ML20032C742

Forwards Ofc of Nuclear Reactor Regulation Responses to Written Statements to ACRS from Public Re Facilities

ML20032C742
Person / Time
Site:	Grand Gulf
Issue date:	10/09/1981
From:	Houston M Office of Nuclear Reactor Regulation
To:	Alderman H Advisory Committee on Reactor Safeguards
Shared Package
ML20032C743	List: ML20032C742 ML20032C744 ML20032C745 ML20032C746 ML20032C747
References
NUDOCS 8111110249
Download: ML20032C742 (16)

Text

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OCT 091981 a

l Docket Nos. 50-516/417 ItEMORA!!DUM FOR:

lleman Aldeman, Reactor Operating Experience Engineer Advisory Comittee on Reactor Safeguards FROM:

H. Dean Houston, Project lianager Licensing Branch No. 2, Division of Licensing Office of, Nuclear Reactor Regulation

SUBJECT:

WRITTEtt STATEHEllTS FROM Ti!E PUBLIC TO THE ACRS Oli GRAND GULF By separate memoranda dated Septerber 23, 1981 to Mr.Denton, you for-warded two written statements, one from Mr. Caleb Dana and one from Mr.

Ken Lawrence.

We have reviewed these statements and our coments on them are provided as Attachments 1 and 2 to this memorandum.

M. Dean flouston, Project !!anager Licensing Branch llo. 2. DL Attachments AS stated above

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. ATTACHMENT 1 2

y NRR ' responses to Statements" bE Caleb Dana in a [[letter::AECM-81-323, Final Deficiency Rept Re Undersized ASME Socket Welds Identified During IE Insp 50-416/80-13,originally Reported on 800718.Constructor Welding QC Engineers Reinstructed Re Min Fillet Sizes for Sockets & Flanges|September 16, 1981 letter]]' _

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to the ACRS.

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-Statement' "I would like to register sty 4ppostions to the project.

I have seen -

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Congressional RecordsLindicating accident rates within the industry and -

9enerally feel ~ accidents are' inevitable as in every other instance of; liff s endeavors. ~I am also' aware of the contentions of some twenty or_. -

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so incidents at nuclear poweFfacilities that would-have: led to ax d-Y

-reactor meltdown, and I belie'v'e that the Rassmussen Report upon which j

reactor safety projections we're generally based is pretty well con-

. sidered now as to be grossly " inaccurate.

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--1 The Reactor Safety Study (RSS) (Rassmussen Report) was published-in!1975.T In July 1977, the NRC organized an Independent Risk Assessment Review N*

Group to:

(1) clarify the achievements and limitations of the Reactor Safety Study Group, (2) assesY the peer connents thereon and the D,N

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responses to the comments (3)~ study the current state of such risk

.L assessment methodology, and ('4) reconmend to..the Conmission how and whether such n'ethodology can h used in the regulatory and ~1icensing process..The results of this' study werel issued September 11978 7 This report,: called the Lewis Repo~rt, contains several' findings and -

reconmendations concerning tKe RSS. Some of the more_significant findings are summarized belod.

o A number of sources of bo'th conservatism and nonconservatism in, I

the probability calculations in RSS were found, which were v'ery

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difficult to balance. Th'e Review Group was unable to detennine-whether the overall probability-of a core melt given in the_ RSS was'high or 1ow, but did' conclude that the error bands were understated.

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.o The methodoloav. which wa's an important advance' over ear'ier methodologies that had been applied to reactor risk, was sound.

(Emphasis added) o-It is.very ' difficult to follow the detailed thread of calculations through the RSS.

In particular, the Executive Sunnary is a poor description of the conten'ts of-the report,'should not be used-as such, and has lent itself to misuse in the discussion of reactor ri s k.'

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On January 19. 1979, the Commiission issued a statement of policy concerning the RSS and the Review Group Report. The Consission accepted the findings of the Review Group.

