ML20053B837
| ML20053B837 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 05/21/1982 |
| From: | Blum J, Holt J, Potterfield A POTTERFIELD, A., PUBLIC INTEREST RESEARCH GROUP, NEW YORK, UNION OF CONCERNED SCIENTISTS |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| ISSUANCES-SP, NUDOCS 8206010272 | |
| Download: ML20053B837 (9) | |
Text
a REMTED CORRESTmWCW UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD TJ -::-,
In the Matter of
)
)
CONSOLIDATED EDIS0N COMPANY OF NEW YORK
)
Docket Nos. 50-247 SP (Indian Point Unit 2)
)
50-286 SP
)
POWER AUTHORITY OF THE STATE OF NEW YORK
)
(Indian Point Unit 3)
)
May 21, 1982 UCS/NYPIRG'S ANSWERS 'IO ITRC STTJT'S INTERPOGA'IORIES The Union of Concerned Scientists and the New York Public Interest Research Group, Inc. answer the NRC Staff's interrogatories as follows:
1.
Identify all documentary or other material that you intend to use during this proceeding to support Contentions 3.1, 3.2, 3.3, 3.6, 4.1, 4.2, and 4.4, 4.5 and 4.6 and that you may offer as exhibits on these contentions or refer to during your cross-examination of witnesses presented by Consoli-dated Edison Company of New York Inc., Power Authority of the State of New York, or the NRC Staff.
NUREG-0396 NUREG-0654, Rev. 1 N'L91-1400, including all Appendices NUREG/CR-1311 NUREG/CR-0603 NUREG-0348 NUREG/CR-0388 Emer e cv Planning Zones for Serious Nuclear Power Plant Accidents State of California Office of Emrgency Services, Alex R.
Cunningham, Director, Novenber 1980.
Regulatory Guide 1.101, Rev.2 Regulatory Guide 1.97, Rev.2 Regulatory Gaide 1.47 NUREG-0742 NUREG/CR-0400
" Evacuation frcm a Nuclear Technological Disaster" Geog. Review Vol. 71, no.1, January 1981, D nald Ziegler, Stanley D. Brunn, and James H. Johnson, Jr.
G E:Tergency Planning in the DII Accident, prepared for FEMA by Human Sciences Research, Inc., 1980.
M)54,3 82060 1 0 ADA
, Loli
. Evacuation Risks-An Evaluation, Joseph M. Hans and Thcmas C. Sell, U.S. Envirm7tal Protection Agency,1974.
SECY-80-552, "7he Use of Prnhahalistic Risk Assessment iri the Licensing Process," December 30, 1980.
IIIA-ENG-7775, Post-Accident Filtration as a Means of Lmoroving Containment Effectiveness, B. Gosset, et. al., Decettber,1977, UCLA School of Engineering and Applied Science NUREG-0850 Doses Pemived While Crossing a Plume of Radioactive Material Peleased During an Accident at a Nuclear Power Plant, R.I.
Scherpelz and A.E. Desrosiers, Pacific Northwest Laboratory, October 1981 (PNL-SA-9383)
SAND 78-009, A Model of Public Evacuation for At:csuheric Radioloc-ical Releases, D.C. Aldrich, et. al., Sandia Laboratories, June, 1978.
NUREG/CR-1433 NUREG-0606 All other references are in res pnses to interrogatories.
- 2. a) Upon what person or persons do you rely to substantiate in whole or in part your case on Contentions 3.1, 3.2, 3.3, 3.6, 4.1, 4.2 and 4.4, 4.5 and 4.67 b) Provide the addresses and education and professional qualifications of any persons naned in your response to 2a. above.
c) Identify which of the above persons or any other persons you may call as witnesses on the contentions referen d in 2a. above.
a) IIS/NYPIBG relies on those persons authoring the above-listed docu:ents. In addition, UCS/NYPIBG relies on Dr. Jan Beyea, Brian Palenik, and Kai Erikson, b) This material is provided for Dr. Jan Beyea, Brian Palenik, and Kai Erikson in Appendices A and B.
Additionally, material which these individuals may rely on to substantiate UCS/NYPIRG contentions has been included in these appendices, c) Dr. Jan Beyea, Brian Palenik and Kai Er1kscn...The.namesfoftany cther witnesses obtained after this date will be subritted as they are determined.
3.
Identify the extent to which the EPZ should be expanded giving your reasons 'for such an expansion.
