ML20009B710
| ML20009B710 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/13/1981 |
| From: | Reveley W LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20009B708 | List: |
| References | |
| NUDOCS 8107170066 | |
| Download: ML20009B710 (24) | |
Text
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NUCLEAR REGULATORY COMMISSION
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Before the Atomic Safety and Licensing Board
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In the Matter of )
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LONG ISLAND LIGHTING CCMPANY ) Docket No. 50-322
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(Shoreham Nuclear Power Station, )
Unit 1) )
LILCO MOTION FOR
SUMMARY
DISPOSITION OF SOC CONTENTION 1 The Contention By Board Order of June 26, 1980, SOC Contention 1 was admitted as follows:
Intervenors contend that the emergency planning zones (EPZ) set forth by the Commission in the NRC Policy Statement of October 23, 1979 (44 Fed. Reg. 61123) are inadequate for the Shoreham nuclear plant in that
- a. The 10-mile (radius) EPZ plume exposure pathway fails to provide adequate consideration of the following local conditions: demography, meteorology, topography, land use characteristics, access routes, local jurisdictional boundaries and release time characteristics.
- b. The 50-mile (radius) EPZ ingestion pathway fails to provide adequate consideration of the following local conditions.
demography, meteorology, topography, land 8107170066 810713 PDR ADOCK 05000322 G PDR
- characteristics, and time of year of releases.
Material Facts As To Which There Is No Genuine Issue To Be Heard
- 1. The NRC Policy Statement of October 23, 1979 (44 Fed Reg. 61123) has been superceded by the Commission's final rule on emergency planning. 45 Fed. Reg. 55402 (1980).
- 2. The Commission's emergency planning rule relies specifically on the work of the Emergency Planning Task Force set out in " Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of ~ht Water Nuclear Power Plants,"'NUREG-0396, EPA 520/1-78-016 (1978). See 10 CFR $ 50.45(s)(1) n.1, 45 Fed.
Reg. at 55410.
- 3. In its final emergency planning rule, the NRC adopted generic emergency planning zones (EPZ) for all large (greater than 250 MWt) light water reactors: "[T]he plume exposure pathway EPZ for nuclear power ^1 ants shall consist of an area
, about 10 miles (16 km) in radius and the ingestion pathway EPZ shall consist of an area about 50 miles (80 km) in radine " 10 CFR S 50.47(c)(2), 45 Fed. Reg. at 55409 (emphasis added). Tce generic nature of the EPZ determination is further indicated by i the rule's supporting documentation: "[I]t was the consensus i
of the Task Force that emergency plans could be based upon a generic distance . . . ." NUREG-0396 at 16.
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, ^4. The NRC recognized that there are site-specific variations among plants and still concluded that it was appropriate to set generic EPZ's. In discussing the fact that low population zones (LPZ's) used in siting nuclear power plants vary from site to site, it was noted that "[w)hile the Task Force recognizes that there are site-to-site variations in LPZs, due in part to varying features of the plant, the Task Force concluded that the size of EPZs need not be site-specific." Id. at III-7.
- 5. The NRC did not intend to require comprehensive site-specific analyses to determine the size of the EPZ's for individual plants. See Material Facts 3-4. While the NRC did provide for some minor perturbations in the zones to account for " local emergency response needs and capabilities as they are affected by such conditions as demography, topography, land characteristics, access routes, and jurisdictional boundaries,"
10 CFR S 50.33(g), 45 red. Reg. at 55408-9, no major case-by-case analyses were mandated. The selection of EPZ's of "about 10 miles" and "about 50 miles" was meant to give some flexibility to emergency planners: "It is expected that the judgment of the planner will be used in determining the precise size and shape of the EPZs considering local conditions
. . . ." NUREG-0396 at 14. "Although the radius for the EPZ implies a circular area, the actual shape would depend upon the characteristics of a particular site." Id. at 16.
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- 6. In setting generic EPZ's, the Commission specifically considered Class 9 accidents. As stated in NUREG-0396, "[t]he Task Force judgment on the extent of the Emergency Planning Zone is derived from the characteristics of design basis and Class 9 accident consequences." Id. at 16; see also id. at Appendices I, III. It was concluded that "a 10 mile plume EPZ would be appropriate to deal with core melt accidents." Id. at I-41.
