ML20009H117
| ML20009H117 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 07/28/1981 |
| From: | Tedesco R Office of Nuclear Reactor Regulation |
| To: | Mittl R Public Service Enterprise Group |
| References | |
| NUDOCS 8108060050 | |
| Download: ML20009H117 (7) | |
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LB#2 TERA ASchwencer TIC MService NSIC DLynch IIRO PDR3 Docket tio. 50-354 OIE(3)
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and 50-355 Attroney, OELD 3
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fir. R. L. itittl General Manager - Projects dlJ I2.
Public Service Electric & Gas P, JUL 2 91981
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C BC Park Place, Room 81611P Newark, New Jersey 07107
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Dear fir. liitti:
9 y
Subject:
Class ? Accident Analyses in the flope Creek 1 & 2 EnvironmD Report The Comission's Statenent of Interin Policy dated June 13,1980, (45 FR 40101),
l states that, "Envirennental Reports submitted by applicants for construction l
permits and operating 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 consider the nore severe kinds of very low probability accidents that are physically possible in environmental irnpact assessents required by he National Environw ntal Policy Act. Such accidents are comonly referred to as Class 9 accidents. A copy of this statement is enclosed.
Your analyses of these accidents should be presented in the Environ.nental Report regarding hope Creek 1 a 2 at tne time you tender your application for an operating license.
t Sincerely, l
Or! gird sinal by hunt L. TWw Robert L. Tedesco, Assistant Director for Licensing Division of Licensing l
Enclosure:
Statenont of Interin Policy (45 FR 40101) cc w/ encl:
l See next page 8108060050 810728 POR ADOCK 05000354 l )l C
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i Mr.
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L. Mitti l
l cc: Fred Broadfoot, Esq.
Public Service Electric & Gas Ccmpany Atsistant General Counsel 80 Park Place l
Newark, New Jersey 07101 l
Mr. Jchn Beottger, Project Manager Public Service Electric & Gas Company 80 Park Place Newark, New Jersey 07101 I
l The Honorable Mark L. First Deputy Attorney General State of New Jersey Nuclear Energy Council 36 West State Street Trenton, New Jersey 07102 l
Richard Fryling, Jr., Esq.
(
Public Service Electric & Gas Company l
80 Park Place Newark, New Jersey 07101 l
l Mr. David A. Caccia Box 70 - A. R. D. #2 Sewell, New Jersey 08080 Dr. John X. LaMarsh' 68 North Chatsworth Avenue Larchmont, New York 10538 Manager, Quality Assurance Public Service Electric & Gas Company l
80 Park Place l
Newark, New Jersey 07101 1
__x
c Mr. R. L. Mitti.,
cc: Mr. N. C. Vasuki, Director Division of Environmental Centrol Tatnall Building Dover, Delaware 19901 Robert D. Westreich, Esq.
Assistant Deputy Public Advocate Department of the Public Advocate nivision of Public Interest Advocacy P. O. Box 141 Trenton, New Jersey 08625 Mrs. Richard Horner Main Street Hancocks Bridge, New Jersey 08038
/
Troy B. Conner, Jr., Esq.
Conner, Moore & Corber 1747 Pennsylvanta Avenue, N. W.
Washington, D. C.
20006 F. Michael Parkowski, Esq.
Deputy Attorney General Tatnall Building Dover, Deiaware 19901 Mr. H. E. Morris, Project Engineer Bechtel Power Corporation 50 Beale Street P. O. Box 3965 San Francisco, California 94119 Mr. W. H. Bateman, Resident Inspector c/o U. S. Nuclear Regulatory Commission P. O. Box 241 Hancocks Bridge, New Jersey 08038 A
4 lead to releases of rd arron and/or J
radioactive malenais. includma sequences that can result an inadequate cooling of reactor fuel and to melting of the reactor core. In this refard, attention shall be given both to the probability of occurrence of such releases and to the environmentalconsequences of such releases.This statement ofintenm poliev is taken in coordination with other on dg safety.related actmties e
that are directly related to accident considerations in the areas of plant design. operational safety. sitmg policy, and err.e gency p!anning The Commission in: ends to continue the rulemaking on this matter when new siting requirements and other safety related requirements incorporatmg accident considerations are in place.
cates: This statement of interim policy is eIfective lune 13.1980 Comment l
penod espires September 11.1980.
