ML20009F284
| ML20009F284 | |
| Person / Time | |
|---|---|
| Site: | Hartsville  |
| Issue date: | 07/28/1981 |
| From: | Tedesco R Office of Nuclear Reactor Regulation |
| To: | Parris H TENNESSEE VALLEY AUTHORITY |
| References | |
| NUDOCS 8107300244 | |
| Download: ML20009F284 (6) | |
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Docket No. 50-5 d, 50-519 ILynch IK POR and 50-520, 50-521 OIE(3)
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Attroney. OELD lir. H. G. Parris lianager of Power Tennessee Valley Authority 500A Chestnut Street Tower 11 Chattannoga, Tennessee 37401
Dear !!r. Parris:
Subject:
Class 9 Accident Analyses in the Hartsville 1 - 4 Environinental Report The Comission's Statement of Interia Policy dated June 13.1980, (45 FR 40101),
states that, " Environmental Reports submitted by applicantt< for construction permits and operattag licenses on or af ter July 1,1981, should include a discussion of the environmental risks associated with accidents that follow the guidance herein." Therefore, in accordance with this policy statenent, we request that you censider the more severe kinds of very low probability accidents tnat are physically possible in environmental impact assessments required by the flational Environnental Policy Act. auch accicbnts are commonly referred to as Class 9 act,slents. A copy of this statement is ecclased.
Your analyses of these accidents should be presented in the Environmental Report regarding Hartsville 1 4 at the time you tender your application for an operating license.
sincerely, Robert L. Tedesco, Assistant Director for Licensing Division of Licensing
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Enclosure:
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Statenent of Interio Policy r:
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Mr. H. G. Parris Manager of Power Tennessee Valley Authority 500A Chestnut Street Tower II Chattanooga, Tennessee 37401 ces: Mr. Jerry E. Wills Tennessee Valley Authority Alan S. Rosenthal, Esq., Chairman 400 Chestnut Street Tower - II Atomic Safety and Licensing Appeal Board Chattanooga, Tennessee 37401 U. S. Nuclear Regulatory Commission Washington, O. C.
20555 Mr. William Hubbard Assistant Attorney General Dr. John H. Buck Supreme Court Building Atomic Safety and Licensing Appeal Nashville, Tennessee 37219 Board U. S. Nuclear Regulatory Connission Leroy J. Ellis III, Esq.
Washington, D. C.
20555 Omer, Ellis & Brabson Chancery Building Mr. Jerome E. Sharfman 421 Charlotte Avenue Atomic Safety and Licensing Appeal Nashville, Tennessee 37219 Board 3409 Shepherd Street Raymond Gibbs, Esq.
Chevy Chase, Maryland 20015 111 Commerce Building 316 West Lytle Street Murfreesboro, Tennessee ?'130 Robert Pytl', Esq.
e 1700 Hayes Street, Suite 204 Nashville, Tennessee 37203 John F. Wolf, Chairman, Esq.
3409 Shepherd Street Resident Inspector /Hartsville Nuclear Chevy Chase, Maryland 20015 Power Station Dr. J. Venn Leeds, Jr.
c/o U.S. Nuclear Regulatory Commission P. O. Box 468 10807 Atwell Hartsville, Tennessee 37074 Houston, Texas 77096 Mr. J. F. Cox Dr. Forrest J. Remick Tennessee Valley Authority 207 Old Main Builcing 400 Connerce Avenue, W10Cl31C Pennsylvai.f a State University Knoxville, Tennessee 37902 University Park, Per.nsylvania 16802 Herbert S. Sanger: Jr.. Esq.
General Counsel Tennessee Valley Authority 400 Connerce Avenue EllB33C-K Knoxville, Tennessee 37902 Mr. H. N. Culver Tennessee Valley Authority 249-A Hamilton Bank Building Knoxville, Tennessee 37902
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a lead to releases af r.htmn and/or radioactive matenais. includine sequences that can result in inadequate cooling of reactor fuel and to melting of the reactor core. In this ref ard, attention shall be given both to the p;obability of occurrence of such releases and to the enCronmental consequences of such releases.This statement of interim policy is taken in coordmation with other ongoing safet)-related activities that are directly related to accident considerations in the areas of plant design. operational safety. siting policy.
and err.ctgency p!anning The Commission intends to continue the rulemaking on th:s matter when new sitmg requirements and other safety i
related requirements incorporating accident considerations are in place.
cafes:This stalernent of interim policy is effective lune 13.1980 Comment
)
penod espires September it.1980 10 CFR Parts 50 and 51 aoongsses:The Commission intends the interim policy Fuidance contained Nuclear Power Plant Accident herein to be immediately effective.
