ML19343B019
| ML19343B019 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 11/13/1980 |
| From: | Bickwit L NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | |
| Shared Package | |
| ML19343B017 | List: |
| References | |
| REF-10CFR9.7, TASK-PS, TASK-SE SECY-A-80-179, SECY-A-80-179A, NUDOCS 8011240478 | |
| Download: ML19343B019 (33) | |
Text
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ki UNITED STATES NUCLEAR REGULATORY COMMISSION WASmNGTON, D. C. 20555 November 13, 1980 SECY-A 17 9A POLICY SESSION ITENi ADJUDICATCrRY~
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For:
The Commissioners From:
Leonard Bickwit, Jr.
General Counsel Subiect:
INDIAN POINT ORDER Discussion:
Earlier today, Commissioner Bradford circulated a redraft of the Indian Point order, marked up to include Commissioners' positions on the various issues now outstanding.
Attachment A to this paper is a retyped copy of Commissioner Bradford's version.
No changes have been made, except that where a paragraph was so heavily annotated and corrected with different views as to be difficult to comprehend, we have in places set forth dif-ferent commissioners' versions in complete sen-tences or paragraphs.
We have introduced no changes or proposals of our own, except to insert the correct date (May 30) of the Commission's earlier order.
As a result, some editorial anoma-lies have been preserved from earlier versions, and will require correction (e.g., paragraph 14, which should be deleted).
vic Stello will be briefing the Commission on November 14 on the recent events at Indian Point Unit 2 involving leakage of water into the reactor cavity.
One approach which the Commission may wish to consider is to defer a decision on interim operation of Units 2 and 3 while it investigates those events and their implications.
We have drafted a paragraph (Attachment B) which would state that the Commission has decided on that course of action.
SECY NOTE:
This paper, which is identical to advance copies which CONTACT:
were distributed to Commission Peter Crane, GC offices early A.M. on N'ovember 14, 634-1465 1980, is scheduled for discussion at an open meeting on Friday, November 14.
801124 0192G
s' o
2 i
On November 13, we circulated a memorandum pro-posing a footnote dealing with procedural matters.
That footnote is reprint.ed here as Attachment C.
4 i
4
-Q r W
,.k.
Leonard Bickwit, Jr.}
General Counsel Attachments:
1.
Attachment A 2.
Attachment B 3.
Attachment C i
I e
ATTACHMENT A i
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION COMMISSIONERS:
John F. Ahearne, Chaiman Victor Gilinsky Joseph M. Hendrie Peter A. Bradford CONSOLIDATED EDIS0N COMPANY OF NEW YORK (Indian Point,
)
UnitNo.2)
)
) Docket Nos. 50-274 POWER AUTHORITY OF THE STATE
)
50-286 0F NEW YORK (Indian Point,
)
Unit No. 3)
MEMORANDUM AND ORDER Background
- On May 30,1980, the Commission issued an order establishing a four-pronged approach for resolving the 1
I issues raised by the Union of Concerned Scientists' petition regarding the Indian Point nuclear facilities, and by the decision of the Director, Office of Nuclear The Cc;anission has received a motion from the Union of Concerned Scientists, dated June 23, 1980, request-ing the disqualification of Commissioner Hendrie from participation in this matter.
In its Diablo Canyon decision (In the Matter of Pacific Gas and Electric, 11 NRC 411 (1980), the Commission, with Commissioner Bradford dissenting, stated that requests for the disqualification of a Commissioner would not be enter-tained by the Commission as a whole but would be r,' erred to the Commissioner whose disqualification was requested. By memorandum of April 23, 1980, Commissioner Hendrie has denied the request for his 1
disqualification.
4 2
Reactor Regulation (NRR), granting in part and denying in part that petition. Me order announced the Commission's intention to hold a discretionary adjudication for the resolution of safety issues concerning the plants; initiated an infomal proceeding for the purpose of defining the questions to be answered in that adjudication, as well as the criteria to be applied; announced the Commission's plan to address the generic question of the e
operation of nuclear reactors in areas of high population density through a generic proceeding, to be decided at a later date; and directed the Commission's General Counsel and Director, Office of Policy Evaluation, to establish a Task Force to address the question of the status of the reactors during the pendency of the planned adjudication.
In this order, we will deal with the issue of interim operation of the Indian Point units during the adjudi-catory hearing and will take the steps necessary to initiate that adjudicatory hearing.