10 CFR Parts 50 and 51 Aoonesses:The Commission intends the intenm policy guidance contained Nuclear Power Plant Accident herein to be immediately effective.
Considerations Under the National However, allinterested persons who l
Environmental Policy Act of 1969 desire to submit written comments or I
AGENCY:U.S Nuclear Pegulatory suggestions for consideration in connecuon with this statement should Commission send them to the Secretary of the Action: Statement of Intenm Policy.
Commission. U.S. Nuclear Regulatory I
suum Amy:The Nuclear Regulatory Commission. Washington. D.C. 20555.
Commission (NRC)is revising its policy Attention: Docketing and Service for considering the more severe kinds of Branch.
very low probobility accidents that are rom runTHrn iniroaMAfroN CONTACT:
physically possible in environmental R. Wavne Houston. Chief. Accident impact assessments required by the Evaluation Branch Office of Nuclear National Environmental Policy Act Reactor Regulation. U.S Nuclear l
(NEPA). Such accidents are commonly Regulatory Commission. Washington.
l D.C. 20535. Telephone: (301) 492-73:3.
11 o in an o ni c a i tion scheme proposed by the Atomic Energy suPPLEMENTAny swonMATIOm Commission (predecessor to NRC) in Accident Considerations in Past NEPA 1971 for purposes of implementing Reiews NEPA.'The March :8.1979 accident at Umt : of the Three Mile Island nuclear The proposed Annes to Appendix D plant has emphasized the need foe of to CPR Part 50 (hereafter the changes in NHC policies regarding the "Annen") was published for comment considerations to be given to serious on December 1.1971 by the (former) a:cidents from'an environmental as well
. Atomic Energy Commission. It proposed as a safety point of view.
to specify a set of standardited accident This statement ofinterim policy assumptions to be used m announces the withdrawal of the Environmental Reports submitted by proposed Annex to Appendix D of to applicants for construction permits or CPR Part 50 and the suspension of the operating licenses for nuclear power rulemaking proceeding that began with reactors. It also ircluded a system for the publication of that proposed Annex classifying accidents according to a on December 1.1971. It is the graded scale of severity and probability Commission's position that its of occurreno.Nine classes of accidents, Environmentallmpact Statements shall were defined. ranging from trivial to include considerations c' the site-very serious. It directed that "for each specific environmental L..sacts class except classes 1 and 9. the attributable to accident sequences that environmental consequences shall be evaluated as indicated." Class 1 events
'Proimed.... Anne. io so CTR Part So-were not to be considered because of Appeedia D. 3e F1t 2:sst. The Commiserce's NEPA.
their trivial conse9uences. whereas in imp;ementing regel.nons==ere subsequently (July is. mo eni.ed.ad rece... io Crn part si tout.
regard to Class 9 events, the Annex that time the Comm<*sion posed ih.i"The Proposed stated as follows:
I Annes is shis under consideration * *
- 3s FR
- 6rs
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ne occurrences in Cass 9 involve withm a 50-mile.adius of the plant. and body on which the plant floats. Here the
(
eequences of pesiu sied successio failures som6 differences between boihng wster staff emphasized its focus on risk to the environment but did not find that the move severe than those peeiulated for th*
reactors (BWRJ and pressunzed water desisn basis for protectne svsiems and reactors (PWRJ. Beyond these few probabihty of a core snelt esent occurnng in the first place was engineered safety festeres. The
specifics, the discussions have essentially any different than forland-consequences could be severe. However. the probabihty of their occurrence is so small reiterated the guidance of the An.s besed plant. In its Memorande. and nen gP Order in the Matter of Offshore Power inat their enuronmentai nsk is entremely conclusion that the probability of low. Defense in depth (multiple ph.s sical occurrence of a Class 9 event is too Iow Systems.* the Commission concurreg in bamersi. quality assurance for design the staffs judgment. Thus, the Reactor manufacture. and opeistion. continued to warrant consideration, a conclusion surseillance and testing and conservative based upon generally stated safety Safety Study and NRC expen.ence with these cases has served to refocus design are a!! appl.ed to proude and considerahons.
silention on the need to reemphasire maintain the required high degree of With the publication of the Reactor that environmental risk entails both assurance tnal potential acciornis in this Safety Study (WASH-1400), in draft probabilities and censequences, a point class are. and will remam. suff.ciendy remote form in AuFust 1974 and final form in that was made in the publication of the in probability that the ensironmental nsk is October 1975. the accident discussions Annex but was rio! given adequate j
enremely low. For these reasons. it is not in Environmental Impact Statements necessary so discuss such events in began to refer to this first detailed study
'] *j s197 the NRC commissioned a appt. cants' Environmental R eports.
