ML20062F131
| ML20062F131 | |
| Person / Time | |
|---|---|
| Site: | 05000516, 05000517 |
| Issue date: | 11/16/1978 |
| From: | Like I REILLY & LIKE |
| To: | Johnson W, Salzman R, Sharfman J NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| NUDOCS 7812150019 | |
| Download: ML20062F131 (10) | |
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ROC PsTED carc'D%E Rzu.Ix, LIxz un Scnwzzana COUNSEI.2. ORS AT Z.AW 200 WEST MAIN STREET BABYI.ON,N.T.u702 g
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WE.tN"JB J. EUM3NETNN RICMaaD C. MAND ENBECO J. CQbeWTANTD80 SETBJCIA A. DEXFSEY November 16, 1978 ff,4)U"4 Jerome E. Sharfman, Esq. Chairman f
Dr. W. Reed Johnson Richard S. Salzman, Esq.
b, f Atomic Safety & Licensing Appeal Board hc/
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U.S. Nuclear Regulatory Commission Washington, D.C.
20555 1
5 Re:
In the Matter of Long Island Lighting Company (Jamesport Nuclear Power Station, Units 1 & 2)
Docket Nos. 50-516 and 50-517 Gentlemen:
At the hearings on the above-captioned matter, the County of Suffolk presented testimony regarding deficiencies in NRC Staff's and LILCO's analyses of Jamesport's site meteor-ology. (Direct testimony of John Frizzola, Cty. Exhs. 45 &
45a, admitted in evidence, tr. 6206-07; cross-examination of Frizzola, tr. 6208-16, 6224-76).
On the basis of such testimony the County argued in its briefs submitted both to the Hearing Board (County of Suffolk's Proposed Findines of Fact and Con-clusions of Law, paras. 10.1-16.51) and on appeal (County of Suffolk's Brief in Support of Exceptions, pp. 50-51) that Staff and Applicants could not, with their present analyses and the methodological flaws contained therein, show compliance with 10 CFR,,Part 100 or properly address other issues that are dependent on dose calculaticns.
I have enclosed for your information as Attachment "A",
a copy of an American Meterological Society (AMS) position paper on the accuracy of dispersion models that was adopted by a standing committee of the Society and appears for the first 78121500(
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Rzu.r.r, Lrxx Ann Scmrrznan Jerome E. Sharfman November 16, 1978 Page 2 time in the August 1978 Bulletin of the Society.
To give you some impression of the significance of these statements, pre-vious statements by the Society have included the topics of weather forecasting, potential-impact of chlorofluorocarbon emissions, flash floods and hurricanes.
These policy state-ments and statements of concern are intended
"...to gi7e guidance to the public on what can (and cannot) be provided by the meteorological profession at the present state of the advance of the science...".
We therefore believe, it is of substantial consequence that the Committee on Atmospheric Turbulence and Diffusion of the AMS has decided to present a
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position paper on the accuracy of dispersion models.
As further for the s'atement's preparation are directly employed by the
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background I might note that many of the scientists responsible Federal Government and most of them have had either direct or indirect influence in regulatory matters.
See Attachment "A",
- p. 1025, n. 1.
To focus the Board's attention on this issue, I have l
reproduced below the key portions of the AMS statement (under-lined) and hace summarized how such findings relate to the County's previously-stated position on the issues covered.
1.
Simbiation of atmospheric dispersion by mathe-matical models which are used to accomplish control of existing sources of, air pollution or potent.tal new sources inherently have levels of n
uncercainty attached tc them.
The NRC staff and applicant, LILCO, lave'r addressed these uncer-tainties even after the County provided extensive testimony on that subject.
The County also provided testimony regarding these uncertainties to the NTC in their solicitation for input to a Reviaed huclear Regulatory Guide on the use of dispersion models.
See Attachment "B".
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2.
Decisions can be imoroved if these uncertainties l
are correctly taken into account. The hearing board of the NRC never.did take our concern with these uncertainties into account nor did Staff or Applicant provide the Board with knowledge of the existing accuracy of their computations.
Such computations have multiple relevancy for alter-nate siting strategy, emergency evacuation, trans-pertaticn and proof of adherence to various Federal regulations, all of which use the output of a dispersion model.
