ML20038A728
| ML20038A728 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 09/22/1981 |
| From: | Hubbard R MHB TECHNICAL ASSOCIATES, SHOREHAM OPPONENTS COALITION |
| To: | |
| Shared Package | |
| ML20038A726 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8111160229 | |
| Download: ML20038A728 (30) | |
Text
- ._ .__ - -
) . .
j UNITED STATES OF AMERICA DOCKETED USNRC l NUCLEAR REGULATORY COMMISSION l
l ?! m-5 ki:26 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD OrFjff,CF SECRET / oy Dr.nu !N3 & SELy" ~
22APCM In The Matter Of: )
) ,: .
LONG ISLAND LIGHTING COMPANY )
) Docket No.--50-322 OL (Shoreham Nuclear Power Station,)
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~-
AFFIDAVIT OF RICHARD ~ BURTON HUBBARD < ~
, ,_ . CONCERNING - - -
S.O.C. CONTENTION 1 STATE OF CALIFORNIA )
^
ss.
COUNTY OF SANTA CLA ~
i I. INTRODUCTION RICHARD B. HUBBARD, being of legal age and duly sworn, I
deposes and says as follows:
! 1. My name is Richard B. Hubbard. I am a technical con-i
- sultant, and a founder (in 1976) and vice president of MHB 1
) Technical Associates, a corporation engaged in the business of l
.nical consulting on energy' and environmental issues, I
l having its principal office at 1723 Hamilton Avenue, San Jose, C ' ' fo rn i a , 95125 I hold a B.S. in Electrical Engineering Shii382pogghhjjg 2
c G
. - , _ _ _ _ _ . _ . _ . _ . ~ . ~ . _ _ _ . . _ _ _ _ , _ _ _ . _ _ _ _ _ _ _ _ _ . _ . _ _ _ . , _ _ _ _ . _ _ _ _ _ . _ . . _ . _ _ . _ . _ . . .
+.
from the University of Arizona (1960) and an M.B.A. from the
'$nivhrsityofSantaClara(1969). I have sixteen years experi-ence in nuclear power plant electronics, instrumentation, and controls , including eleven years experience in responsible managerial positions in the Nuclear Instrumentation Department (1965-1971), Atomic Power Equipment Department (1971-1975) , and Nuclear Energy Control and Ins trumentation Department ~(1975-1976) of the General Electric Company. I am a member of the IEEE
~
Nuclear Power _Engineerin'g Standards Subcommittee responsible for the preparation of Quality Assurance standards for safety-related aspects of nuclear power facilities as an expert witness before the Nuclear Regulatory Commission Atomic Safety and Licensing Boards; before (and at the request of) the NRC's Advisory Com-mittee on Reactor S'a'!e~ guards; before the Joint Committee on Atomic Energy of the United States Congress; and before various s tate legislative and administrative bodies. I am thoroughly familiar with the safety analyses of the Shoreham license Appli-cant (Long Island Lighting Company or LILCO), the Nuclear Steam
- y. ..
Supply System supplier (General Electric), and the NRC Staf f (Staff) as a result of my service as a technical consultant to l
Suffolk County and the Shoreham Opponents Coalition (SOC),
,/ interveno.rs in the Shoreham -Operating License proceeding.
- 2. For the past five years, I, along with my co-founders of FMB Technical Associates, .have conducted numerous technical 2-
rN l
l and economic evaluations. of nuclear power plants. Examples of my recently co:apleted projects directly rc3ated to various aspects of the subject addressed in this af fidavit--nuclear plant risk assessment--are 'as follows:
- a. Critique of WASH-1400:
The Union of Concerned Scientis ts (UCS) prepared a critique of the U.S. Reactor Safety Study (WASH-1400). The UCS Critique was released in November, 1977, and was the culmination of over a year's effort by about a' do zen technical peopic . The UCS Critique was edited by MHB partners Gregory Minor and me , and I also contributed to a number of the chap te rs . Further, I presented sections of the summary of the UCS Critique to the NRC's Risk Assess-ment Review Group.
