ML20038A729
| ML20038A729 | |
| 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 8111160232 | |
| Download: ML20038A729 (12) | |
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. J DOCKETED UDiRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSITi NOV -5 21 :26 BEFORE THE ATOMIC SAFETY AND LICENSIh7FRGKRIEECRETt.r-v u r,s.. i EfiVK-In The Matter Of: )
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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322 OL
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(Shoreham Nuclear Power Station, )
Unit 1) 1
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AFFIDAVIT OF RICHARD BURTON HUBBARD CONCERNING S.O.C. CONTENTION 2 STATE OF CALIFORNIA )
~) _ ss.
COUNTY OF SANTA CLARA )
I. INTRODUCTION RICHARD B. HUBBARD, being of legal age and duly sworn, deposes and says as follows:
- 1. My name is Richard B. Hubbard. I am a technical con-
, sultant, and a founder (in 1976) and vice president of MHB Technical Associates. A statement of my professional quali-
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fications is included as Attachment A to my affidavit provided in S.O.C.'s response to LILCO's Motion for Summary Disposition 8111160232 811102 PDRADOCKOSOOO3gg G
of SOC Contention 1.
ac. r -'
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't II. PURPOSE
- 2. The purpose of this affidavit is to examine the ade-quacy of the consideration of the effects of releases through the liquid pathway in determining the Ingestion Pathway Emer-gency Planning Zone (EPZ) for the Shoreham facility.
III. MATERIAL FACTS AS TO WHICH THERE IS A GENUINE ISSUE
- 3. The NRC Policy Statement of October 23, 1979 (44 Fed.
Reg. 61123) has been superceded by the Commission's final rule on emergency planning. 45 Fed. Reg. 55402 (August 19, 1980).
LILCO has not performed any qualitative or quantitative as-sessments of the potential consequences of releases through the liquid pathway due to a core melt at Shoreham in deter-mining the adequacy of the Ingestion Pathway EPZ (LILCO Re-sponse 9 to SOC interrogatories on Contention 2, dated July 13, 1981).
- 4. The EPZ concept is discussed in the work of the NRC/
EPA Emergency Planning Task Force set out in " Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Nuclear Pow-er Plants," NUREG-0396, EPA 520/1-78-016, which was issued in V
December, 1978, three months prior to the TMI accident. See 10 CFR 5 50.45(s)(1) n.2, 45 Fed. Reg. at 55410. Emergency planning provisions for rel:ases through the liquid pathway are not specifically discussed in NUREG-0396 (p . I-4 4 to I- 5 2) .
Only releases to the " atmosphere" were discussed in NUREG-0396.
- 5. The Shoreham-specific Ingestion Pathway EPZ has not yet been developed by responsible loca1' authorities including Suffolk County, or by state authorities (New York, Connecticut and Rhode Island). Furthermore, neither the NRC or FEMA review of Shoreham emergency preparedness has been conducted at this time. Thus, the Shoreham-specific criteria, if any, for re-leases through the liquid pathway which will be utilized as the
... w basis of the combined applicant, state, and local plans has not yet been documented and, as a result, SOC answers to this motion are premature.
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- 6. In any melt-through resulting from a Class 9 accident at Shoreham, radioactive materials may leach into the ground-water and eventually migrate into the Long Island Sound. Models to assess the consequences of the possible contamination of water by radioactive releases on health, water supplies, costs, emer-gency plans, or interdiction techniques have not been adequate-ly addressed generically in the NRC's Reactor Safety Study (WASH-1400 or RSS) or specifically by LILCO for Shoreham in the FSAR. Little or no preparations have been made to inter-dict the flow of contaminated groundwater from beneath the re-actor containment buildings should a meltdown accident occur.
Omission of the liquid pathway releases from consideration in mitigating measurt.s included in the eventual Shoreham emer-gency plan appears to be a fundamental deficiency.
