ML20197J532

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Forwards Rev to Udall Question 3 Re Effect of Earthquakes on Emergency Plans,Per H Meyers Comment
ML20197J532
Person / Time
Issue date: 04/16/1985
From: Funches J
Office of Nuclear Reactor Regulation
To: Rehm T
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
Shared Package
ML20197J537 List:
References
FOIA-85-653 NUDOCS 8504300161
Download: ML20197J532 (6)


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MEMORANDUM FOR:

T. A. Rehm Assistant for Operations Office of the Executive Director for Operations FRO't:

Jesse L. Funches Director Planning and Progran Analysis Staff Office of Nuclear Reactor Regulation

SUBJECT:

COMMENT RE PRE-HEARING QUESTION FOR 2/28/85 UDALL AUTHORIZATION HEARINGS Enclosed is our revision to Udall Question 3 to respond to Henry Myers' coa.cnt.

If you have any questions, please contact ne or Lars Solander on extension 24516.

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Jesse L. Funches, Director Planning and Progran Analysis Staff Office of Nuclear Reactor Regulation E'1 closure:

As stated cc: !f. Denton D. Eisenhut DISTRIBUTION VDircks F3randenburg (ED0f000519)

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EFFECT OF EARTHQUAKES ON EMERGENCY PLANS:

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IN AUTHORIZING FULL POWER OPERATION AT DIABLO

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CANYON, THE Com!SSION ADOPTED THE POSITION THAT AN EARTHQUAKE WITH MAGNITUDE LESS THAN THE SAFE SHUTDOWN EARTHQUAKE (SSE) WAS UNLIKELY TO CAUSE A REACTOR ACCIDENT. REQUIRING IMPLEMEtKATION OF THE EMERGENCY PLAN. THIS POSITION WAS AN ESSENTIAL ELEMENT IN THE C0mlSS10N'S DECIDING THAT, IN THE DIABLO CANYON FROCEEDING, THERE WAS NO NEED TO CONSIDER THE IMPACT OF AN EARTHQUAKE UPON THE WORKABILIT( OF THE EMERGENCY PLAN.

(A) MiAT ANALYSIS WAS CONDUCTED TO ESTIMATE THE PROBABILITY THAT AN EApNQUAKE, SMALLER THAN-THE SSE, WOULD INITIATE AN ACCIDENT THAT MIGHT REQUIRE IMPLBEllTATION OF THE DIABLO CANYON EMERGEf;CY PLAN 7 ANSER.

THE SAFE SHUTDOWN EARTHQUAKE, OR SSE, FOR A NUCLEAR PLANT IS BASED UPON AN EVALUATION OF THE MAXIPSE EARTHQUAXE POTENTIAL FOR THE SPECIFIC SITE. THE SSE IS EVALUATED AS TMT EARTHQUAKE WHICH PRODUCES THE MXIMIE VIBRATORY GROUND MTION FOR WHICH CERTAIN STRUCTURES, SYSTEMS AND COMPONENTS tilST BE DESIGNED AND CON-STRUCTED TO FEl%IN CUNCT10NAL. ALL STRUCTURES, SYSTEMS AND 4/16/85

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g C1JESTION 3.A. (CONTINUED).

CCNPONENTS fECESSARY TO ACHIEVE A SAFE SHUTDOWN ARE SEISMICALLY

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QUAL {IEDFORTHESSEANDAREEXPECTED,WITHHIGHCONFIDENCE,TO FUNCTION TO BRING THE PLART TO A SAFE SHUTDOWN.

PROBABILISTIC ESTIt%TES FOR THE OCCURRENCE OF AN SSE ARE TYPICALLY ON THE ORDER OF ONE IN A THOUSAfD TO ONE IN TEN THOUSAND PER YEAR.

BECAUSE OF THE SHORT EARTHQUAKE HISTORY IN THE U.S., IN COMPARISON TO THE RETURN PERIOD OF LARGE EARTHQUAKES, AMONG OTHER FACTORS, THESE ESTit%TES MAY HAVE LARGE UNCERTAINTIES.

ONLY IN THE EVENT OF MULTIPLE UNRELATED FAILURES OF SAFETY RELATED SYSTEMS DUE TO SOME Uf0!SCOVERED C0ft10N CAUSE FAILURE MECHANISM -

(SUCH AS A MAJOR DE, SIGN ERROR), COINCIDENT WITH A SEVERE EAR'lH- -

00AKE SUCH AS AN SSE, WOULD THERE BE A CHANCE OF AN ACCIDENT WHICH WOULD REQUIRE OFFSITE EMERGENCY RESPONSE. THE PROBABILITY OF THESE Tho EVENTS OCCURRING PROXIPATELY IN TIE IS VERY NCH LOWER THAN THE PROBABILITY OF EITHER If0!VIDUAL EVENT.

lHE NECESSARY STRUCTURES, SYSTEMS AND COPPONENTS OF Tm DIABLO CANYON PLANT WERE DESIGNED AND CONSTRUCTED IN ACCORDANCE WITH ALL THE APPROPRIATE NRC aEQUIREENTS TO PERFORM THEIR INTENDED FUNCTION DURING AND FOLLOWING AN EARTHQUAKE OF A MAGNITUDE UP TO THESSE.

UDAUJNRR 4/16/85 m

l QUESTl0N'3.

(B) WHAT IS THE BASIS FOR CONCLUDING THAT SUCH AN EARTHQUAKE IS SIGNIFICANTLY LESS LIKELY TO INITIATE AN ACCIDENT REGUIRING IMPLEMENTATION l

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OF THE EE RGENCY PLAN THAN OTHER ACCIDENT INITIATORS WHICH ARE IMPLICIT IN THE IMPOSITION l

OF EMERGENCY PLANNING REQUIREMENTS?