- b. Swedish Reactor Safety Study:
As a part of Sweden's re-evaluation of the role of nuclear power, MHB was contracted by the Swedish
~ ~~
Energy Commission to conduct a $200,000 risk study of a Swedish nuclear plant (Barseb3ck). This study
'c=- was completed in January of 1978, and the results were presented by me and others to the Swedish Par-liament in April, 1978. Subsequently, I conducted
' a follow-up s tudy for the Swedish Nuclear Power In sp e c to ra t e . The s tudy add i c s ced uncertainties in risk assessment (follow-up to the NRC's Risk Assess-ment Review Croup Report).
l
.i
- c. Italian Reactor Safety Study:
In 1980, MHB completed a site-specific risk assessment for reactor accidents at an Italian reactor site (Caorso) utilizing the h' ASH-1400 techniques. Accident consequences were calcu-lated with a modified and updated version of the WASH-1400 consequence model--the CRAC Code. Pre-liminary results of the MHB study were presented by me to the Italian government at a meeting in Venice on January 25 through 27, 1980. .
The final report was presented by Dale Bridenbaugh and me in a forum in Rome on May 16 and 17,' 1980.
- 3. I have also provided technical consultation to the West German government concerning risk assessments of nuclear plants. My experience and qualifications are further described in Attachment A, which is appended to this affidavit.
II. PURPOSE 4 The purpose of this affidavit is to examine the adequacy of the Eme rgency Planning Zones (EPZ) for Shoreham. Sp eci fically ,
this affidavit will address whether the State, local, and Appli-cant emergency plans have adequately addressed the following:
- a. Does a 10-mile (radius) EPZ Plume Exposure pathway provide adequate consideration of the following local conditions : denography, meteor-ology, topography, land use characteristics, access routes, local jurisdictional boundaries and release time ch'aracteris tics ?
1 I
l b.
Does a 50-mile fradius) EPZ Ingestion Pathway l following l
j provide adequate consideration of the local conditions: demography, meteorology, topog-and time of year of raphy, land characte ris tics ,
release?
III . MATERI AL FACTS AS TO WHICH THERE IS A GENUINE ISSUE
- 5. The NRC Policy Sta ement of October 23, 1979 (44 Fed.
Re g .
61123) has been superceded by the Commission's final rule 45 Fed. Reg. 55402 ( Augus t 19, 1980).
on emergency planning.
LILCO has not performed any generic or site-specific studies to confirm the conclusions reached in the rulemaking concerning EPZ k
I bo undarie s (LILCO Response 8 to SOC interrogatories on Contention 1 dated July 13, 1981)i
- 6. The EP2 concept is discussed in the work of the NRC/ EPA out in " Planning Basis for the Emergency Planning Task Force set i Radiological Emergency Development of State and Local Government Response Plans in Support of Light Water Nuclear Power Plants," r NUREG-0396, EeA 520/1-78-016 which was issued in December, 1978, three months prior to the TMI accident. See 10 CFR S 50.4 5(s)(1) n.1, 45 Fed. Reg. at 55410.
- 7. In its final emergency planning rule, the NRC stated in part that:
" Generally, the plume exposure pathway EPZ for nuclear power reactors shall consist of an area about 10 miles (18
km) in radius and the ingestion pathway EPZ shall consist of an area about 50 miles (80 km) in radius. The exact size and configuration of the EPZ's for a particular nuclear power reactor shall be' determined in relation to local emer-gency response needs and capabilities as they are affected by such conditions as demography, topography, land characteris-tics access routes, and j urisdictional boundaries. The size of the EPZs also may be determined on a case-by-case basis for gas-cooled nuclear reactors and for reactors with an authorized power level less than 250 MW thermal. _
The plans for the inges tion pathway EPZ shall focus on such actions as are appropriate to protect the food ingestion pathway." (45 Fed. Reg.