- 7. The NRC determined that the 10 and 50 mile EPZ's were consistent with a " conservative emergency planning policy." 45 Fed. Reg. at 55406.
- 8. The NRC concluded that emergency response plans should " provide dose savings for a spectrum of accidents that could produce offsite doses in excess of the PAGs [ Protective Action Guidelines]." NUREG-0396 at 5. The generic EFZ's included in the emergency planning rule accomplish that goal.
Id. at 16.
Argument i
l A.
l By its terms, SOC Contention 1 challenges the adequacy of the EPZ's established by the Commission's Emergency Planning Policy Statement for use at Shoreham. Since the EPZ's prescribed in the policy statement are the same as those now included in the rule, SOC Contention 1 amounts to an attack on
the emergency planning rule. SOC's responses to the Applicant's interrogatories 1/ further explain its objections to the concept of generically determined EPZ's. In large part, SOC claims that the NRC's EPZ's are inadequate for Shoreham because the NRC allegedly failed to give appropriate consideration to Class 9 accidents. Thus, according to SOC, a complete site-specific accident consequence analysis is required.
The NRC, in its emergency planning rulemaking, set generic emergency planning zones for all large light water nuclear power plants. See Material Facts 3 and 4. The generic determination of the EPZ's included findings that the EPZ sizes selected are appropriately conservative and that public health and safety can be adequately safeguarded by pre-planned emergency measures within the generic zones. See Material Facts 7 and 8. By clear implication, since the NRC found the 10 and 50 mile EPZ's adequate for all large reactors, it found them adequate for Shoreham. By the same token, the NRC's EPZ decision represents a determination that a site-specific accident consequence analycis of the type demanded by SOC is not required. See Material Facts 3-5.2/ In urging this Board 1/ See geperally Answers of the Shoreham Opponents Coalition (SOC) to Applicant's Interrogatories Dated May 21, 1981" (SOC's Answers) at A-1 to A-15, attached as Exhibit 1 to this motion.
2/ LILCO has decided to conduct an accident consequence assessment independent of any r"0 requirement. The purpose of the study is to confirm the effectiveness of emergency planning
to consider the adequacy of the generic EPZ's and to require a site-specific study to set EPZ's for Shoreham, SOC is challenging the adequacy of the NRC's emergency planning rule.
SOC, however, has failed to meet the requirements of 10 CFR $
2.758 for such a challenge. Accordingly, it is impermissible.
B.
LILCO believes that nothing further needs to be said to support the summary disposition of SOC Contention 1, pursuant to 10 CFR 5 2.749. Nonetheless, brief response to the emergency planning points raised in SCC's answers to the Company's May 21 interrogatories may be useful.
(1) SOC's reliance on the Kemeny Commission's criticism of the adequacy of low population zones (LPZ's) as a reason for requiring site-specific analyses, SOC's Answers at A-3, is irrelevant since the NRC no longer uses LPZ's for emergency planning purposes. See NUREG-0396 at III-5 to -8. (2) SOC's reliance on the Rogovin Report's suggestion that " ten miles is not an appropriate cutoff distance for emergency planning,"
SOC's Answers at A-3, is also unpersuasive; the Rogovin criticism as well as the Kemeny Report were considered by the NRC in the emergency planning rulemaking. See 45 Fed. Reg. at measures for Shoreham within the generic EPZ's and to explore ways in which the planning might be improved. The study will not explore EPZ's in excess of the NRC's generic requirements.
_7 55402. (3) SOC's argument that Class 9 accidents were not considered in the emergency planning rulemaking is wrong; Class 9 accidents were taken into accourat in setting the EPZ's. See Material Fact 6. (4) SOC's attempt to support its challenge to the emergency planning rule by citing a study done by California's Office of Emergency Services (OES) is misleading since the report is based on a rejection of assumptions used by the NRC with no explanation why the OES assumptions are better than the NRC's. SOC Answers at A-9. In any event, the NRC's assumptions are controlling here. And (5) SOC rejects the degree of safety the Commission inherently accepted in adopting the emergency planning rule, not because the risk was shown to be too large but rather because it could be further reduced.3/
In short, SOC argues that the NRC failed in its emergency planning rulemaking effort. But a review of the NRC's rulemaking record shows, to the contrary, that it did consider a broad range of factors (including Class 9 accidents); that it did have ample support for its use of the various factors, and that it did make a reasoned judgment as to the acceptable level of risk inherent in adopting the final emergency planning regulations. See generally 45 Fed. Reg. 55402-13; NUREG-0396; 3/ The NRC noted in NUREG-0396 that selection of a 10 mile plume exposure EPZ results in approximately a 30% chance of exceeding a one REM whole body dose in the extremely unlikely event of a core melt accident. NUREG-0396 at I-38. SOC wants more. See SOC's Answers at A-12. Again, the NRC's judgment of acceptable risk is controlling here.
Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, NUREG-0654, FEMA-REP-1, Rev. 1, (1980); Summary of Public Comments and NRC Staff Analysis Relating to Rulemaking on Emergency Planning for Nuclear Power Plants, NUREG-0684 (1980).
Conclusion SOC's allegation that the NRC's generically determined EPZ's are inadequate for Shoreham and its insistence on a site-specific EPZ determination challenge the NRC's final emergency planning rule, in disregard of the requirements of 10 CFR 9 2.758(a). Accordingly, no genuine issue remains to be heard concerning SOC Contention 1, and it should be summarily resolved under S 2.749.
Respectfully .iubmitted, LONG ISLAND LIGHTING COMPANY
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Anthony F arley, Jr. /
Hunton & Williams i P. O. Box 1535 Richmond, Virginia 23212 DATED: July 13, 1981 b
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SOC CONTENTION 1 s.
The Shoreham-specific emergency planning criteria have not yet been developed by LILCO, by local authorities including Suffolk County, or by state authorities. Furthermore, neither the NRC or FEMA review of emergency preparedness has been con-ducted at this time. Thus, the Shoreham-specific distance cri-teria which will be utilized as the basis of the combined appli-cant, state, and local plans has not yet been documented and, as a result, SOC answers to this interrogatory are premature.
However, SOC will provide responses in so far as practical on the basis that the applicant, state, and local authorities will develop the emergency planning zones of about ten and fifty miles for plume and ingestion as provided as guidance in NUREG-0654.*
First, SOC contends that neither the Staff or LILCo have conducted a Shoreham site-specific accident consequence assess-ment utilizing the NRC's CRAC Code (from WASH-1400) or equiva-lent. Such an analysis based on site-specific core inventory, release fractions, release time estimates, shielding factors, health treatment facilities, demography, topography, meteorology, land characteristics, access routes, and local jurisdictional
.. boundaries is necessary to develop the appropriate plume ex-posure and ingestion Emergency Planning Zones (EPZ). As dis-cussed by the Staff in the Shoreham SER** LILCO has not yet sub-mitted emergency plans required by the new regulations which were published in the Federal Register on August 19, 1980, and became effective on November 3, 1980. The regulations contain a revfsed Appendix E to 10 CFR Part 50, " Emergency Planning and Preparedness for Production and Utilization Facilities," which establishes minimum requirements for an acceptable state of on-site emergency preparedness, and a new Section 50.47, " Emergency Plans," which specifies standards which must be met for both on-site and offsite emergency response. This latter section incor-porates the joint NRC/ FEMA standards for use in evaluating state and local radiological emergency plans and preparedness. The Staff also acknowledges NRC and FEMA have agreed that FEMA will make a finding and determination as to the adequacy of state and local government emergency response plans. NRC will determine
- NUREG-0654 (FEMA-REP-1), Rev. 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, page 17, for example.
V* NUREG-0420, Shoreham SER, page 13-1.
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c-9 the adequacy of state and local government emergency responseto plans with Part of 10 CFR respect 50, the requirements of Appendix E to 10 CFR Part 50, and the guidance contained in NUREG-0654, " Criteria for Preparation and Evaluation of Radiological Emergency Re-sponse Plans and Preparedness in Support of huclear PowerAfter the abov Plants," dated November, 1980.the staff will make a finding in the licensing by NRC and FEMA, process as to the overall and integrated state of preparedness.
Such a review will be published, at some future time by the Staff in a Supplement to the Shoreham SER.
