ML20024F192
| ML20024F192 | |
| Person / Time | |
|---|---|
| Site: | Clinch River |
| Issue date: | 09/06/1983 |
| From: | Hulman L Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20024F191 | List: |
| References | |
| NUDOCS 8309090029 | |
| Download: ML20024F192 (6) | |
Text
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6
's UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of UNITED STATES DEPARTMENT OF ENERGY Docket No. 50-537 PROJECT MANAGEMENT CORPORATION TENNESSEE VALLEY AUTHORITY (Clinch River Breeder Reactor Plant)
SUPPLEMENTAL AFFIDAVIT OF LEWIS G. HULMAN I, Lewis G. Hulman, being duly sworn, state as follows:
On August 10,1983,Ia60earedasawitnessinthisproceeding.
In reviewing the transcript of my testimony (Tr. 8505-8509), I noted that certain statements which appear in the transcript are somewhat inaccurate and/or require clarification. Accordingly, I hereby wish to clarify and revise my testimony in accordance with the handwritten changes set forth on the attached copy of pages 8505-8509 of the hearing transcript.
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Lewis G. Hulman Subscrib(dandsworntobeforeme this b._ day of September,1983 i
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1 correct with respect to infant thyroid.
He is correct.
2 But I don't believe that we should be using the infant
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3 thyroid to interpret Part 100 for the reasons I have 4
cited.
5 Dr. Cochran also goes on on page 4 to make o
his third poin alistica He says, and I quote, 7
" Third, I believe the estimated severity of a CDA at t elbeit >
8 CRBR, assumingrealistic,ph2t it conservative, 9
conditions, namely, thyroid doses of 192 rems to adults and 400 rem'to infants at.the LPZ boundary, is 10 il excessive and should not be tolerated for CRBR or for any 12 reactor.
13 In effect, this is also a challenge to the l
14 Staff's use of 300 rem to the adult thyroid as.a 15 benchmark to judge the adequacy of CDA mitigation E
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g based on a realistic CDA scenario.4 f
17 I want to comment on this a couple of ways.
f 18 First, Staff practice has been, as I
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19 said earlier, to use Part 100 for design basis accidents.
us%A SEO 20 In doing s, we compute doses conservatively, 21 depending upon your perspective. We use meteorology, 22 low probability meteorology.
Some people refer to it as 23 5 percent meteorology.
Q 24 otherpeoplerefertoitasdirectionally) 25 1 percent. b O.5 % dwcAcuj.J$ QM cholog g is Myd wO d P tdAo NLW 4
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1 In essence, their numbers are similar, but 2
it is low probability.
We tend to try and maximize the 3
estimate of dose for design basis ace'identse owever, in Reg. Guide 4.2 and in the staff practice, i n'&nvironmenta l 4
s 5
impact statement we tend to use realistic assumptions g
f 6
or beyond design basis accidents, and, in fact, for g
7 design basis accidents in the environmental impact 8
statements we use realistic assumptions.
9 We have done exactly that with the CDA.
10 Dr. Cochran disagrees.
His argument seems to be that 11 you should.use the same assumptions that you use for 12 design basis accidents.
13 We don't agree, and that.hasn't been our
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14 practice.
We see nothing compell'ing in Dr. Cochran's 15 argument to do so'.
We have simply followed our past n
16 practice.
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8507 1
E5:41 JUDGE MILLER:
Let me inquire as a layman. You refer l
3 2 to past practice.
You are not telling us, are you, that it must also be simply because it has been done in the past, 3
so or that it is good?
In other words,.what i.1 the justifica-4 3 1 tion for reliance on past practice beyond history or pedigree?
5 Intheabsenceofanyinformath.cn WITNESS HULMAM:
6 that would tend to indicate we should change, history is the 7
a best precedent we have.
' Dr. Cochran has presented no argument that we can 9
see logic in that would indicate we ought to change it, and to in fact if you go back to the statement of considerations for 11 Part 100-- and there are two versions--and see what the framers 12 13 of Part 100 ha in mind, and if you follow what the C'ommission' s intent is with respect to siting, there is not!hing presented I
14 by Dr. Crot:hran that would lead us to believd that we ought to is 16 change our practice.
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17 JUDGE MILLER:
Thank you.
'l BY JUDGE LINENBERGER:
18
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Well, sir, I really appreciate your Comments here.
I 20 I need one little bit of clarification.
You use the term " low 21 probability meteorology."
Can you amplify just a bit what you 22 mean by that expression?
g 23 A
(Witness Hulman)
Yes.
I think it is rather sinple.
24 I am not a meteorologist.
I have supervised meteorologists.
25 I have watched. numbers being produced.
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M2 8508 1
What I mean by low probability meteorology is the 2 diffusion conditions between a reactor and an individual vary 3
with time and weather conditions.
4 The lower the probability of those weathe'r condition a 5 and diffusion conditions occurring, the worse the diffusion 6
conditions.
7 For example, often in thb morning you see little or a no' wind in the trees.
You see a lot of dew on the ground.
9 That's a poor diffusion condition.
Diffusion does not, would l
10 not--wind would not distribute radioactive releases very well, 11 so the lower the probability, the worse the diffusion condition <
tk &. S E R >
12 What we do generally for design basis accidentsfis 13 use a low probability assumption.
Some people used to call
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14 it a one chance in 20 or a five percent meteorology.
F 15 For be Larc. dismph. yond design basis accidents or for realistic aJ t fu 4A. S E Q. J j
i 16 assessments offaccidentsf', we use the 50 percent, or one chance j
I 17 in two.
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t 18 If we used the low probability meteorolog the l'
doses would have gone up.
Dr. Cochran is exactly correct.
g 2o That's not in dispute.
21 Uhat is in dispute with-the Staff is should we use 22 the low probability meteorology.
If it is a very low probabilit y i
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23 event, it is not within the design basis, we don't think 24 you have to.
It tends to compound the probability.
You have 25 the probability of the accident, the probability of the l
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l E5M3 8509 I
I meteorology and the the probability that there is somebody 2
there, and that he or she or it is going to stay there for the j
3 duration of the accident.
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Q All right.- These comments you havp just given with ma l
5 respect to low probability meteorology, do you consider that 1
o they adequately are applicable to Dr. Cochran's comments about---
7 I'm looking for a specific place here.
Nell, there are dis-a cussions beginning about page 12 and continuing for several pages.in which he makes certa.in observations conedrning 95 9
10 percent chi over Q versus 50 percent chi over Q.
11
)n, How say you to those comments?
. 12 A
That's exactly what I have~been addressing.
The 13 95 percent is the five percent value, just a different scale.
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Id It depends on which one you choose.
Ninety-five percent, I 15 assume Dr. Cochran is referring to the one chance in 20 16 i
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meteorology.
17 In fact, Dr. Cochran is wrong that the 95 percent
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meteorologythathehasquotedherearetheStaffnumberg,but l
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they are not the'95 percent numbers..They are basdd upon 20 i okorhaj4 eh J
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a+t Guidd 1.145, which defines the meteorology as thefone diuchona.llia da.p.twdiwt>
21 peredntgmeteorology, so Dr. Co hran is wrong with respect to j
t emu-kat ahy 22 isgone percent that somebody standing it.y the 95 percent also.
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23 in a certain direction woold see in eloht hours 1.2 times 10 24 to the minus 4 meteorolooy diffusion conditions, chi over Q, LovJhaN O[1 25 withfone chance in a hundred, not one chance in 20.
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