ML20010B121

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Requests That Util Consider Class 9 Accident Analyses in Eia Required by Nepa,Per 800613 Statement of Interim Policy. Accident Analyses Should Be Presented in Environ Rept When Applications for OL Are Tendered.Fr Notice Encl
ML20010B121
Person / Time
Site: North Anna Dominion icon.png
Issue date: 08/04/1981
From: Tedesco R
Office of Nuclear Reactor Regulation
To: Ferguson J
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
References
NUDOCS 8108140041
Download: ML20010B121 (5)


Text

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30G 4 1981 DISTRIBUTION:

Docket Nos. 50-404 Docket No.

50-404 LB #4 r/f DEisenhut bec: TERA EAdonsam NRC/PDR MDuncan Local PDR Hr. J. H. Ferguson SHanauer NSIC Executive Vice President - Power Operations RTedesco TIC Virginia Electric & Power Corapany RVollmer ACRS (16)

P.O. Box 26666 TMurley Richrnond, Virginia 23212 RMattson RHartfield, MPA

Dear Hr. Ferguson:

0 ELD 01E (3)

Subject:

Class 9 Accident Analyses in the North Anna Power Station, Unit 3 Environmental Report The commission's Statement of Interim Policy dated June 13,1960, (45 Fit 40101),

states that, " Environmental Reports submitted by applicants for construction pern.its and operal.ing licenses on or af ter July 1,1930, should include a discussion of the environmental risks associated with accidents that follow the guidance herein." Therefore, in accordance with this policy statement, we reoaest that you consider the more severe kinds of very low probability accidents that are physically possible in environmental impact assessments required by the National Environmental Policy Act. Such accidents are connonly referred to as Class 9 Accidents. A copy of this statenent is encloseo.

Your analyses of these accidents should be presented in the Environmental Report regarding North Anna Power Station, Unit 3 at the time you tender your application for an operdting license.

Sincerely, Original signed by:

Robert L. Tedesco, Assistant Director for Licensing Division of Licensing

Enclosure:

W e

Statement of Interim Policy (45 FR 40101) es q

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' rad te it'em s cf r> f e t.e cndir nd.ce:ise mater.a.s inc!:dmc seq en:es that can resu!::n i.af.equve coc:.ng cf re actor fue: and ie ine:::n; if

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the reacter core. In this regard. atter.: ion sha!! t.e given both to the p robabihiv of occurrence of such re cases and to the env;rc.mentalconsequences of such re: cases.This staternen: efinte..m p e: icy is taken in coord:natien with caher engoing safety.related activities that are directly

  • elated to accident censiderations in the areas of plant des!;n. eperational safety. s!!ing ;.olicy.

and emer;ency p!anning The Ccmmission inten 's to continue the

n. emaking on this.aa::er w hen new si:ing requirements and other safety relaied requirements inccrpers ting 3

accident censideratiens are in place.

catts: This s:atement of interim pobey is effective b.ne 13.1F50 Comment period expires September 11.1960.

10 CFR Parts 50 and 51 Acoatssts:The Ccmmission intends the interim pclicy guidance ccntained Nuclear Power Plant Accident herein to be immediatsl: effective.

Considerations Under the National Howeser. allinterested persons who Environmental Policy Act of 1969 desire to Mr H written cornments or act wcy: U.S Nuclear Regulatory sug;es: ions for consideration in ccnnection with this s:stement should Commission send them to the Secretary of the Acteow: Staternent of In'.erim Folicy, Commission. U.S..'suciear Regulatory suu u Amy:The Nucleat Regulatory Commis sion. Wa shington. D.C. 20555.

Commission INRC)is revisinF ts policy Attention: Docketing and Service f

for considering the rnore severe kinds of Branch.

s ery low probability accidents that are ren ruminen isromw ATiow cowt AcT:

ihysically pessible in envircnmental R.Wavne Heuston. Chief. Accident s

irnpact assessrnents required by the Eva!;ation Eranch Off:ce of Nuclear National Envirenmental Fo! icy Act Rea cter Rega!atien. U.S. Nuclear rcferrec,. Such accidents are commonly Reguia: cry Ccmmission. Washingten.

