ML19242C677
| ML19242C677 | |
| Person / Time | |
|---|---|
| Site: | 07000754 |
| Issue date: | 06/29/1979 |
| From: | Dircks W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML19242C674 | List: |
| References | |
| NUDOCS 7908130186 | |
| Download: ML19242C677 (15) | |
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UlITED STATES OF AMERICA NUCLEAR REGULATORY CC:"tISSION OFFICE CF fiUCLEAR t'ATERIAL SAFETY Afl0 SAFEGUARDS WILLIAM J. C RCKS, DIRECTOR In toe Matter of
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GErlERAL FLECTRIC CCMPAfiY
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Cocket tio.70-754 (10 CFR 2.2C6)
(Vallecitos Nuclear Center,
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License No. 5 'M-960)
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DIRECTOR'S CECISIO:! UNDER 10 CFR 2.205 Cn Cecember 14, 1973, the Friends of the Earth (FCE), San Francisco, California, requested pursuant to 10 CFR 2.206 that the Director of Muclear Material Safety and Safaguards suspend activities under t.icense flo. SiiM-960 at the General Electric Ccmpany's Vallecitos Nuclear Center C/NC).
In addition to suspension of the license, the FCE also requested that all plutonium be removed frca the Vallecitos tiuclear Center and that public hearings be held on future activities at Vallecitos prior to the return of plutoniem to the site. The F0E also asked that the Cc=tission provide the FCE with an. inventory of radioactive materials at the Vallecitos site and structural analyses of buildings at Vallecitos ccntaining radioactive materials.1/
Congressmen Jchn Surton and Ronald V. Dellums, California Assemblyman Thcmas Sates, and other California residents joined the FCE request. 2_/ Similar requests to suspend the license based on new seismic interpretations of the site were recei ted frcm Jan Goldman of ilcrth Fork, California, Marion Hill of Belmont,
-1/ As the FCE requested, tiMSS will provide the FCE structural analyses applicable to the Special Nuclear Material License review when the recorts are ccmpleted.
The operating inventnrics of radicacti'te materials under License No. St;;!-960 in forms conducive to release are listed in General Electric's (GEJ submittals to which the FCE referred in its petition. Because GE has ccc:itted itself not to exceed these levels, these quantities are the only values which are apprcpriate for release cairulations, g3g.tg
-2/ Others joining the FCE's request are J: nice Delfino, Sally Harris, Lore Kohn, and Hiram Wolch of Castro Valley, California; Lo uis Scokbinder, Marjorie Kcenig, Sherman Leuf s, Ann "cctz, Al Murdoch, Jo-Ann Murdoch, and Helen Siai th of Hapicod, California; Lwrence Dans of San Leandro California; and Carbara Shockley of San Loranro, California.
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California, and the Tri-City Ecology Center of Frement, California, and these recuests were consolidated with the F0E's request for consideration. Notice of I
receipt of the F0E's request was published in the Federal Recister on January,10, 1979. 44 Fed. Reg. 2209 (1979).
The bases for the,F0E's request are essentially that (1) the Preliminary Safety Evaluation Report (PSER) issued by the Office af Nuclear Material Safety and Safeguards (NMSS) in November 1977 is deficient in light of new seismic information; (2) Nuclear Regulatory Ccmmission (."RC) estimates of plutonium release frcm the plutonium labs after an earthquake are too 1cw; (3) NRC estimates of plutanium toxicity are tco Icw; and (4) it is inadvisable to allcw the plutonium to remain ensite in light of seismic conditions and the cotential con-sequences of an earthquake at the site.
For the reasons stated in this decision, the petitions to suspend License No. SNM-960 have not presented any nev information wnich would change the PSER under which the Office of Nuclear Material Safety and Safeguards (NPSS) permitted continu-ation of licensed activities under License No. SN.'t-960.
As this decision describes, N:1SS find's that the analysis in its PSER dated November 7,1977, is essentially sound. Based on current analysis of conditions at '!NC and activities under the license, NMSS concludes that continued activities at '/NC unter License No. SNM-960 do net pose :n undue risk to public health and safety. There#cre, the requests to suspend the license are denied.
It is unnecessary to consider the CE's requested r:moval of plutonium from the site and the associated hearing prior to return of h C .t N O
i I plutonium to the site.
