 8,1980" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class c-air mail, or, as indicated by an asterisk, through deposit in the Nucitar Regulatory Commission's internal mail system, this 29th day of. February 1980:
Thomas R. Asher, Esq.
Mr. Ronald J. Bettauer Matthew R. Bogin, Esq.
Assistant Legal Adviser 123217th Street, N.W.
for Nuclear Affairs Washington, D.C.
20036 L/N Room 6420 Department of State Barton Z. Cowan, Esq.
Washington, D.C.
20520 Eckert, Seamons, Cherin & Mellott 42d floor, 600 Grant Street T. R. Dankmeyer, Esq.
Pittsburgh, Pennsylv'ania 15219 General Electric Company 175 Curtner Avenue Thomas M. Daugherty, Esq.
San Jose. California 95125 Westinghouse Nuclear Energy Systems P. O. Box 355 Ms. Connie Clark Pittsburgh, Pennsylvania 15230 Campaign for a Nuclear Free Philippinet 2729 Derby Street Mr. Louis V.'Nosenzo Berkeley, California 94705 Deputy Assistant Secretary for Nuclear Energy and Energy Mr. G. L. Mattison, Director Technology Affairs Center for Development Policy Department of State 225 4th Street, N.E.
' Washington, D.C.
20520 Washington, D.C.
20002 The ' Honorable Frank Church, Chairman Earl Nicholas Selby, Esq.
Committee on Foreign Relations 2361 Columbia Street United States Senate Palo Alto, California 94306 Washington, D.C.
20410 l
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Mr. Vincent P. de Poix, Chairman Nicholas C. Yost, Esq.
Subcommittee on Nuclear Exports General Counsel Atomic Industrial Forum, Inc.
Council on Environmental Quality 1747 Pennsylvania Avenue, N.W.
722 Jackson Place,-N.W.
Suite 1150 Washington, D.C.
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Washington, D.C.
20006 Mr. James N. Barnes Mr. Peter J. Hayes Center for Law and Social Policy Energy and Resources Group 1751 N Street, N.W.
Room 100, Building T-4 Washington, D.C.
20036 University of California at Berkeley Berkeley, California 94720 The Honorable Eduardo Z. Romualdez Ambassador Ms. Lyuba Zarsky Embassy of the Philippines 1523 A Josephine 1617 Massachusetts Avenue, N.W.
Berkeley, California 94703 Washington, D.C.
20036
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The Honorable C'laiborne Pell, Chairman Mr. Stephen Prussman Subcommittee on Arms Control, Oceans, Ebasco Services, Inc.
International Operations and Environment 2 Rector Street Committee on Foreign Relations New York, New York 10006 United States Senate Washington, D.C.
20510 James C. Drew, Esq.
1712 N Street, N.W.
Mr. J. Nicanor Perlas, III Washington, D.C. 20036 Executive Director Philippine Movement for Environmental Dr. Walden Bello l
Protection Friends of the Filipino People 2721 Connecticut Avenue, N.W.
132218th Street, N.W.
Washington, D.C.
20008 Washington, D.C.
20036 Mr. Domingo C. Abadilla, Chairman
- Mr. Chase Stephens, Chief l
Coordinating Council Docketina and Service Section Federation for Environmental Concern U.S. Nuciear Regulatory Commission 99 Times Street Washinoton, D. C.
20555 Quezon City 3008, Philippines
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Ms. Beth Larch, Energy Program J
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The Honorable Ronald V. Dellums Director United States House of Representatives Interfaith Center on Corporate Washington, D.C.
20515 Responsi bility
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475 Riverside Drive, Room 566 Mr. J. A. Scarola, Presiden.t and New York, New York 10027 Chief Executive Officer Ebasco Services, Inc.
Mr. Kirk W. Jones 2 Rector Street National Lawyers Guild New York, New York 10006 Seattle Chapter Room 1206, Smith Tower
. *Samdel 'J. Chilk, Secretary Seattle, Wasnington 98104
- U.S. Nuclear Regulatory Commission Washington, D. C. 20555 fdY:: - k
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Thomas F. Dorian" Counsel for NRC Staff
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