I ANShER THE OBJF.CTIVE OF EMERGENCY PLANNING IS TO ASSURE SUITABLE EMERGEN RESPONSE CAPABILITY FOR A WIDE SPECTRlN OF ACCIDENTS, IRRESPECTIVE OF ANY PARTICULAR INITIATING EVENT. THUS,.NO PARTICULAR ACCIDENT IS USED FOR PLANNING PURPOSES; RATHER, POTENTIAL CONSEQUENCE

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SEQUENCES ARE USED TO DEVELOP AN APPROPRIATE. PLANNING. BASE WITH0 lit REGARD FOR THE INITIATING EVENT.

THE PARTICULAR ELE?EilTS OF AN ACCIDENT SEQUENCE (E.G., INITIATION OF EMERGENCY CORE COOLING, OCCURREllCE OF FIRES, ETC.) ARE CONSIDERED AS INITIATING CONDITIOt!S FOR VARIOUS EMERGENCY ACTION LEVELS, AS IS THE OCCURRENCE, OR PROJECTED OCCURRENCE, OF NATURAL PENOMENA SUCH AS HURRICANES, TORNADOS, FLOODS, AND EARTHQUAKES.

AS DESCRIBED IN THE " CRITERIA FOR PREPARATION AND EVALUATION OF RADIOLOGICAL EERGENCY RESPONSE PLANS AND PREPAREDNESS IN SUPPOR OF NUCLEAR POWER PLANTS" (NUREG-0654/ FEMA-REP-1, REY. 1, APPENDIX 1),

EARTHQUAKESUPTOTmSSEAREINITkATINGCONDITIONSFORTHE" UNUSUAL EVEfN"'AND" ALERT" LEVELS.

I UDALUNRR 4/9/85

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-l QUESTION 3.B. (CONTINUED) THIS' DESIGNATION DOES NOT IMPLY, H0tEVER, THAT THE OCCURRENCE OF

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SUCH'AN EARTHQUAKE WOULD CAUSE AN ACCIDENT WITH OFFSITE RADIDLOGICAL L

IffLICATIONS. RATHER, THESE EMERGENCY ACTION LEVELS DESIGNATE GENERAL PREPAREDNESS CONDITIONS TO ASSURE THAT, AT THE " UNUSUAL EVENT" LEVEL, THE FIRST STEP IN ANY RESPONSE LATER FOUND TO BE NECESSARY HAS BEEN CARRIED OUT AND THE OPERATING STAFF IS IN A STATE OF READINESS TO SYSTEMATICALLY HANDLE THE INFORMATION AfD DECISION-MAKING ASSOCIATED WITH THE EVENT AND, AT THE " ALERT" LEVEL, THE EMERGENCY PERSONNEL ARE READILY AVAILABLE TO RESP 0f0 IF THE SITUATION BECOMES MORE SERIOUS AND TO PROVIDE CURREfST STATUS.INFORMATION TO APPROPRIATE OFFSITE AUTHORITIES. THESE FUNCTIONSAREINTEf!DEDTOASSURETHATALLgESPONSEORGANIZATIONSS THAT COULD BE POTENTIALLY IfNOLVED RECOGNIZE THE EVENTUALITIES THAT MIGHT HAVE TO BE DEALT WITH IF ANY EfERGENCY RESPONSE BECAME NECESSARY.

THE CCFMISSION'S DECISION IN DIABLO CANYON, FOR THESE PURPOSES, DOES NOT DETRACT FROM THE FUNDAMEfEAL REQUIREMENT THAT SUFFICIENT FLEXIBILITY BE PROVIDED IN THE EMERGENCY PLAN TO ACC0rtiODATE A W:DE SPECTRlN OF ACCIDENTS IRRESPECTIVE OF THEIR CAUSE. THIS DECISION PROPERLY RECOGNIZES THAT POTEtEIAL IMPEDIMENTS TO EMERGENCY RESPONSE CAUSED BY MORE FREQUENT NATURAL PHENOMENA (WHICH HAVE BEEN EXPLICITLY CONSIDERED IN THE PLANNING), ARE j

LDALL/NRR 4/9/85

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QJESTION 3.B. (CONTINUED)..

SUFFIb!ENTLYSIMILARTOPERMITANEFFECTIVERESPONSEEVENINTHE EVEtIOF N EARTHOUAKE WHICH HAS NOT BEEN EXPLICITLY PLANNED FOR BECAUSE OF ITS LOW PROBABILITY, FOR THE REASONS DESCRIBED IN THE RESPONSE TO OUESTION 3(A). WE COMPARE THE EMERGENCY PLANNING AND PREPAREDNESS PROVISIONS APPLICABLE TO EARTHQUAKES WITH OTHER NATURAL PHEf10fENA BECAUSE THEY HAVE IN COFNON THE COMPLICATIONS ASSOCIATED WITH THE NATURAL EVENT; FOR EXAMPLE, IMPASSABLE ROADS, SEVERED COPNUNICATION LItiES, AND POOR WORKING CONDITIONS. ON THE OTHER HAND, ACCIDENTS CAUSED BY SIMPLE HLNAN ERRORS OR EQUIP-MENT FAILURES DO NOT HAVE SUCH COMPLICATIONS AND, THEREFORE, ARE tJOT AS SEVERE WITH RESPECT TO EMERGENCY PLANNING REQUIREtENTS.

IN THIS SENSE, THEN, THE LIKELIHOOD OF AN EARTHQUAKE UP TO THE i

SSE IS NOT A SIGNIFICANT FACTOR WITH RESPECT TO THE EFFECTIVEfJESS.

OF THE EfERGENCY PLAN.

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UDALL/NRR I4/9/85 x.

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