In the rcmainder of this decision, NMSS will specifically address the e
concerns raised in the requests to suspend the license with regard to seismicity i
of the site, structural integrity of Building 102, the estimated quantities of plutonium released and its impact on the surrounding populaticn, and plutonium I
toxicity.
Backgrcund As indicated in the Acting Director of Nuclear Reactor Regulation's Order to Shcw Cause 3/ ated October 24, 1977, which suspended activities under Operating
-d License No. TR-1, 42 Fed. Reg. 57,573, the "RC staff met with the GE-VNC staff to discuss all NRC-licensed activities at the site.
Althcugh continued operatien of the General Electric Test Reactor (GETR) was the subject of the Order to Shcw Cause, the safety and envircnmental impact of continuing activities under NRC License No.
SNM-960 were of concern to NMSS. The NMSS staff performed an evaluation of the SNM activities in light of the new geologic interpretations. The November 7 1977, PSER was the prcduct of this effort and was used as the basis for the i
decisicn to permit the activities covered under that license to continue. At the t,
NMSS staff's request, General Electric made ccmmit.'.ents to restrict the activities covered by the SNM license as a result of the staff's preliminary review and the basis used in the pSER. a/- These ccmmitments included limiting quantities, types,
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3/ The issues at hand were the then recently revised ir.ter;retations of the i
geologic and seismic characteristics of the site area.
4] The '.i:ansee's cca.:itments are l.';ted in November 7,1977, pSER cover letter to i
R. W. Carmitrel, Manager, Irradiation' Processing Product Operation, GE VNC, frcm Clifford Y. Smith, Jr., Of ractor, NMSS.
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and fora of materials used at the site, restricting presence of explosive a.cd fler:able matarials in all buildings containing special nuclear material, draining i
of Lake f.ee which was located on the site, anc rastricting operations in Cell fio. 3 of the Radioactive Materials Laboratory which involve fission product or radicstope separation.
a The staff's evaluation as presented in the PSER was based en consideration of the falicuing infernation:
1.
GE VNC's SMN-360 license renewal application and supporting license renewal dccu=ents,5/
2.
Cral presentation made by GE staff in 3ethesda, tiaryland as documented by GE in a November 12, 1977, submittal, 6/ and 3.
The staff's firsthand information and data relative to the then ongoing activities.1[
With respect to the issues specifically raised by the FCE, NMSS believes for the reasons stated in the remainder of this decision that, based on current information, the PSER is a conser/ative cssessment of the consecuences of a seismic event of unspecified high magnitude at VNC.
-5/ At tnat time the NMSS staff and its consultants were reviewing GE VNC's SNM-950 License Renewal Application and su;ccccing license reneual dccuments.
These dccuments may be examined at the local reading reca set up at the NRC Cffice of Inspection and Enforcement, Region V Cffice lccated at 1990 N.
Califcrnia Sculevard, Suite 202, Walnut Creek, California 94596, and at the NRC Public Document R:cm iccated ac 1717 H Street, N.W., Washington, D. C. 20555.
-6/ Letter to Clifford V. Smith, Jr., Director, N.'iSS frcm R$ N. Darmitzel, Manager Ir-adiati:n ?rocessing Pr duct Operation, GE VNC, dated November 12, 1977.
-7/ The firsthand infccmation and data collection was cbtained thrcugh a staff site visit on Oct:ber 25 and 26,1977. This infccmation was documented thrcugh a memorandum to R. W. Starcstecki, Chief, FCRR, frca N. Burkhardt, FCRR,
Subject:
" Trip Repcrt - GE Vallecitos Nuclear Center, October 25 and 26,1977" dated December 12, 1977.
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. I Seirmicity of the Site i
For purposes of the preliminary safety evaluation the staff based its i
review on c:nservative simplifying assumptions which would provide upper bound i
environmental and safety impacts on the surrounding area.
Under the PSER's analysis, a hypothetical seismic event of unspecified magnitude was assumed to occur which would result in structural failure of varying degree to all buildings bousing activities covered under the Sti:1 license.
