ML20010A043
| ML20010A043 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 07/31/1981 |
| From: | Tedesco R Office of Nuclear Reactor Regulation |
| To: | Counsil W NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| NUDOCS 8108100430 | |
| Download: ML20010A043 (6) | |
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1 4 v.a.gssai jg RLTedesco ACRS (16) g TMurley RMattson hr. W. G. Counsil RHartfield, MPA Vice President 0 ELD Nuclear Engineering & Operations OIE (3)
Hortheast Huclear Energy Corapany
~ Post Office Box 270 Hartford, Connecticut 06101
Dear Mr. Counsil:
Subject:
Class 9 Accident Analyses in the hillstone Nuclear Power Station, Unit 3 Environmental Report
- The Cocnission's Statement of Interin Policy dated June 13,1980, (4S FR 40101),
states that, " Environmental Reports submitted by applicants for construction permits and operating licenses on or sfter 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 statement, we request that you consider the core severe kinds of very low probability accidents that are physically possitile in environmental impact assessments required by the National Environmental Policy Act. Such accidents are commonly referred to as Class 9 accidents. A copy of this stateraent is enclos'ed.
Your analyses of these accidents should be presented in the Environmental Report regarding Hillstone Huclear Power Station at the time you tender your application for an operating license.
Sincerely, cristnal signat by Robert L. Tadmoo Robert L. Tedesco, Assistant Director for Licensing Division of Licensing
Enclosure:
Statement of Interim Policy (45 FR 40101) cc w/ encl.:
See next page 8108100430 810731
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Mr. W. G. Counsil Vice President Nuclear Engineering and Operations Northeast Nuclear Energy Company Post Office Box 270 llartford, Connecticut 06101 cc: Mr. John J. Korkosz, Manager Mr. H. R. Nims, Manager City of Chicopee Electric Nuclear Products Light Department Northeast Utilities Service Company 725 Front Street Post Office Box 270 Chicopee, Massachusetts 01014 Hartford, Connecticut 06101 Mr. James E. Tribble Mr. Richard T. Laudenat, Manager Assistant to the President Generation Facilities Licensing New England Electric System Post Office !!ox'270 20 Turnpike Road Hartford, Connecticut 06101 Westborough, Massachusetts 06508 Resident Inspector / Millstone NPS Mr. Bruce R. Garlick c/o U. S. NRC Manager, Energy Sunply P. O. Drawer KK Fitchburg Gas and ciectric Niantic, Connecticut 06357 Light Company 655 Main Street Fitchburg, Massachusetts 01421 Mr. Ward. in K. Brooksbank, Manager Town of aouth Hadley Electric Light Department 85 Main Street South Hadley, Massachusetts 01075 Mr. Ralph H. Wood General Counsel Public Service Company of New Hampshire 1000 Elm Street Manchester, New Hampshire 03101 William,H. Cuddy, Esq.
Day, Barry & Howard One Constitution Plaza Hartford, Connecticut 06103 John D. Fassett, Vice President The United Illuminating Company 80 Temple Street New Haven, Connecticut 06508
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I lead tr reice n of ryhaty ed,*n; rad Dacth e m!cdals,incieint:
.eym cres that can resul. in inadequate cocitng of reactor fut! and to r* e!!ing of the react.,r core. In this revard. attention shall be given both t, the [robability of occuritnce of such re! eases and to the environmental consequences of such releases.This statement of interim pohey is tden in coordination with other ongoing safety.related activities that are directly related to accident considerations in the areas of plant design, operational safety siting pohey, and emergency planning The Commission intends to centinue the rulemaking on this matter when new siting requirements and other safety related requirements incorporating accident considerations are in place.
DATES:This statement of interim pohey is effective June 13.1930 Comment period expires September 11.1980.
10 CFR Parts 50 and 51 ADDRESSE S:The Commission intends the interim policy guidance contained Nuclear Pcwer Plant Accident herein to be immediately effectis e.
f.
Considerations Under the National llowev er. al! interested persons who Environmental Poticy Act of 1959 desire to submit written comments or AGE hCY:U.S Nucleu Regulatory su3.geshons for consideration in Commission connection with this statement should send them to the Secretary of the ACTION: Statement of Interim POIicv.
Co nmission. U.S. hudear Regulatory Commission. Washington. D.C. 20555.