Statement In addition,-I as concerned about the so called " low level permissible" radioactive gas discharges. The best I can~tell there appears to still be controversy regarding what' is a safe level of exposure to radioactivit;y.'

.Until safety. issues are cleared up and the safety assured, I will object to such facilities.

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Response

r The Station's operation will'he goverred by operating license Technical i

Specifications which will be based on the dose design ob.iectives of Appendix I to 10 CFR Part 507 Because these design objective values -

were chosen to pemit flexibility of operation while still ensuring that plant operations are aslow as reasonably achievable (ALARA),

the actual radiological icipacit of plant operation may msult in' doses 2

close to the dose design objectives.. Even if this situation exists, e

the individual doses for the member of the public subject to maximum exposure will still be very small when compared to natural backgmund?

doses ( 100 mrams/yr) or the' dose limits specified in 10 CFR Part 20

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(500 mrems/yr - whole body). ~As a result, the staff concluded that there will be no measurable radiological impact on members of the public from routine operatio[of the Station.

F Operatir.g standards in 40 CFR Part 190, the Environmental' Protection Agency's Environmental Radiation Pmtection Standards for Nuclear Power Operations, specify tha't the annual dose equivalent must not exceed 25 mrens to the whole' body, 75 mrens to the thyroid, and 25 mress to any other organ of any member of the public as the result of exposures to planned discharges.of radioactive materials (redon-and its daughters excepted)'to the general environment from all uranium-fuel-cycle operations ~ and radiation from these operations that can be expected to affect.a given individual. The NRC staff concluded that under normal operations the Grand Gulf size is capable of operating within these. standards.

.The cause and effect relation' ships between radiation exposure and adverse health effects are quite complex but they have been more exhaustively studied than any other environmental contaminant.

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Whole-body radiation exposure resulting in a dose greater than' about 10 rems for a few persons and about 25 rems for nearly all people over a short period of time (hours) is necessary before any physio.

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logical effects to an individual are clinically detectable. Doses about to 10 to 20 times larger than the latter dose, also received over a relatively short period 'of time (hours to a few days), can be expected to cause some fatalities. At the severe but extremely low probability end of the accident spectrum, exposures of these magnitudes are theoretically possible for persons in the close proximit;y of such

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accidents if measums are not"or cannot be taken to provide protection, such as by sheltering or evacuation.

l.ower levels of exposures may also constitute a health risk, but the ability to define a direct cause and effect relationship between any.

given health effect and a knoun exposure to radiation is difficult because of the many other pos'sible reasons why a particular effect

• is observed in a specific individual. For this_ reason, it is necessary to assess such effects on a si:atistical basis. Such effects include cancor and genetic changes in future generations after exposure of a prospective parent. Cancer in the exposed populations may begin to develop only_ after a lapse of 2 to 15 years (latent period) from the time of exposure and then continue over a period.

of about 30 years (plateau period). However. -in the case of exposure of fetuses [i_n u,tero), cancer may(begin to develop at birth (no latent periody and end at age 10 the plateau period is 10 years).

The health consequences mode 1 ~ currently being used is based on the 1972 BEIR Report of the National Acadesty of Sciences.

Most authorities agree that a reasonable and probably conservative estimate of the statistical relationship between low levels of radiation exposure to a large number of people is within the range of about 10 to 500 cluded by the data)poten.'al' cancer deaths (although zero is not ex-per e W person-mus.

The range comes from the latest NAS BEIR III 1980), which also indicates a probable value of about 150. Thi is virtually identical to the value of about 140 used in tiu ant NRC health effects models.: In addition, appro.51mately 220 genetic changes per million-person-rens would be pmjected by BEIR III over succeeding generations. That also compares well with the value of about 260 per million person-rems currently used by the HR,C staff.

S_ta*.ement T

I also object because ultimate waste disposal and transporation

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issues are unresolved safety issues.

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Response.

The impacts from the Uranuim Fuel Cycle (which includes ultimate waste disposal) are described in Section 5.10 and Appendix C of the Draft Environmental Statement (DES) for the Grand Gulf Nuclear Station -

(the Final Environmental Statement (FES) issuance date is iminent).