.at 55410)
- 8. The Shoreham-specific EPZ's have not yet been developed by responsible local authorities including Suffolk County, or by s tate authorities (Ney' York, Connecticut and Rhode Island) .
Furthermore, neither the NRC or FEMA review of Shoreham emer-gency preparedness has been conducted at this time. Thus, the Shoreham-specific distance criteria which will be utilized as the basis of the combined applicant, state, and local plans has not y_e_t been documented and, as a result, SOC answers to this motion are premature.
, 9. The President's Commission on the Accident at Three Mile Island (Kemeny Commission)* noted that a central concept in the
/
then current siting policy of the NRC is that reactors should be located in a " low population zone" (LPZ), an area around the
- Kemeny, John, et al, Report of the President's Commission on the Accident at Three Mile Island, pages 10-17 l
6-
I plant in which appropriate protective action cotoa be taken for the residents in the event of an ec=toent. However, Kemety concluded that the concept ie implemented in a s tro. ge , unnatuI al, and round-about manner. To determine the -ize of the LPZ, the utility calculates the amount of radiation released into the containment in a very serious hypothetical accident but assumes no failure of the containment. Using geographical and meteoro-logical cata, the utility then calcula tes that arer within which an individual would receive 25,000 millirems or more to the whole body, during the entire course of the accident. This area is LPZ. The 25,000-millirem stanco. - *- an. cxtremely large dose ,
many times more serious than that received by any individual during the entire TMI accident.
- 10. TheKemenybommissionbelievedthat the LPZ approach has serious shortcomings. First, because of the extremely large dose by which its size is determined, the LPZs for many nuclear power plants are relatively small areas, two miles in the case,of TMI as_well as Shoreham.
Second, if an accident as serious as the one used to calculate the LPZ were actually to occur, it is evi-dent that many people living outside the LPZ would receive smaller, but s till massive doses of radiation. Third, the TMI accident
. Sows that the LPZ has little relevance to the protection of the niic--the NRC itself was considerin g evacua tion dis tances as as 20 miles, even though the accident was far less serious 7
than those postulated during siting. Kemeny therefore con-cluded that the entire concept is flawed and recommended that the LPZ concept De abandoned in siting and in emergency planning.
As an alternative, Kemeny proposed and SOC concurs that a vari-ety of possible accidents should be considered during siting, particularly " smaller" accidents which have a higher probability of occurring. For each such accident, one should calculate on a site-specific basis probabic levels of radiation releases at a variety of distances to decide the kinds of protective action that are necessary and feasible. Such protective actions may range from evacuation of an area around the plant , to the dis-tribution of potassium iodide to pro tect the thyroid gland from radioactive iodine, to a simple instruction to people several niles from the plant-te stay indoors for a specified period of time. Only such a site-specific analysis can predict the true consequences of a radiological accident.
- 11. As set forth in NUREG-0396 (see page I-36), the NRC's Reactor Safety Study (WASH-1400 or RSS) developed the mathe-matical techniques and data base to provide an understanding of the generic relationship between " Class 9 accidents" and emergency clanning needs. To obtain an appreciation for the distances to which or areas within which emergency planning might be required, a perspective on the relative probabilities of certain critical doses as a function o f dis tance from the I
power plant for these accidents is needed.
curves has been prepared for all A set of such categories (NUREG-0396, of the RSS accident release Figure I-11).
both Pressurized and Boiling W These curves include dents.
