ML102100462
| ML102100462 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 07/21/2010 |
| From: | Sullivan B A Entergy Nuclear Northeast |
| To: | Office of Administration |
| References | |
| 75FR10524 00026, NRC-2010-0080, NUREG-0654/FEMA-REP-1, Rev. 1 | |
| Download: ML102100462 (10) | |
Text
ift 6=r-- Enteigy Entergy Nuclear Northeast Indian Point Energy Center Emergency Planning 450 Broadway, Suite 2 Buchanan, NY 10511 Chief Rulemaking, Announcements and Directives Branch (RDB)Division of Administrative Services Office of Administration Mail Stop TWB-05-BO1 M US NRC Washington, DC 20555-0001 July 21, 2010 7D]_-T r--4-F71
SUBJECT:
Reference:
Docket ID: NUREG-0654/FEMA-REP-1/Rev.
1 Supplement 3, Guidance for Protective Action Recommendations for General Emergencies Federal Register, Volume 75, No. 109, June 8, 2010, p. 32493 NRC-2010-0080
Dear Sir or Madam:
Entergy Indian Point Energy Center takes this opportunity to comment on the draft NUREG-0654/FEMA-REP-1/Rev.
1 Supplement 3, Guidance for Protective Action Recommendations for General Emergencies, as requested in the June 8, 2010 Federal Register (Reference).
Enclosed please find a spreadsheet which provides general and specific comments on the document with supporting rationale.
Thank you for the opportunity to provide comment on these documents.
If you have any questions, please contact Mr. Alain Grosjean of my staff at 914-734-6805.Manager Emergency Planning620 135 Al 1167 /j 6 3)
Entergy Indian Point Energy Center Comments on NUREG- 0654, Supplement 3 July 21, 2010 rationale.
>, General Comments unavaiiamiiiny oT Supporting Documentation, Comprehensive Revision of NUREG-0654 and Implementation Schedule uran r -I U-UoD/-I-/IvI.
-REP-1, Rev.1, Supplement 3, Section 6, "References", page 15: and Federal Register Notice, March 8, 2010 (Re: NRC-2010-0800), states: "The NRC expects to issue the guidance in final form in mid-2011 and nuclear power plant licensees to implement the guidance in their emergency preparedness programs within one year of the issuance of this guidance document in final form"./ Key supporuing uocumeni iisieu unuer ine Supplement 3 references, NUREG/CR-0653 Volume III, has not yet been issued for public review and comment. Given that this document is an important underpinning of the NRC's proposed PAR guidance, it is essential that the information be made available to all stakeholders for understanding and validation of the Supplement 3 recommendations.
It is inappropriate for the NRC to request comments and proceed with the Supplement 3 implementation process when organizations impacted by this change have not had the opportunity to review all of the supporting information.
Implementation of the revised Supplement 3 guidance should be issued at a later time as an integrated, comprehensive package to avoid needless duplication of effort in the future.Furthermore, it has been universally suggested that NUREG-0654, Rev.1, in existence since 1980, should be rewritten in its entirety.Therefore, the implementation schedule for Supplement 3 should encompass as a minimum the final issuance of Volume I1l. Optimally, Supplement 3 guidance should be integrated into a comprehensive NUREG-0654 revision.Doing otherwise, represents a "piecemeal" and inefficient approach.
NRC should extend its planned Supplement 3 implementation schedule accordingly.
Page 1 of 9 Entergy Indian Point Energy Center Comments on NUREG- 0654, Supplement 3 July 21, 2010.Coordination of Supplement 3 Implementation and Updated Evacuation Time Estimate Studies Federal Register Notice, March 8, 2010 and Draft NUREG-0654/FEMA-REP-1, Rev.1, Supplement 3, "Protective Action Recommendation Logic Diagram" and supporting notes, pp. 17-20.NRC emphasizes in the PAR Logic Diagram and in several of the supporting notes that site-specific PAR schemes will be dependent on ETE study results. The availability of new ETE results will hinge on two ongoing activities, namely, the completion of rulemaking changes (that will dictate ETE methodologies and scope), and the completion of the 2010 U.S. Census.The results of new ETE studies will not be completed, reviewed and properly integrated in revised PAR procedures unless flexibility is provided in the Supplement 3 proposed implementation.