The staff's conclusion is that the environmental impact of the Station to the U. S. population'due to the ureniin fuel cycle is insignificant when compared with the impact of natural background radiation.

Impacts from the transportation of Padioactive Materials are discussed-in the DES and FES in Section 5.9.1.1.2(1). The cumulative radiation:

dose to the public from trans'portation (7 person-rens) is very small-when compared to the annual dose of 26,000,000 person-roms to the same population fmm background radiation.

S_tatement Electricity produced by nuclear power is the most expensive form of electricity, even when not including decomissioning and ultimate waste disposal costs, which will certainly be large.

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Response _

The production costs of the Grand Gulf Huclear Station as they relat::

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to other sources of fuel (mainly oil and gas) are discussed in Section 2.2 of the DES and FES and annual savings by the use of the -

Station are presented for the first five years of operation.in Table 2.1.

The results shown would not.be significantly altered if 4

the demand for electricity grows at a lower rate than assumed.

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addition. although Table 2.1 ~shows savings only through 1985, in actuality, fuel-cost savings Wuld continue as long as the Station is licensed and operating - a' period of approximately 30 years. The~

staff does not agree with Mr.' Dana that electricity produced by t

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nuclear power is the most exlensive.

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I also object that nuclear power costs may be included in a utilities (sic) t base rate, hiding the costs.

I believe marginal pricing systems l

should be institude (sic) and, nuclear power costs assessed separately.

Response.

Statement is noted. Since the statement deals with matters not under the jurisdiction of the NRC, no additional response is appmpriate.

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And finally, I wish the nuclear powrir in:!ustry wuld stop begging '

for federal handouts. They're as bad as the welfare chi,alers. Or 5

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These are non specific personel expressions,'which are noted. Ho X;

additional response is appropr.iate.

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.NRR responses to' statements by Ken Lawrence in a September 18, 1981

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Yesterda.f the subcasmittee heard my statement on tornado damage to Grand-f*

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Gulf and the danger g.osed b/ the possible recurrence of such an ' event

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after theiraattor is in operition. The chairman instructed the staffLto re-examine tinse concerns, especially in light of the evidence of damage y

pr to the cor.tainment' tuilding inflicted by the April 17.-1981(sic). ' For this we as gFateful.=

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@I The NRC staff at,the subcomittee meeting quickly looked into this:

f matter and on September 18. 1981 read into the subconnittee's record the j l (

fact. that the matter had bein appropriately investigated by the NRC 'and

py Aha*. there are.no unresolved' safety issues on this construction r,tage 1

'y damago. All safety related structures were satisfactorily evaluated and g

f where r,ppropriate, repairs o( replacements made'.

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-The chainnan subsequently sotight to assure us, as' members of tho' public i /+

who had raised the issue, that the reactor design routinely provided

. protection against the worst' tornado. Of this we were and are skeptical.

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Response,

. Attention is directed to themRC staff's Safety Evaluation Report on Grand Gulf, dated September 1981. Local meteorology is Ecknowled involve tornadoes and we cleavly state (on page 2-10 of that SER)ged to that i

there are no unusual meteoroTogical conditions at the site thet'have not i.

been considered in plant.desfgn and siting and that the' requirement GDC' 2 of 10 CFR 50 Appendix A with respect to meteorolo

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been met. Section 3.5.1.3 of the SER (on page 3-7)gical parameters ~have

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" Missiles Generated by Nacural Phenomena" provides additional detail of our. review and states that. in design for t6rnado missiles, the' applicant has used'a spectrum of missile weights an'd velocities that is in accordance with our current. tornado missile criteria representative of missiles at te%

site, and acceptable. FurtheY discussion is provided in Section's 3.5.2 and 3.5.3 of the SER.

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Thus, the chainnan's assuran(e was, indeed, well founded.

