ML20084F897
| ML20084F897 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 05/03/1984 |
| From: | Locke R PACIFIC GAS & ELECTRIC CO. |
| To: | NRC COMMISSION (OCM) |
| References | |
| CLI-84-4, OL, TAC-49424, NUDOCS 8405040354 | |
| Download: ML20084F897 (19) | |
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1 UNITED STATES OF AMERICA' 00CMETED USHRC 2 NUCLEAR REGULATORY COMMISSION 3 N IblY-4 gh:l'p BEFORE THE COMMISSION 4 r.re_, ,
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In the Matter of )
6
) Docket Nos. 50-275 O/_.
PACIFIC GAS AND' ELECTRIC COMPANY ) 50-323 (Diablo Canyon Nuclear Power Plant )
8 Units 1 and 2) )
9 10 RESPONSE OF PACIFIC GAS AND ELECTRIC COMPANY 11 TO COMMISSION ORDER CLI-84-4 12 The Commission, in its Order CLI 84-4 dated April 3, 1984, requested the parties to the Diablo Canyon licensing proceeding to provide their views on several issues regarding the potential consideration of the com-plicating effects of earthquakes on emergency planning.
Pacific Gas and Electric Company's ("PGandE") responses are t
provided herein.
Issue 1:
Whether NRC emergency planning regulations 21 can and should be read to require some review of the complicating effects of earthquakes 22 on emergency planning for Diablo Canyon.
23 The NRC's regulations cannot and should not be j 24 read to require a specific review of the effects of earth-25 quakes on emergency planning.
l In the Matter of Southern l 26 l 9bD3 e40sO40as4 e4030a j PDR ADOCK 05000275 G PDR l
1 California Edison Company, et al. (San Onofre Nuclear 2
Generating Station, Units 2 and 3), CLI-81-33, 14 NRC 1091 3
(1981). In this regard, it is critical to differentiate:
4 (a) whether the emergency planning process should yield a 5
planning base with sufficient capability and flexibility to l 6
accommodate complicating effects such as earthquakes or 7
(b) whether emergency plans should specifically address and 1 j
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provide analyses of certain earthquakes as initiating or 1 9
ancillary conditions to an emergency. PGandE contends that 10 the former is both sufficient and preferable and is consis-11 tent with the emergency planning basis adopted by the 12 Commission in its regulations.
13 The Commission, in its rulemaking process, artic-14 ulated an emergency planning philosophy that would assure 15 both a broad and flexible preparedness in response to a wide 16 i
spectrum of possible events. In the joint NRC/ FEMA planning 17 document " Criteria for Preparation and Evaluation of
, Radiological Response Plans and Preparedness in Support of Nuclear Power Plants," NUREG-0654/ FEMA Rep 1 (NUREG-0654 ) , -
20 it was stated:
21 No single specific accident sequence 22 should be isolated as the one for which to plan because each accident could have 23 different consequence, both in nature and degree. Further, the range of 24 Possible selection for a planning basis is very large, starting with a zero 25 Point of requiring no planning at all because significant offsite radiological.
26 accident consequences are unlikely to occur, to planning for the worst
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possible accident, regardless of its 2 extremely low likelihood. The NRC/ EPA Task Force [which prepared NUREG-0396 3 " Planning Basis for the Development of State and Local Government Radiological 4 Emergency Response Plans in Support of Light Water Nuclear Power Plants"] did 5 not attempt to define a single accident sequence or even a limited number of 6 sequences. Rather, it identified the bounds of the parameters for which 7 P l anning is recommended..." (Emphasis added) 8 The TMI accident clearly demonstrated the unpre-9 dictability of specific event sequences that might require 10 the implementation of emergency plans. Furthermore, as 11 prescribed in 10 C.F.R. Part 50, Appendix E, "The (emergen-12 cy) plan shall be an expression of the overall concept of 13 operation...." The objective was to institutionalize a 14 response framework that will activate and respond on a graded basis to any emergency; will allow for adjustment and 16 creativity in the specific required actions; and will, under 17 the most severe conditions, allow for the supplementation of
, emergency response through expanded state and federal 19 . .
assistance.
