ML20245B953
| ML20245B953 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 04/23/1987 |
| From: | Bellamy R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20244D847 | List:
|
| References | |
| FOIA-88-198 NUDOCS 8904260401 | |
| Download: ML20245B953 (15) | |
Text
- x.v.s.a.w. .a :a:a.,.u ;: u u.,:wz e ,.e t . a. . . . .; ,- m.. . i.
l
- 1. DED 23 '87 08:59 NRC MILLSYONE 1 P02
..' knel,b 0%
APR 2 s 1ggy , y pn '
f', , / % 3/ , V 4 + e /
MEMORANDUM FOR: Thomas T. Martin, Director "" -
Division of Radiation Safety and Safeguards FROM: Ronald R. Bellamy, Chief Emergency Preparedness and Radiological Protection ranch, DRSS i
SUBJECT:
PIL6 RIM PUBLIC INTEREST ITEMS There have recently been a number of articles in newspapers published in the area around the Pilgrim Station that suggest there is a pattern of in reased cancers in the area, and that Pilgrim effluent releases might be the ca se. I have enclosed a series of question 6 and answers to address these issui s that indicate what the affluent releasts have been from Pilgrim, and the i.inimal impact these releases had on the piblic. i 1
Ronald R. Bellamy. Chief Emergency Preparedness and Radiological Protection Branc'i Division of Radiation Safety and Safeguards i
Enclosure:
Questions and Answers cc w/encls: 1 T. Murley, NRR '
W. Russell. RI J. Allan, RI W. Kane, RI W. Johnston, RI S. Collins, RI L. Bettenhausen, RI F. Congel, NRR L. Cunningham, NRR J. Wiggins, RI M. McBride, SRI, Pilgrim W. Pasciak, RI Region I Branch Chiefs h g _19e PDR
=; w w w n m a :n . w m m y :a w m . w .c .m;n- .
= m.a .
. DdC23'._i?09:00 NRC MILLSTONE 1 P03
.-^
Question._
Is it likely that coastal wind patterns could Keep radiation circula i the same area, and slowly building up over time, instead of dissipatin Answer:
Atmospheric processes are largely governed by statistical mechar ics an No. Particularly when there is a finite amount of rad oective thermodynamics.
released, the coastal wind patterns will quickly disper.e, and material The second law of thermo ynamics continue to disperse, these contaminants.
prohibits been dispersed.
non-condensable airborne gases from concentr and mixed; once the' dye is dispersed it cannot be reconcen agitating the water.
in the atmosphere is deposition (settling out). Deposition in the at nosphere only takes place wii.h particulate material, and the ma Some small amount of radioactive particulate gases which do not deposit.have been released, however, theindeposition the a has been taken into consideration in estimating doses to the publi:
Final Envirorsnental Statement for Pilgrim Station. All of these doses are within the NRC regulatory limits of Appendix I to 10 CFR 50,10 CFR 100, and EPA guidelines.
Question: f l
Some studies have shown that cersain communities surrounding Pilgrim have cancer rates two to three times the average U.S. rates. Could tnis e due to Pilgrim?
Answer:
Scientific data indicate no. NRC regulations establisn waste syst sn design
- requirements on whole-body annual doses over natural background at the The site perimeter due to airborne releases to be less than 10 stem per y tar.
latest data on radiation induced cancer risk for chronic exposure suggests that the risk of dying from radiation exposure is one part inplant ten mop111on rates for for every arem of whole-body exposure received. If the nuclear receivt from the 40 years, the maximum possible exposure an individual coulcThis amo nts to a gaseous effluents would be in the range of 400 mres.
maximum lifetime increase in cancer risk of 400 parts in ten million, or
.00004. The average lifetime risk of dying of cancer inThese the U.S. is about data suggest a O.17 (i.e.17% of the U.S. population dies from cancer).
maximum increase in lifetime risk in death from cancer due to a 400 mrem exposure to be .00004/.17 * .0002 or .02%. This number is much sm.11er than the increase that was observed in the surrounding coesnunities of 10C s to 200%,
suggesting that the increase is not due to the affluents from Pilgria station.