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Statenant After. last night's. hearing,--I' ~ examined the pertinent sections of your staff's Safety Evaluation Report on Grand Gulf. Section 3.5.3 '

states: "The postulated worst-case high-trajectory missile would

.just perforate the containment and its liner." It goes on to state

.that the probability of this ~even is low, and "We have confinned-the applicants' probability value_ for high trajectory missiles."

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Prestanably;this low probability was based.in part on the Local Heteorology report, (SER, pages 2-5 to 2-10), which states:

"Durin the eriod 1950-1975,'73 tornadoes iave been reported within 75 km 46 mi 'of the site, giving-a maar. annual tornado frequency of 2.8 and a computed mean odcurrenc'e interval for the site of. 5,525 years. "This figure apparently assumes that,.in the period examined '

there is an equal probability ~of a tornado striking any point within the 75 km radius,'and that ea~ch tornado strikes only a small area within the radius. The evide'nce I offered yesterday - newspaper' clippings based on scholarly ~ studies-contradicts at least the first of these assumptions.

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One indicates.that the portidn of that 75 km circle to the east of the Grand Gulf had a.substantially higher probability of dangerous tornado activity than that td the west,-thus more than doubling the r

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-likehood of a. tornado in the~irea of the reactor site._ Another showed that the area of greafest tornado danger is slowly retating L

to the west, and will include ~ the Grand Gulf site throughout its projected operating life. As~ 1t advances, the likelihood of a tor-i nado striking within a 75 km Yadius is expected to increase consider-i ably, and presumably so is thi' average ground area covered by any

tornado.

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This increase would also pres'umably increase the probability of missiles, both low-and high-trajectory, well beyond the MP&L ar.d' 7

HRC staff calculations.

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SER Section 3.5,3 on prooability of missile strd.os to tornado ~

l missiles. The statement appTies only to missiles that could be gen-erated from the plant's main ~ turbine, not a tornado.

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L the tiRC staff criteria as emliodied irtRegulatory Guide 1.7G, and 'the~

applicants' design, which corifoms to that criteria, assume a probability.

of 1.0 for tornado missiles a't Grand Gulf ouring its life. That is,

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both the NRC staff and the agiplicant assume that there will be a l

severe tornado at the site 46d the plant structure have been appro-priately designed to withstand such a tornado.

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OCT 0 91981 Docket Nos. 50-416/417 m

MEMORANDUM FOR:

Herman 'Aldennan, Reactor Operating.

Experience Engineer Advisory Comittee on Reactor Safeguards i

FROM:-

M. Dean Houston, Project Manager Licensing Branch'No. 2, Division of Licensing Office of Nuclear Reactor Regulation

SUBJECT:

WRITTEN STATEMENTS FROM THE PUBLIC TO THE ACRS ON GRAND GULF t

By separate memoranda dated September 23, 1981 to Mr.Denton, you for-warded two written statements, one from Mr. Caleb Dana and one from Mr.

Ken Lawrence.

We have. reviewed these statements and our coments on them are provided as Attachments 1 and 2 to this memorandum.

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M. Dean Houston, Project Manager Licensing Branch No. 2, DL Attachments AS stated above

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ATTACHMENT 1 NRR responses-to Statements by Caleb Dana in a [[letter::AECM-81-323, Final Deficiency Rept Re Undersized ASME Socket Welds Identified During IE Insp 50-416/80-13,originally Reported on 800718.Constructor Welding QC Engineers Reinstructed Re Min Fillet Sizes for Sockets & Flanges|September 16, 1981 letter]] to.the ACRS.

Statement

- 4 "I would-like to register my oppostionto the project.. I have seen

- Cpngressional Records indicating; accident rates within the industry and generally feel accidents are inevitable as. in every other instance of life's endeavors.

I am~also aware of the contentions of some twenty or-

. so. incidcnts at nuclear power facilities that would have led-to a-

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reactor meltdown, and I believe that the Rassmussen Report upon which reactor safety projections were generally based is pretty well con-sidered now-as to be grossly inaccurate.

