ML20078P136

Application for Stay of ASLB 810717 Partial Initial Decision Authorizing Issuance of Licenses to Load Fuel & Conduct Low Power Tests & of Aslab 830518 Decision Affirming 810717 Partial Initial Decision.Certificate of Svc Encl

ML20078P136
Person / Time
Site:	Diablo Canyon
Issue date:	10/31/1983
From:	Reynolds J CENTER FOR LAW IN THE PUBLIC INTEREST, JOINT INTERVENORS - DIABLO CANYON
To:	NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
Shared Package
ML20078P041	List: ML20078P038 ML20078P136
References
ISSUANCES-OL, NUDOCS 8311030217
Download: ML20078P136 (44)

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{{#Wiki_filter:, y UNITED STATES OF AhERICA 00CKETED USNRC NUCLEAR REGUIAIORY COPHISSICN BEEORE THE ATOMIC SAFETY AND LICENSING APPF)O)BdMD-2 A9 :28 j-CFFi2 0F SEU'r L CCCETING A SEF ) SRANE In the Matter of ) ) PACIFIC GAS AND ELECTRIC CCNPANY ) Docket Nos. 50-275 0.L. ) 50-323 O.L. ) (Diablo Canyon Nuclear Power ) Plant, Units 1 and 2) ) ) ) JOINP INTERV m ORS' APPLICATION ~ EOR A STAY Pursuant to 10 C.F.R. S 2.788, the SAN LUIS OBISPO M7IHERS EUR PEACE, SCENIC SHORELINE PRESEENATION CONFERENCE, INC., ECOIDGY ACTION CLUB, SANDRA SILVER, GORDCN SILVER, ELIZABEIH APFETREM, and JOHN J. EDRSTER (" Joint Intervenors") hereby renew their September 10, 1981 application to the Atmic Safety and Licensing Appeal Board (" Appeal Board") for an order staying the effectiveness of (1) the Atcuic Safety and Licensing Board's (" licensing board") July 17, 1981 Partial Initial Decision ("PID") which authorized the issuance of licenses to load fuel and conduct low power tests at, Diablo Canyon Nuclear Power Plant ("Diablo Canyon"), Units 1 and 2; (2) the Appeal Board's May 18, 1983 decision affirming the licensing board's July 17, 1981 PID; and (3) the Comission's September 21, 1981 decision authorizing issuance of a low power operating license for Diablo Canyon, Unit 1. The Joint Intervenors request the stay in order to revent irreparable harm and to preserve the status quo until adminis-trative appellate review of all issues underlying issuance of the fuel loading and low power operating license is ccuplete, including review of all quality assurance matters pending before this Appeal Board or the Ccanission. 8311030217 831031 PDR ADOCK 05000275 0 PDR . 7;w

F I A similar application for a. stay was filed by the Joint'Intervenors in September Prior to a decision by the Appeal Board, however, the first of a continuing -1981. . series of design and mnstruction errors was discovered at Diablo Canyon, and, on November 19, 1981, the Ccenission suspended the low power operating license indefinitely. During the past two years, a design verification program has been -inplemented by PGandE and by Teledyne Engineering Services, an ~ auditor-hired by ~ PGandE in response to the Cm mission's suspension order. Although the verification is incomplete in ntunerous respects, the Cmaission is expected to vote on reissuance of_the suspended license on November 8, 1983. 'I. Sul@iARY OF 'HfE DECISICNS 'IO BE STAYED Each of-the decisions to be stayed has authorized-issuance of the fuel loading .and low power operating license for Diablo Canyon, Unit 1. More sprifically, the licensing board approved the adequacy of (1) the PGandE quality assurance / quality { control ("QA/QC") programs for design and cor.struction, and (2) the on-site and off- . site emergency. response plans for purposes of low power operation. The May 18, 1983 { Appeal Board decision affirmed the licensing board's decision, and the Connission's September 21, 1981 decision constituted the-innediate effectiveness review of all matters underlying issuance of the license. II. GROUNDS FOR ' DIE STAY The factors prescribed by 10 C.F.R. S 2.788 (e) to be considered by the Appeal 1 Board in connection with a request for stay are: (1) whether the moving party has made a strong showing that it is likely to prevail on the merits; (2) whether the party will be irreparably injured unless a stay is granted; '(3) yhetherthegrantingofastaywouldharmotherparties;and-(4) whe're the public interest lies... .. _ _ _, _ _ _. _.... _.. _.. _... _.. _ _ _ ~.., _

W' 'g g. A. There is a Strong Probability that the Joint Intervenors Will Prevail on p the Merits 1. -- Quality Assurance. In its July 17, 1981 PID, the licensing board relied upon the mistaken assurances ~of PGandE and NRC Staff witnesses in finding that: The Diablo Canyon quality assurance programs for both the Design and Construction Phase a'd the Operations Phase have been and are in ocupliance with the requirements of.10 C.F.R. 50, Appendix ~B, and that the implementation of-both programs is acceptable to the-Board. The disclosure during the past two years.of numerous design and construction errors, including a breakdown of the quality assurance programs of PGandE and its . major subcontractors, has discredited the board's finding. In July 1982, the Joint Intervenors and the Governor of California requested reopening of the record on the i-issue of quality assurance, whieft application was granted by this Board as to design.M In a related order, the Appeal Board found that "there is now substantial

uncertainty whether any particular structure, system or ocuponent was designed in accordance with stated criteria and cmsnitments."E In-light of this conclusion and the significant new evidence of a similar breakdown in construction quality assurance, there is no longer any factual basis in the record to support the licensing board's findings under Appendix B or the findings required _ by the Atmic Energy Act and the Carmission's regulations to justify issuance of a license.k Because of the long recognized inportance of quality

_ assurance in nuclear power plant design and construction,M and the undeniable 1 breakdown of QA/QC during the design and construction of Diablo Canyon, it must be proven on the record that an effective substitute for regulatory compliance has If ' In the Matter of Pacific Gas and Electric Cmpany (Diablo Canyon Nuclear Power Plant,1 Units 1 and 2), ALAB __, Memorandtsn and Order, at 2-3 (April 21,1983). y 1_E., Order, at 4 (August 16,-1983). y See, n, ~10 C.F.R. S 50.57 (a). ' M See, e.g., In the Matter of Consumers Power Cmpany (Midland Plant, Units 1 4 and 2), AIAB-106, 6 AEC 182,183 (1972); In the Matter of Duke Power Cmpany (William B. McGuire Nuclear Station, Units 1 and 2), AIAB-128, 6 AEC 399, 410 (1973). j g gi-w' - + + +-34e y g.epeyg -9 +- - - - w. -wi9--gr,--,y-e--,-it dyy ed ,ew> -g,c_e-e,M g---w si e e cggy-9-eygw rg M",grg%--y-,wey>-g---gerg .+ ,m y w-5. , ec-e =

a provided the factual basis for the S 50.57(a) and Appendix B findings. Until such a showing has been made, the Atomic Energy Act and the Ccanission's regulations . prohibit licensing of Diablo Canyon. 2. License Suspension and Amendment. Currently pending before the Ccanission i are two applications for hearings to be held prior to a decision to reissue the suspended license, both of which are based on S 189(a) of the htcznic Energy Act, 42 U.S.C. S 2239 (a).E ' Both because the Ccenission' has suspended the fuel loading and Icw power license, and because PGandE has applied for an amendment extending the term of the suspended license frce one to three years,E S 189(a) guarantees the right to a formal adjudicatory hearing prior to reissuance of the license or granting of the amendment. See, e.g., In the Matter of Metropolitan Edison Co. (Three Mile Island Nuclear Power Plant, Unit 1), No..50-289, Order (July 12, 1979); M., 10 N.R.C. 141, . 142 (August 9,1979); Brooks v. Atanic Energy Cournission, 476 F.2d 924 (D.C.Cir. 1973); Sholly v.-U.S. Nuclear Regulatory Ccanission, 651 F.2d 780 (D.C.Cir.1980), vacated on other grounds, _ U.S. _, 51 U.S.L.W. 3610 (February 22, 1983), on remand, _ F.2d _,19 E.R.C. '1055 (April 4,1983).E 3. Validity of the License. Because of the extended period that has elapsed since expiration of the suspended low power license in September 1982, PGandE's i E Section 189(a) guarantees the right to a prior hearing "in any proceeding ( under this chapter for the... suspending,...or amending of any license...." + 1 E License Amendment Request No. 83-08 (August 17, 1983). - i Y In Sholly, the D.C. Circuit Court of Appeals noted explicitly that the 1 time for hearing on an amendment was before any decision: By requiring a hearing upon request whenever a license is " grant [ed], suspend [ed], revok[ed], or amend [ed], Congress apparently contenplated that interested parties would be able to intervene before any significant change in the operation of a . suelear facility. 651 F.2d at 791 (enphasis added). On remand, the Court of Appeals made clear that the only circtzustance in which a hearing on an amendment may be held after its i effective date is where "no significant hazards considerations exist." 19 ERC 1055, 1056. Thus, under the circumstances of this case, S 189(a) requires a hearing prior to a decision on the proposed license amendment.. ,m._,.,.,,.,._-.,._.._y _.-my_y . ~. 7., ...y ,, %m.._, ,m,- .,_-r, ,,7.. -._yi

I . amendment application seeking renewal of the license must be denied'. PGandE has S 2.109,E ut this type of provision has requested an extension under 10 C.F.R. b previously been held inapplic7ble tinder similar circumstances: The kind of case that the statute was meant to cover was that in which time exigencies eithin the agency prevent it frcm passing .on a renewal. application, when an activity of a continuing nature such as radio broadcasting or shipping services is involved. By. contrast, in the case before us, time exigencies played no part in the Corps' refusal to renew. Instead a substantive prob- 'lem arose with the application which had to be resolved before the Corps could grant a new permit. Bankers Life & Casualty Co. v. Callaway, 530 F.2d 625, 634 (5th Cir. 1976), cert. - denied, 429 U.S.1073 (1977) (emphasis added). In this proceeding, a year has elapsed since'the license term expired, and the Omnission has taken no action, not because of " time exigencies" but because of a " substantive problem" precluding the Camission frca issuing a license - the discovery of massive design and construction deficiencies demonstrating that PGandE was not entitled to a license in the first instance. Thus, just as the court in Bankers Life concluded that the license had expired, PGandE's license has also expired and cannot be amended.