Considerations Under the National Howeser,allinterested persons who Environmental Policy Act of 1969 desire to submit written comments or act%cy: U.S Nuclear Regulatory.
sugge:tions for consideration in connection with this statement should Commission send them to the Secretary of the acTiow: Statement ofInterim Policy.
Commission. U.S. Nuclear Regula tory suwuac.v: The Nuclear Regulatory Commission. Washington. D C. 20555.
Cnrr. mission (NRC)is revising its policy Attention: Docketmg and Service for considering the more severe kinds of Branch.
physically possible ml accidents that are sery low probabilit>
,o,,yny,g,,,,o,uay,ogcouyaen environmental R. Wayne Houston. Chief. Accident impact assessments required by the Esatua' tion Branch Office of Nuclear National Environmental Policy Act Reactor Regulation. U.S. Nuclear (NEPA). Such accidents are commonly Regulatory Commission. Washington.
referred to as C!an o accMa D.C. 20555. Telephone: (301) 492-7323.
followmg an Jccioent classification scheme proposed by the Atomic Energy sumsutuvany insonuation:
Commission (predecessor to NRC)in Accident Considerations in Past NEPA 1971 for purposes of implementmg g, y;,,,
NEPA.'The March 28.1979 accident at Unit 2 of the Three Mile Island nuclear The proposed Annes to Appendix D plant has emphasized the need for of to CFR Part 50 (hereafter the changes in NRC colicies regarding the
-Annex") was published for comment considerations to be given to serious on Dece nber 1.1971 by the (former) accidents from*an environmental as well Atomic Energy Commission. It proposed as a safety point of view.
to specify a set of standardized accident This statement ofinterim policy assumptions to be used in announces the withdrawal of the Environmental Reports submitted by proposed Annex to Appendix D of to applicants for construction permits or CFR Part 50 and the suspension of the operatmg licenses for nuclear power rulemaking proceeding that began with reactors. it also included a system for the publication of that proposed Annex classifying accidents according to a on I'ecember 1.1971. It is the graded scale of severity and probability Commission's position that its of occurrence.Nine classes of accidents*
EnvironmentalImpact Statements shall were defined ranging from trivial to include considerations of the site-very senous. it directed that "for each specific environmental impacts class. except classes 1 and 9. the attributable to accident sequences that environmental consequences shall be evaluated as indicated." Class 1 events
- Proposed se en Annes to 30 CDR Part so, were not to be considered because of Appendia D. Je nt r.:ast the Commeneron's NEPA.
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imp;ementing resutaoone were subsequently (July is. iem re.. sed.nd rec.ei. io CrR Part si but al regard to Class 9 events. the Annex
+es time the Cs mmas.on nosed that "The Proposed statid as follows:
Annes sa shil under consideraison * * ** 39 FR 26 rt
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The currences in Cass e invohe within a 50.rnile radius cf the plant. end bndy on which the plent flosts. mre the
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sequences of p stu sied successise failures some differences between bo:hng wster staff empha,ized its fc.cus on risk to the more sesere than those pecula ed for the reactors (BWR) and pressunzed water environment but did not.fmd that the des sn basis for protectn e systems and reactors (PWR). Beyond these few probabihty of a core melt event engineered safety features. Their specifics. the discussions have occurnng in the first place was reiterated the guidance of the Annex essentially any different than fu f and.
consequences could be sese.e. However, the that their environmental rd is e attemely and have relied upon Lbe c* y.x's based plant. in its Metorandum and
)
probability of their occurrence is so small low. Defense in depth (multiple phy sical conclusion that the probability of Or er In i e tarter og ore power bamers), quality assurance foe design.
occurrence of a Class 9 event is too low Systems.* the Commission concurred in manufacture. and operation. c:intinued to warrant consideration a conclusion the staff's judgment. Thus. the Reactor Safety Study and NRC experience with sune.!!ance and testir g and conservative based upon generally stated safety these cases has served to refocus design are a!! applied to proside and considerations.
