ML20009B712
| ML20009B712 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/13/1981 |
| From: | Earley A LONG ISLAND LIGHTING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20009B708 | List: |
| References | |
| NUDOCS 8107170071 | |
| Download: ML20009B712 (15) | |
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Before the Atomic Safety and Licensing Board 4 M '
4 In the Matter of )
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LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322
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(Shoreham Nuclear Power Station,)
Unit 1) )
l LILCO MOTION FOR
SUMMARY
DISPOSITION OF SOC CONTENTICN 2 The Contention By Board Order of June 26, 1980, SOC Contention 2 was admitted as follows:
i Intervenors contend that the emergency planning l requirements for the 50-mile (radius) ingestion pathway for the Shoreham facility, as set forth j in the NRC Policy Statement of October 23, 1979 (44 Fed. Reg. 61123), are inadequate in that th y do not adequately address the effects of releases through the liquid pathway.
Material Facts As To Which There Is No Genuine Issue To Be Heard
- 1. The NRC Policy Statement of October 23, 1979 (44 l Fed. Reg. 61123) referenced in SOC Contention 2 has been l superceded by the NRC's final rule on emergency planning.
j 45 Fed. Reg. 55402 (1980).
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- 2. The Commission's emergency planning rule relies specifically on the work of the Emergency Planning Task Force set out in " Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants,"
NUREG-0396, EPA 520/1-78-016 (1978). See, e.g., 10 CFR
$50-45(s)(1) n.2, 45 Fed. Reg. at 55410.
- 3. The NRC's final rule on emergency planning sets a generic requirement for a fifty mile (radius) ingestion pathway emergency planning zone (EPZ). 10 CFR 550.47(c)(2), 45 Fed. Reg. at 55409, see also NUREG-0396 at 16 ("it was the consensus of the Task Force that emergency plans could be based upon a generic distance . .
").
- 4. The planning requirements for the fifty r.ile EPZ
, are set out in 45 Fed. Reg. at 55408-413. The standards that need to be met in order to comply with the rule are specified in " Criteria for Preparation of Radiological Response Plans for Preparedness in Support of Nuclear Power Plants," NUREG-0654/ FEMA-REP-1 (1980). NUREG-0654 is incorporated by reference in the NRC's emergency planning rule. Nowhere in the rule or NUREG-0654 is there a requirement to analyze releases to the liquid pathway on a case-by-case basis. Rather, the necessary enalysis was done generically during the rulemaking. ,
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- 5. Thus, during the emergency planning rulemaking, the NRC considered the effects of a core " melt-through" release of radioactivity; a core " melt-through" release includes releases to a liquid pathway. Based on that consideration, the Commission concluded that the fifty mile ingestion pathway adequately ensured the health and safety of the public. See NUREG-0396, at I-44 to I-52.
For instance, the Emergency Planning Task Force found that
"[f]or the ' molt-through' class, projected whole boay and thyroid doses in excess of PAG [ Protective Action Guidelines] for those organs are, for all practical purposes, confined to areas within 10 miles of the reactor. Emergency response planning for this type of accident should therefore be primarily directed towards limiting the dose to those individuals located within that distance." Id. at I-50, see also 45 Fed. Reg. at 55406.
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! Argument l
I A.
SOC Contention 2 attacks the adequacy of " emergency planning requirements . . . for Shoreham . . . set forth in the NRC Policy Statement [on Emergency Planning]."
. (emphasis added). Since the Policy Statement referred to l
has been superceded by the NRC's emergency planning rule, the contention is, by its terms, a challenge to l
l requirements adopted during the NRC rulemaking. SOC's
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responses to LILCO's May 21 interrogatories underscore the fact that SOC objects to the results of the emergency plaaning rulemaking. For example, SOC claims "[t]he emergency action level guidelines described in NUREG-0654 for the Ingestion Pathway, including the guidance on the size of the EPZ appear to be derived from WASH-1400 and, thus, results in inadequate assessment of radioactive releases through the liquid pathway." Answers of the Shoreham Opponents Coalition (SOC) to Applicant *c Interrogatories Dated May 21, 1981 at B-8 (SOC's Answers are attached to this motion).
