ML20209G198
| ML20209G198 | |
| Person / Time | |
|---|---|
| Issue date: | 09/09/1985 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8509190158 | |
| Download: ML20209G198 (108) | |
Text
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7 stalRAL
[~ UNITED STATES OF AMERICA .
NUCLEAR REGULATORY COMMISSION In the matter of:
COMMISSION MEETING Discussion on Earthquakes and Emergency Planning (Public Meeting)
Docket No.
(
\
Location: Washington, D. C. y _ 97 Date: Monday, September 9,1985 Pages:
- s.
8509190150 850909 .. )
PDR 10CFR . 9*
PT9.7 PDR ANN RILEY & ASSOCIATES Court Reporters
( 1625 I St., N.W.
Suite 921 Washington, D.C. 20006 (202) 293-3950
O t a 1 D l SCLA 1 M ER 2
3 4
5 6- This is an unofficial transcript of a meeting of the 7 United States Nuclear Regulatory Ccmmission held on Monday
. e Separber 9,1985 in the Commission's office at 1717 H Street, 9 N.W., Washington, D.C. The meeting was open to pubile 10 attendance and observation. This transcript has not been 11 reviewed, corrected, or' edited, and it may contain
, 12 inaccuracies.
13 The transcript is intended solely for general 14 informational purposes. As provided by 10 CFR 9.103, it is 15 not part of the formal or informal record of decision of the to matters discussed. Expressions of cpinion in this transcript 17 do not necessarily reflect final determination or beliefs. No 18 pleading or other paper may be filed with the Commission in 19 any proceeding as the result of or addressed to any statement 20 or argument contained herein, except as the Commission may 21 authorize.
22 23 I 24 l
l 25
( 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 2
3 DISCUSSION ON EARTHQUAKES AND EMERGENCY PLANNING ,
4 5
PUBLIC MEETING 6
Room 11~O '
7 1717 H Street, N.W.
Washington, D.C.
8 Monday, September 9, 1985 9
The Commission met, pursuant to notice, at 10 2:07 p.m. .
11 .
COMMISSIONERS PRESENT:
12 NUNZIO PALLADINO, Chairman of the Commission
. 13 THOMAS ROBERTS, Commissioner ;
. JAMES ASSELSTINE, Commissioner u FREDERICK BERNTHAL, Commissioner LANDO ZECH, Commissioner-15 STAFF AND PRESENTERS SEATED AT COMMISSION TABLE:
16 S. CHILK 17 R. KRIMM E. JORDAN is F. GILLESPIE W. DIRCKS-19 A. KENNECKE J. ZERBE 20 M. MALSCH H. PLAINE 21 AUDIENCE SPEAKERS: !
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33 R. MINOGUE ;
23 C. ONG
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_ - . _ _ . ~. . _ _ _
1 2
i PROCEED I NGS
[ 1 E
2 CHAIRMAN PALLADINO: Good afternoon, ladies and 3 gentlemen. ,
4 Commissioner Bernthal asked that we start without ,
3 l 5 him. He will be here shortly.
. 6 The purpose of today's meeting is to discuss the i
7 draft Final Rule on the subject of considerations of
! 8 earthquakes and emergency planning.
9 The staff has provided a draft for Commission 10 consideration in SECY-85-283. By way of background, the 4 11 Commission decided in the Diablo Canyon licensing proceeding that the complicating effects of earthquakes and f
f 12 6
l i3 emergency planning need not be considered. The Commission 14 proposed rulemaking to codify that decision.
15 After receiving and analyzing pubitc comments and 16 conducting other analyses, ti.e staf f recommended a l 17 different course in SECY-85-283. It is that proposal which i
j 18 we address today.
19 I would like to start today's meeting by asking .
20 the NRC staff to present its proposal and the underlying i l
{ 21 reasons for it. It would then appear appropriate to ask
- 22 OPE and OGC for their comments.. We can then open the floor 23 to further discussions.
4 24 I do not intend to call for a vote today on SECY- ,
25 85-280. However, I_ encourage Commissioner comments and i
l 9
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- L , 1 proposals concerning what our next step should be on this i
- t
- 2 subject.
i
! 3 Let me ask now whether other C i..-issioners have 1
4 opening comments.
! 5 COMMISSIONER ASSELSTINE: Just a procedural ,
i k 6 question. I assume that the SECY paper is available to the i
7 audi ence t. is that correct? How about the OPE memo? [
- 8 MR. CHILK
- The OPE memo is being reproduced right i
i 9 now.
10 COMMISSIONER ASSELSTINE: Okay.
i
! 11 MR. CHILK: It wiJ1 be available.
j 12 COMMISSIONER ASSELSTINE: Good. Okay.
CHAIRMAN PALLADINO: All right. Any other j, 13 3- -
14 comments?
i l 15 COMMISSIONER ZECH: No.
16 CHAIRMAN PALLADINO: Well, then I will turn the t i
i 17 meeting over to Mr. Dircks.
I
', 18 MR. DIRCKS: We will go through the proposal very i i
- 19 briefly, Mr. Chairman. But I do also want to emphastre, we (
i 20 have Dick Krimm from the Federal Emergency Management
\
21 Agency.
l 22
'- CHAIRMAN PALLADINO: We have what?
4 23 MR. DIRCKS: We have a representative from FEMA,
- 24 Mr. Krimm, heretoday'yndyoumay-- I think you should --
i . ?*
i 25 ask him to present the FEMA comments. I think it would be i --
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.) good for completing the record.
- 2 Mr. Gillespie will go through the rule end, as I 4
3 said, it's a very brief presentation. It essentially adds i
4 the three elements that were described in the paper, which l 5 is to give us the -- require the flexibility in any
- 6 communications and transportation capabilities to the i 7 planning requirement. ,
8 Frank, I guess you might go through the elements.
i
! 9 MR. GILLESPIE: We have a very brief package, i
The first vi sual is just the background which, I to i
i 11 think, everyone is familiar with. So, I am not going to I 12 dwell on that.
- g3 The next one is the alternatives that were put in
- 14 the proposed rule which we requested public comment on.
J i j$ The three alternatives were:
I g Promulgation of the proposed rule, leaving the >
j 17 issue open for case-to-case adjudication.
18 Promulgate a final' rule with some limitations on i
j 19 what the consideration for earthquakes would be.
4
! 20 And there was another element in the Federal i
.21 Register notice which we also asked for comments on, and l
22 that was whether other phenomena should be included in our i
23 consideration of earthquakes.
24 The next page just gives the arithmetic, as it i
were, on the number of comment letters received. We had 25 4
I l
4 i
{
5 g - .
I, I one comment letter which was technically the strongest.
2 That was from the Union of Concerned Scientists which 3
raised a number of issues and gave significant background 4 information on each issue.
5 Their concerns were not dissimilar fr'om the topics 6
the staff had under consideration at the same time during 7 the comment period.
8 Several foreign countries were sent a TELEX and a g TELEX was received back, asking if they did anything to to specifically consider seismic events in energency 11 planning. And in general the answer we got back was the 12 same sentence reversed saying, no, they didn't: which tends
. . 13 to give us an answer that is somewhat out of context 14 because it is not in the context of what they actually do 15 do in emergency planning for other things.
16 I only put that in there because every question I 17 go over here -- and we will quickly get into the more la technical areas -- seems to have two sides, and we tried in tg the paper, and it was difficult to try to give a balance to 20 both sides and fairly present it.
21 ACRS reviewed the rule. Their basic comment was 22 Nery supportive. They went one step further than we 23 recommended in the paper. In the ACRS letter it says, "A 24 report similar t'o The TERRA Report for Diablo Canyon" was
. 2 25 envisioned as what they might think.
l
6 i In the paper we specifically attempted to put 2 bounds on what the staff thinking was on how much was 3 enough, and we think that possibly the TERRA Report went 4 farther than was needed for the minimum that needs to be 5 done.
6 So that is not, I don't believe, a significant 7 difference but it is nevertheless a difference between us .
8 and ACRS.
9 Which brings me to the next slide which is the 10 major issues which, Mr. Chairman, you picked up on in a set ij of questions that we got late last week and responded back 12 to. I hope you had time at least to look over our i3 responses.
14 Let me go through each one. In many cases, 15 depending on how you look at one side of the issue or the 16 other, whether it says you don't need what the staff is 37 recommending or whether it says, "This is why wo only have tg to do the minimum amount the staff is recommending."
39 In each case it's a mixture of qualitative and 20 quantitative insights, and whenever that happens, opinion 21 always seems to override. In every case here we've got 22 opinion mixed in. It's our best opinion but opinion 23 nenetheless.
24 Major comment: Limited or no record to support 25 generic finding of floxibility in emergency p'ans.
7 I' -
[ 1 We feel that we have outlined in the Commission 2 paper a significant record of what does exist to show there 3 is flexibility. A limited record can be taken two ways.
4 In this case we feel much of the comment was, we didn't 5 have It written down necessarily, and not t' hat it wasn't 6 there.
7 In reviewing exercises that have been done, severe 3 phenomena have in fact been used as complicating or 9 initiating events tended to be limited to on-site in the 10 description of what happened. And this is a case where we
!! have a very positive record which was limited in the entent 1; of material it coverod.
, , 13 We did review as part of a much larger effort 20 --
14 and there were 20 because it was the 20 we could most 15 easily get at fast -- non-radiological evacuations for two 16 things: To get a feel for the capacity of the local public 17 safety officials and also to get an understanding of what 18 were the common threads that made a successful ovacuation 19 successful.
20 That led us into some of the three main elements 21 that we have in our rule.
27 COMMISSIONER ASSELSTINE: Did that part -- excuse 23 me, Frank -- did that part really focus on evacuations as 24 opposed.to the I'oll range of emorgency planning activitics?
25 MR. GILLESPIE: Okay, let me go back to whero I i
e
8 8
i said it's the -- I believe and the staff generally believed 2
it is the full range, and what we are suffering from is 3
either a lack of documentation or a lack, inability to 4 grasp which file cabinet in which part of the government 5 it's in between the NRC and FEMA.
6 See, I can say that natural phenomena were in fact 7
used as complicating or initiating events in radiological .
exercises, 8
g What I couldn't grasp and"come here and say, "Here is the evaluation of what happened off-site." But in to 11 general I would hope that exercises are consistent. You 12 know, if you used one scenario in one place, you don't 33 suddenly change it in the other.
. u I don't know. We haven't -- I don't know becauso j$ as a neutral party, not being on the appraisal team, this was given to a " neutral" offico, if you will. Tho 16 37 documentation doesn't exist.
ig But from everything we could understand, the good gg appraisals from the exercison of the radiological emergency 20 preparedness plans, from the non-radiological things we 21 looked at, the capacity and ability appears to have been 22 there when it was needed -- which is the value of looking 23 at actual incidents where evacuations were noodod.
24 The capacity appears to be there in the overall scheme of public safety. But no, I can't pick up a NUREG 25
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t i, I report and say, "We have gone out and we developed this 2 record." )
3 That's where I come to a limiting. I now have a 4 limit on my judgments because in fact I can't documhnt it
! 5 the way I'd really like to document it.
- Not right now, 1
- 6 anyway. ;
i a 7 COMMISSIONER ASSELSTINE: Yes.
- i 8 MR. GILLESPIE
- And that's why I said, evorything ,
I) 9 has a limiting case to it. We have bumped up against these 4 !
- 10 limits on each of these issues. ,
, t 1
J .
1 11 We'll go,on to the next one, j i
j 12 COMMISSIONER ASSELSTINE: Just so I understand {
f that first one, though, in terms of your judgment on
- , 13 ,
3
- +
14 flexibility,.what you are really relying upon is some l 13 review, to a certain extent, of some material that we may 16 have in our files or that may be scattered other places, !
l 17 that have never really been pulled together. 7
, I j is MR. GILLESPIE: Yes. l I ig COMMISSIONER ASSELSTINE: And I take it that were l 20 never really part of the rulemaking record of this 21 proceeding in terms of an opportunity for members of the
! 22 public to go in and take a look at this material and to l
! 23 ccmment on it as part of the rulemaking.
1 -
l 24 Mh.*EILLESPIE: I guess my best feel is. if we had
- 25 a year and 1 to of people to do it, maybe between us and !
4 i
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' FEMA we could ge interview the people who actually ran the i
2 exercises. But we are talking an absolutely mammoth job 3 and I'm not then sure what I would have gained out of it 4 other than, "Well, yeah, now you've got the opinion of all 5 those examiners."
6 You know, then someone will say, "All those 7
examiners are prejudiced because they all work for you and 8
they want to give you the opinion you sant."
9 I'm not sure that that massive effort would even in be warranted or that it would change our thinking in the ti rulemaking. When I get to the rule recommendations, I'd 12 like to go over how we coped with that --
i3 COMMISSIONER ASSELSTINE: Okay.
i, MR. GILLESPIE: -- with some significant words in j$ there.
16 COMMISSIONER ASSELSTINE: Fine. I take it, 17 though, that that is more -- that element becomes is considerably more significant when you start something like 39 the OPE approach. If you have had a chance to look at it.
20 MR. GILLESPIE: Well, I've had a chance, and I'd 21 like to let OPE speak for themselves first, or I guess I 22 could --
23 COMMISSIONER ASSELSTINE: Okay.
24 MR. DIRCVS I only saw the OPE approach about 20 25 minutes ago.
L
- i. . .,
11 f 1 MR. GILLESPIE: I read it on the subway on the way 2 down, it was a TELEFAX to me.
i 3 COMMISSIONER ASSELSTINE: Yes.
i 4 MR. GILLESPIE: The second one, defects *in j
$ construction, seismic design, quality
- assurance and
. 6 operator stress can undermine seismic strength.
7 This one is very general, much harder to get your ,
l 8 arms around. But we think we've got some real pocitive I
9 elements that we outlined in the paper on what we feel we j 10 know about how actual structures respond in seismic events, t .
11 the conservatisms built into the design of these plants;
)
12 the whole idea of multiple systems, defense in depth.
,i
, , 13 We have an extremely large research , y sm , which t
- - 14 the results to date would tend to show thet s. m/
i 15 absorption ability of systems is higher than first 1
l 16 anticipated.
1 17 So we think that we can go one step and we can l
I j 18 say, we believe this but the research programs are not 1
i 19 complete. And if you ask me, "Is that complete," I can I 20 say, "We can show you reports; we can tell you where we are ,
I f
21 at. Part of the insights to this is the general design i
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22 criteria that is being considered right now on pipe 1 23 restraints, that all comes out of the same type of i
.24 program $"*}
j . 9 25 Again, I'm not all the way there. It puts a limit i
4 J
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12 4
8 i on what I can say before I start introducing opinion into l 2 it. We feel very strong, though, that there is a lot of
=
3 margin in these plants, particularly plants whose SSE ,
l 4 happens to be very low. Twice a small number is still a 5 relatively small number. It brings a different qu,estion, 6
and then we don't have a homogeneous mix of plants.
i 7
Twice a large number-is a very large number., But j
8 is that so large it is not even credible to have occurred?
! So --
9
. 1 io CHAIRMAN PALLADINO: Will you somewhere along the li line define what you mean by two or three times the safe t
- 12 shutdown earthquake? Is that two times the "G" value; two times the (in a udi bl e) , two times the loads? I'm not sure 13 i
34 what.
j i$ MR. GILLESPIE: We attempted in the rule, and I 16 think we --
l 17 CHAIRMAN PALLADINO: You didn't answer that 18 question for me.
39 MR. GILLESPIE: It's two times the "G" value.
I 20 CHAIRMAN PALLADINO: Two times the "G" value.