UCS/NYPIRG has not at present calculated the area for which the Plume Exposure Pathway EPZ should be expanded to provide adequate pro-tection for the public health and safety. In general, a satisfactory methodology _for doing so is set forth in " Emergency Plann1ng Zones for Serious Nuclear Power Plant Accidents", State of California Office of Emergency Services, Alex R. Cunningham,' Director, November 1980. That nethodology can be successfully applied with the proviso that the prob-abilities calculated for different types of accidents and releases are unreliable. The report nethodology does not limit the determination of the Plume EPZ primarily.to prmpt fatality limits, but also includes 4
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. latent fatalities, early radiation injuries, and impacts en the thyroid as bases for establishing the Plume EPZ boundary. The nethodology also includes specific and explicit consideration of local and site-specific factors such as neteorology (including dcminant trajectories, wind direction and persistance, precipitation, inversion frequency and persistance, and seascoal and diurnal variations in these parameters), population distribution, and characteristics of the local roadway network. 'Ihis nethodology is also based upon an explicit consideration of accidents which exceed the design basis
'Ihe present generic 10-cu.le Plume Exposure Pathway is not sufficient to ensure adequate protection of the public health and safety for those accidents in which offsite protection response will nest urgently be required. It is clear that energency planning is principally directed at accidents beyond the design basis. The design basis accident which is most frequently cited as the one having the most serious offsite consequences is the EBA/IOCA. As the NRC Staff well kncws, the means by which the consegmnces of the DBA/IOCA are calculated based on 10 CFR Part 100 lead to a considerable overestimation of the doses which could be expected in offsite areas.
However, the sour term associated with the DBA/IOCA (as set forth in TID-14844) is equivalent to that from a meltdcwn with an intact containment (see Menorandum dated 2/22/79 frcm Frederic D. Anderscn to the Ccxtmissioners,
SUBJECT:
"NRC Siting Policy and Practice and the PIBG Petition for Rule-Making on Population Ouracteristics (SECY-78-624)"; see also TID-14844, Cal-culation of Distance Factors for Pcwer and 'Ibst Peactor Sites", March 23, 1962, page 8). The NBC Staff has already analyzed the impacts of such an accident and concluded that for 70% of all' sites analyzed (111 sites) the doses to the public would not exceed the Protective Action Guides (PAGs) established by the EPA at distances beyond 10 miles. Such an accident would probably necessitate offsite protective response for area near the reactors (i.e.
within the Im Population Zone) and could result in a response at greater distancer as a precautionary neasure. Since the maximum estimated year 2000 population within two miles of any of the 111 sites analyzed by the staff is 12,500 (at Indian Point), existing plans should be able to accmodate this accident.
As a practical matter, it would be prudent in our opinion to order an evac'uation in the event of any core melt accident.
This is true for y
two principal reasons. First, it is in precisely such an accidentut the potential risk to the public is at its highest. Second, the state-of-the-art knowledge of events concurrent with and following a core melt is fraught with great uncertainties such that it cannot be assumed that the containment will hold. The prudent measure to take in such instances is to require evacuation.
In order to place bounds on the area for which evacuation may be i
required, it is necessary to examine which accidents contribute the most to the overall risk to the public..Upon such an examination, it is quite clear that core melt accidents with containment failure are dominant in establishing public risk.
Accidents within the design basis contribute little to overall risk (see, for example, NUREG/CR-0603, "A Risk Assessment of a Pressurized-Vater Reactor for Class 3-8 Accidents",
October 1979, Brookhaven National Laboratory).
Accidents beyond the
~
l design basis dominate risk and, in particular, accidents at the extreme l
limit of this class of accidents are risk-dominant.
It is clear that a 10-mile Plume EPZ provides insufficient protection for the public in such aceitents.
The staff's own analysis I
e l ;
in NUREG-0396 demonstrates this quite well.
The staff concluded th'at 30%
of all core melt accidents will result in doses in excess of the PAGs beyond 10 miles.
The staff further concluded that in most cases prc=pt fatalities would be limited to within about to miles.
On this basis the staff established the 10-mile Plume EPZ requirement. This basis i faulty on two general counts.
First, the 10-mile Plume EPI presumes that prompt fatalities are the I
consequence of concern and that other consequences are less significant or can be dealt with by way of ad hoc response. Neither formulation is correct.
Certainly emergency planning must have as one of its principal 1
goals the avoidance of prompt fatalities.
However, emergency planning for reactor accidents cannot ignore latent fatalities, early radiation injuries (for which medical trectment capabilities are limited), and non-fatal cancers.
Second, the 30% of core melt accidents estimated by the staff to cause doses in excess of PAGs beyond 10 miles are precisely those 2
accidents for which emergency planning is most urgently needed.
For such accidents, doses will likely be in excess of PAGs to such a large distance beyond 10 miles (i.e., to 20-50 miles) that the planning which has been done within 10 miles will become largely irrelevant to assuring that adequate protective measures can be'taken beyond 10 miles?
