ML19308C232
| ML19308C232 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/29/1979 |
| From: | Cleary P CITIZENS FOR A BETTER ENVIRONMENT |
| To: | |
| References | |
| RTR-NUREG-0396, RTR-NUREG-396, TASK-TF, TASK-TMR CBE-79137, NUDOCS 8001210564 | |
| Download: ML19308C232 (5) | |
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Analysis of NUREG-0396 I
March 1979 PDDR BRGE
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Considerations Parameters Regulatory Position j
B.13 Cooling Tower Mume Lengths cooling tower Natural draft cooling towers pro-The number of hours per year the The visibility duce cloudlike plumes which vary plume is visible as a function of plumes as a function of direction and in size and altitude depending on dirc: tion and distance from the distance from cooling towers should the atmospheric conditions. The cooling towers.
be considered. The evaluation should plumes are usually a few miles in include estimates of frequen:y of length before becoming dissipa-occurrence for plumes as well as ted, although plume lengths of 20 potential hazards to aviation in the to 30 miles have been reported vicinity of commercial and military from cooling towers. Visible airports.
plumes emitted from cooling towers could cause a hazad to commercial and military aviation in the vicinity of commercial and military airports. The plumes themselves or their shadows could have aesthetic impacts.
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B.14 Mume Interaction Water vapor from cooling tower The degree to which impacts may The hazards to public health, plumes may interact with industri-occur will vary depending on the structures, and other resources from al emissions from nearby facilities distance between the nuclear and potential plume interaction between to form noxious or toxic sub-fossil-fueled sites, the hours per year cooling tower plumes and plumes stances which could cause adverse of plume interaction, the type and from fossbfueled sites and industrial public health impacts, or result in concentration of chemical reaction emissions from nearby facilities unacceptable levels of damage to products, the area of chemical fall-should be considered.
biota, structures, and other re-out, and the local atmospheric sources.
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Considerations Peremeters Regulatory Position B.15 Noise Undesirable noise levels at nuclear Applicable Federal, State, and local Noise levels at proposed sites must power stations could occur during noise regulations.
comply with statutory requirements.
both the construction and opera-tion phases and have unacceptable impacts near the plant.
s B.16 Economic impact of Pre-emptive Land Use Nuclear power stations can pre-The level of local economic disloca-If a preliminary evaluation of net empt large land areas, especially tion, such as loss of income, jobs, local economic impact of the use of when large cooling lakes are con-and production, caused by pre-productive land for a nuclear power structed. The land requirement is emptive use of productive land and station indicates a potential for large likely to be an important issue its effect on meeting foreseeable economic dislocation, the NRC staff when a proposed site is on pro-national demands for agriculture pro-will require a detailed evaluation of ductive land (e.g., agricultural ducts.
the potentialimpact andjustification land) that is locally limited in for the use of the site based on a availability and is important to cost <ffectiveness comparison of the local economy, or which may altemative station designs and site-be needed to meet foreseeable station combinations. To complete national demands for agricultural its evaluation, the staff will also need products.
information on whether and to what extent the land use affects national requirements for agricultural pro-ducts.
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Comments Filed 29 March 1979 on Behalf of CITIZENS FOR A BETTER ENVIRONMENT by PETER CLEARY Staff Physicist on NUREG-0396 PLANNING BASIS FOR THE DEVELOPMENT O LOCAL GOVERNMENT RADIOLOGICAL EMER STATE AND PLANS IN SUPPORT OF LIGHT WATER NUCLE ESPONSE POWER PLANTS Summary Nuctrar power plants are viewed by diffe' e t way s.
To :,ome the rn are as r.a fe as houses, while to others they a controlled solcanoes,y likely to spew death and destruction at an perceived neeri for emergency planning similarl arely planony as a y moment. The pure waste of time and moneyy varies from those who regard such preparadonw ' er the worst of all possible accide t to those who demand constant n s.
I rd. ral actan The Nuclear Regulatory Commission then sit NUP.l~G-0396.
at is, documents like amt 3 far Stato trainug courses in the Southwest may band local governments to emergency response up to the property lie offered as inducements. T u ant e".
A few population zone.
rnake millbns of dollars each year from thThe utility has then d e output of the reactor with a cleareq coaccinnce.
The State attompts to balance its budgetThe community ga e reactor in its rate base.
The stage is now set j
inadequate planniry, but until an emergencfor a classic tragedy.
Inadequate
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Unt il 7 fundirq has led to solution has been found tothe twin problems of funding and tes emer ;ency document a.
