ML20032C111
| ML20032C111 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 01/06/1975 |
| From: | Davies S NEW YORK, STATE OF |
| To: | Collins H US ATOMIC ENERGY COMMISSION (AEC) |
| Shared Package | |
| ML100141336 | List: |
| References | |
| NUDOCS 8111070491 | |
| Download: ML20032C111 (3) | |
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@ TATE OF NEW YORr'( o NM COMMUNITY HEAtTH 5tRv!CES
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DEPARTMENT OF HEALTH
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DURcAU OF R ADIOLOOtC AL 6 C Atrea sacnnoco cAucs, u.e.w., e.c.
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January 6, 1975 Harold E. Collins Accetic Energy Ccenission
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Emergency Preparcdacss Washington, D. C.
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Dear Mr. Collins:
State Emergency Plan for Major Radiation AccidThis is in reply to y 1974 relative to the New York ic appreciate receiving these co=ents and th ents Involving Nuclear Facilitics.
- ration of any revisions to the plan.
e offer of assistance in the prep-As you may know, round a nuclear facility (Indian Point) and develoin 1962 New York State m calth in Deccaber 1962 entitled " Protecting the Epaper discu nsive survey merican Journal of Public t
actor - A State Health Department Acts."
nvironmcat Around a Nucicar Pcecr tor accidents at nilk, food, and water supplies.that time concluded that the primary cOur evaluatio oncern was conta:nnation (N'
ruission and Utility staff to insure thatIn the subsequent years, we y.with the US Atomic Energy protect the citizens of New York State.emergency response plans are adequate ign Basis Accident used to determine if thOur present plans have e
on an accident which is 107, of timony by Dr. Dudicy Thompson, USAEC e 10 CFR 100 siting criteria are met November 12, 1971
, at supported Ncv York State'the USAEC's Indian Point Co. 2 heari s position by stating:
ng 1) that realistically should a Design Basis A probability that by a factor of 10 or more;the actual consequences would be lesccident occur, ther s severe probably 2) the levcl of projected radiation dose the 10 CFR 100 siting criteria; would be substantially lower than
- 3) the geogr/'
is approxitaately the same as the Low Paphic area of coverage appro opulation Zone; andvance c=crgency planning 4) accidents ~ reater than 107. of the consequence g
arc exceedin;1y improbably and chat s of. the Design Basis Accident beyond those covered by the develeoed ed suct accidents night 8111070491 760206 vc. ace caergency plan. call f ar rc:c.:rces PDR ADOCK 05000003 g
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o O-HarS1d E. Collins-January 6, 1975 i
Since that time best estimate calculatio'ns of the Loss of Coolant Accidents have been performed by applicants and the USAEC and these calculations indicate that the of f-site radiolo;;ical consc.;uen:cs are less than 17. of those for the Design Basis ' Accident.
The USAEC's Ennronmente.1 Impact Statement on nu lcar facilitics indicates ofi-site consequences of a magnitude well within 10 CFR 20 liuits.
In the State's current plan, detailed planning for accidents up to and in-
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cluding 107. of the Design Basis Accident is provided in Alert "A" of the New York State Specific Operating Procedures. Alert "C" provides for :aarshalling all re-sources for any accident having off-site consequences greater than that covered in Alert "A".
We now understand that,you are requesting the State to provide detailed response plans for an accident that is 10 times more than the USAEC previously re-quired and to provide detailed plans for the evacuation of the population in sub-stantial arcas beyond the Low Population Zone.
Your November 22, 1974 letter suggests that we review our planning documents against the planning cic=ents in the USAEC " Guide and Checklist," dated Decc bcr 1973, and consider expanding the secticas which arc deficient and addressing # those which are absent. On July 5,197.'+, '<r. T. K. DeBoer, representing the Xcw York State Atomic Energy Council, posed a number of questions to Mr. Herbert li. Brown relative to this Guide and Checklist.
