ML20239A105
| ML20239A105 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 08/28/1998 |
| From: | Charemagne Grimes NRC (Affiliation Not Assigned) |
| To: | Samuels S AFFILIATION NOT ASSIGNED |
| References | |
| NUDOCS 9809080208 | |
| Download: ML20239A105 (8) | |
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UNITED STATES I
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NUCLEAR REGULATORY COMMIS810N i
2 WASHINGTON, D.C. 30806 0001 August 28, 1998 I
Mr. Sheldon W. Samuels Vice President, Policy Studies The Ramazzini institute For Occupational l
And Environmental Health Research P.O. Box 1570
' Solomons Island, MD 20688
SUBJECT:
RELICENSING OF CALVERT CLIFFS NUCLEAR POWER PLANT
Dear Mr. Samuels:
Thank you for your letter dated June 24,1998. The NRC encourages public participation in its activities to ensure awareness of all the issues and to identify those of particular importance to the public. The Commission referred your letter to my office for appropriate action upon its receipt on July 23,1998.
Your comments pertaining to the license renewal activities for the Calvert Cliffs Nuclear Power !
' Plant are important to the environmental scoping process now in progress. The concems found applicable to license renewal, raised by you and others, will be considered as part of that
[
process for Calvert Cliffs. You have been included on the distribution list for the supplemental l
environmental impact statement (EIS) and will receive your copy when issued.
l Due to the breadth of your comments, some of your concerns and suggestions are outside the
[
scope of the EIS and the license renewal review of aging management programs provided in 10 CFR Part 54. We will generally describe the NRC's efforts on those other issues, and identify sources for additional information on those subjects, l
The particular concerns you raised regarding the adequacy of emergency preparedness for the Calvert Cliffs plant is a contemporary safety issue that is not unique to license renewal and for
- which the NRC relies upon cooperative efforts with the Federal Emergency Management L
Agency (FEMA) to maintain the emergency preparedness for all plants. Accordingly, this concern has been referred to the NRC's emergency preparedness staff for review and appropriate action.
Several of your other concerns are addressed, very broadly, by the structure of the regulatory i
requirements in the Code of Federal Regulations and the licensing process. Additional information about the NRC's licensing process for nuclear power reactors generally, and the license renewal process more specifically, can be found on the NRC's Internet site at http:Hwww.nrc. gov. Particular information can be obtained on the subjects of risk-informed and performance-based regulatory initiatives, emergency preparedness and response, spent fuel storage and high-level waste, and radiation protection standards.
Your letter specifically mentions your concem that license renewal "may pose a higher level of human risk". Your letter also includes more general concems regarding nuclear risk 9909000208 990828 PDR ADOCK 05000317 F
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O S. Samuels August 28, 1 08 assessments. The NRC is addressing application of risk assessments and risk management j
approaches separate from license renewal. The license renewal EIS supplement will specifically consider severe accident mitigation alternatives, but the NRC concluded when the requirements of 10 CFR Part 54 were established that the scope of the license renewal decision can be limited to managing aging effects for passive structures, systems and components. The limited review scope was based on a conclusion that the existing processes for monitoring and maintaining active systems and components are sufficient to maintain safe plant operation for the period of extended plant operation provided by a renewed license.
You described several concerns relative to workforce protection, general public health, and emergency response. The NRC continues to maintain particular regulatory requirements to ensure protection of the plant workers and the general public from exposure to harmful levels of radiation, and emergency preparedness requirements in the event of a radiological emergency.
The particular concern regarding the distribution of potassium iodide (Kl) to mitigate the effects of a radiological release is a current emergency preparedness issue, for which the Commission recently directed the staff to pursue a formal rulemaking.
Your concerns about economic risks involve matters that go beyond the NRC's statutory authority. Under 10 CFR 50.33(f), the NRC's responsibility for overseeing economic impact of a nuclear plant is limited. Similarly, while the EIS supplement has a limited review of alternatives to license renewal, broader consideration of alternative energy sources is a matter that is not within the NRC's authority. Additionalinformation conceming the implementation of l
a national energy policy and development of alternative energy sources can be obtained from the Department of Energy.
Finally, I would like to address your concerns about the NRC's ability to perform its function and your reference to the recent criticism of the NRC by Congress. The Commission has aadressed many of those concerns in testimony before both Senate and House subcommittees.