(NEP.'. ) to as Cim o ecQ'y ;.

D.C. :C555. Telephone: (M:1) 492-7323.

ft:!?w:nc sn accicent class;;; cation schtme frepcsed by the A:cmic Energy sumE"E NT ARY 8%FC""'T80":

Commissicn [ predecessor to NRC)in AcciJent Considerations in Past NEPA 19'1 fer purreses ofimp.emen::ng g, y;, w, NEPA.' Th e.'.!a rch :E.1sts accdent at Unit : cf the Three 21e 15?and nuc; ear The 7. reposed Annes to A;pendix D p! ant has em;hasi:ed the need for cf 10 CFR rar: 50 thercafter the chances in NRC policies regarding the "Annes") was published for com:.nt considerr tions to be gisen to serious en Decembcr 1. d71 b3 the (ferrner) accidents from an envirenmental as well A:cmic Energy Cemm:ssion. It proposed as a safety peint of view, ic specify a se: of standard: zed accident This sta:ctnen: of in:erim po! icy ass m;nons to be used in announces the withdrawal cf the Envirentnental Repce:s submitted by preposed Annex to Appendix D of to ap;: : ants for cons:ruction perm :s or CFR P.rt 50 and the suspension of the eperating licenses for nuc! car power rulema, ing proceeding that began with reactors. li also included a system for the pubhcation of that proposed Annex.

class:f>ing accidents according to a on December 1.1971. It is the graded scale of seserity and probability Commissio *s position that its of occurrence.Nine classes o'f accidents, s

Enviren nentallmpact Staternents shall were defined. ranging from tris tal to inc;ude considerations of the site-scry serious.It directed that *for each specific environmentalimpacts class. except c! asses 1 and 9. the attributable to accident sequences that ensironmental consequences sha!! be evaluated as indicated." Class 1 events a r.rer...e.... Aene. ie ic esTs r.rt so.

were r.ot to be considered because of.

A;peea D. 3f F%. 41 n; Cem. esien's NEP.4 their trivial consequences. Whereas.in im;.*ma rt.r.g seg.!.l e-s me e e.t es q.er:tly (July regard to Class 9 events. the Annex it ve: re....e.no rec.s:.. so crx r.r, si t,vi.i th e' i.me the Co.r. s.en ec ed t)..t '*Tf.e Prr.,;oed stated as follows:

Amr.es is st li wMer cor, sider bcq * * ** 2s fit i

cic"9

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withir. a 50EEt tedius cf the plant. and I.ody cn whien tht p*a*.1 U*!IIt!f the

  • -n ec% wies er Cias 5insshe
e. g., n n t';. st.:sted s.cce ssise fe!h.res scme differer.ces bctween bef!:ng watsr staff em;1asired 1:s fr us on r'ti trel'e rscr* snere tw.It en f esti.!sted fit the reactors (BWR) and pressuriced wat:r snsfronmer:: but did nc! knd that the des p b.sl for potet:ne sysierns and reactors [PWR). Beyond these few prehabiht) CI
  • ccit f~ tit n!

er.pr.eered safe:3 eatures.Trie" specifics. the discussions have occurring ! the f:rst place w as f

cors*c.,er.ces cald be ses era. Hon es er. the reiterated the guidance of t} er Annen essentially any different than for land.

probab(:7 cf the occartence is so small and a e relied u *n the Annefs based plant.In its Me,mcrandum and te.. Dcfanse m depth (r e!!. pit phys cal ccnclusion that the prchab!!ity of Order in tg..e Matter o. O.sr hore Pew er trst thee e-see.mentat risk is estrcmely r

.s occurrence of a C! ass G egentis toolow Systems.* the Comminien concurred in be: ars). t;;a!.:) astrarte for design.

the staffs jdgment.Thus, the Reactor -

sr.an; fact.are, and operat;cr continued to warrant consideratio. a conclusion su.-s e !:ance and test.rg. and consers atrve based upon re. era!!y stated safety Safety Stuc} and NRC emperience mth these cases har served to refncus de.'n are att app!,ed to proside and considerations.

