ML19308A706
| ML19308A706 | |
| Person / Time | |
|---|---|
| Site: | Salem, Crane  |
| Issue date: | 09/18/1979 |
| From: | Beverly Smith NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | John Lamb, Milhollin G, Shon F Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML16341B242 | List: |
| References | |
| NUDOCS 7912040118 | |
| Download: ML19308A706 (1) | |
Text
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cr Dr. Ja::es C. Lamb, III,,
Cary L. ?.'ilhellin, Esq'., Chairman 213 W-:dhaven Read,,
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}.f r. Frederick J. Shoo
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At mi-S-fc:f znd Licenring Board Panel L'.S. Nuclear Regulatory C:==ission
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In the ?.'at:cr cf Public Service Elec:-ic t. Gas Cempany
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(Salem Nuclear Generating Stat:en, Unit ho. D.
- Docket Nc. 50-272 (Propesed Issuance of Amendment to Facility Ooeratine License No. DPR-70 Gentle:ien:
the Ecard made reference to the enciesed
- 10. 1979, In an Order dated September from l'.r. Lee V. Gossick, Executive Director for Operations,
letter of June 29, 1979
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to Congressman Robert J. Lagomarsino in which the statement was made that "
Since should be noted that the Three ?.'ile Island accident is not a Class 9 acc the date of that letter, the Staff has had an oppertunity to consider this cuestion further,, and its current position on the classification of the Three l'ile Island a is found in the "NRC Staff Response to Board Question No. 4 Regarding the Occurren:
of a Class 9 Accident at Three 13ile Island."
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Barry H. S=ith
. Counsel for NRC Staff i
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Enclosure:
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Uf!!TED STATES f;UCLEAR REGULATOF.Y CC".'.*lSSIO*J
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50-275 and 50-323 5: M:r- :ble P:be-t J. I m ecinn United States House of Representatives k'ashington, D.C.
20515
Dear Congressman Lago.arsino:
I am pleased to respond to your June 1,1979 letter identifying contact with representatives cf citizens in California who have levelled critici:r.s at the Diablo Canyon plant.
Since my May 25, 1979 letter te you responding to your April 24,1979 referral of a constituent's letter has already addressed some of the con: erns expressed in your most recent letter, scme cf the ans-wers here will refer to the May 25th letter.
I should also note that Chair-man Hendrie is responding to your April 2,1979 ietter.
The first identified criticism requested a study cf the consecuen:es of a Class IX(9) accident at the Diablo Canycr plant.
The occurrences in Class 9 involve sequences of postulated successive Oilures more severe than those p:stulated for establishing the design basis for protective systems and engineered safety features for proposed nuclear power plants. Their conse-quences could be severe.
However, the probability of their occurrence is se
.small that their environmental risk is extremely low.
Defense in cepth (multiple physical barriers), quality assurance for design, manufacture, and coeration, continued surveillance and testing, and conservative design are all applied to provide and maintain the required high degree of assurance that potential accidents in this class are, and will remain, sufficiently remote in probability that the environmen al risk is extremely low. These various means for assuring the low probability of a Class 9 acciden; are very thoroughly revit.<ed and evaluated by the fiRC staff during the licensing safety *eview.
In addi-ion, the site must nes: certain site evalua-icn cri-teria s:ecified in 10 CFR Part 100 - Reactor Site Criteria (see 1100.11, for e nnpie ).
The criteria are determined upon eva~ uation cf a particular fissict product release, an expected leak rate fro containmen, application of mete:r-ological conditions perti'.ent to the site.
Eased on these analyses, the appli-cant must derive an exclesion zone, a low population zone and a population center distance that ree'. the bases established in !100.11 (a), (1), (2) and (3). The staff has def. ermined that the Diabic Canyon site nee:s the estad-lished criteria, and ha, described the site acceptability ir. the Final Envi-ronmental Statement fe. the Diablo Canyon,Nucitar Generating Station (May 1973).