Doses are given for the critiater Reactor (PWR 6 -
emergency planners should eb cal values for which concerned.
whole body doses correspond t One and five rem 50 rem whole body correspo d ~o the lower range of; the PAGs illnesses start n s to the dosage' at whichryea l to occur; and 200 rem wh o l at which significant early inj e body is the dose be seen from Figure I-31 uries start to occur. As can but the probability of lar core melt accidents can be s e ve re ,
about ge doses drops 15 miles from the reactor. substantially at ence doses of 5, 25, ~^ aid 300 For r the thyroid, the refer-and upper PAG 1evels, and the em, which correspond ower to the l siting purposes are presented iguideline exposure used for n Figure I-13 12 Given a core melt accident at a generic about a 70% chance ng ofthe exceedi site, there is chance at PAC doses at 5 miles, and a 30% chanceat 2 miles, a 40%
pl an t .
Tha t is, miles is 1.5 x 10-5the probability of exceedi10 miles fro ng PAG doses per reactor year at 10 reactor year) (one
' "no presen tfrom the Reactor Safety St d chance in 50,000 per u y analysis.
Se too basis for judging whether th The NRC too low. e probabilities The error band for the probabili t es i
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Figure 111. ConditionalProbability of Exceeding Whole Body Dose Versus Distance. Probabilities are Conditional on a Core Melt Accident (5 x 10-5),
Whole body dose calculated includes: external dose to the whole body due to the
,- passing cloud, exposure to radionuclides on ground, and the dose to the whole body frorii inhaled radionuclides. .
Dose calculations assumed no protective actions taken, and straight line plume trajectory.
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Figure I 13. Conditional Probability of Exceeding Thyroid Doses Versus Distance. Probabilities are Conditional on a Core Melt Accident (5 x 10-5),
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Thyroid dose calculated includes: external dose to the thyroid due to the passing cloud, exposure to radionuclides on ground, and the dose to the thyroid from inhaled radionuclides.
Dose calculations assumed no protective actions taken, and straight line trajectory.
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Figure I 14. Conditional Probability of Exceeding Thyroid Dose to an Infant Versus Distance.
Probabilities are Conditional on -a Core Melt Accident (5 x 10-5),
Thyroid dose calculated is due solely to radionuclide ingestion through the milk consumption pathway.
Dose calculations assumed no protective actions taken, and straight line trajectory.
. {
of some of the event sequences could be as great as a factor of 100" (NUREG-0490, page 7-10) . Thus, there are substantial uncertainties in the preceding analysis.
- 13. Potential ingestion doses to the thyroid (through the cow / milk pathway) from core melt accidents at a generic site are given in NUREG-0396, Figure I-14. The distance for which emergency planning is needed is not easily de~termined from the information given in the figure. It'is evident that doses can
~_ :- ;; .-_
potentially be quite high out to cons iderabl~e' ' dis tance's .~ ~
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i 14. An accident consequence model was developed for the RSS study which utilized a progression of mathematical and statistical models. These models describe the release of radionuclides from the* reactor containment, calculate the move-ment of the material in the areas surrounding the power plant i and determine the interaction with and influence upon man and his environment. The Calculations of Reactor Accident Conse-quences (CRAC) computer model was developed to perform these
- tasks in a manner which would realistically predict the conse-quences from pos tualted accidents. The models were chosen with the objective of quantifying societal risk and not the strictly I
conserva tive approaches norma 11; iaken in the regulatory process.
) 15. The consequences from the release of a specific amount
)
of radioactive material can range from slight to catas trophic, depending upon the following ke'y elements :
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'.,.. - , ,-,-,,- _ _ --,,-- ._,. _ - _ -, - . -.-. -.--,-,-,- - - ,- - .. - - -- -. -, , . ~ . - - . . - - , - -
- a. The amount of radioactive material released l to the atmosphere,
- b. The number of people exposed to the contami-i nation, and i
- c. The meteorological conditions follwoing the rele as e .
i CRAC calculates sets of consequences from all of the combinations of release magnitudes, population groupings and samplings of actual neteorological conditions.* Each consequence set has a probability of occurrence associated with it which is defined by the proba-bility of the release magnitude. times the probability of the popu-i lation group times the probability of the meteorological condition.
With all combinations generated, a distribution function for a In this consequence is formed with the associated s tatistics.
manner a full range 'of~results is obtained with associated proba-I bilities.