Interim Ooeration The Commission must decide whether the Indian Point Units 2 and 3 should continue to operate on an interim basis during the g
time it takes to complete the adjudicatory hearing we order today. A decision on interim operation is not a decision about the long-tem safety of the Indian Point plants.
In his decision on February 11, 1980, the Director of Nuclear Reactor Regulation found that the interim risk of the continued operation of the Indian Point units did not warrant their shutdown
3 while the matter was being further considered.
Addi tionally, i
the Task Force, fomed to conduct a separate investigation of comparative risks of interim operation, has now completed its work.
The conclusion of the Task Force is that the overall risk of the Indian Point reactor is about the same as the typical reactor on a typical site.
The Task Force found that although the Indian Point site is considerably more risky than the average nuclear power plant site because of the density of the surrounding population, the design features of the plants reduce the accident risk from Indian Point by a comparable factor. The report acknowledged, however, that the degree of uncertainty for the design comparison is much greater than for the site comparison.
Based upon this report, as well as the Director's previous decision, we conclude that the risk posed by the operation of the Indian Point facilities does not warrant the suspension of the operating license during the adjudicatory proceedings.
The Task Force findings and the Director's findings are not the final judgment on the safety of Indian Point Units 2 and 3.
That final judgment may only be made after all parties have had the opportunity to examine in detail the Task Force report and other evidence presented by the NRC staff and present additional evidence of their own.
In the event that the Licensing Board conducting the adjudication detennines that new evidence wat rants interim relief, it may at any time recommend a course of action to the Commission.
[A summary of the Task Force report my be found
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4 I
as Appendix A to this decision and the report itself will be distributed free upon a written request to the NRC.] [PB:
The Task Force Report itself will be distributed free upon a written request to the NRC.]
In making this decision, we have considered the positions gy taken by the many commenters.
Certain of those positions warrant specific discussion.
UCS has alleged that there are specific safety defects in the Indian Point units which raise questions about whether or not the units comply with NRC regulations.
The Director responded to these allegations in his February 11, 1980 Order and UCS responded in turn in the submittal of Itarch 10, 1980.
- 5 We beline these specific allegations raise issues which are best resolved in the forthcoming adjudicatory proceedings. We have not made a judgment about these allegations and rely in the interim upon the judgment of the Director of NRR.
However, we do note that the Task Force report found no significant difference in risk between the Indian Point 2 and 3 designs.
It also found that the technical fixes ordered in the Director's decision would be clearly beneficial in reducing risk, [but it is questionable]
[PB:
but questioned] whether the factor of improvement [is statistically significant when looking at overall risk] [JA, VG, PB:
is significant in light of the uncertainties in estimating overall risk],
If the Board at any time during the proceeding believes that any of these issues are serious enough to warrant immediate action, it should make an appropriate recommendation to the Commission.
5 Several commenters contended that the Commission should not pemit continued operation because of the lack of an emergency plan for the surrounding area. While a successful N [P plan for evacuation at Indian Point would probably reduce overall risk, the fact is that most operating reactor sites do not have an approved plan and Indian Point is not different in this regard.
New York PIRG requested that we make no decision on interim operation until Senate confimation of a new chaiman. We cannot delay Commission business pending a confimation process which is beyond our control.
Furthemore, such delay would not make
.a significant difference in this case since the decision on h) interim operation is unanimous.
New York PIRG also requested that the Commission examine a copy of the FEMA review on the status of state and local emergency planning ordered by the President.
We have examined this report and it does not change the opinion on emergency planning we expressed above.
We note that the Governor of New York has strongly urged ki that the plants remain in operation pending the outcome of the proceeding.
Both UCS and New York PIRG sought to address the Commission pq orally on the subject of interin operation.
By a vote of 2-2, that request was denied.
Adjudicatory Proceeding The Commission has received a motion for reconsideration of that portion of the Commission's order dated May 30,1980 which i
6 directs that an adjudicatory hearing be held on the long-term safety of the Indian Point units.
The basis for the petition is the Task Force's conclusions that Indian Point poses the same overall societal risk and less of an individual risk than a typical reactor on a typical site.
The licensees also contend that the population density is not materfally dissknilar from numerous other sites not subject to adjduica-tory hearings.
We deny the motion for reconsideration.
The licensees would have us treat the Task Force report as the final word on the risks Of the Indian Point site, instead of a document designed to aid the Commission in its decision on interim operation.