SuuMARY:The Nuclear Regulatory Commission (NRC)is revising its pohey Attention: Dacketing and Service for considering the more severe kinds of branch.
very low probability acr.idents that arc ron rURTHER INFOhM ATION CONT AC..
physically possible in environmental R. Wavne llauston: Chie.. Accident impact nrsessments required by the F.valu5 tion Branch Office of Nuclear National Environmental policj Act Reactor Regulation. U.S. Nuclear (NEPA). Such accidents are commonly Regulatory Commission. Washington.
referred to as Clan n aerub ntt_
D.C. 20555. Teleph one: (301) 492-7323.
following an accident classtiscation scheme proposed by the Atomic Energy SUPPLEMENT A54Y INFORM ATION:
Commission (predecessor to NRC) in Accident Considerations in Past NEPA 1971 for purposes of implementing g,y;gw, 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 (hereaf ter the changes in NRC policies regarding the
" Annex") was published for comment considerations to be given to serious on December 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 c' Sterim policy assumptions to be used in announces the wit. orawal of the Environmental Repous submitted by proposed Anner to Appendix D of10 applicants for construction permits or CFR Part 50 and the suspension of the operating licenses for nuclear power rulemaking proceeding that began with reactors. it also included a system for the publication of1:iat prevsed Annex classifying accidents according to a on December 1.1971. h is the graded scale of severity and probability Commission's position that its of occurrer.ce. Nine classes o~f accidents, Environmental Impact Staternents shall w ere defined, ranging from trivial to include considerations of the site-very serious. it directed that "for each specific environmental impacts dass. except classes 1 and 9. the attributable to accident seqs ences that environrnental consequences shall be evaluated as indicated? Class 1 events
'Prc po.ed. - Anaca to to ct* P.n 50-were not to be considered because of An,enda D.as tR 228st The Com,umen NteA.
their trivial consequences. whereas in mq.crnent..y rey !.hune were s AnequenQ (joty m 19r4) revised ani serast as in Cf R Tart si t ut et reFard to Class 9 esents, the Annex the brne the Ce. rasion noird At *%e Proposed stated as follows:
Ar2r.es is sti:1 unJcv runsider4 hon * " 39 IR 2 tar 9
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had within a 'Amile rade of the ph and staff emnh.s: zed its fexs en r:
m to trie TH m d.mnc o ir Ciw p im oNe i
- m. cces of pr ser/ wa nsne f4ces some d.ffereces hetween beihnt wWr environment but rhd act find that the el,re arvere livn tbse We'ated for th e reactors (HWR) and prensurind 'w ater PMbhbiN UI* ""
F dapn laus fo pravectae sysum and reactors (PWR). Beyond these few occurring in the first place was erencerrd sofoy featurco ne" specifics, the dJscu'sions have essentially any difterent than for land-s consequenu s coJJ 1.. e,es cre. llaat so:, the reiterated the guidance of the Annex bued plant. In its Memorandum and protabahty of thcu ottorrente is so smalf and have relied uPon the Annex *s Order ]n the Matter of O! Shore Power that their enviromntal nd is extreme!)
concyusion that the probabihty o.
d in r
low. Defense in depth inutuple physical ocrbrrence of a Class 9 euc* is 100 low the staffs },ua,gment. Tnus, the Reacto,
. ya ems.4 b rs) qubty assurance for desyn.
to warrant considcration, a ccnc!usion Safety Study and NRC experience wil,
trture. and n; eration continued ance and tnt.g and c onservative b ed upon generally stated safety these cases har served to refocus,
vr are a!! apphed tu nronde and considerations.
attention on the need to reemphastze ir un the reqaired high degree of With the publication of the Reactor that envimnmentalrisk entails both
.nce that poteniiil accidergs m this Safety Study (WASHan). in draft pmbdhties n,d consgency a pnt e
are, and wih rum,c. mff.ceently reir ote form iri August 1974 and final farm in that was made m the;'ubhcation of the i robbihty that the ensirurmantal risk is October 1975. the accident discus sions Annex. but was not g:ven adequate esuemd) lu For these rensaas. it is no.
in Environmentallrnpact Statements en ha.s necemry to dizem such n ents in began to refer to this first detailed study lu )
,pp:; cants' Envi cnental kcparts.