a n.:.w.n :,,u z:n..- i.w a. ~
w u,u . . a ; ._a , , . ;
L l i
l DEd 23 '87 09:01 rtRC MILT.STCHE 1 PO4
. 2 l I
_ Question: ,
From the stanopeint of human health effects, how ignificant were the n le.ses that were made during the period from late 1974 through most of 19757 Answer:
Not very significant. In terms of airborne noble gas effluents, the Iighest 1 releases occurred in 1974, and the second highest in 1977. 546,000 l1 and I 413,000 Ci respectively. The average annual release during the entire operational life of the plant was 104.000 C1 (see table). This result ; in a cumulative dose to the.whole-body less than 40 arem (1972-86), based on actual effluent release reports resuf ts. As noted in the answer to the pi svious questions, this level of exposure will have a negligible effect on iner!asing cancer risk. In addition, releases from Pilgrim have been within the regulatory limits and Technical Specifications.
l Question: '
Did the spent resin release that occurred on June 11, 1982, result ii high radiation levels offsite?
Answer:
No. The res1n beads were not oispersed offsite. While they wert con-taminated. the resin beads remained onsite, and the contamination appeared to remain fixed to the beads as no detectable contamination was measuied in sewers, stonn drains, or direct exposure on TLDs. Also, no intakes of radio-activity occurred by radiation workers involved in the cleanup activities.
Actual measurements to verify that no radioactivity was released offsiti were j perfonned independently by both the Itcensee and the NRC. ;
1 l
l l
u .<. :.. . .ws+, . n :s. . :i. w.w.x . . . a. .u : .: - :....n
- . . . .; y - . . .
. DEC' 23 '87 09 02 NRC MILLST.NE 1 P0t
, 3 Pilgrim Pilgrim Airborne Noble Geses (C1) ulqu.
Effluents sct !
1972 18,000 1.5 1973 230,000 o,g 1974 546,000 4.2 1975 46,000 8.01 1976 183.000 2.33 1977 813,000 3.41 1978 32,700 1.77 1979 13,900 0.51 1980 26,200 2.73 1981 5,300 1.94 1982 19,400 0.872 1983 20,100 0.935 1984 20.2* 4.75*
1985 3,266 1.13 1986 131** 0.13**
- Recirculation Pipe Replacement
- Shutdown: NRC ander c. AL A_ e .o
Gr?.mgw::ls mm:;nts;5r..:::~c m.s;;j 2. .1 m., - :
..,....,_, ,u.. s - m. .
]
i
. DEC 23 '87 09502 NRC MILT.5 TONE 1 P06 1
~
WASTE STORAGE P11 grim has a dedicated waste storage facility onsite that sat 1sfies NR; criteria in terms of environmental protection (weather, temperature, ra:n) ano security.
It is only occupied to a small percentage by radwaste today. There are three concerns that the licensee is presently reviewing: (1)itisan older fact 11ty and is not state-of-the-art in terms of traffic, design er handling; (2) it is not large and during times of heavy use could becom -
cramped; (3) it is located outside the protected area which causes prob ems in terms of movement of radwaste, 1
l ll 1
f I
l 4
l l
y -
)
w .x --z w . w x x '.: w i m m c ~
- "1.:: = c w ;c
. ~-zc, b=, ;.
A Pilgrim Off-s ne Re. eases Orcretion of tne PNP 5 facility is governed by operating licensee let hnical Specifications that are based on the dose-design objectives of Apper. dix 1 to 10 CFR 50. Because these design-cbjective values were chosen to permit flexibility of operation while still ensuring that plant operations re uit in -
offsite deses that are as icw as is reasonably achievable (ALARA), the actual radiological impact of plant operation may result in doses close to ci occa-siona11y greater than the dose-design objectives. Even if this si uation exists, the individua' doses for the member of the public subject to noximum exposure will still be very small when compared to natural backgrcund i oses (
100 mrerrs/ year) or the dose limits (500 mrems/ year - total body) speci 'ied in 10 CFR 20 as consistent with considerations of the health ano safety of the public. As a result, the radiological impact on members of the pub 1 e from routine operation of the facility is negligible.