20 Interpreting the Commission's regulations to 21 require the explicit consideration of any specific event 22 scenario, such as an earthquake, would undermine, not 23 enhance the generic nature of planning. This is recognized 24 most clearly in the emergency classification scheme adopted 25 in NUREG-0654, where potential initiating events are' grouped 26 into four classes. As clearly indicated in the examples in i
1 NUREG-0654, natural phenomena, including earthquakes, are 2
contemplated as events which contribute to the emergency 3
planning character of each of these classes. Appropriately, 4
emergency plans are required to address these classes as 5
lumped parameters, to assure that response capabilities are not distorted or preferentially aligned to any particular 7
sequence of events that might be included in any one class.
8 The specific actions which might be required in 9
response to a combination earthquake / radiological emergency 10 are not dissimilar from the response for either emergency 11 standing alone. Following an earthquake, for example, the 12 highways, bridges and overpasses are examined for 13 passability. Communications are checked and appropriate 14 channels are utilized. Technical assessments are conducted 15 to determine the extent of damage. Assistance is requested from outside resources as necessary.1 17 For a radiological emergency the same elements are
, present. The roads are surveyed for possible evacuation, 19 '
communications are checked, technical assessments-are 20 conducted for the radiological risk, and outside resources 21 are requested. Thus, the response for radiological acci-22 dents and an earthquake are decidely similar.
23 24 25 Federal Earthquake Response and Assistance Plan, Federal Emergency Management Agency, Regio,n IX, Draft May 26 (Footnote Continued)
. . u 1 PGandE contends that any additional consideration 2 of earthquake effects and emergency planning would most l 3 logically fall within the Federal Emergency Management 4 Agency's (FEMA) jurisdiction at the Federal level and the 5 State of California's jurisdiction at the state and local 6 level. As noted, the primary impacts of an earthquake would 7 be those related to offsite issues such as transportation 8 routes and communications. These effects do not require any 9 specialized knowledge of radiological or nuclear matters.
10 The current radiological plans required by the NRC assure 11 that any necessary specialized knowledge for radiological 12 effects would be available. These earthquake impacts would 13 most directly challenge the planning and resources available 14 to state and local authorities as they currently exist for 15 non-radiological emergency preparedness. As such, the 16 federal role is properly reserved to FEMA and would be 17 implemented in conjunction with FEMA's general responsibil-18 ities for civil disasters. Within California, for example, 19 this is illustrated by FEMA's active and continuing role in*
20 earthquake response planning in concert with State and local 21 planning.2 22 l 23 l (Footnote Continued) .
24 '1983; State of California Earthquake Response Plan, California Office of Emergency Services, April 1981.
25 See references in footnote 1, supra.
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1 The applicable federal law supports this conclu-2 sion. The Earthquake Hazards Reduction Act of 1977 3 (PL 95-124 as amended by PL 96-472, 42 U.S.C. 7701 et seq.)
4 provides that FEMA "is designated as the agency with the 5 primary responsibility to plan and coordinate the National 6 Earthquake Hazards Reduction Program" (42 U.S.C. 7704).
7 Further, this Act provides that the Director of FEMA "shall 8 recommend appropriate roles for State and local units of 9
government..." in earthquake hazards reduction (M.). The 10 Act does include as one of its objectives the reduction in 11 risk through earthquake resistant construction. Among the 12 areas listed for special attention are " nuclear power 13 generating plants" (Id.). The Act does mention the NRC as 14 an agency that also may have a role in this program (M.).
15 It seems clear, therefore, that Congress intended FEMA to 16 have the lead role in working with State and local govern-17 ments in various elements of earthquake hazard reduction, 18 whereas, the NRC's proper role is to assure that nuclear 19 plants are constructed and operated safely.
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20 Notwithstanding the above arguments, PGandE has 21 conducted detailed studies of the potential effects of I
22 earthquakes on emergency planning for the Diablo Canyon 23 l
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24 25 26 1 Power Plant. These studies were requested by the NRC staff 2 in December 1980, prior to the Commission's order in the San 3 Onofre proceeding (CLI-81-33). The results of these studies 4 provide further confirmation of PGandE's basic thesis that 5 the inherent basic flexibility and capability of the emer-6 gency plans provide the necessary framework for responding 7 to all types of emergencies. A summary of the earthquake 8 emergency planning study conclusions and related matters for 9 Diablo Canyon is attached.
