ML19309D554
| ML19309D554 | |
| Person / Time | |
|---|---|
| Site: | 05000516, 05000517 |
| Issue date: | 06/29/1979 |
| From: | Giardina P SUFFOLK COUNTY, NY |
| To: | |
| Shared Package | |
| ML19309D526 | List: |
| References | |
| FRN-44FR75167, RULE-PR-50 80003, NUDOCS 8004100472 | |
| Download: ML19309D554 (25) | |
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NEW YORK STATE BOARD ON ELECTRIC GENERATIO:I SITING AND THE ENVIROI1 MENT In the itatter of )
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LONG ISLAND LIGHTING COMPANY
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and ) Case 80003
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.. NEW YORK STATE ELECTRIC & OAS )
CORPORATION )
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7' (Jamesport :luclear Power )
Station, Units 1 & 2) )
T, SUPPLEMENTAL TESTIMONY OF PAUL A. GIARDINA SUBMITTED FOR THE COUNTY OF SUFFOLK e N E/ ,
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1 Q. Please state your name, title and employer.
2 A. My name is Paul A. Giardina, and I am the 3 Chief of the Radiation Branch for the Environmental 4 Protection Agency (EPA), Region II Office, located 5 at 26 Federal Plaza, New York, New York 10007 6
7 Q. Have you included a copy of your professional 8 qualifications to this Testimony? .
9 A. Yes. These appear in Appendix "A", attached hereto.
10 11 Q. Did you previously testify in these proceedings?
12 A. Yes. On April 27, 1977, I presented testimony at ,
13 the request of Suffolk County on the issues of emergency 14 response planning and the comparative health effects of 15 the nuclear and coal fuel cycles.
16 17 Q. How does this present testimony relate to t' hat which 18 you previously submitted?
19 A. In my previous testimony and during crosc-examinationi 20 I raised concerns similar to those expressed herein regarding 21 the problems associated with radiological emergency planning 22 for Jamesport and made clear my . reservations about whether
. 23 protective actions could be taken in an area susceptible to 24 the levels of radiation above EPA Protective Action Guides
, 25 (PAG's). At that time I selected a radius of approximately 26 nine miles as an emergency planning area susceptible to 27 those levels. Since that time the field of emergency res-28 ponse planning and protection has been a subject of increased a
29 federal agency attention and concern. A joint EPA /U.S. Nuclea r 30 Regulatory Commission (NRC) task force report on this subject, 31 EPA studies on sheltering, and other NRC and Federal Prepared-32 ness Agency documents - all of which are referenced and dis-33 cussed later in this testimony - attest to this fact. For ex-34 ample, today we have actual planning zone recommendations fror 35 a Federal task force which call for a ten mile inhalation 36 Emergency Planning Zone (EPZ), a development which confirms 37 my earlier nine mile analysis. In 1977 we could only 38 speculate that an acceptable emergency response would be 39 a problem at the Jamesport site; today we are virtually 40 certain that an adequate and effective emergency response 41 is not possible.
42 43 I also raised other points in that_ testimony.and in the 44 subsequent cross-examination related to radioactive material 45 transport, radioactive waste management, and decontamination 46 and decommissioning. In the area of urban radionuclide 47 transport I earlier alluded to an NRC contractor, Sandia .
48 Laboratories, performing a study on this subject. Sandia 49 has now. issued a report on their findings entitled Transport 50 of Radionuclides in Urban Environs: A Working Draft Assess-
., 51 ment 1/ in which it is found that a major accident involving
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1 spent fuel or plutonium could result in u'p to 4000 latent 2 I cancer fatalities and well over a billion dollars These in 3 property damage if it occurred in New York City.
4 accident consequences are clearly' unacceptable and will 5 probably require at the minimum that alternative modesThis of 6 transport be considered for such shipments by LILCO.
7 could, of course, affect plant operating cost projections.
8 9 Of greater significance is the uncertainty of costs 10 related to nuclear waste disposal and decontamination andIt.
11 decommissioning as mentioned in my previous testimony.
12 is true that the Federal government has preemptive authority 13 regarding standard and guidance setting, and regulation of 14 nuclear reactors in the areas of reactor safety, radio-15 active waste disposal and decontamination and decommissioning.
16 However, the Siting Board must be cognizant that the stan-17 dards and regulatory programs for radioactive waste disposal 18 and decontamination and decommissioning are just being formu-19 lated now as well as much of the technology to implement thesc We therefore believe, 20 standards and regulatory programs.
21 as was previously expressed, that there is a good deal of
- 22 speculation in the economic and cost figures presented to To illustrate this point, 23 the Siting Board in this area.
' 24 the EPA has found that there is a very high degree of un-25 certainty with regard to estimating risk levels associated 26 with long term high-level was'te disposal.
Uncertainties 27 could range in these risk estimates up to five orders of 28 magnitude. If the risk estimates associated with standard 29 setting are this variable, certainly cost estimates associated 30 with implementing these standards must be considered variable.
31 32 Thus, while the Siting Board must make its decision on this 33 matter using the assumption that the Federal Government will
{*
34 provide adequate standards and regulatory programs, and i
35 that it will develop the necessary technolog ies, the Board 36 is also required to determine whether these costs are capable 37 of quantification such that a rational licensing decision 38 can be made on Jamesport.
