ML20093L101

Transmittal of Proposed Partial Initial Decision on City of Philadelphia NEPA Severe Accident Contentions.Certificate of Svc Encl

ML20093L101
Person / Time
Site:	Limerick
Issue date:	07/26/1984
From:	Bush M PHILADELPHIA, PA
To:
References
OL, OL-2, NUDOCS 8407310297
Download: ML20093L101 (30)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00t KE m U ml; BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Lawrence Brenner, ChairmzfM R 30 m @-

Dr. Richard F. Cole, Member Dr. Peter A. Morris, Member Y 11: L ?, Y IN THE MATTER OP:

Philadelphia Electric Company: DOCKET NOS. 50-352-02 50-353-02 (Limerick Generating Station,:

Units 1 and 2) g

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j bg M' ' " ]~ 'l,,,,, ,(b - 3 $ b CITY OF PIIILADELPHIA'S TRANSMITTAL OF PROPOSED PARTIAL INITIAL DECISION ON THE CITY OF PHILADELPHIA'S NATIONAL ENVIRONMENTAL POLICY ACT SEVERE ACCIDENT CONCERNS In accordance with the Atomic Safety and Licensing Board's (" Board") June 22, 1984 " Order Correcting Sche.iule for Proposed Findings on NEPA Severe Accident Contentions," trans-mitted herein is the City of Philadelphia's Proposed Partial Initial Decision, which includes proposed findings and conclu-sions of law related to National Environmental Policy Act issues of concern, raised by the City, as admitted by the Board.

Respectfully submitted, f GlLDO $ hh h "

MARTIIA W. BUS!!

Deputy City Solicitor BARBARA W. MATi!ER City Solicitor KATilRYN S. LEWIS Chief Deputy City Solicitor FOR TIIE CITY OF Pl!ILADELPilIA Dated: July 2 6,1984 G407310297 040726 Q PDR ADOCK 05000352 0 PDR

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UNITED STATES OF # ERICA NUCLEAR REGULAICRY 00M4ISSION A10MIC SAFEIY AND LICENSIKi BOARD BEFORE THE ADMINISIRATIVE JUDGES lawrence Brenner, Chairman

, Dr. Richard F. Cole Dr. Peter A. Morris In the Matter of:  :

PHILADEIPHIA EIECIRIC CCNPANY  : DOGET NOS. %352-OL W353-OL (Limerick Generating Station,  :

Units 1 & 2)

CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the l City of Philadelphia's Proposed Partial Initial Decision On City of Philadelphia's National Envirornental Policy Act Severe i

Accident Concerns in the above-captioned proceeding have been i

i served on the following persons named on the attached service list by Federal Express Mail, or by causing the sane to be deposited in envelopes addressed to said persons, first class,

! postage prepaid, and deposited with the United States Postal l Service at Philadelphia, Perrisylvania 19107.

2 Respectfully submitted, ,

YghAh4 -

MARIHA W. BUSH, Deputy City Solicitor Dated: July 26, 1984

( . , ..

. SEltVICE UST .

Honorable Lawrence Brenner (FE) Mr. Frank R. Romano Administrative law Judge 61 Forest Avenue Atanic Safety & Licensing Board

• Anbler, Pennsylvania 19002 U.S. Nuclear PTilatary Cannission Washington, D. C. 20555 Honorable Richard F. Cole (PE) Mr. Gregory Minor Administrative law Judge MIB Technical Associates Accuf c Safety & Licensing Board 1723 Hamilton Avenue U.S. Nuclear N'1=tary Ccastission San Jose, California 95125 -

Washington, D. C. 20555 ,

Honorable Peter A. Morris (FE) Eugene J. Bradley Administrative law Judge Philadelphia Electric C v y Atomic Safety & Licensing Board Associate General Counsel U.S. Nuclear PT *1= tory Cannission 2301 Market Street Washington, D. C. 20555 Pbf1mdalphia, Pennsylvania 19101 Docketing & Service Section Eduard G. Bauer, Jr. .

Office of the Secretary Vice-President & General Counsel U. S. Nuclear Regulatory C W *sion Philadalphia Electric Ccnipeny Washington, D. C. 20555 2301 Market Street Benjastin H. Vogler, Esquire (FE) 0.E.L.D. Mr. Vincent Boyer U.S. Nuclear Regulatory Cannission " -

Senior Vice President Washington, D. C. 20555. . Raclear ations Philadel Electric Cm -

Mark Wetterbahn, Esquire (FE) 2301 Markat Street Troy B. Conner, Jr., Esquire Philadmiphia,. Pennsylvania 19101 Nils N. Nicholas, Escpire Conner & Wetterhahn Mr. J. T. Robb, N2-1 1747 Pennsylvania Avenue, N.W. Pbf1=A=1 phia Electric Cm Washington, D.C. 20006 2301 Market Street ,

Philadelphia, Pennsylvania 19101 Robert L. Anthony .

103 Vernon Lane Honorable Ltwrence Coughlin

' Moyland, Pennsylvania 19065 House of Representatives ~

Coogress of the United States Maureen Mulligan, Esquire Washington, D.C. 20515 -

Limerick Ecology Action -

Post Office Box 761 Frank Hippart, Director  :

l Pottstown, Pennsylvania 19464 Pennsylvania Emergency Managenent Agency B-151 Zori G. Ferkin (FE) Transportation and Safety Buildirg Assistant. Counsel Harrisburg, Pennsylvania 17120 Governor's Energy Council .

1625 North Front Street Roger B. Reynold, Jr., Esquir P.O. Box 8010 324 Swede Street Harrisburg, Pennsylvania 17125 Norristeun, Pennsylvania 19401

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Mr. Marvin I. Imuis Deperonent of L sy Serives 650/6 Bradford Terrace 14 East Biddle Street PhLladelphia, Pennsylvard.a 19149 West Chester, Pennsylvania 19380

. Frederic M. Wants Comty Solicitor Norristoun, Pennsylvania 19404 l

Argus love, Esquire i 10:. East Main Street Norristown, Pemsylvania 19401 Mr. J 2 H. %4d.ce, III  !