10 While the studies identified some areas where 11 emergency plans should be modified to more optimally and 12 specifically address earthquakes, this does not mean that 13 the existing planning base was not fully adequate as a 14 generic tool to provide effective response across the 15 spectrum of postulated events. Rather, it only reflected 16 that if one focused an emergency plan on a specific event or 17 class of events additional planning can be performed. A 18 similar conclusion would be expected if a detailed analysis 19 was performed for any specific emergency scenario.
- 20 In the case of Diablo Canyon Power Plant, the 21 principal additional planning that was performed was at the 22 local level where the County incorporated earthquake !
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24 25 26 3 l Earthquake Emergency Planning at Diablo Canyon, TERA Corporation, September 1981. The Commission ordered that a copy of this document be served on all the parties. ,
CLI-84-4 at p. 3. 1 response planning provisions into its existing Emergency 1 Response Plan.4 2 The emergency planning concepts developed for 3 Diablo Canyon Power Plant are not sensitive to the size of 4 an earthquake. This is not because of some regulatory 5 barrier to consider earthquakes larger than the SSE, but due 6 to the relative uncertainty and variability possible for -
7 damage from any significant earthquake. This variability 8 requires the development of plans general enough such that 9 specific consideration of an earthquake larger than an SSE 10 is not needed. Also, at the high magnitude of the Diablo 11 Canyon SSE (Ms 7.5), the available evidence indicates that 12 local damage saturates such that little or no increase in 13 local damage would be expected for larger earthquakes.
14 Thus, the PGandE and local emergency plans are magnitude 15 independent and provide the capability and flexibility for 16 response to any size earthquake.
17 The risks from an earthquake at Diablo Canyon are 18 not unlike those posed by other natural phenomena throughout 19 the country, such as hurricanes in the Gulf coast, blizzards 20 in the Northeast and tornadoes in the Midwest. These and 21 other natural hazards will a'lways have a potential for 22 23 24 4 San Luis Obispo County / Cities Nuclear Power Plant Emergency Response Plan,Section IV.2 (January 1984).
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( l affecting the offsite response at a nuclear power plant and, 1
l 2 we might add, have a far more frequent occurrence probabil-3 ity than an earthquake coincident with a radiological event.
4 Indeed, as the staff stated in its memorandum (p. 3) to the 5 Commission of January 13, 1984 (attached to Commission Order 6 CLI-84-4), the potential for a coincident earthquake and a 7 major plant accident at Diablo Canyon is an extremely low 8 probability event. Nonetheless, the measures discussed
. 9 above further assure that an adequate response to even these 10 unlikely conditions can be implemented.
11 Finally, earthquake emergency planning at Diablo 12 Canyon has received extensive peer review. The reports 13 commissioned by PGandE were reviewed and appropriate 14 recommendations incorporated by the County of San Luis 15 Obispo in the preparation of its emergency plans. The NRC 16 staff, the State of California and FEMA have also reviewed 17 the County plans which incorporated these earthquake g
18 emergency planning aspects. Additionally, the State 19 Departments of Transportation and Mines and Geology 5 have ~
20 reviewed the earthquake study that formed the basis for 21 those plans. None of these reviews have questioned the 22 adequacy of the earthquake emergency plans that have been in 23 effect since 1982.
24 25 26 5
Unpublished reports.
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1 Issue 2:
2 If the answer to question (1) is no, should such a review be performed for 3 Diablo Canyon on the ground that it presents special circumstances under 10 4 C.F.R. 2.758. If so, what are the !
special circumstances that would permit 5 consideration of the effects of earth-quakes on emergency planning for Diablo _
6 Canyon?
7 PGandE submits that no special circumstances exist 8 that would warrant a finding under 10 C.F.R. 2.758 that the
. 9 effects of earthquakes on emergency planning should be 10 considered for Diablo Canyon. As noted above, severe 11 external phenomena can be postulated for any nuclear plant; 12 for Diablo Canyon Power Plant it may be an earthquake, for 13 another plant a severe flood or snowstorm.
