ML20080N105
| ML20080N105 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 02/16/1984 |
| From: | Boyer V PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML20080N101 | List: |
| References | |
| NUDOCS 8402220118 | |
| Download: ML20080N105 (25) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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Philadelphia Electric Company
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Docket Nos. 50-352
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50-353 (Limerick Generating Station
)
Units 1 and 2)
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APPLICANT'S RESPONSES TO INFORMATION REQUESTS OF THE CITY OF PHILADELPHIA TO THE PHILADELPHIA ELECTRIC COMPANY DISCOVERY 26 FEBRUARY 16, 1984 G
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REQUEST NO. 1.
The marinua concentration of radioactive isotopes in the l
Schuylkill River following a severe accident at distances of:
a) 20 miles downstream (river distance) b)
30 miles downstream (river distance) c)
40 miles devnstream (river distance) d)
at the Schuylkill River's junction yith the Delaware River.
RESPONSE
Philadelphia Electric Company does not have the specific information requested.
- However, in response (designated Discovery 26, Item la) to NRC staff question E240.21, a
comparison to NUREG-0440, Liquid Pathway Generic Study (designated Discovery 26, Item 1b), which considers the direct pathway, is presented.
The conclusion of that comparison was that the consequences for the Limerick site were comparable to the river site results in NUREG-0440.
This comparison assumed that containment base sat melt thru would occur given a core melt as was assumed in NUREG-0440 at page vi, first full paragraph.
This assumption is conservative for the Limerick containment design as shown in the Limerick Generating Station Probabilistic Risk Assessment at page 1-20 item 8 and Response to Question PRA H.08 (c) at pages Q-156i through Q-1561 (designated Discovery 26 Ites 1c).
Therefore, the direct contamination category is not a
significant contributor to risk.
Generic information available on the indirect contamination by way of cloud i
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dspecition is contained in "Contaninction of Surfacs Water Bodies after Reactor Accidents by the Erosion of Atmospherically Deposited Radionuclides" by J. C. Helton, A.
B. Muller, and A.
- Bayer, Health
- Physics, to be published (designated Discovery 26, Iten id) which arrives at the conclusion that indirect contamination is not a
major risk contributor.
PARTICIPANTS IN PREPARATION OF RESPONSE Y.S. Boyer Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 G.
D. Kaiser, Ph. d.
Manager, Consequence Assessment Department Consulting Division NUS Corporation 910 CloPPer Road Gaithersburg, Maryland 20878-1399 S. H. Gibbon Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 J
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REQUEST NO. 2 What the worst case analynis showed for deposition of radioactive elements at a distance of 30 miles from the
- site, not averaged over all wind directions.
Please specify a) the key assumptions I
in the worst case analysis, b) which radioactive isotopes would be deposited
- out, and c) what the concentrations (of the radioactive isotopes) would be in terms of pico curies per square meter.
RESPONSE
Philadelphia Electric Company does not have the requested information.
CRAC2 provides only Cs-137 for ground concentrations and the output option to provide these results in curies per square meter was not selected (see NUREG/CR-
- 2326, Discovery 26 Item 2a, at figure III-2).
The precise distance of 30 miles would have to have been made a midpoint of a
spatial interval to produce the specific result for 30 miles.
If the available option in CRAC2 had been
- selected, results for Cs-137 would have been output at the midpoint of each spatial interval for each weather sequence sampled.
- However, the CRAC2 code and data sets used for SARA are available and the code could be modified to provide an option to output the deposited ground concentrations at the midpoint of each spatial interval for each
- isotope, similar to the existing CRAC2 option for air concentrations shown in Figure III-5 of NUREG/CR-2326 (Discovery 26 Item 2a).
The spatial intervals could be changed to make 30 miles a spatial interval midpoint.
CRAC2 could then be run for all the SARA
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The worst case at the distance of 30 miles could be determined by inspection of the output.
