ML20213A048
| ML20213A048 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 01/24/1987 |
| From: | Kaufmann R NEW HAMPSHIRE, UNIV. OF, DURHAM, NH |
| To: | |
| Shared Package | |
| ML20213A026 | List: |
| References | |
| OL, NUDOCS 8702030073 | |
| Download: ML20213A048 (5) | |
Text
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i AFFIDAVIT I,
the undersigned Richard L.
Kaufmann, being duly sworn, do hereby depose and'say as follows:
1.
I am a Professor of Physics at the University of New llampshire in Durham, New Hampshire.
2.
I hold a B.S.
degree in chemistry from the California Ins t i tute of Technology (1957) and bothyan M.S. and Ph.D. In chemis t ry
.f' rom Yale University (1958 and 1960).
t 3.
I am a member of both the American Physical Society and the American Geophysical Union.
4.
~The 1-mile Plume Expos ~ure Pathway Emergency Planning Zone (PEPZ) proposed;for7Seabrdok Station does not meet eriterla in the
- rationaleDwhich underlay the original decision to require a generie 10-mile zone.
A.
The Firsh, Rationale:
De' sign ' Basis Accident (DBA) analysis.
Us i ng t h'e o r i g i n a l NUREG-0396' methodology, the Seabrook Emergency Planning Zone Study (SEPZS) concludes that even the upper, or' 25 rem Protective Action Guide (PAG) for thyroid exposure is exceeded beyond the 1-mile PEPZ~(page 16'of Applicant's Memorandum in-Support of their Petition (Memo r a n dudi) ).
NUREG-0396 (page I-5 and Figure I 7) showed that none of t h e' '12 9 plants analyzed using this me t hodo'l ogy. exceeded the upper - PAG level at a 10-mile PEPZ boundary.
As a result, Scabrook Station, with the proposed 1-mile PEPZ, would present the highest risk'.of any plant in the country at the PEPZ boundary, using NUREG-0396 meth6dology for the DBA analys is.
The Memorandum states.that if'the methodology is changed
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to be dmore realistic but nevertheless conservative", that even the lower thyroid PAG is met at t he 0. 5'68 mile s i t e boundary (Memorandum y
' pages"17-18).
At least some'of the new methods are not conservative a'
(zero time delays for fully effective filtering and iodine removal)
}
and more impor tant, the use of 50% melsorology directly violates the stated purpose for which the rule was adopted.
"The EPZ recommended is of suf ficient size to provide dose savings to the population in areas where the projected dose from design ba s, i s accidents could be expected to y
exceed the applicable PAGs under unfavorable atmospheric conditions."
NUREG-0396 page 16.
" Assumptions used by the NRC staff to assess conformance with these regulations"..."the resulting fractional m
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release to the atmosphere is assumed to occur at ground level under extremely unfavorable dispersion conditions, i.e., under conditions such that the calculated dose for the given fractional release would not be exceeded more than five percent of the time at the site under review" NUREG-0396 pages I-13 to I-14.
" Inherent in the consequence calculations for the pos t ul a t ed DBA-LOCA i s t he presump t i on o f ' f i ve percen t il e '
meteorology" NUREG-0369 page I-26.
Acceptance of the proposed 50% rather than the previously accepted 5% meteorology would permit a ten-fold increase in the probability that weather conditions.would be unfavorable enough to exceed the estimated exposure doses.
In fact, it has previously been noted that no plants exceed even the lower range PAG outside the Low Population Zone (LPZ) for average (50%) meteorological conditions (NUREG-0369 page I-5).
B.
Rationales 2 and 3 "less severe" and "more severe" class 9 accidents have been combined in the Memorandum to the extent that both compare doses to those in Figure I-11 of NUREG-0396 (page I-33). Figure I-11 is prepared for a range of RSS release categories, and may be comparable to the analysis in the Seabrook Station Risk Management and Emergency Planning Study (RMEPS).
However, it is very speci fically s tated that one of the purposes of a PEPZ should be to " provide for subs tantial reduction in early severe health ef fects (injuries or deaths) in the event of the more severe Clsss 9 accidents."
(NUREG-0369 page 17).
Other restatements of this criterion are:
" Studies have been performed which indicate that if emergency actions such as sheltering or evacuat ion were taken wi thin about 10 miles of a power plant, there would be significant savings of early injuries and deaths f rom even the most ' severe' atmospher ic releases."
(NUREG-0369 page I-7) and "that certain features of the more severe core-melt accidents should be considered in planning to assure that some capability exists to reduce the consequences of even the most severe accidents."
(NUREG-0369 page I-9).
The analysis in NUREG-0396 separately considers the less serious " core melt-through" and the more serious " atmospheric" accident classes (figures I-15 and I-16).
"The upper range of the cor e-mel t _ acc i den t s is categorized by those in which the containment catas t rophically f ails and releases large quan t i t ies of radioact ive materials directly to the atmosphere because of over-pressurization or a s team explos ion."
(NUREG-0396 page I-6 ). Wi th respect to these most severe (atmospheric) accidents, Figures I-17 and I-18 show that "Most early fatalities resulting from ' atmospheric' accidents are projected to occur within approximately 10 miles of the reactor, while early injuries are likely out to somewhat larger distances."
