ML13108A325
| ML13108A325 | |
| Person / Time | |
|---|---|
| Issue date: | 04/18/2013 |
| From: | Kahler C Office of Nuclear Security and Incident Response |
| To: | Hug M Nuclear Energy Institute |
| Shared Package | |
| ML12293A167 | List: |
| References | |
| EPFAQ 2013-004 | |
| Download: ML13108A325 (3) | |
Text
Kahler, Carolyn From: EPFAQ Resource Sent: Thursday, April 18, 2013 9:46 AM To: 'MTH@nei.org' Cc: Anderson, Joseph; Kahler, Robert
Subject:
RE: Response from "Submit a Question about Emergency Preparedness" (EPFAQ No. 2013-004)
Dear Mr. Hug:
Thank you for your recent submission of EPFAQ No. 2013-004, which lists eight questions regarding the implementation of NUREG 0654 / FEMA-REP-1 Rev. 1, Supplement 3.
At this time, your comment has been accepted for review by appropriate U.S. NRC staff. You will be notified via email when EPFAQ No. 2013-004 has been added to www.regulations.gov for a 30-day public comment period. At that time, the ADAMS accession number and Federal Register Notice docket number will be provided for your reference.
To track the status of your submitted question, please visit the website http://www.nrc.gov/about-nrc/emerg-preparedness/faq/faq-contactus.html#status. If you have any questions regarding submitting an EP FAQ, please feel free to contact me at carolyn.kahler@nrc.gov or 301-415-0705.
Sincerely, Carolyn J. Kahler Communications and Outreach Office of Nuclear Security and Incident Response US Nuclear Regulatory Commission Phone: 301-415-0705 Email: Carolyn.Kahler@nrc.gov
Original Message-----
From: MTH@nei.org [1]
Sent: Thursday, April 11, 2013 11:28 AM To: EPFAQ Resource
Subject:
Response from "Submit a Question about Emergency Preparedness" Below is the result of your feedback form. It was submitted by (MTH@nei.org) on Thursday, April 11, 2013 at 11:28:29 relevant-guidance: NUREG-0654-FEMA-REP-1 Rev. 1, Supplement 3, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants RIS 2005-08, Endorsement of Nuclear Energy Institute (NEI) Guidance Range of Protective Actions for Nuclear Power Plant Incidents, April 2005 revision-number: The revision numbers for documents are identified in the relevant guidance section.
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applicable-sections: NEI identifies the applicable sections of Supplements 3 at the beginning of each question.
comments: The below eight questions concern implementation of Supplement 3. NEI identifies the applicable section of Supplement 3 at the beginning of each question.
Question 1 - Section 2.7 and the Attachment block Rapidly progressing severe accident: Can a Rapidly Progressing Severe Accident be defined in terms that are easily identified by the control room staff (e.g., tied to a specific time frame and sites Emergency Action Levels)?
Question 2 - Does guidance for a short term (puff release) release discussed in RIS 2005-08, Endorsement of Nuclear Energy Institute (NEI) Guidance Range of Protective Actions for Nuclear Power Plant Incidents, April 2005, still apply to the development of PARs? If so, under what conditions should it apply?
Question 3 - Question concerns Attachment Note 9: Should the most limiting Evacuation Time Estimate (ETE) for the 0-2 mile zone and 2-5 mile zones downwind be the deciding factor for PAR determination for a Rapidly Progressing Severe Accident?
Question 4 - Attachment block Evacuate 2 mile radius and SIP 5 miles downwind, all others monitor and prepare (staged evacuation): Are there circumstances where it is appropriate to not implement staged evacuation. What type of justification is required?
Question 5 - Attachment block When safer to do so, begin staged evacuation of all affected areas: When is it Safer to do so? What type of criteria should apply?
Question 6 - Section 2.6 and Attachment Note 6: Supplement 3 Section 2.6 provides guidance related to the expansion of Protective Action Recommendations (PARs). Changes in wind direction may indicate that if a release begins, it could affect different downwind sectors.
If the licensee believes that containment may fail, it should pursue the expansion of PARs?
Supplement 3, Note 6 states If the plant has mitigated the conditions that caused the GE declaration expanding the PAR to evacuate downwind sectors upon completion of initial staged evacuation may not be necessary. It appears therefore the reverse is true and if plant conditions still indicate a GE then the downwind sector is evacuated. In addition, other factors related to plant conditions, radiological release conditions and event progression may impact decisions on offsite protective action recommendations.