Nevertheless, additional efforts are continuing to improve the effectiveness and efficiency of our regulatory processes. Much of the Congressional criticism focused on excessive regulatory burdens on the industry, with particular comments on timely and focused license renewal reviews, rather than plant safety concerns.
Thank you for your comments, and your particular interest in the license renewal application for l
Calvert Cliffs and your general interests in the safe operation and emergency preparedness for I
nuclear power reactors.
I Thank you for your comments, and your particular interest in the license renewal application for Calvert Cliffs and your general interests in the safe operation and emergency preparedness for nuclear power reactors.
M 0y Christopher 1. Grimes, Director License Renewal Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation l
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President Mr. Joseph H. Walter, Chief Engineer Calvert County Board of Public Service Commission of Commissioners Maryland 175 Main Street Engineering Division Prince Frederick, MD 20678 6 St. Paul Centre Baltimore, MD 21202-6806 James P. Bennett, Esquire Counsel Kristen A. Burger, Esquire l
Baltimore Gas and Electric Company Maryland People's Counsel P.O. Box 1475 6 St. Paul Centre Baltimore, MD 21203 Suite 2102 Baltimore, MD 21202-1631 Jay E. Silberg, Esquire Shaw, Pittman, Potts, and 'Trowbridge Patricia T. Birnie, Esquire 2300 N Street, NW Co-Director Washington, DC 20037 Maryland Safe Energy Coalition P.O. Box 33111 Mr. Thomas N. Prichett, Director Baltimore, MD 21218 NRM Calvert Cliffs Nuclear Power Plant Mr. Loren F. Donatell 1650 Calvert Cliffs Parkway NRC Technical Training Center Lusby, MD 20657-4702 5700 Brainerd Road Chattanooga, TN 37411-4017 Resident inspector U.S. Nuclear Regulatory Commission David Lewis P.O. Box 287 Shaw, Pittman, Potts, and Trowbridge
' St. Leonard, MD 20685 2300 N Street, NW Washington, DC 20037 i
Mr. Richard I. McLean Nuclear Programs Douglas J. Walters Power Plant Research Program Nuclear Energy institute Maryland Dept. of Natural Resources 1776 i Street, N.W.
Tawes State Office Building, B3 Suite 400 Annapolis, MD 21401 Washington, DC 20006-3708 Regional Administrator, Region i Barth W. Doroshuk U.S. Nuclear Regulatory Commission Baltimore Gas and Electric Company 475 Allendale Road Calvert Cliffs Nuclear Power Plant
. King of Prussia, PA 19406 1650 Calvert Cliffs Parkway NEF 1st Floor Lusby, Maryland 20657 i
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Distribution Collins /Miraglia Travers Thompson Boger Norry Blaha Bums Knapp, NMSS I
Martin, AEOD l
Bangad. SP Miller, RI Cyr, OGC Sheron Roe Zimmerman -
Grimes NRR Mail Room (EDO#980462) w/ incoming PDLRRF iDocket,(50-21]f218) Wong. moommgj Lee Cooke Jolly Public EDO#G980462 EDO R/F L. Callan OGC OPA OCM SECY (CRC-98-0688)
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CONTROL NUMBER:
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SUBJECT:
Relicensing of Calver Cliffs Nuclear Power Plant NRR RECEIVED:
July 28,1998 eP.PE:z:::!:r.ni og PM : toe /
ACTION:
4 l
Please note that the attached green ticket is for APPROPRIATE l
ACIlON. Please review this item and determine whether or not your l
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l Return ONLY this completed cover sheet to the NRR mailroom, O E-7 by August 10.199B.
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.EDO CONTROL: G980462 DOC DT: 07/24/98 FINAL REPLY:
.Shsldon W. Samuels
- Ram 3zzini Institute for. Occupational and Environmental
-H2alth Research-l L TO s. -
Chairman ~ Jackson.
FOR SIGNATURE'OF.:
- GRN CRC NO: 98-0688
!DESC'$
ROUTING:
.. RELICENSING OF CALVERT CLIFFS-NUCLEAR POWER PLANT Callan Travers Thompson Norry Blaha Burns lDATE:'07/27/98-Knapp, NMSS Martin, AEOD
! ASSIGNED TO:"
CONTACT:
Bangart, SP Miller,.RI
'S'PECIAL INSTRUCTIONS'OR REMARKS:
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.For Appropriate Action.
