ML20141H125

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Summarizes ACRS 219th Meeting on 780706-08 Re Util Application for Ol.Subj to Satisfactory Completion of Const, Mods & Preoperational Testing,Facility Can Be Operated at Power Levels Up to 3,338 & 3,411 Mwt for Units 1 & 2
ML20141H125
Person / Time
Site: Diablo Canyon, 05000000
Issue date: 07/14/1978
From: Lawroski S
Advisory Committee on Reactor Safeguards
To: Hendrie J
NRC COMMISSION (OCM)
Shared Package
ML20140C992 List:
References
FOIA-85-653 NUDOCS 8601130427
Download: ML20141H125 (14)
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,g .,g UNITED STATES 3 'a NUCLEAR REGULATORY COMMISSION

'j ADVISORY COMMITTEE ON REACTOR SAFEGUARD 7

-' / WASMCTON. O. c. 20656 July 14, 1978 Honorable Joseph M. Hendrie l Chairman U. S. Nuclear Regulatory Ccmission 1 Washington, DC 20555 l

Subject:

REPORT CN DIABID CANYON NUCLEAR POWER STATION INITS 1 AND 2

Dear Dr. Hendrie:

l During its 219th meeting, July 6-8, 1978, the Advisory Ccmittee on Re-actor Safeguards completed its review of the application of the Pacific Gas and Electric Ccanpany for authorization to operate the Diaolo Canyon Nuclear Power Station Units 1 and 2. 'Ihis project has been considered l at S+m=ittee meetings and site visits as follows: September 12, 1974 l in Washington, DC; February 18-19, 1975 in San Luis Obispo, CA; February i 19, 1975 at the site; May 23, 1975 in Ics Angeles, CA; May 21, 1976 in '

San Luis Obispo; June 25-26, 1976 in San Luis Obispo; October 11, 1976 in Ics Arz3eles; June 21-23, 1977 in Ics Angeles; August 2,1977 in Des Plaires, IL; June 14-15, in Washington, DC; and June 21 in Washington, DC. 'Ihe Ccmittee reported previously on its partial reviews of this application in its letters of June 12, 1975 and August 19, 1977. During its review, the Cannittee had the benefit of discussions with represent-atives and consultants of the Pacific Gas and Electric Cortpany, the West-inghouse Electric Corporation, and the Nuclear Regulatory Ccummission (NRC)

Staff, as well as conments frcan members of the p2blic. 'Ihe Ccmittee also had the benefit of the documents listed.

At the time the Camnittee made its partial review of this application, as reported in its letter of August 19, 1977, the NRC Staff had substan-l tially completed its review of those matters not related to the seismic design and capability of the plant. 'Ihose items remaining outstanding were to be resolved in a manner satisfactory to the NRC Staff. Progress on the resolution of these items has been reviewed and all items have been found either resolved or near resolution.

Since the Committee last reviewed and reported on this application, sev-eral additional nonseismic matters of concern to the NRC Staff have arisen, and sczne of these are not yet completely resolved. 'Ihese include: '

operation of the contairment purge system when the reactor is at power, possible undesirable interactions between the seismic scram circuits and the reactor protection system, correction of an error in the calcu- .

lation of zirconium-water reaction in the Westinghouse emergency core

Honorable Joseph M. Hendrie July 14,1978  !

t cooling system _ evaluation model, and adequacy of the reactor vessel material surveillance specimens. S e status of each of these items has been reviewed and the Committee reccamends that they be resolved in a manner satisfactory to the NBC Staff.

A major problem related to the Diablo Canyon Nuclear Power Station has resulted from the discovery, after the plant was under construction, of a major fault about 6 km offshore frcan the plant. Ebliowing extensive investigations by the Applicant, the NRC Staff, and the U.S. Geological Survey, the Staff accepted the reconnendation of the Geological Survey that this fault, the Bosgri fault, was capable of generating an earthquake having a magnitude as great as 7.5 on the Richter scale. Se Staff then developed seisnic design bases in the form of seismic response spectra appropriate to an earthquake of this magnitude at this distance. Since

these new seismic design bases were considerably more severe than those for which the plant was originally designed, the NRC Staff has required the AEplicant to reevaluate the safety of the plant for this larger earthquake.

