ML20105D383
| ML20105D383 | |
| Person / Time | |
|---|---|
| Site: | 05000000, San Onofre |
| Issue date: | 08/04/1981 |
| From: | Grimes B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20105C680 | List: |
| References | |
| FOIA-84-378 OL, NUDOCS 8502090668 | |
| Download: ML20105D383 (7) | |
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' UNITED STATES.0F AMERICA 4
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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4 SOUTHERN CALIFORNIA EDISON COMPANI,
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Docket Nos. 50-361 OL
.P ETA 1 50-362 OL h
(San Onofre Nuclear Generating Station, Units 2 and 3)
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AFFIDAVIT OF BRIAN K. GRIMES My name is Brian K. Grimes.
I am Director, Division of Emergency Preparedness,
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Office of Inspection and Enforcement, U. S. Nuclear Regulatory Comission,
- j Washington, D. C.
My professional qualifications were attached to my June 22,
,j 1981 affidavit in this proceeding. This affidavit is submitted to address the f;
areas of emergency planning earthquake considerations as a supplement to my June 22, 1981 affadivit.
As stated in my affidavit of June 22, 1981 with regard to emergency planning earthquake considerations, a fundamental premise in the approach to f.
1 emergency planning utilized by the Federal Emergency Management Agency (FEMA) h
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and the NRC is that emergency plans must be developed to facilitate response h
to a wide spectrum of accidents. This is accomplished by considering a wTde
spectrum of accidents in the development of a planning basis - a spectrum j
of accidents which includes rapid releases of large fractions of the reactor a
4 core inventory in a short period of time.
(All of the WAS!!-1400 scenarios were considered in NUREG-0396 in developing the planning basis. The PWR-2 accident rom,t M j
in the WASH-1400 study would result infrele[ses of radioactive material comparable h
to those postulated to result from a catastrophic rthquake in the' Board's b
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July 29,1981 Order.) Although such scenarios are of extremely low likelihood,
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a judgment was made by the staff and the Commission that the planning basis' I
would adequately enhance existing ad hoc capabilities to deal with catastrophic i
events.
i; The conclusion of the staff (as reflected in NUREG-0396 and NUREG-0654 and, I believe, by the Comission in its emergency preparedness regulations published on August 19,1980) was that site specific analyses are not required
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i for the extremely large releases already considered in the generic studies.
The Board appears to assume that the lack of such site specific studies is a U
deficiency which on its face requires additional consideration in this proceeding.
[i I conclude that the Comission's treatment of the accident spectrum question.
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which included ample opportunity for public comment (both on NUREG-0396 and on the Comission's proposed emergency planning regulations) obviates the need
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for site specific consequence evaluations with regard to emergency preparedness.
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I have several specific coments with respect to the Board Order of J.
]l July 29,1981, which relate to the Board's characterization of the staff's
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position and the clarity of the Board's proposed issue.
First, the staff assumed that roadways could be disrupted even in moderate
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earthquak'es and has required the licensee to have the capability to obtain '
damage estimates to transportation facilities offsite to provide a data base to
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- j factor into the decisionmaking process and to have available a range of EI*
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recomendations to offsite authorities. Analyses of specific catastrophic 4
ll earthquake effects are not especially useful to planning as the exact consequences cannot be predicted in advance.
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The Board states that the staff has transplanted the SSE concept to emergency preparedness. What the staff in fact argued was that the SSE concept is a meaningful one in any detailed discussion of earthquake considerations in the emergency planning area and is consistent with the staff's application of the planning basis concept which was developed specifically for emergency preparedness considerations to allow generic consideration of a wide spectrum of accidents. The rationale for the emergency planning basis already includes worst case accidents, including those which might be initiated by seismic events. As stated in rqy June 22, 1981 affadavit "...the characteristics of an accident which could theoretically be created by an earthquake larger than the SSE would not be outside the spectrum of accidents considered in NUREG-0396 upon which the judgment on planning zone sizes and other planning elements were based." The Board is asking for site specific consideration of an accident whose consequences were within the spectrum of accidents considered in developing the Comission's emergency preparedness regulations, syfws b WithrespecttotheBoard'sproposedissue,theBoar8assumefthatevacuption A
f"? h is a desirable alternative.in the case of a catastrophic earthquake and release 3
lk from the facility.
Evacuation would not be the appropriate response in such a Evacuation is not recommended as the imediate action for any sho[t l
case.
ll time scale release where the evacuation is doubtful of completion before 4
- j the exposure would occur. The staff's recomendations in such an event would
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be to instruct the population to take shelter (see Appendix 1 of NUREG-0654, p 1-17, General Emergency item 4.c.).
The appropriate action after plume passage would then be to relocate exposed individuals out of the contaminated j;
area, which would likely be a narrow area on which deposition of particulate 7
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r 4-4 material occurred during plume passage. This relocation effort would result in available resources being focused on a small area within the plume exposure l
EPZ but, because of the magnitude of the postulated release, ad hoc efforts would i
need to be extended well beyond the EPZ under the " footprint" of the plume.
Although the events evaluated in WASH-1400 (and presented in NUREG-0396) assumed relocation would occur within about four hours after plume passage, relocation within about one day would still provide substential benefits in tenns of dose reduction.