attention'on the need to rectnphasize r.s.

cn the re; wired h'sh degree of With the publication of the Reactor that cmironrnental risk entails both an. s re that puenual accidents in this Safety Study (WASH-1400). in draft probabili::es and censeauer.res a point clen are. ate wa remain. sutac.ently remo:e form in August 1574 and final ferm in that was snadein the pul?ication of the in prebabdji> that the erairor.rnental risiis October 1975.the accident discussions I'

Annex. but was net gis en adequate

'.$e'd

D:s'cu s su$h cUenIl in Environmental Impact Staternents e;pUcants' E.ndrc. men:a! Reports.

began to refer lo this first detailed study emphasis.

In July 1577 the NRC commisstoned a of the risks associated with nuclear Risk Asseurrent Review Group *to A footnote to the Annex stated:

power Mant accidents puticularly Atihough tha a.nen nfen to appheant's events which can lead to the rnetting of clarify the achiesernents and limitations of the Reactor Safety Study. One of the Erw: rent ental Errerts. the current the fuelinside a reactor.a Tne references concbssons of this stdy. puWshed in snumpqens ar.d other provisions thereof are to this study were in keeping with the September 1578. es NL' REG / CRC io.

app 5 cab.e. esce;t as the content may intent and spirit of NEPA *no disclose.

" Risk Assessment Review Group Report oderyne require. to AEC draf t and final rele ant info r.ation. but it is obvious Deiade d Statements.

that WASH-14'c did not form the basis to the yparh;u!atoy i

Commission. was that "The Review During the pub!ic ccmment perior that for the conclusion expressed in the followcd publication of the Annex a Annex in 1971 that the probability of Croup was unaMe to d,etumine whether de absolute probabilities of accident ni.mber cf critia!sms of the Annex were occurrence of Class 9 events was too sequences in WASH-1400 are high or reccis ed. Princtral erncng these were low to warrant their (site. specific)

Icw but bel: eves thit the error bounds the fetiewinF:

consideration under NEPA.

greatly understated.,,e in general, on these nLmatu er (1)Thephdescphy of prescribing.

The Commission's staff has, however, This and othat assernptions does not lead to objective identified in certain cases unique findings of the Review Creup have also enalysis.

circurnstences wb'ch it felt warranted subeequently been referred to in I:)It failed to treat the probabilities of more cuensise sad detailed "d'8^*'" *Eb""'"'***' "8 accidents in any but the most general consideration of Class 9 events. One of

" ' ' * " I"' " * * ' I these was the proposed Clinch River "I "" ' ' "" # $'

I way.

[3) Ne sir;c-ting analysis was gis en Breeder Reacter Piant [CRSRP). a liquid I "'I Y' N

^""'**"I to show that C,ian 9 accidents are rnetal cooled fast breeder reactor very Januan.1EmJgCc~ mum.d "

  • I ' *'

'E*#*E" suff tie ntly Irw in prebability that their different from 'he more conventional ns center.:ences :n tems of environmental li*-M water reactor p ants for which the statement accepted...e Endin;s of the res need net be discussed.

n ety e3pericect base is much bros,dcr.

Emiew Group both as to the Ecactor

[41 Ne t.:. dance war gisen as to hcw enmental S'a te ment errident and rc=af rebses of in the Fir;aQ yhe staffincluded a Safety Study's achiesements and as to fpr i C m P.t its limitations.

r.ac.cth c cfunu during plant c:scun:on of the consideratien it had A few Draft Environmental cpmten d ;;d be f.ctored ir,tc the

un t Clan F 6 s ents.

Statements hat e t een published ces:heef.t anah sis.

f 51Yht acc.duit usumptions a se not In 'h' E '[* ""'ew f r the subsequent 'o the ThreicMi:t Island 518ff 'TIOTT 'd 8D accident.These wetc for cens entional 8" SI 8t-I',f'lf F

ene 2.!!3 ap-hab! to g.s cocied or limdii r.etal'ceMed reiictors.