Engineering judgment was used to provide the sequence and extent of failure used in the analysis which is described below. This approach provided a mechanism to determine the maximum f
credible impact of such an event on the surrounding area. Contrary to the FCE's understandir.g, the PSER is not based on an earthquake at the site which cculd produce ground acceleraticn of.759 Again, the PSER assumed a hypothe ical seismic event cf unspecified magnitude that resulted in significant structural failure.
Structural Intecrity of Buildine 102 In analyzing activities under the Siu1 license at WC the tiMSS staff was con-cerned with the structural failure of the m ifldings which would result in the potential generation and release of an aerosol ccmposed of particles less than 10 um aerodynamic equivalent diameter (AED),S! or less. The staff by ensite examination of the $l:M activities estimated the cuantities of material at risk 3/
c in process as well as total inventories. As stated in the OSER, N MMSS deternined
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A particle exhibiting the aerodynamic behavior of a unit-density sphere of the stated size.
-9/
Pc.terial at risk is material that is in a location and condition such that it is a/ailable for release in the event of breach of confinement.
-10/ The locations of quantities of materials that could be released durir.g a catastrochic event was discussed in great detail in the PSER,Section III,
""at:riais At Risk, pages 11-20.
This discussion provided the basis for the staff's detcraination of Building 102 as the caly location which could> %ctm
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crovicn a,icnificant scurce term for matorial availabic for release.
i that Building 102 was the only building that contained a significant invencery of radioactive material available for dispersion.
The quantities of radioactive material hcused in other '/.1C facilities are either small or otherwise contained scch that significant dispersal following a seismic event is unlikely.
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Cuilding '02 hcuses the Advance Fuels Laboratory (AFL), the Plutentum Analytical Labo atory (PAL), and the Radicactive "aterial Laboratcry (F2L). The l
PAL and RML activities are assentially located on the first ficor of Building 102.
The AFL operations are located in the basement of Building 102.
The PSER assumed the fol'cwing mcdes of structural failure for these three laborr.:ories:
Adva:tce Fuel Laboratory (AFL)
Cracks des alop in the walls and ceiling with sections of the ceiling failing en glove bexes causing a breach of confinement.
Glove boxes shift frem their ncrmal location and lose their leak-tight integrity.
Plutonium Analytical Laboratory (PAL)
The walls and ceiling of the PAL, which is lccated en the first ficar of Building 102, collapse.
Gleve bcxes are overturned and crushed by falling debris.
Radicactive "atarial Labcratcrv (RML)
The first ficar walls and ceiling that surrcund the feu.-
main hot cells collapse.
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Intercennecting ductwork and utilities in the RML collapse.
In-cell liners remain intact but filters are punctured.
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l The failure mcdes were a conservative estimate of the impact of a seismic t
event cf the structures for the folic,iing reasons.
The analysis assumed total collapse of the PAL. Tot:1 collapse cf the AFL was not assumed since it is 1ccated in the basement and tctal collapse would result in merely burying the I
material. Thus, total collapse of the AFL would not provide a pathway for the plutonium to escape from the AFL. In assuming partial collapse frca ceiling cracks and sections of concrete falling on gicve bcxes to breach confinement a path was provided for the material tc escape thereby increasing the possibility of release.
It shculd be noted that since the issuance of the pSER, GE-VNC has tied dcwn all glove boxes in the AFL t: increase the resistance to the forces of a sef snic event.11/ Collapse of all RML s?cuctures was assumed except che four main hot cells. The hot cells were assumed to maintain their integrity because they are massive structures, with 2-3 feet thick reinforced concrete walls, ficors, and ceiling. Approximately 70% of the volume of the belcw grade box structure (base mat, fcundation walls, and cell ficor) is concrete. The volume of above grade structure (cell walls and roof slab) is approximately 50% concrete and steel.
The staff develoced scenarios and made simplifying assumptions that impcsed more catassrechic effects utan the facilities than wculd be realistically expected if NMSS had completed a fuli geclogic and structural review of the facilf ues in question. Eased on the aforementioned damage scenarios, scyrce terms were derived for use in the calculation of radiolcgical consequences,
~~~11/ In develo?ing a scurce tem, NMSS assumed that '.he glove boxes wculd overturn, tumble around, lead the glove bcx air with plutonium, and would then be crushed by a large chunk of AFL ceiling.
By tying dev,n the gicve boxes, GE-VNC has reduced the ccssibility of this situation cccurring and thus reduced the possi-bility of material release since vibratory motico alone will not significantly load the air with plutonium.