Response

The Reactor' Safety Study (RSS) (Rassmussen Report) was published in'1975.

In July 1977, the NRC organized an Independent Risk Assessment Review Group to: -(1) clarify the achievements and limitations of the Reactor Safety Study Group, (2) ' assess the peer comments thereon and the-responses to the comments, (3) study the-current state of such risk-assessment methodology, and (4) recomend to the Commission how 'and whether such methodology can be used in the regulatory and licensing

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process. The results of this study were issued. September 1978. This report, called'the Lewis Report, contains several findings and recommendations concerning the RSS. Some of the more significant findings are summarized below.

- o A number of sources of both conservatism and nonconservatism in the probability calculations. in RSS were found, which were very difficult to balance. The Review Group was una',t4 to' determine whether the overall probability of a core melt gwen in the RSS was high or low, but did conclude that the error bands were-understated.

o

. The methodology, which was an important advance over earlier methodologies that had been aoplied to reactor risk, was sound.

.(Emphasis added)

.o It is very difficult to follow the detailed thread of calculations through the RSS.

In particular, the Executive Summary is a poor description of the contents of the report, should not be used as-such, and has lent itself to misuse in the discussion of reactor r i s k.-

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0n 4anuary 19, 1979,

the Commission issued a statement of policy mconcerning the RSS and the1 Review Group' Report.

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' accepted the: findings of-the Review Group.

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In addition, I. am concerned about the.so called low leveli permissible".

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radioactive gas.di3charnes. Th0'best I can tell there appears. to still be controversy regarding what _is -a '3afe level of exposure..to radioactivity.

Until safety. issues are cleared up'and the safety -assured, 'I will object -

to such. facilities.

-Response The Station's o'peration will'be governed by operating license Technical' Specifications which will be based on the dose design objectives of.

Appendix I to 10 CFR Part-50. Because these design objective values were chosen to. permit flexibility of.. operation while still ensuring that plant operations are as' low as reasonably ac11evable (ALARA),

the actual radiolcgical impact of plant operation may result in doses close to the dose design objectives. Even if this situation exists, the individual doses for the member of the public subject to maximum exposure will still ha very small when compared to natural background doses ( 100 mrems/yr) or the dose limits specified -in 10 CFR Part 20 -

(500 mrems/yr - whole body). As a result, the staff concluded that-there will be no measurable radiological impact on members of the public from routine operation of the. Station.

Operating standards in'40 CFR Part 190, the Environmental Protection Agency's Environmental Radiation Protection Standards: for Nuclear Power Operations, specify that the annual dose equivalent must not exceed 25 mrems to the whole body, 75 mrems to the thyroid, and 25 mrems to any other organ of any member of the 'public as the result of exposures to planned discharges of radioactive materials (radon and its daughters excepted) to the general environment from all uranium-fuel-cycle operations and radiation from these operations that can be expected to affect a given individual. ' The NRC staff concluded that under normal operations the Grand Gulf site is capable of operating within these standards.

The cause and effect relationships between radiation exposure and ~ adverse health effects are quite complex but they~ have been more exhaustively studied than any other environmental contaminant.

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p Whole-body radiation' exp'osure resulting in a dose greater than about 10 rems for a few persons and about 25 rems for nearly all people over a short period ~of time (hours) is necessary before ~any physio-

'ogical effects to an individual are clinically detectable. ' Doses-about to 10 to 20 times larger than'the latter dose, also re':eived

-_over a. elatively short period of time (hours-to a few days), can be.

- expected to cause some fatalities. At-the severe but extremely low

' probability end of the accident spectrum, exposures of these_ magnitudes

- are theoretically possible fcr persons in the close proximity of such accidents if measures are not-or cannot-be taken to provide pratection, such as by sheltering or evacuation.

Lower levels of exposures may also' constitute a health risk, but the

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ability to define a direct cause and effect relationship between any given health effect and a known exposure +c radiation is difficult because of the many other possible reasons why a particular effect is observed in a specific individual.