4.. Class Nine Accident Analysis. In the past, the Ca mission did not require consideration under the National Environmental Policy Act ("NEPA"), 42 U.S.C. S 4321 et _seg., of the effect on the environment of core melt accidents (" Class 9" acci-y dents). The premise was.that occurrence of a Class 9 accident was of such low proba-

- bility that neither NEPA nor the Atmiic Energy Act required its consideration. The 4 accident at Three Mile Island ("D1I") destroyed that premise, and the Camission E Thit regulation provides: If, at least thirty (30) days prior to the expiration of an existing license authorizing any activity of a continuing nature, a licensee files an application for a renewal or for a new license for the activity so authorized, the' existing license will not be deemed to have expired until the application has been finally determined. 1

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F I recognized this fact in its " Statement of Interim Policy" by amending its prior policy to require NEPA consideration of Class 9 accident sequences.b But despite the Comnission's explicit recognition that the prior policy was erroneous, it limited this amendment to prospective application absent "special circumstances," and as a result has repeatedly denied Joint Intervenors' requests for NEPA consideration of a Class 9 accident. The Ccenission's action is illegal for two reasons. First, NEPA inposes a statutory duty to supplement an Environmental Inpact Statement ("EIS") to l reflect significant new information or changed circumstances occurring after the l filing of the final EIS. E By the Ccunission's own admission, the 'IMI accident constitutes such significant new information, and the Ccanission cannot legally limit a pre-existing statutory requirement merely by stating that it shall apply only to . future EISs. Second, apart from NEPA requirements, the Ccanission has violated its i own policy that consideration of a Class 9 accident is required where special l circumstances exist, including - as at Diablo Canyon - the proximity of the plant to a man-made or natural hazard. E On either basis, therefore, issuance of a j license for Diablo Canyon absent consideration of the effects of a Class 9 accident l is unlawful. f i 5. Earthquake Emergency Preparedness. The Ccunission's regulations explicitly l. provide that "no operating license for a nuclear power reactor will be issued unless a finding is made by the NIC that adequate protective measures can and will be taken "t in the event of a radiological emergency." 10 C.F.R. S 50.47 (a) (1) (emphasis Y " Nuclear Power Plant Accident Considerations Under the National Environ-mental Policy Act of 1969," 45 Fed. Reg. 40101. l E See, e.g., Warm Springs Dam Task Force v. Gribble, 621 F.2d 1017,1023-24 (9th Cir.1980) (per curiam); Aluli v. Brown, 437 F.Supp. 602, 606 (D. Hawaii 1977), ( rev'd in pdrt on other grounds, 602 F.2d 876 (9th Cir.1979). E In the Matter of Public Service Cctrpany of Oklahczna (Black Fox Station, Units 1 and 2), CLI-80-8, at 434-35 (March 21,1980). 1 i . _ ~ ~. _ _ _,,

added). The evidence at the hearing was uncontradicted, and all parties conceded, that existing applicant, state, and local emergency plans fail to consider and allow for the effects of a major earthquake on the Hosgri fault occurring simultaneously -with a radiological emergency at Diablo Canyon.N ! articularly in light of the P Cmmission's appreciation of the greater seismic risk associated with nuclear plants in California and the continuing importance of seismic safety in this proceeding, this failure is a critical deficiency in emergency preparedness at Diablo Canyon.E I Nevertheless, the Appeal Board concluded that the licensing board was without - jurisdiction to consider the issue, citing the Ccmmission's San Onofre decision. In so doing, the Board violated the Joint Intervenors' right to a hearing guaranteed by S 189(a) of the Atcmic Energy Act, 42 U.S.C. S 2239(a), with respect to a safety issue unique to Diablo Canyon. Because its decision was without independent factual basis, there has been a clear failure by the agency to consider a relevant safety issue, either on a generic basis or within individual licensing proceedings.E / Accordingly, issuance of the license must be reversed. B. Joint Intervenors Will Be Irreparably Injured in the Absence of a Stay If a license is issued for fuel loading and low power testirig at Diablo Canyon, Joint Intervenors will be irreparably harmed in several significant respects. First, l nuclear materials will for the first time be introduced into the reactors, thereby i posing a risk not only of worker exposure but of contamination of the facility's l 1 E! See Low Power Hearing Transcript, Jorgensen, at 2; Sears, at 7; Sears Tr. 11060, 11283; Schiffer Tr. 10878-79 (May 1981). E/ In the Matter of Southern California Edison Company (San Onofre Nuclear Generating Station, Units 2 and-3), Nos. 50-361-OL, 50-362-OL, Order, at 3 (July 29, 1981) (Raising on the board's motion an issue concerning earthquakes and emergency planning); see also, In the Matter of Southern California Edison Co. (San Onofre Nuclear Pyr Generating Station), Memorandum and Order, at 2 (April 8,1981). E! See' Natural Resources Defense Council v. Nuclear Regulatory Cmmission, 685 F.2d 459 (D.C.Cir.1982), rev'd on other grounds sub nce. Baltimore Gas and Electric Co. v. Natural Resources Defense Council, _ U.S. _,103 S.Ct. 2246 (1983)..,__, _

e ocuponents and systems. (Hubbard Affidavit, attached hereto.) This irretrievable ccanitment of resources prejudices the Joint Intervenors' rights by predisposing this agency to issuance of_a full power license for the plant prior to final disposition [ of significant safety-issues, and makes further plant modifications less likely, even though such modifications may later be determined to be necessary. l Second, when an agency has taken an action in violation'of NEPA - such as the l failure to supplement in the -instant. case,- there is a presumption that injunctive ^ relief should be granted against the continuation of that action.until the agency ocuplies with the Act.. See Realty Inccme Trust v. Eckerd, 564 F.2d 447, 456 1977).E nvironmental factors must be fully considered not only before f(D.C.Cir. E actual harm occurs, but before the agency's plans are so advanced that they acquire " irreversible acnentum." Id. at 511; Lathan v. Volpe, -455 F.2d 1111,1121 (9th Cir. 1971) (It is "especially inportant" that an EIS be prepared early so that " flexibility in selecting alternative plans" is not lost). As the First Circuit 'recently observed, L [o]nce large bureaucracies are committed to a course of action, it-is difficult to change that course - even if new, or more j-thorough, NEPA statements are prepared and the agency is told to "redecide." L. I Massachusetts v. Watt, _ F.2d _,19 ERC 1745,1750 - (1st Cir. Sept. 16, 1983). i Courts should therefore intervene as early as possible to forestall the formation of. 'k. E The purpose of such relief is two-fold. First, NEPA was intended not only to prevent harm to the environment, but to ensure that agency decision-makers fully explore the consequences of their actions. Consequently, " courts will not hesitate to stop projects that are in the process of affecting the environment when the agency is in illegal ignorance of the consequences, as when it should have prepared an EIS but-failed-to do so." .I_d. '(enphasis in original). Second, injunctive relief i_ against non ponpliance with NEPA preserves the' agency's freedom to choose ' alternative,.less environmentally damaging methods of proceeding in the future. State of Alaska v. Andrus, 580 F.2d 465, 485 (D.C.Cir.1978). ' E The court held in Watt that plaintiffs were entitled to a preliminary ~ injunction against a planned lease sale of offshore oil tracts because the Department of the. Interior had failed to prepare a supplement to its EIS reflecting its revised estimates of oil likely to be found on the tracts. Plaintiffs would have suffered [ continued] 8- -?W"'" T' T'+f 'h"

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a chain of comitment "that will become progressively harder to undo the longer it continues." Id. Third, if low power operations are allowed to comence, Joint Intervenors will in effect be deprived of any right to appeal because the proposed low power test program will be completed before appellate review can be obtained. Irreparable harm of this sort - the loss of a right to judicial review before the activity in dispute has been cmpleted - has been recognized by numerous courts in granting a stay.E Fourth, once fuel has been loaded into the reactor, the time and associated costs to remove it at sme future time should circumstances warrant will, as a practical matter, prejudice the NRC's consideration of those circumstances by " tipping the scales" away frm removal of. the fuel. Thus, the Joint Intervenors' rights will be irreparably harmed'due to the economic considerations involved with loading of fuel. C. The Granting of a Stay Will Not Harm PGandE The grant of a stay will postpone fuel loading and low power testing of Diablo Canyon only until administrative review of pending appeals has been cmpleted, resulting in minimal harm to PGandE. Iow power testing is beneficial to PGandE c'.ly as a step toward full powr operation. However, full power operation of Diablo i Canyon cannot realistically be expected before March-June 1984, even assuming that PGandE will prevail on all issues pending before the Ccmission or its adjudicatory 1 ( [ footnote 16 cont'd] irreparable harm once the Department was committed to the lease, since the oil ccm-I panies, the Department, and the state agencies would have begun to plan developrent of the tracts, making it more difficult to reverse the decision later. Here, simi-larly, the granting even of a license to load fuel will camit PGandE to a course of action whictl will lessen the chances that the environmental consequences of Diablo Canyon's operation at full power will ever be fully examined. E See, e.g., Public Utilities Commission v. Capital Transit Co., 214 F.2d 242, 245 (D.C.Cir. 1954); Isbrandtsen Co. v. United States, 211 F.2d 51, 55 (D.C.Cir.), cert. denied, 347 U.S. 990 (1954); Zenith Radio Corp. v. United States, 505 F.Supp. 216 (Int. Trade 1980); National Wildlife Federation v. Andrus, 440 (: F.Supp.1245 (D.D.C.1977); Perez v. Wainwright, 440 F.Supp.1037 (S.D.Fl.1977), rev'd on other grounds, 594 F.2d 159 (5th Cir.1979), vacated, 447 U.S. 932 (1980). l.r

boards. Accordingly, a postponement of low power operation until the pending matters are resolved will still permit PGandE to conduct its testing program without the need to delay full power ~ operation. = D. The Public Interest Favors a Stay The public interest would be best served by granting a stay in order to assure that operation of the plant will be safe and will cmply with all applicable regulations. Holding safety hearings after the plant has already been licensed and contaminated by radioactive material makes a mockery of the regulatory process, and undermines public confidence in the agency's willingness to place the public health and safety ahead of the econmic interests of those whm the agency is charged to oversee. -IV. CONCLUSION For the reasons stated above, Joint Intervenors hereby request this Appeal Board to stay the effectiveness of the decisions cited herein. DATED:. October 31, 1983 Respectfully subnitted, JOEL R. REYNOLDS, ESQ. JOHN R. PHILLIPS, ESQ. ERIC R. HAVIAN, ESQ. i Center for Law in the Public Interest 10951 W. Pico Boulevard i Ios Angeles, CA 90064 1 (213)470 3000 x DAVID S. FLEISCHAKER, ESQ. P. O. Box 1178 Oklahma City, OK 73101 By Ll MONb[d( r / COEg R. REYNOLOS f Attorneys for Joint Intervenors l 4 SAN LUIS OBISPO MDIHERS FOR PEACE SCENIC SHORELINE PRESE MATION CONFERENCE, INC. ECOILGY ACTION CLUB SANDRA SILVER ELIZABETH APFETRFRG JOHN J. IVRSTER i .._,m.,.,. __.. - -..