1
'_._____ _ _. - 16 . The beginning point of the consequence calculation is the specification of the postulated accident in terms of the f
q'dantity of radioactive material that could be released to the environment, the amount of energy associated with the release,
/
the duration of the release , the time of release after accident initiation, the warning time for evacuation, the elevation of f
the release and the probability of the accident occurrence.
- Appendix VI of the RSS describes the " Calculations of Reactor Accident Consequences" which is the basis for this computer code. All RSS references unless otherwise specified are to RSS, Appenaix VI, Calculations of Reactor Accident Consequences.
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C The description of the range of radioactive releases from a potential accident,arecdescribed in RSS. Data for five (5) potential BWR release categories ~ and nine (9) potential PWR
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release categories are described. The release data represents the basic input to the consequence model. A schematic block diagram of the RSS consequence model is shown in Figure 16.
Each block in Figure 16 represents a set of factors , a trans fer function that is ' utilized in the calculation of the consequences ~
'-'of a radiation release. h w. .- --
FIGURE 16
-BLOCK DIAGRAM - CONSEQUENCE MODEL YEATHER
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DATA ' "~
Y DESCRIPT!GN gggppggc
. _ . _ _ _ -OF PAD 10 ACTIVE + DISPERSIDri FILEASE
, EEALTH EFFECTS p
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- 00st?'ETRY + POPULATION -
g e PROPERTY I
'0t# AGE
> / GROUC EVACUATION 3/
- CONT /#.!NATICM i
r i
- 17. The presently available reactor accident consequence models are derivatives of the original CRAC model developed for the RSS and made available through the National Energy Sof tware Center in 1977. A group at the Sandia Laboratories has developed CRAC2 for the NRC to examine various types of accidents involving nuclear materials, in addition to reactor accidents. SAI-Chicago has developed NUCRAC to study reactor safeguards and the conse-
. quences of the diversion!of nuclear materials. A rather sophisti-cated reactor accident model created by Pickard, Lowe and Garrick (PLG) in Washington, -D. C. , is known as the CRACIT- code. This particular code was developed as part of a risk assessment pro-gram involving Indian Point and Zion reactor sites. Each of these models treat releases of radioactivity and its dispersal from a site, the distribution *of population about a site, possible res-ponses to radioactive releases, dosimetry and radiation dose
~
effects, and the presentation of calculated' consequences, in a fundamentally similar manner. The major difference between these 1
models, apparently, is the relative sophistication of the treat-ment of these various model components.
- 18. The CRACIT model employs separate population / evacuation and dispersion grids. These features enable a more realistic l
reactor accident simulation to ,bc performed for a specific site.
i Evacuation routes can be accommodated and hourly wind direction changes (varying plume traj ectory) are incorporated. These I
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features allow the simulation of more realistic intersections between the population and the' radioactive plume. This could
~
be important for a~ site such as Shoreham with a coastal loca-tion near a coastal highway. The specific model which LILCO will utilize for their accident consequence assessment was not provided to SOC (see LILCO Motion For Summary Disposition 'of
~
Contention 1, page 5). -
~ -
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I19. The NRC, -through a contract with Sandia;-has 'run the
~
CRAC Code for a number of U.S. reactor sites including Shoreham n
(M. Taylor presentation at NRC's Safety Goal Workshop in July, 1981) with site-specific data. The consequences varied by a factor of approximately three decades as shown on the attached thr'e e figures present3d by Taylor. The NRC refused to provide SOC with the Shoreham-specific results of the Sandia CRAC Code
~
assessment.
- 20. Site-specific consequence analyses as recommended herein have been conducted for the California nuclear plants.
