ML13303A253
| ML13303A253 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 06/10/1981 |
| From: | Rood H, Sears J NRC/IE, Office of Nuclear Reactor Regulation |
| To: | Friends of the Earth |
| Shared Package | |
| ML13303A252 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8106170047 | |
| Download: ML13303A253 (9) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
SOUTHERN CALIFORNIA EDISON COMPANY,)
)
50-362 OL (San Onofre Nuclear Generating
)
Station, Units 2 and 3)
)
NRC STAFF FURTHER RESPONSES TO THIRD SET OF INTERROGATORIES BY FRIENDS OF THE EARTH Interrogatory No. 1:
State whether the N.R.C. (or F.E.M.A.) will require the state and local governments, and other off-site assist agencies to consider the impacts of a major earthquake upon their emergency response plans.
NRC Staff Response The NRC Staff has the responsibility for reviewing the Applicants' emergency response plans. With respect to the emergency response plans for the San Onofre Nuclear Generating Station, Units 2 and 3, the NRC Staff has requested that the Applicants consider in those plans the effects of earthquakes. This request was initially made by letter of December 17, 1980, and was subsequently clarified by letter of May 13, 1981. It is my understanding that a copy of the December 17, 1980 letter has been provided to the Licensing Board and the parties in this proceeding.
The May 13, 1981 letter has also been provided to the parties and will shortly be provided to the Licensing Board.
With respect to the degree of consideration to be given to earthquakes by Applicants, the planning basis should assume the 8106 170097
e-2 occurrence of a moderate earthquake and consequently need not assume earthquake effects more severe than the Safe Shutdown Earthquake (SSE).
The moderate earthquake to be assumed for the planning basis of the Applicants' eniergency-rdsponse plans may seribusly challenge transportation and communication systems. Consequently, Applicants' emergency planning should consider (1) the ability to transport necessary personnel to the nuclear facility to support it, (2) continued communication between the facility and outside agencies, (3) the ability to obtain both onsite and offsite damage estimates to factor into the decisionmaking process and (4) the development of a range of recommendations to take into account the situation produced as a result of the earthquake.
Emergency plans need not be explicitly written to respond to accidents created by failure of plant systems designed for the SSE as failures of such essential safety systems have been made adequately low in likelihood by explicit design against earthquakes at and below the SSE level.
In addition, the characteristics of an accident which could theoretically be created by an earthquake larger than the SSE would be in the spectrum of accidents considered in determining the sizes of the emergency planning zones and the other planning elements which form the Commission's regulations in the area of emergency planning.
Consequently, in planning for a moderate earthquake and meeting the planning standards set forth in the Commission's regulations, an emergency response base capability would be in place which could be expanded during an actual emergency. Emergency planning for less than worst-case events gives confidence that the occurrence of any of a
-3 spectrum of events, including very low likelihood events, would give decisionmakers a planning base from which specific actions could be chosen from among available alternatives.
Interrogatory!Nor2,:gatory :o 2 If the answer to the foregoing interrogatory is in the negative, state how these emergency plans will be adequately coordinated and integrated in order to protect the public health and safety in the event of a major earthquake.
Response
See Response to Interrogatory No. 1.
Interrogatory No. 3:
If the answer to interrogatory number 1 is in the affirmative, state whether the N.R.C. (or F.E.M.A.) will direct the state and local governments to revise their emergency plans to include the possible impacts of a major earthquake upon transportation routes, communications systems, medical facilities, etc.
Response
See Response to Interrogatory No. 1.
Interrogatory No. 4:
If the answer to the foregoing interrogatory is in the affirmative, state when the N.R.C. (or F.E.M.A.) will direct the state and local governments to revise their plans.
Response
See Response to Interrogatory No. 1.
Interrogatory No. 5:
Is the N.R.C. of the position that an earthquake which exceeds SSE levels will cause damage to more than one reactor located at the same site?
NRC Staff Response:
The Staff position is that seismic Category I structures, systems, and components at San Onofre 2 and 3 are designed to remain functional
-4 during and after the SSE, as required by 10 C.F.R. 100, Appendix A.III.(c).
Further, these structures, systems, and components have sufficient margin that theyare capableof withstanding earthquakes. that exceed the SSEc' Howe.erV^the Staff has not evaluated in detai the degree of margin available. If a sufficiently large earthquake in excess of the SSE is postulated, such a highly improbable event could cause damage to one or both reactors at San Onofre 2 and 3.
Interrogatory No. 6:
If the answer to the foregoing interrogatory is in the affirmative, state whether the N.R.C. has directed applicants to evaluate the possible effects of a "simultaneous release-," as defined in 10 CFR 100.10.
NRC Staff Response:
Simultaneous releases at sites having multiple reactor facilities are covered by.10 C.F.R. 100.11(b), not 10 C.F.R. 100.10 as stated in Interrogatory No. 6. The Staff has not directed the Applicants to evaluate, pursuant to 10 C.F.R. 100.11(b)(1), whether or not the San Onofre reactors are independent to the extent that an accident in one reactor would not initiate an accident in another. This is based on the Staff's evaluation that the reactors are independent to the extent that an accident in one reactor would not initiate an accident in another.
With regard to simultaneous releases which might result from earthquake-induced damage at both units at San Onofre 2 and 3, the Staff position is as follows. The likelihood of occurrence of an earthquake, which so exceeds the SSE that it could cause a simultaneous release of radioactivity at both units that exceeds the 10 C.F.R. 100 dose guidelines, is so remote that it need not be specifically considered, either in the plant design or in emergency planning.
