ML20207T387

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Forwards Licensing Board 870107 Order Reaffirming Previous Order That Parties Address Whether Applicant Made Prima Facie Showing That Requirement for 10-mile EPZ Be Waived by 870127.Schedule & Statements of Work Expected by 870114
ML20207T387
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 01/07/1987
From: Reis E
NRC
To: Jordan E, Novak T, Vollmer R
NRC
Shared Package
ML19306D588 List:
References
NUDOCS 8703230511
Download: ML20207T387 (7)
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- January 7,1987 j Note to: R. Vokner ,

3. Jordan T. Novaak

Subject:

Seabrook Exemption Request 1987, reaffirming its Attached is a Licensing Board order of January 7, previous order 'that the parties are to address whether the Appffcants hava made a rima facie showing that the requirement for a 10-mile EPZ should be waived, y anTary 27, 1887. The Board indicatesThe that this need not to be Board further states the parties' view on the merits of the application. rima fhcie that if a party cannot then, set out its views on whether a set out a showing has been made, it should submit a partial response and remannahty certain date of when it would complete its response on the &

facie issue.

Although this order may change our response to the Board, it should not affect our development of the schedulesAt and the statements those meetings it of work was agreed agreed thatto ct the meetings on January 8,1997.

that schedules and statements of work to determinewaiver if the Applicants' petition should be granted, made a prima facie showing, as well as whether a would be compEEB by January 14, 1987. .

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o Edwin 3 ela oc: C. B. Rossi D. Matthews V. Noonan

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CORRESPONDENCE PDR )

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DRgy MEMO FOR: Dave Matthews, I&E Vince Noonan, NRR FROM: Bob Perlis, OGC I

SUBJECT:

SEABROOK EPZ EXEMPTION REQUEST m

On December 18th, PSNH submitted a petition for a waiver (pursuant to 10 CPR 92.758) of the requirement for a 10-mile EPZ at Seabrook. The petition is based on a number of probabilistic studies PSNH has hadr prepared, and it requests a one mile EPZ. I request will have to follow two tracks. The Staff review of PSNH's l First, the Staff will have to assess the technical work embodied in PSNH's studies to determine whether the risk assessments propounded by PSNH are reasonably accurate.

of the 10 mile Second, EPZ under 52.758, we must ascertain whether application requirement under the circumstances presented at Seabrook would serve the purpose (s) for which the requirement was adopted.

This necessitates a staff determination on, among other things, why 10 miles was chosen back in NUREG-0396.

PSNH has identified the following EPZ: four rationales it believes were behind the choice of a 10-mile (1) for design basis accidents, thyroid and whole body doses fall off sharply at 10 miles such that lower level PAG's would be exceeded at

- 10 miles in only.30% of 129 nuclear units analyzed and higher level PAG's would not be exceeded at any unit at 10 miles; (2) for less severe Class 3

9 accidents, WASH-1400 showed that doses would not exceed PAGs at 10

! miles; (3) for more serious core-melt accidents, ~otective actions out to 10 miles and would result in significant savings of e rly injuries and deaths; (4) planning actions to be taken forbeyond 10 miles would provide a basis for any necessary

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10 miles. I have drawn up the following l

(non-exhaustive) list of qizestions that we are likely going to need to

' address in order to respond to the waiver request. As you can see, they raise a number of policy and/or regulatory interpretation questions; a number of different Staff offices may want to have some input into the responses (as may FEMA). I think we need to start considering at least some of these questions very soon.

1.

The most basic question: is PSNH correct in its interpretation of why 10 miles was chosen in NUREG-0396?

Are there four rationales correct, and are they exhaustive (or are there other rationales that need be considered)? In this regard, it 'might be helpful to go back to the individuals who participated in writing 0396 to get their views.

2.

Do we want to focus on the historic origins of the 10-mile rule, or should the staff focus instead on the policy considerations of the rule today without delving into history? It may not be possible to identify a coherent rationale for 10 miles from NUREG-0396, and to the extent that an interpretation today remMns consistent with 0396, we may wish to j

consider whether we want to concentrate on current policy considerations, If we decide against the historical approach, we need to articulate the policy reasons for setting the EPZ ormal case) at 10 miles. A (in theARM y

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policy interpretation will have to include (for this case) either an adoption or rejection of PSN!i's four rationales.