As we stated previously in this order, the Task Force report, compiled in a short time period and not disclosing its detailed methodology and underlying data, will be tested in an adjudicatory setting where parties may present additional or rebuttal evidence.
Fu rthermore, the Task Force report, even if perfectly accurate, does not answer all of the questions the Commission wishes explored by the Licensing Board in a full proceeding.
In short, we will not turn a decision on inte.rin operation into a final decision on the long-tem acceptability on the Indian Point site.
Licensees also contend that the Indian Point demography is not different from other sites.
In fact, according to the Task Force report, Indian Point has the highest population within 10,
$ IL 30 and 50 miles of any nuclear power plant site in the United States.
At 50 miles, its population is more than double any other plant site.
o.
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[Accordingly, the Commission reaffims that a discretionary adjudicatory proceeding will be conducted in the vicinity of
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Indian Point by an Atomic Safety and Licensing Board.
The purpose of the proceeding will be to take evidence and make recommended findings and conclusions on disputed issues material to the question of whether the Indian Point Units 2 and 3 plants should be shut ouwn or other action taken.
The record of the proceeding, together with recommendations, will then be forwarded to the Commission for the final agency decision on the merits of the proct. -ding.
[VG,JA,JH:
In view of the complexity of this proceeding and in order that the Commission may make its decision within a reasonable period of time, we stress that the Board should focus closely upon the questions asked by the Conmission.))
[In our Order of May 30, 1980, we solicited comment on the nature of the questions to be answered by the Licensing Board.
We have concluded that the following questions should be answered by the Board:]
[The Commission directs that the discretionary proceeding will be conducted in the vicinity of Indian Point by an Atomic Safety and Licensing Board, using the full procedural format of a trial-type adjudication, including discovery and cross-examination. The purpose of the proceeding will be to take g
evidence and make recommended findings and conclusions on dis-puted issues material to the question whether the Indian Point Units 2 and 3 plants should be shut down or other action taken.
The record of the proceeding, together with recommendations,
8 3
will then be forwarded to the Commission for the final agency
~
action on the merits of the proceeding.]
[PB: The Commission directs that the discretionary pro-ceeding will be conducted in the vicinity of Indian Point by an Atomic Safety and Licensing Board, using the full procedural format of a trial-type adjudication, including discovery and cross-examination.
The purpose of the proceeding will be to take.
evidence and make recommended findings and conclusions on disputed issues material to the question whether the Indian Point Units 2 and 3 plants should be shut down or other action taken. The record of the proceeding, together with recommendations, will then be forwarded to the Cemission for the final agency action on the merits of the proceeding.
In view of the complexity of this proceeding, and in order that the Commission may make its decision within a reasonable period of time, we stress that the Board should focus clearly upon the questions asked by the Commission.]
[ NOTE: THE PRECEDING PARAGRAPH, INTENDED TO REPLACE PARAGRAPHS 13 THROUGH 15, APPEARS TO HAVE THE CONCURRENCE OF ALL COMt11SSIONERS.]
[ NOTE: THE FOLLOWING TWO PARAGRAPHS ARE ALTERNATIVE APPROACHES TO THE SAftE ISSUE.]
[JA/JH: The primary bases for the Commission's decision will be whether the risks to individuals living in the vicinity of the Indian Point site, including those resulting from the difficulty in evacuating, are significantly greater than the
9 risks to individuals living in the vicinities of other operat-ing nuclear power reactors in the U.S. and whether the societal
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risks from the Indian Point station are significantly above the range of societal risks from other operating units station. The Commission intends to compare Indian Point to the range of risk from other nuclear power plants.]
[VG,PB: The Commission is primarily concerned about the extent to which the large population around Indian Point affects the risks posed by Indian Point as compared to the risks posed by other plants.
In particular, the Commission is concerned about:
(1) the risks to individuals resulting from the difficulty of evacuating the vicinity of Indian Point; and (2) the total risk to persons and property posed by the Indian Point plants. The Commission intends to compare the risks posed by the Indian Point plants to the risks posed by other nuclear power plants.]
The Commission-is also interested in the current state of emergency planning in the vicinity of the Indian Point site and in future improvements in that planning [PB, JA, VG:
as well as in resolving the specific contentions in the UCS Petition to the effect that some of our regulations are not met in one or bothunits.] [ NOTE:
JH DISAPPROVES THE PRECEDING ADDITION.]