Se Applicant has complied with the Staff's reqairement and has carried out extensive reanalyses of the structures and components in accordance with the new seismic design bases and criteria. In those cases for which the plant, as designed and constructed, did not meet the new criteria, structural modifications have been or are being made. In addition, ex-tensive tests have been carried out on mechanical and electrical equip-ment in the plant to qualify it for the excitations produced by the i

larger postulated Bosgri event.

S e Applicant's analyses and tests related to the reevaluation of the i structural and mechanical components for the Bosgri event have been

! subjected to an unprecedented 1y intensive and comprehensive review by the NRC Staff and their consultants. B is review involved numerous meetings between the Staff and the Applicant to review and audit, in considerable detail, the procedures and criteria used by the Applicant in the seismic reevaluation of the plant structures and components.

Since there are expected to be significant differences between the nature of the ground motions close to a large earthquake and that at greater distances, to which most available data apply, the Staff relied heavily on the experience and judgment of its consultant, N. M. Newmark, an acknowledged expert in the field of earthquake engineering and struc-tural design. On his advice, an effective zero-period acceleration of 0.75g was used to determine the free-field response spectra to be used in engineering analyses. %ese spectra were then reduced by varying amounts to obtain spectra for those structures in the plant having foundations extending over large areas. m is reduction for the effects of building size is also based largely on judgment and experience rather than on extensive observations or analyses and has not heretofore been applied in the design of nuclear power plants.

355 m

Honorable Joseph M. Hendrie July 14, 1978 4

Se seismic design criteria proposed by the Staff permitted the use of damping factors for structures in accordance with Regulatory Guide 1.61 in place of the lower, and thus more conservative, values used by the Applicant in the original design. S e Staff also permitted the use of as-built dimensions and masses, and material strengths determined from tests during construction, rather than the more conservative values used in the original design.

~

It is evident frczn the foregoing that the design bases and criteria utilized in the seismic reevaluation of the Diablo Canyon Station for the postulated Bosgri event are in certain cases less conservative than those that would be used for an original design. Se Ccemittee believes, however, that there are offsetting factors that lead to acceptance of these bases and criteria for an already completed plant. Rey include:

(1) the fact that the Ccenittee's consultants believe that the choice of magnitude 7.5 for the postulated Hosgri event is relatively more conserv-

ative than the values considered acceptable for other plants; (2) because 1 of the extent and depth of the Staff's review of the Applicant's seismic reevaluation, the-likelihood of an undetected error in the seismic analy-ses or design is greatly reduced; and (3) the fact that the population 4

density around the Diablo Canyon site is low. For these reasons, the Committee believes that, without endorsing all details of the NRC seismic design bases and criteria, the use of the Staff approach leads to an acceptable level of safety in this instance.

As mentioned previously, the Applicant has tmdertaken a cxmprehensive reevaluation of all safety-related structures and conponents to determine their ability to withstand the postulated Hosgri event. As t. result of these studies, modifications to the plant have been required and are being made.- Se NRC Staff has audited the criteria and procedures used by the Applicant in connection with the reevaluation and with the design of the modifications. Se Ccannittee reconsnends that the remaining out-standing items relating to reevaluation and nodification of the plant should be resolved in a manner satisfactory to the NRC Staff.

S e Applicant ha's made tests, both in place and in the laboratory, to demonstrate thatf various mechanical conponents and electrical systems -

and instrumentation would remain functional if subjected to the postu-lated Hosgri earthquake. S e NRC Staff has reviewed the results of the tests that have been made and has required additional tests or analyses in some instances and additional information in others. Se Cmunittee believes that the approach taken by the Staff in this matter has been

.approprit a e and that the remaining outstanding items should be resolved in a manner satisfactory to the NRC Staff.

I sse 1.i

E  !