. 8 North Avenue Bryn Mawr, Parmsylvania 19010 i Robert L. Suga M.. Esquire S p , Denworth & Hallagers i 16th noor, Center Plaza

, 101 North Broad S::reet

Philadelphia, Pennsylvania 19107 i 7. -Charlas W. Elliocc, Esquire l . . 1101 Build 1rq

~Easton, Pennsylvania 18042 Spence W. Perry, r_g %

i Associate General Counsel i Federal h sy L w .c Agency

moa. 840 1 500 C. Street, S. W.

Washington, D.C. 20472 U. S. N. R. C. Region I i

631 Park Avenue Kirs of Prussia, Pennsylvahia 19406 i

l Thomas derusky, Director Bureau of Radiation Protection Dex. of Envirernmental Resources 5es n oor, Fulton Bank Building Third & locust Streets 4

Harrisburg, Pennsylvania 17120 ,

Aconic Safety & Licensing Appeal Panel

U. S. Nuclear Regulatory Camissien i

Washington, D. C. 20555 e

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II T' IF PEILADSLPNIA'8 P90PdED 8 INIT1AL'PARYIAL DECISION ON CITY OF PMILADELPNIA'S NATIONAL I ENVIRONIENTAL POLICY ACT SEVERE ACCIDENT CONCERNS ,,

1. SUlttARY ,

1. The Limerick Generating Station (" Limerick") consists of two (2) units sad their associated common facilities. The design capacity of each unit is 1055 IWis. The Limerick site is located on the schuylkill River, 21 miles  !

northwesterly from t,he boundary of the City of Philadelphia, in Montgomery County. SER, 2-1. The wind direction from Limerick is toward Philadelphia 272

• of the time. FEs, 5-79. The population of the City of Ph!!adelphia, the ares  ;

with closest population of the highest density, is approainstely 1.7 million.

i The population within the fifty elles radius from the plant is approniastely A ,

e1111on. Tr. 11, 283.  !

2. In this particular aspect of the proceeding, we are considering f the environmental Lapacts that can result from a " severe" accident at timerick.

Severe accidents are those residual accident possibilities that cannot be pre- 7 vented through design or operational safety esasures. " Severe" or core melt  !

accidents have only recently begun to receive close scrutiny. See, Environmental Protection Regulations, 49 Fed. Reg. 9352, March 12, 1984 ("EP f

Regulations"). In fact, this is the first operating licensing proceeding in which a National Environmental Policy Act ("NEPA"), Pub.L.91-190, 92, Jan. 1,  ;

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1970, 83 stat. 452, 42 U.S.C. 44321, analysis has been done for a severe acci-

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j dent. This is in large part due to the new perspective gained,from litt, see Ep

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f Regulations at 9356, combined with the density of the population near the _ ['

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3. The total probability of a severe core melt at Limerick is slightly under 1/10,000 per reactor year. Tr. 11, 290. The value is derived by adding all of the accident probability salues listed on Table 5.11(d), FES.

5-77. sach calculated accident consequence has a projected associated probabi-lity. There are wide variations in both consequences and probabilities. The accidents with the severest calculated consequences are projected to have the lowest probability of occurrence. The entire aim of regulation has been to reduce the chances of the worst typs4 of accidents and to minimise environmental impacts resulting therefrom. To oStain the total site, lifetime core melt accident probability, one multiplies the core melt probability times the number of reactors and their expected life. Tr. 11,193-958 11,487. The thus derived value is 1/166 (30 year life) to 1/250 (40 year life, fr. 11,279). This calculated value assumes a 10$% espacity factor, at 30 years of continual opera-tion, Tr. 11,299-300, but a witnesses' recollection was that the espected capa-city factor might be 80%. Tr. 11,300. Human errors of commission and sabotage are not included in these estimates. Tr. 11,192.

4. The two modes of contamination are altborne ard the water pathway.

As for airborne contamination, for philadelphia the greatest potentist source of fatalities are latent cancer fatalities (not immediate fatalities). "[T]he bul'4 of those [ latent fatality) cancers come from distances beyond ten alles ... ,

perhaps tens of alles down-vind with large populations where individuals will receive more small doses...." Tr. 11,6218 11,677. Latent fatalities begin to appear in the population, on average, ten years after exposure and continue to appear over the lives of those individuals who were exposed. Another large ef fect in terms of numbers is genetic defects. Tr.11,212. Water contaminattun 2

has been estimated to be a small fraction of the air contamination on a point estimate basis. However, contamina:Lon levels abovat EPA standards could con-tinue for a long period--up to $3 years in the most estreme case measured -- as a result of long term term run-off of contamination from the soil into the watersheds. We Jo not know the levels of contamination in the first month after an accident. Tr. 12.171. .