EXHIBIT l' i dNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE APPEAL BOARD ) LIn The Matter Of ) ) PACIFIC GAS AND ELECTRIC COMPANY) Docket Nos. 50-275 0.L. ) 50-323 0.L. (Diablo Canyon Nuclear Power ) Plant, Units Nos. 1 and 2) ) ) AFFIDAVIT OF RICHARD B. HUBBARD-RICHARD B. HUBBARD, being duly sworn, deposes and says e ( as follows: 1,. The purpose of this affidavit is threefold. First, to j . estimate the elapsed time which is likely to be required af ter issuance of a low power operating Sicense to load fuel and to j complete the special low power tests at or below 5% of Rated Thermal Power as Pacific Gas and Electric Company has proposed for the Diablo Canyon Unit 1; second, to describe the substantial - fission product' inventory that would be created in less than one month of 5 percent power operation; and third, to identify the technical difficulties and increased costs associated with l i modifyini 'the structures, systems, and components of the plant should further modifications be required after fuel has been k loaded and operation commenced. A recent statement of my profes-sional qualifications and experience is attached hereto as Appendix A. l t l-

,5 2. In preparing this affidavit, I have reviewed PG6E's C.. proposed. special. low power test program as set forth in the low power license application and as further described in PG6E's safety analysis report provided to the NRC Staff on c February 6, 1981. I also attended, as a consultant to Governor Brown's counsel, all sessions of the recent low power test pro-ceedings which were held in San Luis Obispo from May 19 to May 22, 1981. Thus, I am familiar with the duration of the low power tests as postulated by PGGE and Staff witnesses.

Further, I have reviewed the actual schedule for fuel loading, initial criticality and zero power testing, and low power testing of large pressurized water reactors (PWR's) which have occurred in the pos t-TMI period, particularly North Anna-2, Salem-2, and Sequoyah-1. ~ In addition, on July 10, 1981, I accompanied NRC Commissioner Gilinsky on his tour of the Diablo Canyon facility.

The results of my review are summarized in the following t paragraphs. A. INITIAL CRITICALITY AND DURATION OF LOW POWER h, TEST PROGRAM 3. During Commissioner Gilinsky's tour of the Diablo Canyon facility, both NRC and PG6E personnel emphasized PGSE's readi-ness to load fuel. The necessary fuel is presently on site in i a building immediately adjacent to the Centainment Building. Il Furthei,' due to the duration of the licensing process, PG6E l has had sufficient time to conduct, and in some cases reconduct,

'~its pre-operational tests as set forth in Section 14.1 of the '~ Final Safety Analysis Report (VFSAR"). Thus, I conclude that Diablo Canyon Unit 1 equipment is in an advanced state of readi- - ness to. load fuel, and that virtually all preliminary testing - such' as that described in the FSAR Table 14.1-1 possible prior

• I to fuel loading has been completed.

Further, I conclude that PB6E should be able to promptly load. fuel once such authoriza-tion is received from the NRC. 4. I estimate. that the fuel loading task should be com-pleted in.less than-one week elapsed time. For example, at Salem-2, a Westinghouse-designed-PWR similar in design and rating to'Diablo Canyon, fuel loading began on May 23, 1980 and was com-l pleted on'May.27, 1980. Following fuel loading, the Precritical ~ Test Program of eleven tests, as. set forth by PG6E. in Table 14.1-2 l-of the Diablo Canyon FSAR,should require no more than two i weeks to complete. Thus, there is no technical reason that - initial criticality could not be achieved within two weeks after fuel loading is completed. Therefore, I conclude that it is reasonable to expect that the fuel loading and precritical tes t program could be completed in no more than 30 days after the - - issuance of it low power test license. The reactor could be made l critical immediately thereafter. -s

• / A recent Nucleonics Week article indicated that all step's

~ prior <to fuel load will be completed by approximately Augus t 12, 1981 (p. 4, July 2 3, 1981). In general, all pre-operational testing will be completed before fuel loading ~ (FSAR, p. 14.1-8). [ 3-p. m-erwm y ,--i.,wo-,w---.- y,,.3, --,q,--.e,- --,.,,,.>.r- ,-e,w.- ,3 g-ww. w-. -, .v--=.. w,>-,+~,.- --e-- -v,

I 5. The next phase of startup and testing includes ini-( tial criti.cality (i.e., commencement of the nuclear reaction) and testing (of the reactor at power levels up to 5 percent of rated capacity). FSAR Table 14.1-2 summarizes the normal tests which will be performed. In addition, the ' scope and duration of the special low power tests were described in 1 detail during the recent low power proceedings in San Luis Obispo. The-Licensing Board, in the Partial Initial Decision dated July 17, 1981, noted at page 24, paragraph 61, that PG6E . has proposed a series of..eight special low power tests. The proposed tests would probably last for no 'more than one month and in actuality, as cited by the Board, would perhaps only take about eighteen days (Tr. 10,826-10,728). Other references to the "relatively few days" encompassed by the proposed low power test program are set forth in the recent decision by the i Board at page. 25 (paragraph 65), page 32 (paragraph 82), and page 33 (paragraph 83). Therefore, I believe that it is l reasonable to expect that, absent major problems or absent dis-b- cretionary delay by PGSE (for instance, to conduct some other t tests), initial criticality can be achieved and low power testing l l can be conducted in an. elapsed. time of less than 30 days.

Thus, i

assuming a 30-day period for fuel loading and precritical testing, t the entire fuel load and testing program can readily be completed p' l in no more than 60 days. (. 4-l -,.__,..,.,-.y --.--7..,,,,..,_-,-...s.,

6._ The reasonablenes.s of a 60-day cycle from licensa issuance to completion of the special low power tests was fur-ther confirmed during Commissioner Gilinsky's tour of the Diablo Canyon facility. In response to a question, the Diablo Canyon Plant Manager, Robert C. Thornberry,. stated in my presence that PGGE's current schedules forecast that fuel loading, zero power testing, and the special-low power test rogram will be completed approximately 58 days after receipt of a low power license. Mr. Thornberry added that the schedule might need to be increased if major unanticipated problems were encountered during the test program. 7.. In order to be conservative, I believe it may be appro-priate to add 15 to 30 days to the fuel loading and low power testing schedule to allow time for resolution of any routine unanticipated events. Thus, at the outside, I would expect the entire low power program at Diablo Canyon to take no more than 90 days. I understand that the NRC Staff recently indicated that the entire program would be completed in 101 days, which I feel is consistent with the schedule set forth here~in. I/ EA 8. The post-TMI experience and the current schedules for startup testing lend further support to the preceding conclu-sions. The first plant granted an operating license in the post-TMS period was Sequoyah-1, which received a low power -s

• / See Abtachment to Transcript of NRC Commissioner Briefing of August 27, 1981.

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. license on February 29, 1980. Fuel loading commenced on March-2,1980 and was completed on March 8,1980. Two major problems thereafter seriously delayed the initial criticality of Sequo-yah-1. First, in. response to ISE Bulletin 79-14, TVA required approximately 60 days to inspect and rework pipe hangers and s upports. Seco'nd, in parallel with the hanger ~ reinspection, TVA conducted a base line inspection of the turbine blades. The turbine : reinspection required 4-5 weeks of elapsed time. Routine maintenance problems and pre-operational testing resulted. in further delays. Initial criticality was achieved on July 5, 1980. Following zero power tes ting, the special low power testing program began on July 12 and was completed on July 18, 1980. 9. The second plant to receive a post-TMI license to load fuel and conduct special low power tests was North. Anna-2. The f l authorization to load fuel was issued on April 11, 1980 and the low power testing was completed by July 1,1980, an elapsed time of less than 80 days. c. .10. The Salem-2 low power licen'se was issued on April 18, Th. 1980. As set forth in paragraph 4,. fuel loading was completed g l on May 27, 1980. Initial criticality was achieved on August 2, 1980. The two months delay between fuel loading and initial criti,calgty was largely due to the need to conduct routine pre-p operati'ona1 maintenance testing and surveillance testing (such l. ,.e,. . - ~, .-_.~.,..,,%- ., -. - _ _,,. _ _, -. - -, _ - +, _,,., -, - -, -. ...m.,-

c.- as valve operability) which could have been accomplished prior .( to fuel load. As presented in paragraph 3, I believe that these pre-operational tests will be accomplished at Diablo Canyon prior to fuel loading. Thus, I conclude that the actual duration of the Salem-2, North Anna-2, and Sequoyah-1 fuel loading and low power testing programs is not inconsistent with my conclusions for Diablo Canyon as set forth herein. B. FISSION PRODUCT HAZARD

11. There.is sufficient evidence in the record of the recent low ~ power test proceeding to show that the consequences of a severe accidental release during low power operation would be serious.

The basis for my views are as follows: First, Tabic I of the testimony of Applicant's witness, Dr. Brunot, sets forth the fission product inventories which will be produced e I l in the core-during the proposed Diablo Canyon LPTP The inven- . tory of iodine-131, one of the radionuclides which is a signifi-cant contributor' to the dominant exposure modes for accidents requiring off-site emergency preparedness, is estimated by Dr. L 4,500,000 curies (approximately 1/20th the full power 95, L Brunot as l value as set forth in FS AR Table 11,.1-4). In contrast, for the design basis LOCA addressed by the Applicant in the FSAR, only, c L -192 curies of iodine-131 were postulated to be released to the . environment in the first two hours. The corresponding two-hour + thyroidfjosescitedintheFSARare as follows: I l 7-( a y-- +. -, - ,-,,e- ,,q w ---,s 4s~,,_ ,-,,-,7,,-,,...-,.,.-,-,.%.g...

-( Activity / Thyroid Doses (Rem)**/ Released

• 800 10,000 Nuclide (Curies)

(Meters) (Meters) I-131 27.0 7.3 0.3 I-131 ORG 73.4 19.9 0.8 I-131-PAR-91.8 24.9 1.0 TOTALS : ' 192.2 52.1 2.1 12. Furthermore,.in the Diablo Canyon Emergency Plan ***/ the Applicant has calculated that if the equivalent of 1000 i curies of iodine-131 were'to be released during a " Site Emergency"

• • /

class accident, and assuming the design basis meteorological conditions, then the thyroid dose at the plume centerline would be as follows: Activity - Thyroid Doses (Rem) Released 800 10,000 r Nuclide-(Curies) (Meters) (Meters) I-131-1000 270 12 The preceding relationships between releases and exposures are l all based on numbers in the record in the110w power proceeding. By observation, -it can be inferred that the thyroid doses can 9

• /

FSAR Table 15.5-12 (attached hereto as Appendix B). Y*/ F5AR Table 15.5-14 (attached hereto as Appendix C). UT*/ Emergency Plan, p. 5 (attached hereto as Appendix D). i TFF*/ The release potential and significance for a larger class of accidents, the " General Emergency," were not quantified by the Applicant in the Diablo Canyon Emergency Plan. f l. f' l (. - I .. -.. - _ - -.. _ -. _,. _ - -. ~.. _ _.,. -. - -.. _ - - _ _ _.

