ML20198H619
| ML20198H619 | |
| Person / Time | |
|---|---|
| Issue date: | 09/06/1985 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Palladino N NRC COMMISSION (OCM) |
| Shared Package | |
| ML20197J537 | List: |
| References | |
| FOIA-85-653 NUDOCS 8601310066 | |
| Download: ML20198H619 (23) | |
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umico svares NUCLEAR REGULATORY COMMISslON I
WASHINGTON. O. C. 20555 W.5 "f 5 SEP' 0 61995
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MEMORANDUM FOR:
Nunzio J. Palladino Chaiman FROM:
William J. Dircks Executive Director for Operations
SUBJECT:
SEVERE LOW FREQUENCY NATURAL PHENOMENA CONSIDERATIONS IN EMERGENCY PLANNING:
SECY 85-283 On September 3,1985 you requested answers to questions relating to your deliberations on the subject Comission paper. The attached questions with accompanying staff replies are forwarded for your infomation and use.
/
William J. Dircks Executive Director for Operations Attachments j
cc:
Comissioner Roberts Comissioner Asselstine Comissioner Bernthal Comissioner Zech OPE OGC SECY J. Taylor (IE)
H.Denton(NRR)
G.Cunningham(ELD)
R.Minogue(RES) 8601310066 051223 me
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RESPONSE TO CHAIRMAN PALLADINO
/1.
In view of the statement on the second full paragraph on page 6 of
- , as well as the statement in the paragraph which starts on the bott~om of page 7. of the SECY paper and the information provided in, why are additional emergency preparedness measures needed for severe", low-frequency natural phenomena over those which are already required in 10 CFR 50.47 and Appendix E?
Staff Reply The staff believes and has shown in SECY-85-283 that there is inherent flexibility in existing radiological emergency plans.
Nonetheless, there exist significant uncertainties concerning the complicating effects of natural phenomena.
The staff, in developing the rationale for the proposed rule change weighed the uncertainties involved plus the EAL' logic in NUREG-0654 against the inherent flexibility and the FEMA programs.
This weighing proved to be a very close call.
Nonetheless the staff decided to choose the conservative approach by proposing a regulation that in reality will require minimal additional emergency preparedness measures thereby assuring that the flexibility does exist to mitigate (not eliminate) the consequences of an. accident complicated by offsite disruption of comunication and transportation routes.
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A2.
Is this rule not a backfit and, if it' is, has an appropriate cost /
benefit anal'ysis be'e'n completed?
I do not believe that the statement in the Regulatory Analysis (Enclosure 3 of the SECY paper) adequately address this question; for example, there is no quantification of industry costs on page 4 of Enclosure 3.
Staff Reply The proposed rule.is a backfit; however, the staff believes that nearly all licensees already meet the requirements and, if they do not, compli-ance would require only minimal expenditure of resources.
For example:
1.
To get needed personnel into the plant.
Compliance could be accomplished by the licensee contracting with a helicopter company on a contingency basis to transport emergency personnel after a severe natural phenomenon.
An example of costs are:
San Onofre has their own corporate helicopter fleet used for normal corporate transportation--cost is 50.
Diablo Canyon has contracted with a helicopter company--this contract costs nothing because the heli-copter company already does a significant amount of normal corpor-ate transportation and wanted to be assured of the work if and when a natural phenomenon occurred.
For those utilities that must pay for this type of contract, the staff estimates a yearly cost of under $5,000.
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2.
Comunication.
All utilities already have redundant and diverse coninunication capabilities (requirsd by section. IV.E.. Appendix E ' '
to 10 CFR Part 50).
The staff believes that almost all licensees' comunications capabilities would al rea'dy meet the proposed requirements--if not, a sophisticated beeper system could be purchased for approximately $20,000.
3.
State and local governments should identify alternate routes of travel and methods. for determining whether to shelter or evacuate.
Section J of NUREG-0654 already specifies that alternate routes of travel should be identified in the event of an emergency.
The staff believes that local authorities already understand the options available for protective measures.
For severe natural phenomena that provide a significant warning time, such as hurri-canes and floods, evacuation may be appropriate.
For most other severe natural phenomena, sheltering has always been considered a
. viable and in many instances a preferred t.rotective measure.
Evacuation is not recomended as the imediate at tion for any short time-scale release where the evacuation is doubtful of completion before the exposure would occur.
The appropriate action. would be to instruct people to shelter and then after plume passage to relocate expcced individuals out of the contaminated area which would likely be a narrow area upon which deposition of particulate materials occurred during plume passage.
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Overall costs for modifying (if necessary) State and local government plans
.is. estimate.d.at $20,000 per site.
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A3. What is the definition of "sesere; low-frequency natural phenomena characteristic of 'the site" as proposed under Alternative 3 (page 5,.