Bonorable Joseph M. Bendrie July 14, 1978 i itW  ; At the request d the cammittee, the Applicant has made a study to deter-

    • 3 5 sine the consequences of a failure of any one of the snubbers intended to

. itted restrain the motion of corponents or piping during an earthquake. Pbr data the reactor coolant loops, a deterministic study was made, with accept-

' vatii able results. Ibr systems in the balance of plant, the Applicant made a I i

probabilistic assessment of snubber failures and the consequences thereof. '

Se assunptions on which this study was based have not been found fully and acceptable by the IGC Staff or the Nnmittee. Se Comunittee and the Staff believe, however, that the results of the study have lessened their '

20" 3 concerns and that this matter should be considered generic to all plants, cone to be resolved in a timely manner.

Comed I, o ac' m e NRC Staff has decided that the requirements of Branch Technical

, j

.t. 1 that , -

Position RSB 5-1 should be met for the Diablo Canyon Station. Bis position requires demonstration that the plant can be brought to the.

.ivell " cold shutdown condition using only safety-grade equipnent. Se Staff Pla? review of the ability of the plant to meet this requiranent is essen-tially canplete. S e remaining questions should be resolved in a manner

[

roe o satisfactory to the NRC Staff.

I i cf i lc m e Applicant has elected to use an acceleration of 0.20g to define the ich l' Operating Basis Earthquake. If accelerations greater than this value are observed, the plant will be shut down and inspected for possible i damage. Se Ccanittee considers this value suitably low as a basis for determining when the plant should be shut down following an earthquake.  ;

'0"*" "

A Se Applicant has provided a seismic scram system for the Diablo Canyon a

squio Station. Se occurrence of accelerations greater than 0.4g in any direc-d po tion will automatically shut down the reactor. Se Cannittee believes i and wn that a seismic scram set at a substantial fraction of the Safe Shutdown ,

'ME Earthquake value is a desirable feature, and finds the proposed setting acceptable.

lon o

Sta nose generic problems considered relevant to the Diablo Canyon Station n lab are listed in the Committee's letter of August 19, 1977 and are described actr in the Connittee's Report No. 5 on Generic Items, dated February 24, 1977.
ed Of those items listed, the following are now censidered to be resolved for the Diablo Canyon Station: II-2, II-4, II-5A (Ioose parts monitor) ,  !

tes II-9, IIA-3, IIA-5, IIB-2, IIC-2, IIC-4. Se remaining problems, together with Item IIC-6 from the Caunittee's Report No. 6 on Generic Itens, dated 3*

November 15, 1977, shculd be dealt with by the Staff and the Applicant as solutions are found.

t i

I e

357

e =.M Bonorable Joseph M. Hendrie July 14, 1978 The ACRS notes that, for distan s less than 10 km from the earthquake source, there are currently no strong notion data for shocks larger than magnitude 6 and few reliable data for shocks of magnitude 5 and 6. Also, the theory and analyses of earthquake and seismic wave generation, of seismic wave transmission and attenuation, and of soil-structure inter-action are in a state of active development. The Ccanittee reconuends that the seismic design of Diablo Canyon be reevaluated in about ten years taking into account applicable new information.

The Advisory Cmmittee on Reactor Safeguards bellens that, if due con-sideration is given to the items rentioned above, and subject to satis-factory completion of construction, plant modifications, and preopera-tional testing, there is reasonable assurance that the Diablo Canyon Nuclear Power Station Units 1 and 2 can'be operated at power levels gi to 3338 and 3411 left for Units 1 and 2, respectively, without undue risk to the health and safety of the public.

Stephen Lawroski Chairman References

1. Final Safety Analysis Report (FSAR) for Diablo Canyon Nuclear Power Station Units 1 and 2, and Amendments 1-63 to the FSAR.
2. Safety Evaluation Report dated October 16, 1374 and Supplements 1-7 dated January 31, 1975, May 9, 1975, September 18, 1975, May 1976, September 1976, July 14,1977 and May 26, 1978 respectively. .
3. USG3 Circular 672. Ground Motion Values for Use in the Seismic Design of the Trans-Alaska Pipeline System.
4. USGS Open File Report 75-134. Seismicity of the Central California Coastal Region.
5. Pacific Gas and Electric Ca@any (PG&E) letters to the NRC as follows:

l

a. Baergency plans dated March 21, 1974, June 18, 1976, October 12, 1977 and February 8, 1978 l'
b. Preoperational testing of ECCS dated July 12, 1974 I
c. BCCS analysis dated December 3, 1974, June 10, 1977, May 16, 1978 358
  1. L