of the risks associMed with nuclear Risk Assessment Rev. w Group.ltations ie to
. A footnote to the Annex stated:
power plant accidents, particularly clarify the achievements and b.rm AtihouA this annn refers to apphcant's events which can lead io the melting of of the Reactor Safety Study. One of the Environrnentat Reports. the current the fuelinside a reactor.2 The references c nclunons of this study published m assurnptions and other prosisions thereof are to this study were in keeping with the September 1978. es NUREC/CRMO.
apphcatte, cuept as ti,e content may intent and 5pirit of NEPA "to disclose" Risk Assessment review Group Rtport on.erwise seguire. to AEC draf t and final relevant informat. ion. but it is obvious.
to the U.S. Nuclear Regulatory netailed staten.ents.
that WAS!f-1400 did not form the basis Comm.ission, was that "The Rev.iew During the public comment period that for the conclusion expressed in the Group was unable to determine whet er followed publication of the Annex a Annex in 1971 that the probability of e abu,e pdaMes d MM number of criticisms of the Annex were occurrence of Class 9 events was too
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received. Principat among tnese were low to warrant their (site-specific)
I "" hose numates ajein gmral the felinwing:
consideration under NEPA.
nt
{1)The philosophy of prescribing The Commission's staff has, however, 8'"""Y "" ## "h, assumptions does not lead to objective identified in certain cases unique findings of the Review Group have also alvsis n
"" 9 subsequently been referred to in (2jlt failed to treat the probabilities of u[s n e d t
d Environmental Impact Staternents, along arridents in any but the most general consideration of Clasr 9 cvents. One of with a reference to the Comm:ssion s ese was the proposed Cb.nch River policy statement on the Reactor Safety wn (N No supporting analysis was giun U* "' N *' '
""I N
Study in light of theRisk Assessment to show that Class 9 Jcidents are nmal c ojed fast breeder reactor scry Review Group Report. published on sufficiently low in probabil;tv that their differcat trom tne more conventional January 18.1979. The Commission's consequences in terms of environmental
@t water reactor plants for wkh ec statement accepted the fmdinp of the risks need not be discussed.
Y '.xpuience base is snud kwdn.
Review Group, both as to the Reactor (4 No guidance us given as to I <w accident and normal reIcases of Q"
p" Safety Study's achievements and as to I
e st radioact,ve effluents dering plant discussion of the consideration it had A few Draft Environmental i
operation should be factored into the g en to Cass q cunts.
Statements have been published cost. benefit analysis.
In the early site review for the subsequent to the Three Mile Island (5) The accident assumptions are not generally applicable to gas cooled or fenyman site, e staff performed an accident. These were for conventional ini rmal assensment of the relative.
land-based light water reactor plants hqnid nietal tooled reactors.
differen.ms in Class 9 accident and continued to rcflect the past (6) Safety and environmental risks are ConsMiumn amorg the alternat.
practice with respect to accidents at ive not essentially different considerations.
sites. (SECY-78-137) such plants. but noted that the Neither the' Atomic Energy I" the case of the applicah,on by experience gained from the Three Mile Commission nor the NRC to'ok any Offs,nore Power Systems to manufacture Island accident was not factored into furtier action on this rulemaking escept b*U"E ""CI" P 'ver plants the staff the discussion.
in 1974 when to CFR Part 51 was judged that the environmental risks of Our experience with past NEPA pronmlpied. Over the intervening years s me Class 9 events warranted special reviews of accidents and the TM1 the accident considerations discussed in ynsideration.The special accident clearly leads us to believe that Environnentallmpact Statements for circumstances were the potentia!!y a change is needed.
proposed nutlea, power plants reflected sui us consequences associated with Accordingly, the proposed Annex to the Fuidance of the Annex with few water (hquid) pathways leading to Appe ?ix D of 10 CFR Part M. published except:ons. Tvpically, the discussions of radiological exposures if a rnolten on Dw.inber 1.1971.is hereby accident coniequtnces through Class 8 reactor me wne to fal! rto the water withdrawn and shall not hereaf ter be (dengn basis accidentsJ for each case used by applicants nor by the staff. The haw reflected specific site
'8' i' of 'a"'#*t 'ha' th' R' acto' S*fy *or reasons for the withdrawal are as charactenstir3 arociated with ener refm to nor unes the term 'C14.s 9.ccWent g"
ractrorolog (the dispersion of releases abhuvyh tbs term 4 tommon!; wd s 6.cly of radioactive materialinto the eplent to a rare mch eccdent
- Dmht t;o SIN w.5 de=t er it 18~S 9
'Non c-om. rewry m atmospherc), the actual population O
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The eminnmental convwener s o' isued Sutments. nm thW! n L The Asex rrmnN s m A ation nf the kmds of accilents relmes whose probbihty of occcrence s1.owiy of sutilu speci !