Risks from nuclear power reactors are defined by the proba-bilities and consequences associated with potential accidents.
In gN directing a comparison of the risks of the Indian Point units with those from a representative group of other operating units, the Commission is fully aware of the uncertainties that attend such quantitative risk assessment calculations (reference NUREG-CR-0400, 1
10 the 1.ewis Report, and the Commission policy statement on it.)
Nevertheless, risk assessment methods offer the best means avail-able for objective and quantitative comparision of the kind needed here.
Further, some of the uncertainty that is associated with risk assessment estimates of the absolute values of accident probabilities and consequencer does not apply to comparisons such as those sought here.
Several measures of risk are useful for the comparisons the Commission seeks.
For individual risks, these include the proba-bilities of early effects--fatalities and injuries that could occur M
soon af ter an accident--and of long-term effects--cancers and genetic effects that could occur more than a year after an accident, all as a function of distance from the reactor.
For societal risks the useful measures include early effects, long-tem effects, and property damage and costs in terms of interdiction, decontamination, and crop and milk losses [JA:
and the possibility that some areas affected by an accident might be uninhabitable] [VG, PB: and the possibility that some areas p
affected by an accident might be uninhabitable for long periods].
l
[ NOTE: JH DISAPPROVES BOTH VERSIONS OF THE PRECEDING ADDITION.]
l
[For the societal risk measures (, the full risk distributions, i
1.e.,) the distributions of probabilities and consequencec snould
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be presented as well as the expected risks or mean annual values of the consequences.] [JA, VG, PB:
Societal risk measures should include the distributiors of probabilities and conse-quences as well as the expected risks or mean annual values of I
11 the consequences.] Risk measures of these kinds for the Indian Point units and for a representative group of other operating nuclear power plants were presented in the report of the Con-mission's Task Force on Interim Operation of the Indian Point, NUREG-0715, and were found useful by the Commission in its con-sidaration of the interin operation. natter.
In developing the record of the proceeding, the Board should address a series of questions as follows:
[VG,PB:
1.
(a) What is the range of probabilities assigned by experts to the possibility of a core melt accident at a pressur-ised water reactor? of a breach of containment?
(b) Assuming that a core melt accident, followed by a breach of containnent, has occurred at Indian Point, what are the possible patterns of radiation release under a variety of meteoro-logical conditions?
(c) How much time would be required for an [ effective]
[PB:
adequate] evacuation of the surrounding populat'on?
(d) What are the possible health consequennas of a core melt accident with a breach of containment, assuming that
[ effective evacuation has taken place] [PB: evacuation has taken place according to (c) above]?
(e) What would be the property damage, including long-tem uninhabitability, caused by a core melt accident with breach of containment?]
12
[1. What is the current status and degree of confonnance with NRC/ FEMA guidelines of state and local emergency planning within a 10-mile radius of the site and, to the extent [that it is] relevant to risks posed by the two plants, beyond a 10-mile radius?
[Do the emergency plans afford adequate protection to the public health and safety in the event of a core melt accident y
T that breached the containment with a few hours warning?] [ NOTE:
JH DISAPPROVES THE PRECEDING SENTENCE.]
[JA: What is the proba-bility of such an event? What is the risk resulting from such anevent?] In this context, an effort should be made to establish what the minimum number of hours warning necessary for an effective evacuation of a ten-mile quadrant at Indian Point would be. [JA: The FEMA position should be taken [as a rebuttable-presumption?]forthisestimate.]
2.
What improva...cs in the level of emergency planning can be expected in the near future, [and] on what time schedule,
[JA: and w'1at are there other specific offsite emergency pro-cedures that could feasibly and should be taken to protect the public] [ NOTE:
JH DISAPPROVES THE PRECEDING ADDITION.]
3.
What improverents in the level of safety will result from measures required or referenced in the Director's Order to the licensee, dated February 11, 1980?
(A contention by a party h
that one or more specific safety measures, in addition to those identified or referenced by the Director, should be required as a condition of operating the facility or facilities, would be within the scope of this inquiry.)
13 4.
What risk may be posed by serious accidents at Indian Point 2 and 3, including accidents not considered in the plants' g
design basis, pending and after any improvements described in (2) and (3) above?
S.
Based on the foregoing, how do the risks posed by Indian Point Units 2 and 3 compare with the range of risks posed 22.4 P
by other nuclear power plaf ts licensed to operate by the Com-mission?
