ML20125C603
| ML20125C603 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Diablo Canyon |
| Issue date: | 08/10/1984 |
| From: | Asselstine J NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20125C531 | List: |
| References | |
| FOIA-84-814, FOIA-84-A-82 NUDOCS 8506120094 | |
| Download: ML20125C603 (17) | |
Text
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UNITED STATES
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q NUCLEAR REGULATORY COMMISSION n
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. E WASHIN GTON. O.C. 205SS C O 4
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OFFICE OF THE
- Aucust 10, 1984
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CO'a'.* t SSIO N E R
!!EMORANDUti FOR:
Samuel J. Chilk, SECY
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FROM:
James K. Asselstine p _- - >
SUBJECT:
DISSENTING VIEWS Of! DIABLO CANYON ORDERS Atuched are final versions of my dissenting views on both the Diablo Canyon orders - earthquakes and emergency planning and immediate effectiveness.
Please attach them to the ap'propriate Comission order.
cc: Chairman Palladino Comissicner Roberts Comissior.er Bernthal Comissioner Zech
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OGC OPE SECY e.
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BELLB4-A-82 PDR k_
['lSSENTIliG VIEWS OF C0tMISSI0ilER ASSELSTIllE I am unable to vote in favor of the issuance of a full pcwer operating license for Diablo Canyon Unit 1 at this time because of the Comission's treatment of two issues:
the complicating effects of earthquakes on emergency planning, and the re-evaluation of the adequacy of seismic design for small and large bore piping in the plant. The Ccmission's decision regarding the effects of earthquakes on emergency planning is being addressed in a separate order, and my views on the Comission's handling of this issue wil.1 be set forth in detail there.
Suffice it to say here that this issue is materia.1 to the Comission's licensing decision in the Diablo Canyon case and that the Comission is compelled as a matter of law and logic to afford the parties to this proceeding an opportunity to litigate the issue prior to authorizing the issuance of a full power license for the plant.
Ilith regard to seismic design, the record of this proceeding, allegations filed by former workers at the site and subsequent NRC inspections, including those performed by NRC inspector Isa Yin, all document a widespread quality assurance breakdown in the. seismic design work for small bere piping in the plant. This quality assurance break-down raises serious questions regarding both the adequacy of quality assurance for other design activities for the plant and the adequacy of the Indeper: dent Design Verificaticn Program (IDVP). Those questions are cf special irfortance for the IDVP, which was established to verify that the seismic design problers that led to the Comission's suspension of the Diable Cenyon low pcwer license had been identified and corrected.
These questions existed at the time that the Commission authorized the reinstatement of the low power license for Diablo Canyon Unit 1.
L' hen I voted to permit low power operation, it was with the understand-ing that Mr. Yin and other elements of the NRC staff were in agreement on the measures needed to resolve those questions prior to a Commission decision authorizing full power operation.
I am particularly disap-pointed in the staff's subsequent handling of Mr. Yin's concerns. Given the special significance of seismic design for this plant and the extent of the quality assurance breakdown in the se'ismic design progran for 4
portions of the plant, it was incumbent on the NRC staff to make every effort to verify that all significant design errors had in fact been l
identified and corrected.
Based upon the continuing concerns expressed by Mr. Yin regarding the adequacy of the staff's verification efforts and the extent of the seismic design quality assurance breakdown in the i
case, I am not yet satisfied that the Commission has the information needed to conclude, with a high~ degree of confidence, that all signifi-i cant seismic design errors for this plant have been identified and corrected. The Agency's handling of these questions is particularly unfortunate since the adequacy of the seismic design of the plant is a natter of public concern and since it appears that an adequate design verification program to resclve Mr. Yin's concerns could be completed in a matter of a few weeks.
s Eiablo Canyon - Earthquakes and Ecergency Planning Dissenting Views of Commissioner Asselstine The Ccmmission's performance in its handling of this issue--the ccmplicating effects of earthquakes on emergency planning--is most disappointing.
In its apparent determination to avoid adjudicating an issue that the agency itself has acknowledged to be material to emergency planning, the Comission has -repea.tedly changed its mind about how to treat this issue only to end up right back where it started three years aco--promising a generic rulemaking.