Operating standards of 40 CFR 190 the Environmental Protection A iency's Environmental Radiation Protection Standards for Nuclear Power Operitions, specify that the anniJa1 dose equivalent must not exceed 25 mrems to th; whole body. 75 mrems to the tnyroid, and 25 mrems to any other organ of any member of the public as the result of exposures to materials (radon and its daughters excepted)toplanned discharges the general of radioactive environment from all uranium-fuel-cycle operations and radiation from these operations titat can be expected to affect a given individual. The PNPS facility has operated within these standards.
Pilgrim Station Radioactive"Iffluent Data 1979-1986 Capacity Noble Airborne Non Tritiated Liqyid Solid Waste Year Factor Gases Tritium lifquids Tritium V61. m 3 ?:tivity, C1 1979 82.5 13,875Ci 156Ci 0.51Ci 13.4Ci 3.026 22.000 1980 51.7 26,062C1 44Ci 2.74Ci 40.0C1 2,937 1.600 1981 58.7 4,488Ci 77Ci 1.95C1 34.0C1 1.064 938 1982 56.0 19,413Ci 19Ci 0.78Ci S.9Ci 2.286 959 1983 80.3 19,991C1 60C1 0.94Ci 15.6Ci 665 1,481 1984 0.1* 18.401 1.8Ci 4.75Ci 14.8Ci 1.794 1.199 1985 84.4 3.259Ci 7.2Ci 1.13Ci 12.5C1 996 494 1986 17.5** 126Ci 4.5Ci 0.13Ci 8.101 443 385
- Recirculating Pipe Replacement j ** Shutdown - NRC order Based on 15 BWR$ of comparable vintage (ftr 1983):
Average hoble gases 14,619C1 2f9-85726Ci Average Airborne Tritium 50.2Ci; 2.9 258C1 Average Non Tritiated liquid 1.25Ci; 0-12.4Ci Average Tritium in liquid 11.3gi;0-94.7C13 Average Solid Waste Volume 806m ; 357-1680m i Average Solid Waste Activity 13.000C1; 5(1-5750101 4
1
w.a 1. 2 a =.~.= wm . . a.u:w a a.~..=> .
~
- , w. w .. . . ,: -
DEC 23 '87 09:04 NRC nILt.: STONE 1 POV hDk --
b p u ee5
'G
- T4 \
. .4C04_
, _ . .... A V 9. .
..W. a o rft .I t i . . . 3
_ _P. j s i, rn . . . .
. _ . _ _ . ip 3. g %., 5 t,7
- _ . - - - i tt. . . . . _ . _,
M 7 9-- 5o7
__ .. 8 L 5. . . . . . . _
4.ti_.
.__ L% 7 5.. 7 oi . 6.S.J. _- _
. .__.7. f 6 - . .
.l y >. c_ _ .__...5.4.1....___..
_ . . . . 4._1 "o . _ _ . .. 254.9o.. . ._ .. . .
_ . d ~7 'i . _ . . . B 18. . .. _ _.. _ . . ._. 0 t.1. - ___ 3I61 i
_ . . i 4 'l.4 . . . .. .. 6.0_.4c.. ... _ . . _ _ . 3_I.4. ._ . . . . . l _1_ L._1__ _ _ . _ . . . . _ _ _
. . _11_1't 1 13 _).h 9 *1 t s IS
.J1 % 18. L.L... .. .. . . . $. e.t J . . ... .
3 s LA. . . _ . . _ _ _ _
. . _ . (. 9 S./ .. . . . 9.80._.... . ._ 15 4.1.
__. /.%.3.L. . _ _ _ _ .
ft.62 . ___9 4 o _ . _ _ . . _ - - .i.t._4_ 4 . _ .
. .- _. /5_3 5. . _ ._ ..
fy 8i _ to S b Sto _ . It L 2.
!? BV . lo o 3 .. B1.0 .. 40't - . . . . . _
_ _ h_..%.5 . 7__7.9 . 24 B13 m '"
O ec .. 6 5 3 . .__ ._. ./ 2:5 o. . . .. .87+ _ _ . . _ . . . ._ _.
li o 7 s. . . . _ . . . . . . . . . . . _ . . .. A. l .b. . .. ..i_ _ .T. S. O .. _ . _ . _ _
t.$.c cm .. _ . ... .. ~. _~2. O W.. _..