For this reason, it is necessary to assess such effects _ on a statistical basis. ' Such effects include cancer and genetic changes in future generations after exposure of a prospective parent. Cancer in the exposed populations may begin -to develop only after a lapse of 2 to 15 years (latent period) from the time of exposure and then continue over a period of about. 30 years (plateau period). However, in the case of exposure of fetuses (in utero), cancer may(begin to develop at birth (no latent' period) and end at age 10 the plateau period is 10 years).

The health consequences ~ model currently being used is based on the 1972 BEIR Report of the National Academy of Sciences.

Most authorities agree that a reasonable and probably conservative estimate of the statistical relationship between low levels of radiation exposure to a large number of people is withir. '.he range of about 10 to' 500 potential cancer deaths (although zero is not ex-cluded by -the data) per million person-rems.

The range comes from the latest NAS BEIR III Report (1980), which also indicates a probable value of about 150. This value is virtually identical to the value of about 140 used in the current NRC health effects models.

In addition, approximately 220 genetic changes per million-person-rems

.would be projected by BEIR III over: succeeding generations. That also compares well with the value of about 260 per million person-rems currently used by the NRC staff.

Statement I also object because ultimate waste disoosal and transporation issues are unresolved safety issues.

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Response

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1TheJimpacts[fromtheUranuimFu'elCycle.(whichincludesultimatewaste-disposal) are' described in Section-5.10 and Appendix' C of. the Draft-Environmental Statement -(DES) for the Grand Gulf Nuclear Station -

'(the Final: Environmental Statement (FES) issuance' date issiminent).

-The ' staff's conclusion is that the environmental impact of.the Station.

to the U. S.. population due to the uranium fuel cycle is insignificant when -compared with the : impact of natural. background radiation.

Impacts from the transportation of Radioactive Materials are' discussed in-the DES and FES in Section 5.9.1.1.2(1).

The cumulative radiation dose to the public from transportation (7 person-rems) is very small when compared to the~ annual. dose of 26,000,000 person-rems to the p

same population from background radiation.

Statement-Electricity produced by ' nuclear-power is the most expensive form of electricity, even when not including decommissioning and ultimate waste disposal costs, which will certainly be.large.

Resconse The production costs of the Grand Gulf Nuclear Station as they relate to other sources of fuel'(mainly oil and gas) are discussed in.

Section 2.2 of'the DES and FES and annual:savi.ngs'by?the use;of; the "

Station are presented for the first five yea"s of operation in Table 2.1.

The results shown would.not be significantly altered if the demand for electricity grows at a lower rate than assumed.

In addition, although Table 2.1 shows savings only through 1985, in actuality, fuel-cost savings would continue as long as the Station:

is licensed and operating - a period of approximately 30: years. The staff does not agree with Mr. Dana that electricity produced by nuclear power is the most expensive.

Statement I also object that nuclear power costs may be included in a utilities (sic) base rate, hiding the costs.

I believe marginal pricing systems-should be institude (sic) and nuclear power costs assessed. separately.

Response

Statement is noted. Since the statement deals -with-matters not undar the jurisdic ion af'the NRC, no. additional response is appropriate.

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l "I Andifinallip' ;pnish the nuclear-powercindustry would:stop. begging

.forTfederal: handouts..~ They're as; bad as the welfare chislers.

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4These ah inon_' specific.. personal expressions','which are'noted. No Ladditionall response l..is appropriate.

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' ATTACHMENT 2:

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p NRR' responses to ~ statements by Ken Lawrence in a September:.18,1981

-letter to the-ACRS.

Statement-Yesterday the subcommittee heard my-statement en tornado damage to Grand-Gulf and the danger posed by the possible recurrence of such an event after the reactor is in. operation. The chairman instructed the staff to re-examine these concerns, especially in light of the evidence of damage-to'the containment building inflicted by the April 17,~ 1981 (sic).

