ML20077S746
| ML20077S746 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 09/19/1983 |
| From: | Bush M PHILADELPHIA, PA |
| To: | |
| Shared Package | |
| ML20077S735 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8309220197 | |
| Download: ML20077S746 (5) | |
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11NITED STATL*S OF #fERICA NUCLEAR REGULA*It)RY COMMISSION 00gMETED p
'A*It211C ' SAFETY AND 1,1Cl;NSING BOARD 13 SEP 21 M1:17 g
'In the Matter of philadelphia -
'i Docket Kos. 50-352 OL SQQQ%I$f' Electric Cosrpany (Linerick Generating Station,
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Units 1 and 2)
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STAT 1 TENT OF THE CITp OT pHIIADEI.PllIA -
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PURSUANT TO ORDERS OF JULY 26.3.1983 AND SEPTpfyER 7,1983
'. \\,s As suggested kry the Board in'its Order of September 2,1983 and in an
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- cifort to amicably re' solve possible df fferences, the City and the Applicant met l
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.As a result of
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cn September 13, 1983 to dise'uss various aspects of the SARA.
i this~ meeting, a number of concerns previous 1'y identified by the City were satisfied.. However the City continues to have concerns and desires to participate i'n this proceeding, pursuant to 10 CTR 2.715(c) in three areas;
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g (1). The it. pact. of human errors of conaission during accidents or
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' transient. aigration as initiators of accidents.
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(2)'..Th..e health effects on residents of. t.he City if a. radioactive plume moves at Icast 50 miles outward into sectors coveri g' the~ City u
under the likely circumstances of had weather, non-normal behavior and difficult evacuation within and beyond ten siles.
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(3)~ "ac health effects of contamination of the Schuylkill and
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l Delaware Rivers,5 he primary sources of drinking water for the City.
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t These issues are set forth with greater specificity in Appendix "A" attached
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hereto.
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% With r,egard to foints 2'and 3 the city maintains its objections be
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cause,the Applicant. has not to date presented any data sufficient to adeguately
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(,.,;.* s5 Mort a chst benefit analysis of 'the possibic scenarios associated with' ti. esc
'cAcernsas.reqdiredbyNEPAand10CTR$$51.20,51.21,51.23and51.26.
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onit.. with this caditions1 inferniatica in.hnnd that the city can deterprine its
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i-final posit' ion on tlsis SARA.
g The City desires to part'.cipate 'in this' proceeding in order to protect t
its present interests or interests that raay develop as tbc matter progresses.
I, Execpt to the extent addressed above, the City of Phf121phia does not at 'this j
time take any position on the issues raised by I,imerich Ecology ("IZA") in
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ff1fng its September 1,1983,
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lt shon7d he noted the parties have agreed to continue their dialogue regarding these matters and are optimistic that an informai resolution is still-t possible.
The City's f ailure to file its statement by September 1,1983 was for e
good cause an'd is excusabie 10 CPR 7.74(a)(1)(i). Under Duke Power Co.,
i (Catauba) Nuclear Station Unf ts 1 and 2, AT.AR-687,16 NRC 460, 469 (1982) good-9.:
cause is shown where a fillag although late, is such that it:
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(1) is wholly dependant upon the interests of a particular document c
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(2) co'uld not be addressed with any degree of specificity (if at all)~
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in advance of the public availability of dat document.
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(3) S'as tendered with requisite promptness once the document comes t
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into existence and is accessibic for pubiic exacination.
The City's [irst concern was previously raised by IIA. The second and
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third concerns address the previously unayailable SARA document and are timely 4
flic'd f ri respItEe to that docum' int. The City could-obviously not know with any c
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degree of specificity how the Applicant prepared its SARA
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.j, filing. Af ter receipt of the SARA, the City pronptly engaged a consultant'to J;..
revidw iiie:doennint 'an'd iniiihted discussions with the App 1f eant in an [ttempt t
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- to identify its positions in' regard thereto. !!ad the City moved more quickly,
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T..;.me,wu1d..have bcen forced to raise'ncediess issues.
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..J Unicas this filing is. allowed, the City's interest. in the matter'will M. l' j
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not be prot'ceted.
The second and third concerns were not raised by JJ.A. Unless these concerns are a'ddressed in the Draft g
l-r:nvironmental Statcacnt, the ~ City's interests will not be protected.
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The City's interest will not he adequately represented by the existing l
parties,10 CJR 2.714(i)(1)(1). ;No other party has raised the second and third l
ne City has a particular and direct interest in the healthful t
concerns.
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asintenance 'of its water supply and in its potential liability for any costs associated with possibic major accidents at 1.icnerick.
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The City's participation in the p oceeding vi11 not unnecessarily s,
i broaden the issues before the Board or delay the proceeding.
The concerns raised by the City are relevant and material to the proceeding and wi)) involve.