Using information from Section 2.6 and logic derived from Note 6, what specific guidance applies to plant condition expansion of PARs for a wind shift?
Question 7 - Section 2.6: How is the expansion of PARs for a wind shift applied to the time period when the control room is in command and control?
Question 8- Section 2.6: Diurnal wind shifts or the passage of a storm front can cause extreme wind shifts. How are weather conditions factor into the expansion of PARs decision making process?
proposed-solution: Proposed solution question 1: A rapidly progressing severe accident may be defined as a loss of all core cooling systems AND a loss of the containment barrier in accordance with the Emergency Action Levels AND responsibility for PARs has not been transferred to the TSC or EOF. If these criteria cannot be immediately confirmed, assume a rapidly progressing severe accident is not occurring. Licensees may choose to substitute a loss of core cooling with an identifiable instrumentation value such as greater than or equal to Containment High Range Area Radiation Monitor Potential Loss EAL Threshold (20% Clad Damage). Any value used should be of sufficient magnitude to indicate the loss of core cooling and/or 20% clad damage or greater.
Proposed solution question 2: This answer assumes that guidance discussed in RIS 2005-08 associated with a short term release (puff release) still applies to PAR development.
The NEI guidance contained in the RIS states it is appropriate to identify likely sources of short term releases in the planning process so that considered protective actions can be developed. For example, controlled evolutions such as containment venting are characterized by definitive actions that provide some measure of certainty regarding release duration and resultant doses. On the other hand, releases from unmonitored release paths would result in highly uncertain assessments of source term.
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Therefore, it is appropriate to apply the PAR strategy of shelter in place for controlled venting from containment during the period of time when the augmented emergency response is in command.
Proposed solution question 3: It is acceptable to use the limiting ETE for the 0-2 mile zone and the limiting ETE for all 2-5 mile zones down wind. One PAR strategy should be developed for 0-2 miles and one overall strategy for all 2-5 mile zones down wind. These PAR strategies are not dependent on wind direction.
It is not expected that a matrix of PARs consisting of shelter in place or evacuate be developed depending on wind direction.
Proposed solution question 4: Yes, it is acceptable with the proper justification to not use staged evacuation. The licensee provides a basis for the following justifications - (1) ETE demonstrates the evacuation times are not improved for the 0- 2 mile radius by using staged evacuation. AND/OR (2) ETE increases to the 2-5 mile zone outweigh ETE advantages to the 0-2 mile zone.
Proposed solution question 5: It is Safer to do so when the augmented Emergency Response Organization (ERO) is staffed for both the licensee and OROs. No further protective actions are initiated by the control room (accept for a wind shift) until the augmented ERO is present to evaluate conditions and perform assessments.
When the augmented ERO is staffed, consider the prognosis for continued radioactive release, assess the radiological conditions offsite, and (1) if the 0-2 mile radius was sheltered in place, determine if the 0-2 mile radius should remain sheltered in place or be evacuated; (2) if the 2-5 mile zones were sheltered in place, determine if they should remain sheltered in place or be evacuated; (3) determine if the 5-10 mile downwind sectors should be evacuated.
Proposed solution question 6: There are conditions used for PAR development without a reliance on dose assessment or dose projection results exclusively. Examples of criteria to use to determine when conditions apply are identified in NEI 12-10, Guideline for Developing a Licensee Protective Action Recommendation, Appendix B, and Section 2.2.
Proposed solution question 7: The PAR is extended to the new sector.
Proposed solution question 8: A diurnal wind shift (for example; sea breeze effects) or the passage of a storm front can cause extreme wind shifts. During an extreme wind shift the PAR in the initial wind direction is not extended to the sectors the wind is shifting through unless it is shown (dose assessment) that the PAG is exceeded. The PAR is extended to the sectors in the final wind direction if the conditions in question four are met. For the sectors where the plume passes through, where the PAGs are not exceeded, it is not necessary to include these areas in the upgraded PAR. A new PAR is required within 15 minutes once determined the wind is persisting to a new sector or on completion of a dose assessment indicating a PAG is exceeded in a new sector.
originator: Martin Hug organization: Nuclear Energy Institute (NEI) phone: 202.739.8129 3