- 7. As set forth by LILCO in the FSAR, Long Island is un-derlain by soil deposits extending to depths ranging from a few tens of feet below sea level in northwestern Queens County to nearly 2,000 feet beneath the south of Suffolk County. In central Suffolk County, test wells encountered rock at more than 1,400 feet below sea level. Rock is estimated to be ap-proximately 1,000 feet below sea level at the Shoreham site.
The materials that overlie the bedrock and constitute'Long Is-land's groundwater reservoir are unconsolidated deposits of gravel, sand, silt, and clay.*
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~ 8 '.' The natural groundwater elevations measured across the area occupied by the Shoreham plant varied from 7 to 10 m1w, but because the site might be flooded during extremely severe storms, and since the geological formations are very permeable, the
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- FSAR, page 2.4-21.
. i design criteria for subsurface loadings included flooding con-siderations. The design of safety related structures has been reviewed to ensure they are capable of withstanding hydrostatic pressures and uplift due to a stillwater elevation of 26.0 m1w caused by inundation of the site by a storm surge. The natural groundwater elevations were temporarily lowered to various ele-vations during construction, as discussed in FSAR Section 2.5.4.6.
However, there are no plans for permanent dewatering during the life of the plant.* .
- 9. In the generic risk study cited in NUREG-0396, the RSS authors indicate that "the effects of contamination of water supplies has not been considered in detail"** and assume without a detailed analysis that streams and rivers would be contaminated for only a short time.II** The inadequate analysis of water con-tamination is a major flaw in the RSS presentation. The finan-cial costs and the societal dislocation due to major contamina-tion from strontium-90 and other isotopes appen.r to be potential-ly_y_ery large. They deserve assessment in tho Shoreham emergen-cy preparedness measures.
10. The RSS authors also assumed that partial core melt 4
always led to complete core melt. They further assumec, be-I cause of lack of direct experience, that once a core lost its
- FSAR, page 2.4-27.
- WASH-1400, Main Report, page 76.
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- WASH-1400, Main Report, page 134.
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initial configuration, it would be difficult to contain, i.e.,
even if the containment building above the core were not to fail, the core itself would probably melt through the concrete foundation. It is not clear that the core would necessarily follow this course. It may, instead, melt down but remain con-tained from below by the foundation due to adequate upward heat transfer. If the molten core has penetrated the containment building through the bottom, its interaction with the sur-rounding soil and water table was not well-defined.* Further-more, core melt-through was not evaluated with the same compre-hensiveness as were atmospheric releases because of the lat-ter's more immediately observable adverse effect.**
- 11. Finally, the RSS Teport indicates that airborne re-
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leases are much more significant contributors to the total risk than releases via the liquid pathway. The U.S. Department of Interior did not agree with the notion that the liquid path-way was significant as indicated in the RSS report and recom-mended additional study of the effects of variation of the hy-drogeological conditions from site to site. The NRC accepted i
- Battelle Columbus Laboratories is continuing the studies that they prepared for hSS in two main areas - release fractions and the physical processes of a core meltdown. Battelle is developing a new code, MARCH, to describe the thermal and mechanical aspects of a core melt. At this time, there ap-l pears to be substantial uncertainty in modeling the core melt penetration.
- Minutes of Meeting Five of the Risk Assessment Review Group, page 57.
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p the comment and instituted a research program at Snndia. A summary of the Sandia study results for U.S. reactor sites is included herein as Attachment A. Clearly, the potential radiation doses could be significant at distances of 50 miles and greater. However, the significance of the Sandia results for Shoreham specifically is not clear at this time since the NRC refused, during discovery, to provide SOC with the Shore-ham-specific results.*
IV. CONCLUSION .
- 12. Based on the foregoing, I conclude that releases for a core melt accident through the liquid pathway could con-stitute a major problem for Shoreham because of the site charac- ;
teristics set forth in the FSAR and summarized in the preceding.
The impact of a core-melt accident through the liquid pathway can conceivably be reduced at Shoreham if certain mitigating measures are er. ployed. Thus, the effects of interdiction, in-cluding emergency planning measures, both close to the site of the accident and farther along the pathways to the aquatic and human population, follcaing a study using the various Sandia models discussed herein or equivalent, should be conducted for the Shoreham Site.