The President's Commission on the Accident at Three Mile Island (Kemeny Commission)* noted that a central concept in the then current siting policy of the NRC is that reactors ~
(LPZ), an area should be located in a " low population zone"in which How-around the plant appropriate pro be taken for the residents in the event of an accident.is implemented in a ever, Kemeny concluded that the c.oncept To determine the strange, unnatural, and round-about manner.the utility calculates the amou size of the LPZ, in a very serious hypothetical ac-released into the containment Using geo- ^
cident but assumes no failure of the containment.
graphical and meteorological data, the utility then calculatesli-that area within which an individual would receive 25,000 mil rems or more to the whole body, during the entire course The Z:,000-millirem of the st andard accident. This area is the LPZ.
is an extremely large dose, many times more serious than that re-ceived by any individual during the entire TMI accident.
the LPZ approach has The Kemeny Commission believed thatbecause of the extremely large dose First, serious shortcomings.
by which its size is determined, the LPZs for many two miles in thenuclear case ofpower TM1 plants are relatively small areas,Second, if an accident as serious as the
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as well as Shoreham. it is evi-ll-one dent used to calculate the LPZ were actually to occur,that m er, but still massive doses of radiation.the LPZ has little relevance to th dent shows that the public -- the NRC irralf was considering evacuation dista as far as 20 miles, Kemeny therefore concluded
~ than those postulated during siting.
- of the President's Commission on Kemeny, John,et al, Reportat Three Mile Island,'pages 16-17.
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that the entire concept is flawed and recommended that the LPZ concept be abandoned in siting and in emergency planning.
As an alternative, Kemeny proposed and SOC concurs that a var-iety of possible accidents should be considered during siting, particularly " smaller" accidents which have a higher probabili-For each such accident, one should calculate i
ty of occurring.
on a site-specific basis probable levels of radiation releases .
I at a variety of distances to decide the kinds of protective ac-tion that are necessary and feasible. Such protective actions ,
I may range from evacuation of an area around the plant, to the distribution of potassium iodide to protect the thyroid gland ,
from radioactive iodine, to a simple instruction to people sev- I eral miles from the plant to stay indoors for a specified per- -
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iod of time. Only such a site-specific analysis can predict I
the true consequences of a radiological accident. .
Another major review group formed by the NRC af ter the 'p TMI accident, the Commission's Special Inquiry Group, directed by Mitchell Rogovin, has also suggested that ten miles isFor nota .
an appropriate cutoff distance for emergency planning.*
further discussion of some of the deficiencies in the logic ;
which went into the choice of a ten mile cutoff distance, see T. Lombardo, T. Perry, " Mitigating the Effects of a Nuclear Ac- -
cident," Spectrum, July, 1980, page 30.
Neither the Shoreham saf,ty analysis nor the NRC's NEPA review for Shoreham considered Class 9 (very large) accidents. ,
As a result of the Class 9 accident at TMI-2 and the NRC's
' Risk Assessment Review Group's conclusion (NUREG/CR-0400) that estimates of the absolute probabilities of accidents in WASH-1400 (NRC's Reactor Safety Study) are not reliable, the NRC has
- no theoretical or practical basis for excluding the safety and In environmental assessment of Class 9 c.ccidents at Shoreham.
an interim policy statement Ly the NRC (Federal Register, June 13, 1980), the NRC has decided to approach this problem on a plant-by-plant basis considering the potential consequences for l
l large accidents at specific sites. However, no Shoreham assess-l ment prior to fuel loading is presently contemplated. This is I a serious omission.
l
' In the course of preparing WASH-1400, major insights into the neture of reactor risk were discerned. One of the significant i
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- Rogovin, Mitchell, et al, Three Mile Island: A Report to 2 the Commissioners and to the Public,.page 133. i e
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conclusions of the study is that the risk to the public from
- nuclear power reactors arises primarily from core meltdown ac-cidents (Class 9 accidents).
In a subsequent program under-taken by Brookhaven National Laboratory (BNL), Science Appli-cations, Inc. (SAI), and Battelle Columbus Laboratories (BCL),
the risk contribution of Class 3 to 8 accidents was examined.*
Class 3 to 8 accidents,** incidents that may be expected to occur over the lifetime of a plant and which do not exceed the design bases of the plant, are analyzed in safety analysis re-ports and environmental reports. As illustrated in Table A-1, TABLE A-1 COMPARISON OF EXPECTED RELEASES ,
Risk, weighted Curies / reactor-year ***
Normal operational release 1.7 Class 3-8 accidents Actuarial data 0.05 Extrapolated 0.05-0.2 Total 0.1-0.3 Class 9 accidents 540
- R.E. Hall, et al, A Risk Assessment of a Pressurized-Water Reactor for Ciass 3-8 Accidents, NRC Report NUREG/CR-0603, Brookhaven National Laboratory, NTIS, October, 1979.