In the meantime, the Comission's only accomplishment has been to deny parties the right to adjudicate the issue and to delay any action on this issue until the only two plants, Diablo Canyon and San Onofre, for which this issue probably has any real significance have been licensed.
I cannot agree with the Commission's decision or its reasons for reaching that decision. The Commission's decision ignores fundamental principles of emergency planning, offends common sense, and abuses the j
legal process.
I would recognize the obvious--that earthquakes ought to be considered for plants located in areas of high seismicity such as California, and let the parties adjudicate the specifics in individual cases.
I would provide the perties to the Diablo Canyon proceeding an opportunity for a hearing and let them litigate whether the Diablo l
C6nyon emergercy plan is flexible enough to deel with the complicating effects cf earthquakes en emergency planning.
[
w l
History The history of the Concission's handling of this issue shows exactly why the Commission's decision today is so disturbing.
Rather than sitply allowing the issue to be considered by a licensing board, a step that probably would have added about a week of hearing time to the San Onofre and Diablo Canyon proceedings, the Commission has instead followed a tortuous path from adjudication to generic rulemaking to case-by-case consideration, to generic adjudication, only to end up right back at generic rulemaking.
In early 1981 the staff took the position in the San Onofre proceeding that consideration of the complicating effects of earthquakes up to the Safe Shutdown Earthquake (SSE) was appropriate.
The staff disagreed, however, when the Licensing Board tried to raise sua sponte the issue of the effects of earthquakes exceeding the SSE. The Comission on its own motion ordered the Licensing Board not to consider "the impacts on emergency planning of earthquakes which cause or occur during an accidental radiological release." Southern California Edison Co. (San Onofre Nuclear Generating Station, Units 2 and 3), CLI 81-33, 14NRC1091(1982). The Ccmmission determined that its regulations did r.ot require such consideration and concluded that whether the regulations should require such consideration was a generic issue to be ceciced by rulenking.
San Onofre, 14 HRC at 1091-92 (1981).
O
Cased on the San Onofre decision, the Licensing Board in the Diablo i
Canyon operating license proceeding refused to allow any censideration of the effects of earthquakes on emergency planning at the Diablo Canyon site. There was, therefore, no opportunity to litigate any issue connected with the complicating effects of earthquakes on emergency 1
planning.
After the Diablo Canyon Board's decision, the staff on June 22, 1982, issued a memorandum which stated that it was the staff's technical judgment that a generic rulemaking was not necessary because of the very low likelihood of earthquakes in most parts of the country. However, the staff took the view that for California and other creas of high seismic risk in the Western United States explicit, site specific consideration of the effects of earthquakes on emergency planning is necessary.
As the staff explained:
It is the judgment of the staff that for most sites earthquakes need not be explicitly considered for emergency planning purposes because of the very low likelihood that an earthquake severe enough to disturb onsite or offsite planned responses will occur con-currently with or cause a reactor accident. Planning for earth-quakes which might have implications for response actions or initiate cccurrences of the " Unusual Event" or " Alert" classes in areas where the seismic risk of earthquakes to offsite structures is relatively high may be appropriate (e.g.,forCaliforniasites and other areas of relatively high seismic hazard in the Western U.S.).
liemorandum to the Commissioners from William Dircks, Executive Director for Operations, dated June 22, 1982, entitled
" Emergency Flanning and Natural Hazards," p.1.
The staff wcnt on to sey that it requests appliccnts for licenses for Celifornia facilities and the Federel Emergency Management I.gency (fella)
4 to censider eartho.uake effects in their energency planning and review.
Percrandum of June 22, 1982, Enclosure at 3-4. In fact, at both San Onofre and Diablo Canyon the staff required the license applicants to specifically consider this issue.
The Commission realized that this position by the staff seerred to contradict the Corraission's San Onofre decision and thus cast doubt on the validity of the Licensing Board's ruling in the Diablo Canyon case.
The Comission asked the staff to elaborate and in a further memorandum, the staff repeated its conclusion that " planning for earthquakes which cisht have emergency preparedness implications may be warranted in areas where the seismic risk to offsite structures is relatively high (e.g.
i California sites...)."
fiemorandum to Chairman Palladino from William Dircks, Executive Director for Operations, dated January 13, 1984, entitled " Emergency Planning and Seismic Hazards," p. 2, f.n.2. The staff also stated that it thought current emergency planning review criteria were adequate for this.
