ML20212G114
| ML20212G114 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 02/27/1987 |
| From: | Newberry S Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20212G091 | List: |
| References | |
| OL, NUDOCS 8703050267 | |
| Download: ML20212G114 (13) | |
Text
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j UNITED STATES OF AMERICA liUCLEAR REGULATORY COMMISSION BEFORE TIIE ATOMIC SAFETY AND LICEilSING BOARD In the Matter of
)
)
Docket Nos. 50-443 OL PUBLIC SERVICE COMPANY OF
)
50-444 OL NEW HAMPSHIRE, et g.
)
Off-site Emergency Planning 2
(Seabrook Station, Units 1 and 2
)
AFFIDAVIT OF SCI 7IT ITHBERRY I su a Section Leader in the Facilities Operations Branch, PhR-A, Division of Licensing, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Conmission.
I received a B.S. in Naval Science fran the U.S. Naval Acadsgr, and an M.S. in Mechanical Engineering from the Catholic thiversity. As part of my responsibilities with the Fccilities Operations Branch, I am coordinating a portion of the Staff review of the Seabrook Applicants' petition for a waiver of the 10-mile avergency planning zone for Seabrook.
'Ihe purpose of this affidavit is to provide a brief sunnary of the work Drcokhaven National Laboratory ("BNL") has perfonned for the Staff with respect to the issues raised in Applicants'. waiver petition, and to provide a brief outline of the work that renains to be done before the Staff can take a position on whether the petition should be granted.
BAO DEIND Ch July 21, 1986, Public Service Capany of New Hanpshire ("PSMI") subnitted PIG-0465, the Seabrook Station Bnergency Planning Sensitivity Study and 8703050267 870227 PDR ADOCK 05000443 G
PIG-0432, the Seabrook Station Risk Management Bnergency Planning Study (IEEPS). PIG-0465 considers the bases for the' 10 mile emergency planning zone (EPZ) and proposes justification for a snaller EPZ at Seabrook.
PIC-0465 relics, heavily on PIG-0432 and the Seabrook Station Probabilistic Safety Assessment (SSPSA) (PIC-0300).
In August of 1986 the staff requested that Brookhaven National Laboratory assist than in a review of selected topics from PIO-0465 and related docunents. 'Ihe review included meetings at both NRC headquarters and at Brookhaven National Laboratories. Site visits were conducted in Septanber, October and NoveTber. BNL and NRC staff presented infonnation to ACRS sub-comnittee and full comnittees in Septa 2er and October. Ntznerous technical meetings were held between PSbil, BNL and the Staff, and the DRAFT BNL report was carpleted on Decenber 5,1986.
Meetings were held with BNL and the Applicants in January of 1987. Comnents on the report were provided by PSMI at a January 14 meeting with BtL and the Staff and were documented by PSMI in a letter to Mr. Victor Nerses of the NRC Staff (NYN-87-002, January 20, 1987).
I21 REVIEW
'Ihe Brookhaven review did not reassess all aspects of the Seabrook risk profile as estimated in PIG-0465 and supporting docunents.
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Brookhaven was asked to focus on specific areas that could cause the containment to fail or be bypassed during t'he early portion of a severe core melt accident. Specifically, Brookhaven was asked to assess:
- 1) the probability estimate for the occurrence of interfacing systans 10CA;
- 2) the probability of contairment bypass due to equignent malfunction,-
personnel error or an undetected design error at the time of a severe accident;
- 3) the conditional probabilities of early contairunent failure, following an assessanent of contairment loads and contairment capacity;
- 4) the appropriateness of the source term and site consequence methodology presented in the Seabrook sutmittal.
i During the course of the review, BNL was also asked to consider: 1) possible accidents while the reactor is shutdown; and 2) the potential for inducing stean generator tube failure as a consequence of conditions resulting from a severe accident.
He review approach used by DNL was to perfonn a risk sensitivity study for each concern using alternative scenarios suggested by their review. Rese sensitivity studies resulted in revised dose versus distance curves using conditional risk indices provided in PID-0465 and supporting docunents. He BNL estimates were intended to provide an indication of the significence of INL's alternative scenarios.
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SIMMlfl OF BNL FINDINGS INL is scheduled to publish their final report by luarch 6,1987. He following discussion of their conclusions is based on review of their IIIAFT l
report and discussions with the authors. Lhile we do not expect the i
following conclusions to change, it should be arphasized that Brookhaven's l
conclusions are not yet final, and that these conclusions are Brookhaven's 1
i and have not necessarily been adopted by the ITIC Staff.