A. J q gwR. -
p w e. m; L 1. 9;ket M I f7 3 ./.E .B . .C ... _ 2 6. 34.e._. h.. .. . _ . . 5 $.__ .. . 10'1% _ . .
[
. .. .... . . . . . . . ._ .. . . . . .. .. . . . . . . _ . - ._ _ _ _ _ _J.
Ik J 8 6 v3 (l. . . . . . . . . . .. . . . . .
21_S3 ._.
... l9e.o~.19.85 ~ .
7.8t. P. . c . w . . . ... ..Q. j.a . ... . . . . _ _ ..
Ws . . .
g g g g g . g g . .. - -. .__.....M'
..e . . .
na = c.mn.w. - .~ .x n. c ., .- ,n n . ,.,. ~.m v., . .v,- .. . . , ;.u ..m
'.',1/t.
- 41 * :$ t' - -e !.. : l'IlLLk:: I'! _ 1 . "JJ
)
.. I IU :STIONS AND ANSWERS IN PREPARA11DN FL < JANUARY 7,1988 P!L6 RIM HEARING
}utstion: Will NRC requiro that al' (f the FEMA identified deficiencies be corrected prior to re La rL?
answer: In the report of their s 11-initiated review, FEMA identified six areas in which the Massachuset s anc local emergency plans were rinricinnt Sncsurn thn plint rii 11rnidy thntdnwn for nther rearnnt, thnen dnficianciar. wara not ha in avaluated to determine if each one would leavu Lv be s.v. plutvly s.u e i n.LuJ ye lv, Lv . . L.. L . U. .J u,~. . ti..
timing of submittal of revised p' ans to TEMA for review, and FEMA's report to NRC, we will not knoi ntil shortly prior to restart, which items are still uncorrected, a id what significance to place on them.
Qt astion: Will an exercise be rage r:d to satisfactorily resolve those deficiencies prior to restart?
Asswar- FFMA has indicated that to w of the deficiencies would be amenable ,
I to e,os e n. tion b.y s er ien u r pl s md pr us.edurn s.linnyn, imL t.lial. ut.imr3 would require desenstration ir. a drill (teot usi.easarily en exen.ise).
Althnugh a full-participation ?x'rcise must be conducted by the 6nd of i
June,1988 (ar. a cnndition of ;h t exemption granted for not conducting an exercise in 1987, this exer:ite has not been determined to be necessary prior to restart.
l
ww= m m :a.uc..ra=~: w x.:na 2.a~ w.:.xv.=.. :, . . - . : .... . : : ... .
.' .DEC 31
- 37 16r39 HRC MILLtir :H E 1 P03 l
e fu > Lion:. V!wl is Lliu NRC pusillun .m Llic Commonwealth's plan to anLarge th6-1 EPZ?
in war: the present EPL has been rsviewed by FEMA and the NRC and found to be acceptable. We are ont awat n af the details of the planned enlargement. hnwever the fallat irs thinos must he rnnsidered prinr to enlarging the EPZ:
We are not aware of any ec hnical Just.ification fur enlervliiv 1. lit-EPZ.
We would need to ha annu es that the enlargement of the F02 would not drain resources in si ci a manner as to lessen the level of protection for those in ha current EPZ.
FEMA and the NRC would n t be bound to evaluate any deficiencies which were found to exis n the expanded portion of the FP7.
In general, we have no objecti"n to providing more detailed planning for the areas outside the existing F1/. but due to the greatly redur.ed risk, see no need of the same level .t planning as required for the population within the current EPZ.
Qtattion: What do you maan by "addio cod prior to rectart" when you rofer to the FEMA identified deficienci is"
-=______:_--____:_____-
av..m au.e. a m w :w.x axa.w a.;.- - m.= m ; + - -- .a ~ . - . ..
..DCC 31 ' N 10:31 NRC l'lILLGTI1C 1 PO4 l
\
t
~
in.wer: - We mean that sufficient trcgress has been made to correct the deficiencies to the extent that te believe that there is an adequate level of protection of public ! eilth and safety.
Juntion: What would the NRC do if tl e state did not prepare a plan?