I d_.
t Given this position by the staff, the Commission decided to ask the l
perties to the Diablo Canyon proceeding whether and under what circum-stances the effects of earthquakes on emergency planning should be censidered for the Diablo Canyon plant. Pacific Gas and Electric Company 1
(Diablo Canyon fluclear Power Plent, Units 1 and 2), CLI S4-4, 20 NP.C_(/pril 3,1954).
The Commission, referring to the staff's January 19E.: rremorandur, noted thct the staff crpeared "to believe that some specific ccnsideration of the effects of seismic events r:ay be warranted
i t
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for plants located in areas of relatively high seismicity." CLI 84-4, 2
Slip Opinion at 2.
i l
In its response to the Commission's order, the staff attempted to fl reverse course.
Staff Counsel explained that while staff stated in its i
January 13, 1984 memorandum that " seismic events are considered and evaluated to a limited extent as part of our current emergency planning 1
reviews, those staff reviews are infonnal and do not reflect a required licensing element which must be satisfied in order to warrant issuance of a license".I "NRC Staff's Memorandum Regarding Consideration of Effects of Earthquakes on Emergency Planning (CLI-84-4)", dated May 3, j
1984, p.3, f.n.2.
Commission Decision l
i l
In its decision today, the Comission has concluded that there is no i
reason to depart from its decision in San Onofre that the NRC's regulations "do not require consideration of the impacts on emergency j
planning of earthquakes which cause or occur during an accidental release," for Diablo Canyon and that the determination of whether to i
IThe flaw in the staff's argument is obvious.
Having acknowledged that it is concerned enough about the issue to require licensees to censider it, the staff cannot now argue that " informal" review by the i
staff is a satisfactory substitute for formal review in individual licersing proceedings.
If the issue is material to the Comission's licensing decision, as the staff's own statements ar.c actions ccncede, j
then the egency must adnit that sctisfactory resoluticn of the issue is l
a required licer. sing eierent.
\\
amend the regulations to include the consideration of earthquakes should be addressed cs a generic matter.
(CLI-84 _) Slip Op. at 1.
There are several problens with the Comission's decision and its underlying rationcle.
The cornerstone of the Commission's decision is the Commission's ccr.clusion that the probability of an earthquake disrupting an emergency response is so low that it need not be considered in emergency planning.
The basis for the Comission's conclusion is its detemination that for various reasons there is unlikely to be a radiological release and an earthquake at the same time. The Connission's arguments on this score l
ignore one of the fundamental precepts of emergency planning: we plan for low prcbability occurrences because no matter how safe we try to make nuclear power plants there is always a possibility that some event will occur which will require use of one or more aspects of emergency planning. The probability arguments used by the Comission are really arguments that we do not need any emergency planning, rather than that we need not consider earthquakes in emergency planning. The Comission l
l simply asscrts that there is a low likelihood of a release ar:d an earthquake at the same tirae and assunes that that ends the inquiry.
l l
Unfortunately, the CerTaission ignores the fact that safety calculatiens are subject te seme uncerteinties.
The philosophy behind etergency pier. ring is to iccegnize this uncertainty and to previde defense in depth in protecting the public.
Inceed, the Commissicr.'s emergency
- w planning regulations are founded on the judgment that adequate emergency planr.ing is an essential element in protecting the public health and safety incependent of the Comission's other regulations and safety reviews focusing on the design of the plant itself. Obviously, we do not plan for every conceivable but highly unlikely event.
We should not, for example, waste resources planning for the effects of hurricanes on emergency responses in Kansas or for snow in Southern California.
Instead, we plan to take into account the natural phenomena which present the more likely risks for a particular area. Thus, we consider hurricanes for plants in Florida, tornados for plants in the Midwest, j
and volcanic eruptions in the Pacific Northwest. By the same token, we should consider the complicating effects of earthquakes for plants in 3
high seismic risk areas such as California.
n The Comission tells us, however, that the prcbability of an earthquake disrupting an emergency response in an Emergency Planning Zone (EPZ) is too low even to be considered. To apply this argument to California, where almost 90 percent of the seismic activity in the United States
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occurs and where earthquakes which damage, obstruct or disrupt roads, buildings, bridges and comunications networks occur with some regularity, simply ignores common sense.