For this we are' grateful.

Response-The NRC staff at the subcommittee meeting quickly looked into this matter and on Se'ptember 18, 1981 read into the subcommittee's record the fact,'that the matter had been appropriately investigated by the-NRC and that there are no unresolved safety issues on' this construction stage

. damage. All safety related structures wer6 satisfactorily evaluated and where' appropriate, repairs ar replacements made.

Comment

-The chairman subsequently sought to assure us, as members of the public who had raised the issue, that the reactor design routinely provided protection against-the worst tornado. Of this we were and are skeptical.

Response-Atter, tion is directed to the NRC staff's Safety Evaluation Report on -

Grand Gulf, dated SeptemberJ1981. Local meteorology is acknowledged to involve tornadoes and we clearly state -(on page 2-10 of that SER) that there are no unusual meteorological-conditions at the site that have not i

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been considered in plant design and siting and that-the requirement GDC 2 of.10 CFR 50 Appencix A with respect to meteorological. parameters have been met.-

Section 3.5.~1.3 of the SER (on page 3-7) " Missiles Generated by Natural Phenomena" provides additional detail of our. review ~and -

states that, in-design for tornado missiles, the applicant has used a spectrum of. missile weights and velocities that is in accordance with our current tornado' missile criteria representative of missiles at the

- site and acceptable. Further discussion is provided in Sections 3.5.2 and 3.5.3 of the SER.

Thus,;t' e: chairman's assurance was, indeed, well. founded.

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' Statement.

N-JAfter last: night'sihaaring,iIcexamined the pertinent sections of your-

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staff's: Safety-Evaluation Report Jon Grand Gulf..Section 3.5.3 states:

1"The postulatedisorst-case-high'-trajectory; missile wouldljust. perforate-

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L the containment and its= liner;".It goes oonito state that the probability -

'of!this even is low. and;"tle:have1 confirmed the applicants'" probability Lyalue: for high trajectory missiles."

(See page.3-9)

Presumably this low probability-was based in part on the Local Meteorology report,;(SER. :pages 2-5.to?2-10), which ' states:

During 'the period 1950-1975, 73 tornadoes have; been reported within 75 km (46 mi) of the -

site, giving 'a mean. annual tornado frequency of 2.8 and a computed mean occurrence. interval for ~the-site.of 5,525 years. - "This figure apparently-cassumes that, 'in 'the period ' examined, there is an equa1 ' probability of a tornado striking any point within the 75 ba radius,'and that each tornado

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strikes'only a:small area-within the radius.

The evidence I offered yesterday - newspaper clippings based on scholarly studies-contradicts'

- at 'least the first of these assumptions.-

One ' indicates that the portion of that 75 km circle to'the east of the Grand Gulf had a substantially higher probability of dangerous tornado

. activity than :that to 'the west, thus more than doubling the likenood qf a tornado in. the area of' the ' reactor site. Another showed that the area of. greatest tornado danger is slowly rotating /to the west, and will-2 include'the Grand Gulf site throughout its projected operating life. : As it advances the likelihood of a tor-nado striking within-a.75 bn radius

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sis expected to increase' consider-ablyc and presumably so' is the-average :

ground area covered by'any' tornado.

This increase would also presumably increase the probability of. missiles,-

both-low-and high-trajectory, well beyond the MP&L and NRC staff calculations.

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Response

Unfortunately, Mr. Lawrence is incorrectly applying a statement in SER Section-3.5.3 on probability of missile ' strikes 'to tornado missiles.

The statement applies only to missiles that could be generated from the plant's main 'turbina, not e tornado.

In essence the HRC staff criteria its ' embodied in Regulatory Guide 'l.76, and the applicants' design, which

' conforms to that criteria, assume a probability of 1.0 for tornado missiles at Grand Gelf during its life. That' is, both the NRC staff. and the applicant' assume,that there will be a severe tornado at'.the site

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and the plant structure'ha been appropriately designed to withstand such a-tornaco.

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