ML20236B560

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Responses of Jj Forster to Interrogatories Propounded by NRC Staff Dtd 760621.*
ML20236B560
Person / Time
Site: Diablo Canyon, 05000000
Issue date: 07/20/1976
From: Silver G
AFFILIATION NOT ASSIGNED
To:
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML20236A877 List: ... further results
References
FOIA-87-214 OL, NUDOCS 8707290147
Download: ML20236B560 (5)
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NUCLEAR REGULATORY COPNISSION g BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ,

In the Matter of ) .l PACIFIC GAS AND ELECTRIC C0. ) Docket Nos. 50-275/323-OL Diablo Canyon, Units 1 and 2 )

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RESPONSES OF JOHN J. FORSTER TO INTERR0GATORIES PROPOUNDED BY NRC STAFF DATED JUNE 21, 1976 Reliance is not being made upon issues specifically related to interrogatories 1, 2, 3, 4, 6, 10, 11.-

SA. We find no documents to provide a reasonable basis for the Staff's asser-tion (Addendum, (a)3. at 3-10) that water testing (proposed in Addendum, j

p. 3-10, par. 2) will not expose potential damage before it is done.

SB. Given the Diablo Cove-South Cove geometry, recirculation could be caused by wind or coastal current.

50,0. Information.not available.

7A. Since the FES and Addendum fail to make a prediction of reasonably ,

sufficient scope and depth, of the nature of the thermal plume we find it l' awkward to specify species.

78. Information not available.

7C. Size and location of areas cannot be specified until the Staff treats the plume in a quantitative fashion.

70. No.

7 E F,G. Information not available.

8A. Addendum at p. 3-10 indicates for downcoast cuurents little can be said about the 4*F surface isotherm [ (b) 8.] and for upcoast currents [ (c) 12.] l only that the 4*F surface isothenn is expected to " cover an extensive area. '

The maximum extent could not be determined in the model, however, due to the limited extent of the thermistor array and the size of the model." Modeling t]ithout results would appear to be inadequate.

l 8 B.C. Information not available.

8707200147 870721 PDR FOIA

, CONNDR87-214 PDR I J

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l 2-9A. No. I

98. Convert the plant into an historical museum.

9C. A thermal plume of vanishingly small size is the only one allowed by a )

reactor operating at a vanishingly low level. l

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9 D,E. Information not available. '

12A. Plant malfunctions ar breakdowns caused by earthquakes may cause a low reliability factcr. In the absence of complete geologic, seismologic, and related structural reviews, it is difficult to make a decision as to reliability factor. Neither OBE nor SSE have been agreed upon. The ASLB must consider the cost-benefit aspects of the plant, and reliability will enter into such a consideration.

128. Quantitative data is not available, but clearly as reliability falls, so do capacity factor and plant availability, and with them the cost-benefit balance swings toward the cost end.

12C. See 12A,B above. We do not know the downtime schedule.

120. We are not sure of the meaning of operational efficiency. But capacity factor and plant availability could be lowered by fuel shortages, accidents including those due to seismic forces, and unrealistic design.

12E,F. Information not available.

13A. This phrase refers to an ECCS which, upon being found to be deficient in design or construction, requires additional work or retrofitting and, therefore, added expenditures.

138. We are not convinced that compliance can be rigorously shown but our instant argument is in connection with 10 CFR Part 50, AppendixA. Our position is that neither Applicant nor Staff has made substantial headway toward ensuring the ECCS (and other plant structures) complies with Criterion

2. There has been no showing that the ECCS can properly withstand the effects of a maximum credible earthquake on the Hosgri-San Simeon Fault Zone.

13C F E. Information not available.

14.A. Both Applicant and Staff assessments of radionuclides buildup in the food chain are inadequate because they fail to consider the effects of ac-cidents, greater than class 8.3, caused by earthquakes on the nearby Hosgri-San Simon Fault Zone, that could result in releases of large quantities of radionuclides that could enter the food chain in substantial amounts.

The accident analyses are improperly based on a postulated earthquake whose maximum expected ground acceleration at the site is 0.2g. Due to the existence of the Hosgri-San Simeon Fault, whose historical record includes a quake of 7.5 magnitude, we cannot accept the 0.29 value. Under the circumstances, we can-not rule out the possibility of a broad spectrum of accidents, including those of Class 9, thus leading to serious radiological consequences and massive radionuclides buildup in the food chain.

I

\ 8 Further, it is to be noted that PG&E has not yet made submittals relative to meeting the criteria set forth in 10 CFR 20 Appendix I. Interveners must be able to review these submittals rather than rely upon Applicant's or Staff's assurances of compliance. (See Sec. 3.4 of FES Addendum.)

148. There has been no clear statement as to the total number of reactors  !

that are anticipated for the State of California. As each new reactor. comes j on line, it adds its increrrnt to the total amount of effluents, releases, and discharges. There is nothing in the documents of this docket that in-dicates the existence of upper limits on effluents established to ensure the health and safety of the public. Certainly a threshold theory of radiation damage, which we understand the NRC to sponsor, recognizes " upper limits." ,

(See Hiroshima and. Nagasaki data.)