In support of this assertion, j
the Comission contends that the Dicblo Canyon site is located in an l
erea of low to ecderate seismicity.
This argument is based upon an ar,alysis ir. the record of the recurrence rate for earthquckes in the
.entral Celifornia ccastal regien for the years 1950 through 1974. What
- he Octmission does not riention, however, is that.the only plent in the i
3 country with a comparable SSE and OBE (Operating Basis Earthquake)--the key bases for the seismic design of the plant--is San Onofre (.679 and
.349 respectively).
In fact, the SSE's and OBE's for plants in other parts of the country are significantly lower (for other plants the SSE is typically.25g or less and the typical OBE is.11
.12g, with the hichest being.13g) than those for Diablo Canyon (SSE of'.759 and OBE of i
.20g).
Clearly, by requiring the plant to be designed to withstand an earthquake with ground motions almost twice those of other plants in the country, the Commission explicitly made the technical judgment that the earthquake risk for the Diablo Canyon area is not comparable to other areas of the country, and is, in fact, muc;. higher.2 i
2 Survey (USGS)yavailableinformationcompiledbytheU.S. Geological Publicl 1-would seem to indicate that earthquakes of sufficient magnitude to cause possible damage, obstruction or disruption to roads, buildings, bridges and comunication networks occur throughout many parts of California, including the San Luis Obispo area, with some reSula rity.
" Earthquake History of the United States", Publication l
41-1, 1982 Reprint with Supplement.
According to this information, four l
earthquakes have occurred in the imediate San Luis Obispo area since 1830, and at least one of these earthquakes has been of magnitude 7-8 on j
the l'odified tiercalli scale. Jd.,pp.138,140,141,156,162,164.
In i
addition, two other earthquakes, of magnituies 6.5 and 7.5, have cccurred within 50 miles of the Diablo Canyon site since 1922.
" Earthquake Epicenter Map of California, 1900 through 1974", State of California, the Resources Agency, Department of Conservation 1978. This publicly available informaticr., although not in the record of the Diablo Caryon proceeding, would also appear to contradict the Commission's l
assertions regarding the frequency of occurrence of earthquakes in the vicinity of the Diablo Canyon site which are sufficiently severe to i
i etuse damage to structures and disrupt communications, kuch of this I
sare information is also in the FSAk for Diablo Canyon, which is a part I
of the record in this proceeding.
I l
.g.
r Further, the Commission's argument must be considered in light of the other natural phenomena the Comission includes in its consideration of emergency planning.
If the probability of an earthquake disrupting an emergency response in an EPZ in California is too unlikely to be considered, that probability must by definition be much lower than the probability of disruption caused by the other natural phenomena which the Corxaission does consider.
It must, for example, be less likely than the probability that a tornado will disrupt an emergency response in an EPZ in the tiidwest or that a hurricane will disrupt an emergency response in a California EPZ.
l The probability that a tornado will travel through a particular 10 mile area and thereby initiate or disrupt response to an emergency at a nuclear plant must be quite low; yet, the Comission requires consideration of that issue for certain plants.
Similarly, the probability of a hurricane striking the San Luis Obispo coastal area and initiating or disrupting an emergency response must also be quite low; i
yet, the Comission considered that very issue in the Diablo Canyon case.
I see no factual basis for the Comission's assertion that f
earthevakes in California tre so much more unlikely than either of these i
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events that carthouakes need not be considered.
Tht Comission's order also misses another very inportant point.
Dr.ergency plenning is not relevant only to accioents resulting in the 1
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offsite release of radiation.
Er.ergency planning is also relevant for respcnses to ercrgencies which do not rctuit in a radiological release,
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including emergencies initiated or complicated by earthquakes below the l
SSE.
For example, whether or not an earthquake results in the offsite release of radioactivity, an emergency plan must take into account the assurance of continued ccmmunication between a plant and offsite emer-gancy response agencies, the ability to obtain damage estimates for the plant and the offsite transportation and communication facilities to provide data for decisions on appropriate responses, the availability of backup facilities to ensure continued functioning of an emergency response capability, and the ability to transport necessary personnel to a plant to deal with the emergency.