The above discussion does not treat the other likely effects of such a catastrophic event such as fatalities which would occur if homes collapsed.
Those involved in such an earthquake would receive priority attention from the j
full resources of the U. S.' government and such aid would not be restricted to the licensee or the State and local responding jurisdictions as implied in the Board's statement of the issue.
In view of the at. e discussion, it is not clear what the Board would consider " timely" evacuation or protection for those in the EPZ. The Board i
should recognize an important aspect underlying the emergency preparedness j
regulations. That is, in the worst case accidents (from whatever scenario) fatalities cannot be ruled out even with emergency p'reparedness measures that i
fully meet the Commission's regulations. The Board assumes that a test of I
adequacy can be obtained by postulatir.g worst case events while the Consnission's t
L regulations take an entirely different approach to the matter.
Even if one were to procede with the Board's approach, it is not clear fro ~ the Board's Order whether a discussion of accident consequences is desired.
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(The consequences, as noted above would be similar to those of the WASH-1400 3
PWR-2 case which results in a large, fast release at near-ground level.)
i In summary, emergency planning for the San Onofre site has included 7
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consideration of both large accidents and earthquake effects. The combination
.j of responses to these effects, while highly dependent on the actual situation, i!
has been considered by providing for a feedback of offsite conditions to the 11
)i licensee so that recommendations.for protective actions related to radiological i;
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hazards can be appropriately adjusted. The added postulate of the Board of 1'
an extremely large earthquake and radiological hazard does not affect the type of response but only the degree to which additional outside resources would
'i need to be called on to supplement the local and State response. The mechanism for bringing these additional resources into play is the same as in any large j
disaster situation in which the Federal Emergency Management Agency (FEMA) i serves as the coordinator of the total available civilian and military resources of the U. S. Government. The NRC and FEMA staffs could provide testimony on
- I how this is done in practice if this would be of assistance to the Board.
g I declare under penalty of perjury that the foregoing is true and correct.
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Executed on August 4, 1981.
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a Brian K. Grimes t
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l
In the Matter of
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y SOUTHERN CALIFORNIA EDISON COMPANY, Docket Nos. 50-351 OL q'
50-362 OL (SanOnofreNuclearGeneratingStation.
Units 2 and 3)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF COMMENTS WITH RESPECT TO THE BOARD"S ORDER OF JULY 29,1981 RAISING AN ISSUE CONCERNING EARTHQUAKES AND EMERGENCY PLANNING" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or q
as indicated. by an asterisk by deposit in the Nuclear Regulatory Comission's internal mail systep this a*h day of August.198h
- James L. Kelley, Esq., Chairman David R. Pigott, Esq.
Administrative Judge Samuel B. Casey, Esq.
Atomic Safety and Licensing Board John A. Mendez. Esq.
U.S. Nuclear Regulatory Commission Edward B. Rogin, Esq.
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Washington, D.C.
20555 Of Orrick, Herrington & Sutcliffe A Professional Corp. oration o
1 Dr. Cadet H. Hand, Jr.,
600 Montgomery Street Administrative Judge San Francisco, California 94111 j
c/o Bodega Marine Laboratory University of California Alan R. Watts, Esq.
P. O. Box 247 Daniel K. Spradlin l
Bodega Bay, California 949'23 Rourke & Woodruff 10555 North Main Street Mrs. Elizabeth B. Johnson, Suite 1020 1
Administrative Judge Santa Ana, California 92701 j
Oak Ridge National Laboratory 4; -
P. Q. Box X, Building 3500 '
' Richard J. Wharton, Esq.
Dak Ridge, Tennessee 37830 University of San Diego School of Law Alcala Park Janice E. Kerr, Es San Diego, California 92110 J. Calvin Simpson,q.Esq.
Lawrence Q. Garcia, Esq.
Mrs. Lyn Harris Hicks California Public Utilities Commission GUARD i
5066 State Building 3908 Calle Ariana San Francisco, California 94102 San Clemente, California 92672 s
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' Charles R. Kocher, Esq.
A. S. Carstens James A. Beoletto, Esq.
2071 Caminito Circulo Norte Southern California Edison company Mt. La Jolla, California, 92037 2244 Walnut Grove Avenue Rosemead, California 91770
- Atomic Safety and Licensing Board Panel.
David W. Gilman U.S. Nuclear Regulatory Commission Robert G. Lacy Washington, D.C.
20555 San Diego Gas & Electric Company P. O. Box 1831
- Atomic Safety and Licerising Appeal San Diego, California 92112 Board Panel
' U.S. Nuclear Regulatory Commission Phyllis M. Gallagher, Esq. ~,
Washington, D.C.
20555 1695 West Crescent Avenue Suite 222
- Secreta ry Anaheim, California 92701 U.S. Nuclear Regulatory Commission ATTN:
Chief, Docketing & Service Charles E. McClung, Jr., Esq.
Branch j
Fleming, Anderson, McClung & Finch Washington, D.C.
20555 23521 Paseo De Valencia Suite 308A e
Laguna Hills, California 92653 1 ;*
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