ML20054E755
| ML20054E755 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 06/07/1982 |
| From: | Klopp G COMMONWEALTH EDISON CO. |
| To: | |
| Shared Package | |
| ML20054E730 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8206140148 | |
| Download: ML20054E755 (8) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In The Matter of
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COMMONWEALTH EDISON COMPANY
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Docket Hos. 50-454 OL
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50-455 OL
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(Byron Nuclear Power Station, )
Units 1 & 2)
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AFFIDAVIT OF GEORGE KLOPP The attached questions and answers constitute my testimony in the above-captioned proceeding.
The testimony is true and accurate to the best of.my knowledge, information and belief.
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Ge6rge Klopp
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Subscribed and sworp to beforg me this 7+L day of (L%-x~, 1982.
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TESTIMONY OF GEORGE KLOPP ON DAARE/ SAFE CONTENTION 2a Q.
Please state your name.
A.
George Klopp.
Q.
Is your employment position and educational and profes-sional background discussed in the affidavit you pre-pared addressing DAARE/ SAFE Contention 47 A.
Yes.
Q.
To which contention is this affidavit addressed?
A.
Contention 2a.
Contention 2a asserts generally that, given the concentration of nuclear power plants in Northern Illinois, the addition of the Byron Station units places an undue and unfair burden of risk from exposure to accidental radioactive material releases on the DeKalb-Sycamore and Rockford area residents.
As such, the contention addresses the concept of cumula-tive risk from nuclear plants.
Q.
Will the residents in the DeKalb-Sycamore and Rockford areas be exposed to an increased risk from nuclear power plant accidents if the Byron Station is permitted to operate?
A.
If one accepts the usual definition of the word risk (i.e. the chance or likelihood of loss or damage),
the answer has to be affirmative.
Obviously, the likelihood of an accident is not zero even though it O
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-o is expected to be very small.
As a result of this, we e
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dents cannot, mathematically, be zero.
Q.
How does the distance from a nuclear power plant affect the degree of risk from nuclear power plant accidents?
A.
Past probabilistic risk assessment studies, analyzing nuclear power plant risk, show that the degree of risk decreases rapidly with distance.
This is due to a number of factors.
First, as one moves away from a plant there is a lesser probability of exposure to a plume containing radioactive materials because of the number of square miles of area involved and the finite size of the plume.
Secondly, due to wind dispersion the likely dose to which one could receive also de-creases with distance.
Finally, the further one is situated from a plant the more time the individual has to take protective action, such as shelter or evacua-tion.
Q.
How do these considerations relate to Intervenor's con-tention that the addition of Byron adds an undue burden of risk to residents in the DeKalb/ Sycamore and Rock-ford areas?
A.
The areas identified in the contention are generally within the 30 raile radius surrounding the Byron Station.
They are also generally anywhere from 45 to 87 miles from other nuclear power plants in Northern Illinois.
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First, it should be noted that all of these other plants are currently operating under NRC licenses.
Given that fact; their distances from the cited area; and the results of past risk studies; I would conclude that these other plants pose a risk to the public in the Rockford, DeKalb, Sycamore area that is no slight as to be insignificant.
The extent to which that segment of the public is at risk from nuclear power plant operation would therefore be determined over-whelmingly by whatever risk accrues from Byron Station.
Lastly, I should point out that there are no factors in the design or siting of Byron Station that would indicate that Byron Station, of itself, presents any unusual or unique risk to the residents of the cited area.
r DAARE/ SAFE CONTENTION 3 O
CONTENTION 3 Intervenors contend that the FSAR does not adequately describe the elements set forth in 10 C.F.R. Part 50, Appendix E, IV, D as required by 10 C.F.R. Part 50, Appendix E, 111, nor is the actual emergency plan presently planned to be used by Applicant in compliance with said criteria, so as to demonstrate that the Applicara 's emergency plans for the Byron Station provide reasonable as-surance that appropriate measures can and will be taken in the event of an emergency to protect public health and safety and prevent damage to property.
Inter-venors further contend that Applicant's emergency plan for Byron is inadequate in that it fails to take into account any of the following factors, each of which must be factored into emergency plans for them to be meaningful and adequate:
a.
that the evacuation of the affected areas would necessitate the evacuation of more than twenty-thousand students attending Northern Illinois University in DeKalb, most of whom rely upon public transportation, or those without cars at other colleges in the affected areas.
b.
that, in the event of an acute gasoline shortage coinciding with the need for evacuation, contin-gency plans for evacuation of those otherwise able to transport themselves by means of gasoline-powered vehicles, including public transportation, would need to be transported by other means.
c.
that in the event of an accident requiring evacua-tion, there is no assurance that local and state and national authorities required to interface will in fact themselves have plans in place which adequately protect the affected public both within and without the LPZ.
d.
that in the event of an accident requiring evacua-tion, Applicant and others have plans in place to t6Ke emergency measures other than evacuation because evacuation is or may be impractical in many affected areas.
e.
that in the event evacuation is required, Applicant has no plans to deal with weather-depandent worst case analysis or the potential consequences of a h,)s core melt with breach of containment.
u 3-2 MATERIAL FACTS TO WHICH THERE IS NO
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GENUINE ISSUE TO BE HEARD 1.
Emergency planning measures for Byron will include specific plans to evacuate individuals located within the plume exposure emergency planning zone.
This planning zone consists of a radius around the plant of approximately 10 miles.
(Affidavit of John Golden pp.
6-7.)
2.
Because it is unlikely that the evacuation of persons outside the 10 mile emergency planning zone will be necessary, specific plans to evacuate students attending Northern Illinois University, which is approximately 28 miles from Byron are not necessary.
(Golden Affidavit
- p. 7.)
3.
Evacuation of students located within the 10 mile EPZ will be provided for in the Byron emergency plan.
(Golden Affidavit p. 5.)
4.
Because it is unlikely that there will be an acute gasoline shortage which would effect the implementation of evacuation plans, it is not necessary to develop specific plans for this contingency.
(Golden Affidavit
- p. 7.)
5.
There would be sufficient time to develop plans for an acute gasoline shortage, if it appeared that such a shortage was likely.
(Golden Affidavit p. 8.)
6.
The site specific annex to the Illinois Plan For Radiological Accidents'for Byron will be written by the
3-3 same agency which developed the generic Illinois Plan O
for Radiological Accidents, and will'be developed through consultation with Edison and local authorities responsible for emergency planning.
(Golden Affidavit i
pp. 8-9.)
7.
The Byron emergency planning will include. measures other than evacuation, which will be implemented under appropriate circumstances.
(Golden Affidavit pp. 10-12.)
8.
The type of protective actions recommended in the event of an emergency will be based, in part, upon weather conditions and the nature of the accident.
Accidents involving substantial core degradation or melting will be included as potential accidents for emergency planning purposes.
(Golden Affidavit pp.
12-13.)
DISCUSSION DAARE/ SAFE Contention 3 alleges that the Byron emergency pian will be inadequate due to the asserted failure of the plan to consider certain enumerated factors.
The affidavit of John Golden demonstrates that the various emergency plans will either specifically consider the factors enumerated, or that it is not necessary to develop specific plans to address these factors to assume that the public health and safety is adequately protected.
No factual issue has been raised by Contention 3
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which controverts the facts established in the Affidavit
n 3-4 of John Golden.
Accordingly, Edison is entitled to a favorable decision on the Contention as a matter of law.
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