ML20209D434

Recommends Commission Approve Publication,For Public Comment,Of Proposed Amends to 10CFR50.47 & App E,Permitting Consideration of Earthquakes in Context of Emergency Preparedness

ML20209D434
Person / Time
Issue date:	10/10/1984
From:	Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
Shared Package
ML20209D027	List: ML20209D022 ML20209D163 ML20209D349 ML20209D368 ML20209D434 ML20212F051 ML20212F057 ML20212F063 ML20212F070 ML20212F074 ML20212F080 ML20212F086
References
FOIA-86-197, TASK-RINV, TASK-SE SECY-84-394, NUDOCS 8410180401
Download: ML20209D434 (7)

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.0ctober 10, 1984 SECY-84-394 l

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For:

The Comissioner's From:

William J. Dircks 1

Executive Director for Operations' -

Subject:

PROPOSED AMENDMENTS TO 10 CFR PART 50, SECTION 50.47 AND APPENDIX E; CONSIDERATION OF EARTHQUAKES IN THE CONTEXT OF EMERGENCY PREPAREDNESS i.

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Purpose:

To obtain Comission approval for publication in the Federal Register of a proposed ' amendment that would not I

permit consideration of earthquakes in emergency planning.

Category:

This paper covers a major policy matter.

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Background:

On December 8, 1981, the Comission ruled in a than pending adjudication that its emergency planning regu-l 1ations do not require consideration of potential earth--

l quake effects on emergency plans for nuclear power reactors.

In the Matter of Southern California Edison et al.- (San Onofre Nuclear Generating) Station,

Company, Ct.I-81-33, 14 NRC 1091 (1981. In so Units 2 and 3),

ruling the Comission stated:

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-l The Comission will consider on a generic basis i

whether regulations should be changed to address the potential impacts of a severe earthquake on emergency planning.

For,the

interim, the proximate occurrence of an accidental radio-logical 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. 14 a

NRC at 1092.

I The Comission recently affirmed this position in the Diablo Canyon proceeding.

In the Matter of Pacific Gas and Electric Comoany (Diablo Canyon Nuclear Power Plant, i

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The Comissioners 1) 20 NRC (August 10 1 and 2), Cl.I-84-12, Tomission stated that it e..,

Units In this decision the 1984).

would initiate rulemaking "to address whether the poten-

- tial ~for seismic impacts on emergency planning is a enough concern for large portions of the significant nation to warrant the amendment of the regulations to specifically consider those impacts." Slip Opinion at 9.

The focus of this rulemaking is to "obtain additional infomation to determine whether, in spite of current indications to the contrary, cost-effective reductions in overall risk may be obtained by the explicit consideration of severe earthquakes in emergency response planning."

Id.

i The attached Federal Register notice is the staff's Ij response to that Comission order.

Experience has shown that the ability to take protective 1

actions throughout the plume exposure pathway (EPZ) could

'l Discussion:

d be hampered during the life of the plant by temporary adverse conditions resulting from natural phenomena such as rain, snow, flooding or by activities in the vicinity of the plant -such as major road repair.

Existing NRC regulations require that emergency plans be comprehensive i

and flexible enough to assure the capability to take appropriate protective action to mitigate the effects of a nuclear emergency under such conditions.

Similar types of adverse conditions could result from earthquakes below the Safe Shutdown Earthquake (SSE), which occur proximate in time with an unrelated accidental release of nuclear material from the facility.

However, emergency plans which meet the standards in 10 CFR 50.47 and Appendix E provide reasonable assurance that appropriate protective measures can and will be taken under such circumstances.

When considering the possibilities. of plant damage from seismic events, it is important to understand the severity of seismic events, their range of probabilities, and the l

potential for reactor accidents caused by seismic events.

i Three classes of seismic events are considered in this first' class includes earthquakes. of discussion. 'The relatively low grcund motion..up to the Operating. Basis The OBE ground motion depends on: plant Earthquake (OBE).

These accelerations vary in the range of about location.

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.05g to.10g (higher in areas of high seismicity).

During an OBE, all safety-related plant systems would be expected to remain cperating.

The second class of events includes earthquakes with ground motion higher than the OBE but equal to or less than the Safe Shutdown Earthquakes; the ground motion of the SSE is typically about twice that of the CBE.