Interfacing Systens IfrA - %e IM, review includes several concerns in this area. He most significant concern in this area is the likelihood of the initiation of such an event, which is primarily a function of valve failure rate. BNL estimates a higher likelihood of initiation of this type of event (than did PID) using alternative valve failure rates v'hich BNL judges to be more appropriate. However, BNL concluded that this would be unlikely to significantly change the risk profile presented in PIG-0465, largely because of the substantial reduction in radiological releases due to credit for pool scrubbing in the Ecsidual Heat Renoval vault space.
Accidents During Shutdown - he primary concern in this regard is that because contairrnent integrity (i.e., containment isolation) is not required during all shutdown conditions, a severe accident occurring during shutdown conditions might not be contained. His issue was not addressed in the original PIG studies, and the BNL review in this area is limited (this review iten was added duringr the course of the BNL review). During the course of the BNL review, additional infonnation on this subject was requested fran the Applicants. Bounding analyses provided at that time by the Applicants indicated that accidents during shutdown have the potential to significantly inpact the risk estimates in PLG-0465. Additional infonnation provided by the Applicants in responso to the BNL DRAIT report reduced the significance of accidents during shutdown by considering the reduction in source tenn attributable to the length of time between shutdown and the accident (the amount of radioactivity and the rate of heat generation in the core decreases as the duration of the shutdown increases).
thifle BNL has concluded that certain aspects of Applicants' analysis have J
merit, BNL was not able to assess the validity of the risk estimate for accidents during shutdem within the scope and' time frame of its review.
Induced Stean Generator Ebe Rupture - Eis is another area that Brookhaven was asked to consider after its review was under way. This area was not reviewed in detail by INL, but was considered by the IEC Staff. This postulated sequence involves the loss of steam generator tube integrity due to a condition of high tarperatures and high pressure in the steam generators during a core melt accident. He potential concern imrolves movanent of high tenpcrature fluid from the region of the melting core into the steam gener' tor tubes which leads to their failure. High pressure fluid fran the melting core would then ba released to the secondary side of the stean generators from where it could be relecsed to the environment via the steam generator relief valves, thus bypassing the contairment. h e Staff requested that a peer review of the INL and Staff work on this issue be performed by T. G. Deofanous of the University of California. Dr.
Reofanous' conments were received in Januarv of 1987. Questions renain on whether induced stean generator tube rupture would occur in the event of a severe accident. Preliminary Staff judgenent is that the phenanenon is of low likelihood, but detailed analysis to support this judganent has not yet been perfonned. IEL perfonned sinple sensitivity studies to assess the potential inpact of induced steam generatoh tube rupture on risk, hhile the sensitivity estimates using a low probability of induced stear generator l
tube rupture showed no inpact on risk, the estimates using a higher probability could have a rather significant inpact on risk if assuned to represent an early bypass of the containnent.
w 4.
Containnent Isola' ion Failure and Pre-existing Leakage - his issue t
addresses the possibility that contairunent may'not be isolated during or inmediately following an accident. His area has not been reviewed in detail by INL or the Staff. The Staff concluded in a memorandun dated February 9,1987 that the purge and vent valves in a fully closed position should provide reliable isolation under severe accident conditions.
Estimates made by the Applicants using generic data for containnent isolation failure (hUtEG/G-4220) which the Applicants believe to be bounding, show that this issue has a small irrpact on risk.
Contairrnent Structural Integrity - Based on its analysis of the Seabrook contafrunent, BNL concludes that failure leading to gross leakage is not expected to occur before reaching a pressure of 165 psig. Contairunent penetration failure is also estimated to be in this range, depending on the particular penetration and wet or dry contairunent conditions. nese pressures are approximately three times the design pressure of the Seabrook 4
contairrnent.
