ML20038A973
| ML20038A973 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/20/1981 |
| From: | Markee E Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20038A943 | List: |
| References | |
| NUDOCS 8111240545 | |
| Download: ML20038A973 (16) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING C0ARD In the Matter of
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Texas Utilities Generating Docket Nos. 50-445 Company, et al.
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50-446
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(Comanche Peak Steam Electric Station, Units 1 and 2)
AFFIDAVIT OF EARL H. MARKEE ON CONTENTION 9 I, Earl H. Markee, being duly sworn, depose and state:
Q1. By whom are you employed and describe the work you perform?
A1.
I ca employed by the U.S. Nuclear Regulatory Commission as a principal meteorologist in the Accident Evaluation Branch, Division of Systems Intecfation, Office of Nuclear Reactor Regulation. A copy of my statement of. professional qualifications is attached to this affidavit.
I am responsible for the evaluation of the meteoro-logical characteristics of nuclear teactor sites, the implications of the meteorological characteristics on safety requirements of nuclear facility design and the impacts of such facilites on the environment.
I supervised the NRC Staff's evaluation of the Comanche Peak meteorology and the Staff's short-tenn (accident) and long-tenn (routine) diffusion estimates.
Q2. Would you describe the scope of the subject matter addressed in your affidavit?
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A2.
I have been askad to determine if the facts presented in para-graphs 1, 2, 5, 6 and 7 of the Applicants' " Statement of liaterial Facts As To Which There Is No Genuine Issue Regarding Contention 9" (hereafter " Applicants' Statement of liaterial Facts") are correct and if the NRC Staff supports the Applicants' position.
I have also been asked to address 1) the Comanche Peak meteorological considerations as presented in 6 4.3.3.1 (" Local fieteorology")
of the Staff's " Final Environmental Statement related to the Operation of Comanche Peak Steam Electric Station, Units 1 and 2," (NUREG-0775), September 1981 and 69 2.3.2. and 2.3.3. of the Staff's " Safety Evaluation Report related to the operation of Comanche Peak Steam Electric Station, Units 1 and 2",
(NUREG-0797),
July 1981; 2) the calculations in FES Table 5.7, "Sumary of Atmos-pheric Dispersion Factors and Deposition Values for Maximum Site Boundary and Receptor Locations Near CPSES" and 3) the Staff's short-tem (accident) and long-term (routine) diffusion estimates and procedures presented in 9Q 2.3.4 and 2.3.5 of the SER.
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I supervised the preparation of tiie meteorology portions of FES 9 4.3.3 (99 4.3.3.1 and 4.3.3.2), Table 5.7 of the FES and I
'99 2.3.2, 2.3.3, 2.3.4 and 2.3.5 of the SER.
FES 99 4.3.3.1 i
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(and the introductory portion of Q 4.3), FES Table 5.7 and SER 69 2.3.2, 2.3.3, 2.3.4 and 2.3.5 are included as attachments l
to this affidavit and their contents are true and correct to the best of my knowledge and belief, with the following exception in SER 9 2.3.4.
The northwest sector site boundary "(2206 ft.)"
should be "(2206 m)."
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. Also, by way of explanation, the relative concentration estimates made by the Applicants in response to FSAR (Final Safety Analysis Report) Question 372.17 were essentially the same as those made by the Staff.
However, the Applicants utilized a model in their eval-uation which produced substantially higher relative concentratior.
estimates than the estimates used by the Staff.
Q3. Have you read those portions of statement of material facts accom-panying Applicants' Motion for Summary Disposition of Contention 9 relating to the issues you are addressing (paragraphs 1, 2, 5, 6 and 7) and do you concur with those portions of the statement of material facts?
A3.
Yes.
Q4. Wiiat method was used by the Staff to detennine atmospheric transport and diffusion estimates for radioactive releases to the atmosphere?
A4.
