ML20009H174
| ML20009H174 | |
| Person / Time | |
|---|---|
| Site: | Bailly |
| Issue date: | 07/31/1981 |
| From: | Tedesco R Office of Nuclear Reactor Regulation |
| To: | Shorb E NORTHERN INDIANA PUBLIC SERVICE CO. |
| References | |
| NUDOCS 8108060370 | |
| Download: ML20009H174 (6) | |
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ACRS(16)
Attorney, OELD Hr. E. M. Shorb First Vice President Northern Indiana Public Service Coupany Hammond, Indiana 46325
Dear Hr. Shorb:
Subject:
Class 9 Accident Analyses in the Bailly Environnental Report The Coanission's Statement of Interin Policy dated Juno 13,1980, (45 FR 40101),
states that, " Environmental Reports submitted by applicants for construction peraits and operating licenses on or after July 1,1988, should include a discussion of the environmental risks associated with accidents that follow the guidance herein.' Therefor), in accordance with this policy statenent, we request that you consider the more severe kinds of very low probability accidents that are physically p'ossible in environmental impact assessments required by the National Environnental Policy Act. Such accidents are convaonly referred to as Class 9 accidents. A copy of this statement is enclosed.
Your analyses of thesa accidents should be presented in the Environmental Report regarding Bailly at the time you tender your application for an operating Itcense.
Sincerely, Orike' sieed by W L Talesco Robert L. Tedesco, Assistant Director for Licensing Division of Licensing
Enclosure:
Statement of Interim Policy (45 FR 40101) cc w/ encl:
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NRC FORM 318 (10-80) NRCM O240 OFFICIAL RECORD COPY usc.co: m i e seo
- - rdethern Indiana Public Service Company E. M. Shorb First Vice President Northern Indiana Public Service Company 5265 Hohman Avenue Hammard, Indiana 46325 ccs:
Meredith Hemphill, Jr. Esq.
Assistant General Counsel Bethlehem Steel Corporation 7J1 East Third Street Bethlehem, Pennsylvania 18106 William H. Eichhorn, Esq.
Eichhorn, Marrow & Eichhorn 5?43 Hohman Avenue hammond, Indiana 46320 E:: ward W. Osann, Jr., Esq.
W.)lfe, Hubbard, Leydid, Voit & Osann, Ltd.
S1ite 4600 One IBM Plaza Caicago, Illinois 60611 Robert J. Vollen, Esq.
10 North Dearborn Street i
Clicago, Illinois 60602 l
Diane B. Cohn, Esq.
Siite 700 2)00 P Street, N. W.
Washington, D. C.
20036 L
Richard L. Robbins, Esq.
Lake Michigan Federation 53 West Jackson Boulevard l
Chicago, Illinois 60604 Kathleen H. Shea, Esq.
Lawenstein, Newman, Reis, Aleirad & Toll 1025 Connecticut Avenue, N. W.
Washington, D. C.
20036 Daan Hansell, Esq.
R;ssell Eggert, Esq.
Office of the Attorney General State of Illinois 1L3 W. Randolph Street
-Chicago,' Illinois 60601 J. R. Whitehouse, Superintendent N:.tional Park Service-Rcute 2, Box 139A Cresterton, Indiana 46304 t
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s lad o r:letsis cf rad non andhr radioactive matenais, meludme l
sequences that can result in inadequate cooling of reactor fuel and to meltme of the reactor core. In tks reFard, mitention shall be given both to the probabihty of occurrence of such releases and to the enviror. mental consequences of such j
releases.This statement ofinterim policy is taken in coordmation with other ongoing safety.related activities that are directly related to accident cons:derations in the areas of plant design. operational safety. siting policy, and emergency p!anning The Commission intends to continue the rulemaking on this matter when new siting requirements and other safety i
related requis ements incorporating accident considerations are in place.
oATas:This statement of interim policy is effective June 13.1980 Comment penod expires September it.1530.
10 CFR Parts 50 and 51 AcoRessts:The Commission intends the interim policy guidance contained Nuclear Power Plant Accident herein to be immediately effective.