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'? AUTHOR:
SHELDON!SAMUELS l
- AFFILIATION:
, ADDRESSEE:
CHAIRMAN'JACKSONi
" LETTER'DATE:
Jun 24'98 FILE CODE: ID&R 5 CALVERT CLIFFS
SUBJECT:
RELICENSING OF CAL; VERT CLIFFS NUCLEAR-. POWER PLANT ACTION:
l Appropriate ln
' '~DT%RIBUTION:
C \\IRMAN,-COMRS.
. SPECIAL HANDLINGi NONE-
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NOTES:
- DATE-DUE:
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' AFFILIATION:
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" R.,AMAZZ N INSTITUTE FOR OCCUPATIONAL AND ENVIRONMENTAL HEALTH RESEARCH P.O. BOX 1570 June 24, 1998 SOLOMONS ISLAND, MD 20688 3
. Shirley A. Jackson.
PHONE: (410l 326-2543 RW Dr 4
- ir FAX: (410) 3264808 US Nuclear Regulatory Commmission g
g ghington,DC20555 Re: Relicensing of Calvert Cliffs Nuclear Power Plant
Dear Dr. Jackson:
This memorandum is written at the request of local affected citizens. It is sent to you for inclusion in the record of any hearing on the question of the relicensing of the Calvert Cliffs Nuclear Power Plant, but also for direct consideration of the Commission because the issues examined here are broader than those within the scope of a public hearing on the relicensing of a single plant.
The burden of protection must not only be on the cor.pany and the plant. It is important to address the federal, state and local infrastructure essential to protecting human health, the environment, and our well being in general, in the management of the unforgiving technologies associated with the peaceful use of nuclear energy.
Public support for the use of nuclear energy in power generation assumes that the federal government would ensure the highest level of technical and moral capability of those in industry to whom society delegates stewardship. The Supreme Court [1] has provided guidance on how this level should be measured in terms of human risks, how to evaluate conflicting health, social and environmental priorities, and defined feasibility as the effective use of best available technology. The licensing procedure should answer the question of whether or not BG&E specifically has demonstrated by past performance that it met and can meet the performance of the most successful achievers of that standard.
The decision cannot be made, as the company may contend, simply on the basis of what will occur under projected optimally-controlled conditions in its continually revised mechanical process.
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Ouestions of Federal Infrastructure The Commission's enforcement and inspection capability, now being questioned [2], is the keystone in the federal infrastructure. If the Commission lacks the ability to fulfil its mission by reduction of its current capabilities, then consideration should be given to a moratorium on any further licensing or relicensing of nuclear power plants.
The question of whether power should be generated by use of nuclear energy is separable from the relicensing issue. Locally and nationally, the key issue is whether or not the Nuclear Regulatory Commission should set a precedent in this first relicensing proposal, by permitting the continued operation of reactors that may pose a higher level of human risk than was predicted at the time of original licensing or has actually been experienced since operations began.
Questions of State and Local Infrastructure State agencies, prior to relicensing, should be required to demonstrate their capability in risk assessment, management and communication, with special reference to local infrastructure they control, necessary to fulfilling their obligations to monitor and control human health risks associated with Calvert Cliffs Nuclear Power Plant.[3]
A risk assessment / management study needs to be done by state and federal agencies before co.1cluding that in fact the risk levels have been or will be increosed, and what can be done to mitigate the risks as an alternative to reactor shut down.
Such a study is not a requirement for relicensing by the applicant. But as a matter of national environmental policy, such studies, both quantitative and qualitative, should be done as the first step in aiding stakeholder participate in the decisionmaking process.[4]
Ecological risk factors, such as effects on the Bay as a food supply, or health effects across the Bay in Dorchester County where a community is growing down wind of the reactors for a significant percentage of time, appear not to be assessed.
What follows are some of the questions that would be posed in a comprehensive risk assessment - risk' management study.
Evacuation: The criteria used for original licensing included an evaluation of the population density and evacuation routes in the effective risk zone of the site. The basis for approval in this regard may no longer exist, given immense l
I population growth, increased loading and deterioration of evacuation routes. An updated, adequate plan may need to be l
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devised. New road and bridge construction may be necessary. Total evacuation for large segments of the population may not be i
feasible, and in the case of the two major biological laboratories, may be impossible. Alternatives need to be defined and communicated.