I us been estimated shall alsa be circumste nm, as a bms for opeamp
[C%s 9J ths.t.iiccordiry to the Neuctor discussed in probabilistic terms. Such reo;iening cr expands r,ny premus or Shiv bdp)b'inate the accid ut consevnce3 shall be characterized ~n ongoing p oceedmg.'
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- 2. The denh!!!bn of Cless 9 accidents tenns of potential radiological liowever it is also the intent of the in I.e Anner is not sufficient!) prepse c Aposares to individuals. to populatica Commission that the staff take steps to I
i to warrant its further use in Co nmmion groups, and. where appbcable to biota.
identify additional cases tnat might I
pohey, ru!cs, and regulations, nor as a
!!cnith and safety risks that may be warrant early consideration of either decision criterion in arney proctice.
ast.ociated with exposures to people additiorm! features or other actions l
'3. Tne Annex's prenription of shall be discussed in a manner that which would pres ent or mitigate the a.uumptions to be used in the analysis fairly reflects the current state of consequences of serious accidents.
of the environtr. ental consequences of knowledge regarding such risks.
Cases for such censideration are those accidents does not contribute to Socioecono:nic impacts that might be for which a Final Environmental associated with ernergency rneasures Statement has already been issued at obkttive consideration.
during or fo!!owing an accident should the Coestruction Permit stage but for
- 4. The Annex does not give adequate cont.ideration to the detaiteil treatment also be discusseiThe environmental which the Operatmg License review of measures taken to p event and to risk of accioents should also be stage has not yet been reached. 5 mitigate the consequences of accidents compamd to and contrasted with carrying out this directive. the st if in the safety eview of each application.
radiological risks associated with should consider relevant site features.
.W c!assification of accidents normal and anticipated operational including popula' ion density, associated with accident risk in comparison to such proposed in that Annex shall no longer releases.
be u7ed. In its plate the fo!10 wins in nrumulgating this interim guidance, features at presently operating plants.
interim gmdaner is given for the the Commission is aware that there are Staff should also ;.onsider the hkelihood treatment of accident risk and v W Iibly rernain for some time to that substantive changes in plant design considerations in NEPA reviews.
come meny uncertainties in the features which may compensate further application of risk assessment methods, for adverse site features raay be rnore An.ident Considerations in Future and it erpects that its Environmental casily incorporated in plants when NEPA Reviews y m@
c nstrucu n has not yet prPssd W P*d I"knyenu w n
it is the position cf the Cornmission muta mu.s in as pnha she far.
Environmental Rgarts subm, tied by that its Environmentallmpact cytin ates On um other hand the applicants for construction parmits and i
Statements. pursuant to Section 102(c)(i) 7 L na,smn believes that the state of of the National Environmental Policy the artys sufhem.ntly advanced that a for operating licenses on or after joly L Act of 1%9. shallinclude a reasoned h"8 "*ng shouh,t now be made m the 19&t should include a discussion of the consideratmn of the environmental risks use f i.nm memodologies m the en ironmental risks associated with (imp acts) attributable lo accidents at the
'?ulat ry procens, and that such use accidents that follows the guidance particular facility or facihties within the will represent a contructa e and rational given herein.
scope of each such statement. In the f rward tep in the discharge ofits Related Policv Matters Under analysis and discussion of such risis,
'"P " ", 'C8-
%gwy approdmately equal attention shall be 11is the intent of the Comm,ssion m i
given to the probahihty of occurrence of isspieg this Statement of Interim Policy lo addition to its responsibilities iclo ses and to the pmhability of that the staff willinitiate treatments of unkr NEPA. the NRC also bears occunene.e of the environmental accident considerations,in accordance resp onsibility under the Atomic Enerpy 1onwquences of those releases.
with the foregoing guidance, in its Act for th protection of the public Rc! cases refer to radiation and/or ongoing NEPA reviews,i.e.. for any health and safety from the hazards radmactive materials entering
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pnn. ceding at a licensing stage where a associated with the use of nuclear emironmental exposure pathwavs.
Final Environmental Impact Statement energy. Pursuant to this responsibdity inc!udinc air, water, and ground water.
