ML20105D311
| ML20105D311 | |
| Person / Time | |
|---|---|
| Site: | 05000000, San Onofre |
| Issue date: | 06/22/1981 |
| From: | Grimes B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20105C680 | List: |
| References | |
| FOIA-84-378 OL, NUDOCS 8502090649 | |
| Download: ML20105D311 (11) | |
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4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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SOUTHERN CALIFORNIA EDISON COMPANY, Docket Nos. 50-361 OL ij p_A1
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50-362 OL
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(San Onofre Nuclear Generating
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Station, Units 2 and 3)
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AFFIDAVIT OF BRIAN K. GRIMES My nuae is Brian K. Grimes.
I am Director, Division of Emergency Preparedness, Office of Inspection and Enforcement, U.S. Nuclear q
Regulatory CommissionrWashington, D. C.
My professional qualifications
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d are attached as part of this affidavit. This affidavit is submitted to 3
address the areas of emergency planning earthquake considerations and i
selection of Emergency Planning Zone (EPZ) size.
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Emergency Planning Earthquake Considerations A fundamental premise in the approach to emergency planning utilized 1
by the Federal Emergency Management Agency (FEMA) and the Nuclear
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Regulatory Commission (NRC) is that the emergency planning basis must be 1
capab'le of responding to a wide spectrum of accidents. This was the i
- 3 conclusion reached by the Task Force which authored NUREG-0396.M d
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y NUREG-0396, EPA 520/1-78-016. " Planning Basis for the Development of
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State and Local Government Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants," December 1978, pp. 4-6.
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That Task Force report was subsequently endorsed by the Commission in its Policy Statement with respect to the Planning Basis for Emergency Responses to Nuclear Power Reactor Accidents (Policy Statement). 44 Fed.
Reg. 61123 (October 23,1979). The concept is ' reiterated in d
NUREG-0654.U Consequently, as a single specific accident sequence for a
a light water reactor nuclear power plant could not be identified as a planning basis, both NUREG-0396 and NUREG-0654 emphasized that the most
,t important element of any-planning basis is the distance from the nuclear f acility which defines the area over which planning for predetemined j
action should be carried out.U Not only is this area, termed the Emergency Planning Zone or EPZ, crucial but the _ characteristics of the q
- ,, 7 EPZ are significant.
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The need for specification of areas for major exposure pathways is evident. The location of the 2'
population for whom protective measures may be needed, responsible authorities who would carry out protective actions and the means of communication to 3
these authorities and to the population are all is dependent on the characteristics of the olanning areas.
(Emphasis supplied). NUREG-0654, p. 8.
U It is, therefore, inherent in the planning approach utilized by FEMA
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and the Commission, i.e., the Emergency Planning Zone concept, that the
.1j characteristics of the Emergency Planning Zones themselves must be factored into emergency planning considerations. For example, if an EPZ Y
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y NUREG-055', FEMA-Rep-1, Rev.1. " Criteria for Preparation and d
Evaluation of Radiological Emergency Response Plans and Preparedness V
in Support of Nuclear Power Plants," November 1980, pp. 5-7.
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NUREG-0396, p. 8, NUREG-0654, p. 7.
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3-is an area with singular adverse weather attributes, those attributes must be considered in emergency planning. This reasoning would extend to l
all attributes that might adversely affect an Emergency Planning Zone.
Appendix 4 of NUREG-0654 speaks to this point directly.
Evacuation time estimates are required to consider adverse conditions which might reasonably be expected to occur during the plant lifetime at a particular site and be severe enough to affect the time estimates for a particular event.
Two conditions--normal and adverse--are considered in the analyses. Adverse conditions would depend on the characteristics of a specific site and could include flooding, snow, ice, fog or rain.
(Emphasis supplied. ) NUREG-0654 Rev.1, pp. 4-6.
O It should be streIsed that this reference is to NUREG-0654 which the nr i
Commission has adopted to provide guidance in developing plans for coping with emergencies.O It is clear then that the characteristics of a particular Emergency Planning Zone must be taken into account to give meaning to Commission's emergency planning regulations.