Razzn;Lxxx an ScMwxrnra
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Jeroma E. Sharfman, Chairman November 16, 1978 Page 3 3
Even in idealized conditions (ie., uniform terrain, steady meteorology) the precision of the models that use the Pasquill-Gifford (P-G) curves...or that are otherwise developed using these observations is closely tied to the scatter of these experimental data, including the inherent scatter of the meteorological quantities...
Simply stated, not only do the models_used have uncertainties in their output but errors in experimental derivation of F-G curves and related atmospheric quantities
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make the maximum downwind ground level concen-tration that should be expected (from the model) to be within 20 to 40% of what would be actually observed in the case of an elevated source, assuming ideal conditions.
However, as the County has' agreed, the NRC method of deriving. the P-G curves through use of the temperature gradient indicator has never been verified experimentally and has no theoretical justiciation.
Therefore, agreement between observed and predicted dilution rates for esti-mating ground level doses from elevated radiolo-gical emissions using the delta-T indicator recommended by the NRC even in ideal conditions, would have an envelope of uncertainty between observed and calculated dose rates that cannot even be estimated.
4.
In circumstances when dispersion models are applied that are different from the carefully controlled 20-40% envelcpe using actual experi-mental. data bases', the scatter of estimate of concentrations (ie., dose rates) can be excected to exceed these (ideal) values.
A factor of 2 is cro' ably realistic for cractical modeling c
applications.
However again the NRC delta-T method with little basis in experiment or theory give real world acplications of discersion mcdels an envelope of uncertainty exceeding a factor of two at least.
Rzmx,Lzzz Aarn scacrzman Jeroma E. Sharfman, Chairman November 16, 1978 Page 4 5
Success in exceptional cases such as flows over
, surfaces markedly different from thoL9 represen-ted in basic experiments'(assuming suitable P-G indicators have been used) including dispersion over forests, cities, water and rough terrain can only be obtained by developing site specific models based on observations of meteorological and disper-sion parameters at that location.
Such site specific models can have accuracies as good as a factor of 2. -
Attempts to apply standard idealized dispersion modeling to these exceptional conditions have often produced poor results.
In some cases these attenots produce results that differ from the real situation
-3 by an order of magnitude (factor of 10).
'd The County has presented these exceptional cases as they relate to Jamesport and has asked for further analysis to isclate the site specific problems which can cause such large uncertainties in the model output.
The NRC also suggests further analyses of the meteorology and dispersion at complicated sites in their Regulatory Guides which the County has shown for Jamesport consists of coastal induced circulations superimposed on the rouchness changes surrounding the site.
The Staff and Applicants did not consider-these complications and did not perform further site specific experiments todefinethecomplicationsassuggestedbytheCounty.']'
In addition the delta-T method derived from on-site tower observations is insufficient for defining the dispersion regime around~Jamesport and could only be used after extensive development of a correlation between the temperature gradient and other direct (tracer) or surrogate (wind direction fluctuation) methods of indicating dispersion classes.
the Hearing Board did nto and could not evaluate the consequences of these complications on the dose rate estimates.
6.
Finally the AMS committee states that the situation expressed by them imposes obligations on all those _
concerned with the problem of estimating concentrations of airborne pollutants.
Users must ce aware of the degree of uncertain V inherent and attempt to estimate the cegree of uncertainty and communicate this inrcr-nation clearly to users.
Information on this uncertainty of concentration (dose) estimates should be included in official covernment zuidelines and reflected in reculatory thinking.
Eziu.7,4xx Axn ScaxmLSOD Jer'ome E. Sharfman November 16, 1978 Page 5 The County in its lengthy documentation of this problem did make the board aware of the problem, did communicate this information to the Board and did include this knowledge to the NRC for inclusion in their updated draft of a guide on dispersion models.
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I realize that the AMS Statement cannot now be considered as evidence in this case.
However, as Special Counsel for the County of Juffolk, and in view of this Board's knowledge and
,,i concern over this issue (see, Transcript of Cral Argument > pp.
157-58), I feel that a development of this significance abould not go unnoted.