_c be scaled approximately linearly with fission product releases. This. relationship is not surprising in that Dr. Brunot stated in his testimony that estimated exposure is directly proportional to the core inventory which could contribute to that exposure.*/ 4 (We believe he must be assuming a constant release fraction). Brunot further estimated exposure levels by scaling exposures linearly based on the reduced fission product -inventories at LP as compared to -the FP operation. **/ Thus, using the Brunot scaling methodology, and assuming release fractions of 1.0 percent or 0.1 percent, the exposures for an. accident during the Diablo Canyon LPTP can reasonably be extrapolated.approximately as follows: L ' Activity Thyroid Doses (Rem) Released 800 10,000 l( Nuclide-(Curies) (Meters) (Meters) I-131' -4,500 (0.1%) 1,221 49 I-131 45,000 (1.~0%) 12,211 492 'In either of the preceding cases, the potential thyroid exposures appear to be of significant magnitude. Thus, the next ques tion i is whether the postulated release fractions are reasonable. vh. 13. The probabilities for nine major PWR release categor- [ ies- (PWR-1 to PWR-9) were developed in the NRC's Reactor Safety Study. (WASH-1400). ***/ The event sequences in PWR-1-7 lead to ' */ - 'Byl5not Tes timony, p. 11. e

• • /-

Brunot Testimony, p. 12.

• • • /

The dominant PWR accident sequences from WASH-1400 for each of the release categories. are set forth in Appendix ,( E which is attached hereto. _g_ - ~ ,___.-..m..,

l i l (( . partial or complete melting of the reactor core while those

in the last two categories do not involve melting of the core.

i These severe ac~cidents can' be distinguished from design basis L accidents in that they involve deterioration of the capability l - of the containment structure to perform its intended function "of limiting the release of radioactive materials to the environ - I ment. In release categories 1 to 3, the event sequences include l containment failure by steam explosion, hydrogen burning, or overpressure. In ' release categories 6 and 7, the dominant con-tainment failure mode is.by melt-through of the containment base mat. The other release categories contain event sequences in which the systems intended to isolate the containment fail to act properly. The uncertainties in the absolute values of the (. l probabilities are significant. The error band for the probabili-ties of some of the event sequences could be as great as a factor of 100 as discussed by Staff witness Lauben in the low power pro-ceeding. The containment releases postulated in WASH-1400 are described in more detail in Appendix F which is attached hereto. It is important to note that the magnitudes (curies) of radio-l , active releases for each PWR category are obtained by multiply-ing the release fractions shown in Table VI 2-1 of Appendix F by the amounts of radionuclides that would be present in the t I core at the time of the hypothetical accident (for Diablo l C. Canyon LP; inventory, see Table I of Brunot testimony). For 1 (: l l l l l

( . example, if one started with the iodine-131 inventory of 4.500,000 curies calculated by Brunot and the release fractions set forth by ' the WASH-1400 authors, the magnitude of the iodine releases for each of the-nine PWR accidents, if it occurred during the proposed Diablo Canyon LPTP, would be ds follows: PWR Activity Rele ase Release Rele ased Category Fractions (Curies) 1 0.70 3,150,000 2 0.70 3,150,000 3 0.20 900,000 4 0.09 405,000 5 ^ 0.03 135,000 6 8x10-4 3,600 '7 2x10-5 go 8 1x10-4 450 9 1x10-7 0.45 ( 14. Several conclusions are obvious. First, the 1.0% release fraction postulated herein is exceeded by a.. factor of l 3 to 70. for WASH-1400 release Categories 1 through 5. The 0.1% 1 release is consistent with a Category 6 release occurring during LP operation. Thus, I conclude that the proposed 1.0% and 0.1% release fractions are conservative representations of the poten-Nk. tial releases.*/ Therefore, because.of the relatively rapid buildup (half-life of hours to days) of the radioactive isotopes l l

• /

Indeed, the NRC indicated recently that the possession of as L little as 3.3 curies of I-131 constitutes a sufficient amount to be9 "of potential significant conceEn'in the event of a major accident....."~46 Federal Register 29714 (June 3, 1981). The I-131 ' inventory af ter. one month of low power operation of Diablo Canyon will be 4.5 million curies, or more than one million times greater than the NRC's recently stated thres- -hold. level of concern. ~ I r=- ---e- +,e,--e rw - we ---w-

---

*-rw--

--s m w-e ~n-"* x-v's--~-- --*--www-V

---

s

<--e--w -av w w > - - - ~

f . = listed in _ Table 3 olNUREG-0654*/ which dominate prompt health consequences' resulting 'from pos tulated accidental releases, I Econclude that even at St power after less than 30 days the fis-sionLproducts available for release pose 'a significant potential hazard. C. PLANT CONTAMINATION 1

15. Operation at low power will not only cause a buildup of fission products within the reactor core, making it inaccessi-ble for contact repair and/or modification, but will also cause a spread of radioactive contaminants throughout the primary portion of the steam supply system.

It will also contaminate certain i - auxiliary systems such_ as the Chemical and Volume Control System, Equipment smd Floor Drainage Systems, and the Liquid Radioactive C t Waste System. If fuel failures and/or steam generator tube fail-ures oor leaks.are experienced, a large number of other systems, {. including the turbine, condensate, and other components within the Steam and Power. Conversion System could become contaminated. Contamination and irradiation of such equipment greatly increases the care required and the time and cost of future modifications 4 } that could be required at Diablo Canyon. I conclude, therefore, that it is important that power operation, including low power testing, not be permitted until reviews and evaluations that could lgad to required plant modifications have been completed. l' 6

• / NUREG-0654, Rev.1 (FEMA-REP-1), Criteria for Preparation and and Evaluation of Radiological Emergency Response Plans and

~ Preparedness in Support of Nuclear Power Plants, Novemoer, -{~ 1980. 12-e -*,-,+w g wws.-+g--se-me y-e-rmw*- -m--in-p.www--,-c,-wrret-y+--*-w ews

cwy, e,

y i-g-w. + +--g--=w ei- ---r--p---+my--p----e ssm +e w.-e e=-e y ,1%-ww--y,vgim+mw,---www

~.1 D. CONCLUSION

16. Based on the foregoing, I conclude: (a) that fuel loading, initial criticality, and low power testing, including

-the special low power tests,. can be accomplished at Diablo Canyon Unit I within approximately-60 days, with ; an outside maximum elapsed time of approximately 90 days, after issuance of the low power -operating license; (b) that it is feasible for fuel loading to be completed within one week a'fter issuance of the low power license; and (c) that the fuel loading and pre-critical testing portion.of the startup schedule should be com-pleted within less than 30 days following issuance of the low power license.and that immediately thereafter initial criticality could be achieved. Further, I conclude that because of the relatively rapid buildup of the radioactive isotopes which dominate health consequences, even at 5% power the.. fission products such as iodine-131-available for release pose a signifi-cant hazard. Finally, I conclude that operation at low power will contaminate some of the facility's components and systems. This unnecessary commitment of resources creates technical diffi-

• /t.

culties and increased costs associated with modi.fying the reactor, should further modification be required after fue1~ has been loaded and power operation commenced. t II . f ** ..J:8 (_ 1 13- ,y---. .. - - - -. -, +,. ,..-,4 ..gew-,, w. _.,..y. g ...,y i._,,,%. ,,,.,4wm,-.--,..%_.w,.,v, ..,,..,,-,ww..ew.., ,___-,m-~.

s ~ i;,.. t.h% 3\\ 5;: s I have read the foregoing and swear that it is true and 'securate to the best of my knowledge. 1 %7 'O, g h i RICHARD. B. HUBBARD '.k i i Subscribed and sworn to before me this f day of September, T 1981. $_w =+= : -= ' NOTARY M BLIC ~ - ' ~ ( L'%' "h OFFICIAL SEAL JAMES F LEHMAN l,

NOTARY PUBLiC CAUFCR.N!A. t i'J SANTA CLAM '0UN1Y

\\ Commission expires E/ Af c:=m. ex6* s AUG 21,1954. f s. ,,,. e m.-.-- w % i 'IA, T Y c'l l , (.., ,s k I,i s 14- ,.g. .k ,y y w. g-r-a..---- m -,- - - -.- -n-,, ,,,,_,,w-, ,-,-4y, s pq

f-APPENDIX A i PROFESSIONAL QUALIFICATIONS OF RICH ARD B. HUBBARD RICHARD B.. H U3B A RD MHB Technical Associates 1723 Hamilton Avenue - Suite K Son Jose, California 95125 (408) 266-2716 EXPERIENCE: 9/76 - PRESENT Vice-PreJident - MHB Technical-Associates, San Jose, California. Founder, and Vice-President of technical consulting firm. Special-is ts in independent energy. assessments for government agencies, particularly technical and economic evaluation of nuclear power facilities. Consultant in this capacity to Oklahoma and Illinois Attorney Generals, Minnesota Pollution Control Agency, German Ministry for Research and Technology, Governor of Colorado, Swedish Energy Commission, Swedish Nuclear Inspectorate, and the U.S. Department of Energy. Also provided studies and tes timony for ( various public interes t groups including the Cer:er for Law in the Public Interes t, Los. Angeles; Public Law Utility Group, Baton Rouge,. Louisiana; Friends of the Earth (F0E), Italy; and i the Union of Concerned Scientis ts, Cambridge, Massachusetts. Provided testimony to the U.S. Senate / House Joint Committee on Atomic' Energy, the U.S. House Committee on Interior and Insular Affairs, the Califor.ia Assembly, Land Use, and Energy Committee, the Advisory Committee on Reactor Safeguards, and the Atomic S af ety ' and Licensing Board. Performed comprehensive risk analysis of the -accident probabilities and consequences at the Barseback Nuclear Plant for the Swedish Energy Commission and edited, as well as f, - contributed to, the Union of Concerned' S cientis t's technical review of the NRC's Reactor S af ety S tudy (WASH-1400). 2/76 - 9/76 l Consultant, Project Survival, Palo Alto, California. Volunteer work on Nuclear Safeguards Initiative campaigns in Cali-fornia, Ogegon, Washington, Arizona, and Colorado. Numerous presentations on nuclear power and alternative energy options to civic, g'o v,e rnm e n t, and college groups. Also resource person for public service presentations on radio and television. A-1 y w on- --e e- .,,-g me-a-~~ %e - --n-n-am-,,e,ww---,---o---s,w -e~w,--,,,,,,,,--,--w,---y-v e-e-e--n-m--g -ee-o,,,,,-,-w----,.