A more logical schedule should allow for: 1) completion of the 2010 Census, 2)finalization of NRC's revised ETE rulemaking requirements, 3) completion of updated, site-specific ETE studies, and 4) incorporation of approved ETE information in site-specific PAR logic.Information and insights provided by updated ETE studies following the 2010 Census will not be available to meet NRC's current implementation milestones for Supplement 3.The schedule published in the original Federal Register associated with the draft Supplement 3 (Vol. 75 No. 44 dated March 8, 2010) indicated that licensees would.be required to implement the guidance by mid-2012.
It is unlikely that revised site-specific ETEs based on the 2010 Census and the final rulemaking requirements will be available at that time.1. 4 I More Outreach to OROs is Needed By Both FEMA and NRC Draft NUREG-0654/FEMA-REP-1, Rev.1, Supplement 3, (all)Over several years, OROs coordinated with licensees to customize PAR strategies to fit site-specific conditions.
Many OROs do not see the benefit of significant changes to PAR strategies that were established to meet long-standing federal requirements.
The concepts contained in the proposed Supplement 3 guidance represent a major "paradigm shift" for many OROs. We suggest that FEMA as well as NRC consider conducting more coordinated regional outreach.to OROs by way of "town hall meetings" or other forums. This will permit both agencies to directly address the public health merits of the proposed changes.Further focused and coordinated outreach by both NRC and FEMA at the regional level will assist licensees in gaining ORO acceptance of new PAR strategy changes and help OROs in maintaining the confidence of their constituents.
Offsite Response Draft NUREG-0654/FEMA-While PAR planning discussions between The licensee version of the Organization's REP-1, Rev.1, Supplement 3, licensees and OROs may achieve general PAR logic diagram cannot and Independent Protective "Protective Action consensus on changes to the site-specific PAR should not encompass all Action Decision-making Recommendation Logic framework, the final decision-making authority possible offsite conditions that Diagram" and supporting notes during actual emergency conditions must rest may exist during an actual Page 2 of 9 Entergy Indian Point Energy Center Comments on NUREG- 0654, Supplement 3 July 21, 2010 Nos. 2, 4,7,8,9,10 and 11, pp. with OROs. Therefore, the development of site- emergency.
By regulation, 17-20. specific PAR logic diagrams must contain a OROs retain the final authority caveat that OROs will have additional for protective action decision information (e.g., evacuation impediments making.status) that may warrant deviations from licensee recommendations, The basic message throughout the proposed Supplement 3 should reflect the view that the primary licensee responsibility is to focus on the science of the plant emergency conditions, and the ORO(s) to focus on offsite control of the emergency response, including impediments.
Application of PAR Draft NUREG-0654/FEMA-The proposed guidance focuses on radial Suggested wording would Guidance to ERPAs and REP-1, Rev.1, Supplement 3, distances from the plant. However licensees assist in ORO understanding Areas Section 1 -"Introduction" page and OROs usually translate PARs and PADs and acceptance of the 2, and Section 2 -into ERPAs or other locally identified sub-areas.
intended scope of Supplement"Implementation of Guidance", The proposed Supplement 3 should state 3 revisions.
page 5. explicitly that PAR revisions can use existing ERPAs or sub-areas and that the NRC and FEMA are not requiring reconfiguration of current boundaries.