attention on the need to reemphasize maintain the required high deree of With the pubhcation of the Reactor that environmental risk entails both,
assurance ihai potential accidents in this Safety Study (WASH-1400). in draft class are. and will remam. sufficierely remote fann in AuFust 19N and nul form in probabilit:es and consequences. a point in probabihty that the environments l nsk is that was made in the publication of the estremelv low. For these rea sons. it is not O. clo er 1975. the accident discussions Annen. but was not gis en adequate necessary to discuss such esents in in EnvironmentalIrnpact Statements applicanis' Envircnmente! Reports.
began to refer to this first detailed study e(pha s
197 the NRC commissioned a g,ec "j; 'j'y' R,isk Assessment Review Crour'"to A footnote to the Annex stated:
'*'S c.anfy t3e achiciements and limitations Although this annes refers to appheant's events which can lead to the meltmg of of the Reactor Safety Study., One of the Ennronmentaliteparts. she current the fuelinside a reactor.' The references d h P'"" ' '*" ' ' h "I * "
e nelusions of this study.publisned m
- "'*P""". ' n*c^ep*'a s"the content may to this study were in keeping with the September 1F8. as NUREC/CR4W.
appbcable e t
intent and spint of NEPA "to disclose
" Risk Assessment Review Group Report otherwise require. to AEC draft and Cnal relevant information, but it is obvious that W ASH-1400 did not form the basis to the U.S. Nu. clear Regulatory Detailed Statements.
Commis sion,. was that.'The Review Dunng the public comment penod that for the conclusion expressed in the "E***#8 folioned pubhcation of the Annex a Annex in 1971 that the probability of the aboh $aWu d acch nurnber of criticisms of the Annex were occurrence of Class 9 events was too
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received. Pnncipal among these were low to warrant their (site. specific)
I w. but beheves that the error bounds the foHowing:
consideration under NEPA.
on those estimates are in general.
(1) The philosophy of prescribing.
The Commission's staff has. however, greatly understated. This and other assumptions does not lead to objective identified in certain cases unique findings of the Review Croup have also analysis.
circumstances which it felt warranted
"" "9"'""F (2)It failed to treat the probabilities of more extensive and detailed EnvironmentalImpact Statements along accidents in any but the most general consideration of Class 9 events. One of
- "I'""***
these was the proposed Chnch River E
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- I (3) No supporting analysis was given Breeder Reactor Plant (CRBRP). a li9uid Study in light of the Risk Assessment to show that Class 9 accioents are metal c led fast breeder reactor very Review Croup Report, published on sufficiently low in probabihty that their different frorn the more conventional January 18,1979. The Commission's consequences in terms of environmental Hg water nactor plants for which the statement accepted the find:ngs of the risks need not be discussed.
safety expeneqe base is much broader.
Review Croup both as to the Reactor (41 No guidance was given as to how In the Final Environmental Statement accident and normal releases of Safety Study's achievements and as to f r the CRBRP 8 the staff meluded a its hmitatioits.
radioactive efnuents during plant discussion of the consideration it had A few Draft Environmental operation should be factored into the swent Clan 9 n ents.
Stalements have been published cost benefit analysis.
in the early site review for the subsequent to the Three Mile Island
- 15) The accident assumptions are not Perryman site, the staff performed an accident. These were for conventional generally applicable to gas cooled or inf rmal auessment of the relative land. based light water reactor plants hquid metal cooled reactors.
Memncu in Class 9 accident and continued to reDect the past (6) Safety.nd environmental risks are not essentially different considerations.
c nsequences among the alternative practice with respect to accidents at Neither the Atomic Energy sites. [SECY-7s'-137) such plants, but noted that the Commission nor the NRC took any In the ecse of the apphcation by experience gamed from the Three Mile further action on this rulemaking except Offshore Power Systems to manufacture Island accident was not factored into m 1974 when 10 CDt Part $1 was 0 atmg nuclear power plants the staff the discussion.
judged that Ote environmental nsks of Our expenence with past NEPA promulgated. Over the intervening years the accident considerations discussed in some Class 9 events warranted special reviews of accidents and the ThU Environmentallmpact Siatements for consideration. The special accident clearly leads us to believe that proposed nuclear power plants redected circumstances were the potentially a change is needed.
the guidance of the Annex with few serious consequences associated with Acordingly, the proposed Annex to exceptions. Typically, the discussions o.
water (liquid) pathways leading to Appendix D of 10 CFR Part 50. published accident consequences through Class a radiological exposures if a molten on December 1.1971. is hereby reactor core were to fallinto the water withdrawn and shall not hereafter be (design basis accidents) for each case have renected specific site used by applicants nor by the staff. The
' *' ""'"h * "> ' 8 "" S. fei v Si ud F reasons for the withdrawal are as charactenstid associated with newer refers to por uses ihe te*m " Class s accideni.
joggowC meteorology (the d.spersion of releases eisho# m,, i,,m,, c mmoniy,,,g., ioo,,iy Of radioactne matenalinto the ew.;eano. com mesi.ccmeni.
atmosphere). the actual population
'NURECAn 39 Febrw) 19 r.