1 5/75 - 1/76 Manager - Quality Assurance Section. Nuclear Energy Control and 1 instrumentation Department, General Electric Company, San Jose, l 1 California. Report to the Department General Manager.- Develop and implement ' quality plans, programs, methods, and equipment which assure that products produced by the Department meet quality requirements as defined ~ in NRC regulation 10 CFR 50, Appendix B., ASME B oiler and Pressure %ssel Code, customer contracts, and GE' Corporate policies and procedures.. Product areas include radiation sensors, reactor vessel internals, fuel handling and servicing tools, nuclear plant control' and pro tection ins trumentation sys tems, and nuclear steam ' supply and Balance of Plant control room panels. Responsible for approximately 45 exempt personnel, 22 non-exempt personnel, and 129 hourly personnel with an expense budget of nearly 4 million dollars and equipment investment budget of approximately 1.2 million-dollars. 111/71 - 5/75 Manager - Quality Assurance Subsection, Manufacturing Section of . Atomic Power Equipment Department, General Electric Company, San Jose.-California. Report to-the Manager of. Manufacturing. Same functional and f product responsibilities as in Engagement #1, except at a lower ( organizational report level. Developed a quality system which received.NRC certification in 1975. The system was also success-fully' surveyed f or ASME "N" and "NPT" symbol authorization in 19 7 2 and 1975, plus ASME "U" and "S" symbol authorizations in 1975. Responsible for-from 23 to 39 exempt personnel, 7 to 14 non-exempt personnel, and 53'to 97 hourly personnel. 3/70 - 11/71 Manager - Application Engineering Subsection, Nuclear Instrumen-tation Department, General Electric Company, San Jose, California. Responsible for the post order technical interface with architect engineers-and power plant owners to define and schedule the ins tru-mentation and control systems f or the Nuclear S team Supply and Balance of Plant portion of nuclear power generating stations. Responsibilities included preparation of the plant instrument list with approximate location, review of interface drawings to define functional design requirements, and release of functional require-i ments-fo$ detailed equipment designs. Personnel supervised includad',17 enginee rs and 5 non-exemp t personnel. A i O . _ _, _., -,... -. - - - - - - -., - -.. _ - -.. ~. ~ ~. - - - .-m--_..__,

12/69 - 3/70 C Chairman - Equipment Room Task Force, Nuclear Ins trumen tation Department, General Electric Company, San Jose, California. Responsible for a special task force reporting to the Department i General Manager.co define methods to improve the quality and reduce the ins talla tion time and cos t of nuclear power plant control rooms. S tudy resulted in the conception of a factory-fsbricated control room consisting of signal conditioning and operator centrol panels mounted on modular floor eactions which are completely assembled in the factory and thoro'ughly tes ted for proper operation of interacting devices. Personnel supervised 1 included 10 exempt personnel. l 12/65.- 12/69 Manager - Proposal Engineering Subsection, Nuclear Ins trumentation i Department, General-Electric Company, San Jose, California. Responsible-for the application of instrumentation systems for nuclear power reactors during the proposal and pre-order period. Responsible for technical review of bid specifications, preparation l of technical. bid clarifications and exceptions, definition of i i material list for cost estimating, and the "as sold" review of contracts prior to turnover to Application Engineering. Personnel supervised varied from 2 to 9 engineers. a /64 -'12/65 Sales Engineer, Nuclear Electronics Business Section of Atomi"c l Power Equipment Department, General Electric' Company, San Jose, California. Responsible for the bid review, contract negotiation, and sale of ins trumentation sys tems and components for nuclear power plants, L test reactors, and radiation hot calls. Also responsible for industrial sales of radiation sensing systems for measurement ~ of chemical properties, level, and density. '10/61 - 8/64 Application Engineer, Low Voltage Switchgear Department, General i Electric Company, Philadelphia, Pennsylvania. Responsible for the application and. design of advanced diode and silicon-controlled rectifier constant voltage DC power systems and variable,; voltage DC power'aystems for indus trial applications. Designegf-f ollowed manuf acturing and personally tested an advanced SCR pow,er supply for product introduction at the Iron and S teel Show'. j P ro j e c't Engineer for a DC power system for an aluminum pot line sold to. Anaconda beginning at the 161KV switchyard and encompassing all the equipment to convert the power to 700 volts DC at 160,000 amperes.

a A-3 L

l

9/60 - 10/61 f CE Rotational Training Program Four 3-month assignments on the CE Rotational Training Program for college technical graduates as follows: a. Installation and Service Eng. - Detroit, Michigan. Installation and startup testing of the world's largest automated hot strip steel mill... b. Tester - Industry Control - Roanoke, Virginia. Factory testing of control panels for control of steel, paper, pulp, and utility mills and power plants. c. Engineer . Light Military Electronics - Johnson City, New York. Design of ground support equipment for testing the auto pilo ts on the F-105. d. Sales Engineer - Morrison, Illinois. S ale of appliance controls including range timers and refrigerator cold controls. iDUCATION: Bachelor of S cience Electrical Engineering, University of Arizona, 1960. Mas ter of Business Administration, University of Santa Clara, 1969. 1 PROFESSIONAL AFFILIATION: 'ik, Regis tered Quality Engineer, License No QU805, S tate of California. Member of Subcommittee 8 of the Nudlear Power Engineering Committee i of the IEEE Power Engineering Society responsible for the prepara-tion and revision of the following 3 national Q. A. Standards: l a. IEEE 498 (ANSI N 4 5. 2.16) : Requirements for the Calibration and Control of Measuring And Tes t

,1f Equipment used in the Construction and Maintenance of

1. '. Nuclear Power Generating S tations.

L l -4 L

-PROFESSIONAL AFFILI ATION: ( Con td) b. IEEE 336 (ANSI N45.2.4): Installation, Inspection, C* and Testing Requirements for Class lE Instrumentation and Electric Equipment at Nuclear Power Generating S tations. c. IEEE 467

Quality Assurance Prog' ram Requirements for the Design and Manufacture of Class IE Instr.umentation and lectric Equipment for Nuclear Power Generating Stations.

I am currently a member of the IEEE'Ad Hoc Ccamittee which recommended the issues to be addressed in the development of a standard relating to the selection and utilization of replace-ment parts for Class'IE equipment during the construction and operation phase. I am also a member of the work group which will. prepare this proposed s tandard. PE RS ON AL DATA: Birth Date: 7/08/37 Married; three children Health: Excellent PUBLICATIONS AND TESTIMONY: L 1. In-Core System Provides Continuous Flux Map of Reactor Cores, R.B. Hubbard and C.E. Foreman, Power, November, 1967. 2. Quality Assurance: Providing It, Proving It, R.B. Hubbard, Power, May, 1972. 3. Tes timony o f R.B. Hubbard, D.C. B ridenbaugh, and G.C. Minor before the United S ta'tes Congress, Joint Committee on Atomic ^ . Energy, February 18, 1976, Washington, DC. (Published by the Union of Concerned S cientis ts, Cambridge, Massachusetts.) '. Excerpts from testimony published in Quote Without Comment, Chemtech, May, 1976. \\ 4 Tes timony of R.B. Hubbard, D.G. B ridenbaugh, and G. C., Mino r I to the California S tate Assembly C'ommittee on Resources, Land Use, and Energy, Sacramento, California, March 8, 1976. 5. Testimony of R. B. Hubbard and G.C. Minor before California S tage Senate Committee on Public Utilities, Transit, and Energy, Sactamento, California, March 23, 1976. c 6. Tes timony or R.B. Hubbard and G.C. Minor, Jddicial Hearings Regarding Grafenrheinfeld Nuclear Plant, March 16 & 17, 1977, Wurzburg, Germany. L A-5 -n- -,,-.-,,,,,.~,--e y --.--,,7.-,.,,---....-..,----rmv - - -,, - +, - - = ~ - - + y v --r~ ,w - +- e

e PUBLICATIONS AND TESTIMONY: ( Con td) -f .7. Testimony of R.B. Hubbard to United States House of \\' Representatives, Subcommittee on Energy and the Environ-ment, June 30,-1977, Washington, DC, entitled, Effectiveness of NRC Regulations - Modifica tions to Diablo Canyon Nuclear Units. 8. Testimony of R.B. Hubbard to the Advisory Committee on Reactor - Safeguards,. August 12, 1977, Washington, DC, entitled, Risk , Uncertainty Due to Deficiencies in Diablo Canyon Quality Assurance Program and Failure to Implement Current NRC Practices. 9. The Risks of Nuclear Power Reactors: A Review of the NRC Reactor Safety Study WASH-1400, Kendall, et al. edited by R.B. Hubbard and G.C. Minor for the Union of Concerned Scientis ts, August,.1977. 10. Swedish Reactor Saf ety Study: Bars ebHek Kis k Ass essment, MHB Technical Associates, January 1978 (Published by Swedish Depart-ment of Industry as Document DSI 1978:1). 11. Testimony of R.B. Hubbard before the Energy Facility Siting Council, March 31, 1978, in the matter of Pebble Springs Nuclear Power Plant, Risk Assessment: Pebble Springs Nuclear Plant, Portland, Oregon. (L 12. Presentation by R.B. Hubbard bef ore.the Federal. Minis try f or Research and.'Tachnology (BMFT), August 31 and September 1.-

1978, Meeting'on Reactor Safety Research, Risk Analysis, Bonn, Germany.

l-13. -.Tes timony by R.B. Hubbard, D.G. Bridenbaugh, and G.C. Minor ~ before the Atomic Safety and Licensing Board, September 25, 1978, in the matter of _the Black Fox Nuclear Power S tation Cons truction l Permit hearings, Tulsa, Oklahoma. 14 Tes timony of R.B.- Hubb'ard before the Atomic Safety and Licensing Board, November 17, 1978, in the matter of Diablo Canyon Nuclehr Power Plant Operating License Hearings, Operating Basis Earth quake-and Seismic Reanalysis of Structures, Systems, and Com-ponents, Avila Beach, California. 15. Testimony of R.B. Hubbard and D.G. B ridenbaugh bef ore the Louisiana Public Service Commission, November 19, 1978, Nuclear l Plant ~ and Power Generation Costs, Baton Rouge, Louisiana. 16. Tesgimony of R.B. Hubbard before the California Legislature, L Subcommittee on Energy, Los Angeles, April 12, 1979. c A-6 .--h,,,--,.-,.,,y- ,,.p, ,,,,,.4,-,,.,,,,,,.+,,,,,,,,,,,,,-.,,-,..,y,-.r-,,,,,,- ,y-7 ....4,---.y.,.,,,.,y.-,y,,,- ,,,y r w -- -v7-wm----siw-s,- m-----e~Tw~v-