But as just indicated the NRC did consider the possibility of releases to the liquid pathway when it generically set the size of the EPZ's. See Material Fact
- 5. The NRC concluded that the fifty mile ingestion pathway EPZ would provide adequate protection in the event
( of such a release. Id. In fact, according to the NRC, the impacts of liquid pathway releases would not be significant more than ten miles from the reactor.
Consequently, the N5C saw no need to impose a requirement to analyze the effects of liquid pathway releases on a I
case-by-case basis. See Material Fact 4.
SOC disagrees, and has challenged the adequacy of the emergency planning rule. SOC, however, has failed to meet the requirements of 10 CFR 6 2.758 for such a challenge.1/
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l 1/ Nothing in SOC's Answers suffices to meet the 5 2.758 l
criteria. It is also well to note that these answers raise a
l Accordingly, it is impermissible.
B. ,
In the Company's view, nothing more need be said to support the summary disposition of SOC Contention 2. In the event more is needed, however, the attached affidavit of Brian R McCaffrey indicates why liquid pathway releases present no special problems for Shoreham.
Conclusion SOC may not challenge the NRC's emergency planning requirements for the fifty mile EPZ without first
! satisfying 10 CFR S 2.758. SOC has failed to do so.
(footnote cont'd) number of issues irrelevant to SOC Contention 2. Among other things, SOC asks _that " potential interdiction systems, including emergency actions and the potential safety and environmental improvement . . . be developed as part of the Shorehan safety assessment and EIS." SOC's Answers at B-1.
" Interdiction systems" seem to refer to some sort of new engineered safety feature. The need for such systems, if any, is the subject of the Commission's degraded core rulemaking.
See Advanced Notice of Proposed Rulemaking, 45 Fed. Reg. 65474, i 65476 (1980). SOC also attacks the adequacy of the Final Environmental Statement for Shoreham. The environmental phase
- of this proceeding has long been closed, however. and this l Board has denied SOC's attempts to revive it. See Board Orders
! of August 4, 1978, March 5, 1980 and May 1, 1980. Moreover,
' further consideration of the environmental impacts of Class 9 accidents has been foreclosed for Shoreham by Commission policy, 45 Fed. Reg. 40101, 40103 (1980), as Weil as a line of cases stemming from the Commission's decision ir. Offshore Power Systems (Floating Nuclear Power Plants), CLI-79-9, 10 NRC 257 (1979). See, e.g., Public Service Company of Oklahoma (Black Fox Station, Units 1 and 2), ALAB-587, 11 NRC 474 (1980).
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Accordingly, no genuine issue remains to be heard concerning its Contention 2, and it should be summarily resolved under 6 2.749.
Respectfully submitted, LONG ISLAND LIGHTING COMPANY f
. % >su c . D f1, $L W.' Taylor ele 77'III .
Anthony F. arley, Jr.
Hunton & Williams P. O. Box 1535 707 East Main Street
. Richmond, Virginia 23212 DATED: July 13, 1981
( c i B. SOC CONTENTION 2 In any melt-through resulting from a Class 9 accident at Shoreham, radioactive materials may leach into the groundwater Models to or eventually migrate into the Long Island Sound.
assess the consequences of the possible contamination of water by radioactive releases on health, water supplies, costs, emer-gency plans, or interdictionin techniques WASH-1400have not been adequate-or specifically by LILCO ly addressed generically SOC believes that little or no pre-for Shoreham in the FSAR.
parations have been made to interdict'the flow of contaminated groundwater from beneath the reactor containment buildingsOmission of the should a meltdown accident occur.
way releases from consideration in mitigating measures includ- ~
ed in the eventual Shoreham emergency plan ~ appears to be a fundamental deficiency. Therefore, including SOC believes a description emergency actions of potential interdiction systems, should and the potential safety and environmental improvements, be developed as part of the Shoreham safety assessment and EIS.