I i
Contairunent Loads - BNL did not attapt to generate Seabrook specific containnent loads in its review. Because of a similar contairrnent volune to j
reactor power ratio for the Zion and Seabrook plants, BNL evaluated the Seabrook containment response to the Zion Toads v.hich were taken from earlier BNL analysis to support 17tAFT NUREG-IISO, Reactor Risk Reference
~
f Docunent. His was intended to provide an indication of the sensitivity of the Seabrook risk estimates to these loads. BNL considers these estimates to be preliminary. Canparing the median load estimates with the Seabrook 4
containnent capacity would indicate a low probability of early containnent failure. However, extrapolating the upper range of Zion loads to Seabrook significantly increases the Seabrook risk estimates, t.hile considered to a limited degree, the questicn of whether the loads from the direct j
containnent heating phenomenon are judged to occur was not resolved in the scope of the BNL review. BNL points cut that since the capacity (i.e.,
strength) of the Seabrook containment is about 23 percent greater than Zion, the range of early containnent failure probability (all other things being equal) should be lower at Seabrook then Zion. BNL did not quantify this probability in this review, i
Source Terms - ENL concludes that the fission product source tenns used in PIC-0465 appear in general to be consistent with the approaches used in WASH-1400. They also conclude that the analysis presented by the Applicants is reasonable with respect to the asstuption that water in the residual heat renoval vault is sufficientiv subcooled to warrant consideration of significant decontanination. As noted earlier, this is an inportant consideration for the interfacing systen IDCA risk estimate.
Consequence Model - ENL believes that the consequence modeling in PIG-0465 is fairly presented and that the relatively anall differences between the PIG "CTACIT" predictions and those conputed by BNL using "MAOCS" are explained by differences in modeling techniques used in the two cmputer codes. DNL found that the MACG code generally predicted dose versus distance curves that extended to slightly shorter distances than predicted by CRACIT. BNL did not check the risk of early fatalities predicted in
PIfr0465 but did note that the MACCS code would tend to predict more early fatalities than OtACIT.
BNL Conclusions - In general, BNL finds that its dose versus distance sensitivity study results in the above areas for Seabrook are lower than those in NURBG-0396, O but higher than those in PIG-0465. 'Ihe alternative risk catimr.tes in the BNL sensitivity studies reflect renaining questions and indicate a level of confidence less than that of the Applicants in some of the areas BNL was asked to consider, including containnent loads, induced stean generator tube rupture, and accidents during shutdown.
M RIHER REVIEW EFK RTS
'Ihe Staff review of the Applicants' petition for a waiver pursuant to 10 GR 2.758 is continuing. Major areas of Staff review will include risk assessment, ancrgency planning, and design basis accident analyses. Based on our current assessnent of work done to date in these areas and our understanding of the necesesrv level of effort to review the petition on its full merits, we estimate that all aspects of the review can be cccpleted by Novanber 1987.
It nmst be anphasized that although the Staff has identified certain major review areas at this time, it is possible that an aspect of the review might change, or alternative areas may be identified as the review continues.
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" Planning Basis For 'Ihe Developnent Of State and Incal Governnent Radiological Bnergency Response Plans In Support Of Light Water Reactors."
-g-We believe that a raore ccmplete understanding of the Seabrook plant and risk assessment needs to be developed before a position can be taken on the risk assessment aspects of the petition. This is primarily due to.the low probability estimates for early contairunent failure which are a cornerstone of the Applicants' petition. Unresolved questions remain fran the ENL review of PTB-0465 in the areas of contairmnent loads (including the contribution to contairment accident loads resulting from the direct containment heating phencrnenon), induced steam generator tube rupture, and severe accidents at shutdown. We believe the BNL questions merit further investigation. Therefore, further detailed evaluation of accidents at shutdown and stearn generator tube rupture is necessary.
Identification of a Seabrook specific contairmnent event tree with Seabrook specific contairunent loads using the BNL structural capability estimates is also being considered. We also believe that further review of internal and external accident sequences in the SSPSA needs to be carpleted to consider the likelihood and uncertainty of early containment failure at Seabrook.
In addition to assessing the validity of Applicants' risk assessnent, the Staff will also be reviewing the Applicants' analysis of the consequence of design basis accidents at Scabrook.
In this regard, independent staff consequence calculations are planned. The Staff also will be examining certain energency-planning related issues, including the adaptt.bility of emergency plans for the taking of ad hoc measures beyond one mile if necessary (the fourth rationale identified in Applicants' petition), and the rationales for having selected ten miles as the appopriate zone for the
O,
pitsm exposure pathway EPZ. Again, these review tasks may change and/or additional tasks may be added as the review continues.
A meeting with the Advisory Cacmittee For Reactor Safeguards is planned for sunetime in April 1987 to discuss the Scabrook review.
'Ihe above statements are true and correct to the best of rmy knowledge and belief.
N j_
Scott Newberry i
Subscribed and sworn to before me this 27th day of February,1987 Notary Public My Conmission Expires: 07/01/90
1 Nj[
IINITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '87 MAR -4 All :28 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
., Jy
.,a In the Matter of
)
)
Docket Nos. 50-443 OL PI1DLIC SERVICE COMPANY OF
)
50-444 OL NEW HAMPSHIRE, et al.