In its June 22, 1982 memorandum to the Connission, the NRC staff recognized this:
"There is no explicit guidance in [the Comission's regulations] as to the extent to which adverse earthquake conditions are to be i
taken into account in emergency planning at particular sites...The occurrence of earthquakes of a nature that could have implications for onsite or offsite response actions or initiate occurrences of the " Unusual Event" or " Alert" class is an adverse characteristic of o
the type discussed above." Memorandum at 3-4.
The staff went en to note that they ask applicants for licenses for California facilities and FEl% to consider such earthquakes (smaller than the Safe Shutdown Earthquake) in their emergency planning for this very reason.
l l
The Comission simply ignores the fact that the staff has been requiring licensees for plants located in California to consider the effects of earthquakes un crergency pitnning.
The staff has stated that while it does r.ct think such considerttion is neccssary for plcnts in most areas j
of *.he ccuntry, " planning for carthquakes which might have emergency
'w preparedness irplicatiens may be warranted in areas where the seismic risk to offsite structures is relatively high (e.g. California sites.)"3 Memoranda of June 22, 1982, and January 13, 1984.The complicating effects of earthquakes on emergency planning were formally censidered by the staff in the San Onofre proceeding, and were informally considered by the staff for Diablo Canyon.
By their own actions, the agency's technical experts have demonstrated that they consider this issue to be material to the Comission's licensing decisions in these two cases, j
Given the fact that the staff experts on this issue have been concerned I
enought to consider it, I see no basis for the Comission's argument that in the cases of Diablo Canyon and San Onofre, seismic effects on i
emercency planning are irrelevant.
Since the issue is clearly material j
oo the agency's licensing decision in those two cases, the Comission is required by law to grant the parties an opportunity to litigate that i
issue.
See, UCS v NRC, No. 82-2053 (D.C. Cir. May 25,1984.)
4 l
4 3 In its response to the Comission's order, staff ccunsel attempted to withdraw this conclusion. The fact remains, however, that staff has indeed been considering the complicating affects of earthquakes on i
emergency planning at California plants, including Diablo Canyon.
Staff required PG&E to prepare a report on this issue.
Presumably, the staff does not ask license applicants to look at issues which it thinks are 2
irrelevant.
Perhaps the staff's new position has something to do with the fact that for the only two plants located in "high seismic areas",
l the staff has now ccepleted its review of seismic effects on emergency planning, ibis appears to be the only plausible reason 1or such a radical change in staff's position. Further, staff explained that what it really war.ted was to censider this issue, but only " informally".
Set, ebove at p.5.
Apparently recognizing the weaknesses in their low probability argument, ry colleagues have also attempted to support their decision by arguing that the disruption to emergency response caused by fog, hurricanes and heavy weather are similar to the disruptions which may result from an earthquake.
Thus, the Comhsion argues, emergency plans implicitly have enough flexibility to deal with earthquakes as well' This is an interesting argument.
Unfortunately, the Comission cannot point to any evidence in the record of this proceeding to support such a factual firding. Although the Diablo Canyon record includes information on natural phenomena other than earthquakes, there was no discussion in that record of earthquakt effects, or whether the plans for dealing with other natural phencrena are flexible enough to implicitly include the effects of earthquakes. The Coceission's conclusion seems, therefore, to be based on the Comission's intuitive feeling that the finding ought to be true rather than on any kind of factual record.
This is precisely the type of factual question that should only be decided based upon a site-specific, factual record, developed and tested in a hearing (or at least after consideration of infomation in the record of a rulemaking specificallyaddressingthisissue.)
Fint.11y, the Cemission has decided that the regulations are not sufficiently cicar on whether earthcuakes must be censidered in emergen.
cy planning and so intends to conduct a generic rulemaking on the isste.
The Comission disagrees with the staff's view that a generic rulemaking is rct recessary, although it r,ffers ne persuasive rceson for rejecting
., a I
the staff's technical judgment on this question. Unfortunately, the Comission's belatedly renewed promise of a generic rulemaking appears te be little more than window dressing.
The Commission's justification for not considering seismic effects on emergency planning at Diablo Canyon clearly shows that it has already decided the issue.
If the i
l Comission will not require the consideration of earthquakes for plants located in er rea of the country where 90 percent of the seismic i
activity occurs, it is unlikely to conclude that they must be considered for plants elsewhere.
Since the Comission appears to have already decided this fundamental issue, it is unclear what it hopes to j
accomplish with such a rulemaking.