Thus, if emergency planning for reactor accidents is to have a rational basis and provide for adequate protection of the public health and safety, such planning must account for core melt accidents with containment failure.
Such accidents are accounted for in the California OES report and UCS/NYPIRG believes that the methodology set forth therein, if applied to Indian Point, will provide a more reasonable starting point for determining the area for which advance evacuation planning is required.
- 4. a) Identify what you mean by " adequate sheltering" in your Contention III(A)b. In your response to this Interrogatory give exsmples of " adequate sheltering."
b) Define what you mean by the tenn " degraded" with regard to the roadway network in your Contention III(A)c.
c) Define what is meant by the tenn " upgraded" and the words "made capable of being used" as these words are used in Contention 4.2 and your Contention III(A)e with regard to the roadway network.
a) Adequate sheltering capability would be' sheltering capable of reducing radiation exposure during and following plume passage to an axtent such that significant adverse health consequences do not occur.
Such sheltering should be available for all residents of the area at risk, plus all transients in the area at risk at the time of the accident.
b) 'Ihe tern " degraded" as used in UCS/NYPIPG contention III(A)c means, in general, less than nonnal. As used in this contention, a degraded roadway network wouM occur in any of the following cases:
(A) Accidents ulock2ng one or nere lanes of an evacuation route.
(B) Highway repairs or other roadway construction or repair work which blocks one or nere lanes of an evacuation route.
(C) Weather-related conditions such as snow or icy roads which limit the speed of traffic on evacuation routes.
(D) Excessive nunbers of transients causing heavier tMn normal traffic to such an extent as to reduce the speed of traffic l
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. on evacuation routes.
(E) Weather-related conditions such as rain or fog which limit visibility sufficiently to reduce the speed of traffic on evacuation routes.
(F) Flooding sufficient to restrict access to evacuation routes.
(G) Any ccxtbination of the above.
4c) It is the responsibility of e:rergency planners to detemine the manner of upgrading the roadway network, i.e. the definition of
" upgraded", which would pemit successful evacuation of all residents in danger before the plume arrival time. "Made capable of being used" implies the ability to use the roadway network for such an evacuation.
- 5. Identify the " specific steps" (with reasons given for each step) that you believe must be taken by NRC, State, and local officials to prcncte "public awareness" as referenced in Contention 4.5.
Such specific steps would include a stepped-up public infonration program incorporating :raterial which would prcrcote such an awareness.
The reasons for this are given in UCS/NYPIRG's Bases for Contention 1(B)7.
Affinned this 21st day of May,1982:
Amanda Potterfield, Esq. "
Subnitted by:
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e Amanda Potterfield Joan/ Holt Jpffre? M. Blum Counsel for NYPIRG Profect Director Cbunsel fdr UCS Box 384 NYPIRG 423 VaWeilt Hall Village Station 5 Beekman Street 40 Washington Sq. South New York, New York 10014 New York, N.Y. 10038 New York, N.Y. 10012 212-227-0265 212-349-6460 212-598-3452
l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMilSSION e
'E2 iM 20 ?! T9 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD M
..CC:.i
_p-In the Matter of
)
)
CONSOLIDATED EDIS0N COMPANY OF NEW YORK
)
Docket Nos. 50-247 SP (Indian Point Unit 2)
)
50-286 SP
)
POWER AUTHORITY OF THE STATE OF NEW YORK
)
(Indian Point Unit 3)
)
Certificate of Service I hereby certify that copies of:
UCS/NYPIRG'S ANSERS 'IO NRC STAFF'S INIERPOG7 DORIES _
have been served on the official minimum service list for the above captioned prog,eeding by depositing in the United States mail, first class, 1W O..Y.
this 2 M day of Fay
, 1982.
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Joa Hol t Amanda Potterfield, Esq.
P.O. Box 384 New ork Public Interest Research Group, Inc.
Village Station 5 Beekman Street New York, New York 10014 New York, New York 10038
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. UYi UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of:
Docket Nos. 50-247 SP CONSOLIDATED EDISON COMPANY OF 50-286 SP NEW YORK (Indian Point, Unit 2)
POWER AUTHORITY OF THE STA1E OF
)
NEW YORK (Indian Point, Unit 3)
SERVICE LIST Docketing and Service Branch Paul F. Colarulli, Esq.
Office of the Secretary Joseph J. Levin, Jr., Esq.
U. S. Nuclear Regulatory Comission Pamela S. Horowitz, Esq.
Washington, D.C.
20555 Charles Morgan, Jr., Esq.
Morgan Associated, Chartered Louis J. Carter, Esq., Chairman 1899 L Street, N.W.