In the case of San Onofre Units 2 & 3, the site is in California which has a substantial earthquake potential, a fact that is recognized s
in the seismic design of these units. Consequently, high seismicity is a.
characteristic which affects the EPZs around the San Onofre site and is to be considered. in emergency planning.
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The more difficult question is the extent to which earthquake effects are to be taken into account in emergency planning. The answer
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to this question is dependent upon the nature of the risk and the nature t
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10 C.F.R. Part 50, Appendix E, footnote 1.
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4 4-of the remedy to deal with the risk.
In areas of low seismicity, the nature of risk is such that the NRC Staff does not require any explicit consideration of earthquake effects in emergency planning.
In areas of high seismicity (high earthquake frequency and magnitude), specifically i;
- i California, the nature of the risk warrants specific consideration of II earthquake effects.
To this end, the NRC Staff has made requests to the Applicants on December 17,,1981, and.May 13, 1981, to consider earthquake effects in its emergency planning, and the NRC Staff has also requested FBtA to consider earthquake effects in its evaluation of off-site plans.
The Staff has, however, concluded that additional requirements such as 13 1.
the design of additional facilities, structures and systems to
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specifically withstand earthquakes is not necessary.
In particular, no p-special seismic design of public notification systems, environmental monitoring capability or communications equipment is contemplated.
- Also, consideration need not be given to a seismic event coincident with a 4
significant accident at the plant due to the very low likelihood of such i]'
a ccincidence.
[j With respect to on-site effects, consideration should be given to
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the ability to transport necessary personnel to the plant to cope with Il;j degraded modes of plant operation possibly resulting from the earthquake.
In add 1 tion, there should be assurance of continued communication between the plant and of f-site agencies.
With respect to off-site effects, it is our understanding that the FEMA Radiological Emergency preparedness staff believes that'the Emergency Operation Centers (E0Cs) of each i
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of the jurisdictions involved in the emergency planning effort for a specific nuclear facility should have suitably distant backup facilitie.s to pennit continued functioning of a jurisdiction's emergency response given the possible failure of its primary EOC.
In addition, the capability should exist to obtain damage estimates i
both to the plant and to transportation and communication facilities off-I site to provide a data base to factor into the decisiorrnaking process.
Finally, the Applicants should have available a range of recommendations to off-site authorities, taking into account the degree of damage to the plant caused by the earthquake and to transportation and consnunication f acilities off-site.
l The specific size or magnitude of earthquake to be considered for 1
emergency planning purposes is not a critical element as long as the magnitude postulated is less than or equal to the Safe Shutdown 4
Earthquske (SSE), because such earthquakes are accounted for in the plant i
design. A moderate size earthquake, something less than the SSE, will produce impacts on transportation and communication facilities which, if t
I considered in emegency planning, would also provide an amegency i
response capability useful in coping with any less likely larger j
earthquakes. As noted above, the planning basis for emegency l
preparedness does not include explicit planning for any specific event or events, but rather is a base capability which can be expanded or l
contracted to address an actual emergency. The measures which cope with.
consequences of moderate earthquakes (e.g., backup communications and-4 EOCs, and feedback of damage estimates regarding transportation. routes to decisiorinakers) would be equally applicable in the event of a large i
Explicit consideration of less than worst-case effects suffices to give confidence that the occurrence of any of a spectrum of events, including very low likelihood events, provide decisiomakers with a planning base from which specific actions could be chosen from among
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available alternatives.
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However, the magnitude of the earthquake does become critical when one considers the SSE with its potential for a sudden radiological release from the plant itself.
Presumably, if one postulates an earthquake less than or equal to the SSE, while one could have impacts upon communications and transportation as a consequence of the earthquake, nonetheless the plant would not pose an immediate j
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radiological hazard.
If, however, one postulates an earthquake in excess
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of the SSE, then one has the potential for a very real radiological 1
hazard complicated by the nonradiological impacts posed a major
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In both FEMA's and Staff's view, such a contingency does not
- 1 warrant specific emergency planning efforts due to th_e remote likelihonef of its occurrence.