In order to put the results in probabilistic perspective a routine would be l
written to present the results for each sorrce term as conditional Complementary Cumulative Distribution Functions (CCCDFs) of deposited concentration for the important isotopes at 30 miles, On these curves the worst case would appear at the tail of the CCCDP curve.
These curves would then be used to develop a
Complementary Cuculative Distribution Function (CCDF) by weighing the CCCDF's by the source term frequencies.
This curve would provide frequency concentration information in a form consistent with SARA and in a probabilistic perspective that would aid interpretation.
The analysis could be performed for approximately $8,000 to
$10,000 and could be completed in two to three weeks.
PARTICIPANTS IN PREPARATION OF RESPONSE V. S. Boyer Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 G.
D. Kaiser, Ph.d.
Manager, Consequence Assessment Department Consulting Division NUS Corporation 910 CloPPer Road Gaithersburg, haryland 20878-1399 S. H. Gibbon Philadelphia Electric Company
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REQUEST NO. 3 Information requested in (2) (b) and (c), at 20, 30 and 40 miles for the sectors in which Philadelphia is situated (Please prorate for any sectors in which Philadelphia is partially situated).
RESPONSE
Philadelphia Electric Company does not have the requested
.information (See Response to Request No. 2).
The information could be generated in the same runs described in the response to Request No.
2 with the additional specification of 20 and 40 miles as spatial interval midpoints.
PARTICIPANTS IN PREPARATION OF RESPONSE V.
S.
Boyer Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 G.
D. Kaiser, Ph.d.
Menager, Consequence Assessment Department Consulting Division NUS Corporation 910 Clopper Road Gaithersburg, Maryland 20878-1399 S. H. Gibbon Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101
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REQUEST NO. 4 a)
What percentage of people (and absolute numbers) that are evacuating from the 10 mile EPZ sectors in the direction of Philadelphia are assumed to go toward Philadelphia.
b)
Please explain any other assumptions used for these people including but not necessarily limited to evacuation rate (s) and sheltering.
RESPONSE
The SARA analysis, which used year 2000 projected population and the CRAC2 computer code, assumed 100% of the population within the EPZ evacuated with various delay times.
The number of people from zero to 10 miles in the "ESE" and "SE"
- sectors, as shown on SARA Table 10-2,.when totaled, is 33,149.
The "E" sector is not included because the area within the City of Philadelphia boundaries which is in this sector is less than 10% of the area of that sector between 30 and 35 miles.
In the CRAC2 computer code these individuals are assumed to evacuate radially within the sectors to a
distance of 20 miles at which time they cease to accumulate dose. Assumptions dealing with the evacuated populace are provided in SARA 10.1.6.1.1 through 10.1.6.1.4.
PARTICIPANTS IN PREPARATION OF RESPONSE Y. S. Boyer Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 W
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Manager, Consequence Assessment Department Consulting Division NUS Corporation 910 Clopper Road Gaithersburg, Maryland 20878-1399 S. H. Gibbon Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 l
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REOUEST NO. S Whether you are aware of the experience around THI that people who were not asked to evacuate did so anyway, i.e.,
the
" shadow phenomenon?"
What allowance, if any, for that is incorporated in the health effects analysis.
RESPONSE
While Philadelphia Electric Company is aware of the " shadow phenomenon", it was not modeled in SARA.
The consequence model
- used, CR AC2, does not permit the modeling of such detailed effects.
If people who were not asked to evacuate were to do so this could well reduce the consequences because they would accumulate a smaller radiation dose than if they were to stay.
A countervailing effect might be that they would interfere with and slow down planned evacuees.
- Overall, the two effects would tend to balance out and other considerations affecting evacuating and non-evacuating populations would be more significant (e.g., delay before evacuation and eff ective shielding).
PARTICIPANTS IN PREPARATION OF RESPONS?
V.
S. Boyer Senior Vi ce President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101
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Manager, Co,nsequence Assessment Department Consulting Division NUS Corporation 910 CloPPer Road Gaithersburg, Maryland 20878-1399 S. H. Gibbon Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 m
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REQUEST NO. 6 For any CRAC runs done for bad weather, please specify a) how these assumptions were different and b) the incremental differential in results.