Considerations Under the National However,allinterested persons whc,
e Environmental Policy Act of 1969 desire to submit written comments or -
AGENCY:U.S Nuclear Regulatory suggestions for consideration in connection with this statement should Commission send them to the Secretary of the Actron: Statement of Interim Policy.
Commission. U.S. Nuclear Regulatory suwuAny:The Nuclear Regulatory Commission. Wa shington. D.C. 20555.
Commission [NRC)is revising its policy Attention: Docketmg and Service for considering the more severe kinds of Branch.
very low probability accidents that are FoR FURTHER INFORM ATioN CONTACT:
physically possible in environmental R. Wavne Houston. Chief. Accident.
impact assessments required by the Evalua' tion Branch Office of Nuclear National Environmental Policy Act Reactor Regulation. U.S. Nuclear (NEPA). Such accidents are commonly Regulatory Commission. Washington.
g','#'
"'s d n efa D.C. 20555. Telephone: [301) 492-7323.
f tion scheme proposed by the Atomic Energy suppttusNTAny iNFoRu ATiom Commission (predecessor to NRC) in Accident Considerations in Past NEPA 1971 for purposes ofimplementing Rcviews NEPA.'The March 28.1979 accident at Unit 2 of the Three Mile Island nuclear The proposed Annex to Appendix D plant has emphasized the need for of 10 CFR Part 50 (hereafter the changes in NRC policies regardmg the
" Annex") was published for comment considerations to be given t a serious on December 1.1971 by the (former) er ' fents from'an environmental as well Atomic Energy Commission. It proposed as a safety pomt of view.
to specify a set of standardized accident This st.stement 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 perrnits or CFR Part 50 and the suspension of the operstmg licenses for nuclear power rJemaking proceeding that began with reactors. it also included a system for the publication of that proposed Annex classifying acc' dents accordi.g to a on December 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 serious. 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 indiceted " Class 1 events
'Prosmed as an Annen to lo CF1t Pero so-were not to be considered because of Appendan D. 3a FR 22851 The Commenteon s NEFA.
their trivial conse9uences, whereas in imp;emenhns resaf ahons were subsequently (July is. is er rensed.nd reca.i. so Crn Peri si bue as rega-d to Class 9 events. the Annex fl st time the Comm.ss,on noted that "The Proposed _
stated as jollows:
Annea es sedi under aneider. hon * * " 39 FR 26**9
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- The occurrences in Class e involve within a 50-mile radius of the pisnt.pd body on which the pltnt fisats. Hsre the, f
eequences of postu:sied successne failures some differences between boiling water staff emphasized its focus on risk to the environment but did not.fmd that the more severe than those peculated for the reactors (BWR) and pressurized water probability of a core melt event design bassa for protectne systems and reactors (PWR) Beyond these few occurring in the first place was engineered safety features. Their specifics. the discussions have essentially any different than for land-consequences could be seure. However. the reiterated the guidance of the Annex based plant,in its Memorandum and
]
Nat alnYk is e i eme and have relied upon ths Annex's Order in the Matter of Offshore Power nv e
low. Defense in depth (multiple phy sical conclusion that the probability of Systems.* the Commission concurred m occurrence of a Class 9 event is too low bemers). quehty assurance for design.
the staffs judgment.Thus, the Reactor manufacture, and operation. continued to warrant consideration, a conclusion Safety Study and NRC experience with sur eillance and sesting and conservative based upon genera!!y stated safety these cases has served to refocus design are all app!.ed to provide and considerations.
attention on the need to reemphasize maintain the required h2gh degree of.
With the publication of the Reactor that environmental risk entails both assurance that potential accidents in this Safety Study (WASH-1400).in draft Probabilities and centequences,a point class are, and mil remam, sufficiently remote form in AuFust 1974 and final form in that was made in the publication of the m probability that the environenenta nsk is October 1975, the accident discussions Annex but was not gnen adequate euremely low. For these reasons, it is not m Environmental Impact Statements necessary to dacuss auch evenis in e
asis beFan to refer to this first detailed study g 1977 the NRC cc.mmissioned a appbcants* Environmental Reports.