"***i '".enme ni the re:auve

!and.bned 1.;ht w ater inetor plant:

dificrcnces in Class 9 accident and cent:n.cd to reflect the past it) Safety and environmontal risks are C?^"[9"*"*es among the alternat,ive ptsetice with rupect to accidents at not enential:v different considerations.

sdn. SECW.1M such p: ants. but ncted that the i

Ne thcr the'/.tctnic Energy in the case of the applicatien by experience cained frc= the Three Mile Cc.nminien nrr the NRC took any OUthen Pew cr 53 sums to manufactum Island accident was not factored into f.rtha act cn en this ruitmaking except Coahns r"JO*! TE'" Mants. IDe 5)aff the discussion, i

in 1F 4 whcn 10 CFR Part 51 was jud;ed that the environmental r:sks of Our exper;cnce with past NEPA prcme!; ate d. Os er the intervenir g 3 cars seme Class 9 es er 4 warranted special revicws of accidents and the TMI the accident censiderations discursed in consideration.The special accident clearly leads us to believe that i

Entirer.menta!!mpact Statements for circumstances were the potentially, a change is needed.

propond n.c' ear power p! ants reficcted sulous con, sequences associated with Acccrdin;!y.the propcsed Annex to the guidarace of the Annex with few

    • '"II' quid) pathways lesdmg to Appendix D of 10 CTR Part 50. published exceptiens.T pica!!y.the discussions of accident cenirquences throuFh Class a ra diolog.ical expcsures if a rnollen

. on Decerrber ).1971. is hereby 3

nector core w are to fallinto the wster withdrawn end shs!! not hereafter be

[drs gn basis accidents) for each case used by appliesnts nor by th. staff.The bas e rcficcted specific site me,,, 'ef er. i. nce 6.e she i '-i ci.'.'". e'.ccideni-reasons for the withdrawal are as

  • ' ' ' " " ' ' ' * ' "' 'Y-8'"##

characterists anociated with gojjow.s.

r rndeorcie;v lthe d:spenion of releases

.w.np e., sem. w~nent, u.,s.. too.er, of radioac:m materialinto the ews Cent so e ewe eneta.ccident.

'Nctei se Smce.5 erie

  • H n%,

atmo; hue).the aetcal population

'Ntxc-cus. T.t.ro.r3 so r.

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  • g e

4 n

The environ: cr.tal c cnse quenct s of iss td Sinetets.nor,ath.t a

1. Tre A-. a p r scribes cont.dcts'..in cf the k'nds of accidents reisanes whree ;rchabt! sty cf ecc. ence showing cf nm!'ar spec a!'

tc. the Reactor hs been tsumatc d shall also be circumstances. as a ! asis fer e;s.trg.

!C:=s it; that. et c:rd n; he accident d:scussed in probabdistic terms. Such reo;,enir F. or tsr.andin; any prtweat or i

S:vd.'ccmirate t

~~ Safe 3 3

consequences shall be characterized in en;oing proceed.ng.'

risk.

2. The def.nition cf Class 9 accidents terms cf potential radiolegical How e s er. it is also the intent cf the expesures to individuals. to mo Comrnisslon that the staf!!ake steps te, groups. and. where ap;!;cabfe.pulation i

in the Annet in t.ct sufheiently precise to biota.

Identify a diticnal cases that rnrght to war: ant es furthtr use in Commiss;on pobey.rutes. and re;u:ations, nor as a Health and safety risks that may be warrant car!y censiderst!cn cf either ciccision enterion in agency prattice, associated with e>.perures to; cople additio.al feat res or ether acticas

3. The Annet's prescription of shallbe discussed in a manner that.

which w ould pres ent or =!!!; ate the

- assurnptiens to be used in the analysis f.ir!y ref;ects the currer.: state of consequences of ser:ous a:cidents.

of the environmental consequences of knowledge regarding such risks.

