ML20009H221
| ML20009H221 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 07/29/1981 |
| From: | Kelley J Atomic Safety and Licensing Board Panel |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD), SOUTHERN CALIFORNIA EDISON CO. |
| References | |
| ISSUANCES-OL, NUDOCS 8108070053 | |
| Download: ML20009H221 (4) | |
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- g UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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B-JUL 311981 >
T2' ATOMIC SAFETY AND LICENSING BOARD O
g BEFORE ADMINISTRATIVE JUDGES k
J James L. Kelley, Chairman Elizabeth B. Johnson P
3 Cadet H. Hand SERVED JUL 31 iggy In the Matter of
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Docket Nos. 50-361-OL 50-362-OL
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500THERN CALIFORNIA EDISON COMPANY, 3
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s (San Onofre Nuclear Generating
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((v j] k '
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Station, Units 2 and 3
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July 29, 1981 i
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' a nUG 0 61981 Q
, u.s. gana ORDER
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(Raising on the Board's Motion an Issue Concern N
Earthouakes and Emergency Planning) ca The Board has decided to raise on its cwn motion an issue concerning the possible effects of a very large earthquake on the San Onofre fac.111 ties and en implementation of emergency plans for those facilitics.
We raise this issue for these reasons. Although the NRC Staff and FEMA consider possible earthquake effects for certain limited purposes, both l
take the position that an earthquake in excess of the safe shutdown earthquake (SSE) determined for this facility for design purposes need not i
be considered in the separate emergency planning context. This position is apparently based upon expertise, judgment and legal factors; we are not aware of any analysis of relevant f actual issues, such as the extent of possible damage to evacuation routes. The Staff's rationale for its l
. osition is set forth fully in its views filed at our request on June 22, l
p 1981.*
1 1
- The Applicants basically ac :e with the Staff on this issue. Both Intervenors believe that this issue should be explored.
l MgoN 8108070053 810729 PDR ADOCK 05000361 68l G
2 While the Staff position is an arguable one, we believe that a developed factual record may show it to be inconsistent with the finding we are being called upon to make - " reasonable assurance that adequate protective measures can and will be taken" at San _ Onofre "in the event of a radiological emergency." 10CFR50.47(a)(1). To be sure, the SSE concept is the linchpin in the seismic design of the plant. See 10 CFR Part 100, Appendix A, V(a)(1).
But it is an engineering and design concept; it does not necessarily have anything at all to do with emergency planning. The different rules establishing the SSE and emergency planning requirements (10 CFR 50.47) do not even refer to each other.
Yet the Staff has decided to transplant the SSE concept from the design area to the emergency planning area without, in our. judgment, an adequate demonstration that the circumstances are sufficiently similar.
Contrary to the Staff's approach here, it has long been established that different accidents may be postulated for different regulatory purposes. "The use of successively increasing conservatism in postulated accidents contributes an added measure of protection to the public health and safety." Vermont Yankee Nuclear Power Corp., 8 AEC 809, 812 (1974).
l We have before us -the question whether the SSE, as previously assigned for l
design purposes, provides acceptable assurance for the protection of the l
[
public health and safety.
Even more severe earthquakes should not be i
postulated for design purposes without a substantial factual showing. But it does not follow that an earthquake more severe that the SSE -- severe enough to daage the facility -- should not be postulated for the entirely separate purposes of emergency planning. Although it is extremely unlikely, an earthquake in excess of the SSE could conceivably occur near
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3 the facility.
If that were to happen, we should assume for regulatory purposes that it could cause a large radioactive release at the plant and, simultaneously, heavy damage to communications facilities and highway evacuation routes.
In a seismic area like California, an Applicant and nearby jurisdictions can at the very least be required to consider what
' hey would do in such an event, and to make appropriate plans consistent with reasonable cost projections.
Accordingly, we are raising the following issue on our own motivo:
Assume an earthquake on the portion of the Offshore Zone of
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Deformation closest to the f acility of magnitude M 7.5 and s
producing peak ground accelerations at the facility in excess of
.67 ; assume extensive structual damage including breach of 9
containment, large radioactive releases, and a need to evacuate virtually all of the people in the plume exposure pathway EPZ; assume extensive damage to communications links and to highways designated in the emergency plans as evacuation routes, including Highway 5 and the parallel highway; highway damage includes collapse of bridges and overpasses and surface breaks rendering the highways temporarily impassable.
In these circumstances, what steps could be taken by the Applicants and the responding jurisdictions to carry out evacuation in a timely manner and/or protect those in the EPZ pending evacuation?
This issue has no bearing on the actual geology and seismology of the SONGS site.
It hypothesizes an earthquake of a certain magnitude and PGA values only to test the adequacy of emergency plans.
The parties may file canments on this issue by August 3,1981, and the Board may modify the issue in the light of comments received. Either the Carstens cr GUARD Intervenors, but not both, may participate in the resolution of this issue, through presentation of evidence and cros s-ex anination. The Board expects both the Applicants and the NRC Staff to address the issue.
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4 For the reasons stated above, the Board finds that the issue it 'is raising herein is a serious safety matter within the meaning of 10 CFR 2.760a.
~
i FOR THE ATOMIC SAFETY AND LICENSING BOARD
%t ACL Qfnet'.. Kelleg Chainnan ADMINISTRATIVr JUDGE Dated at San Diego, California this 29th day of July 1981.
cc: Leonard Bickwit, Jr.
General Counsel
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