1 Bonorable Joseph M. Hendrie July 14, 1978

d. Seismic analysis and/or requalification dated December 27, 1974, July 2 L 1975, March 2, 1976, January 27, 1977, October 4, 1977, Ibvember 2, 1977, December 21, 1977, January 5, 1978, February 14, 1978, April 17 & 26, 1978, May 2 & 26, 1978
e. Steam generators dated April 7,1975, February 14, 1978, May 11, 1978
f. Reactor vessel supports dated January 13, 1976, July 20, 1976, hbruary 10, 1978
g. Geophysical survey records dated December 8 & 16, 1975, March 2 &

26, 1976

h. Protection systems noise tests dated hAr 24, 1975, March 23, 1976
1. Contairunent testing dated January 8,1976, March 23,1976, July 29, 1976, December 1, 1977

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j. Anticipated transients without scram dated September 30, 1976
k. Environmental qualification of conpcnents dated January 19, 1978, hbruary 10 & 15, 1978, May 3, 1978
1. Performance during grid undervoltage canditions dated March 20, 1978
m. Inservice inspection program dated October 10, 1977
n. 7tuperature monitoring system dated December 5, 1977
o. Containment spray additives dated January 9, 1978
p. Stress evaluation of piping systems dated January 24, 1978, March 7,1978, April 12,1978
q. Diesel generator operating status indications dated December 30, 1977
r. Fire protection systems dated February 6, 1978
s. Seismic scram dated February 21, 1978, April 17, 1978
t. Post Accident Monitoring Instrumentation dated June 13, 1978
u. Responses to SER consnents dated June 30, 1978, July 6, 1978
v. Turbine-generator stop valves dated April 11 & 26, 1978
w. Reactor vessel internals dated February 22, 1978, April 11, 1978
x. Operating Basis Earthquake dated April 11, 1978
y. (bntainment penetrations dated June 6,1978
z. Steam line break inside contairnent dated September 15, 1977 8

aa. Containment isolation dated July 8, 1977 bb. Security Plan (Proprietary) dated July 22, 1977 cc. Systems for Safe shutdown dated April 17,1978, May 2,1978

6. Statements from interested members of the public as follows:
a. Kingsburg District Chamber of Commerce dated August 10, 1977
b. Mr. H. Weber dated July 6, 16, 30, 1976, September 20, 1976, October 11, 1976.
c. Donna J. Cuffiero dated September 27, 1977 359

Honorable Joseph M. Hendrie July 14, 1978

d. J. R._Bakalian, Executive Director, Nuclear Moratorium Task

- Force dated June 8, 1978

e. D. S. Fleischaker, Attorney For Intervenors dated March 29, 1978, April 11, 1978, June 9, 1978
f. Sandra A. Silver dated February 10, 1975
g. E. E. Apfelberg dated February 11, 1974
h. R. Nader dated April 8, 1976 w/ enclosure
i. G. O'Ryan (Citizens Against Pollution) dated June 17, 1976
j. J. N. Brune dated November 3, 1976, June 23, 1977
k. Center for Law in the Public Interest dated November 19, 1976, March 28, 1977, June 23, 1977
1. K. J. Husemeyer dated March 5, 1977
m. R. B. Hubbard dated March 10,1977, April 27,1977, June 23 & 30, 1977, July 8 & 12, 1977, August 2, 12, 25, 30, 1977, October 10, 1977
n. R. R. Curry dated June 23, 1977
o. J. Klugewiz/K. Kempton dated June 23, 1977 e

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CUESTION 2. PLEASE STATE THE FACTUAL BASIS FOR THE COMMISSION'S CONCLUSION THAT THE ISSUE OF SEISMIC COMPLICATIONS ON EMERGENCY RESPONSE SHOULD BE TREATED IN A GENERIC FASHION. PROVIDE A CHRONOLOGY OF THE VIEWS OF THE NRC STAFF AND THE ADVISORY COMMITTEE ON REACTOR SAFEGUARDS ON WHETHER THIS ISSUE IS GPIERIC OR SITE SPECI?!C?