39 40 Q. What is the purpose of your testimony? (1) to take 41 A. The purpose of this testimony is fourfold:
42 exception with the recommended decision taken by the Presidin E
43 Examiner, Fredric T. Suss,_ dated May 15, 1979 on Case 80003, i*
44 Long Island Lighting Company - Jamesport Generating Station, i
45 Nuclear. Units 1 and 2 in an application of the Long Island l
46 Lighting Company for a certificate of environmental compata-47 bility and public need to construct'two 1150 MWe nuclear 48 fueled generating units at a site in the Towns of Riverhead 49 and Southold, Suffolk County; (2) to support the opinion i,
50 expressed by the Public Service Commission (PSC) in its
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1 " Order on Appeal Reversing Presiding Examiner's Rulings" 2 issued on January 30, 1976 declaring incorrect the Presiding 3 Examiner's ruling "not to receive evidence concerning any 4 postulated radiological accidents and the consequences there-5 of because this would be sheer speculation not entitled, in 6 his view, to evidentiary weight."*, and to support the PSC's 7 decision "that the effects on health and safety stemming 8 from plants meeting the NRC standards are germane to the 9 comparative environmental evaluation required by the statute 10 of possible alternative means of supplying the power deemed 11 ne,cessary by the applicant"**; (3) to agree with 12 the opinion of the State of New York Board on Electric 13 Generating Siting and the Environment (Siting Board) in 14 " Order Establishing Decision Procedures" dated May 23, 15 1979 "that there was a strong showing that consideration of 16 information not available until after the close of the record 17 would materially affect our (Siting Board) ultimate decision, 18 that the record should be updated, and that the parties shoulc 19 be given an opportunity to be heard on the nature and signifi-20 cance of the additional information to be considered"***; and 21 (4) to provide testimon_y "that these recent developments 22 will have a close and material impact on the evidence accumu-23 lated in the record on these issues to date "****, as stated 24 in the Siting Board's " Order Denying Petitions for Rehearing 25 and Deciding Interlocutory Appeals" issued on March 8, 1979 26 27 Q. Do you have any comments on Presiding Examiner Suss' 28 findings regarding federal jurisdiction over radiological 29 hazards?
30 A. Yes. In the Recommended Decision provided by the Pre-31 siding Examiner, Fredric T. Suss, under Section XII, Radio-32 logical Hazards, Finding No. 320, the Examiner states, "In 33 the Sterling Case _* the Examiners found that Article VIII 34 must be interpreted in the light of Federal jurisdiction and 35 court decisions:
36 37
- " Order on Appeal Reversing Presiding Examiner's Ruling",
38
.39 State of New York Public Service Commission, 1/30/76, p.4.
40
- Ibid, p. 3 41 ,
42 '
43 *** " Order Establishing Decision Proceeding" State of New York 44 Board on Electric Generation Siting and the Environment, 45 May 23, 1979, p. 4. ,
46 47 ** **" Order Denying Petitions for Rehearing and Deciding Inter-48 locutory Appeals", State of.New York Board on Electric 49 Generation, Siting and the Environment", 3/8/79, p. 11.
50 51 52
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1 "Section 141 (4c) of Article VIII states that the article 2 does not apply where the federal government has exclusive 3 jurisdiction. Accordingly, it is concluded that matters 4 concerning radiological health and safety, including 5 such items as the uranium fuel cycle, transportation of 6 radioactive materials, radioactive residuo disposal, and 7 security and decommissioning of nuclear plants, cannot be 8 dealt with in this proceeding. The intervenors have 9 argued at great length on these subjects but all that 10 can be done here is to refer them to the NRC with '
11 assurances that the agency is fully capable of properly 12 dealing with the matters".
13 14 Q. Do you agree with Mr. Suss' findings on this subject?
15 A. No. It is true that the Federal government has overall 16 jurisdiction regarding radiological health and safety, 17 including such items as the uranium fuel cycle, radioactive 18 waste disposal, nuclear power plant security, and decontamina-19 tion and decommissioning of nuclear power plants. But it is 20 important that the Federal government's jurisdiction not be 21 misconstrued. The role.of the Federal government in these 22 areas is generally to set safety, health, and environmental 23 guides and standards, to develop and enforce a regulatory 24 program, and in some cases, such as with nuclear waste disposa l, 25 develop the necessary technology in accordance with standards 26 and regulatory programs. However, in cases where the State 27 becomes involved in the licensing process such as the Article 28 VIII proceedings in New York State, there is a role the State 29 must play in licensing the proposed site. This role involves 30 determining whether the plant, once built and operated in 31 accordance with the various applicable Federal. guidance and 32 regulations, is suitable on the site in question from an 33 environmental and economic standpoint. It is also the functio l 34 of the State to determine which mode of generation (ie., coal, 35 oil, nuclear, cofueling with solid waste, etc. ) is the best
'36 alternative when environmental and economic considerations 37 are reviewed. For example, a hypothetical nuclear power 38 plant when erected on Site A may involve decontamination and
.39 decommissioning costs that are substantially greater than if .
40 the same plant were to be crected on Site B just because of 41 site idiosyncrasies. It is the role of the Article VIII 42 procedure to determine which site, in this case A or B,would 43 be most suitable and this judgment is not one that is reserved 44 for Federal jurisdiction. Similarly, it is the role of New ^
45 York State through Article VIII to determine if a plant 46 fired by coal, or by gas or by uranium is the best for a ,
47 particular site, and not the role of the Federal government.
48 49 Q. Are there other radiological concerns in which the State 50 is not preempted? ,
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- 1 A. Yes. There are also areas involving r,adiation issues 2 that are clearly not reserved for Federal jurisdiction and, 3 in fact, involve State decision. making such as the area of
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4 radiological emergency responce planning around fixed nuclear 5 facilities. Nowhere in the Code of Federal Regulations or in 6 any law promulgated by the U.S. Congress is there any specific 7 reference giving the Federal government preemptive jurisdic-8 tion over the State in radiological emergency response 9 planning around fixed nuclear facilities. On March 18, 1976 10 the U.S. General Accounting Office (GAO) issued a report '
i 11 entitled, Stronger Federal Assistance to States Needed for 12 Radiation Emergency Response Planning 2/ which made the l 13 following_ statements:
l, 14
- 15 "In regulating the construction and operation of these
! 16 power plants, the Nuclear Regulatory Commission requires 17 licensees to develop plans for dealing with radiation 18 emergencies on or near power plant sites, including 19 developing agreements with State and local authorities 20 to obtain emergency assistance.