Because probabilities of occurrence have large uncertainties for the SSE, typica' estimates are in the order of one in a thousand to one 'in ten thousand per year. NRC regulations require that plants be designed to achieve a safe shutdown after an SSE.

Given an SSE, all i

seismically qualified equipment would be expected to I

function to bring the plant to safe shutdown.

An earthquake up to and including an SSE would be cause for an alert emergency action level classification, but would not cause failures that would result in a significant accidental release from the plant. Thus, although such an event would initiate certain emergency plan actions, no e

offsite response would be required. Only in the event of l

multiple unrelated failures of safety-related systems due 3

to some undiscovered common cause failure mechanism (such as a major design error), coincident with a sevore earthquake such as an SSE, would there be a chance of ar.

accident which would require offsite emergency response when there was extensive offsite damage. The probability of these two events occurring proximately in time is very much. lower than the probability of either one, perhaps on the order of one in a million per year.

The final class of events includes all earthquakes with ground motion levels above the SSE.

Fragility analysis has been used to estimate the probability of failure as a function of ground motion associated with these earth-i quakes. The Zion, Indian Point, and Limerick probabilistic risk assessments estimated that grcund motion on the' order of 0.5g to 0.75g acceleration would be required to darnage these nuclear power plants to the extent that significant release of radioactivity could occur.

Of course.. some plants, such as those...in. high seismic regions..are designed to withstand farthquakes with ground motion,this high; they would resist damage to still higher leveTs of

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1 ground motion. The probability estimates for such ground accelerations are significantly less than the probability

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estimates for the SSE for these plants (the Zion Indian i

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. Point, and Limerick SSEs are

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.15g, and

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respectively).

I Based upon the probabilistic risk assessment results for I

these three plants, the NRC staff considers that for most I

earthquakes (including some earthquakes core severe than i

the SSE) the power plant wculd generally not be expected l

to pose an offsite radiological hazard.

For earthquakes l

which would cause plant damage leading to imediate i

offsite radiological hazards, but for which there would be i

relatively minor offsite

damage, emergency response i

capabilities around nuclear power plants would not be i

seriously affected.

For earthquakes which cause more i

severe offsite damage, such as disabling a siren-alerting j

system, the earthquake itself acts as an alerting system.

I For those earthquakes which cause very severe damage to l

both the plant and the offsite area, emergency response would have marginal benefit because of its impairment by i

offsite damage. However, the expenditure of additional l

resources to cope with seismically caused offsite damage any be of doubtful value considering the modest benefit in 4

overall risk reduction which eculd be obtained.

It should be noted that the Federal Emergency Management Agency (FEMA) raviews offsite radiological emergency i

planning and preparedness to insure the, adequacy of Federal, State, and local capabilities in such areas as emergency organization, alert and notification, comunica-tions, measures to protect the public, accident assess-a

ment, public education and information, and medical l

support.

Detailed, specific assessment of potential earthquake consequences and response are not part of this j

process related to radiological emergencies.

Also, FEMA i

8 has coordinated planning for the Federal response to

.l' radiological ' emergencies including -~ comercial nuclear l

power plant accidents.

These efforts have resulted in FEMA publishing the Federal Radiological Emergency Response Plan in the Federal Register (49 FR 35896). on

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'1 September 12, 1984.

In addition.. FEMA has an active

program of earthquake preparedness which includes hafirds and vulnerability analysis, estimates of damage and 2

casualties, planning for Federal response to a major l

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earthquake, and assistance to State and local governments i

in their earthquake planning and prepareriness activities.

l FEMA. believes that all of these activities are suffi-4

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._. ciently flexible to complement each other in preparing for i

an event that may require a concurrent response to a major i

earthquake and a serious accident at a nuclear power i

plant.

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After careful consideration, the staff proposes to amend i

10 CFR 50.47 and 10 CFR Part 50 Appendix E to codify the position that the Comission has taken in the San Onofre and Diablo Canyon cases.

A new subsection (e) would be added to 10 CFR 50.47 and a sentence would be added to the

" Introduction" section of Appendix E.

While these amend-ments are simple in form, the staff recognizes that they represent a significant policy determination.

The staff l

therefore invites comment not only on the proposed texts, but also on the fundamental question of the relationship 4

between earthquakes and emergency planning at nuclear power facilities.

