ML20141H137
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umTeo STATES I
g NUCLEAR REGULATORY COMMISSION D
j WASHINGTON, D. C. 20086 g
j July 5, 1985 MEMORANDUM FOR:
Chairman Palladino Comissioner Asselstine Comissioner Bernthal Comissioner Zech FROM:
William J. Dircks Executive Director for Operations
SUBJECT:
CONSIDERATION OF POTENTIAL COMPLICATING EFFECTS OF EARTHQUAKES ON EMERGENCY PLANNING The purpcse of this memo is to inform you of our progress and direction in preparation of the subject final rulemaking package which I plan to submit to you by early August 1985.
On December 21, 1984, the Comission published a proposed rule change to 10 CFR Part 50 that relates to Emergency Planning and Preparedness at Production andUtilizationFacilities(49FR49640). The proposed rule stated that neither emergency response plans nor evacuation time analyses need consider the impact of earthquakes which cause or occur proximate in time with an accidental release of radioactive material from a nuclear power reactor.
To date, 61 coment letters have been received. Twenty five (25) letters favored the promulgation of t t proposed rule. The letters favoring the proposed rule were from utilities, consulting fims representing utilities, 2 private citizens and the Department of Energy.
Thirty-four (34) letters opposed promulgation of the proposed rule. Many voiced strong displeasure, shock or disbelief at the position the Comission was taking in the proposed rule change. The majority of these letters were from private citizens, and environmental groups.
Additional input was also received from Japan, France, Sweden, Germany and Taiwan, all of which stated that the potential complicating effects of earthquakes were n.ot specifically considered in their nuclear power reactor emergency planning.
Several issues raised in the public cumnents (and in particular in coments from The Union of Concerned Scientists) will require substantial technical analysis prior to going forward with promulgation of a final regulation.
For A
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' The Commissioners 2
example the staff needs to:
(1) assess whether there are sufficient facts to support the staf#s belief that the complicating effects of elrthquakes on emergency plans are adequately taken into account by the flexibility that exists in all emergency plans; (2) deal with the issue that defects in seismic design and quality assurance in construction can substantially undennine the seismic strength of plant systems and structures; (3) evaluate the Ifmited existing infonnation on the contribution of seismic events to overall core melt risks, recognizing that only a few PRAs assess seismic risks and the treatment entails many uncertainties; (4) deal with the question why emergency plans should not consider the complicating effects of very severe earthquakes (i.e., 2 to 4 times the SSE) whose return frequency is 10E(-4) to 10E(-5) while current emergency plans concern themselves with plant accidents whose estimated return frequency are also in this range.
These complex analyses, which are underway, are not expected to be completed before late July, 1985.
After careful review of both the San Onofre and Diablo Canyon decisions l
regarding the complicating effects of earthquakes on emergency planning, as well as the issues identified above, the staff is considering 3 alternative
' approaches:
Alternative 1: Adoption of the proposed rule into a final rule with minor but important word changes, for example, "no additional emergency prepared-i ness measures need be established to account for severe, low frequency natural phenomena tnan is already required in 10 CFR 50.47 and Appendix E."
i Alternative 2: Leaving the issue open for adjudication on a case-by-case Desis; aCCompl1sned Dy withdrawing the proposed rule or by requiring Consid-eration of earthquakes.
l Alternative 3: Promulgation of a final rule which clarifies the original intent of the Commission to require that emergency response plans shall 4
assure that the following capabilities exist relative to the complicating impacts of severe, low frequency natural phenomena.
1.
Ability to transport necessary personnel to the plant after the event in order to augment the original staff to cope with degraded modes of plant operation.
4 2.
Ability to obtain damage estimates to the plant and to be able to commu-nicate these estimates to offsite authorities. The information should be available to factor into the decisionmaking process, including reco-suendations for protective actions after severe, low frequency natural phenomena.
i 3.
Emergency plans for offsite authorities should take into account various degrees and locations of damage to the plant environs. This shall be l
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The Commissioners 3
limited to knowing alternate routes of travel as well as establishing criteria for de,termining whether to shelter, relocate or to evacuate, Having considered all of the above, as well as all connents received, past operating reactor and emergency preparedness experience, I am leaning toward a recommendation that a final rule be promulgated which would embrace the concepts of Alternative 3.
This alternative would be a clarification and articulation of the Commission's original intent as to what is specifically required to assure the necessary flexibility to cope with the complicating effects of severe, lov frequency natural phenomena on emergency planning.
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. Dircks Executive Director for Operations cc: SECY OGC OPE M. Cutchin em O
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l QUESTION 3.
IN DECIDING NOT TO CONSIDER THE POSSIBLE 40MPLICATING EFFECTS OF EARTHQUAKES ON EMERGENCY PREPAREDNESS IN ITS.1981 DECISION TO LICENSE SAN ONOFRE UNIT 2, THE COMMISSION STATED THAT IT WOULD INSTEAD CONSIDER THE ISSUE ON A GENERIC BASIS.
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THIS APPROACH WAS REPEATED IN THE COMMISSION'S 1984 DECISION TO LICENSE DIABLO CANYON.
PLEASE EXPLAIN WHY THE COMMISSION APPARENTLY DID NOT ADDRESS THIS ISSUE IN A GENERIC FASHION IN THE INTERVENING YEARS AS ORIGINALLY PROPOSED AND PROVIDE ALL DOCUMENTS DETAILING ANY ACTIONS THAT WERE TAKEN.
ANSWER.
4 AS EXPLAINED IN PART lil 0F THE COMMISSION'S AUGUST 10, 1984 DECISION ON DIABLO CANYON (CLI-84-12), FOLLOWING THE NRC STAFF ADVICE TO THE COMMISSION THAT, IN ITS VIEW, GENERIC CONSIDERATION OF THIS ISSUE WAS NOT NECESSARY, THE COMMISSION WAS DIVERTED FROM THIS ISSUE BY THE PRESS OF OTHER IMPORTANT COMMISSION BUSINESS AND THE COMMISSION TOOK NO ACTION UNTIL THE DIABLO CANYON CASE REVIEW.
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I MARKEY/0GC 6/26
Question 3:
Attached we Comissioner Asselstine's docurents relevant to this question.
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NOTATION V0TE RESPONSE SHFET T0:
SAM L J. CHILK, SECRETARY OF THE COMMISSION FROM:
COMMISSIONER ASSELSTINE
SUBJECT:
ssCv-83-377 - Rzvzzw or anxa-728 (PACzrrC cas ANo ELECTRIC COMPANY, DOCKET NOs. 50-275, 50-323 OL)
APPROVED xxxxx DISAPPROVED ABSTAIN NOT PARTICIPATING REQUEST DISCUSSION COMMENTS:
I would like a report from OGC and ELD by September 15 on what approach the Comission should take to deal with the issue of " complicating effects of earthquakes on emergency planning."
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DAlt SECRETARIAT NOTE:
PLEASE ALSO RESPOND TO AND/OR COMMENT ON OGC/0PE MEMORANDUM IF ONE HAS BEEN ISSUED ON THIS PAPER.
NRC-SECY FORM DEC. 80
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NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D.C. 20585
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November 14, 1983 ceries or Twa commissionen MEMORANDUM-FOR:
Herzel H.E. Plaine, OGC Guy H. Cunninghan, ELD FROM:
James K. Asselstine
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SUBJECT:
DIABLO CANYON - S Y 83-377 y In Secy 83-377. OGC stated that OGC and ELD were going to work out informally the issue of what the Connission should do to deal with
" complicating effects of earthquakes on emergency planning."
I agreed with that approach but asked for a status report from OGC and ELD.
I would like to know by November 30, 1983 what you intend to recomend, cc:
Chaiman Palladino Comissioner Gilinsky Comissioner Roberts Comissioner Bernthal SECY
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NOTATION VOTE AMENDED RESPONSE EHEET SAMUE1. CHILK, SECRETARY OF THE COMMISSION J
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FROM:
domirssronza Assstsr wz
SUBJECT:
SECY 83-377 - REVIEW 0F ALA8-728 (PACIFIC GAS AND ELECTRIC C0fFANY, DOCKET N05. 50-275,50-323 OL)
APPROVED SEE set 0W DISAPPROVED srr annw -
AsSTAIN NOT PARTICIPATING REQUEST DISCUSSION COMMENTS:
Approved in part, utsapproved in part.
I AGREE WITH COtt11SSIONER GILINSt,Y'S SEPARATE VIEWS ON THE CLASS 9 ACCIDENTS. ISSUE.
THE LICENSING BOARD HAS DEFINED "SPECIAL CIRCUMSTANCES" OUT OF EXISTENCE, AND.
THE COP 941SSION SHOULD HAVE CORRECTED THIS MISTAKEN INTERPRETATION OF C0 POLICY.
I ALSO AGREE THAT WE MJST DO S00ETHING ABOUT THE " COMPLICATING EFFECTS O QUAKES ON EMERGENCY PREPAREDPiESS." I AM STILL AWAITING OGC & ELD'S ON THIS ISSUE.