As set forth by LILCO in the FSAR, Long Island is underlain by soil deposits extending to depths ranging from a few tens of feet below sea level in northwestern Queens Cou? .y In to nearlySuf-central 2,000 feet beneath the south of Suffolk Countyfolk County, test Rock is estimated to be approximately feet below sea 1.evel. the Shoreham site. The materials 1,000 feet below sea level atthat overlie the bedrock and constitute Long water reservoir are unconsolidated deposits of gravel, sand, silt, and clay.*
The natural groundwater elevations measured across the area occupied by the Shoreham plant varied from 7 to 10 mlw, but be-cause the site might be flooded during extremely severe storms, and since the geological formations are very permeable, the de-sign ations.
criteria for subsurface loadings included flooding co ed to ensure they are capable of withstanding hydrostat by inundation of the site by a storm surge. The natural ground-water elevations were temporarily lowered to various elevations How-during ever, construction, as discussed in FSAR Section 2.5.4.6.
- life of the plant.**
- FSAR, page 2.4-21.
- FSAR, page 2.4-27 B-1
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In the generic risk study, the authors of WASH-1400 in- '
dicate that "the effects of contamination of water supplies has not been considered in detnil"* and assume without a de-tailed sis that analy'short streams time and inadequate
."** The rivers wouldanalysis be contaminated of water for only a contamination is a major flaw in the WASH-1400 presentation.
The financial costs and the societal dislocation due to major contamination from strontium-90 and other isotopes appear to be potentially very large. They deserve assessment in the Shore-ham safety assessment. '
The WASH-1400 authors also assumed that partial core melt always led to complete core melt. They further assumed, be-cause of lack of direct experience, that once a core losti.e., its initial configuration, it would be difficult to contain, to even if the containment building above the core were not ,
fail, the core itself would probably melt through the concrete foundation. It is not clear that the core would necessarily follow this course. It may, instead, melt down but remain con-tained from below by the foundation due to adequate upward heat transfer. If the molten core has penetrated the containment building through the bottom, its interaction with the sur-rounding soil and water table was not well-defined.*** Fur-thermore, core melt-through was not evaluated with the same comprehensiveness as were atmospheric releases because of the latter's more immediately observable adverse effect.****
Finally, the WASH-1400 report indicates that airborne re-leases are ruch more significant contributors to the total risk
- WASH-1400, Main Report, page 76.
- Wash-1400, Main Report, page 134.
- Battelle Columbus Laboratories is continuing the studies that they prepared for WASH-1400 in two main areas - release frac-tions and the physical processes of a core meltdown. Battelle r
is developing a new code, MARCH, to describe the therril and l mechanical aspects of a core melt. At this time, there ap-pears to be substantial uncertainty in modeling the core-melt penetration.
- Minutes of Meeting Five of the Risk Assessment Review Group, page 57.
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than releases via the liquid pathway. The U.S. Department of Interior did not agree with the notion that the liquid pathway was as insignificant as indicated in the WASH-1400 report and recommended additional study of the effects of variation of the hydrogeological conditions from site to site.* The NRC accepted the comment and instituted a research program at Sandia. The Sandia study results for a set of generic reactor sites were re-leased in draft form to the NRC and subsequently to MHB in early 1980.**
Figure 2-A provides a schematic diagram of flow of informa-tion in the basic computer programs used in the Sandia study.
The general flow of information between the computer programs is indicated in the central column. Other programs either used to generate input data or else whose previously generated output '
was used as input data are given on the left side of the figure, while input data obtained from literature sources is shown on the right side.
Two sets of programs were used by Sandia as shown in Figure 2-A to describe the releases into the hydrosphere: INTER and WECHSL to provide information about both the appropriate time scales for the various possible releases and the overall. com-position of the melt in different environments; and SOURCE to csiculate the amounts of radioactivity which go into each of the releases. The interaction of the melt with the structural ma-terial of the reactor, with the concrete floor of the contain-ment and with the soil beneath the containment, were taken as described by the models employed in INTER and in WECHSL. SOURCE calculates the amount of every important nuclide contained in each of the three basic types of releases for any given WASH-1400 accident category, and any core inventory. The output of SOURCE consists of the amount of each radionuclide released in-to the groundwater as a function of time.***
Transport of the radioactivity in the hydrosphere was des-cribed by two programs: GRDWATR and SRFWATR. GRDWATR des-cribes the transport of the radionuclides by groundwater move-ment from the area beneath the containment to any nearby sur-face water-bodies or wells, SRFWATR describes the subsequent transport in lakes, estuaries, oceans and river systems. With
- NUREG-0410, NRC Program for the Resolution of Generic Issues Related to Nuclear Power Plants, January, 1978, Task A-33,
. page 2.