- U.S. Atomic Energy Commission, Consideration of Accident. in Implementation of the National Environmental Policy Act of 1979--Discussion of Accidents in Applicant's Environmental Reports: Assumptions, Annex to Appendix D, Title 10, Code of Federal Regulations, Fart 50, Federal Register, 36(231):
22851-22854 (Dec. 1, 1971).
- The units of weighted curies used in this table involve a sum-mation of all the important radionuclides weighted by a factor to account for the relative effect of that radionuclide to
' iodine-131 in producing latent fatalities (including fatali-Although these weight-ties from malignant thyroid tumors).
ing factors would actually be dependent on the conditions of a specific accident, they provide a convenient approximate means of measuring accident consequences.
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the results of this study indicate that, on the basis of ex-
. pected value, Class 9 accidents are predicted to have a much than either greater impact on human health and the environmentClass 3 to 8 ac ability of core meltdown. While the plant analyzed was a PWR, we believe the conclusions are also applicable to the Shoreham BWR.
Using the same weighting factors for the different radio-nuclides as in Table A-1, the total radioactivity potentially available for release from the containment atmosphere at one hour in a core meltdown accident is 108 weighted Ci. The major fraction of the risk calculated in WASH-1400failed originated from during or meltdown accidents in which the containment shortly after core meltdown, before significant deposition -
(greater than an order of magnitude reduction) could take place.
In contrast, the amount of radioactivity that would be released to the environment from Class 3 to 8 accident (the Shoreham de-sign basis accidents) would be very small, typically less than 1 weighted Ci. Although these accidents have been predicted to occur with frequency up to as much as four orders of magnitude greater than core meltdown accidents involving large atmos-phere releases of radioactivity, the difference in consequences still would be approximately seven orders of magnitude. Thus the risk, measured by the product of probability and conse-quence, for Class 9 accidents is predicted to be much greater.
Therefore, emergency planning measures must be developed to mitigate the consequences of these releases.
It is also relevant and important to note that the WASH-1400 Evacuation Model presumes more extensive evacuation Thethan the ten introductory miles presently assumed to be proposed by LILCO. "In the case of a po-mention of evacuhtion in WASH-1400 states:it is assumed that people tentially serious accidental release, living within about 25 miles of the plant, and located in the direction of the wind, would be evacuated...."*
Other references to evacuation sre in WASH-1400, Appendix V1, where it is explained that credit is taken for evacuation section to in all directions to five miles and in a downwind 25 miles in order to concentrate evacuacion facilities where they 450 l
will do the most good.** The 25-mile limitation precluded the WASH-1400 authors considering evaucation from any U.S. city
- WASH-1400, Main Report, page 51.
- WASil-1400, Appendix VI, page 11-4.
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larger than Cincinnati. (Approximate population of 450,000 in
. 1970.) However, the WASH-1400' authors did assert that large U.S. cities, such as New York, Boston, Philadelphia, Chicago, and Los Angeles, with reactors et their edges, cannot reason-ably be evacuated in less than one week.*
Further, unlike the Shoreham site-specific conditons, the WASH-1400 authors assumed in the evacuation model that the popu-lation movement is always radially outward from the reactor, i.e., there is no crosswind movement. During the evacuation, the population is assumed to be unshielded from exposure to air-borne radioactive material both externally and through inhala-tion and to be shielded from exposure to ground contamination due to surface roughness and the automobile. If the evacuating population is overtaken by the cloud of radioactive material, it ,
is assumed that people will have moved outside of the contami-nated area within a four-hour period. Beyond 25 miles, the people are assumed to be relocated within seven days if the chronic dose due to exposure to ground deposited radionuclides exceeds a specified value. However, if the dose accumulated within the first seven days due to exposure to contaminated.
ground exceeds 200 rads, then the people are assumed to be re-located within one day.
Three categories of potential health effects are calculat-ed in WASH-1400: early and continuing comatic effects, late -
somatic effects (cancers), and genetic effects. Since early and continuing somatic effects are ucually observed after large, acute doses of radiation (e.g., whole-body doses of 100 rads),
they would be limited to' persons within 50 miles (not 10 miles) or so of the reactor even for the largest conceivable release.**
Conversely, late somatic and genetic effects may result from very low doses albeit with low incidence. Consequently, these effects may occur a* long distances frcm the reactor.