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f 1] AIL PLEASE ALSO RESPOND TO AND/OR COMMENT O SECRETARIAT NOTE:
MEMORANDUM IF ONE HAS BEEN ISSUED ON THIS PAP HRC-SECY FORM DEC. 80
QUESTION 4 WHY DID THE NRC REQUIRE PACIFIC GAS & ELECTRIC TO PREPARE A REPORT ON THE COMPLICATING EFFECTS OF EARTHQUAVES ON EMERGENCY PREPAREDNESS--THE TERA REPORT--AND WHY DID THE NRC STAFF REQUIRE CALIFORNIA LICENSEES TO CONSIDER EARTHQUAKES SMALLER THAN THE SSE IN THEIR EMERGENCY PLANS, IF THIS ISSUE WAS NOT MATERIAL TO PUBLIC HEALTH AND SAFETY AND TO LICENSING DETERMINATIONS?
- ANSWER, SUBSEQUENT TO THE JULY 22, 1980 AND AUGUST 8, 1980 ERUPTIONS OF MT, ST. HELENS, VOLCANIC ERUPTIONS AND EARTHQUAKES BECAME ISSUES OF HIGH PUBLIC INTEREST, ~IN RESPONSE TO AN OCTOBER 9, 1980
)
MEMORANDUM FROM THE SECRETARY OF THE COMMISSION REGARDING THE CONSIDERATION OF VOLCANIC ACTIVITY IN THE TROJAN SITE AREA AND INTEREST EXPRESSED IN EARTHQUAKE HAZARDS AT CALIFORNIA SITES, THE NRC STAFF REQUESTED THAT APPLICANTS AND LICENSEES IN CALIFORf!! A AND THE TROJAN PLANT IN OREGON FROVIDE ANALYSES OF THE IMPACT OF EARTHQUAKES OR VOLCANIC ERUPTIONS, AS APPROPRIATE, ON THEIR EMERGENCY PLANS.
THE STAFF'S REQUESTS FOR THIS INFORMATION WERE MADE PRIOR TO THE COMMISSION'S DECISION IN DECEMBER 1981 IN THE SAN ONOFRE PROCEEDING THAT CONSIDERATION OF THE EFFECTS OF EARTHQUAKES ON EMERGENCY PLANNING WAS NOT REQUIRED.
l MARKEY/0GC 6/26
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Question 4 Commissioner Asselstine's Connents:
I would note first that the staff apparently still believes that some consideration of the impacts of earthouakes en ccergency planning is necessary, regardless of the Commission's San Onfore decision.
Further, I would point out that the San Onofre decision was a very limited decision.'
The Commission's decision in Diablo Canyon did more than just reaffirm that decision, it went far beyond it.
(See answer to question 6.)
In its emergency plan for Diablo Canyon, the licensee is required to declare an " alert" at the plant, to activate the on-site technical support l
center and the on-site operational support center, and to promptly notify state and local authorities in the event of an earthquake which produces a ground acceleration of 0.2g.
These required action involve designated PG&E personnel traveling from wherever they may be at the time of the earthquake to the site in order to provide assistance to the shift in coping with the effects of the earthquake.
In addition, the state and local authorities must augment their resources and bring their primary resperse centers to standby status. The Commission also requires Diablo Canyon to declare a
" site area emergency" and to activate the on-site technical support center and the near site emergency operations facility in the event of a 0.6g earthquake. " Site Area Emergencies" are events that~are in process or ha"e occurred which involve actual or likely major failures of plant functions i
needed for protection of the public. These Commission requirements are f
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2-based (sn the staff's technical judgment on the possible effects of such earthquakes on structures and components.
Because the Comission refused to allow consTreration of the complicating effects of earthquakes on emergency planning, there is nothing in the record of the Diablo Canyon proceeding to show whether these required actions can even be carried out.
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QUESTION 5.
WERE THE PARTIES TO THE DIABLO CANYON LICENSING PROCEEDING PROVIDED AN OPPORTUNITY TO CHALLENGE
--ON THE RECORD THE COMMISSION'S CONCLUSION THAT EMERGENCY PLANS FOR THE FACILITY ARE SUFFICIENTLY FLEXIBLE TO ALLOW FOR THE COMPLICATING EFFECTS OF AN'EARTHOUAKE ON EMERGENCY RESPONSE.
STATE THE FACTUAL BASIS FOR THE COMMISSION'S CONCLUSION THAT SUCH FLEXIBILITY EXISTS AND PROVIDE ANY CITATIONS TO THE ON THE RECORD PROCEEDING THAT SUPPORT THIS VIEW.
ANSWER.
IN CLI-84-12 THE COMMISSION FOUND THAT THE SCOPE OF EMERGENCY PLANS TO DEAL WITH THE VARIETY OF NATURAL PHENOMENA WHICH COULD INTERFERE WITH THEIR OPERATION IMPLIED SOME FLEXIBILITY TO DEAL WITH-THE EFFECTS OF EARTHQUAKES.
FOR EMERGENCY PLANNING PURPOSES IT DID NOT MATTER WHETHER AN IMPASSABLE ROAD WAS IMPASSABLE BECAUSE OF HEAVY FOG OR BECAUSE OF AN EARTHQUAKE.
THE COMMISSION'S POSITION ON THIS MATTER WAS SIMPLY A LOGICAL INFERENCE DRAWN FROM THE UNDISPUTED EVIDENCE.
FOR EXAMPLE, THE EFFECTS OF FOG AND HEAVY RAIN ON ROAD CAPACITY, AN ELEMENT OF EVACUATION TIME ANALYSIS, WERE CONSIDERED.
OTHER IMPEDIMENTS, INCLUDING ROAD CONSTRUCTION AND ROAD BLOCKAGE, WERE ALSO LITIGATED.
THESE MATERS ARE ADDRESSED IN THE TESTIMONY OF PGRE WITNESSES G. P. SMITH, JR. AND R. WINSLOW WHICH IS INCLUDED IN THE TRANSCRIPT OF THE HEARING FOLLOWING PAGE 12184 (AT PAGE 6-13)
MARKEY/0GC 6/26
2-QUESTION 5 (CONTINUED)
AND TRANSCRIPT PAGES 12196 TO 12213.
IN ADDITION, PG&E EXHIBITS 78 (EVACUATION TIME ASSESSMENT FOR DIABLO CANYON), 80 (SAN LUIS OBISPO COUNTY-NUCLEAR POWER PLANT EMERGENCY RESPONSE PLAN, DRAFT, OCTOBER 1981), AND 84 (EVACUATION TIME ESTIMATES) ALSO ADDRESS POTENTIAL IMPEDIMENTS TO EVACUATION, THE COMMISSION'S INFERENCE OF FLEXIBILITY WAS DRAWN FROM THE RECORD IN THE COURSE OF REACHING ITS OVERALL CONCLUSIONS.
THE COMMISISON IS LEGALLY FREE TO DRAW INFERENCES FROM EVIDENCE AND TESTIMONY IN THE RECORD.
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m MARKEY/0GC 6/26
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Question 5 Commissioner Asselstine's comments:
The Commission's determination that the Diablo Canyon emergency plans are flexible encugh to deal with the effects of earthquakes because they considered the effects of fog and rain is a factual determination.
Because it is a factual determination which the parties to the Diablo Canyon operating license proceeding were not permitted to litigate, the Commission could not properly rely on that determination to support its decision. Whetter the plan is flexible enough and accounts for the
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probable effects of an earthquake on emergency response, is exactly what the parties to the Diablo Canyon proceeding would have litigated. While the Commission says it did not rely on this finding, clearly it used that finding to support its decision.
If not, why did it mention it in the Commissicn order, CL1-84-12? Moreover, even though the final written decision of the Commission is somewhat unclear on the point, it is evident i
from the transcripts that some Commissioners found this a very persuasive argument and based their decision, at least in part, on this finding.
Further, there is a logical flaw in the Commission's finding. The complicating effects of fog and heavy rain are not obviously the same kind of effects as would be caused by an earthquake. Earthquakes knock down structures, bridges, roads, telephone and siren poles, move earth, etc.
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2-The effects of most heavy fog or rains are not necessarily of the same caliber.
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QUESTION 6.
WHAT WAS THE FACTUAL BASIS OF THE COMMISSION'S 1981 DECISION TO EXCLUDE CONSIDERATION OF SEISMIC
--COMPLICATIONS ON EMERGENCY RESPONSE IN THE SAN ONOFRE LICENSING PROCEEDING?
ANSWER.
IN ITS DECISION IN THE SAN ONOFRE PROCEEDING (CLI-81-33), THE COMMISSION DETERMINED THAT CONSIDERATION OF THE COMPLICATING EFFECTS OF EARTHQUAKES ON EMERGENCY PLANNING WAS NOT REQUIRED BASED ON ITS REVIEW OF THE RULE AS WRITTEN AND THE RECORD ASSOCIATED WITH THE EMERGENCY Pl.ANNING RULEMAKING.