21 MR. GILLESPIE: And when we looked at the ha:ard 22 curves that have been developed by Lawrence Livermoore for
! 23 the ten eastern plants, it's frequency versus "G" value.
j 24 And we went two times the "G" value and went up on the 25 curve and said, "Now, what's the frequency?"
i i
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1 CHAIRMAN PALLADINO: So you are talking about two i
i 2 times the "G" value.
3 MR. GILLESPIE: Right.
1 4 CHAIRMAN PALLADINO: If some place it says it's 4
i 5 6.5, then it's 13.
6 MR. GILLESPIE: But as it happens --
- 7 CHAIRMAN PALLADINO
- Or two to four.
l 8 MR. GILLESPIE: Yes, in more instances it was 2
9 more. 'If you had a "G" value of .15 and.you doubled it, to you were at .3.
1 11 CHAIRMAN PALLADINO: Or if you quadruple it, then i
j '
s 12 you'd be at .6.
- 4
!. 13 MR. GILLESPIE: Yes.
14 CHAIRMAN PALLADINO: Okay. That's what you meant. !
i 15 MR. GILLESPIE: Yes. There is no complicated
.i .
! 16 arithmetic in there. . We've tried to --
T
! 17 CHAIRMAN PALLADINO: Well, it's not clear what two i
l 18 times the earthquake --
19 MR. GILLESPIE: Okay, I apologi:e for not having
}
20 made that clear. That's what we intended.
2 21 CHAIRMAN PALLADINO: Okay, thank you, i 22 MR. GILLESPIE: I think defects in construction ,
t l 23 are taken care of, again, by_the significant margins which l I -
24 e: tis't Ih the designs themselves. Again, though, this is
! . 9 25 limited by the consideration that if you'do have an 1 "~1 J
_ . _ . _ _ . . . . _ . _ - . ~ . _ . . - . . - , , . , _ _ _ _ . . . . . - , . , , . _ - . _ _ _ - . _ . - . _ , . . . . _ . . ,-_ _ _. , . . _ _ . . . _ . , . _ - . , . , .
14 j' ) undetected, an undetected deficiency and it's susceptible 2 to a seismic ha ard, you won't know it until you have'the
! 3 seismic ha:ard.
! 4 Again there is a limitation on it. It's a 5 practical limitation that will never go away. It's 6
something we are always open to be questioned on. I don't
, 7 want to build up -- I'm trying to maintain a balance. It 8
was very difficult in the paper because you talk on one -
l 9 side of:an issue and you build up your emotion there, and 1 .
l, io then you talk on the other side and it sounds like being l ti contradictory.
l .
- 12 COMMISSIONER ASSELSTINE: Yes, as I recall the i
13 Statement of Considerations, while it pointed out all these j 14 things that are encouraging, at the same time you al so made t
33 the point, but when you get to amergency planning and 1
g considering matters for emergency planning, even the 37 confidence that you have based upon this kind of work and 18 this kind of information really doesn't end the inquiry.
39 And that a-fundamental element of emergency
! 20 planning is that you do take into account the possibility 21 that these things will occur notwithstanding the best 22 efforts in the seismic area.
- 23 MR. DIRCKS: I think that's why we have gone the 24 routo that we have --
2$ COMMISSIONER ASSELSTINE: Yes.
i a
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f, - 1 MR. DIRCKS: -- to enhance the planning effort.
I 2 COMMISSIONER ASSELSTINE: Yes.
o 3 MR. GILLESPIE: That brings me to my next -- that l 4 leads me right into the next bullet we have here, which -- '
< $ CHAIRMAN PALLADINO: I'ncidentally, I would like to 6 get into some of those questions.
j 7 MR. GILLESPIE: --is, current emergency plans are 8 designed to consider a broad spectrum of events the worst 1 1 9 of which have probabilities of " recurrence" -- the word to should be in there -- of ten to the minus four to ten to 11 the minus five.
I 12 ~ Emergency plans to consider a broad spectrum of 1 t 13 e v e n t. s . In general, the Class 9 accident which is the far - ;
i 14 end of thac spectrum in fact is in this frame. And when we i
1 35 took our curves and went two and four times the SSE, the i ,
i 16 return frequency comes out as the same number on the end of 1
l 17 that spectrum of events. l i
18 CHAIRMAN PALLADINO: I didn~t follow that. Say it 19 again?
20 MR. GILLESPIE: The Class 9 accident from -- we 21 call it the more traditional internal initiator, has [
1.
j '
22 generally given in PRA space a return frequency of ten to 23 the minus four, ten to the minus f;ve, starting with the i 24 ReaIh,or Safety Study..
l . G ,.
25 That's the end of the spectrum. It's not the
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f t
4 l
i 16 i 1
1 accident that's planned for specifically, but that's the 2
end of the spectrum of accidents which could happen.
3 That's how it's always been approached in emergency J
4 planning.
! 5 If I take -- and this is where the two and the
7 two and said, "Now, where does that take us on frequency on h a those ten curves?" Well, we are still down about ton to g the minus fourth on most of them. And we said, "Well, t jo let's double it again and see where that takes us."
n And that took us up in the range of ten to the 12 minus fifth. Now, if I have four timos the SSE, I am kind
- i t of backed, definition wise, into saying, maybe I have to
{ y3 a say now,l've got a one-to-onc correlation between four i
j j$ times the designed SSE and a radiological release.
- 16 I certainly didn't feel comfortable in making the I 37 assumption at that high level that I wasn't. So, I was in
) 18 a gray area, I was right on the borderline.
l
- 19 We are consistent with the end of the spectrum i 20 from initiation point of view as far as the roturn 4
21 frequency, predicted return frequency, of an initiator.
22 CHAIRMAN PALLADINO: Are you saying that the I
23 probability of a 30 "G" earthquake, a site in California, 24 would have a return frequency of ten to the minus fourth,
! 25 ten tu the minus fifth7 i i
l 1
17 p- .
( ) MR. GILLESPIE: No, no, we never got up to 30 "G."
2 CHAIRMAN PALLADINO: Well, four times seven and-a-3 half.
4 MR. GILLESPIE: No. This is 2 we are dealing 5 with the rule and most of the sites actually are in the 6 East.
7 CHAIRMAN PALLADINO: Okay. Go ahead.
3 MR. GILLESPIE: In the West, we are up at "G" g values for Diablo Canyon like .75.
to CHAIRMAN PALLADINO: Yes, .75 --
11 MR. GJLLESPIE: But at some point you reach a --
12 CHAIRMAN PALLADINO: I don't want to exaggerato.
, , 13 MR. GILLESPIE: -- you reach a point where you 14 can't have an earthquake that big, which is why when I 15 referenced back to what I said earlier, we have to make a 16 distinction bntweer two times a large number and two times 17 a small number. And in a rulemaking, you are forced into 18 kind of an averaging effect over everybody and the majority 19 rules.
20 Now, let me take the more typical plant of our 21 plants and say, .2, two timos the SSE is .4. Then ycu get 22 into the " ology" space which is where these curves came 23 from, and I'll bring to your attention on the curves a 24 Egution. The curves have two uncertainties in them, an
- 9 25 upper and lower bound, which aro 15 and 85 percent 1
u__
,,--n-- , + . s 4 6 L m-- d s i . . ,
18 i percentile ranges.
I 2
That's because if they wanted to put five in i
3 ninety-five on it as the PRA reference document says, the 4
4 uncertainty band would probably be about five decades wide 5 to go to the next step.
6 Now let me say, everything I have said is so 7
highly uncertain, I wouldn't want to have to. stand by it at
]
4 all. That's'the catch we are at right now. Those are not 8
i traditional uncertainty bands.
9 to COMMISSIONER ASSELSTINE: If I understand you,
{-
i j 3; what ycu are saying is that when you look at the kinds of i
! 12 initiators that we look to for emergency planning purposos, ,
? ,
-13 if you look at internal initiators --
j .
34 MR. GILLESPIE:- Yes.
t l
7 15 COMMISSIONER ASSELSTINE: -- as opposed to the i
16 external ones, and you look at the frequency of those g7 internal initiators that we look at, and then you try and-f
- is compare those to the external initiators, earthquakes on I
39 the order of the SSE or larger compare in terms of the I
20 frequency of occurrence with the internal initiators that i
21 we routinely consider for emergency planning purposes.
22 hR. GILLESPIE: Yes.
23 CHAIRMAN PALLADINO: At some plants. Encuse me, 24 you.didn't say that-for all the plants because I asked you, I
- 25 even though I did my calculation by a factor of ten.
I
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19 I 4 !
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l i COMMISSIONER ASSELSTINE: You asked him four 2 times, yes. I said at.or --
3 MR. GILLESPIE: No, no -- yes --
4 CHAIRMAN PALLADINO: The SSC --
5 MR. GILLESPIE: -- and the rules as an averaging i 6 effect, and in effect most of the plants are in the East 1
1 7 and not in the West.
! 8 CHAIRMAN PALLADINO: Yes, but this rule applies I
9 equally to all plants.
10 MR. GILL'ESPIE: Euqally to all plants.
i 11 . CHAIRMAN PALLADINO: So the statement saying that 1
12 you have to go to a three "G" -- I hope I did my arithmetic ;
, 13 right this time -- .75 times four. That's an impossible 14 kind of earthquake.
i
' MR. GILLESPIE: Oh, I would imagine it is.
13 16 CHAIRMAN PALLADINO: Well, then you have gone 17 beyond this ten to the minus four, ten to the minus fifth. r i
! 18 MR. GILLESPIE: Yes. And the rule is independent i
19 of the frequency.
20 . CHAIRMAN PALLADINO: I don't follow that. You i 21 just said the reason you go into four times is because you i 22 want to get to the same frequency as the internally i 23 generated --
! a gi' a 24 ; MR. GILLESPIE: In looking at the records that
! . Q'
) 25 exist, which~is really what we had to deal with, the i
e S.
j s
l 20 l#
i documentation in fact exists which say that at many plants -
2 - and we've got ten in particular that we happen to have ;
3 looked at,.plus the ones that have PRAs done in them -- a 4 very, very, very extensive earthquake like in the range of j 3 four times the SSE has this kind of return frequency.
.l 6
Now, in rulemaking space I'm saying, in my 7 averaging effect I'm considering all plants. Some will'in J
8 fact indeed because I know there is a limitation on the g physical energy tha's can come out of the. earth, I'm never j jo going to make that at plants probably with the larger in SSEs. I agree.
12 CHAIRMAN PALLADINO: Okay. Well, why don't you go l 1 i 13 0"7
.i 34 MR. GILLESPIE: I agree. Let me go on to the nent j$ one, and I'll touch that again when I go over the specifics j 16 in the rule. .
17 There exists limited information on the i i
18 contribution.cf seismic events to overall core melt i 39 frequencies.
20 Again, the -- reference document has been :
I 23 generally accepted; it's been peer reviewed; it talks about 22 about an uncertainty of about five decades. And there have j
23 only been about four or five of them. Indeed, there is not t
24 a record. There is limited information in core melt 25 frequency of PRA space. There is nothing, really, I would l
i
{
1
21 i
.( ) hang my hat on to go either way.
2 COMMISSIONER ASSELSTINE: Is that statement, 3 together with the ones you made in connection with the ,
4 previous point in effect that the uncertainties that are t 5 associated with seismic events, likelihood and consequences i
! 6 are greater than, to a certain entent, thap the other i
7 initiators that we look at?
a MR. GILLESPIE: Oh, certainly, we can understand
< 9 the plant, and the system, and the pipes that are in there -
10 j 11 COMMISSIONER ASSELSTINE: Yes. ,
4
- 12 MR. GILLESPIE: -- much better than trying to r _, 13 predict a natural occurrence of a hurricane. Most 14 certainly, that's --
1$ COMMISSIONER ASSELSTINE: Okay. So our ability to j g know whether we are right or wrong in terms of projecting i
17 the consequences of earthquakes is less certain than our
, is ability in the other areas.
l 19 MR. GILLESPIE: No. Now, you brought a new term [
l l
20 in'there, the consequence part of it. The ability to 21 predict the earthquake is very uncertain.
22 COMMISSIONER ASSELSTINE: Okay.
23 MR. GILLESPIE: We have a very improving aDility 24 on our understanding of what certain energy inputs to a 25 plant will do to the plant. And what's coming out of that
+ ,
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22 l is.the far more optimistic side of it, that these systems i
2 can take a lot more because of the very, very conservative 3 design tnan was originally intended.
4 If you are willing to allow elastic or, let me
$ say, inelastic deformation of a piping system versus 6 assuming it doesn't bend, you get a double and a guillotine i
7 break, you've got an energy absorption mechanism.
i 8
Now, that brings in another -- have I twisted the 9 valve body so the valve is intact but doesn't work? But I a
jo still have a pressure boundary that's intact. I've got i
it some plussos going for me that are coming out of the 12 insights we have now.
33 So when you say the ability of the plant, I have 1
34 to then put some of the pros i n this argument. It goes 15 both ways.
16 Now, let me get to the final slide is the rule --
17 MR. DIRCKS: Let me just mention.-I think what the
! rule is, what the proposed final rule is, is essentially a 18 39 conservatism built into this process. Whether or not there l
20 would be an accident at the plant, we are in effect saying, 21 assume that -- whatever i t is -- and then a good plant 22 should have the following three elements in it.
23 And that's what -- essentially, we are getting i
24 back to these three elements which we think a reasonable
) ,< 25 and a good plant should have. It's a communications ,
4 4
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23 1 capability and transportation capability, and an estimate [
2 of alternate routes and evacuation plans.
3 I mean, that's what'we are trying to get into 4 here, rather than trying to go into the whole business of
, 5 PRA analysis on plants.
6 CHAIRMAN PALLADINO: But your prudence, at least j 7 the way I understand it, is guided by your worry about 8 uncertainty. But uncertainty of a low event, low 9 probability event, doesn't make it a high probability to event.
11 MR. GILLESPIE: No, but what we are gaying is --
1 12 CHAIRMAN PALLADINO: It's still a low probability i
- _ 13 event. You don't know how low, that's the problem. It's
'- - 14 not that it's far more frequent so that it's no longer a 15 low probability event.
16 I think we work.this uncertainty bit to death l
l 17 because uncertainty will exist on all low probability
! 18 events because you won't have, over a reasonable life time 1
4 19 of a man, enough events to get any statistically good 20 information.- So you are going to always have the a
21 uncertainty.
22 But if the data that you have shows that they come 23 very infrequently, that doesn't -- the fact that you are i
! 24 not sure that it won't once in a while come-more frequently t
25 doesn't.mean that they are not low frequency items.
i
L 24 8
i MR. GILLESPIE: I guess I'm --
2 CHAIRMAN PALLADINO Well, it's something that i
3 bothers me. And then we talk about uncertainties in terms 4 of decades because what you do there is favor the 5
uncertainty on the positive side, not on the negative side j 6 because if you are close to zero and you get ten times 7
closer to zero, you are still very close to zero.
8 But if you go in terms of ten times or decades on 9 _the positive side, you increase the number fantastically.
jo And normal experience does not show that uncertainties go j 33 by decades, at least not in my experience which has i
'2 included a lot of things.
- 33 In manufacturing you say, plus or minus five 34 mills. You don't say, plus or minus ten times whatever 15 your clearance is supposed to be. '
g And I think we've got to watch how we let 37 uncertainty drive us because it will drive usLvp a wall.
ja MR. GILLESPIE: Okay. And because we were doing i 39
_that and we went by the best estimates we had available and 20 the best estimates we had available from existing PRAs, and 21 from the ten that were done.where we brought together a 22 panel of experts as best we could to look at the ten 23 eastern plants scattered over the region in an attempt to 24 get a picture of the whole East.
25 If I take their central estimate of a return
-d>
'n3,
. _ _. -. . . . _ = _ - - - - - - _ _ .