Given the multiple relevance of site meteoro-logy to various issues which have been raised in these proceedings, it may be that this Board will determine that a reopening of the record is necessary to explore the significance of the AMS Statement and the impact of its findings on the Jamesport application.
In such event, the County stands willing to
-. _ __ introduce testimony by County meteorologist Frizzola to address these concerns.
Very truly yours, Irving[ k h h
/h p;
(_
Like Special Counsel for the County of Suffolk IL/jg CC:
To All Parties with enclosures
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Attachmsnt "A"
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59, Number 8, August 1978 Organization issue A.2Q Z
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t's page........ 4.. 930
- Y pre calendar of meetings....... 1006
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tution and By.l.aws.... 931 t
L th publications of the AMS.... 1008
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~nf ganization of the AMS.... 936 certiDMEDre_gygpr h,Y.%
O; council of the AMS......... 944 CCMs.......... 1. ??.'QE.WJ O Mis members of commissions, seal of approval prograrn for boards, and committees... 945 radio and TV weathereasting 1015 a
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5 past presidents, honorary educational activities...... 1020 h
members, and fellows..... 965 t'R Editor, Kenneth C. Spengler d rectory of local chapters... 967 Policy statements......... 1023 Technical Editor, J. E. Caskey, Jr.
the Society's awards......... 980 corporation members....... 1024 Educational Afairs Editor, Owen E. Thompson Focus on Forectsting Editor
- position paper 3
Fredcrick Sanders
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News Editor, Eileen M. Blum Copy Editor, Reine Rosenbaum Accuracy of Dispersion Models Editorial duktant, Joan Urdang
.tMS 1977 cammittee on Atmospheric Turbetence and Diffusion 1025 Meetings Editor, Evelyn Mazur Anistant Meetings Editors, Twila A. Bombard correspondence Kathleen L. Forrest Advertising, Lilly G. Albo
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James Gillroy's " Weather" Etchings.............. F. A. C;Ilord 1027 8 " "
- socieir. eeoind to adaonais. somr utict=.
profesional and siembership news, anoonace.
meats. and society activitiaL Editing and I
i puwabias are uude, the direction or Kenneth
- c. spaen. E=== ties Director. Mc=b"' "'
encouraged to send information to be commdered announcements........... 1028 -
at AMS headquarters...... 1049 for peblication, send four copies of each stana.
s ICAS items............... 1029 AMS notice-59th Annual 3
scrini (tot and u: struioso. ro, smm on pseparation and style, see "Inforru rm fo, catnwi=~ os in-ie caem or a rmat AMs book reviews............. 1031 Business Mee' tin 9 "'"
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resesreh journal.
Aus oscen ad co - i-3 Presa ne, getters to the ed. tor........ 1026 condidates for CCM....... 1051 Cearse P. Cressmaa. Presulent.E:ect. Chester i
W. Newtos; Emacause Directae. Kesseth C.
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spoen: s=rrearr.rr= =r. D,id v. La.
news and notes...,....... 1039 meetings of the AMS....... 1053 dd 4a: rass rresuients. Charles L. Esier. Jr.,
4 and Werne A. Baum; and Councilors: Derawn about our members * * * * * * * *
- 1042 Ackerman. William D.
Boeser, James P.
8sace. Francis s. Johnsas. Mtert J. Kaeha.
Contents of AMS journals... 1059 i
I Jr, Roy L. Leap. Jr.. ;targaret A. LaMone.
news from our chapters..... 104.1 rredencx r. oubr. Jr Norman A. russ.
profesu,onal d, rectory...... 1063 i
readerich saaden. r==t w. stewut. ven=
AMS announces undergraduate i
E. suond. John E. Wallace. Robert M. White.
Jar s. moton.
awards and scholarships.. 1048 index to. advertisers........ 1072 Ful.1;shee reoathly by the Amencan Meteoro.
bcical society at 4s Beacos st Boston.11 ass.
l 021C3. second< class pastage paad ' at r+ostca.
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Man.. and at addaional mailine ceices. sub.