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L SECY-85-283)?
What severity level is intended?
What is the lowest level of frequency to be considered?
For example ~, would consideration be given to a 30" snow storm in Florida? How does the frequency of s,uch a snow storr compare with the frequency of an earthquake exceeding the SSE in California?
Staff Reply The proposed rule requires an assumption that nomal comunication and road networds have been disrupted.
The objective is to assure that emergency plans for all nuclear power plants are sufficiently flexible so that the best possible job of mitigating the consequence of a nuclear accident will be done even if such disruptions occur.
Since the rule focuses on the ability to respond to consequences (i.e., disruption of corinunication and road networks), regardless of how they were caused, there is no need to consider the frequency of the initiating events or to establish a cutoff frequency or severity level range for such events.
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6 A4 Would not the assumption that normal road networks are disrupted (page 5 of SECY paper) make.it virtual.ly impossible to carry out the functions listed under Alternative 3?
ould this lead to a requirement for one or mor,e dedicated standby helicopters for such unlikely events?
Staff Reply Most natural phenomena do not produce equal impact over a broad region and there would probably be alternative transportation routes available in many cases.
In oractice, local ot thorities would check the primary routes to detennine if they were passable before ordering their use.
Emergency plans already identify alternative routes of travel (currently existinginNUREG-0654,sectionJ).
If all of the available routes were severely disrupted, local officials would probably order sheltering and not evacuation.
The overall thrust of the proposed rule is to do the best you can do under the circumstances aided by planning based upon disrupted normal comunications and road networks.
Although there would be a requirement that provisions be established to bring needed staff onsite as necessary to cope with degraded modes of operation, there is no requirement for having the capability to evacuate persons from the plant environs.
The implementation would not require dedicated standby helicopters but could require an agreement by a licen-see with a transportation provider (not necessarily helicopters) to
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7 transport emergendy personnel to the site after
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Bl. What " event" is being referred to on page 1, numbered paragraph 27 What is' meant by "de' graded modes?"
Are w'e assuming the occurrence of an.
accident?
Staff Reply-The event the staff is referring to is any natural phenomena that might cause a site area or general emergency at a nuclear power plant as described in NUREG-0654.
" Degraded modes" might include anything from
- loss of offsite power to disruption of plant safety systems and does not necessarily assume the occurrence of an accident.
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- 82. On page 2, numbered paragraph 4, how would the requirement o' " knowing f
i alternative routes of travel" work. in t ractice in view of the assumpt. ion stated elsewhere in the SECY paper that "the severe natural phenomena has (sic) disrupted normal comun'ication and road networks?"
Staff Reply This paragraph is intended to provide offsite authorities as much infor-mation as possible for."... consideration of alternative actions" after the occurrence of a natural phenomena.
Most natural phenomena do not produce equal impact over a broad region and there would probably be alternative transportation routes available in many cases.
In practice, local, authorities would check the primary routes to determine if they were passable before ordering their use.
Emergency plans already identify alternative routes of travel (currently existing in NUREG-0654, section J).
If all of the available routes were severely disrupted, local officials would probably order sheltering and not evacuation. The overall thrust of the proposed rule is to do the best you can do under the circumstances aided by planning' based upon disrupted nonnal commu-nications and road networks.
10 B3.
Please specify the "important word changes" in Alternative 1 on page 4, and explain the'ir importance.
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Staff Reply The proposed rule change published on December 21, 1984 'sta ted that neither emergency response plans nor evacuation time estimates need consider the complicating effects of earthquakes. The public perception of this propos.ed. rule change was that NRC was
" writing off" or
" ignoring" carthquakes.
Instead, if the proposed rule stated that no s
additional emergency preparedness measures need be established to account for earthquakes (or severe, low frequency natural phenomena) than are already required in Appendix E, it would make clear that there already exist reasonable plans for coping with earthquakes.
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- 84. With respect to Alternative 3, see basic questions 3 and 4.
Staff Reply Please see.the staff replies to basic questions 3 and 4.
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- 85. On page 6, second bullet, how do current emergency plans "take into con-sideration plant accidents whose probability are in the range of 10-4 to 10-5 "
For example, is a licensee required to maintain the ability to
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transport personnel to the plant after the accident notwithstanding any conceivable accident whose probability is 'in the range of 10~4 to 10-57 Please provide some examples to illustrate what is meant by "2 to 4 times the SSE."
Staff Reply In the development of NUREG-0396, " Planning Basis for the Development of State and Local Government Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants," December 1978, the staff recomended, and the Comission agreed with, the establishment of a 10-mile plume exposure emergency planning zone.
In establishing this EPZ, the consequences of a spectrum of accidents, including class 9 accidents, was considered.