25 h I frequency, it is very consistent with the return frequency 2 of internal initiators of Cl ass 9 accidents.
3 CHAIRMAN PALLADINO: Yes --
4 MR. GILLESPIE: Throw the uncertainties away, and !
5 I'm stating that as a fact.
- 6 CHAIRMAN PALLADINO
- That, I wasn't disputing. I 7 .was disputing the uncertainty issue.
g MR. GILLESPIE: Which causes me to go to our rule 9 recommendation.
to CHAIRMAN PALLADINO: However, if you are going to 11 have a rule that's going to cover the entir,e c'ountry, you 12 ought to look at the entire country.
33 MR. GILLESPIE: Oh, again we are -- yes, the
, 14 cogni:ance was there that -- well, let me go through the 15 elements of the rule --
16 CHAIRMAN PALLADINO: All right, go ahead.
17 MR. GILLESPIE: -- and try to show how we dealt la with that because you are right, it's very difficult to 19 write a generic rule to cover the whole country when there 20 is a difference, and a large difference, from one end to 21 the other.
22 The first part of'the rule is the ability to !
23 ' transport people back into the plant. This is -- and, Mr.
24 Chairman, you asked a comment on this because we talk in I 25 the paper about degraded modes,'and~what did we mean_.by l
ii i
l I
l- .
26 4
8 i degraded mode?
2 The ability to transport people back in, we say 12 3 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> seems to be reasonable to us. We actually deep 4
down believe that this is a spectrum of things. As a i
5 minimum, you are going to have a loss of the grid.
i 6 CHAIRMAN PALLADINO: A loss of what?
7 MR. GILLESPIE: A loss of.the grid, the plant that 8
has a severe thunderstorm, a tornado, a hurricane, you are 9 going to set yourself up to be expected to cope with that.
10 Now, as I understand it with the recent hurricane 11 in the Gulf, the plants took the initiative in advance to 12 get extra staffing on site to cope with that.
33 We think this then is very reasonable. We meant 14 by degraded mode anything that is not operating normally at 15 a hundred percent power in a very stable condition. You 16 may need extra people in there for shift relief. It may 17 just be a fact that it's raining very hard or there has is been an ice storm and you have to do something extra with a
39 your fleet of trucks to get people in even just for shift 20 relief. And that might be before or after whatever 21 happens.
22 CHAIRMAN PALLADINO: And I gather that!s not in 23 our rules now.
24 MR.-GILLESPIE: That is not i n our - rul es r.ow , the 25
. ability to communicate status to off-site authorities. It
l 27
- h. I clearly --
2 (Commissioner Bernthal joins meeting.)
3 COMMISSIONER ASSELSTINE: On that first one, 4 though, doesn't what you do depend on what the complicating 5 factor is?
6 MR. GILLESPIE: Well, I think the complicating 7 factor -- and the Chairman hit me with that in the 8 questions -- the 30-inch snow fall in Florida. I guess we 9 were hoping or expecting that a certain amount of common 10 sense would prevail. And this happens, okay? I mean, .t h i s a 11 is in -- ,
. 12 CHAIRMAN PALLADINO: Have there been -- is there a
,, 13 history of 30 inch snows in Florida?
14 MR. GILLESPIE: No. No, there isn't.
15 CHAIRMAN PALLADINO: Have we gone back the.
16 requisite number of years so that we can tell whether it's 17 ten to the minus fifth or ten to the minus fourth?
18 MR. GILLESPIE: No. But one of the things that --
19 let me read you the exact words in the rule because you --
20 one of the ways that we decided to deal with that was the 21 word " assume."
22 "In addressing the following capabilities, the -
23 licensee shall assuma," and then, "that normal 24 communications and road networks are disrupted."
25 Indeed, it doesn't make any difference what i
i l
l l
t i
l ~,_ - _ __
28 1
disrupts them. We are saying --
2 CHAIRMAN PALLADINO: No, I beg to differ with you 3
because I have to know what assumptions I'm going to make 4 if I'm going to make emergency planning.
5 If you say, assume the road networks are 6 disrupted, your answer implied, "Well, they are not j 7 completely disrupted." Well, then.I think you ought to say 8
that because my understanding was when you said 9 " disrupted," it's completely disrupted.
10 MR. GILLESPIE: Okay. Then we have not --
33 CHAIRMAN PALLADINO: But then I say, well, maybe 12 they were disrupted by one event, but must I also assume 33 that other natural phenomenon -- maybe has a slightly
. j, higher probability like a severe thunderstorm comes up at 15 the same time.
g Now, can I use alternate ways, like helicopters, 17 to get people in there or to evacuate pecple? You have to
- ig have some bound on how far you are going to go. And that i
39 was my whole trouble when you used a words like, suvere low 20 frequency natural phenomena." I don't know what you mean 21 by them, how Icw.
22 And the complicating effects of various phenomena 4
23 have to somewhere stop and I need to know where the staff 24 wants to stop it. I gathered you don't include complete 25 disruption of roads if I understood the answer to my 1
29 1 ,
7
[ ] question.
. 2 MR. GILLESPIE: It would in general not be 3 anticipated that most kinds of occurrences, even such as
} 4 hurricanes, eTrthquakes that may generally happen, would 5 entirely devastate the whole circumference and radiate out i
6 around a plant. .
. 7 CHAIRMAN PALLADINO: But then, what do you mean by s " Normal road networks are disrupted?" You mean that part 9 of them are disrupted?
4 to MR. GILLESPIE: Part of them are disrupted. . The 11 freeway may be disrupted yet, there vs a secondary road i
12 that still goes parallel to it, that's still intact.
, i3 Or there is a road going out to the north, even 14 though we have to assume that all access to the western 15 sector from the plant is disrupted.
i 16 CHAIRMAN PALLADINO: Well, now, once you get on 17 that route, don't you also have to evaluate the time it is takes because if you had a four-lane road that's disrupted 19 and you now got a two-lane road, that --
20 MR. GILLESPIE: It's going to take longer.
'2I CHAIRMAN PALLADINO: Yes.
22 MR. GILLESPIE: We agree. And we tried to -
23 emphasize in the paper that this is not -- we are not 24 trying to equate the same level of protection with this 25 complicating effect as would be there on a nice sunny day
! l
30
' when something happens at the plant.
i 2
The attempt is to have those things in place which i 3 are required. Now we have a general disaster around the 4 si te. Indeed, if it does affect the site as these sites 5 are designed, we've got true tragedy in the area around the 6 site. And there are going to be trade-offs.
- 7 Indeed, the-nuclear. power plant saying that
].
8 nothing is wrong may be valuable. If something is wrong, l >
{ g you want to.mitigato as much as possible.the effects. I'm i
jo never going to make it the same because I've changed the j 11 mix. I want to make it the best it can be. >
12 Now, for that public safety official who has got 13 this general disaster on his hands, it's now probably been a taken out of the hands of the state radiological health 15 people, he's got decisions to make. In fact, it may come i
g that his decision is that this nuclear power plant is not 37 his biggest problem and he's got to divert his ambulances, is his buses, his trucks, some place else. -
j9 I want to have him have the information he needs, 20 and that's what that was intended.- And I want the plant to
. 21 be-able-to get people in to get the plant-in a stable
,' 22 condition -- even if it's not all that unstable and it's a 23 relatively minor accident at the plant as far as the plant 24 isn't threatened, it's shut down safely but they've got a 25 loss of the grid. The diesels are running. They need to
_ ,. .- ..~. .. , , , . . . , _ . - _ , , - - . , _ . . _ . - _ - - - . _ , _ . , . - . .. -. - -
. _. .=-.- - . .-. . . ~ _ - - - ~
31 1
f f. I get a relief on there for the guy running, the mechanic, 2 running the diesels.
3 That was'the intent of these two bullets.
4 CHAIRMAN PALLADINO: But you still say that you 5
must assume that the roads are disrupted and the i 6 communications -- normal com,munications, normal roads are i 7 disrupted. And once you say that, it doesn't leave you l 4
8 many options.
9 So you need to know what's going to be the bounds to on this whole thing so you can deal with it.
I 11 MR. DIRCKS: I think in apy emergency plan, 12 though, you do have to anticipate disruption. But I don't
!_, 33 think you can always specify the disruption. All this is 14 saying is, count on disruption and make sure you'have 15 flexibility to deal with the disruption.
16 This one says, if you have an emergency at the 17 facility, don't count on the main highway being able to
- 18 transport automobiles back and forth. You may have to plan
- 19 on some other means of transportation to get --
i 20 CHAIRMAN PALLADINO: Like a helicopter.
21 MR. DIRCKS: Like a helicopter. You may have off-
, 22 road vehicles. You may have other -- .
23 COMMISSIONER ASSELSTINE: Or a combination of 24 those.
[ 25 MR. DIRCKS: Or a combination. But you are i
0 d
t
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32 58 i putting the burden on the ability of the licensee to come 2 up with --
3 CHAIRMAN PALLADINO: Yes. But see, we are talking i
4 about very low probability events. And then, if I talk i 5
about a very low probability event, must not I also look at 6 a far more probable event like a flood, like a hurricane at 7 'the same time in certain areas? I have trouble --
i g MR. DIRCKS: But the effect on the road system may i 9 be the same. Eleni, for example --
1 jo CHAIRMAN PALLADINO: No, but it may yet complicate
! 11 what alternatives you have. .
12 MR. DIRCKS: Yes.
i g CHAIRMAN PALLADINO: And I want to know how far I 34 have to go before I stop complicating the events I have.
i 15 If I take a very low probability event, now it would seem' i
! 16 appr priate for somebody to'say, "Well, a far more probable
! 17 event might occur at the same time and therefore I've got i
18 to treat it all."
39 MR. GILLESPIE: I'think -- a 20 MR. DIRCKSt- I guess the -- you are getting in one 21 of these positions, if it's so complicated you can't do any i
22 planning.
4 23 CHAIRMAN PALLADINO: That's exactly where I'm 4
24 afraid we are going.
i 25 MR. DIRCKS: Yes.
i j
L 3
o
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30 1 CHAIRMAN PALLADINO: That's exactly my problem.
2 MR. DIRCKS: But the option would be, you don't 3 have any requi'redent at all'to build in f l e::i b i l i ty.
i 4 CHAIRMAN PALLADINO: Well --
i 5 MR. DIRCKS: If you say it's so complicated, you 6 can't do anything -- .
7 CHAIRMAN PALLADINO: We are talking about severe a low probability natural phenomena, and that's where I have 9 my basic problem because how low -- once you define how to low, then I can help you asses or I can make c.y own 11 assessment. ,
l 12 But if you don't know how low, I don't know where ,
i
. 13 to stop. That's my problem.
- -- 14 MR. GILLESPIE
- Okay. One of the things we are 15 trying to get at -- and I guess we didn't articulate it i
16 very well in the rule -- was, what we were looking at was 17 the capability to do it.
i l 18 CHAIRMAN PALLADINO: Yes, but let me go even 19 further. We have rules now for more probable events. Do 20 we require that these people be able to send additional 21 staff to the facility?
22 MR. GILLESPIE: Within the current. guidelines? .
23 COMMISSIONER ASSELSTINE: Yos.
24 MR. GILLESPIE: Yes.
25 CHAIRMAN PALLADINO: Do we?
- -s , , --- -- - ,gp. ..m,. e..- -g.. -.e- --.,--,,ee--,,,-,-g.-y-
34 i
j' i MR. GILLESPIE: Yes.
2 CHAIRMAN PALLADINO: Well, then why don't they i
- 3 apply for this circumstance? ;
1 4 COMMISSIO.NTR BERNTHAL: If they can do it there, 5 why can't --
! 6 CHAIRMAN PALLADINO: Yes, why can't thev do it 7 here?
8 MR. GILLESPIE: Okay, let me get to the -- we 9 -attempted here to also be consistent with the emergency 10 action guidelines which. call for certain actions at various ji levels.
12 CHAIRMAN PALLADINO: But doesn't -- don't our l
i3 present rules require that you be able to get people to the t
i, site in the event of emergency?
i j$ MR. GILLESPIE: Yes, they do,
{ -16 CHAIRMAN PALLADINO: Then why'do I need to have i
l 17 something that says, well, you've got to -- for very low i
i frequency natural events, I've got to put something is
_j9 special?
i i
20 If this exists, then it already applies and I f' 21 don't'think you need to add that.
I 22 MR. GILLESPIE: Well, what it doesn't have is the 23 capability of having-pre-thought out what would be i ..
l 24 considered imaginative answers at the last minute. j i
25 CHAIRMAN PALLADINO: I'm sorry, I don't understand e
)
i i , _ _ _ -,_ _ . . _ . . _ . _ _ . . _ _ . _ _ , _ _
35
- p. .
( l that. If there is a requirement, they must have thought it i
2 out otherwise it can't be --
3 MR'. GILLESPIE: Because if it's the requirement --
4 the complication you are throwing into the requirement is, 5 they have to think out alternatives. If the person's t
6 normal car when he gets called and says, "Come in to the
, y plant," can't make it across the roads but a utility line 8 truck can because it's a much bigger vehicle and can 5
9 traverse a much rougher territory, the utility could have 10 pre-thought out in advance the number of trucks they*ve got 11 available to go get the guy with the truck.
I 12 Also, they might have pre-thought out how many -- '
i j_ , 13 what's the minimum shift augmentation I have to get in to l 14 plan for to do it this way if I have to use trucks.
, 15 CHAIRMAN PALLADINO: Don't they do that kind of 16 planning now in response to the requirement to be able to
- 17 get people on site?
l 1 is MR. GILLESPIE: No, I don't believe --
19 MR. JORDAN: To some extent but not for severe 20 natural --
21 CHAIRMAN PALLADINO: Well, then --
4 22 MR. GILLESPIE: Not for severe natural phenomena, 1
I 23 and the intent of this -- ,
24 CHAIRMAN PALLADINO: I'm more worried about the
- 25 more common phenomena. ;
i.
f I i Y
-. .. .- -. . - . . - . _ - ~ ._ - .. - -. - _ - - ~. _
r l
)
l 36 i
i MR. JORDAN: Yes, for the common phenomena --
2 CHAIRMAN PALLADINO: If you don't have a 3 requirement for the more common phenomena I say, well, 4 maybe we better fix up the more common phenomena.
5 COMMISSIONER ZECH: Well, we do have that right i
6 now f r some plants in the northern climates. I know they 7 have snow vehicles that I have been told that they use in g the winter time occasionally to even go to the homes and 4
- 9 pick up the on-coming shift people.
i 10 So, that's in place now at least in some plants
} ij that I'm aware of.
j 12 MR. GILLESPIE: And again, we've gone out of rule 13 space and into plant-specific space. We are now --
t 14 CHAIRMAN PALLADINO: I was in rule space. I was I 15 trying to find out what you do now and if it's not enough, l
16 then we ought to fix what we do now, regardless of whether
)-
17 we are talking --
i is MR. GILLESPIE: We are anticipating - you are
- 19 making a distinction between low frequency and fairly 4 20 frequent. We.are anticipating in writing the rules that i
21 we've got a spectrum of things that could happen. And 1
1 22 indeed, whether it's -- let me take the Gulf Coast.
, 23 Whether it's a hurri-ane, a periodic flooding or 24 generally something associated with water flooding roads is 25 the problem. And it's a spectrum of water flooding roads I
1 1
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37 F
t, 1 is the problem in the southeast.
1 2 In the north you may have flooding in some cases, i
- 3 but in most cases snow is probably going to be, at Yankee, 4 a predominant problem, the spectrum of snows. .