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22 23 State and local authorities are responsible for coping with radiation emergencies that extend beyond 24 the immediate vicinity of nuclear power plants; j
25 however, no Federal agency has authority to re-26 quire States to develop radiation emergency plans."
27
! 28 Neither NRC nor any other Federal agency has auth>rity to 29 directly require States to develop radiation emergency plans, 30 although a number of agencies have responsibilities for g
31 assisting States and local governments to voluntarily develop 32 plans.
33 34 As was noted in my previously-filed testimony, a Federal 35 Register Notice 1/ dated December 24, 1975 outlines the respon -
. 36 cibilities of various Federal agencies for planning for i 37 incidents involving radioactive materials. Two agencies
! 38 with specific responsibilities in this area are the NRC and i
39 the EPA. On December 1978 an NRC and EPA task force prepared 40 a report entitled, Planning Basis for the Development of State 41 and Local Government Radiological Emergency Response 71ans In 42 Support of Light Water Nuclear Power Plants NUREG-0396, 43 E~PA 520/1-78-016 3/ This document is a report and 44 while it does not constitute formal Federal Radiation 45 Guidance as of yet, the task force does give recommended plann pn f 46 information for radiological emergency response. Specifically ,-
- 47 the task force that prepared NUREG-0396 recommends that j 48 emergency planning should predetermine appropriate emergency 49 responses within an emergency planning zone (EPZ) around r 50 each nuclear facility. EPZ3 should be defined for both 51 52 ,
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1 the short term " plume exposure pathway" and for the longer 2 term " ingestion exposure pathways".
3 4 Q. Please describe emergency planning requirements which 5 the federal government recommends to predetermine appropriate 6 state and local emergency responses within an EPZ around 7 each nuclear facility.
8 A. The Emergency Planning Zone concept is illustrated in 9 Figure 1. EPZs are des.ignated as the areas for which planning 10 is recommended to assure that prompt and effective actiods 11 can be taken to protect the public in the event of an accident.
12 Responsible government officials should apply the applicable 13 planning items listed in Guide and Check List for the Develop--
14 ment and Evaluation of State and local Government Radiologica:
15 Emergency Response Plans in Support of Fixed Nuclear Facilities 16 NUREG-75/111,5/ in the development of radiological emergency 17 response plans. The following are example planning elements 18 considered appropriate for the EPZs:
19 20 1. Identify responsible onsite and offsite emergency 21 response organizations and the mechanisms for acti-22 vating their services, 23 24 2. Establish effective communication networks to
. 25 promptl,r notify cognizant authorities and the 26 public, ,
27 28 3 Designatt pre-determined actions as appropriate 29 and as contained in NUREG-75/111, EPA 520/1-75-001, 30 and Emerguncy Planning such as evacuation, sheltering:
31 and thyroid blocking of iodine, D
32 .
, 33 4. Develop procedures for use by emergency workers, 34 35 5 Identify applicable radiation measurement equipment, 36 37 6. Identify emergency operations centers and alternat.e
, 38 locations, assembly points, and radiation moniboring-l 39 locations,
~40 41 7 Implement training programs for emergency workers 42 as appropriate, and 43 44 8 : Develop test procedures for emergency response plans.
1 45 "
46 Emergency planning should predetermine. appropriate emergency .
47 responses within the EPZ as a' function of population groups, 48 environmental conditions 6/, plant conditions 1/, and time' '
49 invailable'to-respond. For the' plume exposure phase,. shelter 50 -and/or evacuation would likely be the principle immediate 51 n
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1 protective actions to be recommended for the general public 2 within the EPZ. The ability to best reduce exposure should 3 determine the appropriate response. -
4 5 For the ingestion exposure Emergency Planning Zone, the 6 planning effort involves the identification of major exposure 7 pathways.from contaminated food and water and the associated' 8 control points and mechanisms. The ingestion pathway exposurc- s 9 in general would represent a longer term problem, although sor e 10 carly protective actions to minimize subsequent contamination 11 of milk or other supplies should be ir.itiated (eg., put 12 cows on stored feed).
13 14 The EPZ guidance does not change the requirements for emergenc y 15 planning, it only sets bounds on the planning problem.
16 17 Q. How is the size of the EPZ established?
18 A. Several possible rationales were considered by the task 19 force for establishing the size of the EPZs. These included 20 risk, probability, cost effectiveness and accident consequenct 21 spectrum. After reviewing these alternatives, the. Task Force 22 chose to base the rationale on a full spectrum of accidents 23 and corresponding consequences t'empered by probability con-24 siderations. These rationales are discussed more fully in 25 Appendix I to NUREG-0396.
26 27 The Task Force that prepared NUREG-0396 agreed that emergency 28 response plans should be useful for responding to any accident 29 that would produce offsite doses in excess of the PAGs. This 30 would include the more severe design basis accidents and the 31 accident spectrum analyzed in the Reactor Safety Study @/.
32 After reviewing the potential consequences associated wi,th 33 these types of accidents, it was the consensus of the Task 34 Force that emergency plans could be based upon a generic 35 distance out to which predetermined actions would provide 36 done savings for any such accidents. Beyond this generic 37 distance it was concluded that actions could be taken on 38 an ad hoc basis using the same considerations that went into 39 the initial action determinations.
40 41 Q. What is the relationship between the size of the EPZ and 42 . possible accidents?