- Doches No STN 50-est. September 14. t e 1i.
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'. The Annes prosenbes The environmental consequences of issued Statements. nor, absent a t
consideration of the kinds of accidents releases whose probabilit) of ocrcrence showing of similar special (C!ess 9) that, according to the Reactor has been estimated shall also be circumstances, as a basis for opening.
Safety Stud). de.mnate the accident discussed in probabihstic terms. Such reopening. or expandag any preuous or nsk.
consequences shall be charactenzed in ongoing proceeding *
- 2. The definition of Class 9 accidents terms of potential radiological However,it is also the intent of the in the Annes is not sufficiently precise exposures to individuals. to population Commission that the staff take steps to to warrant its further use in Commission groups. and. where applicable. to biota.
identify additional cases that m'Fht pokey, rules. and regulations, nor as a deahh and safety risks that may be wemnt early consideration of either decision entenon in nency practice.
associated with exposures to people a6 :onal features or other actions 1 The Annem's presception of shall be discussed m a manner that which would prevent w rnitigate the assumptions to be used it. the analysis fairly reflects the current. hts of consequences of serious accidents, of the environmental comequences of knowledge regarding such risks.
Cases for such consideration are those acciden's does not con.ribute to Socioecono-nic impacts shai might be for which a finai Environmental objective consideration.
associaied with emergency neasures Statement has already been issued at 4 The Annen does not gise adequate dunng or foMowing an accid:nt should the Construction Permit stage but for censideration to the detailed treatment ahn be discussed. The enviranmental which the Operating License reuew of rr.casures taken to prevent and to nsk of accioents should also be stage has not yet been reached. In mitigate the consequences of accidents compared to and contrasted with carrying out this directive the staff in the safety review of each appheation.
radiological risks associated with shuuld consider relevant site features.
The classification of accidents normal and anticipated operational including populat%n density, associated proposed in that Annes shall no longer relea ses.
with accident nsk in companson to such be used. in its place the following in promulgatmg this intenrn guidance, features at presently operating p'ents.
intenrn guidance is g:ven for the the Commission is aware that there are Staff should also consider the hkelihood treatment of accident risk and will!ikely rernain for some time to that substantive change 4 in plant design considerations in NEPA reviews.
come many uncertainties in the features which may compensate further Arrident Considerations in Future apphcation of risk assessment methods.
for adverse site features may be more NEPA Reviews and it espects that its Environmental easily incorporated in plants when Impact Statements willidenti y maj r c nstruui n has no' vet progressed very It is the position of the Commission uncenainties m its pr babihstic fa r.
that its EnvironmentalImpact estimates. On the other hand the Environmental Reports submitted by Statements. pursuant to See: >n to:(c)(i)
Commission beheves that the state of applicants for construction permits and of the National Environmental Pohey the art is sufficiently adsanced tha: a for operating bcenses on or after ju!y 1.
I Act of 1909. shallincluds a reasoned hginning should now be made in the 1960 should include a discussion of the consideration of the enuronmental nsks use f these methodologies m the environmentai risks associated witn (impacts) attnbutable to accidents at the reSulat ry process. and that such use accidents that follows the guidance particular facility or facilities within the will represent a contructive and rational gisen herein.
scope of each such statement. In the ar tep in the discharge of its analysis and discussion ; f such r sks.
p Cona.eration apprnsimately equal attention shall be it is the intent of the Commission in gnen to the probabihty of occurrence of releases and to the pababihty of issuing this Statement of Interim Pohcy in addition to its respor.sibihties that the staff willimtiate treatments of under NEPA. the NRC also bears occurrence of the environmental conwmiences of those releases.
accident considerations. in accordance responsibility under the Atomic Energy Releases refer to radiaten and/or with the foregoing guidance,in its Act for the protection of the public radioactive materials entenng ongoing NEPA reviews i e.. for any health and safety from the hazards enuronmental esposure pathways.
proceeding at a licensing stage where a associated with the use of nuclear incudine air, water. and ground water.
