ML20141G927

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Comments on Review of FP Gillespie 840925 Memo Re Proposed Rule Change to 10CFR50,50.47 & App E, Consideration of Earthquakes on Emergency Preparedness. Proposed Minutes of ACRS 295th Meeting & Final Version of 10CFR50 Encl
ML20141G927
Person / Time
Issue date: 10/09/1984
From: Merrill O
Advisory Committee on Reactor Safeguards
To: Fraley R
Advisory Committee on Reactor Safeguards
Shared Package
ML20140C992 List:
References
FOIA-85-653 ACRS-GENERAL, NUDOCS 8601130183
Download: ML20141G927 (6)


Text

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'o UNITED STATES

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. # "g l' ,.,.. g NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS

{ s WASHINGT ON, D. C. 20555

....* October 9, 1984 MEMORANDUM FOR: Raymond F. Fraley, Executive Director, ACRS e

FROM:

Owen S. Merrill, ACRS Staff Engineer

SUBJECT:

COMMENis ON THE REFERENCED MEMORANDUM

Reference:

ACRS Review of Proposed Rule Change to 10 CFR Part 50, 50.47 and Appendix E; Consideration of Earthquakes on Emergency Preparedness Memorandum from F. P. Gillespie to R. F. Fraley, September 25, 1984 I have reviewed the referenced memorandum and discussed it briefly with Mr. M. Jamgochian, NRR's project engineer for this project. My coments relevant to the referenced document and enclosure follow.

1. The ACRS's schedule for Subcomittee and full Comittee meetings during the ng/t two months is inconsistent with the " planned schedule" given on page 1 of the memorandum. The referenced topic has been proposed for consideration during the 295th ACRS meeting.

November 1-3, 1984. However, it will not be discussed by the Reactor Radiological Effects Subcommittee until their meeting on November 30-December 1,1984, after which their recomendations will be reported to the full Comittee at the 296th ACRS meeting on December 13-15, 1984. Thus, December 15 is the earliest date that the ACRS Review can be completed in accordance with the current ACRS schedule.

2. According to Mr. M. Jamgochian, on the advice of legal counsel, paragraph 2.1 on page 6 of Mr. Dircks' undated memorandum to the l

Commissioners has been deleted.

3. The two references cited in Mr. Dircks' memorandum to the l~ Comissioners pertaining to the matters of the San Onofre and
Diablo Canyon actions are attached for your information (Attachments 1 and 2, respectively). A follow-up document on i

Diablo Canyon, which was not referenced in the subject memorandum l

and enclosure, is also attached (Attachment 3).

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l N h h 851125

[ BELLB5-653 PDR i

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- Raymond F. Fraley 2 October 9, 1984 Attachments:

1. In the Matter of Scuthern California Edison Company, et al. (San Onofre Nuclear Generating Statior., Units 2 and 3. Memorandum and Order, (CL-81-33), December 8, 1591,
2. In the Matter of Pacific Gas and Electric Company, (Diablo Canyon Nuclear Power Plant, Units 1 and 2) Decision (CLI-84-12), August 10, 1984
3. Op. cit., Memorandun and Order (CLI-84-13), August 10, 1984.

cc w/atts:

ACRS Members S. Duraiswamy, ACRS J. McKinley, ACRS cc w/o atts:

M. Libarkin, ACRS T. McCreless, ACRS

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NOVEMBER 1-3,1984 PROPOSED MINUTES OF THE 295TH ACRS MEETING

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. informal way. Chairman Palladino suggested that there is some flexibility in the policy statement. It may be counter produc-tive to go'too far in a prescriptive way because one will get into greater areas of uncertainty. Chairman Palladino also requested that clarification of the Comittee's recomendation regarding a type of and schedule for "some systematic approach to an examination of each nuclear plant now operating or under construction for possible sigt.ificant risk contributors."

VI. Emergency Planning (0 pen to Public)

0. S. Herrill was the Designated Federal Official for

[ Note:

this portior, of the meeting.]

D. W. Moeller presented his thoughts on the proposed amendment to 10 CFR Part 50 Section 50.47 and Appendix E; Consideration of Earthquakes in the Context of Emergency Preparedness (SECY-84-394 issued on October 10,1984). He indicated that the occurrence of an accidental radiulogical release and an earthquake that could disruptnormalemergencyplanningsufficientlyunlikely(remote) that consideration in individual licensing proceedings pending '

He stated generic consideration of the matter is not warranted.

l that the probability of an earthquake large enough to cause major onsite damage that would result in a significant radiological l release from the plant is extremely low and for such large earthquakes, offsite damage would make offsite emergency plans R. F.

prenised on normal conditions marginally useful at best.