~
5 CHAIRMAN PALLADINO: But I think a heavy snow in i
6 Florida would be a bigger problem than a heavy snow in 7 Maine --
8 MR. GILLESPIE: Okay.
1 4
i 9 CHAIRMAN PALLADINO: -- because they are prepared to for it and the other one isn't.
, 11 MR. GILLESPIE: We were envisioning writing into i
12 the rule a capability which covered a broad spectrum, and ;
- _ 13 we were addressing the whole spectrum of what you would 4
- 14 normally expect at that site. t is CHAIRMAN PALLADINO
- No, you are talking about 16 severe low frequency' natural phenomena. Snow in Maine is
! 17 not a low frequency natural phenomena, but snow in Florida,
- 18 heavy snow in Florida, I think is.
19 So you've got to keep in perspective what you are 20 talking about, and I think that's part of our problem. ,
21 If we need to have people get back into the sito, 22 Y^u need them -- and you don't think our present rule is l
1 23 adequate, then that ought to be fixed up, notwithstanding 24 consideration of the low frequency versus high frequency.
25 MR. GILLESPIE: I would say we agree --
I i
l l
38
) CHAIRMAN PALLADINO: All right.
2 MR. GILLESPIE: -- that it's the ability to have 3 preplanned some other options for a. span of things --
4 COMMISSIONER ASSELSTINE: That's right.
5 MR. GILLESPIE: -- that's important. I'm in total 6 agreement, and I can only apologize if it didn't come out 9
7 the way --
8 CHAIRMAN PALLADINO: No, no need to apologire.
9 I'm just trying to understand.
ja MR. GILLESPIE: No, I'm agreeing. Yes, the 11 spectrum of events that we had envisioned from the bottom 12 to the top, and I agree the top is low probability and the 33 other end is higher probability.
34 The ability to communicate, again, so the off-site 15 authorities can do what they have to do in making trade-off 16 judgments, they are going to have other things going on.
17 They have to make some hard decisions, is The other thing is the ability in a real emergency 39 to tell them that nothing is wrong. That may be almost as 20 important as saying, "Something is wrong," particularly in 21 a real disaster where the power plant, I would e::pect ,
22 would survive where other things didn't.
23 If you have to get power back on the grid for 24 hospitals, it would be very important to communicate the 25 capability of doing that to the local authorities.
. _ - _ - .- .~_ . -. . __ - _ . . . --
39 T
4 i COMMISSIONER ASSELSTINE: No, that's --
2 CHAIRMAN PALLADINO: Isn't that in our present 3 rule?
4 COMMISSIONER ASSELSTINE: Not for natural
- 5 phenomena.
1
. 6 MR. GILLESPIE: Not with this complicating effect.
i 7 CHAIRMAN PALLADINO: Not for natural --
, 8 MR. GILLESPIE: No, not with this complicating 1
! 9 effect.
to COMMISSIONER ASSELSTINE: Yes, that's right.
I 11 Isn't that part of --
! 12 CHAIRMAN PALLADINO: But you also said that most a
, 13 of them have it. So, I don't know --
14 MR. GILLESPIE: Most of them have a diverse enough 15 set of communications capabilities that we would expect j 16 that they would easily be able to comply with this.
17 Between the radios, the company radios -- the security
- la requirements say they have to have radios to talk to the
! 19 local police forces.
+
20 CHAIRMAN PALLADINO: Well, don't they need those 21 for more frequent phenomena?
i 22 MR. GILLESPIE: I'm not disagreeing, they do need 23 them for more frequent phenomena.
i 24 CHAIRMAN PALLADINO: Well, then it we need to fix 25 up that part of the rule, then why don't we fix it up for 7
l l
l l
40 i all things, not just very low natural phenomena, very low 2 frequency natural phenomena?
3 MR. GILLESPIE: Again, I can't --
$ 4 CHAIRMAN PALLADINO: Well, this is why I'm --
5 MR. G I LLESP,.IE: No, I can't disagree with your 6 statement.
7 CHAIRMAN PAL'LADINO: Excuse me, Jim, I didn't mean l
to interrupt. I was just trying to finish my point.
! 8 9 COMMISSIONER ASSELSTINE: Frank, isn't that i
jo precisely the point, that whether it's natural phenomena or i it other things, you have a range of possible occurrences.
12 Take hurricanes, for example, at a Florida plant.
13 You can have a mild hurricane or tropical storm.
34 You could also have the worst hurricane anybody has ever 15 envisioned in recorded history. There are a range of
, g probabilities associated with those kinds of things.
17 I assume that there are emergency planning 18 measures -- bringing people on the site, communicating the j9 status of the plant -- that apply at various levels of that 20 kind-of an occurrence. Even a tropical storm, you want to I
21 make sure you have the ability for the communications 22 networks to work. You want to have the ability to move -
I 23 people back and forth to the site.
24 I suppose as you get to the more unlikely but 1
25 higher consequence kinds of occurrences, those jobs may get
41 1 tougher. And what you want to do is show that you have at 2 least.the flexibility to deal with a range of those things 3 putting some bounds, perhaps, on the outer extreme.
4 MR. GILLESPIE: Yes.
5 COMMISSIONER ASSELSTINE: And isn't the same thing 6 .true of earthquakes, that when you have lower level 7 earthquakes, ones that are more likely, you still may need 8 the ability to get people to the site. You still may need -
9 the ability to communicate with the site to find out if 10 everything is okay. Just as you say, to get the word out 1
11 that there is no problem, that there has been no damage.
12 And in fact, I think the emergency plans in the
_- 13 seismic areas even call for that kind of performance at'the 14 lower levels. That's different from saying, we have to 15 _ worry about this four times the SSE situation way out on 16 the end, just like we have to worry about the most extreme 17 hurricane that anyone has ever possibly imagined.that would 18 destroy every way in to a plant; every form of ,
i 19 communication; every opportunity to get a truck or anything
, 20 else in to a site.
21 CHAIRMAN PALLADINO: But when you talk about in 22 .the South hurricanes, tropical storms, those are rather 23' frequent phenomena in the terms that we are talking about 24 here.
25 Talk about a 30-inch snow in Florida. Now, that's I
.~. . - . .~. - -- . _ - .
?
42 8- not a very frequent phenomena. What are the circumstances, i
2 what must you do there? They have no road equipment. If 3 all the roads,. normal roads, are impossible, perhaps even l 4 the helicopter is impossible because it may still be i
5 snowing. ,
6 So, I don't know, again,'where I've got to stop.
-7 Remember, the thru$t is on severe, low frequency natural I 8 phenomena. And most of-the time we tend to think of the
, 9 more probable. phenomena.
in MR. GILLESPIE:. Okay. If I would -- I guess I 1
ti concede again the wording problem I have there. We got-12 those words and maybe continue to use them from 0-654, the I
13 emergency action levels which cover the span.
u At one level, it talks about an earthquake,. ,
1
.15 tornado, etcetera,-up to -- in the earthquake area it says
, g up'to the-OBE, and then at the next level it talks about up 37 to the SSE, and then the ne::t level talks about exceeding
! 18 the SSE.
4
- j9 COMMISSIONER ASSELSTINE: Yes.
20 MR. GILLESPIE: And in every case from more 21 probable to less probable, the same words are used, low
! 22 frequency natural phenomena.
23 COMMISSIONER ASSELSTIrJE: Yes.
24 MR.:GILLESPIE: So, I am guilty of attempting to ;
L 25_
stay within_the, if you would, accepted words that we have i
l
43 lr-1 I put already in the document, which kind of had a meaning 2 that spanned the whole group.
3 I agree with you, Mr. Chairman, you are in -- what 4 you are sayin,g is what we had intended to say. We wanted 5 to -- this is an end of a spectrum. We wanted to cover a 6 whole spectrum and, indeed, we believe that the more 7 frequent things need to have the flexibility more than the 8 less frequent things.
9 COMMISSIONER ASSELSTINE: But'isn't the answer on 10 where you draw the line, where you set that outer bound 11 that, " Gee, we*ve made prudent judgments for internal 12 initiators, on what we think is prudent to look at for
,, 13 emergency planning purposes."
14 Why i s it unreasonable, then, to say that.we are 15 going to look at natural phenomena that fall within the 16 general, the'same general range of probability, 17 particularly where you are looking at natural phenomena 18 that have the potential for widespread disruption around l
19 the plant? Just, as 1 think, the ACRS pointed out to us 20 when we had the meeting.
I 21 There are a few of these natural phenomena --
. 22 hurricanes and earthquakes being the two that they had 23 identified during our meeting -- that have the potential to 24 really disrupt things in the vicinity of the plant.
25 And why not use as the benchmark the probability mm I
44 h
i of the internal initiators that we view as prudent and then
{8 2
treat the same natural phenomena that have the same general 3
probability? ,
4 . CHAIRMAN PALLADINO: But where we ran into 5 problems, I amjtold on earthquakes, i s well, we can't run 4
6 into that problem, and now hurricanes I think are frequent
-7 enough in the areas that are considered'that I don't see i t 8
as a low frequency natural phenomenon.
9 COMMISSIONER BERNTHAL: Well, I think, if I can i
put this in the face, the Cem.wission when i t met with the
]a 10
~
i j ACRS not so long ago discussed the question of pr babilities, and at.that time i n fact I urged that we ask 12 -
,3 somebody, I don't care whether it is ACRS, but somebody
}
4 u .ought to do a comprehensive study of probabilities here so li i
that we know what we are talking about.
15 g I would argue, and Jim and I have discussed this, l
37 and he knows'I would argue that hurricanes are in no sense 18 in the same category as are at least two-things, ,
! j9 earthquakes and-tornadoes, because in this day and age you 1
20 can very well predict if a hurricane is in the vicinity, 21 and the Gulf Coast was certainly a good recent example,
-22 y u have hours of warning generally before the onslaught of 23 a hurricane.
j' 24 Whereas, tornadoes and earthquakes, where they do l 1
4 25 severe damage, i t is-entirely unpredictable, and I don't 1
1
- "r'
, 4r 4e.e=t.+e r-qm w p 5-qsog 7 --g--' g -r -tMte-e--y7ge- ei- -e e-- P e ympy Wy-' =,g.ow.v,.=,%aiwe 9Wy.-g-p--q 9 g w- 193r-i re y .eyyUWetp&c gy -
45 T
} ) think we have a good handle on the actual relative 2 probabilities, and I think that i s really what you are 3 groping at, Mr. Chairman.
4 CHAIRMAN PALLADINO: Well, all I was trying to 5
understand is what was meant by low frequency, severe low 6 frequency natural phenomena that we are considering here j 7 and how do we bound it.
4 8 COMMISSIONER BERNTHAL: I think unpredictable is 9 an additional point though because being severe and low to frequency may very well apply to hurricanes in Boston. I 11 don't think there is any question about it. .But what is 5 12 also true is that in this day and age you are going to know l, 33 if a hurricane is going to strike the City of Boston. That 14 wasn't true 50 years ago. It is true today, a 15 Whereas, a tornado.and earthquake, you surely 16 won't know whether it is going to strike Boston or Diablo 17 Canyon or wherever it might be.
is COMMISSIONER ASSELSTINE: I am not sure that helps 19 you, because it seems to me that makes it even more 20 important to do the preplanning for those kinds of things 21 because you flexibility may well be more limited. But I 22 think on the probability point.though I think the staff has 23 given us the answer on that, and what they said is we
- 24 routinely consider accident initiators, internal accident i
l 25 initiators that.have probabilities of on the order of ten i7 e
r .%. . = _ , . - - - . - , . . ..-y ..w- . , , , . . ---,-...v -- , m y - ~-
46 8
i to the minus four to ten to the minus five.
2 And when you look at these natural phenomena, 3
these natural phenomena have probabilities, including the 4
earthquakes, have probabilities that are well within that 5
range. ,
6 And if you consider the internal initiators with 7
those kinds of probability ranges, then logically you must 8
consider the enternal initiators with that kind of 9 probability. I think that is exactly what the staff has 10 been saying.
- COMMISSICNER BERNTHAL: You are t al l:i ng about the 12 common cause event now though.
33 COMMISSIONER ASSELSTINE: No, no.
j, COMMISSIONER BERNTHAL: If you are not talking 15 ab ut common cause ---
16 COMMISSIONER ASSELSTINE: Okay. I think it is i7 most likely that it is the common cause event, that is 18 right.
39 COMMISSIONER BERNTHAL: It has to be the common 20 cause event.
21 MR. GILLESPIE: Clearly we are not dabbling with 22 two independent events. We are saying the common cause.
23 COMMISSIONER ASSELSTINE: That is right. It is 24 the common cause.
25 MR. DIRCKS: It might be helpful, since we are
i 47 4 7--
f 1 talking about offsite planning, and we are certainly 2 offsite planners here, I have Dick Krimm at the enc of the 3 table from FEMA whose agency does have this responsibility, 4 and it might be helpful to get Dick involved i r: this 5 discussion.
6 MR. KRIMM: I would be very glad tc. I just might .
7 mention that the office which I head at FEMA is the Office g of Natural and Technological Hazards where we get into both 9 the area of earthquakes, hurricanen, dam safety and other to types of natural phenomena as well as the technological 11 ha:ards of radiological emergency planning and ha:ardous 12 materials.
,, i3 Probabilities do vary, and let's take a flood for 14 example. You have a one percent annual chance flood, which 15 we use in the Federal Emergency Management Agency as 16 identifying a flood hazard area. Some people ref er to this
! 17
. flood as a flood that occurs once in a hundred years, which 18 is somewhat of a misnomer.
19 You have a less frequent type flood, which some 1
20 refer to as a 500 year flood, or the Corps of Engineers 21 uses a standard project flood for building dams and so 22 forth. I would say a standard project flond is a very low-
, 23 level type of frequency, i
24 Tropi cal storm Agnes in 1972 caused a standard 25 project type of flood along the Susquehanna River in P O I
. - ~ - - e v , - -, , , , . . -- , . , , - - , , . . . - , -r, -.r< .w.--
48 8
y certain areas. You talk about hurricanes, and the National 2
Oceanic and Atmospheric Ad.'inistration has five levels of 3
hurricanes. Hurricane Eleni was a Category 3 hurricano, as 4
well Hurricane Frederick, which occurred in 1979. Whereas, 5
Hurricane Camille, which was a very devastating hurricane 6
also, was a Category 5.
7 So when you are looking at probabilities, and I 8
will mention in my testimony I think you do have to do a i
j g study of just what we are talking about as far as 10 probabilities in low frequency, but they range in ij everything. -
12 For example, in California there are earthquakes' occurring every day. But one is more concerned with you 33 i, get on the Richter scale of an earthquake of six or more magnitude. And the United States Goological Survey has 15 g just made their first earthquake prediction in the
- 37 Parkfield, California area where they do predict a l
18 magnitude of 7.5 or greater earthquake sometime within the 39 next five years, and this is based on historic knowledge.
20 Earthquakes in the eastern part of the United 21 States are less know and far less frequent. There were 22 severe earthquakes in Charleston in 1886.- The New Madrid i
23 earthquake in 1811/1812, the New Madrid fault in Missouri, 24 was the most severe earthquake that has occurred in the
! 25 lower part of the United Statos, or what we call the Lower i
l l
l l
49 e
[. i '48 States.
2 COMMISSIONER ROBERTS: But about which we really 3 know very.little.
4 MR. KRIMM: We know very little. Toe faults are 5 not clearly defined in the eastern part of the United 6 States, and I think my point I am trying to make is that 7 the seismic risk in the eastern part of the United States g is far less than it is west of the Rockies.
9 So you really have to start looking at to probabilities to find out exactly what we are talking about 11 and what is the safety factor.