Compatibility with Revised FEMA REP Program Draft Supplement 3 makes no reference to the Licensees and OROs are Proposed FEMA REP Manual, Standards I and J; Draft FEMA REP Program Manual that was expected to discuss and Program Manual Draft NUREG-0654/FEMA-issued for comment in May, 2009 and does not presumably agree on REP-1, Rev.1, Supplement 3, state that NRC and FEMA will assure that final acceptable PAR strategies.
technical guidance on protective actions for the However, until the Supplement public is coordinated in a consistent manner for 3 guidance receives formal licensees and OROs. The proposed FEMA endorsement, OROs will Supplement 3 guidance will significantly impact be reluctant to commit to ORO plans and procedures, and yet does not significant departures from have the formal endorsement of FEMA. This is established PAR philosophies worrisome to OROs because the methodologies.
implementation of draft Supplement 3 may ultimately conflict with the proposed revisions to the FEMA REP Program Manual which is now undergoing adjudication.
The implementation timeline of the revised Supplement 3 should await the published results of the comment adjudication process, particularly as it applies to the implementation of Planning Standards I and Page 3 of 9 Entergy Indian Point Energy Center Comments on NUREG- 0654; Supplement 3 July 21, 2010 J, and ETE-related guidance contained in the REP Program Manual.Acceptability of PAR Site-Specific Strategies and Methodology Draft NUREG-0654/FEMA-REP-1, Rev.1, Supplement 3, Section 2 -"Implementation of Guidance" page 5, first paragraph, states" The PAR Logic Diagram( Attachment 1)is not intended to be used without site-specific modification";
and "Protective Action Recommendation Logic Diagram" and supporting notes, pp 17- 20.Our preliminary review of the proposed Protective Action Recommendation Logic Diagram indicates that the standard format and content will require substantial revision to be meaningful to licensee and ORO users.For example, the entire section from the "Do impediments to evacuation exist?" decision diamond and all boxes to the right (the "yes" path) would be deferred to OROs. Only OROs will have access to meaningful, current information on the status of impediments, whether the impediments are emerging or clearing.In addition, there is not enough guidance for licensee shift personnel to determine that the decision diamond "Rapidly progressing severe accident?" is a "yes". Therefore, it is entirely likely that the final, agreed upon site-specific logic diagram could reduce down to the center part of the proposed logic diagram. The Supplement 3 wording in Section 2 should clearly state that site-specific PAR schemes are fully acceptable in a greatly simplified format as long as they have a sound technical basis and are agreeable to OROs.The development of site-specific PAR methodology should allow any "logic diagram" format and content that is meaningful and useful to licensee and ORO personnel, even if it departs substantially from the NRC version proposed in draft Supplement 3.Human Factor Elements Draft NUREG-0654/FEMA-The proposed model PAR Flow diagram is The added complexity of the Associated with the REP-1, Rev.1, Supplement 3, complex and cumbersome with its numerous proposed PAR logic diagrams Proposed PAR Logic Section 1 -"Introduction" and supporting notes, etc. The licensee, in particular may contribute to confusion Diagram Section 2 -"Implementation of operational shift personnel will have difficulty and delay in issuing timely and Guidance" page 5, second implementing this guidance in a timely and effective protective actions.paragraph.
accurate manner unless the flow charts are significantly simplified.
Supplement 3 implies the potential need to develop three PAR Flow Diagrams -one for licensee operational shift I personnel, one for the augmented licensee ERO I Page 4 of 9 i Entergy Indian Point Energy Center Comments on NUREG- 0654, Supplement 3 July 21, 2010 and one for OROs for protective action decision-making. The ACRS recommended against making PAR strategies overly complicated, such that they slow down decision making during emergencies.
I I Required Documentation to Support Adopted PAR Flow Diagrams Supplement 3, Introduction, page 3 states: "This supplement is considered"Federal Guidance" as referred to in the regulation, and it will be used to aid in determining compliance with 10 CFR 50.47(b)(10)".
In Section 2, Implementation of Guidance, page 5, paragraph two states:" The NRC suggests that nuclear power plant licensees and the OROs responsible for implementing protective actions discuss and agree to various elements and criteria of the licensee and ERO PAR logic diagram(s)".