Cases for such censideration are those scridents does not contribute to Socioeconomic impacts that might be for which a Tmal Envirce. mental objectn e cens?deration.

associated with ernergency rneesures Statement has already been issued at

4. The Annes does not give adequate during or fo!!cwir.; an accident should the Construct!ca Ptimit stage but for censideratica to the detaile'd treatment also be discussed.The environmental which the Operating License review of raessures taken to prevent and to risk of accitients sheuld also be stage has not yet been reached. !n mitigate the consequences of accidents compared to and contrasted with carrying out this directive.the staff 7

in the safety review of each application.

radiolegical risks associated with should consider relevant site features.

1 Tlye classification of accidents normal and anticipated cperational including pcpulation dens!!y. associated with accident risk in comparison to such preposed in that Annes shall no longer releases.

I tie used. In its place the following in prornulgating this interim guidance, features at presently cperating plants, interim guidance is given for the the Commitsien is aware that there are Staff should also consider the likelihood treatment cf accident risk and willlikely rernain for seme time to that substantive changes in p ant design considerkons in NEPA reviews.

corne many uncertainties in the features whir.h may ce=pensate further Accidect Considerations in Future application of risk asstssment rnethods.

for adverse site features inay be rnore and it expects that its Environmental easily incorporated in plants when NEPA Reviews Irnpact Statements willidentify major construction has not y e';,re;tessed very that its En..osition of the Commission uncertainties in its probabilistic far.

lt is the p

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virentnental Impact estimates. On the other hand the Environmenta! Reports submitted by I

Commissien believes that the state of applicants for censtruction pstrnits and for operat,ng licenses on or after July 1.

cte ati nal orment Pol c the art is sufficiently advanced that a i

Act of t959.shal! include a reasoned be; inning should now be rnade in the 1663 shou!d inc!qe a discussion of the consideration of the environmental risks use of these methodologies in the environrnenta! rms sesociated with (imracts) attributable to accidents at the regulato.> process, and that such use accidents that fc!:ow s tne guidance 4

particular facility or facilitics within the wW represent a centructive and rational g.nen herein.

scope of each such staternent. In the ferward step in the discharge ofits dP Q '. h M analysis and discuss!cn'of sdh risks.

repensMWs.

Consideration apptchate!) equal attention shall be

!!is the intent of the Cemmissien m.

given to the pictability of occurrence of issuing this Staternent of Interim Po! icy In addition to its respons,bi'. ties re! cases and to the pro'bability of that the staff w.!! initiate treatments of,. under NEPA. the NRC aiso bears occurrence cf the environmental accident corsideratiens. in accordance responsibility under the Atctnic Energy l

Eticas'es reic; te radiation and/or with the feregeing guidance. in its Act for the ; ctaetien cf the pab!ic ec~rt.cncts cf tr.ese re! cases.

en;cing NEPA resiews. l.e., for any health and safety from the hacards radioactis e attr.a!> cnierinc envircementcl e spesure path' ways, pmeing at a licensing stage where a assoc!sted with the use of rueltar Fina! E virenmentalimpact Statement energy. Pursuant to this respensibility inclu6nc air. water anc ground water.

Estem er accident sequences that has not yet been issued.These new the Commissicn notes that there are lead i..m:snses shallinclude but not be treatments, which wi!! take into account current!y a nt.=be. of enpeing activities hmited to these that can scarenably be si;n;ficant site. anc plant specific being considered by the Ccemission features. will result in rnore detailed and its staff which intirr.ately relate to espe-ted to eccur. In. plant accident discussions of accident risks than in the " Class 9 accident" questien and sequenets that can iend to a spect urn of which ese either the sub;ect of current re! cases s.ha!: be d scussed a.d shal!

presious environmental statements, include scquences that can ics:.!! in partico!arly for these re!ated to ru'.cmak:ng er are candidate sub,'ects for inadequate cro!ing of reacter fuel and to consentienallisht water p? ants at landr rulemaking.

rnetting of the reactor core.The cecnt to based sites.It is expected that these -

On December 19.1979 the i

resised treatrnents will lead to Commission iss:.ed fer pub!ic cm. ment

  • sshich es erts arising from causes conclusions regarding the envitentneatal a proposed rule which would l

esternal to the' plant which are risks of accidents similar to those ^it significantly resise its requirements in considered pessib!e centributors to the