RESPONSE
While no CRAC runs were performed to attempt to explicitly analyze the effects of bad weather, the data base for the Sandia generic model is derived from US evacuation experience.
Included are a rain case, a fog case, and a snow case [see Reactor Safety Study (designated Discovery 26, Item 6a) Table VI J-1].
Hence, bad weather is included in the evacuation model which was applied in SARA.
No specific analysis was performed beyond the use of this model.
- However, to estimate the effect of explicitly considering bad weather, it could be assumed that 4% of the time (SARA, page 10-11) the evacuation is adversely affected by bad weather to such an extent that the assumptions for evacuation speeds for the seismic evacuation case are appropriate (3
hours delay and 1 aph evacuation speed).
In this case, an estimate of the effect of this change may be made.
First, attention should be called to two typographical errors in Table 10-12 of SARA:
under the column identified
" internal" the value for VRH2O should be 2.7-5 and the Total should be 4.9-5.
Next, the seismic contribution for C4T and VRH2O from Table 10-12 should in turn be divided by the
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corrcspending point caticata coismic frequencies from Table 12-8 and then multiplied by the point estimate internal frequencies from Table 12-8.
These results should then be multiplied by 0.04 and sunned.
The result of 3.0x10-6 may then be compared to the sum of VRH2O and C4f from Table 10-12, using the corrected value above, of 3.7x10-s.
This shows that the explicit inclusion of slowing of evacuation due to bad
- weather, in addition to that included in the model data base, would only have a small (less than 10% increase) effect on the results.
PARTICIPANTS IN PREPARATION OF RESPONSE V.
S.
Boyer Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 G. D. Kaiser, Ph.d.
Manager, Consequence Assessment Department consulting Division NUS Corporation 910 clopper Road Gaithersburg, Maryland 20878-1399 S.
H. Gibbon Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101
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REOUEST NO. 7 a)
A description of the different breathing rates, if any, assumed in the analyses, b)
'What the differences were in results as a function of breathing rate assumptions.
BESPONSE The breathing rates assumed in SARA are documented in SARA at 10.1.6.4.
The breathing rate given is 2.66x10-*a3s-a on page 10-13 and is tha same as that which was used in the Reactor Safety Study (Discovery 26, Item 6a) and documented in the PRA Procedures Guide (Discovery 26, Item 7a) at page 9-34.
The precise value or range of values chosen for the breathing rate is a relatively unimportant input to the calculations.
Based upon a preliminary scoping execution of CRAC2 for the source tern VRH2O (Discovery 25, Item 7b) the breathing rate was simply doubled to 5.32 x 10-*a3s-8 This assumption is equivalent to assuming that the entire population out to 500 miles was breathing at an average rate indicative of 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of heavy work and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of resting.
The whole-body maarea increased by 15%, latent cancer fatalities increased 375, and early fatalities increased 40%.
These results would indicate that even a conservative doubling of the breathing rate would not have a large effect on public risk.
SARA has indicated that other uncertainties, such as variations in source terms, are auch more significant.
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l PARTICIPANTS IN PREFARAT.ON OF RESPONSE V. 3. Boyer Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 G. D. Kaisar, Ph.d.
Manager, Consequence Assessment Department consulting Division NUS Corporation 910 Clopper Road Gaithersburg, Maryland 20878-1399 S. H. Gibbon Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101
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REQUEST NO. 8 a)
W1.e ther a
constant value for cancer per radiation dose was assumed.
b)
If
- not, what values were assumed for different dose levels.
RESPONSE
A constant value for cancer induction was not assumed and the values used are in SARA section 10.1.7.
Sensitivity analysis results for a
constant value are shown in Figu're 10-26 and discussed in section 10.3.3.1 of SARA.
PARTICIPANTS IN PREPAR ATION OF RESPONSE Y. S.
Boyer Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market street Philadelphia, PA 19101 G. D. Kaiser, Ph.d.
