ML20072L535

Response to 830308 First Set of Interrogatories & Document Requests on Contention DES-17.Affirmation of Svc Encl. Related Correspondence

ML20072L535
Person / Time
Site:	Catawba
Issue date:	03/28/1983
From:	Guild R, Jeffrey Riley CAROLINA ENVIRONMENTAL STUDY GROUP, GUILD, R., PALMETTO ALLIANCE
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
NUDOCS 8303310345
Download: ML20072L535 (6)

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March-28, 1983 c ,

UNITED STATES OF' AMERICA NUCLEAR REGULATORY ' COMMISSION g BEFORE THE ATOMIC SAFETY AND LIC 1 G BOARD g3 @R 30 -

In the Matter of ' )

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DUKE POWER COMPANY, ET AL, )

Docket Nos. 50-413

) 50-414 (Catawba Nuclear Station, )

Units 1 and.2)'

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CESG'S RESPONSE TO KRC STAFF 3S FIRST SET OF IllTERROGATORIES AND DOCUMENT REQUESTS ON CONTENTION DES-17 TO PA AND TO CESG

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4 SESG responds herewith, fcr CESG and for Palmetto Alliance to the titled request by Staff dated March 8,1983 INTERR0GATORY 1 Please explain fully the sequence of the weather scenario or ~

scenarios which you intend to describe by the phrase "the extreme condition of paragraph of DES-17 inversion and very slow air movement," as used in the first The vicinity of the Catawba plant has been characterized as a

one of.thei five regions in the continental U.S. most subject to 7 atmospheric temperature inversions. Particularly during summer m

wind velocity drops to about zero in the period before and af,ter cuns,et. The prevail ^ing wind is from the south west. A most seriousconditionwouldbeoneinwhichtheplumefromalarks radioactive release was transported over Charlotte, at which

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point stagnation began.

INTERROGATORY 2 The description noted above in Interrogatory 1 pertains to design-basis accidents. In addressing "the matter of assessing serious.

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act.idents'," however, different descriptive terms are used - i.e. ,

" extreme, but frequently encountered, weather conditions." Are these described " extreme" conditions the same conditions as those referred to with respect to the analysis of design basis accidents? If not, please describe fully the sequence of the weather scenario or scenarios intended by the latter descriptive terms.

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, The same extreme weather scenarios are envisioned for both' DBA and, extreme accidents. An increment of weather severity would be rainfall while a radioactive plume containing particulates and condensibles was stagnant over Charlotte.

INTERROGATORY-3,

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Do you coritend that a,ny regulations, policy statement, guideline, or authority requires the Staff to utilize "the extreme condition of inversion and very slos air movement" in the analysis of design-basis accidents in the FES? If so, please identify each such requirement. -

I am not concerned with'whether or not inclusion of such an analysis is' required of the Staff. I am concerned with the fact

'that it is a physical possibility with a moderately high incidence of occurrence. .

INTERROGATORY 4 '

Do you contend that the methodology of estimating 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> radiation

. doses from' design-basis accidents at the exclusion area boundary, used to arrive at Table 5.9 values is an inappropriate method of assessing

.3 the irnpact of design-basis accidents?

Yes.

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. I INTER,ROGATORY 5 If your answer to Interrogatory 4 is affirmative, please explain fully the reasons why the methodology referred to in Interrogatory 4 does not provide an appropriate basis for determining radiation doses frbm design-basis accidents.

The DES states "The results also use the meteorological dispersion

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cbnditions that are an average value determined by actual site me'asurements." In dealing with risk in my opinion the worst gase

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mus t'? b,e ' c onsid ere d . We all know that the worst case auto accident results in death or irrecoverable serious injury. We also know that the average' injury is less serious. To assess the potential impset of DBA's we should'be presented with the full extent of the range of consequences, ih this instance involving the mo~st aggravating

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• weather condition.

INTERROGATORY 6 u

If your answer t'o Interrogatory 4 is affirmative, please. describe fully the method or methods n' vietermininq radiation doses from -

design-basis accidents which you believe is (arel appropriate, and the basis for your belief that;such method (s) is.(are) approoriate.

16 See answer 5 foregoing for appropriateness of using extreme-weather in estimating exclusion area boundary' doses. As to methodology: the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> radiation dose calculation assumes 5 removal-of persons from exposure in no longer .than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This may be the case most of the time. But if the release occurs duM.ngra heavy snowfall, and at an hour when no one is listening to a

. radio, and'with sufficient acoustic deadening due to snowfall

-to keep sirens'from being heard, a not too unusual combination of circumstances, a longer exposure period will result. .An appropriate methodology would generate the worst credible case to estimate the dosageconkequencesofaDBAreleaseatsiteboundary. I do not mean that the foregoing example is such a case, though it is more

. l severe than the average case considered.

.IllTERR0GATORY 7

Do you base your position that serious (beyond design-basis) a(cidents must consider " extreme" weather conditions as you define such

- te'rm in answer to Interrogatory'2 on any regulation, guideline, policy

statement or other authority? If so, please i.dentify such authority.

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No.