S. The City of Philadelphia participated in this aspect of the pro-ceeding. The City's litigation effort was directed toward trying to have '

available study results so that (a) the City officials, and the NRC could assess the potential risk to the City, with its relatively high population density and '

1 moderately prosisate location, and, (b) the City and thu NNC could assess and tactor into their decisionmaking, a full and reasonable range, of potential non-tamination and the associated probabilities for all accident sequences, weather conditions, and possible esposure levels (evacuation scenarios) and dose conver-l alon levels. In light of the record here so developed,the requirements of NEPA, and the on going state investigation into any potential benefits that might be associated with Unit No. 2's operation, the Commission will stay any l licensing of V' nit No. 2 pursuant to NEPA, until the Commission has available for further NEPA review the results of the Pennsylvania Public Ut!!!ty Commiselon's investigation, see paragraph 8 belt 4 i

!!. APPROPR!Att ANALYT1C FRAMRWONK FOR KVALUA110N 0F RISK IN THE NEPA CONTEXfl BENRF178 VERSUS ENVIRONMMNTAl. C00T8

6. "lRllsk acceptability is related to the benefit to the population incurring the risk." Tr. 11.475. This is not only analytically the appropriate frenework, but is also the requirement of NKPA. Calvert Cliffs' Coordinating

Committee. Inc. v. AEC, 449 F.2d 1109, 1113-4 (D.C.Cir. 1971). The Court'there held that NEPA requires a " balancing act." Any consideration of environmental impacts, or costs, sust be weighed, or evaluated. In the context of any benefits that would accrue from the federal action. One specific section of NEPA requires the responsible federal official to include a " detailed statement" on "the relationship between local short-term uses of man's environment and the

. maintenance and enhancement of long-term productivity ...." 42 U.S.C.

54332(2)(c). Here we munt examine the efficacy of the proposed short-term uses of the environmenta, that is, Unit No. 2's operation, to determine whether the proposed action does provide a benefit that might offset P.he potential severe environmental impacts.

7. The Staff did present an updated estculation of the economic bene-fits associated with the operation of both units. FES,.6-1 d 3 The Staff stated that this was not a "[nleed for power leeue." FES, 1-S. Rather, the Staff indicated this was an " economic" analysis. 1,b i,d . The analyses were entremely abbreviated and should be greatly espanded as to Unit No. 2, albeit not by the 8;aff here, until the issue has been fu11y examined by the ,

Pennsylvania Public !!tility Commission. See paragraph 26, infra. f However, this issuewascorrectlyraisedagelnatthisstagebytheStaff. The Commision by its rules did not intend to bar the NRC Staff's initiative (or its own) as to need for power or economic consideration at this stage of the licensing process.

8ee Need for Power and Alternative Energy leeues, Final Rule, Response to Comment No. 4, 47 Ped. Reg. 12940,41 (Narch 26, 1982). Such is properly the posture of the ataff as it le the Commission that is charged with assuring that NEPA's mandate is fulfilled. Re enamination le justified here, in part,'because 4

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, of the vastly changed circumstances in the energy environment since 1974 when 4

the que'stion was last determined by the NRC. As to Unit No. 2, which is not even currently planned for operation until 1990, Philadelphia Electric Company, Annual Report, 1983, p. 33, these conclusions fail to provide a basis for a full and adequate NEPA analysis. Even the abbreviated recent analysis in the 1983 DES and the FES, must be greatly expanded and subjected to full consideration. Conservation, load management, co-generation,-uprating of existing plants, solar, and other alternative energy sources have not been con-sidered. These options are not only considered viable today, whereas in 1973 the experience was more limited, but they are an integral part of the Nation's energy policy. See National Energy Act of 1978.

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8. 'As importantly, the Pennsylvania Public Utility Commission, the state regulatory body that examines issues of need and econonics, has recently initiated an investigation into any potential benefits that operation of the second unit'may offer the public. See attached Motion Re: Order To Show Cause Why The Construction Of Limerick Unit II Is In The Public Interest, July 6,1984

(slip op.), signed by a majority of the Commissioners. That motion indicates that this body will examine w' aether the plant is needed for reliability purposes and whether there are less costly alternativds to Unit No. 2. These results are

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precisely of the. nature that need to'be weighed in,the balance with the environ-x .

mental impacts measured here. For this reason \we will stay any decision con-cerning-1 censing cf Unit No.;2 until that'inesstigation is complete.

. s . _

.III. ~ DESCRIPTIOli OF THE COMPLEX AND UNCERTAIN -

EISK ASSESSMENT METFODOLOGY AND PROCESS

1. V A.' Ifist'ory

of RisiU A3sessment N

9. Risk asses'veents is a compleisn'aurtakisg. ~ ,

Th[last generic study commissiEuedbythnAECwasissuddin1975(WASH-ldOO). Thattstudy, the result

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of the efforts of sixty specialists, consisted of eighteen volumes. In 1979, the then NRC Commission accepted the criticisms and appreciation of the Reactor Safety Study as proferred by a review group in the " Risk Assessment Review Group Report." EP Regulations at 9356. The analysis that was done here relied in large part on the basic WASH-1400 study, with site specific and other revisions. -

s B. Risk. Assessment Methodology

10. In very general terms, " risk" can be broken down into two com-ponents: the probabilities of accidents and the associated consequences. The basic areas of input that make up risk assessment are:

a) the probabilities of accidents; b) the degree and nature of release into the atmosphere; c) the probabilities of relevant weather con-ditions; d) the level, location and activity of popula-tion; e) the conversion of dose to health consequence. .

11. More specifically, the NRC Staff has calculated the probabilities of various types of severe accidents. These probabilities are a function of the causes of severe accidents, e.g., system failures, earthquakes, etc. The Staff also attempted to determine, once a failure occurred, what would be released into the atmosphere. This result is a function of various factors such as the l amount of plating out of radionuclides in the plant, the level of degradation'of core, the status of the containment structure, etc. These are called " source 6

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terms." Included in the measurement process'are the probabilities of various weather conditions, i.e., wind direction, atmospheric dispersion, cloud deple-tion, precipitation, and ground contamination (FES, 5-78). Also input,are l i

' assumptions as to level of exposure of the population, given any one option in ,

l the three above-described categories of variables. The level of population exposure is a function of the exposure period, the population density level and the type and proportions of human activity during the exposure period, i.e.,

indoors /outdours, types lof buildings with their associated sheilding values, ,

, situation of density of population in relation to cloud location, and evacuation scenario. Finally, once it is assumed there is a certain level and time period of contamination to a defined number of people, the consideration then is what level of health consequences will. result from a given dose of radiation. This factor is called dose conversion factor.