We agree with the Acting Deputy Assistant of the Department of the Interior who wrote in a March 28, 1973 letter to Daniel R. Muller, "The environmental impacts of this plant when combined with other thermal-electric plants on the California coast does  ;

not appear to have been properly considered. We think that i the final environmental statement should discuss the contri-bution of environmental effects from the proposed plant in ,

coastal waters from all existing and proposed power plants."

(FES, p. A14-1-23) 14 C. We object to this question on the ground that it is too general.

14 D. We object to this question on the ground that it is too general, however, set forth below are several considerations which Staff documents treat in- 1 t

adequately.

The FES does not treat the radiological impact on plant workers. Sec. 14.13. 7 of the Addendum admits that relative to the radiation exposure to workers, "The total dose for the plant will be influenced by several factors for which definitive numerical values are not available." 4 At p. 5.58 of the FES, Staff observes that "The dose estimated to the thyroid of a two-year-old child from radioactive iodine in milk is 10 times that for an average adult." Yet (FES p. A14-1-17) in FRP Report #4 (p. 23) it states that "It has been estimated that a small number of infants (6-18 months) in localized areas conceivably could receive doses from 10 to 30 times the average."

Section 14.13.6 of the FES estimates that the " Thyroid dose resulting from the ingestion of fresh milk from a cow pastured at 5 mile north-north-west has been changed from 3 to 16 millirems. However, with the present (modified) gaseous source term, this will be reduced to 4,7 mrem." This value is so close to the maximum permissible dose of 5 mrem that an adequate FES treatment would provide a basis for the 4.7 figure. This is particularly important for iodine.

The FES and Addendum has not taken into consideration the possibility of an earthquake on the Hosgri-San Simeon Fault Zone that could cause accidents, including Class 9, resulting in a release of large quantities of radionuclides that could enter the food chain in substantial ~ amounts. .

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All FES doses are given on yearly bases. Interveners consider this to be an improper and inadequate assessment because there is a linear relation between effect and dose magnitude. Therefore all calculations must include total cumulative doses.

A major accident, including Cicss 9, caused by an earthquake on the nearby Hosgri-San Simeon Fault Zone could contaminate air and water with significant quantities of radionuclides. These radionuclides would be carried by wind and water currents to various plants, animals, and humans, thereby getting into the food chain and causing somatic and genetic defects including cancer and leukemia.

14E. We presently have no formal comittments from potential witnesses.

14F. BEIR Report 146. See answers to interrogatories 14 A,B,0 above.

15A. Data of Stewart and McMahan show that right down into the background region, namely a few hundred mrem, an excess of concers and leukemias in infants exposed in utero, showed a linear relation between dose and effects.

The range was from 1500 crem down to 300 mrem.

That cancers are caused by radiation has been common knowledge since the forties, and from the BEIR report at p. 2.

" ... additional expnsure of the U.S. population of 5 rem per ,

30 years (i.e., U0 mrem /yr.) could cause from roughly 3,000 l to 15,000 cencer deaths annually, depending on the assumptions j used in the calculations." l l

The BEIR cemittee as well as the ICRP and NCRP state that in the interest l of the public nealth, the presumption inust be made that effect is a linear I function of dose and that there is no lower " threshold'.' In the field of genetic injury it is also agreed that there is no threshold.

A major accident, including Class 9, at the Diablo plant, caused by an earthquake on the Hosgri-San Simeon Fault Zone could contaminate air and water with significant quantities of radionuclides. These radionuclides could be carried by wind and water currents to plants, animals, and humans, thus getting into the food chain from where they eventually pass to humans, causing somatic and genetic damage.

158. BEIR Report Gofman & Tamplin, "Epidemiologic studies of carcinogenesis by ionizing radiation" presented July 20, 1971 at the Sixth Berkeley Symposium on Mathematical Statistics and Probability.

Stewart and Kneale, " Radiation Dose Effects in Relation to Obstetric X-Rays and Childhood Cancers" The Lancet 7658: 1185-1188, 1970.

Stewart and Kneale, " Changes in the Cancer Risk Associated with Obstetric Radiography, The Lancet, 7532: 104-107,1968 15 C. We presently have no formal comittments from potential witnesses.

. ..t .

16A. (1)

Commission Whether are toPacific collect Gas and Electric epidemiologic dataCo. on and thecancer.

human U.S N

> infant mortalities and other somatic effects, and genetic eff s, leukemias, ects of radio-during the time thereafter. operating lifetime of the plant and fo c period of (2) possibility of accidentsWhether includi the plant set:mic design and con offsite radiological conse(quences.ng Class 9) causing adverse onsite and January 12, 1974, Contentions 1 and 2.][See Petition to Intervene dated, (MFP) 168. (1)

Please see response to immediately preceeding interrog (2) .

include the requested basis.We are preparing a Motion to be sum 16C.D(1)and(2)

Information not available.

tories are true and correct to, information, belief. thees best of g know To Interroga-and

, JOHN J. FORSTER By 4

~Gordon Silver CC: ASLB Members All Parties Secretary, NRC Dated: hly20,1976 ' .

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