43 A. The Task Force judgment on the extent of the Emergency 44 Planning Zone is derived from the characteristics of design 45 basis and Class 9 accident consequences. Based on the infor-46 mation provided in Appendix I to NUREG-0396, and the appli-47 cable PAGs a radius of about 10 miles was selected for the 48 plume exposure pathway and a radius of Ebout 50 miles was 49 selected for the ingestion exposure pathway, as shown in tabic 1 50 Although the radius for the EPZ implies a circular area, the act 51 52 4
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L .J D 1 shape would depend upon the characteristics of a particular 2 site. The circular or other defined area would be for 3 planning whereas initial response would likely involve only .
4 a portion of the total area. -
5 6 The EPZ recommended is of sufficient size to provide dose 7 savings to the population in areas where the projected dose 8 from design basis accidents could be expected to exceed the 9 applicable PAGs under unfavorable atmospheric conditions.,
10 As illustrated in Appendix I to NUREG-0396, consequences of 11 less severe Class 9 accidents would not exceed the PAG levels 12 outside the recommended EPZ distance. In addition, the EPZ 13 is of sufficient size to provide for substantial reduction in 14 early severe health effects (injuries or deaths) in the event 15 of the more' severe Class 9 accidents.
16 17 Table 1. Guidance on Size of the Emergency Planning 18 Zone 19 Critical Organ .
20 Accident Phase Exoosure Pathway EPZ Radius 21
, 22 . .
23 Plume Exposure Whole Body (external) about 10 mile 24 Pathway radius #
. 25 26 Thyroid (inhalation).
27 28 Other organs (inhalation) 29 30 Ingestion Pathway ** Thyroid, whole' body about 50 mile. ,
31 bone marrow radius ***
32 ,
(ingestion) 33 34 35 -
36
- Judgment should be used in adopting this distance based 37 upon considerations of local conditions such as demography ,
38 topography, land characteristics, access routes, and 39 local jurisdictional boundaries.
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- Processing plants for milk produced within the EPZ should 41 42 be included in the emergency response plans regardless 43 of their location.
44 *** The recommended' size' of the ingestion exposure EPZ is base i 45 on an expected revision of milk pathway Protective Action 46 Guides based on FDA-Bureau of Radiological Health recommen--
47 dations.- The Task Force understands that: measures'such as 48 placing dairy cows on stored feed will'be recommended' for 49 projected exposure levels as low.as about 1 5 rem to the 50 infant thyroid. Should the current FRC guidelines, 10 rem 51 2,/ be maintained, an EPZ of about 25 mi,les would achieve 52 thn nhjectiven ne tha mn n te vnnno.
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]l 1 Q. What are the time factors associated with releases?
2 A. The planning time frames are based on design basis 3 accident considerations and the results of calculations 4 reported in the Reactor Safety Study 8/. The guidance cannot 5 be very specific because of the wide range of time frames 6 associated with the spectrum of accidents considered. There-7 fore, it, will be necessary for planners to consider the pos-8 sible different time periods between the initiating event and 9 the arrival of the plume and possible time periods of releasea 10 in relationship to time needed to implement protective actionn .
11 The Reactor Safety Study indicates, for example, that major 12 releases may begin in the range of one-half hour to as much 13 as 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> after an initiating event and that the duration 14 of the releases may range from one-half hour to several days 15 with the major portion of the release occurring well within g 16 the first day. In addition, significant plume travel times 17 are associated with the most adverse meteorological conditionn 18 that might result in large potential exposures far from the 19 site. For example, under poor dispersion conditions associated 20 with low windspeeds, two hours or more might be required for 21 the plume to travel a distance of five miles. Higher wind-
, 22 speeds would result in shorter travel times but would provide 23 more dispersion, making high exposures at long distances much 24 less likely. Therefore, in most cases, significant advance
. 25 warning of high concentrations should be available since
. 26 NRC regulations 7/ 10/ require early notification of offsite 27 authorities for major releases of radioactive material. The 28 warning time could be somewhat different for reactors with 29 different containment ch'aracteristics than those analyzed 30 in the Reactor Safety Study. The range of times, however, 31 is judged suitably representative for the purpose of developir g 32 emergency plans. Shorter release initiation times are typi-33 cally associated with design basis events of much smaller 34 potential consequences or with the more severe Reactor Safety 35 Study accident sequences.
36 37 Q. How do the time factors associated with releases affect 38 emergency planning? .
39 A. The planning basis for the time dependence of a release 40 is expressed as a range of time values in which to implement i_ 41 protective action. This range of values prior to the start 42 of a major release is of the order of one-half hour to several 43 hours. The subsequent time period over which radioactive 44 material may be expected to be released is of the order of 1 .
45 one-half hour (short-term release) to a few days (continuous 46 release). Table 2 summarizes the Task Force guidance on the 47 time of the release. .
48 >
u49 The time available for action is strongly related to the time I 50 consumed in notification that conditions exist that'could caure
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. 1 a major release or that a major release is occurring. Develor -
2 ment and periodic testing of procedures for rapid notification 3 are encouraged. It is generally recommended that each State 4 plan be fully tested once per year so that accurances can be 5 made that appropriate protective actions such as evacuation, 6 and sheltering can be taken at the PAG levels.
7 8
9 Table 2 - Guidance on Initiation and Duration of Release '
10 .
11 Time from the initiating event 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> to one day 12 to start of atmospheric release 13 14 Time period over which radioactive 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> to several 15 material may be continuously released days 16 17 Time at which major portion of 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> to 1 day afte r 18 release may occur start of release 19 20 Travel time for release to ex- 5 miles - 0.5 to 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> a 21 posure point (time after release) 10 miles - 1 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 22 23 24 Q. What are the radiological characteristics of releases?