14 As discussed above in the response to Issue 1, 15 emergency planning elements associated with any severe 16 phenomena are similar in nature. Planning for floods, 17 storms, or earthquakes requires coordination and evaluation 18 q of communications and transportation and timely integration 19 of available resources to assure effective response. -Since*
20 these planning elements are generic and applicable to 21 essentially all severe phenomena, no special circumstances 22 exist for their consideration solely for earthquakes at 23 Diablo Canyon Power Plant. To pursue the particularization 24 of effects on emergency planning at one plant due to one 25 event would necessarily require the same course of action 26 for all other events. Special circumstances.cannot be l
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I found, and the issue must be judged on its merits as called 2 for under the Commission's first question.6 3 l Respectfully submitted, '
4 ROBERT OHLBACH PHILIP A. CRANE, JR.
5 RICHARD F. LOCKE DAN G. LUBBOCK 6
Pacific Gas and Electric Company 7
P. O. Box 7442 San Francisco, CA 94120 (415) 781-4211 9
ARTHUR C. GEHR -
Snell & Wilmer 10 3100 Valley Center Phoenix, AZ 85073 11 ' (602) 257-7288 BRUCE NORTON 12 Norton, Burke, Berry & French, P.C.
13 P. O. Box 10569 Phoenix, AZ 85064 14 (602) 955-2446 15 Attorneys for Pacific Gas and Electric Company 1
By Dated: May 3, 1984 Richard F. Locke 19
- 20 6 Special note should be taken of the isolated and 21 relatively remote location of Diablo Canyon to any ;
significant permanent population. For example, in the !
22 six-mile zone surrounding Diablo Canyon, there are only i approximately 65 permanent residents. In the Matter of l 23 Pacific Gas and Electric Company (Diablo Canyon Nuclear !
Plant, Units 1 and 2), LBP-81-21, 14 NRC 107, 135, 136 i 24 (1981). Further, Diablo Canyon is located in an area of-California that has been characterized as one of low to 25 moderate seismicity. In the Matter of Pacific Gas and Electric Company (Diablo Canyon Nuclear Power Plant, Units 1 l and 2), ALAB-644, 13 NRC 903, 993-994 (1981). ^
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ATTACHMENT EMERGENCY PLANNING PROVISIONS FOR DIABLO CANYON Earthquake emergency preparedness at Diablo Canyon and the County of San Luis Obispo has already been addressed as a result of the NRC Staff's letter of December 19, 1980. The planning for Diablo Canyon and the County is a multi-tiered effort with planning and response capabilities from Federal and State resources identified and coordinated with the County and PGandE.
The seminal work in this area was a study entitled " Earthquake Emergency Planning at Diablo Canyon" which was commissioned in 1981 by PGandE in response to a NRC staff request to address earthquakes and emergency planning.
The principal conclusions of that study were:
- 1. Even on a pessimistic basis, a large earthquake in the study area would not be expected to result in total neutralization of emergency response capabilities. This is attributable to the inherent resistance of much of the physical equipment and structures involved and the diversity of capabilities provided by redundant and separate means of transport and communications, i
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- 2. Evacuation, as a protective action option, is available within a reasonable time for most geographic areas under estimated damage conditions. The availability of evacuation is enhanced considerably by pre-analyses of potential damage and repair resources, and the establishment of plans to survey, assess and repair damage and to utilize available evacuation routes in a maximum manner.
The emergency procedures of the California Department of Transportation (CalTrans), of the California Highway Patrol and the San Luis Obispo County Engineer's office are integrated in a way that response to an evacuation order can be accomplished in a very short time frame.
l Procedures of CalTrans in the event of- an earthquake in any given area call for imediate inspection of key overheads and bridges and coordinated redirection of traffic flows, if required.
Assessment of major damage that might close roadways can be quickly accomplished by aerial surveys directed from the ground. In the San Luis Obispo area, flights might be launched from the County Airport, the National Guard heliport, Santa Maria airport, Fresno or Bakersfield, or from airports outside the area. Such a survey can be accomplished within hours of the occurrence of an earthquake.
Repair resources have been identified in the earthquake study and by the County of San Luis Obispo and CalTrans. Additional personnel to perform repairs could be airlifted by helicopter or fixed wing aircraft. The ,
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availability of heavy construction units of the California National Guard 1 1 -!
- at San Luis Obispo and the statewide resources of CalTrans would I
considerably diminish response and repair time.