- The proj ect coordinator of the Sandia Study, presently em-ployed at the Oak Ridge Laboratory, recently expressed ques-tions concerning changes made to the Study (see Attachments B and C).
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I have read the foregoing and swear that it is true and accurate to the best of my knowledge.
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RICHARD B. HUBBARD
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Subscribed and sworn to before me this day of September, 1981.
NOTARY PUBLIC L My commission expires Y I br
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. ,m . ,s v NUREC/CR-1596 SANDS 0-1669 AN
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The Consequences From Liquid Pathways After a Reactor Meltdown Accident S. J. Niemczyk (Project Coordinator)
K. C. Adams W. B. Murfin L T. Ritchie E. W. Eppel' J. D. Johnson The Dikewood Corporation Date Published: June 1981 Sandia National Laboratories Albuquerque, NM 87185 operated by
~ ~ ___. Sandia. Corporation for the U.S. Department of Energy N.
Prepared for Probabilistic Analysis Staff Office of Nuclear Regulatory Research f U.S. Nuclear Regulatory Commission Washington, DC 20555 Under Memorandum of Unders'anding DOE 40-550-75
/ NRC FIN No. A1,200
- Presently associated with the University of New Mexico.
3-4
Summary The potential radiological impact of a core-melt On tL basis of surface-water characteristics and xcident on the human population has been investi- the related populations-at-risk, sites range from those pled.In particular, the radiation dose received from having no significant exposure pathways to the hu-radioactivity which could reach the population via man population to sites having several potentially hquid pathy ays has been considered. important exposure pathways. Sites with surface wa.
Radioactivity could be released directly to the terbodies having rapid initial dilution and fast flush-hydrosphere af ter a core-melt accident as a result of ing and/or small potentially exposed human popula-rnelt-through of the containment basemat followed tions would tend to have little net human exposure by any of three processes: (1) leaching of the melt and, therefore, few adverse impacts; sites with water-debns; (2) escape of sumpwater through the hole bodies having slow dilution and flushing and large formed by the melt (or from passage out of the potentially-exposed populations would tend to have untaiment by an alter.. ate route); and (3) depressuri- much more human exposure and, therefore, more ntion of the containment atmospbre through the impacts. .,
rncit hole. The three types of releases would differ in order to bound the possible radiation doses to primarily in their rates, their magnitudes and their humans that could result from release to the hydro-radioactive compositions. sphere following basemat melt-through, calculations Both the containment atmosphere and the sump- were made under assumptions that tend to maximize water releases would occur relatively rapidly. How- population doses. Among the conservative assump-ever,most of the radionuclides present in these twc, tions made were the following:
releases in substantial quantities would be expected 1. Instantaneous release to groundwater of all to be rather short lived. Therefore, such releases radioactivity from both sumpwater and melt could have a significant impact at a specifM site only debris.
if the travel times of the important radionuclides to 2. One-day transit time from the release point to a the hurnan population were small. .. surface waterbody.
In contrast, leaching of radionuclides from the 3. No interdiction measures taken to prevent ex-nelt debris would be expected to occur relatively posure of humans.
dowly. Most of the long-lived isotopes would be The doses reported in the next two paragraphs are npected to be found primarily in the melt debris. believed to be upper bounds on exposures that would Consequently, even though this release occurred rel- occur under realistic conditions.
alively slowly, the impact could still be significant. At approximately 35%. of all the reactors consid-In contrast to the situation for releases to the ercu, the radiation dose to the entire human popula-atmosphere, accidents corresponding to the most tion as a result of releases to the hydrosphere via the probable RSS (Reactor Safety Study) meltdown cate- hole in the containment basemat formed by the melt gories would result in the largest releases to the is estimated to be relatively small (in general, much hydrosphere. Furthermore, substantial amounts of less than 108 to 105 person-rem). At another 25% of the radioactivity would generally be expected to be re- reactors, the resultant radiation dose is estimated to leased to the hydrosphere during any me:tJown be no more than 10' to 107 person-rem, whi!e at the accident involving comple:e melt-through of the remainmg 40%, the potential dose is no larger than containment basemat. 107 to 10a person-rem for such releases.