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! 12. For each of the 15-20 " release categories" or accident types ana-lyzed by the NRC, hundreds of computer runs are done for 91 different " start times" for weather conditions and, in turn, assuming three different exposure levels / evacuation times. Given the number of release categories analyzed under many varying weather conditions, there are thousands of resulting values. As

stated above, these results change as a function of the assumption as to eva-cuation time / exposure level. In cammary, one will have a range of possible con-sequences which range is a function of release category, weather, population and, ultimately, dose conversion factors. Each of these results has an asso-ciated probability of the type (release category) of accident occurring and the probability of the weather conditions (wind direction, atmospheric dispersion, precipitation in relation to population density). Tr. 11,629. These results 7.

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range from the most extreme within each release category (worst weather, high density population and highest exposure / slowest evacuation time, most sensitive  ;

, conversion factors) to the most moderate.

C. Uncertainties

13. The record in this proceeding has shown that the process of assessing the probabilities and consequences of severe accidents contains many uncertainties, is based on limited data and contains many judgments. Tr.

11,181; 11,286. The codes have been validated through theory, not actual experience. Tr. 11,171. Different codes have been compared to one another.

Tr. 11,171. The only experimental date used in the models is the atmospheric dispersion model, Tr. 11,175, and there still are uncertainties associated with that mode. FES, 5-112. A reasoned evaluation of environmental impacts here is with an awareness of these limitations. Quantitative computerized results can easily take on a level of. validity that we would not so readily attach to the judgments, estimates and equations that form the tasis of tbt computer models.

14. The uncertainties in this analysis, according to the Staff, are primarily created by how little is known about how to quantify the human error element, the limited data base on failure rates of individual' plant components, the limited data base on external causes of accidents, and the lack of knowledge as to the accident scenarios at the plant (quantity and chemical form of radioactivity released). FES, 5-108 through 5-110 and Tr. 11,332-33; 35. There are also uncertainties, according to the Staff, due to modeling errors and

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uncertainties in the modeling of atmospheric dispersion, including the transport of radioactivity. To a lessor, but still substantial extent, there are uncer-tainties, according td the Staff, associated with duration and energy of 8

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e, release; meteorological sampling, emergency response effectiveness and other

' that will not be repeated here. FES, 5-112 through 5-115.

15. This range of uncertainties is estimated to result in " risk" values that may be too low by a factor of 40 and too high by.a factor of 400.

TR.ll,176. There remains a 5% chance that the values could lie outside the uncertainty range. Tr. 11,315. (The results, per se, are discussed in Section IV below.) The Staff witness testified that the uncertainty figure applies to the "overall assessment of risk from all accidents." Tr. 11,183. The witness further stated: "It does not apply when we use a specific sequence. It applies to overall risk estimat'es not to individual probability or consequence." Tr.

11,183. Staff witness Acharya stated that "you canot apply a risk uncertainty estimate to consequences only. It is to the product of the two and we have no estimate of the uncertainty of either, just their product." Tr. 11,861.

16. Howeve', r the Staff has quantitively broken down the areas of uncertainty to (1) probability quantification, (2) source term uncertainty and (3) consequence value uncertainty. Tr. 11,178. Initially, the Staff witnesses were unwilling to specify any weight to each of these three areas. Tr. 11,180.

Subsequently, the three separate areas of uncertainty were valued quan- ,

titatively, as follows: a) the projected probability value could be in a range of a factor 30, either higher or lower. Tr. 11,286-87, b) tne fractions of the radionuclides that are associated with the release categories could be higher by a factor of 3 or lower by a factor of 30, Tr. 11,28', and c) the conditional estimates of the consequences could be higher or lower by a factor.of ten, Tr.

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IV. QUANTITATIVE CONSEQUENCE AND PROBABILITY RESULTS

. . A. Staff Calculated Consequences For Airborne Pathway

17. The analysis done by the Staff calculated the conditional mean individual dose level at 20 miles, to be 13 rem. At 25 miles it is projected to be 8 rem and at 30 miles, to be 5 rem. Figure L. 15, FES. The total probabi-lity value is discussed in paragraph 3 above. These consequences are termed conditional mean values because they are conditional upon an accident occurring.

Many accident probabiIities are derived and each of those probabilities, which have a wide range all smaller than the one in ten thousand, are totalled to get the one in ten thousand estimate. While the total accident probability is one in about ten thousand reactor years, the conditional mean consequence value is not associated with any one accident. These are simply the average consequence values derived if.all accident sequence consequences values (themselves an average of results associated with a difference weather scenario) are summed and that total is divided by-the num'ber of accident consequences examined. To get person rem and then latent fatality values for the City, these values can be derived in rough terms by multiplying the mid-point value of 8 rem times the A City of Philadelphia's population of 1.7 million. Tr. 11,689. The resulting person rem exposures is 13,600,000 person rem. Computerized results would be somewhat different depending on where individuals are located in relation to the contamnation. This result would not give Philadelphia's tail end. values. Tr.

11,689. From the record here, one "could not derive the range of consequences and probabilities to citizens of Philadelphia in terms of health ef fects." Tr.

11,848.

18. Utilizing 400 cancer deaths per 1 million person rem, the upper 10 l

end of the dose conv6rsion range, Daebeler et al. at 48, the conditional mean latent-fatalities are 5,440. If an assumption of 140 is used, the result is 1,904 latent fatalities. If it is thought appropriate to reduce the health i effects because the exposure levels are below 30 rem, these calculated results would be divided by 5, for 1080 and 388, respectively. The dose distance curves do not- reveal peak values. For these results to occur the wind would have to be blowing in the direction of Philadelphia. The wind direction from the plant is toward Philadelphia 27% of the time.

19. PECO presented average calculated individual doses, conditional upon the occurrence of an accident. (2.4 x 10-5). Daebeler, et al., Figure 2.