FURTHERMORE, THE COMMISSION'S CONCLUSION THAT "THE PROXIMATE 0CCURRENCE OF AN ACCIDENTAL RADIOLOGICAL RELEASE AND AN EARTHQUAKE THAT COULD DISRUPT NORMAL EMERGENCY PLANNING APPEARS SUFFICIENTLY UNLIKELY THAT CONSIDERATION IN INDIVIDUAL LICENSING PROCEEDINGS PENDING GENERIC CONSIDERATION OF THE MATTER IS NOT WARRANTED," IS SUPPORTED BY THE AFFIDIVIT OF MR. BRIAN K. GRIMES, THEN DIRECTOR, DIV!SICN OF EMERGENCY PREPAREDNESS, NRC 0FFICE OF INSPECTION AND ENFORCEMENT.
MR. GRIMES' AFFIDAVIT WAS ATTACHED TO "NRC STAFF VIEWS WITH RESPECT TO QUESTIONS POSED BY ATOMIC SAFETY AND LICENSING BOARD IN THE AREA 0F EMERGENCY PLANNING" FILED BEFORE LICENSING BOARD IN THE SAN ONOFRE PROCEEDING ON JUNE 22, 1981.
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MARKEY/0GC 6/26 x
- - - Question 6 Commissioner Asselstine's comments:
In the same affidavit cited by the Commission above in support of the San Onofre decision, Mr. Grimes stated:
In the case of San Onofre Units 2 & 3, the site is in California which has a substantial earthquake potential, a fact that is recognized in the seismic design of these units.
Consequently, high seismicity is a characteristic which affects the EPZs around the San Onofre site and is to be considered in emergency planning.
This same reasoning is applicable to the Diablo Canyon site.
Moreover, it is worth noting that the Commission's conclusion in the San Onofre case was a very narrow one. The Commission fcund only that the immediate (i.e. while a rulemaking was in progress) likelihood of an accidental radiological release and disruptive earthquake occurring at the same time was sufficiently low to permit deferring consideration of the issue in a rulemaking.
In the Diablo Canyon case and in its subsequent proposed rule,-the Commission broadened this narrow conclusion to make a much more sweeping finding that the likelihood of a disruptive earthquake and an accidental radiological release occurrinp at the same time is so low that the complicating effects of emergency planning need not ever be considered.
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OVESTION 7.
WHAT, IF ANY, ANALYSIS WAS CONDUCTED BY THE COMMISSION OR ITS STAFF TO ESTABLISH WHETHER AN EARTHQUAKE SMALLER THAN THE SSE COULD INITIATE AN ACCIDENT REQUIRING THE IMPLEMENTATION OF THE DIABLO CANYON EMERGENCY PREPAREDNESS PLAN?
PLEASE PROVIDE ANY CITATIONS TO THE ON THE RECORD PROCEEDING ON THIS ISSUE.
ANSWER THE COMMISSION'S DECISION WAS BASED ON THE ENTIRE RECORD OF THE HEARINGS BEFORE THE LICENSING AND APPEAL BOARDS, WHICH INCLUDED EXTENSIVE CONSIDERATION OF THE SEISMIC DESIGN OF DIABLO CANYON, AND IS CONFIRMED BY THE STAFF ANALYSIS CONTAINED IN THE MEMORANDA WHICH WERE ATTACHED TO CLI-84-4 AND SERVED ON THE PARTIES.
THAT ANALYSIS RELIED ON ENGINEERING JUDGMENT, WHICH CONSIDERED THE AVAILABLE SEISMIC RESEARCH.
NO SPECIFIC PROBABILISTIC ANALYSIS WAS CONDUCTED.
THE SAFE SHUTDOWN EARTHQUAKE, OR SSE, FOR A NUCLEAR PLANT IS BASED UPON AN EVALUATION OF THE MAXIMUM EARTHQUAKE POTENTIAL FOR 1
THE SPECIFIC SITE.
THE SSE IS EVALUATED AS THAT EARTHQUAKE WHICH PRODUCES THE MAXIMUM VIBRATORY GROUND MOTION FOR WHICH CERTAIN STRUCTURES, SYSTEMS AND COMPONENTS MUST BE DESIGNED AND CONSTRUCTED TO REMAIN FUNCTIONAL, PROBABILISTIC ESTIMATES FOR j
THE OCCURRENCE OF AN SSE ARE TYPICALLY ON THE ORDER OF ONE IN A THOUSAND TO ONE IN TEN THOUSAND PER YEAR.
BECAUSE OF THE SHORT MARKEY/0GC 6/26 4
-QUESTION 7 (CONTINUED) HISTORY IN THE U.S.,
IN COMPARISON TO THE RETURN PERIOD OF LARGE EARTHQUAKES, AMONG OTHER FACTORS, THESE ESTIMATES MAY HAVE LARGE UNCERTAINTIES.
ALL STRUCTURES, SYSTEMS AND COMPONENTS NECESSARY TO ACHIEVE A SAFE SHUTDOWN ARE SEISMICALLY QUALIFIED FOR THE SSE AND ARE EXPECTED, WITH HIGH CONFIDENCE, TO FUNCTION TO BRING THE PLANT TO A SAFE SHUTDOWN.
WITH THESE STRUCTURES, SYSTEMS AND COMPONENTS FUNCTIONING PROPERLY, ONLY IN THE EVENT OF MULTIPLE UNRELATED FAILURES OF SAFETY RELATED SYSTEMS DUE TO SOME UNDISCOVERED COMMON CAUSE FAILURE MECHANISM (SUCH AS A MAJOR DESIGN ERROR), COINCIDENT WITH A SEVERE EARTHQUAKE UP TO A SEVERITY OF AN SSE, WOULD THERE BE A CHANCE OF AN ACCIDENT WHICH WOULD REQUIRE OFFSITE EMERGENCY RESPONSE.
THE PROBABILITY OF THESE TWO EVENTS OCCURRING PROXIMATELY IN TIME IS VERY MUCH LOWER THAN THE PROBABILITY OF EITHER INDIVIDUAL EVENT.
THE NECESSARY STRUCTURES, SYSTEMS AND COMPONENTS OF THE DIABLO CANYON PLANT WERE DESIGNED AND CONSTRUCTED IN ACCORDANCE WITH ALL THE APPROPRIATE.NRC REQUIREMENTS TO PERFORM THEIR INTENDED
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FUNCTION DURING AND FOLLOWING AN EARTHQUAKE OF A MAGNITUDE UP TO THE SSE, MARKEY/0GC 6/26
__ Question 7 Comissioner Asselstine's coments:
The logic in the Comission's response is fundamentally flawed. The Comission would have the Congress believe that, if a plant meets the NRC requirements related-to earthquakes, then there is no need for emergency planning en the basis of seismic risk. All plants are required to meet NRC requirements before they are permitted to operate; yet they are also required to have emergency response plans. There is no basis for distinguishing NRC seismic requirements from any other requirements.
Emergency planning is necessary because of uncertainties in risk and the uncertainties in the seismic risk are among the largest.
It is so difficult to calculate the seismic risk that most probabilistic risk assessments do not even address it.
Further, an earthquake even at or.
below the safe shutdcwn earthquake represents a potential comen cause failure mode that could negate the defense-in-depth concept.
I have substantial doubts that knowledgeable people would support the Comission's position that the potential for a severe earthquake being a comon cause failure mechanism has been reduced to a vanishingly small level by NRC requirements.
Examples of why an earthquake less than a " safe shutdown earthouake" should not be ruled out as a potential cause of an accident requiring off-site emergency response, are the attached IE Infomation Notices No.
85-45 (" Potential Seismic Interaction Involving The Movable In-Core Flux Mapping System Used in Westinghouse Designed Plants"), dated June 6, 1985,
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_ _. _. _ _ _.__. and No. 85-47 (" Potential Effect of Line-Induced Vibration on Certain Target Rock Solenoid-Operated Valves"), dated June 18, 1985, which identify an overlooked seismic vulnerability in plants such as Diablo Canyon and San Onofre, respectively.
1 The Commission would also have the Congress believe that "the probabilitythatanearthquakelessthantheSSE[whichisanearthquake producing ground acceleration of 0.759] would result in a radiologic f
release and simultaneously complicate the emergency plan (is) too low to require specific consideration of the effects of earthquakes on emergency planning." The Commission's own requirements for Diablo Canyon require implementation of the emergency plan when earthquakes less than the SSE occur. -In its emergency plan for Diablo Canyon the licensee is required to declare an " alert" at the plant, to activate the on-site Technical Support Center and the on-site Operational Support Center, and to promptly notify State and local authorities in the event of an earthquake which produces a ground acceleration of 0.2. These required actions involve designated 9
l PG&E personnel traveling from wherever they may be at the time of the earthquake to the site in order to provide assistance to the shift in coping with the effects of the earthquake.
In addition, the State and i
l local authoriti;es must augment their resources and bring their prinary i
response centers to standby status. The Consnission also requires Diablo Canyon to declare a " site area emergency" and to activate the on-site Technical Support Center and the Near site Emergency Operations Facility in the event of a 0.69 earthquake. " Site Area Emergencies" are events that are in process or have occurred which involve actual or likely major 4
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6-failures of plant functions needed for protection of the public. These Consnission requirements are based on the staff's technical judgment or the possible effests of such earthquakes on structures and components. Becasue the Connission refused to allow consideration of the complicating effects of earthquakes on emergency planning, there is nothing in the record of the Diablo Canyon proceeding to show whether these required actions can even be carried out.