)
Off-site Emergency Planning
)
(Seabrook Station, Units 1 and 2
)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF INITIAL RESPONSE TO APPLICANTS' PETITION FOR WAIVER" in the above-captioned have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, by deposit in the Nuclear Regulatory Commission's internal mail system this 27th day of February,1987.
Helen Hoyt, Esq., Chairman
- Gustave A. Linenberger, Jr.*
Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S.
Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Dr. Jerry Harbour
- Ms. Carol Sneider, Esq.
Administrative Judge Assistant Attorney General Atomic Safety and Licensing Board Office of the Attorney General U.S. Nuclear Regulatory Commission One Ashburton Place,19th Floor Washington, DC 20555 Boston, MA 02108 Deverly Hollingworth Richard A. Hampe, Esq.
209 Winnacunnet Road New Hampshire Civil Defense Agency Hampton, NH 03842 107 Pleasant Street Concord, NH 03301 Sandra Gavutis, Chairman Calvin A. Canney, City Manager Board of Selectmen City Hall RFD 1 Box 1154 126 Daniel Street Kensington, NH 03827 Portsmouth, NH 03801
- v.,
Stephen E. Merrill Paul McEachern, Esq.
Attorney General Matthew T. Brock, Esq.**
- George Dana Bisbee Shaines & McEachern Assistant Attorney General 25 Maplewood Avenue Office of the Attorney General P.O. Box 360 25 Capitol Street Portsmouth, NH 03801 Concord, NH 03301 Hoherta C. Pevear Angie Machiros, Chairman State Representative Board of Selectmen Town of Hampton Falls 25 High Road Drinkwater Road Newbury, MA 09150 Hampton Falls, NH 03844 Allen Lampert Mr. Robert J. Harrison Civil Defense Director President and Chief Executive Officer Town of Brentwood Public Service Co. of New Hampshire 20 Franklin Street P.O. Box 330 Exeter, NH 03833 Manchester, NH 03105 Charles P. Graham, Esq.
Robert A. Backus, Esq.
McKay, Murphy and Graham Backus, Meyer a Solomon 100 Main Street 116 Lowell Street Amesbury, MA 01913 Manchester, NH 03106 Diane Curran, Esq.
Philip Ahren, Esq.
Harmon & Weiss Assistant Attorney General 2001 S ttreet, NW Office of the Attorney General Suite 430 State House Station #6 Washington, DC 20000 Augusta, ME 04333 4
Fdward A. Thomas Thomas G. Dignan Jr., Esq.
Federal Emergency Mannprement Agency Ropes & Gray 442 J.W. McCormack (POCF) 225 Franklin Street Boston, MA 02109 Boston, MA 02110 H.J. Flynn, Esq.
William Armstrong Assistant General Counsel Civil Defense Director Federal Emergency Management Agency Town of Exeter 500 C Street, SW 10 Front Street Washington, DC 20472 Exeter, NH 03833 Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel
- Doard*
l U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory C.ommission Fashington, DC 20555 Washington, DC 20555 l
1
. e Jane Doughty Docketing and Service Section*
Seacoast Anti-Pollution League Office of the Secretary 5 Market Street U.S. Nuclear Regulatory Commission Portsmouth, NH 03801 Washington, DC 20555 hiaynard L. Young, Chairman William S. Lord Board of Selectmen Board of Selectmen 10 Central Road Town hall - Friend Street South Hampton, NH 03287 Amesbury, MA 01913 Michael Santohuosso, Chairman Peter J. Matthews, Mayor Board of Selectmen City Hall South Hampton, NH 03287 Newburyport, MN 09150 Mr. Robert Carri g, Chairman Judith H. Mizner, Esq.
F Board of Selectmen Silverglate, Gertner, Baker Town Office Fine and Cood Atlantic Avenue 88 Broad Street North Hampton, NH 03862 Ecston, MA 02110 R. K. Gad I!!, Esq.
Mrs. Anne E.
Coodman, Chairman Ropes & Gray Board of Selectmen 225 Franklin Street 13-15 Newmarket Road Boston, MN 02110 Durham, NH 03824 Gary W. Holmes, Esq.
Honorable Gordon J.
Humphrey Holmes & Ellis United States Senate 47 Winnacunnet Road 531 Hart Senate Office Building IIempton, NH 03842 Washington, DC 20510
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Robert G. Perlis Counsel for NRC Staff i
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