Final Enuronmental impact Statement energy. Pursuant to this responsibility Event or accident sequences that has not yet been issued. These new the Commission notes that there are leaaliu Messes shallinclude but not be treatments, which will take into account currently a number of ongoing actmties hmited to those d st can reasonably be significant site and plant. specific being considered by the Commission expected to occur. In. plant accident features. will result.in more detailed and its staff which mtimately relate to sequences that can lead to a spectrum of discussions of accidat nsks than in the *Cl ass 9 accident" question and releases shall be discussed and shall previous environmental statements, which art wither 'he subject of current include sequences that can result in particularly for those related to rulemaking or are candidate subjects for anadequate cooling of reactor fuel and to consentionallight waur plants at land-rulemaking.
rnetting of the reacter core. The estent to based sites. It is espected that these On December 19.1979 the which events ansing from causes revised treatments willlead to Commission issued for pubhc comment
- entemal to the plant which are conclusions regarding the ensironn. ental a proposed rule which would considered possible contnbutors to the risks of accidents similar to those that significantly revise its requirements in nsk associated with the particular plant would be reached by a continuation of to CFR Part 50 for emergency planning shall also be discussed. Detailed current practices. particularly for cases for nuclear power plants.One c4 the quantitative considerations that form involving special circumstances where considerations in this rulemaking was the basis of probabihstic estimates of C: ass 9 risks have been considered by releases need not be int sporated in the the staff, as described above.Thus this a comm....onen c.t.a.hy.ad a,.drord d...sr,e EnvironmentalImpact Statements but change in policy is not to be consirued
="h the mclusioa of ibe precedn i-o.*a'eace.
]',[[*,','{r 'y'j,'y','.deaisy"l*"7'"' ""h shall be referenced therem. Such as any lack of confidence in conclasions references shall include. as applicable, regarding the ensironmutal risks of
,,,oaeov po.a.oa on c:... s ecc reports on safety evaluations.
accidents expressed in any preuously
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.e the patc5tia! consequences of Class 9 cccicents in. generic sense.'
I.; August 1973. pursuant to the Comm: sion's request. a Siting Policy Task Fcree made recummendations with r spect to possible chanFes in NRC racct:r sitmg policy and critena.'
i curt:ntiv set forth in to CFR Part 100 As stat:d t!ierein its recommendations I
wsra snade to accomplish (amor g others) the following goa!:
To iake into consideration in siting the risk associssed with.!ccidents beyond the des gn bsers iCair 9) b> establishirs Vrvlation drnsity cad dis nbution critena.
This matter is currently before the Commission.
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This and other recommendations that
- have been made as a result of the investigations Mto the Three Mile Island i
tecidInt are curiently being brought i
together by the Commission's staffin f
the form of proposed Action Plans.'
l. Among other matters, these encorporate recommsndations for ru!emaking related to degraded core cooling and core melt
' accidents.The Commission expects to issue dzcisions on these Action Plans in the near future. it is the Commission's policy and intent to devote NRC's major resources to matters which the i
Commission beheves will make eustmg and future nuclear power plants safer, and to prevent a recurrence of the kind of accident that occuned at Three Mile Island. In the interim. however. and
. pending completion of rulemaking scrivatiss in the areas of emergency plan iing. siting criteria, and design and opsrational safety, all of which involve considerations of serious acci: lent potential. the Commission finds it essential to improve its proceduree for describing and disclosing to the public 1
the basis for arriving at c" sions regarding the ensironmental risks due to cccidents at nuclear pc.ver plants. On complation of the rulemaking activities en thase areas. :nd based also upon the espsrisnce gained with this statement of intenm policy and guidance, the Commission intends to pursue possible changes or additions to 10 CFR Part *1 to codafy its position on the role of cccid ent nsks under NEPA.
J
'Ct NUREC.4M 'Ptoenics See.e for the Dreelopment of Sisie and Local Co.ernmens Redseleyecal Einersency Response P'ans m Support of L.she Weser N cieer Power Plants." Novemt,er sus
'NtlAEC-sa s " Report of the Sehns Polecy Teek Force." Ai. eves 97s
'Desh NURECaec "Acteen Plane for tenplementsag Recomreendee.one ' the Pree. dent's Commise.en end Oiher Sivo..
TMI-2 Accident." Decemtre* 10 te's L
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