Based on the Staff's evaluation of the on-site meteorological data and the terrain at and surrouading the site, the Staff concluded 1) that the " constant near wind-direction model (Gaussian straight-line trajectory model) presented in Regulatory (Reg.) Guide 1.111, Rev.1 E was appropriate for use in detennining transport and diffusion esti-mates for routine radioactive releases to the atmosphere and 2) that the model presented in Reg. Guide 1.14N was appropriate for use in If See Reg. Guide 1.111, Rev.1 " Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light Water Reactors", July 1977.
2f See Reg. Guide 1.145, " Atmospheric Dispersion Models for Potential Accident Consequence Assessments At Nuclear Power Plants", August 1979.
determining transport and diffusion estimates for accidental radio-active releases to the atmosphere.
Q5.
In calculating the dispersion of gaseous radioactive effluents, were actual meteorological data employed?
A5.
" s.
The Staff considered on-site meteorlogical data for the four year period between May 1972 and May 1976.
These data, which are discussed in FES QS 4.3.3.1 and SER H 2.3.2 and 2.3.3, were input to the models mentioned above in order to estimate atmospheric dispersion of gaseous radioactive effluents.
Q6.
In detennining relative concentrations of radioactive effluents, did the NRC Staff consider various atmospheric transport mechanisms at and beyond the exclusion boundary?
A6. Yes. The nodels and procedures upon which the Staff's short-term (accident) and long-term (routine) diffusion estimates are based (see SER 66 2.3.4 and FES Table 5.7, respectively) include con-sideration of various transport mechanisms, such as transport by wind-flow, and dilution and ground deposition by atmospheric turbulence.
Q7. Were the dilution factors calculated using on-site meteorological data conservative?
A7. Comparison of me.teorological data from Fort Worth during the four years of on-site data collection (May 1972 to May 1976) to long-term averages (fifteen years) at Fort Worth indicates that the four yecrs
-u of on-site date may produce dilution factors which are conservative with respect to conditions over the sifetime of the plant. This is due to the fact that wind speeds were lighter during the four year period, thus indicating that average off-site concentrations will be lower _ over the long term. The influence of Squaw Creek Reservoir, when heated due to plant operation, will produce more unstable ai thus better abnospheric diffusion conditions resulting in lower concentrations than indicated by the on-site meteorological data used in both the Staff's and Applicants' diffusion estimates.
Q8. According to the procedures utilized by the NRC Staff and the Applicants in their evaluations, where will the maximum concentra-tions in the air of radionuclides be located?
AS.
Since the procedures specified in NRC Staff Reg. Guides 1.111 and 1.145 for this plant layout assume a ground level release of radionuclides with initial mixing due to turbulence generated by the plant structures, the maximum off-site concentration in the air at ground level is calculated to occur at the site boundary.
Al so, with this assumption, the calculated concentrations beyond the site boundary will be lower than those at the site boundary because the concentration from a ground level' release decreases with distance from the source. The assumption of a ground level release and building-caused mixing also tends t; L oduce higher ground level concentrations at all distances than for an elevated release. During the course of a long period of time it is expected that elevated releases will occur at least part of the time.
Therefore, the m
ground level release assumption provides conservative estimates of atmospheric radioactive effluent contentrations.
Q9.
Is the movement of storm-cloud formations in the Dallas-Fort Worth area part of the assessments of transport mechanisms for gaseous radioactive releases fran Comanche Peak?
A9. Yes. The predoainant movement of storm cloud formations in the Dallas-Fort Worth area is from the southwest to the northeast.
How-ever, radioactive effluent releases from Comanche Deak are not expected to occur only during storm conditions.
Such releases are expected to occur randomly, during the plant lifetime, and the on-site meteorological data for the four year period of record analyzed by the Staff and the Applicants is expected to provide a reasonable representation of the frequency cf the various meteorological conditions during this period, including storms.
Therefore, the short-term and long-term diffusion estimates based on this period of data record adequately account for the spectrum of meteorological conditions leading to transport and diffusion l
of radioactive releases, i
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I hereby certify that the above statements are true and correct to the best of my knowledge and bellaf.