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-S-Releases and oses i
The releanc mechanisms presented in the pSER *.;ere first generatico material transport medels (i.e., puf f release and constant conti tucus release).
Engineers use this bounding technique as a first cut at the problem to see whether or not a problem exists and what the controlling features are.
In this approach, the assumptions made were simple in nature :: 'ening release not hindered by trans-i portatien mechanisms,vhich would reduce the quantities released and projected impact on the surrounding area, such as plutonium deposition within the area and 50".
metecrology.
Using the simplified approach as presented in the first generation medels, the assumptions used enccmpassed the suspcasion mechanisms such as aftershocks and winds although they were not specifically identified in the analysis.
In the development of the pSER source terms, NMSS assumed the current working level i
inventories for the varicus processes and experiments, and devised release mechanisms based on the aforementioned damage scenar'os.12/ It was asred that the glove boxes wculd overturn, tumble around, load the glove box am with 3
plutonium in concentrations of 3C0 mg/m, and then the glove boxes would be crushed by large cnunks of the AFL ceiling breaching the glove box and releasing the material.13/ This methcdology provides suspension mechanisms for release that are greater than one wculd expect frcm suspension of material as a result of after-shocks and winds.
H/ As noted earlier, GE has cc=11tted itself to restrict cperaticns to the current 9:neking level inventeries.
3 H/ Experimental data shcws maximum air leading factors of ICO mg/m. Thus, the PSER's assumption of 3C0 mg/m air Tcading within the glove boxes is con-servative by a factor of 3.
J. M.
elby et al. " Consideration in the Assessrent of the Consc<;uencts of Effluents frca.-lixed Oxide Fuel Fabrication Plants",
3NHL-1697 Rev.1. Battelle Pacific Northwest Labcratory at page 76 (June 1975).
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With respect to the AFL, aftershocks and winds are not considered a major i
factor in determining the upper bound material release quantitics for the e
follcuing renons. Becauss. of the location of the AFL and of the physical I
properties of pittoniuh, aftershocks and winds play a mincr role in the transport of material cut of the AFL rubble af ter the primary earthquake movement has taken j
place. 14/ The winds would have to folicu a torturous path to reach the plutonium in the AFL. Nind speed reduction wculd occ.r because of surface drag and dirccticnal changes since the wind viculd have to pass tnrcugh a hole in the bastment ceiling, descend to near the basement ficer and find its way through the rubble to reach the bulk of the plutonium. The wind velocity at that point wculd essentially be zero. Most plutonium would be covered with rubble. ibratory motion as a result of af tershocks will not suspend a significant amcunt of material. The glove box has already been crushed after the first earthquake strike.
Thus, the potential i
I for additicr.al air loaoing has been greatly diminished. Co sidering these factors, i
suspension of material due to aftershccks and winds wculd be credited to the i
initial release as prese.nted in 1.':e pSER.
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Fire was not considered as a mechanism for dispersion of plutonium since the laboratcries did not centain an appreciable amcunt of flammable material. As I
i explained in the PSER,
" potential secondary effects including fires, explosien-I and ficcding, were considered by the staff since tEese events may represent means by which material can beccme mcbilized.
The absence of appreciable quantitics cf fla=abic materiai
-14/ Winds aere carisidered in the analysis of the hot cells and the p/L.
For the hot cells the effect of :inds.;cre inccrporn?d as part of the breathing rate of the damaged cells PSER at page 23.
For the PAL, the effects of winds were considered in the assumptinn of piutoni'.1 flux frca the floor or 1 x 10-d/ scc.
for the nitrate and 6 x 10-8/sec. for the pc.eder, PSER at page 26.
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. lessens the potential for fires. This has been verified independently by the staff. Consequently heat sources, such as electrical short circuits, are not likely to result in severe fires. GE has agreed that no adcitional quantities of fla=able materials shall be used or stored in these areas without prior URC approval. -
The license did state the 6 percent pre-mixed hydrogen / inert gas is stored onsite cutside Building 102 and is made avail-able through a piping system to the AFL for use in the sintering prccess. Also, a limited quantity of quenching gas is present. The licensee does not consider these gases as explosive mixtures. The staff agrees. The licensee stated that no explosive mixtures are stored in the RML and AFL. Therefore the staff did not assune this as a credible mechanism for dispersing piutonium.
