ML20058F385
| ML20058F385 | |
| Person / Time | |
|---|---|
| Issue date: | 12/01/1993 |
| From: | Buslik A NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Lesar M NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| FRN-58FR47159, RTR-NUREG-BR-0058, RTR-NUREG-BR-58 58FR47159-00001, 58FR47159-1, NUDOCS 9312080093 | |
| Download: ML20058F385 (2) | |
Text
y j 0000 2>
g, pc Q g
h 9dPS.
/TT December 1. 1993 I
NOTE 10:
Michael Lesar, AMMM' FROM:
Arthur Buslik. RES/PRAB
[
/
l
SUBJECT:
COMMENTS ON DRAFT REGULATORY ANALYSIS GUIDELINES 1 am a USNRC employee who would like to comment on the draf t regulatory
{
analysis guidelines: the Federal Register notice asking for comments is on page 47159 of Vol. 58. No. 171. dated September 7, 1993.
My comments follow.
4 1.
Comments on the dollar / person-rem value to be used in NRC regulatory analysis.
The use of a $1000 per person-rem criterion as a conversion factor for all offsite consequences, coupled with accident consequence analysis as was done in the NUREG-1150 studies, leads to a negative value for a statistical death j
averted. for certain accident sequences.
That is to say. the offsite financial consequences by themselves (without monetized health effects) exceed the product of the population dose by $1000 per person-rem.
The use of a
$1000 3er person-rem criterion for all offsite consequences is therefore untenaale.
Orie accident for which this is true is the station blackout core damage dCCiderit in NUREG-1150 for the SURRY plant.
From data given in a letter written by Tom Brown of Sandia National Laboratory, to James Johnson of the j
U.S. NRC on the subject of NUREG-1150 risk results dated August 16. 1991.
one obtains a population dose to 50 miles. per accident. of i
4.2E2 person-Sieverts, or 4.2E4 person-rem.
From the same letter, the offsite financial consequences (excluding monetized health effects) is $1.1E8.
(See Table 4.1 of Tom Brown's letter). Thus, if one treats the $1000 per person-rem as a conversion factor for all offsite consequences. one obtains $4.2E7 as the of fsite costs, which does not even cover the purely financial offsite costs of $1.1E8. coming from evacuation, decontamination. temporary and permanent land interdiction, and crop and milk disposal.
A far better approach is to identify separately the various components of the offsite consequences, as the consequence model MACCS (NUREG/CR-4691. vol. 2) does, and compute their financial costs.
The health effects could then be i
monetized separately, and added in.
One could perhaps monetize the health effects by representing the health effects by a population dose and using some conversion factor to convert these to dollars.
However, the dollars per person-rem factor must refer only to offsite health effects. to avoid l
inconsist encies.
The use of $1000 per person-rem for offsite health effects alone might be a reasonable value; assuming 5 deaths per 10000 person-rem, this would correspond to 2 million dollars for each statistical life saved.
Of course, the amount of money society is willing to pay to avert a statistical death, or to avert the life shortening due to a reactor accident is a value judgement. On the other hand, the use of $1000 per person-rem as a surrogate to include both offsite health effects and offsite financial consequences flies in the f ace of the fact that the offsite financial Comments on draft Regulatory Analysis Guidelines--p. 1 Buslik 9312080093 931201 PDR REGGD XX.XXX C PDR
Y s
isequences without including monetized health effects frequently exceeds the product of $1000 per person-rem and the population dose to 50 miles.
The amount of land interdicted depends on the protective action guides (PAGs).
An example of a PAG for continuation of living in a contaminated environment is 2-rem effective whole body dose equivalent in the first year, and.5-rem in the second year.
(See table 11.3 of NUREG-1150).
For a given PAG. more i
serious radioactive releases will lead to a greater interdicted area.
This decreases the variation of population dose with accident severity.
- However, there is a distortion in the relative costs of a severe accident and a less severe accident. because the greater cost associated with interdiction of a larger land area is not included.
2.
Comment on guidance for addressing safety goal considerations in the regulatory analysis.
The safety goal considerations discussed in the draft Regulatory Analysis Techrncal Evaluation Handbook. NUREG/BR-0184. involve the conditional probability of early containment failure.
It seems to be suggested on page 3.7 of this document that the NUREG-1150 definition of early containment failure should be used.
This definition. for PWRs. is a containment failure occurring before or within a few minutes of reactor vessel breach.
It is by no means evident that the NUREG-1150 definition of early containment failure i
is what should be used.
In fact. SECY-93-138 (Recommendation on Large Release Definition) suggests that a possible definition would be a release within the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following the onset of core damage.
It would seem in any event that the definition should involve the potential for serious offsite health consequences, and it is by no means evident that, say, a release occurring within two hours of reactor vessel breach could not have serious offsite health consequences, including early fatalities.
If the conditional probability of early containment failure is to be part of the regulatory analysis. then a decision by the Commission must be made as to what an early containment failure is in this context, and not take the rather arbitrary definition given in NUREG-1150 without justification.
wh Comments on draf t Regulatory Analysis Guidelines--p. 2 Buslik
/