(NUREG-0 396 page I-49 ),
and tha t, as not ed previously, "i f emergency actions such as sheltering oc evacuation were taken within about 10 miles of a power plant, there would be significant savings of early inj ur ies and deaths f rom even the mos t ' severe' atmospherie releases"
-(NUREG-0396 page I-7).
The pet it ion and support ing documents do not provide curves that can be compared with the NUREG-0396 Figures I-16, I-17, and I-18 for injuries and f atalit ies given the most serious " atmospheric" class of release. The statements that a 10-mile PEPZ is unnecessary, would not serve its intended purpose, and would accomplish no health and safety purpose therefore are not supported by the petition.
C.
The fourth rationale for selecting a 10-mile PEPZ is that " detailed planning within 10 miles would provide a substantial base for expansion of response ef forts in the event that this proved necessary" (NUREG-0654 page 12).
An expansion of the response into Massachusetts will require involvement by Massachusetts officials in'the planning effort.
Since the 1-mile PEPZ is entirely within New Hampshire, the possibility of ad hoc extension of the emergency zone would be seriously degraded by acceptance of the proposal.
Massachuset ts would be impacted by the mos t ser ious accident category (the category for which an ad hoc expansion is required) so that the four th rat ionale requires the PEPZ to include both New Hampshire and Massachusetts.
If an ad hoc expansion or an evacuat ion beyond 1 mile is taken for any reason (see item 3 below), the 10-mile PEPZ will serve health and safety purposes, contrary to statements in the petition.
5.
The principal conclusion of NUREG-0396 was to establish a generie approximat ely 10-mile PEPZ for all nuclear power plants, and not to use the rationales cited above as specific criteria that each plant should meet in the smallest possible site-specific PEPZ.
The following statements illustrate this intent:
"In relation to emergency response an EPZ is an area in which best effort is performed making use of existing emergency plans and is not an area in which particular criteria must be met."
NUREG-0396 page 27.
" Radiological emergency planning is not based upon probabilities, but on public perceptions of the problem and what could be done to protect health and safety.
In essence, i t is a mat ter of prudence rather than necess i ty."
j NUREG-0396 page I-2.
"While the Task Force recognizes that there are site-to-site variations in LPZs, due in part to varying features of the plant, the Task Force concluded that the size of the EPZs need not be site specific.
The principal reason for this is that the size of the LPZ is determined primarily by the type and extent of engineered safety features installed in the reactor plant and their response to design basis accidents. The loss of ei ther some or all engineered e
safety features are postulated in Class 9 accidents.
If the engineered safety features are lost during an accident, then the LPZ has no meaning with regard to the size of the areas around the plant in which emergency response would be appropriate.
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a "A. pr incipal aim in establishing EPZs is to foster a
- breadth, versatility and flexibility in response preparat ion and capabilit ies in a sys temat ic manner.
From the standpoint of general emergency planning guidance, emergency planning needs seem to be bes t served by adopt ing uniform Emergency Planning Zones for initial planning studies for all light water reactors."
NUREG-0396 pages III-7 and III-8.
6.
Past experience, such as the relatively minor release at Three Mile Island, shows that people will evacuate from distances well beyond 1 mile from a nuclear plant if a serious accident takes place.
Governors may recommend such action against the advice of the NRC, and a partial evacuation is likely to take place even if nearby state governors do not so recommend.
It is unrealistic to conclude that anyone could order evacuat ion of a 1-mile zone without simultaneously initiating an ad hoe evacuation of a much larger
- region, in the event of an emergency, those in charge of the public safety require the benefit of a 10-mile evacuation plan that has been thoroughly reviewed and is current.
It should be noted that the summer populat ion dens i ty within 2 miles of Seabrook Station is twice the highest density (permanent resident population was used) at any of the 91 sites studied in NUREG/CR-2239, and that roads are very limited considering this population density.
In the event that people evacuate for any reason, the existence of a 10-mile emergency evacuation plan certainly will play an important role.
The contention that'"The extra nine miles for Seabrook accomplish no health and safety purpose" (Memorandum page
- 25) _is in disagreement with actual experience during past events.
7.
In the event that the grant of permanent waiver or exception under 12.758 is determined to be inappropriate, the petition requests a grant of relief under 150.47(c).
The first criterion for granting such relief is that the deficiencies are not significant for the plant in ques t ion.
The previous statements show that a 10-mile PEPZ would provide a significant addition to the saf ety of people living in this extended zone in the event of a very serious accident or in the event that evacuation takes place for any reason.
The second eriterion is that interim compensating activities have been or will be taken promptly, but no interim plans have been proposed.
The final criterion is that there are other compelling reasons to permit plant operation.
The proposed other compelling reason is financial.
It certainly is true that past poor decisions by Public Service Company of New Hampshire (PSNH) of ficials have created severe f i nana ial probl ems. The f act that PSNH has been unable to make sound financial decisions is an inadequate reason to waive safety requirements.
8.
Based on the above, it is my opinion that the PSNH petition under 10 CFR 92.758 and 10 CFR 150.47(c) should be denied.
These statements are true and correct to the best of my knowledge.
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Dated:
January 24, 1987 Richard L.
Kaufmann STATE OF NEW HMIPSHIRE COUNTY OF STRAFFORD, SS Personally appeared the above-named Richard L.
Kaufmann and took oath that the above statements subscribed by him are true to the best of his knowledge and belief.
/bf I'
Notary Public
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