-5 Interrogatory No. 7:
If the answer to interrogatory number 5 is in the negative, state the N.R.C. position on the issue of "simultaneous release" caused by a major earthquakee a
run m
- v.
NRC Staff Respo6ise See Response to Interrogatory No. 6.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
SOUTHERN CALIFORNIPAEDISON-COMPANY-)"
'^'>
Docket Nos.
50-301 O.L.
)
)
50-362 O.L.
1--3 0
(San Onofre Nuclear Generating
)
Station, Units 2 and 3
)
AFFIDAVIT OF JOHN R. SEARS I am a senior reactor safety engineer in the Nuclear Regulatory Commission Staff's Emergency Preparedness. Licensing Branch.
The NRC Staff Responses to Friend's of the Earth Interrogatories served on February 18, 1981 and numbered 1,2,3, and 4 were prepared by me. The re sponses given are true and accurate to the best of my knowledge.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on June/q 1981.
John R1 Sars
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of 3
SOUTHERN CALIFORNIAEDISONCOMAPANY Docket Nos. 50-361 0.L.
50-362 O.L.
(San Onofre Nuclear Generating Station, Units 2 and 3
)
AFFIDAVIT OF HARRY ROOD I am a senior project manager in the Nuclear Regulatory Commission Staff's Licensing Branch No. 3.
The Responses to Friend's of the Earth Interrogatories served on February 18, 1981 and numbered 5, 6, and 7 were prepared by me. The responses given are true and accurate to the best of my knowledge.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on June 9, 1981.
Harry Rood
'.w g,*nta'O~ki&ow1 It, an d 4 or the Third -Set air Intorrcgatorlas by Frimt o? the Cat~h =*pat-t th M2lederal Fmargenimy Mmei*Agency' (In4A) h= ttM CUthorlty to "requirsO or "diret" statew and local govarnmants to US=c Crtein act ions..This is nuft the case.
VEtIA hao a major role piroviding assistance ' nwd guidance Ito state anid local apjelciea nd It does..
rot dlrod.VVy tat8 or local egency to meet. any requiremnts, W1th ramipr~ -to esrthquafke 'conaiderst lm ?bw the Saon Onafre Muclear
~~r~woting~
S-tin andis 3i (SOWS: 2 & -3)
ENA hesiconsid~red garthqweko effets in wmikng its. Interim findings-and Determination Fo1at&n to the Status at' State end Local (argoricy, Ireepredneiss fair the am Onofre ruclear GenerstIng Stot ion (JUits 2 w-td.3) dated Jwve 3, 1991'.;
F'OR, purposes of the avalusstioi, earthuk of facts n~o m~ore OWvew then UM Soire Shiutdo" Earthquakea (SSE). tma a i
to occur ineowetly of a eertot ecoldont.
Yhis planning haste im deamied'aidequate given the:
muw3bteztsl conservetiam applied by the Muclear Regulatory Cmisslon (MfRC)
In astabliehing the SSE,, and ths resulting low likelihood of Ito occurence.
Even should such a low likelihood event occur,* a planning be-se would be.
ailabdo WWd could be expended. to mvet actual *conditions, given a state' of awr~mncy prepairedneais in conlrorpsce: with the esergmwy 'prarednewsa plamng stwndei of 10 CFR sub-saction 5..7 fin Its eminatao or state mw ioci ploans, FEt4A comiluded that, uhiXS.
Mwrant plans reflect, no direct imseam~vnt of onrthq uske I mwai a) I pl~wmig to date clues considur the ramifications of. such evsrsts and a "msel cepability ouists to respond through basic emergency planning to chat we, ownaidered to be the swat likely and froquvn& levels or seloauic it is IFR1 futhi conclusion. that the emrgency prepsrdm ofr off-alto jwliclcons reflects a level of -preparedness through existent beesic plaiming to wiviloal ly rrasporWz to the patimtial* seismic -problem.
FDOA Antiwie to work actively with both the state 10d loc goverrimenta ina joint dinmlop~rimntl endeavor to. aodifyexisting planninmg to place Uvaso Jurisdkction In a better position to respond to potwntIal earthquoet~
Inte~aory3.
If the answer to the foregoing interrogatory Is In the negqative,, state howf Ithves e rgsncy plans wlll be aqutely coordinted and Integrated In order to pvoot the public health end sarety In tthe event -ii a wajor eartuoks.
ftm a
S"e wnwe r to. Interrogatory I1.
Ir ml esiarto the rorG901ng Inter rogatory in In the offirmat.1vey, state W t"e MW~ (or rENA) will direct the state and local governtments to revisa their p' aSeep wnwo r to interregatorylI.
MUMT STATES OF AIXERXCA In' VQ FA2~@t of)
MJTHEft? CALIFORNIA EDISON COMPANY)
IDoclt Nba. 50O-361 0.1.
I
~"-362 0.
( a nofrr Rmnlear Gorvratlnq'
)
Station* UnIta 2 and 3 AFFIDAVIT OF Robert T. Jeake t Qhe Acting Dir=.-tor of the Radiological. Eaner~ensey Preprdneas Division,.
rodarm Eavrgamby Hene mnt Agency..
v t
- vhe, to ttv Criendo or the Earth 1nterroqtor1ees erved an February 18y 1981 MmO~~brad 1. 3, and 4 wor prepsared by m6e The rmsporwss given are trum mnd eccurstoe to the beat of my knoweledge.,
I cbelore undr pealty or perjury that the foregoing Is true ndcorrect.
Ewvcutod on Jun~e Ill 1951.
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