At 21 miles, the projected life time site probability is 1/62,000 at 30 rem and

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1/32,500 at 5 rem. Daebeler et al. at Table 9. These results assume' normal ac.tivity for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

20. The Staff, in testimony, examined one of the most severe accidents with the lower projected probability value. That case was II-T/WW with a proba-bility of 1/500,000. Adding the two probabilities (for the, accident and wind toward the E and ESE sectors) associated with this accident sequence, results in a 5 x 10(-7) projected probability value. Hulman et al., May 16, 1984 at 24.

This projected value, adjusted for the site (2 units, 40 years), is 1/25,000.

The mean or average projected conditional consequence value for the entire popu-lation associated with this sequence is 18 million (SE sector) and 13 million (ESE Sector) person-rem. The Staff calculated the expected health consequences to be 1,100 and 800 latent cancer fatalities, respectively. Latent fatalities

, occuroverh;helivesoftheindividualsexposed. This reflects the base value

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of 60 cancer per mi1 lion person rem. Tr. 11,865. A value of 400 is toward the l

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' upper of the'. range of uncertainty on this relationship. Daebeler, et al., at l

48. In calculating health effects, the Staff also reduced'the expected health I consequence by 80% as a result of their optimistic view of the health effects of low level radiation. Tr. 11,863. ,

21. As shown in City Exhibit No. 2, the calculated potential exposure from this accident sequence at 22.5 miles (interval 19) ranges from a ri h k Peak value of 100 rem (with a .22% chance) to a low of I rem (97.8% chance). Thus peak values can be substantially higher than mean values:  ?

Table 1, infra, portrays the NRC's study results in terms of a range of projected mean' latent fatalities within 50 miles and the associated pr:babili-ties. These figures are derived from the FES, Figure L.6, and are descr#. bed below. Column (1). The consequence values are based on dose conversio. values of 60-140 latent cancer fatalities per million -person rem, Tr. 11.Pf2 68, plus a

! further reduction by a factor of 5 (80%) for exposures that are below 30 rem.

Tr. 11,863 According to the NRC a range of 10 to 500 cancer fatalities per million person rem is shown in the literature. FES 5-67. Comparative con-sequence codes have resulted in differences that range by a factor ot 10.

Tr. 11,474-75. Column (5). The consequence values are adjusted for the Staff's uncertainty factor of 10. This uncertainty range includes the possible higher

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latent cancers per million person reu conversion factor plus other unspecified causes of uncertainty. Column (2). This shows the average probabilities asso-ciated with each average consequence value, stated in terms of one reactor for one year, i.e, "per reactor year." These are mean consequence and probability values in that health consequences associated with all weather scenario results

are averaged. Thus these results do not state the full range of consequences.

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TABLE 1 NRC's Calculated Latent Fatalities Within a Fifty Mile Radius, Using bl40 Cancers Per Mf.llion Person Rerus and as Adjusted for Uncertainty Factors Latent Canceh Base Case Mjusted for Probability Excludinc Thyroid Prnhahi1i ty 2 Units, 30 Mjusted for Consecuence Within.50 Miles, Per Reactor Years of hhty value, Mjusted Using NRC Values Year Operation Factor of 30 for Uncertainty

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(1) (2) (3) (4) (5) 10 1/14,285 1/238 1/8 100 100 1/25,000 1/416 1/14 1,000 1,000 1/100,000 1/1,666 1/56 10,000 10,000 1/10,000,000 1/166,666 1/5,555 100,000 15,000 1 /100,000,'000 .1/1,666,666 1/55,555 150,000 20,000 l /555,000,000 1/9,250,000 1/308,333 200,000, i G

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Single peak values could be many multiples of the mean values. See City- Exh.

No. 2. Column _(3). This adjusts the probabilities to reflect the total proba-bilities associated with the site (2 units) during an expected 30 year lifetime.

Column (4). Multiplication of the probability value by the Staff's estimated uncertainty factor gives a bounding range of the highest possible level of pro-bability. Tr. 12,075. (There is still a 5% chance the probability could be outside of this bounding range.)

B. Calculated Water Contamination

22. The Staff assumed that about 50% of the City is suppIled from each river and that about six days' supply was available in the existing system.

This was based on an assumption that conservation measures could be enforced and on the availability of 1.121 billion gallons of filtered water storage and 503 million gallocs of untreated and in process water (86.2 mg. at Belmont, 177 mg.

at Queen Lane and 176 mg. at Baxter). The Staff assumed that 7% of the City's consumption level, in the Belmont and Roxborough high service districts, could not immediately be met by the Delaware, but that with storage capacity and other alternatives, individuals residing in those areas would never consume Schuylkill sater if that watershed were ever contaminated. It was assumed that strontium-90 and cesium-137 contribute to 90% of the dose and all other radionuclides the remaining 10%. Lehr at 6. It was also assumed that the greatest long term conce.rn was strontium-90.

23. There have been a wide range of experiments 1 study results in terms of percentage removal of strontium-90 from water. Lahr at 7 et seq'.

Removal levels appear to be a function of treatment process and contamination.

l Results range from 0% to 75% for alum ferrous sulfate plus time treatment. In 13 l

l

Y order to maximize contamination removal, any such treatment facilities would

~

have'to be modified so that the water can be treated with lime-soda softening twice. This would reduce the treatment system's through-put in half.

24. Reduction of contamination in the Schuylkill River to EPA levels of 8 picocuries/ liters for almost all of the cases analyzed would not be

possible at all in the first year. Thus the asssumption that the Delaware can supply-all of the City for at least a year and in some cases 20-50 years is cru-4 cial. Similarly, the immediacy of providing service to high service territory is a large factor in determining the dose levels to that population. It was 4

assumed here that the high service territory would not consume contaminated Schuylkill water, but would be served by alternative means.