Ar:wcr: We have not addressed th t issur. so the answer is that we don't know hnw we would respond.
Qt ssLion: Du the plans have to be .plroved prior to restart?
Ar wer: If by ' approved" you meni he furisial approval defined in FEMA'>
regulation 44CFR350, the answc* c no. The plans must be in a form that we would have reasonable assurin m that they could be implementml in a manner which would provide ade tu :Le protection for the health und safety of Llie publit.. The rugul.itlun ; illow for cunlinued plant operation as long as their is a finding of e .sonable assuranc.e that publir. health and safety can be protected. h .t assurance can be gained through plan review and exercicco prior to ;h i formal approval of the state's emergency plan.
DixxLinn: Why is the P110 rim resta t process continuing witn tno FEMA-identifled deficiencies u ir: solved?
Atswer: The restart pror.ess prin:1: ally involves the BEco's correction of identified deficiencies to the N:C's satisfaction. Pilgrim is prosently shutdown with plant activities biing conducted in accordance with the i
i _ _
.:x.
mmm=m:2.i:.u.u.:.wemmazu . .a:.:.cswa:sm: :i:~.w .w w:: :v a- . ..
.. ., Ddd 31 ' 37 16.s 33 NPC MILLSTt'N E 1 P01 f
conditions of their license as a dified by our Confirmatory Action .
Letter. It would not be prude' t management for them to not prepare for restart.
Further, none of the FlMA identified deficiencies appears to be of such complexity that it c an not be corrected. In fact FEMA outlined what would be necessa y for each item to be corrected in their report. Based on that it is riasonable to assume that the deficiencies will be satisfat:torily resolve < .
Juistion: Does the NRC have suffic et t technical resources to perform the same icvel of emergency plar, r v ew as FEMA?
tnswer: Yes. The FEMA review in' o'ves a collegial body called the Regioaal Assistance Comittee R/ C) which consists of representatives from several federal agencies niluding DOT, EPA, FDA, HHS, Dept. of Agriculture, NOAA, and NRC. M st of the skills are available "in-house", however we could a'sc call upon assistance from the other agencies or qualified contracte rs as FEF.A does.
l l
1 i
l l
- u. .
- -- - -- {
p .. . . _ . , u . .m.. . m- . .m - c ,2.s u . . . a, . .. . . -. m. -
i Issue: What are the regulatory requirements regarding the operation (or re-start) of nuclear power plants with identified deficiencies in offsite emergency preparedness? ,
Response: The Commission's regulations require the submission and implementation ;
~
of licensee, statt *nd local governmental emergency plans which meet the standards in 10 CFR 950.47(b) and Appendix E .o 10 CFR Part 50.
As described in the Memorandum of Understanding between FEMA and NRC (50 Fed. Reg.15485, April 18,1985), FEMA has lead responsibility for assessing offsite radiological emergency response plans and prepared-ness. The NRC assesses onsite emergency planning and reviews FEMA's assessment of offsite plans for the purpose of making findings on the overall state of emergency preparedness. The NRC must find reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.
The Commission recognizes that there can be deficiencies in the emer-gency planning and preparedness associated with a nuclear facility.
However, there must be substantial coepliance with the regulations, i.e., compliance sufficient to find that there is reasonable assurance that adequate protective measures can and will be taken in a radiolo-gical emergency. Indeed, even in those instances where the Comission can no longer make its reasonable assurance finding, emergency pre-paredness deficiencies may not require facility shutdown. See 10 CFR 550.54(s)(2)(fi). In practice, radiological emergency response plans are rarely if ever perfect and complete. This is the reason for the continuing FEMA and NRC oversight of this area. Deficiencies will be found and assessed for significance. While all deficiencies are ex-pected to be corrected, not all will change a finding of reasonable assurance by the NRC.