This paragraph should be clarified to better define what type of supporting documentation will be adequate to demonstrate that the licensee meets 10 CFR 50 requirements during NRC compliance inspections.
We also recommend that NRC define the type of supporting documentation that would need to accompany submissions of revised plan and procedure changes.We recommend that the draft Supplement 3, Section 2 clarify that all background information, analyses, assumptions, unique site-specific characteristics and ORO inputs be contained in a companion document, and not required to be part of the body of the licensee PAR implementing procedure.
Comment provided to seek clarification for compliance.
Page 5 of 9 Entergy Indian Point Energy Center Comments on NUREG- 0654, Supplement 3 July 21, 2010 I Specific comments I rl- I UIIjJI IEULW%.LIVl Actions Following A Rapidly Progressing Severe Accident Draft NUREG-0654/FEMA-REP-1, Rev.1, Supplement 3,"Protective Action Recommendation Logic Diagram" and supporting Notes Nos. 1,4, 5, 9 and 10, pp. 17-20.-Event Recognition and Timeliness Note 1 of the model PAR Logic Diagram defines a rapidly progressing severe accident as a General Emergency (GE) with rapid loss of containment integrity and loss of ability to cool the core, and furthermore requires a determination under these conditions that a radiological release is expected in less that 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Draft Supplement 3 correctly states that this condition is very unlikely, but at the same time, the licensee is still required to make a PAR involving the potential, immediate evacuation of nearby populations within 15 minutes of declaring the GE. It will be very difficult to properly diagnose a rapidly progressing severe accident, which could lead to a delay in meeting the 15-minute PAR requirement.
Many, if not most licensees will likely default to the "No" path if this scenario cannot be readily determined (as is allowed in the note), and will follow the PAR logic down the center of the PAR Logic Diagram.Prompt Protective Draft NUREG-0654/FEMA-Many OROs are uncomfortable with consenting Actions Following A REP-1, Rev.1, Supplement 3, to an immediate evacuation under rapidly Rapidly Progressing "Protective Action progressing accident without major supporting Severe Accident Recommendation Logic elements being in place (for assessment of Diagram" and supporting Notes impediments and traffic control).
Even with-ORO Implementation Nos. 1, 4, 5, 9 and 10, pp. 17- improved messaging to the public, ORO Concerns 20. emergency managers believe that prompt evacuation may lead to chaotic conditions and confusion of the public if the OROs are not yet Page 6 of 9 Entergy Indian Point Energy Center Comments on NUREG- 0654, Supplement 3 July 21, 2010 operational.
They also believe that prompt, uncontrolled evacuations could present a greater burden on ORO resources to regain control of the emergency response.
The draft Supplement 3 should state this concern and make the "rapidly progressing severe accident"Yes" logic path entirely optional.Prompt Protective Actions Following A Rapidly Progressing Severe Accident-Staged Evacuation Initiation Draft NUREG-0654/FEMA-REP-1, Rev.1, Supplement 3,"Protective Action Recommendation Logic Diagram" and supporting Note No. 10, pp. 17-20.In the last box in the bottom left-hand corner of the PAR Logic Diagram, the meaning of 'When safer to do so, begin staged evacuation of all affected areas" is not adequately explained by Note 10. The note states that shelter-in-place times in excess of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> reduce dose, and that dose is not reduced in less than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.This appears contrary to the reduced effectiveness of sheltering protection over time that is shown in the PAR Study, Volume I. If the note statement is assuming that a concurrent release would make premature staged evacuation (less than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) following sheltering-in- place undesirable from a dose perspective, then the statement should be clarified.
The statement "when safer to do so" is also unclear. Does it mean that offsite exposure rates have significantly decreased at that time, or is it referring to a PAG that would prompt a staged evacuation?