25. The Staff approached the water contamination issue by making an analysis of one relatively lower probability and relatively higher consequence accident scenario. This particular accident sequence's proability of occurrence is 1/500,000 for one unit for one reactor year. Acharya at 13. The site and lifetime adjusted probability is 1/8333, with no adjustment for uncertainty.

26. According to the Staff, under the assumption that this accident scenario has occurred, "the Sct.uylkill River is likely to be highly contaminated 1

and there is a 50% probability *that the concentrations in the Delaware River following the accident would be less than 15 picocuries per liter (15 p Ci/1)." Wescott at 11. It is highly probable that contamination of the Schuylkill will exceed 8 picoeuries, for strontium, given this type of accident.

Tr. 12,173. If there is a deposition on the Delaware, there will"always" be a deposition in the Schuylkill. Tr. 12,154.

1

(; 27. The Staff calculated a 60% chance that Loth watersheds would be i

i 1

14

w 2.

contaminated. Wescott at 6'. If the highest expected depositions were to occur in one watershed, wind conditions would generally (probability unknown) preclude

' ~

similarly high depostions on the other' watershed. Acharya at 7. The Staff was not able to calculate in detail the interrelationship between both rivers for -

contamination levels and probabilities. Tr. 12,168.

28. It could take 53 years for Schulykill River contamination levels to reach 100 p Ci/1. Wescott at 16. There is a less than a 50% chance that after 30 years the levels of contamination will be at 100 p Ci/1. Achyara at 8.

However, there is a 13% chance that levels will be 100 p Ci/l after the imme-diate initial washoff period. Westcot at 11.

29. For the. Delaware River, the probability of virtually no con-tamination, assuming this accident scenario has occurred and given the NRC weather model, is 38%. There is a 50% chance that 15 p Ci/l will not be exceeded and a 85% chance that 100 p Ci/l will not be exceeded. Acharya at 10.

We have no figures on contamination levels in the first few months because of data availability limitations. Batram at 15-16.

30. PECO reviewed all accident probabilities and the associated mean consequences values together in their analysis in contrast to the Staff results that examined one accident sequence and looked at the chance of various doses, assuming the accident occurs.

31. PECO examined probabilities associated with an average annual con-centration of 96 p Ci/1. The predicted per reactor year values for the Schuylkill and Delaware were 1/300,000 and 1 in 7 million, respectively. Batram at 17. The adjusted 2 unit lifetime predicted values are 1/5,000 and 1/28,3,000.

The adjusted probabilities calculated to be associated with concertracions l

l .

15

, . - . . _ , , , - - - . - ,...r..- , - - - , . , - , _ _ , ,,,,..-.w,, , - , - . . . , . . - , - -,,,.,em.._g,y-. ~ ---.m,-

?

~ *f . , _ ', -

. reaching 8 pCi/1 are_1/1,000 and 1/6,000 respectively. Batram at Figure 4(a) and Figure 5(a). The calculcted probability of exceeding 8 p Ci/l in the two watersheds on a one month average basis (immediately subsequent to a sever

' accident), adjusted for two units, during their lifetime, were estimated to be 1

1/1,111 and 1/2,380, respectively. Ibid.

32. NEPA requires worst case analysis, especially if there are uncer-tainties in the analysis. Sierra Club v. Sigler, 695 F.2d 957 (5th Cir.1983).  ;

33. The FES conclusory results here were presented, discussed and com-pared to other adverse environmental impacts in terms of predicted " risk"

, values. FES, 5-98 et seq. A " risk" number in contrast to probability and con-sequence values are without any understandable meaning to decisionmakers. The l

conclusions of the NEPA should be in a form easily understood by public offi-i .

cials. 40 C.F.R. 51502.8. Risk values also do not portray the relationship

, between probabilities and consequences. Tr. 11,631. The CCDF curves, which do

portray probabilities and consequences separately, contain mean or average con-sequences values for all accident sequences examined and all weather conditions (average of consequence results associated with 91 weather condition start times). Thus, they do not show peak values. (Nor do they,show uncertainty bounds, see paragraph 34 below.) Table K.1 in the FES shows projected average I consequence values for each release category listed on Table 5.11(d) separately, in contrast to CCDF curves. Tr. 11,285. However, each of these are averaged values derived from results associated with each of the 91 weather sequence start times. Tr. 11,285. Dose distance curves, as also presented in the FES, do not show peak values; they are graphs of mean individual exposures. Tr. ,

- 11,834.

l 16

, y- -,-,---,v.---,- --,,,,.-.--.,.nym,-,.ve- -, -wyve , r 7 y v - w~-,,, ,w--,g 2-3,w.y. ,.p.ws,*,mi-,----,,,,----r,.my,-,--,,c. ,,- - , - - .g, , .y- -nv.+y---,-w-%,-,,,tw-.r-

l

34. The Staff witness, Acharya, stated that CCDF curves'normally

'" reflect the uncertainty of the estimates upon which the CCDF was constructed, by showing an upper bound and a lower bound." Tr. 11,216. A single CCDF curve does not display the range of uncertainty. Tr. 11,315. These uncertainty bounds were not portrayed as integral to the CCDF curves presented in the FES,

35. The Staff "did not examine the individual frequencies with the high or low probability that would result in high doses beyond the ten mile EPZ." Tr. 11,692. Nor did the Staff's analysis measure "the range of the pro-bability of events which would result in high doses substantially beyond ten miles." Tr. 11,693.

36. Table L.4 shows a jump in risk at distances that are covered by i Philadelphia. Tr. 11,675.

37. To the extent the CRAC's random methodology fortuitously captured a bad weather scenario, see paragraph 38 below, those consequence results are obscured by the averaging process that forms the basis of Table K 1.

