ML20030C978
| ML20030C978 | |
| Person / Time | |
|---|---|
| Site: | 05000471 |
| Issue date: | 08/21/1981 |
| From: | MASSACHUSETTS, COMMONWEALTH OF |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20030C977 | List: |
| References | |
| NUDOCS 8108310115 | |
| Download: ML20030C978 (15) | |
Text
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737r.'iD UNITED STATES OF AMERICA NUCLEARREGULATORYCO!g1[SSION g3 a 2 BEFORE Ti1E ATOMIC SAFETY AND LICENSING BOARD L'3
)
In the Matter of
)
BOSTON EDISON COMPANY et al.
)
Docket No. 50-471
)
J,
,/y[er / N!U^ f (Pilgrim N" clear Generating
)
)
Station, Unit 2)
[sanc]eY
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)
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gYf)ve.$Cf-DETAILED STATEMENT OF THE COMMONWEALTH'S EMERGENCY PLANNING CONTENTIONS The Applicants and Staff have f ailed to account properly I.
for local emergency response needs and capabilities in establishing boundaries for the plume exposure pathway and ingestion pathway Emergency Planning Zones for Pilgrim II, as required by 10 C.F.R. 550.3 4 (a) and 10 C.F.R. Part 50, Appendix E.1/
Specifically, Applicants and Staff have
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Applicants have admitted,in their answers to interroga-tories propounded by rhe Commonwealth, that the only 1_/
See Response of of local jurisdictional boundaries.
Boston Edison Company, et al. to Commonwealth of Massachusetts' was that First Set of Interrogatories to Boston Edison Company Relative 2-6.
Applicants admit that, aside to Emergency Planning, pp.
f rom this one f actor, their selection of EP2 boundaries EP A 520/1-78-016, " Planning Bases for the Development of State and Local Government Radiologica). Emergency Response Plans in p 08310115 810827 DR ADOCK 05000471 P.O.S. F 2 70l 0
failed to consider adequately or to account properly for the effect of the following factors specific to Pilgrim II on local emergency recponce needs and capabilities and, hence, on the appropriate size and configuration of the Pilgrim II EPZ's:
A.
The large seasonal and transient populations on Cape Cod during summer months; B.
The limited road network on Cape Cod; C.
The limited access routes f rom Cape Cod to the main-land and the fact that those routes feed into the evacuation network for the population within 10 miles of Pilgrim II at points which are 11.5 and 14.5 miles, respectively, f rom the proposed plant site; D.
The proximity of the proposed plant site to Cape Cod Bay and the groundwater conditions and soil 1/ (cont. )
Support of Light Water Nuclear Power Plants,"
December, 1978, and NUREG-0651: FEMA-REP-1, Rev. 1, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants."
Id.
The Staff similarly states, in answer to interrogatories, that these documents serve as the bases for its agreement with the EPZ boundaries established by the Applicants.
See NRC Staff's Response to the Commonwealth of Massachusetts' First Set of Interrogatories to the NRC Staff Relative to Emergency Planning, p. 2.
The Commission's Emergency Planning Rule, 10 C.F.R. Part 50, Appendix E, Section II, specifically requires that the " size of the EPZs
. be determined in relation to local emergency response
..needs and capabilities, as they are affected by such conditions i
as demography, topography, land characteristics, access routes,
and jurisdictional boundaries."
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composition on said site, with their resulting implications for travel of radionuclides through a liquid pathway in the event of a reactor meltdown accident at Pilgrim II;2/
E.
The number, location, and capacity of local sheltering facilities and the degree of protection f rom radionuclides af forded thereby; F.
The heightened sensitivity to radiation (over that of the average healthy adult male) of the large numbers of children and pregnant women who are present on Cape Cod during the summer months; Local meteorological conditions, including the G.
distribution of wind directions and speeds and the frequency of hurricanes; Radionucli%'s which will be significant contributors H.
to dominant exposure modes for prompt and latent effects in the event of a PWR-1 to PWR-7 accidental release as described in the NRC's Reactor Safety l
2/
See NUREG/CR-1596, "The Consequences f rom Liquid Pathways of a Reactor Meltdown Accident," June,1981.
I i
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i at Study (WASH-1400), or its equivalent,
Pilgrim II.d!
The consequences of a PWR-1 to PWR-7 accidental I.
at harvest release at Pilgrim II, or its equivalent, time.