Manager, Consequence Assessment Department Consulting Division NUS Corporation 910 Clopper Road Gaithersburg, Maryland 20878-1399 S. H. Gibbon Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101
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RE0ilEST NO. 9 a)
Describe the bases and assumptions for rapid relocation in the " sheltering zone" used in the analyses.
b)
State whether any studies or texts were relied upon and provide, if any (' r a reference if voluminous).
O c)
Specify particular assumptions, if different, for the 10-25 mile area that cover the sectors in the direction toward Philadelphia.
RESPONSE
a)
The discussion of and basis for rapid relocation are given in SARA at page 10-11.
b)
No additional studies or texts were relied upon.
c)
The sectors towards Philadelphia were treated in SARA with the same assumptions as other sectors.
PARTICIPANTS IN PREP AR ATION OF RESPONSE V. S. Boyer Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 G. D. Kaiser, Ph.d.
Manager, Consequence Assessment Department Consulting Division NUS Corporation 910 Clopper Road Gaithersburg, Maryland 20878-1399 S. H. Gibbon Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101
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l REQUEST NO. 10 was any attempt made to analyze the environmental impact of human errors of commission during an accident or transient nitigation.
If yes, please describe ef f orts and provide any available written documentation.
If no, explain in light of the historic record of this as contributor to accidents.
RESPONSE
- Yes, a
state of the art analysis of human errors of commission was included in the event trees and fault trees developed for the LGS-PRA and used in SARA.
Examples of the PRA treatment of errors of commission generally are grouped into the following areas:
1.
Explicit evaluation of operator error
- common mode miscalibration of instruments, improper valve line up, and common mode maintenance errors and miscalibration of setpoints leading to failure to depressurize the reactor.
2.
Implicit inclusion in the failure rate data base -
diesel generator common mode failure rates and valve failures due to maintenance errors sucn as improper installation of valve seals.
3.
Initiatino event probabilities - operator errors causing scrans contribute to the initiating event frequencies used in the PRA.
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Sp2cific inctancss of inclusion of oporater orrors of commission occur throughout the PRA "Quantification of Event Tree Functions".
PARTIC! PANTS IN PREPARATION OF RESPONSE V.
S.
Boyer Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 L. G. Frederick Program Manager Availability Engineering General Electric Company 175 Curtner Avenue San Jose, CA 95125 E. T. Burns Delian Corporation 1340 Saratoga - Sunnyvale Road Suite 206 San Jose, CA 95129 H. F. Hansell Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 1
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REQUEST NO. 11 a)
What assomptions were made as to percentage of population that would evacuate within the ten mile EPZ.
Provide bases for the assumption.
RESPONSE
The percentage of population assumed to evacuate was 100%.
The basis for this assumption is provided in SARA at page 10-10.
A rough estimate can be provided of the likely increase in the public risk of early fatality if it is assumed that a 55 fraction of the population does not evacuate.
The basis for St as the fraction of nonparticipating people is
- that, in actual evacuations, Civil Defense Personnel observed this fraction ("A Model of Public Evacuation for Atmospheric Radiological Releases" by D.
C.
Aldrich et. al., SAND 78-0092, (1978) at page 13 (designated Discovery 26, Itea lla)].
From
- SARA, Table 10-12, the accident sequences C4T and VRH2O contribute significantly to the point-estimate public risk of early fatality.
( 2. 3 x 10 -
- per year out of 3.3x10-* per year).
Two additional CRAC2 runs (designated Discovery 25, Items 11b and 11c respectively), one each for VR!l20 and C45 were performed which assumed a delay time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and subsequent evacuation at a high speed (suf ficient speed to ensure that the incremental radiation dose accumulated during evacuation is small compared to that accumulated during the delay time).
The areas under the conditional CCDFs so
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obtcined eero sucacd and cultiplied by 0.05 and then multiplied by the sum of the point estimate f req uencies for VBH2O and C4T f rom Table 12-8.
The result was 5.1x10-5 per reactor year.
The total contribution to public risk of C4 f
+ 0.95x2.3x1'-* = 2.7x10-*
and VBH2O vould then be S.1x10-5 0
per reactor year.
