ML19305B706
| ML19305B706 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 02/19/1980 |
| From: | Weiss E SHELDON, HARMON & WEISS, UNION OF CONCERNED SCIENTISTS |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML19305B707 | List: |
| References | |
| FRN-44FR75167, RULE-PR-50, TASK-OS, TASK-SD-906-1 NUDOCS 8003200122 | |
| Download: ML19305B706 (5) | |
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g NUCLEAR REGULATORY COMMISSION 03 1 Docket No. PR-50 (44 FR 75167)
UNION OF CONCERNED SCIENTISTS COMMENTS ON PROPOSED RULEMAKING ON EMERGENCY PLANNING NRC has invited public comment on proposed amendments to 10 CFR Part 50 which would change NRC rules on emergency plan-ning and require compliance with the new regulations as a pre-requisite to issuance of operating licenses and to continuing operation of existing plants.
UCS previously filed comments in response to the NRC's advance notice of croposed rulemaking on this subject.
(44 Fed. Reg. 41483, July 17, 1979)
A co py is attached.
As a general matter, UCS strongly supports the concept of a direct link between licensing and emergency olanning.
How-ever, we find serious shortcomings in both alternatives proposed by NRC.
A 10-Mile Emergency Planning Zona for Plume Exposure is Clearly Insufficient i
The proposed change to 650.33 accepts without technical
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jus tification a 10 mile EPZ for plume exposure.
The Commission has adopted this position witnout scrutiny of the validity of its underlying bases, nor indeed'without disclosure of its j
underlying technical bases.
A major reactor accident such as the most serious analyzed in WASH-1400l'the Reactor Safety Study, - could cause death and illness significantly beyond ten miles from the reactor site; there is little dispute over this.
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. Attached is a statement presented to the New York City Council on June 11, 1979, by Dr. Jan Beyea of Princeton University.
Using the "P WR-2 " failure sequence from NASH-1400 and typical meterological conditions, Dr. Beyea calcula-ted the major health effects from an accident at Indian Point at 35 miles from release.
(See pages 9-10 and table VIB)
If the wind is blowing towards Manhattan, between 1800 and 18,000 people could die from cancer.
Virtually all children and most adults exposed would develop thyroid nodules, a large fraction of which would require surgical treatment and lifetime medica-tion thereaf ter.
This analysis demonstrates that evacuation may well be required far beyond a 10 mile radius and that, for purposes of emergency planning, a 10 mile EPZ for plume exposure is clearly inadequate.
NRC must answer certain fundamental questions before it can determine an appropriate " generic" plume exposure planning zone for planning purposes:
1).
What is the appropriate design basis accident for emergency planning ?
2).
What would the consequences be of this accident in terms of short and lonq-term health effects and property damage?
Based upon the answers to the above, NRC can proceed to determine appropriate zones for mitigating measures, including evacuation, sheltering and administration of potassium iodide.
As yet, however, NRC has never permitted these basic ques tions L
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to be publiclyfpentilated in an open forum.
Although a 10-mile EPZ for plume exposure is an improvement over the previous NR C po s i tion, it is still essentially arbitrary
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i and _d oes not represent anything approaching a worst case.
}' Wi t h Respe c t. t >
SS50.47 and 50.54, Alternative "B"
is Preferable to Alternative "A",
But Both Lack Suf ficiently Specific Standards for Exemptions In UCS 's view, Alternative A is tod 11y unacceptable.
While establishing theoretichl deadlines for NRC concurrence in emer-gency plans, it would require the Commission to make additional findings inforder to enforce its provisions, after the deadline 3
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had passdd# with regard to the " significance" of the deficien-cies, the ' presence of cor pensaking measdres,
or the presence of other, wholly unspecified "comoelling reasons" which would justify operation.
T hu s, th'e deadline is toothless, particularly considering thh amount of time which_it would certainly take the Commission to'make the pos t-deadline findings.
jn addition, the provision permitting plants to continue coer'ating on the basis of some " cot 6pelling reasons" is completely N I b.per.-ende,d and without de fini. ion.
Utilities would certainly y
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a i. argue that economic factors, such as the cost of replacement i
' power, constitute compelling reasons.
In UCS 's view, such cinsiderations are outside the scope of the Atomic Energy Act.
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U, The CommissionIis not authc rized to permit plants to operate which f ail to mee t minimum requirements necessary for the crotec-tion of public safety on the grounds that r e olac~e me n t power is f\\
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expensive.
To permit exemptions to be granted on these grounds p
is to emas'culato - the rule at the outset, since some economic cost t
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is always associated with shut-downs.
4 The utilities have known for many months that they would be required to bring emergency plans around reactor sites up to current standards.
The time for tenoorizing is past.
Alternative "B"
is an improvement over Alternative "A,"
at least to the extent that the deadlines would operate auto-matically to require shutdown of non-complying plants in the absence of an exemption.
However, the grounds for such an exemption are precisely the same as those for Alternative "B".
UCS believes that the grounds for exemption should be very narrowly drawn.
Only if the plan's deficiencies are de minimus (i.e. insignificant) AMD compensating measures have been taken AND appropriate protection actions, including evacua-tion, can be taken for persons within the plume EPZ should exemptions be permitted both for operating licenses and presently operating plants.
Appendix E Does Not Clarify the Relationship Between Emergency Planning and Site Evaluaction The proposed amendments to Appendix E do not clarify the relationship between emergency planning and site evaluation, although the two are closely connected.
The assumption implicit in the emergency planning rules is that all sites can comoly.
This results at least partially from the lack of an objective per f ormance standard by which to judge the feasibility of protective measures, particularly evacuation.
Thus, although "it is expected" that all persons within
.the EPZ shall be " alerted" of the need for orotecti"e action
within 15 minutes of notification by the licensee of state and local officials, no standards are provided for the overall time for evacuation, which is the most critical carameter of all.
Under the proposed rule, emergency plans could oresuma-bly be approved for a site even if the plume EPZ could not be i
evacuated for 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> or more, while other sites would require substantially less time.
The underlying chilosophy of the rule would appear to be that it is acceptable to make the best of a bad site.
This would not only permit plants to continue to operate in areas of very high pooulation density (such as Indian Point and Zion ), but it would allow new plants to be sited in locations which are, as a practical matter, not eva-cuable within a reasonable period of time.
In order to provide genuine assurance th.'t meaningful protective measures could be taken in the event of a serious accident, NRC mus t establish some objective criterion for the maximum permissible time to accomplish evacuation of the plume EPZ.
In the absence of such a criterion, the evacuation plan-ning regulations exalt form over substance.
Submitted by:
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Weiss SilELDON, 19.R MON & WEISS 1725 I Street, N.W.
Suite 506 Washington, D. C.
20006 (202) 833-9070 General Counsel, Union of Concerned Scientists DATED:
February 19, 1980 1