The Applicants' PSAR f ails to comply with the requ'irement II.
of 10 C.F.R. Part 50, Appendix E, snd 10 C.F.R.
S 50. 3 4 (a) that it "contain suf ficient information to ensure the compatibility of proposed emergency plans for both onsite areas and the EPZ's, with facility design features, site layout, and site location.
." because there is therein evidence of the feasibility of protectira insufficient 3/
NUREG-0396 and NUREG-0654, in arriving at their generic guidance on the size of EPZ's, rely en the potential consequences of a spectrum of accidents, including the PWR-1 to See NUREG-0396, pp.
PWR-7 accidents described in WASH-1400.The Pilgrim II fission product 4-6 ; NUREG-0 654, pp. 5-7.
inventory, however, exceeds the inventory of the 3200-megawatt thermal reactor used as the model for WASH-1400's estilt.ates of And the Pilgrim II average fuel burn-up accident consequences.
(thermal) per metric ton exceeds the 17,600 megawatt-daysThus, the generic guidance of NUREG-0396 assumed in WASH-1400.
and NUREG-0654 is based on estimates of accident consequences which fail to account for radionuclides which will be significant contributors to dominant exposure modes for prompt and latent effects in the event of a PWR-1 to PWR-7 release at Pilgrim II.
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. @ction in the event of a PWR-1 to PWR-7 accidental release, or its equivalent, at Pilgrim II.
This is true fut the following reasons:
A.
The PSAR contains no evidence of plant-specific probabilities of PWR-1 to PWR-7 releases.
B.
The PSAR contains no evidence of site-specific consequences in the event of PWR-1 to PWR-7 releases.
C.
WASH-1400's estimates of accident probabilities and consequences are not sufficient evidence of the probabilities and consequences in the case of Pilgrim II because:
1.
WASH-1400 provides insufficient evidence of accident consequences where evacuation is restricted, as may be tha case under the current emergency plans for Pilgrim II, to a ten-mile radius.
2.
WASH-1400 proaides insufficient evidence of the consequences resulting from releases through liquid pathways in the event of a reactor meltdown accident, which omission is particularly critical in the case of Pilgrim II given the proximi *,y of the proposed plant site to Cape Cod Bay and the groundwater conditions and soil composition on the site.
3.
The PSAR contains no evidence that WASH-1400's assumptions regarding medical treatment are applicable to Pilgrim II.
4.
There is a large degree of uncertainty associated with WASH-1400's estimates of accident probabilities.
The assumptions upon which WASH-1400's 5.
estimates of accident probabilities and consequences are based are not
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conservative for Pilgrim II and are inconsistent with the following factors specific to Pilgrim II:
A.
Pilgrim II fission product inventory; B.
Pilgrim II fuel burn-up; The heightened sensitivity c.
to radiation (over that of the average healthy adult male) of the large number of children and pregnant women who are in the Town of Plymouth and on Cape Cod during the summer months; d.
The population density pattern in the area of the Pilgrim site, as reflected by the Applicants' own filings in this proceeding; Meteorological conditions e.
specific to the Pilgrim site, including the distribution of wind directions and speeds and the frequency of hurricanes.
6.
The PSAR contains insufficient information to assure that the assumptions upon which WASH-1400's estimates of accident probabilities and consequences are based are consistent with the following factors specific to Pilgrim II:
The degree of protection a.
afforded by the protective action of sheltering in the t
event of an accident at Pilgrim II.
I b.
The latent consequences of a PWR-1 to PWR-7 accidental
(
release at Pilgrim II, or its equivalent, at harvest time.
(
large degre; of uncertainty associated I
D.
Occ uce of tha with WASH-1400's estimates of accident probabilities, the probabilities of exposures exceeding Protective set forth in NURE3-0396 may be Action Guides (P AG 's )
seriously understated for Pilgrim II.
The evacuation time estimates contained in the PSAR E.
have been limited to a geographical area determined without reference to local emergency response needs and capabilities.
(See Section I. above).
The evacuation time estimates contained in the PSAR F.
have not been properly calculated so as to estimate accurately the time required to evacuate the population within the plume exposure pathway EPZ proposed by the Applicants.
Specifically, those evacuation time estimates fail to:
Account for the full public 1.
tran pertation-dependent population; Account for the effect on evacuation times 2.
i of the bottlenecks at the Sagamore Rotary and along the Cape Cod Canal; Account properly for population growth prior to the commencement of operation and 3.
over the life of the plant; Account for the time required to evacuate 1
(
4.
special institutions; Account properly for 5.
preparation / mobilization time;
6.
