ML20207E113

Statement of Views on Questions Re Design of Nonconforming Structures to Withstand Hurricanes & Tornadoes.W/Certificate of Svc.Related Correspondence

ML20207E113
Person / Time
Site:	South Texas
Issue date:	07/17/1986
From:	Sinkin L CHRISTY, W., Citizens Concerned About Nuclear Power, INC.
To:	Atomic Safety and Licensing Board Panel
References
CON-#386-046, CON-#386-46 OL, NUDOCS 8607220264
Download: ML20207E113 (5)

Text

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UNITED STATES OF AMERICA 75tOWSED NUCLEAR REGULATORY COMMISSION USNRC 4

BEFORE THE ATOMIC SAFETY AND LICENSING BOARDg g .

In the Matter of ( QFFICE OF SECRETARY

) u0CMETING & SERVICE HOUSTON LIGHTING AND ( Docket Nos. 50-498 OL BRANCH POWER COMPANY, ET AL. ) 50-499 OL

(South Texas Project, (

Units 1 and 2) (

CITIZENS CONCERNED ABOUT NUCLEAR POWER, INC. (CCANP) i STATEMENT OF VIEWS ON QUESTIONS CONCERNING DESIGN OF NONCONFORMING STRUCTURES TO WITHSTAND  !

j HURRICANES AND TORNADOS In its Partial Initial Decision issued June 13, 1986 (LBP-85-15, slip op. at 71-89), the Licensing Board declined to grant summary disposition of Intervenor Contention 4 insofar as the contention dealt with the design of three structures, or portions  !

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thereof, to withstand hurricane-generated missiles. Contention 4 states, in part, that there are non-Category 1 structures which "are not designed to withstand winds generated by hurricanes and if damaged could provide missile type projectiles which

! could penetrate Category I structures which are inadequately protected." (emphasis added) j The record is clear that there are indeed Category I structures, or portions thereof, which are inadequately protected i

i against hurricane-generated missiles. These are (1) the Isolation Valve Cubicle (IVC) roof area; (2) certain Mechanical Electrical Auxiliary Building (MEAB) HVAC openings; and (3) certain diesel

! generator exhaust stack openings.

The Applicants and Staff do not argue that these structures are designed to withstand hurricane-generated missiles. Instead, they argue that the probability of a hurricane-generated missile striking such a structure and the probability of such a strike

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resulting in a radioactive release to the environment is so low that the Board can enter a finding of reasonable assurance as to the licensing of the Project.

CCANP views this entire matter as a licensing amendment matter which is not being so treated. The Applicants committed themselves to designing Category I. structures to withstand hurricane-generated missiles. The Applicants failed to meet that commitment in various areas of the plant. The Applicants now offer post hoc rationalizations, in the form of probabilistic risk assessments (PRAs), as to why there was no need for the Applicants to design said structures as per their commitments.

These rationalizations do not change the fact that the Applicants have failed to meet their construction permit commitments and now request the ASLB to amend those commitments.

Furthermore, even accepting arguendo that approval of these design failures is not a licensing amendment, the ASLB is being asked to rely on an inherently unreliable methodology.

Application of probabilistic risk assessment to the nuclear power endeavor is a highly complex and relatively imperfect technique of assessing the risk entailed in a given decision. In this particular case, the decision rests on sparse data about a very complex weather system, on studies not performed by the NRC, and on repeated applications of the PRA methodology.

Hurricanes as a system are among the least understood phenomena on the planet. Tornad'oes generated within a hurricane have not been the subject of extensive historical study either.

Said tornadoes are quite difficult to study because their appearance is difficult to predict, their point of contact with 2

the Earth is very difficult to predict, and the placement of scientific equipment adequate to measure these phenomena is, therefore, extremely difficult. Applicants rely on data from a limited 30 year historical record of occurences developed under these circumstances.