Administrative Judge Washington, D.C.
20036 7300 City Line Avenue Philadelphia, Pennsylvia 19151 -
Charles M. Pratt, Esq.
Thomas R. Frey, Esq.
Power Authority of the Dr. Oscar H. Paris State of New York Administrative Judge 10 Columbus Circle Atomic Safety and Licensing Board New York, N.Y.
10019 ll.S. Nuclear Regulatory C6 mission Washington, D.C.
20555 Ellyn R. Weisf Esq.
William S. Jordan, III, Esq.
Mr. Frederick J. Shon Harmon & Weiss Administrative Judge 1725 I Street, N.W., Suite 506 Ato6fc Safety and Licensing Board Washington, D.C.
20006 U.S. Nuclear Regulatory Comission Washington, D.C.
20555 Joan Holt, Project Director Indian Point Project Janice Moore, Esq.
New York Public Interest Counsel for NRC Staff Research Group Office of the Executive 5 Beekman Street Legal Director New York, N.Y.
10038 U.S. Nuclear Regulatory Comission Washingtoti, D.C.
20555 John Gilroy, Westchester Coordinator Indian Point Project Brent L. Brandenburg, Es.q..
New York Public Interest Assistant General Counsel Research Group
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Consolidated Edison Co.
240 Central Avenue of New York, Inc.
White Plains, New York 10606 L Irving Place t'ew York, N.Y.
10003
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. D wie 'Ihcrson, Esc Jeffrey M. Blum, Esq.
Yarc L. Parris, Tsq.
New York University Law School County Attorney 423 Vanderbdilt Hall County of Rockland 40 Washington Square South 11 New Hemstead Road New York, N.Y.
10012 New City, N.Y.
10010 Charles J. Maikish, Esq.
Geoffrey Cobb Ryan Litigation Division Conservation Comittee The Port Authority of Chairman, Director New York and New Jersey New York City Audubon Society One World Trade Center 71 West 23rd Street, Suite 1828 New York, N.Y.
10048 New York, N.Y.
10010 Ezra I. Bialik', Esq.
Greatei-New York Council on Energy Steve Leipsiz, Esq.
c/o Dean R. Corren, Director Environmental Protection Bureau New York University New York State Attorney 26 Stuyvesant Street General's Office New York, N.Y.
10003 Two World Trade Center New York, N.Y.
10047 Atomic Safety and Licensing Board Panel Alfred B. Del Bello U.S. Nuclear Regulatory Comission Westchester County Executive Washington, D.C.
20555 Westchester County 148 Martine Avenue Atomic Safety and Licensing f
l New York, N.Y.
10601 Appeal Board Panel J
U.S. Nuclear Regulatory Comission Andrew S. Roffe, Esq.
Washington, D.C.
20555 New York State Assembly Albany, N.Y.
12248 Honorable Richard L. Brodsky Member of the County' Legislature Renee Schwartz, Esq.
Westchester County Botein, Hays, Sklar & Herzberg County Office Building Attorneys for Metropolitan White Plains, N.Y.
10601 Transportation Authority 200 Park Avenue
. Pat Posner, Spokesperson New York, N.Y.
10166 Parents Concerned About Indian Point Stanley B. Klimberg P.O. Box 125 General Counsel Croton-on-Hudson, N.Y.
10520 New York State Energy Office 2 Rockefeller State Plaza Charles A. Scheiner, Co-Chairperson j
Albany, New York 12223 Westchester People's Action Coalition, Inc.
Honorable Ruth Messingar P.O. Box 488 Member of the Council of the White Plains, N.Y.
10602 City of New York District #4 Alan Latman, Esq.
City Hall 44 Sunset Drive New York, New York 10007 Croton-on-Hudson, N.Y.
10520 d,l
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. l f
Lorna Sa17'an f
Mid-Atlantic Representative Friends of the Earth, Inc.
208 West 13th Street New York, N.Y.
10011 Zipporah S. Fleisher West Branch Conservation Association 443 Buena Vista Road New City, N.Y.
10956 Mayor George V. Begany Village of Buchanan 236 Tate Avenue Buchanan, N.Y.
10511 Judith Kessler, Coordinator Rockland Citizens for Safe Energy 300 New Hemstead Road New City, N.Y.
10956 l
David H. Pikus, Esq.
Richard F. Czaja, Esq.
L 330 Madison Avenue
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New York, N.Y.
10017 Ms. Aranda Potterfield, Esq.
P.O. Box 384 Village Station New York, New York 10014 Mr. Donald L. Sapir, Esq.
60 East Mount Airy Boad RFD 1, Box 360 Croton-on-Hudson, New York 10520
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