ML20136G130

Comments on Draft Rule & Commission Paper Re Complicating Effects of Earthquakes on Emergency Planning.Nuclear Power Plants Pose Very Low Risk of Early Casualties in Event of Severe Reactor Accidents

ML20136G130
Person / Time
Issue date:	06/17/1985
From:	Rowsome F Office of Nuclear Reactor Regulation
To:	Gillespie F NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
Shared Package
ML20136D809	List: ML20136D806 ML20136E606 ML20136E685 ML20136F238 ML20136F289 ML20136F441 ML20136F940 ML20136G130 ML20136G165 ML20136G173 ML20136G275 ML20136G290
References
FOIA-85-653 NUDOCS 8506260552
Download: ML20136G130 (4)

Text

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[ 5. j NUCLEAR REGULATORY COMMISSION l WA$mOTON, D. C. 20555 s>

%.',,..d~ . JUN 171985 M Q.

(h f ,i FEMORANDUM FOP: Frank P. Gillespie, Director Division of Risk Analysis & Operations Office of Nuclear Regulatory Research FROM: Frank H. Rowsome, Assistant Director for Technology Division of Safety Technology

SUBJECT:

CC WENTS ON TFE DRAFT RULE AND COMMISSION PAPER CN TFE COMPLICATING EFFECTS OF EARTHQUAKES ON EMERGENCY PLANN!NG I. Comission Paper A. Omissiers of Optiens for Resolving the issue The draft Cc vissier paper crits a number of optiens te resolve the issue w.iche are more appealing, in my judgment, than tne cptier recorrenced. These include

1. Gcod Neighbor Rule I". light c' the evidence that nuclear power clarts pose very low risks of early casualties in the event of severe reactor accidents, and in light of the evidence that anticipatory 7 evacuation is ineffective in reducing the risk of fatalities '

in any case, the NRC repeals its emergency preparedness rules. In their stead, the NRC will pursue its Severe Accidert Policy so as to further assure that nuclear power plants are safe enough to pose no undue risk without the assumption of offsite erergency preparedness or unusually prompt emergency response offsite.

Pro: Solves all the problems with over-regulation in the Errergency Preparedness (EP) rules and regulations.

Con: This bets on the outcome of the Severe Accident Policy.

Onsite accident rnanagement requirements and the screering of ors for outlier vulnerabilities are not yet ir. place or ready for rulemding.

2. Exclusion of Evacuation Planning in Favor of Relocation Planning i y '

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s JUN 171985 In light of the evidence that anticipatory evacuation is ineffectual in reducing early casualties and does not significantly reduce the societal risk of latent casualties of reactor accidents, the NRC mandates that EP focus on trolesettengfter plume passage rather than anticipatory everestiend Priorities for relocation from contaminated areas should be based on realistic estimates of the local hazard and other competing demands on emergency response capabilities of responsible state and local authorities to protect public health and safety. Licensees are responsible for providing realistic prognoses and/or measurguents of the-radiation hazard offsite, and to infenn local emergency response authorities ef sthe contaminated areas and the urgency for relocation. That capacity alone is necessary and sufficient for compliance.

Pro: (1) Makes EP more effective at fatality risk limitation.

(2) There is no need to single out reactor accidents triggered by regional non-nuclear disasters such as earthquakes, floods, or hurricane.

(3) EP would be far less burdensome under this rule.

Con: Relocation planning, though more nearly cost effective than evacuation planning, still does not pass a benefit / cost test. Some licensee costs would be entailed in the switchover from the present EP rules.

3. Relocation planning for accidents triggered by non-nuclear regional disasters.

Planning for offsite emergency response to reactor accidents triggered by severe environmental phenomena should be limited to planning for relocation from hot spots of residual radiological contamination af ter plume passage.

Pro: This may be less controversial than the options above.

Con: Solves only the narrow problem, and leaves many other difficulties with the EP regulation unaffected.

All these options would require re-notification in the Federal Register, and options 1 and 2 would require a revision of NUREG-0654 and some work to narshal the arguments in its favor.

However, all of these options look more attractive to me than any of the five in the draf t Comnission paper. See, also, my April 11 memorandum on EP for background information (enclosed).

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B. Improvements to the present list cf alternatives in the Commission

! paper.

1. Alternative 1 Alternative 1 could be recast to be broader (e.g., hurricanes, floods) and could be better justified by the evidence that EP

' does not reduce risk, particularly for such initiating events.

2. Alternative 2.

I disagree that alternative 2 would provide for no litigation. We could easily be trapped irto litigatino what

" additional EP measures" mean and what the existing rules imply for severe ervirormental initiators.

3. Alternative 4.

We do not have the authority to regulate general earthquake ,

preparedness. Should a claim to this authority, implicit int Alternative 4, survive, it would aggravate the Catch-22 features in the existing EP rules by getting nuclear plant licensing further enmeshed in state and local emergency preparedress of all kinds. This is e fatal " con." I would not list it as an option.

II. Draft Final Rule and Alternative 5 in the Commission Paper

'f you 90 thead with scrething like your draft Final Rule, I see the following problems:

a A. Requirements Creep We have e long history of requirements creep, particularly with the EP rules and NUREG-0654s because the several groups charged with interpreting them, including the courts, have read more into 4 them.than was our original expectation or intent. I am concerred that a court could draw the conclusion from this draft rule that 4 cffsite emergency response facilities and equipment should neet seismic Category I standards with tornado missile protection. I suggest you craft tighter language to exclude this and other r opportunities for expansive interpretation.

B. Constraint to Design Basis Natural Phenomena The whole point of emergency preparedness is to deal with beyond design basis accidents. Although a part of the agency's logic in the San Onofre and Palo Verde decisions, this illogical exclusion

I '

' y9y of beyond design basis initiating events should not be perpetuated in this rule.

C. Omission of Accident Prognosis and Hazard Evaluation capabilities For emergency preparedness to fulfill its promise, a licensee must  ;

be equipped to make realistic projections (before and during '

releases) and estimates (after releases) of the hazard at various locations offsite, in order to advise state and local authorities  ;

of the appropriate emergency response priorities. This applies to all nuclear reactor emergency planning, but particularly to i reactor accidents triggered by non-nuclear regional disasters.

This is so because offsite emergency response personnel must judge how to apportion their resources between dealirg with the oirect  ;

effects of the non-nuclear disaster and dealine with the threat of l radiation casualties. In most cases, the non-nuclear disaster i will require imediate emergency response, but plant releases, if they occur at all, will usually take many hours after the l initiating event. Therefore, the planning capabilities listed in the rule should include another element on the ability to make realistic prognoses of the radiation hazard offsite for accidents i in progress and to survey contamination levels, once contamination occurs, and te translate such data into realistic estimates of the ,

health hazard in the path of the plume.  :

l Frark H. Rowsere, Assistant Director of Technology Division of Safety Technology Office of Nuclear Reactor Regulation  !

Enclosure:

Memorandum to H. Denton, et al, from F. Rowsome dated April l 11, 1985, Re: Emergency I Preparedness i

cc: H. Denton/D. Eisenhut T. Speis R. Bernero/D. Muller /L. Hulman M. Jamgochian J. Malaro E. Jordan S. Schwartz F. Pagano '

D. Matthews W. Olmstead V. Stello/E. Sniezek/M. Taylor I

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