The probability of class 9 accidents is in the range of 10~4 to 10-5 This probability range was derived from the Reactor Safety Study, WASH-1400 (see, for example, Table 5-1 in the Main Report).
NUREG-0654, section B,
specifies that certain emergency personnel must be able to augment onsite personnel in the event of an emergency (especially a site area or general emergency).
Attached are figures taken from Lawrence Livennore Lab Report UCID #20421, Volume 1, which shows examples of the estimated frequencies of earthquakes at nuclear power plants and their. relationship to the SSE.
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o 13 E.U.S'SCISMIC HAZARD CHARACTERIZATION INCLUDING SITE CORRECT ION PERCENTILES = 15.0,50.0'AND 85.0'
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14 E.U.S SEISMIC HAZARD OMRACTERIZATION INCLUDIPC SlTC CORRECT ION PEROENTILES = 15.0,50'.O AND 55.0
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- 86. On page 7, first paragraph, what " dose estimates" are referred to?
In the 'second paradraph*, may the Commission legally rely on the results of the staff's review as a basis for the final rule?
Staff reply Dose estimates refer to projected offsite doses resulting from radio-active releases from the plant, which is already provided for by a
c In general terms, the Comission may legally rely on a staff review conducted in the context of an ongoing' rulemaking proceeding provided that such review is made a part of the rulemaking record.
In this instance, however, the staff's review is not formally documented as a part of the rulemaking record inasmuch as it was based on very preliminary results of a larger contract effort being conducted by Pennsylvania State University for the Commission which is not yet completed.
The staff's review was based on crude data concerning 20 actual, non-nuclear evacuations for which data was readily available in the timeframe for this rulemaking.
In the staff's judgment, this data lends support to the view that "no additional emergency ' preparedness measures need be established to account for severe natural phenomena."
In light of the staff's position in SECY-85 283 and recognizing that the staff's review is not formally part of the rulemaking record, however, reliance on this review is not necessary to promulgation of the new rule.
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17 B7. On page 8,
within what time period must the licensee be able to transport the necessa'y personnel to the plant?
r Staff Reply The licensee would-have 12 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the start of the phenomenon to transport the necessary personnel to the plant (See pages 31-32 of
.. to the Comission Paper).
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18 B8. What, if any, hearing rights are created?
Staff Reply Promulgation of the rule proposed by the staff would have a variety of-effects on licensing proceedings dependent on the individual status of each. With respect to proceedings in which final agency action has been taken, the.new rule could give rise to requests for the initiation of a proceeding undir '20 CFR 9 2.206.
Such requests would normally be subject to initial action by the Director of NRR or IE, as appropriate, and subsequent review of the Director's decision by the Commission.
In those proceedings in which final agency action has not yet been taken, two different situations pertain.
For those cases in which an initial decision has not been rendered by the Licensing Board, parties may. seek to file a new, late-filed contention based on the new rule.
In such instances, an intervenor would have to satisfy the standards of 10 CF3 5 2.714 pertaining to late-filed contentions.
L In cases in which the record has been closed, either before or after an initial decision has been rendered, an intervenor would have to move to reopen the record and satisfy the standards for reopening a closed record in addition to the late-filed contention requirements.
Such motions could be filed with tha presiding 1.icensing Board, Appeal Board or Comission, as appropriate.
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19 In sum, then, it is possible that a hearing could be held to litigate l.
I issues based on' the new rule if determined appropriate by the Director of NRR or IE in response to a, petition filed Onder 10 CFR 5 2.206, or '
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based on the' admission of' a late-filed' contention in' an ongoing or reopened licensing proceeding.'
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Please* explain the statement on page 28 that presently required licensee O
actions, taken in con' junction with state an local responsibilities
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1 during an emergency, lead the Comission to conclude that the final rule I
is logical and' warranted?
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Staff Reply.
I The staff f, eels that the capab'ilities outlined in the staffs proposed regulations must already exist in order to permit a license to perform the actions that are required in the event of a site area or a general emergency (which would be declared in,the event of a severe natural phenomena).
The'refore, the staff feel ~s that these requirements are logical and warranted in helping licensees fulfill those requirements in l
NUREG-0654 which already exist.
Because the proposed Federal Register is from the Comission, it is only appropriate that the Comission make that finding if the Comission felt that it reflected the majorities wishes.
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21 C2.
On page 31, Item 1, is it contemplated that licensees would need to have alternate transportation (e.g., standby helicopters)?
Staff Reply Standby of. dedicated helicopters is not considered necessary. A contin-gency agreement between the licensee and a helicopter company on other transportation providers would be sufficient.
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On pag 6 38, what basis is to be used to decide what are " severe, low-i frequency natural phsnomena characteristic of the site?"
1 Staff Reply Please see. Staff reply to question A1.
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