The existing plan [largely implemented by plant personnel] calls for evacuation only in case of a Chernobyl-like disaster. In less immediately urgent circumstances, the increased risk of disease resulting from " sheltering" at home is deemed acceptable. Such risks, especially those imposed by deprivation of information and freedom of action, may be unnecessary and thus unethical.[5]
Plant Risk Factors An updating of the risk assessment done by NRC and BG&E at the time of original licensing should take into account plant operating experience, deterioration and projected life of control and containment structures. Dual natural gas and nuclear fuel use at the same site, which is being discussed, might multiply those risks.
Instrumentation directly and continuously monitoring changes in critical measurements telemetered outside the plant and observed by appropriately trained state or county personnel should be investigated. A critical element in the Three Mile Island incident was the inability of company control room personnel to read, interpret and take appropriate, timely action. In a recent incident at the plant in question, excessive worker exposure occurred for similar reasons.
Workforce Protection: Of all workers exposed to ionizing radiation, those in nuclear energy [6] are exposed on average to a dose of 8.4 mSv/ year This is at least eight times the dose experienced by most other workers in other job categories, and about four times the exposure of naval reactor personnel [2.2 mSv/yr.] Averaging does not take into account special i
circumstances. Thus, at plants that have experienced in-plant incidents, such as those often cited by NRC at Calvert Cliffs, it is prudent to reconstruct the dose or exposure to ionizing and non-ionizing toxic agents. The sickness and death experience needs to be analyzed and monitored prospectively by a neutral agency. Most of the workers at risk are only now entering that time in the latency period for cancer when the disease might be expected to become clinically manifest.
I A computerized record system may need to be kept at a designated
(
clinical center for use in an emergency. Local primary providers need training on the special time-dependent care workers may require (such as whole body scanning and chelation, a detection and removal technique for plutonium-impacted workers.] A neutral i
i source for risk information to exposed workers and their families needs to be identified.
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Storage of Spent Fuel: The state and Native American tribal
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governments in Nevada appear to have rejected use of Yucca Mountain as a waste repository. Thus, it may be prudent to assume that the accumulated spent fuel will be stored onsite. The risks and costs of projected management of permanent on-site storage should be explored, e.g., classification.
Emergency Response Infrastructure: Local first responders (police, fire, EMT) appear not to be adequately aware, trained or i
equipped to assist the population at risk, or to protect themselves from exposure both to ionizing and non-ionizing toxic agents at the plant that would be widely dispersed in a nuclear incident. No specialized federal or state resources can be assumed to be immediately available to assist the local police, fire, emergency medical and hospital structure. Access by responders to the critical ten mile zone around the plant on both sides of the bay (which includes two long-term care medical facilities, housing for senior citizens, several day care centers and at least four schools] may be hindered given the in-place blocks to evacuation routes, which would be enhanced during an incident.
However, more likely than a major nuclear disaster, smaller radiation and non-radiation incidents have and can be expected to continue to occur. All responders need not only special training for both kinds of events, but also immediate identification of the ionizing and non-ionizing toxic agents being used in the plant, and access to precautionary procedures for self protection.
l l
Many of these procedures have been developed and are already widely available to fire fighters and EMTs in hazardous waste and industrial plant situations. In addition, the state of Pennsylvania has developed first-responder procedures for measuring radiation exposure among themselves and the people they protect.[7]
The local hospital and its staff need to be trained and equipped i
to evaluate, treat, and transport radiation victims.
Public Health and Communications: A survey of emergency resources for assessment, management and communication by public agencies needs to be done and reported to the public. Currently, l
both agencies and the public are reliant on information communicated by the plant, on measures that must be taken either to evacuate or, as is likely for many, take coping measures in their homes and schools [such as protected sources of drinking water during a power failure.]