For an operating plant, such as Pilgrim, the regulations provide con-siderable enforcement flexibility to the NRC. Unlike safety deficien-cies, identification of an emergency planning deficiency does not require immediate shutdown of a facility. Where a significant deficiency in emergency planning is revealed, a 120-day period is initiated in which the deficiency must beiddressed. Even after this i
= _ _ _ _ _ - _ _ _ _ _ _ _
wwixww ;1:. :.;.c:::=n= wi=;; .wa w;vm w wvio . ~;.: , ni;c - :m -
"120-day clock" has run, the regulations provide that the NRC has the 1 enforcement discretion to allow the plant to continue operation even in the face of such a deficiency. This regulation and the broad flexibility which it accords to the NRC has been judicially approved. )
(County of Rockland v, NRC) _
l 1he Comission's emergency planning rules require " reasonable assu-rance" of " adequate protective measures." 10CFR550.47(a). This requirement recognizes that there cannot be the same degree of pre-cision in emergency planning as is demanded by the NRC for plant design and construction. Commission regulations provide that if the Commission finds that an emergency planning deficiency exists, the facility operator has 120 days to correct the deficiency before the Commission need determine "whether the reactor should be shut down until such deficiencies are remedied or whether other enforcement action is appropriate."
Whereas significant deficiencies in a safety system at an operating reactor would cause it to be shut down at once, the identification of significant deficiencies in emergency planning results in the initia-tion of a four-month period within which the deficiencies are addressed, not in an automatic shutdown of the facility.
Prior to contemplating enforcement action the NRC normally would, consistent with its regulations, provide the licensee a four-month opportunity to demonstrate that the deficiencies are not significant for the plant in question, that adequate interim compensatory measures have been or will be taken, or that there are other compelling reasons for allowing operation to continue.
The United States Court of Appeals for the Second Circuit in County of Rockland v. NRC, held that a nuclear power plant emergency planning deficiency does not require the NRC to take enforcement action to shut down that plant. The Court in County of Rockland specifically recog-nized the four-month grace period set forth in the NRC's emergency planning regulations and further noted that even at the end of that period the NRC still retained the authority to decline to take any
m ..w m w. w u u u, m , -, w a w.r.mm c.a. - - m w.1 < . ww cx - - n a...
3-enforcement action. The County of Rockland court found "nothing in
- the language or legislative history of the [ Atomic Energy Act] or
[ Energy Reorganization Act], nor in the regulations promulgated by the Comission," that required NRC enforcement action even in the event an emergency planning deficiency wert found by the agency.
j Thus, even assuming that the NRC is wrong in its conclusion that there l is no deficiency in the emergency plans sufficient to prevent a finding or reasonable assurance of adequate protective measures, NRC regula-tions provide an additional four months for study of the problem at Davis-Besse before the agency must confront the need to take enforce-ment action.
[The following material is from the final rule on emergency plac.cf rg issued on 12/3/87].
In 10 CFR 550.54(s)(2)(111), the Comission provided that if it " finds that the state of emergency preparedness does not provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency...and if the deficiencies...are not corrected within four months of that finding, the Comission will I determine whether the reactor shall be shut down until-such deficien-cies are remedied or whether other enforcement action is appropriate."
In other words, a plant ordinarily may operate for at least four months with deficiencies in emergency planning before the NRC is re-At quired even to decide whether remedial action should be taken.
the time that the Comission created the so-called "120-day clock" for deficiencies in emergency planning, it was settled Comission law (and remains so today) that the NRC must issue an order directing a licen-see to show cause why its license should not be modified, revoked or suspended whenever it concludes that " substantial health or safety issues ha[ve] been raised" about the activities authorized by the license. Consolidated Edision Company of New York (Indian Point).
l
- 4 - _ _ _ _ _ _ _ _ _ - _ . _ _ _ _ _ _ _ _ -
pirii:i RL mrDY.ts2,:::: : c:.s T li. w3.7: : o.1:3 - .,,.& . L :.T^ : .a.
"~:,
4
- In the context of that standard, the 120-uay clock provision of emer-gency planning deficiencies amounts to a Commission finding that, at i least for the first 120 days, even a major deficiency in emergency planning does not automatically raise a " substantial health or safety ,
issue" with regard to plant operation. By contrast, a major safety l deficiency relating to emergency core cooling system--would warrant immediate shutdown.
In sum, despite language indicating that emergency planning was
" essential," the Comission in 1980 created a regulatory structure in which emergency planning was treated somewhat differently, in terms of the corrective actions to be taken which deficiencies are identified, from the engineered safety features (" hardware") that would be relied on in an emergency qt