Risk Assessment Review Group "to A footnote to the Annex stated:
p r
aeci icul rly clarify the achievements and limitations Ahhough this annem refers to applicant's events which can lead to the melting of of the Reactor Sa,fety Study. One of the EnvironmentalReports the current the fuel inside a reactor.e The references conclusions of this study, published,n i
assumptions and other prousions thereof are to this study were in keeping with the.
September 1978, as NU, REG /CR.0400.
appbcable. encept as the content may intent and spirit of NEPA "to disclose
" Risk Assessment Review Group Report otherwise require to AEC draft and final nlevant inrormation. but it is obvious to the U.S. Nuclear Regulatory Detailed sistements.
that WASH-1400 did not foru the basis Commission, was that "The Review Durmg the public comment period that for the conclusion expressed in the Croup was unable to determine whether followed publication of the Annex a Annex in 1971 that the probability of "C# '"
riumber of criticisms of the Annex were occurrence of Class 9 events was too sequences y WASHM am Mgh or received. Principal among these were low to warrant their (siteopecific)
I w.but beheves that the error l'ounds the following:
consideration under NEPA.
on those estimates a,rc :n general, (1)The philosophy of prescribing.
The Commission's staff has, however.
gna$ un ersta and ohr assumptions does not lead to objective identified in certain cases unique fmdmgs of the Review Croup have also analysis.
circumstances which it felt warranted subsequently been referred to in 12)lt failed to treat the probabihties of more extensive and detailed Environmental Impact Statements, along
(
sccidents in any but the most general consideration of Class 9 events. One of
- 88 "'
- F these was the proposed Clinch River E
- I'I'***"
'I (3) No supporting analysis was given Breeder Reactor Plant (CRBRP), a liquid Study in light of the Risk Assessment to show that Class 9 accidents are metal c 3ed gast breeder reactor very Review Group Report. published on sufficiently low in probabihty that their different from the more conventional Jan ary 18.1979. The Cornmission's consequences in terms of environmental light water reactor plants for which the statement accepted the find.ngs of the risks need not be discussed.
safety eyperience base is much broader.
Review Croup. both as to the Reactor (41 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 mcluded a its I mitatioits.
radioactive effluents during plant discussion of the consideration it had A few Draft Environmental operation should be factored into the given i Class psents.
Statements have been published cost benefit analysis.
In the early site review for the accident.These were for conventional subsequent to the Three Mile Island (5)The accider$t assumptions are not Penyman site, the staff performed an -
genera!!y applicable to gas cooled or inf rmal assessment of the relative land based light water reactor plants liquid metal cooled reactors.
differences in Class 9 accident.
practice with respect to accidents et and contmued to reflect the past (6) Safety and environmental -isks are C nsequences among the alternative not essentially different considerations.
sites. (SECY-78' 137) such plants but noted that the Neither the Atomic Energy in the case of the application by experience gamed from the Three Mile Commission nor the NRC took any Offshore Power Systems to manufacture Island accident was not factored into further action on this rulemaking except il ating nuclear power plants, the staff the discussion.
in 1974 when 10 CFR Part 31 vas judgej that the environmental risks of Our expenence with past NEPA promulgated. Over the interser' ; g:..s some Class 9 events warranted special reviews of accidents and the TMI the accident considerations discussed in consideration.The special accident clearly leads us to believe that Environmenta! Impact Statements for circumstances were the potentially a change is neeced.
proposed nuclear power plants reflected senous consequences associated with Accordingly. the proposed Annex to the guidance of the Annex with few water (liquid) pathways teacing to Appendix D of to CFR Part 50. published exceptions. Typically the discussions of radiological exposun iif a molten on December 1.1971. is hereby accident consequences through Class a reactor core were to f allinto the water withdrawn and shr'! not hereafter be idesign basis accidents) for each case used by applicants nor by the staff.The have refietted specific site
" '"'" * *'"' 8 "*'" S* k'? S'*dF reasons for the withdrawal are Ps characteristin associated with never refers so por use. the temi'C!.es 9 acodeni,,
foll***
meteorology (the dispersion of releases
.iu a.,h ih.. ierm. commaair..ed.. too. tr of radioactne matenlinto the em.ient io. core meh ere*ni.