- Sandia Study (Draft) performed for the U.S. Nuclear Regulatory Commission, "Effect of Liquid Pathways on Consequences of Core Melt Accidents," January, 1980, (Provided to Black Fox service list for construction permit proceeding), Figure 1.2.
- Sandia Study (Draf't), pages 10 to 13 of Chapter 1.
B-3 .
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F FIGURE 2-A _
FLOW OF INFORMATION ~
SANDIA STUDY OF HYDROSPHERIC CONSE RELEASE ORIGEN F < DATA
---# SOURCE .
INTER (WECHSL) t CORRA.L c
y
_l GE0 HYDROLOGICAL GRDWATR _f DATA BIOLOGICAL, y RADI0 BIOLOGICAL
~
" & SURFACE WATER SRFWATR - DATA l
- N POPULATION f l INREM II $ & USAGE DATA RSS CODE -
+ PATHWAY o L l
EXREM l
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B-4
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er -------w -
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C C simple analytic
' the exception of the river system program, models have been employed to consider the movement within each waterbody; for the river system, a moreofcomplex The output GRDWATR compart-is the ment model has been developed.amounc the output of of each nuclide SRFWATR is es- crossing r.h interface as a function of time; and in the sediment as a function of location and time.*s PATHWAY computes the radiation dose to theEssentially populations at risk, along with the resultant health effects.
standard NRC Regulatory Guide 1.109 dosimetry models have been employed. The health effects models in The PATHWAY output of are PATH- essential-ly the same as those used in WASH-1400.
WAY consists of the radiation dose received by the population for each appropriate pathway as a function of each of fourcategory; type of time after the accident; accident release; and relative leaching rate. The total resultant factors:
health effects for each pathvay are also tabulated.**
The differences between the radiation doses received through atmospheric pathways and through hydrospheric path-ways can be understood by comparing and contracting the pa ways themselves.
are reviewed in Table 2-A.***
The major conclusions by the Sandia authors in their draft report for plants like Shoreham without specific interdiction barriers were in part as follows:
- a. "In contrasttheto the mostsituation for releases probable RSS meltdownto the cate-atmosphere, in the largest releases to the hy-gories resultSignificant drosphere. amounts of radioactivity are generally expected to be released to the hy-drosphere during any meltdown accident. <
- b. At approximately 50% of all the sites considered, there is estimated to be essentially no radiation dose to the human population as a result of releases
- Sandia Study (Draft), pages 10 to 13 of Chapter 1.
- Sandia Study (Draft), pages 10 to 13 of Chapter 1.
- Sandia Study (Draft), Table 1.1.
B-5
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P TABLE 2-A i
. DIFFERENCES BETWEEN ATMOSPilERIC AND llYDR6SPilERIC PATilWAYS i
' ATMOSPilERIC RELEASED llYDROSPilERIC RELEASED Atmosphere: Primarily more volatile Melt Debris: Primarily less ,
SOURCE volatile RN's (Ru, Sr, La,...).q radionuclides (I, Cs, Te,...).
Sump water and depressuriza-
- , tion
- Primarily more volatile
! RN's.
Population reached rapidly (hours). Population usually reached slow-DISFIRSAL ly (months to centuries longer).
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' All RN's move essentially together; Each RN moves through the ground at its own rate; each RN moves i
deposition mechanisms differ only through the surface waterbodies
! for the noble gases.
with its own set of interactions.
Primarily inhalation and external Primarily ingestion (drinking PATilWAYS (ground). water, aquatic food) and extern-I al (shorelines) O Dominant pathways are relatively Some dominant pathways are very complex.
i simple.