No figures are presented in WASH-1400 for the conditional probability of a latent death resulting from a BWR release as a function of distance. However, WASH-1400, Figure VI 13-26 shows the conditional probability for an individual of dying from latent cancer as a function of distance from a reactor given the PWR-1A and PWR-1B releases. The probability of latent cancer fatalities is relatively constant out to about 100 miles from the reactor
- WASH-1400, Appendix VI, page 11-5. ~
- ** NUREG-0340, Overview of the Reactor Safety Study Consequence Model, page 16.
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g0 2 393 10 Miles from Reactor FIGURE VI 13-26 Conditional probability of latent cancer death given a PWR-1A or PWR-1B release. (Apprc:. int.ately, absolute mortality probabilities are 10-6 por reactor year times stated ones).
Source: WASH-1400, Appendix VI, page 13-37.
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1 l beyond which it decreases rapidly. The small difference be- .
tween the two curves is doe to the different heat rates in the o PWR-1A and PWR-1B releases. With the large heat rate in the PWR-1B release, it is less li.kely for an individual close to the reactor to be subject to significant doses. Therefore, the probability for a latent cancer death would be lower close to the reactor for the hot release case (PWR-1B) than for the cool release case (PWR-1A). A similar result would be expected for a BWR-1 release from Shoreham. Thus, for Shoreham, the number of latent fatalities and health effects is roughly proportional to the population living between 25 and 100 miles from the re-actor and to the associated mitigation measures for this group.
A Site-specific consequence analyses as recommended herein have been conducted for the California nuclear plants. The California results confirm that the 10 and 50 mile EPZ's are not appropriately conservative. Following the March 28, 1979, l
accident.at Three Mile Island, Governor Brown formed a task force to study California's emergency preparedness for nuclear i power plant accidents. One of the task force's principle recom-mendations was that site-specific analyses be conducted of the 1 consequences of hypothetical serious nuclear power plant acci-dents. As rcquired by subsequent legislation, a site-specific study of this nature has been conducted by the State Office of l
Emergency Services (OES). Based on the results of this Study, the DES has recommended Emergency Planning Zones (EPA's) for each of the nuclear power plant sites. The rationale behind the selectior, of these EPZ's is presented in the following por-4 tion of this response.
- As noted in the OES report, the selection of the ten-mile
.- radius (for the plume exposure EPZ) by the NRC/ FEMA was based primarily on the foll" wing considerations:
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! a. projected doses from the traditional design basis accidents would not exceed Protection Action Guide levels outside the zone; l
b, projected doses from most core melt sequences would l
not exceed Protective Action Gui e levels outside the zone; i
! c. for the worse core melt sequences, immediate life '
threatening doses would generally not occur outside the zone:
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- d. detailed planning within 10 miles would provide a substantial base for expansion of response efforts in the event that this proved necessary.*
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- NUREG-0654, page 9.
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Based upon the site-specific results of the State's study, the OES analyzed the impact of a similar set of hypothesized
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accidents on the areas about each of the California sites.
EPZ's were developed upon this site-specific basis rather than the generic basis used by the NRC/FE!!A. Based upon the site-specific results, the OES concluded EPZ's should be extended beyond the basic 10 mile NRC/ FEMA requirements. The outer boundaries of the extended EPZ's presented above for the three large reactor sites in the State with ratings comparable to Shoreham vary in distance from about 18 to 35 miles from the :
reactors, as shown in Table A-2. .
TABLE A-2 DOWNWIND DISTANCES FROM REACTOR SITE WHERE PROBABILITY OF EXCEEDING SPECIFIED WHOLEBODY DOSE IS 0.01 (1%) FOR CORE-MELT ACCIDENTS
- Maj or Penetration '
Melt-Through Leaks Failure Reactor 0.5 rem 25 rem 200 rem Diablo Canyon 4.5 miles 20 miles 26 miles Rancho Seco 5 miles 18 miles 28 miles San Onofre 1 8.5 miles 13 mil.es 18 miles San Onofre 2, 3 4 miles IP miles 35 miles The decision to extend the EPZ boundaries beyond the zone dimensions required by NRC/ FEMA was based upon a disagreement in the application of the (c) and (d) considerations above that were used by the NRC/ FEMA in their election of the basic 10 miles radius for the EPZ. As indicated by the dose-distance relation-ships developed during the study, the results of the State's study of the California site-specific consequences showed basic agreement
- Cunningham, Alex, Emergency Planning Zones for Serious Nuclear
. Power Plant Accidents, California OES, November, 1980, Table 4.1.