(The Board should limit its inquiry to generic examina-tion of the range of risks and not go into any site-specific examina-tion other than for Ir.iian Point itself.)
6.
What would be the energy, environmental, economic or gd other consequences of a full or an offpeak shutdown of Indian PointUnit2and[orUnit3.
[ NOTE:
JA, JH, VG DISAPPROVE; PB APPROVES.]
7.
Are Units 2 and 3 in compliance with those NRC regula-tions about which specific contentions of non-compliance have been made? [ NOTE: JA, JH DISAPPROVE; VG, PB APPROVE.]
8.
What is the official position of the State of New York with regard to the long-tem operation of the units?
(An g3[
answer to this question is desirable as part of this proceeding, but we note that the Board lacks the power to compel it.)
[ NOTE:
VG AND PB FAVOR ALTERNATIVE VERSIONS; JH DISAPPROVES; JA APPROVES "0NLY IF WE DESIGNATE WHO SPEAKS FOR NY (SEE C0f1 MENT)".]
[PB:
8.
Does the Government of the State of New York care fN to express an official position with regard to the long-term operation of the units?]
14
[VG: The Board should convey to the Commission any views submitted by the State of New York or by any local governments.
The Commission intends to obtain the views of the State of New York and of the local governments before making its decision.]
[JA:
The recent leak of large aaounts of water into the containment and reactor vessel cavity at Indian Point 2 is still under review by the NRC Office of Inspection and Enforcement.
l 4
Upon completion of that review, the Commission will address what implications it has regarding operation of Units 2 and 3 and what additional instruction should be given to the Board established by this order.]
I
[VG: The recent leaks of large amcunts of water into the containment and reactor vessel cavity and Indian Point Unit 2 are still being reviewed by the Commission's Office of Inspection and
.f Enforcement.
Prior to pemitting resumption of operations at
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Indian Point Unit 2, the Commission will detennine whether its decision of July 15, 1980, to pennit continued operation at Indian Point Unit 2 and Unit 3 remains valid.]
[PB REFERENCES HIS M810 0F 11/10.]
It is so ORDERED.
For the Commission SAflUEL J. CHILK Secretary of the Commission
-Dated at Washingtan, D.C.
this day of
,1980.
4 APPENDIX A -- THE TASK FORCE ON INTERIM OPERATION A.
CHARTER OF THE TASK FORCE i
The task force was asked to examine the following specific questions; 1.
A description of the Indian Point site demography as compared to other U.S. reactor sites.
2.
A comparison of reactor accident risks (spectrum of probabilities and consequences for health impacts and property damage) at the Indian Point site to reactor accident risks at other sites.
3.
The effects of potential public emergency response systems (evacuation, sheltering, etc.) on reactor accident risks at Indian voint.
The area studied should be large enough to include New York City. This evaluation 4
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should include an assessment of the effects of uncertainties associated with successfully completing such actions.
4.
A comparison of the reliability or accident probabilities of the Indian Point 2 and 3 reactors to each other and to other reactor designs which have been analyzed.
This should include consideration of the changes ordered by tha Director, NRR; technical design comments received in response to the Commission's February 15 solicitation of comments; and the effects of partial reductions in power level.
- 5. ' An assessment of the economic, social, and other "r.on-safety" effects of shutting down or reducing the output of either or both reactors.
The Commission directed that the Task Force develop the information necessary for a Commission decision on interim operation, consider the comments that had been filed with the Commission in the matter of interim operation, cnd resent that information to the Commission.
B. TASK FORCE FINDINGS On June 12, the Task Force presented its report to the Commission, and on June 26, it briefed the Commission as to its findings in a public meeting.
The Task Force found the following with respect to the first four items of ite charter:
1.
Site Democrachy With New York City within less than 50 miler to the south, the Indian Point site has the highest or one of the highest surrounding population l
densities of all U.S. nuclear ' power plant sites, as shown by the various populaiion density criteria examined by the Task Force.
The data for total population levels out to 10, 30, and 50 miles show Indian Point
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figures as highest for the U.S.
Total estimated populations to these distances are approximately 218,000, 398,000, and 17 million, respectively, as compared with corresponding median populaEion levels for all U.S. power reactors of 24,000, 334,000, and 1 million.
When considering reactor accident risk, the population in a given
, direction,, (i.e., in one 22-1/2 degree sector), is often more significant than population density averaged over all directions.
