ML20105D081
| ML20105D081 | |
| Person / Time | |
|---|---|
| Site: | 05000000, San Onofre |
| Issue date: | 08/04/1981 |
| From: | Hoefling R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| Shared Package | |
| ML20105C680 | List: |
| References | |
| FOIA-84-378 OL, NUDOCS 8502090589 | |
| Download: ML20105D081 (3) | |
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W sg August 4, 1981 UNITED STATES OF AMERICA I
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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50-362 OL I
(San Onofre Nuclear Generating l
l Station, Units 2 and 3)
J NRC STAFF COMMENTS WITH RESPECT TO THE BOARD'S ORDER OF JULY 29, 1981 RAISING AN ISSUE r.ONCERNING EARTHQUAKES AND EMERGENCY PLANNING I.
INTRODUCTION On July 29, 1981, the Atomic Safety and Licensing Board in this proceeding issued an Order raising on the Board's Motion an issue concerning earthquakes and emergency planning.
In its Order, the Board pemitted the parties to file comments by August 3,1981, on the issue framed with the possibility that the Board might modify the issue in light of the ce;:nents received. The Board subsequently extended the time for filing to August 4, 1981. Comments of the NRC Staff follow.
II. DISCUSSION The Staff would reiterate that in its view the issue proposed by the Board is not necessary for consideration in this licensin?
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4 proceeding.
As the Staff argued in its June 22, 1981 pleading,M a fundamental premise in t,he approach to emergency planning utilized by the NRC and FEMA is,that emergency plans must be capable of responding to J
a wide spectrum of accidents and such a spectrum was considered in the development of the planning basis which underlies the Comission's l,
emergency planning regulations. Consequently, an adequate planning basis is assured by conformance with,the Comission's regulations and site specific analyses are not required for the extremely large releases already generically considered in establishing the regulations.
Thus, the Staff continues to be of the view that the Commission's emergency planning regulations already con ider catastrophic events in s
establishing a planning basis.
Consequently, while the Vennent Yankee case / would not bar inquiry into the need for site specific 2
earthquake considerations in the emergency planning area given an
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earthquakeinexcessofthesafeshutdownearthquake(SSE)asamatterof 1
4 law, such an inquiry must be based on a showing that an extension to site specific consideration of earthquakes beyond the SSE is warranted, i.e.,
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. l If NRC Staff Views with Respect to Questions Posed by the Atomic Safety l9l and Licensing Board in the Area of Emergency Planning, June 22, 1981, pp. 8-10.
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Vennent Yankee Nuclear Power Coporation (Vermont Yankee Nuclear Power Station), CLI-74-40, 8 AEC 809 (1974)
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3-that there is a factual basis for the extension. The Staff continues to y
be of the view that, as no such showing has been made in this proceeding.,
extension of emergency planning considerations beyond the SSE is not necessary.
Certain specific comments of the NRC Staff requested in the Board's
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Order are provided in the attached affidavit of Brian K. Grimes.
III. CONCI.USION The Staff reiterates its view that the Board's site specific inquiry in the emergency planning area requesting consideration of extremely unlikely earthquakes in excess of the SSE is not necessary. Nonetheless, comments of the Staff with respect to the Board's Order of July 29, ~ 1981 are provided.
i Respectfully submitted, j
j Richard K. Hoefling Counsel for NRC Staff
.g Dated in Bethesda, Maryland this 4th day of August,1981 3/ The Board apparently agrees on this point for it states in its Order, i:
"Although it is extremely unlikely, an earthquake in excess of the SSE li could conceivably occur near the facility" [ Emphasis supplied] (pp.-2-3).
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