1 I would also point out that. in a recent letter to the Consnission the Advisory Consnittee on Reactor Safeguards (ACRS) did not support the Consission's conclusion that there was a technical basis for not considering the complicating effects of earthquakes on emergency planning.
The ACRS stated: "We see no technical reason for the exclusion of earthquakes from the natural phenomena censidered in off-site emergency planning for nuclear power plants." Letter from David A. Ward, Chainnan ACRS, to Nunzio J. Palladino, Chairman NRC, dated June 10, 1985, "ACRS Consnents on The Consideration of Earthquakes in Off-Site Emergency Planning," p. 1.
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SSINS No.:
6835 IN 85-45 UNITED STATES NUCLEAR REGULATORY C009tISSION OFFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D.C.
20555 June 6, 1985 IE INFORMATION NOTICE NO. 85-45:
POTENTIAL SEISMIC INTERACTION INVOLVING THE MOVA8LE IN-CORE FLUX MAPPING SYSTEM USED IN WESTINGHOUSE DESIGNED PLANTS Addressees:
i All power reactor facilities holding an operating license (0L) or a construction permit (CP).
Purpose:
This information notice is provided as notification of a potentially generic problem involving seismic interactinne within the mawahle f'ux mancina system at Westinghouse destaaad a na h.
It is expected that recip'ents w111 review b nuamation for applicability to their facilities and consider actions, if appropriate, to preclude a similar probles from occurring at their facilities.
However, suggestions contained in this information notice do not constitute requirements and, therefore, no specific action or written response is required.
i b.
Description of Circumstances:
i On June 22, 1984, Carolina Power and Light (CP&L) Company informed the Nuclear Regulatory Commission (NRC) of a potentially reportable ites per the provisions of 10 CFR 50.55(e) and 10 CFR 21 at their Shearon Harris Nuclear Power Plant (SHNPP) Unit 1.
The NRC was infomed that interactions between the nonsafety related portions of the flux mapping system and the tubing / seal table during a seismic event had not been adequately considered by Westinghouse.
At that time CP&L was waiting for Westinghouse to perfom a structural integrity analysis for the portion of the in-core flux sapping system that is located above the i
in-core instrumentation tubing / seal table.
In a letter dated February 12, 1985, CP&L informed the NRC that the potential seismic interactions were indeed reportable.
The potential interactions exist because portions of the flux mapping system that have not been seismically analyzed are located directly above the in-core instrumentation tubing / seal table. failure durina a seinale event c>uld consi-I bly cause multinle failures in the f1ur - aiaa tuhina or fittinas taat wou d
nroouce a small break late af ---'--? ---'"--' _ Recent discussions with Westingnouse nave revealed that the potential seismic interactions could exist l
at other Westinghouse plants including operating plants.
Furthermore, multiple failures of flux mapping tubing and/or fittings constituto an unanalvred small Areak loss of coolant accident because the break flow wou d effectively be fros i
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IN 85-45 June 6, 1985 Page 2 of 2 the bottom of the reactor vessel.
Thus, the consequences could be beyond the licensing design basis for loss of coolant accidents.
It should be noted that gny loss of reactor coo ant system ar.caure boundary integrity caused hv seismi-t n the fium --aa4aa eye +== wa"Ic be outsiae the desian casi, i r-
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basis of a plant mad thaea'^--
" a *" -a * * ' a raamedle<< of we.stner tne conse-auences were within tha<. far less of coolant accidents analvred in safety analysis reports.
The NRC staff has discussed this issue with the Westinghouse Regulatory Response i
Group. Based on discussions with the Regulatory Response Group and Westinghouse, it is our understanding that Westinghouse will notify their customers of this problem by letter in the near future.
No specific action or written response is required by this information notice;
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however, contingent upon the results of further staff evaluations, a bulletin i
or a generic letter requesting specific licensee actions may be issued.
If you have any questions regarding this matter, please contact the Regional Admini-strator of the appropriate NRC regional office or this office.
gr J
Jo an,'6 rector i
Divisio f Emergency Preparedness and E insering Response Office of Inspection and Enforcement Technical
Contact:
David Powell (301) 492-7155
Attachment:
List of Recently Issued IE Information Notices A
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r SSINS No.: 6835 IN 85-47 UNITED STATES NUCLEAR REGULATORY C0pWISSION f
0FFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D. C.
20555 June 18, 1985
~
IE INFORMATION NOTICE NO. 85-47:
POTENTIAL EFFECT OF LINE-INDUCED VIBRATION ON CERTAIN TARGET ROCK SOLEN 0ID-0PERATED VALVES Addressees:
All nuclear power reactor facilities holding an operating license (OL) or a constructionpermit(CP).
Purpose:
1This information notice is to alert addressees that certain models of Tirget Rock (TR) solenoid-operated valves have failed during environmental qualification testing. The analysis of the test failure suggests that line vibration induced by hydrodynamic force in piping and other forms of mechanical vibration may cause the loosening of the solenoid holddown nut of those TR solenoid valves with design features similar to TR valve models that were tested.
Because of the potential safety significance of line-induced and other vibra-tions on TR solenoid operated valves, it is suggested that recipients review this information for applicability to their facilities and consider actions, if appropriate, to preclude a similar problem occurring at their facilities.
Suggestions centained in this notice do not constitute NRC requirements; therefore, no specific action or written response is required.
Description of Circumstances:
On November 14, 1984, Arizona Public Services Company provided the NRC with a final report on a 10 CFR 50.55(e) reportable condition relating to qualification testing of certain TR solenoid-operated valves.
Four'TR valves, procured by Combustion Engineering (CE) for use at Palo Verde Nuclear Generating Station Unit 3, were tested to the requirements of NUREG-0588, Category I.
Test valves included two 1-inch TR valves, model 77L-001 and two 2-inch TR valves, model 77L-003. The qualification test involved irradiation to 50 megarads, thennal l
aging at 260*F for 635 hours0.00735 days <br />0.176 hours <br />0.00105 weeks <br />2.416175e-4 months <br />, mechanical cycling, vibrational aging to represent nonnal service vibration, seismic testing, and finally, testing in a simulated LOCA environment. The licensee reported that during the qualification testing, a number of anomalies were identified, and the test was discontinued when the test valves failed to function for different reasons during the seismic testing.
CE and TR appraised the overall safety significance of the observed test anomalies for the licensee..They considered the failure of the valve to onen
_on demand as a result of enlenola leaa snortino caused by line-inauced vibration 11 850614024o
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IN 85-47 June 18, 1985 1
Page 2 of 3 maar un he a e-
= =ada a' 'milure that, in a seismic event could natantdally diemb' e several redundant vaivae at u n same time.
This fa lure of the valve ~
to open on aan no is the only observec test anomeTy considered to have significant generic safety implieetions and is the subject of this information notice.
The root cause of the valve failure to open is attributable to the mechanism used to secure the solenoid to the upper works assembly of the valve. The valves used at Palo Verde have a jam nut and a lock washer that are used together to secure the solenoid.
If the upper works assembly is rotated during va' ve handling or installation, the jam nut can become loose, allowing axial rotation of the coil. As a corrective action, the licensee has stated in its latest report to the NRC that existing TR valves Models 77L-0001 and 77L-003 are being upgraded. The upgrading includes a complete factory refurbishment of the valves with potting of the coil into the solenoid housing. The potting till prevent differential movement between the coil and housing to preclude lead wire abrasion during line-induced vibration.
Target Rock Corporation also has reported that the following TR valve models and plants may be affected by line-induced vibration:
Valve Models Power Plants 1
J 72A-001/002/003/004/005/007 Monticello Nuclear Power Plant l
72V-001 Duane Arnold Energy Center
'l 73E-002 Trojan Nuclear Plant l
75G-002/003/008/005/013 San Onofre Nuclear Generatina Station 2
75GG-001 Grand Gulf Nuclear Station 75KK-204/207 Susquehanna Steam Electric Station 768-002/024/039/040/041/042/043/044 Midland TR has made the recomendation to the NRC that the utilities for the above i
listed power plants consider perfonning a review of safety-related systems that incorporate the above listed solenoid valves to determine if solenoi/ locking devices are installed on their valves. TR recommends that locking devices for the listed valves be installed per TR Service Bulletin 8302 (attached), if they j
have not already been installed and the potential for line-induced vibration 1
exists. (Note: the locking device of Service Bulletin 8302 is different from the potting mechanism used for the Palo Verde solenoids.)
t
e IN 85-47 June 18, 1985 e
Page 3 of 3 No specific action or written response is required by this infonnation notice.
If you have any questions regarding this matter, please contact the Regional Adninistrator of the appropriate NRC regional office or this office.
~
[
A dward L. Jorda, Director Division of Emergency Preparedness and Engineering Response Offica of Inspection and Enforcement I
Technical
Contact:
N. B. Le, NRR (301)492-9686 G. Hubbard, IE (301)492-9759 Attachments:
1.
Target Rock Service Bulletin 8302 2.