The California results confirm that the 10 and 50-mile EPZ's are not appropriately conservative. Following the March 28, 1979 accident at Three Mile Island, Governor Brown formed a task force to study California's emergency preparedness for -
nuclear power plant accidents.' One of the task forces 's princi-ple recommendations was that site-specific analyses be conducted b
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7 of the consequences of hypothetical serious nuclear power plant acciden ts . As required by subsequent legislation, a site-specific study of this nature has been conducted by the S' tate Office of Emergency Services' (OES). Based on the results of this Study, the OES has recommended Emergency Planning Zones (EPA's) for each of the nuclear power plant sites.. The rationale behind the selection of these EPZ's is presented in the following portion of this
~~~
j a f fidavit . _ f
- 21. As noted in the OES report, the selection of the ten-mile radius (for the plume exposure EPZ) by the NRC/ FEMA was based l 1
primarily on the following considerations: . a. projected doses from the traditional design basis accid.ents
. would not exceed Protection Action Guide levels outside the zone;
- b. projected doses from most core melt sequences would not exceed Protective Action Guide levels outside the zone;
- c. for the worst core melt sequences, immediate life threatening doses would generally not occur outside the zone; -
- d. detailed planning within 10 miles would pro-vide a substantial base for expansion of response efforts in the event that this proved necessary.
- 22. Based upon the site-specific results of the State's study, the OES analyzed the impact of a similar set of hypothe-sized accidents on the areas about each of the California sites.
~
y EPZ's were developed upon this site-specific basis rather than the generic basis used by the'NRC/ FEMA. Based upon the ' site-specific results, the OES concluded EPZ's should be extended beyond the basic 10-mile NRC/ FEMA requirements. The outer boundaries of the extended EPZ's presented above for the three large reactor sites in the State with ratings comparable to Shoreham vary in distance ~from about 18 to 35 miles from the
^-
reactors , as shown in Table" 22.
~
~ um: nn- . n. u TABLE 22 ~
DOWNWIND DISTANCES FROM REACTOR SITE WHERE PROBABILITY OF EXCEEDING SPECIFIED WHOLEBODY DOSE IS 0.01 (1%} FOR CORE-MELT ACCIDENTS
- Major n a nment Penetration Melt-Through Leaks Failure Reactor 0.5 rem 25 rem 200 rem Diablo Canyon 4.5 miles 20 miles 26 miles Rancho Seco 5 miles 18 miles 28 miles San Onofre 1 8.5 miles 13 miles 18 miles San Onofre 2, 3 4 miles 18 miles 35 miles i
- Cunningham, Alex, Emergency Planning Zones for Serious Nuclear Power Plant Accidents, California OES, November, 1980, Table 4.1. ,
i L
- 23. The decision to extend the EPZ boundaries beyond the zone dimensions required by NRC/ FEMA was based upon a disagree-ment.in the application of the ~(c) and (d) considerations above that were used by the NRC/ FEMA in their election of the basic 10 miles radius for the EPZ. As indicated by the dose-distance relationships developed during the study, the results of the j State 's study of the California site-specific consequences showed
, basic agreement with observations (a) and (b) of the NRC/ FEMA selection consideration presented above. That is, the State's 1 results indicated there was at leas t a 99.9% probability that the projected doses from the most probably (melt-through) acci-dent sequences would not be expected to exceed Protective Action Guide (PAG) levels beyond a basic 10-mile EPZ boundary. In this regard,' the State's -results supported the first two of the NRC/ 4 FEMA observations. 24 However, the OES concluded that prudence dictates that the EPZ's be extended so that advance planning can be performed to aid in resolving the potential problems associated with the
- more severe types of accidents, the penetration leakage and i .
major containment failure classifications. The very severe accidents in these classifications make up about 10 to 20% of i
/ all the hypo thesized core -meltdown accidents , even for relatively new reactor designs. It did not seem prudent to restrict plan-ning attention to responding only to the potential for incurring I
7 ' y immediate life threatening radiation doses for such severe acci-dents. Thus, the~' extended zones' were selected so that the po-tential for incurring health ' impacting doses was reduced not only for early fatalities ~,.but also for early injuries and de-layed cancer effects as well.