ANSWER.

IN ITS MEMORANDUM AND ORDER OF DECEMBER 8, 1981 PERTAINING TO SAN ONOFRE, CLI-81-33 (14 NRC 1091(1981)), THE COMMISSION NOTED THAT:

"A REVIEW OF THE RULEMAKING FILE ASSOCIATED WITH THE COMMISSION'S EMERGENCY PLANNING REGULATIONS (SEE 45 FR 55402; 44 FR 75167; 44 FR 41483) REVEALS THAT THE COMMISSION DID NOT ADDRESS THE QUESTION OF HOW THE CONSEQUENCES OF A SEVERE EARTHQUAKE WOULD INFLUENCE EMERGENCY PLANNING... THE CURRENT REGULATIONS ARE DESIGNED WITH THE FLEXIBILITY TO ACCOMMODATE A RANGE OF ONSITE ACCIDENTS, INCLUDING ACCIDENTS THAT MAY BE CAUSED BY SEVERE EARTHQUAKES. THIS DOES NOT, HOWEVER, MEAN THAT EMERGENCY PLANS SHOULD BE TAILORED TO ACCOMMODATE SPECIFIC ACCIDENT SECUENCES OR THAT EMERGENCY PLANS MUST ALSO TAKE INTO ACCOUNT THE DISRUPTION IN IMPLEMENTATION OF OFFSITE EMERGENCY PLANS CAUSED BY SEVERE EARTHQUAKES."

MARKEY/0GC 6/26 .-..._

QUESTION 2 (CONTINUED) ,

THE COMMISSION CONCLUDED THAT:

"THE COMMISSION WILL CONSIDER ON A GENERIC BASIS WHETHER REGULATIONS SHOULD BE CHANGED TO ADDRESS THE POTENTIAL IMPACTS OF A SEVERE EARTHQUAKE ON EMERGENCY PLANNING."

FURTHER, IN ITS DECISION OF AUGUST 10, 1984 PERTAINING TO DIABLO CANYON (CLI-84-12), THE COMMISSION REAFFIRMED ITS 1981 SAN ONOFRE FINDING. IN PART 111 0F CLI-84-12 THE COMMISSION STATED THE FOLLOWING:

". . . . . . WE BELIEVE THAT FURTHER GENERIC RULEMAKING EXPLORING THE EFFECTS OF EARTHQUAKES ON EMERGENCY PLANNING 4 COULD BE USEFUL. IN PARTICULAR, THE COMMISSION BELIEVES THAT IT WILL BE USEFUL TO ADDRESS WHETHER THE POTENTIAL FOR SEISMIC IMPACTS ON EMERGENCY PLANNING IS A SIGNIFICANT ENOUGH CONCERN FOR LARGE PORTIONS OF THE NATION TO WARRANT THE AMENDMENT OF THE REGULATIONS TO SPECIFICALLY CONSIDER THOSE IMPACTS. THE CHIEF FOCUS OF THE RULEMAKING PROCEEDING WILL BE TO OBTAIN ADDITIONAL INFORMATION TO DETERMINE WHETHER.

IN SPITE OF-CURRENT INDICATIONS TO THE CONTRARY, COST EFFECTIVE R' EDUCTIONS IN OVERALL RISK MAY BE OBTAINED BY THE EXPLICIT CONSIDERATION OF SEVERE EARTHQUAKES IN EMERGENCY RESPONSE PLANNING. IN ADDITION RULEMAKING WOULD ALLOW A GREATER SPECTRUM OF PUBLIC PARTICIPATION IN THE RESOLUTION 0F THIS MATTER ON A GENERAL, AS OPPOSED TO PLANT-SPECIFIC, BASIS. .