- Dochen No STN 50-43r. September 14. W?s a(mo' phere). the au. "I pupCIation
'NIlAEC'4378 I'bftd'T 18??-
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The environmental consequIncis of issued Stmm;nts. n:r. absint a
- i. The Annes prosenbes consideration of the kmds of accidents releases whose probabiht.s of occurence shnwing of similar special has been est. mated shall also be circumstances. as a basis for opening.
(Class 9) that. accordmg to the Reactor discussed in probabihstic terms. Such reopening.or expandmg any presious or Safety Study. dominate the accident consequences shall be characterized in ongoing proceeding?
nsk.
1 The defamtion of Class 9 accidents terms of potential radiological However. it is also the intent of the in the Annex s not suffeceently precise exposures to individuals. to population Commission that the staff take steps to to warrant its further use in Commission groups, and. where appbcable, to biota, identify additional cases that might pohey. rules. and regulations, nor as a Health and safety risks that may be warrant early consideration of either decision entenon in agency practice.
associated with exposures to people additional features or other actions 3 The Annex's prescnption of shall be discussed in a manner that which would prevent or mitigate the assumptions to be used m the analysis fairly reflects the currentfstate of consequences of serious accidents.
of the environmental consequences of knowledge regardmg such risks.
Cases for such consideration are those accidents does not contnbute to Socioecono nic impacts that might be for which a Final Environmental objective consideration.
assnciated with emergency measures Statement has already been issued at
- 4. The Annex does not F se adequate dunng or followmg an accident shculd the Construction Permit stage but for i
consideration to the detailed treatment also be discussed. The environmental which the Operating Iicense review of measures taken to prevent and to risk of accidents 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 apphcation.
radiological risks associated with should consider relevant site features.
The classification of accidents normal and anticipated operational including population density. associated with accident risk in comparison to such pr posed in that Annen shall nolonger rele ses.
be used. In its place the following in promulgating this interim guidance.
features at presently operating plants.
mterim pidance is given for the the Commission is aware that there are Staff should also consider the hkelihood treatment of accident risk and willlikelv remain for some time to that substantive changes in plant design considerations in NEPA reviews.
come many u'ncertainties in the features which may compensate further apphcation of risk assessment methods, for adverse site features may be more Accident Considerations in Future and it noects that its Environmental easily incorporated in plants when Impact Statements will iden.ify major construction has not yet progressed very NEPA Reviews it is the position of the Commission I' '
that its EnvironmentalImpact estimates. On the othe~r hand the Environmental Reports submitted by Statements. pursuant to Section 102(c)(i)
Commission believes that the state of applicants for construction permits and of the National Environmental Policy the art is sufficiently advanced that a for operating licenses on or after July 1.
l Act of 1969. shall include a reasoned begmmng should now be made m the 1980 should include a discuss.on of the e
consideration of the ensironmental risks f these methodologies in the environmental risks associated with use (impacts) attributable to acciden's at the regulatory process, and that such use accidents that follows the guidance particular facility or facilities wihin the will represent a contructive and rational gis en herein, scope of each such statement. In the f rward step in the discharge ofits Related Policy Matters Under analysis and discussion of such risks.
reponsibi ities.
Conside.. lion approximately equal attention shall be it is the mient of the Commission in given to the probability of occurrence of issuing this Statement of Interim Pohey in addition to its responsibihties releases and to the pro'bability 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 conwouences of those releases.
Releas'es refer to radiation and/or with the foregoing guidance, in its Act for the protection of the public ongo.ng NEPA reviews i.e., for any health and safety from the hazards radioactive materials entering proceeding at a licensing stage where a associated with the use of nuclear enviror. mental exposure pathways, Final Environmental Impact Statement energy. Pursuant to this responsibility including air, water and ground water.
