ML20003E624

Requests That NRC Return OL Application to Util Until Probabilistic Risk Assessment Is Completed to NRC Specs Required in HR Denton 800527 Testimony & NRC 810105 & 26 Ltrs to Boyer

ML20003E624
Person / Time
Site:	Limerick
Issue date:	03/31/1981
From:	Nogee A KEYSTONE ALLIANCE
To:	Tedesco R NRC
References
NUDOCS 8104070410
Download: ML20003E624 (2)

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1 Keystone Alliance 3700 Chestnut St., Philadelphia PA 19104 (2151 387-5254 g5 / g..

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March 31, 1981 h

Robert L. Tedesco g{ #RO'61981 Nuclear Regulatory Comission [\  % g re.,

Washington, D.C. 20555 -\

Dear Mr. Tedesco,

A very preliminary assessment of Philadelphia Electric's Probabalistic Risk Assessment for the Limerick Generating Station reveals that the document is l totally inadequate, and fails to meet the very purpose for which it was l requested by the NRC.

In his testimony to the Comit'.ee on Interior and Insular Affairs of the House of Representatives on May 1.7, 1980, Mr. Harold Denton testified that:

"This evaluation would utilize thi methodology used in the reactor safety study, sometimes called WASH-1400, but would include specific information relating to the Limerick site in order to arrive at a relative risk comparison for the l Limerick generating s Mtion as compared to the WASH-1400 reference plant." (p.11)

"... to have them undertake a detailed risk assessment report using the specific population density around Limerick, the specific meterology of the plant, the evacuation times and the specific plant design so I will get a much better objective understanding of whether the design features compensate for the population density

or whether there is an unde risk in the operation of this plant." (p.12) l The Risk Assessment as submitted fails to accomplish these goals

1. The document contains no CCDF of either early or late cancers where Limerick is compared to WASH-1400 only on the basis of design changes and site specific t characteristics. PECO's comparisons also include a different data base and l

methodology which the Company admits produced a smaller risk than WASH-1400's.

There is thus no basis on which to make the proper comparison intended.

2. There is no CCDF for propertydamage, as requested in your letter to Mr. Boyer of January 26, 1981.

3. The Limerick PRA used population density figures from 1970, despite the fact Glat the Company has population projections for the year 2000 in its evacuation plan. What good is it to know the consequences of an accident happening 15 years t

Ofore a plant comes on line? All CCDF's should utilize year 2000 or later pro-l jections. We7

4. The evacuation time assumptions utilized were the same as for the WASH-1400 5 report, despite the enormous increase in population density. The Lewis Commission criticized the WASH-1400 evacuation times as being optimistic. /0 Because of these clear and grave problems, we hereby request that you immediately return the entire Operating Licensslt8 ' Philadelphia Electric until they have completed the PRA to the specifications required in Mr. Denton's testimony and your letters to Mr. Boyer of January 5 and 26.As you stated, "it would be inappropriate to commence review of your FSAR prior to receipt of your final Risk Assessment Study Report."

I look forward to your prompt action and reply. Thank you.

l D 64 0 704/6

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.,s Sincerely, Ala sta f J. Nogee cc: Harold Denton Darrell Eisenhut Donald Sells 1

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