4 MARKEY/0GC 6/26

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QUESTION 2 (CONTINUED) WE PREVIOUSLY INDICATED IN SAN ONCFRE THAT THIS MATTER WOULD BE CONSIDERED ON A GENERIC BASIS. SOME TIME AGO THE NRC STAFF ADVISED US THAT, IN ITS VIEW, GENERIC CONSIDERATION WAS NOT NE'CESSARY. HOWEVER, WE WERE DIVERTED FROM THIS ISSUE BY THE PRESS OF OTHER IMPORTANT COMMISSION BUSINESS, AND WE TOOK NO ACTION IN RESPONSE TO THAT ADVICE. IN RETROSPECT, SINCE WE DISAGREE WITH THE NRC STAFF'S VIEW, WE SHOULD HAVE ACTED SOONER AND INITIATED RULEMAKING. THE NEED TO ADDRESS THIS ISSUE IN THIS CASE HAS AGAIN FOCUSED OUR ATTENTION ON THIS MATTER. BY THIS ORDER WE ARE INDICATING OUR DESIRE TO INITIATE RULEMAKING SHORTLY, AND

-DIRECTING THE NRC STAFF TO GIVE PRIORITY ATTENTION TO THIS MATTER."

THE STAFF EXPRESSED ITS VIEWS PERTAINING TO THE ISSUE ON THREE OCCASIONS: 1) A JUNE 22, 1982 MEMORANDUM FROM THE EXECUTIVE DIRECTOR FOR OPERATIONS (ED0) TO THE COMMISSION: 2) A JANUARY 13, 1984 MEMORANDUM FROM THE EDO TO THE CHAIRMAN; AND 3) THE MAY 3, 1984 NRC STAFF'S MEMORANDUM REGARDING CONSIDERATION OF EFFECTS OF EARTHQUAKES ON EMERGENCY PLANNING (Cll-84-4).

THE JUNE 22, 1982 MEMORANDUM STATED..."IT IS THE JUDGEMENT OF THE

- STAFF THAT FOR MOST SITES EARTHQUAKES NEED NOT BE EXPLICITLY 8

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 CONCURRENTLY WITH OR 4

/.ARKEY/0GC 6/26 . - _ -

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QUESTION 2 (CONTINUED) CAUSE.A REACTOR ACCIDENT." THE STAFF ALSO INDICATED THAT WHILE PLANNING _FOR EARTHQUAKES WHICH MIGHT HAVE EMERGENCY PREPAREDNESS IMPLICATIONS MAY BE WARRANTED IN AREAS WHERE '.HE

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SEISMIC RISK TO OFFSITE STRUCTURES IS RELATIVELY HIGH (E.G.,

CALIFORNIA SITE AND OTHER AREAS OF THE WESTERN U.S.), CURRENT REVIEW CRITERIA ARE CONSIDERED ADEQUATE.

IN THE JANUARY 13, 1984 MEMORANDUM, THE STAFF CONCLUDED THAT:

"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 RADI0 ACTIVE RELEASE UNDER CONDITIONS WHERE OFFSITE DAMAGE IMPAIRS EMERGENCY RESPONSE.

C. FURTHER, CLARIFICATION OR REFINEMENT OF CURRENT REQUIRE-MENTS AND GUIDANCE MIGHT REDUCE THE IMPAIRMENT OF EMERGENCY RESPONSE INDICATED IN B ABOVE, BUT THE VALUE OF SUCH REDUCTION IS UNCERTAIN."

IN ITS RESPONSE TO CLI-84-4, THE STAFF STATED THAT "... BASED ON ITS CONSIDERATION OF THIS ISSUE, THE STAFF BELIEVES THAT THE CURRENT RESIDUAL RISK IS ACCEPTABLE AND THAT CONSIDERATION OF THE COMPLICATING EFFECTS OF EARTHQUAKES ON EMERGENCY PLANNING FOR DIABLO CANYON IS NOT REQUIRED."

MARKEY/0GC 6/26

. y QUESTION 2 (CONTINUED)  ;

THE VIEWS OF THE ACRS ON THIS SUBJECT WERE EXPRESSED ON TWO OCCASIONS: ON -MARCH 16, 1981 AND JUNE 10, 1985. ON MARCH 16,

, - 1981 THE ACRS RECOMMENDED THAT THE NRC STAFF GIVE FURTHER CONSIDERATION TO THE DEVELOPMENT OF EMERGENCY PLANS AND THE OPERABILITY OF EQUIPMENT NEEDED TO DEAL WITH NUCLEAR EMERGENCIES WHICH RESULT FROM NATURAL DISTURBANCES SUCH AS EARTHQUAKES.