Events or accident sequences that has not yet been issued. These new the Commission notes that there are lead au seleases shallinclude but not be treatments, which will take into account currently a number nf ongomg activities limited to those that can reasonably be significant site. and plant. specific being considered by the Commission features. will result.in more detailed and its staff which intimately relate to expected to occur. In. plant accident discussions of accident risks than in the " Class 9 acci 2ent" question and sequences that can lead to a spectrum of releases shall be discussed and shall previous environmental statements, which are either the subject of current include sequences that can result in particul.rly for those related to rulemaking or are candidate subjects for madequate cooling of reactor fuel and to consentionallight water plants at land.
rulemaking.
melting of the reactor core. The extent to based sites. It is expected that these On December 19.1979 the revised treatments willlead to Commission issued for pubhc comment
- which events arising from causes conclusic s regarding the environmental a proposed rule which would external to the plant which are risks of accidents similar to those that signifit.antly revise its requirements in considered possible contributors to the risk associated with the particular plant would be reached by a contmuation of 10 CFR Part 50 for emerSency planning shal: also be discussed. Detailed ct.. rent practicr s. particulariy for cases for nuclear power plants.One of the quantitative considerations that form involving special circumstances where considerations in this rulemaking was the basis of probabihstic citima'es of Class 9 risks have been considered by releases need not be incorporated in the the staff. as described above. Thus, this a com=...one. c.t.n.' s.ad ar.drord d..sn,
- "h 'he mcle.'ea onhe preced ng imo.enie nces EnvironmentalImpact Statements but change in policy is nc? to be construed
%". [,,,* den.*EA.*.I "'* "' "h shall be referenced therein. Such as any lack of confidence in cnnclusions references shallinclude, as applicable.
regarding the environmental risks of moy
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accidents expressed in any previously a u nt ms7 reports on safety evaluations.
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p th; potentia' consequences of Class 9 eccidents in a penene sense.'
la August 1979. pursuant to the Commission's request. a Sding Policy '.
Tcsk Force made recummendatioris with respect to possible changes in NRC rz etor siting policy and entena.'
currently set forth in 10 CFR Part 100. As stated therein. its recommendations w:re made to accomplish [among C th: sl the fo!!owing goal-To take into consideration in siting the nok c4*ocialed with accidents beyond the design basis (Class PJ b establishirs population 3
density and distnbuhon eniena.
This matter is currently before the Ccmmission.
This as d other recommendations that -
h v2 been made as a result of the invistigations into the Three Mile Island cccident are currently being brought tog;ther by the Commission's staffin thy form of proposed Action Plans.'
Am ng other matters. these incorporate r:c mmendations for rulemaking related t3 digraded core cooling and core melt c ccidents. The Commission expects 4 issu2 decisions on these Action Plans in th2 near futere. It is the Commission's policy and intent to devote NPC's major ruources to matters which the Ccmmission believes will make existing cnd future nuclear power plants safer.
cnd to prevent a recurrence of the kind cf cccident that occurred at Three Mile Isi:nd. In the interim. however and pinding completion of rulemaking activities in the areas of emergency pl:nriing, siting entena. and design anJ
- srpIr:tional safety, all of which involve c:nsiderations of serious accident
- potintial. the Comtnission finds it cissintial to improve its procedures for describinF and disclosing to the public the bisis for arriving at conclusions regrrdmg the environmental risks due to cccidents at nuclear power pla:its. On c:mpletion of the rulemaking activities in thTse areas. :nd based also upon the expirience gained with this statement of intsrim p ' icy and guidance. the Commission intends to pursue possible chs.nges or addit.ons to 10 CFR Part 51 to codify its position on tb role of cccid1nt nsks under NEM.
' Cf NUPEC.43es. %nnies Bases for the D. siopmene of Sisee and LocalCo ernment ReMoyeca; Emergency Response Plans en Support of I gLe W eser Nuclear Pe er Plants." No.emt,er we
- NURECa2s " Report of the 5.tmg Pot cy Task Force. Awevet Is7s
'Detle NURECameo. " Action Plans for imitementag Recommendshons of sne Pmident s Comm.es.on end Other Sindes of the TMi-2 Acciant.-Decemberlo Is's s
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