ML20009H176
| ML20009H176 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 08/03/1981 |
| From: | Tedesco R Office of Nuclear Reactor Regulation |
| To: | Ehrensperger W GEORGIA POWER CO. |
| References | |
| NUDOCS 8108060372 | |
| Download: ML20009H176 (6) | |
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AUG 3 1981 Locket File bec:
LB#1 Rdg TERA DEisenbut NRC/PDR BJYoungblood L/PDR JGrant NSIC MRushbrook TIC Docket Nos.: T 50'G41 RLTedesco ACRS (16)
J and' 50-425 PVollmer
'O TMurley g
RMattson js'9
' l lir. U. E. Ehrensperger RHartfield, MPA l
7 Senior Vice President, Power Supply OELD Georgia Pcwer Company OIE-(3)
Post Office Box 4545
.Ej AUd O 51981
- 9
\\{%',u.s. g 7 p Atianta, Georgia 30302 4
Dear fir. hrensperger:
'A 'TT c.
Subject:
Clas 9 Accider.t Analyses in the Alvin W. Vogtle Nuclear I
Units 1 a 2 Environmental Report The Codaission's Statement of Interim Policy dated June 13,1980, (45 FR 40101 ),
states dat, " Environmental Reports subm1+.ted by applicants for construction permits and operating licenses on or af ter July 1,1980, 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 more severe kinds of very low probability accidents that are physically possible in environnental impact assessments required by the National Environmental Policy Act. Such accidents are commonly referred to as Class 9' accidents. A copy of this,tatement is enclosed.
Your analyses of these accidents should be presented in the Environmental Report regarding Alvin W. Vogtle Nuclear Plant at the tir;e you tendar your application for an ooeratinrj license.
Sincerely, o-Istun1 6 med by Rabat L. Teksm Robert L. Tedesco, Assistant Director for Licensing Division of Licensing
Enclosure:
Statement of Interim Policy (45 FR 40101) cc w/en:1.:
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-OFF1ClAL RECORD COPY USGPO: mI-m.m
tr-Mr.'W. E. Ehrensperger-
. Senior Vice President Power-Supply Georgia Power Company P. O. Box 4545 Atlanta, Georgia 30302 4
cc: qMr.-L. T. Gucwa-Chief Nuclear Engineer Georgia Power Company.
P.:0. Box 4545 Atlanta, Georgia 30302 Mr. Ruble A. Thomas Vice President Southern Services,-Inc.
P. O. Box 2626 Birmingham, Alabama 35E02 Mr. J. A. Baily Project Licensing Manager
~ Southern Company Services, Inc.
P. 0.-Box 2625 Birmingham, Alabama 35202 George F.-Trowbridge, Esq.
Shaw, Pittman, Potts and Trowbridge 1800 M Street, N. W.
Washington, D. C.
20036 L
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radMdc!3 e ':M er.a}s inc$U: ng sew;nces th at Usn Te sult in ir: sdequ'lle coOIiry of reacto-f.gI aN to.Te'*ing of the reactor core. In this reyard. attentmn shall be given both to the prc. bah:lity of -
occurrence of such re* ases and to the environmenta! conser;uences of such releases.*I'r.is statement of inte.-im policy is tabn in coordination with othe* cnpoing saftty related activities that are directly related to accident considerations in the areas of plant des:gn. o;,erational safety. siting policy.
and eme:gency planning The Commissien intends to centinue the rulemaking on this matter when new sitmg requiremet.ts and other safety re!ated requirements incorporcting accident considerations are in place.
DATES This statement of interim policy is effective June 13.1W Comment period expires September 11.1960.
to CFR Parts 50 and 51 AnoatssEs:The Cornmi > ion intends the interim policy guidance c.ontained Huclear Power Plant Accident herein to be immediatelv effective.
t Considerations Under the National llow es er. all inter ested' persons w ho Environmental Policy Act of 19G9 desi.e 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.
ACTION: Statement cf Interim policy.