25 A. To specify the characteristics of monitoring instrumen-26 tation*, develop decisional aids to estimate projected doses, 27 and identify critical exposure modes,, planners will need .
28 information on the characteristics of potential radioactivity 29 releases. For atmospheric releases from nuclear power 30 facilities, three dominant exposure modes have been identified .
31 These are (1) uhole body (bone marrow) exposure from external 32 gamma radiation and from ingestion of radioactive material; 33 (2) thyroid exposure from inhalation or ingestion of radio-34 iodines; and (3) exposure of other organs (eg., lung) from 35 inhalation or ingestion of radioactive materials. Any of 36 these exposure modes could dominate (ie., result in the 37 largest exposures) depending upon the relative quantities
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- 38 of various isotopes released. -
! 39
! 40 Radioactive materials produced in the operation of nuclear 41 reactors include fission products and transuranics generated
! 42 within the fuel material itself and activation products 43 generated by neutron exposure of the structural and other 44 materials within and immediately around the reactor core.
45 -
46 47 *An Interagency Task Force on Emergency Instrumentation (off-
. 48 site) is now preparing guidance 11/ on the type and quantity 49 of instruments needed for the va?lous exposure pathways.
50 Federal agencies represented on the Instrumentation Task Force 51 include NRC, EPA, DCPA, HEW & DOE.
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1 The fission products consist of a very.large number of 2 different kinds of isotopes (nuclides), almost all of which 3 are ir.itially radioactive. The amounts of these fission 4 products and their potential for escape from their normal 5 places of confinement represent the dominant potential 6 for escape from their normal places of confinement represent 7 the dominant potential for consequences to the public.
8 Radioactive fission products exist in a variety of physical 9 and chemical forms of varied volatility. Virtually all ,
10 activation products and transuranics exist as non-volatile 11 solids. The characteristics of these materials shows quite 12 clearly that the potential for releases to the environment 13 decreases dramatically in this order: (1) gaseous materials; 14 (2) volatile solids; and (3) non-volatile solids. For this 15 reason, guidance for source terms representing hypothetical 16 fission product activity within a nuclear power plant contain-17 ment structure emphasizes the development of plans rel'a ting 18 to the release of noble gases and of volatiles such as 19 iodine. However, consideration of particulate materials 20 should not be complete'ly neglected. For example, capability 21 to determine the presence or absence of key particulate
. 22 radionuclides will be needed to identify requirements for 23 additional resources.
24 25 Tabic 3 provides a list of key radionuclides that might be -
26 expected to be dominant for.cach exposure pathway. More 27 detailed lists of core inventories are presented in Chapter 28 15 of recent Safety Analysis Reports and in Appendix V of 29 the Reactor Safety Study. Both of these sources give 30 details on the time histories of the release fractions for 31 a spectrum of postulated accidents.
32 w
33 Q. Do you have an opinion as to the radiation exposure that ~~~
34 could result from a design base accident at Jamesport?
35 A. Yes. Based on our review of the Jamesport faci,lity and l 3G our analysis of the 10 mile EPZ for the inhalation pathway, L i
37 EPA believes that a design base accident could result in the -
38 release of sufficient radioactivity so as to cause radiation 39 exposures to the general population above EPA protective 40 action guide levels of 1 to 5 rems for whole body exposures 41 to airborne radioactive materials and-5 to 25 rems for thyroi t 42 doses due to inhalation from a passing plume in a large 43 portion of the 10 mile EPZ (see Figures 2,3,4). Further we 44 project doses from such an accident could_ be realized at a 45 level'above 5 rems t'o the adult thyroid 10' miles.from the
-46 facility within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, and at a level above 1 rem to_the 47 whole: body 5 miles out from the facility within 2 1.nurs. Ex-48 posures lasting up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> could result in-a 25 rem exposu re 49 to the adult thyroid within a 5 mile radius.of the-plant.
50 These estimates all? assume no protective-actions are taken.
. 51 +
52 1
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Tabic 3 ,
WI gC,]
RADIONUCLIDES WITH SIGNIFICANT CONTRIBUTION TO DCitINANT EXPOSURE MODES _-
M Radionuclides with Significant g, Contribution to Lung Exposure *
(Lung only controlling when , ,
g thyroid dose is reduced by iodine
__ g Radionuclides with Significant blocking or there is a long delay Radionuclides with Significant Contribution to Thyroid Exposure Centribution to Whole Body Exposure prior to releases). O~
Half Life Half Life A Half Life -
(days)_
Radionuclide (days) Radionuclide_ (days) Radionuclide f' 8.05 I-1 31 8.05 I-131 8.0a j I-131 . e 0.0858 Te-132 3.25 ' I-132 0.0858 g I-132 '
O.875 I I-133 0.875 Xc-133 5.28 I-133 0.0366 I-133 0.875 I-134 0.0365 I-134 Xe-135 0.384 I-135 .028 I-135 .028 I-135 .028 Cs-134 750 L Te-132 3.25
-0.117 Cs-134 '750 Kr-88 0.117 f
.Kr-88 Kr-88 0.117 Cs-137 11,000 Cs-137 11,000 Ru-106 355 Te-132 3.25
! ' Ce-144 284 I '
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Figure 3 l ADULT THYR 0lD lHH ALATION DOSE FROM ALL 10 DINES VS. DISTANCE N 100 % DBA JAMESPORT.
30
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Figure 14 INFANT THYROID DOSE VIA MILX Gh FROM GR AZlHG COWS V5. DISTANCE g .I HO PROTECTIVE ACTIONS ....
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[
D f) ]
Would the consequences of a DBA be affected by prevailing
~
1 Q.
2 meteorological conditions?