I have agreed to the Commission's i
decision to conduct such a rulemaking, but only because some I
consideration of this issue is better than no consideration at all.
i l
It is absolutely amazing, the lengths to which the Comission will go to l
avoid finding that a party is entitled to a hearing on an issue.
In i
this case, the Commission has constructed an elaborate, but flawed, rationale in an attempt to explain why ettthquakes need not be considered in emergency planning for Diablo Canyon. The Comission has i
then proceeded, as a factual matter, to consider the effects of I
earthquakes on emergency planning. As a last resort, the Commission has i
again promised to conduct a generic rulemaking on this issue, a promise that it made three years ago but did not keep. The unfortunate censequence of this delay has been to put the issue off until the two Califorr.ia plants have been licensed.
F i
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/'N usneosutis
/.k NUCLE AR REGULATORY COMMisslON fi
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wAssiscTos o e rosss JAN 131984 l
3 J
,Y MEMORANDUM OR:
Chairman Pallad FROM:
Willia
. Dircks s%
ive Director for Operations
SUBJECT:
EMERGENCY PLANNING AND SEISMIC HAZARDS l
On September 9, 1983, a meeting was held with you to discuss the Staff's views on the need for and extent of consideration of the potentially compli-cating effects of earthquakes in the context of emergency preparedness.
Please recall that this issue emanates from the Comission's Memorandum and Order in the San Onofre proceeding, CLI-81-33, issued in December 1981, in which the Commission determined that "its current regulations do not whichcauseoroccurduringanaccidentalradiologicalrelease."ythquakes require consideration of the impacts on emergency planning of ea The Comission further noted that it "will consider on a generic basis whether regulations should be changed to address the potential impacts of a severe earthquake on emergency planning" and, a memorandum from the Secretary to the I In the San Onofre proceeding, the Licensing Board sought to raise, sua sponte, the issue of the effects of an earthquake exceeding the Safe Shutdown Earth-quake on the applicants' and responding jurisdictions' abilities to carry out an evacuation in a timely manner and/or protect those in the EPZ pending evacuation.
It had been the Staff's and FEMA's positions before the Licensing Board that in that proceeding, while consideration of the complicating effects of earthquakes up to the SSE was appropriate, consideration of the potential of earthquakes exceeding the SSE was not warranted.
The Licensing Board rejected this view and instead affirmed its prior position calling for consi-deration of the potential effects of an earthquake exceeding the SSE. There-after, the Commission, as indicated above, reversed the Licensing Board's decision.
Parenthetically, based on the Comission's San Onofre decision, the Licensing Board, in the Diablo Canyon proceeding rejected a contention regarding consideration of the effects of earthquakes on emergency preparedness.
In an unpublished order issued on March 5,1982, the Comission denied the Governor's request for interlocutory review of the Licensing Board's action. The Licensing Board's ruling was affirmed by the Appeal Board in ALAB-728, slip op, at 20-21 (May18,1983) and review by the Comission was denied (CLI-83-32 December 9, 1983).
q9W I(T p
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Chairman Palladino,
Executive Director for Operations, by memorandum of March 1,1982, directed the Staff to undertake such consideration.
By memorandum to the Commissioners dated June 22,1982 (copy attached). the Executive Directgr responded to the questions posed in the Secre ary's March 1 memorandum.
After our September 9,1983 meeting with you on this subject, you requested further technical discussion to provide a rationale for either including or not including specific emergency planning requirements for seismic events.
The following thoughts are presented to respond to your request:
1.
Offsite Damace Associated With Extreme Seismic Events Offsite damage generated by earthquakes can significantly affect nuclear emergency response.
The earthquake hazard and potential for such damage varies across the United States.
Severe damage, such as the failure of buildinos, bridges, and other engineered structures can typically be associated with large
, damaging earthquakes and their related ground motion levels.
For a large part' of the U.S. east of the Rocky Mountains, where most nuclear power plants are p;."J located, such ground motion levels would be well beyond the Safe Shutdown Earthquake (SSEL For areas associated with higher earthquake hazard, such as h
2 the West Coast, these ground motion levels could be at or even less than the
'SSE.
Suchhighhazardareasmayalsoexistintheeast(forexample,theNew d5 Madrid, Missouri, area), however, no nuclear power plants are presently sited p-within these areas in the east.
2.