3. What role does risk play in the process of determining EPZ size?

Insofar as risk is considered in the derivation (and perpetuation) of the 10 mile EPZ, does one focus on absolute risk or risk conditional on core melt? In other words, can a plant take credit for accident prevention in the emergency planning sphere? Also, can a plant take credit for design features, such as containment, which mitigate the consequences of a core melt, or must we look at emergency planning requirements only after there has been an unplanned release? I. haven't had an opportunity to read PSNH's full submittal; if they rely on risk conditional on core melt (which I believe they do), the only question we may have to answer here is whether risk conditional on core melt is an appropriate consideration.

4. If NUREG-0396 used a spectrum of accide'nts, must.a waiver petition (and any challenges thereto) rely on the same spectrudi? If not, what accidents should be looked at in establishing EPZ size?
5. Did NUREG-0396 consider in its risk analysis a spectrum of plant designs, or only one particular plant? How plant specific was. the original determination of 10 miles, and how plant specific should the rule be?
6. What risks are we protecting against? Do we look at all the PAG's, or just early fatality doses? Whole body, thyroid, or both?
7. What role does the ability to take ad hoc measures beyond the EPZ play, and what are the parameters within which such measures need be effective? In evaluating this aspect of PSNH's request, do we look at the ability to take ad hoc measures only out to 3 miles, or 11+ miles? How are such ad hoc measures affected by time components of accident development? In other words, if PSNH could sh' ow that its containment would slow down releases, could this make up for a weakness in the EPZ planning base because of the small base? This may be narrowed when we see the actual terms of the submittal.
8. What role do dose savings play in a proposed shrinking of the zone?

Assuming that expanding the EPZ at Seabrook beyond 1 or 2 miles would result in some dose savings in the event of certain accidents, how does one make a determination that various dose savings are or are not significant?

9. How heavily can we rely on PRA's and risk assessments in determining the size of the EPZ? Hasn't the Commission taken a position against relying on PRA's for IIcensing purposes? How does the safety goal fit into a IIcensing decision like this one?
10. If we can rely on PRA's in establishing an EPZ size, what level of certainty do we need to have? How much confidence do we need to have in the specific numbers generated; how much uncertainty can be tolerated?

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11. What individuals, branches, offices, and other agencies do we need to get involved in answering these questions? This question needs to be addressed as soon as possibic; undoubtedly the answer will differ for the different questions.

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e \J MEMO FOR: Joe Scinto FROM: Bob Perlis

SUBJECT:

Seabrook Waiver Schedule The following schedule includes input from Len Soffer, NRR, and Dave Matthews, Falk Kantor, and Don Perrotti, I&E. It addresses two issues:

the correctness of the criteria utilized by -PSNH in its petition and the fourth rationale (expansion of the planning base for ad hoc actions where necessary).

1. ARE THE POUR RATIONALES ADVANCED DY PSNH AS THE BASIS FOR THE 10-MILE EPZ CORRECT, AND ARE THEY COMPLETE?

The review necessary here does not differ depending upon whether a prima facie approach or a full merits analysis is used. Essentially, the goals here are to review the relevant mateffal to determine whether the rationales identified by PSNH for a 10-mile EPZ are included in the documents , and to further determine whether additional rationales were cited as playing a role in the development of the 10-mile sone. This review can be completed by February 20,'1987. The following eight areas will be covered in the review; except where otherwise indicated, the review will consist largely of a careful reading of the documents mentioned:

1. NUREGs 0396 and 0654, and any supporting materials (i.e., SECY papers for Commission presentation). (Soffer /Kantor)
2. Statements of consideration issued in support of the adoption of 550.47. (Soffer) ,
3 SECY papers in support of the adoption on 550.47 (SECY 80-275, 275A and 275B). (Soffer /Kantor)
4. Transcripts of NRC meetings in 1979 and 1980 to discuss regulation. (Perlis)
5. Transcripts of Congressional hearings in 1979 and 1980 that discussed emergency planning issues. (Perlis)
6. Review of testimony given in San Onofre (Grimes), Indian Point (Schwartz), and Catawba (Soffer) hearings. (Ferlis)
7. Check for NRC decisions from proceedings mention in #6 and elsewhere that may have involved issue of 10-mile EPZ. (Perlis)
8. Contact the individuals listed in NUREG-0396 to f!nd out whether we missed anything and to determine whether they agree with the results we come up with. (')