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""y Cot'er: Fery Slippy.IVesther, one of a series of nine 'wcatter* ctching by de farnous En';!ish i
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l acamemvers is aeadaue sa request: sanec is.
cancaturist. Jarues Gillray (IM-IS15). Thro, ugh the gi:ncrosity of Dr. Franklin A. Gifford.
nes are 31 neh. 4 Ries: all hsiness corsmuni.
pft prints of these nute etchings now hang in the Harr: son Gray Otis house. AMS He2d.
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catens. purcasas orers, and L-9es :a the quarters. 45 Ilescon St., noston. GUTord writes. 'It is entirely pmoble.. that ex: noles l
Eme:uthe Dir ector. Amencan afeteorological of [Gillray's] ctchings could hac been seen in th: Clis housc'* Jurin7 iu estiv dass. 'for l
'ocet y. 45 Bevon !L. Doston, Mats. 02103 (417 22r.2423).
niore det:lla. see corte:pondence by Citford, which begins on pge If.r5.
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1 C sorrisht 19's. Amer;can Metromforical soc 2ety.
, i utes, tardrs, etntrarts. er otaer tscerpts recurre permtsson or Scense frem the American Meteo ost. cal hciety.Renunaication syste na t
ti awn.ual resers and rosocont M,rarvs act.
aar for them. mar :reew use :n teena. ra ia fectubs 'CS of the U.i u.pyruht Law (1; tm., as revned by P.L. 94.;33),iba wurnaa only il the ase is cc erraiard to be *2ar use" u.icer 5ccucn 107. c s urma htmrrsion to qvue tir:erly frem tNs jownal in suauna woess, mth 4;Laamitet.
met of the sourte..s ge rtt~1.
The arrestace of tne ccsas and copyrittt nouce at the !, otter, at tre :i.st saec of an art:cle in th:s p ra:4.pdicates cc:th.
I honal :teasea t
,y tee American '.letcor atet. cat iactet y that comes c,4
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of memic den's: tha consent is emn em the conwuos. ho*evee. that the cceer paythe aruchs map bc rw.e ior de errsonal or in:cenal use, or tur pemnas or internaa
'aac the.ta:ct1 per.roept fee througm the Csoyrw.at C earai:e Crs:er, !nc..
J10 *.lainsoi Ave. New Yort. N.Y.100 7 thaa consent does not enend to ot! er kinds of c.r rint. Any cemtr6butsons in this inue tnat do eef bear therr fetarate A*.is copynght act.cs esther are c;aemDted !,y the ALL3 frota proteta.',a undur its copyn&At sr are U s C.wernment mes e
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.b 00!!0]r818m8HIS and Stalem8D"3 al 00008f'n 0!!!18 AES 3
The purpose of these Statements will be to give guidance to the public on what can (and cannot) be provided by the meteorological profession at the present state of advance of the science, to urge appropriate action in pending matters of public policy that are of concern tu atmospheric science, or to address the meteorological profession on matters that require urgent attention.
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Currently ApprovedStatements Statement on Tornado Detection, Trac!dng, and Warning (January 19, 1975), Buu.rrin, April 1975, p. 464.
Statement on Mobile Homes and Severe Windstorms (January 19,1975), Buu.zrzn, April 1975, p. 466.
Statement on Meteorological Satellites (October 3,1975), Buu.Krrn, January 1976, p. 58.
The Hurricane Problem, A Statement of Can'ern by the American Meteorological c
Society (July 2,1976), Buu.aTru, August 1976, p. 996.
Statement on Weather Forecasting (Scptember 30, 1976), Buuzrzn, December 1976, p.1460.
Statement on Potential Atmospheric Impact of Chlorofluorocarbon Emissions (September 30, 1976), Buu.rrtu, December 1976, p.1462.
Flash Flood >-A National Problem, A Statement of Concern by the American Meteoro-l logical Society (January 29, 1978), Buuznn, May 1978, p. 585.
An ofEcial Statement of tite Amerian Meteorological Society is one that has received Council approval, or, in a situadon that the Executive Committce defines as an emer-gency, approval by the Committee on Public Policy (COMPUP).
Guidance in the preparation of such Statements has recently been provided by the Council (see Buurrin, May 1974, p. 439, and also an e rlier policy statement in Buu.rris, July 1963, p. 446).