the s as esr Risk Assessment Review Croup"to A footnote to the Annes stated:
f
,}y clanfy the achievemet.ts and, limitations Abhough this annen refers to apphcant's events w hich can lead to the snehng of of th. Reactor Safety Study. One of the l
Environmental peports. the current the fuel inside a reactor.8 The references conclusions of this study. published m, assumpiio.a and other prousions thereof are to this study were in keeping with the September 1978 as NUREC/CR4400, appbcabh.encept as the consens may intent and spint of NEPA "to disclosc
" Risk Assessment Review Group Report otherw.se require, to AEC drafi and final relevant information. but it is obvious.
to the U.S Nuclear Regulatory Deisiled siaiements.
that WASH-1430 did not form the basis Carr iission was that."The Review i
i Dunng the public comm nt penod that for the conclusion expressed in the Croup was unable to determine whether followed publication of th : Annex a Annex in 1971 that the probability of the aWuk prdaWies d accMeM number of criticisms of trie Annex were occurrence of Class 9 events was too sequences in WASH-1400 are high or received. Pnncipal among these were low to warrant their (site. specific)
I w.but beheves that the error bounds the following:
consideration under NEPA.
n those estimates are in general.
l (1) The philosophy of presenbing -
identified in certain cases unique fmdings c 'the Review Croup have also The Commission's staff has, however.
greatly understated. This and other l
assumptions does act lead to oojective analy sis.
circumstances which it felt warranted subsequendy kn dM to m 12)It faded to treat the prcbabihties of more estensive ard detailed Ennromnental Impact Statunents, along i
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accidents m any but the most general consideration of Class 9 events. One of
- V-these was the proposed C! inch River E "'I '*'"' "
- ' ' ' I
[3) No supporting analysis was given Breeder Reactor Plant (CRBRP). a hquid Stude in hght of the Risk Assessment to show that Class 9 cciden's are metal c led fast breeder reactor very Review Group Report, pubbshed on sufficiently iow in probabihty that their different frorn the more conventional January 18.1979. The Commission's consequences in terms of environmental light water reactor plants for which the statemeni accepted the find.ngs of the nsbs need not be discussed.
safety experience base is much broader.
Review Group both as to the Reactor (4) No guidance was given as to how in the Final Environmental Statement Safety Study's achievements and as to accident and normal releases of f r the CRBRP.8 the staff meluded a its limitations.
radioactive effluents during plant discussion of the cor. sideration it had A few Draft Environmental operation should be facnred mto the given to Class 9 nents.
Statements has e been published l
cost. benefit analysis.
In the early site review for the subsequent to the Three Mile Island (5) The acciderit assumptions are not Perryman site,the staff performed an accident.These were for convent:onal generally applicable to ga s cooled or mi rmal assessment f the relative land-based light water reactor piants I
hquid metal cooled reactors.
differences m Class 9 accident.
practice with respect to accidents at and contmued to reflect the past (6) Safety and ennronmental nsks are c nsequences among the alternative I
not essentially different consideraions.
s.tes. (SECW78L137) such plants. but noted that the Neither I;a Atomic Energy in the case of the application by expenence gamed from the Three Mile Commission nor the NRC took any Offshore Power Sysiems to manufacture Island accident was not factored into furt!,er action on this rulemakin except 0 ating nuclear power plants. the staff the discussion.
m 1974 when 10 CFR Part 51 was judged that the ensironmental niks of Our expenence with past NEPA promulgated. Over the intervening years some Class 9 esents warranted special renews of accidents and the TMI the accident considerations d:scussed in consideratior..The special accident clearly leads us to believe that Environmental lmpact Statements for circumstences were the potentially a change is needed.
proposed nuclear power plants reflected suious cos., 'quences associated with Accordingly, the proposed Annex to the Fundance of the Annes with few wain piquul pathways leading to Appendix D of to CFR Part 50. published 8
exceptions. Typically, the discussions of radiological exposures if a molten on December 1.1971. is bereby accident consequenc'es through Class 8 reactor core were to fallinto the water withdrawn and shall not hereafter be t
Idesign basis accidentsj for each case used by applicants nor by the staff.The have reflected specific site ni...nnim.i ih.i ihe sie.cier s.r ie siudy reasons for the withdrawal are as e
charactenstics associated with never refere io not use the term "CI.se s.cc. dens.