12 If you want to build a levy or a dam, for example, j3 that is going to protect New Orleans from almost any type
)a 14 of flooding, you do go to a standard project type of j$ flood. But for land use planning purposes you would go to 1
16 the 'one percent annual chance type of flooding.
17 CHAIRMAN PALLADINO: .But that doesn't compare with 18 what we are talking about because we are looking for 19 something that has ten to the minus fourth and ten to the 20 minus fif th recurrence frequency. So you are going from
- i 21 100 to 500 and it hasn't gone out yet to what I believe 22 these people are talking about when they talk low
- 22 frequency.
- 24 MR. KRIMM
- Well, probability ---
l 25 CHAIRMAN PALLADINO: So you are talking more like,
.q
_ . . . + -,,n - - .,.r
, w 50 3
and I don't know if my arithmetic is going to be right, one 2
in ten thousand years, and now you are going to design for 3
that. You don't do that kind of thinking, and yet that is i 4
what we are proposing here. We look to something 1
l 5 reasongble and not severe low frequency natural phenomena 6
such that they have to have a frequency of ten to the minus 7
fourth and ten to the minus fifth.
i' MR. KRTMM: Well, I think when you look at the 8
i 9 life span of a nuclear power plant, which I believe is 40 i
10 years; is that correct?
n COMMISSIONER ASSELSTINE: Correct.
12 MR. KRIMM: And then you start taking, let's say, ,
33 a flood, a 500-year flood, and you take the probability of l 3, that flood occurring over the lifetime of the nuclear power 15 P l ant, you do get really into what I would consider a low f- f requency phenornena.
16 37 CHAIRMAN PALLADINO: But, see, we have got-to use I the same definition of low frequency. They'are using ten jg j9 to the minus four and ten to'the minus fifth. So, 20 therefore, you should be using,-if you were to follow their i
21 anal gy, design it for one in ten thousand years and, 1
! '22 therefore, that'is even a lower probability for having it i
23 ccur_during the 40 year life of a plant.
2j MR. GILLESPIE: Now, if I might, the ten ~to.the minus fifth came for earthquakes. We were very. specific on 25 i
7
_ - - - . . - - . . . ,,.. [.._.,-_ ,
51 i-f r- '
i that. Now let me go one step further.
2 . COMMISSIONER ASSELSTINE: And for ones that are 3 multiples of the SSE.
4 MR. GI'LLESPIE: As I said ---
5 CHAIRMAN PALLADINO: Excuse me, but'you said that i
6 because the internal events are going to bring about
- 7 disruption or some real accident at ten to the minus four 8
and ten to the minus fifth, we should bring the external 9 ones up to the same range.- So that is what I am basing my 10 comments on.
11 MR. GILLESPIE: But there is physical -- only so 12 much water can fall out of the sky. So, in fact, you may
,, j3 not have to worry in that case about a ten to the minus 14 fifth hurricane when a level five hurricane is just the j y3 most that can ever happen because you have got a saturation i
16 problem.
17 There are physical phenomena which also bound it, ja and I am not trying to bound it totally on frequency. The 39 example used, we had. numbers for earthquakes-which we could 20 reference. So we used ---
4 21 CHAIRMAN PALLADINO: I am not talking about what 22 falls out of the sky. I.am_saying there.must be some 23' history of a flood that. occurs about once in every ten 24 thousand years that must be higher than the one in five 25 hundred, and I say if he was going to follow the same
, .i .
4 e
g g e. _ .-,,
,l <
- 9 _
52 8
y thinking process that is being proposed here, he would have 2
to use the one in ten thousand, not the one in five 3
hundred, regardless 6f how much rain it takes to produce 4
it, or maybe it was a dam failure. I don't know what 5
produced it.
- Well, okay. I a'm sorry. I am just having trouble 6
7 with this whole rule.
CCMMISSIONER BERNTHAL: Well, I think the point 8 ,
g that you are trying to nake'is a legitimate eno, and I 10 think that probably it re' ally gets to the point thogtgh that ij we go above and beyond 1H this busrness what most other 12 entities in this society'do when it comes to planr;ing for l y3 risks and ha:ards. We simply have a higher standard here.
\
j, And if FEttA plans routinely to addecsc emergencies 15 associated with hundred year events, let's say, or even g five-hundred-year events, that is not what we do. We tend -
37 to go far beyond th'at , and I think the Chairman is right -
gg that it seems quite clear tha$ what we are proposing to do y9 here is take srecific emergency precautions for the ons in 20 a thousand to one in ten thousand and perhaps even one in a hundred thousand year event. And FEMA may wish or may not 21 22 wish to go on the record and say we simply don:t plan for ,
8 23 that sort of thing. S 24 I noted, incidQntally, i n ,,sode of the materials 25 here that Japan, and you may have already discussed this, s
t
-4 4
?
~= . .. -- - - - .
53
. r- -
f, . i and I am sorry.I was late, . but Japan does not take specific 2 account of earthquakes in their emergency planning, and I s-ha 3 have found that.very curious because if there is any 4 country that is higher risk than California when it comes b 5 to earthquakes, it surely is Japan.
6 MR. DIRCKS: We have to go back and take a look at 7 what they have in emergency planning to begin with, g COMMISSIONER BERNTHAL: The question is do they do 9 a' broader kind of preparation than FEMA does, for example.
jo MR. DIRCKS: I am not even sure of their 11 evacuation requirements in Japan.
12 MR'. KRIMM: Well, Japan has a very active i 13 earthquake program with frequent earthquake drills and so 34 forth. So that as a total country they are more prepared 15 for earthquakes than we are in the United States.
g COMMISSIONER BERNTHAL: But it might be worth 4
j7 doing a comparative analysis since we don't seem to know
! 18 exactly how what we are proposing to do might compare with ig what they do.
I 20 COMMISSIONER ASSELSTINE: The staff point out, 21 Fred, before you came that that line in the information i
22 they submitted might have been a little misleading and i t
, 23 didn't fully reflect what was ---
24 MR. GILLESPIE: The countries in general reversed 25 the question in the same sentence we asked them and sent i t i
e B
- - . +- - ,.-.-,y , ,. , . - - - ,-.-- , _ w ,,g,-
54
?
'8 g back to us. What you have to look at is in the total 2
context of. emergency planning. Do they even bother with 3
evacuation in Class 9 accidents?
- 4 The whole philosophy of emergency planning may in .
l 5
. fact be different in those countries, and the answer may be
-6 indeed, yes, they don't bother with these low frequency 7
external phenomena, but they also don't bother with the 8
ones we both with internally. So the total context is 9
missing from that line, i
- 10 COMMISSIONER ASSELSTINE
- Dick. I had a question.
n MR. KRIMM: Surely. -
12 COMMISSIONER ASSELSTINE: You talked about the ranges of hurricanes, the smaller ones as opposed to the 33 3, larger ones, Eleni versus Camille. Isn't the same thing 15 true on earthquakes? Don't you have a set of smaller ones g that can disrupt communication and can disrupt to some 37 extent your ability to use the existing transportation i
jg networks? And as an emergency planner, don't you want to 39 know that these plans have sufficient fle: ibility f or those l -20 lower ones as well, the more frequent ones, to be able to 5
21 accommodate those kinds of disruptions, both in i 22 communications _and on transportation?
I MR.,KRIMM: The more. frequent earthquakes, at 23 24 least in California where we have the best records, the 25 nes that occur almost daily or even annually, are of such i
1 i .
i
55
.r , ,
) a low magnitude that they do very little disruption.
2 COMMISSIONER ASSELSTINE: I was thinking of the ,
3 ones in between those and the --- l l .
j 4 MR. KRIMM: Let's take Coelinga, for example, 5
which I'think was around a 6 earthquake on the Richter !
}.
i I 6 Scale. That caused some disruption,'but they were able to i
j 7 handle it.
g The other point I frequently made, and I made this 4
when I testified out at~ San Onofre_on the question of
- 9 I
to earthquakes, that a' community that has a rep plan in effect 11 for offsite preparedness is able to handle almost any other 12 type of emergency that comes along. I mean they really_are 1
l, 13 well prepared and I think are better prepared than almost 1-- .
34 any other type of community.
4 I 15 So if you had, let's say,.a 6 earthquake occurring' ,
1 1
16 in the vicinity of a nuclear power plant, I think they 17 would have alternative. plans that they could get' people to f is the plant.
19 COMMISSIONER ASSELSTINE: But that is the purpose s
20 of having the emergency plans, right? .i 21 MR. KRIMM: Right, yes. .;
i l .22 COMMISSIONER ASSELSTINE: That is to be ablo to I i
i 23 ensure that you have got that flexibility because the plans j 24 themselves call for certain actions, actions to make sure 25 that you.can activate your center, you can notify State i
i r ,
i
- i I
i i
l 56 3
people, you can notify people of the condition of the plant 2
and you can bring people in if you need them.
3 The whole purpose of the emergency plan in those 4
areas where you have the potential for that kind of 5
activity is to make sure that the f l er:i b i l i ty is there and 6
that they have thought about those things and it is built 7
into the plan.
8 CHAIRMAN PALLADINO: But I understand that the 9
present ones require that you have the ability to bring 10 people in under those kind of circumstances and that ycu ij will be able to communicate dut.
12 COMMISSIONER ASSELSTINE: Well, the plans may do j3 it, and the staff may have required that kind of review and 3, analysis, but the regulations don't require it. That is j$
the purpose of this rule.
16 CHAIRMAN PALLADINO: Well, then I got a different j7 answer before. I got the answer that they are required.
ig MR. JORDAN: Maybe I should try to address that.
j9 CHAIRMAN PALLADINO: And if they are not required, 20 then we are talking about a different subject and then we 21 ught to go back to look at what we need for probable 22 events.
23 MR. JORDAN: For the probable events the 24 transportation and the multiple and diverse communication 25 links are indeed required, but they are not clearly
57
- p. .
1, i required for the severe event that the staff ---
2 CHAIRMAN PALLADINO: It doesn't matter. Once I 3 have got the diversity, then what do I have to worry about 4 what caused the problem?
5 MR. JORDAN: That is "part of the staff's view in 6
saying that the existing diverse i::ommunications, for 7 instance, is very likely to be able to withstand the most 8
severe seismic event, because the utility with its 4
. 9 radionet, with microwave towers and with telephones we feel j to there is a very high likelihood that one of those would i
it survive and be sufficient for that immediate response 12 rather than create an entirely new and different l
13 communication link. So i t is ---
_ . ja CHAIRMAN PALLADINO: You make a good case for 15 flexibility, and then say but we are not going to believe 16 that good case for flexibility. We are going to add g7 something on anyhow, and I don't know what added protection jg we are getting.
19 Incidentally, my answer about the cost benefit, I 20 never did get what the benefit was. I only got what the 21 cost was, and I.am not sure all the costs were included. I i
i 22 could give you some costs that weren't included.
l 23 We have got a problem here where we have got,to l
j 24 make a judgment, and it has got to be a reasonable 25 Judgment. But I don't find that we have a good basis for j~l i
i i
L .
m . _ . _ ~ . . - . _ _- _. _ . .___ . _ - .
I i
58 i
i saying that we get added protection that is very 2
significant by saying you have got to check your particular 3
requirements against every conceivable low frequency I
j 4 natural phenomenon, because you say you already have them, ;
i and if they are flexible enough for the more probable i 4 6 things, I expect they are going to be flexible enough for- ,
+
j 7 the more improbable things.
~
g But no matter what you do, you have got to tell me r
9 where to stop, and I am having difficulty.
Well, excuse me. I have spoken too much.
10 COMMISSIONER ASSELSTINE: I have one more question l
1 n
l 12 for Dick, and that is this notion of you don't have to g3 worry to much about what the initiator is to determine ja whether there is flexibility.
j I guess I would be interested in your reaction to 15 16 that, and let me give.you an, example, and I won't use t
J i7 earthquakes, I will use a different one. .
{ 18 Say y u have an emergency plan for a plant in j9 Florida that says if we need additional people, we have got 20 this company helicopter and we are 25 minutes away from the 21 plant where our engineering staff is, and if we have 22 pr blems, we are going to helicopter these people in.
Is that going to satisfy say in the case of a 23 i
24 hurricane, particularly the way that things dodge and swerve ar und sometimes? Don't you have to look at'what
! 25 i
i i
i
4 J
59 I
1 the initiator is?
1 ~
2 MR. KRIMM: I think Commissioner Bernthal pointed 3 out very well that today even though the hurricanes do go 4 back and forth, and Eleni was a very good example, you do i
l 5 have an idea of where it is going to go in, and during
! 6 Hurricane David, the Brunswick plant did' shut down f
, 7 beforehand.
8 Now if you are going to need additional people at g the plant prior to the hurricane coming, then they abould 4
to get the people in there before because you can't get them J
l 11 there during the hurricane.
I 12 COMMISSIONER ASSELSTINE: Okay. Well maybe a snow g3 storm in the Northeast is a better example.,
{ -
14 CHAIRMAN PALLADINO: You are talking about very 15 probable events.
l g MR. KRIMM: Again, you know, if you have the 17 weather forecast coming which indicates a heavy snow storm, is then you would want to try to'get the people there
{
ig beforehand.
20 COMMISSIONER ASSELSTINE: So you really think you 21 don't need to look at what the initiator is and that yod 22 can just.look at the potential, as the staff has said, for 23 the disruption and just go from.there?
24 MR. KRIMM I think you have to view the cause i
! 25 because there are different things. For example,-in a
! i t- 1 l
s i
- . .- -. . . - ~ . . . - . . . . - - - - .-
l l
v 60
)' ; hurricane you kind of have some warning, and also with a A
snow storm you would-have some warning. For an earthquake 2
you do not at this point. The prediction is not well i- 3 i
4 enough honed. A dam break, you would not it, for example.
' You do for most floods, but not for a flash flood type of 5
6 thing.
i 7
So you sometimes do have to weigh those factors into consideration. You can't ignore completely what the j 8 l 9 cause may be. But I think, to reiterate, most communities 10 having a g d emerg ncy plan in effect.would be able to i
11 cope with i t and they w6uld figure out some way. It may be l
12 that some of the people at the plant are just going to have i
to work longer, you know, or be there longer. l 33 i,
I think you also to take into consideration what j the phenomena is as to whether or not the plant is shut 15
( 16 down and so forth. A tornado, for example, comes very 1
l 37 quickly, and it may be that the people at the plant who are i
l gg there are going to have to work longer. I mean I think
{ j9 that is just a reality that you have to face.
! CHAIRMAN PALLADINO: Incidentally, when we talk 20 i
21 about helicopters, people spend two-thirds of their day 22 away fr m the office. So you have to postulate that there has to be some road access at least to the helicopter.
23 COMMICS!GNER ASSELSTINE: Yes, that is true.
24 25 MR. KRIMM: When an emergency occurs, for example, l
1 i e r
,-- ,, -._s . _. _ , , - - _ , - - , - - , , _ - , - -- -,,, -_--....v- - . - - - - - . - - -
' 61 1
i Civil' Defense Directors and other people go to these places 2 to prepare for the emergency and they stay there 48 to 64 3 hours working and, you know, taking a cat nap or something 4 like that. But I think that is one of the things that you i
5 do have .to face, that the people who are there onsite are
! 6 just going to have to work longer and harder.
- 7 COMMISSIONER BERNTHAL
- I find i t curious that 8
this debate seems to have taken a turn toward a major 9 consideration that I don't recall having-been a significant I to part of the previous debate, and that is how to get people 33 in to help out in the plant if something goes wrong.
j 12 I don't deny that that might be a concern here,
, , i3 but I thought this question was about the ability to carry 34 out an evacuation of the public in an accident scenario.-
l 15 If that isn't even the major consideration here, then I i
e 4
g really question what this is all about.
i 17 I mean it may well be that that element of-getting
! y people in.if times get tough was part of the previous
- 19 debate, but that was not front and center of what we were i
l 20 talking about before. If it was, I was sitting in a 21 different meeting I think than some of the rest of you.