An official Statement on a technical subject (such as weather forecasting, weather modi 5cadon, etc.) will automatically be withdrawn and no longer listed in the Buurrix l
three years from its date of publication in the Buurrix, unless the cognizant committee recommends to the Council that its life be extended for another three years in either its I
present or amended form, and the Council so approves. An oficial Statement on a special topic, contained, for example, in a letter from the AMS. President or in testimony before Congress of an official of the AMS on a matter of government or public policy, is usually directrd at a speciSc matter of current concern and therefore may not be l
noteworthy for more charr a year. Such topical Statements will be reviewed annually by j
the Executive Ccmmittee and withdrawn or extended by it as deemed appropriate.
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l Bulletin American Meteorological Society 1023
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Ii ACCUPaDr GMl8DSP8!DH MDM
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' a, A Position Paper of the AMS 1977 Committee en Atmospherie Turbulence and Diffusion Use of various kirtds of mathematical modCls to Calculate the Pasquill-Gifford dispersion curves. 'nius the pre.
f,tmospheriC dispersion of airborne pollutants has be.
cision of mode!< thme use the Pasnuill Cijlo.DLKtIrve5"br come very widespread, particularly as a result of legal that are otherwise developed using these observations 13.
requirements to analyze environmental impacts under closely tied to the scatter of these experimental data the C1can Air Act. I.ead federal agencies such as the bases. includine the inherent scatter of the meteorological Nuclear Regulatory Commission (NRC,1977) and the n,nsaritie< &ne'n snd turbulent winds) that govern the Environmental Protection Agency (EPA,1977) have re.
pollutant concentration field. Based on these facted cently promulgated official guidelines detailing how these a user estimates a certain concentration value by these meteorological cdculations should be performed for the modeling techniques. in ideal circumstances (i.e., uni.
purpose of federal regulatory reports such as environ.
form terrain, steady meteorology, source and ambient mental impact statements. The calculation methodology parameters measured carefully by research-grade instru.
commonly used in such studies was discussed from a sci.
menu)._the observed maximum downwind vround-level
)'
entific point of view at a recent American Afeteorological concentration value should be exnected to be withirt Society workshop (AAIS 1975) and has formed much of 10-20% of the calculated value for a surface level source the subject matter of an active series of AAIS symposiums and within 20-40M for an elevated source. such as a rmfl (Ah!S 1971,1974.1976,1977). The interesc of a wide
. stack _(see Pasquill.1974. Table 6.XI).
, segment of the meteorological community, as well as This situation can be viewed from another perspec.
that of a large group of concerned environmental en.
tive. If it is assumed that the same idealized conditions
> gineers and scientists, is attested to by the exceptionally exist and if the errors of the model-generated maximum large and' sharply increasing attendance at these meetings.
value of the ground-level concentration at a point are Local. state, and federal regulations are currently averaged over a comparable time interval, then they will being writters and implemented to control exisrinw Pr agree with the intrinsic. scatter present in the wind proposed sources of pollution in order to achieve air velocity and temperature measurements. At present, this quality standards and prevent significant deterioration scatter it irreducible, and dispersion estimates can ap.
cf air quality. Afuch of this is accomplished through the proximate this degree of scatter only in the most ideal use of mathematical models. which i he-ently have 'excis circumstances, cf uncertainty attached to them. For example, if an air When dispersion modeline is applied in circumstances qt7a'lity standard is 100 pg/m*, and a model predicts a
_that are different from the carefully enntrgiled, ideslized concentration of 99 pg/m*, it is necessary to point out.
situation descri' ed shove (which is to say mesi res!-world o
that the model prediction is only accurate within X%.
applications), the scatter of estimate of concentrations s s and that the model prediction could be anywhere in the can be expected to exceed these values. Accur-ev within range 99 (t = 10-*X) pg/m*. Decisions can be imnroved "a fnetor of 2" has frequently been esdmated in con.
