ML20028G673

Affidavit of Rl Kaufmann Supporting Seacoast Anti-Pollution League Motion for Summary Disposition of Contention Suppl Iii.Svc List Encl

ML20028G673
Person / Time
Site:	Seabrook
Issue date:	02/11/1983
From:	Kaufmann R NEW HAMPSHIRE, UNIV. OF, DURHAM, NH
To:
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ML20028G671	List: ML20028G670 ML20028G673
References
NUDOCS 8302170289
Download: ML20028G673 (3)

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AFFIDAVIT I, the undersigned Richard L. Kaufmann, being duly sworn, do hereby depose and say as follows:

1. I 'am a Professor of Physics at the University of New Hampshire in Durham, New Hampshire.

2. The Final Environmental Statement related to the operation of Seabrook Station (Units 1 and 2) contains only results of prob-abilistic risk assessment calculations. It does not contain estinates of the n,nsequences of a single major (class 9) accident, conditioned on any specific release or source term.

3. The figures and tabl s relating to a severe accided (Figures 5.4, 5.5, 5.6, 5.7, 5.8,a .10, and F-1) valy provide an estimate of the overall probability of various environmental impacts per reactor year.

4. Table 5.9 lists the probabilities of occurence for four (4) major accident sequences. There are no tables, figures, or other statements which describe the range of consequences that are predicted if a single major release does take place.This is true with respect to thevtables listed in (3) above, in addition to Table 5.9. 4m 4

5. The lack of estimates of the consequences from a single major accident could be corrected by running the CRAC2 code with SST 1 source term specifically for the Seabrook plant, and by including the results of this. study in the FES.

6. As a minimum, the resulting Final Environmental Statement should contain a table listing the smallest, largest, and median number of early fatalities, early injuries, cancer deaths, and costs conditional on an SST 1 release. The probability of an SST 1 release and the uncertainty of each entry should also be included in the Final Environmental Statement.

7. The Final Environmental Statement does not identify any specific major uncertainties in the risk analysis.

8. Such a quantitative uncertainty analysis is included in NUREG/CR-2239, SAND 81 - 1549, " Technical Guidance for Siting Criteria Development",

D.C. Aldrich, et. al., Sandia National Laboratory (DRAFT).

9. The Final Environmental Statement related to the operation of Seabrook Station (Units 1 and 2) merely expresses a staff judgement that the uncertainty bounds could be well over a factor of ten (10),

but are not likely to be as large as a factor of one hundred (100).

8302170289 830211 PDR ADOCK 05000443 C PDR m

10. NUREG / CR-2239, SAND 81-1549 concludes that there are factor of ten (10), factor of one hundred (100), and factor of one thousana (1000) uncertainties in various specific risk estimates. An example is the peak early fatality estimate, which has a stated uncertainty factor of one thousand (1000).

11. There are presently no state and local emergency plans which meet the assumptions used in the preparation of Figures 5.4, 5.5, 5.7, 5.8 and Table 5.10 (one hour delay to start of evacuation, followed by evacuation at a steady speed of 2.2 m.p.h. away from the site).

12. Figure F-1 shows i.he sensitivity of early fatalities to variations in the evacuation procedures. The other figures and tables listed in (11) above do not reflect any sensitivity to evacuation character-istics.

13. The assumptions used to prepare Figure F-1 are grossly oversimplified.

There is no consideration of the possibility of washout of high radiation doses over population centers, or the effects of a severe winter storm, which might require evacuation delays of much more th&n one day.

These statements are true and correct to the best of my knowledge.

"A d k-  %

RICHARD L. KAUFMANN, (Dated February 11, 1983)

STATE OF NEW HAMPSHIRE COUNTY OF STRAFFORD, SS February 11, 1983 Personally appeared the above-named Richard L. Kaufman and took oath that the statements by him subscribed are the truth to the best of his knowledge and belief.

Before me, AW f,Notfry Public -

~

Robert A. Backus 1

SERVICE LIST Helen Hoyt, Chm. Thomas G. Dignan , Esq.' ~'

Admin. Judge Ropes and Gray Atomic Safety & Lic. Ap. 225 Franklin Street Board - U.S. NRC Boston, MA 02110 Washington, DC 20555 03 RB 16 A11:07 bour

[.Jer g Judge Docketing and Service.Sec.

Atomic Safety &Lic. Ap. OficeoftheS'ecrepa{yjtrJ g .,

Wach ngt n DC 20555 W shington, DC 20555 Roy P. Lessy, Jr., Esq.

Robert L. Chiesa, Esq.

Offico of Executive Legal Director 95 Market Street U.S. NRC Manchester, NH 03101 Washington, DC 20555 Phillip Ahrens, Esq. Jane Doughty Asst. Atty. General Field Director Stato House, Station #6 SApL Augusta, ME 04333 5 Market Street Portsmouth, NH 03801 Wilfred L. Sanders, Esq.

Sanders & McDermott Tupper Kinder, Esq.

408 Lafayette Road Attorney General's Office Hampton, NH 03842 State of New Hampshire Concord, NH 03301 Dr. Emmeth A. Luebke David R. Lewis Admin. Judge Atomic Safety & Lic. Drd.

Atomic Safety & Lic. Ap. U. S. NRC - Rm. E/W-439 Board - U.S. NRC Washington, DC 20555 Washington, DC 20555 Jo Ann Shotwell, Asst. AG Ono Ashburton Place, 19th Floor Boston, MA 02108 William S. Jordan, II, 2sq.

Ellyn R. Weiss, Esq.

1725 I Street, N.W.

Suito 506 Washington, DC 20006 Edward J McDermott, Esq.

Sandoro and McDermott 408 Lafayette Road Hampton, NH 03842