GE nas agreed that no such materials shall be used or stored in these areas without prior URC approval." (PSER, at pag.es 17-18)
The NMSS release esticates, as calculated fcr the assumed structural failure, have been recently confirmed by the Pacific Northwest Laboratory (PNL).
Follcuing the issuance of the PSER, the staff asked PNL to independently review its estimates of consequences.
PNL's findings are contained in a report entitled, "Scurce Term and Radiation Dose Estimates for Postulated Damage to the IC2 Building at the General Electric Vallecitos Nuclear Center", dated Fecruary 1979, which is attached to and made part of this Decision.
PNL developed three scenarios representing significant levels of less of ccafinement due to mcderate, substantial, and majcr damage to Building 102 at 7:iC.
The damage scenarios were not correlated to any specific level of seismic activicy.
The three scenarios are:
1.
Mcderate damage scenario - perforation of the encicsures in and the structure comprising the Plutonium Analytical Laboratory.
2.
Substantial damage scenario - complete loss of confinement of the Plutonium Analytical Laboratory and loss of the filters scaling the inlet to the Radioactive.!aterials Laboratory CTIC7c#
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hot cells.
3.
itajor damage scenario - the damage outlined in (2) plus the perforation of enclosures holding a significant inventories of dispersible plutonium in and the structure ccmprising the i
Advanced Fueis Laboratory.
The results of the PNL review have shcwn that for the worst case (major damage scenario) the maximum-exposed individual was estimated to receive 0.7 rem to the lung and I rem to the bone, which are comparable to the doses presented i
in the PSER (PSER Table V-2 at page 31). The calculated 50-year committed dose is equivalent to 50 years of exposure to natural background radiation and medical X-rays.
Releases frca the failed structures, if any, are expected to be controll6d after any earthquake. Temporary isolation of the material frca the environment may be achieved through several methods.
For example, large clastic sheets i
can be drawn over the ' openings, thereby depriving the material of exposure to driving forces of winds. After the releases o m Tontrolled, clean up can proceed in an orderly fashion such that add.ional releases, if any, will be as icw as reasonably achievable and are not expected to exceed levels greater than those specified under 10 CFR Part 20, " Standards for Protection Against Radiation".
Cnce controlled, the clean up at '/NC wculd not pese extracrdinary problems that would preclude use of normal procedures for decantamination'of the site, 4
i Pre-clean up and decontumination for the offsite area will not pose a health and safety problem as a result of the postulated catastrophic earthquake.
PNL's estimates for the worst case scenario indiciate that the maximum residual plutonium contamination, as a result of a three day uncontrolled continucus release, are L5571(?[563
. I within EPA's proposed guidelines of 0.2 aci/m?
Therefore, there is no indi cation that offsite clean-up and decontamination will be necessary since the postulated ground contamination is belcw the proposed E?A standard, i
Water contamination will not be a problem, even assuming that the basement floor has developed cracks. Because of the transport properties of plutonium in either the oxide or nitrate form, transportation through the soil into the grcund-water is an extremely sicw process. Significant groundwater contamination by plutonium migraticn through the soil is impossible because of the time require-ment, plutonium concentraticn in the soil, the end plutonium concentratica in the groundwater, and the dilution factors involved with groundwater motion.
Centamination of the nearby San Antonio reservoir is not considered in the PSER since the dam for the reservoir is located cn the considered fault netwerk.
If the earthquake destroyed the dam, there would be no reservoir, buc assuming dam failure,'no flooding of the VNC would cccur since the topography of that regicn would not peruit flocding of the site. Even if the dam withstocd the earthquake, that reservoir along with the others in the area would not be signifi-cantly ccr.taminated due to the volume of water contained in these reser/cirs as ccmpared to the quantities of plutonium released. By way of comparison only, and not to est:blish a guidaline for accidental releases, any contamination of bcdies of water would be expected to be well helow the concentrati5n limits established in 10 CFR Part 20 for releases to unrestrictcd areas.
As further assurance that the impact of such an event will be minimized, GE VNC has a writtan emergency control plan for the site. The plan meets the re-quirements for plutenium handling facilitics as set forth in 10 CFR 70.22(i),
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i Specific plans have been developed for various emergencies including carchquakes.