Commission. U.S. Nuclear Reyelato;y
$UWARY: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 Dranch.
very low probability accidents that are FoR FURTHER INFORMATioN CONT ACTI physicah,y possible in envircnmental R. Wayne llouston. Chief. Accident impact spessments required by the Evaluation Dranch Office of Nuclear National Environmenta! Po! icy Act Re et r Regulation. U.S... Nuclear (NEPA). Such accidents are commonly Regulatory Lommission. Washington.
l referred to as Clau o a rri& nts following an accident c!assscaIion D.C. 20555. Telephnne: [301) # 2-7323.
scheme proposed by the Atomic Energy SUPPLEMENT ARY INFORMATtOM Commission (predecessor to NRC) in Accident Considerationsin Past NEPA 1971 for purposes of trnplementing py;gw, NEPA.8 The March 28.1979 accident at Unit 2 of the Three Mile Island nuc! car The proposed Anncx to Appendix D l
plant has emphasized the need for ol10 CFR Part 50 [hereafter the l
changes in NRC policies regarding the
" Annex") was published for comment comiderations to be given to serious on December 1.197t by the (former) accidents from an environmental as well Atomic Energy Commission. It proposed l
as a safety point of view.
to specify a set o' standardized accident This statement of interim policy assemptions to be used in announces the withdrawal of the Environmental Reports submitted by pro;ued Annes to Appendix D of10 applicants for construction perrnits or CFR Part 50 and the suspension of the operating licenses for nuclear power rulemaking proceeding that began with reactors. It elso included a system for the publication of that proposed Annex classifying accidents according to a on December 1.1971.1t is the yraded scale of severity and p.obabihty Commission's position that its of occurrence.Nine classes of accidents" l
Environmental Impact Statements shall were def:ned, ranging from trivial to include considerations of the site-sery serious. It directed that "for each specific environmental impacts class. except classes t and 9. the attributable to accident sequences that environmental consequences shall be evalaated as ir.dicated." Class 1 events
% mt am Annes to 20 cm r.rt 30 were not to be considered because of l
Appa.h R M FR m.R Tk Consvin : NFPA-their trisial consequencrt whcicas in tm;4. r.'esit-r.g reg JaticM were shedentl3 (juty f
it. If 4j revised an3 *ecast as to CFR Pct si t,ut at regard to Clhs 9 events. the n, nnex i
ftial tee the Cwnr mor. reted that "The Propped stated as fo!!ows!
Annes n sta!1 un-r t.onsidmbon * * ** 39 R 2F# 9 1
n
-4
I 4
l body on which the pl ant Coats. Ifne the t
W m d:na.as n CWs 9 irmdve within r150-mile radm of the pl+nt had staff em@s: red P3 fows ten risk to the rymes rif p+,*mt'smessi.e faMu es scme differtmces between bdhng w ?ct envitor:mtnt but d;d no! find tnaf the r
rire mere than 6 me psidated for !Le reactors (BWR) und pressurited wata P70k bdiiF Of 6 C0" *
- d d-s9n basis in pmicetive s3sierns and scactors WWR).13evond thest few occurring h2 the fir 5! place was armeered nafe:y features. Frie r specifics, the discussions hue essentia!h any different th.*n for !and.
wnsessenus t os:J Lv nevere. lfowcar. the reiterated the guidance of the Annex based plant. In its Memorandum and prnbal4.ty of their ocrarrence is su smaf!
sad have relied iipon tk.. Annex s Order in t'ra Matter o ONmre Power that tMr envianmentet risk ia ret rnely conclusion that the probabihty of low. Defense m depth (rnoittle phy sical occurrence of a Class 9 cvent :s toa low Systems.' the Comm:ssmn concurred m barner*). qu.d.fy nmrance for deshn.
the staff's judgment.Thus the Feactor j
n.anufacture and nyration. continued to warrant considctation a usef asion Safety Study and NRC cxperience with I
surved! ante and testinF and coaservative based upon generally stated safety these cases ha* sened to relocus desqn are,11 a;>phed to ponde and considerations.
attention on the need to recmphasize meiatsin th required high de;;ree of.
Safety Study (WASH-1400),in draft p.obsbili!!es and cc scGences a point With the publication of the Rractor that environmentalmk entails both assurance that potential accidents m this class are, and so!! rmain, sufficwafly ressore form in Aug 'st 1974 and final f arm in that was madein the publication of the m probabil:ty that the environrn ntal rak is October 1975. the accident du um ons gnnex g ut was not given at}equage a
entremeh low. re these trmns at is no, in EnvironmentalImpact Stati na nts j
necessary to datus such eunts in began to refer to this first detailcd study emphasis.
