ML24323A151
| ML24323A151 | |
| Person / Time | |
|---|---|
| Issue date: | 11/15/2024 |
| From: | Tom Gurdziel NRC/SECY |
| To: | |
| References | |
| NRC-2019-0062, 89FR86918 | |
| Download: ML24323A151 (1) | |
Text
From:
tgurdziel@twcny.rr.com To:
RulemakingComments Resource Cc:
Diane Screnci (She/Her)
Subject:
[External_Sender] Advanced Reactor, Rule 53 Thoughts (Comments Tom #4)
Date:
Friday, November 15, 2024 5:33:00 PM
- Hello,
As I continue to read about proposed changes, today I got to the 10CFR50 section. In order to try to understand the explanation, I had to go to 53.1109(g)(2)(i)(A). There I read:
Public dose.considering accident likelihood and source term, timing of the accident sequence, and meteorology
This is incorrect. Accident likelihood should NOT be a part of a dose calculation. The dose would be a result of, (and after), the accident actually occurred. And today, doing this calculation correctly has apparently become even more important with todays increased interest in environmental justice.
Here is a small example. Suppose I borrow a neighbors 4 wheeler to use on a very rough trail. And let us say the chance of needing a $50 tire repair is 1 times 10 to the minus 4. (This is one chance in 10,000.) OK now say I actually damage one tire and need to have it repaired. I think it is clear that the cost to me is going to be $50.
But if I do an NRC-type calculation for cost, I would multiply the $50 by the accident likelihood (which is 1 times 10 to the minus 4). This is $50 times 1/10000 or.005 dollars. See, the NRC-type cost would only be a half a cent!
Clearly, there is a problem here that needs to be corrected.
Thank you,