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The Honorable Robert J. Lagobarsino _
It should be noted that the Three Mile Island accident is not a Clas However, the review of that accident will be carefully evaluated for possible implications regarding Class 9 accidents, and the results will accident.
Le applied as appropriate.
Regarding the question on seismic problens, ny earlier letter addressed th I will add however, a brief excerpt from my Fay 30, 1979 letter to subject.
Governor Ednond G. Erow., Jr.
7 k'ith respect to public concern regarding the adecuecy of the Diabic Cany n plant to withstand earthcuakes, that matter was extensively dealt with during the course of the public hearing on the Diablo Canyon application.
Expert testinony was presented to the Licer. sing The Licensing Board will take Ecard by parties to the proceeding.
this testimony into account in reaching its decision regarding the The Licensirg Eca-d's decision will be subject to ' appeal Epplicaticn.
and review by the NRC Atomic Safety and Licensing Appeal Ecard and the Conmission.
Regarding the emergency plan, the NRC had concurr nia plan was the San Luis Obispo County response plan for nuclear powtr plants
!!e now lock forward to reviewing the energency preparedness naasures being power plant Review Fanel.
You nay be revised by the California Emergency assured that they will be given careful consideration in our evaluation of the adequacy of emergcncy plans for the Diablo Canyon plant to assure the l
public health and safety.
letter discussed our ongoing reviews of the Three Mile Island My Fay 25,1979 accident and the planned application of that study to plants that are cur-In rently under construction and have apolications for an operatin; license.
ansucr to the last item in your June 1,1979 letter, before censiderin; issu-ante of an operating license for Diablo Canyon, we cast deterrir.e that there risk to is reasonable assurance that the plant can be operated without ur.du the health and safety of the public.
Sincerely, G i r.: C L:a'.'.~:::::.:,
Lee V. Gossick l
Executive Director for Operations
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August 24. 1979 Roger J. Mattson, Director, TMI-2 Lessorts-bearned Task Force NOTE T0:
FROM:
Fredric D. Anderson, Site Designation Standards Branch Division of Siting, Health & Safeguards Standards
SUBJECT:
CO:*F.ENTS O!! RESPONSE TO BOARD QUESTICN CONCERNIf;G CLASS 9 ACCIDEf;TS (t:0TE: MATTSON TO CUNNINGHAM, 8/16/79)
I reviewed your response to the Salem spent fuel board question on Class 9 accidents and the TMI-2 accident.
I disagree with the position taken by the Task Force regarding the TMI-2 accident being classified as a Class 9 accident as defined in the proposed Annex to Appendix D cf 10 CFR Part 50 (stated in Appendix I to R.G. 4.2, Revision 2, July 1976).
I have reviewed
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this position as a concerned NRC staff mer.ber and one of the staff listed in the et list for your reply.
In truth, the definitions for accident classes as given in the Annex for er.vironmental reports are not applicable to the detemination of an actual I
accident. Actual accident scenarios should not be forced to match the perceived analytical models for accidents used to postulate potntial consequences.
Because of the many differences expected in acci. :t scenarios depending upon the purpose for the evaluation, the NRC staff uses different accident scenarios (classes) for analyzing system failures as given in SRP and R.G. 1.70, for analyzing consequences from design basis accidents as given in SRP, R.G. 1.70 and specific guides such as R.G. 1.3, 1.4, 1.24, 1.25 etc., and for analyzing environmental impact from accidents as given in R.G. 4.2.
Therefore, the correct answer to the Board question vould be that the Class 9 accident nomenclature was not applicable to assess any real
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accident scenario.
If NRC feels compelled to respond to the Class 9 accident questian for TMI-2 in a manner consistent with the conceived public understancing of a Class 9 accident, the answer should be that the TMI-2 accident pas not a Class 9 accident.
The reason is that the commonly held definition for a Class 9 l
accident is an accident resulting in fuel melt with failure *of engineered safety features designed to mitigate the consequences of the accident --
the extreme case is containment failure.