I Suilding emergency teams have been trained in the use of survey instruments, pro-i tective apparel and remote manipulation equipment.
Periodic drills are conducted to assure adequate perscnnel response to emergency situations, and responsibili-I ties are designated idr maintenance of communication equipment and standby equip-ment and instruments. Arrangements have been made for hospitals, with supervision by ccmpetent nuclear safety personnel, to receive and care for injured who may be ccntaminated.
During an emergency the General Electric Test Reactor (GETR) shift supervisor is assigned control of all emergency operations and insures coordina-tion between the Emergency Control Organization and outside organizations such as law enforcement agencies, fire control agencies and mutual aid organizations.
This respcnsibility includes the operations at the laboratories which house the 4
SNM activities.
Plutonium Toxicity l
In the PSER, the Staff ccmpared the calculated dcse consequences with annual expcsures for cccupaticnal workers allcwed on a routine basis under 10 CFR Part
- 20. The doses frcm the assumed seismic event were found to be of the same magnitude as the aforementioned regulatcry dose limits. The use of the regulatory limit was not intended to establish guidelines for accidental releases and the resultant estimated deses. They were used to put into perspective the consequences of such a pcstulated catastrcphic event for ahicn no definitive criteria exist.
To the extent the Friends of the Earch challenge the validity of the dose tevels given
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in 10 CFR Part 20 and postulate greater material toxicity than now assumed by the Commissicn, that challenge is essentially directed to the Ccmmission's regu-lations and should be addressed in a petition for rulemaking to the Ccmmission.
Conclusion Continued operaticn of activities covered under License No. SN:i-960 does not 9
pose a significant health and safety risk to the public.
The F0E petiticn and other requests to suspend License No. SN"-960 have not provided new information that would chance NT4SS's ccnclusions as presented in the PSER. fioreover, the plutonium release estimates presented in thq PSER were recentiy. cenff.nred by FNL, Nonetheless, NMSS is continuing to evaluate the effects of seismic phecnemena on the VNC site. Before the Order to Shcw Cause for the GETR was issued, N"$5 had initiated a program of analysis of the effects of abnormal natural phencmena (earthquakes, severe weather and flooding) on existing cc=mercial plutonium research and develcpment and fabrication facilities, SE/ ncluding General Electric's i
Vallecites facility. This natural phecncmere review program will provide a
.ealistic assessment of the range of likelihecd o' occurrence and credible con-sequences of natural phencmena.
In the course of the analysis of the effects of natural phencmena, MMSS will refine the release calculations on the basis of the structural response to specific seismic events and the risk asscciated with ccntinued S"l1 opera tions.
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James E. Ayer and Winsten Burkhardt, " Analysis of the Effects of Abnormal Natural Phencmer.a en Existing Piutenium c bricatico Plants", presented a
at American "uclear Scciety Tcpical Meeting, Sal Harbor, Florida, "ay 2-4, 1977.
The paper dealt with the acprcach being used to perform :he analysis.
It does not present the results of the analysis.
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These reviews will, of course, take into account the latest evidence regarding the geologic and tectonic conditions at the Vallecitos site.
A copy of this Decisicn will be placed in the Commission's Public Document Rocm at 1717 H Street, N.W., Washington, D.C. 20555 and the local reading rocm for VNC set up at the NRC's Office of Inspection aad Enforcement, Region V, located at 1990 N. California Soulevard, Suite 202, Walnut Creek, California 94596.
A copy of this decisicn will also be filed with the Secretary of the Ccemission for its review in accordance with 10 CFR 2.206(c) of the Commission's regulations.
In accordance with 10 CFR 2.206(c) of the Commission's Rules of Practice, this decision will constitute the final action of the Commission twenty (20) days after the date of issuance, unless the Ccamission on its cwn motion institutes review of this decision within that time.
D William J. Dircks, Director Office of Nuclear Material Safety and Safeguards Dated ag Silve7 Spring, Maryland this Lday of \\s,1979.
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Enclosure:
PNL Rpt.
"Scurce Term & Radiation Dose Estimates for Pos;ulated Damage to the 102 Building at the General Electric '/allecitos Nuclear Center",
dated Tebruary 1979.
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