Here too, Indian Point ranks among the highest:
eig'hth with respect to the highest-population sector at 10 miles, and highest at 30 and 50 miles.
2.
Comoarison of Accident Risks Accident risk, in the sense of the product of accident probabilities and consecuences, is partly a function of population density and distribution around the plant.
In addition, it is a function of design and operational characteristics of the reactor plant, local meteor. ology, and measures --
such as sheltering or evacuation -- which could be taken to reduce the effect of a reactor accident on the public.
The Task Force compared Indian Point risks with those of other reactor sites and designs, dis-tinguishing among effects of population densities and of design and other factors.
a.
Site Asoects '
To discern the risk effects of site considerations alone, the Task Force calculated risk measures for various sites for a " benchmark" D"P D ~"]D' M @N w N S hlfd h ow
N reactor, whose'dasign remained constant regardless of site.
(The
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Surry pressurized water reactor was used as the benchmark design, but with a power level increased to 3025 thennal megawatts, the rating of Indian Point 3.)
Six sites were analyzed for this comparison.
Four -- Indian Point, Zion, Limerick, and.Fenni -- represent sites of relatively high population.
One, Palisades, represents what the Task Force believed is a site with typical or average population distribution.
The last, Diablo Canyon, represents a remote site, that is, one with relatively low population density.
The comparison was made in terms of fou principal risk measures:
early fatalities, early (radiation) illnesses, latent cancer fatal-ities, and public property damage costs.
For each of these measures, the Task Force considered both accident consequences and, using the benchmark reactor, the probability of their being exceeded.
Integration of consequences of accidents for all probabilities represents the overall risk.
Risk estimates of this sort necessarily involve wide uncertainties, as the Task Force emphasized.
The large uncertainties in absolute values of risk estimates generally introduce wide uncertainty bands in comparisons.
Subject to those uncertainties, and subject to the assumed conditions, including unshielded exposure during the entire radioactive cloud passag3, the Task Force found that Indian Point risks attributable to site (i.e., surrounding population) factors alone compared with risks of other sites as follows:
D""D D V TQ A k/fd o oc o
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(1)
Early fatalities:
V Indian Point risks are essentially the same as those of the 33 other sites with dense local population.
The less densely popu-lated sites showed progressively much lower risk levels.
Early gi
{
g fatalities are dominated b'y the population within 10 miles of the
- g g gg w.u.
- Ete.Q bmk plant, so the.large population of New York City is not a factor Stag-here.
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Early illness from radiation:
3
[1 These risks are dominated by the population within 50 miles.
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Thus, New York City is important here.
Indian Point risks were l8.vw.u %g comparable to those of the other high-population sites. The 4
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Palisades and Diablo Canyon sites.were not very different from T
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each other but were found to be substantially lower than the d.M R6 v.h "
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Td 3 e,.y (3h latent cancers (i.e., delayed cancers, occurring possibly i,d a number of years after radiation exposure, which are A dH-t M statistica'iy expected in excess of those 'that would ~
otherwise have occurred):
IM "b5
^ ^ ^ " "
These are dominated by the population within about a 200-mile gh gg, radius of -the plant.
Because of this, the individual site risk curves for latent cancers reflect the character of the region.
3 The latent cancer risk for these sites, and probably all other h'
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m Tsites, is appror.imately the same.
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(4)
Pro'perty damage, excluding damage to t.he plant itself, was estimated as proportional to population density.
Accordingly, Indian Point was at or near the high end of property dam' age estimates, differing only moderately from the other high-density sites, but sharply higher than Palisades and, especially, Diablo
, Canyon.
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pr:t.ii'.it,7 ', m, ;.', : f:7 ti e t e u _ s.n e hy __ a na,..,
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the worst of the accident consequences -- those that result in fatal doses or severe ground contamination -- would ensue only from certain accident scenarios entailing core meltdown and gross containment failure, coincident with particularly adverse weather conditions.
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Expected consequences, i.e., consequences statistically expected, I
taking annual accident probabilities and magnitudes of consequences into account, compare as follows, as summarized in Table 5 of the Task Force report, which follows.
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-tst 1J d.43!~- -n ej-I bMF c;I Pc-r- "TH '7 lh..
on'. Commiutm 3 qJn}
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TABLE 5 EXPECTED ANNUAL CONSE00ENCES (RISRDROM 6 SITES
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WIJN THE SURRY REBASELINED PWR DESIGN
\\
'Early Ea rly Latent Property
.i!