PUBLICATIONS AND TESTIMONY: (Contd) 17. Testimony of R.B.'Hubbard and G.C. Minor before the Federal ' Trade Commission, on behalf of the Union of Concerned ~ - S cientis ts, Standards and Certification Proposed Rule 16 CFR Part 457, May 18, 1979. 18. ALO-62, Improving the Safety of LWR Power Plants, MHB Technical Associates, prepared for U.S. Department of, Energy, Sandia National Laboratories, September, 1979, avai~1able from NTIS. 19.. Tes timony by R.B. Hubbard before the Arizona State Legislature, Special Interim House Committee on Atomic Energy, Overview o f Nuclear Safety, Phoenix, AZ, September 20, 1979. 20. "The Role of the Technical Consultant," Practising Law Insti-tute program on " Nuclear Litigation," New York City and Chicago, November, 1979..Available from PLI, New York City. 21. Uncertainty in Nuclear Risk Assessment Methodology, MHB Technical Associates, January,.1980, prepared for and available from the Swedish Nuclear Power Inspectorate, Stockholm, Sweden. 22. Italian Reactor Safety Study: Caorso Risk Assessment, MHB Technical Associates, March, 1980, prepared for and available from Friends of the Earth, Rome, Italy. 23. Development of Study Plans: Safety Assessment of Monticello and Prairie Island Nuclear S tations, MHB Technical Associates, ll August, 1980, prepared for and available from t'he Minnesota i Pollution Control - Agency. 24. Affidavit of Richard B. Hubbard and Gregory C. Minor bef ore the Illinois Commerce Commission,.In the Matter of an Investi-gation of the Plant Construction Program of the Commonwealth Edis on Company, prepared for the League of Woman Voters of Rockford, Illinois, November 12, 1980, ICC Cas e No. 78-0646. '.[? 25. Systems Interaction and Single Failure Criterion, MHB Tech- ~nical Associates, January 1981' pre from the Swedish Nuclear hower inspeSared for ands tock$ol11able to ra t e, m, Sweden. ,it g, '. " l l i i l A-7 - -. ~..

~. -. f O .o ~ TABLE 15.5-12 CALCULATED ACTIVITY RELEASES FROM LOCA-DESIGN BASIS CASE (CURIES) a NUCLIDE -2 Hrs 2-8 Hrs 8-24 Hrs 24-96 Hrs 4-30 Days i i m 1-131 0.2703t 02 0.0 C.O 0.0 0.0 E' l 1-132 c.3ctSE O2 0.0 0.0 0.0 0.0 l 1-133 0.t?O7L 0? 0.0 0.0 0.0 0.0 n j I-134 0.7tet3t 02 C.O O.0 0.0 0.0 .I l 1-135 0.5712C OE O.0 0.0 0.0 0.0 y i 1-1310 F< G O.7340E O2 0.2170E G3 0.5561E 03 0.1070E C4-0.3227E 04 5 g 1-1320HC (,. E 2 2 5 E O2 0.676? E O2 0.186?E 0? O.'?40E-01 0.0! L7E-10 so m Y 1-133GRG O.le39I O2 0.431*E 03 0.007E E 03 0.5263F 03 0.5383E O2 1-1340RC 0.9P47F' 02 0.?4f.9 E G2 0.?O4 5E '00 0.? P11 f -06,0.76f SE-31 y 1-1350RG 0.1411[ 03 0.?P3Pr 03 0.26bPE 03 0.314BI O2 0.1834E-01 p 1-l'31 P A R 0.c17fE DE O.2713F 03 0.6951E 63 0.1'33BF 04 0.4033E 04 s 1-132 PAR O 1041F 03 0.1065E 03 0.2327E O2 0.1155E 00 0.1070E-09 o 1-13'3Utf ~' O.204Pt Of D.5392E 03 0.1010E 04 0.e 574F 03 0.6728E O2 1-134 PAR O.1231L 03 0.3066 0 02 0.?557E 00 0.3514F-06 0.3331E-31 m I-13 5 F' AR 0.17t>4E. 63 0.354PE 03 0.3335E 03 0.3435F 62 0.??93F.-01 i KR-P.3M O.92fiOf 63 0.74 E7E G3 0.8940E O2' O.1154E.00 O.2f78E-12 3 KR-t! 5 0.f;179E O2 0.1913E O'3 0.5097E 03 0.1145 F. 04 0.9P27F 04 j KR-FSM 0.2h230 04 0.4660E 04 0.2723E 04 0.1141E 03 0.1413E-02 iI KR-87 0.3F47E 04 0.10 f-4 r 04 0.7273 E 02 0.5752E-07 0.453GE-10 KR-BE 0.70c0E 04 0.8484L 04 0.2368E 04 0 22200 02 0.3333E-06 < l' Xs-13'3 0.1/44'F' 05 6.4442 4 05 0.1241 6 0.2205E 06 0.439?E 06 XE -133 M t;. a ?.' 0 F 0 - 0.1211 E 04 0.2819E 04 0.376tE 04 0.e55tE 04 XE-135

f. 7402E 64 C.1655F C6 'O.2028$ 65"O.4316E 04 0.1910E 02 l#

Ab-13bH 0.f',0(l 03 0.4137L 01 0.4690E-06 0.7061E-25 0.0 i XE-138 0.2d64L 04 0. 65.% E 01 0.1164E-06 0.125?f-27 0.0 e w -n

D D D a TABLE 15.5-14 THYROID DOSE '1WO HOUR - CONTAINMENT LEAKAGE - DESIGN BASIS CASE (REM) ~"" ^ us C15 T ANCF FROM P.E L.E A SE POIN1 0gn MICL10 0 P(OM I?OOM ?OOOM 4000P. 7000H 10000M 2OOGOM l 1-131 0.7342E D1 0.4~t15F 01 0.?LSSE 01 0.10800 01 0.44F3r 00 0.3053F 00 0.1 ??PE 00 ts I-13? D.'3913L '00 6.*'51 t E 00 0.13P3 E 00 0.17 E E L-01 O'.2656F-01 0.1677F-01 0.e547F-02 E ln 1-133 0.45thF. 01 0.20266 01 0.1611 t-01 0.6703E 00 0.3093F 00 0.1865E 00 O.76 25 E-01 $ E 0 1-134 0.3i4'1L'60'0.20030'00 6.1146E 00 0.4767E-01 0.22 00E-01 0.134F,F-01 0.54 22f-02 0 C 2 1-135 0.1300L (.1. (. E.3 '3 6 E 00 0.4566E 00 0.1C12E 00 0.0623E-01 0.5407F-01 0.?l7'r-01 m I-1.s10F.G 0. l oc4 L 02 0.11F2L 02 0.7049E 01 0.1933E 01 0.1353L 01 0.F202E 00 0.?3361 00 $ c, , I--13 2CR0 0. 0176 F 00 0.t? % f 60 0.2E50E' 00 0.1202E 00 0.554PF-01 0. 34 00E -01 0.136t.E-01 1 1-13 3O R(. 0.1203E O2 0.7734 0 01 0.c ? t.3E. 01 0.1770E 01 0.P166E 00 0.EOO4E 00 0.?013E 00 P ^ I-13 40F.G U.4 bl 9 E 00 6.2 604 5- 00 0.1t'<76 00 0.6646E-01 0.3067E-OI O.1578F-01 0.75eOE-07 .n 1-1350kC O.3211F C 1 0.2004F 01 0.113* F 01 0.4723'E 00 0.H79E 00 0.1336 E 00 0.5372 r-01 $ 1-131PAh b.24520 ( 2 (. I t ( 20 02 0.BF11 E 01 0.3666E 01 0.1692E 01 C.1037E 01 0.4170F 00 5 1-13?FAR 0.10??F 01 0.t5ttL 00 0.3613[ 00 0.1503E 00 0.6936L-01 0.4250E-01 0.1710E-01 i 1-133 PAR. 6.1504 t 02 0.oc t.7 L 01 0 5317 0 01 0.I212E 01 0.1021F 01 0.625SE 00 0.2bl6E 00 'f 1-134PAk ~ 0.E64FE 00 G.?630f 00 0.1%7F 06 0.6307E-01'O.3833f-01 0.7349E-01 0.c450E-02 1 1-135PAh 0.4014E 01 0.20 POL 01 0.141rfF G1 0.59046 00 0.27245- 00 0.1660E 00 0.67156-01 i t ...T.O. T A L 0.95c3F.02 C 61. c_6 E 0 2.. 0 3.3 01 f. 02 0 _1_411 E _0.. 2_0.. 6. 511E _01

• 0 3 64 0E 01 0.1605F 01 l n 4

APPENDIX D -(Sourco: Diablo Canyon Emergency Plan) 4.1.3 Site Emergency 4.1.3.1 Description The Site Emergency action level reflectsoconditions where there is a clear potential for significant releases, such releases are.likely, or they are_ occurring, but in all cases where a core meltdown situation is not indicated based on current information. Beca'use the possible release associated with a Site Emergency is significant, care must be taken in alerting offsite authori~ ties to distinguish whether the release is.merely potenti.al, likely, or actually occurring. Response of offsite authorities will be guided initially by.this determination. 4.1.3.2 Release Potential and Significance The Site Emergency class includes releases up to 1000 Ci of I-131 equivalent and/or up to 108 Ci of Xe-133 equivalent. Assuming design basis meteorological conditions, the maximum Site Emergency release would produce the following doses due to direct exposure to the plume centerline: DOWNUIND WHOLE BODY DOSE THYROID DOSE DISTANCE ASSUMED FROM Xe-133 FROM I-131 ( (m) (x/0)(sec/m ) (mrem) (rem) 3 800 (site 5.3 x 10-4 6000 270 boundary) 10000 2.2 x 10-s 250 12 . (edge of LPZ) 16000 1.2 x 10-5

• b.