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Earl H. Markee Subscribed and sworn to before me this DC f hday of November,1981 (n nr/c '7 7) (50 r Notary Public
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.J Hy Coacnission expires:
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/,/15 3 Attachments:
FES, S 4.3.3.1, Table 5.7 SER, $$ 2.3.2, 2.3.3, 2.3.4, and 2.3.5 i
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Professional Qualifications of Earl H. Markee I
IamPrincipalMeteorologistintheAccidentEhaluationBranch,Dihisionof Systems Integration, Office of Nuclear Reactor Regulation. My responsibilities includeehaluationsofthemeteorologicalcharacteristicsofreactorsitesand their implications with respect to safety requirements of nuclear facility design andtheimpactofthesefacilitiesontheenhironment.
I receihed a Bachelor of Arts degree in mathematics with a minor in physics in 1952 from Gettysburg College.
I attended Massachusetts Institute of Technology for one year to obtain the academic background for qualification
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as a meteorologist in the U. S. Air Force.
I was a wing weather officer with the U. S Air Force until 1956. After completion of my military obligation, I accepted a position as Research Meteorologist with the U. S. Weather Bureau on assignment to the U. S. Public HealthSerhiceinCincinnati, Ohio,whereIparticipated in urban air pollutionmeteorologyresearchandprohidedtechnicalassistancetostate
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and local gohernment agencies on air pollution.
In 1962, I accepted a position as Senior Research Meteorologist with the l
EnhironmentalSciencesSerhicesAdministrationonassignmenttotheU.S.
Atomic Energy Commission at the National Reactor Testing Station in Idaho.
i My duties included the performance of research in the field of atmospheric l
turbulenceanddiffusionandehaluationofthemeteorologicalaspectsof reactor experiments and siting of these experimental reactors.
I returned toschoolforoneyearandrecei0edaMasterofSciencedegreeinmeteorology fromtheUnihersityofUtah,SaltLakeCityin1969.
In 1970, I accepted a l
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- position as Meteorologist witn the U. S. Atomic Energy Commission. Subsequently, Iwaselehatedtothe_positionofPrincipalMeteorologist.
I am a professional member of the American Meteorological Society and the Air Pollution Control Association.
IhaYeauthoredeightresearchpapers which were published in technical journals and several other research reports.
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- Safety Evaluation Report re atec to t7e operation of Comanche Pea < Steam E ectric Station, Units 1 and 2 Docket Nos. 50-445 and 50-446 Texas Utilities Generating Company, et al.
~ U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation July 1981
2.3.2 Local Meteorology Mean monthly temperatures in the area of the proposed site range from about 45'F in January to about 81*F in July and August. Maximum monthly precipita-tion occurs in April and May, coinciding with maximum monthly averages of thunderstorm days.
Onsite data indicate a predominance of south to south-easterly winds occurring about 40% of the time, and a mean wind speed of 8.5 mph.
The " fastest mile" of wind in the site area is 69 mph and was recorded at Waco (about 60 mi southeast of the site) in June 1961.
During the period 1955 to 1977, 122 tornadoes were reported in the one-degree latitude-longitude square containing the site, resulting in a mean annual tornado frequency of about 4.5.
The computed recurrence interval for a tornado at the plant site is 316 years.* Annual snowfall in the area is not generally signifi-cant, ranging from 1.5 in. to 4.3 in, throughout the site area.
Freezing rain occurs occasionally during the winter and early spring, most often in January.
The requirements in 10 CFR Part 100.10 to co mider onsite meteorological conditions and those in GDC 2 to consider nat. ural phenomena have been met for the meteorological parameters.
2.3.3 Onsite Meteorological Measurements'Prol, ram An onsite meteorological measurements program was operated from May 1972 to May 1976, and accumulated data from instruments installed on a 200-ft tower situated about 1500 ft east of the reactor structures.
Instrumentation on the meteorology tcwer consists of wind speed and direction sensors at the 33-and 200-ft elevations, instroments to measure the vertical temperature gradients (AT) between 33 and 100 ft and between 33 and 200 ft, and dewpoint temperature sensors at 33 and 200 ft.