On the basis of subsurface hydrologies alone, sites ,
The somewhat artificial construct of an
- average range from those that essentially preclude any im- individual" was used to estimate the individual doses pacts to the human population via liquid pathways to which correspond to the population doses quoted those that can allow significant impacts to occur. Sites above. It is assumed that this individual is average with very slow groundwater movement and/or with with respect to usage habits for all the liquid path-long distances to nearby surface water tend to be in ways, that all of the individuals usage for the liquid the former category; sites with relatively rapid pathways involves the contaminated waterbody, and poundwater movement and with short distances to that the individual lives long enough to be exposed nearby surface water or wells usually are in the latter to all the dominant radionuclides. Under these condi-rategory. tions, the to an average individual over an entire 15
r lifetime as a result of the releases to the hydrosphere easier: the actions required at the source (via the melt hole)is estimated to be less than 1 rem at would usually be of a much smaller scale approximately 60% of all the reactors under discus- than most pathway procedures; sion. Furthermore, the total dose to such an individ-more effective: mitigating actions taken ual is estimated to be no more than I to 10 rem at close to the s'ource could have the another 20% of the reactors and no more than 100 rem potential of completely eliminating at the remaining 20% of the reactors. the radiation exposure of the human These percentages for both population and aver- population whereas pathway procedures age individual doses are generally thougl t to be would never be that effective, except conservative. However, they do not take into account . for isolated aquifers; the effect of various design features which might more permanent: some source procedures permit the early emergency of radioactivity into the would not need to be repeated on hydrosphere and, hence, result in a significant dose as regular basis as some pathway at some site possessing such features. Furthermore, procedures would need to be; and, they do not include the effects of direct entry of less expensive: the actions required could sumpwater into surface water. In addition, they do. be performed on a very localized scale not take into consideration the effects of certain instead of ovez a large part of the variations of both the surface water hydrologies and affected environment, the associated populations-at risk which could result in higher than expected doses. successful source interdiction could be expected to virtually eliminate the radiation dose received by Variations of conditions at actual sites could ea:lly the human population. At a majority of the sites, result in the doses being either higher or lower than there would be suffficient time to employ interdic-those obtained in this (generic) study by at least an order of magnitude. Likewise, reasonable variations tive procedures at the source. However, they would not necessarily always be possible due to both subsur-in certain portions of the modeling could result in face and engineered features existing at some sites y estimated doses which differed from those presented Furthermore, they would not be possible for direct here by an order of magnitude. Thus, the estimated releases of sumpwater into the accessible portions of doses and their related percentages of occurrence the environment.
have rather large uncer:afnties associated with them.
It is possible that the lack of knowledge of the The calculations indicate that if interdictive (miti- subsurface regions could hamper any source interdic-gating) actions are not taken, then the liquid path- tion procedures performed at some sites. For sites at l ways can perhaps contribute significantly to the risk t which relatively rapid action would be necessary, i
related to a core meltdown accident. Successfulinter- such ignorance could conceivably preclude or at least diction in the vicinity of the accident site (the radio- delay successful source interdiction.
active source) could prevent essentially all adverse For situations in which source interdictive proce-consequences resulting from the liquid pathways. dures were not either feasible or successful, then the Interdictive actions taken farther along the pathways radiation dose could be mitigated only by actions i
could only sometimes effectively prevent all the con-sequences.
taken along the exposure pathways. The effective-Interdictive procedures taken at the source are ness of such procedures would depend upon the characteristics of the affected waterbody(ies),
always preferable to procedures implemented along the exposure pathways. Relative to pathway proce-dures source procedures can usually be described as being the following:
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