'<any of these points go to the hear.t of the concept of the New York State Plan and before meaningful acend=cnts can be made to it, it is felt a response should be made to the points Mr. DcBoer addressed. We i
vould appreciate your advising us as to waccher the OSAEC staff believes that there,k is a greater probability of the occurrences of the Design Basis Accident and it.;
iftheprobabilityf.
off-site consequences than was previously believed.
Uc fecl that of an accident occurring with off-site consequences comparabic to the Design Basis Accident is indeed extrc=ely low, then there is no justification for the extensive detailed advanced planning that the Cornission now appears to require.
The WASH-1400 Reactor Safety Study, USAEC analyses and applicants' analyses show that there is a vide variety of reactor accidents that can be considered and that a corresponding wide range of off-site consequences and related probabilitics exists for these accidents.
The WASH-1400 report indicates that the probability of 100 or more fatalitics resulting frca toxic gases.is 1 in 100 years; tornado 1 in 5 years; hurricane 1 in 5 years; and for 100 nuclear reactors 1 in 10,000 We believe that years.
the USAEC is placing unduc emphasis on detailed planning for a catastrophe with an extrenely low probability of occurrence.
One aspect of the New York State Plan that we agree requires further development is the response of local authorities in the in:tediate post-incident period while the State's response is,being =arshalled. At the present time, planning activity is being carried out with local authoritics on this aspect of the State's overall plan.
Another aspect of our plan that we are expanding concerns surveillance and protection of our water systcas, milk, milk products, and food.
In the accidents which have the greatest probability of occurring, the potential for human radiation exposure from ingestion of contaminated water, food, milk or milk products is vastly greater G L 2.I LJa
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Harold E. Collins- ~
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than expos'ure from inhalation. Uc believe that prioritics for detailed planning " t.-
should be undertaken based upon probabilitics of the accident and the potential for human exposure.
To date there has been no specific Federal guidance as to " acceptable" limits of population exposure from air, water, food, or ailk. Uc have used as our guide Federal Radiation Council Reports Nos. 5 an,d 7 and based on these reports, the arca that cust b : considered extends a considerabic distance beyond the Low Population Zone. The Indian Point site presents a specific probica to us.
In addition to a
.large population, we have a Federal psychiatric hospital, State rehabilitation hospital, and U.S. Military Acadcay all within a relatively short distance from the site.
New York State is considering utilization of the $250,000 planning grant
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availabic through the Federal Disaster Assistance Administration (FDAA) for assistance in the developacnt of a number of disaster planning program areas. Ona of these areas is the one concerning State and Local response to major accidents involving a nuclear facility.
In accordance with FDAA requircaents, a formal application will be presented at an appropriate tiac for assistance in these various programs.
Your offer th.at a field cadre be sent to New York for help in the developacnt of the, State's radiation caergency responsa plans is appreciated.
Houcver, until scac of the points discussed above, and in Mr. DeBoer's letter of July 5,1974 are resolved, it 's doubtful that the Stato could benefit froa this type of direct assistance.
In considering this whole subject it cust be realized that if State and local agencies cust now plan for the evacuation of areas beyone the Low Population Zona, it will be necessary for us to look at cach nuclear facility now operating and to evaluate how'cffective we would be in protecting the population froa consequences of an accident 10 times greater than heretofore required by the USAEC.
It should also be noted that if the probability of an accident is considered great enough.
t to require extensive advanced detailed planning to cope uith it, then consideration should be given to the fact that the probability of such an accident and the risk to the public may be too great to pcrait the construction and operation of nuclear power reactors.
I would appreciate hearing as soon as possible so that we can proceed with our further review of caergency plans.
Very e uly yours, s
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ONyf hM Sherucod Davics, M.P.H., P.E.
Director Eureau of Radiological Health cc: Major Cencral J. C. Baker Mr. J. Hayes Mr. T. K. DcBoer Mr. L. Czech