- 25. A direct comparison of NEC/ FEMA generic estimates of
-dose-distance-probability relationships with the State's site-t ,
specific results is presented in OES Figure 4-13. The results ' of the two different sets of CRAC calculations made by the NRC and the State show basic similarities, but also some substantial differences. The NRC results appear to have been smoothed to the State's data represents follow the general outlines of their CRAC results, whi1Mdirect, unmodified output from CRAC (for the Rancho Seco site in the particular example shown) . The results presented in the figure (for both the NRC's and the States 's data) represent the com- __ __,__. _bined cutput of the codes for all accident classifications (major containment failure, penetration leakage, and melt-through cate-gor _ies ) . The results have been combined to reflect the appro-priate weighting factors of the relative probabilities of recei-7 ving accidental doses from each and all of the accident classifi-cations.* f ,4
- 26. As the NRC observed in NUREG-0396, there is about a 30%
chance of exceeding the (1 rem) PAC level at the basic 10 miles plume exposure EPZ boundary,' according to their own data. The Cunningham, Alex, page 66.
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DISTANCE (111 LES ) 9 Figure 4-13 WHOLE BODY DOSE ESTIliATES STATE STUDY NUREG - 0396 s 1 !
. , . . _ , . . . . _ - . , - - . _ . _ , . . _ _ ~ _ _ _ . _ _ . . . . _ _ _ _ _ . . , _ _ , . _ . _ _ _ _ . _ _ _ _ _ _ . . . _ _ _ , _ _ _ _ _ _ _ _ _ _ _ _ . . , . _ _ , _ _ _ . _ __ _ _ _ _
c State's date would indicate a somewhat lower probability of about 20% at the same' distance. At the same 10 miles' distance, the NRC results suggest a probability of about 10% of exceeding a 50 rem dose, and about a 3% probability of exceeding 200 rem. Based upon the NRC's and the State's data, adopting extended EPZ boundaries with distances from the reactor of about 18 to 35 miles would reduce the probability of early fatalities. by a factor of 0.1 or more (to a probability of about 0.1% of exceeding 200; rem); , the probability of early injuries (at 25 rem) would be reduced by a factor of about 0.5 to 0.25 (to a probability of about 7 to 9%); and the probability of exceeding PAG doses would be r-duced about a factor of from 0.5 to 0.8 (to a probability of about 15%). Thus, extending the EPZ boundaries results in a prudent reduction in the probabilities of earI ^ health effects and a substantial reduction
~
in the probability of delayed he'alth e ffects (associated with 0.5 to 1 rem PAG dose limits). I
- 27. Site-specific modeling of the impact of population on Class 9 accident consequences has not been conducted by LILC0 or reviewed by the NRC. The NRC has reviewed only the population in the low population zone as related to emergency planning.* The Shoreham site has exceptionally Ligh projected population. In the year 2000 it will h.ve a population within 50 miles that puts it ,
l in the top 5% of all reactors; within 10 miles it is in the top l 20% (see Figures III and IV from SOC's response to LILCO l interrogatories).
- NUREG-0420, page 2-6.
