ML18030A299

Forwards Dept of Environ Resources Comment on Suppl 2 to Des

ML18030A299
Person / Time
Site:	Susquehanna
Issue date:	06/04/1981
From:	KETCHUM A PENNSYLVANIA, COMMONWEALTH OF
To:	NRC
References
NUDOCS 8106090456
Download: ML18030A299 (4)

Text

REGULATOR NFORhttATION DISTRIBUTION 8 EH (RIDS)ACCESSION'BR:81'06090456 DOC~DATE!81/06/04 NOTARIZED:

NO.DOCKET'r'ACIL:50 387 Susquehanna Steam-Electr ic Stationr Uni t 1~Pennsyl va 05000 8 50 388 Susquehanna Steam Electr ic Station>Unit 2>Pennsyl v 500 08 AUTH,NA4IE AUTHOR AFFILIATION K ETC HUhl g A~Pennsylvaniai State of REC IP~4AHE RECIPIENT AFFILIATION NRC>>No Detailed Affiliation Given N SUBJECT!For wards Oeot of Envir on Resour ces comment on Suppl 2 to OES.DISTRIBUTIo N CODE: COD IS COPI ES RECEIVED;LTR L ENCL l SIZE: TITLE: Environs Report Amendments 5 Re'lated Correspondence NOTES:Send ICE 3 copies FSAR 8 all amendssi cy:BlvR LRG PS(L,RIB)Send IEE 3 copies FSAR 8 all amends,i cy'.8'HR LRG PR(L,RIB)05000387 05000388 REC IP IE~-'T IO CODE/NAME ACTION: LIC BR 02 BC 18 STARKERS 05 INTERNAL: EN" ENG BR nb IAE 15 OELO-01 FIN BR oa COPIES LTTR ENCL 1 1 1 1 1 2 2 1 0 1 1 RECIPIENT IO CODE/NABLE LIC BR 42 LA 19 HYO/GEO BR NRC POR 02 RAO ASST BR 09 SIT ANAL BR 07 COPIES LTTR ENCL 1 1 1 1'1 1 EXTERNAL: ACRS NSIC 20 04 3 3 1 LPOR 03 1 1 JUN~R SN, TOTAL NURBER OF COPIES REQUIRED: LTTR'ENCL k'~~Commonwealth

, ot Pennsylvania f'Eeer~imy P.O.BOX 1323-HARRISBURG, PA.17120-(717)787-8046 783-3'133 JUN 04 I9B)GOVERNOR'S OFFICE OFFICE OF THE BUOGET RE: PSCH I

Dear Applicant:

Attached are comments concerning your State Clearinghouse submission referenced above.Sincerely, Anne Ketchum Supervisor at COMMON>VEALTH OF PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL RESOURCES P.0.Box 2063 Harrisburg, PA 17120 Hay 27, 1981

SUBJECT:

Review and Evaluation of PSCH No.: 5-81-04-004 Supplement to Draft Environmental Statement Related to Operation of Susquehanna Steam Electric Station, Luzerne County ro: Anne Ketchum, Supervisor Pennsylvania State Clearinghouse FROM: CL'IFFORD L.JONES Secretary of Envir nm!'t 1 Resources The Department.

has reviewed the subject Draft Environmental Supplement.

He would like to offer the following comments.(Section 6.1.4.1)The more pessimistic assumptions that are used for the design basis accident analysis should be explained in more detail.It should be made clear that the quantity of noble gases and iodine that are assumed to be released to the containment for these accident assessments are of the same magnitude as the source terms that.are assumed for Class 9 accidents, and therefore could not occur unless severe fuel damage or melting had occurred.For comparative purposes, Table 6.1.4.1 should include realistic thyroid doses and the calculated exposures using worst case assumptions.

'(Section 6.1.4.2)It should be stated that significant changes have occurred in the GE Bt(R design since the Peach Bottom design, especially in the area of containment design, which should have lowered the overall probability of severe accidents.

These major design changes should be identified in summary fashion.A technical basis should be given for the statement that it is the staff's judgment that the calculated results of the consequences are more likely overestimates than underestimates.

(Section'.1.4.5)

It does not appear that a melt-through accident was considered to be a credible scenario for BMR's in the RSS.Furthermore, the LPGS does not appear to consider a BHR design in its assessment of land-based reactors.Therefore, additional justification should be given for including this scenario as part of the assessment; and if included, the risk in terms of dose should be better quantified.(Section 6.1.4.6)The various methods by which risk is presented in both tabular and graphic form leads to confusion in interpreting the results.For example, the ratio of acute fatalities'o latent cancer fatalities in Table 6.1.4-5 does not agree with the apparent ratio between Figures 6.1.4-7 and 6.1.4-8.It would be much more straightforward to show the average individual risk versus distance from the reactor (including inside the ten-mile radius)in either tabular or graphic form for both acute and latent cancer fatalities, with and without protective actions.This same figu're could then include the risk from other man-made and natural risks, including natural background radiation and background cancer risks, for comparative purposes.It appears as if the risks from the realistic assessment of design basis accidents is less than the risk from the realistic assessments of Class 9 accidents, with or without protective action.It is also apparent that the risk from Class 9 accidents is greater than the risk from normal operation.

Based on this somewhat anomalous situation and coupled with the uncertainties which are attached to the assessment for Class 9 accidents, i t would appear that further justification is necessary for the Staff to conclude that these accidents do not warrant additional study to determine whether public health and safety is adequately protected.

It should be noted that various rule making proceedings are currently in progress which should better quantify the risk from these severe accidents and may, in fact, lead to a requirement for additional safeguard equipment to decrease this risk.