22 COMMISSIONER ASSELSTINE: I think it was discussed l
23 right from the beginning as a matter of fact.
. 24 COMMISSIONER BERNTHAL : But it was not the major !
l 25 issue.
l
} )
- , ee r - . + - y 4 ---n.--+y e. . . - - m ++~..-4.w .- m- .c.- ,_-r ,- mr,- -.w - . - --y-, g--- .w- w
62 a
y COMMISSIONER ASSELSTINE: Well, it was one elem,ent 2
of the lower event that requires the full range of ,
3 omergency planning' actions and not just evacuation, but 4
bringing people to the site and being able to communicate.
5 COMt1ISSIONER BERNTHAL: I simply find it highly 6
improbable, I mean far more improbable than the question of i
7 whether this broad preparation that we already do for a 8
wide range of emergency situations that should apply to 9 most situations. I find it highly improbable that the kcy
. 10 issue here is whether we can get one or more individuals in 3; or a shift change in in the event of some natural phenomena 12 is the key issue.
33 MR. DIRCKS: I think we started off with the three j, options. One, do you take earthquakes into account in emer9ency planning. Two, you don't have to. And, three, 15 g is do it on a case-by-case basis.
j7 I think given those three, we said to the extent gg that it is prudent and at low cost, why not do it, and 39 these are the elements that we said would make sense if you 20 wanted to do something.
21 Now you again say, as we started off saying, you 22 don't have to do anything in a special term. Or you can go 23 back to where we were pre-San Onofre where the staff did 24 cay take it into account on a case-by-casc basis, and that 25 is what got us into this situation in the first place.
e
63 k i CHAIRMAN PALLADINO: And then it was on the record 2
where the staff said no, you don't have to do it, if I 3 recall correctly.
4 MR. DIRCKS: Well, at one point during this 5 enchange.
6 CHAIRMAN PALLADINO: Well, I am just telling you 7 what the record shows.
COMMISSIONER ASSELSTINE: Fred, your other element 9 is the third one up there though, and I wouldn't discount to that one, looking for alternate routes for travel or 11 methods for determining whether to shelter or evacuato.
12 That is the third element. I am not sure I would put a j3 priority on which one is of greater or losuor importance.
u I think they are all involved. One is dealing with the 15 situation at the plant and communicating out, and also 16 dealing with the evacuation or other responses.
17 COMMISSIONER BERNTHAL: Encept that I really have is difficulty believing that the first two of those are so 39 phenomena specific as you I guess and some others seem to 20 feel earthquakes are.
21 I think that at least the public surely was under 22 the impression that what this Commission was talking about 23 was the question of whether we had to promulgate a rule 24 that dealt with the ability for evacuation in the face of a 25 major earthquake. I don't think that there was much of the f
e
64 8
y first two of these in.
We don't have the analysis again in detail I 2
3 quess, but my instinct is that the broad preparation wo do 4
for the first two of those is not very phenomenon 5 SP'CifiC' I **Y D* "IO"9' COMMISSIONER ASSELSTINE: Well, that is why I 6
asked Dick his opinion as an emergency planner of whether 7
at least to some extent you have to look at the individut1 8
9 phenomena, and he said yes, you do to come a:ttent.
10 CHAIRMAN PALLADINO: Don't the state and local
- governmente identify alternate routes of travel and mothods 12 f r determining whether to shelter or evacuate for probable 33 events?
9 MR. GILLESPIE: They are recuented to, but not with this complication. I think, if I cculd, for clarity 15 g explain ---
37 CHAIRMAN PALLADINO: With which complication, 18 because in answer to my Question you say most natural 39 phenomena do not produce equal impact over a broad region 20 and there would probably be alternative transportation 21 routes available in many cases.
22 Well, go ahead. I am sorry.
23 MR. GILLESPIE In the answer we were dealing with 24 the spoetrum of accidents, and lot ma, if I cculd, just 25 read directly what it says on communications in the rules
65
) and why what we want to put in the rules on ommunicationc 2 would augment this.
3 The rules say, and this is Append i:: E to Part 50, 4 "At least one onstto and one offstto communications 5 system. Each system shall have a backup power source. All 6
communications in the plan shall have arrangements for 7 emergencies, including titles end alternates for those in 8 charge of both," et cetera.
9 We require a backup power source. We require a jo redundancy. We do not require those to work in heavy rain 11 storms. We do not require them to work in floods. Even i; the more common phenomena got dragged in as a result of
, i3 NUREG 0654, which is the implementing guidance on what we 14 meant by this.
- $ CHAIRMAN PALLADINO
- I missed you somewhere along je the 1tne.
17 MR. GILLESPIE: Indeed, you wore concerned before tg about covering the whole apoctrum ---
19 CHAIRMAN PALLADINO: You said you requarod a 20 backup. Now do wo want two backups? Are wo going to 21 spectfy baclups that work in snow, backups that work in f 22 rain, backups that work in hurricanos and backups that work in earthquakes? I am not sure ! Inow what you moan.
23 24 MR. GILLESPIE: The concern you raisod before wan 25 we woro focusing entirely on low frequency eventu.
66 g CHAIRMAN PALLADINO: Yes.
2 MR. GILLESPIE: We thought we were focusing on the 3
whole spectrum from more probable to loss probable events.
4 The reason we are focusing on that is right now within the
' rules those more probable events in the rules are in fact 5
not coverod. Where they are covered is in the site 6
7 specific plans, which are a combination of the staff's evaluation of the rules and the generally eccepted guidonce 8
9 document of NUREG 0654, which in tho joint NRC/ FEMA guidance document on how to develop a plan. So in fact the i 10 gj loss probably e'vonts are not covered in the rules.
g CHAIRMAN PALLADINO: But you say you want a backup g to I think it was the communications system.
. 3, MR. GILLESPIE: That is right.
- 3 CHAIRMAN FALLADINO
- Now here you aay one on 16 alternative communication systems. So what is the j7 difforenco?
ig MR. GILLESPIE: That wil) work in light of a j9 complicating phenomena, which means you would havo to show 20 some diversity.
21 CHAIRMAN PALLADINO: No, no. The answer to the question on that was that we don't talk about that. We 22 talk about the fact that there has boen disruption to our 23 24 normal communications in this case. So if we are going to 25 have a disruption in normal communications, and you ask ma
67 r-i for an alternative, I say that is my backup. So I have
(
2 trouble knowing the backup from the alternative when you 3 say that the condition we are protecting against is the 4
condition where we have disruption of normal communications 5 in road networks.
6 MR. GILLESPIE: Let me read the exact words 7 again. "At least one onsite and one offsite communications 8
system. Each system shall have a backup power source."
9 Indeed, what a utility would do is they have got jo such multiple communications links and they have more than it just a backup power sourco. Utilitics have indeed whole
. 12 systems that back each other up.
, i3 The preplanning of saying yes, if something 34 happens to my microwave tower, which I have designated to g$ be my primary system which has i ts backup power supply is 16 down, I will revert to system "x". Given an emergency they 17 would probably do_it anyway. What wo were endeavoring is 18 to have that prethought out within the rule.
tg CHAIRMAN PALLADINO: But if that is necessary for 20 the low frequency event, I think it is far more necessary 21 for the more prob'able.
22 MR. GILLESPIE: I agree, and the more probablo 23 C"'S ~~~
24 CHAIRMAN PALLADINO: That doesn't have anything to 25 do with the impact of low frequency earthquakos on
. _ , .- . . ~ . _ - , . _ _ . - . . . _ . _ _ _ . . . - = . _ . . . _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ _ _ _ - . _ _ . . _ _ _
-s -
t 68 l
8 g emergency planning. It has to do with emergency planning i
i 2 in general and we have got to fix it up.
3 MR. GILLESPIE: I agree.
f
- 4 CHAIRMAN PALLADINO
- But not tie it to this issue.
i 5
MR. GILLESPIE: Okay.
4 6 CHAIRMAN PALLADINO: Well, excuse me.
, 7 MR. GILLESPIE: I agree with you, Mr. Ch ai rman .
j 8 (Laughter.)
l . 9 I am feeling guiltier and guiltier about having 10 authored these darn words because we are in agreement.
n - (Laughter.)
]
j 12 And, in fact, I think in the answers to your l
i j
,3 questions we said we would expect that because of the
, y, implementation an,d because of what utilities already have 15 available, we would expect that they would say hey, our i
16 proprietary network of communications would be out backup.
I i7 Indeed, we would expect that would be there.
18 It is the preplanning in that it is not ad hoc, i
I 39 and we did intend that in the spectrum.of accidents we i
{ 20
- would capture the more probable events. ,
i i
i 21 CHAIRMAN PALLADINO: So you are'saying you have ;
22 got to plan for the very improbable, but you don't have to 23 plan f r.the probable?
-24 MR. GILLESPIE: No. Our intent was the spectrum.
25
. CHAIRMAN PALLADINO: .Well, but'this is not the 1
l f
l^
9
. _ _ . _ . .. _ _ __ __- __ . _ _ _ _ ___~ _ _m _ . . .
1 o- .
69 Y
( 't focus of this rule. <
2 MR. GILLESPIE: My mistake in the rule is 3 highlighting one end of the spectrum without balancing it 4 with the other end of the spectrum.
5 CHAIRMAN PALLADINO: That.is the whole subject of 6 this rule I think. It doesn't talk about covering the
, 7 whole spectrum.
g MR. GILLESPIE: Well, we thought we covered that 9 by the word " assume," but ---
io CHAIRMAN PALLADINO: Well, okay. Did you finish 11 your presentation?
o 12 MR. GILLESPIE: I am done.
13 (Laughter.)
i l- , 14 A'while ago.
15 (Laughter.)
16 CHAIRMAN PALLADINO: Shall we ask for OGC and OPE 4
i 17 comments. -
l 7
4 tg MR. ZERBE: Well, after this period, I don't know r
i 19 whether ---
20 (Laughter.)
~
21 You have our paper that we sent out, and we don't 72 basically disagree with many of. the things the staff ham i
i 23 '
suggested.. .But in looking at their paper, we didn't really I
24 find any particular reason why the rule as you propose 25 wasn't okay. And we suggested that ---
1
- 9 e
, . _ . , , . _ _ _ . . , _ . m._ y- s . . . .-_..,__m - ,- , ,,. . . ~.,v
=.. .. _ _ ._ . . _ _ _ . _ . ~ . . _ _ _ _ _ _ . _ _ _
i 70 4
.l* i CHAIRMAN PALLADINO: Which rule that was proposed? ;
2 MR. ZERBE: The proposed rule that the Commission 3
put out for comment.
, CHAIRMAN PALLADINO: All right. I see.
MR. ZERBE: We did suggest, however, that the
[ 5 6
Commission should give some consideration to the points 4
{ 7 that the staff brought out specifically along the lines t
that you were just discussing, that they really clarify 8
i 9 what is in the regulations today.
So we attached really a modification to the 10 i gj staf f 's final rulo, but we also have modified the 12 Commission's -- we have a copy that modifies the 1
j Commission's original proposed rule, and I will just pass 33
, y that out for.ypu now.
1 f
j$
If you look at page 4, what we have proposed doing g was to make the modifications shown on page 4 below the --
37 it essentially is the items below the stars there. This l l
- g would take the place to Appendix E, Section 4 of Appendix l
j j9 E, and we would add the words that modify as shown.
! 20 We w uld say . . . neither the emergency response 21 plans nor evacuation time analyses need specifically -- add the word 'specifically' -- to consider the impact of -- and
] 22 t
we changed '
earthquakes' to " severe low frequency natural 23 24 phenomena'."
25 But then we did add what the staff ---
k 4
,m.< v.-. - -___..._,_+.ye-
-.,w-,. _--yy +--% , c_ v- ,.y . _ - _ . , , -._.y.* -
- , - ,,,- - ,< ,,, .,-_,.,_.-y _
71 F I didn*t pick up
/_ i CHAIRt1AN PALLADINO: Excuse me.
. 2 where you were.
3 MR. ZERBE: I am on page 4 there in the middle.
4 We would propose adding to Appendix E specifically
.f $ what.the staff was just talking about to demonstrate the 6
flexibility that is already in the system to accommodate 7
disruptions in normal communications in road networks.
8 We would proposal what is shown under Itam A there g that pertains to transporting people into the site and j go making arrangements for communications, ji Then "B" would be a similar situation that would 1
12 pertain to the state and local government emergency plans.
(i l
j3 So in a sense we have captured what the staff has
- y in their bottom line, but we don't sco any reason why one i
15 has to specifically earmark this for a low frequency l
i 16 phenomena. It applies to other than the low frequency l 17 phenomena, and we are just interested in the bottom line,
~
i i
is that this kind of information does got developed and put
! j, into the emergency plan.
i 20 So we are really not much different than the l
I 21 staff, but We ---
4 22 CHAIRMAN PALLADINO: So what would you be doing 23 with this?
24 MR. ZERBE: We Just side stepped all the
}
25 probability evaluations and what-have you relative to I
l 1 i
4
- ~ - . . - . - - - _ - _ . . . ._ -_-- -..-
72 j earthquake frequencies and tcrnadoes and that sort of thing 2
and just say you do now protect against that kind of thing 3
in your emergency planning. But we specifically put in 4
their points that they wanted to make clear in the 5
' regulation that aren't in there now. All those underlined 6
things are not in there now.
CHAIRMAN PALLADINO: What would you do with this 7
8 document, the one that they proposed?
9 MR. ZEREE: This is the modifications to Section 4 of Appendix E of Par.t 50. That is what they propose to 10 33 change. They propose not doing anything to 50.47, and we don't see any reason to do anything to 50.47. So 12 everything gets focused specifically on Part 50, Appendix 13 j,
E, and we make those additions 'to the existing Appundix E.
CHAIRMAN PALLADINO: But then what about the rest 15 16 f the paper, would you throw it away?
37 MR. ZERBE Well, that would have to be adjusted.
ig If the Commission chose to go down this road, we would have 39 to get together with the staff, or they would make those other adjustments to the rest of the federal notice. We 20 21 don't address that here, but it would just conform to what 22 is in -- this is what happens to the rule. This is specifically what we would propone to do.
23 CHAIRMAN PALLADINO: Well, 1 look at the rule as 24 25 being everything that we published here, including the
7 7
. i, i summary.
2 MR. ZERBE: Well, we had looked at the rule just 3 as the changes in Appendi:< E.
4 CHAIRMAN PALLADINO: Well, I have to think about 5
your ---
6 MR. ZERBE: The other parts of the federal notice 7
would have to be accommodated appropriately.
8 COMf1ISSIONER ASSELSTINE: But what you are 9 proposing I think is very different from what the st af f has jo proposed. You are proposing a specific finding that the 11 Commissicn doesn't have to consider low frequency natural 12 phenomena. Whereas the staff is saying you do to the
, , ) oxtent of the following items, and that is a very differont
,. . ja thing.
i$
MR. ZERBE Yes, but the staff said in the last 16 there that their paragraphs, as wo havo noted in tho 37 bottom, cover not only low frequency events, butggsre l
I is normal events, and we are agreeing with that. And if that 19 is the case, we see no reason ---
20 COMMIGGIONER ASSELSTINE: No, no, you are not 21 agreeing.~ You say, you make the specific finding, the 22 finding that is in the proposed rule that you do not have 23 to consider the impacts of severo low frequency natural 24 phenomena. In order t o Fria c h that judgment, you are going 25 to have to explain why you shovidn ' t consider the art ternal e
74 8
g initiators when you do consider the internal initiators.