Populations are straightforward. Populations are not obvious.
Acute, latent and chronic. Primarily c15ronic.
!!EALT!! .
EFFECTS Source: often possible INTERDICTION Source: not possible.
- Pathway: possible Pathway: possible.
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to the hydrosphere via the hole in the con-
' tainment basemat formed by the melt. At an-other 15% of the sites, there is estimated to be a resultant radiation dose of approximately 2 to 3 x 100 person-rem, while at the remain-ing 35% the potential dose is about 2 to 5 x 107 person-rem for such releases.
- c. Variations of conditions at actual sites could easily result in the doses being either higher-or lower than those obtained in this study by at least an order of magnitude. Likewise, rea-sonable variations in certain portions of the modeling could result in estimated doses which differed from those presented here by an order -
of magnitude.
- d. *The calculations indicate that if interdictive actions are not taken, then the liquid path-ways can perhaps. contribute significantly to the risk of core meltdown accident."*
Releases for a core melt accident through the liquid pathway could constitute a major problem for Shoreham because of the site characteristics set forth in the FSAR and summar-ized in the preceding. The impact of a cote-melt accident l
through the liquid pathway can conceivably be reduced at Shoreham if certain mitigating measures are employed. Thus, the effects of interdiction, including emergency planning measures, both close to the site of the accident and farther along the pathways to the aquatic and human population, fol-lowing a study using the various Sandia models discussed here-in or equivalent, should be conducted for the Shoreham site.
The supplemental responses to the specific interrogatories are as follows:
B.1: Refer to general description in the preced-ing for a general discussion of the path fol-lowed by liquids and dissolved radioactive i
contaminruts released from a nuclear plant during an accident. In general, radioacti.vity
[
- can be released directly to the hydrosphere after a core-melt accident as a result of f
- Sandia Study (Draft), pages 6-16 and 6-17.
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leaching of the core-melt debris, escape 2 of sumpwater, and depressurization of tSe containment atmosphere. Most of the long-lived isotopes, including the actinides, are expected to be found primarily in the melt debris. Therefore, even though this release occurs relatively slowly, the im-pact for a soil site such as Shoreham can still be significant.
B.2: The emergency action level guidelines des-cribed in NUREG-0654 for the Ingestion ~
Pathway, including the guidance on size of the EPZ appear to be derived from WASH-1400 and, thus, results in inadequate assessment ^
of radioactive releases through the liquid pathway.*
B.3: Yes.
B.4: The NRC regulations which require considera-tion of hypothetical Shoreham releases through the liquid pathway include 10 CFR 50, Appendix E, 10 CFR 50.34(b), 10 CFR 50.33, 10 CFR 50.47, and 10 CFR 50.54 for the basis as described in the preceding.
B.5 The facts and documents on which SOC now re-an lies are described in detail in the general response to this interrogatory. The facts
- and documents on which SOC expects to rely **
during the Shorcham hearings sill include the preceding as supplemented by facts and documents provided by LILCO and the NRC on this docket in the future, and by facts and documents provided by LILCO and the NRC in response to any forthcoming SOC discovery request and/or interrogatories.
B.7: The documents on which SOC now relies are described in the foregoing. Since the docu-ments are publically available, no copies have been provided by SOC.
B.8, SOC has not yet decided which vitnesses it will B.9, utilize in the hearings. When this decision is made the response to these interrogatories and B.10:
- NUREG-0554, pages 13 to 18 and Appendix 1.
- To the extent they ,are now known.
B-8
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, will be supplemented with the requested information. To the extent that SOC's present consultants are assisting in re-viewing and/or responding to these inter-rogatories, their resumes are attached
. hereto.
B.ll SOC first engaged the services of their and consultants, MHB Technical Associates, in -
B.12: December, 1979, and has had a continuing discussion with them regarding the conten-tions in this case. However, as of this writing, the consultants have not made any reports to SOC related to this contention. .
General studies or observations that SOC now relies or expects to rely on during
. the Shoreham hearing are set forth in the preceding. Also, see response to B.5 and B.6.
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