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- 3. Emergency planning must be considered as an; evolving process and in the context of other related plans and events. The detailed assessment of earthquake effects and' plans provided in the' study are perhaps the leading edge of planning for these t'ypes of emergencies. Planning resources, and attention, should be distributeh such that local, state and federal i
emergency planning is conducted in an integrated and harmonious manner.
Federal, State, County and PGandE plans already address earthquake 1 planning aspects as sumariz'ed below:
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, ,s Federal / State:
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The Federal role is cocrdinated'by FEMA, which has developed earthquake response plans that channel federal assistance and resources to the state and locallevelohanas-neededbasis.
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The -State of California has recognized the s
potentia 1' safety concerns associate'd with earthquakes and has acted to put into pl3ce an extensi[vd plan f'r o eartNguake response. Assistance to local authortties would be drawn from"throughout the state and allows for escalation to federal resources as well. Th x,'eutility, ;
county, state and federal plans
) would provide a coordinated, wejl-planned response to the situation.
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The State of California has als$. addressed the'effActs of earthquakes on e w ,
transportation. Af ter the 1971 Sari Fernando earthquake, the California
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Department of Transportation (CalTrans) began a retrofit program to upgrade the seismic capability ofg brjdjes, including those in the vicinity of Diablo Canyon Power Plant., ,
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Public and County communication systems were evaluated for earthquake effects, including the emergency broadcast system (EBS). The public telephone system is i l
expected to perform given its inherent seismic capability and experience in recent California earthquakes.
County:
The San Luis Obispo County / Cities Nuclear Power Plant Emergency Response plan (Section IV.2) already considers the complicating effects of an earthquake for a radiological emergency. The plan specifically addresses earthquakes in several ways:
- 1. An Earthquake Damage Assessment Center (EDAC) is established to respond to damage as a result of an earthquake. Emphasis will be on maintaining primary evacuation routes and communication systems. This group, composed of members of the County Emergency Organization and augmented by liaison personnel from public utilities (PGandE, Pacific Bell, Southern California Gas Co., etc.), will conduct operations from their office in the Emergency Operations Center (EOC).
The EDAC evaluates damage through surveys, or reports. .from involved agencies. An assessment of damage is made with repair and restoration i
activities initiated on a priority basis. Activities are monitored with.
updates given to the County Direction and Control Group.
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Communications are evaluated and appropriate repair or modification undertaken. Communication systems which are evaluated and repaired, if necessary, include PGandE, San Luis Obispo County, Pacific Bell and radio and television stations, especially the EBS stations.
The EDAC coordinates its activities with the Unified Dose Assessment.
Center (UDAC). The UDAC makesta technical assessment of the' offsite radiological effects. It is a joint county, state, utility and federal operation. Together, the UDAC and EDAC make a recommendation to the direction and control group on which range of protection actions should be undertaken in each area.
- 2. The County Plan contains strategies for evacuation and sheltering based on damage assessment from earthquake' effects. Offsite damage is f
categorized as none, light,~ moderate or heavy. Corresponding evacuation times have been determined and include repair time requirements.
4 Diablo Canyon - Onsite ,
a-5 PGandE has available specialized procedures and equipment onsite to assist in i
responding to earthquakes. A Diablo. Canyon Power Plant Emergency Plan-Procedure goes, into considerable detail on plant personnel response. There-are detailed actions to be implemented for specific ranges of. indicated ground acceleration. -
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1 For specified earthquakes, the instructions include a checklist to be performed by inspection crews to evaluate safety systems throughout the plant. Drawings specify which areas are to be inspected. Forms are then filled out to be returned to plant engineers for evaluation.
The plant itself is equipped with two seismic measuring systems. One of the systems is designed to automatically trip the unit if the ground acceleration exceeds a preset level . The plant operators in the control room are also instructed to shut the reactor down if certain ground acceleration levels are exceeded or if a plant survey indicates any significant damage.
Communications equipment onsite were evaluated. Given the redundancy and diversity of communication channels (private telephone / microwave, public telephone, and radio telephone) and their seismic capabilities, it was concluded that sufficient capability would exist af ter a large earthquake.
Modes of evacuation of non-essential plant personnel and resupply of personnel and equipment were also reviewed. Alternatives exist such that onsite evacuation and resupply could be accomplished.