Probability -
\\
Weighted Con-Fat,alities Injuries Cancer /Yr*
Damage $**
Site secuence eer vc Diablo Canyon 1
x10-5 2.5x10~4 1.8x10-4 1290 2.9x10~4 1.2x10-3 2.7x10~4 2670 Palisades 9.2x10-4 6.3x10'3 3.6x10~4 4780 Femi 3.5x10-3 1.1 x10-2 4.7x10-4 6980 Limerick 4.3x10~4 4.7x10-3 1.2x10-2 6030 Zion 6.1x10-3
- 1. 5x10~2 5.4x10~4 9550 Indian Point
- Total Latent Cancers Would Be 30 Times Higher
" Bas'ed on 1974 Dollars THERE ARE LARGE UNCERTAINTIES WITH THE ABSOLUTE VALUES P NOTE:
ASSUMPTIONS:
1.
SURRY DESIGN.
I.P. UNIT 3 POWER LEVEL (3025 MWT).
2.
WITHIN 10 MILES - ENTIRE CLOUD EXPOSURE + 4 HOURS GROUND 3.
NO SHIELDING BEYOND 10 MILES - ENTIRE CLOUD EXPOSURE + 7 DAY GROUND EXP SHIELDING BASED ON NORMAL ACTIVITY.
4.
WIND ROSE WEIGHTED 1970 CENSUS POPULATION D'ISTRIBUTION.
5.
IDENTICAL 91 WEATHER SEQUENCES FOR ALL SITES.
+ The expected annual consequence, or risk, is the sum of the products of the
-I probabilities and consequences (early fatalities; early injuries, etc) for the various accident sequences considered in the study.
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b.
Desien Effects The Task Force perforne$,/
an analysis to estimate the extent to which the impact of the relatively unfavorable site demographic character-istics on the relative risk at Indian Point would be modified by design characteristics of the Indian Point plants.
The analytical approach was to consider accider.t sequences that, based on previous studies, could reasonably be viewed as dominating.overall risk.
The sequences examined included reactor-transient accidents and loss-of-coolant accidents.
The design-effects comparison was done by comparing what the risks of plants of the Indian Point and other designs would be were they all located at the Indian Point site and. operated at the same power level.
The Task Force points ' ut that large uncertainties surround the -
o results -- uncertainties believed larger than those surrounding estimates for site-dependent differences alone.
Sebject to those uncertainties, the Indian Point reactors were estimated to have a 1 in 100,000 annuil probability of suffering severe core damage, as compared with probabilities some 3 to 20 times higher for six other representative U.S. pressurized-water and boiling-water reactors.
The risk of the Indian Point reactors appeared from the Task Force analysis to be even lower compared to the other reactors examined than the ratio of their estimated core damage accident probabilities would suggest.
The changes completed and in progress at Indian Point 1
A e r,.je,
as a result of the decision of the Director o'f Nuclear Rehetor Regulation concerning the petition of the Union of Concerned Scientists produce a further risk reduction estimated by the Task Force at a factor of three.
The risks, in terms of statistically expected annual consequences for the Indian Point and three other plant designs, were they all located at the Indian Point site, would compare as follows, as sum.arized in Table 8 of the Task Force report, reproduced below.
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EXPECTED ANNUAL CONSEOUENCES (RISKL+fROM 5 LWR DESIGNS
~
AT THE INDIAN POINT SITE t
\\ weighted con-Fa}Early Probability-Early Latent Property Injuries Cancer /Yr*
Damage $**
.. y talities Desion t e r..,,, -.
IP After Fix 2.2x10-4 2.7x10-4 1.6x10-5 399 IP Before Fix 6.3x10-4
- 9. 5x10-4 4.4x10-5 700 Surry Rebaselined 6.1x10-3 1.5x10-2 5.4x10-4
'9550 t
Sequoyah Ice 2.7x10-3 2.2x10-2 1.2x10-3 14800 Condenser 1.7x10-2 3.1x10-2 1.1x10-3 13500 Peach Bottom BWR Rebasel.ined
- Total Latent Cancers Would Be 30 Times Higher
- Based on 1974 Dollars NOTE:
THERE ARE LARGE UNCERTAINTIES WITH THE ABSOLUTE VALUES PRESENTED IN THIS TABLE.
ASSUMPTIONS:
1.