Account properly for the ef fect on evacuation times of adverse weather
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conditions; 9.
Account for other than home-based evacuation traffic; 9.
Account for the possibility that multiple-car families will evacuate in more than one car; 10.
Use realistic assumptions with respect to the information available to evacuees when choosing evacuation routes.
G.
The evacuation time estimates prepared by Battelle Pacific Northwest Laboratories for the NRC Staff have not been properly calculated so as to confirm that the evacuation time estimates contained in the PSAR are realistic.
Specifically, the Battelle estimates f ail to:
1.
Account for the public transportation-dependent population; 2.
Account properly for population growth prior to the commencement of operation and over the life of the plant; l
3.
Account for the time required to evacuate special institutions; i
4.
Demonstrate any basis for the distribution of preparation times assumed or percentages of the population assigned to each time; l
i l
5.
Account for adverse weather conditions; 6.
Account for other than home-based a
evacuation traffic; 7.
Account for the possibility that multiple-car families will evacuate in more than one car; l
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_9 8.
Use realistic pre-planned evacuation routes or routes consistent with those which local officials will recommend; 9.
Use realistic free flow rate ass umptions; 10.
Employ a methodology sufficiently refined to produce results which are useful for purposes of confirming the estimates contained in the PSAR.
H.
There are significant discrepancies between the evacuation time estimates contained in the PSAR and those calculated by Battelle Pacific Northwest Laboratories for the NRC Staff.
I.
The evacuation time estimates contained in the PSAR and those calculated by Battelle Pacific Northwest Laboratories for the NRC Staf f underestimate actual evacuation times because they fail to account for any of the following possibilities:
1.
vehicles breaking down or running out of l
fuel; 2.
traffic accidents; 3.
abandoned vehicles; 4.
disregard of traffic control devices; and 5.
evacuees using inbound traffic lanes for j
I outbound travel.
J,.
The evacuation time estimates contained in the PSAR and those calculated by Battelle Pacific Northwest Laboratories for the NRC Staff are sufficiently high to warrant the conduct of a f ull plant-specific accident probabilities and site-specific accident consequences analysis and consideration of design modifications and other preventive and mitigative measures.
K.
The PSAR contains insufficient evidence to assure the feasibility of evacuation as a protective action given the f act that reception centers for evacuees have been located within twenty miles of the site.
L.
The PSAR contains insuf ficient evidence of the availability and adequacy of local sheltering facilities tc assure the feasibility of sheltering as a protective action in the event of a PWR-1 to PWR-7 release at Pilgrim II.
I f
M.
The PSAR contains insufficient assurance of prcmpt protective action decision-making.
1.
The PSAR does not provide for direct lines of communication, with appropriate back-up, with the Governor of Massachusetts and the Secretary of the Massachusetts Department of Public Health during that period of time before those officials arrive at the Civil Def ense Agency Headquarters Eme gency Operations Center.
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The PSAR, through its provisions for and "Second-line" "First-line d
notification, does not assure that all offsite authorities responsible for implementing protective actions will be notified within fifteen minutes of the occurrence of an emergency, as required by NUREG-0654.
3.
The PSAR contains no letters of agreement providing for prompt (15 minute) protective action decision-making on a 24-hour basis by off-site agencies.
N.
There are no established quantitative or qualitative standarcs by which one can assess the feasibility of protective action in the event of a PWR-1 to PWR-7 release at Pilgrim II.
III.
Because the Applicants' PSAR contains insufficient evidence of the feasibility of protective action in the event of a PWR-1 to PWR-7 accidental release, or its equivalent, at Pilgrim II, there is insufficient basis f or the Board to strike the cost / benefit balance required by the National Environmental Policy Act of 1969, 42 U.S.C. 54332 et sca.S/
l 4/ The Board expressly notes, in its Partial Initial Decision in this matter (at p.191), that the costs and benefits of l
emergency planning have not yet been f actored into its I
cost-benefit analysis and that the cost-benefit balance which it has tentatively struck must be reassessed in the light thereof.
I,he PSAR fails to set forth adequate preliminary plans for IV.
coping with emergencies as required by 10 C.F.R. 50, Appendix E, and 10 C.F.R. 550.34 (a).
A.
The PSAR fails to describe the means by which the public is to be notified and instructed of the need to evacuate or to take other protective action as required by' 10 C.F.R. 50, App.