38. The 1976 data base that was used in the CRAC analysis might not contain the worst meterological sequence. Tr. 11,766. It is more likely that CRAC (random sampling) compared to CRAC 2 (binning) would miss very bad weather conditions, although both could miss it. Tr. 11,673. There is no assurance that rain beyond ten miles is picked up by CRAC. Tr. 11,685.

l 39. The Staff attempted to approximate bad weather by use of 91 weather samples, Tr. 11,745, and by considering an emergency response mode that l is slower enan the base case. Tr. 11,744. Weather sampling has been discussed above. The Staff has also indicated bad weather would af fect the tail end l .

l

, 17

, -r,---_ __v-- - - , - - - - - - - , , ,n+.,,-----,-,---w-,-,----,,.-,,-,e-,, -

- - - - ~ - - , , , - - - - - , , , .- , , - - - , - -

s

. . l values. Tr. 11,745. That is, peak values would be higher. Finally, the Staff witness testified that, at any rate, the 40 uncertainty variable bounds bad 1

weather effects. Tr. 11,746.

40. The problem remains of bounding the effects of slowed evacuation due to possible back-ups as evacuees might approach the City area. The Board can envision a situation wherein evacuees move toward Philadelphia in order to escape the plume and the direction of the plume changes. There is no credible evidence on this record of!the ability to overcome the difficulties associated i

with knowing the precise direction of the wind and the location of the plume at these distances from the plant at all times, or being able to notify all l evacuees of such, given the myriad road network, large members of evacuees and

limited monitoring device. We are not convinced that modeling more people, eva-i cuating at the same rate, as did the Staff at pp. 15-17 of Hulman et al.,

May 16, 1984, fully reflects the difficulties here. At any rate, however, the

$ uncertainty range covers this effect and we consider heavily this uncertainty i

• range in our conclusions.

j 41. The analysis done by the Company showed a doubling of " risk" asso-

! ciated with slowed evacuation time. Tr. 11,631. This result does not indicate j the level of increase in consequences and the associated expected probability 1 -

value.

Tr. 11,632.

I V. CONCLUSIONS OF LAU i

! Based on the foregoing Findings of Fact, which are supported by j reliable, probative and substantial evidence as required by the Administrative Procedure Act and the Commission's Rules of Practice, and upon consideration of i the entire evidentiary record in this proceeding, the Board reaches the l

18 l .

(

. ~ . _ . , - - .-,u-_-~._---_._,__-.____,._____,-,_.-~.u_.___.

.- 4 ,

following conclusions pursuant to 10 C.F.R. I 2.760s:

1. The National Environmental Policy Act of 1970 ("NEPA") directed federal officials "to use all practicable means, consistent with other essential considerations of national policy," to protect the environment. 42 U.S.C.A.

54331. Consistent with that mandate, the Nuclear Regulatory Commission, prior to issuance of an operating licensing for both Limerick units, must fully disclose the environmental impacts of the units' operation and must factor into its_ licensing decision consideration of NEPA's mandate.

2. The inforastive uses of the environmental impact study are to provide information to the general public and public officials at all levels of government, 40 C.F.R. 51500.1(b), and to provide the basis for an informed deci-sion on the part of the NRC. Sierra Club v. Frcchike, 345 F.Supp. 440, 444 (W.D. Wis. 1972), aff'd 486 F.2d 946 (7th Cir. 1973). On this count the study must be reasonably thorough and must take a "hard look" at the environmental consequences. Kleppe v. Sierra Club, 427 U.S. 390, 410, n.21 (1976).

3. NEPA does not mandate inform'ational requirements only, however.

NEPA injects environmental considerations into the decision making process itself. Weinberger v. Catholic Action of Hawaii, 454 U.S. 139, 143 (1981). An essential element of decision making is whether alternatives should be con-sidered in light of any benefits of the action in relation to the measured environmental impacts of the action. 42 U.S.C.A. 54332(2)(c)(iii).

4. In keeping with the National Environmental Policy Act, 40 CFR 1502.22(b) and the Commission's Environmental Protection Regulations, 49 Fed.

Reg. 9352, 9347 (March 12, 1984), the Board has considered a full range of both the probabilities of various accident scenarios and their associated consequen-i 9

19

+

i 1

ces. .Given the developmental' status of these types of analyses and their high degree of uncertainty, a reasoned approach is to review and consider this range,

including the calculated uncertainty range. We have considered on this record a reasonable range of dose conversion factors, exposure levels (protective action effectiveness), bad weather, and the probability calculation uncertainty range.

]. Although upper bound results were not portrayed here in every instance, we.have

i.  ;

compensated for that lacking by giving greater weight to the uncertainty range, '

especially the upper bounds.  ;

5.

• Based on our consideration of this record in the above describel ,

l framework and what has been thereby disclosed in terms of the environmental i l impacts of potential severe accidents and the uncertainty in measuring botn the j probabilities and consequences associated therewith, we conclude that further f NEPA assessment in terms of weighing environmental costs versus benefits of the j project is warranted for Unit No. 2. A stay by our Commission of any deter-mination of licensing of Unit No. 2, in terms of the acceptability of environ-mental impacts, is appropriate for the following additional reasons:

1 (a) The pending availability, for NRC review, of I

i. the Pennsylvania Public utility Commission's investigation results will precisely focus on

! and develop the economic issues associated with Unit No. 2's potential operation.

j (b) Unit No. 2 is only partially completed, with ,

in-service not scheduled until the 1990s. A I l stay of licensing now will not have the

construction scheduling impact associated with l e,uch a stay for a nearly completed plant.

[

l

(c) There have been vastly changed circumstances j since 1973, when this issue was last examined l . by the Commiss' ion in an adjudicatory context. l These changes will affect the economics of the plant's operation. Also the partial nature of ,

I construction completion will affect the econo-

\ -

i.