In July 19:7 the NRC commissioned a appbcants' En vircamental R eports.
of the rnks associated with nuclear Risk A=sessment Reviev Group"to A footnote to the Annex stated; pcmcr plant accidents, particularly clarify the achievements and hmitations Ahhough this a :r.ex rders to awhcanti esents which can lead to the me!!ine of of the Reactor Saiety Study." One of the Environmental Rerorts. the current the fuel inside a reactor 2 The refere'nces c nelusi ns of th,s study. published in i
amreptions and other provisions thereof ar' to this study were in keeping with the September 1976 es NUREG/CR-0400.
m;9 stJe. c = cept as tne content rnay intent and spirit of NEPA "to disclose"
- Risk Assessment Revie,w Croup Report 1
otherwise require. to AEC draf t and final nlevant inic,at. ion, but it.is ohu.ous Commission,'jelear ReFu.atory I the U'S' N Detailed Stakmentsl that WASHm00 did not farm the basis was that *The Rev,ew -
i Daring the pubbe comn.ent period that for the conclusion expressed in the to ddede wMu p w cs un fo!! awed pubbcation of the Annex a Annex in 1971 that the probability of the absolute probabilit,es of accident i
number of critaisms of the Annex were occurrence of Class 9 events was too sequences in WAsli-1400 are high or ruewed. Prmcipal among these were low to warrant their (site-specific)
I w. but be ieves that the error bounds the followins consideration under NEPA.
"N"**"'*"kS" I" 8#"""b (1)The philosephy of prescrib.ing.
The Commission's staff has, howeser.
greatly uiJerstated.This and other assumptions does not Icad to obp, ctive identified in certain cases unique findings of the Reuew Group have also
" ""I 5 ' 5-circumstant es which it felt warranted su @ uen @ en re emd to na F
(:!)It failed to treat the probabih.. ties of inore extens ve and detailed Environmental Impact Stateme nts. along accidents in any but the most general consideration of Clahs 9 crents. One of undi a re enn to die Commmo a s 3
these was the proposed Clinch River P" #F. statement on the Reactor S ifety
"" E.
(3) ho supporting analysis was given Breeder Reactor Plant (CRBRP). a liquid Study in light of the Risk Assessment to show that Clas 9 accidents are metal enoled fast breeder reactor very gcy;ew Group Report, published on sufficiently low in prohabdity tha their different scom tne more conventional January 18.1979. The Comn'ission's consequences in terms of environmental
@ A " " * " " d # P "".'S I
statement accepted the find:ngs of the rkks need not he discussed.
5"ICIF "P"Icnce base is much broader.
Review Group, both as to the Reactor (4) No guidance was gn en as to how In the i-ma! E.nvironmental Statement Safety Study's achievements and as to accident and normal releases of i r the CR13RP.2 the staff mcluded a its limitatioris.
radioactive offinents during plant discussion of the consideration it had A few Draft Environmental o;mration shouhi be factored into the given to Class 9 events.
Statements have been puh!ished c ost-henefit analysis.
in the early s,te review for the subsquent to the Three Mile Island i
p)The accident assumptions are not pryman site, the staH pmfonned an accident.These were for conventional generall'y oppbcable to gas cooled or ini nnal assessenent f he relatne land-based IW~ ht water reactor plants hquid metal confed reactors.
differences in Class 9 accident and continued to reficct the past W) Safety and environmental risks are consquenm among the abernat.
practice with respect to act.idents at ive not esrentially different considerations.
r, tes.,(SECY-78-137) such plants, but noted that the Neither the Atomic Energy in tne race of the apph. cation by experience Fained from the Three Mile Commission nor the NRC took any Offshom Power Systems to manutacture Island accident was not factored into further action on this miemaking except 0 alig aclear power plants,iae staff the discussion, in 1st when to CFP tt-t 51 was judged that the environmental risks of Our experience with past NEPA pron.ulpted. Over the irJervening years some Class 9 events warranted special reviews of accidents and t..e TMI the accident considerations discussed in censideration.The special accident c!carly leads us to believe that Eneironmentallmpact Statements for circumstances were the potentially a change is needed.
propusad nuclear power piants reflected seri us consequences associated with Accordingly, the propor.ed Annex to the poidance of the Annex with few watyr [hquid) pathways leading to Appendix D of 10 CFR Part 50. published exceptions. Typit. ally, the discussions of radiciogical exposures if a molten on Decernber l.1971. is hereby etcident consequences through Class 8 reactor com were to fallinto the water withdrawn and shall not hereafter be (design basis accidents) for each case used by applicants nor by the staff. The have reflected specific site characteristib$ associated widi
(( (*
reasons for the withdrawal are as f"Il"* 8 rnetrorulogy {the dispersion of relaases a%%h this term as commen'y wed,o teefv af radioacti.e inaterial into the quotent to a cme melt amden:
- Dcd et No STN SA.41%permt.cr 14 19 9
'NUhEfMIn. February 1977.
atmosphere), the acl4 bl population I
i 9
8 f
4
+
.s The en.ironmental cenwquem es of iswed hiementt not ahW.t a
., (
- 1. N A:.*an pro uibes releases whose ;schabihty of ocumam shnwing cf sim;br special cecQ :ation r.! the kinds of accidynts hu beer estimated shell also be cimu:nstancn as a basis for openint (CW W tha.!f.h cordmg to the Re<!or discussed in probabil:stic terms. Such reopening. or expand;ng any prevem or hfm b".dy bninate the accident ria.