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2. REVIEW OF THE FOURTII RATIONALE: THE SUFFICIENCY OF THE PLANNING ZONE TO SERVE AS A BASE FOR EXPANSION OF EFFORT IF NECESSARY A number of preliminary issues need to be addressed here. The PSNH submittal on this issue is very cursory: one affidavit (Robinson) which essentially states that if 550.47 is satisfied at one mile, ' you ' will have an adequate base for expansion. Eventually, the Staff will need some detailed information from PSNH describing what emergency planning they will have in place for one-mile (and possibly beyond), and an explanation of why that planning provides an adequate base for whatever expansion may be necessary. The immediate issue becomes: what does the Staff do before we get any additional information? Do we reject the present submittal as not making a prima . facie case, do we ask for additional information first, do we rely on iWrmation that is not included in the petition, or can we identify any other options?

A less immediate problem, but one that is perhaps more serious: what elements do we want to see in order to determine whether a planning base is sufficient to allow for expansion? Present practice is to accept a 10-mile base as per se adequate for expansion; no review is performed and no review standards exist. If we require an explanation from PSNH as to why a one-mile base is sufficient, we're treading new ground here.

Finally.. depending upon the type of analysis that will be applied.

here and the factual submittal that will be required from PSNH, you may or may not see a difference between a prima facie review and full merits review. Below, I have charted the work we tHIEk needs to be done; the l best guess I can tell you on schedule is that the work in other areas '

will probably bound the time needed to review the work on this rationale.

SCHEDULE ITEMS l 1. A review will be made of NUREG-0396 to determine if that document

! contains any underlying bases for this rationale sufficient to help determine what review standards should be applied. Len Soffer will perform this task.

2. A review will be made of testimony given in Catawba and TMI by the
  • Staff on the issue of expanding an EPZ beyond 10 miles; there may be guidance here. Perlis will do this review.

By February 20, the Staff will have reviewed both the above elements and will have determined whether the Robinson Affidavit is sufficient for a prima facie case.

As noted above, before any additional work can be performed, a detailed submittal will be necessary. After the submittal comes in, the Staff review must include the following:

1. The scope of the expansion effort must be defined. This is in the final analysis a policy question, but before any policy can be made, a better understanding of the nature of severe accidents at Seabrook is necessary. In particular, we need to know the range of accidents and consequences, dose / distance curves over time , special meteorology
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considerations (what happens in the summer?) so that we can determine the scope of the expansion effort (i.e., how far out is expansion necessary, what are the time constraints, etc.).

2. A second policy issue: given the answer concerning scope of exp'ansion, what capability must be demonstrated in terms of responding to emergencies ' beyond the planning zone? Review elements must be identified; these elements will be controlled by the level of protection deemed necessary beyond the planning zone. FEMA may be involved here; a number of Staff offices likely will get involved; where do you begin???

This is going to be very difficult; it can be combined to a large extent with defining the scope of expansion, but this is new ground and there is probably very little (if any) guidance floating around.

3. The final (hopefully, easy) part: given your answers on the scope and the level of expansion deemed necessary, does the (as yet unreceived) submittal from PSNH meet our new standard. This would be an I&E review with probable input from FEMA; I would think the more time-consuming portions of this review come from establishing the standard.

One final issue needs to be addressed. After the ma facie issues are addressed, if the . regulation is going to be waived, t e taMay need to suggest a new standard to determine what EPZ will be established for Seabrook., The Co^mmission or ASLB may preempt any Staff decision here,

, but if they don't, we'll have to make a policy determination here. All the work the Staff has identified on the four rationales will have "to be done in any event, and may well have some application to whatever standard the Staff proposes, but it may well be that additional work will be necessary depending upon the ultimate standard selected. It might be helpful to start identifying individuals to work on developing an appropriate standard (i. e. , comparative risk, reasonable dose savings, safety goal, etc.). If done early, this task need not expand your schedule; if done after the full merits review of the four rationales, it may well add to the overall time needed.

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