In addition, the characterisites of an accident which coulbheoretically be created by an earthquake larger than the SSE would not be outside the spectrum of accidents considered in NUREG-0396 upon
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which the judgment on planning zone sizes and other planning elements were based. Also, to provide an adequate emergency response for such an occurrence would require a commitment of societal resources of great magnitude. Such a commitment is not warranted given the low likelihood of occurrence of earthquakes in excess of the SSE. Consequently', due to
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1 the remote likelihood of its occurrence and due to the great commitment
't of resources required both the FEMA
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.I f-Radiological Emergency Preparedness Staff and the NRC Staff are of the view that earthquakes more severe than the SSE need not be explicitly considered for emergency planning purposes. As noted above, however, as
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a consequence of planning for moderate earthquakes, a planning base is si ff
, available in the event of the less likely larger earthquake.
II. Selection of Emergency Plannina Zone (EPZ) Size The size of the EPZs are substantially set by regulation. The Commission's regulations on this point-read:
Generally, the plume exposure pathway EPZ for nuclear 4
power plants shall consist of an area of about 10 miles (16 km.) in radius. And the ingestion patNay EPZ shall consist of an area of about 50 miles (80 ii km.) in radius. The exact size and configuration of the EPZ surrounding a particular nuclear power reactor D,
shall be detemined in relation to local emergency
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response needs and the capabilities as they are affected by such conditions as demography, topography, land characteristics, access roads and
!f jurisdictional boundaries.
The size of EPZs may also be determined on a case-by-case basis for gas-cooled o
nuclear reactors and for reactors with an authorized a
power level less than 250 MW thermal.
Consequently, while the size and configuration of EPZs may be affected by the conditions indicated, it is the NRC Staff's position thaf.
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the Commission's intent was that variability in size would be minimal, _
i.e., perhaps 11 miles, perhaps 9 miles. However, in no case was the j
detemination of an EPZ to be considered g initio on a case-by-case l1 -
l basis. Such consideration'. were reserved for gas-cooled reactors or for 11 reactors with limited power levels.
With respect to large power reactors such as those at San Onofre, t,.
y only minimal variation of the 10 mile and 50 mile limits was in, tended to a
suit the peculiarities of a local site. Consequently. some judgment i
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must ba employed to fimly set the shape of the EPZs but the Commission's regulations place a limit to the degree of judgment needed. The regulations would not mandate EPZs substantially different from the 10-and 50-mile EPZs which have been set by regulation.
Under the regulations, it is then the task of emergency planning l
officials to consider the specific conditions at each site and to delimit the EPZs to be used for emergency planning within the above constraints.
Should offsite authorities choose to expend resources to extend EPZs to large distances, compliance with the regulations would not be affected as long as such' planning did not reduce the level of preparedness called for by the Commission's regulations within the EPZs called for by the
'1 Commission regulatiois'.
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Infomation relative to the factors considered in setting EPZ size is, evaluated by FEMA during its review of the' off-site plans. No site-
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,y specific studies are required to detemine EPZ size. The points of signi-a ficance for the determination of the actual boundaries is whether the boundary is clearly defined, San be readily ccmmunicated to the public, and accounts
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for local conditions near the nominal 10 mile or 50 mile boundary so that those members of the public within the EPZs who would be affected by protective action r'ecommendations would be planned for.
1 I declare under penalty of perjury that the foregoing is true and correct.
Executed on June 1 1,1981.
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's, Brian K. Gri,mes
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.-..--__.-__._l dh UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE C0ffilSSION In the Matter of PACIFIC GAS AND ELiCTRIC COMPANY
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Docket Nos. 50-275 OL
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50-323 OL (Diablo Canyon Nuclear Power Plant )
Units 1 and 2)
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CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S MEMORANDUM REGARDING CONSIDER-ATION OF EFFECTS OF EARTHQUAKES ON EMERGENCY PLANNING (CLI-84-4)" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or as indicated by an asterisk through deposit in the Nuclear Regulatory Comission's internal mail system, this 3rd day of May, 1984:
o Samuel J. Chilk John F. Wolf Esq., Chairman Office of the Secretary Administrative Judge U.S. Nuclear Regulatory Comission Atomic Safety and Licensing Board Panel Washington, DC 20555*
U.S. Nuclear Regulatory Comission Washington, DC 20555*
- j Herzel H. E. Plaine, Esq.