3 h A. Y e s . . ._ E PA_, in its review of the local geograohyJithin_th,e 4 EPZ. notepl h3T~s[duld j ide.sigo__ base accident occur at a time 5 where the wind was blowing from the east--no_rlheasjlq_t_hq_w.en-northwest. the ma.for routes of land evacuation __gnguDd_thq_
6 7 proposed Jamesport facilit,y would be susceptible to the.highe_si 8 exposure levels. This could make evacuation as a nn_qtc.clive 9 action impossible. This would leave sheltering as the_on}y_
10 available protective action that could be us_ed_ho.ci.tigat_e 11 both the whole body and thyrQ_i_d i dcag.s_from nelga.s_es_.of_np.b,lp 12 gases and iodine.
13 14 Q. How effective would sheltering be as a protective action 15 in the event of a Jamesport DBA? l 16 A. EPA has investigated the relative effectiveness of 17 sheltering as a protective action and has published a report 18 on this subject entitled, The Effectiveness of Sheltering as j 19 a Protective Action Against Nuclear Accidents involving Gas- j 20 eous Releases Parts I and II, 520/1-78-001 A & B.12/ This ;
21 report provides information with regard to the relative 22 effectiveness of evacuation and sheltering as protective 23 actions. It turns out that evacuation is the only action, ,
24 that when executed properly, can achieve 100 percent effec- l 25 tiveness as far as dose reduction is concerned. While i 26 sheltering can provide dose reduction EPA 520/1-78-001 A&B l 27 states: !;
28 l 29 " Sheltering becomes less attractive compared with 30 evacuation for increasing durations of airborne ex-31 posure for whole body and thyroid dose considerations -
particularly small structure shelte' ring. For example, 32 33 for exposure ddrations of around 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> or more, 34 evacuation would be largely recommended in lieu of 35 small structure sheltering. Large structure sheltdr-36 ing, however, may still be somewhat competitive with 37 evacuation as an emergency protective action for 38 cloud exposure periods between 3 and 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Even 39 at 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, however, the large structure shelter with 40 a low ventilation rate may be only marginally compe-41 titive for certain situations of predicted long -
42 evacuation transit times away from the radioactive
~43 source region".
44 45 Q. How effective would evacuation be as a protective action 46 in the event of a Jamesport DBA?
47 A. Based on these studies and review of the previously 48 mentioned facts, EPA believes that exposures above EPA 49 PAG levels could occur within a 10 mile EPZ in a rapid 50 fashion and that using evacuation.as a protective action 51 52
e .
" 18.
l:
h h__ b ,cbg
. . - - . - ~ . . . - - . .
1 to mitigate such exposures may not be possible for over 40%
2 l of the time based on wind directions presented in the James-3 l port Final Environmental Impact Statement NUREG 75/079 13/
4 Utilization of sheltering as an alternate protective action 5 to evacuation does not appear as a suitable alternative for 6 exposure duration'in excess of 3 to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. For this 7 reason 1t seems reasonable to state based on the latest 8 available information that sheltering may not be adequate and 9 evacuation may not be possible for a large portion of the, 10 general population surrounding the proposed Jamesport facility 11 and within the EPZ.
12 13 Q. How does your finding relate to N.Y. State's radiological 14 emergency response plan?
15 A. This finding is in no way a negative commentary on the '
16 New York State radiological emergency response plan which 17 was formulated by the New York State Department of Health s 18 (DOH). EPA notes that DOH has formulated a plan which require d 19 a substantial level of effort. The result of DOH's diligent pursuit of this is a plan that has received the concurrence ,T 20 21 in February of 1979 of the NRC pending successful field l
. 22 testing. EPA is aware of DOH's.cfforts as we have participated, 23 in the concurrence process. EPA notes that DOH has provided ,
24 as part of its plan a detailed specific operating procedure ?
25 (SOP) for the area adjacent to each operating nuclear facility - '
26 in the State. These SOPS will attempt to utilize EPA PAG 27 and protective action guidance to the best extent possible. ,
28 EPA's review of these SOPS for existing reactors that have 29 operating licenses in the State of New York leads us to believe 30 that DOH should be able to assure that evacuation of the 31 general population within the 10 mile EPZ surrounding these '
32 facilities during accidents such as a design base accident 33 would be possible under all but the most unfavorable conditions 34 (ie., an extremely large snowfall concurrent with an accident) .
35 Based on this beller, EPA thinks that DOH has fulfilled 36 their emergency response planning responsibilities.
37 33 Q. Does the Jamesport site meet EPA's PAG guidance?
39 A. Apparently No. EPA believes that if the Jamesport site 40 is licensed DOH will find it virtually. impossible to provide 41 the same reasonable assurances of meeting EPA PAG guidance 42 when it must formulate its SOP for Jamesport. This will not 43 occur for reasons of lack of competence or diligence but 44 because'of the physical impossibility of the situation. DOH 45 would truly be in an untenable position because the only 46 way adequate protective actions could be carried out would 47 be to prescribe unprecedented planning measures such as 48 air tight long term shelters for everyone in the 49 EPZ and located and spaced so that they could be reached 50 Mithout restrictii.s access to the shelters. Such unpre-51 52
19 1 cedented planning measures would be very costly and would 2
run counter to the recommendations made by the joint NRC-3 EPA task force report in NUREG-0396. In fact, the task 4 force stated in that report several examples of emergency 5 procedures it does not recommend as being justified by the 6 report; that is the task force report should not be used as 7 justification for developing these "Nocapabilities special localfor these decontaminat ion 8 protective actions. These are: ~
9 provisions for the general public (eg., blankets,. changes of ine clothing, food, special showers) . No stockpiles _ of anti-c'entan 10 11 ation equipment for the general public.No No construction special of radiological 12 specially equipped fall-out shelter.