Second, the events for which the PRA analyses are used are:

(1) occurence of a hurricane-generated tornado; (2) the generation of missiles by such a tornado; (3) the striking of the inadequately designed area by such a missile; and (4) damage to equipment by the tornado-generated missile. Given the lack of an  ;

adequate historical data base on the weather phenomena in question, the first PRA is a relatively meaningless exercise and certainly has less reliability than the limited reliability of PRA analyses conducted on better understood phenomena. With four different probabilistic risk assessments being performed, the unreliability of the overall assessment increases dramatically; there is room for error in each of the analyses, so the more analyses, the more likely an error has occurred.

Third, the model for the distribution of potential tornado missiles by number and length is based on a survey performed by the Electric Power Research Institute, a nuclear industry research organization, not the NRC.

Finally, it should be noted that the recent Applicant and Staff submissions on this matter */ both agree that the areas in

• Applicants' Answers to the Board Questions Concerning Design of Nonconforming Structures to Withstand Hurricanes and Tornados dated July 11, 1986; NRC Staff Response to Licensing Board's

" Memorandum and Order (Board Questions Concerning Design of Nonconforming Structures to Withstand Hurricanes and Tornados)"

of June 23, 1986 dated July 14, 1986.

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I question could be protected, but Applicants argue that the cost and time delay is excessive for the benefit received. CCANP believes that the benefit sought is assurance of safety versus reliance on hypothetical models and a questionable use of mathematics and that, given the licensing amendment natgre of this decision, the maximum benefit should be sought in the absence of the greater protection offered by the licensing amendment process, i.e. the Applicants should be ordered to provide missile protection.

These views are offered for the Board's consideration in its deliberations.

Respectfully submitted, p/ y A Lanny Alan Sinkin Christic Institute 1324 North Capitol Street Washington, D.C. 20002 (202) 797-8106 Counsel for Intervenor,

! Citizens Concerned About Nuclear Power, Inc.

Dated: July 17, 1986 Washington, D.C.

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UNITED STATES OF AMERICA

. NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of (

)

HOUSTON LIGHTING AND ( Docket Nos. 50-498 OL POWER COMPANY, ET AL. ) 50-499 OL (South Texas Project, (

Units 1 and 2) (

CERTIFICATE OF SERVICE I hereby certify that copies of CITIZENS CONCERNED ABOUT NUCLEAR POWER, INC. (CCANP) STATEMENT OF VIEWS ON QUESTIONS CONCERNING DESIGN OF NON-CONFORMING STRUCTURES TO WITHSTAND HURRICANES AND TORNDADOS were served by messenger (*) or by deposit in the U.S. Mail, first class postage paid to the following individuals and entities on the 17th day of July 1986.

Charles Bechhoefer, Esquire Brian Berwick, Esquire Chairman Asst. Atty. Gen.

Atomic Safety and Licensing Board State of Texas U.S. Nuclear Regulatory Commission Environmtl. Protection Washington, D.C. 20555 P. O. Box 12548, Capitol Sta.

Austin, Texas 78711 Dr. James C. Lamb, III Administrative Judge Oreste Russ Pirfo, Esquire 313 Woodhaven Road Office of the Exec. Leg. Dir.

Chapel Hill, North Carolina 27514 U.S. Nuclear Regulatory Comm.

Washington., D.C. 20555 Frederick J. Shon Administrative Judge Jack R. Newman, Esquire U. S. Nuclear Regulatory Commission 1615 L Street, NW, Suite 1000 Washington, D.C. 20555 Washington, D.C. 20036 Melbert Schwarz, Esquire Baker and Botts Mrs. Peggy Buchorn 300 One Shell Plaza Executive Director, C.E.U. Houston, Texas 77002 i Route 1, Box 1684 Brazoria, Texas 77422 Atomic Safety and Lic. Bd.

U.S. Nuclear Regulatory Comm.

Diane Curran, Esquire Washington, D.C. 20555 j Harmon, Weiss & Jordan 2001 S Street, N.W., Suite 430 Atomic Safety and Licensing Washington, D.C. 20009 Appeal Board U.S. Nuclear Regulatory Comm.

Pat Coy Washington, D.C. 20555 5106 Casa Oro '

San Antonio, Texas 78233 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Comm.

Washington, D.C. 20555

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