11 these uncertainties are correctiv taken into secount, nection with routine applications of dispersion modeling
' alodels used for calculating the near field (distances (Islitzer and Slade 1968). This estimate is nroba bly
<lTm) of dispersion of inert pollutants for short averag.
realistic for orictic il modeline zoolications for which ing times (minutes to hours) have been developed with the controlling meteorological parameters are measured the aid of various definitive sets of dispersion experi.
from a tower, conditions are reasonably steady and hori.
ments carried out during the 1950s and 1960s under zontally homogeneous (! css than ~50% variation from
_ideslired conditions (i.e.._ uniform terrain, stendv mete.
the spatial and temporal average during the experiment),
orology). For example, the Prairie Grass (Barad.1958; and no exceptional circumstances exist that could atfect
' Haugen 1959) and Porton (Pasquill,1974) observations die atmosph'ere's dispersive capacity in ways not ac.
have played an important role in the dgvelopment af counted for in the model. In other words, good data are available, but they are not of top-grade research caliber.
s This paper was prepared by the Aats 1977 Committee on Some imoortant meteomlogics! circumstances that can Asniospheric Turbulence and DiGusion (S. R. Hanna. Chair.
man: T. V. Crswford W. B. Bendel. J. W. DeardonT. T. W.
5e clnsed "excepu.onal,. are given below (AAIS,1975):
Hont, G. H. Fichtl. D. Randerson. S. P. S. Arya, anu J..'.t.
Nonnan). The first draft was written by F. A. Cinord Jr., a
- 1) acrod namic wake Sows of all kinds, including stack I
former chairman of the committee. We apprec:ste the many suggesuons matte by the AhtS Committee on Sletcorologicai downwash, building wakes, higisway vehicle watcs.
Y. Aspects of Air PM!ution (n. A. rgan. Chairman).
and wakes generated by terrain obstacles:
O. b ~i/Ci" CY,,1 w@,tettar,b i
bic act i t$ C N f-".
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Budetdi.1rribrica gucal8cdety 1015 heue dad w edwen vgulm, W u n -W)evt ce..
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, }.(k, Vol. 59, No. 8, August 1973
- 2) buoyant fluid f!ows, including power plant stack The situation briefly summarized in the previc.as para-plumes, and accidental releases of heavy, toxic graphs imposes obligations on all those concerried with gases:
the problem of estimating concentrations of airborn2
- 3) (lows over surfaces markedly different from those nolintsnes. Users of dispenion models__must be aware of represented in the basic experiments, including dis.
the Ic-tree of uncertainty inherent in concentration esti-persion over forests. cities water sud rough terrsin; mates, attempt to estimate the de'!ree of uncertainty that
- 4) dispersion in extremely stable and unstable condi-exists in their models, and communicate this information tions; cipriv ra usert atomr with the estimates. Research on
- 5) (Jispenion at creat downwind distances (">10-20 km),
this upect of dispenion analysis should be increased Our present direct, observational knowledge of disper-considerably, eith the objective of specifying pollutant concentration fields in more detail as a function of the sion in most of these cases amounts to a few special case variability studies. To provide a sullicient background for dispenson of the associated atmospheric turbulence Selds. Information on the uncertaintv. of concentration models, it is desirable that comprehensive wind tunnel and field studies be undertaken in each of these researth estimates should also be included in official stovernment guidelia,=,nel refferred in rerulatorv-aeency thinkinz on areas. Sucren is obtained in many of these exceptional gpherie nollutiort Finally, the need to obtain basic essei_gniv_by develooint site soecific models based on f,3ppgg( rne. tar _ological and Abnersion osrameters information on dilIusion patterns, including their vari-ability, in all exceptional, nonidest situations should be
- tt that footion. Such site. specific models can have ac-curneN as nod as a factor of 2. Acremnes to aoolv stan-recognized. Supplying this information by means of dard, idealized dispersion modehng to these exceptional suitable theoretical and field experimental research pro-s r
situations have often produced poor results. in some a an urgent matter as it will help provide more cases, these attemots produce results that ditfer from the effecuve and accurate dispenica modeling in many im-rest situation by an order of magnitude. We are currently portant practical applications.
making much progress in some exceptional areas, such as in estimating the shapes of building and automobile References wakes and in developing methods of estimating disper.
sion during unstable conditions.Some research programs AMS, 1971: Conference on Air Pollution Meteorology have begun that will measure dispenion over great dis.
(R*l'igh). Boston,159 pp.
l tances and over water surfaces, but other research areas
, 1974: Symposium on Atmospheric Didusion and Air such as dispenion of heavy toxic gases and dtspersson Pollution (Santa Barbara). Boston,434 pp.