Furthermore, the term "all affected areas" is vague, and should instead say "all affected areas where a PAG is reached or exceeded".
The language in the note should be clarified.
Expansion of PAR Only Draft NUREG-0654/FEMA-The wording/logic contained in the box found in Comment provided to highlight to Areas Where PAGs REP-1, Rev.1, Supplement 3, the lower right-hand corner contradicts the inconsistency in the guidance.Could Be Exceeded After "Protective Action wording in Note 6. Assuming the answer is "No" GE Conditions Are Recommendation Logic to "GE conditions remain?", then there should Page 7 of 9 Entergy Indian Point Energy Center Comments on NUREG- 0654, Supplement 3 July 21, 2010 Terminated Diagram" and supporting Note be no reason to expand PAR. The wording in No. 6. pp. 17 and 19. the box and the note should be changed to"Continue to monitor the emergency" or equivalent.
Public Confusion Draft NUREG-0654/FEMA-Spontaneous, voluntary evacuation is still Resulting from Staged REP-1, Rev.1, Supplement 3, probable even for staged evacuation.
Evacuation "Protective Action Messaging, even when well intended .can lead Recommendation Logic to public confusion, mistrust and uncertain Diagram" and supporting Notes response.
This could lead to a greater burden Nos. 3, 4 and 5. pp. 17-20. on ORO resources to control the emergency response.Appropriate Selection of Draft NUREG-0654/FEMA-The statement in Note 7 is unrealistic for two ETE Information REP-1, Rev.1, Supplement 3, reasons. First, this is a very complex"Protective Action determination for the operational shift to make,-(Note 7) Recommendation Logic as it competes with other plant accident Diagram" and supporting Notes mitigation duties.No. 7, pp. 19, states: These (ETE) values should be Furthermore, at this time "T=X hours" following representative for the site and the expected 2-mile evacuation (9 0th percentile), should not include special the shift staff should have relinquished events.. .the shift staff is command and control to the augmented ERO, expected to make this PAR which would be in communication with the without conferring with OROs". ORO(s). The OROs at this time would have more specific information on which set of ETEs to select based on offsite conditions.
Timeframes Provided in Draft Supplement 3 provides timeframes such the PAR Logic Diagram as.. .(Note 9).. .which appear to be fixed. The language should be clarified to state these as-(Note 9) examples only and appropriate time values would be developed by site-specific analysis.Messaging for Draft NUREG-0654/FEMA-Several useful messaging suggestions are Comment presented to Evacuation of Various REP-1, Rev.1, Supplement 3, embedded in the text of these sections (which improve usability of the Population Groups Appendix, Section 3, "Public focus on pets, staged evacuation, school messaging guidance.Information Materials", page A- evacuation, shadow evacuation, transient 6 through A-7 (pets); Section 4, dependent people, special needs people and"Emergency Alerting and special facilities).
We recommend that the key Instructions", Sections 4.2.2.1 -messaging elements be presented as more 4.2.2.6 pp. A-15 through A-17. concrete recommendations in a "bullet" format I for ease of use.Page 8 of 9 Entergy Indian Point Energy Center Comments on NUREG- 0654, Supplement 3 July 21, 2010 Adequacy of Public Communications Systems Draft NUREG-0654/FEMA-REP-1, Rev.1, Supplement 3, Appendix, Section 5, "Additional Guidance for More Effective Messaging", page. A-1 9, states: "A better approach is to ensure adequacy of the available systems and for emergency response agencies to use these services as well, to provide additional information to the public".The wording as stated could be expanded into more specific, concrete recommendations on how to implement guidance on how available communications services can be used.Comment presented to improve usability of the messaging guidance.Special Needs The variety and extent of suggested outreach Population Assistance methods for assistance of special needs populations may artificially raise expectations for other non-radiological emergencies.
The common wisdom has been for such groups and individuals to pre-plan and obtain help from I family, friends and neighbors.
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