2 MR. ZERBE We say specifically you don't have to 3
identify them as a special case. They are covered under l 4 the general situation that is in the rules today and made 5
more clear by these additions that the staff wanted to 6
- k'*
7 So we would say that with those modifications, if i g the Commission wants to .nake those, what that would do j 9 would just make more specifically clear what the Commission 10 had in mind in its omergency planning regulations today.
ii- CHAIRMAN PALLADINO: Incidentally, this paper 12 makes a very good case for finding that you don't need to do anything additional. As a matter of fact, after I read 33
, y all your, issues, I said, boy, encept that I had road i
15 s mething up front, but I thought that was e good support 16 fr the Commission's position.
4 1 37 MR. ZERBE: Well, wo said that, and we said you gg should consider this and maybe you don't want to do that.
CHAIRMAN PALLADINO: Dut also the EDO said it was
] i, 20 a very closo call. So ho munt have had a little bit of the 21 same feeling that this was pretty good to support that 22 nothing more needs to be done.
23 ncuse me, Jack.
24 MR. ZERDE: Well, relative to the CDO, we did sund 2$
a copy down Friday, but we didn't mako a point to call it i
75
' (- . directly to your attention. It went to your office Friday t, i 2 afternoon. We didn't get it out until Fridav afterroon.
3 CHAIRt1AN PALLADINO: Well, I think all o4 un are 4 going to have to give a little more thought to this.
5 COMMISSIONER ASSELSTINE: I had a question for 6 OGC.
7 CHAIRMAN PALLADINOg Sure.
8 COMMISSION 2R ASSELSTINE: And that was, first. I g would be interested in your reactici to the OFE alternatise 10 and, nacond. I would be i t .ter est ed in your view on this it information that is offered in the staff's statement of 12 consideration to support the flowibility notton, and i3 whether thet information has been part of the rulemal.ing
. ja record and whether members of tho public have boon given a 15 fair opportunity to comment on all of that information that g the Chairman just referred to that providos such a l arge 17 portion of the underpinning for the flenibility argument ja that he has included in the staff's proposal as well as to more strongly even in the OPE proposal.
20 MR. PLAINE: Well, with all due doforenco to Mr.
21 Gilleupie's problems, ! quons the thing that troublod us 22 was the adoquacy of the rulomalings that in to say, the 23 lack of support really given by the proemblo to the 24
'pproach. And it may bo that thore8 mi rjht be some nocoscity 25 for reaubmtsnton of some of thn motorial to the public. I i
76 3
am not sure that that isn't ruled out.
COMMISSIONER ASSELSTINE: Did the public have 2
3 access as part of the rulemaking to all of this information 4
that Frank was describing that 14 in our files or that is 5
in FEMA's files or some place else?
MR. PLAINE: Well, I am not so sure.that they 6
7 did. I saw some documentation indicating that perhaps they 8
didn't.
9 COMMISSIONER ASSELSTINE: And I take it they have jg been given an opportunity to ---
i; MR. PLAINE: Yes, and I think we would want to 12 lo k at that a little more closely. I can't givo you y3 anything specific at the moment, but that was a problem, 9, and I ,think we can comment on that in writing, if you would lik'*
15 g COMMISSIONER ASSELSTINE: That would be helpful to g7 me, gg CHAIRMAN PALLADINO: What would you propose?
i, COMMISSIONER ASSELSTINE: I would like OGC's 20 comment on whether the information that is offered as part 21 of the statement of considerations of the rule was part of 22 the rulemaking record so that the public had a fair 23 opportunity to review that information and to comment on it 24 as port of the comment process on the proposed rule, and 25 whethor that ropresonts a pechlom with proceeding with tho m.___________ _ _ __. _____.. _ - _ ._ . . . _ _. _ . _ _ _ _ . - _ _ _ - _ _ _ . . . _ _ _ _ _ _ _ . ___.m_-_ __ . . _ _ _ _ _ _ _ _ _ _ _ - _ _ _ -
.. . .. ~. . . - _ _ _ _ - . _ . - - - -- -. - _ . _ - _ . - . - . . _ - - .
l 77 i
f j staff's proposal or with the OPE proposal.
(
I 2 CHAIRMAN PALLADINO: And the possible outcome i
3 might be going out again for comments?
i I 4 COMMISSIONER ASSELSTINE: Issuing a now proposec, i
i 5 rule.
I I r
! 6 CHAIRMAN PALLADINO: I was just trying to I
7 understand.
I j 8 COMMISSIONER ASSELSTINE: I guess also, if you are !
l 9 going to put something together in writing, I would like 1
to your cemments on the OPE alternative.
] :: MR. PLAINE: We haven't had a chance to really l
l 12 look at that, but we are going to do that and include in l_, 13 writing. !
j .
34 COMMISSIONER ASSELSTINE: Okay. i 1
i $
CHAIRMAN PALLADINO: Well, I think we should j l f j 16 receive that information from OGC. I for one, I really 37 haven't made up my mind. I think there are more questions j 13 raised by this than answered. As a matter of fact, I think i
jg a better case is made in the staff paper for going the way i
20 that the Commission had suggested going than going the way
- 21 that the paper comes out. I think the case is not very 22 strongly supported for the paper, but I haven't decided yet i
23 what I would like to see done about it and I am open to all l 24 sorts of suggestions.
P COMMISSIONER SERNTHAL: I am surprised, frankly,
! 25 i t
!i i l i i
i I r
I 78 t
i at the one sentence in the staff's suggestion, and I think' ,
this-is what probably underlies your misgivings,. Joe. I 2 .
3 find it is often helpful in this volume of material that we _;
4 tend to get on these subjects to actually sit down and read 5
the words of the rule. .
And if you would just shut out from your mind for 6
7 a moment everything else and read the rule and what it says or the proposed staff change, there will have to be a lot d
9 of clarification, it seems to me, as to how you are going to to implement and how the' Commission should accept this ij sentence, "In addrossing the.following capabili. ties, the licensee shall assume that the severe natural phenomenon 12 has disrupted normal communication and road networks."
13
. j, , And once you have made that statement,-It seems to 15 me y u have to start talking very seriously about somo 16 cut ff f probability, and that is really,behind what the j7 Chairman was saying, it seems to me.
gg I can postulate very easily a comet or meteorito -
v ,,
gg fall tomorrow that you surely would not be able to cope
~
20 with, and I can assure you will ' disrupt very ' severely' all ,"
21 e ad.and communications not ocks. Obviously that'is not 22 what you mean to be done here, but it seems to me you have 23 opened up, if you just read the words here, something that 1s very broad and has no criteria. That is a real conc [rn.' i ,
24 25 Whore do we stop? I think that is what the I
u__.__._____._________________.___._________. ____ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ ______._m__ _ _ _ _ _ _ _ _
79 T
(, i Chairman said at one point.
2 COMMISSIONER ASSELSTINE: Isn't the same thing 3 true on the internal initiators?
4 CHAIRMAN PALLADINO: Sure.
5 COMMISSIONER ASSELSTINE: I mean you can postulate 6 a set of internal initiators that are so extreme and so y unlikely that there is virtually nothing that can be done 8
about them, and yet the. staff has made that judgment g consistently all the way along in implementing and appl ing to emergency planning requirements.
it And I think what the staff was saying the paper is 12 all they oropose to do is to treat the external Initiators 33 the same way, and those that fall in the same range of 34 probability as external initiators, they will look at the i$ potential complicating effects of those.
16 CHAIRMAN PALLADINO: But I say do that for the 17 more probable events as well as any improbable events you is want to consider. And if we need to fix up our existing 19 regulations, that is a different subject from the one we 20 were addressing.
~
21 Let me ask another question. When we design for 22 earthquakes in the nor theast or the eastern part of the 23 country, and we pick the safe shutdown earthquale, do we 24 Pick one that has a certain recurring' frequency? It.seems 25 to me that we do.
1 1
80
' MR. ONG: No, we-don't, sir.
3
.2 CHAIRMAN PALLADINO: We don't.
3 MR. ONG: There is no requirement fer return rates 4
5 CHAIRMAN PALLADINO: For the OBE.
6 MR. ONG: Yes, sir.
CHAIRMAN PALLADINO: And so we pick one for the 7
j 8 OBE; is that right?
i 9
MR. ONG: Yes, sir.
- .jg CHAIRMAN PALLADINO: What is that recurring ji frequency?
12 MR..ONG: It is not entirely clear as a staff j3 practice.
g ,
MR. MINOGUE: There is no requirement for a return 15 frequency for either the SSE or the OBE.
i
~
16 CHAIRMAN PALLADINO: There is neither.
j7 COMMISSIONER ASSELSTINE: That is'right.
jg MR. MINOGUE: In the science people will generally j9 agree that the recurrence interval of the OBE selected in 20 accordance with the regulation would be in the range of
, 21 about five hundred years, but that is not required in the 22 regulation.
23 The SSE is'an attempt to define the limiting.
24 carthquake, and Mr. Gillespie talked about that earlier.
25 And to thefextent you understand the' geology and 1
, - - ..- ,. , ,. - _v, - - ,
81 p_ ,
(. i seismology, vou can do that either very well or not so 2 well. That is just the uncertainty question that was also 3 touched on earlier.
4 CHAIRMAN PALLADINO: If we assumed that on the 5 average people used one in five hundred years for the OBE, 6 then how much higher do we go to the SSE7 7 MR. MINOGUE: You really can't answer it
- hat g way. The regulation requires a deterministic procedure 9
that considers both the seismic history, that is recorded 10 events, and that is a short period, and the geologic record i
I 11 to the extent you are able to understand it.
12 The intent is to develop an earthquake which is g3 the limiting earthquake, and if that were done correctly u with full knowledge, you would be in a range of return 15
. frequencies of ten to the fourth and maybe even ten to the i
g fifth.
17 But in fact over the years the science has been 18 developing rapidly. So that generally earthquakes that
^
-99 were determined some years ago are lower than that value, 20 or that is more likely, and that leads to the figures that 21 are in the paper which quote the Livermore report as 22 assigning recurrence intervals to the SSE's that were 23 actually used for design.
'24 CHAIRMAN PALLADINO: Have.we increased the SSE 25 value greatly in the eastern part of the United States, and i
l- ,
1
_ _ . _ _ . . _ _ _ . _ . . - _ . =_ . - _
82 !
li y from what to what?' ,
2 MR. MINOGUE: Over~the course of the last 15 or 20 3
years there has been a depression of about a factor of two.
4 CHAIRMAN PALLADINO: About a factor of two, okay.
5 COMMISSIONER BERNTHAL: Of_two? ,
6 MR. MINOGUE: That is correct. .
?
CHAIRMAN PALLADINO: I thought we had gone from 7
4 8
ab ut .15 to .25. .
l 9
COMMISSIONER BERNTHAL: I am afraid to ask what the uncertainties are? It sounds like that i s really in f 10 t
. . p the noise.
12 MR. MINOGUE: Well, the uncertainties are quite i
, j3 high because of the poor expression of eastern geology.
34 , Generally speaking, because the seismic history is so i
15 sh et, if you look to the structural geology.to reach back 16 in time into geologic history to get a better-handle, in 37 the East the geology is buried.. So it is very difficult to 18 inf er from the geologic. expression what the long history is.
39 20 COMMISSIONER BERNTHAL: The change of heart of a 21 facter of two either way is not something I-would gain or 22 lose much-sleep over at night-given the uncertainties in 23 ur ability to understand and predict earthquakes.
4 .
24 CHAIRMAN PALLADINO: Well, you have answered my i
. question.
l 25 i
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83
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( j MR. ONG: Yes, sir, which was no for the SSE. I 2 don't disagree with anything that Bob said, but I wouldn't 4
i 3 want it to go unsaid that Licensing Boards have 4 interpreted, and granted there is no regulation for the OBE 5 return rate, but there are some words in there saying a
- 6 staff requirement for a certain thing.
7 MR. MINOGUE: I tried to cover that, that the 8
people working in the scientific field would generally 9 agree on a return frequency for the OBE, if it were i to determined seismologically, of about 500 years, or three to it five hundred years.
4 12 CHAIRMAN PALLADINO: Are you saying that you don't .
13 multiply by some factor to get the safe shutdown 34 earthquake?
15 MR. MINOGUE: No, it is the other way around. The i
g regulation requires that-the OBE be at least half the SSE.
CHAIRMAN PALLADINO:
_17 So your' target i s ten to the ig minus fourth or thereabouts?
39 MR..ONG: No, sir. It i s usually in terms of 20 "G's" and not in terms return rates.
l 21 .
MR. MINOGUE: That is correct.
22 CHAIRMAN PALLADINO: Say it again?
23 MR. ONG: They are in terms of "G" values. Like 24 typically an.OBE would be half the size of a "G" value of
' 25 the.SSE.
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84
?- j CHAIRMAN PALLADINO: Well, I have read tons of 2
material that talks about the return rate of certain "G" 3
V#1"*S*
4 MR. ONG: Yes, sir, it i s in testimony, but it is 5
not a requirement. ,
COMMISSIONER BERNTHAL: But you surely when you 6
7 take all things into account are not planning what has 8
happened in the four-billion year history of the earth in 9
some continent, but you are taking into account what has 10 happened in-some reasonable time frame in Cali4oenia or 3; some other state.
n MR. MINOGUE: The regulation is explicit on that.
g You don't reach back into the mountain building period in
,y, the eastern United States. It is basically nootechtonics y u are 1 king at. It is the last 30,000 years of seismic 15 history as you can infer it from the geology.
16
.g7 COMMISSIONER BERNTHAL: And that is ten to the jg .minus 4 per year rouqhly?
.j9 MR. ONG: Yes, sir. There are numbers replete in 20 different records like one in a thousand and one in ten thousand and as smcIl as one in one hundred thousand. But 21 there are estimates by various experts that are in the 21 record.
23 CHAIRMAN PALLADINO. What surprises me is that I 24 had to multiply by a factor of two to four to get into the 25 j.
i i
I t
l 85 !
t 7_ .
i f, i region of-ten to the minus fourth and ten to the minus I
2 fifth because, if my memory serves me, that is about where 3 we picked the SSE.
1
! 4 Now maybe the ones we picked early didn't have the i
5 benefit of the-information that came later, but still our 6- targets were ten to the minus fourth and ten to the minus y fifth, and there may be a couple of cases that go far
- g enough back that we would have to multiply by two to three l
g to get there.
jo MR. MINOGUE: That is correct, Mr. Chairman.
11 Conceptually when that regulation was drafted, the intent 12 was that probability range. But the feeling was that the e
p nature of the phenomena, the. level of uncertainty and the 34 fact that there are limiting processes in the earth's 15 response to earthquakes led the regulation'instead to be in ,
16 deterministic form ---
37 CHAIRMAN PALLADINO: I agree, but to determine --- ,
4 1
t MR. MINOGUE:
ig --- to come out with what really is
- j9 seen as the maximum probable earthquake. The Corps of 20 Engineers in the analogous situation for' floods uses the r
~
21 term " probable maximum-flood," and the standard project 22 flood that was referred to earlier would be analogous to 23 the operating basis ---
24 CHAIRMAN PALLADINO: Starting frem my early days i ' 25 on the ACRS when.we were dealing with Bedaga. Bay and I had
- e e I
86 3
'to learn a lot about reismicity, I started to get a feel ,
2 for what people talked about when they were talking about 3
the SSE, and my memory serves that it was in the order of 4
ten to the minus forth and ten to the minus fifth, and that 5
is why I was surprised when you said I have to multiply by 6
two or four to get to on the average. ,
7 Now there may be some early ones where they didn't i 8 have the benefit of later information that has to be looked 9
at, but ---
10 MR. MINOGUE: Mr. Chairman, the question you asked g was in terms of the East Coast earthquakes, and there the 12 increased knowledge over the-last 15 years or so has led to
- that much of a change. You wouldn't find that pattern in 33
, g the West because there the geology is much better expressed i 15 and the seismicity is much higher. - So it is a lot easier 16 to make a good determination of the SSE with less
, g uncertainty.
t 18 CHAIRMAN PALLADINO: Well, okay. I have problems i
39 with what'is being proposed here for that.