I 20  !

l

. _ . . _ _ _ _ _ _ _ _ . . . _ .. __ _ __ _ _. - _. _ ... _ ._-_ ~.. _ . _ _ , _ . . _ .

alc analysis when comparing Unit No. 2 to alternatives, in contrast to comparing ths

+

economics of a completed plant to the econo- .

mics of alternatives.

(d) The lack of previous consideration at the construction stage of conservation,_cogenera-tion, etc., as alternatives also compels reconsideration. Conservation, good manage-ment, cogeneration, and rate structures to promote efficient use of production are now an-essential component of the Nation's energy policy. National Energy Act of 1978. They are no longer viewed as " remote and specula-tive" possibilities.

In conclusion, before doubling the potential for the public's exposure to these

~

environmental impacts in such a high density population area, NEPA requires us, as federal officials charged with the protecting environment, to stay a decision on Unit No. 2 until the Pennsylvania Pennsylvania Public Utility has completed its investigation.

9 e

4 6

9 9

21 l

I i

. . ,1 e'~

e ORDER WHEREFORE IT IS ORDERED, that this Partial Initial Decision shall becomeeffectiveimmekistelyandshallconstitutewithrespecttothematters decided herein the final action of the Commission forty-five (45) days after the date of issuance hereof, subject to any review pursuant to the Commission's Rules of Practice.

h A notice of appeal may be filed any party within ten (10) days after service of this Partial Initial Decision. Within thirty (30) days after service of a notice of appeal (forty (40) days in the case of the Staff), any party filing a notice of appeal shall file a brief in support thereof. Within thirty (30) days of service of the brief of the appellant (forty (40) days in the case

of the Staff), any other party may file a brief in support of, or in opposition i

to, the appeal.

IT IS SO ORDERED.

i i

THE ATOMIC SAFETY AND LICENSING BOARD Judge Lawrence J. Brenner, Chairman Judge Peter A. Morris, Member i

j Judge Richard F. Cole, Member I -

i .

1 O

i 22

. 3 J .. .

e , ~-- .

?.

Public Meeting July 6, 1984 MOTION RE: ORDER TO SHOW CAUSE WHY THE CONSTRUCTION 07 LIMERICK UNIT II IS IN THE PUBLIC INTEREST On October 10, 1980, this Commission entered an Order at docket number I-80100341 initiating an Investigation into the need for, and economy of, the Limerick Nuclear Generating Station of Philadelphia Electric Company (PECO). At the end of the Investigation, the Commis-sion concluded that the simultaneous construction of Limerick Units I and II would not be in the public interest because of PECO's precarious financial condition and the effect that the continued construction of both units would have upon PECO's ability to, provide safe and reliable

- service. PECO was given the option of either cancelling Unit II, or suspending Unit II until Unit I was completed; however, if PECO refused to suspend or cancel

• Unit II, the Commission would not approve any future securities issuances to raise capital for construction of Unit II.

The Commission's Order was reversed by the Commonwealth Court but was upheld by the Supreme Court of Pennsylvania. Pennsylvania Public Utility Commission v. Philadelphia Electric Co., 501 Pa. 153, 460 A.2d 734 (1983). After the Supreme Cou'rt decision, PECO indicated that it in-tended to suspend Unit II until Unit I was completed, and then resume construction.

Recent developments have raised anew grave concerns regarding PECO's ability to provide adequate service at reasonable rates. PECO i

filedforageneralrateincreaseonApril27,ld84,andhasalready announced its intention to file for another increase after Unit I W___._________.-_.__.______-________.-_

g a . ~. -.

r u o comes on line in 1985. The amount of human suffering that these in-creases could cause is deplorable. The spectre of these rate increases also threatens to further undermine the economic climate in Southeastern Pennsylvania. Indeed, recent attempts by the Scott Paper Co. to generate its own power and sell the excess to PECO, and by Luken's Steel Co. to obtain power from Pennsylvania Power & Light Co, are both attributable in part to the high level of PECO's current rates. Future rate increases can only accelerate the efforts of industrial customers to either seek alternative sources of power or to move out,of PECO's service territory.

Unit I is scheduled to be completed in April 1985. At that ,

time, PECO could resume const'uction r of Unit II. In light of vecent developments, however, we are concerned that the impending construction of Unit II might not be in the best interest of PECO's ratepayers.1/

Therefore, we should order PECO to show cause why the construction of Unit II is in the public interest. Specifically, this proceeding should address the following issues: #-

1. Is construction af Unit II necessary for PECO to maintain adequate reserve margins?

2. Are there less costly alternatives - such as cogeneration, additional conserva-tion measures, or purchasing power from neighboring utilities or the P.J.M.

interchange - for PECO to obtain power cr decrease consumption?

3. How will the large capital requirements necessary to complete Unit II affect PECO's financial health and its ability to provide adequate service?

-1/ We are also concerned whether PECO's current bond rating of BAA3, which means that PECO's bonds have speculative characteristics, might drop further if PECO resumes construction of Unit II when Unit I is completed.

i l 'o w e

4. Shtuld tha _Commic21cn rajset cny cccuritise '

o filings, or impose any other appropriate remedy, to guarantee the cancellation of ".,

Unit II? ' '-..

5. If Unic II is cancelled, what, if any,  %

Percentage of the sunk costs should PECO L.,

be permitted to recover from its rate-payers?

6. If construction of Unit II is found to be in the public interest, should the Com-mission adopt an " Incentive / Penalty Plan" as an inducement to cost efficient and timely construction?

We believe that our duty to guarantee just and reasonable rates and to maintain adequate service require that the above issues be addressed by all affected parties and resolved by the Commiss. ion prior to April 1985, the date upon which construction of Unit II could resume; T m EFOP.E, WE MOVE:

1. That the Philadelphia Electric Company be ordered to show cause why the completion of Limerkek Nuclear Generating Station, Unit II, would be in the public interest.

2. That the Law Bureau prepare the necessary Order to Show Cause.

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