List of Recently Issued IE Infonnation Notices i
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UNITE]STATEa g
NUCLEAR REEULATORY COMMISSION y
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June 10, 1985 Honorab M unzio J. Palladino Chairman U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Dear Dr. Palladino-
SUBJECT:
ACRS Com ENTS ON THE CONSIDERATION OF EARTHQUAKES IN OFF-SITE EMERGENCY PLANNING During its 302nd meeting, June 6-8, 1985, the Advisory Committee on Reactor Safeguards completed its review of the proposed amenhent to 10 CFR 50, " Emergency Planning and Preparedness for Production and Utilization Facilities."
This topic was also considered during the i
301st ACRS meeting on May 9-11,1985, the 297th meeting on January 10-12, 1985 and during a joint meeting of our Reactor Radiological Effects and Site Evaluation Subcommittees on January 3-4, 1985.
During j
these reviews the Committee had the benefit of discussions with the NRC Staff, representatives of the Federal Emergency Management Agency, and invited experts.
The Committee also had the benefit of the documents referenced, including the public comments submitted to the NRC on the i
proposed amen hent.
j On the basis of these discussions, we offer the following comments:
1.
We see no technical reason for the exclusion of earthquakes from the natural phenomena considered in off-site 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 off-site authorities should have the benefit of studies indicating the types and potential locations of such damage. The study of this kind already performed l
for the region surrounding the Diablo Canyon site would clearly mest the intant of this comment.
2.
Ist the. assessment of the impact of natural events on emergency planning, the major effort should be to identify potential problems and to devise alternative approaches for their resolution.
This would include requirements for assuring appropriate means for communication, for identifying alternative routes for the evacu-ation of the local population, and for identifying ciretanstances under which sheltering might be a more effective response than evacuation.
In many cases, such assessments may lead to a decision that no further response or action is required. The goal should be G/11 -- To EDO for Appropriate Action. Dist:
RF.85-461 cs 4 rh [ ? /d /,b W l s uv 't~
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I 2-June 10, 1985 Honorable Nunzio J. Palladino j
to assure that emergency plans, as developed, contain sufficient flext-bility to cope with the potential added impacts of such events.
We hope you will find these comments useful.
5 Sincerely, David Chairman i
References:
1.
U. 5. Nuclear Regulatory Commission,10 CFR Part 50, " Emergency
~;
Planning and Preparedness for Production and Utilization Facil-ities " Proposed Rule Federal Register, Vol. 49, No. 247, pp.
49640-49643 dated December 21, 1984 2.
Sixty-one public comments received by S. J. Chilk, Secretary of the Commission, in response to Reference 1.
3.
Correspondence from the following in response to requests for information regarding this subject:
a.
Andre Messiah, Ministry of Industry, Service Central de Surete, des Installations Nucleaires, France, dated March 29, 1985 b.
I. A. Breest, Federal Minister of the Interior Federal Republic of Germany, dated March 22, 1985 c.
Thayer from Taipei, Taiwan, dated April 24, 1985 (Limited Official Use) d.
T. Taniguchi, Ministry of International Trade and Industry, Japan, dated April 20, 1985 e.
M. Wakasa, Reactor Regulation Division, NSB, STA, Japan, dated April 19, 1985 f.
G. Mandeus, Director Information Services, Swedish Nuclear Power Inspectorate, dated April 16, 1985 4.
TERA Corporation, " Earthquake Emergency Planning at Diablo Canyon,"
Volumes 1-3, dated September 2, 1981 i
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June 10, 1985
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Honorable ltunzio J. Palladino Chainman U. 5. Iluclear Regulatory Commission Washington, O. C.
20555 4
Dear Dr. Palladino:
SUBJECT:
ACR$ COBOIENTS ON THE CONSIDERATION OF EARTHQUAKES IN 0FF-S DERGENCY PLANNING During its 302nd meeting, June 6-8, 1985, the Advisory Committee on Reactor Safeguards completed its review of the proposed amendeont to 10 CFR 50, " Emergency Planning and Preparedness for Production and Utilization Facilities."
This topic was also considered dering the 301st ACR$ meeting on May 9-11,1985, the 297th meeting on January 10-12, 1985 and during a joint meeting of our Reactor Radiological Effects and $lte Evaluation Subcommittees on January 3-4, 1985.
During these reviews the Committee had the benefit of discussions with the Mtc Staff, representatives of the Federal Emergency Management Agency, and invited experts.
The Committee also had the benefit of the documents referenced, including the public comments submitted to the NRC on the proposed amenhent.
On the basis of these discussions, we offer the following comments:
1.
We see no technical reason for the exclusion of earthcuakes from the natural phenomena considered in off-site emergency planning for nuclear power plants.
However, we believe that only 14P
- consideration of earthquakes is appropriate.
For s i t e. -we # -
earthquake capable of severely dawi;ing ernergency travel ruutes is sufficient.ly likely to occur, the' local off-site authorities should i
have the benefit of studies indicating the types and potential
~
locations of such damage. The study of this kind already performed ftr the regten surrounding the Diablo Canyon site would clearly mest the intent of this comment.
2.
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 approaches for their resolution.
This would include requirements for assuring appropriate means for communication, for identifying alternative routes for the evacu-ation of the local population, and for identifying circumstances i
under which sheltering night be a more effective response than evacuation.
In many cases, such assessments may lead to a decision that no further response or action is required.
The goal should be
- 11 -- To EDO for Appropriate Action.
Dist: RF.85-461 i
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Nonorable Nunzio J. Palladino June 10, IC"5 to assure that amargency plans, as developed, contain sufficient flexi-bility to cope with the potential added Japacts of such events.
We hope you will find these comments useful.
$1ncerely, l
Dev d k
Chairman
References:
1.
U. 5. Nuclear Regulatory Commission,10 CFR Part 50, " Emergency Planning and Preparedness for Production and Ut111 stion Facil-ities " Proposed Rule. Federal Register, Vol. 49, No. 247, pp.
49640-49643 dated December 21, 1984 2.
Sixty-one public comments received by 5. J. Chilk, Secretary of the Commission, in response to Reference 1.
3.
Correspondence from the following in response to requests for information regarding this subject:
Andre Mess < ah, Ministry of Industry, Service Central de Surete, a.
des Installations Nucleaires, France, dated March 29, 1985 b.
I. A. Breest, Federal Minister of the Interior, Federal Republic of Germany, dated March 22,1985 c.
Thayer from Taipei, Taiwan, dated April 24,1985(Limited official Use) d.
T. Taniguchi, Ministry of International Trade and Industry.
Japan, dated April 20, 1985
. ;c r 2,.o.. ' a sfon, N58, STA, Japan, datad l;
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tne Inform. U.9 Services, Swedish Nuclear r.
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- F,1985 e-4 TERA W.~ e -
.....uake Faere-.v Planning at Diablo Canyon,"
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QUESTION 8.-
WHAT IS THE BASIS FOR THE CONCLUSION OF THE
' COMMISSION THAT AN EARTHQUAKE SMALLER THAN THE
--SSE REQUIRING EMERGENCY RESPONSE IS LESS LIKELY THAN OTHER ACCIDENT INITIATORS REQUIRING EMERGENCY RESPONSE?
PLEASE PROVIDE ANY CITATIONS TO THE ON THE RECORD PROCEEDING THAT SUPPORT THE COMMISSION'S POSITION.
ANSWER.
THE COMMISSION DECISION DOES NOT REST ON A COMPARISON OF THE RELATIVE PROBABILITIES OF NATURAL PHENOMENA AS ACCIDENT INITIATORS.
RATHER, THE COMMISSION DECISION IS BASED ON THE RECORD MATERIAL WHICH SHOWS THAT THE PROBABILITY THAT AN EARTHQUAKE WILL INITIATE AN ACCIDENT OR OCCUR COINCIDENT IN TIME WITH A NON-SEISMIC ACCIDENT INITIATOR IS SO LOW THAT THE COMPLICATING EFFECTS OF EARTHQUAKES ON EMERGENCY PLANNING NEED NOT BE SEPARATELY LITIGATED.
THIS RECORD MATERIAL INCLUDES THE UNUSUALLY EXTENSIVE REVIEW OF THE ADEQUACY OF THE SEISMIC DESIGN OF DIABLO CANYON AND THE CONCLUSION THAT THE PROBABILITY OF OCCURRENCE OF A SIGNIFICANT EARTHQUAKE (I.E. AND EARTHQUAKE CAUSING A GROUND ACCELERATION AT OR ABOVE THAT WHICH WOULD BE CAUSED BY THE 0.PERATING BASIS EARTHQUAKE) IN THE VICINITY OF THE PLANT IS LOW.
ALAB-644, 13 NRC 903, 989-994 (1981).
HAD A SIMILAR RECORD FOR OTHER NATURAL PHENOMENA BEEN BEFORE THE COMMISSION,.AND HAD THE PARTIES RA! SED THE ISSUE OF CONSIDERING l
THE. COMPLICATING EFFECTS OF THOSE OTHER NATURAL PHENOMENA THE COMMISSION COULD HAVE CONSIDERED WHETHER THE COMPLICATING EFFECTS OF THOSE NATURAL PHENOMENA SHOULD BE LITIGATED.