g ws,.
ineleorology i.the dispersion of releases
.nhoos h in.. e,m u...
i, u.e4.. i
.,iy of radioactive matenalinto the egm.iem io e cm meli.ccideni-
- Mei he m mst Serie=ber 14 2irm atmosphere) the actual population
'smcess rebrwy terr e
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The environmental consequences of issued Stalements. nor, absent s
- i. The Annea prosenbes releases whose probabihty of occurence shnwing of similar special consideration of the kmds of accidents has (* en estamMed shall also be circumstances. as a basis for opening.
(C! ass 91 that. accordmg to the Reactor discussed n plobabihstic terms. Such reopening. or expandmg any pres sous or Safety Study, dominate the accident consequences shall be charactented in ongoing proceedmg.'
- nok,
- 2. The definition of Class t 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 la marrant its further use in Commission groups, and, where appbcable. to biota.
identify additional cases that might Health and safety risks that may be warrant early consideration of either pohey. rules. and regulations, nor as a associated with exposures to people additional features or other actions d2 cision crilenon in agency practice.
- 3. The Annez's presenprion of shall be discussed in a manner that w hi-would prevent or mitigate the essumptions to be used in the analysis fairly reflects the current state of cons :,uences of serious accidents.
j of the environmental consequences of knoatedge regarding such risks.
Cases for such consideration are those cecidents does not conenbute to Socioecono nic impacts that might be for which a Final Environmental objective consideration.
associated with emergency measures Statement has already been issued at l
- 4. The Annea does not gise adequate dunng or following an accident should the Construction Permit stage but for consideration to the detailed treatment alsn be discussed.The environmenta!
which the Operstmg I.icense review cf measures taken to prevent and to nsk of acci6ents should also be stage has not yet been reached. In i
mitigate the consequences of accidents compared to and contrasted with cacrying out this directive. the staff in the safety review of each apphcation.
radiological risks associated with should consider relevant site features.
i
(
" Die classification of accidents normal and anticipated operational including population density. associated l
proposed in that Annen shall no lonFer releases.
with accident risk in comparison to such ba used. In its place the following In promulgating this intenm guidance.
features at presently operating plants.
intenm guidance 3s given for the the Commission is aware that there are Staff should also consider the likelihood treatment of accident risk and willlikely remain for some time to that substantive changes in plant design considerations in NEPA reviews.
come many uncertainties in the features which may compensate further application of risk assessment methods, for adverse site features may be more Acrident Coosiderations in Futur, and it expects that its Ensironmental easily incorporated in plants when NEPA Reviews Impact Statements willidentify major construction has not yet progressed very It is the position of the Ccmmission uncertainties in its probabihstic far.
that its E.wironmental Impact estimates. On the other hand the Environmental Reports submitted by Slatements, pursuant to Section to:(c)(il Commission believes that the state of applicants for construction permits and
?
of the National Environmental Pohey the art is sufficiently advanced that a for operatmg licenses on or after July 1.
Act of 19% shallinclude a reasoned besmning should now be made in the 1980 should include a discussion of the i
consideration of the environmental nsks use of these methodologies in the environmental risks associated with (impacts) attnbutable to accidents at the regulat ry pr cess, and that such use accidents that follows the guidance particular facility or facilities withira the will represent a contructive and rational gisen hewn.
scope of each such statement. in the f raard tep in the discharge of its Related Policy Matters IJnder analysis and discussion of such risks.
fePonsi (ties.
epproximaiely equal attention shall be It is the mient of the Commission in gnen to the probabihty of occurrence of issuing this Statement of Intenm Pohey in addition to its responsibilities releases and to the probability of that the staff willinitiate treatments of under NEPA. the NRC also bears occurrence of the environmental accident considerations. in accordance responsibility under the Atomic Energy l
conacouences of those releases.
Releas'es efer to radiation and/or
- 'th the foregomg guidance in its Act for the protection of the public 0"F0'ng NEPA reviews. i.e, for any health and safety from the hazards rediosctive matenals entenng environmental esposure pathways, proceeding at a licensing staee where a associated with the use of nuclear Final Environmental impact Statement energ). Pursuant to this responsibihty includme air, water, and ground water.