INDIAN POINT SITE METEOROLOGY - 91 WEATHER SEQUENCES WIND ROSE WEIGHTED 1970 CENSUS POPULATION DISTRIBUTION UNIT 3 POWER LEVEL (3025 MWT) 2.
WITHIN 10 MILES - ENTIRE CLOUD EXPOSURE + 4 HOURS GROUND EXPOSURE NO SHIELDING BEYOND 10 MILES - ENTIRE CLOUD EXPOSURE + 7 DAY GROUND EXPOSURE SHIELDING BASED ON NORMAL ACTIVITY g
x
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+
The expected annual consequence, or risk, is the sus of the products
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of probabilities and consequences (early fatalities; early injuries, etc) for the various accident sequences considered in the study.
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2
ew c.
Overview i
After separately examining the risk of the Indian Point site and of the Indian Point design, the Task Force summed up its findings, as -
follows:.
[T]he site is about an order of magnitude more risky than a typical site and the design about as much less risky than a typical design.
There is much more certainty in our comparison of the relative site risks than there is ir. the comparison of the design risks.
It is reasonable to conclude that the two about cancel, that is, the over-all risk of the Indian Point reactor is about the same as a typical reactor on a typical site.
We recognize that such a comparison makes no explicit compensation for the Indian Point risk entailing no,tably higher cc:: sequences even if at lower probability than is typical.
It is not unusual in risk aversion to demand lower risk as the potential consecuences increase -- as the stakes get.
higher. Accordingly, one might argue that the probability should be more than a magnitude lower if the consequences can be a magnitude higher.
3.
Emercency Plannino Considerations The Task Force analyzed the sensitivity of the Indian Point risks to the effects of evacuation and sheltering.
The Task Force reported analyses which assumed that all persons who would be evacuated from the vicinity of the plant in an accident would suffer cloud exposure from the radionuclides released.
As a result of this pessimistic assumption, the analyses presented showed little di.fference in public risk for the alternatives ~ of different radii of evacuation, sheltering, or even no evacuation for one day after the accident.
Under the same assumption the Task Force analyses showed somewhat higher risk of early fatalities for the no evacuation alternative, and some reduction of the early illness risk for the sheltering and 50-mile evacuation
_MA\\Luno
's alternatives, but the eticulated differences are small in relation to the uncertainties of the analysis.
The Task Force did some further analyses which were reported to the Commission in the briefing at the June 26, 1980 open Commission' meeting, which indicated that prompt notification and evacuation out to 10 miles could substantially reduce the early fatality risk.
4.
Soecial Desion and Operational Provisions a.
Difference Between Units 2 and 3 The Task Force found no risk significant differences between the Indian Poin. 2 and 3 designs.
It made this finding in its examina-tion of the two designs in relation to the seven accident sequence scenarios that it judged to dominate overall risk.
b.
Effects of Desien and Doerational Chances The design and operational fixes completed or imminent at Indian Point in accordance with the decision of the Director of Nuclear Reactor Regulation in connection with tb pecition of the Union of Concerned Scientists reduce risk by a factor of three, in the Task Force's estimation.
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c.
Effects of Power Level Reduction Reduction of power level would reduce risk primarily through two mechanisms:
(.1) proportionate reduction in the longer-lived radioactive fission-product inventory, which would produce a less-than-proportionate
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decrease in accident consequences; and i
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(2) reduction in accident probabilities thro' ugh lowered fue's temperatures and reduced rate of decay heat after shutdown, both of which would improve the reactor core's tolerance for poor cooling.
Though the Task Force performed no. detailed study, it concluded from its consideration of these mechanisms that it appeared reasonable to-say that risk would be reduce ( in proportion to the reduction in Power level.
e
ATTACHt1ENT B On June 12, the Task Force on Interim Operation presented its report to the Commission, and on July 17, in a public meeting, the Commissioners indicated their intent, based on the report of the Task Force, to permit operation of Indian Point Units 2 and 3 during the pendency of the adjudication.
In light of the recent events at Indian Point Unit 2, however, involving leakage of water in the reactor cavity, the Commission has decided to defer its decision on the question of interin operation, while that incident and its implications are studied. We see no reason, however, to delay further the initiation of the adjudicatory hearing, with the recognition that.the issue of interim operation will be addressed in a subsequent Commission order.
In this Memorandum and Order, therefore, we initiate the adjudicatory proceeding, and provide guidance to the Licensing Board and to the parties as to the questions to be addressed and the criteria to be applied.
,