140 7 (10 mile zone) As can be seen, such a release occurring with unfavorable . meteorological conditions would certainly require that protective measures be taken on the site and in the downwind sectors throughout the plume exposure Emergency Planning Zone. However, even in the case of a maximum release, it is likely that offsite doses would be much lower than those tabulated above due to such factors as more favorable meteorology and the effects of sheltering. The appropriate near term response for such an occurrence is to make an assessment of conditions'as they actually ( exist and take action based on this assessment, as L discussed below. 4-5 n.1

APPENDIX E (Source: WASH-1400, Main Report) TABl.E 5-2 PWR DOMINANT ACCIDENT SEQUENCES vs. RELE.ASE CATEGORIES act:4st emccase C.,. e as .. C.se aelt C. 1 2 3

• II
• I ato-a, I ao-a
• as-6
• as-r
• a-s a

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• ANF-4 AN.(
• 8

-80

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• I
• 8

& Preentlities asle ' is10

• 1s10 '

1s30

• M S Of*t S O-4 5 *$

5 $a *6ls10 ' A3s10-10 13s10-6 1

• I I3s10 *

$ D-e S CD-0 3 0.T -10 8 D-e A,gg-11 1,gg-0 I I3s10*II 6s!O g 3 4s10

• 8 S "**

S 0-8,, O t-t,, S s-t 8 C'** 11 8 1 1 late *1'O g :10+6 g ! ate-4 1 SMAL8. LaCA 3 4s10 2s10 l isle 8 8 F*4,, 3 ntet=10 3 W-T,gg S t e,gg 1 aste es10 1s10 este 3 3 3 g S C-4,, S C e,g, g g Isl0 3s10

• I
• I S Freeabilities 3:10
• 2 10
• 2s10 '

Is10

• 8:10
• 4sto 6:10
• 3:10 3:10
• g 8 '*"e-4 8

8 8 D-e,, 3 * -12 22att-4 2 -t I 6-7,, 8 8-e 2 3 2 2 3

• 10 tal 810 tale late Sale 1s10 8 "I*T-10 I "**

8 "*0 8 CD-C,, 8 I"* 2 J -0 2 -0 2 2 -6 2 -9 nate 2s10 es10 late Jane este '2"t al e** 9 I I* $ CD-e 8 * *10 2 .T 2 =10 2:4 10 1s10 5 SLO 2 8 C-e f2

• 6 2

-10 9:10 2:10 8 C-4,, ( S C-e,g 2 g :10 tale 2 5 s presea111:1ee 1:10 ' 3 10

• 310**

3s10 ' 3 10 ' 3:10

• 3s10
• g 8C-9 8C*T p.e set 3:10.g3 3:10 33 1a10,,

jale,, A8ACTCR vtsstl. 17 4 1 10*l8 sumas. : e l DC=4 ell tale a Prend111ttee ast0 1s10 g,gg 2:10 1:10 ' 1:10

• 1s10 '
• II

-10 et +10 suTEaracInc STSTEAs taca +6 l (CNSCE WaLVEB * % 410 4:10' 410

• W Praha4111ttes 4:10 '

TMLS* tI TMLa**y9 TML-e,g

• 10 TMLB'* 7 TML

1. h TML-8

• 6 l

g 3:10 Tale 6s10 2:30 este 6sto 1 trams!ENT TMLa * *4 TIQ-e TWO-S.10 TE9*C EVENT = T 2:30-6 3s50' 3:10 3s10

• TunQ-e,

Mt., 1:10* 1 ale

• I l

T Pretah111ttee late 3:10* 4x10 ' 1s10 ' as10* 2m10* Sal 0 l (!) stamATION OF AAA ACCIDENT $1QUENCES PER SK12ASE CaTECOBf l l On%,

9. ic'

.sie-I -5 -5 .sie + . sic' isie ' ..i0 * ..i0 .siO .sie *

• I 5

-5 (St va&MEl 9s10

• es10 6ste '

9s10

• 2s10*

aste

• 110 4, g,-4 4s10 UPPER Boute3
• I 4916 vaLUE3 9s10" este '

este Sale

• est0 '

2s10 2s10

• esto
• 4s10
• I lassee The paemeettitles for east release estetert for esen event tree and ee I for all accident seqwences are Os eedian values ei the ensinant seendent sequences emmed by neate Carte simetallen pies a 104 seat:13estem free IAe 44)sesat l

setesse category promet!11ty. KEY TO TABLE 5-2 ON FOLLOWING PAGE E-1

~ v.. .o KEY TO PWR ACCIDENT SEQUENCE SYMBOLS A - Intermediate to large LOCA. B - Failure of electric power to ESTs. B' - Failure to recover either onsite or offsite electric power within'about 1 to 3 hours following an initiating transient which is a loss of of fsite AC power. C - Failure of the containment spray injection system. D ~ Failure of"the emergency core cooling injection system. F - Failure of the containment spray recirculation system. G - Failure of'the containment heat removal system. H - Failure of the emergency core cooling recirculation system. K - Failure of the reactor protection system. L - Failure of the secondary system steam relief valves and the auxiliary feedwater system. M - Failure of the secondary system steam relief valves and the power conversion system. - Failure of the primary system safety relief valves to reclose after opening. (QR - Massive rupture of the reactor vcssel. S - A small 14CA with an equivalent diameter of about 2 to 6 inches. - A small 1 CA with an equivalent diameter of about 1/2 to 2 ' inches. 52 T - Transient event. V - LPIS check valve failure. a - Containment rupture due to a reactor vessel steam explosion. S - Containment failure resulting from inadequate isolation of containment openings and penatrationse y - Containment failure due to hydrogen burning. 6 - Containment failure due to overpressure. c - Containment vessel melt-through. b KEY 'IO TABLE 5-;. . E-2

l APPENDIX F (Source: WASH-1400, Appendix VI) Section 2 Releases from Containment 2.1 GENERAL REMARKS A large portion of the work of the Reactor Safety Study was expende'd in determ'ining the probability and magnitude of various-radioactive releases. This work is described in-detail ~in the preceding appendices as well as Appendices VII', and VIII.. In order to define the various releases that.might occur, a series of release categories were identified for the postulated types of containment failure in both BWRs and PW Rs. The probability of each release category and the associated magnitude of j radioactive releases (as fractions of the initial core radioactivity that might leak from the containment structure). are used as. input data to the consequence model. In addition to probability.and release magnitude, the parameters that characterize the various hypothetical accident sequences are time of. release, duration of release, warning time for evacuation, height of release, and energy content of the released plume. I The time of release refers to the time interval between the start of the hypothetical accident and the release of radioactive material from the containment building to the atmosphere; it is used to calculate the initial decay of radioactivity. The duration of release is the total time during which radioactive material is emitted into the atmospherer -it is used to account for continuous releases by adjusting for horizontal dispersion due to wind meander. These parameters, time and duration of release, represent the temporal behavior of the release in the dispersion model. (Theyareusedtomodela" puff"releasefromthecalculationsofreleaseversus time presented in Appendix V. The warning time for evacuation (see section 11.1.1) is the interval between awareness of impending core helt and the release of radioactive material from the l. containment building. Finally, the height of release and the energy content of the released plume gas affect the manner in which the plu' e would be dispersed in m j -the atmosphere. Table VI 2-1 lists the* leakage parameters that characterize the PWR and BWR release categories. It should be understood that these categories are composites of numerous event tree sequences with similar characteristics, as discussed in Appendix V. 7L .2.2 ACCIDENT DESCRIPTIONS To help the reader understand the postulated containment releases, this section presents brief descriptions of the various phys'ical processes that define each release category. For more detailed informatibn on the release categories and the techniques. employed to compute the radioactive releases to the atmosphere, the reader is referred to Appendices V, VII, and VIII. The dominant event tree sequences in each release category are discussed in detail in section 4.6 of Appendix V. PWR 1 'll This releasegcategory.can be-characterized by a core meltdown followed by a steam t explosion on contact of molten fuel with the residual water in the reactor vessel. 1The containment spray and heat removal systems are also assumed to have failed and, therefore, the containment could be at a pressure above ambient at the time of the steam explosion. It is assumed that the steam explosion would rupture the upper -portion of the reactor vessel and breach the containment barrier, with the result l [ that a substantial amount of radioactivity-might be released from the containment ( ~in a puff over a period of about 10 minutes. Due to the sweeping action of gases generated during containment-vessel meltenrough, tne release of radioactive materials would continue at a relatively low rate thereafter. The total release would contain 2-1 n.,

lb (oproximately 70% of the iodines and 40% of the alkali metals presen -the time of release.1 Because the containment.would contain hot pressurized aces :at the time of failure, a relatively high release rate of sensible energy frca the containment could be associated with this category. This category also includes certain potential accident sequences that would involve the occurrence of core. melting and a steam explosion af ter containment rupture due to overpressure. In these sequences; the rate of energy release would be lower, although still r31stively high. PWR 2 .This category is' associated with the failure of core-cooling sysheks 'aNd core . melting concurrent with the failure of containment spray and heat-removal. systems. .Foilure'of the containment barrier would occur through overpressure, causing a oubstantial fraction of the containment atmosphere to be released in a puff over * 'a period of about 30 minutes. Due to the sweeping action.of gases generated during czntainment vessel meltthrough, the release of radioactive material would continue et a relatively low rate thereafter. The total release would cont'in approximately~ .70% of the iodines and 50% of the alkali metals present in the core \\t the time of r31 ease. As in PWR. release category 1, the high temperature and pressure within c:ntainment at the time.of containment failure would result in a relanively high release rate of sensible energy from the containment. PWR 3 This category ' involves an overpressure failure of the containme t due to failure of crntainment heat. removal. Containment failure would occur prior to the commencement of core melting. Core melting then would cause radioactive materials to be released through. a ruptured containment barrier. Approximately 20% of the iodines and 20% of the elkali metals present in, the core at the time of release would be released to the j tmosphere. Most of the release would occur over a period of about 1.5 hours. The lease of radioactive material from containment would be caused by the sweeping . tion of gases generated by the reaction of the moltan' fuel with concrete. Since thtse gases would be initially heated by contact with the melt, the rate of sensible anargy release to the atmosphere would be moderately high. ( - PWR 4 f This category involves failure of the core-cooling system and the containment spray ~ l injection system after a loss-of-coolant accident, together with a concurrent l failure of the containment system to properly isolate. This would result in the l release of-91 of the iodines and 41 of the alkali metals present in the core at the time of release. Most of the release would occur continuously over a period of 2 to 3 hours. Because the containment recirculation spray.and heat-removal systems s, would operate to remove heat from the containment atmosphere during core melting, .g,' a relatively low rate of release of. sensible energy would be associated with this . category. k PwR s L This' category involves failure of the core cooling systems and 'is similar to PWR release category 4, except that the containment spray injection system would operate to further reduce the quantity of airborne radioactive material and to initially suppress containment temperature and. pressure. The containment barrier would have a large leakage rate due to a concurrent f ailure of the containment system to properly isolate, and mosE of the radioactive material would be released continuously over c period of several hours. Approximately 31 of the iodines and 0.9% of the alkali metals present in the core would be' released. Because of the operation of the cantainment heat-removal systems, the energy release rate would be low. 4The release fractions of all the chemical species are listed in Table VI 2-1.