20 MR. ONG: Before sitting down, could I just say 21 ne m re thing along that line because I have been 22 listening to you talk about these numbers like ten to the 23 minus four and ten to the minus five.
24 We have looked at certain curves that the staff 3
25 has made up based on contractor studies, and I would like L
I'
2 G7 a
p-- ,
{ ; to point out.that they seem to be using 50th percentile and 2 85th percentile estimates for perhaps three reactors. They i 3 are sort of at the center of the distribution.
I 4 I want to point out that if you look at the 5 spreads of these numbers, I think there are some numbers i
6 that may be as high as ten to the minus three and some 4
7 almost as small as ten to the minus seven without naming 8
certain reactors.
9 And, secondly, also, that some of these reactors, 10 there are estimates made of probabilities by the licensee f it themselves. So they might have different numbers. These 2
12 are strictly I think from the contractor.
_ , 13 MR. MINOGUE: The reference that we are reciting j4 is a Livermore report that looks at 10 plants in the East.
15 They are really selected to-give you a pretty good spread g throughout the East. So they pretty much characterire 4
17 eastern seismicity.
ig What they did was to use what amounted to an 39 Adelphi process'where they took a very carefully selected 20 broad group of experts representing the various views, and 21 they all. looked at the available science, the information 22 submitted by the licensees, et cetera, and came up with i
23 estimates, and these were then cross-compared by a process l
24 that I will admit I don't know the subtleties of.
25 CHAIRMAN PALLADINO: Well, we have gone into this r1
88 I'
i at least far enough to answer my question.
Well, let me make a proposal to the Commission. I 2
think I have to sort out this matter in my own mind, and I 3
4 would promise that within the next week I would get my 5
thoughts sorted out and get to you. ,
However, you may have thoughts that you want to 6
I devel op , . and I think as soon as we can exchange them, we ,
7 might have a better chance of understanding the issues. l 4 8 j 9 And, incidentally, if you -need more answers, I [
~10 would say now is the time to, and by now I mean in this 33 time period and not this afternoon, to frame the questions i 12 and get them to the people that you'think can most likely answer them.
13 COMMISSIONER BERNTHAL: I still think, as I have a
g said before, that we are lacking basic information on g probabilities here, but I realire that is not a three-week j g project..
ig CHAIRMAN PALLADINO: Well, I don't know how long a project it is. I think it.is important for us to get a 39 20 well thought-out rule that we feel we can support and live 1
21 with.
I -
COMMISSIONER ZECH: ILagree, but I think we ought 22 to try to.put some timetable on it.to move along with it as 23 far as we can. I hope the OGC can give us what they have 24 b en asked'to give us.
25
. . ,- - . . . ~ , - . , , , - . - , . , , - - ,.
89 r
t, i I for one think that we ought to get this generic 2 rule out. We have been talking about it for a long time 3 now, and I think it is our responsibility to get it out as 4 soon as we can.
5
.I certainly agree, Mr. Chairman, that we don't 6
have all the answers here today, but I think, frankly, from 7 my standpoint the staff has done a very fine job in trying 8
to come up with a clarification on this issue. I feel that g they have taken a giant step forward to assist us in a 10 decision. Whereas I know we are not quite there yet, I had 11 hoped that we could get their fairly soon.
12 I personally have been convinced that I can't
. 13 really agree that earthquakes or any other natural a phenomena should not be considered in emergency planning.
15 They should not be, in my view, categorically excluded from 16 consideration in emergency planning. And I think the staff 17 has tried to assist us in that regard in a very commendable 18 manner.
19 So I just urge that we give some priority to this 20 matter and we try to resolve it in a reasonable and 21 thoughtful manner, but with some kind of schedule that 22 would resolve it here in the near future.
23 CHAIRMAN PALLADINO: Well, I guess on a few points 24 I have to disagree. I think if there are things that need 25 to be done for low frequency events and, by doggone, those 1
1
. s 1
90 i'
y are much more important, that they be done for the more L 2 probable events. So you are talking about fixing up one ;
3 rule and not introducing another.
4 COMMISSIONER ASSELSTINE: Well, there is no reason 5
that you can't do both. I would just like to say, along ,
i -
6 with the comments that Lando made, there are some things in the statement of considerations that I have proble'ms with.
7 8
But by and large, I think under what are obviously rather 4
9 difficult circumstances, that at least the staff's effort 10 in' putting the package together represents an attempt to
, ij put together an objective proposal for the Commission to
~
12 c nsider and to try and-1ook at the full range of issues j3 and the full range of views, and I think you are to be
, y complimented for that. It.is a good try.
15 (Laughter.)
g COMMISSIONER BERNTHAL: About the best you are j7 going to get.
13 (Laughter.)
j9 CHAIRMAN PALLADINO: Any other. comments?
20 MR. KRIMM: Mr. Chairman, because.the rule does 2i affect FEMA's role in offsite emergency planning, I would, 22 if it'would be satisfactory, just like to make.a few 23 comments.
i 24 Would that be agreeable? '
f 25-CHAIRMAN PALLADINO: -Okay, sure.
i
-, . . . .- , , - 2,.. -
91 r-f, 1 MR. KRIMM: First of all, FEMA really takes the 2 position that we feel that the proposed ruling is 3 unnecessary from a cost-benefit basis in the viewpoint of 4 state and local government.
5 COMMISSIONER ZECH: It is unnecessary?
6 MR. KRIMM: Yes. We would say that before the 7 Commission adopts any rule change, it would seem 8
appropriate to ccnduct a probabilistic analysis to gain 9 assurance as to whether additional emergency planning and 10 preparedness efforts are warranted.
11 In the event that ycu do adopt a rule, we would 12 like you to realize that FEMA will need at least si:: months 33 to interpret the meaning and ramifications of the rule ja change language, both as it affects state and local 15 governments in compliance and FEMA in issuance of guidance 16 and evaluation of plans.
17 In addition, at least another 12 months will be 18 needed for offsite state and local governments to comply 19 with new requirements.
20 A joint NRC/ FEMA guidance would have to be
~
21 developed for adequate implementation of the rule change.
22 FEMA's concurrence is limited to considerations related to 23 plans only and does not envision demonstrations and
), exercises of any additional capabilities that might be 25 involved.
I
, i 92 s
y FEMA's cencurrr.nce is based on the understanding that the best scientific information is used for analyzing 2
the effects of each of the severe low frequency natural 3
4 phenomena considered.
And with reference to the licensee communicating 5
6 damage information to offsite authorities, include a 7
requirement that where necessary the licensee is to assure that offsite authorities have the required redundant 8
9 communications for receipt of the information.
jg COMMISSIONER ASSELSTINE: Dick, I take it if you ij don't see the need for benefit of a rule, that you would 3.j favor is basically going on a case-by-case basis to look at in each case which natural phenomena you think are of 33
, y, sufficient concern to examine in that individual case 15 rather than have a rule that cuts across the board g essentially?
y7 MR. KRIMM: No, we wouldn't. We really don't see jg the necessity of any type of rule. As we have said many 39 times before, we think all the various types of plans that 20 are out there now, not only just the rep plans, but the 21 earthquake preparedness plans, the hurricane preparedness 22 plans that are being developed and the other types of 23 emergency plans which states are required to adopt, all of 24 these things are there and we feel adding additional 25 burdens is going to place greater requirements and perhaps I
93 e
j' unnecessary requirements on state and local governments and 2 also perhaps on the licensees.
3 COMMISSIONER BERNTHAL: Let me ask just one final 4 question getting back to the sentence I read earlier. And 5
if this was resolved before I walked in here, I apologi:e, 6
and I will just communicate privately with the staff.
7 But I would like to know whether the question of 8
the literal plain reading of the staff's proposed version 9 of this rule, I would li ke to I-:now how the staff interprets 10 that to feel that they have not opened the door here to 11 virtually all severe low frequency natural phenomena that 12 might have the capability to disrupt normal communications
__ 13 and road networks? To me that means anything I can
- ja imagine.
15 Or are we to assume, as Commissioner Asselstine 16 has suggested, that common sense of course prevails here 17 and that we are talking about things that are of the order is of ten to the minus four, just like internally initiated 19 events, and if that is the case, then why don't we say so.
20 It is a long question, and we don't have to answer 21 all that here now.
22 MR. GILLESPIE: That was our intent, and that was 23 intended to be the case.
24 COMMISSIONER BERNTHAL: It doesn't say so in the 25 F"1
- i i
i 94 f g MR. GILLESPIE: Indeed, it was intended to cover f 2 the whole spectrum of adverse conditions with that being 3
the end point.
4 I agree, the words in the rule cover the ends of i 5 the spectrum. Our-intention was to cover the whole J'
6 spectrum.
7 COMMISSIONER BERNTHAL: There is no end of the 1
8 spectrum.
- 9 MR. CILLESPIE: In attempting to define those a
i 10 things which are the minimum capabilities necessary, no 1
gg matter what the conditions, if they are adverse or they are l
I 12 off normal conditions, the ability to communicate, the g3 ability to get people into'the plant to stabili:e whatever y, is there and the ability to assess what my protective j3 actions are going to be, be it evacuate or to shelter or a i
mix of evacuation, relocate shelter, which direction do I f 16 i
- 37 move the people and have the mechanism in place to cope i
j 18 with that. We have already prethought out the obstacles g, that the phenomena that common sense would say would happen i
20 in that area.
21 COMMISSIONER BERNTHAL: For ten to the minus four 22 roughly, give or take an order of magnitude either way, 23 type events. But you surely have not done that for ten to y the minus nine events.
. 25 MR. GILLESPIE: No. In answering that comment and I
i 1
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our analysis of that, we were really going at the comment
[( )
2 we received from the public, and it was UCS that said how P
3 can you talk low frequency, low frequency, low frequency, 4 but you do consider things of this frequency as an end 4
5 point in normal emergency planning. And that is what that 6 portion of the paper was intended to get at. We were y conceding that the ends of the spectrum is the same for 8 bcth.
9 COMMISSIONER ASSELSTINE: That is right.
l j 10 MR. GILLESPIE: And then we went on and usc-d the it word " assume" in the rule wording itself to try to divorce 12 ourselves from being tied too much to the frequency.
i 13 I was not'as successful as I would have hoped to 14 have been in that.
15 COMMISSIONER'BERNTHAL: I think your answer 16 demonstrates to me at least that'you do*need to think a j
37 little bit about a modification here that makes clear that i
ig there is an end to the spectrum. There is not an end to 1
39 any natural spectrum. What you are suggesting'is that the
- 20 Commission should,~to; borrow a phrase, establish a safety 21 goal here when it comes to emergency planning.
22 That is really what you are saying, whether it is 23
. ten to the minus four or. ten to the minus five, there must 24 be some probability-realm here beyond which we are not- ,
a 25 g ing to spend'our time. The rule doesn't say that. ;
T 6 - - , - . - , -r - p y - - -n- -- - y
, s 96
~
8 j MR. GILLESPIE: I wasn't trying to go quite that 2
far. The question was were we being inconsistent with our 3
previous approach to emergency planning.
4 COMMISSIONER BERNTHAL: I understand. If that is 5
what you intended to do, then I think probably you do need 6
to tie it to in some qualitative way at least semi-l 7
quantitative to the spectrum of probabilities that the l 8
Commission currently considers for onsite initiated events.
I g That is enough, and I am finished.
l Mr. Chairman, I have one additional 10 MR. MALSCH:
n suggestion that I would make. I had some difficulty 12 reconciling Mr. Krimm's statement or the statement on page j3 9 of the staff paper that " FEMA concurs in this paper."
a y, I wonder if we might ask FEMA to submit their 15 views in writing.
16 MR. KRIMM: The view is that we don't think it is
~
37 necessary to have this additional rule, but we have talked jg it over with the NRC staff and we agree with what has been j9 developed, but with a caveats that I read.
- 20 CHAIRMAN PALLADINO
- I still think it would be 21 wise to submit what you feel the FEMA position is.
22 MR. KRIMM: I will be very happy to submit-it in 23 writing to you.
24 CHAIRMAN PALLADINO: That is a good point.
l 25 Anything more to come before us?'
- 2. -
_ _ , ~ - ,, . _ g .
y
97 C, i COMMISSIONER ROBERTS: I thank Mr. Krimm for 2 coming.
3 CHAIRMAN PALLADINO: Thank you very much, Mr.
4 Krimm, and thank you very much, gentlemen.
5 The meeting is adjourned.
6 (Whereupon, at 4:05 p.m., the meeting adjourned.)
7 8
9 10 11 12
. 13
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14 15 16 17 18 19 20 21 22 23 24 25 e ,
3 1 CERTIFICATE OF OFFICIAL REPORTER l 2
S 4
5 This is to cartify that the attached proceedings 6 before the United States NucIear Regu I a t ory Cornmi ss i on in the 7 matter of COMMISSION MEETING 8
9 Name o,f Proceeding': Discussion on Earthouas and Emergency Planning (Public Feeting) 10 11 Docket No.
12 place: Washington, D. C.
8 13 cate: Monday, September 9, 1985 14 i 15 were held as herein' appears and that this is the original 16 transcript thereof for the file of the United States Nuclear .
17 Regulatory Commission.
13 ,
- (Signature) g g%
(Typed Name of Repornr) Mary C.'Simons 20
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- W 22 23 Ann Riley & Associates. Ltd.
24 25
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4 0 AUGUST 1984 - DIABLO CANYON DECISION 0 DECDBER 1984 - PROPOSED RULE PUBLISHED IN FEDERAL REGISTER ji jl l THE SAN ON0FRE AND DIABLO DECISIONS AND THE PN0 POSED RULE ALL STATED THAT THE POTENTIAL
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O 34 LETTEPS OPPOSED THE PROPOSED RULE-9 WERE IN PETITION FORM WITH 94 SIGNATU 0 2 TAKING N0 08VIOUS POSITION i
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OF EARTHQUAKES WERE NOT SPECIFICALLY CONSIDERED IN THEIR EMERGENCY PLANS.
O ACRS STATED THAT THEY SEE NO TECHNICAL REASON FOR THE EXCLUSION OF EARTHQUAKE IN EMERGENCY PLANNING. HOWEVER, ONLY LIMITED CONSIDERATION WAS NEEDED.
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j REC 0004 ENDED RULE CHANGE & PROPOSED IMPLEE NTATION ,
O ABILITY TO TRANSPORT PERSONNEL BACK INTO THE PLANT - COULD BE IMPLEMENTED BY AN AGREEMENT BETWEEN A LICENSEE AND A TRANSPORTATION PROVIDER.
O ABILITY TO CODORINICATE PLANT STATUS WITH OFF-SITE AUTHORITIES - COULD BE IMPLEMENTED BY REDUNDANT AND DIVERSE TRANSMITTING CAPABILITIES.
0 REC 0004END THAT STATE AND LOCAL GOVERfe9ENTS IDENTIFY ALTERNATE ROUTES OF TRAVEL AND METHDDS FOR DETERMINING WHETHER TO SHELTER OR EVACUATE - FOR MOST SEVERE NATURA'.
PHENOMENA SHELTERING WOULD BE THE MOST VIABLE AND PREFERRED PROTECTIVE ACTION
- DO THE BEST YOU CAN UNDER THE CIRCUMSTANCES.
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