The Potential Imoact of Offsite Damace on Emergency Response The impact on emergency response capability from earthquakes is clearly. site region dependent and is generally proportional to the degree of offsite damage.
Tnat is, the higher the intensity of the earthquake, the more extensive and severe is the damage it causes.
For seismic events that result in significant and widespread damage to surrounding areas, the response capability would be degraded through extensive disruption of transportation and comunication 2To very briefly sumarize the Staff's position as expressed in its June 22nd response, the Staff concluded that the Commission's regulations do not require amendmentsince(1)formostsitesthereisonlyaverylowlikelihoodthatan earthquake severe enough to disturb onsite or offsite planned responses will occur concurrently with or cause a reactor accident, and (2) while planning for earthquakes which might have emergency preparedness implications may be warranted in areas where the seismic risk to offsite structures is relatively high (e.g.,
California sites and other areas of the Western U.S.), current review criteria setforthinNUREG-0654(whicharederivedfromtheCommission'sregulationsin 10 CFR 550.47) are considered adequate.
Chaiman Palladino,
networks, and from the failure of major structures.
In this instance the range of protective actions and the capability of the offsite jurisdictions to initiate and implement them could be drastically reduced.
reduction would vary based on conditions in the region around the site.Thedegreeofth1D For example, even with substantial damage to all bridges, a site might have so few bridges in its vicinity that blockage of roads would not be significant.
3.
Plant Damage Associated With Seismic Events Uhen considering the possibilities of plant damage from seismic events, it is important to understand the severity of seismic events, their range of probabi-lities, and the potential for reactor accidents caused by seismic events.
Three classes of seismic events are considered in this discussion.The first class includes earthquakes of relatively low ground motion, up to the Operating Basis Earthquake (0BE).
The OBE ground motion depends on plant location.
These accelerations vary in the range of about,.05g to.109(higherinareas of high seismicity).
remain operating.
During an OBE all plant systems would be expected to The second class of events includes earthquakes with ground motion higher than the OBE but equal to or less than the Safe Shutdown Earthquakes (SSE); the ground motion of the SSE is typically about twice that of the OBE.
Probabili-ties of occurrence for the SSE have typically been estimated to be on the order of one in a thousand or one in ten thousand per year.
that plants be designed to achieve a safe shutdown after an SSE.NRC regulations require Given an SSE, all seismically qualified equipment would be expected to function to bring the plant to safe shutdown.
cause for an alert emergency action level classification.An earthquake up to and However, only in the event of a coincident failure of a safety function (safety systems are designed for the SSE design error) or 3::atundiscovered co man caum fail _ure mechanism (such as a major eLrgmy res)ponse. there be a chance of an accident which would require of fsfte would failure) occurring simultaneously is very much lower than the pro either one, perhops on the order of one in a million per reactor year or less.
The final class of events includes all earthquakes with ground motion levels above the SSE.
Fragility analysis is used to estimate the probability of failure as a function of ground motion associated with these earthquakes.
The Zion, Indian Point, and Limerick Probabilistic Risk Assessments estimated that, in general, ground motion on the order of 0.59 to 0.75g acceleration would be required to damage a nuclear power plant to the extent that significant release of radioactivity could occur.
Of course, some plants, such as those in high seismic regions, are designed to withstand earthquakes with ground motion this high; they would resist damage to still higher levels of ground motion.
The probability estimates for such ground accelerations are significantly less than the probability estimates for the SSE for these plants (the Zion. IP, and Limerick SSEs are.17,.15, and.15 9
9 9 respectively).
The absolute prcbabilities for earthquakes at and beyond the SSE are extremely difficult to estimate and thus have large associated uncertainties.
l l
F Chairman Palladino
- 4.
Current Emeroency Preparedness Considerations Seismic events are considered and evaluated te a limited extent as part of our current emergency planning reviews.
The followina olanning standards, addressed by the licensee, some of which explicitly address (pimir evente.
Arp state and/or local emergency plans as explained in the following sections from NUREG-0654, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants."
II.D.4 Emergency Classification System "Each State and local organization should have procedures in place that provide for emergency actions to be taken which are consistent with the emergency actions recommended by the nuclear facility licensee, taking into account local offsite conditions that. exist at the time of the emergency."