Mr. Glen 0. Bright 1
General Counsel Administrative Judge j
Office of the General Counsel Atomic Safety and Licensing Board Panel l
U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission
.l Washington, DC 20555*
Washington, DC 20555*
t Dr. John H. Buck Dr. Jerry Kline l
Atomic Safety and Licensing Appeal Administrative Judge
.i Board Panel Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, DC 20555*
Washington, DC 20555*
Dr. H. Reed Johnson Philip A. Crane, Jr., Esq.
Atomic Safety and Licensing Appeal Pacific Gas and Electric Company Board Panel P.O. Box 7442 U.S. Nuclear Regulatory Comission San Francisco, CA 94120 Washington, DC 20555*
Thomas S. Moore, Chainnan Mr. Frederick Eissler Atomic Safety and Licensing Appeal Scenic Shoreline Preservation Board Panel Conference, Inc.
U.S. Nuclear Regulatory Comission 4623 Nore Mesa Drive Washington, DC 20555*
Santa Barbara, CA 93105
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. Elizabeth Apfelberg David S. Fleischaker, Esq.
1415 Cozadero P.O. Box 1178 San Luis Obispo, CA 93401 Oklahoma City, OK 73101 Mrs. Raye Fleming Mr. Richard B. Hubbard m
1920 flattie Road MHB Technical Associates
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Shell Beach, CA 93449 1723 Hamilton Avenue - Suite K j
San Jose, CA 95125 i
Richard E. Blankenburg, Co-publisher Wayne A. Soroyan, flews Reporter Mr. John Harrs, Managing Editor South County Publishing Company San Luis Obispo County i
P.O. Box 460 Telegram-Tribune Arroyo Grande, CA 93420 1321 Johnson Avenue P.O. Box 112 Mr. Gordon Silver San Luis Obispo, CA 93406 firs. Sandra A. Silver 1760 Alisal Street fir. Thomas H. Harris, Energy Writer San Luis Obispo, CA 93401 San Jose fiercury News 750 Ridder Park Drive Joel R. Reynolds, Esq.
San Jose, CA 95190 John R. Phillips, Esq.
.i Center for Law in the Public Maurice Axelrad, Esq.
Interest Newman & Holtzinger, P.C.
10951 West Pico Boulevard 1025 Connecticut Avenue, N.W.
Third Floor Washington, D.C.
20036 2,l Los Angeles, CA 90064
! 1 Docketing and Service Section il Arthur C. Gehr, Esq.
Office of the Secretary Snell & Uilmer U.S. Nuclear Regulatory Consnission 4
3100 Valley Center Washington, DC 20555*
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Phoenix, AR 85073 Mr. H. Daniel Nix Paul C. Valentine, Esq.
California Energy Comission
- I 321 Lytton Avenue MS-17 Palo Alto, CA 94302 1516 9th Street 1
Sacramento, CA 95814 Harry fl. Willis Seymour & Willis Atomic Safety and Licensing
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601 California St., Suite 2100 Soard Panel San Francisco, CA 94108 U.S. Nuclear Regulatory Comission
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Washington, DC 20555*
Janice E. Kerr, Esq.
Atomic Safety and Licensing Appe~al Lawrence Q. Garcia, Esq.
Board Panel 350 McAllister Street U.S. Nuclear Regulatory Comission San Francisco, CA 94102 Washington, DC 20555*
itr. James 0. Schuyler, Vice President liichael J. Strumwasser, Esq.
fluclear Power Generation Susan L. Durbin, Esq.
Pacific Gas & Electric Company Peter H.'Kaufman, Esq.
77 Beale Street 3580 Wilshire Blvd., Suite 600 San Francisco, CA 94106 Los Angeles, CA 90010
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- l. t Bruce florton, Esq.
Lewis Shollenberger, Esq.
Nurton, Burke, Berry & French, P.C.
Regional Counsel 2002 E. Osborn Road USNRC, Region V P. O. Box 10569 1450 Maria lane, Suite 201 Phoenix, AZ 85064 Walnut Creek, CA 94596 t
j tir. Lee it. Gustafson i
Pacific Gas and Electric Co.
j 1050-17th Street, N.W.
llashington, DC 20036-5574 4
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.awrence J. Chandler Special Litigation Counsel J
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