IllTERROGATORY 8 j "Mhat is the " consideration" which you believe should be accorded to (a) " extreme inversion and very slow air movement" and/or (b) " extreme, but frequently encountered, weather conditions" other than is already given in the FES with respect to design-basis and severe-accidents, respectively?

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By "consideation" I mean that the Staff-should have identified several scenarios which were developed with the highest exposure in m'ind. Several of these are discussed foregoing: plume stagnating over the site boundary a rain just heavy enough to bring down radioiodine.at the highest obtainable concentration, defects in warning which sould re it in an exposure of at least 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. h;

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In severe accidents the mechanisms resulting in the highest credible depos,ition of particulates should also be employed. Andthecritprien of the' exclusion area boundary should, for the most serious accidents be. expanded. Doses in the emergency evacuation zone, for Rock Hill and for Charlotte should be calculated, both 1.aximum individual and total man rem, based on a variety of evacuation assumptions. ,

INTERR0GATORY 9 '

. Why does not the methodology for determining the radiation doses '

for (a) design-basis accidents, and (b) severe accidents described in Sectidns 5.9;.4.5(1), .5.9.4.5(3) and 9.4 adequately consider such conditions?

I surmise, but do not know, that the methodology referenced

. . l l does *not consider worst case conditions because the NRC still has a policy of promoting nuclear industry and does not incline to '

acquainting members of the public or intervenors with worst case i b i prpjections.

. INTERROGATORY 10 Do you contend that the environmental impacts of design-basis,and severe accidents should be accounted for solel .

l of'the "eitreme" weather conditions which you 'y based on considerationstate have n considered? Please explain the reasons for your answer.

l l The question'doesn't make sense. " Account" for' impacts"?

l Perhaps-the response to 5 addresses the matter the interrogatory ,

! had in mind.

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INTERROGATORY 11 If your answer to Interrogatory 10 is affinnative, describe each of 1the environmental impa^ cts which you believe should be taken into account in the FES.

See response to; 8. Additionally the'effect on subsequent habitability and agricultural use of land receiving particulate ,

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fallout'should be exami,ned for a range of cases: The highest level' of radioactivity and the corresponding area, intermediate levels of radioactivity and . correponding greater areas; a variety of scenarios for resultant ground water and runoff concentrations of radionuclides including for all cases the relation of radioactiv- '

i-ty to calendar time.

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INTERROGATORY 12 If any of the impacts described in your answer to Interrogatory 11 are based on calculations, please provide such calculations.

Neither CESG nor PA has the resources to make specific

• calculatior$is. However it is obvious in a semiquantitative sense that all of,tnese scenarios would result in higher dosages than

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disp 1ayed in the DES..

INTERROGATORY 13

.Please identify each document, correspondence or other communication, written or oral, upon which your answers to Interrogatories.1-12 are based.

The wind occurrence data of ER Table 2.3 0-2 and 2.3 0-3 wa e plotted by sector. The CP FES and the OL DES were relied on.

Conversat. ions too numerous to recount with a number of persons

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were'had.

Suscribed'to. Resp etfully su tted, I

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Robert. Guild esse L. Riley Counsel l'or Palmetto Alliance 3 Spokesman for CESG

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UNITED STATES OF AMERICA NUCLEAR-REGULATORY COMMISSION

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

. DUKE POWER COMPANY,;et al., ) Docket Nos. 50-413

' )50-41h *

(Catawba Nuclear Station, )

Units 1 and 2) ', ) l' AFFIRMATION OF SERVICE I he'reby affirm that copies of "CESG's Response to NRC Staff's First Set of Interrogatories and Document Requests on Contention DES-17 to FA and CESG" in the above captioned matter have been served on the following in the U.S. mail this 28th day of March, 1983 James L. Kelley, Chairman Michael McGarry, III, Esq.

Atomic Safety & Licensing Board Debevoise and Liberman U.S. Nuclear Regulatory Commission 1200 17th Street, N.W.

Washington, D.C. 20555 Washington, D.C. 20036 .

Dr. Dixon Callihan William L. Porter, Esq.

Union Carbide Corporation Albert V. Carr, Esq.

P.O. Box Y Duke Power Company

' Oak Ridge, Tennessee P.O. Box 33189 Charlotte, NC 282h2 Dr. Richand F. Foster

$P.O. Box 4'263 Ge orge E. Johnson, Esq.

Sunriver, Oregon 97701 Counsel for NRC Staff U.S. Nuclear Regulatory Commission Atomic Safety & Licen. sing : Appeal Panel Washington, D.C. 20$$$

U.S. Nuclear Regulatory Commission _

Washington, D.C. 20555 . Robert Guild, Esq. . .

. Attorney for the Palmetto Alliance Atomic Safety & Licensing Board P. O. Box 12097

, Panel .

' Charleston, South Carolina 29412 U;S. Nuclear Regulatory Commiss' ion Washington, D.C.

20555 Palmetto Alliance 2135% Devine Street 29205-Docketing and Service Section. Columbia, SC

. U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Henry Presler, Chairman Charlotte Meck. Env't'l. Coalition Richard',P. Wilson', Esq.

942 Renley Place-- -

Assistant Attorney General Charlotte, NC 2'8207 2600'JBu11 Street Columbia', SC 29201

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Jes'se L. Riley for CESG

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