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issues clearfy within the statutory framework. k'hfic addressing these points g
vill certtriniY.take time, such an inquiry is essential to the farhioning of a
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i Statement wh[ch will properly address the impact of I.iperick upon the s
environment [nd the health and safety of the pubife, particularly the 1.8 t
nillion citizens.of the City of Philadelphia.
j Tho' Applicant, has previously indicated that it would have no objection
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to this' late'fiiing by the City.
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Accordingly[. the City ' respectfully requests that this Board accept.
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-j this statemedt as tidly and. address.the issues raised herein.
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7 Respectfully sub5ftted,
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.HARTH4 W. BUSH
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Septimber 1 9 1983'
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APPENDIX'"A" CITY-1 The SARA has not considered the range of accident scenarios necessary to produce a' reliable :nd realistic cost-benefit analysis as required by 10 CFR 51.20 and 10 CFR 51.21.
As currently formulated the SARA does not provide sufficient analysis to allow compliance with 10 CFR 51.23 and 51.26.
The specific scenarios which are emitted include the following:
A.
Human errors of commission during accident or transient i
aitigation have not been considered as an initiator.
CITY-2 The SARA methodology does not accurately reflect the Limerick conditions and the conservative assumptions necessary to make a realistic cost-benefit analysis and thus does not ccmply with 10 CFR 51.20 and 10 CFR 51.21 or allow compliance with 10 CFR 51.23 and 26.
The following specific deficiencies exis..
l A.
The evacuation scenarios assumed for the SARA (Section 10.3.2) are not representative of the conditions which would be expected if the plume is moving in the direction of Philadelphia.
Thus the values used in the cost-benefit comparisons do not accurately reflect a realistic estimate of the radiological effects (both median and upper estimates) which could result from an accident at either of the two Limerick plants.
B.
The evacuation scenarios assumed for the SARA -(Section 10.1.6) in the event of a seismically.-initiated accident are unrealistic for the 1211owing reasons:
1.
The assumption of " normal behav',or" beyond the EPZ is unrealistic following an earthquake-indicated accident." The earthquake would result in disruptive behavior such as, for example, uncalled for evacuation, abnormal activity, more people outs.ide shelters.
C.
The SARA uses assumptions from WASH 1400 and the LGS-PRA for critical factors in the calculation of consequences which are act representative of the realistic conditions in the vicinity of Limerick, particularly.as pertains to the direction toward Philadelphia.
These include (Section 10.1.6 of SARA):
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Unrealistic assumption of complete evacuation of 10 mile circle around the plant.
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Unrealistically assumption of " normal" behavior beyond 25
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Assumption of good weather during evacuation; no scenario is derived for evacuation in bad weather.
D.
The SARA uses health effects modeling which is not representative of those applicable to Limerick and are not sufficiently conservative to produce a reliable cost benefit analysis.
These include (SARA Section 10.3.3):
1.
People beyond 10 mile EPZ are unrealistically assumed to be involved in " normal behavior" for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, then evacuated.
2.
A single breathing rate is assumed for all people which would not be the case.
3.
The SARA assumes the low value from a range of values for latent-cancer fatalities, expressed in fatalities / person-rem., (SARA Section 10.3.3).
CITY-3 The SARA does not contain the necessary information for making decisions and policies necessary to reduce the radiological effects of an accident and thus its results and cost-benefit analysis do not comply with the requirements of 10 CFR 50.20 and 10 CIR 50.21 nor does irr-provide--suff-kientr-ba:i: f:: :n:17sds pursuant -to 10- CFR 51.23 and 10 CFR 51.26.
The specific reasons are as follows:
l A.
The dose distance relationship is missing from the analysis in SARA.
The SARA states that a bone-marrow dose of 200 Rem, where hospitalization is often required, "is rarely exceeded beyond 40 miles downwind...", (SARA at p. 12-16).
However, it does not give the likelihood of receiving this serious does at 25-35 miles which is the distance a plume would travel to reach major population of the City of Philadelphia.
B.
The absence of dose-distance curves does not allow the assessment of the likelihood of' exceeding the EPA Protectives Action Guides (PAG's) at locations within the EPZ and at locations in the l
Ingestion Pathway which includes the City of Philadelphia.
C.
The consideration of evacuation only up to 25 miles from the plant does not give the true indication of possible reductions in public risk in the case where the plume is moving toward a large population zone beyond this distance (such as the City of Philadelphia which is 25-35 miles from Limerick).
i D.
The comparisons of alternate evacuation strategies show that it is possible to reduce the number of fatalities by different i
evacuation strategies (SARA figures 10-23, 10-24) and reducing l
evacuation delay time (SARA figure 10-25) but it does not provide the necessary information to assess if this is true in all directions of plume travel, including toward the City of Philadelphia.
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