The increase in public risk is 195 This scoping calculation shows that including a nonevacuating fraction of the population would not be expected to increase the public risk by a
large
- amount, and that other uncertainties discussed in SARA, such as variations in source tern, are auch more significant.
PARTICIPANTS IN PREPARATION OF RESPONSE V.S.
Boyer Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 G.
D. Kaiser, Ph. d.
Manager, Consequence Assessment Department Consulting Division NUS Corporation 910 clopper Road Gaithersburg, Maryland 20878-1399 S. H. Gibbon Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101
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REQUEST NO. 12 It is noted that PECo's SARA analysis assumed normal behavior beyond ten miles for twelve hours then evacuation.
For PECo Oniv:
a)
What evacuation times were assumed?
b)
If any sensitivity analyses were done with other assumptions, please describe the assumptions and the results.
RESPONSE
a)
The evacuation of the populace beyond 10 miles is " rapid relocation which is discussed in SARA at page 10-11.
Rapid Relocation assumes the instantaneous cessation of dose accumulation.
b)
In the preparation of SARA and subsequent to its submittal a
number of CRAC2 cases were run to specifically evaluate the sensitivity of the results to the assumptions on behavior of the population beyond 10 miles.
Except for the cases discussed below no analysis or evaluation of these CRAC2 cases has been made.
1)
Results for sheltering in basements for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> followed by Rapid Relocation are provided in SARA Tables G-4 and G-24.
2)
A series of CRAC2 cases were run as a result of discussions with the City of Philadelphia showing the effect of a 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> delay in relocation with u
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"norcel activityn during tha 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> on the population of the City of Philadelphia.
A summary of the results of this is provided on the following page:
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Chance Per Reactor Year That Various Radioloaical Effects Will occur in Philadelphia If No Counter-I k
measures are Taken for 48 Hours l
l Internal Seismic Total Chance that there will be one or more one in 5 One in 1.5 One in 1.1 cnrly fatality in the city of billion billion billion Philadelphia i
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Chance that there will be one or more one in 4 One in 1.4 One in 1
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psrsons in Philadelphia requiring billion billion billion ho:pital treatment (bone marrow done more than 200 ren)
Chance that there will be one or more one in 125 One in 80 One in 50 persons in Philadelphia with whole million million millon body dose in excess of 25 rea Chance that there will be one or more one in 10 One in 12 One in 5 h
persons in Philadelphia with whole million million million body dose in excess of 5 rem
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A number of additional CRAC2 runs were made which included changes in the assumptions on behavior of people beyond 10 miles along with other changes so that the impact of the individual changes cannot be separated.
An example of this is the CRAC2 runs, referred to in
Response
to Request No.
11 above (Discovery 26, Items 11b and 11c), for no evacuation of 5% of the population which also included no relocation (until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) of the population from 10 to 25 miles.
PARTICIP.\\ PTS IN PREPARATION OF RESPONSE V.
S. Boyer Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 rarket Street Philadelphia, PA 19101 G.
D. Kaiser, Ph.d.
Manager, Consequence Assessment Department Consulting Division NUS Corporation 910 Clopper Road Gaithersburg, Maryland 20878-1399 S.
H. Gibbon Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101
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COMMONWEALTH OF PENNSYLVANIA ss.
COUNTY OF PHILADELPHIA V. S. Boyer, being first sworn, deposes and states:
That he is Senior Vice President of Philadelphia Electric Company, the Applicant herein; that he has rcad the foregoing Applicant's Responses to Information Requests of the City of Philadelphia to the Philadelphia Electric Company and knows the contents thereof; and that the statements and matters set fcrth therein are true and correct to the best of his knowledge, information and belief.
g
' Senior Vice Ppidt.';
Subscribed and sworn to before me this day of February, 1984.
Notary Public PATRICIA O. SCHOLL Notri PuRc, P*arafelpYa. Mhht Ma Co.
i M comm:ssic, Ercira Februry 10,1986 t
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