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a NOVENIER 1-3, 1984 PROPOSED MINUTES OF THE 295TH ACRS MEETING

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Fraley, ACRS Executive Director, pointed out that current emer-gency plans have contingency plans for floods, ice storms, and other typ of inclement weather. He thought that this neces-sarily should also cover earthquakes. M. T. Jangochian, NRC, pointed out that NRC's responsibilities refer to onsite emergency planning whereas FEMA is responsible for offsite emergency planning. He mentioned an October 23,1984 meeting the Staff had with the Comissioners during which Chairman Palladino indicated that power plant sites in areas subject to tornadoes must con- .

sider tornadoes in their emergency plans. In areas of high seismicity, earthquakes should be considered. He noted that the

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Cornission, nevertheless, proposed not to require that all emergency plans look at earthquakes. The Comission clains that there ought to be flexibility in the emergency plans for alterna-tives such as evacuation. D. W. Moeller pointed out that there is a basic question whether cost effective reductions in overall risk can be obtained by explicit consideration of severe earthquakes in emergency response planning. He suggested that i

AEOD's attempt at addressing effects on emergency plans regard-

-less of the size of earthquakes is not feasible.

M. Jamgochian explained that the NRC paper sent to the ACRS for review is to be scrapped and redone in accord with the Consnis-siener's wishes. He indicated that Comissioner Bernthal wishes other unlikely occurrences to be considered besides earthquakes.

He mentioned that NUREG-0654 contains acceptance standards for Appendix E for evacuation time estimates and considers normal 42

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' N0VDBER 1-3,1984 PR0 POSED MINUTES OF THE 295TH ACRS MEETING 4

conditions as well as adverse conditions. He noted that the licensing board questioned whether evaluation time estimates should consider the complicating effects of earthquakes up to the

' safeshutdown(SSE) earthquake. The NRC Staff feels strongly that earthquakes less likely but more severe than the SSE ought to be considered in emergency plans. He pointed out, however, that the Comission in the case of San Onofre and Diablo Canyon 4

has saio that the corrplicating effects of earthquakes do not have to bt considered in emergency planning. He indicated that the Comission in attempt to codify these rulings has decided to put these changes in the rule and that is why the proposed amendment to 10 CFR Part 50.47 has been withdrawn. The new draft may include other phenomena.

D. W. Nceller noted that FEMA has the lead in the National Earthquake Hazard Reduction Program and the ACRS ought to look further at this program. He suggested that emergency response plans for plants in the western U.S. ought to consider earthquake complications. C. P. Siess pointed out that it would take two to three tines the SSE to cause a nuclear plant accident but the damcge from such an earthquake would be so great that local efforts would be focused on the concern for rescuing people from the earthquake effects rather than on the nuclear plant accident.

M. Jamgochian pointed out that the NRC Staff has informally requestedthatapplicants(Diablo/SanOnofre)submitreports i considering the complicating effects of earthquakes. He noted

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PROPOSED HINUTES OF THE 295TH ACRS MEETING NOVEMBER 1-3. 1984 thet both plants have informally submitted reporcs for up to and including the SSE.

D. W. Moeller indicated that it appears that the proposed rule on the consideration of earthquakes emergency response planning will be going back for redrafting. He thought this the best alternative since it may be unwise to release the current draft of the proposed rule to the general public as it may not get public acceptance.

V 11.- ACRS Subcommittee Report on the Humboldt Bay Nuclear Plant

[ Note: J. C. McKinley was the Designated Federal Official for I

this portion of the meeting.)

D. W. Moeller indicated that the ACRS Subcommittees on the Humbolot Bay and Reactor Radiological Effects reviewed the decommissioning plan submitted by Pacific Gas and Electric Coupany (PG&E) for the Humboldt Bay Power Plant, Unit 3 on 9

September 10, 1984. He indicated that the major source onsite is sper.t fuel which has such a low burnup that it can be stored in air ano does not need to be cooleo in the spent fuel pool. he noted that there are systems to detect fuel leaks but the Subcommittee thought that they were not as sophisticated as presented. He indicated that the Subcomnittee might look into the occupational exposures that would result from the " canning" of leaking fuel elements. He thought that crud on the outside of 44

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