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. 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )
)
PACIFIC GAS AND ELECTRIC COMPANY ) Docket No. 50-275
) Docket No. 50-323 Diablo Canyon Nuclear Power Plant, )
Units 1 and 2 )
)
CERTIFICATE OF SERVICE <
The foregoing document (s) of Pacific Gas and Electric Company has (have) been served today on the following by deposit in the United States mail, properly stamped and addressed:
Judge John F. Wolf "
Mrs. Sandra A. Silver Chairman 1760 Alisal Street San Luis Obispo CA 93401 l
Atomic Safety and Licensing Board US Nuclear Regulatory Commission Washington DC 20555 Mr. Gordon Silver 1760 Alisal Strett Judge Glenn O. Bright San Luis Obispo CA 93401 Atomic Safety and Licensing Board US Nuclear Regulatory Commission John Phillips, Esq.
Washington DC 20555 Joel Reynolds, Esq.
Center for Law in the Public Interest.
Judge Jerry R. Kline 10951 W. Pico Blvd. - Suite 300 Atomic Safety and Licensing Board Los Angeles CA 90064 US Nuclear Regulatory Commission Washington DC 20555 David F. Fleischaker, Esq.
P. O. Box 1178 Mrs. Elizabeth Apfelberg Oklahoma City OK 73101 c/o Betsy Umhoffer 1493 Southwood Arthur C. Gehr, Esq.
San Luis Obispo CA 93401 Snell & Wilmer 3100 Valley Bank Center Janice E. Kerr, Esq. Phoenix AZ 85073 Public Utilities Commission Bruce Norton, Esq.
. State of California 5246 State Building Norton, Burke, Berry _& French, P.C.
l 350 McAllister Street P. O. Box 10569 San Francisco CA 94102 Phoenix AZ 85064 Mro. Raye Fleming Chairman 1920 Mattie Road Atomic Safety and Licensing Shall Beach CA 93449 Board Panel US Nuclear Regulatory Commission Mr. Frederick Eissler Washington DC 20555 -
l Scanic Shoreline Preservation [
Conference, Inc.
4623 More Mesa Drive Stnta Barbara CA 93105 j
Chnirman Judge Thomas S. Moore .
Atomic Safety and Licensing Chairman l Appeal Panel Atomic Safety and Licensing l US Nuclear Regulatory Commission Appeal Board Washington DC 20555 US Nuclear Regulatory Commission Washington DC 20555
- Secretary US Nuclear Regulatory Commission Judge W. Reed Johnson Washington DC 20555 Atomic Safety and Licensing Appeal Board Attn: Docketing and Service US Nuclear Regulatory Commission Section Washington DC 20555 LOwrence J. Chandler, Esq. Judge John H. Buck Henry J. McGurren Atomic Safety and Licensing US Nuclear Regulatory Commission Appeal Board Office of Executive Legal Director US Nuclear Regulatory Commission Washington DC 20555 Washington DC 20555 Mr. Richard B. Hubbard
- Commissioner Nunzio J. Palladino MHB Technical Associates Chairman 1723 Hamilton Avenue Suite K US Nuclear Regulatory Commission San Jose CA 95125 1717 H Street NW Washington DC 20555 Mr. Carl Neiberger Telegram Tribune
- Commissioner Frederick M. Bernthal P. O. Box 112 US Nuclear Regulatory Commission San Luis Obispo CA 93402 1717 H Street NW Washington DC 20555 Michael J. Strumwasser, Esq.
Susan L. Durbin, Esq.
- Commissioner Victor Gilinsky Peter H. Kaufman, Esq. US Nuclear Regulatory Commission 3580 Wilshire Blvd. Suite 800 1717 H Street NW Los Angeles CA 90010 Washington DC 20555 M urice Axelrad, Esq.
- Commissioner James K. Asselstine Lowenstein, Newman, Reis, and US Nuclear Regulatory Commission Axelrad, P.C. 1717 H Street NW 1025 Connecticut Ave. NW Washington DC 20555 Washington DC 20036
- Commissioner Thomas M. Roberts US Nuclear' Regulatory Commission 1717 H Street NW Washington DC 20555 Date: May 3, 1984
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