13 medical provisions for the general public. No new constructic n No speciall 14 of special public facilities for emergency use.No special decontaminati on 15 stockpiles of emergency animal feed. ~No participation by the 16 equipment for property and equipment.
17 general public in test exercises of emergency plans."
18 Is the Siting Board preempted from refusing to certify 19 Q.
20 the Jamesport site based on radiological em'ergency response-21 grounds?
22 A. No. Since it is clear that the area surrounding the 23 Jamesport facility will not be susceptible to the same 24 radiation protection recommendations that are achievable a:
25 at virtually every other operating reactor site in the country 26 that are recommended by the Federal government, the question 27 then becomes does the State of New York through the Article VIII process or through the Siting Board have any jurisdictior.
l 28 29 in this area so that it can mitigate this problem. Presiding
~
30 Examinder Suss in the his recommended decision State'is preempted fromhasthis at several area times stated that 31 32 and it would be inappropriate for the State to base its sitin g 33 decision on radiological emergency response planning. EPA be-34 lieves-these findings made by Presiding Examiner Suss are in- g 35 correct and to the_ contrary, EPA believes that making a'Sitin re-36 decision on radiological emergency response _is not only not p that the State siting 37 empted by the Federal jurisdiction, but 38 process is the most appropriate place for this type of decision- n-39 making, considering it is the State and not the Federal gover 40 ment that has the ultimate' responsibility for formulating and l-41 executing a State radiological emergency . response plan for a l
l 42 fixed nuclear facility disaster.
43 5: 44 Q. What is the basis for your opinion?
- 1. The U.S. NRC is the responsible agency for issuing-45 A.
L 4-46 a construction permit (CP) or_an operating license (OL) ll 47 for a nuclear power plant. The NRC has in the-past and '
11 48 can today issue a CP or an OL without the affected State l '
49 having an emergency response plan let'alone one that has-received NRC's concurrence. Today, over 24 States ha l
"e 50 l
51 commercial nuclear power plants licensed to operate,'yet j ;,
52 only 12 have concurred in radiological emergency response 3
- - - z -. _--%
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. _: - - . . .u I -e 1 i plans. However, virtually all of the plants licensed l
2 l in these 12 states were licensed prior to the State 3 ! Emergency plan receiving NRC concurrence.
4 i 5 l 2. There are no NRC rules or regulations preempting 6 States from using emergency response or -protective action l 7 matters as a decision making tool in determining which l 8 proposed site is best for a nuclear reactor.
9 10 3 There is no NRC rule or regulation preempting a 11 State from refusing to certify site based on radiolo-
, 12 gical emergency response grounds even after the NRC 13 has. issued a construction permit for the facility in 14 question.
15 16 4. The only NRC regulations governing emergency response 17 are contained in Appendix E to 10 CFR 50 10/ and these only 18 require that the~ facility operator and the local govern-19 ments adjacent to the facility enter into an agreement 20 on the necessary emergency response functions in.a 21 limited area, usually extending no further than the
. 22 '
EPZ and generally an area much-smaller than the LPZ.
23 24 5 The NRC has no official jurisdiction over. State
- 25 radiological emergency response plans other than 26 as to provide guidance, advice, and a procedure for. which -
27 the State may get concurrence in their plan. The 28 NRC does not license State plans.
29 30 Q. Please summarize your findings and your Agency's position 31 on the Jamesport site.
32 A. Based on our findings, EPA recommends that the Siting 33 Board deny the Application of Long Island Lighting Company 34 for a certificate of environmental compatibility and public .
35 need to construct two'1150 MWe nuclear fueled generating 36 units at a site in the Towns of Riverhead and Southold, 37 Suffolk County, on.the grounds that the State of'New York 38 could not provide radiological emergency' response protection 39 to citizens residing within a ten-mile radius of the pro--
l 40 posed plant that is consistent with protective actions-41 outlined in EPA's Manual of Protective Action Guides and 42 Protective. Actions for Nuclear Accidents.
43 44 EPA also finds .that other issues 'related to radiation such 45 as the costs associated with decontamination and decommissioning.
46 radioactive waste disposal, and radioactive material shipments,
, provide sufficient uncertainties to make a positive determinat ior l 47 L 48 as to whether the Jamesport site is ultimately acceptable 49 highly speculative.
50 l .
l p
. e' .
REFERENCES ,
.l. Transport of Radionuclides in Urban Environs: A Horking Or af t Assessment, SAND 77-1927, May 1978, Sandia Laboratories Albuquerque, New Mexico.
~
- 2. Stronger Federal Assistance ot States Needed for Radiation Emergency _
Response Planning,!! arch 19,1976, 'J.S.Seneral Accounting O f fice ,
3ashington, D.C.
- 3. Federal Register, Volume 40, No. 248, December 24, 1975, Page3 59494 ,
59495
- 4. Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans In Support of Light Water Nuclear Power Plants NUREG-0396, EPA 520/1-78-016, December 1978 U.S. f!uclear Regulatory Commission and U.S. Environmental Protection Agency, Washington, D.C. s
- 5. Guide and Check List for the Development and Evaluation of State and Local Government Radiological Emergency Response Plans in Support of Fixed Nuclear Facilities, MUREG-75/lll, Dec.1974, U.S. "uclear Regulatory Commission.
- 6. Manual of Protective Action Guides and Protective Actions for Nuclear incidents , EPA-520/1-75-001, Sept.1975, U.S. Environmental Protection .
Agency.
- 7. Emergency Planning for Nuclear Power Plants , Gegulatory Guide .l .101,
, Mar.1977. .U .S. Muclear Regulatory Commission, Mashington, D.C.
- 8. Reactor Safety Study: An Assessment of Accident Risks in U.S.
Commercial Nuclear Power Plants, (flVREG-75/014), October 1975, UASH-1400, U.S. Nuclear Regulatory Commission.