(Emphasis added)
II.H.5.a Emergency Facilities and Equipment "Each licensee shall identify and establish onsite monitoring systems that are to be used to initiate emergency measures in accordance with Appendix 1, es well as those to be used for conducting assessment.
This equipment shall include:
a.
geographical phenomena monitors, (e.g., meteorological, hydrologic, seismic);"
II.H.6.a Emergency Facilities and Equipment "Each licensee shall make provisions to acquire data from or for emergency access to offsite monitoring and analysis equipment including:
(Emphasis added) a.
geographical phenomena monitors, (e.g., meteorological, hydrologic, seismic);"
II.J.10.k Protective Response "The organization's plans to implement protective measures for the plume exposure pathway shall include:
k.
Identification of and meansjor_ dea]Jng_with_ potential impeaments-(e.g., seasonal impassibility of roads) tn u_se of evacuation routes, andfcytingtncy.Jneasurn;"
For each of the emergency response classes given in Appendix 1 of NUREG-0654, severe natural phenomena (including seismic events) are included as part of the
r Chaiman Palladino -
example initiating conditions. The seismic events soecifically included in this appendix are the Oneratino ben Farthnnake. and the Safe Shutdown Earth-
'cuake as well as "any earthquake felt in-plant or detected on station seismit
' ns trJnentation. "
i The preceding show that seismic events are considered in emergency planning but, as is evident, these review criteria are not very clear and clarification of them could lead to some improvements in emergency preparedness, perhaps by leading to more refined analysis of potential road blockage, etc. However, it is not clear that such improvements would substantially reduce the impaiment of emergency response caused by seismic damage offsite.
3 The Federal Emergency Management Agency (FEMA) reviews offsite radiological emergency planning and preparedness to insure the adequacy of Federal, State, and local capabilities in such areas as emergency organization, alert and notification, connunications, measures to protect the public, accident assess-ment, public education and infomation, and medical support.
Detailed, specific 1
assessment of potential earthquake consequences and response are not part of l
this process related to radiological emergencies.
FEMA does. however have an active program of earthouake oranaradness which inF1"dae ae+4=e+== af damane '
i and casualties, planning for Federal response to a major earthquake, and l
assistance to State and local governments in their earthquake planning and preparedness activities. FEMA believes that these seoarate activities th=+
a enncorrent raennnta to I
would comolement each other in tha avan +
auc1=e* nm =" niant was
=ad e nr h accidaat 2+
=
i a y r ese+hanaka required.
j 5.
Risk perspectives Recent pRAs (e.g., Zion, Indian Point) have indicated that very large earthquakes l,
(much greater than the SSE) can dominate the risk from a nuclear power plant.
Such earthquakes can cause massive plant damage leading to immediate offsite radiological hazards.
In addition, massive offsite damage was assumed in these analyses which substantially degraded the emergency response.
i l
Based upon the Pita results, the staff finds that for most earthquakes (including some earthquakes more severe than the SSE) the power plant would not be expected to pose an inriediate offsite radiological hazard.
For earthquakes which would cause plant damage leading to immediate offsite radiological hazards but for which there would be relatively minor offsite damage, emergency response capabilities around nuclear power plants would not be seriously affected.
For earthquakes which cause more severe offsite damage, such as, for example, i
disabling a siren alerting system, the earthquake itself acts as an alerting l
system.
For those risk dominant earthquakes which cause very severe damage to J
both the plant and the offsite area, emergency response would have marginal benefit because of its impaiment by offsite damage. The expenditure of additional resources to cope with seismically caused offsite damage is of doubtful value considering the modest benefit in overall risk reduction which j
t could be obtained.
Chairman Palladino
- 6.
Summa ry Based on the preceding discussion the following summary points can be made:
a.
In general, earthquakes up to and including the SSE are not expected to pose an immediate offsite radiological hazard, b.
Earthquakes beyond the SSE may cause plant damage and radioactive release under conditions where offsite damage impairs energency response.
c.
Further clarification or refinement of current requirements and guidance might reduce the impairment of emergency response indicated in b. above, but the value of such reduction is uncertain.
(Signed) William J.Sitchs William J. Dircks Executive Director for Operations
Attachment:
As stated cc: Commissioner Gilinsky Commissioner Roberts CommissionerAsselstiniI Commissioner Bernthal OGC OPE OCA 6