Comenters are also being asked to

. address the merits of three possible alternatives:

1 1.

Adoption of the proposed rule codifying San Onofre and Diablo Canyon.

2.

Leaving the issue open for adjudication on a case-by-

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case basis.

i 3.

Requiring by rul'e that emergency plans specifically address the impact of earthquakes.

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FEMA is directly involved in the evaluation of offsite i

emergency preparedness and, therefore, would be affected by the promulgation of this proposed rule change.

There-fore, the NRC staff consulted with the FEMA staff during the development of this paper.

FEMA concurs in the

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proposed rule change.

Cost Estimate:

The staff anticipates that there wil1 -be no decrease or increase in cost to the NRC, Stat'E atd Tocal governments f?

and to licensees associated with the proposed rule change because it is interpretative in nature.

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Reconnendation:

That the Commission:

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1.

. Approve:

The publication for public coment of the 1

l proposed rule change in the Federal Register (Enclosure 1).

l 2.

Note:

I a.

That appropriate Congressional conmittees will j

be notified of the proposed rule.

b.

That the ACRS is being infonned of the proposed rule.

c.

That, pursuant to 951.51(d)(3) of the Comis-I sion's regulations, an environmental impact statement, negative declaration, or environ-mental impact appraisal need not be prepared in i

connection with' the subject proposed amendment because there is no substantive or significant j

environmental impact.

j d.

That the Federal Register notice contains a statement that the NRC certifies that the proposed rule will not, if promulgated, have a l

significant economic impact on a substantial number of small

entities, pursuant to the l

Regulatory Flexibility Act of 1980,5605(b).

e.

That the Federal Register notice contains a i

statement

that, pursuant to the Paperwork Reduction Act of 1980, the NRC has made a j

preliminary detennination that the proposed rule i

does not impose new recordkeeping, infonnation collection, or reporting requirements.

f.

That the staff will directly notify affected

.j applicants, licensees State governments, and i

interested persons of the proposed rule.

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g.

That a public announcement of the proposed rule will-be'made.

h.

That a Preliminary Value/ Impact Analysis has t

been prepared (Enclosure 2).

.n William. Dirck Executive Director for Operations l

Enclosures:

See next page 1

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Enclosures:

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I 1.

Federal Register Notice of Proposed Rulemaking 2.

Preliminary '9alue/ Impact Analysis 3.

Proposed Public Announcement J

Ccmmissioners' comments or consent should be provided directly to the Office of the Secretary by c.o.b. Thursday, October 25,

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1984.

I Commission Staff Office comments, if any, should be submitted j

to the Commissioners NLT Thursday, October 18, 1984, with an information copy to the Office of the Secretary.

If the f

paper is of such a nature that it requires additional time for analytical review and comment, the commissioners and the Secretariat should be apprised of when comments may be expected.

I DISTRIBUTION:

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M3 3B B TECHNICAL ASSOCIATES h'qpRgggi&

TECHNICAL CONSUL TANTS ON ENERGY & THE ENVIRONMENT D le G Brudenbaugh 1723 Hamilton Avenue-Suite K Rochard B Hubbard San Jose California 95125 Gregory Q, Minor Phone (408) 266 27I6 March 4,

1986 Mr. Donnie H. Grimsley, Director Division of Rules and Records Office of Administration U.S.

Nuclear Regulatory Commission Washington, D.C.

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• • r,: 7 g a.r RE: FOIA REQUEST Rtt

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Dear Mr. Grimsley:

hdM Y Pursuant to the Freedom of Information Act, please make available at the Commission's Washington, D.C.,

Public Document Room single copies of records in the following categories:

A.

From the Chron Files of Mr. Hans Schierling from January 1, 1984, to the present, all records concerning in any way the Diablo Canyon Nuclear Power Plant, Units 1 and/or 2.

B.

From the Reading Files of Mr. Hans Schierling i

from January 1, 1984, to the present, all records concerning in any way the Diablo Canyon Nuclear Power Plant, Units 1 and/or 2.

Please provide partial responses as batches of documents become available.

If you have any questions concerning this request, please contact me at the telephone number given above. Your prompt attention to this request will be appreciated.

Very T uly Yours

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Gr g A. Holmes Associate Consultant u, < A a i /fwh t-t t> ns ~ v ~