)
Current educational materials promote misconceptions through the use of misleading language, such as the term " safe". Since the term " safe" means freedom from harm to many if not most people, i
it is without a scientifically demonstrable basis for use in discussing environmental carcinogens. [8]
No entirely " safe" or risk-free levels of exposure have been found in human populations for ionizing radiation. Current releases of radiation to the ambient environment, even if they pose a low order of risk, are not known to be risk-free. More, in the case of nuclear workers, individual risks increase with the rise of cumulative exposures.[6]
Another misconception is perpetuated in what some in the industry call "the standard of small significance", a term that has been used to describe the effects of both relatively small unplanned and routine emissions at the plant. FSat is meant by this
" standard" is the averaging of low levels of risk over very large, heterogeneous populations. While arguably these levels might not be expressed in greater than normally expected deaths or disease in such a population, the averaging process obscures risk in especially susceptible subrets of the community and workforce populations.[9]
Susceptibility may be generated by past personal exposures to radiation, synergistic or addit!.ve effects with medicines and other toxic agents, differences in age [with greater susceptibility among children and the elderly] and genetic differences. These susceptible can be expected to experience death and disease at rates greater than normally expected and not at all of "small significance." Thus, these subsets may be consciously and unnecessarily sacrificed as the price of continued relicensing.
Clearly, the educational task might properly be assumed by credible, specially-trained public health staff.
KI Distribution Compliance with the recent NRC advice to states for prophylactic distribution of potassium iodide tablets, while not mandatory, is nevertheless a consideration in relicensing.
Industry opposition to this standard precaution is evidence of the industry's inability to manage nuclear energy. In France, where 77% of the power is nuclear, within a 10 km radius of French nuclear facilities, the government distributes potassium iodide [KI] pills for use by children in case of a nuclear emergency. The inexpensive pills block and replace radioactive forms of iodine that the children may ingest and which might raise their risk of thyroid cancer. WHO recommends that all school children in Europe have immediate access to KI tablets in the event of an incident. Poland used such tablets after the Chernobyl incident.[10] Pennsylvania has already taken steps to provide KI tablets to all populations at risk.[7] t
~*
^
Economic Risks Economic arguments - actual threats of the loss of jobs, tax increases and a shortage of electricity - are being cited in pressing state and local legislators, officials, business, and taxpayers to support relicensing. Most of Calvert County's treasury surplus is attributed to tax revenues from the plant and its workforce.
Unfortunately the picture painted of the county's profit and economic well-being may be an illusion. The failure of the state and local governments to alert stakeholder to their financial responsibility and to provide for an adequate, responsive public health and emergency response infrastructure has resulted in higher than necessary risks to life, and to prop,erty now, and response costs and other economic sequellae that would be compounded in the event of a nuclear incident.
In any comprehensive cost / benefit analysis, the large costs of these measures (which by-and-large are not being taken) significantly reduce the actual net income from plant taxes.
Another hidden set of costs lie in decremental shifts of real estate value and incremental shifts of insured and uninsured personal and property liability, from the company to the community.
Thus, much - if not all - of the county " surplus" derived from plant-generated taxes may not really exist. Much - if not all -
is already obligated, i.e.,
it should be spent on infrastructure.
Since the power generated supplies other counties, these costs currently are unfairly distributed, i.e.,
concentrated in the county that derives the least economic benefit, and diluted in counties that derive the greatest benefit: power costs subsidized by tax payers in risk-impacted Calvert County. Pressing for a redistribution of these costs should become a legislative priority of the state.
Public discussion of the impact of a plant closing on the company and the County's tax and employment base does not take into account the value of the property as a " brownfield" or the market value of dismantled reactor components. The increasing unavailability of power plant sites in the Middle Atlantic, plus the site's established power grid connections and trained workforce makes the conversion of the site attractive for other power producers in the forthcoming deregulation of the power industry.
For example, the next generation of electric power technology, in which BG&E has no demonstrated or entrance capability, might well l
' include on-site use and/or manufacture of hydrogen fuel cells for l
commercial and residential facilities by competing enterprises, i
While still at a developmental stage, albeit an advanced stage, I
l t
these may be available by the time the current licensing period has ended. It is an alternative that should be explored in the risx management plan.
Respectfully submitted,-
n..-;fC}-
}f!
Sheldon W.
Samuels Vice President, Policy Studies Beferences
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[2] Wald, ML At a Hearing, Nuclear Regulators Are Criticised on 2 Fronts. New York Times, 7-18-98, p. A9
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[5] Samuels, SW. Ethical and Metaethical Criteria for An Emerging Technology: Risk Assessment. [J. Brit. Soc. Occ. Med.]
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[10] News and Comment France Distributes Iodine Near Reactors. Science. 275:5308 March 28, 1997, s l l