E,Section II, Items C and G.
B.
The PSAR fails to provide for timely and adequate notification of off-site authorities.
1.
The PSAR fails to provide, as required by NUREG-0654, for notification of of f-site authorities within 15 minutes of the occurrence of an Unusual Event.
2.
The PSAR does not call for provision of suf ficient information to of f-site authorities upon the occurrence of an Unusual Event to assure that the purposes of such notification. as set forth in NUREG-0654, will be satisfied.
3.
The PSAR, through its provisions for "Fi rs t-line" and "Second-line" notification, does not assure that all of f site authorities responsible for implementing protective measures within the plume exposure pathway Ep2 will be notified within 15 minutes of the occurence of an emergency, as required by NUREG-0654.
C.
The evacuation time estimates contair.ed in the PSAR have been limited to a geographical area determined without reference to local emergency response needs and capabilities.
(See Section I. above).
D.
The PSAR contains insuf ficient evidence that there will exist the capability for
dose projection using real-time l
meteorological information, as required by
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10 C.F.R. Part 50, Appendix E, Item H, since PSAR Amendments 41 and 43 are luuva=lstent 16 their commitments with respect to provision of radiation monitors 1
in accordance with Reg. Guide 1.97, Rev. 2.
]
4 O
e
y UNITBD STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE TiiE ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
)
BOSTON EDISON COMPANY et al..
)
Docket No. 50-471
)
(Pilgrim Nuclear Generating
)
Station, Unit 2)
)
)
)
CE_RTIFICATE OF SERVICE I hereby certify that the within Statement nar been served on the following by deposit of copies thereof in the United States Mail, first cicss mail, postage prepaid this 21st day of August, 1981:
Andrew C. Goodhope, Esq.
Henry Herrman, Esq.
Chairman Room 1045 Atomic Safety and 50 Congress Street Licensing Board Boston, Massachusetts 02109 3320 Estelle Terrace Wheaton, Maryland 20906 Mr. & Mrs. Alan R. Cleeton 22 Mackintosh Street Dr. A. Dixon Call'shan Franklin, Massachusetts 02038 Union Carbide Corporation P.O. Box Y William S.
Abbo t, Esq.
Cak Ridge, Tennessee 37830 Suite 925 50 Congress Street Dr. Richard F. Cole Boston, Massachusetts 02109 Atomic Safety and l
j Licensing Board Thomas G. Dignan, Jr., Esq.
U.S. Nuclear Regulatory Ropes & Gray j
Commission 225 Franklin Street Washington, D.C.
20555 Boston, Massachusetts 02110 4
Patrick J. Kenny, Esq.
Atomic Safety and Licensing Edward L.
Selgrade, Esq.
Appeal Board Deputy Director U.S.
Nuclear Regulatory Mass. Office of Energy Commission Resources Washington, D.C.'
20555
. 73 Tremont Street Boston, Massachusetts 02108 l
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_-.-_,_..,.s-___
d Atomig Safety and Licensing Office of the Secretary Board Panel Docketing and Service Section U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Chief Librarian Jack R. Goldberg Plymouth Public Library Office of the Executive North Street Legal Director Plymouth, Massachusetts 02360 U.S.
Nuclear Regulatory Commission William S.
Stowe, Esquire Washington, D.C.
20555 Boston Edison Company 800 Boylston Street Thomas S. Moor 3, Chairman Boston, Massachusetts 02199 Atomic Safety and Licensing Appeal Board Francis S. Wright, Esquire U.S. Nuclear Regulatory Berman & Lewenberg Commission 211 Congress St.
Washington, D.C.
20555 Boston, Massachusetts 02110 Christine N. Kohl, Esquire Dr. John H.
Buck Atca.ic Safety and Licensing Atomic Safety and Licensing Appeal Board Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Was hington, D.C.
20555 Stephen H. Lewis R. K. Gad III i
U.S. Nuclear Regulatory Ropes & Gray l
Commission 225 Franklin Street Office of the Executive Boston, Massachusetto 02110 Legal Director l
Washington, D.C.
20555 l
l Michael Blumm l
U.S.
Nuclear Regulatory Commission Office of the Executive Legal Director Washington, D.C.
20555 k
'n o Ann Shotwell l
Assistant Attorney General Environmental Protection Division Public Protection Bureau Department of the Attorney General One Ashburton Place,19th Floor Boston, Massachusetts 02108 (617) 727-2265 f
l
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