.l' consequences shall be characterized in ongoing proceeding
- 2, The deb.tt!Ln of Class 9 accidants terms of potential radiological lioweser. it is also the intent of the in the Anna is not sufficiently precise exposures to individuals, to p' dation Commission that tha staff take ste; s to la wa: rant its further use in Commission groups. and, where applicabb + Swta.
Identify additional cases that might lieu!:L and safety risks that nmy be warrant cadv consideration of either puhey. rules, and regu!ations, nor as a associated with exposures to people additional fe'atures er other actions decision criterion in agency pr.ictice.
- 3. The Anneis prest.rtpfmn of shall be discussed in a manner that which would prevent or rnit: sate the assemptions to be used in the analysis fairly reikcts the current state of consequences of sericas accidents.
of the er.vironmental consequences of
} nowledge regarding such risks.
Cases for such consideratio, are those accidents does not contribute to Sncioeconenic impacts that might be for which a Final Environmental objective consideration.
essociated with eraergency measures Statement has already been issued at 4 The Annex does not give adequate during or following an accident should the Construction permit stage but for consideration to the detaile'd treatment also be discussed.The enuronmental which the Operating License review of measures taken to prevent and to risk of accidents should also be stase has not 3 ct been reached. In mitigate the consequences of accidents compared to and contrasted with carrving out this directive the staff in the safety review of each appbcation.
radiological risks a.ssociated with shotild consider relevant site features; The classification of accidents no mal and anticipated operational including population densitv. associated with accident risk in compiri<on to such proposed in that Annex shall no longer releases.
be used. In its place the following In promulgating this interim guidance.
features at present!y operating piants, mterim guidance is given for the the Commission is aware that there are Staff should also consider the hkelihood treatment of accident risk and willlikely rernain for some time to that substantive changes in p: ant decign considerations,n NEpA revs,ews-come many uncertainties in the features which may compensate further application of risk assessment methods.
for adverse site features may be more Av.ident Considerations in Future and it expects that its Environmental easily incorporated in phnis when Impact Statemen's will identify major constructim: has not yet orogressed very NFpA Reviews tr is the pn.,. tion of th? Comm.ission uncertamties in its probabilistic far.
~
i J,
that its Environmentallripact
- U.**; On the other piand the Environrnental Reports subm.tted by i
Statements, pursuant to Sectmn 102[c)(i)
Commission believes that the state of applicants for construction perraits and of the National Environmental policy the art is sufficiently advanced that a for operatmg licenses on or after July 1.
Act of 1%9. shal include a reasone[i begmnmg should now be made in the 1930 should include a discussion of the tensiderat;on of the environmental reks f thm methodologies m the ensironmental risks associated with use (irr. pacts) attributable to accidents at the "7uiatory pr ms, and that such use accidents that follows the guidance particular f acility or facibiies wi:hin the wiu reprmnt a contructive and rationc!
E sen herein.
i scope of cath such statement. In the f rward tcp,m the discharge of its Related policy Matters Under analysis and discussion of such risks.
approxi:nately equal attention shall be it is the(mient of the Comm...
Consideration
'9" issma m given to the probability of occurrence of issuing th.s Statement of Interim policy in addition in its responsibihties reicases and to t!ie probability of that the staff willinitiate treatments of under NEI%. the NRC also bears occanence of the environmen'tal accident considerations,in accordance responsibility under the Atomic Energy tonw.;urnces of those releases.
with the foregoing guidance. in its Act for the protect:on of the public bimes refer to radiation and/or ongoing NEpA reviews, i.e., for any health and safety from the hazards rc d6artive materials entering procending at a licensing stage where a assortated with the use of nuclear ensimnmental exposure pathways, Final Endmnmental Impact Staterne nt energy. pursuant to this responsibility indu.hnc oir, water. and ground w afer.