Events or accident sequences that has not yet been issued. These new the Commission notes that there are lead to o ! cases shall include but not be treatments, which will take into account currently a number of ongoing activities hmited to thnse that can reasonably be significant site-and plant. specific being considered by the Commission features, will result in more detailed a.M its staff which intimately relate to empnied to occur. In. plant accident sequences that can Icad Io a spectrum of discussions of accident risks than in the " Class 9 accident" question and relmes shall be discussed and shall previous environmental r,tatements, which are either the subject of cunent inc!ude sequences that can resu't in particularly for those related to rulemaking or are candidate subjects for inadequate cooling of reactor fuel and to conventionallight 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 resised treatments willlead to Commission issued for public comment
- which es ents arising fioin causes conclusions regarding the environmental a proposed rule which would cxtemal to the plant which are considered possib!e contrib.itors to the r sis of accidents similar to those that significantly reAe its requirements in
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tid associated with the particular plant would be reached by a continuation of 10 CFR Part 50 for emergency planning sha!! also be discussed. Def ar!cd current practices, particularly for cases for nuclear power plants. One of the quantitative considerations that fonn involvir.g special circumstances where considerstions in this rulemaking was Class 9 risks have been considered by the basis of probabilistic estimates of relcans need not be incorporated in the the staff. as desCIIbed above. Thes, this
- Commminen C:Imdy ar.d Ikedford d.ugree Environrnental Impact Statements but change in pclicy is not to be construed
@h the indWe cf the pm edmg two senrrm en They feet that thc3 aec absobtely encoaabter.t wnh shall be referenced therein. Such as 'ny lack of confidence in conclusions an even. banded ree;prainst of the former, references shall m.olude, as apph,cabic, regarding the environtnental risks of eme smon on O..:9 acddecis reports on safety evaluations, accidents expressed in any previously e.. m m g.
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-tht pvendai corwI;uences of CLss 9
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ocpJe nts ga gnetic sense.'
j
. I., nupst tr9 pursuant to the Corr.mbsior/s request a Eting Policy -
Tied force inade seccmmendations with respect to possib!c changs in NRC
- reactor sitir.; policy end criteria.*
currently ut forth in 10 CFR Part ito. As stated therein. its recommendations w ere in4de to accarnplish (among othus; the fc!!cs.iag goal.
To take mio consideratio in siting the risk ~
nemaaled swh acndents tierond the design has's (C.eu v! by establishing papelation densay.nd d:strantion criirna.
This matter is cunently before the Commission.
This'and other recommendations that have been made as a resu!I of the savestigations into the Three Mile 13!and accident are currently being brought tapether by the Commission's staffin the form of proposed Action Piers?
' Among other matters. these int.nrporate eecommendations for rulemaking related to dagraded core cooling and core melt auidents.1,he Commission expects to issu6 decisions on these Action Plans in the rear future. It is the Commission's policy and intent to devole NRC's major resour(es to ma!!crs which the
' Commipion believes will make existing and future nuckar power plants safer.
and to prevent a recurrence of the kind t of accident that occurred at Three Mde i Island. In the interirn. however. and
- pendmg completion of rulemaki ig l activities in the areas of emergenty
! pla.minF siting criteria, and desin and
[ operational safet), all of which ins olve l considerations of serious accident
- l potential, the Commission finds it -
[ essential to improve its procedures for
[ describing and disclo+.ing to the public
! t he basis for arriving at conclusions
! t egardmg the environmental risks due to ar.cidents at nuclear power plants. On
- om;detion of the rulernaking activities
'n these areas.and based also upon the uperience pained with this statement of sntetim pohey and guidance the Commission intends to pursue possible ihangs or additions to 10 CFR Part 51
- to cr>cify its rr t; tion on the role of
!acei. lent rin. under NEPA.
'Cf NUpf&o% "Planrang Ibsts ter the lf>e6etyment of 5'ete and Leol Gosemenent
- p <tecten tal r weisency R e.pm.e P
- .n, m Su; port l-t Lyht Weier % dear Fm.et 5%nts." No.cmtier l1976
- NI:Pf&c.;s. " Report of the Saims Pote) Task
!)n ce? Aupat19'e
- Drofi NU3 f G4em "Atle n P;4ns for
!!mp'ersns g ficc%mendettons of the hesdent's Cwr.em..+a and Other Stud ea of the Thti-2
- Asodent? tMede 10. W9
.