' risk associated with the particular plant would be reached by a conti.uation of to CFR Part 50 Tor emergency planning i

s!.all also be discus sed..*htailed

. current practices, particular!y for cr es for nuclear power plants.One of the quantitctise consideratiens that form inciving special circumstances whe*e considerations in this rulernakIng was l

the basis of probabilistic estimates of Class 9 risks have been censidered by releases nted not be incorporated in the the staff.as described above.Thus. this

'comm....enui cer,ty erd s.eerd e...r ce

~6'h ne inc! wen cf tbe rreutr.s '-e ser.ier4es.

Enviren=en911mpact Statements but change in policy is not to be construed 3',d'.'.[. p,.*[,,,'iica v. c:.. s eccainsp shall be refercnced therein. Such as any laek of confidence in conclusions references shall include, as ap;!icable, regardmg the environmental risks of

.n 3ccidents expressed in any previously

+ +4 rm reist.

reports on safety esaluations.

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a e.

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e s

h.*
e* s.nse
;.cn:es ?! Ciass 9 b n*s in a evn: sensi.'

lr. Ai.st :r*k. persuant to the -

s m.as:ce.'s repest. a Siting Policy

. A Ter:t made reeu:- iendatiens wl:h

. :c:t to pessib e changes in NRC 5

etor siting pe!.:y and criteria.'

r:.t:y set ferth :n to CFR Part100. As

.yd therein. Its teecm:nend/tions te r ade 'e a::c=phsh (am:, g 3.tts):he n:::w! g geat

- Te tue inte r * =:dcration in siting the risk

.ariated d. pdents be3 end the design i s !Ciart 7! t,s estabhshing peru!ation sq and d:s.nbution criteria.

~;* is rnatter is currcntly bt se the n

=rnis s!!n.

~'his and other recommendations that s e been rnade as a result of the

.estigati ns into the Three Mile Isrand

dent are currently being brouF t h

j e:htr by the Commission's staff in

+

bem cf proposed Action Plans.'

20. g other rnatters, these incorporate 7,mondations for ruiemaking related

- h;raded core cooling and core melt udents.The Comrnissien expects io -

2,;[ccisiens en these Action P:ans in

~

near future. It is the Cornrniss.on's

/

m:y and intent to devote NRC's major curc:s to rnatters.which the T. mission belies es will make existing

- f fu:ure nucIcar power p ants safer.

to prevent a recurrence of the kind
cident that o: curred at Three Mile nd. In the ime:im. however and s

trq completion of ruiemaking

,..tws in the areas of emergency

!ng. sain; cnter:a. and design anc

.!.cna! sa.i:y. al1 cf wh'ch invo!s e

. dcatists cf Serices x:! dent *

.tal, the Ccmmis'.!cn f.nds it

-tesi ta i pres e i" precedures for Emg and d:56: sing to the oublic s:s fc r a-Fv.n; at cen:! mens

' n;;he ensirenmenta. risks due to

. n:s a: nt::rar p~ver ;:ents. On Wn cf de rufe naking a:thities

se areas, and Lat.
d also upon the ran:e gained with this s: ster.ent of x peEc3 and g;idance.the

~ ;f akn :ntend! to pursue possible p c-a d6C. ns to 10 CFR Par: 51

!,. its pi.s.*icn on the role of a

s n: r!As Lnder !2PA.

n.

s SIO.c:v.. Nsnirr No e for the

..r.: ef $1,*e er d to:st Cc.ar-ment

,.pe!L r e 3 ?r) Rey 6?st T.a.s a 5.rport w.ter Nt's.r Fe=er Nets." Nese t.er L T Ma:s. asepe-t cf the Siteg Falcy Ted

^ A.g.st19"5 4 !t NL) ecd **e1 "At' eon N* a for

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e r'stg E er r.-e -lat.cm cf 11 r headertt's so.:? v.s CG e %!.ee e'sVe TMt *

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.~ :,+ e-! et 10 19'8 4

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