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with observations (a) and (b) of the NRC/ FEMA selection con-sideration presented above. That is, the State's results in-dicated there was at least a 99.9% probability that the pro-jected doses from the most probably (melt-through) accident sequences would not be expected to exceed Protective Action Guide (PAG) levels beyond a basic 10 mile EPZ boundary. In this regard, the State's results supported the first two of the NRC/ FEMA observations.
However, the OES concluded that prudence dictates that the EPZ's be extended so that advance planning can be per-formed to aid in resolving the potential problems associated with the more severe types of accidents, the penetration leakage and major containment failure classifications. The very severe accidents in these classifications make up about '
10 to 20% of all the hypothesized core-meltdown accidents, even for relatively new reactor designs. It did not seem prudent to restrict planning attention to responding only to the potential for incurring immediate life threatening radia-tion doses for such severe accidents. Thus, the extended zones were selected so that the potential for incurring health impacting doses was reduced not only for early fatalities, but also for early injuries and delayed cancer effects as well.
A direct comparison of NRC/ FEMA generic estimates of dose-distance-probability relationships with the State's site-spe-cific results is presented in OES Figure 4-13. The results of the two different sets of CRAC calculations made by the NRC and the State show basic similarities, but also some substan-tial differences. The NRC results appear to have been smcoth-ed to follow the general outlines of their CFAC results, while the State's dose-distance-probability data shown represent the direct, unmodified output from CRAC (for the Rancho Seco site in the particular example shown). The results presented in the figure (for both the NRC's and the State's data) represent the combined output of the codes for all accident classifications (major containment failure, penetration leakage, and melt-through categories). The results have been combined to reflect the appropriate weighting factors of the relative probabilities of receiving accidental doses from each and all of the accident classifications.*
As the NRC observed in NUREG-0396, there is about a 30%
chance of exceeding the (1 rem) PAG 1evel at the basic 10
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- Cunningham, Alex, page 66.
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Figure 4-13 WiiOLE BODY DOSE ESTI!tATES STATE STUDY NUREG - 0396 s
A-ll .
C C .
miles plume exposure EPZ boundary, according to their own data.
- The State's data would indicate a somewhat lower probability of aboutthe 20% at the same distance. At the same 10 miles dis-NRC results suggest a probability of about 10% of exceeding a 50 rem dose, and about a 3% probability of exceed-tance, ing 200 rem. Based upon the NRC's and the State's data, adopt-ing extended EPZ boundaries with distances from the reactor of about 18 ta 35 miles would reduce the probability of early fatalities by a factor of 0.1 or more (to a probability of about 0.1% of exceeding 200 rem); the probability of early injuries (at 25 rem) would be reduced by a factor of about 0.5 tr 0.25 (to a probability of about 7 to 9%); and the probability of ex-ceeding PAG doses would be reduced about a factor of from 0.5 to 0.8 (to a pro ability of about 15%). Thus, extending the EPZ boundaries results in a prudent reduction in the probabili-ties of early health effects and a substantial reduction in the .
probability of delayed health effects (associated with 0.5 to 1 rem PAG dose limits).
Thus, based on the foregoing, SOC concludes that there is substantial precedent for the prudence of conducting a Shoreham-specific comsequence analysis to develop the appropriate emer-gency planning EPZ's. Further, we believe that such an analysis would indicate that the Plume Exposure EPZ of 10 miles and an .
Ingestion EPZ of 50 miles is not conservative and does not re-sult in adequate protection of the public health and safety.
The supplemental responses to the specific interrogatories are as follous:
A.1 Site-specific modeling of the impact of population on Class 9 accident consequences has not been con-ducted by LILCO or reviewed by the NRC. The NRC has reviewed only the population in the low popula-tion zone as related to emergency planning.* The Shoreham site has exceptionally high projected popu-lation. In the year 2000 it will have a population w ithin 50 miles that puts it in the top 5% of all reactors; within 10 miles it is in the top 20% (see Figures III and IV). If population and the resulting consequences are considered in the NRC decision to require implementation of Class 9 mitigation tech-niques, Shoreham would be a prime candidate.