Events or accident sequences that has not yet been issued. These new the Commission notes that there are lead du acleases shallinclude but not be treatments, which will take into account currently a number of ongomg activities limiled to those that can reasonably be significant site-and plant specific bemg considered by the Ccmmission features. will result.in more detailed and its staff which intimately relate to expected to occur.!n plant accident sequences that can lead to a spectrum of discussions of accident nsks than in the " Class 9 accident" question and releases shall be discussed and shall previous environmental statements, which are either the subject of current include sequences that can result in particularly for those related to rulemaking or are candidate subjecta for inadequate cooling of reactor fuel and to conventional light water plante at land-rulemaking.
melting of the reactor core.The extent to based sites. it is espected tFat these On December 19.1979 the revised treatments willlead to Commission issued for pubhc comrnent
- I which events arismg from causes
(
ettemal to the plant which are conclusions regarding the environmental a proposed rule which would nske of accidente -Car to those that significantly revise its requirements in
(
considered possible contnbutors to the l
nsk associated with the particular plant would be reached by a continuation of 10 CFR Pait 50 for emergency planning I
shall also L.iscussed. Detailed current practices. particularly for cases for nuclear power plants. One of the quantitative considerations that form involving special circumstances where considerations in this rulemahng was I
the basis of probabihstic estimates of Class 9 nsks have been considered by releases need not be incorpwrad in the the staff.as described above. Thus, this acomm....ones Caceky and er,dford di..sree
-'ih she nach iaa er the preced.cs i-o seniences-EnvironmentalImg,act Statements but change in policy le not to be construed
$',,Q,',,[,*i'l$,g,,?,*[yll,g*;'*"' *d' shall be referenced therein. Such as any lack of confidenes in concit.sions reference: shall mclude, as applicable, regatding the environmental nsks of
,,,,,,, p.,,,,en on Case e eccide rsports on safety evalustans.
accidents exprer sed in any previously
- *e FR rStar.
S
m-g W
e th2 poteritia! consequences of C! ass 9 cccCants in a penenc sense '
l.s August 1973. pursuant to the Ctmmission's request.a S.hns Policy T:sk Force made recommenAstions with re:pect to possible changes in NRC r :ctor citing policy and criteria.'
curr:ntly set forth m 10 CFR Par'.100 As
+
st:ted therem. its recommendations w:re m de to accomplish famong Ethirs) the following goal:
To ins into consseeration in siting the risk asiocut?d with ace' dents beyond the design brets (CI:ss #1 by esiablishteg population dInsity cad disinbution critena.
This matter is currently before the Cammission.
This and other recommendations that e
h ve be:n made as a result of the invsstes:tions into the Thrae Mile Island eccidInt are currently being broueht togsth2r by the Commission's staff in the firm of proposed Action Plans?
Aming other ma tters, these incorporate rrc mmsndations for rulemaking related la digraded core cooling and core melt accidsnts. The Commisuca espects to issue dicesions on these Action Plans in ths nser future. it is the Commission's pohey snf intent to devute NRC's major i
l rssourc?: to matters which the Commission believen will make esistmg and futurs nuclear power plants safer.
and to pravent a recurrence of the kmd i of accidsnt that occurred at Three Mile 1 Island. In the intenm. however, and 1 panding completion of rulemaking i activiters in the areas of emergency f pisnrimg. sit'ng entena, and design and eperationzi safety all of wur.h i: solve considerstions of serious accident -
poitntist. the Commission finds it I asstntial to improve its procedures for discribmg and dise. losing to the pubhc
] the basis for ernving at conclusions
' rzystdmg the environmental mk s due to cecidrnts at nuclear power plants. On
, complItion of the rulemaking activities in thrse gress. :,nd based also upon the emperience gamed with this statement of inizrim policy and guidance, the 4
Commission miends to pursue possible chsngts or additions to 10 CFR Part 51
, is codify its position on the role of cccidant nsks i der NEPA.
e i
'Ct NUREC e3m. "Planmes Beeis for she De+0 pmene of Sease sad lacel Co.ernment Badeelevicci Er ergeno Responee Plane in Support j of L.g:>e wsier N. clear Power Planis? %.emt.er ira
- NUBEG.em:1. -Report of she 5.i.ng Pelecy Tash s
l Forts" Ai.evet to's
'Drsfi NU;tc.sino "Act en Piene for imMemexting setemmendersons of the Pwe. dent e
- femmeos.on end Other $a Aes of she TMI-2 Accidsss " Decembe* iG f o't
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