- 9. Federal Radiation Council Staff Report No. 5, July 1964; Staff Report No. 7,' lay 1965.
10.10 CFR Part 50, Licensing of Production and Utilization Facility,_
Appendix E, U.S. Nuclear Regulatory Commission, Washington, 9.C.
i
- 11. Interim Guidance on Offsite Radiation Measurement Systems, A Report to Developers of State Radiological Emergency Response Plans by the Federal Interagency Task Force on (offsite) Emergency Instrumentation l
for Nuclear Incidents at Fixed Facilities, August 1977,~U.S. Nuclear Regulatory Commission, Mashington, D.C.
- 12. The Effectiveness of Sheltering as a Protective Action Against
! Nuclear Accidents involving Gaseous Releases, Parts I and II, EPA 520/1-78-001 A & B, April 1978, U.S. Environmental Protection Agency, Washington, D.C.
- 13. Final Environmental Statement Related to the Construction of Jamesport Nuclear Power Station, Units 1 and 2, MUREG-75/079, October 1975, U.S. Nuclear Regulatory Commission Washington, 7.0.
- 14. Federal Response Plan for Peacetime' Nuclear Emergencies (Interim Guidance)_ April 1977. Federal Preparedness Agency, General Services Administration.
- - - - . .- a._..... _ .a. . _ .._ _ , _ _ , _ , , _ , _ . , , _ , . , , , _ _ _
~ . .
Appendix "A" .
STATEMEllT OF PROFESSIOi!Al. QUALIFICATI0flS,
, , Til b nM h f Li u M al h ej_[ h lr q[d h b QUALIFICATI0tl 0F PAUL A. GIARDIffA ily name is Paul A. Giardina. My business is the United States Environ-mental Protection Agency, (EPA) Region II, 26 Federal Plaza, .*few York,
!!ew York. Since July 1975 I have been employed by the EPA as follows:
July 1975-February 1977 Regional Radiation Representative February 1977-June 1978 Chief, Regional Office of Radiation Programs June 1978-July 1978 Acting Director, Environmental Programs Div.
July 1978-flovember 1978 Chief, Regional Office of Radiation Programs flovember 1978-Present Chief, Radiation Branch for the Region II Office which includes flew York, flew Jersey, Puerto Rico and the Virgin Islands. I have reported to the Director of the Environmental Programs Division from July 1975 until flovember 1978 except when I acted as the Direc. tor at which time I reported to the Regional Adminis tra tor. From flovember 1978 to the present I have reported to the Director of the Air and Hazardous Materials Division. *1y responsibilities include the formulation and execution of the Region II Radiation Program.
This program includes: the radiological review of light water nuclear power plant environmental impact statements; assistance to States in development, testing, evaluation, modification and maintenance of State
- radiological emergency response plans; the gathering and reporting of technical information on selected facilities and procedures including nuclear power plants, radioactive waste disposal sites, and radioactive shipment transport methods; and other technical assistance to States pertaining to radiation program activities. In carrying out these responsibilities, personnel under my direction provide technical support for the Agency's Regional radiation program. ,
I received my Bachelor of Science in Nuclear Engineering from the Univer-sity of tilchigan (Table A-1 contains pertinent course work completed) in .
1971 and my Masters of Science in Nuclear Engineering from the New York University Institute of Environmental tiedicine and the School of Engineering (Table A-2 centains pertinent course work completed) in 1973.
In flovember 1978 I took part and received a certificate of completion for the Masters Seminar in Environmental Law and Regulations from the Govern- '
l .nent Insti tute, Incorporated.
From 1974 to 1975, I was employed by Ebasco Services Incorporated in the Consulting Environmental Engineering Department as an Associate Air Quality Engineer. From 1971 to 1974, I was employed by the Consolidated Edison Company of flew York Incorporated in the Office of Environmental Affairs and held the title of an Assistant and an Associate Air Quality Control Engineer.
I am a member of the American Association for the Advancement of Science, the American fluclear Society, the Health Physics Society and.
the League of Technical Professionals. ,
. . . . ~.. ...-...,_ -
- A A-?
. Table A-1 Pertinent Undergraduate Course (fork Principles of Nuclear Engineering I Principles of Nuclear Engineering II Nuclear Engineering Materials Applied Radiation Laboratory Nuclear Reactor Theory I i
Nuclear Reactor Theory II Nuclear Radiation Measurements Thermonuclear Fusion Nuclear Reactor Laboratory Table A-2 Pertinent Graduate Course llork Radiological Health Radiation Protection Radiation Hygiene Measurements Reactor Theory I Reactor. Theory II .
~
Environmental Toxicology Environmental Contamination --
Problems in Environmental- Health Dispersion of Pollutants in the Atmosphere
' Air Pollution
- Air Pollution Engineering
( .
o *g [_
e AFFIDAVIT OF PAUL A. GIARDINA STATE OF NEW YORK) ss.:
COUNTY OF SUFFOLK)
PAUL A. GIARDINA, being duly sworn, states as follows:
- 1. I am the Chief of the Radiation Branch for the Environmental Protection Agency, Region II office, located at 26 Federal Plaza, New York, New York, 10007;
- 2. I have prepared testimony on behalf of the County of Suffolk for submission in Case 80003 related to emergency response planning and radiation health effects issues. A statement of my professional qualifications is appended thereto. The statements contained in my testimony are ue and correct to the best of my knowledge and bel-9 - .
! th ' y he-Paul A/. G iardina
~
Sworn to before me this 29th day of June, 1979.
i JJ ,
i b 4, -
JANICE M. OLSEN NOTARY PUBLIC, State of Nu. h,rk No. 524527177, Suffolk County Term Empires March 30,19 90 i
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