1rther " guidance" is of little use v.EG-0W s
unless it et completely rewritten.6, it is doubt ful if the " guidance" will eIn the ng ver be of any use,
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WHY WAS NUREU-03'16 PREPARED?
All emergency plannity involves considerable guesswork and a lot of p:eparation for events which do not occur. F or example, a fire department must always be on the alert and be able to concentrate men and equipment on the site of a fire in a matter of minutes.
Over a period of years, the size and frequency of fires is recorded, and the fire department's manpower is adjusted accordingly. Even so, much of a fireman's time is s,nent preparing to act rather than acting. To cope with unusually large fires, communication between adjacent fire departments may be developed. Flooding is a slightly different matter. Spring floods occur regularly along the Mississippi, but they normally develop slowly. This allows the emergency teams to consist of mixtures of professionals, trained volunteers and response untrained volunteers.
A nuclear power plant accident would be completely different.
A large release of radioactive material has never occurred at a U.S. power plant, but if one did it would require unprecedented rapid and widespread responses from numerous emergency agencies. Preparing for an accident which has never happened comes very low on a State's budget, but the requirement that the response be so fast worries unprepared emergency services.
Out of tnis worry came a request to the Nuclear Regulatory Commission (NRC) from the Conference of (State) Radiation Control Protiram Directors asking NRC to "make a determination of the most severe accident basis for which radiological emergency response plans should be developed by offsite agencies".1 NURFG 0.W6 in a response to this request. It is also an attempt to reconcile an inconsintency between NRC and Environmental Prutection Agency (EPA) quidehnes.
The EPA has published its guidance for radiological emergency response in the for m of a Manual of Protective Action Guides (PAGs).
The idea of a PAG level is that, given an accident, one may roughly calculate the cumulative dose to an individual assuming no protective action is taken.
If this " projected dow" is greater than the appropriate PAG level, then some predetermined protective action s%uld be taken.
The aim of PAGs is to greatly simplify emergency response; at a given P-TG level, a given response should occur.
Within the general framework of providing maximum health protection for an endangered public, the public official charged with response to a hazardous situation may be faced with a number of decisions which must be made in a short time. A number of possible alternativas for action may be available, but the informatico needed to select the optimum alternative may not be available.
In those situations where a public official must rapidly select the best of several alternatives, it is helpful if the number of decision points can be reduced during the accident response planning phase. I. Emphasis in original.)-
The need f or rules in haz irdou :
a~a@mic politien:
situations in briefly described in a work on k
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Plainly, tfm rnure rules you can invent waste time over fNitless puzzling about right a d, the less need th sort of mies are those which prohibit wrong. The best n
innocent, actions, such as smokirg in Coll important, but perfectly Madirgicy on Sunday without academical drege courts, or walking to help to obscure these troublesome considregulati ess.
or wrong they to relieve the mind of all sense of obligation terations in other case,, a s
owards society.
fabric of Roman Law had not been elaborate e world if the grand the sword from having to think for himselfo save the man behind loss of coolant accident (DBA/LOCA and the RTh staff analyses of the design basis indicate that in the event of a core m)elt accid eactor Safety Study (RSSfanalyses are quite likely to occur out to several miles awa ent projected doses above PAG levels y from the reactor.
A dilemma results: EPA has declared that PAG l Prutective Action Guides are the numericalevels should as tri;qer points to initiate protective action projected doses which act NRt ' has found that P AG levels may be rea h a reaetor iccident.
act on::: ;o nothing shnold happen when the triqTherefore qer in pulled.
etermined response I IOW dot.S Nt IRl]. 0 596 Ol Al NUP.t.G 0 596 WiiH fHrSI ISSt JES?
elaborately avoids both the request to define accident" and the problem of havirg no plan swift response, it does this by independant setss at all for areas w a "most severe First there is an analysis of the DBA/LOCA of logic worthy of the scholastics.6 rem ! squre I.7). var,.vid"h; e.q., the thyroid dose at 10 milat 129 reactors at 67 The results The report concludes:For 70"6 of the sites the done is less thaes rarges f leve!.
n 5 rem, the lower PAG From these results, the Task Force co r~merqency Planniry Zone for the plumencluded that about a 10 mile pntifPd ta assure exposure pathway thon-areas where PAGs could be excsat predetermined actions would was companble to a design basis accident. eeded in the event of a release n
Thi*, r; ihvtuusly nonwnse.
129 omta et equisalent to averaging over 129It assumes that averagiry over e
ascident at accidents at one unit, a totally invalid (s
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