- NUREG-0420, page 2-6. ,
A-12
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FIGURE III CO'TARISON OF POPULATION LEVELS k'ITHIN 50 MILES OF REACTOR SITES IIIIlsihiill III iI i[Ig ZW T~ mq lie !!al 154.
, i ll isi I Il 6*ss III II lili 15] 'Ill Ill!
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tom TMt vtan 20ao -
ut Am PO*uLAtlON . 2 700 One ul Dia POP'JL af 80%
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WINivydPCPULAllON*17DiY u a.miuvu earoLaiio= . 2: maa. ore
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POPULATIONS EQU AL TO. OR t E SS TH AN. THE INDIC AT E D VALUE Source: NUREG-0348 A-13
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- PIGURE IV
.. CONPARISON OF . ULATION E'ITHIN TENM_, ILES ( REACTOR SITES , ,
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Source: NUREG-0349 ,
1 A-14 i - ,-- . . , . - _ . _ _ _ _ . __ __ __ _
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A.2: Site-specific modeling of the impact of meteor-ology on the consequences of releases resulting -
from Class 9 accidents has not been conducted by LILCO or reviewed by the NRC. As discussed in the preceding, the DBA releases represent less than one millionth the potential releases.
A.3: No site-specific modeling of the effects of to-pography on plume dispersion within the 100 mile radius (approximately) of the Shoreham site have been conducted by LILCO or reviewed by the NRC.
Also, the effect of the Long Island Sound water on deposition velocity of radioactive materials is extremely uncertain.
A. No site-specific modeling of the impact of land an use characteristics and local access routes on A.5: the accident mitigation measures resulting from releases due to a Class 9 accident have been de-veloped by LILCO or evaluated by the NRC. The NRC has only reviewed the road networks and land use factors (as related to emergency planning) for the LPZ.*
A.6: Local and State (New York, Connecticut, and Rhode Island) emergency plans for even the 50 mile radius from the plant have yet to be submitted or reviewed by NRC/ FEMA as set forth in the cur-rent regulatory requirements in Appendix E to 10 CFR 50. Thus, coordination of State and local
. jurisdictions during and following an emergency at Shoreham have not yet been demonstrated. Also, LILCO has not provided the " implementing" emer-gency procedures as recently set forth in Section V of the emergency planning regulations.
A.7: No Shoreham-specific analyses of plume lift-off and plume dispersion for releases resulting from Class 9 accidents based on Shoreham-cpecific re-lease times and release energies have been de-veloped by LILCO or reviewed by the NRC.
A.8: The Policy Statement has been superceded by the t
NRC Final Rule on Emergency Planning (45 FR 55402)
~
of August 19, 1980, which has an effective date of November 3, 1980.
- NUREG-0420, page 2-6.
I A-15 l
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A.9: See answer to A.8. .
- A.10: Same as answers to A.1 through A.9.
A.ll The facts and documents on which SOC now re-an lies are described in detail in the general 2
- response to this interrogatory. The facts and documents on which SOC expects to rely
- during the Shoreham hearings will include the preceding as supplemented by facts and _
documents provided by LILCO and the NRC on this docket in the future, and by facts and documents provided by LILCO and the NRC in response to any forthcoming SOC discovery reques t. - .
A.13: The documents on which SOC now relies are
. described in the foregoing. Since the docu-ments are publically available, no copies have been provided by SOC.
A.1 , SOC has not yet decided which witnesses it and ' cision will utilize in the hearings. When this de-is made the response to these interro-A*16
- gatories will be supplemented with the re-quested information. To the extent that SOC's present consultants are assisting in review-ing and/or responding to these interrogatories, their resumes are attached hereto.
A.17 SOC first engaged the services of their con-and sultants, M11B Technical Associates , in Decem-A.18: ber, 1979, and has had a continuing discussion with them regarding the contentions in this case. However, as of this writing, the con-sultants have not made any reports to SOC re-lated to this contention. General studies or observations that SOC now relies or expects to rely on during the Shoreham hearing are set forth in the preceding. Also, see' response to A.ll and A.12. .
- To the extent they are now known.
j -
l A-16 t
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