ML20010A720

Memorandum on Consideration of Accidents in Emergency Planning.Traces Commission Consideration of Class 9 Accidents & WASH-1400 Accident Consequence Scenarios. Certificate of Svc Encl

ML20010A720
Person / Time
Site:	Summer
Issue date:	08/07/1981
From:	Knotts J KNOTTS, J.B., SOUTH CAROLINA ELECTRIC & GAS CO.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20010A712	List: ML20010A711 ML20010A716 ML20010A720
References
ISSUANCES-OL, NUDOCS 8108120103
Download: ML20010A720 (5)

Text

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ATTACHMENT B o

August 7, 1981 UNITED STATES OF AMERICA -

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:

SOUTH CAROLINA ELECTRIC AND ) Docket No. 50-395-OL GAS COMPANY, et al. )

)

(Virgil C. Summer Nuclear )

Station, Unit 1) )

APPLICANTS' ME1CRANDUM ON CONSIDERATION OF ACCIDENTS IN EMERGENCY PLANNING The consideration of Class 9 accidents and WASH 1400 accident consequence scenarios by the Commission may be traced briefly as follows. The Commission's notice adopting its final amended rule on emergency planning (45 Fed. Reg. 55402, August 19, 1980) stated:

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! " Predetermined protective actiors are needed for the EPZs . . . . These distances l

I are considered lasse enough to provide a

! response base that would support activity outside the planning zone should this,ever be needed.", (45 Fed. Reg. at 55406) t The Commisrion cited, as "the regulatory basis" for the adoption of the. ten and fifty mile EPZs, the policy endorsed by the Commission in a policy statement published on October 23, 1979.

That policy statement (44 Fed. Reg. 61123, October 23, \

1979) concurred in and endorsed NUREG-0396, saying:

l "In endorsing this guidance, the Commission I

recognizes that it is appropriate and 810812010G 810907 PDR ADOCK 0500039"!

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l prudent for emergency planning guidance to take into consideration the principal characteristics (such as nuclides re-leased and distances likely to be involved]

of a spectrum of design basis and core melt accidents . . . . The Commission is direct-ing its staff.to incorporate the~ planning basis into existing documents used in the evaluation of State and local emergency response plans to the extent practicable."

(id.)

NUREG-0396 had said in this regard:

"If adopted by the NRC, the Task Force expects that the key elements of the guidance would be incorporated in the NRC's primary emergency planning guid-ance publication for States and their local governments (NUREG-75/111) 1/

and therefore used by Federal agencies as a part of the basis for concurrence in State and local government' Radio-logical Emergency Response Plans in support of power reactor facilities."

(NUREG-0396, Foreward at ii) .

NUREG-0396 considered both the consequences and proba-i .

bilities of a full range of accidents, including those exceeding both Part 50 design basis events and Part 100 assumptions, and including specifically a range of Class 9 events and WASH 1400 scenarios.

i "As an alternative to attempting to define a specific accident sequence, the Task

> Force decided to identify the bounds of l The Foreward to NUREG-0654 indicates that it provides 1/

a basis for, inter alia, state and local governments to develop emergency plans and improve emergency preparedness, and that it " supersedes other previous guidance and criteria published by NRC and FEMA on this subject." (NUREG-0654 at i) . The text states "This document supersedes NUREG-75/lll . . . . (NUREG-0654 at 5)

i the parameters for which planning is recom-mended based upon a knowledge of the potential consequences, timing, and re-lease characteristics of a spectrum of accidents." (NUREG-0396 at 5; see also pages 6, 8-9, 14-15, 17, 24, and Appendices I and III).

It is thus clear that NUREG-0396 was considered by the Commission in promulgating its final emergency planning rules.

It is likewise clear that the guidance of NUREG-0396 was to be, and was, considered and drawn upon-2/by the federal planners who prepared NUREG-0654, the successor document to NUREG-75/lll. (See note 1/) .

Re ectfully submitted, V: f.

Jose 'B. Knott#, Jr.

Coun el for Applicants ,

date: August 7, 1981 2/ NUREG-0654 at 4-18, especially Tables 1, 2, 3 on pages 17-13, and Appendix 1. The planning basis in Part I of NUREG-0654 is carried over into the standards and evaluation criteria in Part II, e.g. page 42, and page 46. For example, the

! licensee must include the initiating conditions in i Appendix 1; see e.g., pages 1-16 through 1-19.

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d UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:

SOUTH CAROLINA ELECTRIC & ) Docket No. 50-395 eL GAS COMPANY and )

)

SOUTH CAROLINA PUBLIC SERVICE )

AUTHORITY )

)

(Virgil C. Summer Nuclear 1 Station) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Motion to Exclude Testimony of Dr. F.aku on Contention A8" and Attachments in the above captioned matters, were served upon the following persons by deposit in the United States mail, first. class postage prepaid this 7th day of August, 1981.

Herbert Grossman, Ecq. Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Board Panel ,

Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 George Fischer, Esq.

Dr. Frar.k F. Hooper Vice President and Group School of Natural Resources Executive- Legal Affairs University of Michigan South Carolina Electric &

Ann Arbor, Michigan 48109 Gas Company Post Office Box 764 Mr. Gustave A. Linenberger Columbia, South Carolina Member, Atomic Safety and 29202 Licensing Board Panel U.S. Nuclear Regulatory Steven C. Goldberg, Esq.

Commission Office of the Executive Washington, D.C. 20555 Legal Director U.S. Nuclear Regulatory Commission

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Chairman, Atomic Safety and Licensing Appeal Board Panel Washington, D.C. 20555 U.S. Nuclear Regulatory Commitsion Mr. Brett Allen Bursey Washington, D.C. 20555 Route 1, Box 93-C Little Mountain, S.C. 29076

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Mr. Chase R. Stephens John C. Ruoff Docketing and Service Section Post Office Box 96 Office of the Secretary Jenkinsville, S.C. 29065 U.S. Nuclear Regulatory Commission Robert Guild, 'isq.

Washington, D.C. 20555 314 Pall Mall Columbia, South Carolina 29201 Richard P. Wilson, Esq.

Assistant Attorney General South Carolina Attorney General's Office -

P.O. Box 11549 Columbia, South Carolina 29211 g

Jo d h B. Knotts, Jr.

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