( he release fractions of iodine and alkali metals are indicated here to L.llustrate the variations in release with release category.

we e _~,

, r.... ~ This category involves a core meltdown due to f ailure in the core cooling systems. i The containment sprays would not operate, but the containment barrier,would retain its integrity until the molten core proceeded to melt through the concrete containment base mat. The radioactive materials would be released into the ground, with some leakage to the atmosphere occurring upward through the ground. Direct leakage to 4 the atmosphere would also occur at a low rate prior to containment-vessel.meltthrough. Most of the release would occur continuously over a period of about 10 hours. The. release would include approximately 0.08% of the iodines and alkali metals i present in the core at the time of release. Because leakage.from.ontainment to c the atmosphere would be. low and gases escaping through the ground would be cooled .by contact with the soil, the energy release rate would be very low. FWR 7 ~ This category is similar to PWR release category 6, except that containment sprays would operate to reduce the containment temperature and pressure as well as the amount of airborne radioactivity. The release would involve 0.002% of the-iodines and 0.001% of the alkali metals present in the core at the time of release.' Most of the release would occur over a period of 10 hours. As in PWR release category 6, the energy release rate would be very low. PWR S ~ \\ This category approximates a PWR design basis accident (large pipe break), except that the containment would fail to isolate properly on demand. The other engineered safeguards are assumed to function properly. The core would not melt. The release would involve approximately 0.01% of the iodines and 0.05% of the alkali metals. Most of the release would occur in the 0.5-hour period during which containment pressure would be above ambient. Because containment sprays would operate and core { melting would not occur, the energy release rate would also be low. PWR S This category approximates t PWR design basis-accident (large pipe break), in which only the activity initially contained within the gap between the fuel pellet and cladding would be released into the containment. The core would not melt. It is assumed that the minimum required. engineered safeguards would function satisfactorily j to remove heat from the core and containment. The release would occur over the 0.5-hour _ period during*which the containment pressure would be above ambient. Approximately 0.00001% of the iodines and 0.00006% of the alkali metals would be released. As in PWR release category 8, the energy release rate would be very low. swa 1 This release category is representative of a core meltdown fellowed by a steam explosion in the reactor vessel. The latter would cause the release of a substantial quantity of radioactive material to the atmosphere. The total release would contain approximately 40% of the iodines and alkali metals present in'the core at the. time of containment failure. Most of the release would occur over a 1/2 hour period. Because of the energy generated in the steam explosion, this category would be characterized by a relatively high rate of energy release to the atmosphere. This category also includes certain sequences that involve overpressure failure of the -containment prior to the occurrence of core melting and a steam exp?osion. In these sequendes, the rate of energy release would be somewhat smaller than for those discussed'gb^ove, although it would still be relatively high. (-. - 2-3 _.._..~.,_ _

/3 .. e \\(~x. This release category is representative o_f a core meltdown resulting from a transient cv:nt in which decay-heat-removal systems are assumed to fail. ' Containment over-prassure failure would result, and core melting would follow. Most of the release w:uld occur over a period of about 3 hours. The containment failure would be such that radioactivity would be released directly to the atmosphere without si,gnificant ratantion of fission products. This category involves a relatively high rate of cn:rgy release due to the sweeping action of the gases generated by the molten mass. Approximately 90% of the iodines and 50% of the elkali metals present in the' core

• would be released to the atmosphere.

swa 3 This release category represents a core meltdown caused by a transient event accompanied by a failure to scram or failure to remove decay heat. Containment failure would cetur either before core melt or as a result of gases generated during the inter-cction of-the molten fuel with concrete af ter reactor-vessel meltthrough. Some ficsion-product retention would occur either in the suppression pool or the reactor building prior to release to the atmosphere. Most of the release would occur over c period of about 3 hours and would involve 10% of the iodines and 10% of the alkali metals. For those sequences in which the containment would fail due to overpressure efter core melt, the rate of energy release to the atmosphere would be relatively high. For those sequences in which overpressure failure would occur before core calt, the energy release rate would be somewhat smaller, although still moderately high. swn 4 This release category is representative of a core meltdown *with enough containment skage to the reactor building to prevent containment failure by overpressure. The ntity of radioactivity released to the atmosphere would be significantly reduced by n rmal ventilation paths in the reactor building and potential mitigation by the secondary containment filter systems. Condensation in the containment and the action cf the standby gas treatment system on the releases would also lead to a low rate cf cnergy release. The radioactive material would be released from the reactor building or the stack at an elevated level. Most of the release would occur over c 2-hour period and would involve approximately 0.08% of the iodines and 0.5% of the clkali metals. swa 5 This category approximates a BWR design basis accident (large pipe break) in which Cnly the activity initially contained within the gap between the fuel pellet and (1 cicdding would be released into containment. The core would not melt, and containment i lOakage would be small. It is assumed that the minimum required engineered safe-gunrds would function satisfactorily. The release would be filtered and pass through i ths eluvated stack. It would occur over a period of about 5 hours while the containment is pressurized above ambient and would involve approximately 6 x 10~8 -7 of the iodines and 4 x 10 1.of the alkali metals. Since core melt would not cccur and containment heat-removal systems would operate, the release to the atmosphere wculd involve a negligibly 'small amount of thermal energy. N J' '. ~ w l 1 m e ,1 m

,e = -81 t. e 3 'ee TABLE VI 2-1

SUMMARY

OF RELEASE CATEGORIES REPRESENTING HYPOTHETICAL ACCIDENTS %

• ve Thee of Ehsettee maratog Time Elevet&ee g set g

helease euehability*I pelease of Selease fet tvecuatten of aslease teergy telease ^ g 0I 8 IJI 3 *3 re-en Te-sb so-Sr he8CI ta fo t overy Geometer-yr l the n thrt

• thel f ee t e r e d

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• 9.5

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m/a 6 e 84-I 3 a le-' 8 m le-Il e e 3 m Be** 1 s 10-9 4 e lo-I Pwe 9 e a 8.*.

e. S

8. S m/a e

m/a S s. 'ne -3 ews a a e are a.e e.s a.s as ase s.e v = ar8 e.sa e.ee e.ie eles e.s .w. .. se-4 m.. 3.e e a ..e 3. so-3 e.,e e.se

e. >.

e. 80 0.8 e. 30-3

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3.s 3.. as as ,. irs e.ie S.no e.se e.e. 8.0, e. 30 u e...-. ..e ..e 3, .,a ..e .. i e-. .. i s-. ... ir ..i.-> e-. e. ir. .. it-a J, i .w.. .. ir. ..e .,a ie e. e-. > e is ' .. so-in .. ie ' e:.io->> .. iria e e 1 del serheveene em the toetope greve med reteese mecheetene is presented to appeedts vis. ib) eegents seesee to combleed with elementet tedless in the calculottene. any error te megligthne elece See telease fsecties se reletteely emett fes all losge release estegestes. Icl Inclesee no, em. Co no. Tc. 443 Includeo s. a.m. Es. WD. Co. Pt. Bd. pp. Pee am. Ca. lei assident oogeancee ottate Pwn 8 category have two distimet emergy roleeses that ef fect seemumeces. rwe & categety to omnesw teen rwn na mata e probantatty of e so-* pe,..ser-yees sea se 304 ste/me sea ese an eten e prM Beep of 5 a le*I per seector year ese 52e a los gg,fgg, (f) Het erettenhae, sol a te mete eneeetten to e e4 se plees of eene repeeeemtseg the mie-potet of a potentsal consotament breen. any to. nee==.me seeest. eeen i.e.ii,mt.e4 coe.oresti... t + 4 "o 4 = t o e -t s 'l* k 8. S E g,.:

4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD

) In the Matter of ) ) PACIFIC GAS AND-ELECTRIC COMPANY ) Docket Nos. 50-275 O.L. ) 50-323 0.L. (Diablo Canyon Nuclear Power ) Plant, Units 1 and 2) ) ) ) CERTIFICATE OF SERVICE I hereby certify that on this 31st day of October, 1983, I have served copies of the foregoing JOINT INTERVENORS' APPLICATION FOR A STAY mailing them through the U.S. mails, first class, postage prepaid.

• • Thomas S. Moore, Chairman Atomic Safety & Licensing Appeal Board Mr. Fredrick Eissler U.S. Nuclear Regulatory Scenic Shoreline Preservation Commission Conference, Inc.

Washington, D.C. 20555 4623 More Mesa Drive

• • Dr. W. Reed Johnson.

Atomic Safety & Licensing

• • Malcolm H. Furbush, Esq.

l Appeal Board Vice President & General U.S. Nuclear Regulatory Counsel Commission Philip A. Crane, Esq. Washington, D.C. 20555 Pacific Gas & Electric Company 77 Beale Street, Room 3135 i

• • Dr. John H. Buck San Francisco, CA 94106 Atomic ~' Safety & Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.

20555 l I

r .o -

• Nunzio Palladino,
• James Asselstine, Chairman Commissioner U.S. Nuclear Regulatory U.S._ Nuclear Regulatory Commission Commissioner Washington, D.C.

20555 Washington, D.C. 20555

• Victor Gilinsky,
• Frederick Bernthal, Commissioner Commissioner U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.

20555 Washington, D.C. 20555

• Thomas Roberts,
• Samuel J. Chilk, Commissioner Secretary U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commissioner Washington, D.C.

20555 Washington, D.C. 20555 Mr. Harold Denton Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555

• Herzel Plaine, Esq.

Office of General Counsel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ~

• Docket and Service Branch Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C.

20555

• • Lawrence Chandler, Esq.

Office of the Executive Legal Director - BETH 042 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ~ * - Janice E. Kerr, Esq. Lawrence Q. Garcia, Esq. J. Calvin Simpson, Esq. California Public Utilities Commission 5246 McAllister Street San Francisco, CA 94102

• • John Van de Kamp, Attorney General Andrea Sheridan Ordin, Chief Attorney General Michael J. Strumwasser, Special Counsel to the nttorney General State of California 3580 Wilshire Boulevard, Suite 800 Los Angeles, CA 90010 t

e .o - David S. Fleischaker, Esq. Post Office Box 1178 Oklahoma City, OK 73101 Richard Hubbard MHB Technical Associates 1723 Hamilton Avenue, Suite K San Jose, CA 95725 Arthur C. Gehr, Esq. '~ Snell & Wilmer 3100 Valley Center Phoenix, AZ 85073

• • Bruce Norton, Esq.

Norton, Burke, Berry & French, P.C. 2002 E. Osborn Phoenix, AZ 89016

• • Maurice Axelrad, Esq.

Lowenstein, Newman, Reis & Axelrad, P.C. 1025 Connecticut Avenue, N.W. Washington, D.C. 20036 Virginia and Gordon Bruno Pecho Ranch Post Office Box 6289. Los Osos, CA 93402 Sandra and Gordon Silver 1760 Alisal Street San Luis Obispo, CA 93401 Nancy Culver 192 Luneta San Luis Obispo, CA 93402 Carl Neiburger 'f' l Telegram Tribune l Post Office Box 112 l San Luis Obispo, CA 93402 l Betsy Umhoffer 1493 Southwood San Luis Obispo, CA 93401 'D M /1 M CHRISTINA CONCEPCf0N i

• Delivered via Express Mail
  • Delivered by Hand at Design Hearings in Avila Beach, CA

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