The applicant has submitted 4 years of hourly average onsite data on magnet.ic tape with joint wind speed, wind direction, and AT data recovery of about 95%.
- The recurrence interval is computed by the method presented in a paper by H.C.S. Thom, " Tornado Probabilities."
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Joint frequency distributions of wind speed and direction and atmospheric stability as daffned by vertical temperature gradients were also providad in a fora sinilar to that suggested in Regulatory Guide 1.23.
The meteorological measurce.:nts pro 0 ram met the position stated in Regulatory Guide 1.23 and.
provided adequate data to represent the onsite meteorological conditions as required in 10 CFR Part 100.10.
The onsito data provided an acceptable basis for making conservative estimates of atmosphoric diffusion for design-basis accidents and routine releases from the plant.
2.3.4 Short-Term (Accident) Diffusion Estimates The short-term (less than 30 days) accidental releases from butidings and vents were evaluated by the staff according to the guidance provided in Regulatory Guide 1.145. Wind direction and speed measured at the 33-ft level and AT between the 200- and 33-f t levels were used as input. A ground-level release with a building wake factor, cA, of 1600 m was assumed.
The maximum 2
sector (0.5 percentile) relative concentration (X/Q) for the O to 2 hr time period was calculated to be 1.5 x 10 4 sec/m8 in the northwest sector at the site boundary (2206 ft).
low population zone The maximum sector X/Q at the outer boundary /m of the 0to8hr,1.5x10-[LPZ)(6440m)wascalculatedtobe2.3x105 8
sec for for 8 to 24 hr, 6.0 x 10 e for 1 to 4 days and 1.6 x 10 s for 4 to 30 days, all in the northwest sector. The relative concentration estimates made by the applicant were essentially the same as those made by the staff.
The staff's calculated short-term X/Q values are used in the accident analyses presented in Chapter 15 of this report.
2.3.5 Long-Term (Routine) Diffusion Estimates Estimates of diffusion of routine releases resulting from normal plant operations were made according to the guidance in Regulatory Guide 1.111, Revision 1, for a constant mean wind direction model. A ground-level release with a building wake correction factor of 1600 se was assumed and open terrain recirculation licantcalculated(hesamenumericalvaluesforthe factors were used.
The app /Q values were used in evaluating the applicant's long-term diffusion.
The X proposed gaseous releases and compliance with 10 CFR Part 50, Appendix I design objectives discussed in Section 11.2 of this report.
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Final Environmental Statement related to the operation of Comanche Peak Steam Electric Station, Units 1 and 2 Docket Nos. 50-445 and 50-446 Texas Utilities Generating Company s
U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation September 1981 p.o y,
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1 4.3.3 L_.eorologyandAirQuality The regional climatology is described in Section 2.6 of the FES-CP. More recent data on the local meteorology and severe weather affecting the site are
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now available, and are sumarized below.
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4.3.3.1 Local Meteorology Onsite meteorological data for three additional years (May 1973 to May 1976) have been submitted by the applicant.
The temperature data indicate that the monthly mean temperature at the site ranges from 7*C in January to about 27*C in July and August.
This is consistent with what other local data sources indicate (as reported in the FES-CP). The absolute-minimum temperature for the four year period at the site was -14 C; the maximum was 38*C.
Wind data from the site for the four year period indicate a predominance of south to southeasterly winds (40% of the time).
The mean wind speed for the onsite data was 3.7 m/s, with 0.9% calms. A wind rose.of the onsite data is presented in Figure 4.4.
N NNW NNE NW NE WNW ENE
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Figure 4.4.
Comanche Peak Wind Rose, 15 May 1972 to 14 May 1976.
(Length of black bar indicates the percentage of time that the wind comes from the indicated direction.)
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Stable ate.cspheric conditions occurred over 75% of the four year period.
Unstable conditions accounted for less than 6% of the total valid hours reported.
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