MARKEY/0GC 6/26 1
... - -.... -. _. ~ Question 8 Comissioner Anelstine's coments:
The Comission's response to this question is artful, but somewhat misleading. The Comission's decision may be based on material in the
' record which deals with the probabilities of earthquakes. However, the implication that the Comission draws from those record discussions or probabilities, i.e... that the probabilities are so low that the complicating effects of earthquakes need not be separately litigated -- is itself a factual determination. That factual determination should have been the subject of litigation since the issue was properly raised by parties to the proceeding.
While the Comission is also correct that its decision does not rest on a specific comparison of the relative probabilities of natural phenomena, that is not the point, and in fact is the problem.
Implicit in the Comission's decision is, necessarily, a finding that earthquakes are somehow so much more unlikely to disrupt emergency response than other natural phenomena that earthquakes need not be specifically considered in emergency planrjing. The Comission has never explained why that is so, nor has it specifically compared earthquakes to other relatively infrequent natural phenomena that it considers in emergency planning for other plants.
Further, the ACRS does not support the Comission's conclusion. The ACRS has told the Comission: "We see no technical reason for the exclusion of esrthquakes from the natural phenomena considered in off-site emergency
8-planning for nuclear power plants." Letter from David A. Ward, Chainnan ACRS to Nunzio J. Palladino, chainnan NRC, dated June 10, 1985.
"ACRS Coreents on tinr Consideration of Earthquakes in Offsite Emergency Planning,"
- p. 1.
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CUESTION 9.
PLEASE STATE WHETHER THE COMMISSION BELIEVES THAT,
__FOR THE DI ABLO CANYON PLANT, THE S!MULTANEOUS OR PROXIMATE OCCURRENCE OF A MAJOR EARTHQUAKE AND A RADIOLOGICAL EMERGENCY IS LESS PROBABLE THAN THE SIMULTANEOUS OR PROXIMATE OCCURRENCE OF A HURRICANE AND A RADIOLOGICAL EMERGENCY, A TORNADO AND A RADIOLOGICAL EMERGENCY OR A VOLCANIC ERUPTION AND A RADIOLOGICAL EMERGENCY.
STATE THE FACTUAL BAS!$ FOR THE COMMISSION'S VIEW AND PROVIDE ANY CITATIONS TO THE ON THE RECORD PROCEEDING THAT SUPPORT THE COMMISSION'S POSITION.
ANSWIR.
AS DISCUSSED ABOVE, THE COMMISSION'S DECISION DID NOT REST ON A COMPARISON OF THE RELATIVE PROBABILITIES OF NATURAL PHENOMENA AS ACCIDENT INITIATORS.
MAPXEY/0GC 6/26 1
.UC ESTION 10:
THE COMMISSION'S BRIEF FOR THE RESPONDENTS BEFORE THE U.S. COURT OF APPEALS STATED THAT "WHEN THE RELEVANT PROBABILITIES ARE CONSIDERED, THE COMMISSION'S DECISION IS WELL SUPPORTED."
(A)
SPECIFICALLY.WHAT RELEVANT PROBABILITIES DID THE COMMISSION CONSIDER?
(B)
WHAT RELEVANT PROBABILITIES ARE PART OF THE RECORD PROCEEDING?
PLEASE PROVIDE ANY CITATIONS.
ANSWER:
THE " RELEVANT PROBABILITIES" CONSIDERED BY THE COMMISSION, AND THE RECORD SUPPORT FOR THEM, WERE:
- 1' THE LOW PROBABILITY THAT AN EARTHQUAKE UP TO AND IhlLUDING THE SAFE SHUTDOWN EARTHQUAKE (SSE) COULD RESULT IN A RADIOLOGIC RELEASE.
THE CONCLUSION THAT THIS PROBABILITY IS LOW IS SUPPORTED BY THE ENTIRE RECORD OF THE ADEQUACY OF THE SEISMIC DESIGN, A RECORD WHICH IS UNUSUALLY EXTENSIVE IN THIS CASE.
AMONG OTHER THINGS, THAT RECORD SHOWS THAT THE VALUE OF THE SSE USED TO DESIGN THE PLANT IS VERY CONSERVATIVE.
LBP 26, 10 NRC AT 478-85 (1979)
THIS CONSERVATISM IN THE PLANT'S SEISMIC DESIGN BASIS 4
MARKEY/0GC-6/26
QUESTION 10(A)'s (B) -
IMPLIES A CORRESPONDING CONSERVATISM IN THE EVALUATION OF THE PLANT'S CAPABILITY OF SUCCESSFULLY WITHSTANDING THELEFFECTS OF AN EARTHQUAKE.
(2)..THE LOW PROBABILITY OF AN EARTHQUAKE EXCEEDING THE SSE.
T THE RECORD CONTAINS DATA ON EARTHQUAKE MAGNITUDES AND FREQUENCIES IN THE VICINITY AROUND DIABLO CANYON.
THAT DATA SHOWS THAT.THERE IS AN INVERSE RELATION BETWEEN EARTHQUAKE MAGNITUDE AND THE FREQUENCY OF EARTHQUAKE OCCURRENCE--THE LARGER THE EARTHQUAKE, THE LESS FREQUENTLY IT WILL OCCUR.
CALCULATIONS IN THE RECORD SHOW THAT 275 YEARS IS THE SHORTEST INTERVAL BETWEEN CONSECUTIVE OCCURRENCES OF AN EARTHQUAKE RESULTING IN A GROUND ACCELERATION OF 0,2G, THE OPERATING BASIS EARTHQUAKE (OBE) FOR THIS PLANT.
ALAB-644, 13 NRC AT 992 (1981).
THE PROBABILITY OF OCCURRENCE OF AN EARTHQUAKE IS RELATED TO THE INTERVAL BETWEEN CONSECUTIVE OCCURRENCES, ALSO KNOWN AS THE RETURN PERIOD.
THE DATA IN THE DIABLO CANYON RECORD SHOWS THAT THE RETURN PERIOD FOR AN EARTHQUAKE HAVING THE MAGNITUDE OF THE SSE, AN EARTHQUAKE RESULT!NG IN A GROUND ACCELERATION OF 0.75G, IS MUCH GREATER THAN FOR AN EARTHQUAKE HAVING THE MAGNITUDE OF THE OBE.
FOR EXAMPLE, THE RECORD SHOWS THAT THE AVERAGE RETURN PERIOD FOR A MAGNITUDE 6.5 EARTHQUAKE ON THE SECTION OF THE MARKEY/0GC-6/26
~
c QUESTION 10(A)ma (B),
-HOSGRI ADJACENT TO DIABLO CANYON, AN EARTHQUAKE TEN TIMES SliALLER THAN THE SSE, IS ABOUT 1,000 YEARS.
LBP -
79-26710NRC.AT482'(1979).
FURTHERMORE, PG8E WITNESS JOHN A. ELUME TESTIFIED THAT IF A 7.5 MAGNITUDE EARTHQUAKE IS CONSIDERED POSSIBLE ON THE HOSGRI FAULT, AN EFFECTIVE ACCELERATION OF 0.75G WOULD HAVE AN AVERAGE RETURN PERIOD OF ROUGHLY 100,000 YEARS.
LBP 26, 10 NRC AT 489 (1979).
BECAUSE THE RECORD SHOWS THAT RETURN PERIODS !NCREASE WITH INCREASING EARTHQUAKE MAGNITUDE, THE RECORD ALSO SHOWS THAT THE RETURN PERIOD OF AN EARTHQUAKE HAVING A MAGNITUDE EXCEEDING THE SSE IS GREATER STILL AND, THUS, THAT THE PROBABILITY OF AN EARTHQUAKE EXCEEDING THE SSE IS LOW.
INDEED, A FUNDAMENTAL PREMISE OF SEISMIC DESIGN IS THAT THE SSE Is THE BASIS FOR DESIGN BECAUSE OF THE LOW PROBABILITY OF OCCURRENCE OF AN EARTHQUAKE EXCEED THE SSE.
(3)
THE VERY LOW PROBABILITY OF THE CONTEMPORANEOUS OCCURRENCE OF AN EARTHQUAKE LARGE ENOUGH TO AFFECT THE EMERGENCY PLAN AND AN INDEPENDENTLY CAUSED ACCIDENT LEADING TO A RADIOLOGIC RELEASE.
AS DISCUSSED ABOVE, THE RECORD CONTAINS CALCULATIONS SHOWING THAT THE SHORTEST RETURN TIME OF AN EARTHQUAKE RESULTING IN A GROUND MOTION OF 0.2G IS 275 YEARS AND DATA SHOWING THAT THE RETURN INTERVAL OF LARGER MARKEY/0GC-6/26
QUESTION 10(A) s (B),
EARTHQUAKES IS EVEN LONGER.
THUS, THE RECORD SHOWS THAT THE LARGER.THE EARTHQUAKE, THE LOWER THE PROBABILITY OF ITS OCCURRENCE.