Since TMI-2 did not experience fuel melt or ESF failure of a mitigative system, the accident cannot be classified as a Class 9 accident by conmon definition.
If NRC feels that the staff should force-fit the TMI-2 accident scenario with operator error and bad judgments into the R.G. 4.2 class accident scenario L
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Roger J. Mattson,
which evaluates how radioactive material couic ce releasec to tne envircr. mar.
and the consequences, the TMI-2 accident could not be deemed a Class 9 accident since the releases did occur by evaluated pathways. Rather than defining whether conditions of the TMI-2 accident. corresponded to the defined classes given in R.G. 4.2, I would rather describe what accident classes did not occur at TMI-2.
TI. Class 9 accidents involve sequences of postulated successive failures mer: : err: thr-th::e postulated fr-crt?is'iar a etecti"a sveta-c and engineered safety features.
The TMI-2 accident conditions were not more severe than postulated for any of the engineered safety features th: ugh the pr:te:tive sy:tems did take s e severe conditions.
The consequences were not severe as defined for Class 9 accidents --
they were rather trivial.
2.
All Class 8 accidents are defined as events initiated by pipe breaks and reactivity additions and are relatcble to design basis Lccidents used in the safety analysis rerort. The THI-2 accident was not initiated by either a pipe break or a reactivity addition and was not relatable to such accidents evaluated in the SAR.
3.
All Class 6 and 7 accidents involve fuel handling conditions. TMI-2 accident did not involve fuel handling.
4.
Class 4~ accidents are defined for BUR facilities. TMI-2 is a PWR facility.
5.
Class 1 accidents are defined as trival incidents and TMI-2 accident was not a trivial incident.
The accident classes that remain as contributors to the TMI-2 accident are:
Class 2, small release outside containment; Class 3, radwaste system failure; and Class 5, fission products to primary and secondary system (PWR). The
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reported consequences from the TMI-2 accident are consistent with the predicted conscouences from.such class accidents as the Class 2, Class 3 and Class 5 defined accidents.
If the NRC wishes to discuss the TMI-2 accident in respect to system analysis categories as given in R.G.1.70, then a further review of the TMI-2 scenario would be required.
In conclusion, the TMI-2 accident was not a Class 9 accident by any raticnal analysis and comparison of the definition for a Class 9 accident with the TMI-2 accident scenario.
I would recc= mend that the NRC staff (maybe your Task Force) prepare an analysis and evaluaticn of the TMI-2 accident to show the accident development scenario in terms of the response of various systems especially in respect to fission product releases from the fuel; where, what and how much of the fission product inventory was inside i
containment, inside auxiliary building and released to the environment; and
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Roger J. Mattson.
what the effect of the hydrogen exploding ioside the reactor vessel (regardless of the impossibility) would have bedn.
There are probably other unresolved questions in addition to the above that need investigation for comparison with measured or predicted results from the TMI-2 accident.
falu O YNi<v-n Fredric D. Anderson Site Designation Standards Branch cc:
Guy li. Cunningham
- Barry S.mith Janice l'oore Gary Zeck Walt Pasec'ag Robert Tedesco John Vogicydde John Guibert e
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3.
The classification is moot.
The major environmental consequence of TMI-2 was that we scared h--l out of 1.5 million people, or Such a broad cast and adverse consequence is not covered so.
by our regulations, guides, or the Atomic Energy Act.
4.
We need a much better consequence oriented classification scheme.
Health effects and property damage should be considered quantitatively.
The attached table is illustrative of a starting point.
I doubt that we know how to handle the matter of psychological stress.
We certainly can't avoid such stress given an appropriate and actual initiating (The way things are going I'm not sure that we can avoid it in event.
the absence of an initiating event!)
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Jim Martin
/ Accioent Analysis Branch, D5E Office of Nuclear Reactor Regulation
Attachment:
As stated
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cc:
L. Soffer R -Houston
. Kreger D. Muller
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