Euznts e occident sequences that has not yet been issued. These new the Commission notes that there are lemt r ir' ases shat! include but not be treatments, which will ;ake into account currently a number of ongoing activities hmilai to J _ ihat can reasonably be signif: cant site-and plant-specific being considered by ti.e Commission expected in occur. in plant acciden't features. will result in more detailed and its staff which intimately relate to discussions of accident risks than in the " Class 9 accident" question and sequences that can lead to. spectrum of refenes sh. Il lie discussed and shall previous environmental statements, which are either the subject of current inc!cde sequences that can result in particularly for those related to rulemaking or are candida'c subjects for inadequate coohng of reactor fuel and to ronventional light water plants at land-rulemaking.
based sites. It is expected that these Dr. December 19.1979 the melting of the rearmr cure. The extent to revised treatments willlead to Commission issued for pub!:c comment
- which events L.ising from causes conclusions regarding the environmental a proposed rule which would external to the plant which are risks of accidcnts similar to those tiaal significantly revise its requirements in considered possible contributors to the wou!d be reached by a continuation of to CFR part SC for emergency planning risk associated with the particular plant shat! also be discussed. Detailed current practices. particularly for cases for nuc! car power plants. One of the involving sp %1 circumstances where considerations in this rulemaking was quantitative umiderations that form Class 9 risks have been considered by the basis of p.t.abilistic estimates of releast:s nec.. or be incorporated in the the staff, as describec above. Thus. this
- conmu.;oner, c.1:nity.na nwtw I an.ye.
with the incIwir M ihe receir.g t au.crie ras Environmerii I.npact Statements but change in policy is not to be construed e mth aC shall be refer %ed thwein. Such as ary face of confidence in conclusions
- {,
i references sha!! include, as applicable, regardmg the ensironmental risks of
, rm,,%, g,,,n a.,,,.a,,...
accidots expressed in any previously
.umum reports on safety evaluations.
i A
/
m-t y ;r *< r.d cn. eg a nces of Class 9
, e. res m, a y o et c. s. u.. '
l ir., 51t'r9.pa:3 m2.. ' ta the Com=ssio:n rept st. a !i;t:n;: Pobry Ta tJa. l'orn %d. rer.umiacodations with respect to pu?tib!e chanps m NRC rei.; tor s:M;: pol cy and criteria.'
currently set forth in 10 CFR Part im As statcd t:v' rem its recoinmenda! ions w ere 17.8 de to at :m'pl:sh (:rmong oth us' :t.c E!!n Mn;: pa!.
To Me iramnuaci t.cn in siorg the risk
.mau a '( ' with s.rcihts beyond the rWn b.es(C % T 43 enthhhmt ; c;miatmn de nsay.nd d.s':.!,otmn critena Tf is mtter is ct.rrently 1.cfore the Crcinission.
Ti.;.s and other recommenhtic.ns that hne twen rnade as a result of the investmtions into the Thiee Mde Is!and accident are currently being Inoufit lepther by the Commission's staff in th-forrn of proposed Action P ans +
Am wy obr rnatters. these incorr ate ruommendations for rulem:iking related tr. degraded core cooling and core melt as riderus. The Commission expects to iuue decisions on these Action P!ans in the r. ear future 1: is the Comtnission's pscy and intent tu devoir NRC's rnajor r.ecurces to rn.itters which the Commipon brheves will raake existing and futnre nuc! car power p! ants safer.
and to present a recurrence of the kind of accident that occurred at Three Mile Is!and in the ir.terim however. and pend.ny co:np!ction of wiemaking at inities m the areas of crncipncy planmrg. siting t riteria. and desi;n and oper a'ional safet3. all of which involve i ondierations of serious accident potential, the Cominission Imds it insential to impros e its pun.edures for desaibmp and d.sclosing to the pub!ic the buii, fc.r arrhiny at conclusions trgarding the enuronmental risks due to
.n.cidents at nuclear power p! ants. On ua ;let'on of the rulem.sking activities in the se arras, and based also upon the ex;serience pained with this staternent of triters:n pohty and guidance, the Commission miends to pursue po.ssib!c th-inpas or additions to 10 CFR Part 51 to codify its positior. on the role of
. accident risks onder NEPA.
= Cl N1 % f rare "Pla on stNo.s for lhe
!M e1. p i..m o' *.'s se a nd Imat Gm emmene k <'dy c e' T's - gency Fever.se PNns m Su; port of 1.ph' W e'er Nr!.ar Fe er F:ar.'s." Nmerst.et Ws
- Nt:n Qci" Report of ib sng Polq Ted ie ie A.+.s: F9
- IP.!: Ni'RrC4.ec. "Actu.n M m for I.t p'e.*, Fe recaner2 *t. m r' i:.c hes dent's
, Cw..so nidOAcrSNAe*cfIce W i-2 Ar t.t ent." Tmenc 10.1 r9 e
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