AND THE ENTIRE RECORD ON THE ADEQUACY OF THE PLANT'S DESIGN TO WITHSTAND ALL DESIGN BASIS ACCIDENTS SUPPORTS THE FINDING THAT THERE IS A LOW PROBABILITY OF A NON-EARTHQUAKE CAUSED ACCIDENT WHICH WILL LEAD'TO A RADIOLOGIC RELEASE.
THuS, THE RECORD SUPPORTS THE CONCLUSION THAT THE PRODUCT OF THE PROBABILITIES OF THE CONTEMPORANEOUS OCCURRENCE OF AN EARTHQUAKE LARGE ENOUGH TO INTERFERE WITH EMERGENCY PLANNING AND AN UNRELATED RADIOLOGIC EMERGENCY IS VERY LOW.
9 e
MARKEY/0GC-6/26
-_-__ _ =
=__
-l Question 10:
Commissioner Auelstine's Coninents:
One " relevant probability" the Commission neglected to mention or to consider is the possibility that there would be a need for some sort of emergency response - i.e. getting people or equipment to the plant - for less than an SSE. The Commission ignores the fact that for an earthquake below the SSE radiological releases are not the only reason there might be a need for emegency response. The Diablo Canyon emergency plan specifically recognizes this and requires the licensee to take certain actions should a.2g or a.6g earthquake occur - both are less than the SSE.
(See answer to question 4.) The effects of less than an SSE earthquake are exactly the kinds of effects the NRC staff experts think should be considered.
(See affidavit of Brian Grimes of June 22, 1981 and see Memorandum from William J. Dircks to the Commission dated July 5, 1985.) Further, the Commission fails to recognize that the uncertainties in all of these " relevant probabilities" are exactly why we have emergency planning. Since seismic risk is a large part of the risk associated with the plant, that potential should be considered in emergency planning.
c
^
i QUESTION 10:
THE COMMISSION'S BRIEF FOR THE RESPONDENTS BEFORE THE U.S. COURT OF APPEALS STATED THAT "WHEN THE RELEVANT PROBABILITIES ARE CONSIDERED, THE COMMISSION'S DECISION IS WELL SUPPORTED."
(C)
DOES THE COMMISSION AGREE WITH THE ASSERTIONS OF THE GENERAL COUNSEL DURING THE COMMISSION DELIBERATIONS THAT THERE IS "NO CONVINCING RATIONAL BASIS FOR THE COMMISSION'S VIEW THAT THE COMPLICATING EFFECTS OF EARTHQUAKES ON EMERGENCY
. RESPONSE DESERVES NO CONSIDERATION."
IF THE COMMISSION DOES NOT AGREE, WHAT IS THE BASIS FOR SUCH DISAGREEMENT?
PLEASE PROVIDE ANY CITATIONS TO THE FACTUAL ON THE RECORD PROCEEDING THAT SUPPORT THE COMMISSION'S POSITION.
ANSWER:
CONTRARY TO THE UNDERLYING ASSUMPTION OF THIS QUESTION, THE GENERAL COUNSEL'S STATEMENT DID NOT REFER TO THE COMMISSION'S DECISION IN DIABLO CANYON.
RATHER, THE QUOTED STATEMENT BY THE GENERAL COUNSEL' REFERS TO HIS ASSESSMENT OF RELYING SOLELY ON THE PRIOR DECISION OR THE SAME ISSUE IN THE SAN ONOFRE PROCEEDING, TO REACH THE SAME CONCLUSION IN THE DIABLO CANYON PROCEEDING.
THE COMMISSION TOOK THE GENERAL COUNSEL'S ADVICE TO RE-EXAMINE IN THE DIABLO CANYON PROCEEDING THE 0GC-6/26 q
m QUESTION 10 (C) ISSUE OF THE COMPLICATING EFFECTS OF EAPTHQUAKES ON EMERGENCY PLANNING.
THE COMMISSION BELIEVES THAT THE RECORD OF THE DIABLO CANYON PROCEEDTAG AMPLY SUPPORTS THE COMMISS10N'S DECIS10N.
THE GENERAL COUNSEL'S BRIEF TO THE D.C. CIRCUIT SUPPORTS THE RATIONALITY OF THE DIABLO CANYON DECISION REACHED BY THE COMMISSION.
0GC-6/26
.:..._..:.=.
QUESTION 11:
DOES THE COMMISSION BELIEVE THAT A POTENTIAL LICENSING DELAY THAT COULD RESULT FROM THE PUBLIC REARING PROCESS IS A RELEVANT CONSIDERATION IN THE COMMISSION'S DELIBERATIONS OF WHETHER A CONTESTED SAFETY ISSUE IS MATERIAL TO A LICENSING DECISION?
ANJWfR:
.THE COMMISSION BELIEVES THAT A POTENTIAL LICENSING DELAY THAT COULD RESULT FROM THE PUBLIC HEARING PROCESS IS CLEARLY NOT A RELEVANT CONSIDERATION IN THE DETERMINATION OF WHETHER AN ISSUE IS MATERIAL'TO A LICENSING DECISION.
HOWEVER, THE COMMISSION REASONABLY CAN TAKE INTO ACCOUNT THE AVOIDANCE OF UNNECESSARY DELAY IN DETERMINING HOW TO STRUCTURE ITS PROCEEDING TO MEET THE REQUIREMENTS OF THE ATOMIC ENERGY ACT AND THE NRC REGULATIONS.
e OGC-6/26
QUESTION 12:
DID THE COMMIS$10N CONSIDER OR RELY ON EXTRA-RECORD INFORMATION IN ITS DELIBERATIONS
~CONCERNING ISSUANCE OF A DIABLO CANYON FULL POWER LICENSE.
ANSWER:
TO THE EXTENT THAT A COMMISSION DECISION ON FULL-POWER OPERATING LICENSE CONCERNS UNCONTESTED ISSUES, THE COMMISSION MAY, AND DOES, RELY ON ANY AVAILABLE INFORMATION.
AS FOR CONTESTED ISSUES, SUCH AS THE EFFECTS OF EARTHQUAKES ON EMERGENCY PLANNING AT DIABLO CANYON, THE COMMISSION'S DECISION RELIED ONLY ON INFORMATION IN THE RECORD AND REASONABLE INFERENCES FROM THAT INFORMATION.
THE COMMISSION'S DECISION.DID NOT RELY ON ANY EXTRA-RECORD MATERIAL.
WHILE THE COMMISSION'S DISCUSSIONS AT THE CLOSED MEETINGS INCLUDED THE MATERIAL SERVED ON THE PARTIES WITH CLI-84-4, THE COMMISSION'S DECISION DID NOT RELY ON THAT MATERIAL BECAUSE IT CORROBORATED EVIDENCE IN THE ADJUDICATORY RECORD OR INFERENCES FROM THAT EVIDENCE.
OGC-6/26
)
Question 12 Comissioner Asselstine's coments:
The transcripts of the Comission meeting clearly indicate that extra record material was discussed and that in fact some Comissioners based their decision, at least in part, on that infonnation. Further, the
" inferences" the Comission drew from the record material were factual
. determinations which should have been the subject of a hearing.
(See responsetoquestion8.)
e
QUESTION 13.
PLEASE PROVIDE A LISTING OF ALL SCHEDULE SLIP-PAGES AND LICENSING DELAYS SINCE THE ISSUANCE OF
__ THE CONSTRUCTION PERMIT AT DIABLC CANYON.
THIS SHOULD INDICATE THE CAUSE AND LENGTH OF EACH DELAY.
ANSWER.
i THROUGHOUT THE DIABLO CANYON PROJECT DELAYS OCCURRED IN THE PACIFIC GAS AND ELECTRIC (PGsE) SCHEDULE AS WELL AS IN THE NRC LICENSING. SCHEDULE, PGaE NORMALLY INFORMED THE NRC STAFF OF THEIR DELAYS WHICH THEN WERE CONSIDERED BY US WITH RESPECT TO OUR SCHEDULE FOR LICENSING ACTIVITIES.
HOWEVER, WE DO NOT NORMALLY MONITOR SCHEDULE DELAYS BY APPLICANTS OR LICENSEES, AND THEREFORE WE CANNOT PROVIDE YOU WITH SUCH INFORMATION.
DELAYS WERE CAUSED, IN GENERAL, BY NEW INFORMATION WHICH BECAME AVAILABLE DURING THE REVIEW PROCESS AND IMPACTED THE NRC REVIEW ANu LICENSING PROCESS AS WELL AS THE PG8E SCHEDULE.
WE CANNOT RECONSTRUCT AN ACCURATE HISTORY OF OUR LICENSING SCHEDULE AND DELAYS FOR THE DIABLO CANYON PLANT. HOWEVER, SINCE THE ISSUANCE OF THE UNIT 1 CONSTRUCTION PERMIT IN APRIL 1968 FIVE ISSUES RESULTED IN SCHEDULE DELAYS AS DISCUSSED BELOW WITH RESPECT 1
MARKEY/0GC 6/26
QUESTION 13 (CONTINUED) TC DIABLO CANYON UNIT 1.