4 IN ITS JUNE 10, 1985 LETTER TO THE COMMISSION, THE ACRS COMMENTED THAT IT SAW "... NO TECHNICAL REASON FOR THE EXCLUSION OF EARTHQUAKES FROM THE NATURAL PHENOMENA CONSIDERED IN OFFSITE EMERGENCY PLANNING FOR NUCLEAR POWER PLANTS. HOWEVER, WE BELIEVE THAT ONLY LIMITED CONSIDERATION OF EARTHQUAKES IS APPROPRIATE. FOR SITES WHERE AN EARTHQUAKE CAPABLE OF SEVERELY DAMAGING EMERGENCY TRAVEL ROUTES IS SUFFICIENTLY LIKELY TO OCCUR, THE LOCAL OFFSITE AUTHORITIES SHOULD HAVE THE BENEFIT OF STUDIES INDICATING THE TYPES AND POTENTIAL LOCATIONS OF SUCH DAMAGE. THE STUDY OF THIS KIND ALREADY PERFORMED FOR THE REGION SURROUNDING THE DIABLO CANYON SITE WOULD CLEARLY MEET THE INTENT OF THIS COMMENT." (IHE REPORT REFERRED TO HERE IS THE TERA CORPORATION REPORT,

" EARTHQUAKES AND EMERGENCY PLANNING AT DIABLO CANYON," SEPTEMBER, 1981.1 THE ACRS ALSO COMMENTED THAT "...IN THE ASSESSMENT OF THE IMPACT OF NATURAL EVENTS ON EMERGENCY PLANNING, THE MAJOR EFFORT SHOULD BE TO IDENTIFY POTENTIAL PROBLEMS AND TO DEVISE ALTERNATIVE l APPROACHES FOR THEIR RESOLUTION. THIS WOULD INCLUDE REGd!REMENTS l

MARKEY/0GC 6/26 l

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QUESTION 2 (CONTINUED) _

FOR ASSURING APPROPRIATE MEANS FOR COMMUNICATION, FOR IDENTIFYING ALTERNATIVE RQUIES FOR THE EVACUATION-OF THE LOCAL POPULATION, AND FOR IDENTIFYING CIRCUMSTANCES UNDER WHICH SHELTERING MIGHT BE A IN MANY CASES, SUCH MORE EF.FECTIVE RESPONSE THAT EVACUATION.

- ASSESSMENTS MAY LEAD TO A DECISION THAT NO FURTHER RESPONSE OR ACTION IS REQUIRED. THE GOAL SHOULD BE TO ASSURE THAT EMERGENCY PLANS, AS DEVELOPED, CONTAIN SUFFICIENT FLEXIBILITY TO COPE WITH THE POTENTIAL ADDED IMPACTS OF SUCH EVENTS."

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Question 2 Comissioner ATselstine's cements:

I would just point out two things. First, a careful reading of the

' staff's various statements demonstrates that while the emphasis may have I

changed, the staff's basic position on the need to consider the complicating effects of earthquakes on emergency planning has not changed.

The staff in fact required the licensee, PG8E, to consider the-complicating effects of earthquakes less than the SSE on emergency planning for Diablo

'. Canyon as it required the licensee for San Onofre to do so. However, when it became apparent that the issue might hold up the Diablo Canyon license, '

-the staff began to argue that these requirements were not really requirements but they were informal actions by the staff. Thus, even

, though the staff thought it important enough to require the licensee to

, consider earthquakes for emergency plarrirg, staff argued that this was not a " requirement". So if one reads all of the staff's memoranda and filings on this issue _ carefully, it becomes clear that the staff still believes some consideration of the issue is necessary; the only question is whether that consideration should be formal or informal. Further, a recent memorandumfrom[thestaffindicatesthatthestaffmaybegoingto reiterate the position it took in 1981 and 1982. (See attached memo.)

Second, the position of the ACRS on this issue has been and continues to be that some consideration of the effects of earthquakes on emergency planning is necessary at some sites.

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