COMPARISON OF POPULATION LEVELS WITilIN 50 MILES OF REACTOR SITES-ii ili aE M W E .3 % l W W I I .si. [ @ ' T [,. ,,, j 4_
, I l i .. I ij s ea. Il Pcrut at iO% mit w'% t %0 wst t i
- At l11 hwChi a h *L a%18af 81 Somint tiea2:Kg u t 6% PD*g L a t some
- 7 ?Cc too ,
ut Dea % POPut alsO% = 1 ST OT we%euem 9 LruL a1aO%
- 11 NT ,
enAnswww P & u6afiO% *72 BC F
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J 1 i d I ! ! .E.U . 11 J'al ?:1. 1.1_.lJJ L11,'!C ;111.JI t L s lu lli 11 J1L ci:1.111. J _L .Jil,:'!I t ! ! . J.J 11.!!j.L 9 81 0 C", e 1
- 7 e6 1 2 8 5e , M 4? w so PD sc so a se et nens nn CUY ULATIVE PI RC iT A G E Q F l'L/ P. T S WIT H $ U R A C U P CitJ G P Cd u LA T iv '.'S E O U A t O. O R t t 5 5 T H A *J. T ai[ (PJDl" Al t D V A t V[
Source: NuREG-0348
i t ou tu; i<. COMPARISON OF POPULATION WIT!!IN TEN MILES OF REACTOR SITES
%iiii, i l 4 allt iili i l ll!l esoa"blA Nh M h"
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18'i EH'"' 353 4 II Iiii H33 5 4 I i 'I M ]
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D').:' ?. ?.e.L * !!!)"112 U.1D1.1.1 110 BUiL wil L W . l l1.l. L ) L.1L! L12 ne ne na a r e v e s e m % e n o 01 cmetc2 66 1 2 6 se C u rA UL Aliv t r f R C C N T A G E THEtr.DrCAff0 Of Pi A f.15 V.IT H SUR RO'UNDING vaiUf FCPUL AllOrds t OU AL 10. OF Lt 551H At. Source: NUREC-0348
- 28. Shoreham is located on the north shore of Long Island in a region of unique demographic snd land characteristics. The center of downtown Riverhead 4.s approximately 10 miles from the plant.(thus, the 10-mile EPZ would cut through Riverhead) . Im-mediately to the east of Riverhead, the island is divided into two forks : the north fork extends approximately 30 miles east of Riverhead and the south fork approximately 50 miles to the east.
These two forks are characterized by a number of unique factors, two of which have particular significance for emergency planning. The firs t of these is the area's poor and limited road network. The north fork has two cast-west arteries, both of which are one lane in each direction (except for a small segment of the northernly most artery). The south fork has but a single east-west artery, virtually all of whidh'is one lane in each direction. Each of
~
these three arteries passes within 10 miles of the Shoreham plant. Thus, there is no means of egress from east of the plant except by passing within 10 miles of the plant. The second critical factor is the dramatic increase in population during the month of May through Septembe r. According to the Nassau-Suffolk Regional Planning Board, the population in the five towns cast of Shoreham increases from about 100,000 year-round residents to more than 250,000 during the May through September period. The area is poorly served by public transportation, which is the method of transportation relied on by much of the seasonal population.
( Massive traffic jams on both forks are routine occurrerces during the tourist season.
- 29. Thus, I conclude that there is substantial precedent for the prudence of conducting a Shoreham-specific consequence analysis to develop the appropriate emergency planning EPZ's. Further, I believe that such an analysis would indicate that the Plume Exposure EPZ of 10 miles and an Ingestion EPZ of 50 miles is not conservatve and does not result in adequate protection of the public health and s a fety.
IV. CONCLUSION
- 30. Based on the foregoing, I also conclude that State and local Emergency Plansy4 including the selection of EPZ's has not yet been developed. Further, I conclude that the generic 10-mile (radius) EPZ Plume Exposure pathway has not been demonstrating as providing adequate consideration of the following Shoreham site-specific conditions: demography, meteorology, topography, land use characterisitics, access routes, local juridictional bounda-ries and release time characteristics. Finally, I conclude that the generic 50-mile (radius) EPZ Ingestion Pathway has not been demons trated as providing adequate consideration of the following Shoreham site-specific conditions : demography, meteorology, topc-graphy, land characteristics, and time of year of release.
-im, y - , - - , ~ . . , - . ,.-. - - , . . ,.
I have read the foregoing and swear that it is true and accurate to the best of my knowledge.
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S / Y Y, RICIIARD D. HUBBARD Subscribed and sworn to before me this 2V day of September, 1981. e g
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OFFICIAL SEAL
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W ?.4 . JAMES F LEHMAN
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