THE PGaE AND THE NRC SCHEDULE FOR UNIT 2 WAS AT ALL TIMES APPROXIMATELY ONE TO ONE AND ONE HALF YEARS BEHIND THE UNtf 1 SCHEDULE (UNIT 2 CONSTRUCTION PERMIT WAS ISSUED IN DECEMBER 1970).
1.
HOSGRI FAULT CONSIDERATIONS IN AUGUST 1973 PGaE SUBMITTED THE DIABLO CANYON UNITS 1 AND 2 FINAL SAFETY ANALYSIS REPORT (FSAR) FOR OUR DETERMINATION OF WHETHER THE FSAR WAS SUFFICIENTLY COMPLETE TO INITIATE A DETAILED OPERATING LICENSE (OL) REVIEW.
DURING THIS ACCEPTANCE REVIEW THE STAFF BECAME AWARE FOR THE FIRST TIME OF THE EXISTENCE OF THE 4
HOSGRI FAULT.
THE FSAR WAS DOCKETED IN OCTOBER 1973.
AT THAT TIME THE NRC SCHEDULE FOR ISSUANCE OF A FULL-POWER LICENSE WAS i
NOVEMBER 1974.
IT SOON BECAME APPARENT THAT THE NOVEMBER 1974 SCHEDULE WAS NOT ACHIEVABLE. PG8E SUBMITTED EXTENSIVE DETAILED INFORMATION ON THE HOSGRI FAULT WHICH RESULTED IN FURTHER QUESTIONS BY THE STAFF AND SITE EXPLORATION.
A SECOND SUBMITTAL WAS MADE IN THE FALL OF 1975.
IN APRIL 1976 THE NRC STAFF CONCLUDED THAT A SEISMIC EVENT OF MAGNITUDE 7.5 M, ORIGINATING AT THE HOSGRI FAULT NEAR THE SITE, IS THE APPROPRIATE DESIGN BASIS EARTHQUAKE FOR THE DIABLO CANYON PLANT.
d MARKEY/0GC 6/26
QUESTION 13 (CuNTINUED).
PGaE COMPLETED THE NECESSARY REDESIGN AND ANALYSIS FOR THE HOSGRI EVENT AND THE STAFF COMPLETED ITS EVALUATION BY LATE 1978.
THE
~
DIABLO CANYON _ SEISMIC 3ESIGN WAS THE SUBJECT OF HEARINGS BY THE ATOMIC SAFETY AND LICENSING BOARD FROM LATE 1978 TO EARLY 1979.
ABSENT ANY OTHER CONSIDERATIONS WE FIND THAT AN OPERATING LICENSE FOR DIABLO CANYON UNIT 1 COULD HAVE BEEN ISSUED IN ABOUT JUNE 1979, 2.
THREE MILE ISLAND ACCIDENT AS A RESULT OF THE TMI ACCIDENT IN MARCH 1979 WE TEMPORARILY t
SUSPENDED THE ISSUANCE OF OPERATING LICENSES.
THIS IMMEDIATELY IMPACTED THE SCHEDULE FOR DIABLO CANYON UNIT 1.
WHEN WE RESUMED THE ISSUANCE OF OPERATING LICENSES IN EARLY 1980 WE LIMITED SUCH LICENSES TO LOW-POWER OPERATIONS (SEQUOYAH WAS THE FIRST FACILITY TO RECEIVE SUCH A LICENSE).
ONLY AFTER SUFFICIENT AND SATISFACTORY OPERATION AT LOW-POWER LEVELS DID WE THEN ISSUE A FULL-POWER LICENSE.
THIS APPROACH IS STILL APPLIED TODAY.
IN MID 1979 DIABLO CANYON WAS IDENTIFIED AS ONE OF SEVEN NEAR TERM OPERATING LICENSES (NT0LS) TO COMPLETE THE TMI ACTION ITEMS IN THE NEAR TERM FOR ISSUANCE OF A LOW POWER LICENSE.
3.
SEISMICALLY INDUCED SYSTEM INTERACTIONS AS A RESULT OF THE TMI ACCIDENT WE ALSO REQUIRED FURTHER EVALUA-TIONS DIRECTED TO THE POSSIBLE INTERACTIONS OF NONSAFETY AND SAFETY-GRADE SYSTEMS DURING NORMAL OPERATIONS AS WELL AS DURING TRANSIENTS AND ACCIDENTS.
IN RESPONSE TO A RECOMMENDATION BY THE MARKEY/0GC 6/26 w
QUESTION 13 (ivdTINUED).
ADVISORY COMMITTEE ON REACTCR SAFEGUARDS (ACRS) IN NOVEMBER 1979, PGaE DEVELOPED A PROGRAM TO EVALUATE SUCH SYSTEMS INTERACTIONS, IN PARTICULAR AS INDUCED BY SEISMIC EVENTS AND COMMITTED TO COMPLETE THE PROGRAM PRIOR TO FULL-POWER OPERATION, PG8E IDENTIFIED AND COMPLETED ALL NECESSARY MODIFICATIONS BY LATE 1984.
4.
INDEPENDENT DESIGN VERIFICATION PROGRAM THE LOW-POWER LICENSE FOR UNIT 1 WAS ISSUED IN SEPTEMBER 1981.
SHORTLY THEREAFTER PGaE DETERMINED AND I'NFORNED THE STAFF THAT AN EQUIPMENT LAYOUT DRAWING FOR UNIT 2 HAD BEEN USED IN THE ANALYSIS OF UNIT 1.
AS A RESULT, THE STAFF RAISED QUESTIONS REGARDING THE DESIGN QUALITY ASSURANCE APPLIED TO THE DIABLO CANYON PROJECT.
IN NOVEMBER 1981 WE SUSPENDED THE UNIT 1 LICENSE PENDING THE SATISFACTORY COMPLETION OF AN INDEPENDENT DESIGN VERIFICATION PROGRAM (IDVP) FOR THE SEISMIC DESIGN.
THE STAFF REQUIRED FURTHER INDEPENDENT DESIGN VERIFICATION OF ALL OTHER DESIGN ASPECTS PRIOR TO ISSUANCE OF A FULL-POWER LICENSE.
THE IDVP FOR THE SEISMIC AND NON-SEISMIC DESIGN WAS COMPLETED IN LATE 1983.
THE MODIFICATIONS WERE COMPLETED IN EARLY 1984 AND IN APRIL 1984 WE COMPLETED REINSTATEMENT OF THE DIABLO CANYON UNIT 1 LOW-POWER LICENSE.
THE FULL-POWER LICENSE WAS ISSUED IN NOVEMBER 1984 AFTER THE U. S.
COURT OF APPEALS' LIFTED ITS STAY ON THE ISSUANCE OF THE LICENSE.
l MARKEY/0GC 6/26
QUESTION 13 (CuNTINUED) '
i 5.
ALLEGATIONS SINCE EARLY 1_983 NUMEROUS ALLEGATIONS WERE MADE REGARDING THE DESIGN, CONSTRUCTION, OPERATION AND MANAGEMENT OF THE DIABLO CANYON NUCLEAR POWER PLANT.
THESE ALLEGATIONS WERE MADE BY A VARIETY OF SOURCES, PRIMARILY BY EMPLOYEES OF PGaE CONTRACTORS 3
AND SUBCONTRACTORS. AS OF TODAY IN EXCESS OF 1700 ALLEGATIONS HAVE BEEN MADE.
OUR STAFF HAS SCREENED EACH OF THESE ALLEGA-TIONS AND PGaE WAS REQUESTED TO PROVIDE ADDITIONAL INFORMATION.
IN PARTICULAR, IN THE AREA 0F PIPING AND PIPE SUPPORT WE CONDUCTED IN EARLY 1984 AN EXTENSIVE EVALUATION EFFORT, INCLUDING AUDITS AND SYSTEM WALKDOWNS AT THE PLANT (A SIMILAR EFFORT WAS FERFORMED LATER FOR UNIT 2).
6.
JUDICIAL STAY THE COMMISSION ISSUED A FULL-POWER LICENSE FOR DIABLO CANYON UNIT 1 IN AUGUST 1984.
SUBSEQUENTLY, THAT LICENSE WAS STAYED BY THE D.C. CIRCUIT COURT UNTIL THE COURT DISSOLVED THE STAY ON OCTOBER 31, 1984.
IN
SUMMARY
, FOR DIABLO CANYON UNIT 1 A DELAY OF TEN YEARS OCCURRED FROM NOVEMBER 1974, AS HAD BEEN SCHEDULED WHEN THE OL APPLICATION WAS DOCKETED, TO DECEMBER 1984, WHEN THE FULL-POWER LICENSE WAS ISSUED.
IT IS DIFFICULT TO DETERMINE THE EXACT IMPACT EACH OF THE MARKEY/0GC 6/26 i
QUESTION 13 (CONTINUED) 6-ABOVE ISSUES HAD ON THE OVERALL COMPLETION FOR THE DIABLO CANYON PLANT.
HOWEVER, IT IS REASONABLE TO CONCLUDE THAT THE HOSGRI FAULT AND THE INDEPENDENT DESIGN VERIFICATION PROGRAM WERE THE MAJOR CONTRIBUTORS TO THE DELAY.
O MARKEY/0GC 6/26
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