1975: Lectures on Air Pollution and Environmental Im-over forests are largely unknown.
p,'ct Analyses. Boston. 296 pp.
Point source dispenion models have been applied with
, 1976: Third Symposium on' Atmospherie Tur6ulence, modifications ta cover long-range dispenion, large are2 Digusion, and. fir, quality (Raleigh). Boston,596 pp.
sources, and long time aversge dispenion. Extensions of
,1977: Jomt Conference on Applientions of. fir Pollution the basic point. source model to urban dispersion should Meteorology (Salt Wre City). Boston, 413 pp.
tand to produce concentration estimates with smaller Bar:d,.\\f. I (Ed.),1958: Project Prairie Gram A. field pro.
statistical variations because the effect of one or more of gram in diffusion. Ccophys. Res. Pap. No. 59, Vols. I and the uncertainties is usually removed in the process.
- 2. Rept. AFCRC.TR-53-235, AD-152572 and AD-15:573, Consequently, and somewhat paradoxically, dispersion Air Force Cambridge Research Center, Hanscom AFB, estimates for urban areas should be subjec: to less scatter El.
.97 :
ide Ine n air quality models. of5cc of Air than the short.rsage, point. source estimates. If we possessed ideal source and meteorological input informa-Q.aality Planning asui Standarps, Research Triangle Park, N.C.
tion, scatter of model estimates might in these cases be flaugen, D. A., (Ed.),1959: Pmject Prairie Crass, A field as unst! as 10-20$*, (Pasquill,1974).1-lowever, it is ditTi-program in diffusion. Geophys. Res. Pop. No. J9, Vol. 3, cult to messure source strengths and meteorological d.tta Rept. AFCRC-TR.58-235, AD.217075, Air Force Cambndge over the broad urban surface, and in pr:ctice the un.
Research Center, Hanscum AFB, Mass., 673 pp.
certainties in these input parameters set lower limits on Ishtzer, N., and D. 51sde,1968: Diffusion and transport ex-the expected accuracy of the dispersion model. Factor of Pniments. Meteorology cnd.f tumic Energy 1968, edited by o s12de, t;sAEC TID 21190, Germantown, Md., pp.117-.
2 accuracy is perhaps the best that can be expected in g
most applications of urban-scale dispersion roodels.
NRC,1977: Methods for estimating atmospheric transcort The discussion so far has been concerned only with and dispersien of gaseous ef!!uents in routine releases f'rsm I
- nert pollutants..,bv additionsi chvsical or chem; cal ligr.t. water <ooled reactors. Regulatory Guide 1.111, Wash.
processes. tuch as chemical transformations, dry deposi-ington, D.C.
e tion. rasumensien. or prectoitstion stavengmt, orocuce Paxtud!,
F., 1974: Atmosphene Digusion. 2nd ed.,jaan j
additions't uc;risjnties in no_d-j_p_rydi_ctions.
Wilev, New York, pp. 166-233, 295 400.
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1
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Attachment "B" Comments solicited by the NRC"on Safety Guide 1:111 and sent
,to USNRC -- Secretary of the Commissibn,.May 14,. 1976.
~
P. 3 These'(nuclearl plants are' located at-discrete sites whose meteorology requires separate and distinct methods for assessing the radiation dose to the public.
P.
4 Too much. 'is assumed of' cur ability to simulate and describe'the behavior of~ effluents'at the complex locations typical of these plants.
P. 5 Details of topography, cha'nges in flow patterns due to interfaces such.as water bodies and roughness changes create conditions not originally described in the model.
P.
6 At perhaps the most complicated of sites, shore-line
,q or coast-lines, where location of light-water cooled b../
nuclear power plants are concentrated there is no specific guidance (by the NRC) - unique solutions by applican,ts would have to be undertaken for describing these phenomena.
- P. 7 In this respect siting decision' governmental groups responsible for should have before them not only the analyses derived from the premise that guidelines must be used but also a scenario of outcomes.-
l
-P. 8 All sectors involved in siting and hazard oriented problems relating to nuclear reactors would benefit from exposing all limitations inherent in the analyses.
.)
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